Comments: Opposition to the Lowry Ranch Comprehensive Area Plan (CAP) and requests that the Energy and Carbon Management Commission (ECMC) deny the application.

Since the Lowry Ranch CAP was originally proposed, Arapahoe County residents have expressed numerous concerns about the planned development. With this comment, we will limit our discussion to specific concerns about impacts to air quality.

The Lowry Ranch CAP should not be approved because:

1. The proposed development is located within the Denver Metro/North Front Range (DMNFR) area which was recently classified as in Severe nonattainment for the 2008 Ozone National Ambient Air Quality Standards.
2. The ECMC does not presently have rules that address cumulative impacts or a process for sufficiently considering air quality impacts of proposed oil and gas developments. 

Earthworks research suggests that emissions from pre-production equipment and activities continue to be an issue despite the adoption of voluntary best management practices (BMPs) intended to mitigate impacts and are not fully accounted for by monitoring conducted by operators.