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HomeMy WebLinkAbout1.22 Ursa BM PUD Standards Analysis - BMC B NTC Revisions 08-06-15Article 7 Standards Analysis Ursa Operating Company and Battlement Mesa Partners Major Impact Review Application Battlement Mesa PUD Phase I BMC B OAProject No. 014-1829 OLSSON ASSOCIATES Article 7 — Standards Analysis Ursa Operating Company and Battlement Mesa Partners Battlement Mesa PUD Phase I BMC B GARFIELD COUNTY ZONING RESOLUTION OF 1978 5.03 CONDITIONAL AND SPECIAL USES SECTION 5.03(1) UTILITIES Ursa's water requirements for the proposed land use are temporary in nature. After the well pad enters the production phase, sources of non -potable water for drilling and completions activities and potable water for employees will not be required. The facility will not be manned on a regular basis and will not require fresh water distribution and a wastewater system to properly function. Workers will provide their own potable water in their trucks. Ursa will provide bottled or potable water to personnel at their field office. A source of water will not be required for the production operations of the facility. Water will not be required for the operation of sanitary facilities. Portable toilets will be used, and all wastes will be hauled to a licensed treatment facility. Copies of "Will Serve" letters from Redi Services and Western Colorado Waste are included in the Wastewater Management Section of this submittal. Per details included in the SUA between Ursa and the landowner, no landscaping is proposed for this project location. Thus, there are no requirements for water for irrigation purposes. Ursa has entered into a Water Service Agreement (WSA) with the Battlement Mesa Metropolitan District (BMMD) to obtain non -potable water for use in drilling and dust control. A copy of the contract is included in the Water Supply section. A letter confirming legal and adequate water supply is provided, also. During drilling and completion operations, potable water will be provided at this facility by Stallion Oilfield Services via their existing water contract(s). A copy of the will serve letter is included as part of this application in the Water Supply Section. Letters from the Town of Silt confirming legal and adequate water supply are provided. SECTION 5.03(2) STREET IMPROVEMENTS A Detailed Traffic Study performed by Olsson Associates is included in this submittal. Based on the expected trip generation rates discussed in the report, the increase in average daily traffic is expected to be up to 30 vehicles per day during the construction phase in the vicinity of the site, which is anticipated to increase traffic by approximately 1% on many of the impacted roadways. 760 Horizon Drive, Suite 102 TEL 970.263.7800 Grand Junction, CO 81506 FAX 970.263.7456 www.olssonassociates.com Ursa Operating Company Battlement Mesa PUD Phase I — BMC B Daily traffic is anticipated to increase by approximately 10% on County Road (CR) 307. At the end of construction, site traffic contributions will decrease to two vehicles per day. All movements at the access are anticipated to operate at acceptable levels of service throughout construction. The addition of site traffic, even in the height of construction, does not increase the existing volumes to amounts required for auxiliary lanes where they are not already provided. Once construction is complete, the daily volumes will reduce to approximately four vehicles per day for the two well pad sites. Based on the results of the analysis, no mitigation is recommended for the site. Ursa will adhere to Garfield County Road and Bridge criteria for securing heavy haul permits as well as permitting additional truck traffic along CR 300, CR 300S, and CR 307 within Battlement Mesa. SECTION 5.03(3) IMPACTS TO ADJACENT LAND USES The well pad will be visually buffered from adjacent residences through topography, distance, and vegetation. If necessary, Ursa may install a sound wall during drilling and completion operations to mitigate for sound and some visual impacts. Any lighting will be directed downward and inward away from adjacent properties. All equipment that remains on the pad after drilling and completions will be painted a neutral color to blend into the landscape. The proposed well pad has one access point off of River Bluff Road at the southern end of the project site. The site will be organized to provide safe access to and from the site and parking off the public right-of-way. It will not disrupt solar access to adjacent properties, pedestrian access, nor access to common areas along River Bluff Road. The operations of activities on the site will be managed to avoid nuisances to adjacent uses relating to hours of operations, parking, service delivery, and location of service areas and docks. All parking and service areas will be on-site. No street activities will be allowed, except in cases of emergency. According to Ursa's Fugitive Dust Control Plan, dust control may consist of water, surfacing materials, or non -saline dust suppressants as appropriate for road conditions. Per the SUA, no flaring will be permitted within 2,000 feet of an occupied dwelling, except in an upset condition. Production equipment will comply with applicable Colorado Department of Public Health and Environment (CDPHE) and Colorado Oil and Gas Conservation Commission (COGCC) regulations governing VOC emissions. Ursa will be in compliance with the applicable CDPHE Air Quality Control Commission regulations, including Regulation No. 2 requirement that no oil or gas operation may cause or allow the emission of odorous air from any single source that is detectible after the odorous air has been diluted with seven or more volumes of odor -free air. Ursa has implemented a compliance program to address Regulation No. 7 requirements regarding emissions from tanks and other facilities. Drilling and completion operations are subject to the maximum permissible noise levels for industrial zones. During the production phase of the well, Residential/Agricultural/Rural zone maximum noise levels will apply, per the SUA and COGCC Rules. Standards Analysis Page 2 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B Stationary engines and their exhausts will be located and oriented to direct noise away from the homes closest to the well pad. Ursa will evaluate noise generation from equipment and require contractors to refit mufflers, etc., in situations where the volume of sound produced exceeds noise levels for Residential/Agricultural/Rural zones. Engine braking will be prohibited by Ursa for its personnel and contractors. Per the SUA, there will be no time of day restrictions with regard to drilling, completing, re - completing, workover, or reservoir fracture stimulation operations. Routine ongoing maintenance and production operations activities will be limited to the hours of 7:00 am to 8:00 pm. The proposed well pad may be surrounded by a sound barrier to mitigate visual and noise impacts during drilling and completion activities. Once the well pad enters the production phase, the barrier will be removed. Visual impacts are mitigated by the topography, distance, and vegetation. The SUA with Battlement Mesa Partners does not require additional landscaping at this pad site, due to its location next to the storage area and wastewater treatment plant. Production tanks and well head facilities will be low profile. Tanks, buildings, and equipment will be painted to blend in with the surrounding landscape. If a nuisance complaint is received on a location for noise, odor, dust, or other nuisances, Ursa's standard operating practice is to respond to each complaint as soon as possible. The person receiving the complaint, usually the Landman, gathers as much information (such as wind direction, time, duration, strength, nature of odor or noise, etc.) about the issue as possible. This information is relayed to the operations leads who begin to determine the source of the issue and what may be causing it. Once the root cause of the issue is identified, the team determines mitigation efforts that will help remedy the concern(s). The land team follows up with the stakeholders on the effectiveness of the mitigation efforts and adjustments are made as necessary. All complaints are logged and tracked to improve Ursa's overall best management practices (BMP) performance on existing and future assets. 5.03.08 INDUSTRIAL PERFORMANCE STANDARDS SECTION 5.03.08(1) SOUND VOLUMES Drilling and completion operations are subject to the maximum permissible noise levels for industrial zones. During the production phase of the well pad, Residential/Agricultural/Rural zone maximum noise levels will apply, per the SUA and COGCC Rules. Stationary engines and their exhausts will be located and oriented to direct noise away from the homes closest to the well pad. Ursa will evaluate noise generation from equipment and require contractors to refit mufflers, etc., in situations where the volume of sound produced exceeds noise levels for Residential/Agricultural/Rural zones. Engine braking will be prohibited by Ursa for its personnel and contractors. Per the SUA, there will be no time of day restrictions with regard to drilling, completing, re - completing, workover, or reservoir fracture stimulation operations. Routine ongoing maintenance and production operations activities will be limited to the hours of 7:00 am to 8:00 pm. Standards Analysis Page 3 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B SECTION 5.03.08(2) VIBRATION GENERATED During the production phase of the proposed well pad, ground vibration will not be measurable at any point outside the property boundary. SECTION 5.03.08(3) EMISSIONS OF SMOKE AND PARTICULATE MATTER During the production phase of the proposed well pad, adjacent lands will not be impacted by the generation of vapor, dust, or smoke beyond the normal impacts of activities occurring around the adjacent properties. Ursa will apply the appropriate level of controls to accommodate potential impacts via adherence to CDPHE Air Quality regulations and the implementation of industry BMPs included in the SWMP and Ursa's Fugitive Dust Control Plan. The proposed well pad and access road will be graveled to reduce fugitive dust, which will be controlled using water or other dust suppressants. SECTION 5.03.08(4) EMISSIONS OF HEAT, GLARE, RADIATION AND FUMES During the production phase of the proposed well pad, adjacent lands will not be impacted by the generation of heat, glare, or fumes beyond the normal impacts of activities occurring around the adjacent properties. Ursa will apply the appropriate level of controls to accommodate potential impacts via adherence to CDPHE Air Quality regulations and the implementation of industry BMPs included in the SWMP and Ursa's Fugitive Dust Control Plan. Naturally occurring radioactive materials are not expected to be an issue at the proposed well pad. Colorado oil and gas operations are not known to have a significant problem with naturally occurring radioactive materials (NORM) or technologically enhanced naturally occurring radioactive materials (TENORM); however, there have been some instances where pipe scale has contained radium and associated radon gas. A NORM survey including site specific testing could be performed to further assess the radon potential at the Site to serve as a baseline assessment if used pipe or pipe scale is to be disposed offsite in the future. SECTION 5.03.08(5) STORAGE AREA, SALVAGE YARD, SANITARY LANDFILL AND MINERAL WASTE DISPOSAL AREAS No storage areas, salvage yards, or sanitary landfills are associated with the proposed well pad. The standards regarding these uses do not apply to the proposed well pad use. Temporary mineral waste disposal areas will exist on the proposed well pad. All materials and liquids will be stored in accordance with accepted standards and laws and will comply with the National Fire Code. Any materials or wastes kept on the site will be deposited in such a manner that they will not be transferred off the property by any reasonably foreseeable natural causes or forces. No materials or wastes which might constitute a fire hazard or which may be edible by or otherwise be attractive to rodents or insects will be stored outdoors. Cuttings Sampling and Stabilization: Both surface and production hole drill cuttings will be generated at each well pad. Raw cuttings (not stabilized) will be sampled and profiled at the location of generation in accordance with Ursa's Waste Management Plan. Once the raw cuttings are sampled, they will be stabilized (absorption/removing liquids) in a temporary area on the well pad. The cuttings will be stabilized using either native soils (preferable) or a commercially Standards Analysis Page 4 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B available inert adsorbent (sawdust, EZ Stabil, etc.). In some cases, relocation of cuttings to another location during drilling would be required due to the small pad size permitted by the previous operator. If the volume of cuttings on the well pad during drilling exceeds the capacity of the on-site temporary area, limits operational capabilities to complete drilling, or creates safety concerns, a COGCC Sundry Notice (Form 4) will be submitted for approval to relocate the cuttings to another location pending the results of sampling analytical results. Cuttings Management and Disposal: If sampling results for either surface or production hole cuttings meet COGCC Table 910-1 standards, they will be treated as non -waste (essentially soil material) and will be managed under one or more of the following options: 1) remain on site for pad stabilization/reclamation; 2) be relocated to another location for pad stabilization/reclamation; 3) made available as fill material to the general public; 4) be relocated to a COGCC approved cuttings management facility; or 5) disposed of at an approved waste facility. Options 2 — 4 would be in accordance with a COGCC approved Sundry Notice (Form 4). Disposal at an approved waste facility would be managed for Item 5 under an approved waste manifest in accordance with CDPHE regulations. If cuttings don't meet standards, then Ursa will implement one of two options: continued mixing to meet Table 910-1 standards for beneficial reuse/relocation or transport to an authorized waste facility in accordance with Federal and State (COGCC/CDPHE) regulations, including manifesting. Final decisions will be based on site-specific operations logistics. SECTION 5.03.08(6) WATER POLLUTION The proposed well pad does not fall within the Town of Parachute's Watershed Protection Area, but does fall within a COGCC 317B Buffer area. Ursa will comply with all applicable CDPHE Water Quality Control Standards. A copy of Ursa's Battlement Mesa Field Stormwater Management Plan and Permit is included with this application. Ursa will implement a range of BMPs to assure the protection of water quality during construction, interim reclamation, operation, and final reclamation of the proposed well pad. 9-03.01 APPLICATION SECTION 9.03.01(1) SUPPORTING INFORMATION All supporting information and plans are included in this application package. The approved Stormwater Permit is included in Section 4-203.E.16. CDPHE is currently developing a new permit and associated certification for the above permitted facility. The development and review procedures required by law have not yet been completed. The Construction Stormwater General Permit, which "expired" June 30, 2012, was administratively continued and will remain in effect under Section 104(7) of the Administrative Procedures Act, C.R.S. 1973, 24-4-101, et seq (1982 repl. vol. 10) until a new permit/certification is issued and effective. The renewal for this facility was based on the application that was received 5/14/2013. Ursa will obtain utility permits and oversize/overweight load permits as required from Garfield County Road and Bridge, prior to construction. Ursa will file the applicable COGCC forms and permits including, but not limited to Form 2 and Form 2A. Standards Analysis Page 5 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B SECTION 9.03.01(2) VICINITY MAP A Vicinity Map is included in Section 4-203.C. Site Plans for the proposed well pad are included in Section 4-203.D. An Adjacent Property Owners Map can be found in Section 4-203.6.3. SECTION 9.03.01(3) LETTER TO COUNTY COMMISSIONERS This application package, in its entirety, serves as the letter to the County Commissioners explaining in detail the nature and character of the Special Use requested. LAND USE AND DEVELOPMENT CODE 2013 DIVISION 1. GENERAL APPROVAL STANDARDS SECTION 7-101. ZONE DISTRICT USE REGULATIONS Ursa Operating Company (Ursa) and Battlement Mesa Partners (BMP) proposes to pursue natural gas drilling activities in the Battlement Mesa Planned Unit Development zone. Table 3- 403: Use Table indicates that Oil and Gas Drilling and Production is a permitted use in all zones in Garfield County. Garfield County Resolution 82-121 lists extraction of natural resources as a special use within the Battlement Mesa PUD. This resolution indicates that: Where preceding general standards or the following supplemental regulations do not adequately describe what is permitted or required, reference shall be made to the officially adopted Garfield County Zoning Resolution of January 2, 1979, including the zoning amendment, opted October 15, 1979, (79-132) and to the officially adopted Garfield County Subdivision Regulations of January 2, 1979, and amendments of October 15, 1979. As a result, the County requires a Special Use Permit in order to extract natural resources within the PUD demonstrating that the proposed extraction activities comply with the standards and criteria of the county's 1979 zoning code. SECTION 7-102. COMPREHENSIVE PLAN AND INTERGOVERNMENTAL AGREEMENTS The BMC B well pad development generally conforms to the Garfield County Comprehensive Plan. The Battlement Mesa community was originally planned and constructed to accommodate oil and natural gas development in the Piceance Basin. The Future Land Use Map from the Comprehensive Plan illustrates the subject property as Planned Unit Development (PUD). The site is located in the Public, Semi -Public, Recreation (PSR) subzone within the PUD. The existing use is not within an area governed by an intergovernmental agreement. The following sections of the Garfield County Comprehensive Plan apply to the BMC B well pad development and further substantiate that natural gas well pads located in appropriate areas of Garfield County are in compliance with the Comprehensive Plan: For approximately 12 months prior to submitting the Land Use Permit Application, Ursa has invested significant time and effort towards stakeholder and community involvement. Ursa has held numerous local meetings in order to assure that the Battlement Mesa property owners as well as the Battlement Mesa community at large are fully apprised of Ursa's proposed project activities, compliance with regulatory framework, compatibility with all PUD zone districts, and mitigation of impacts. Overall Vision — Future Land Use Standards Analysis Page 6 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B Garfield County is dedicated to managing and directing growth to dedicated Urban Growth Areas and other areas that can accommodate growth cost effectively, in order to create thriving communities while promoting a diverse, sustainable and healthy economy, protecting wildlife, maintaining or improving the quality of our natural environment, and preserving the county's rural and western heritage. The URSA application submittal goes into great detail in various reports and narratives as to how the proposed drilling operations will operate in conformance with multiple regulatory agencies. Ursa's adherence to regulatory policies and rules will result in limited, short-term impacts to the surrounding properties while infusing economic benefits, promoting a thriving community and minimizing impacts to wildlife. Land Use Table LAND USE DESIGNATION Industrial (I) DESCRUPT!ON Indoor manufacturing, outdoor equipment storage, business parks, energy processing and uses that produce odor, noise, Tight, and/or emissions_ COMPATIBLE ZONING industrial (1) Planned Unit Development (PUD) Density of residential uses: None Example: Ursa's application submittal conforms to the portion of the Land Use Table from the Garfield County Comprehensive Plan shown above. Section 4 - Economics, Employment and Tourism Policies: Garfield County will encourage the development of a diversified industrial base recognizing physical location -to -market capabilities of the community, and the social and environmental impacts of industrial uses. Ursa's application submittal conforms to this policy. The development of natural gas resources in Garfield County contributes to a diversified industrial base. The physical location of the proposed drilling locations will take advantage of a broad system of pipelines in the Piceance region which route natural gas to sales points thus capitalizing on location -to -market capabilities. By adhering to the Garfield County and Colorado State regulatory criteria for the development and production of natural gas, Ursa will mitigate social and environmental impacts to the highest practical level. Strategies and Actions: Standards Analysis Page 7 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B Ensure that commercial/industrial developments are compatible with adjacent land uses and preserve the visual quality of the county. Ursa's application submittal conforms to this strategy. By adhering to the Garfield County and Colorado State regulatory criteria, Ursa will ensure the post -development locations are compatible with adjacent land uses and will preserve the visual quality of the county. Compliance activities that accommodate these strategies and actions include: Compliance with COGCC rules regarding interim and final reclamation Use of Best Management Practices (BMPs) in all areas of operations Compliance with Ursa's agreement with the landowner requiring visual mitigation of the well sites to preserve the visual quality of the Battlement Mesa area Section 8 - Natural Resources Goals: Ursa's application submittal conforms to the following goals: 1. Ensure that natural, scenic, ecological, and critical wildlife habitat resources are protected and/or impacts mitigated. By adhering to the Garfield County and Colorado State regulatory criteria, Ursa will ensure that natural, scenic, ecological, and critical wildlife habitat resources are protected and/or impacts mitigated. Specific compliance activities accommodating this goal include: Consultation with the Colorado Division of Parks and Wildlife. Development and implementation of a Wildlife Mitigation Plan. Preparation of a Garfield County Wildlife and Vegetative Analysis for each development location. Implementation of Ursa's comprehensive inspection and corrective action plan(s). 2. Preserve natural drainage patterns so the cumulative impact of public and private land use activities will not cause storm drainage and floodwater patterns to exceed the capacity of natural or constructed drainage ways, or to subject other areas to an increased potential for damage due to flooding, erosion or sedimentation or result in pollution to streams, rivers or other natural bodies of water. By adhering to the Garfield County and Colorado State regulatory criteria, Ursa will ensure the preservation of natural drainage patterns and mitigate potential stormwater impacts from construction activities. Specific compliance activities accommodating this goal include: Preparation of Stormwater Management Practices and securing Stormwater Management Permits as required Colorado Department of Public Health and Environment (CDPHE) criteria. Preparation of a Garfield County Grading and Drainage Plan for each development location. Standards Analysis Page 8 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B 3. Protect existing access to natural resources. Ursa's proposed development will have no significant impact to existing access to natural resources. Please also see the response to Section 8 — Natural Resources Goals, Item #1 above. 4. Ensure the appropriate reclamation of land after extraction processes. By adhering to the Garfield County and Colorado State regulatory criteria, Ursa will ensure the appropriate reclamation of land after extraction processes will be performed. Specific compliance activities accommodating this goal include: Preparation of Stormwater Management Practices and securing Stormwater Management Permits per the CDPHE criteria. Preparation of Reclamation Plans and securing bonding per the COGCC criteria. Policies: 1. The county will encourage and cooperate with the protection of critical habitat including state and federally protected, threatened, or endangered species. Ursa's proposed development will accommodate this policy. Please see the response to Section 8 — Natural Resources Goals, Item #1 above. 2. Garfield County will encourage the protection of watersheds, flood plains, and riparian areas. By adhering to the Garfield County, Colorado State, and Federal regulatory criteria, Ursa will ensure the appropriate level of protection for watersheds, flood plains, and riparian areas. Specific compliance activities accommodating this goal include: Compliance with COGCC Rule 317b Public Water System Protection criteria. Compliance with local Watershed Protection rules and policies. Preparation of Stormwater Management Practices and securing Stormwater Management Permits per the CDPHE criteria. Review and document potential impacts per the criteria identified by the US Army Corps of Engineers (USACOE). Preparation of a Garfield County Floodplain Analysis as well as Grading and Drainage Plans for each development location. Preparation of a Wildlife and Vegetative Analysis that includes an assessment of riparian areas for each development location. Section 9 - Mineral Extraction Vision - Mineral Extraction Resource extraction, including oil and gas development, has been encouraged to operate in the county due to the contribution the industry makes to the county's overall goal of having a diverse and stable economy. While resource extractive industries are welcomed in the county, they are expected to mitigate negative impacts that result from their operations. Standards Analysis Page 9 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B The Ursa application submittal demonstrates Ursa's commitment to minimizing and mitigating the negative impacts of their natural gas development within Garfield County and Battlement Mesa. Ursa conducted numerous meetings with local stakeholders to discuss logistics, methods, and typical impacts associated with their natural gas development operations. Ursa has made every effort to reduce and minimize the total number of drill pads in proximity to the Battlement Mesa community. Issue Garfield County has significant mineral resources that have, and will continue to have, a considerable benefit to the economic health of the county. Despite the current downturn in natural gas development, Ursa is committed to developing their natural gas leaseholds which provides an economic benefit of Garfield County. Goal 1. Ensure that mineral extraction is regulated appropriately to promote responsible development and provide benefit to the general public. Ensure that mineral extraction activities mitigate their effects on the natural environment, including air quality, water quality, wildlife habitat or important visual resources. As noted above, by adhering to the Garfield County, Colorado State and Federal regulatory criteria, Ursa will mitigate their effects on the natural environment, including air quality, water quality, wildlife habitat or important visual resources. Ursa has created and implemented a cross-reference matrix to address the broad range of regulatory criteria which apply to the proposed project. In working with mineral extraction projects, the county will protect the public health, safety and welfare of its citizens. Ursa is aware that the Garfield County BOCC has deemed it appropriate to address concerns raised in the Health Impacts Assessment (HIA) as part of the land use approval process for natural gas development in the PUD. During the first scheduled Planning Commission meeting, Ursa will provide a document correlating the relevant components of the HIA against Ursa's regulatory compliance activities Policy 1. Garfield County recognizes that surface and mineral owners have certain legal rights and privileges, including the right to extract and develop these interests. Private property owners also have certain legal rights and privileges, including the right to have the mineral estate developed in a reasonable manner and to have adverse impacts mitigated. The property rights of mineral lessees must be balanced with the rights of private property owners and the general public. Ursa has negotiated in good faith with the property owners of the PUD, local land owners, Battlement Mesa community organizations, and other stakeholders to locate the natural gas well pads in areas that will minimize and mitigate impacts to the surface owner and adjacent land owners while accommodating Ursa's right to develop the resource(s). The Standards Analysis Page 10 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B Surface Use Agreement with the surface owner outlines various details to mitigate surface impacts. 2. Mineral resource extraction activities will protect critical wildlife habitat as identified by state and federal agencies. Development within these designations that cannot be designed, constructed and conducted so as to have a minimum adverse impact upon such habitat or these wildlife species, shall be discouraged. Ursa's proposed development will protect critical wildlife habitat in the PUD so as to have a minimum of adverse impacts upon such habitat or these wildlife species. All proposed project areas were evaluated for threatened and endangered species; none were found. Please also see the response to Section 8 — Natural Resources Goals, Item #1 above. 3. Natural drainage patterns will be preserved or mitigated so the cumulative impact of mineral extraction activities will not cause storm drainage/floodwater patterns to exceed the capacity of natural or constructed drainage ways, or to subject other areas to increased flooding, erosion or sedimentation or result in pollution to streams, rivers or other natural bodies of water. Ursa's proposed development will preserve or mitigate natural drainage patterns and minimize the cumulative impacts to drainages, waterbodies and watersheds. Please also see the response to Section 8 — Natural Resources Goals, Item #2 above. 4. Facilities that are appurtenances to oil/gas development activities (compressors, etc.) are considered appropriate in all land uses so long as they meet the respective mitigation requirements of the ULUR to maintain compatibility with surrounding land uses. The only appurtenance anticipated for the proposed development is pipeline infrastructure that will allow for the transport of natural gas and produced water. All pipelines will be permitted according to the mitigation requirements of the ULUR and Land Use and Development Code (LUDC) and will adhere to the appropriate Garfield County, Colorado State and Federal regulatory criteria. Any emergent appurtenant facilities will be permitted according to the criteria detailed above. This submittal goes into great detail in the various reports and narratives as to how the development of the natural gas resources will be conducted in an environmentally responsible fashion. The importance of the oil and gas industry to the economic health of the Garfield County economy is noted in the aforementioned Vision, Issue, Goal and Policy statements taken from the Comprehensive Plan. The proposed drilling and production locations are needed by Ursa to assure that natural gas can be moved from source to market and, ultimately, the consumer. The economic benefits provided by Ursa and other oil and gas operators are clear from the many investments made in communities and other community benefits derived from the industry. SECTION 7-103. COMPATIBILITY The BMC B pad is located in the Battlement Mesa PUD zone district Public, Semi -Public, and Recreational (PSR). Garfield County is a "Right to Mine" County guaranteeing mineral rights owners the right to extract minerals in all zone districts of the county. Visual and sound impacts will be mitigated according to the existing Surface Use Agreement (SUA) with Battlement Mesa Partners. Standards Analysis Page 11 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B SECTION 7-104. SOURCE OF WATER Ursa has entered into a Water Service Agreement (WSA) with BMMD to obtain non -potable water for use in drilling and dust control. A copy of the contract is included in the Water Supply section. A letter confirming legal and adequate water supply is provided, also. During drilling and completion operations, potable water will be provided at this facility by Stallion Oilfield Services via their existing water contract(s). A copy of the will serve letter is included as part of this application in the Water Supply Section. Letters from the Town of Silt confirming legal and adequate water supply are provided. These water requirements are temporary in nature. After the well pad enters the production phase, sources of non -potable water and potable water for employees will not be required. The facility will not be manned on a regular basis and will not require fresh water distribution and a wastewater system to properly function. Workers will provide their own potable water in their trucks. Ursa will provide bottled or potable water to personnel at their field office. A source of water will not be required for the production operations of the facility. Water will not be required for the operation of sanitary facilities. Portable toilets will be used, and all wastes will be hauled to a licensed treatment facility. Copies of "Will Serve" letters from Redi Services and Western Colorado Waste are included in the Wastewater Management Section of this submittal. Per details included in the SUA between Ursa and the landowner, no landscaping is proposed for this project location. Thus, there are no requirements for water for irrigation purposes. B. Determination of Adequate Water Ursa has entered into a Water Service Agreement (WSA) with BMMD to obtain non - potable water for use in drilling and dust control. A copy of the contract is included in this section. Supply may be suspended at any time due to inadequate water capacity or water pressures in the system or emergency and fire. A letter confirming legal and adequate water supply is provided, also. During drilling and completion operations, potable water will be provided at this facility by Stallion Oilfield Services via their existing water contract(s). A copy of the will serve letter is included as part of this application in the Water Supply Section. Letters from the Town of Silt confirming legal and adequate water supply are provided. SECTION 7-105. CENTRAL WATER DISTRIBUTION AND WASTEWATER SYSTEMS A. Water Distribution System During drilling and completion operations, potable water will be provided at this facility by Stallion Oilfield Services via their existing water contract(s). Fresh non -potable water for drilling and dust control will be supplied by the BMMC via the ODWSA. A source of water for the operation of sanitary facilities is not required. Portable toilets will be used and all wastes will be hauled to a licensed treatment facility. During the production phase, the facility will be unmanned with personnel onsite only for short intervals. Potable water will not be required for daily operations. Personnel will provide their own potable water carried in their vehicles. Ursa makes potable water Standards Analysis Page 12 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B available at their field office to staff and contractors. Sanitary facilities will not require a source of water and will be provided by portable toilets. Water for landscaping will not be required for this proposed well pad pursuant to the SUA. B. Wastewater System During the Drilling Phase, sanitary facilities will be provided via a vault and haul system by Stallion Oilfield Services. A will serve letter is included in the Wastewater Management Section. After drilling is completed and the rig is removed staff will not be assigned to the facility on a regular basis. Personnel will be at the facility only for short periods of time. Workers will be performing routine facility maintenance and inspections. Sanitary facilities will be provided by portable toilets placed on site. These portable toilets will be maintained by Redi Services and Western Colorado Waste. All waste is hauled to a licensed treatment facility. Will Serve letters are included in the Wastewater Management section, documenting the maintenance of these sanitary facilities. SECTION 7-106. PUBLIC UTILITIES A. Adequate Public Utilities Adequate Public Utilities are available to serve the land use. Ursa is working with Holy Cross Energy to provide electrical service to the pad. Other public utilities are not required. A copy of Holy Cross's will serve letter is included at the end of this section. B. Approval of Utility Easement by Utility Company Ursa has not finalized their agreement with Holy Cross Energy to provide electrical service to the pad. All appropriate easements will be secured as part of this process. C. Utility Location Utility easements will be located per the LUDC and Surface Use Agreement in consultation with Holy Cross Energy. D. Dedication of Easements Ursa has not finalized their agreement with Holy Cross Energy to provide electrical service to the pad. All appropriate easements will be dedicated to the public as part of this process. E. Construction and Installation of Utilities Ursa has contracted with Holy Cross Energy to provide electrical power to the site. A copy of the will serve letter is provided at the end of this section. Utilities will be installed in a manner that avoids unnecessary removal of trees or excessive excavations and will be reasonable free of physical obstructions. Standards Analysis Page 13 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B F. Conflicting Encumbrances Ursa has not finalized their agreement with Holy Cross Energy to provide electrical service to the pad. All appropriate easements will be free from encumbrances. SECTION 7-107. ACCESS AND ROADWAYS The road is anticipated to function adequately as proposed and is typical of existing roads providing access to natural gas production in Garfield County. A. Access to Public Right of Way Legal access to the site is gained from CR 307, River Bluff Road, through a surface use agreement with Battlement Mesa. B. Safe Access Access to the site is consistent with other similar uses. See Access Road Assessment report included in this submittal. The entire roadway is visible to traffic flows on the access road. The access road will be constructed of 8 inches of class 6 aggregate base course over 18 inches of scarified and recompacted native soil subgrade. The road will adequately support the 20-30 year projected ESALs from production traffic. Maintenance for the access road to the pad is to be performed by Ursa contractors sufficiently tooled to adequately maintain not only access roadways, but the pad facilities as well. Anticipated maintenance is snow plowing, borrow ditch grading, stormwater BMP maintenance, weed/vegetation control, resurfacing and recompaction. Through production, Ursa production personnel will monitor maintenance needs and direct the Ursa contractors to perform such on an as needed basis. C. Adequate Capacity Traffic congestion is not anticipated as a result of the proposed BMC B gas development activities. The access road is being constructed at a standard that generally exceeds the County's standard with the exception of the cross slope. D. Road Dedication The access road is a private road. No rights-of-way will be dedicated to the public. E. Impacts Mitigated Based on the expected trip generation rates, the increase in average daily traffic is not expected to increase on County Roads such that a modification of the existing access permit would be required. Total traffic volumes will remain low and are anticipated to be accommodated by the existing County and private roadways. Additionally, the majority of existing traffic on this road is associated with the natural gas industry and the maintenance personnel for the Battlement Mesa Water and Wastewater District facilities. Standards Analysis Page 14 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B F. Design Standards The Ursa BMC B Access Road is proposed to be constructed to a standard that exceeds those of Garfield County's Semi Primitive Driveway standard. SECTION 7-108. USE OF LAND SUBJECT TO NATURAL HAZARDS The Geologic Hazard Report indicates that no natural hazards have been identified in the area of the proposed BMC B well pad. A copy of this report is included in this submittal. The Arvada loam soils are shown to be corrosive to both steel and concrete. The subsoil has a high shrink -swell potential. These potential hazards will be mitigated by appropriate engineering and design of the facilities on the site. SECTION 7-109. FIRE PROTECTION A. Adequate Fire Protection The proposed well pad is located within the Grand Valley Fire Protection District. The District is aware of the well pad location and can provide adequate fire protection and response. Ursa has participated in emergency training programs such as the Parachute/Battlement Mesa Hazard Disaster Planning exercises with Grand Valley Fire Protection District. They will continue to support these programs. B. Subdivisions The proposed well pad is located within the Battlement Mesa PUD, but outside a platted subdivision. Ursa is willing to consult with Grand Valley Fire Protection District regarding access, fire lanes, water sources, fire hydrants and maintenance provisions. DIVISION 2. GENERAL RESOURCE PROTECTION STANDARDS SECTION 7-201. AGRICULTURAL LANDS A. No Adverse Affect to Agricultural Operations The proposed well pad is not located in an area being used for agricultural operations, therefore, there will be no adverse effect or impacts to agricultural operations and production. B. Domestic Animal Controls The operation of the proposed facility will comply with this standard. No domestic animals are allowed on the site. All features on the proposed facility that could present an entrapment hazard to animals will be screened or otherwise mitigated for safety. C. Fences The proposed well pad will not generate a potential hazard to domestic livestock or wildlife. No open storage of hazardous materials or attraction will be conducted on the site. The site may be enclosed with a visual and sound buffer during drilling and completions Standards Analysis Page 15 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B operations. After drilling is completed on the site and all wells are in production, the visual and sound buffer will be removed. The well pad will not be fenced after it is placed into production. Well cellars and any other site features that present a potential entrapment hazard will be screened or otherwise secured. D. Roads The access road will be located so that normal maintenance of the road, including snow removal, will not damage fencing on adjacent parcels. Dust control will be utilized, both during and after construction, to minimize adverse impacts to livestock and crops. Dust control may consist of water, surfacing materials, or non -saline dust suppressants as appropriate for road conditions. A copy of Ursa's Fugitive Dust Control Plan in included in the Air Quality section of this submittal. E. Irrigation Ditches No irrigation ditches are adjacent to the proposed well pad site. Implementation of the engineered grading and drainage plan and conformance with stormwater best management practices will assure that any irrigation ditches near the subject parcel will not be impacted by the facility. SECTION 7-202. WILDLIFE HABITAT AREAS A. Buffers Topographic, vegetative, and other visual and sound buffers will be used to screen the activity of the proposed well pad from habitat and residential areas. A. Locational Controls of Land Disturbance No migration corridors will be affected by the proposed well pad. Human presence and activity may affect animal distribution by creating avoidance areas and increasing stress on wintering big game. Over time, deer and elk that winter in this area have become habituated to the considerable human activity and the indirect effects of avoidance and displacement have decreased. Interim reclamation will be focused on erosion and sediment control and native vegetation. Foraging activities for raptors are unlikely to be disrupted and any effect would be very small given the abundance of foraging habitat available. The nests detected in the survey area are screened from the proposed project area by vegetation and topography, mitigating any potential impact. Ursa's policies do not allow the feeding of wildlife. Trash will be kept in bear proof trash containers and removed on a regular schedule during drilling operations. After the proposed well pad has been placed into production, any trash generated during routine maintenance and inspection visits will be removed by personnel as they leave the site. Low speed limits already in place on area roads will be enforced. Equipment is outfitted with bird cones to prevent perching. Standards Analysis Page 16 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B B. Preservation of Native Vegetation 1. Per the SUA, no landscaping is required for the proposed well pad. Reclamation activities will focus on native vegetation and erosion and sediment control. 2. Application of the Integrated Vegetation and Noxious Weed Management Plan (IVNWMP) and Ursa's Noxious Weed Management Plan will provide a degree of mitigation for the native vegetation that has already been removed. Ursa will comply with COGCC Rules regarding revegetation and control of noxious weeds. 3. Vehicles and equipment traveling from weed -infested areas into weed -free areas could disperse noxious or invasive weed seeds and propagates, resulting in the establishment of these weeds in previously weed -free areas. Several simple practices will be employed to prevent most weed infestation. The following practices will be adopted for any activity to reduce the costs of noxious weed control through prevention. The practices include: Prior to delivery to the site, equipment should be thoroughly cleaned of soils remaining from previous construction sites which may be contaminated with noxious weeds. If working in sites with weed -seed contaminated soil, equipment should be cleaned of potentially seed -bearing soils and vegetative debris at the infested area prior to moving to uncontaminated terrain. All maintenance vehicles should be regularly cleaned of silt. Avoid driving vehicles through areas where weed infestations exist. C. Habitat Compensation Fencing is not proposed for the project after drilling and completion activities are finished on the site. Weed management best practices will be implemented to further reduce potential loss of habitat. The development of the proposed well pad is not expected to significantly affect any critical environmental resources or habitat to an extent where habitat compensation would be required. D. Domestic Animal Controls Livestock and big game will likely avoid the proposed well pad. Dogs and other domestic animals are not allowed on site. SECTION 7-203. PROTECTION OF WATERBODIES A. Minimum Setback 1. The northern edge of the well pad disturbance is more than 35 feet from the Ordinary High Water Mark (OHWM) of the Colorado River. The eastern edge is more than 25- 50 feet from the adjacent wetland. Standards Analysis Page 17 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B 2. There are no entrenched or incised streams on or adjacent to the proposed project area. 3. No hazardous material will be stored on the project site. See the SPCC Plan included in this submittal for measures to protect surface and ground water from spills. B. Structures Permitted in Setback No structures will be located within the 35 foot setback. C. Structures and Activity Prohibited in Setback No structures will be located within the 35 foot setback. No work of any kind will occur within the 35 foot setback. D. Compliance with State and Federal Laws The proposed well pad will be designed through the use of erosion and sediment controls and adherence to Ursa's stormwater management plan and SPCC plan to not impact any Waterbody of the US. SECTION 7-204. DRAINAGE AND EROSION A. Erosion and Sedimentation The proposed well pad is covered under Ursa's CDPHE Battlement Mesa Field Wide Storm Water Management Plan (SWMP). The Certification Number is COR03K566 and was Administratively Continued at the time of issuance. The SWMP and permit are included in the Stormwater section of this submittal. BMPs such as straw wattles, inlet and outlet protection, vehicle tracking pads, and vegetative buffers will be utilized to ensure the continued protection of water bodies from stormwater runoff during construction and operation of the facility. COGCC and CDPHE regulations require that well pads and roads are monitored for erosion and sediment control through the production phase and final abandonment and reclamation of pad. Site specific plans (i.e. diagrams) will be developed and inspected against at the frequency required by CDPHE regulations, to include 14 day, 30 day, and major storm event inspections until 70% reclamation is achieved. Corrective actions and maintenance will be tracked and implemented. The post -construction stormwater program will be managed in accordance with COGCC. Inspections and corrective actions will be conducted through 80% interim reclamation and annually thereafter. These inspections are also tracked and corrective actions implemented. Native soils will be used whenever available to construct stormwater BMPs, supplemented by non-native materials based on site-specific conditions. The estimated cost of installation and maintenance of the erosion and sediment control measures is typically between $5,000 and $15,000. Standards Analysis Page 18 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B B. Drainage 1. This standard requires that lots be laid out to provide positive drainage. Lots are not proposed as part of this land use application. The proposed well pad will be graded so that existing drainages will not be impacted. 2. Via the implementation of the Grading and Drainage Plans included in this submittal, the proposed facility will not impact residential development or natural drainage patterns. C. Stormwater Run -Off The site has been designed to COGCC standards for stormwater management to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation. BMPs will be maintained until the facility is abandoned and final reclamation is achieved pursuant to COGCC Rules. The proposed well pad may be within 100 feet of a wetland, but it will not create 10,000 square feet or more of impervious surface area. 1. Avoid Direct Discharge to Streams or Other Waterbodies. Stormwater Runoff from project areas will be controlled by use of BMPs such as straw wattles, inlet and outlet protection, vehicle tracking pads, and vegetative buffers. 2. Minimize Directly -Connected Impervious Areas. The site design will not create more than 10,000 square feet of impervious surface area. 3. Detain and Treat Runoff. Ursa has incorporated stormwater detention facilities into the design for this site. Stormwater runoff will be controlled via a combination of sediment basins, top soil berms, and wattles. a. The maximum calculated detention necessary to capture the stormwater runoff volume generated from a 25 year, 24 hour storm is approximately 2,822 cubic feet. A detention pod with this capacity and drainage features to convey water to the pond will be provided on site. See the Grading and Drainage drawings and report included in the Grading and Drainage section. b. The project site is above the 100- and 500 -year floodplain of the Colorado River, therefore a 100 -year storm event should not cause property damage. c. Channels downstream from the stormwater detention pond discharge have been designed to prevent increased channel scour, bank instability, and erosion and sedimentation from the 25 -year, 24-hour storm event. d. The main goal of the site design is to provide detention and sedimentation control for the project. The only area where a significant increase in runoff coefficients occur is the gravel pad and road. A detention pond will be sized appropriately and provide a location for sedimentation of the stormwater runoff generated from the developed site. The remaining site will remain in native vegetation and provide historic flow patterns and characteristics. Standards Analysis Page 19 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B Temporary erosion control measures will be required for the duration of construction. A CDPHE Stormwater Permit for Construction activities will likely be required. Best Management Practices will be utilized during construction to control the stormwater runoff. Key temporary erosion control measures include installation and maintenance of silt fence, straw waddles, inlet protection, a stabilized construction entrance and all necessary acceptable best management practices that would relate to this project. e. All culverts and drainage pipes utilized at this facility are designed and constructed according to the AASHTO recommendations for a water live load. SECTION 7-205. ENVIRONMENTAL QUALITY A. Air Quality For Exploration and Production (E&P) facilities, the CDPHE requires that an air permit be submitted no later than 90 days following the date of first production. This allows operators the ability to more accurately calculate actual emissions from new facilities. CDPHE has three different options for general permits which may be used to permit the facility: GP01, GP05, and GP08. The General Permit serves as a replacement for the traditional construction permit for E&P facilities. At this time, Ursa is evaluating which permits will be the most appropriate for operations at the facility. However, in accordance with this requirement, Ursa will prepare and submit permit applications to CDPHE within the allotted time frame. Ursa ensure compliance with air quality regulations. Ursa is participating in the CSU Air Quality Study in Garfield County. B. Water Quality No hazardous materials will be stored on site. An SPCC plan will be in effect for the tank batteries associated with the well pad production operations. A copy of the plan is included in the SPCC section of this submittal. SECTION 7-206. WILDFIRE HAZARDS A. Location Restrictions The proposed well pad is located in an area designated as having low wildfire hazard according to the Garfield County on-line GIS map resources. It is not located within a fire chimney as identified by the Colorado State Forest Service. B. Development Does Not Increase Potential Hazard The proposed well pad will not increase the potential intensity or duration of a wildfire, or adversely affect wildfire behavior or fuel composition. C. Roof Materials and Design Roof materials for any proposed structures will be made of noncombustible materials. Any proposed construction will comply with requirements of the 2009 International Fire Code. Standards Analysis Page 20 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B SECTION 7-207. NATURAL AND GEOLOGIC HAZARDS A. Utilities The determination to locate utility facilities above ground will be based upon the recommendation and requirements of the utility service provider and approved by the County. Except for potential flooding, above -ground utilities, such as transformers, are not expected to be affected by geologic or other natural hazards. Trenches for water pipelines, natural gas pipelines, and electrical lines are expected to be associated with the proposed development. The slopes and corrosive soil may pose technical challenges to the installation of these utilities; however, it is expected that these limitations can be overcome with proper design and installation. B. Development in Avalanche Hazard Areas Avalanches are not expected to affect the proposed natural well site, since it is located at an elevation of approximately 5,160 feet amsl. C. Development in Landslide Hazards Areas According to the Geologic Hazard Report, no landslide hazards are located to the south of Interstate 70 in the Parachute — Battlement Mesa area. D. Development in Rockfall Hazard Areas The site is not located within an area that has been mapped as having rockfall or the potential for rockfall. D. Development in Alluvial Fan Hazard Area The site is located in an area that is not mapped as being in an alluvial fan hazard area. The site is located on alluvium, floodplain, alluvial terrace, and fan gravel deposits and is underlain by older mudflow and fan gravels. The site is on the northeastern part of an alluvial fan created by Monument Gulch and other unnamed intermittent drainages. These deposits lie about 100 feet above the Colorado River flood plain. Any potential hazards will be mitigated by appropriate engineering and design of the facilities on the site. F. Slope Development The area south of the Colorado River and in the vicinity of the site is not shown as being identified in a slope hazard area. The Arvada Loam soils are found on 6% to 20% slopes. Engineering, design, and construction practices of the proposed development are expected to mitigate the limitation of slopes at the site since the site is located within an area developed for other land uses, including development of natural gas well pads. The site may require mitigation for slope, and will be graded and constructed for this purpose. The site is in an area near the Colorado River with slopes that are not as steep as surrounding areas. Standards Analysis Page 21 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B G. Development on Corrosive or Expansive Soils and Rock The Arvada loam soils are corrosive to both steel and concrete, and the subsoil has a high shrink -swell potential. Corrosive and expansive soils are potentially present in the vicinity of the proposed BMC B Pad site which is a limitation for some site development. Any potential hazards will be mitigated by appropriate engineering and design of the facilities on the site. H. Development in Mudflow Areas The site is located in an area of mud flow and fan gravel deposits overlain by alluvium and flood plain deposits, and alluvial terrace deposits. The site is located on a terrace near the Colorado River drainage. These deposits are Holocene in age and future mud slides are a potential hazard if the area were to receive heavy rains. These flows are expected to originate from higher elevations to the south and would follow the drainages to lower elevations closer to the Colorado River floodplain. Any potential hazards will be mitigated by appropriate engineering and design of the facilities on the site. I. Development Over Faults There are no major faults shown in the Grand Valley area. There are no mapped faults shown in the immediate vicinity of the site. SECTION 7-208. RECLAMATION A. Applicability The proposed well pad will be a COGCC approved location. Ursa will abide by all reclamation requirements set out by the SUA. All of Ursa's surface disturbances are covered under a statewide bond held by the COGCC. 1. Installation of ISDS. No ISDS will be installed. 2. Driveway Construction. All areas within the Construction Easement of the access road will be reclaimed according to Ursa's Reclamation Plan once road construction is completed. Reclamation will be in association with the implementation of the appropriate stormwater BMPs. 3. Preparation Area. All areas disturbed during development that do not comprise the longer-term functional areas of the site but are those areas used for the short-term preparation of the site will be reclaimed on an interim basis per COGCC Rules. B. Reclamation of Disturbed Areas A copy of Ursa's Reclamation Plan is included in the Reclamation Section of this submittal. Areas disturbed during development will be restored or landscaped per the Surface Use Agreement (SUA) with Battlement Mesa Partners. 1. Contouring and Revegetation. Areas disturbed by grading will be contoured so they can be revegetated as appropriate for interim and final reclamation per the SUA. At the end of the productive life of the well pad, all equipment will be removed, and the Standards Analysis Page 22 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B surface will be contoured and seeded with an appropriate seed mix. Inspection and necessary maintenance will continue until desirable vegetation is established and with 70% surface coverage as compared with the original on-site vegetation. Typically, 70% coverage is achieved within two growing seasons of reclamation, using weed - free species and plant cover typical to that site as noted in the Reclamation Plan and agreed upon with the Owner of the property. 2. Application of Top Soil. Top soil will be utilized in berms and/or used in landscaping around the well pad. 3. Retaining Walls. No retaining walls are planned for this project. 4. Slash Around Homes. No residences will be part of the proposed project. 5. Removal of Debris. Within 6 months of substantial completion of soil disturbance, all brush, stumps, and other debris shall be removed from the site. 6. Time Line Plan. Per the SUA, Ursa will commence with landscaping work as soon as initial dirt work at the site commences and complete landscaping prior to the commencement of drilling activity at the well site Location, taking into consideration the growing season. The site will enter final reclamation in 20 to 30 years, at the end of the life for the natural gas wells on the well pad, and within 12 months after plugging the wells on the site per the SUA and COGCC Rules. DIVISION 3. SITE PLANNING AND DEVELOPMENT STANDARDS SECTION 7-301. COMPATIBLE DESIGN Operation of the proposed well pad will be consistent with nearby uses and the Planned Development Unit as set up in Garfield County Resolution 82-121 recorded October 20, 1982. During the production phase of the wells, the facility will be unmanned, except during times of maintenance and load out and transportation of condensate and produced water from the pad. The well pad will be visually buffered from adjacent residences through topography, distance, and vegetation. If necessary, Ursa may install a sound wall during drilling and completion operations to mitigate for sound and some visual impacts. Any lighting will be directed downward and inward away from adjacent properties. All equipment that remains on the pad after drilling and completions will be painted a neutral color to blend into the landscape. The SUA with Battlement Mesa Partners does not require additional landscaping at this pad site, due to its location next to the storage area and wastewater treatment plant. A. Site Organization The proposed well pad has one access point off of River Bluff Road at the southern end of the project site. The site will be organized to provide safe access to and from the site and parking off the public right-of-way. It will not disrupt solar access to adjacent properties, pedestrian access, nor access to common areas along River Bluff Road. Standards Analysis Page 23 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B B. Operational Characteristics The operations of activities on the site will be managed to avoid nuisances to adjacent uses relating to hours of operations, parking, service delivery, and location of service areas and docks. All parking and service areas will be on-site. No street activities will be allowed, except in cases of emergency. 1. According to Ursa's Fugitive Dust Control Plan, dust control may consist of water, surfacing materials, or non -saline dust suppressants as appropriate for road conditions. Per the SUA, no flaring will be permitted within 2,000 feet of an occupied dwelling, except in an upset condition. Production equipment will comply with applicable CDPHE and COGCC regulations governing VOC emissions. Ursa will be in compliance with the applicable CDPHE Air Quality Control Commission regulations, including Regulation No. 2 requirement that no oil or gas operation may cause or allow the emission of odorous air from any single source that is detectible after the odorous air has been diluted with seven or more volumes of odor -free air. 2. Drilling and completion operations are subject to the maximum permissible noise levels for industrial zones. During the production phase of the well, Residential/Agricultural/Rural zone maximum noise levels will apply, per the SUA and COGCC Rules. Stationary engines and their exhausts will be located and oriented to direct noise away from the homes closest to the well pad. Ursa will evaluate noise generation from equipment and require contractors to refit mufflers, etc., in situations where the volume of sound produced exceeds noise levels for Residential/Agricultural/Rural zones. Engine braking will be prohibited by Ursa for its personnel and contractors. 3. Per the SUA, there will be no time of day restrictions with regard to drilling, completing, re -completing, workover, or reservoir fracture stimulation operations. Routine ongoing maintenance, development and production operations activities will be limited to the hours of 7:00 am to 8:00 pm. C. Buffering The proposed well pad may be surrounded by a sound barrier to mitigate visual and noise impacts during drilling and completion activities. Once the well pad enters the production phase, the barrier will be removed. Visual impacts are mitigated by the topography, distance, and vegetation. The SUA with Battlement Mesa Partners does not require additional landscaping at this pad site, due to its location next to the storage area and wastewater treatment plant. D. Materials Tanks, buildings, and equipment will be painted to blend in with the surrounding landscape. Standards Analysis Page 24 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B SECTION 7-302. OFF-STREET PARKING AND LOADING STANDARDS Adequate parking will be made available to accommodate Ursa personnel during regular operation, inspection, and maintenance of the well pad facility. All activities on this site will be conducted out of any public right-of-way. General parking standards for industrial uses do not apply, because the general public is not permitted on the site for safety reasons. All off-loading and loading will take place on the well pad out of the public right-of-way. See the Site Plan for truck circulation related to water delivery and the production phase of the well pad. Loading and unloading of vehicles will take place in a manner that will not interfere with the flow of traffic on River Bluff Road (CR 307). Parking and loading surfaces have been designed by an engineer to ensure proper drainage of surface and stormwater. See Grading and Drainage Plan section of this submittal. Due to safety concerns, handicapped or accessible parking is not appropriate for this land use. Traffic circulation patterns on site will be such that no vehicle will be required to back on to the public right-of-way. The access driveway for the proposed well pad runs to the south off of the well pad to River Bluff Road. The apron off of River Bluff Road is constructed to accommodate drilling rigs and tanker trucks typical for hauling produced water. The driveway has a clear vision area of 300 feet in both directions of River Bluff Road. The minimum width of the access road is 25 feet to facilitate the access and egress of drilling rigs to the well pad and provide maximum safety of pedestrian and vehicular traffic on the site. Due to the topography of the parcel for proposed well pad site, landscaping is not planned for the proposed project site. Any illumination will be downcast and shielded per Garfield County standards. For more information, see the Traffic Study and the Road Assessment Report included in this submittal. SECTION 7-303. LANDSCAPING STANDARDS This type of industrial use is typically exempt from the landscape standards of the Development Code, but given the fact that the requested land use is within the Battlement Mesa PUD, consideration has been given to provide landscaping that is consistent with the character of development and agreed upon with the Owner. The SUA does not require landscaping for this proposed well pad due to its location away from most residences within the PUD. SECTION 7-304. LIGHTING STANDARDS A. Downcast Lighting During drilling operations, if a drilling rig is within 1,000 feet of an occupied dwelling, Ursa and its subcontractors will align the lighting equipment to minimize the proportion of the lights that are directed toward the dwellings and will install lighting shield devices on all of Standards Analysis Page 25 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B the more conspicuous lights. Lighting will be directed inward and downward except as deemed necessary for safety reasons. After drilling and completion operations, any lighting will be directed inward and downward, towards the interior of the site. B. Shielded Lighting Exterior lighting shall be shielded so as not to shine directly onto other properties. C. Hazardous Lighting Light from the site will not create a traffic hazard to be confused as traffic control devices. D. Flashing Lights The facility will not contain flashing lights. E. Height Limitations There will be no permanent light sources exceeding 40 feet in height on the site. SECTION 7-305. SNOW STORAGE STANDARDS Snow will be stored in a vacant section of the proposed well pad. The site will be graded to accommodate snowmelt to insure sufficient drainage. SECTION 7-306. TRAIL AND WALKWAY STANDARDS A. Recreational and Community Facility Access The proposed well pad is located on private property within the Battlement Mesa PUD. A connection to public facilities is not appropriate or feasible. DIVISION 10. ADDITIONAL STANDARDS FOR INDUSTRIAL USES SECTION 7-1001. INDUSTRIAL USE A. Residential Subdivisions The proposed well pad is not located in a platted residential subdivision. B. Setbacks All activity associated with these uses shall be a minimum of 100 feet from an adjacent residential property line, unless the use is on an industrially zoned property. C. Concealing and Screening Per the SUA, Ursa agrees to construct the proposed well pad to mitigate visual impacts to adjacent properties through the use of topographic and vegetative buffers. Aboveground facilities will be painted to blend in with the environment. Standards Analysis Page 26 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B D. Storing All products will be stored in compliance with all national, state, and local codes and will be a minimum of 100 feet from adjacent property lines. E. Industrial Wastes All industrial wastes will be disposed of in a manner consistent with federal and state statutes and requirements of CDPHE and COGCC. Cuttings Sampling and Stabilization: Both surface and production hole drill cuttings will be generated at each well pad. Raw cuttings (not stabilized) will be sampled and profiled at the location of generation in accordance with Ursa's Waste Management Plan. Once the raw cuttings are sampled, they will be stabilized (absorption/removing liquids) in a temporary area on the well pad. The cuttings will be stabilized using either native soils (preferable) or a commercially available inert adsorbent (sawdust, EZ Stabil, etc.). In some cases, relocation of cuttings to another location during drilling would be required due to the small pad size permitted by the previous operator. If the volume of cuttings on the well pad during drilling exceeds the capacity of the on-site temporary area, limits operational capabilities to complete drilling, or creates safety concerns, a COGCC Sundry Notice (Form 4) will be submitted for approval to relocate the cuttings to another location pending the results of sampling analytical results. Cuttings Management and Disposal: If sampling results for either surface or production hole cuttings meet COGCC Table 910-1 standards, they will be treated as non -waste (essentially soil material) and will be managed under one or more of the following options: 1) remain on site for pad stabilization/reclamation; 2) be relocated to another location for pad stabilization/reclamation; 3) made available as fill material to the general public; 4) be relocated to a COGCC approved cuttings management facility; or 5) disposed of at an approved waste facility. Options 2 — 4 would be in accordance with a COGCC approved Sundry Notice (Form 4). Disposal at an approved waste facility would be managed for Item 5 under an approved waste manifest in accordance with CDPHE regulations. If cuttings don't meet standards, then Ursa will implement one of two options: continued mixing to meet Table 910-1 standards for beneficial reuse/relocation or transport to an authorized waste facility in accordance with Federal and State (COGCC/CDPHE) regulations, including manifesting. Final decisions will be based on site-specific operations logistics. F. Noise Drilling and completion operations are subject to the maximum permissible noise levels for industrial zones. During the drilling and completions phase, an appropriate sound barrier may be erected and would remain in place through completions of the natural gas wells to minimize noise. During the production phase of the well, Residential/Agricultural/Rural zone maximum noise levels will apply, per the SUA and COGCC Rules. Standards Analysis Page 27 Ursa Operating Company Battlement Mesa PUD Phase I — BMC B Stationary engines and their exhausts will be located and oriented to direct noise away from the homes closest to the well pad. Ursa will evaluate noise generation from equipment and require contractors to refit mufflers, etc., in situations where the volume of sound produced exceeds noise levels for Residential/Agricultural/Rural zones. Engine braking will be prohibited by Ursa for its personnel and contractors. G. Ground Vibration During the production phase of the proposed well pad, ground vibration will not be measurable at any point outside the property boundary. H. Hours of Operation Per the SUA, there will be no time of day restrictions with regard to drilling, completing, re - completing, workover, or reservoir fracture stimulation operations. Routine ongoing maintenance and production operations activities will be limited to the hours of 7:00 am to 8:00 pm. I. Interference, Nuisance, or Hazard During the production phase of the proposed well pad, adjacent lands will not be impacted by the generation of vapor, dust, smoke, noise, glare, or vibration beyond the normal impacts of activities occurring around the adjacent properties. Ursa will apply the appropriate level of controls to accommodate potential impacts via adherence to CDPHE Air Quality regulations and the implementation of industry BMPs included in the SWMP and Ursa's Fugitive Dust Control Plan. The proposed well pad and access road will be graveled to reduce fugitive dust, which will be controlled using water or other dust suppressants. This proposed use will comply with Colorado Revised State Statutes and COGCC Rules regarding noise impacts at all times. If a nuisance complaint is received on a location for noise, odor, dust, or other nuisances, Ursa's standard operating practice is to respond to each complaint as soon as possible. The person receiving the complaint, usually the Landman, gathers as much information (such as wind direction, time, duration, strength, nature of odor or noise, etc.) about the issue as possible. This information is relayed to the operations leads who begin to determine the source of the issue and what may be causing it. Once the root cause of the issue is identified, the team determines mitigation efforts that will help remedy the concern(s). The land team follows up with the stakeholders on the effectiveness of the mitigation efforts and adjustments are made as necessary. All complaints are logged and tracked to improve Ursa's overall best management practices (BMP) performance on existing and future assets. Standards Analysis Page 28