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HomeMy WebLinkAbout12.0 Call Up BOCC PacketGarfield County MEMORANDUM Community Development 108 8th Street, Suite 401, Glenwood Springs, CO 81601 Office: 970-945-8212 Fax: 970-384-3470 TO: Board of County Commissioners FROM: Glenn Hartmann, Senior Planner DATE: June 6, 2014 SUBJECT: Call -Up Request Regarding the Director's Decision Ursa Speakman A Injection Well (GAPA-7835) BACKGROUND -PROCESS On May 30, 2014, A Director's Decision Letter was issued by the Director of the Community Development Department for conditional approval of a General Administrative Land Use Change Permit for the Ursa Speakman A Injection Well Application. On June 5, 2014, the Community Development Department received a request from the Battlement Mesa Concerned Citizens to Call -Up the decision for review by the Board of County Commissioners. The request was received within the 10 day Call -Up period which will expire on June 9th The request for Call -Up is being processed in accordance with Section 4-112 of the Garfield County Land Use and Development Code. The Code provides that a Call -Up may be initiated by the Board of County Commissioners, the Director, the Applicant or any affected Adjacent Property Owner. The Battlement Mesa Concerned Citizens are preparing an updated request to specifically include endorsement/signature by an Adjacent Property Owner (by code definition a property owner within 200 ft.). Staff anticipates receiving the updated request prior to the Board's consideration of the request and no later than June 9th to meet the code requirements. The Land Use and Development Code calls for the request to be scheduled at a Public Meeting at the next available Board meeting. At that meeting, the Board shall by a majority vote. decide whether to review the Director's decision. Should it be decided that the Board will review the Director's decision the Board shall schedule a public hearing and provide notice as required in the original application. Should it be decided that the Director's decision will not be reviewed, the Director's decision shall be final. AGENDA NOTES In accordance with the Land Use and Development Code we have placed this item on the next available Board of County Commissioners agenda, Monday, June 9th under the Public Meeting section of the agenda, as part of the rolling agenda. The agenda item will be limited to the Board of County Commissioner's deliberation on whether to Call -Up the request and schedule a public hearing before the Board. Detailed discussion of the Application should be deferred to the future public hearing if the Application is called up. Included in the Board's packet is the following information: • Request letter from the Battlement Mesa Concerned Citizens • Director's Determination Letter • Staff Report (including information on the Application and Referral Comments) Community Development Staff and the County Attorney's Office will be available at the public meeting to answer any questions regarding the Application, Director's Decision, and the Call -Up process. The Applicant and the Battlement Mesa Concerned Citizens have been advised of the public meeting. Glenn Hartmann From: Dave Devanney [dgdevanney@comcast.net] Sent: Thursday, June 05, 2014 2:59 PM To: Glenn Hartmann; Fred Jarman Cc: Powers Jeff; Simpson Don Subject: BCC: GAPA-7835 hearing request Fred and Glenn — RE: File no. GAPA-7835 On behalf of the members of Battlement Concerned Citizens (BCC), we are requesting a hearing with regard to the referenced injection well permit application. We have identified two areas that we feel should have further consideration. 1. The Community Development staff report does not address the issue of possible seismic activity as a result of this injection well. We request that the county require that Ursa cease and desist from all current and future injection well operations at the Speakman A site, in the event of any detected seismic activity within a one mile radius of the site. The source of such detection shall be any state or federal agency responsible for earthquake monitoring. A level of two (2) or more (minor) on the Richter scale could be set. If necessary, seismic monitoring equipment should be provided. Recent news stories from around the state and nation are raising questions about the potential link between seismic activity and proximity to injection wells. See news report from Greeley by clicking here. Residents of Battlement Mesa are concerned with the growing number of injection wells near their community and the significant negative impact that could result in the event of seismic activity. We also ask that a Battlement Concerned Citizens (BCC) representative be notified in the event of such activity. 2. The Community Development staff report indicates that Ursa plans to put a pipeline in place in the future and that truck traffic will be reduced by one-third. We request that the county require that Ursa, within 60 days of receiving approval, have pipeline capability in place, to move the produced water to the injection well site from the other local well -pads. Once in place, there should be no need for truck traffic on or near Stone Quarry Road in the vicinity of these well -pads, except in emergency situations, for the transport of produced water for injection. Residents of Battlement Mesa are already concerned and have complained about the high volume of truck traffic near their homes and would like assurance that the volume will be decreased, and thereby, the noise, vibration and wear & tear on their roadways. Further, we ask that Garfield County monitor the volume of truck traffic in that area of Stone Quarry Road, on a periodic basis, and compare current values with historic values, in order to detect truck traffic trends. We also ask that a Battlement Concerned Citizens (BCC) representative be notified of such results. We are planning to attend the BOCC meeting in Parachute next Monday to verbally present this request to the county commissioners. Please advise us if you have any comments or suggestions. Sincerely, Dave Devanney, BCC co-chair Doug Saxton, BCC member COPIED: Jeff Powers, Ursa Don Simpson, Ursa 2 May 30, 2014 Garfield County Community Development 108 8th Street, Suite 401, Glenwood Springs, CO 81601 Office: 970-945-8212 Fax: 970-384-3470 Lorne Prescott, Olsson Associates 760 Horizon Drive, Suite 102 Grand Junction, CO 81506 RE: Director's Decision Administrative Review Ursa Operating Company LLC, Speakman A Small Injection Well (File GAPA-7835) Dear Lorne: This letter is being provided to you as the authorized representative for Ursa Operating Company LLC, James Speakman and Monique Speakman in regard to the General .Administrative Review Application for a Small Injection Well, known as the Speakman A Injection Well. The proposed use is located at approximately 5242 County Road 300 on property also known by Assessor's Parcel No. 2409-244-00-124. The Director's Decision on the Application is based on the following findings and subject to the Applicant's representations and conditions of approval. 1. That proper public notice was provided as required for the Director's Decision. 2. Consideration of the Application was extensive and complete, that all pertinent facts, matters and issues were submitted and that all interested parties were given the opportunity to provide input prior to the Director's Decision. 3. That for the above stated and other reasons the proposed Land Use Change Permit for the Ursa Speakman A Small Injection Well Facility is in the best interest of the health, safety, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. That with the adoption of conditions, the application is in general conformance with the 2030 Comprehensive Plan, as amended. 5. That with the adoptions of conditions the application has adequately met the requirements of the Garfield County Land Use and Development Code, as amended. A Director's Decision is hereby issued approving the Application subject to the following conditions: 1. That all representations made by the Applicant in the application shall be conditions of approval unless specifically altered by the conditions of approval. 2. That the Ursa Speakman A, Small Injection Well Facility shall be operated in accordance with all applicable Federal, State, and local regulations governing the operation of this type of facility. 3. Prior to issuance of the Land Use Change Permit, the Applicant shall provide updated drainage information and/or designs adequate to address the referral comments from the County's Consulting Engineer, Chris Hale. 4. Prior to issuance of the Land Use Change Permit, the Applicant shall provide an updated site plan including designation of truck circulation areas within the well pad to be used for truck delivery traffic. The site plan shall also address circulation patterns to be implemented when active drilling and placement of a drill rig on the well pad occurs. 5. Prior to issuance of the Land Use Change Permit, the Applicant shall provide an updated dust control plan for the site and access roads with more specifics on the timing of watering and application of dust suppressing chemicals. The plan shall include the well pad area surrounding the injection well facilities. 6. The facility shall maintain compliance with CDPHE Storm Water Management Permits, Drainage and Grading Plans, Reclamation and Erosion Control Plans for the site. The Applicant shall maintain all required COGCC permits and forms for the facility and shall comply with all conditions or requirements of said permits and forms. 8. The facility shall maintain compliance with COGCC Noise Standards/Regulations and the facility shall be required to utilize an electric pump as represented. If future compliance issues are identified the Applicant shall provide noise mitigation in order to achieve compliance along with a technical evaluation by a qualified professional to confirm compliance. 9. The Applicant shall comply with all SPCC Plan provisions and shall keep the plan current and updated for any changes to the facility. 10. As represented in the Application the facility shall have only termporary lighting for unscheduled night time maintenance. All lighting shall comply with Section 7-306 Lighting, with all lighting to be directed inward and doward toward the interior of the site. Facilities and storage tanks shall be 2 painted a non -glare neutral color to lessen any visual impacts. 11. The Emergency Response Plan shall be updated to include a section on response to and prevention of field or wild land fires. Separation between the injection well pad facilities and native vegetation at the perimeter of the site shall be maintained. 12. The Applicant shall maintain all required CDPHE permits for the facility including any applicable air quality, APEN permits. 13. The Applicant shall comply with the referral comments from Colorado Parks and Wildlife (CPW) including compliance with the Battlement Mesa Wildlife Mitigation Plan. Said plan and agreement between Ursa Operating Company and CPW includes a limitation on Trucking to between the hours of 10:00 a.m. and 3:00 p.m., when and where possible, compliance with COGCC Noise Regulations and use of bear proof trash containers for all food related trash. 14. The Applicant shall comply with the access representations and Traffic Report including limiting trucking to the designated haul route and the limitation to a maximum of 20 daily water truck deliveries to the facility. The daily trucking limitation may be calculated based on a weekly average to account for minor operational variations. Trucking of water to the site shall utilize watertight tanks and shall comply with all COGCC or CDOT requirements for hauling of production water. This Director's Decision will be forwarded to the Board of County Commissioners for a period of 10 days so that they may determine whether or not to call up the application for further review. Once this time period has passed with no request for review or public hearing, and provided all relevant conditions of approval have been resolved the Land Use Change Permit will be issued. Please contact this department if you have any questions. Sincerely, Tamra Allen, AICP Planning Manager, Community Development Department � c4�� 1 o f.�d Ste. y;rr CC: Board of County Commissioners Kelly Cave, Assistant County Attorney 3 Director Decision 5/29/14 File No. GAPA-7835 GH PROJECT INFORMATION AND STAFF COMMENTS REQUEST PROPERTY OWNER APPLICANT ASSESSOR'S PARCEL # PROPERTY SIZE LOCATION ACCESS General Administrative Land Use Change Permit for a Small Injection WeII Facility James Speakman and Monique Speakman Ursa Operating Company LLC 2409-244-00-124 The facility will be located on a 4.6 acre site which is within an overall 78.25 acre parcel. The property is located at approximately 5242 County Road 300, approximately 0.75 miles southwest of the Battlement Mesa Community, in Section 24, T7S, R96W. The facility is accessed by private roadways off of County Road 300 including a portion of what is known as Daybreak Drive. EXISTING ZONING The property is zoned (R) Rural I. GENERAL PROJECT DESCRIPTION The Applicant is requesting an Administrative Land Use Change Permit for a Small Injection Well, with less than 5,000 bbls of production water storage. The facility will be located on an existing COGCC approved well pad. It will be subject to COGCC Rule 325, and Forms 31 and 33 for injection wells. COGCC Form 26 is also required to address the source of the produced water to be handled by the injection well. The Facility will include the following equipment: • One injection well and electric pump • Six storage tanks totally between 1,800 and 3,000 bbls • 3 ft. high containment wall for the tank battery • Two combusters • A valve set 1 • A 20 ft. by 50 ft. (maximum size) electric pump building • Two foot high earthen berm on the site perimeter Produced water from local Ursa facilities will be transported to the site initially by truck and in the future by pipeline. Two Ursa well pads just south of Battlement Mesa will be served by the injection well facility. Traffic generation projections and a Traffic Analysis have been provided which include the proposed hauling routes. The Facility will be monitored typically during daylight hours by an Ursa Employee. A dust mitigation program will be implemented and CDPHE Air Quality permits will be obtained if required (may be required for the storage tanks). A Storm Water Management Plan has been prepared with storm water management improvements and Best Management Practices already implemented and/or planned for the site. 2 Monitoring, alarm, and remote shut down controls are planned for the facility. The Application also includes an area wide Spill Prevention Control and Countermeasures Plan and which includes specific details for the Ursa - Speakman site. Containment as required by COGCC will be implemented for the production water storage tanks associated with the injection well. The projected storage amount is consistent with the standard for a small injection well facility (less than 5,000 bbls). The site is currently covered by a statewide bond for reclamation and reclamation plans are included in the Application submittals. A noxious weed management plan has been prepared for the site. Lighting will only occur during unscheduled nighttime activities and minimal noise impacts are anticipated based on the use of electric pumps. Site Plan Speakman A Pad 1WI14OfThe SE114,The NE114OfThe SEIU4 Si A Portion Of the NE V4 Of the SW 114,/' <_\ vection 24, Township 7 South, Range 96 West, Of the 6th Principal Meriden, / i / County Of Garfield, State Of Colorado / 7� for Injection Well 1. • i Production Water Storage Injection Well Pump Building Injection Well 1 "` 01.1044 cropnk O. IV aterwmg , di 144 t 41k, \ erre S SITE PLAN •Al•-I4Y 10 tir w�n�; '+^--1"=^^4`�._Arum ^Ilii tiL 3 Benefits outlined in the submittals include minimizing new impacts on wildlife, reduced road maintenance, engineered controls for transfer system reducing potential for human error, reduction in transportation costs. II. LOCATION - SITE DESCRIPTION The site is currently a developed COGCC well pad with approximately 12 existing wells and plans for up to a total of 25 wells for the site. Land uses within 1,500 ft. include agricultural uses, natural gas extraction, public lands and a portion of open space within the adjoining Battlement Mesa PUD. Developed portions of the PUD including RV uses and residential homes are slightly farther from the site, estimated at another 150 ft. northeast of the site (total distance of 1,650 ft. +/-). Rural residential homes and properties are also located immediately west and north of the site and some distance south of the site. The site slopes up moderately from the County Road with the well pad graded and leveled out of the slope. The site is graded to slope down from the well pad on the north, west and east perimeters. The site slopes up to the south along the access road alignment. Ursa Speakman Site Aerial Photo 4 Native vegetation surrounding the site is generally sagebrush, with some pinion and juniper woodlands. No additional native vegetation will be removed for the proposed facility and the placement of the project on an existing well pad will minimize additional impacts. The site is located on a terrace above the Colorado River which is approximately 2,000 ft. to the northeast. Dry Creek is located approximately 1,645 ft. to the west. III. PUBLIC COMMENTS AND REFFERAL AGENCY COMMENTS Public Notice was provided for the Director's Decision in accordance with the Garfield County Land Use and Development Code as amended and included mailing notice to all property owners within 200 ft. and any mineral rights owners on the property. The Applicant has provided evidence of compliance with the notice requirements. Comments from referral agencies, County Departments, and the public are summarized below and attached as Exhibits. 1. Garfield County Consulting Engineer, Chris Hale, Mountain Cross Engineering: • Provided technical questions regarding the drainage engineering and calculations. 2. Garfield County Road and Bridge Department, Dan Goin District 3 Foreman: • No written comments were received, however, Dan Goin provided verbal comments that they did not have any concerns and had reviewed the haul routes. 3. Garfield County Vegetation Manager, Steve Anthony: • Provided comments indicating that the weed management plan is acceptable and that with the location on an existing well pad reclamation falls under the jurisdiction of the COGCC. 4. Garfield County Environmental Health: Morgan Hill, Environmental Health Specialist noted the following topics. • Support for Air Quality Permitting. • Recognized the importance of adherence to the SWMP and SPCC plans. • Noted safety concerns related to traffic. 5. Colorado Parks and Wildlife: • Noted the location is within a mapped area for Mule Deer severe winter range and Elk winter concentration range. • Indicated that the site is within a 1/4 mile of the Colorado River in an area of critical habitat for four federally listed fish species. • Noted the agreement with Ursa Operation Company regarding the Battlement Mesa Wildlife Mitigation Plan (BMWMP) which covers the site and the need to comply with provision of that plan including limited hours for trucking activity, 5 compliance with COGCC noise limits, and use of bear proof dumpsters/trash receptacles for food related trash. 6. Town of Parachute: • Submitted a letter indicating that the Town had no issues regarding granting the application. 7. Colorado Division of Water Resources: • Submitted a letter indicating that they had no comments at this time. 8. Battlement Mesa Concerned Citizens: • Verbally contacted the Community Development Department and noted general concerns with traffic (haul routes & traffic counts), noise, air quality, and use of current technology for installations. 9. Other referral agencies that did not submit comments include: (a) the Colorado Department of Public Health and Environment Water Quality Division and Air Quality Division; (b) Bureau of Land Management; (c) Grand Valley Fire Protection District; (d) Battlement Mesa Service Association; and (d) Battlement Mesa Metro District.. IV. STAFF COMMENTS AND ANALYSIS In accordance with the Land Use and Development Code, the Applicant has provided detailed responses to the Submittal Requirements and applicable sections of Article 7, Divisions 1, 2, and 3, including Section 7-1001 Industrial Use Standards. The Application materials include an Impact Analysis and related consultant reports, technical studies, and plans. 7-101 — 103: Zone District Regulations, Comprehensive Plan & Compatibility The proposed use demonstrates general conformance with applicable Zone District provisions contained in the Land Use and Development Code and in particular Article 3 standards for the Rural Zone District. The Comprehensive Plan 2030 designates the site as RMH (Residential Medium High Density). Excerpts from the Land Use Description Section Chapter 2 and Section 8, Natural Resources and Section 9, Mineral Extraction are provided below. Chapter 2 — Land Use Designations Residential Medium High (RMH): Small farms, estates, and clustered residential subdivision; density determined by degree of clustering and land preserved in open condition. 6 Section 8 — Natural Resources Issues *The county maintains high air quality standards, however there may be a propensity for air pollutants to exist in the western part of the county Goals 1. Ensure that natural, scenic, ecological, and critical wildlife habitat resources are protected and /or impacts mitigated. 4. Ensure the appropriate reclamation of land after extraction processes. Policies 1. The County will encourage and cooperate with the protection of critical habitat including state and federally protected, threatened, or endangered species. Section 9 — Mineral Extraction Goals 1. Ensure that mineral extraction is regulated appropriately to promote responsible development and provide benefit to the general public. 2. Ensure that mineral extraction activities mitigate their effects on the natural environment, including air quality, water quality, wildlife habitat or important visual resources. 3. In working with mineral extraction projects, the county will protect the public health, safety and welfare of its citizens. Policies 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. 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 LUDC to maintain compatibility with surrounding land uses. The location and design of the proposed facility is in general conformance with the Comprehensive Plan Policies subject to proper mitigation of impacts. Comprehensive Plan Future Land Use Map - Excerpt ,Parachute/A Ursa Speakman Site The Application has also provided information on neighboring land uses indicating the general character of the area. The request demonstrates general compatibility with adjoining uses provided proper mitigation is implemented and compliance with conditions and COGCC regulations maintained. 7-104 & 105: Source of Water & Waste Water Systems The Application represents that the facilities will operated with only occasional staff activities. The proposal demonstrates that the uses will be adequately served by provision of water in individual staff vehicles and provision of portable toilets on site per OSHA standards. 3. The Application also includes extensive documentation that the water for injection is from non -tributary sources addressing any Division of Water Resources issues. 7-106: Public Utilities The site will be served with electricity to be provided by Holy Cross Energy for the operation of the electric pump for the injection well. Holy Cross facilities are currently found on portions of the site with easement locations for service line extensions to be determined. Service will be to the pump building located along the westerly perimeter of the site. 8 OIL AND GAS ACTIVITY AND PIPELINE MAPPING Cal Ursa Speakman Site j telt • 7-107: Access & Roadways • • .yam; PIPELINES = Purple, Green and Tan Lines OTHER ACTIVITES (INCL. WELLS) = Red Triangles The Applicants access their property from County Road 300 via private roads including Daybreak Lane. The applicant has provided a detailed analysis of the roadway including engineering representations. The submittal reflects compliance with the County's Roadway Standards as contained in Table 7-107. Dust control and ongoing maintenance are considerations that should be included as conditions of approval. The Applicant's Traffic Study identifies that truck traffic associated with the three Ursa Well Pads to be served by the injection well will be reduced by approximately 1/3 when the injection well becomes operational (reduction from 30 total trips to 20 total trips). The truck haul route will also be significantly shortened and will no longer connect to the main Parachute 1-70 Interchange but will run along the east edge of the Battlement Mesa PUD on County Road 303, County Road 300, and Stone Quarry Road. 9 The Traffic Study further documents that the traffic generation will be a minor increase based on existing volumes and noted that all intersections where site traffic will be turning are expected to be adequate. No requirements for County or State permitting were noted and no deficiencies identified. 7-108: Natural Hazards The Application provides significant information on natural hazards including information on soils, geology, and slopes. The information supports a determination that the proposed use is not subject to significant natural hazard risks. 7-109: Fire Protection The Application includes an Emergency Response Plan for the site that includes notification procedures for the Grand Valley Fire Protection District. The District received a referral packet but did not submit comments. The only structure proposed for the facility is the electric pump building. The Fire Protection District maintains facilities and equipment within the Battlement Mesa PUD. 7-201: Agricultural Lands With no new disturbed areas no additional impacts on nearby agricultural lands are anticipated. The well pad is not currently fenced and the proposed facility does not propose any changes. 7-202: Wildlife Habitat Areas The Applicant has provided an Environmental Impact Report, completed by WestWater Engineering, dated February 2014. The report indicates that no special status plant species are expected to occur in the project area. The report also addressed threatened, endangered or candidate species and noted a number of species that may be found in Garfield County including some species of fish with habitat in the Colorado River near the site. The report concludes that other than the fish no other species are expected in the area of the site as habitat conditions are not appropriate. The Study also addressed potential for raptor nesting and concluded that the sparse vegetation on the site provides poor to marginal nesting habitat. No raptor nests were found within 0.25 miles of the site. The study notes that the project is placed within the boundaries of an existing development and therefore avoids cumulative impacts on habitats. The Report concludes that "The development of the project is not expected to significantly affect any critical environmental resources." 10 7-203: Protection of Water Bodies Potential impacts on water bodies has been addressed by the Storm Water Management Plan (permit), drainage plans, and Spill Prevention Containment and Countermeasures Plans for the site. The site location is on a terrace above the Colorado River which is approximately 2,000 ft. to the northeast. Dry Creek is located approximately 1,645 ft. to the west and a drainage swale is located east of the site. Distance from these features along with the engineered drainage plans for the site mitigate the potential for impacts. 7-204: Drainage and Erosion (Stormwater) The Applicant has provided a copy of the State Storm water Management Permit and Plans applicable to the site. The Applicant has also provided Best Management Practices including areas already stabilized and re -vegetated. The drainage report concludes that due to the low runoff of the historic and existing conditions, no detention is required for the site, however a temporary detention feature is designed to be in place during construction of the injection well. Referral comments from the County's Consulting Engineer should be addressed as conditions prior to the issuance of the Land Use Change Permit. 7-205 Environmental Quality Air quality permits from CDPHE associated with the injection well are not anticipated base on the use of an electric pump and the request by the Applicant that the production water tanks be considered exempt. The condensate tanks currently on site are used in conjunction with well production and are regulated by COGCC and CDPHE. A recommended condition of approval shall call for the Applicant to obtain and keep current all permits as required by the CDPHE and maintain compliance with all conditions contained therein. Storm Water Management Permits, Installation of Best Management Practices, SPCC Plans, and Reclamation and Erosion Control Plans address protection of water quality. Compliance with all COGCC Permitting requirements and conditions is also an essential component of ensuring environmental issues including type of water injected, the formation injected into and the capacity of the well are addressed. 7-206: Wildfire Hazards The site is located in an area mapped with low to moderate wildfire hazard. Only a single pump house structure is proposed and no comments were received from the Fire Protection District. The site plan shall maintain a separation between the facilities and natural vegetation. The Emergency Response Plan shall be updated to include provisions regarding Field or Wildland Fire Prevention and response. 11 7-207 Natural and Geologic Hazards The Geologic Hazard Report addresses a broad range of potential hazards including landside, rock fall, soils, alluvial fans and slopes. No significant hazards to the proposed facility were noted in the report and the site is not located within a flood plain. 7-208: Reclamation The Applicant has included a reclamation plan that addresses re -vegetation and reclamation issues. A reclamation bond with the State is currently in place and shall be maintained to include well pad reclamation associated with the injection well facility. 7-301 & 302: Compatible Design, Parking, and Loading The proposed use is consistent with and compatible with typical oil and gas exploration and production activities. Large areas of the site plan are available for parking, circulation, and loading activities. 7-303: Landscaping As an industrial use landscaping submittals and standards are not applicable to the proposal. 7-304: Lighting No permanent lighting is proposed and the Application makes reference to only using lighting during unscheduled night time maintenance activities. Any lighting shall be required to meet the County standards for being down directed, shielded, and oriented toward the interior of the site. 7-305 Snow Storage Adequate portions of the site plan are available for snow storage and can be accommodated by the drainage and storm water rnanagement plans. 7-306 Trails Trails standards are generally not applicable based on the industrial nature of the proposal and surrounding uses. 7-1001 INDUSTRIAL USE STANDARDS The Application represents that the facility will comply with all the Industrial Use Standards contained in Section 1001. The Application contains a variety of documents to support compliance and the following summary addresses key issues. 12 • The facility is currently visually screened along the north and eastern portions of the well pad by a sound buffering installation. Once drilling activities are completed the existing buffer will be removed. • Hours of operation for the injection well pump are effectively 24 hours a day. However other support or maintenance activities should be conducted between the hours of 7 a.m. and 6 p.m. as represented in the application. In addition the Applicant's Wildlife Mitigation Plan (BMWMP) and agreement with Colorado Parks and Wildlife call for a limitation on trucking to between 10:00 a.m. and 3:00 p.m., when and where possible. • All industrial products and wastes will be stored in accordance with all applicable state and federal regulations. • The Applicant represents that COGCC noise limits will be adhered to and has provided a noise estimate to support that representation which does not assume any mitigation from the existing barrier. Consistent with the noise estimate the Applicant shall be limited to use of an electric pump for the injection well. Ongoing compliance with the noise standard shall be required including once the noise mitigation barrier is removed after the completion of drilling activities. • No other nuisance or ground vibration hazards are anticipated based on type of use. V. ADDITIONAL STAFF ANALYSIS Future pipelines to serve the injection well are encouraged as a means to further reduce traffic impacts. Any future pipelines will need to comply with the County's permitting requirements or be determined to be exempt. Pipelines that are over 2 miles in length and greater than 12 inches in diameter or pipelines 5 miles or greater are required to be permitted by the County. VI. SUGGESTED FINDINGS 1. That proper public notice was provided as required for the Director's Decision. 2. Consideration of the Application was extensive and complete, that all pertinent facts, matters and issues were submitted and that all interested parties were given the opportunity to provide input prior to the Director's Decision. 3. That for the above stated and other reasons the proposed Land Use Change Permit for the Ursa Speakman A Small Injection Well Facility is in the best interest of the health, safety, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. That with the adoption of conditions, the application is in general conformance with the 2030 Comprehensive Plan, as amended. 5. That with the adoptions of conditions the application has adequately met the requirements of the Garfield County Land Use and Development Code, as amended. 13 VII. RECOMMENDATION The following recommended conditions of approval are provided for consideration as part of the Director's Decision for approval of the Application. 1. That all representations made by the Applicant in the application shall be conditions of approval unless specifically altered by the conditions of approval. 2. That the Ursa Speakman A, Small Injection Well Facility shall be operated in accordance with all applicable Federal, State, and local regulations governing the operation of this type of facility. Conditions Prior to Issuance 3. Prior to issuance of the Land Use Change Permit, the Applicant shall provide updated drainage information and/or designs adequate to address the referral comments from the County's Consulting Engineer, Chris Hale. 4. Prior to issuance of the Land Use Change Permit, the Applicant shall provide an updated site plan including designation of truck circulation areas within the well pad to be used for truck delivery traffic. The site plan shall also address circulation patterns to be implemented when active drilling and placement of a drill rig on the well pad occurs. 5. Prior to issuance of the Land Use Change Permit, the Applicant shall provide an updated dust control plan for the site and access roads with more specifics on the timing of watering and application of dust suppressing chemicals. The plan shall include the well pad area surrounding the injection well facilities. Other Conditions 6. The facility shall maintain compliance with CDPHE Storm Water Management Permits, Drainage and Grading Plans, Reclamation and Erosion Control Plans for the site. 7. The Applicant shall maintain all required COGCC permits and forms for the facility and shall comply with all conditions or requirements of said permits and forms. 8. The facility shall maintain compliance with COGCC Noise Standards/Regulations and the facility shall be required to utilize an electric pump as represented. If future compliance issues are identified the Applicant shall provide noise mitigation in order to achieve compliance along with a technical evaluation by a qualified professional to confirm compliance. 9. The Applicant shall comply with all SPCC Plan provisions and shall keep the plan current and updated for any changes to the facility. 14 10. As represented in the Application the facility shall have only termporary lighting for unscheduled night time maintenance. All lighting shall comply with Section 7-306 Lighting, with all lighting to be directed inward and doward toward the interior of the site. Facilities and storage tanks shall be painted a non -glare neutral color to lessen any visual impacts. 11. The Emergency Response Plan shall be updated to include a section on response to and prevention of field or wildland fires. Separation between the injection well pad facilities and native vegetation at the perimeter of the site shall be maintained. 12. The Applicant shall maintain all required CDPHE permits for the facility including any applicable air quality, APEN permits. 13. The Applicant shall comply with the referral comments from Colorado Parks and Wildlife (CPW) including compliance with the Battlement Mesa Wildlife Mitigation Plan. Said plan and agreement between Ursa Operating Company and CPW includes a limitation on Trucking to between the hours of 10:00 a.m. and 3:00 p.m., compliance with COGCC Noise Regulations and use of bear proof trash containers for all food related trash. 14. The Applicant shall comply with the access representations and Traffic Report including limiting trucking to the designated haul route and the limitation to a maximum of 20 daily water truck deliveries to the facility. The daily trucking limitation may be calculated based on a weekly average to account for minor operational variations. Trucking of water to the site shall utilize watertight tanks and shall comply with all COGCC or CDOT requirements for hauling of production water. 15 VIEWS OF THE SITE 16 • kr M1120112011(3 17 18 May 28, 2014 Mr. Glenn Hartman Garfield County Planning 108 8th Street, Suite 401 Glenwood Springs, CO 81601 RE: Review of Speakman A Injection Well: GAPA-7835 Dear Glenn: MOUNTAIN CROSS ENGINEERING, INC. Civil and Environmental Consulting and Design This office has performed a review of the documents provided for the Administrative Review Application of the Speakman A Injection Well. The submittal was found to be thorough and well organized. The following comments were generated: 1. There appears to be fill that will be generated with the re -grading of the well pad. The Applicant should address how the fill will be managed. 2. There is a large discrepancy in the areas between the Historic and the Existing basin delineations of the drainage analysis. It appears that the existing condition may split the Historic delineation into two basins, however only one basin appears to be included in the analysis. The Engineer for the Applicant should provide an explanation of how the basin delineations were determined or revise the analysis to include the remaining area of the Historic basin. 3. The Engineer for the Applicant should provide more detail on how the 1 -hour precipitation depths are determined from the 24-hour precipitation events. 4. The narrative for Section 7-204. Drainage and Erosion, in the Standards Analysis portion of the application materials describes detention that is different than proposed in the drainage analysis. This should be reviewed and the discrepancies reconciled. Feel free to call if you have any questions or comments. Sincerely, Mountain Cross Engineering, Inc. Chris Hale, PE 8261/2 Grand Avenue, Glenwood Springs, CO 81601 P: 970.945.5544 F: 970.945.5558 www.mountaincross-eng.com Glenn Hartmann From: Dan Goin Sent: Thursday, May 29, 2014 12:50 PM To: Glenn Hartmann Subject: Traffic Counts Attachments: CR 300 Stone Quary Rd 2014 Traffic Count Study.rtf: CR 3000 Old Stone Quary Rd. 2014 Traffic Count Study.rtf: CR 303 Gardner Lane 2014 Traffic Count Study.rf Here's the traffic counts you asked for. Let me know if there's anything else you need.\ Thank you. Dan 1 AADT-157 -- English (ENU) Datasets: Site: Input A: Input B: Survey Duration: Zone: File: Identifier: Algorithm: Data type: Profile: Filter time: Name: Scheme: Units: In profile: MetroCount Traffic Executive Adjusted Flow [CR 300] BOR CR 300 Stone Quarry 2014 Traffic Study 8 - East bound A>B, West bound B>A. - Lane= 0, Added to totals. (/2.000) 0 - Unused or unknown. - Lane= 0, Excluded from totals. 8:00 Wednesday, April 30, 2014 => 16:23 Wednesday, May 07, 2014 CR 30007May2014.ECO (Plus) R556ZXFF MC56-L5 [MC55] (c)Microcom 190ct04 Event Count (v3.21 - 15275) Axle sensors - Paired (Class/Speed/Count) 8:00 Wednesday, April 30, 2014 => 16:23 Wednesday, May 07, 2014 Default Profile Count events divided by setup divisor Non metric (ft, mi, ft/s, mph, Ib, ton) Events = 7000 / 7000 (100.00%) Day Hits RawVol DayFac MonFac AdjVol - Date 0 Wednesday, April 30, 2014 1 1 562.000 1.000 1.000 2 1 530.500 1.000 1.000 3 1 494.500 1.000 1.000 4 1 363.500 1.000 1.000 5 1 469.000 1.000 1.000 6 1 566.000 1.000 1.000 7 Total days = 6, Coverage = 1.64% ADT = 497.583, SD = 75.787 AADT = 497.583, SD = 75.787 Weekdays = 4, Coverage = 1.10% AWDT = 531.875, SD = 44.823 AAWDT = 531.875, SD = 44.823 Weekend days = 2, Coverage = 0.55% AWET = 429.000, SD = 92.631 AAWET = 429.000, SD = 92.631 562.000 - Thursday, May 01, 2014 530.500 - Friday, May 02, 2014 494.500 - Saturday, May 03, 2014 363.500 - Sunday, May 04, 2014 469.000 - Monday, May 05, 2014 566.000 - Tuesday, May 06, 2014 Wednesday, May 07, 2014 ADT and adjustment factor by month Jan Feb Mar Apr May - Vol = 2985.500, Days = 6, ADT = 1.00000 Jun Jul Aug Sep Oct Nov 497.583, Adjust = 1.00000, 1/Adjust = Dec ADT and adjustment factor by day of week Mon - Vol = 469.000, Days = 1, ADT = 469.000, Adjust = 1.06095, 1/Adjust = 0.94256 Tue - Vol = 566.000, Days = 1, ADT = 566.000, Adjust = 0.87912, 1/Adjust = 1.13750 Wed Thu - Vol = 562.000, Days = 1, ADT = 562.000, Adjust = 0.88538, 1/Adjust = 1.12946 Fri - Vol = 530.500, Days = 1, ADT = 530.500, Adjust = 0.93795, 1/Adjust = 1.06615 Sat - Vol = 494.500, Days = 1, ADT = 494.500, Adjust = 1.00624, 1/Adjust = 0.99380 Sun - Vol = 363.500, Days = 1, ADT = 363.500, Adjust = 1.36887, 1/Adjust = 0.73053 AADT-154 -- English (ENU) Datasets: Site: Input A: Input B: Survey Duration: Zone: File: Identifier: Algorithm: Data type: Profile: Filter time: Name: Scheme: Units: In profile: MetroCount Traffic Executive Adjusted Flow [CR 303] CR 303 Gardner Lane 2014 Traffic Study 8 - East bound A>B, West bound B>A. - Lane= 2, Added to totals. (/2.000) 0 - Unused or unknown. - Lane= 0, Excluded from totals. 8:00 Wednesday, April 30, 2014 => 15:36 Wednesday, May 07, 2014 CR 30307May2014.EC2 (Plus) U764DSC4 MC56-L5 [MC55] (c)Microcom 190ct04 Event Count (v3.21 - 15275) Axle sensors - Paired (Class/Speed/Count) 8:00 Wednesday, April 30, 2014 => 15:36 Wednesday, May 07, 2014 Default Profile Count events divided by setup divisor Non metric (ft, mi, ft/s, mph, Ib, ton) Events = 6584 / 6584 (100.00%) Day Hits RawVol DayFac MonFac AdjVol - Date 0 Wednesday, April 30, 2014 1 1 747.500 1.000 1.000 747.500 - Thursday, May 01, 2014 2 1 465.000 1.000 1.000 485.000 - Friday, May 02, 2014 3 1 383.000 1.000 1.000 383.000 - Saturday, May 03, 2014 4 1 295.500 1.000 1.000 295.500 - Sunday, May 04, 2014 5 1 401.000 1.000 1.000 401.000 - Monday, May 05, 2014 6 1 487.000 1.000 1.000 487.000 - Tuesday, May 06, 2014 7 Wednesday, May 07, 2014 Total days = 6, Coverage = 1.64% ADT = 466.500, SD = 155.066 AADT = 466.500, SD = 155.066 Weekdays = 4, Coverage = 1.10% AWDT = 530.125, SD = 150.356 AAWDT = 530.125, SD = 150.356 Weekend days = 2, Coverage = 0.55% AWET = 339.250, SD = 61.872 AAWET = 339.250, SD = 61.872 ADT and adjustment factor by month Jan Feb Mar Apr May - Vol = 2799.000, Days = 6, ADT = 1.00000 Jun Jul Aug Sep Oct Nov 466.500, Adjust = 1.00000, 1/Adjust = Dec ADT and adjustment factor by day of week Mon - Vol = 401 000, Days = 1, ADT = 401.000, Adjust = 1.16334, 1/Adjust = 0.85959 Tue - Vol = 487.000, Days = 1, ADT = 487.000, Adjust = 0.95791, 1/Adjust = 1.04394 Wed Thu - Vol = 747.500, Days = 1, ADT = 747.500, Adjust = 0.62408, 1/Adjust = 1.60236 Fri - Vol = 485.000, Days = 1, ADT = 485.000, Adjust = 0.96186, 1/Adjust = 1.03966 Sat - Vol = 383.000, Days = 1, ADT = 383.000, Adjust = 1.21802, 1/Adjust = 0.82101 Sun - Vol = 295.500, Days = 1, ADT = 295.500, Adjust = 1.57868, 1/Adjust = 0.63344 AADT-153 -- English (ENU) Datasets: Site: Input A: Input B: Survey Duration: Zone: File: Identifier: Algorithm: Data type: Profile: Filter time: Name: Scheme: Units: In profile: MetroCount Traffic Executive Adjusted Flow [CR 3000] CR 3000 Old Stone Quary Rd 2014 Traffic Count Study 8 - East bound A>B, West bound B>A. - Lane= 0, Added to totals. (/2.000) 0 - Unused or unknown. - Lane= 0, Excluded from totals. 8:00 Wednesday, April 30, 2014 => 15:25 Wednesday, May 07; 2014 CR 300007May2014.ECO (Plus) GPO8FJPN MC56-L5 [MC55] (c)Microcom 190ct04 Event Count (v3.21 - 15275) Axle sensors - Paired (Class/Speed/Count) 8:00 Wednesday, April 30, 2014 => 15:25 Wednesday, May 07, 2014 Default Profile Count events divided by setup divisor Non metric (ft. mi, ft/s, mph, Ib, ton) Events = 3319 / 3319 (100.00%) Day Hits RawVol DayFac MonFac AdjVol - Date 0 Wednesday, April 30, 2014 1 1 273.000 1.000 1.000 273.00.0 2 1 281.000 1.000 1.000 281.000 3 1 211.500 1.000 1.000 211.500 4 1 161.500 1.000 1.000 161.500 5 1 241.000 1.000 1.000 241.000 6 1 260.000 1.000 1.000 260.000 7 Total days = 6, Coverage = 1.64% ADT = 238.000, SD = 44.992 AADT = 238.000, SD = 44.992 Weekdays = 4, Coverage = 1.10% AWDT = 263.750, SD = 17.462 AAWDT = 263.750, SD = 17.462 Weekend days = 2, Coverage = 0.55% AWET = 186.500, SD = 35.355 AAWET = 186.500, SD = 35.355 ADT and adjustment factor by month Jan Feb Mar Apr May - Vol = 1428.000, Days = 6, ADT = 1.00000 Jun Jul Aug Sep Oct Nov - Thursday, May 01, 2014 - Friday, May 02, 2014 - Saturday, May 03, 2014 - Sunday, May 04, 2014 - Monday, May 05, 2014 - Tuesday, May 06, 2014 Wednesday, May 07, 2014 238.000, Adjust = 1.00000, 1/Adjust = Dec ADT and adjustment factor by day of week Mon - Vol = 241.000, Days = 1, ADT = 241.000, Adjust = 0.98755, 1/Adjust = 1.01261 Tue - Vol = 260.000, Days = 1, ADT = 260.000, Adjust = 0.91538, 1/Adjust = 1.09244 Wed Thu - Vol = 273.000, Days = 1, ADT = 273.000, Adjust = 0.87179, 1/Adjust = 1.14706 Fri - Vol = 281.000, Days = 1, ADT = 281.000, Adjust = 0.84698, 1/Adjust = 1.18067 Sat - Vol = 211.500, Days = 1, ADT = 211.500, Adjust = 1.12530, 1/Adjust = 0.88666 Sun - Vol = 161.500, Days = 1, ADT = 161.500, Adjust = 1.47368, 1/Adjust = 0.67857 May 29, 2014 Garfield County Glenn Hartmann Garfield County Community Development Department RE: Speakman - GAPA 7835 Dear Glenn, Vegetation Management The Noxious Weed Management Plan and Reclamation Plan are acceptable. This facility is on an existing pad, therefore all reclamation issues fall under the jurisdiction of the Colorado Oil and Gas Conservation Commission. Please let me know if you have any questions. Steve Anthony Garfield County Vegetation Manager 0375 County Road 352, Bldg 2060 Rifle, CO 81650 Phone: 970-945-1377 x 4305 Fax: 970-625-5939 Glenn Hartmann From: Morgan Hill Sent: Thursday, May 29, 2014 11:04 AM To: Glenn Hartmann Subject: Speakman A Ursa Injection Well Referral Comments Hi Glenn, My comments on the Speakman A Ursa Injection Well are as follows: Air quality: o Permitting requirements seem to be fully covered, which only include the tank battery. o Thank you for acknowledging that Ursa will apply appropriate controls to minimize potential impacts to air quality and nuisance conditions. Please continue to maintain strict controls to minimize impacts to adjacent lands due to the close proximity to occupied structures. o Also due to the close proximity to occupied structures, Ursa should be careful to minimize dust and other air emissions in the construction of pipelines connecting to the injection well when those are constructed. Water Quality: o There are multiple draws in the proximity to the existing and proposed well pad which have the potential to transport pollutants to the Colorado River as it is located fairly close. From my observations, the applicant does have an adequate SWMP and SPCC plan; however, I once again encourage strict adherence to the controls mentioned in both of these plans to minimize potential impacts. Safety and Welfare: o We appreciate the attempts to minimize truck traffic in both the construction and operation phases of this project. Since trucks will be traveling along roads used by residents of Battlement Mesa, Ursa employees and their sub -contractors should be sure to use caution and reduce speeds for the safety of pedestrians and other road users. From: Glenn Hartmann Sent: Thursday, May 29, 2014 8:57 AM To: Morgan Hill Subject: RE: Referral Comments Hi Morgan: Thanks for your follow-up. I'm working on that file this morning and plan on presenting a staff report/recommendation to Tamra this afternoon, so today certainly works for your comments. If you can get them to me by lunch or early afternoon that would be great, otherwise as soon as possible. Thanks in advance for your input. Glenn. Glenn Hartmann Community Development Department From: Morgan Hill Sent: Wednesday, May 28, 2014 2:28 PM To: Glenn Hartmann Subject: Referral Comments Hi Glenn, Today has been a bit on the busy side and hasn't left time for me to get my comments in for the Ursa Injection well - would tomorrow be OK? 1 COLORADO PARKS & WILDLIFE 6060 Broadway • Denver, Colorado 80216 Phone (303) 297-1192 cpw.state.co.us 05-25-14 To: Glenn Hartmann Garfield County Community Development Department 108 8th Street, Suite 401, Glenwood Springs, CO 81601 RE: GAPA - 7835 Thank you for the opportunity to comment on the proposed injection well facility to be located 0.75 miles southwest of the Battlement Mesa Community (Section 24, T7S, R96W). Colorado Parks and Wildlife (CPW) has a statutory responsibility to manage all wildlife species in Colorado; this responsibility is embraced and fulfilled through the CPW's mission to protect, preserve, enhance, and manage the wildlife of Colorado for the use, benefit, and enjoyment of the people of Colorado and its visitors. We encourage Garfield County to afford the highest protection for Colorado's wildlife species and habitats through the development and implementation of management actions combined with the use of best management practices (BMPs) to protect wildlife and their habitats. The project location is utilized year-round by many species of game and non -game wildlife. The site lies within an area mapped by the CPW as mule deer severe winter range and elk winter concentration range. Additionally, the proposed site lies less than a '/ mile from the Colorado River in an area of critical habitat for four federally listed fish species. In June 2011, Ursa Operating Company (formerly Antero Resources) entered into an agreement with the Colorado Parks and Wildlife (CPW) known as the Battlement Mesa Wildlife Mitigation Plan (BMWMP). This document was intended to provide guidance in the development of the Antero's natural gas resources in the Battlement Mesa area so that impacts to local wildlife would be minimized or mitigated. Since the proposed site is within the boundaries of the established BMWMP, the CPW recommends that the 2011 WMP is utilized during the planning and development of this project. The CPW's chief wildlife concern is the increase in disturbance to wildlife (particularly during the winter months) caused by water trucks delivering produced water to the facility. By adhering to the agreed upon Best Management Practice (BMP) of limiting truck traffic to the hours of 10 am - 3 pm when and where possible, negative impacts to big -game can be greatly reduced. Also, by following the recommended BMP of utilizing buried waterlines to transport fluids to the facility, traffic disturbance concerns can be virtually eliminated. STATE OF COLORADO John W. Hickenlooper, Governor • !Wks King, Executive Director. Department of Natural Resources Bob D. Broscheld, Director, Colorado Parks and Wildlife Parks and Wildlife Commission: Robert W. Bray • Chris Caetilian, Secretary • Jeanne Home BB Kane, Chair • Gaspar Penicone • James Prbyl • John Singletary Nark Smith, Vice -Chair • James Vigil • Dean Wingfield • Michelle Zimmerman Ex Officio Members: Nike King and John Salazar i CPW recommends that sound mitigation be used for any compressors or injection pumps associated with the facility and its operations. CPW expects that sound mitigation measures would be consistent with the 800 series COGCC Rules for aesthetic and noise control. Finally, in accordance with COGCC Rule 1204 a-1, the CPW recommends that bear - proof dumpsters and trash receptacles be utilized for all food -related trash on location to minimize nuisance bear issues in the area. If you have any questions, please feel free to contact Scott Hoyer, District Wildlife Manager for Parachute at 970-250-0873. JT Romatzke Area Wildlife Manager Colorado Division of Wildlife Glenn Hartmann From: Glenn Hartmann Sent: Friday, May 30, 2014 3:07 PM To: Glenn Hartmann Subject: Small Injection Well LUP From: Hoyer - DNR, Scott [mailto:scott.hoyer@state.co.us] Sent: Friday, May 30, 2014 2:22 PM To: Glenn Hartmann Subject: Re: Small Injection Well LUP Hi Glenn, Our phone discussion yesterday about restricting vehicle traffic to between the hours of 10 am to 3 pm got me thinking about our WMP with Antero (now Ursa). I re -read the WMP and it states that well pad visits during the production phase will be limited, when and where possible, to the hours of 10 am to 3 pm to minimize impacts to wildlife unless operational concerns warrant visits outside of this time -frame. Looking at the comment letter that we submitted, I think that it gives the impression that our WMP agreement completely restricts traffic to this 5 -hour time -frame. I just wanted to clarify that the language of limiting traffic time- frames "when and where possible" was part of the agreement. Please let me know if we need to submit a revised letter clarifying this point or if you have need more information. I can be reached via email or at 970-250-0873 Thanks much Scott Hoyer District Wildlife Manager, Parachute (970) 250-0873 jr4 own. of7rckut e 222 Grand Valley Way Parachute, Colorado 81635 (970) 285-7630 Stuart S. McArthur, Town Administrator May 9, 2014 Garfield County Building and Planning Department ATTN: Glenn Hartmann 108 8th Street, Suite 401 Glenwood Springs, CO 81601 SUBJECT: SPEAKMAN URSA "A" INJECTION WELL - GAPA-7835 The purpose of this letter is to respond to your Referral Form dated April 30, 2014, for File Number GAPA - 7835. The Town of Parachute has no issues regarding granting this application. If you have any additional questions or concerns, please contact me at 970-285-7630. Sincerely y Stuart S. McArthur Town Administrator SSMc f Glenn Hartmann From: Franco - DNR, Ivan [ivan.franco@state.co.usj Sent: Friday, May 23, 2014 8:45 AM To: Glenn Hartmann Subject: Speakman Ursa A Injection Well Mr. Hartmann, Thank you for the opportunity to review the above referenced referral, however the Colorado Division of Water Resources does not have any comments to offer at this time. Sincerely, Ivan Franco, E.I.T. Water Resources Engineer Water Supply Team P 303.866.3581 x8243 I F 303.866.3589 1313 Sherman Street, Room 818, Denver, CO 80203 Ivan.Franco@state.co.us 1 www.water.state.co.us 1