HomeMy WebLinkAboutExhibit R - Phil Vaughan letter dated 05.20.2013Microsoft Office Outlook - Memo Style
1 Tamra Allen From: Phil Vaughan [phil@pvcmi.com] Sent: Monday, May 20, 2013 11:29 AM To: Tamra Allen Subject: Garfield County ULUR 5/8/13 Tamra Allen Memo to the Garfield County Board
of Commissioners Attachments: 05-08-13-GarcoStaffMemo-LandUseCodeRedlines.pdf Tamra, I hope that you are doing well today. I have had the opportunity to review the attached 5/8/13 memo
presented to the Commissioners on 5/13/13. This memo was prepared for the Board of County Commissioners redlining changes made during the 5/7/13 public hearing. Please find comments
below that I will present to the Board of County Commissioners during the Public Hearing. 1. Table 3 ‐403‐ Use Table A. Page 3‐24. Employee Housing Facility, Major and Minor have been
deleted as a possible use from the Resource Lands‐Escarpment and Resource Lands‐Talus Slope zone districts. Reply: There are a number of existing natural gas drilling pads located on
the Resource Lands‐Talus Slope Zone District, and I suspect others will be developed in the future. I would recommend adding the Major Employee Housing Facility back in to the Resource
Lands‐Talus Slope Zone District as a Limited Impact Review and the Minor Employee Housing Facility back in to the Resource Lands‐Talus Slope Zone District as an Administrative Review.
This will allow for these critical housing facilities to be placed on these locations, with protections in place via standards set forth in Sections 7‐ 705 and 7‐706. B. Page 3‐26. Compressor/Pipelin
e Pump Station (Not subject to Article 9). Reply: Please find below the current proposed Garfield County definitions noting Compressor/Pipeline Pump Station and the deletion of “Compressor,Booster”.
Garfield County-Compressor/Pipeline Pump Station. An installation consisting of equipment utilized to increase pipeline pressures, and monitor operating conditions, and associated control
equipment in order to move gas and/or liquids in pipelines. Compressor, Booster. Booster Compressors tTypically consist of a single compressor unit located on an existing well pad and
are generally skid‐mounted. Multi‐well pads may require additional Booster Compressor units. Booster Compressors are commonly used to create the same gas velocity that existed earlier
in the life of the well or for a new well. Compressor, Booster is currently not noted in Use Table 3‐503. It is my recommendation that the definition of “Compressor, Booster” should
be retained in Article 15‐ Definitions and “Compressor, Booster” should be added to Table 3‐503 in Industrial Use‐Extraction as a Use‐by‐Right in all zone districts. Oil and Gas Drilling
and Production is currently noted as a use‐by‐right in all zone districts as well. Please note below the proposed Garfield County definition of Oil and Gas Drilling and Production. I
do not feel that this definition adequately defines that Compressor, Booster is included in this activity.
2 Garfield County‐Oil and Gas Drilling and Production. Any operation utilizing equipment that advances a borehole into substrata for the purpose of discovery, development, and/or production
of oil or gas that occurs on an approved COGCC site. C. Page 3‐28. Water Impoundment. This use has been deleted in the Resource Lands‐Escarpment and Resource Lands‐Talus Slope zone districts.
Reply: The proposed revision to the Garfield County definition of “Water Impoundment” in Article 15 is the following: Garfield County-“Water Impoundment. Surface storage and water tank
storage including Includes wastewater treatment settling ponds, surface mining ponds, detention and retention ponds, artificial lakes and ponds, water tanks and similar water storage
and/or treatment facilities. features. “Water Impoundment” aAlso includes surface or tank d, but not limited to, is produced water and condensate impoundments as those the terms are
used by the oil and gas industry. A new Water Impoundment includes an expansion of an existing Water Impoundment except where such expansion was previously authorized by land use action
approved prior to the effective date of this Code.” There are a number of existing natural gas drilling pads located on the Resource Lands‐Talus Slope Zone District, and I suspect others
will be developed in the future. I would recommend adding Water Impoundment back in to the Resource Lands‐Talus Slope Zone District as a Limited Impact Review. This will allow for these
water impoundment facilities to be placed on these locations, with protections in place via standards set forth in Section 7‐1001. This definition of Water Impoundment appears to include
surface facilities utilized in natural gas drilling and production. I would like to propose the following definitions for Water Impoundment and Oil and Gas Drilling and Production: Water
Impoundment. Surface storage and water tank storage including wastewater treatment settling ponds, surface mining ponds, detention and retention ponds, artificial lakes and ponds, water
tanks and similar water storage and/or treatment facilities. Oil and Gas Drilling and Production. Any operation utilizing equipment that advances a borehole into substrata for the purpose
of discovery, development, and/or production of oil or gas including all surface facilities associated with such operations. This activity includes surface or tank produced water and
condensate impoundments as those terms are used by the oil and gas industry. I believe that these 2 proposed definitions will aid in determination of how Garfield County plans to regulate
these activities. Surface or tank produced water and condensate impoundments are a part of oil and gas drilling and production and should remain as a use‐by‐right in Garfield County
versus a Limited Impact Review process. Thank you for your assistance and please let me know of your reply regarding these suggested changes. Sincerely, Phil Vaughan Phil Vaughan Construction
Management, Inc. 1038 County Road 323 Rifle, CO 81650 970‐625‐5350