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HomeMy WebLinkAbout7.0 BOCC Staff Report 12.05.2005Exhibits for Public Hearing on December 5, 2005 — BOCC Special Use Permit for an E & P Waste Facility Southeast of GarCo Airport— EnCana Oil and Gas (USA) Inc Exhibit Letter (A to Z) Exhibit A Mail Receipts B Proof of Publication C Garfield County Zoning Resolution of 1978, as amended D Garfield County Subdivision Regulations of 1984, as amended E Garfield County Comprehensive Plan of 2000 F Staff Report dated 12 -05 -05 G Application for the E &P Facility Special Use Permit H Email dated 9 -30 -05 from Jim Rada I Letter dated 10 -04 -05 from Michael Erion J Unexecuted Watershed District Permit between City of Rifle and EnCana K Application to the State for Monitoring/Observation Water Well Permit Power Point presentation prepared by Planning Staff L IA (I (.V Lire,* .1d \g") °Se ,fitee• d��l C'0113 • F l� u j� y,t r Ate rC (,J2 ll.S I f 4GkrI 4L/e( ( .If.c 44 6141 /1l141ler +4. LrQL• t5 yui4.4k41 � mop/ � w � u� In� a. A-4 IL- o,,,,�� f- 4" 4 Cu ra ° ON a 64 4. r tA G S 6r �u,iwp kr u �, r� 1,oa �, �� ti�,L Pa/ P jinn „ r � w 5 erttit � REQUEST: BOCC 12 -05 -2005 RW PROJECT INFORMATION AND STAFF COMMENTS Special Use Permit for "Storage, Processing, and Material Handling of Natural Resource" Exploration and Production Facility for a Bioremediation Land Farm. OWNER/APPLICANT: EnCana Oil and Gas (USA) Inc. REPRESNTATIVE: Wagon Wheel Consulting LOCATION: Approximately one mile southeast of the GarCo Airport SITE INFO: 8.48 Acres, Parcel # 217919300128 ACCESS: CR 333 WATER: No proposal for potable water SEWER: No sewer service is proposed EXISTING ZONING: ARRD (Agricultural Residential Rural Density) Location map of proposed site — southeast of Rifle 1 Photo is a portion of the proposed site 1. BACKGROUND The Building and Planning Department is in receipt of a Special Use Permit (SUP) application for "Storage, Processing, and Material Handling of Natural Resource" for a Centralized Exploration and Production Waste Facility - Bioremediation Land Farm on a 8.486 acre property owned by EnCana Oil & Gas (USA), Inc. The property is located approximately one mile southeast of the GarCo Airport. As required in §9.03.04 of the Zoning Regulations, this request was heard by the Board of County Commissioners for a possible referral to the Planning Commission. On August 8, 2005 the Board voted to refer this item to the Planning Commission. This decision was based the possible environmental impact to the area and to educate the public concerning the activity of the land farm. 2. PROPOSAL EnCana Oil and Gas USA, Inc are proposing a land farm to treat and reuse soils that have been polluted with petroleum hydrocarbons. The proposal is to use the subject property as a centralized treatment facility for impacted soils from EnCana's well sites and other E&P facilities. The treatment process will consist of bioremediation land farm cells which use microbes to degrade petroleum hydrocarbons contained within the soils. Operation of the land farm provides an environmentally responsible alternative to disposing of the petroleum impacted soils in the local landfill. By remediation of the soils to State standards, EnCana is able to reuse the soils at other facilities. The Site would be fenced and benned to protect from trespassing. It is expected the impacted soils would be brought to the site and treated. After the treated soils reach acceptable State levels, EnCana will remove the soils from the site for safe use at other locations. 2 1. GENERAL REQUIREMENTS FOR ALL SPECIAL USE PERMITS §5.03 Conditional and Special Uses (Zoning Resolution of 1978, as amended) 1) Utilities adequate to provide water and sanitation service based on accepted engineering standards and approved by the Board of County Commissioners shall either be in place or shall be constructed in conjunction with the proposed use. Staff Comments: Due to the nature of the work to be conducted at the site, potable water will not be necessary. If sanitation service is needed, it will be provided to the employees by portable toilets. 2) Street improvements adequate to accommodate traffic volume generated by the proposed use and to provide safe, convenient access to the use shall either be in place or shall be constructed in conjunction with the proposed use. Staff Comments: Garfield County Road and Bridge Department has issued a driveway permit to EnCana for ingress and egress to CR 333. The land farm will create traffic trips that will vary day to day dependant upon the amount of soils needed to be treated. Trucks and heavy equipment will be used on site. 3) Design of the proposed use is organized to minimize impact on and from adjacent uses of land through installation of screen fences or landscape materials on the periphery of the lot and by location of intensively utilized areas, access points, lighting and signs in such a manner as to protect established neighborhood character. Staff Comments: The proposed facility is adjacent to a well site. A six foot high fence will be installed around the perimeter of the facility to insure safety and security. No buildings or structures requiring a building permit are expected. The visual impact of the site should be minimal §5.03.07 Industrial Operations (1) The applicant for a permitfor industrial operations shall prepare and submit to the Planning Director ten (10) copies of an impact statement on the proposed use describing its location, scope, design and construction schedule, including an explanation of its operational characteristics. One (1) copy of the impact statement shall be filed with the County Commissioners by the Planning Director. The impact statement shall address the following: (A) Existing lawful use of water through depletion or pollution of surface run -off, stream flow or ground water. Staff Comments: The facility will require the use of water to suppress dust and treat the soil. . The water will be brought to the site from existing EnCana water sources. If needed, the applicant will 3 provide water through a well or detained storm water. The applicant will need to properly line the facility to protect against pollution of surface run -off, stream flow or groundwater. (B)Impacts on adjacent land from the generation of vapor, dust, smoke, noise, glare or vibration, or other emanations Staff Comments: Impacts to adjacent land is expected to be minimal. Vapors emanating will be less than those found at a typical gas condensate tank battery. By keeping the soils moist, dust will be suppressed. Noise at the site will consist of machinery operating at the site and will be below the standard of 75 decibels at 25 feet from the property. (C) Impacts on wildlife and domestic animals through the creation of hazardous attractions, alteration of existing native vegetation, blockade of migration routes, use patterns or other disruptions. Staff Comments: The site will be fenced with a six foot chain link fence with locking gates which will keep out wildlife, domestic animals, and serve to deter entry by unauthorized personnel. (D) Affirmatively show the impacts of truck and automobile traffic to and from such uses and their impacts to areas in the County. Staff Comments: Traffic to the site will be episodic. There will be daily traffic to the site for land farm operators and authorized personnel making routine inspections. (E) That sufficient distances shall separate such use from abutting property which might otherwise be damaged by operations of the proposed use(s). Staff Comments: The site is isolated from abutting uses; there are no residential properties in close proximity to the site. The nearest building is located more than 1,500 feet to the northwest. The remaining use near the proposed land farm is a well site. (F)Mitigation measures proposed for all of the foregoing impacts identified and for the standards identified in Section 5.03.08 of this Resolution. Staff Comments: The applicant is proposing a six foot high fence around the entire perimeter of the site that will provide safety and security. There are few impacts expected as a result of the land farm. Machinery will only be operated during the unloading activities and when turning the soil. (2) Permits may be granted for those uses with provisions that provide adequate mitigation for the following: (A) A plan for site rehabilitation must be approved by the County Commissioners before a permit for conditional or special use will be issued. Staff Comments: The applicant is required by the COGCC to submit a closure (reclamation) plan. This plan is attachment G of the application materials, which outlines in detail the proposed measures for reclamation. Additionally the applicant is required to post $50,000 in financial assurance with the COGCC for reclamation purposes. The proposed reclamation plan is acceptable to staff. The applicant has not submitted a weed inventory or a weed management plan for the site. Prior to issuance of this SUP the applicant shall provide this information. 4 (B)The County Commissioners may require security before a permitfor special or conditional use is issued, if required. The applicant shall furnish evidence ofa bank commitment of credit, bond, certified check or other security deemed acceptable by the County Commissioners in the amount calculated by the County Commissioners to secure the execution ofthe site rehabilitation plan in workmanlike manner and in accordance with the specifications and construction schedule established or approved by the County Commissioners. Such commitments, bonds or check shall be payable to and held by the County Commissioners. Staff Comments: It shall be at the discretion of the Board of County Commissioners to determine whether additional security is needed. (C) Impacts set forth in the impact statement and compliance with the standards contained in Section 5.03.08 of this Resolution. (A. 93 -061) §5.03.08 Industrial Performance Standards All industrial operations in the County shall comply with applicable County, State, and Federal regulations regulating water, air and noise pollution and shall not be conducted in a manner constituting a public nuisance or hazard Operations shall be conducted in such a manner as to minimize heat, dust, smoke, vibration, glare and odor and all other undesirable environmental effects beyond the boundaries of the property in which such uses are located, in accord with the following standards; (1) Volume of sound generated shall comply with the standards set forth in the Colorado Revised Statutes at the time any new application is made. (A. 93 -061) Staff Comments: The proposed use of the site will create noise that is proposed to be below 75 decibels at 25 feet from the property. The applicant shall be aware of all sound volume standards and meet all State requirements. (2) Vibration generated: every use shall be so operated that the ground vibration inherently and recurrently generated is not perceptible, without instruments, at any point of any boundary line of the property on which the use is located;. Staff Comments: No vibrations are expected to result from the operation of land farm. During construction it may be necessary to compact the soils, but is anticipated that this activity will not be perceptible. (3) Emissions of smoke and particulate matter: every use shall be operated so as to comply with all Federal, State and County air quality laws, regulations and standards. 5 Staff Comments: There will not be emissions of smoke from the land farm. Due to the nature of the treated soils, open flames will not be permitted onsite. All air quality permits will be issued by the State and shall be in place prior to issuance of this SUP. (4) Emission of heat, glare, radiation and fumes: every use shall be so operated that it does not emit heat, glare, radiation or fumes which substantially interfere with the existing use of adjoining property or which constitutes a public nuisance or hazard. Flaring of gases, aircraft warning signals, reflective painting of storage tanks, or other such operations which may be required by law as safety or air pollution control measures shall be exempted from this provision. Staff Comments: The land farm will not create glare, radiation or fumes that will substantially interfere with adjoining property. The activity on the site will be passive, microbial degradation which will not cause radiation or fumes that will interfere with the existing use of adjoining properties. Once again, the applicant shall be aware of all State and Federal guidelines and provide any mitigating measures prior to issuance of this SUP. (5) Storage area, salvage yard, sanitary landfill and mineral waste disposal areas: (A97 -112). (A) Storage of flammable or explosive solids or gases shall be in accordance with accepted standards and laws and shall comply with the national, state and local fire codes and written recommendations /comments from the appropriate local protection district regarding compliance with the appropriate codes; (A97 -112) Staff Comments: Storage of the waste soil will not be explosive and shall be in accordance with all COGCC rules. (B) At the discretion of the County Commissioners, all outdoor storage facilities may be required to be enclosed by fence, landscaping or wall adequate to conceal such facilities from adjacent property; (A97 -112) Staff Comments: The proposed facility is adjacent to an existing well site. A six foot high fence and berming will be installed around the perimeter of the facility in order to insure safety and security. Although the site will be visible from adjoining property, it will be compatible with existing uses and will not detract from the "neighborhood character" (C) No materials or wastes shall be deposited upon a property in such form or manner that they may be transferred off the property by any reasonably foreseeable natural causes or forces; (A97-112) Staff Comments: The contaminated soils will be managed on site and will not be tracked offsite by trucks. Staff is recommended the affected areas of the land farm be properly lined to mitigate any leaching of pollutants into the ground water. 6 (D) Storage of Heavy Equipment will only be allowed subject to (A) and (C) above and the following standards: (A97 -112) 1. The minimum lot size is five (5) acres and is not a platted subdivision. 2. The equipment storage area is not placed any closer than 300 ft. from any existing residential dwelling. 3. All equipment storage will be enclosed in an area with screening at least eight (8) feet in height and obscured from view at the same elevation or lower. Screening may include berming, landscaping, sight obscuring fencing or a combination of any of these methods. 4. Any repair and maintenance activity requiring the use of equipment that will generate noise, odors or glare beyond the property boundaries will be conducted within a building or outdoors during the hours of 8 a.m. to 6 p.m., Mon. -Fri. S. Loading and unloading of vehicles shall be conducted on private property and may not be conducted on any public right-of-way. Staff Comments: Equipment will be stored on the site by independent contractors and the machinery will be on site within the fenced area. The lot size is 8.48 acres. There is no residential dwelling within 300 feet. Fencing and berming is proposed for the site. (E) Any storage area for uses not associated with natural resources shall not exceed ten (10) acres in size. (A97 -112) Staff Comments: The proposed site is 8.48 acres and no additional storage is proposed. (F) Any lighting of storage area shall be pointed downward and inward to the property center and shaded to prevent direct reflection on adjacent property (A97112). Staff Comments: The applicant has not submitted any lighting plans. Should outdoor lighting be used, the applicant shall ensure that all lighting is downward and inward facing and no light will trespass on adjoimng property. (6) Water pollution: in a case in which potential hazards exist, it shall be necessary to install safeguards designed to comply with the Regulations of the Environmental Protection Agency before operation of the facilities may begin. All percolation tests or ground water resource tests as may be required by local or State Health Officers must be met before operation of the facilities may begin. Staff Comments: The applicant has stated the operation and construction will be in accordance with all COGCC standards and requirements. The applicant is also proposing three to five ground water monitoring wells and three leak detection wells. Regardless, ground water pollution is a concern to the City of Rifle and to Garfield County. Staff is recommending the storm water detention pond must be lined and the land farm area must be contained within an impermeable material. 7 4. SUGGESTED FINDINGS 1. That proper public notice was provided as required for the hearing before the Board of County Commissioners 2. That the hearing before the Board of County Commissioners was extensive and complete, that all pertinent facts, matters and issues were submitted and that all interested parties were heard at that meeting. 3. That for the above stated and other reasons, the proposed Special Use Permit is in the best interest of the health, safety, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. That the application is in conformance with the Garfield County Zoning Resolution of 1978, as amended. 5. PLANNING COMMISSION RECOMMENDATIONS — On October 12th, 2005 Planning Commission voted unanimously to recommend approval of the Special Use Permit to the BOCC with the following conditions. Staff is in full support of the Planning Commission's recommendation of approval with conditions. 1. That all representations of the Applicant, either within the application or stated at the hearing before the Board of County Commissioners, shall be considered conditions, of approval unless explicitly altered by the Commission. 2. That the operation of the facility be done in accordance with all applicable federal, state, and local regulations governing the operation of this type of facility. 3. Should the need arise, the County reserves the right to retain outside expertise, at the expense of the applicant / operator of the facility, in order to conduct tests or analyses of the physical nature, water chemistry or groundwater properties on or away from the site. 4. That this facility is for the sole use of the applicant. If any other entities are to be added as users, then they would be subject to an additional SUP as well as rules and regulations as administered by the COGCC. 5. The Applicant shall submit a weed inventory and control plan of the subject property. 6. The Applicant shall comply with all standards as set forth in §5.03.08 "Industrial Performance Standards" of the Garfield County Zoning Resolution of 1978 as amended. 7. The storm water detention pond must be lined. 8 8. The ownership of E & P wastes shall be documented as to generation and the disposal location. Such data shall be made available to the County upon request. 9. That the Applicant shall obtain a City of Rifle Watershed District Permit prior to issuance of the SUP 10. That the ground water monitoring wells and leak detection wells can be phased. The number of wells and their location shall be reviewed and approved by the Garfield County Environmental Health Manager (Jim Rada). These wells shall be sampled and tested in accordance with State and Federal regulations. Results shall be provided to the County on an annual basis. 11. That the Applicant shall insure its contractor obtains Storm water Discharge Permit from CDPHE prior to issuance of the SUP and complies with the approved erosion and sediment control plan. 12. That the Applicant shall submit an Air Pollutant Emission Notice to the CDPHE prior to issuance of the SUP. 13. That the Applicant phases the berming to the area or areas that are immediately used for the land farm. 14. Prior to issuance of the SUP, that the applicant shall submit an access easement that specifically allows for the proposed use. 15. Prior to thi . • p ication _ + ' : + efore the ► : • of County - . ssione that theapplicant m with ichael Eri + • of Reso . • Engineers clarify resolve---I6- concerts and commendat' s as to the g of the land E area. 16. That the Board of County Commissioners shall have an annual review of this SUP. 6. RECOMMENDED MOTION "I move to approve the Special Use Permit request for a Centralized Exploration and Production Facility for a land farm to treat soils contaminated with petroleum hydrocarbons on a parcel owned by EnCana Oil and Gas (USA), Inc that is southeast of the Garfield County Airport." 9 Page I of 1 Richard Wheeler From: Jim Rada Sent: Friday, September 30, 2005 3:39 PM To: Richard Wheeler Cc: Mark Bean; Mary Meisner; Steve Anthony Subject: Encana Centralized E &P Waste Management Facility SUP Application Richard, Thanks for taking some time to talk to me this afternoon about the above referenced project. Also, thanks for the EPA land farming link. That was very helpful_ The design appears to be sound. My site visit with Jimmy Smith this morning was very informative and helpful in understanding the topography and other site characteristics. At your request, I am offering the following suggestions to perhaps improve the development of this site and to provide the County with an opportunity to more effectively limit future issues with this operation. 1, I strongly encourage phased grading of this site. Jimmy indicated that the intent is to use only a small portion of the site initially for the land farming operation. Depending on the area needed, surface grading could be limited to only the actual area needed. There is a substantial amount of healthy vegetation on this site. I suggest that rather than initially regrading the entire 8.48 acres, that Encana only construct the fence around the site and the detention pond along with a berm around the necessary area of disturbance along the west edge (from the entry road to the north end) and north edge of the site then proceeding around the pond to the eastern edge of the disturbance area. Drainage from the south (including the well pad immediately upgradient) could then be allowed to filter through the vegetated area rather then being channelized toward the ephemeral drainages near the site. As more area is needed, then additional site grading and berm building could take place in an easterly and southerly direction to accommodate the facility's needs. This would not only retain the native vegetation but would hopefully limit problems with weed management, water quality, soil erosion, dust etc. and would allow the natural drainage patterns to remain intact until additional area is needed. 2. I also suggest that, if allowed under the law, language be included that allows the county to access the site and/or require submission of monitoring records as needed for purposes of investigating environmental or public health concerns. On another note, I'm curious if there is a possibility here for a future collaborative effort as the county moves toward clean up of the old maintenance facility underground storage tank site. If needed, maybe this site could be used to deal with some of the waste from that cleanup project if other County facilities cannot fully manage the load. Just a thought. Let me know if you need anything else or clarification of anything I've said here. Thanks, Jim Rada, REHS Environmental Health Manager Garfield County Public Health 195 W 14th Street Rifle, CO 81650 Phone 970 -625 -5200 x8113 Cell 970 -319 -1579 Fax 970- 625 -8304 Email jrada ©garfield- county.com Web www.garfield- county.com 10/5/2005 EX IBIT a ■ ■■■■ �R criv. D :::::RES JLJFRCE OCT042005 ••••• ■ ■■ ■■ E N G I N E E R I N G I N C. Richard Wheeler Garfield County Building & Planning Department 108 Eighth Street, Ste 201 Glenwood Springs CO 81601 RE: EnCana Centralized E & P Waste Management Facility Special Use Permit Review Dear Richard: GAR I- to LG L.!,_;uNTY BUILDING & PLANNING October 4, 2005 At the request of Garfield County, Resource Engineering, Inc. (RESOURCE) has reviewed the Special Use Permit Application from EnCana Oil & Gas (USA), Inc., for a proposed Centralized E & P Waste Management Facility located near the Garfield County Airport. The submittal included a three -ring binder prepared by Wagon Wheel Consulting. SUMMARY The proposed Special Use Permit Application appears to meet the technical criteria for the Special Use requirements in Section 5.03, the specific requirements in Section 5.03.07, and the standards in Section 5.03.08 of the Garfield County Zoning Regulations. The requirements of each Section are more specifically discussed below. Several conditions of approval are recommended and presented at the end of the letter. SPECIAL USE GENERAL REQUIREMENTS The general requirements for any Special Use include providing adequate water and wastewater service and adequate road improvements and/or access for the proposed use. The proposed Special Use does not require potable drinking water or wastewater services. The facility would be accessed from County Road 333 using an existing access road for EnCana's Well Pad K19NE. The application indicates that the characteristics of the traffic in the area will remain the same as current conditions. Transport of contaminated soils from the various well pads and facility sites is required regardless of whether the subject facility is approved. Such traffic will be periodic. The facility will create the demand for operations and testing personnel traffic. Although no estimate is listed in the application, it can be conservatively estimated at 10 vehicle trips per day (equivalent to a single family lot). GARCO Road and Bridge should be contacted regarding any specific issues related to County Roads impacts. INDUSTRIAL OPERATIONS REQUIREMENTS Section 5.03.07 of the County Zoning Regulations outlines additional specific criteria for industrial operations. These criteria require that the applicant prepare and submit an impact statement of the proposed use. The Applicant's impact statement affirmatively addresses the items outlines in Section 5.03.07. These issues include stormwater management, spill prevention control, water supply, dust, smoke, vapor, noise, glare, vibration, wildlife, and traffic. Consulting Engineers and Hydrologists 909 Colorado Avenue • Glenwood Springs, CO 81 601 U (970] 945-6777 • Richard Wheeler October 4, 2005 Page 2 of 3 Section 5.03.08 of the County Zoning Regulations describes required industrial performance standards for the project. The application outlines compliance with these standards. Several conditions of approval related to compliance with these standards are presented later. The project site is within the City of Rifle Watershed Protection District for the potable water supply and requires a permit from the City. The project also requires an Air Pollutant Emission Notice (APEN) and a Stormwater Discharge Permit from the Colorado Department of Public Heath and Environment. In accordance with Section 5.03.08, these permits should be included as a condition in any approval of the County Special Use Permit. ANALYSIS The proposed activity includes site grading and construction of a contaminated soil remediation pad, stormwater detention pond, and associated temporary structures. The entire facility will be surrounded by a 2 foot containment berm. The facility will treat and remediate contaminated soils from EnCana 's operations in the area. The facility will use fertilizer and other nutrients as part of a bioremediation process. Clean water will be imported from remediation processes and dust control. A stormwater pond capable of storing the 100 year event will be constructed at the downslope end of the property. The plans do not indicate that the stormwater pond or "earth farm" pad area will be lined. These areas must be lined to prevent potential for groundwater contamination. Groundwater monitoring wells will be placed around the site to detect any hazardous leaks from the site. Erosion and sediment cor.trol measures will be implemented and a Stormwater Discharge Permit is required from the Colorado Department of Public Health and Environment for construction activities. The site is anticipated to operate for 20 to 25 years. The site closure plan includes removal of any residual E & P wastes, restoration of site soils and grading to baseline conditions, placement of topsoil and seeding with indigenous grass seeds. CONDITIONS OF APPROVAL 1) The stormwater detention pond must be lined and the land farm area must be contained within an impermeable material. 2) The ownership of E & P wastes shall be documented as to generation and the disposal location. Such data shall be made available to the County upon request. 3) EnCana shall obtain a City of Rifle Watershed District Permit. 4) The monitoring wells shall be sampled and tested in accordance with State and Federal regulations. Results shall be provided to the County on an annual basis. 5) EnCana shall insure its contractor obtains a Stormwater Discharge Permit from CDPHE and complies with the approved erosion and sediment control plan. R NJ f EXHIBIT 1g Richard Wheeler Page 3 of 3 October 4, 2005 6) EnCana shall submit an Air Pollutant Emission Notice to the CDPHE. Please call if you have any questions or need additional information Sincerely, RESOtJRC E ► I ERING, INC. Michael J. n, E. Water Res•urce Engineer MJE /II 885 -23.0 rw EnCana e&p waste cc: Jimmy Smith, Wagon Wheel Consulting ..•.• R N EXHIBIT EnCana Special Use Permit E &P Waste Facility 9 `31i $T a i FI — r-- 6 Y �6 �A V 1 1 ) ( (;1 ; ECM scy •.xm i �.. \ r' \ti I 4 ..i. ■ e� 9 IA tar Iri a To.I. a pE3`1 l U 111 1 —i 2 BEFORE THE CITY COUNCIL OF THE CITY OF RIFLE, COLORADO CONCERNING THE APPLICATION FOR A WATERSHED DISTRICT PERMIT OF ENCANA OIL & GAS (USA) INC. FOR A CENTRALIZED EXPLORATION AND PRODUCTION WASTE MANAGEMENT FACILITY FINDINGS OF FACT, CONCLUSIONS OF LAW AND APPROVAL OF WATERSHED DISTRICT PERMIT NO. 5 -05 I. BACKGROUND 1. On July 21, 2005, EnCana Oil & Gas (USA), Inc. ( "EnCana" or the "Applicant") applied to the City of Rifle (the "City ") for a watershed district permit to construct and operate a Centralized Exploration and Production Waste Management Facility located in the South 'A, Section 19, Township 6 South, Range 92 West, 6th PM, Garfield County, Colorado (the "Facility "). The Facility is located within five (5) miles of the City's Colorado River water intake structure within the City's Watershed District jurisdiction and the application was submitted pursuant to City of Rifle Ordinance No. 22, Series of 1994, codified in Article II of Chapter 13 of the Rifle Municipal Code ( "RMC "). The proposed activities include the construction and operation of a centralized exploration and production waste management facility. 2. For the purposes of this permit (the "Permit"), the application shall consist of the watershed permit application and accompanying materials submitted by Wagon Wheel Consulting, all correspondence and materials submitted to the City by the Applicant or its agents and representatives, as well as all representations, whether oral or written, made as part of the application, and the Erion Letter, discussed below. These items shall be collectively referred to herein as the "Application." 3. Any and all other permits issued or to be issued by county, state and/or federal agencies in relation to the construction and operation of the Facility are incorporated herein by this reference. 4. Following his review of the application, Michael Erion, P.E. of Resource Engineering, Inc., Consulting Professional Engineer for the City, stated his findings in a letter dated September 23, 2005, attached hereto and incorporated herein by this reference (the "Erion Letter "). The Erion Letter concluded that the proposed activities to be performed do not present or create a clear or foreseeable risk of significant injury to the City's waterworks or pollution to the City water supply so long as the Applicant adheres to the conditions stated in the Erion letter. Therefore, the activities are classified as a Minor Impact under the RMC. 1: 120055CIienta 'RifleSR- 3(255)EnCana• i 1805DocumentsTumitNo5- 05.wpd -1- City of Rifle, Colorado Watershed District Permit No. 5 -05 EnCana Oil & Gas (USA) Inc. E &P Waste Management Facility II. FINDINGS OF FACT 5. The proposed activities are within the defined boundaries of the City's Watershed District as defined in RMC § 13 -2 -20, specifically within five (5) miles of the City's Colorado River municipal water diversion and intake structure. The proposed activities include the construction and operation of a Centralized Exploration and Production Waste Management Facility. 6. The Application filed by EnCana is complete. 7. EnCana has paid the application fee required under RMC §13-2-110. 8. A duly noticed Public Hearing was held before the Rifle City Council (the "Council ") on October 19, 2005. At the hearing, testimony was presented by Michael Erion regarding the activities proposed by EnCana and the applicability of the City's Watershed District Ordinance. Mr. Erion explained to the Council that its jurisdiction on this matter extended five (5) miles beyond the City's Colorado River intake, and that it's authority was limited to the protection of the City's water supply and quality. Mr. Erion also explained the provisions of the Permit and recommended issuance of the Permit subject to the terms and conditions set forth in the Erion Letter, which classified the proposed activities as a Minor Impact pursuant to RMC §13- 2- 120(c). Jimmy Smith of Wagon Wheel Consulting on behalf of EnCana also provided testimony regarding the Application and the proposed activities. Testimony was opened up for members of the public. 9. The City Council expressed concern regarding materials from operations performed by entities other than EnCana may have contaminants not known to EnCana that can be processed by the Facility. Council therefore wanted a condition that only EnCana may process material at the Facility. Council further wanted as much water quality monitoring information obtained by EnCana provided to the City. With those additional conditions, the Council found that the proposed activities do not present or create a clear or foreseeable risk of significant injury to the City's waterworks or pollution to the City water supply if proper Best Management Practices (BMPs) for the activities are in place as proposed in the Application and outlined as conditions in the Erion Letter. 10. The Council hereby finds and determines that the issuance of the Permit requires the inclusion of conditions as set forth in the Erion Letter, that such conditions are necessary to prevent a risk of injury to the City's waterworks and pollution of the City's water supply, and that such conditions are authorized pursuant to § 13 -2 -140 of the RMC. (: 120055CIieoteatinclR- 3(255)EnCana.I 1801Documeule\P,rmitNo5- 05.wpd -2- City of Rifle, Colorado Watershed District Permit No. 5 -05 EnCana Oil & Gas (USA) Inc. E &P Waste Management Facility 18. This Permit shall not be effective until approved by the City and agreed to and by EnCana. Dated this day of , 2005. By CITY OF RIFLE, COLORADO Mayor City of Rifle Watershed District Permit No. 5 -05 accepted and agreed to this day of , 2005. 1:120055CIienla\Rifk \R- 3(235)E nCona - 11801DocumcnlsWermitNo5- 05.wpd By: -4- ENCANA OIL & GAS (USA) INC. Name: a A r o E. R r s s o Title: eo/o erz,a ri o v✓s a 2-4.42,6<_ COLORADO DIVISION OF WATER RESOURCES DEPARTMENT OF NATURAL RESOURCES 1313 SHERMAN ST., RM 818, DENVER CO 80203 phone — info: (303) 866 -3587 main: (303) 866 -3581 Fax: (303) 866 -3589 http: / /www.water.state.co.us ]ON ITORING /OBSERVATION Water Well Permit Application Review Instructions on reverse side prior to completing form. The form must be completed in black or blue Ink or typed, Office Use Only eilEk ovl t.lyRt . , kl sL • • ars Form GWS -46 (02/2005) 1 Well Owner Information 6. Use Of Well Name of well owner EnCana Oil & Gas Use of this well is limited to monitoring water levels and/or water quality sampling Mailing address 2717 County Road 215 Suite 100 7. Well Data (proposed) city Parachute State Co Zip cads 81630 Total depth 150 feet Aquifer Tributary 8. Consultant information (if applicable) Telephone (970)285 -2600 Name of contact person Wayne Shelton 2. Type Of Application (check applicable boxes) ❑ Use existing well ® Construct new well ❑ Other ❑ Replacement for existing monitoring well: Permit no.: Company name Shelton Drilling Corp. Mailing address 20522 Hwy. 82 P.O. Box 1059 3. Refer To (if applicable) Monitoring hole acknowledgment MH- Well name or # E &P Waste - Monitor Well # 1 City Basalt State Co Zlp Code 81621 4. Location Of Proposed Well County 3rfield Telephone # (970) 625-4182 NE 114 of the SW 1!4 9. Proposed Well Driller License #(optional):1095 sction 19 ownshlp Nor S 6 ©® Range E or W 92 ❑ El Principal Meriden Sixth Distance of wen from section limes (section fines am typically not property mes) 1901 Ft from ❑N ®s 1299 Ft. from ❑E ®W For replacement wells only - distance and direction from old well to new well feet direction Well location address (if applicable) 10. Signature Of Well Owner, Consultant Or Authorized A A. ent The making of false statements herein constitutes perjury in the second degree, which is punishable as a class 1 misdemeanor pursuant to C.R.S. 24 -4-104 (13)(a). I have read the statements herein, know the contents thereof and state that they are true to my knowledge. Sign trerg {f+yt be original signature) Date Print name & title 7lcrose Optional: GPS well location information in LITM format You must check GPS unit for required settings as follows: Office Use Only /i1 aS o, R4d174e( Format must be UTM ❑Zone 12or❑ Zone 13 Units must be Meters Datum must be NAD83 unit must be net to hie north Was GPS unit checked for above? ❑ YES Easting Northing Remember to set Datum to NAO83 USGS map name DWR map no. Surface elan. 5. Property Owner Information Name of property owner EnCana Oil & Gas (USA) Inc. tailing address 11717 County Road 215 Suite 100 state arach ute Co Zip Code 81630 Telephone # (970) 285 -2600 Receipt area only DIV %OLORADO DIVISION OF WATER RESOURCES .PARTMENT OF NATURAL RESOURCES /313 SHERMAN ST., RM 818, DENVER CO 80203 phone — info: (303) 866 -3587 main: (303) 866 -3581 I : (303) 886 -3589 http:Nwww.water.state.co.us Office Use Only Form GWS-46 (02/2005) >� ` ',7,41E1 }Fiv , 7 'U F„ .., ,.iONITORINGIOBSERVATION Water Well Permit Application Review instructions on reverse side prior to completing form. The form must be completed in black or blue Ink or typed.s: 1. Well Owner Information 6. Use Of Well Name of wall owner EnCana Oil & Gas -� -- — Use of this well is limited to monitoring water levels and/or water quality sampling Malang address 2717 County Road 215 Suite 100 7. Well Data (proposed) Total depth 150 feet Aquifer Tributary City Parachute State Co 7.9 code 81630 8. Consultant Information (if applicable) Name of contact person Wayne Shelton Telephone* (970)285 -2600 2. Type Of Application (check applicable boxes) Company name Shelton Drilling Corp. ❑ Use existing well ❑ Replacement for existing monitoring well: ® Construct new well permit no : ❑ Other. Mailing address 20522 Hwy. 82 P.O. Box 1059 3. Refer To (if applicable) coy State Zip Coda Basalt Co 81621 Monitoring hole acknowledgment .ri- Well name or It E &P Waste - Monitor Well # 2 ToleObene N (970) 625-4182 J4. Location Of Proposed Well 1ty atfield NE 1/4 of the SW 174 9. Proposed Well Driller License #(optional):1095 10. Signature Of Well Owner, Consultant Or Authorized Agent Section 19 Township N or S 6 ❑ ® Range E or W 92 • ® • Principal Meridian Sixth The making of false statements herein constitutes perjury in the second degree, which is punishable as a class 1 misdemeanor pursuant to C.R.S. 244 -104 (13)(a). I have read the statements herein, know the contents thereof and state that they are true to my knowledge. Distance of wall from section lines (section lines ere typically not properly irres) 2228 Ft. from ❑ N ® S 1365 Ft from ❑ E O w Sign Let be original signature) } / 'r / �y� �-' [[[ J Data //-/-05- For replacement walla only - d stances and direction from old well to new well feet direction Print none s titiee -rh a its 0. ,Qb s Sot4c4 it eti, Well location address (if applicable) Office Use Only Optional: GPS well location information in UTM format You must check GPS unit for required settings as follows: USGS map name DWR map no. Surface elev. Fermat must be UTM ❑ Zone 12 or ❑ Zone 13 Units must be Meters Datum must be NAD83 Unit roust be set to true north Was GPO unit checked for above? ❑ YES Fasting Receipt area only Northing Remember to set Datum to NAD93 5. Property Owner Information Name of property owner TCana Oil & Gas (USA) Inc. Mailing address "717 County Road 215 Suite 100 flit! iron DA Alin State Zip Code Parachute Co 81630 Telephone s - -- - - - - - - - COLORADO DIVISION OF WATER RESOURCES '7EPARTMENT OF NATURAL RESOURCES t313 SHERMAN ST., RM 818, DENVER CO 80203 1 phone — info: (303) 866 -3587 main: (303) 866 -3581 .: (303) 866 -3589 http:llwww.water.state,co.us Office Use Only —1 Form GWS-46 (02/2005) RECEIVED NOV 17 :, ,..,.Ch .1 :..F.'. '"4FR d ONITORING /OBSERVATION Water Well Permit Application Review instructions on reverse side prior to completing form. The form must be completed in black or blue ink or typed. 1. Well Owner Information 6. Use Of Well Name of well owner EnCana Oil & Gas Use of this well is limited to monitoring water levels and/or water quality sampling Mallirg address 2717 County Road 215 Suite 100 7. Well Data (proposed) Total depth 150 feet Aquifer Tributary City Parachute State Co Zip code 81630 8. Consultant Information (if applicable) Name of contact person Wayne Shelton Telephone P (970)285 -2600 2. Type Of Application (check applicable boxes) comparynanre Shelton Drilling Corp. i] Use existing well • Replacement for existing monitoring well: ® Construct new well Permit n0.: 0 Other. Marling address 20522 Hwy. 82 P.O. Box 1059 City State Zip Code Basalt Co 81621 3. Refer To (if applicable) Monitoring hole admowiedgment .IH- Well name or # E &P Waste - Monitor Well *3 Talmo• (970) 625 -4182 14. Location Of Proposed Well 9. Proposed Well Driller License #(optianal):1095 I •ty .ilrfield NW 1/4 of the SE 1/4 10. Signature Of Well Owner, Consultant Or Authorized Agent Section 19 Township N or S 6 ® Range E or W 92 ❑ ® Principal Meridian Sixth The making of false statements herein constitutes perjury in the second degree, which is punishable as a class 1 misdemeanor pursuant to C.R.S. 24 -4-104 (13)(a). I have read the statements herein, know the contents thereof and state that they are true to my knowledge. Distance of well from section lines (section lines are typically not property nest 2565 Ft from • N ID S 2539 Ft from ® E 0 w Sign here Must be original signature) �� AIIP f A / Data / /—/ For replacement wells only — distance and Suaction from old well to new well feet direction Print name 8 title yy 4' 2' . d Gy1 /14- ( Well location address (if applicable) Office' Use Only Optional: GPS well location information in UTM format You must check GPS unit for required settings as follows: USGS map name DWR map no. Surface elev. Format must be UTM q Zone 12 or O Zone 13 Units must be Meters Datum must be NAD83 Unit must be set to true north Was GPS unit checked For above? ❑ YES Easting Receipt area only Northing Remember to set Datum to NADa3 5. Property Owner Information Name of property owner c_nCana Oil & Gas (USA) Inc. Melling address 2717 County Road 215 Suite 100 Slate Zip Code Parachute Co 81630 Telephone S COLORADO DIVISION OF WATER RESOURCES GWS-46 MONINST (0212005) DEPARTMENT OF NATURAL RESOURCES MONITORING /OBSERVATION WELL PERMIT APPLICATION INSTRUCTIONS Applications must be typewritten or printed in BLACK or BLUE INK or typed. ALL ITEMS in the application must be completed. Incomplete applications may be returned to the applicant for more Information. Applications are evaluated in chronological order. Please allow approximately six weeks for processing. FEES: This application must be submitted with a $190 filing fee. (The fee for an application to replace or deepen an existing permitted monitoring /observation well is also $190.) Acceptable forms of payment are check or money order, payable to the "Colorado Division of Water Resources ", and Visa, or MasterCard (card number and expiration date must be provided on a separate attachment). Fees are nonrefundable. USES: This form (GWS -46) is to be used when applying for a permit where the only uses are monitoring of water levels and /or water quality sampling. For well construction criteria refer to the Colorado Water Well Construction Rules, 2CCR 402-2. A copy of the Rules may be obtained from any Division of Water Resources Office for a fee of $5, or you may refer to our web site at http: //water.state.co.us. ITEM INSTRUCTIONS: (numbers correspond with those on the front of this forma 1. Provide the name of the well owner and the mailing address where all correspondence will be sent. 2. Check and complete all boxes that apply_ 3. Provide the MH number assigned by the Division of Water Resources in response to the notice of intent to construct a monitoring /observation well. Complete the well name if the structure has a name or identifying number. 4. The county, 'A of the % section designation, section #, township, range, principal meridian, and distances from section lines for the proposed well must be provided. This information is critical in the evaluation, and error or omission may cause a delay. In a typical case, a township is comprised of 36 square section miles, with each section ideally one mile square, or 5,280 feet on each side. Sections are further divided into quarter sections. Each % Section is 2,640 feet square and comprises 160 acres. Each /4 section can be further divided into additional quarters. Each '/4 of the % Section is 1 ,320 feet square and comprises 40 acres. The distances are measured from the section lines. In the following example, the well is located 2,500 feet from the South Section line and 1,400 feet from the East Section line: 6280 ft T 2640 ft 1 1320 ft Well Location Example: NW1 /4 of the SE1 /4 of Section 3, 2500 feet from the South and 1400 feet from the East Section Lines respectively. s01*i S lion Lk* (An option to providing distances from section lines and the %4 of the 1/4 section designation is to provide an accurate GPS location in UTM format. The required GPS unit settings must be as indicated on this form.) Colorado contains two (2) UTM zones. Zone 13 covers most of Colorado. The boundary between Zone 12 and Zone 13 is the 108th Meridian (longitude). West of the log' Meridian is UTM Zone 12 and east of the 108th Meridian is UTM Zone 13. The 108th Meridian is approximately 57 miles east of the Colorado -Utah state line. On most GPS units, the UTM zone is given as part of the Easting measurement, e.g. 1270123456. Check the appropriate box for the zone. 5. Provide property owner information. 6. Use of this well is limited to monitoring water levels and /or water quality sampling only. 7. The actual or anticipated total depth must be provided. Provide the name of the aquifer in which the well will be completed. 8. Provide consultant information (if applicable). 9. Monitoring/observation wells must be constructed by a Colorado licensed well construction contractor or authorized individual, as defined in the Well Construction Rules, 2CCR 402 -2. Only a licensed contractor may construct any monitoring/observation well that penetrates a confining layer, or, is to be converted into a future production well. The well must be constructed in compliance with the Well Construction Rules, unless a variance has been approved allowing an alternative construction design. 10. An ORIGINAL signature of either the well owner, consultant, or their authorized agent must be on the application. IF YOU HAVE ANY QUESTIONS regarding any item on the application form, please call the Division of Water Resources Ground Water information Desk (303 -866- 3587), or the nearest Division of Water Resources Field Office located in Greeley (970 -352 - 8712), Pueblo (719- 542 - 3368), Alamosa (719 - 589 - 6683), Montrose (970 - 249 - 6622), Glenwood Springs (970 - 945 - 5665), Steamboat Springs (970 - 879- 0272), or Durango (970 -247- 1845), or refer to our web site at http: /fwater.state.co.us. 107° 43' 57.000" W 39° 31' 8.152" N 39° 31' -107' 42' ', ' - =..� X49 .+i'.•hY".i 107° 41' 10.854" W 39° 31' 12.027" N • rrs:.... 39° 31' - ly. ,; � n 1 y 11 11. v 44pp 39° 30' 1 y ) ,; � ., ._II.;� V:-'17-----% 4,4 �) � r - . �� ` � Li e 39° 29' 58.521" N 71 107° 43' 54.271" W 1927 North American 0alum, UTM grid zone 13 Generated 13y BigTapo7 Stwvw.igage.cam) Map compiled from USGS Quads: Silt; CO Hunter Mesa- CO I rrrai41.i.r.y 2II Mrr.wW rkxgb INe,,, :xxl m C,, Pnl , i 4irwl •a41.,11+I ?.?1-1.3.• i1•17.1 IIIIn 1-N 11•, 111-1 AM 00,11 M_\ CLIENTS \CORDILLERAN \EN- CANA \E- P- WASIE- MAN \SIIESFlG1).DWG 03/23/2005 2 :13PM A 0 1. 14 Mile 0 1000 2000 Feet 0 0.5 Kilometer L� COLORADO MAP LOCATION -107" 42' ; 39° 30' 39° 30' 2.394" N 107 °41'8.171 "W PROPOSED CENTRALEZED E & P WASTE MANAGEMENT FACILITY LOCATION FIGURE 1 GENERAL SITE LOCATION MAP CENTRAIJZED E & P WASTE MANAGEMENT FACILITY ENCANA OIL & GAS (USA) INC_ GARFIELD COUNTY. COLORADO REVISION DATE: 3/25/05 REVISION NUMHEIt DD/ DRAWN BY RJV APPROVED Er DC PROJECT # E05103 SCALE_ 1- =2000' CORDILLERAN SEC. 19 _ T DRAINAGE DITCH (ARROWS SHOW DIRECTION OF FLOW) 6' CHAIN LINK STORM WATER DIVERSION DITCH PROPOSED E & P WASTE MANAGEMENT FACILITY b 0 SCALE IN FEET CULVERT r -_ ENCANA LOT 3 SECURITY FENCE GATE WELL PAD (K18NE) 6' CHAIN LINK LEGEND fl PROPOSED MONITORING WELL LOCATION - 150 FEET TOTAL DEPTH ® PROPOSED LEAK DETECTION WELL LOCATION (30 FEET TOTAL DEPTH) ALT ALTERNATE LOCATIONS NOTE: ADAPTED FROM TRi STATE LAND SURVEYING INC SURVEY DRAWING hi: \ cfien[s \CORDILERAN \EN— CANA \E —P— waste — man \site pl1n(fig3).dwg PROPOSED WATER SUPPLY EST. >150 FT TOTAL DEPTH FIGURE 3 SITE PLAN AND LAYOUT MAP CENTRALIZED E & P WASTE MANAGEMENT FACILITY ENCANA OIL & GAS (USA) INC, GARFIELD COUNTY, COLORADO REVISION DAYS: REVISION NUMBER: 3/23/65 °cif DRAWN 9r: RN APPROVED BY: DC PROJECT # E05108 SCALE: 1"=120' CORD! LLERAN O J 0 I- O z R R 9 9 3 2 W W 2653. 46' (Meas.) 0 Z T6S, 6th P.M. N89.48'E — 24.29 (G.L.o.) N8879 41 E — 4290.46' (Meas.) Reba, Lot 1 Lot 2 Set 5 L .� Stone Monitoring 1365' Well 12 1299' 19 Rebar 1995 Alum. Cap (Ls 19598) Monitoring Well /3 2w -SL Lot 4 7987 Cap LS 15846 N88:36'19 E 1608.47' (Meas.) N89'33'E — 64.16 (G L.0.) c0 Well Pad (K19 NE) 1991 Cop 2539 Set Slone N88 39 27 E — 2662.87' (Meas.) = SECTION CORNERS LOCATED Basis of elevation is the Rifle 2 Triangulation Station. 39'31'53.80" N Lat. & 107'47'07.78" W Long. (NAD 83). Elevation = 5323.1' (NAVD88). h '9 "W - 2640.24' (Me 0 C O z ENCANA OIL & GAS (USA) INC MONITORING WELLS SECTION 19, T6S, R92W, 6th P.M., GARFIELD COUNTY, COLORADO. d O O Q U) O B A R S C A L E O Q O NOTES: 1. Well footages are measured at right angles to the Section Lines. 2. Bearings are based on Global Positioning Satellite observations. THIS IS TO CERTIFY THAT THE PREPARED FROM FIELD NOTES- MADE BY ME OR UNDER MYI9 THE SAME ARE TRUE AND MY KNOWLEDGE AND BELIES. . rn REGIS REGIS STATE N 4) :r WAS I r ?VEYS HAT T T TO I'1,9t_ T OF # 30125 . 4 'o= ED LANSiin'.y' E'FOR' ATION No. b t LAi'Ts�� F COLORADO ������ TRI STATE LAND SURVEYING & CONSULTING 180 NORTH VERNAL AVE. — VERNAL, UTAH 84078 (435) 781 -2501 DATE SURVEYED: 11 -14 -05 SURVEYED BY: T.P. DATE DRAWN: 11 -15 -05 DRAWN BY: F.T.M. REVISED: SCALE: 1" = 1000' October 24, 2005 Jimmy Smith Wagon Wheel Consulting 111 East 3rd Street, Suite 213 Rifle, CO 81650 CGarfield County BUILDING & DEPARTMENT & PLANNING DEPARTMENT RE: Special Use Permit request for "Processing, Storage, and Material Handling of Natural Resources" for the Centralized E &P Waste Facility Dear Jimmy, The Board of County Commissioners will discuss and review the application at a public hearing scheduled on December 5th 2005 at 1:15 PM. The meeting will be held in the Commissioners' Meeting Room in the Garfield County Plaza Building, 108 8th St., Glenwood Springs, CO 81601. As a matter of process, the Board of County Commissioners shall hold an advertised public hearing on the proposed Special Use Permit at regularly scheduled meeting. The Applicant shall be solely responsible for the publication, property posting, and mailing of all notices. Applicant shall present proof of publication and mailing at or before the meeting. The item cannot be heard if correct noticing requirements have not been met. Notice for the meeting shall be given as follows: 1. Notice by publication, including the name of the applicant, description of the subject lot, a description of the proposed subdivision and nature of the meeting, and the date, time and place for the hearing shall be given once in a newspaper of general circulation in that portion of the County in which the subject property is located at least thirty (30) but not more than sixty (60) days prior to the date such hearing, and proof of publication shall be presented at hearing by the applicant. 2. Notice by mail, containing information as described under paragraph (1) above, shall be mailed to all owners of record as shown in the County Assessor's Office of lots within two hundred feet (200') of the subject lot, all owners of mineral interest in the subject property, and all tenants of any structure proposed for conversion to condominiums, at least thirty (30) but not more than sixty (60) days prior to such hearing time by certified return receipt mail, and receipts shall be presented at the hearing by the applicant. 3. The site shall be posted such that the notice is clearly and conspicuously visible from a public right -of -way, with notice signs provided by the Planning Department. The posting must take place at least thirty (30) but not more than sixty (60) days prior to the hearing date and is the sole responsibility of the applicant to post the notice, and ensure that it remains posted until and during the date of the hearing. Enclosed is the appropriate notice and "posting sheet "for the Board of County Commissioners meeting. Note: Due to the amount of agencies that have reviewed this application, staff will need 4 additional copies of the completed application. Copies need to be submitted by November 18111 2005. Best regards, ------7 Richard Wheeler — Senior Planner 108 8th Street, Suite 201, Glenwood Springs, Colorado 81601 (970) 945 -8212 (970) 285 -7972 Fax: (970) 384 -3470