Loading...
HomeMy WebLinkAbout1.0 General Application Materials Index Ursa Operating Company LLC Tompkins Injection Well OA Project No. 014-2878 Article Topic 4-101.A Preapplication Conference Summary 4-118, 202 Waiver Requests 4-203.B.1 General Application Materials 4-203.B.2 Deeds, Easements and Agreements 4-203.B.3 Adjacent Land Owners and Mineral Rights Owners Information 4-203.B.5 Project Description 4-203.C Vicinity Map 4-203.D Site Plan 4-203.E Grading and Drainage Plan 4-203.E.16 Stormwater Management Permit and Plan 4-203.E.18 Reclamation Plan 4-203.E.21 Spill Prevention, Countermeasures, and Control Plan 4-203.G Impact Analysis 4-203.G.3 NRCS Soils Report 4-203.G.4 Geologic and Soils Hazard Report 4-203.G.6 Wildlife and Vegetation Impact Analysis 4-203.G.7 Fugitive Dust Control Plan 4-203.G.7 Sound Study 4-203.L Traffic Study 4-203.M Water Supply and Distribution Plan 4-203.N Wastewater Management and System Plan 7 Standards Analysis 7-107 Access and Roadways Assessment 7-202.C.3 Noxious Weed Plan 7-1003.C Emergency Response Plan Miscellaneous Permits NTC Response Article 4-203.B.1 General Application Materials Ursa Operating Company LLC Tompkins Injection Well OA Project No. 014-2878 Garfield County Community Development Department 108 81h Street, Suite 401 Glenwood Springs, CO 81601 (970) 945-8212 www.garfield-countv.com TYPE OF APPLICATION Ii Administrative Review LAND USE CHANGE PERMIT APPLICATION FORM D Development in 100-Year Floodplain ------ - --D Limited Impact Review D Development in 100-Year Floodplain Variance D Major Impact Review D Code Text Amendment D Amendments to an Approved LUCP D Rezoning OUR DM1R DsuP 0 Zone DistrictO PUD D PUD Amendment D Minor Temporary Housing Facility D Administrative Interpretation D Vacation of a County Road/Public ROW D Appeal of Administrative Interpretation D Location and Extent Review D Areas and Activities of State Interest D Comprehensive Plan Amendment D Accommodation Pursuant to Fair Housing Act D Pipeline Development D Variance D Time Extension (also check type of original application) INVOLVED PARTIES Owner/ Applicant Name: Ursa Operating Company LLC (applicant) on behalf of Thomas Tompkins (o wner) Phone: ( 970 )625-9922 Mailing Address : 792 Buckhorn Drive City: Rifle State: CO Zip Code: 81650 E-mail: rbleil@ursaresources.com; cmascioli@ursaresources .com Representative (Authorization Required) Name: Tilda Evans Phone: ( 970 )263-7800 Mailing Address : 760 Horizon Drive, Suite 102 City: Grand Junction State: CO Zip Code: 81506 E-mail : tevans@olssonassociates .com PROJECT NAME AND LOCATION Project Name: Tompkins Injection Well Assessor's Parcel Number: 2407 -054 -00 -085 ------------ Physical/Street Address: 0269 County Road 309 , Parachute, CO 81635 Legal Description: SESE, Section 5, Township 7 South, Range 95 West, 6th PM Zone District: Rural Property Size (acres): 35 ------------ PROJECT DESCRIPTION Existing Use : Rura l residential and agri cultural Proposed Use (From Use Table 3-403): _1n-'-je_c_tio_n_w_e_11_, s_m_a_u _________________ _ Description of Project: To allow Ursa Operating Company to drill a small injection well on an existing natural gas well pad to dispose of produced water created during Ursa's natural gas exploration and production activities in th e Battlement Mesa field .. REQUEST FOR WAIVERS Submission Requirements Ii The Applicant requesting a Waiver of Submission Requirements per Section 4-202. List: Section: 4-203.J Development Agreement Section : 4-203.K Improve ments Agreement Section: ______________ Section:---------------- >- Waiver of Standards ii The Applicant is requesting a Waiver of Standards per Section 4-118. List: Section: 7-107 , Table 7-107 Roadway Standards Section:---------------- Section: Section:---------------- I have read the statements above and have provided the required attached information which is correct and accurate to the best of my knowledge. Si~ c).-(1-1{ Date OFFICIAL USE ONLY FileNumber: _______ _ Gar.field County PAYMENT AGREEMENT FORM GARFIELD COUNTY ("COUNTY") and Property Owner ("APPLICANT")----------- .....;U;;..;r~s..;;;.a;.....O~p..;;;.e.-ra=t=in"""'g......,;;;;C""'"o""'-m'""'p"""a"'"'n-'-y~L=L""'"C _________________ agree as follows : 1. The Applicant has submitted to the County an application for the following Project: __ _ Tompkins Injection Well 2. The Applicant understands and agrees that Garfield County Resolution No. 2014-60, as amended, establishes a fee schedule for each type application, and the gu idelines for the administration of the fee structure. 3. The Applicant and the County agree that because of the size, nature or scope of the proposed project, it is not possible at this time to ascertain the full extent of the costs involved in processing the application. The Applicant agrees to make payment of the Base Fee, established for the Project, and to thereafter permit additional costs to be billed to the Applicant. The Applicant agrees to make additional payments upon notification by the County, when they are necessary, as costs are incurred. 4 . The Base Fee shall be in addition to and exclusive of any cost for publication or cost of consulting service determined necessary by the Board of County Commissioners for the consideration of an application or additional County staff time or expense not covered by the Base Fee . If actual recorded costs exceed the initia l Base Fee , the Applicant shall pay additional billings to the County to reimburse the County for the processing of the Project. The Applicant acknowledges that all billing shall be paid prior to the fina l consideration by the County of any Land Use Change or Division of Land . I hereby agree to pay all fees related to this application: Billing Contact Person:_C_a_r_i _M_a_s_c_io_l_i ---------Phone: ( 970 ) 284-3244 Billing Contact Address: 792 Buckhorn Drive City: Rifle State: CO Zip Code: _8_1_6_50 ___ _ Billing contact Email : cmascioli@ursaresources.com Printed Name of Person Authorized to Sign: _C_a_r_i_M_a_s_c_io_l_i ---------------- CE> Garfield County STATEMENT OF AUTHORITY Pursuant to C.R .S. §38-30-172, the undersigned executes this Statement of Authority on behalf of Ursa Operating Company LLC a Limited Liability Company (corporation, limited liability company, general pa r tnership, registered limited liability partnership, registered limited liability limited partnership, limited partnership association, government agency, trust or other), an entity other than an individual, capable of holding title to real property (the "Entity"), and states as follows: The name of the Entity is Ursa Operating Company LLC andisformedunderthelawsof _________________________ _ The mailing address for the Entity is----------------------- The name and/or position of the person authorized to execute instruments conveying, encumbering, or otherwise affecting title to real property on behalf of the Entity is Don Simpson. V ice President . Business Development and Robert Bleil, Regulatory & Environmental Manager, and John Doose, Landman and Cari Mascioli, Regulatory Tech The limitations upon the authority of the person named above or holding the position described above to bind the Entity are as follows (if no limitations, insert "None"): None -------------~ Other matters concerning the manner in which the Entity deals with any interest in real property are (if no other matter, leave this section blank):---------------------- EXECUTED this _st_h __ day of January 2016 Signature : ~ ~ Name (printed): _D_o_n_S_1m_p'-s_o_n __________ _ Title (if any): Vi ce President -Business Development STATE OF _C_o_lo_ra_d_o _____ ,) )SS. COUNTY OF Garfie ld ) ------- The foregoing instrument was acknowledged before me this~ day of_Ja_n_u_a~ry ____ __, 20~ by Don Simpson on behalf of Ursa Operating Company LLC a Delaware Corporation Witness my hand and offici t seal. t My comm ission expires: ll ~:{~/~ (Date) KASEY L EUSEA [SEAL] NOTARY PUBLIC STATE OF COLORADO NOTARY Iv 20114045803 MV COMMISSION EXPIRES NOV. 24, 2019 I ·I , 1 January 6, 2016 Mr. Glenn Hartmann 1 • OPERA~NG OJMPM~Y Garfield County Community Development 108 g th Street, Suite 401 · Glenwood Springs, CO 81601 RE : Agent Authorization Dear Mr. Hartmann, I, Thomas L. Tompkins, authorize Ursa Operating Company LLC to act on behalf of and represent me in all matters regarding underground injection control related to land use permitting in Garfield County. Please contact me if you have any questions. Sincerely, Thomas L. Tompkins I, f •• I I Tompkins Pad Property Owner Mobile-Phone : 970-98&-1390... ~ . '/"::/>~~ ~~ ,-.,,. ,· . • CC: John Doose, Ursa Operating Company LLC Rob Bleil, Ursa Operating Company LLC Cari Mascioli, Ursa Operating Company LLC , I . • , I www.ursaresources.cbm '" 1, 1', ' (970) 625-9922 Telephone (970) 62 5-9929 Fax fi?Ursa Ja n uary 6, 2016 Mr. Glenn Hartmann OPERA:TING COtv\PANY Garfield County Community Development 108 8th St r eet, Suite 401 Glenwood Springs, CO 81601 RE : Agent Authorization Dear Mr. Hartmann, Ursa Operating Company LLC authorizes Tilda Evans and Olsson Asso ci at es to act on behalf and represent Ursa Operating Company LLC in all matters related to land use perm itting i n Garfield County. Please contact me if you have any questio ns. Sincerely, Robert Bleil Regulatory/Environmental Manager Office : (970) 625-9922 (Primary) Ext. 303 Direct Line : (970) 329-4373 Cell : (720) 425-0303 Ema il : rbleil@ursaresources .com CC: Tilda Evans , Olsson Associates Cari Mascioli, Ursa Operating Company LLC John Doose, Ursa Operati ng Company LLC www.ursaresources .c om (970) 625-9922 Te lephone (970) 6 2 5-9929 Fa x Article 4-101.A Preapplication Conference Summary Ursa Operating Company LLC Tompkins Injection Well OA Project No. 014-2878 =G Garfield County Community Development Department 108 gth Street, Suite 401 Glenwood Springs, CO 81601 (970) 945-8212 www .garfield-county.com TAX PARCEL: 2407-054-00-085 PROJECT: Ursa Tompkins Pad Injection Well PROPERTY OWNER: Thomas Lynn Tompkins OPERATOR: Ursa Operating Company REPRESENTATIVE: Tilda Evans, Olsson & Associates Rob Bleil, Ursa Operating Company DATE: November 25, 2014 Updated May 20, 2015 Updated December 8, 2015 PRACTICAL LOCATION: Section 5, T7S, R95W, north of County Road 309 (see attached map) ZONING: Rural (R) TYPE OF APPLICATION: Administrative Review -Injection Well , Small (less than 5,000 bbls of on pad tank storage) I. GENERAL PROJECT DESCRIPTION This proposal is for the drilling of an injection well on the proposed Ursa Tompkins Pad . The injection well will be operated by Ursa Operating Company. The pad is proposed to be 2.95 acres in size on an overall site of approximately 35 acres. The facility will have access directly off of County Road 309 with only a short access driveway. The Tompkins pad is planned for 16 wells plus the injection well. The water to be used in the injection well will be piped to the site. Preliminary plans indicate that storage associated with the injection well will be four 500 bbls tanks for a total of approximately 2 ,000 bbls. Equipment on the site will be typical for well production and injection well facilities and will include an approximately 20' x 40' electric pump house and pipelines and related infrastructure. An additional five produced water tanks and one condensate tanks will also be located on the site and would bring the total tank storage on the site to 5,000 bbls. The condensate tank is for the collection of byproducts for sale and will be trucked off-site as typical for production well pads. The overall water storage is less than the 5,000 bbls maximum for a small injection even when considering the additional production water storage not immediately associated with the injection process. The well pad will be developed in accordance with COGCC Permitting requirements. Additional COGCC review and forms for the injection well will be required including Forms 31 and 33 (associated with depth, capacity, and testing) and Form 26 (associated with sources of the injection water). Overall COGCC permitting addresses and monitors water sources, well injection zones and capabilities of the well for injection. In regard to the water issues the Application should demonstrate compliance with all Division Water Resources regulations (including CRS 37-90-137). Information on other typical industrial impacts (noise, traffic, air quality) should all be provided. Stormwater Management Improvements and BMP 's should be addressed and are anticipated to be in place on the well pad. The Application needs to demonstrate compliance with the County Roadway Standards contained in Table 7-107 or request waivers. A traffic analysis to address any off-site and County Road impacts is also needed. Trucking to the site is anticipated to be limited to the construction phase and removal of condensate with hauling of water only occurring during an emergency disruption of pipeline service to the site. The Applicant should confirm that COGCC reclamation bonds will be in place. The site plan mapping should include a surveyed description of the site along with the legal description for the overall tract. The property owner is technically required to be the Applicant so the Application will need to include evidence of authorization for the operator to represent the owners which may include lease agreements and related documentation . The Applicant's representative has Indicated that with recent commencement of construction of the Tompkins Gathering Pipeline by Ursa Operating Company, development of the Tompkins Injection well is moving forward toward submittal. Ursa Operating Company has obtained two other small injection well approvals in the Parachute -Battlement Mesa Area. Both of the other injection well permits were called-up or referred up to the Board of County Commissioners for their review. No additional information or changing conditions have been noted by the Applicant's representative. II. REGULATORY PROVISIONS APPLICANT IS REQUIRED TO ADDRESS • Garfield County Comprehensive Plan • Garfield County Land Use and Development Code o Article Ill, Zoning • Rural Zone District • Use Table 3-403-Injection Well, Small o Article IV, Application and Review Procedures • Section 4-101 Common Review Procedures • Section 4-103 Administrative Review • Table 4-102 Common Review Procedures and Required Notice • Table 4-201 Application Submittal Requirements • Section 4-203 Description of Submittal Requirements o Article VII, Standards • Divisions 1, 2, and 3 as applicable • Sections 7-1001 , Industrial Uses • Article XVI, Definitions -Injection Well, Small Ill. PROCESS The following summary is based on Table 4-102 and other applicable sections of the Land Use and Development Code. 1. Pre-application Meeting 2 . Submittal of Administrative Review Application (3 hardcopies and 1 digital PDF copy) 3. Review by staff for Technically Completeness determination 4 . Submittal of additional application materials if necessary 5. Notice of completeness and scheduling of the Director's Decision 6. Applicant submits additional copies for referrals 7. Applicant completes required public notice (certified mailing) a minimum of 15 days prior to the Director's Decision date. 8 . Staff report prepared 9 . Director's Decision (approval, approval with condition, or denial) 10. Ten day Call-up Period. The Board of County Commissioners can call up the Application or the Director of the Community Development Department, the Applicant or any affected Adjacent Property Owners can request to the Board that the Application be called up. 11. Satisfaction of any conditions of approval required prior to issuance of the Land Use Change Permit. IV. SUBMITTAL REQUIREMENTS Application submittals for an Administrative Review are outlined in Table 4-201. A summary of key submittal topics is provided below: 1. General Application Materials including : Application Form and Fees , Payment Agreement Form, letter of authorization to represent, recorded Statement of Authority, and evidence of ownership such as a deed 2. Authorization for the use -copy of lease documents 3 . Listing and map of property owners within 200 ft. of the overall site. 4. Listing of any mineral rights owners on the site, including names and addresses 5 . Vicinity Map and Site Plan Maps 6. Impact Analysis -Reports 7 . Traffic Analysis -Report 8. Drainage plans, Best Management Practices, and Storm Water Management Plans and Permits 9 . CDPHE Air Quality Permits, Applications , or representations regarding compliance. 10. Article 7 Standards need to be addressed with application formatting that follows each Article 7 Section as applicable recommended . Representations are needed regarding potable water and sanitation needs both during construction and operation . 11. Access Road alignment and Table 7-107 Roadway Standards need to be addressed. The very short access roadway may simplify this topic. However, if needed the policy on roadway waivers is attached . 12. Copies of applicable COGCC Forms and Permits and/or description of the status of the COGCC review and future Forms and Permits that will be required. Clarification of any issues that COGCC review addresses is also appropriate. 13. The site plan and required installations should address truck circulation related to water delivery if any and any pipeline infrastructure for transportation of water to the site. 14. The Application should include information confirming that all pipelines existing or proposed are in compliance with County Regulations. 15. The Application should address any adjustments or COGCC Waivers from setback requirements between the well pad/injection facility and neighboring residences. 16. Geologic Hazards assessments should include the latest information or analysis on potential for seismic activity/hazards associated with the injection well. Waivers from submittal requirements can be requested in writing. The requests should address the Waiver Criteria found in Section 4-202. Any waivers from Standards need to be requested as part of the Application Submittals and need to address the Waiver Criteria found in Section 4-118. The Application submittal needs to include 3 hard copies of the entire Application and 1 Digital PDF Copy of the entire Application (on a CD or USB Stick). Both the paper and digital copies should be split into individual sections. Please refer to the pre-application summary for submittal requirements that are appropriate for your Application. v. APPLICATION REVIEW a. Review by: Staff for completeness and recommendation. Referral agencies for additional technical review b. Public Hearing: ...X... Director (with notice but not a public hearing) __ Planning Commission _ Board of County Commissioners _ Board of Adjustment c. Referral Agencies: May include but are not limited to: Colorado Department of Public Health and Environment (CDPHE), Colorado Division of Water Resources, County Road and Bridge, County Vegetation Manager, County Environmental Health Manager, Fire District, County Consulting Engineer, County Oil and Gas Liaison, Town of Parachute, Battlement Mesa Metro District, Battlement Mesa Homeowners and/or Citizen Groups. VI. APPLICATION REVIEW FEES a. Planning Review Fees : $ 250.00 b. Referral Agency Fees: $ tbd ($ hourly fee for engineer review-will be billed during the course of the project) c. Total Deposit: $ 250.00 (additional hours are billed at$ 40 .50 /hour) General Application Processing Planner reviews case for completeness and sends to referral agencies for comments. Case planner contacts applicant and sets up a site visit. Staff reviews application to determine if it meets standards of review . Case planner makes a recommendation of approval, approval with conditions, or denial to the appropriate hearing body. Disclaimer The foregoing summary is advisory in nature only and is not binding on the County. The summary is based on current zoning, which is subject to change in the future, and upon factual representations that may or may not be accurate. This summary does not create a legal or vested right. This pre-application summary is good for six (6) months from the date of the written summary. Pre-application Summary Prepared by: Glenn Hartmann, Senior Planner Date , ~ 0 E ... ,,.. ] .. E l ""' Garfield County Administrative Review Process (Section 4T103) Step 1: Pre-application Conference •M•V be waived by DlreclDr •Appllca nt has 6 months ta submit appl'catron Step 2: Application Submittal Step 3: Completeness Review •10 business days ID review •If Incomplete, 60 days to remedy defk:lencles Step 4: Schedule Decision Date and Provide Notice •Malled to adjacent propertv owners within 200 t.H!t and mineral owners at least 15 days prior to decision date Step 5: Referral •21 day comment period Step 6: Evalution by Director Step 7: Director'$ Decision •Call -up Period • within 10 days of Director's Decision •Applicant has 1 year to meet any conditions of approva I Policy 01-14 Waivers for Roads and Demonstration of Compliance March 3, 2014 Section 7-107, Access and Roadways, of the Garfield County Land Use and Development Code (LUDC) requires all roads to be designed to provide for "adequate and safe access" and reviewed by the designated County Engineer. The LUDC defines "road" as "a County road, State highway, public road, street or alley, or private thoroughfare which affords primary access to abutting property, excluding a driveway accessing a single property." The LUDC defines "private road" as "a right-of-way constructed, established, owned, and maintained by a private party for access exclusively to private property." Many of the roads in Garfield County are private roads in that they are gated and do not serve the general public and they pre-existed the design currently required by the County's Road Standards as defined in Table 7-107. The LUDC allows for the waiver of specific standards provided that the following criteria have been met: 1) an alternative design achieves the intent of the subject standard to the same or better degree and 2) the proposed alternative will impose no greater impacts on adjacent properties than would occur through compliance with the specific standard (Section 4-118). In applications that include roads that do not meet current County road standards as outlined in Table 7-107, the County has asked that Applicants request a waiver of Section 7-107.F, Design Standards, and include in the Application submittal sufficient information, prepared by a professional qualified in the specific discipline, to demonstrate that they meet the criteria outlined in Section 4-118 for granting a waiver. In doing so, the application must include: A Statement of Adequacy -The evaluation of the existing roadway and waiver will need to include a clear statement that finds that the road will be adequate for the proposed use. This statement must be signed by a professional engineer qualified in traffic engineering and licensed by the State of Colorado. To support this evaluation, the following information will be required to be provided: o Geometry of the road -A description of how the private road does/does not meet the design standards in Table 7-107. This should include a chart that compares the private road design to those standards in Table 7-107, as well as a map that shows the existing road design and highlights those areas that deviate from the standards. A narrative may also be helpful in describing the characteristics of the road as they compare to Table 7-107 design standards. Unless available, this is not intended to imply construction- level drawings. o Safety/Structural Issues -A description of obvious safety and/or structural issues observed and a statement about how these issues will be addressed. o Maintenance -A description of how the road is and/or will be maintained. This should be supported with the submittal of any existing or proposed maintenance agreements for the road sections. o Travel Demand -An accurate count of the existing peak travel demand as well as the Average Daily Traffic on the road. This should also include the types of vehicles that currently use the road as well as the additional amount and type of traffic that the proposed use will generate through all phases of its development. Other Evidence of Compliance. In addition, Sections 7-107.A, B, C, D, and E are required to be addressed, which includes documentation about legal access. Sufficient evidence will be required to be submitted to demonstrate compliance with these sections of the Code. Article 4-118, 4-202 Waiver Requests Ursa Operating Company LLC Tompkins Injection Well OA Project No. 014-2878 760 Horizon Dr., Suite 102 TEL 970.263.7800 Grand Junction, CO 81506 FAX 970.263.7456 www.olssonassociates.com Waiver Requests Ursa Operating Company LLC Tompkins Injection Well Pursuant to Section 4-202 of the Garfield County Land Use and Development Code, Ursa Operating Company LLC (Ursa) requests a waiver for the submittal requirement of a Development Agreement and an Improvements Agreement for the Tompkins Injection Well. Section 4-203.J. Development Agreement A waiver request shall be considered based on the following criteria: 1. The Applicant shows good cause for the requested waiver; Response: Ursa Resources wishes to neither propose a phasing schedule nor extend establishment of vested property rights. 2. The project size, complexity, anticipated impacts, or other factors support a waiver; Response: The proposed injection well facility will be located on an existing COGCC approved natural gas well pad. The well will be drilled as soon as practical after the Land Use Change has been approved. 3. The waiver does not compromise a proper and complete review; and Response: The Administrative Review request can be properly and completely reviewed without a development agreement. 4. The information is not material to describing the proposal or demonstrating compliance with approval criteria. Response: A development agreement is not material to describing the purpose, operation and maintenance of the facility or demonstrating compliance with applicable approval criteria. Section 4-203.K. Improvements Agreement A waiver request shall be considered based on the following criteria: 1. The Applicant shows good cause for the requested waiver; Response: No public improvements are being proposed that would warrant the creation of an improvements agreement. Ursa Operating Company LLC Tompkins Injection Well Waiver Requests Page 2 2. The project size, complexity, anticipated impacts, or other factors support a waiver; Response: As stated above no public improvements are being proposed with this request. 3. The waiver does not compromise a proper and complete review; and Response: The application can be properly and completely reviewed without an improvements agreement. 4. The information is not material to describing the proposal or demonstrating compliance with approval criteria. Response: An improvements agreement is not material to describing the purpose, operation and maintenance of the facility or demonstrating compliance with applicable approval criteria. Pursuant to Section 4-118 of the Garfield County Land Use and Development Code, Ursa requests waivers for the following standards for access and roadways for the Tompkins Injection Well. Section 7-107 Access and Roadways F. Design Standards. Roadways, surfaces, curbs and gutters, and sidewalks shall be provided as follows (see Table 7-107: Roadway Standards): A waiver of standards request shall be considered based on the following criteria: 1. Achieves the intent of the subject standard to the same and better degree than the subject standard: Response: The access road to the Tompkins well pad does not meet the standards for ROW width, shoulder width, ditch width, cross slope, and shoulder slope for a semi primitive road as described in Table 7-107. The access road is approximately 175 feet long from CR 309 to the Tompkins well pad. The intent of the minimum ROW is to make sure that there is sufficient area for the road, shoulders and ditches. The access road is actually a private driveway 29 to 52 feet wide. The general public is not invited or permitted to use the road. There are no shoulders present, however, the road width exceeds the minimum requirements for a semi primitive road. There is sufficient width to allow for two-way traffic. Roadside ditches were not constructed. The existing roadway allows for storm drainage to sheet flow across the roadway. The road is regularly maintained by Ursa as mandated by the Water Injection Well Lease and Surface Use Agreement. The existing cross slope is 2.8 percent to 3.5 percent. The road geometry changes occasionally with maintenance activities. While ponding may occur in areas of shallow cross Ursa Operating Company LLC Tompkins Injection Well Waiver Requests Page 3 slope, the road is inspected on a daily, weekly, and monthly basis for maintenance issues, which are addressed in a timely manner. There is no shoulder slope, because there are no shoulders on this road. The access road is wide enough to allow two-way traffic. Traffic speeds are low due to the short length of the access road, so adding additional width to the road for shoulders is not necessary. Further information regarding the access road in included in the Access and Road Assessment section. 2. Imposes no greater impacts on adjacent properties than would occur through compliance with the specific requirements of this Code. Response: Full compliance with the standards referred to above would require that the road be widened, causing additional disturbance to fix a relatively short road and redesign the current drainage. This would require additional encroachment on to the lessor’s property. These deficiencies do not impose any impacts on adjacent properties greater than would occur through compliance with the standards. The road functions adequately as built and is typical of existing roads providing access to natural gas production facilities in Garfield County. For further assessment of the roadway, see Access and Road Assessment section. Ursa Operating Company LLC Tompkins Injection Well Waiver Requests Page 4 This page intentionally blank.