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HomeMy WebLinkAbout6.0 Staff Report & Attachments 04.20.2015Director Decision 4/20/15 File No. GAPA-8215 GH PROJECT INFORMATION AND STAFF COMMENTS REQUEST Administrative Land Use Change Permit for Storage Facilities 604-12-13 and 697-16-16. APPLICANT/PROPERTY OWNER OXY USA WTP LP ASSESSOR'S PARCEL # 2169-214-00-026 PROPERTY SIZE The facilities are located within on overall 7,732 acre parcel owned by the Applicant. LOCATION The proposed uses are located approximately 20 miles north of the Town of DeBeque on private roads off of County Roads 204 and 213. Storage Site 604-12-13 is located in Section 4, T6S, R97W and Storage Site 697- 16-16 is located in Section 16, T6S, R97W. ACCESS EXISTING ZONING The facilities are accessed by private roadways off of County Road 204 and 213. The property is Resource Lands Plateau (RLP) I. GENERAL PROJECT DESCRIPTION The Applicant is requesting approval for two Storage Sites for the storage of various equipment and supplies which may include separators, natural gas production equipment, fuel storage, piping, piping connections, well head equipment, ladders, secondary containment parts and storm water control supplies. Both Storage Sites have previously been developed and improved as well pads. Storage Site 604-12-13 is located within a 10.6 acre pad and Storage Site 697-16-16 is located within a 4.8 acre pad. The sites will generally be unmanned with staff only accessing the sites for loading and unloading activities. Access to the sites is by approximately 10 miles of private roadways past the end of County Road 213. No additional site disturbance is proposed and the sites are covered by existing COGCC bonds for reclamation. Existing storm water management improvements 1 including berms and settlement ponds are in place and will require ongoing maintenance. Vicinity Map 604,12-13 Annex 5lorape Arm Proposed Storage Areas Access Road Map RHsol Hew 3 2414 Weird 1-cai17. Cdat 0 45 1 15 nxo 1S °95V . PNne+.a 144494 Ando SloropArsaAnsmaPiaa41 �.m l,rowt Hd Pak Hood Y' • Gsa+ Neale /lard 4%4 Pawd P.+4e Rod • 111.11.• 1.1 The Application includes various roadway assessments including the private roads serving the sites. The assessments provide evaluations of the roadway in accordance with the County's Roadway Waiver Policy. Both sites may include creation of a gravel pad (approximately 25 ft. x 25 ft.) for installation of fuel storage with related containment pursuant to SPCC Plan and State requirements. 2 II. LOCATION - SITE DESCRIPTION The sites are located central to OXY's operations and are accessible to numerous other oil and gas facilities including well pads, pipelines, water impoundments, and similar operations. The sites are generally devoid of vegetation and reflect evidence of ongoing weed management. They are improved with existing compacted dirt as a driving surface. They are graded and generally level. The 604-12-13 site is has steep slopes descending on both the east and west sides of the site. The access to the site is from the north and a secondary pad (not part of the storage facility) is located to the south. The 697-16-16 site is located on a large bench with sleep slopes down to the southeast and a vertical cut slope above the site. Natural drainages are located below each of the sites and Targe stabilized slopes comprised largely of natural soils and rock exist below each site. The slopes are devoid of any vegetation. The surrounding area has typical scrub — shrub native vegetation including sage brush and gambel oak. III. PUBLIC COMMENTS AND REFFERAL AGENCY COMMENTS 1. 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 and pursuant to Section 4-101(E)(5) the Director has made a determination that constructive notice was completed. 2. Garfield County Consulting Engineer, Chris Hale, Mountain Cross Engineering: • Noted the geologic hazard reports determination that the sites are subject to rockslide hazards and the need to address mitigation of offsite geohazards. • Indicated that steep slopes should be mitigated to prevent sloughing and erosion. • Noted that the application materials recommended ditch and culvert maintenance on County Road 213 and minor improvements at the intersection of County Road 204 and 213. 3. Garfield County Road and Bridge Department, Wyatt Keesbery, District 2 Foreman: Provided verbal comments that the Road and Bridge Department works closely with OXY on maintenance issues on County Road 213. He indicated that they have not undertaken any maintenance work yet this year. 4. DeBeque Fire Protection District, Mike Harvey, District Fire Chief: Indicated that the District had no comments or objection to the changes at this time. 3 STORAGE SITE 697-16-16 SITE PLAN & GRADING BMP'S 5. Colorado Parks and Wildlife, JT Romatzke, Area Wildlife Manager: • Noted that no significant impacts to wildlife are expected provided that their recommendations are incorporated into the project. • Indicated concerns with nighttime lighting (no lighting is proposed). • Requested use of bear proof trash containers. • Indicated that newly exposed soils should be re -vegetated as soon as possible. • Use of weed free seed mixes for re -vegetation. • Maintaining low speed limits less than 25 mph to avoid wildlife collisions 6. Garfield County Vegetation Manager, Steve Anthony: Provided comments that the Weed Management Plans are acceptable, that reclamation is under the jurisdiction of COGCC, and that implementing the Best Management Practices noted in the Application in 4 regards to storm water pollution prevention and erosion and sediment control are encouraged. lierasffejtor *..A*. Mr11M•s." Mir**,~ iM44 vu.ravkM s' 1.141. E s v.. 7. Garfield County Oil and Gas Liaison, Kirby Wynn: Indicated that he had no issues or recommendations. 8. The Applicant provided a response letter to the referral comments dated 4/13/15 a copy of which is attached with this report. The letter notes the detailed analysis on rock fall mitigation in the application submittals and clarifies area of compliance in place regarding the Colorado Parks and Wildlife recommendations. 5 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 in particular Article 3 standards for the Resource Lands Zone District. The Comprehensive Plan 2030 designates the site as Resource Production/Natural which is described to include land used for oil and gas production and support buildings and facilities. Excerpts from the Comprehensive Plan are provided below: Section 8 — Natural Resources 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. Section 9 — Mineral Extraction Goals 2. Ensure that mineral extraction activities mitigate their effects on the natural environment, including air quality, water quality, wildlife habitat or important visual resources. Policies 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 Application provided information on neighboring land uses which are primarily ranching and oil and gas development. The Application demonstrates general compatibility with adjoining uses and general conformance with the Comprehensive Plan. 6 PIPELINES = Purple, Green and Tan Lines OTHER ACTIVITES (INCL. WELLS) = Red Triangle$ OIL AND GAS ACTIVITY AND PIPELINE MAPPING Proposed Storage Facilities 7-104 & 105: Source of Water & Waste Water Systems The Application represents that the facilities will operate with only occasional staff activities. The use will be served by provision of water in individual staff vehicles and provision of portable toilets within close proximity to the sites. 7-106: Public Utilities No public utilities are needed for operation of the facility. 7-107: Access & Roadways The Applicant accesses the site from County Roads 204 and 213. The Applicant's Traffic study identifies a minimal amount of traffic that will be associated with the facilities. The study indicates that the proposed storage facilities will "reduce cumulative impacts of natural gas operations by reducing the need to haul equipment in and out of the field on public roadways". Minor maintenance type improvements (i.e. ditch cleaning, repair of culvert erosion, surfacing at intersection turning radius) were recommended. The Application also includes extensive analysis of the OXY private roadway system. The analysis supports granting of a waiver from the Table 7-107 Roadway Standards and includes information on the road geometry (turning radii), safety/structural issues, maintenance, and travel demand. The reports include representations from a licensed professional engineer that the roadway system is adequate to serve the sites. The submittals meet the requirements of the Roadway Waiver Policy 01-14. Typical Access Road Upper Mesa Road Waivers from grade (mountain roadway section), cross sections (related to ditches and shoulders), turn radius (mountain roadway section related to switchbacks), and lane width are being requested. The Applicant will be upgrading the access immediately adjacent to the 604-12-13 site to reduce the road grade to 12% or less to be code compliant at that location. Best management practices are also recommended in the Roadway Standards Assessment prepared by Olsson and Associates. These should 8 be included as conditions of approval. The Applicant has provided copies of fugitive dust control plans for the roadway system that include reduced speeds along with application of dust suppressants and watering as necessary. /"11OXY LISA WTI5 i OXY 760 Horizon Drive. Surto 101 likimet Grand Junction. CO 81604 Figre 1 •Overview Map for Garfield County Road Standards Assessment tlpdstad: January 19, acts Gao90 d County Colorado 0.5 d1 0a ti tem T6 Vern. Seas on Cued Sneak Croy Roadway Section a"VMeg Road Segment Roma Segment vemr ROM Sa9ma+0 Pub1c Road 6r..el Pubic Road Pawt Par: Raked N 7-108: Natural Hazards The Application provides an engineering report and analysis on natural hazards prepared by Olsson and Associates. The report indicates that "There is potential for unstable or potentially unstable slopes and associated rock fall and slides to impact the development". The report recommends that a qualified professional engineer make a final determination of how to best mitigate these risks. A subsequent report prepared by Rock Solid Solutions titled Rockslide and Landslide Assessment Memorandum 9 (dated 1/29/15) identifies a number of recommendations including setbacks and off- sets from the perimeter of cut slopes which are intended to mitigate potential hazards. The report includes a determination that, "The risk to personnel and facilities to rockfall and landslide hazards on the two (2) storage pads is minimal". The report overview indicates this is based on the design, construction, location and utilization of the facilities in conjunction with the frequency of exposure to personnel. The recommendations from the Olsson report and the Rock Solid Memorandum should be reflected on the site plans. Storage Site 604-12-13 Cut Slope 7-109: Fire Protection The Applicant's Emergency Response Plan includes sections on fire response and prevention. The sites are managed to remove or eliminate weeds or vegetation from the active storage areas that may become fire hazards/fuels. Referral comments from the DeBeque Fire Protection District did not indicate any concerns with the storage proposals. 7-201: Agricultural Lands With no new disturbed areas no additional impacts on agricultural or ranching lands are anticipated. The sites are not currently fenced and the proposed facilities do not propose any changes. 10 7-202: Wildlife Habitat Areas The Applicant has provided a Wildlife Health Standards Analysis and an Environmental Impact Report for both of the sites, completed by ERO Resources Corp. each dated 10/23/14. Key findings of the reports are summarized below: • The sites were either in close proximity to Greater Sage Grouse Habitat or mapped by CPW within habitat areas. However no visible evidence such as scat, secal droppings, tracks or feathers were observed during the consultants site visit and the sites were noted to not include any suitable Greater Sage Grouse Habitat. • No impacts on general wildlife are anticipated as typically they have adapted to human disturbances. • No raptor nests were observed in the vicinity of the sites. • No wetlands are located within the project areas. • Three weeds species were observed on the sites. Weed management on the site is conducted pursuant to the Applicant's Weed Management Plan. • The reports include recommendations for mitigation of impacts including additional weed surveys, reseeding any new or temporarily disturbed areas and slow speed limits. An map excerpt from the Garfield Count Greater Sage Grouse Management Plan is provided below and reflects the general relationship between the sites and the Private Lands Management areas. The Management plan outlines that for private lands "the principles and policies and best management practices are voluntary but strongly encouraged..." The plan continues that Figure 5 (see below) is a consultation map where Applications within the management areas are encouraged to consult with a professional biologist regarding the nature of the habitat and potential mitigation needs. Referral comments from the CPW did not identify any specific concerns or recommendations related to habitat mitigation associated with the Greater Sage Grouse. Compliance with the ERO Consultants recommendations and the CPW recommendations should be included as conditions of approval and should address any broad habitat and wildlife compatibility concerns. 11 I flIJ EXCERPT FROM GARFIELD COUNTY GREATER SAGE GROUSE MANAGEMENT PLAN FIGURE 5: GREATER SAGE GROUSE MANAGEMENT AREAS Storage Facility Locations Study Area Bou -1,1 y Parcel Boundary • Public Lands Mangement Area EdMunicipal Boundary County Boundary Interstate 4.1e6 State Highway 12 7-203: Protection of Water Bodies No wetlands are located on either site. The 697-16-16 site is 713 ft. from the nearest live stream and the 604-12-13 site is 1,175 ft. from the nearest live stream (Cascade Creek). The Application includes the Storm Water Management Plan and state permits. Compliance with the Storm Water Management Plan and provisions of the SPCC Plan (related to any fuel storage) should be a condition of approval. EXISTING DRAINAGE IMPROVEMENTS SLOPES ADJACENT TO THE 604-12-13 SITE 7-204: Drainage and Erosion (Stormwater) The Application contains detailed grading and drainage plans prepared by licensed professional engineers ( D.R. Griffin & Associates dated 1/2/15). The reports contain drainage calculations, drainage system recommendations, maintenance recommendations, and plans with BMP recommendations. The reports include the following recommendations at various locations on the two sites: • Installation of check dams and wattle Togs as needed. 13 • Regular maintenance of sediment traps. • Installation and maintenance of erosion control blankets and hydro -mulch steep areas until sufficient vegetation is established if erosion occurs. • On Site 604-12-13 a sediment trap is identified to need re -grading and maintenance to approximate design contours on a regular basis as needed and installation of a culvert if one does not exist just below the sediment trap. • Install and maintain perimeter wattle logs using "j -hook" methods at the edge of disturbance if needed. The analysis in the report indicates that "While additional erosion mitigation measures are not expected to be needed, measures shall be taken if erosion issues appear." 7-205 Environmental Quality Protection of Environmental Quality is addressed through various plans and mitigation recommendations including the Grading and Drainage Plans, SPCC Plans, Storm Water Management Plans, Fugitive Dust Suppression Plans, Geo -Hazard Analyses and Plans, Weed Management Plans, and Wildlife Environmental Impact Reports and recommendations. 7-206: Wildfire Hazards The sites are located in areas mapped with moderate to high wildfire hazards. The Applicant's Emergency Response plan addresses fire response and prevention measures. Compliance with weed management plans and providing a non -vegetated buffer at the perimeter of the sites is recommended to limit wildfire fuels. Locating potential fuel storage away from the perimeter of the site is also recommended. 7-207 Natural and Geologic Hazards The Application provides extensive reports addressing Geologic Hazards (see Staff comments in Section 7-108). While potential for rock fall is noted the Application includes recommended setbacks from areas of potential hazards and a finding that the site is suitable for the proposed uses and that risk to personnel is minimal (Rock Solid Solutions Rock Fall and Landslide Assessment 1/29/15). 7-208: Reclamation The site is subject to existing reclamation plans and is represented to be covered by an existing reclamation bond with the COGCC. Reclamation standards and provisions are addressed in several sections of the submittals and include contouring, re -vegetation, use of native and desirable seed mixes, use of weed free mixes, and meeting a standard of 70% cover within two growing seasons. 14 WILDFIRE HAZARD MAPPING GARFIELD COUNTY GIS DEPARTMENT Green = lower hazard Yellow = moderate hazard Orange/Red = higher hazard APPROXIMATE LOCATIONS OF STORAGE SITES 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. The site plan should be updated to provide general patterns for vehicular circulation compatible with the scale of vehicles and equipment being moved and location for the potential fuel storage. 7-303: Landscaping Landscaping submittals and standards are not applicable to the industrial proposal. 7-304: Lighting No lighting is proposed for the facilities. 7-305 Snow Storage Adequate space exists on each site for location of snow storage areas. 15 7-306 Trails Trails standards are not applicable based on the industrial use. 7-1001 INDUSTRIAL USE STANDARDS The Application represents that the facility will comply with all the Industrial Use Standards contained in Section 7-1001. The Application contains a variety of documents to support compliance and the following summary addresses key issues. • The facility will meet all setback requirements. • The proposed facilities are distant from any neighboring properties and effectively screened by topography and distance. • Explosive and hazardous material will not be store on the site with the exception of the potential fuel storage on a 25 ft. by 25 ft. gravel pad. • Hours of operation will be on an intermittent as needed basis, 7 days a week. A waiver from the standard limit on hours of operation is supported. • All storage will be in accordance with all applicable state and federal regulations. • Noise will meet light industrial standards generally consistent with truck traffic. No noise generating equipment is proposed. 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 OXY USA WTP LP Storage Facilities 697-16-16 and 604-12-13 are 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 adoption of conditions and the granting of a waiver from Section 7- 107 Roadway Standards related to road grade, lane width, cross section details, and curve radius consistent with the roadway assessments by Olsson & Associates and Rock Solid Solutions that found the roadway to be adequate for the proposed use, the Application will adequately met the requirements of the Garfield County Land Use and Development Code, as amended. 6. That with the adoption of conditions and the granting of a waiver from Section 7- 1001 to allow 7 day a week operation of the Storage Facilities based on the minimal 16 impacts of the proposed uses and the remote location of the facilities, and the overall size of the Applicant's property, the Application will adequately met the requirements of the Garfield County Land Use and Development Code, as amended. 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 OXY USA WTP LP 697-16-16 and 604-12-13 Storage Facilities 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 an updated site plan that shall include the following: a. Delineation of rock fall hazard mitigation setbacks and off -sets from steep slopes and cut slopes consistent with the recommendations of the Rock Solid Solutions Rockslide and Landslide Assessment Memorandum (dated 1/29/15) b. Delineation on the site plan or inclusion of site plan notes setting forth general circulation patterns for vehicle access and storage areas on the site. c. Indication of the approximate locations for potential 25 ft. by 25 ft. fuel storage pads, in locations away from the perimeter of the site or notes addressing location criteria. Other Conditions 4. The Applicant shall comply with all recommendations contained in the Drainage Reports including the proposed BMP Maps including the re -grading of sediment traps to design contours on a regular basis as needed and installation of a culvert as needed below the sediment trap. 5. The Applicant shall maintain all elements of the roadway access system to the current standards reflected in the Olsson Roadway Standards Assessment (dated January 2015) and the Rock Solid Solutions Roadway assessment memorandum (dated 2/4/15) to ensure that the roadway continues to be operated adequately to serve the proposed uses. The Applicant shall implement the Best Management Practices for each roadway segment as set forth in the Olsson Roadway Standards Assessment. 6. The Applicant shall coordinate with the Garfield County Road and Bridge 17 Department any maintenance issues associated with culvert erosion, ditch cleaning, and wheel tracking/turning impacts along County Road 213 as noted in the Applicant's Traffic Report. 7. The facilities shall maintain compliance with CDPHE Storm Water Management Permits, Grading and Drainage Plans, SPCC Plans and Reclamation Plans, Fugitive Dust Management Plans, and Weed Management Plans for the site. 8. The Applicant shall maintain in place reclamation plans/requirements and reclamation bonds with the COGCC for the sites. The Applicant shall provide the County with copies of any extensions granted by COGCC for reclamation. 9. The Applicant shall comply with the referral comments from Colorado Parks and Wildlife (CPW) dated 4/5/15 and the recommendations contained in the Applicant's Environmental Impact Analysis and Wildlife Health Standards Analysis prepared by ERO Resources Corp., dated October 23, 2014. 18 VIEWS OF THE SITE AND ACCESS ROADWAY 697-16-16 Facility 19 604-12-13 Facility Access Roads at the 604-12-13 Facility 21 April 3, 2015 Mr. Glenn Hartman Garfield County Planning 108 8th Street, Suite 401 Glenwood Springs, CO 81601 RE: Review of OXY Storage Facilites: GAPA-8215 Dear Glenn: MOUNT/MN CROSS ENGINEERING, INC. Civil and Environmental Consulting and Design This office has performed a review of the documents provided for the Administrative Land Use Change Permit Application of the OXY Storage Facilities. The submittal was found to be thorough and well organized. The review generated the following comments: 1. The geologic hazard report mentions that both sites may be subject to rock fall, landslides, and debris flow hazards. From the report, these emanate from offsite. The Applicant provides a report from an engineer concerning rockslide and landslide hazards but this report appears to address these hazards within the storage facilities. The Applicant should address mitigation of offsite geohazards. 2. Within each proposed storage yard are near vertical slopes that could pose a hazardous condition, at a minimum revegetation would be nearly impossible. These steep slopes should either be laid back to stable slopes and revegetated or mechanically stabilized to prevent sloughing and erosion. If they are to be mechanically stabilized, consideration should be given to mitigate a falling hazard for personnel. 3. The application materials recommend maintenance on the CR 213 ditches and culverts that have been eroded. 4. The application materials recommend additional pavement at the intersection of CR 204 and CR 213. Feel free to call if you have any questions or comments. Sincerely, Mountain Cross Engineering, Inc. Chris Hale, PE 826 1/2 Grand Avenue, Glenwood Springs, CO 81601 P: 970.945.5544 F: 970.945.5558 www.mountaincross-eng.com Glenn Hartmann From: firechief@debequefire.org Sent: Wednesday, March 25, 2015 11:35 AM To: Glenn Hartmann Subject: 697-16-16 & 604-12-13 RE: OXY Starge Facilities Administrative Land Use Change Permit The De Beque Fire Protection has reviewed the administrative land use change request 697-16-16 and 604-12-13 and has no comments or objections to the changes at this time. Thank you. Mike Harvey District Fire Chief De Beque Fire Protection District 970-283-8632 P.O. Box 380 De Beque, CO 81630 1 April 6, 2015 COLORADO Parks and Wildlife Department of Natural Resources Northwest Regional Office 711 Independent Avenue Grand Junction, CO 81505 Glenn Hartmann Garfield County Building and Planning Department 108 8th Street, Suite 401 Glenwood Springs, CO 81601 RE: Oxy Storage Facilities (697-16-16 Ft 604-12-13) Dear Mr. Hartmann: Colorado Parks and Wildlife (CPW) would like to thank you for the opportunity to work with Garfield County in the review of the Oxy Storage Facilities 697-16-16 &t 604-12-13. The two proposed storage areas are located within sites that are 10.6 acres and 4.8 acres. Site 604-12-13 is located at NW 1/4, Section 4, T6S, R97W, 6th PM The 604-12-13 site location was previously developed as a COGCC permitted -well pad site. The well pad was constructed; however, the wells were never drilled. At this time the Applicant does not anticipate drilling on the site location. Site 697-16-16 is located at NE 1/4, Section 16, T6S, R97W, 6th PM. The 697-16-16 site location was previously developed as a COGCC permitted -well pad site and currently has 10 producing wells located on the lower tier of the well pad. The storage area will be located at the upper tier of the pad. No significant impacts to wildlife are anticipated if the following recommendations are incorporated into the development of this project: Bob D. Broscheid, Director, Colorado Parks and Wildlife • Parks and Wildlife Commission: Robert W. Bray, Chair • Chris Castilian, Vice Chair Jeanne Horne, Secretary • John Howard, Jr. • Bill Kane • Date Pizel • James Pribyl • James Vigil • Dean Wingfield • Michelle Zimmerman • Alex Zipp • The application states that lighting and utilities will not be installed. In the event lighting is required, CPW recommends night lighting should be of the full -cutoff type and/or timed or otherwise minimized to reduce disruption to wildlife. • Black bear are commonly found in the area during the spring/summer months. To reduce the likelihood of bears becoming habituated to garbage and other attractants, trash should be stored in locking, bear -proof containers emptied on a regular basis. • Following the completion of construction activities, newly exposed soils should be revegetated as soon as possible to prevent erosion and to reduce the likelihood of non-native plants becoming established in the area. Seed mix used for revegetation should be certified as weed -free and consist of native seeds from plants that are common to the area. • To reduce the likelihood of truck - wildlife collisions, proper speed limits (< 25 mph) should be posted and enforced on all service roads. • Fencing around the pit should consist of a minimum of a 7 -foot chain-link fence capable of preventing elk and deer from entering the pit; concurrently it should have a small mesh type of fencing along the bottom of the fence (buried one -foot below grade level and extending a minimum of two -feet above grade) capable of preventing small animals from entering between the gaps (gaps should be no larger than three - inches). Colorado Parks and Wildlife appreciates the opportunity to work with Garfield County on this and other projects for the benefit of wildlife. If you have any questions please contact Albert Romero, District Wildlife Manager, at 970-216-3847. Sincerely, JT Romatzke Area Wildlife Manager cc: Ron Velarde, NW Regional Manager Michael Warren, Energy Liaison Albert Romero, District Wildlife Manager File April 16, 2015 Garfield County Glenn Hartmann Garfield County Community Development Department RE: Oxy Storage Facilities GAPA-8215 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; however staff does have concerns about the cut slopes that have not been reclaimed. The applicant is encouraged to implement the Best Management Practices detailed in their permit, for the bare slopes, in regards to stormwater pollution prevention and erosion and sediment control. 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: Kirby Wynn Sent: Friday, April 10, 2015 8:26 AM To: Glenn Hartmann Subject: Liaison referral comments for Oxy storage permit application Hi Glenn, I have no issues or recommendations to provide regarding the Oxy permit referral. Looks OK. --Kirby Kirby Wynn Oil and Gas Liaison Garfield County Community Development Dept 0 (970) 625-5905 C (970) 987-2557 1 April 13, 2015 Garfield County Community Development Department Attention: Glenn Hartman 108 8th St Suite 401 Glenwood Springs, CO 81601 Subject: Administrative Review for OXY USA WTP LP 604-12-13 and 697-16-16 (GAPA 8215) Re: Response to Referral Comments Dear Glenn: The following letter is in response to referral comments for the Storage Sites application. • Response to Chris Hale of Mountain Cross Engineering, Inc. comments 1) OXY adheres to mitigation efforts throughout the Cascade field as describe in the Rockslide and Landslide Assessment Memorandum and the Geologic Hazards Reports. As recommended, OXY attempts to avoid areas with geologic hazards. However, due to the nature of the terrain within OXY production field, avoidance is not always possible. Facilities and access roads are engineered to mitigate potential threats from geologic hazards. OXY adheres to strict safety procedures and personnel training, detailed in the Emergency Response Plan. 2) The proposed site locations have been designed to mitigate any potential threats of rockfalls and landslides to personnel and equipment. Site locations are previously developed and graded with no issues of landslides or rockfalls. Equipment will not be stored directly adjacent to steep slopes. In areas where vegetation is not possible, berms have been established to deter any rockfalls. Both sites have been engineered to reduce impacts from geologic hazards. Mitigations efforts are detailed in the Rockslide and Landslide Assessment Memorandum and Drainage Reports. • Response to Colorado Parks and Wildlife (CPW) comments 1) No lighting will be installed at the proposed site. Temporary lighting is not anticipated to be used at the storage site locations. 2) No trash or bear attractants will be stored at the Storage sites. All food and other waste must be transported off site by personnel. 3) Areas to be re -seeded will be re -seeded immediately following completion of construction activities. A certified weed -free native seed mix will be used to re -seed disturb areas. Oxy adheres to the Oxy Weed Management Plan, which details seed mixes and best management practices. 4) Private access roads have a speed limit of 25 miles or less. Activities will adhere to Oxy policies, including traffic regulations and posted speed limits (25 mph in project area). 5) The proposed use is for two storage sites, not a pit or water storage. Equipment and supplies stored at the site locations will not impact wildlife, as stated in the Environmental Impact Reports. As stated in the application, fencing will not be installed. Thank you and please let me know if you have any questions or require additional information. Sincerely, Katy Middleton Blue Sky Permitting and Planning, LLC