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HomeMy WebLinkAbout3 Exhibits AA - ZZ• • Draft Battlement Me sa HIA, Revision 1 February 2011 Executive Summary I. Introduction EXHIBIT I ,4.Jr Conducted by Colorado School of Public Health The Garfield County Board of County Commissioners (BOCC) requested that the Colorado School of Public Health (CSPH) conduct a Health Impact Assessment (HIA) to address citizen concerns about health impacts of natural gas development and production in the Battlement Mesa Planned Unit Development (PUD). The two primary functions of the HIA are to : • Identify ways in which Antero's proposed natural gas development project can affect the health of the Battlement Mesa residents . • Develop a priority list of recommendations to minimize the potential health impacts of Antero's proposed project. We worked with community members to identify the eight areas of concern: Air Pollution ; Water and Soil Contamination; Traffic from Industry; Noise and Light Pollution ; Community Wellness; Economic Impacts ; Impacts on the Healthcare System; and Accidents and Malfunctions. Natural gas development in Battlement Mesa could, potentially, affect each of these eight areas of concern and human health. For example, trucks , drilling and hydraulic fracturing processes add sources of noise that would not exist were it not for natural gas development. Noise is also associated with variou s other health outcomes (e .g ., stress , heart disease). We used existing data sources to conduct quantitative and qualitative analyses in these eight areas of concern as well as describe the baseline conditions in Battlement Mesa . The baseline conditions are a one time "snapshot" of Battlement Mesa resident health and environmental quality . In addition to being useful for the HIA, the d es cription of baseline conditions serves as a comparison point for any future studies. We also analyzed any existing relevant data to assess how the natural gas industry operations might affect each of the eight areas of concern. The principal findings of the HIA are that health of Battlement Mesa residents will most likely be affected by chemical exposures, accidents/emergencies resulting from industry operations, and stress-related community changes . To address these potential health impacts , we provide more than 70 specific recommendations . These recommendations address the principal findings by focusing on pollution prevention, advancement of public safety and development of a Community Advisory Board. The following section s discuss these broad goals in the context of the principal findings , important remedies, and limitations of the HIA. II. Possible Health Effects Possible Health Effects Due to Chemical Exposures ES-page I • • • Draft Battlement Me sa HIA, Revi s ion 1 February 2011 Conducted by Colorado School of Public Health We used a variety of information sources and method s to assess the possible impact of chemical exposures on the health of Battlement Mesa resid ents. The information sources included Garfield County air monitoring data and related reports, resident statements of health effects related to the nearby natural gas activities , and health studies that explore the effects of chemical exposures. The Human Health Risk Assessment (or HHRA, Appendix D) is one tool that puts this information together as an integrated analysis . The risk assessment process is a method developed by scientists and pol icymakers to estimate how likely it would be for people to experience specific health effects (including , but not limited to cancer) as a result of being exposed to certain chemicals . We used a "screening" risk assessment methodology, as recommended by the U.S . Environmental Protection Agency when data gaps exist, to determine if chemicals exposure s from Antero 's natural gas project in the Battlement Mesa planned unit development could ad versely affect public health. This kind of risk assessment provides a way to compare different chemical hazards and different exposure routes in circumstances where information about sp ecific exposure levels and health effects is limited. The HIA team also followed guidance from the U.S. Environmental Protection Agency on how to interpret the existing information. The Human Health Risk Assessment used information from a variety of sources to conclude that natural gas processes release chemicals that are known to impact health; chemicals emitted into the air from natural gas processes are more likely to impact health than chemicals released into the water or the soil; exposures from air emissions are likely to be highest during well completion activities; and residents living near a well pad (defined as within Yz mile) are more likely to experience health effects than residents living farther away from a well pad (defined as greater than Yi mile). For decision makers, the primary value of a risk asse ssment is in its capacity to rank the relative magnitude of exposures and prioritize actions . The Battlement Mesa Human Health Risk Assessment identifies which airborne chemicals mo st likely to impact health. This information can help guide decisions about where to focus pollution prevention efforts . Since the risk assessment indicates that in Battlement Mesa exposure to chemicals in the air is more likely to occur than exposure to chemicals in the water or soil, methods to reduce air pollution and monitor the air should be the focus of current and future pollution prevention . Possible Health Effects Due to Unsafe Industrial Operations in a Residential Neighborhood Natural gas development is potentially hazardous because it uses large numbers of heavy trucks for well pad construction, drilling and completion op erations, maintenance activities and pipeline installations. T hus gas industry traffic can pose important safety concerns in residential neighborhoods . More vehicles and heavy truck traffi c in school zones and on residential streets increases the likelihood of motor vehicle crashes, some of which could result in fatal and non- fatal injuries. Decreasing or eliminating industrial traffic on residential streets will reduce or remove associated safety risks. ES-page II • • • Draft Battlement Me sa HlA, Revision l February 2011 Conducted by Colorado School of Public Health Industrial incidents, such as accidents and malfunc tions involving wells and pipelines near homes, place residents at increased risk of exposure to fires, explosions and uncontrolled chemical releases . Previous reports to the Colorado Oil and Gas Conservation Commission indicate that minor and major incidents occur in the course of natural gas processes . Prevention of well site accidents, pipeline breaches and other inc idents will reduce the risk of injuries and illnesses to community members. Attention to preventing minor spills and accidents , tracking and analysis of near-misses, and analysis of incidents when they do occur will provide the information necessary to prevent a catastrophic event. Possible Health Effects Due to Community Changes Social norms (in other words, community members ' s ense of their "normal way of life") can be impacted in various ways , including : • The presence of industrial activity in a previously non-industrial area • A perceived loss of shared community ideals and cohesion • Declining property values • Impacts to the education system • Sudden changes in population numbers, demographics and customs Community impacts of the natural gas industry during the boom of 2003-2008 and decline of 2009 included increased crime and sexually transmitted diseases, declining property values and impacts on the educational environment. Some residen ts report that socia l norms in Battlement Mesa have been impacted by the proposal of the Antero project and have caused Battlement Mesa residents additiona l stress . The potential health e ffects of stress are difficult to quantify but should not be underestimated . Stress contributes to risk for heart disease , obesity, and other common chronic health conditions. Addressing impacts to the Battlement Mesa community can help address changes to social norms and potentially decrease health effects related to increased stress . III.Remedies to address Principal Findings Reduce the Likelihood that Battlement Mesa Residents will be Exposed to Industrial Chemicals At this time, there are no studies that document a "safe" distance between natural gas wells and homes, schools, and other places occupied by community members . Preliminary studies in the natural gas fields, results of air modeling from other industrial operations, and the laws of physics le ad us to a basic conclusion: pollutant concentrations generally decrease with increasing the distance from an emission source . Since each well pad is unique, it is difficult to determine one safe setback for all residences . This issue is further complicated by noting that multiple well pads in the same general area may impact the air in or around a residence. It is not known if current set back distances from a well ES-page Ill Draft Battlement Mesa HIA, Revision 1 February 2011 Conducted by Colorado School of Public Health pad to residences are sufficient to protect the public from chemical exposures that may result in short or long term health effects. Therefore, steps should be taken to decrease emissions from all sources and wherever feasible increase the distance between well pads and roads and res idences to and schools. We recommend that Antero be required to use the best available technology to reduce air emissions from gas production sites. Promote Safe Industrial Operations in a Residential Neighborhood Because Antero proposes to develop natural gas operations within a residential community, safe industrial operations are very important. Removal of industrial traffic from residential roads will reduce the safety hazard associated with heavy trucks within the planned unit development. Regular inspection of well installations, pipeline installations, maintenance procedures and other infrastructure is warranted. When major or minor incidents occur reports should be made to Garfield County Oil and Gas Department as well as Colorado Oil and Gas Conservation Commission. These reports should include plans for actions to prevent these incidents from happening in the future. Clear emergency response policies and procedures particular to natural gas development in Battlement Mesa should be developed. Emergency response plans should consider schools, the assisted living facility, businesses and residents who may be impacted by an industrial emergency in the planned unit development because there are limited routes in and out of Battlement Mesa. Foster Effective Communication Between Stakeholders Natural gas development and production activities are projected to continue in Battlement Mesa for twenty to thirty years. Communication between Antero, the citizens of Battlement Mesa, the Battlement Mesa Company, and Garfield County officials will be crucial for addressing community concerns. We recommend that Garfield County establish a Community Advisory Board to foster better communication between stakeholders for the duration of the natural gas project. The BOCC should consider hiring someone trained in mediation , or some other form of alternative dispute resolution, to facilitate the community advisory board meetings. This expert could help the Community Advisory Board develop clear by-laws, responsibilities, meeting procedures and conditions for membership, among other things. The Community Advisory Board would provide a way for stakeholders to communicate issues that impact all parties. For instance, Antero could update community residents and Garfield County officials about changes to their development plans. The Community Advisory Board would a lso be a mechanism for providing input to how the million-dollar donation from Antero supports community and physical health. Mediation services should proceed as long as members agree that the services are useful. IV. Information Gaps The HIA is based on data that already existed when the HIA began. Neither the health data nor the environmental data that were available to us were sufficient to make specific predictions ES-page IV • • Draft Battlement Mesa HIA, Revision l February 2011 Conducted by Colorado School of Public Health about expected health impacts. Without taking multiple individual measurements, it is difficult predict individual exposures and health impacts. Therefore, we were not able to forecast the specific numbers of people who could experience health effects or the magnitude of changes in disease rates. Filling Information Gaps We recommend the collection of baseline and ongoing air, groundwater, surface water, and soil data around well pads and the centralized water storage facility. Furthermore, this information should be publicly available . This information will provide baseline levels for comparison to (and thus direct feedback) the impacts of the Antero -Battlement Mesa project and allow for improvement of project best practices as the project goe s through development, production , and reclamation periods. Environmental studies should further characterize air emissions and odor events and model exposures to residents living near natural gas operations. Monitoring and evaluation of exposure to air toxics, particulate matter, and ozone should be conducted . We further recommend that Garfield County continue to support collection and analysis of baseline and ongoing health information. Health studies should include measurements re lated to physical health, lifestyle and social cohesion, educatio n, crime, sexually transmitted infection, mental health and suicide, substance abuse , and economic impacts . These environmental and health studies will help a sse ss the impact of residential natural gas development on the environment, community, and ind ividual health and the effectiveness of pollution control measures. It will provide valuable information for Garfie ld County to address community concerns about the impacts of natural gas development in residential neighborhoods. ES-page V • • • Draft Battlement Mesa HlA, Revision l February 2011 Part One: Health Impact Assessment Preface Conducted by Colorado School of Public Health H!A is used to evaluate objectively th e potential health effects of a project or policy before it is built or implem ented . H!A can provide recomm endations to increas e positi ve health o utco mes and minimize adverse health outcomes. Th e HIA framework is us ed to bring potential public health impacts and consideration s to th e decis ion-making process for plans, projects, and policies that fall outside of traditional public health arena s, s uch as tran sportation and land use. -Centers for Dis eas e Control 1 The health of an individual human being is determined by a complex interaction of social, economic, genetic, and environmental factors which he or she experiences throughout life. Income, access to clean drinking water, unpolluted air, social support from friends and family, healthy food , access to education, and a whole host of other factors combine to have a profound effect on the health of an individual. Similarly, when social, economic, and environmental conditions are common to a group of people, those conditions can influence the health of the population as a whole . Public policies have the potential to impact an individual 's and a population's health. While there are public programs and policies designed to influence population health (e.g . food safety regulations), population health is not accounted for in all or even most of the policies that can impact health. To improve the accessibility and utility of existing sc ientific knowledge as it applies to program and policy development, public health researchers have developed the Health Impact Assessment (HIA) approach. While HIAs vary in their goals and methods, the general approach is consistent across HIAs: A group of public health experts works with community stakeholders to identify the potential health risks and potential benefits to public health of a proposed policy, program, or project. The HIA team then collects information to assess how likely public health will be impacted. Based on the potential impacts and the estimated likelihood of those impacts, the HIA team offers recommendations to maximize public health gains and minimize negative effects of the program, project or policy at hand. While the goal of an HIA is to anticipate and provide recommendations that advance public health, it cannot be expected to prevent all negative health impacts of a given decision. A HIA is an approach to incorporating public health into decision-making processes. As opposed to costly retrofitting and remediation, HIAs are proactive and preventive public health tools that have the potential to save health care costs in the long-term. HIAs are open processes that necessarily include stakeholder participation, review, and input as an essential part of the methods. Through this open dialogue, the HIA seeks to generate realist ic and broadly supported recommendations to protect public health. A HIA differs from a scientific epidemiological study in that an epidemiological study typically evaluates the effects of exposures on populations after the exposures have occurred, whereas, a Part One Page 1 • • Draft Battlement Me sa HIA , Revi s ion l February 2011 Conducted by Colorado School of Public Health HIA is conducted before a project or policy is started, with the ultimate goal of identifying potential exposures and determining if there are need s to mitigate their impact on health. Both kinds of investigations provide valuable information to those concerned with understand ing and protecting public health. Regarding Ozone and Human Health The impact of ground level ozone and ozone precurs ors are not included in this HIA . The Antero project itself will contribute ozone precursors (volatile organic compounds (VOCs) and nitrogen oxides), however, it is the sum of the ozone precursors produced in the county that contributes to ozone levels county wide. Ozone can cause important ne gative health effects and should be the considered when discussing public health in Garfield County . However, the impact of Antero's contribution to ozone on the health of Battlement Mesa citizens is not discussed in this assessment. Regarding Climate Change and Human Health This Health Impact Assessment does not account fo r the potential health effects of climate change . There is reason to believe that fossil fuel combustion has changed the global climate2 . There is also reason to believe that climate change will impact human health2 • However, it is in the opinion of the HIA authors that while this speci fi c natural gas dev elopment contributes to climate change, is not likely to influence the global climate enough to have a measurable impact on the health of Battlement Mesa residents. Part One Page 2 • • • Draft Battlement Me sa HIA, Revi s ion 1 February 2011 1 Introduct ion C o ndu cted by Colorad o School of Public Health The Colorado School of Public Health (CSPH) was co mmissioned by the Garfield County Board of County Commissioners (BOCC) to conduct a Hea lth Impact Assessment (HIA) in order to address citizen concerns about health impacts of natu ra l gas deve lopment and production in the Battlement Mesa P lanned Unit Development (PUD). The HIA scop e of work was informed by citizen concerns and was limited to Battlement Mesa . The HIA proces s included stakeholder participation and review. The two primary functions of the HIA are to : • Identify ways in which Antero 's prop os ed natural ga s development project can affect the health of the Battlement Me sa residents. • Develop a priority list of recommen dations to minimi ze the potential health impacts of Antero 's proposed project. We worked with community members to id entify the eight areas of concern: Air Pollution; Water and Soil Contamination; Traffic from Industry; Noise and Light Pollution ; Community Wellness; Economic Impacts ; Impacts on the Healthcare Sy stem ; and Accidents and Malfunctions . Natural gas development in Battlem ent Mesa could, po tentially, affect each of these eight areas of concern and human health. For example, trucks , drilling and hydraulic fracturing processes add sources of noi se that would not exist were it not for natural ga s deve lopment. Noise is a lso associated with variou s other health outcomes (e.g., stress, heart disease) . The principal findings of the HIA are that health of Ba ttlement Mesa residents will most likely be affected by chemical exposures, accidents/emergencies resulting from industry operations, and stress-related community changes . To address these potential health impacts we provide more than 70 specific recommendations . These recommendations address the principal findings by foc u sing on pollution prevention; advancement of public safety; and development of a Community Advisory Board . Methodical assessments of each of th e areas of concern use available data, tools and scientific lit erature to provide justification for the recommendations. The HIA identified several information gaps. Becaus e of these gaps , we were not able to provide precise predictions of hea lth outcomes potentially ass ociated with th e natura l gas project. The recommendations provided were developed to pro tect public health in light of these gaps . Recommendations to fill information gaps are also included. The document is a revision of the original HIA whi ch was released for public and stakeholder commen t in September 2010. The HIA was revi se d and reorganized based on public and stakeho ld er comments and new ly avai lable information. Appendix E contains comments . We assigned a code (e.g. Al or BCCl) to each comm ent. These codes then correspond to our specific response to comments contained in Append ix F . For example, a comment assigned a code of Al in Appendix E has a specific response coded Al in Appendix F . Below is a summary of the natura l gas project p lans , c ommunity concerns and responses to these concerns to date . Also below is a summary of the Battlement Mesa Baseline Hea lth Profile . Part One Pag e 3 • • Draft Battlement Mesa HIA, Revision I February 2011 Conducted by Colorado School of Public Health 1. 1 Antero's Plan to Drill within the Battlement Mesa PUD Technological advances (e.g. hydraulic fracturing) have contributed to natural gas development in areas previously not considered for such activitie s . Whereas oil and gas development has historically taken place in locations that are geographically distant from human habitation (other than, perhaps , the housing for oil and gas workers themselves), it is increasingly common for drilling activities to occur in rural, suburban, and urban areas close to where people otherwise unaffiliated with the industry live, work and play . Throughout the United States and in Garfield County, the residents in close proximity to drilling activities are raising concerns about the potential impacts drilling may have on air quality, water quality , public safety, and public health4 . In its purpose statement accompanying their rules, the Colorado Oil and Gas Conservation Commission (COGCC) specifies counties, including Garfield, within Colorado's Piceance basin as facing particularly challenging public health issues because of the rapid growth of the industry into populated areas in this area5. The human health impact of natural gas development and production has not been thoroughly studied . In the Spring of 2009, Antero announced plans develop natural gas within the Battlement Mesa PUD, utilizing mineral rights acquired from Exxon, The Battlement Mes a Company (BMC), and others6 . Figure I shows the locations of the 9 well pads Antero in tends to develop within the PUD as well as 3 other pads outside the PUD. There will be approxima tely 200 wells on the pads in the PUD . Antero also plans to develop a wa te r storage and management system within the PUD, which will reduce truck traffic associated with the well development process. In addition, pipelines for natural gas and water movement will be install ed. The contract that establishes the PUD requires th e Garfield County BOCC to review any proposed land-use changes within the Battlement Mesa PUD through a Sp ecial Us e P ermit (also known as the SUP) process. The Garfield County BOCC has the authority to require modifications to the plans outlined in a given Special Use Permit application . Because its plans pertain to the Battlement Mesa PUD , Antero will submit a Special Use Permit to the BOCC before initiating drilling activities . In addition to county review , Antero will also submit plans through a state permitting process, conducted by the COGCC. Under a 2008 rule 7 , natural gas operators may submit Comprehensive Drilling Pl ans to COGCC5 . If Antero submits a Comprehensive Drilling Plan to COGCC, COGCC will review the development project as a whole, which streamlines permitting for individual w ells within Antero 's project. There have been no permit applications submitted to Garfield County or COGCC as of the date of this HIA report. Antero has, however, entered into a legally-binding Surface Use Agreement with the BMC . This Surface Use Agreement outlines characteristics of the natural gas drilling plans for the Battlement Mesa PUD . While not as detailed a s a Special Use Permit or Comprehensive Drilling Plan, the Surface Use Agreement between Antero and the BMC provides some information regarding Antero 's plans for the Battlement Mesa project. Furthermore, Antero held 19 community meetings, which were open to the public, during 2009-2011 where plans for Part One Page 4 • • • Draft Battlement Mesa HlA, Revision 1 February 2011 Conducted by Colorado School of Public Health Antero's project were described. Power point presentations from these meetings are available online8-9 . These sources of information plus information provided to us by Antero are used as a basis for this HIA. Appendix A includes a summary of the natural gas drilling process. Appendix B includes a review of energy development in the Piceance basin and the Surface Use Agreement between Antero and BMC. Appendix BB includes a site description of the Battlement Mesa Community. 1.2 Community Concerns After Antero announced its intentions to drill within the Battlement Mesa PUD, community members living in Battlement Mesa expressed concern regarding potential environmental, health, and safety impacts. Citizen concerns have included but are not limited to: • The proximity of drilling and gas production to homes, recreational areas, and schools • "Vulnerable" populations with diminished immune capacity • Exposure to airborne volatile organic compounds (VOCs), diesel emissions, particulate matter (PM), and other air contaminants • Exposure to fluids used in the hydraulic fracturing process, hydrocarbons, and VOCs through soil or water exposure routes • Potential increased risk of fires, explosions and/or motor vehicle crashes • Changes in community "livability" A grassroots advocacy organization, the Battlement Mesa Concerned Citizens (BCC) formed under a parent organization, the Grand Valley Citizens Alliance. In November 2009, the BCC submitted a citizen petition to the Garfield County BOCC requesting that BOCC require Antero to address health concerns before drilling for natural gas within the Battlement Mesa PUD. While the human health impacts of natural gas development and production have not been specifically studied using state-of-the-art public health epidemiologic research methods, there has been substantial research related to exposures of potential concern in the natural gas industry. For instance, drilling for natural gas has the potential to increase occupational and community exposures to VOCs such as benzene, toluene, ethyl-benzene and xylene (BTEX). Heavy metals associated with drilling waste, particulate matter (PM) generated by transportation activities and diesel fuel combustion, and ozone precursors (ozone formation) are also known to be associated with natural gas development. Some constituents of hydraulic fracturing chemicals may pose health risks to workers or community members. Sufficient exposures to these chemical compounds are associated with serious negative health outcomes such as lung disease in children and adults (i.e., asthma, chronic bronchitis, obstructive disease), cardiovascular disease, poor birth outcomes (premature birth, low birth wei§ht, congenital malformations), various cancers, and other long and short-term health issues 1 -14 • Part One Page 5 • • • Draft Battlement Me sa HIA, Revi s ion I February 20 11 Conducted by Colorado School of Public He a lth Environmental contaminants to which people may be exposed include air emissions , ground and surface water pollution and soil contamination . In addition, physical hazards can include increased truck traffic and domestic explosions assoc iated with gas seepage into domestic water supplies . Social hazards can include a variety of community disruptions associated with boom- and-bust cycles, itinerant workforces, and industrialization of residential areas 15 • 1.3 Initial Responses to Community C oncerns In response to community concerns, Antero has held several informational community meetings9 and has responded to community concerns by modifying some of its drilling plans, for example the remova l of drilling pad C (replaced by the Parks and Rec pad). The Surface Use Agreement between Antero and BMC includes some measures which are intended to reduce the impact on the community's health and qua lity of life. Even before it commissioned the HIA, Garfield County had undertaken many steps in response to community concerns regarding natural gas development and production in the county . Garfie ld County Public Health Department (GCPH), the county health department, initiated and managed the Saccommano Report and currently manages on-going ambient air monitoring stations at several locations in Garfie ld County. The Garfield County Oil and Gas Department (GCOG) initiated and managed an intensive study of w ater quality and hydrology of the Mamm Creek Gas Field. GCPH also has participated in numerous Colorado Department of Public Health and Environment (CDPHE), COGCC , and United States Environmental Protection Agency (EPA) air and water studies documenting: • Air toxics (e.g. benzene) in ambient air, at levels higher than leve ls measured in a neighboring county with no gas development 16 • Evidence of ground -level ozone formation , which once surpassed the EPA 8 hour standard of 7 5 parts per billion (ppb) in 2008 17 • Ground water containing thermogenic methane in natural gas development and d . 18-20 pro uction areas • Trends in health impacts consistent with potential exposures (via a county-wide health assessment) 21 • Citizen concerns over oil and gas impacts to health (via county-wide surveys)2 2 In November 201 1 the BOCC instructed GCPH to address the BCC's concerns raised in its citizen petition. GCPH approached the CSPH with a request to collaborate on a HIA . Subsequently, the BOCC agreed to contract with the CSPH to conduct this HIA. Through funding from the Pew Health Impact Project, a Canadian HIA cons ultation firm with experience in reso urce deve lopment projects, Habitat Health Impact Consulting has provided technical assistance to the CSPH for this HIA. Part One Page 6 • • • Draft Battlement Mesa HIA , Revision 1 February 2011 1.4 Battlemen t Mes a H ea lth Profile Conducted by Colorado School of Public Health As part of the HIA, we completed the Battlement Mesa Health Profile. We used available data to evaluate the baseline health of the residents of the Battlement Mesa Community. These data were analyzed using the 2000 U.S. Census information to calculate rates. Several measures of health are best determined by using zip code to define a community. We use the zip codes 81635 and 81636, which are used by the residents of Battlement Mesa, Parachute and surrounding areas . Because these zip codes are shared, Parachute is included along with Battlement Mesa in the descriptions of physical health determinants and some social health determinants. Some of the social health determinant measurements were not available at a zip code level, and so we provide descriptions of these at a county level. While the assessments of stressors focus on the impacts to those living within the Battlement Mesa PUD, others living nearby may experience some effects as well. The entire Battlement Mesa Baseline Health Profile is available in Appendix C. 1.4.1 Measures of Phys ica l Hea lth To assess the baseline physical health of the Battlement Mesa/Parachute area, we obtained inpatient hospital diagnoses, cancer, birth, and death analyzed information from the CDPHE for the years 1998-2008. The analysis included health diagnoses, birth outcomes , and causes of death with a known association between disease and the exposures of concern, as well as those for which community members voiced concerns of elevated occurrence of disease. Major categories of disease and death included depression and those involving the nervous system, ear/nose/throat, vascular system and pulmonary system. Major categories of cancer included: Hodgkin lymphoma and non-Hodgkin lymphoma, multiple myeloma, leukemia, melanoma, breast cancer, prostate cancer, bladder cancer, colorectal cancer, and cancer of the adrenal gland. Birth outcomes included low birth weight and preterm delivery. Health for Battlement Mesa/Parachute residents was compared to the health of Colorado residents. Overall, the citizens of Battlement Mesa appear to be generally healthier than other citizens of Colorado . They experienced fewer hospitalizations and fewer deaths. Battlement Mesa women experienced the same rates of cancer and of negative birth outcomes as other women in Colorado. In Battlement Mesa men, we observed a slightly higher than expected rate of prostate cancer, which we felt is an observation likely due to variability of small numbers or statistical chance (when multiple independent tests are compared, there is a statistical probability that 5 % of the tests will be abnormal by chance alone). No other differences were noted between men in Battlement Mesa when compared with other Colorado men. There are no systematic databases describing out-patient or emergency room visits . Data regarding mental health was not available . Part One Page 7 • • Draft Battlement Mesa HIA, Re vision 1 February 2011 1 .4.2 Measu res of Communi ty Hea lt h Condu cted by Co lorado School of Public He alth To evaluate the baseline community health in Battlemen t Mesa/Parachute, we obtained available information regarding sexually transmitted infections, crime, substance abuse, and education . Where information concerning Battlement Mesa was not available, we looked at Garfield County data. Systematic collection of measures of community health, cohesion and well-being in Battlement Mesa being are not being conducted. Overall, the incidence of sexually transmitted infections in Garfield County rose during the years 2005-2008, peaking between 2007 and 2008 . Between the years 1992-2005, for adults, violent crime arrests doubled; property arrests fluctuated throughout the period, and increased slightly; and drug violations increased almost ten-fold. In the same time period, for juveniles, violent crime arrests increased; property arrests fluctuated but did not change significantly; and drug violations increased almost ten-fold . Substance abu se and mental health information extracted from the GCPH's 2006 asses sment on community ne eds indicates depression , anxiety and stress along with tobacco smoking and alcohol abuse appear to be the top indicators of the burden of mental health and substance abuse, respectively, in Garfie ld County . Part One Page 8 • • • Draft Battlement Mesa HIA, Revision 1 February 2011 Conducted by Colorado School of Public Health Figure 1: Locations of Proposed Well Pads within the Battlement Mesa Planned Unit Development Part One Page 9 • • Draft Battlement Mesa HIA, Revision I February 2011 3 Findings and Recommendation s Conducted by Colorado Schoo l of Public Health In this section, we provide over 70 specific recommendations, based on the assessments of the eight areas of concern, to protect the health of the Battlement Mesa residents for the duration of Antero's project. 3. 1 Findings and Specific Recommen da tions from Air Quality Assessment W h at we know: Air po ll ution is a known hazard to the public health. There is sufficient information available to indicate that even with current practices and technologies the natural gas industry produces large amounts of air pollutants . In addition, Antero 's recent well development activities on the Watson Ranch pad resulted in short term health impacts . Antero has proposed additional mitigation measures for the project in Battlement Mesa but these mitigations are as yet untested. Further mitigation measures may be needed to reduce the likelihood of health effects . As it stands, the Antero project has the potential to pollute the air and negatively impact the public health in Battlement Mesa. Many information gaps exist. What we do not k now: Currently, there is not enough information to determine whether or not current federal, state, and COGCC regulations and rules are sufficient to protect public health from air pollution resulting from natural gas development and production in high population density areas such as the Battlement Mesa PUD. To protect the health of Battlement Mesa residents , we recommend the implementation of air pollution prevention measures some of which may be above and beyond those mandated in federal, state, and COGCC regulations and rules as an integral part of Antero's project and the monitoring of air quality and the health of residents in Battlement Mesa to ensure public health is protected throughout Antero's 30-year project. Prior to approval of the special use permit, we recommend the B O CC require Antero to: 1. Demonstrate that the low emissions flow back technology Antero is developing is effective in reducing air emissions. Antero should pilot test the system and monitor air emissions using EPA methods with detection limits adequate for the assessment of human exposure and prevention of human health effects . An effective demonstration would show that levels of air pollutants, such as benzene, as measured in 24 -hour ambient air samp les at 350, 500, 1000, 2000, and 3000 feet and in each cardinal direction, from the we ll pad perimeter, are not higher than those measured at the Battlement Mesa monitoring station. Antero should make all test results publically avai lable on Garfield County's website and/or on a publicly access ible website approved by the Battlement Mesa Commu nity, three months prior to any drilling within the PUD. Part One Page 12 • • Draft Battlement Mesa HlA, Revision 1 February 2011 Conducted by Colorado School of Public Health 2. Disclose all chemicals that will be used on its well pads within the PUD. We recommend Garfield County to keep a list of these chemicals on its website and/or on a publicly accessible website approved by the Battlement Mesa Community. 3 . Establish a system for immediate response to odor complaints that includes options for ceasing operations, notification of affected residents, and temporary relocation of residents until the source of the odor is identified and resolved. We encourage Antero to communicate the timing of well completion activities to Battlement Mesa residents , which could allow for voluntary shutting of windows and air intakes or temporary relocation. 4. Submit a quality assurance project plan (also known as a QAPP) to GCPH and GCOG for review and approval for all monitoring specified in these recommendations to assure monitoring information will be adequate for informing public health decisions prior to any activities in the PUD. As a condition of the special use permit, we recommend that the BOCC require Antero to: 5. Complete the installation of a fully functional water storage facility and water pipeline network prior to any drilling within the PUD to realize the full air pollution prevention benefit. 6. Use permitted tanks rather than a pond at the centralized water storage facility . See recommendations for Water and Soil Asses sment for further details of water storage facility recommendations. 7. Use an effective and validated low emissions flow back process for all well completions within the PUD. 8. Route production tank venting emissions through a VOC combustor operated with auto- igniters on all well pads within the PUD. 9. Use vapor recovery technology when availabl e, rather than combustion, to further reduce air pollution . 10. Obtain an emissions permit from CDPHE for each well pad production tank within the PUD, per COGCC rules . The COGCC rul es require permitting for production tanks within v.I mile of an occupied structure with the capacity for 5 tons per year of VOC emissions, which is the case for most of Antero's proposed well pads . Our recommendation may be beyond the COGCC rule at one or two well pads. This recommendation is necessary, however, for the protection of public health because odors have been noticed up to Yi mile from the Watso n Ranch pad. The v.I mile distance in the rule is not based on a health-based air pollution standard, and the permit provides a mechanism for the establishment of inspection and monitoring requirements. 11. Work with GCPH to implement an air monitoring program for all well completion activities within the PUD and at the centralized water storage facility. At a minimum, this program should include collection of 24-ambient air samples and grab samples, real- time VOC monitoring , odor monitoring , and collection of grab samples when odors are noticed . Part One Page 13 • • • Draft Battlement Mesa HlA, Re vis ion 1 February 2011 Conducted by C olorado Sc hool o f Public He a lth 12 . Annually disclose all chemicals and volumes u sed on its well pads within the PUD and include any chemicals that are VOCs in the a ir monitoring program . We recommend Garfield County to keep a list of these chemicals on its website and/or a publicly accessible website approved by the Battlement Mesa Community. 13. Implement the system for immediate respons e to odor complaints that includes options for ceasing operations . Implement a system for notification of affected residents , and temporary relocation of residents until the source of the odor is identified and resolv ed . We encourage Antero to communicate the timing of well completion activities to Battlement Mesa residents, which could allow for voluntary shutting of windows and air intakes or temporary relocation . 14. Make all air monitoring results within the PUD publically available for po sting on the Garfield County website and/or a publicly acc es sible web site appro ved by the Battlement Mesa Community, no later than 60-days follo wi ng the collection of samples . 15 . Comply with COGCC green completion practices and EPA 's natural gas STAR pro gram to reduce voe emissions to the lowest le vel te chnically possible at all well pads within the PUD. 16 . Specify where in the PUD Antero will use elec tric grid power for drilling and/or other operations. 17. Adhere to dust control measures and traffic measures specified in the Special Use Agreement. 18 . Establish and implement a plan that ensures all trucks u sed for it s plan within the PUD meet emission standards specified in the Clean Fuel Vehicles (heavy trucks) for the Clean Fuel Fleet Program (CFR Part 88.105-94) to reduce VOC , P AH , and PM emissions . This will reduce air pollution in the PUD. 19 . Prevent the idling of trucks on well pads and a long roads in the PUD for longer than 10 minutes . 20. Ensure truckloads of dirt , sand, aggregate materials , drilling cuttings , and similar materials are covered to reduce dust and PM emissions . We recommend that the BOCC: 21. Assign a county inspector to monitor Antero 's compliance with the special use permit and that the special use permit contain provis io ns for regulatory action if Antero is found to be in non-compliance. 22. Assign an independent observer acting on the ir behalf, to participate in the demonstration of the low emission flow back tank described in recommendation 1. The independent observer would be responsible for confirming sample locations and timing as well as monitoring for odors. The independent observer would collect grab samples if odors are noticed during the demonstration for evaluation of possible short-term peak exposures . Finally, we strongly encourage Antero to: Part One Page 14 • • • Draft Battlement Me sa HI A, Re vis ion I February 2011 Conducted by Col orad o School of Public He a lth 23 . Use all its best management practices for reduction of air pollution in the PUD during the next phase of drilling and well completions at the Wat son Ranch pad and /or other pads outside the PUD, to conduct rigorous air and odor monitoring , and to make all result s publically available . This is an ideal opportunity for Antero to show the BOCC and the residents of Battlement that it can effectively control air emi ssion s and address community concerns. 3.2 Findings and Specific Recommendations from Water and Soil Quality Assessment What we know: Water pollution is hazardou s to the p ublic health . Garfi e ld County Oil and Gas studies , EPA studies , and other studies demon strate that natural gas development and production can release contaminants to domestic water supplies and compromise water quality. Individual circumstances can influence the potential contamination of wate r. In Garfi eld County, accid ents and malfunctions have been the most common cause of water contamination from natural gas development and production. However, the Mamm Creek Hydrological Study indicates some impacts to groundwater, such as increased levels of chloride and methane, from routine natural gas operations. If a domestic water resource is contaminated, remediation is time and cost intensive and may not restore the water resource to a quality for domestic u se . What we do not know: The hydrogeology in Battlement Mesa ha s not been characterized and the relationship between groundwater, domestic water supplies, and the Colorado River in not well understood. The extent of the impact of routine natural gas development and production on water quality is not known . Systematic monitoring is needed to verify that ground water is not compromised by routine natural gas development and production operations. Systematic monitoring can also provide early warning if water becomes contaminated . To protect the health of Battlement Mesa residents and to protect the Battlement Mesa 's secondary drinking water source, we recommend the implementation of water and soil pollution prevention measures some of which may be above and beyond thos e mandated in federal , state, and COGCC regulations and rules as an integral part of Antero 's project and the monitoring of water quality and the health of residents in Battlement Mesa to ensure public health is protected throughout Antero 's 30-year project. As a condition of the special use permit, we recomm end that the BOCC require Antero to: 1. Disclose all chemicals that will be used on it s well pads within the PUD . 2. Characterize the geology and hydrogeology w ithin the Battlement Mesa PUD and the primary and secondary domestic water supplies, according to the specifications in COGCC rule 908. 3 . Submit a quality assurance project plan (also kn own as a QAPP) to GCPH and GCOG for review and approval for all sampling and monitoring specified in these recommendations to assure monitoring information will be adequate for informing public health decisions . Part One Page 15 • • Draft Battlement Mesa HIA, Revi s ion 1 February 2011 Conduc ted by Colorado Sc hool of Public He a lth 4 . Complete the installation of a fully functional wat er management facility and water pipeline network prior to any drilling within the PUD to decrease potential of contamination of soil and surface water on individual well pads and decrease potential for truck accidents to contaminate surface waters and soils in case of an ac cident. Before approval of the special use permit, we recommend that the BOCC require Antero to: 5 . Comply with COGCC rule 908, which pertains to non-commercial centralized E&P waste management facilities, for the centralized water storage facility , which will be handling E&P waste (i .e., recycling water used in well completio ns ). One of the best management practices Antero has proposed for its Battlement Mesa project is a centralized water storage pond, which will allow for pit-less drilling on the p ads, the recycling of water us ed in well completions , and reduced potential for water an d soil contamination at the well sites . We have recommended that this facility be installed prior to any drilling. COGCC rule 908 requires permitting, a hydrogeological characterization , groundwater, so il , and surface water testing for centralized E&P waste management fa c ilities . 6 . Use permitted tanks, rather than a storage pond for water storage at the centralized water storage facility . While tanks are not required by COGCC , the use of tanks reduces the potential for water and pollution that could occur if a pond/pit liner was compromi sed or if a pond/pit overflowed . Tanks also have the adde d advantage of reducing air pollution and reducing inadvertent wildlife and pet exposures . 7. Locate the centralized water storage facility be loc ated at lea st a mile from any resid ential structure or school as a condition of approval of the special use permit. This is because the water storage facility will be handling E&P w as te (i .e. recycl ed water from well completions). 8 . Annually disclose all chemicals and volumes u sed on its well pads within the PUD and include any chemicals that are VOCs in the water monitoring program as a condition of the special use permit. We recommend Garfield County to keep a li st of these chemical s on its website. 9 . Install at least one up-gradient and two down-gradient groundwater monitoring wells at each well pad as well as at the centralized water storage facility , in addition to the voluntary water well testing program specified in Antero 's best m anagement practices . Antero should also conduct baseline sampling for, at a minimum, the following : all major cations and anions, total dissolved solids , iron, manganese, nitrates, nitrites , selenium , benzene, toluene , ethylbenzene, xylenes, methane, pH, specific conducta nce , and any chemical identified in the full disclosure of chemicals of potential concern. This monitoring will ensure that drilling, hydraulic fracturing and other operations do not c ompromise ground water. 10 . Conduct monthly monitoring of the well site groundwater wells for the parameters specified in the proceeding recommendation during well drilling and completion activities , followed by annual monitoring for the duration of Antero 's project. All result s of this monitoring should be made available to the public within 60 days of sample collection and posted on Garfield County's website. If (1) benzene, ethyl benzene , toluene, or xylenes are detected at levels greater than the concentration levels specified in Table 910-1 of the COGCC rules ; (2) any cations, anions , metals, or total dissolved solids exceed 1.25 times background Part One Page 16 • • • Draft Battlement Me sa HIA, Revi s ion I February 2011 C onducted by Colora do School of Public Health concentrations; (3) methane or any chemical identi fied as a concern from the full disclosure of chemicals exceeds 1.25 background concentrations ; or ( 4) if pH or specific conductance exceeds the limits specified in COGCC table 910-1 , the BOCC should require Antero to remediate as a condition of the special u se permit. This type of monitoring is the best way to ensure pollution control measures are effective in pro tecting the groundwater resource . 11 . Conduct baseline soil and surface water testing at a ll well pad locations and at the location o f the centralized water facility for the parameters sp ec ified in COGCC Table 910-1, in addition to the wetland/drainage survey and mapping speci fie d in Antero 's best management practices 12 . Perform monthly monitoring of any surface water bodies that are located within Y2 mile of a well pad or the centralized water storage facility u s ing the same pa rameters specified for the groundwater monitoring during well drilling and completion activities , followed by annual monitoring for the duration of the proj ect. This type of monitoring is the b es t way to ensure pollution control measures are preventing exposures through contamination of surface water. 13 . Conduct soil testing at all well pad locations a nd at the c entralized water facility during reclamation activities . All results of this monito ring should be made available to the public within 60 days of sample collection and posted on a publicly accessible website approved b y the Battlement Mesa Community web site. If (1) benzene, ethylb enzene , toluene, or xylene s are detected at levels greater than the concentratio n levels specified in Table 910-1 of th e COGCC rules; (2) any cations, anion s, metals, or total dissolved solid s exceed 1.25 times background concentrations ; (3) methane or any chemical identified as a concern from the full disclosure of chemicals exceeds 1.25 background concentrations; or (4) if pH or specific conductance exceeds the limits specified in COGCC table 910-1 , the BOCC should require Antero to remediate as a condition of the special u se permit. This type of monitoring is th e best way to ensure pollution control measures are preventing exposures through contamination of soil. 14 . Adhere to COGCC rules 317B, 603 , 904, and 908 , including provisions in these rules that are at the discretion of the director, and identify any variance s or exceptions to these rules and make any variances or exceptions publically avail able (as posted on Garfield County website and/or a publicly accessible website approved by the Battlement Mesa Community) 2 months prior to submission of the special use permit. 15 . Develop and implement plans to ensure remo val of mud from vehicles leaving the well pads and access roads to prevent tracking of mud onto Battlement Mes a and Garfield County roads . 16 . Adhere to all its best management practices in A p pendix E for spill prevention, control, and storm water control, and groundwater and surface w ater resources . 17 . Create a berm for all down gradient well pad perimeters and surface water diversion ditch es to prevent pollution of water and soil. 18. Conduct monthly inspection of water and gas pipeline for leaks to prevent water and soil pollution and that the results of the inspections be posted on the Garfield County Website. 19 . Immediately Report to GCOG (in addition to COGCC) any spill of one or more barrel s. Notification should take place within 24 hours and keep records of spill quantities , clean-up activities and preventive measures taken to a vo id future spills . Notification should be immediate if water sources are impacted . Part One Page 17 • • Draft Battlement Mesa HlA, Revision 1 February 2011 Conducted by Colorado School of Public Health 20 . Cover all drill cuttings when stored on well pads to prevent wind transport and soil pollution. We recommend that the BOCC: 21. Assign a Garfield County inspector to monitor Antero's compliance with the special use permit and that the special use permit contain provisions for regulatory action if Antero is found to be in non-compliance of the special use permit. 3.3 Findings and Specific Recom m endations from Traffic and Transportation Assessment W h at we know: An increase in traffic is associated with an increase in risk for motor vehicle accidents that can involve cars, pedestrians, and bicycles. These accidents can result in severe injury and death and the risk of severe injuries in motor vehicle accidents increases as the speed of traffic increases. Accidents involving heavy truck s have greater potential for death than those involving sma ll er vehicles. Increased traffic also increases air pollution and noise levels, and decreases quality of life for those living nearby. We know that Antero anticipates increased truck traffic on residential roads for the duration of the 5 year well development period. W h at we d o not know: We do not know if Battlement Mesa has dangerous traffic spots or the normal pedestrian/bicycle patterns . Based on these findings, the fo ll owing are specific recommendations to reduce the potential impact of traffic and transportation. As a condition of the special u se p erm it, we recommend that the B O CC require Antero to : 1. Install a fully funct ional water storage facility and pipeline network before any development of well pads in the Battlement Mesa. 2. D evelop industrial haul routes outside the PUD to remove natural gas development and prod uction-associated traffic from residential roads prior to any well pad construction within the PUD. Industrial traffic should be diverted from Stone Quarry Road to industrial haul routes at locations were homes are backed along the road . If indu strial haul routes outside the PUD are not constructed then we recommend the f ollowing co n ditions be met: 3. Communicate and coordinate with the local school district to develop a plan for transportation and safety needs of all chi ldren going to and from school by car, bus, bicycle and walking during and outside of school zone hours to prevent injury to school children . 4. Enforce truck speed limits to 20 mph within the PUD for all areas for all truck traffic associated with the project to reduce the severity of injury should an accident occur. Part One Page 18 • • • Draft Battlement Mesa H IA, Revision 1 February 2011 Conducted by Colorado School of Public Health 5. Mark pedestrian/bike high use routes and establish safe crossing zones where they intersect Battlement Mesa Parkway or other haul routes to alert drivers of potential pedestrians and bicyclers. 6. Install safety measures (ie, signaled cross walks, elevated sidewalks, green space buffers) for pedestrians/bikes where established walking/biking routes overlap/run along haul routes to prevent accidents. 7. Require safe driver training for workers and subcontractors and Antero implement penalty system for unsafe workers, to encourage safe driving. 8. Implement a system to identify and remove unsafe drivers to prevent accidents and injuries. We recommend that Garfield County: 9. Provide Sheriffs Auxiliary Unit with authority to log speeding and unsafe driving incidents and complaints within the PUD. Information about incidents involving the Antero workers or subcontractors can be provided to Antero , subcontractors and the Sheriffs department so that prob lems and unsafe conditions can be resolved. 10. Request that the Garfield County Sheriffs Department or other qualified entity review Antero's Traffic Impact Analysis and request feedback on possible safety mitigations and traffic hot spots to ensure the plan is protective of public health. We recommend that Antero: 11. Consider speed control measures on worker ingress and egress routes within the PUD (ie decreased speed limits, signage, real time speed measurement signs, photo speed ticket vans, speed bumps or other measures) to prevent speeding. 3.4 Findings and Specific Recommen dations from Noise, Vibration, and Light Assessment W h a t we k now : Noise can have negative effects on public health yet can vary at the individual level. Background noise leve ls in most of Battlement Mesa are low. We know that well development activities wi ll last several months for each well pad and that some homes will be proximate to more than one well pad, thus experiencing well deve lopment noise for many months. COGCC noise rules do not take into account possible health impacts of noise from extended well development periods. Noise levels associated with well development activities have been measured above levels that are likely to cause health impacts, even though these levels meet C OGCC permissib le leve ls. Noise mitigation effectiveness may be in part determined by local topography and meteorology. W h a t w e do no t know: We do not know if planned noise mitigation strategies will bring noise levels at residences below which hea lth impacts do not occur. We do not know a single distance from we ll s that is sufficient to provide protection from noise impacts. Part One Page 19 • • • Draft Battlement Mesa HIA , Revision 1 February 2011 Conducted by Colorado School of Public Health Based on these findings, the following are specific recommendations to reduce the potential impacts to public health from Noise, Vibration, and Light. As a condition of the special use permit, we recommend that the B O CC require Antero to: 1. Improve sound mitigation to achieve noise levels below 55 dbA in the day and 50 dBA at night during all well development and production activities at the distance of 350 feet from the noise source on the well pad. Require Antero to monitor noise and to use best mitigation technology available to maintain these levels throughout the development period . 2. Require best available noise reduction technology for heavy equipment, including trucks and truck brakes, to reduce noise levels. 3. D evelop and implement Community Advisory Board which can address the Battlement Mesa resident's concerns about noise. This can help prevent long-term nuisance noise levels , in cooperation with Battlement Mesa residents and Garfield County. For further details regarding the recommendation for a Community Advisory Board, see recommendation for Community Wellness Assessment. 4. Alert residents of anticipated noise , including time, duration, decibel levels, and machinery to be u sed to protect public health. 5. Deve lop industrial haul routes to remove truck traffic from the PUD and away from the homes on Stone Quarry road . If industrial h aul ro u tes are not developed then: 6. Reduce speed limits for trucks within the PUD to 20 miles per hour to reduce noise and vibration levels. 7 . Consider installation of traffic noise barriers near the St. John Elementary School and/or Grand Valley Middle School to reduce noise levels at schools if school staff indicates that there are noise impacts at the school. 8 . Install permanent/semi-permanent noise mitigation structures (sound walls) along haul routes CR300 and other routes where trucks are anticipated to be passing throughout the development period to reduce noise levels. 3.5 Findings and Specific Recommendations Related to Community Wellness What we know: A variety of physical and social factors impact the health of a community. Natural gas deve lopment can have positive and negative social and community impacts, mostly during the development period. Battlement Mesa saw increases in crime, sexually tra nsmitted disease and schoo l population and a decline in educational environment during the years of natural gas boom in Garfield County. D rug and alcohol abuse are of concern within the natural Part One Page 20 • • • Draft Battlement Mesa HIA, Revision 1 February 2011 Conducted by Colorado School of Public Health gas industry. Citizen concerns reflect the community's previous and current experience with the natural gas industry. Citizens report current decline in social cohesion and community experience and some citizens report health impacts due to these changes. The Antero project will impact outdoor amenities. Impacts to the community will in a large part depend upon how well other concerns, such as air quality, traffic and noise, are mitigated. What we do not know: We do not know the extent to which the Antero project will support existing and new local business, or the way the one million dollar donation to the community will be used. We do not know what fraction of citizens are currently experiencing decline of quality of life, nor how many are likely to have such concerns once the development period begins. Measurements related to mental health and suicide, substance abuse, lifestyle and social cohesion are not routinely monitored. Recommendations to Reduce Impacts to Community Wellness Based on these findings, the following are specific recommendations to reduce the potential impacts to community wellness. We recommend that Antero, Battlement Mesa Citizens, and Garfield County: 1. Establish a Community Advisory Board to facilitate on-going community engagement between Antero, Garfield County officials, Battlement Mesa Company and residents of Battlement Mesa for early identification of impacts to community wellness. A Community Advisory Board can provide direct and frequent interactive communication between these groups. It can provide an ongoing mechanism for citizens to report problems and concerns to Antero and can allow Antero to address concerns in a timely manner. It can also provide feedback to the county regarding success of residential natural gas development. A Community Advisory Board can also provide an opportunity for Antero to apprise the residents of current activities and changes to plans, which can help reduce uncertainty for residents and may decrease anxiety. The Community Advisory Board can also provide input regarding the use of the one million dollar donation to ensure that the use of this money supports community and physical health. We recommend that Garfield County: 2. Review sexually transmitted infection clinic access, outreach and education, with particular attention to in-migrant workforce to reduce spread of sexually transmitted infections within the community. 3. Identify operators and subcontractors that have implemented drug and alcohol free work- place programs and encourage Antero to do so and subcontract to companies that also do so. Provide Antero with contacts to those that educate employers regarding benefits of such programs. Part One Page 21 • • • Dr a ft Battlement Me sa HIA , Revi s ion 1 February 201 1 We recommend that Garfield County and Antero: Cond ucted by C ol orado Sc hool of Publi c He a lth 4 . Support baseline and ongoing studies to determine the impact of residential natural ga s development on community health and the effec ts on individual health . This information will provide direct feedback to the Antero-B attlement Mesa project, allowing for improvements in community aspects as the proje ct continues . It will also provide valuable information for other communities experiencing or anticipating residential natural ga s development. These studies should include m eas urements rel ated to lifestyle and social cohesion, education, crime , sexually transmitted infection, mental health and suicide , and substance abuse. 5 . Ensure recommendations to mitigate other conce rn s (air quality, traffic , and noi se) are implemented . Reco m m endation s to Support B en efi ts t o Commu nity Well ness Based on these findings , the following are specifi c recommendati o ns to fo ster the potential benefits to community wellness. We reco m mend that Garfield Cou n ty: 6. Encourage use of local business , especially those that enhance community cohesion, such as local restaurants and coffee shops . 7 . Utilize Antero 's one million dollar donation to enhance community cohesion. 3.6 Findings and Specific Recomm en dations from Economic and Employment Assessment W h a t w e k no w : The Antero project in Battlement Mesa will employ approximately 120-150 people. Some Battlement Mesa residents will benefi t directly from the Antero project but mo st residents will not directly benefit. Natural gas devel opment causes a decline in property value , especially during the development phase of the proj ec t and land values partially recover when the development phase of a project ends . The development phase for the Antero project in the PUD is expected to last at least 5 years . Antero's project within the PUD will not likely initiate a boom and bust cycle. Land values effects will be im p acted by how well other concerns , such a s air emissions, traffic, noise and community wellnes s, are mitigated. W h a t we do n ot k n ow : Specific time lines for deve lo pment and maintenance activities for the project are not known and this gap contributes to uncertainty . It is not known if the Antero project wi ll impact renta l or sales housing demand in Battlement Me sa . It is not known how land values will respond to the 5 year development period or if land values in Battlement Mesa will fo ll ow the same patterns as those seen in the Land Val ues Study. R ecommenda tion s to R educe Impa cts fro m E cono m ic Eff ects Part One Page 2 2 • • • Draft Battlement Mesa HlA, Revision I February 2011 Conducted by Colorado School of Public Health Based on these findings , the following are specific recommendations to reduce the potential impacts to property values. We recommend that before the project starts, the BOCC require Antero to: 1. Require that Antero develop a reasonable and specific timeline for all activities associated with development and maintenance of the wells. Require that Antero communicate changes to the plans at the earliest possible time before any changes in the plans occur. This would address some concerns in the real estate market. If sellers and buyers can confidently anticipate the steps and timing of the well development process, the real estate market may react less unfavorably to the project. We recommend that Antero, Battlement Mesa Citizens, and Garfield County do the following before the Project starts: 2 . Establish a Community Advisory Board that meets regularly and frequently with Antero (at least every month). Garfield County, citizens , Antero and the Battlement Mesa Company should be a part of this bo ard. The Community Advisory Board can actively interact with Antero to facilitate communication to and from the residents and the county. Establish clear and timely communications methods to facilitate information regarding changes to the timeline and activitie s . Provide the Community Advisory Board with sufficient powers to allow for resident input , which can demonstrate that residents can voice their concerns . 3. Consider multiple methods of communication to residents regarding development and maintenance activities . We recommend that Garfield County: 4. Continue to consider public health as a high level priority when judging uses of local government revenues derived from the natural gas development and production to maximize protection of public health. 5. Ensure recommendations to mitigate other concerns (air quality, traffic, noise and community wellness) are implemented . Recommendations to Support Benefits from Employment Effects Based on these findings, the following are specific recommendations to foster the potential benefits from employment. We recommend that Garfield County: Part One Page 23 • • • Draft Battlement Mesa HlA, Revision 1 February 2011 Conducted by Colorado School of Public Health 6. Support local educational institutions that provide training for industry related jobs during the development period and retraining for when industry jobs end after the development period. 3. 7 Findings and Specific Recommen dations Related to Health Care Infrastructure W h at we kno w: The availability of healthcare facilities and professionals affects public health . The level of health insurance in an area affects health care infrastructure . Battlement Mesa has primary care and some specialist services in the community. Specialized and emergency care is at least 20 miles away. It is not expected that health care infrastructure will be impacted by the Antero project to the extent that will impact health of the residents. What we do no t kn ow: The level of health insurance coverage amongst workers in natural gas deve lopment and production is no t known. The number of Antero workers and families that will uti lize medical care in Battlement Mesa is unknown . Based on these findings, the fo ll ow ing are specific recommendations to prepare for the potential impact to the Health Care infrastructure. We recommend that Garfield County: 1. Monitor which companies, including Antero and subcontracting companies, provide health insurance to employees to determine how the natural gas industry contributes to health care infrastructure. 2 . Monitor health care utilization in Garfie ld County to determine if rates of uncompensated care are associated natural gas industry cycles. 3. Ensure that county revenues continue to meet changes in county services, including public healt h services. 3.8 Findings and Specific Recommendations from Assessment of Accidents and Malfunctions W hat we kno w : A small numb er of accidents and malfunctions occur on a regular basis in natural gas development and production. These acc idents and malfunctions can have minor to catastrophic consequences and can impact air, water, and soil quality along with the health of workers and nearby residents. Lack of adherence to rules and regulations, as well as regulatory oversight and enforcement increases the likelihood of accidents and malfunctions. While Part One Page 24 • • • Draft Battlement Mesa HIA , Revision 1 February 2011 Conducted by Colorado School of Publi c Health increased preventive measures and enforcement of regulations can reduce the likelihood of accidents and malfunctions, they cannot ensure that a catastrophic event will not occur in the Battlement Mesa PUD as a result of Antero's project. What we do not know : We do not know how many accidents and malfunctions will occur in the PUD and we do not know if a catastrophic event w ill occur in the Battlement Mesa PUD as a result of Antero 's project. We do not know if the current setbacks and placements of pads, pipes , and maintenance stations are sufficient to protect residents from catastrophic malfunctions. We also do not know if there are emergency plans in place that adequately address catastrophic incidents . Based on these findings, the following are some of the specific recommendations to reduce the potential public health impact from accidents and malfunctions. We recommend that as a condition of the special use permit the BOCC require Antero to: 1. Work with emergency responders in Battlement Mesa (e.g ., the sheriff and fire departments) and Battlement Mesa residents to establish a comprehensive emergency response plan that includes notification and communication system s, evacuation routes , plans for evacuating schools , the assisted living facility, and capacity of local emergency responders hospitals , and sheltering in place, accurate maps of pipelines, shut-off valves , and well pads, as well as identifying air intakes at the schools, assisted li v ing facility, and recreation center prior to any activity in the PUD . We recommend that the copies of the emergency response plan be kept at the sheriff department, fire department, a ll responding hospitals, and on a Garfield County website and /or a publicly accessible website approved by the Battlement Mesa Community. 2 . Test the emergency response plan in cooperation w ith emergency responders by performing a drill prior to any natural gas operations commence in the PUD and annual drills thereafter, as well as annual reviews and updates of the emergency response plan. 3. Annually disclose all chemicals used on its well pads within the PUD and include a list of these chemicals in the emergency response plan. 4. Notify the sheriff and fire department one week prior to well drilling, hydraulic fracturing , flow back, and pipeline pigging activities. 5 . Implement the emergency response provisions provided in Antero 's best management practices submitted as comments to the September 2010 Draft HIA . 6. Implement the well site and facility security provisions provided in Antero 's best management practices submitted as comments to the September 2010 Draft HIA. 7. Adhere to its best management practices for pipe lines and all COGCC rules throughout the life of the project as a condition of the special use permit. 8. Institute mechanism for reporting safety concerns, near-misses, and minor incidents to the appropriate designated county agency or department to reduce accidents and malfunctions. Reports of these concerns and incidents should a lso be made to the Community Advisory Board, along with plans for preventive and corrective actions. Part One Page 25 • • Draft Battlement Me sa HIA , Revi s ion 1 February 2011 C onducted by Colorado School of Public Health 9 . Develop an ongoing fire prevention program in coordination with the local fire department 's community fire prevention program. This program should include routine inspection and implementation of wildfire mitigation plans (for example, all areas surrounding well pads are kept clear of vegetation that could contribute to sp reading). We recommend that Garfield County: 10 . Clearly mark primary and secondary evacuation routes from Battlement Mesa. 11. Perform quarterly tests of emergency notification systems within Battlement Mesa (e.g., sirens and reverse 911 ). 12. Request the Battlement Mesa fire department to inspect all proposed well pad locations and make recommendations for the prevention of we ll pad fires spreading from the pads up to relocation of pads and that these recommendati ons are incorporated into the special u se permit. 13 . Require all gas pipelines to follow established tru ck haul routes and allow no gas pipelines through the center of the PUD . 14. Assign a county inspector to oversee and inspect a ll pipeline construction and maintenance in the PUD . Part One Page 26 • • Draft Battlement Mesa HlA, Revision 1 February 2011 Conducted by Co lorado School of Public Health 4 Summary of Assessments on Health in Battlement Mesa Eight potential stressors to health were identified and ass essed: air quality; water and soil quality ; traffic and transportat io n; noise/vibration/lighting; community wellness; employment /economy; health system infrastructure; and accidents/malfunctions. These assessments take into account Antero's proposed control plans and mitigation strate gies, to the extent that they are known (from public presentations, Surface Use Agreements, and other information provided by Antero). Any significant deviation from the currently available information will not necessarily be reflected in this assessment. Scientific literature de scri bing known impact of stressors to health was reviewed . Each stressor was qualitatively characterized base d on seven attributes relevant to public health: direction of health effects; geographic extent; likeli hood; vulnerable populations ; duration of exposure; frequency of exposure; and magnitude/sev erity of health effects. For each attribute, consistent definitions were created as shown in the tab les below. The characterization consists of describing and ranking each potential health impact in terms of each attribute and prioritizing (low, medium, and high) the potential stressor as it rel ates to other potential stressors . Direction of Potential Health Effects Positive Negative Changes that may improve health in the community Changes that may d etract from health in the community Geo2raphic Extent of Health Effects Localized Effects mainly occur in close proximity to drilling or other related activities ~~~~~~~----< Community-wide Effects occur acro ss most or all of the Battlement Mesa PUD Presence of Vulnerable or Benefited Populations within Battlement Mesa Yes There are subpopulations that are more susceptible to adverse health impacts (e.g. children, the elderly or people with pre-existing health conditions) or will benefit mo re than the rest of the population No Affects all subpopulations evenly Duration of Exposure I Short I Lasts less than one month Part One Page 27 • • Conducted by Draft Battlement Mesa HIA , Revision 1 February 2011 Colorado School of Public Health Medium Lasts at least one month but less than one year Long Lasts one year or more Occurs constant! , recurrently and/or numerously Likelihood of Health Effects Unlikely Possible Likely There is little evidence that health effects will occur as a result of the Antero drilling in the PUD Evidence suggests that health effects may occur, but are not common in similar situations Evidence suggests that health effects commonly occur in rojects of this t e Ma nitude/Severit of Ne ative Health Effects Low Medium High Potential to cause health effects unlikely or that can be uickly and easily mana ed or do no t re uire treatment Potential to cause health effects that necessitate treatment or medical mana ement and are reversible Potential to cause health effects that are chronic, irreversible or fatal Ma nitude of Positive Health Effects Low ormmor Medium Potential to make some im rovements to health Hi h Potential to make major im rovements to health EXAMPLE: The following characterization of a hypothetical health impact from Antero 's plan illustrates how attribute levels are assigned. Impact Direction Geographical Vulnerable/ Duration Frequency Likelihood Magnitude of health Extent of Benefited of of exposure of health of health effects exposure populations expos ure effects as a effects result of Pro"ect H othetical Negative Localized No Short lntre uent Unlike! Low The hypothetical health impact may produce negative health effects only in areas in close proximity to the development areas and is localized. No particular population is more vulnerable to the health effect. The duration of the hypothetical impact is expected to be less than a month, short, and only occur once, infrequent. It is unlikely to occur and any health Part One Page 28 Priority Low • • • Draft Battlement Mesa HIA, Revision 1 February 2011 Conducted by Colorado School of Public Health effects could be easily managed at home and would be low. The hypothetical health impact has a low priority compared to other potential stressors. 4. 1 Summary of Health Assessments The following table summarizes the characterization of stressors and the numerical ranking of impacts on the health in Battlement Mesa. By prioriti zing the stressors we are able to conclude that air quality, traffic, and accidents/malfunction are more likely to negatively impact the public health of residents throughout the community than other stressors. Other stressors that may produce relatively important health impacts include noise and community stress . We have prioritized community stress as medium but recognize that the impacts to the community depend in a large part on the mitigation of other stressors. If mitigation of air, traffic and noise are not sufficient then the sense of community will be negatively impacted, associated stress will increase, and steps to protect community wellness should take a high priority. Compromise of water supplies could produce important effects to heal th but are not likely to occur. There will be some positive impacts associated with employment and possibly community wellness . We have prioritized accidents and malfunctions as high but note that incidents of this nature are difficult to predict. Recent events have demonstrated that although accidents and malfunctions are infrequent, on ra re occasions they can be devastating; therefore, significant care should be taken to prevent them. Assessment Direction Geographical Vulnerable/ Duration Frequency Likelihood Magnitude of health Extent of Benefited of of of health of health effects exposure populations e xposure exposure effects as a effects result of Project Air Quality Negative Local to Yes Lo ng Frequent Likely Moderate Community-to High wide Water and Negative Community-Ye s Long Infrequent Unlikely Moderate Soil Quality wide to High Traffic Negative Community-Ye s Lo ng Frequent Possible Low to wide high Noise, Negative Local Yes Lo ng Frequent Possible Low- Vibration, Medium Light Community Positive Community Ye s Lo ng Frequent Possible Low Wellness wide Community Negative Community Yes Long Frequent Possible Low to Wellness wide High Economy, Positive Community Yes Lo ng Infrequent Unlikely Low employment wide and property value Part One Page 29 Priority High Medium High Medium Low Medium- Hig h Low • • • Draft Battlement Mesa HIA, Revision 1 February 2011 Assessment Direction Geographical of health Extent of effects exposure Economy, Negative Community employment wide and property value Health Positive Community- Infrastructure wide Health Negative Community- Infrastructure wide Accidents Local or and Negative Community malfunctions wide Vulnerable/ Duration Benefited of populations exposure Yes Long Yes Long Yes Long Yes Short Part One Page 30 Conducted by Colorado School of Public Health Frequency Likelihood Magnitude Priority of of health of health exposure effects as a effects result of Project constant Likely Low to Low high Infrequent Unlikely Low Low Infrequent Unlikely Low Low Infrequent Possible Low to High h igh • • Draft Battlement Mesa HIA , Revision I February 2011 5 Assessment of Health Impacts Conducted by Colorado School of Public Health The following sections provide an assessment, characterization, and recommendations for each potential health impact. 5.1 Assessment of Air Quality on Health in Battlement Mesa "What happens if the air is so bad that I have to close all my windows and shut off my swamp cooler?" June 15 stakeholder meeting Exposure to airborne contaminants from natural ga s development and production is a major concern to Battlement Mesa residents. Gas development and production operations result in the release of many airborne contaminants . The potential for release of contaminants to air increases with well installation errors , blow outs , or well fir e s. Sources of contaminants during these operations include the natural gas resource itself, chemicals used in well development operations, such as hydraulic fracturing, wastes from well deve lopment activities such as produced water, and diesel exhaust from trucks and generators . 5.1.1 Air Quality and Health Natural gas development and production operations and the diesel engines used to support them have the potential to release many hydrocarbons, carbonyls, and other contaminants into the air. People can be exposed to these contaminants as they breathe ambient air in and outside of their homes . Some of these contaminants, such as benze ne, diesel exhaust, and PM2.5, are human carcinogens. Others, such as carbonyls, alkanes, ground-level ozone, and 1,2,4- trimethylbenzene, can act as irritants of the eyes, skin, and respiratory tract or cause neurological effects2 3-24 . In addition, hydrocarbons, carbonyls, and nitrogen oxides serve as precursors for ground level ozone formation. The health effects of many other potential contaminants are not known. Descriptions of health effects of the air contaminants of potential concern are presented in Section 4 of the Human Health Risk Assessment (Appendix D). In addition to the effects that each of these substances can produce by itself, there is also the possibility of complex health reactions occurring as a result of the interaction of multiple substances. The current state of the science is limi ted in ability to assess exposures to these complex mixtures of air toxics, especially, synergistic and antagonistic interactions at low levels. Preliminary studies that indicate complex mixtures can act additively or synergistically to increase effects on human health. For example, studies of healthy adults indicate that continuous exposure to sulfur dioxide or nitrogen dioxide increases ozone absorption. Studies of asthmatics suggest that ozone enhances response to allergen challenge. Other studies have reported injury Part One Page 31 • Draft Battlement Me sa HIA , Revision 1 February 2011 Conducted by Colorado School of Public Health to lungs with exposure to the combination of ozone and PM is larger than when exposed to either alone. 24 -25 . 5.1.2 Current Air Quality Conditions There are several sources of air emissions that currently affect air quality in Battlement Mesa. The main sources are vehicle emissions and natural gas development and production, as described below. With the exception of two natural gas wells, Battlement Mesa does not currently house any industrial activity. There are many gas wells outside the PUD boundaries that impact the ambient air quality within the PUD. There is a public utility station near the southeast PUD border with the potential for fugitive emissions of natural gas . Current residential traffic in the Battlement Mesa PUD, described in Antero 's traffic analysis , also has impact on the current ambient air quality. Interstate-70 impacts the current ambient air quality . The Garfield County Emissions Inventory for 2007 indicates that highway vehicles were a primary contributor to carbon monoxide and nitrogen dioxide emissions and that highway vehicle emissions of carbon monoxide, nitrogen dioxide , sulfur dioxide, particulates , voes, and benzene have all decreased since 1996. The oil and gas industry was a primary contributor to sulfur dioxide, nitrogen oxide, carbon monoxide , VOC , and benzene emissions in 2007 and emissions due to oil and gas • sources have all increased in the same time period26 . High concentrations of ozone precursors (VOCs and nitrogen oxides) have been observed in areas with hi~h natural gas production operations in Garfield County2 6 . CDPHE ranked Garfield County as 51 out of 64 Colorado counties in level s of these ozone precursors in 2009, while Garfield ranked only 14th in population27 . According to these reports, because VOC levels are already very high, ozone formation in Garfield County is likely to increase as nitrogen oxide increases . In 2008, the 8-hr average ozone concentrations measured at the Rifle monitoring station surpassed the 75 ppb NAAQS one time and 8-hour average ozone concentrations did surpass the minimum range of the proposed 60 -70 ppb NAAQS on five days in March and April 2009, with a maximum concentration of 64 ppb2 8 . Overall, ozone levels in Garfield County are increasing since measurements began in 2005. Natural gas industry practices of capturing and flaring emissions reduces VOC emissions , while increasing nitrogen oxide emissions . This may contribute to more ozone formation . It is unclear if oz one concentrations measured in Rifle are representative of ozone concentrations in Battlement Mesa because of differences in proximity to Interstate-70, elevation, industry, and meteorology . EnCana Oil and Gas (USA) Incorporated (EnCana) began conducting ozone measurements in 2007 at their mountain station in Garfield County . The mountain station is located at 8407 feet above sea level in a remote area with very little natural gas development and production . While Encana's ozone data are from a rural area within Western Garfield County, it may not be a good estimate of ambient ozone levels in the Battlement Mesa PUD. Ground level ozone concentrations vary by elevation, with higher concentrations at higher elevations. Part One Page 32 • • Draft Battlement Me sa HIA , Revision I February 2011 Conducted by Colorado School of Public Health PM2.s and PM 10 concentrations are meas ured at the Rifle monitoring station where several 24- hour PM2.5 concentrations surpassed 35µg /m3 in 2009 , with the highest observed concentration at 41µg /m3 28 In 2008, PM 10 , concentrations in Parachute surpassed the 150 µg /m324 hour NAAQ S standard, li kely due to natural gas industry construction activities . The PM2.s and PM10 concentrations measured in Rifle and Parachute may not be representative of concentrations in Battlement Mesa because of differences in proximity to Interstate-70 , elevation, industry, and meteoro logy. 5.1 .3 What We Know and What We Do Not Know There is sufficient information available to indicate that Antero's project in Battlement Mesa has the potential to impact air quality and the public health. However, many information gaps exist and it is not possible to predict what and how many health effects will occur as a result of Antero's project. There also is not enough inform at ion to determine whether or not current federal, state , and COGCC regulations and rules are sufficient to protect public health from air pollution resulting from natural gas development and production in high population density areas such as the Battlement Mesa PUD . To protect the health of Battlement Mesa residents , we recommend the implementation of air pollution prevention measures , some of which may be above and beyond those mandated in federal , state , and COGCC regulations and rules as an integral part of Antero's project. We also recomm end the monitoring of air quality and the health of residents in Battlement Mesa to ensure public health is protected throughout Antero's 30-year project. What follows is a discussion of what we know and what we do not know and specific recommendations for preventing air pollution during Antero's project. What We Know We know that natural development and production impacts air quality in Garfield County. Garfie ld County's 2007 emission inventory indicates that the oil and gas industry is the highest contributor to nitrogen dioxide , benzene, and sulfur dioxide emissions within Garfield County. For example, the oi l and gas industry contributes fiv e times more benzene to the inventory than any other emission source listed . The oil and gas industry also is a significant contributor to VOC, PM10, and carbon monoxide emissions26 . Therefore, it is expected that Antero 's project has the potential to impact air quality in the PUD. Garfield Co unty's 2009 Air Qu a lity Monitoring Summary Report attributes natural gas production activities as the largest contributing source of light alkanes in Garfield County. The large amounts of these light alkanes increase the potential for ozone formation28. Benzene, ethylbenzene, to luene, xylene , and trimethylbenzene measurements for 2009 in Garfield County were compared to regional measurements from 37 s ites across the United States . Levels of benzene, to luene , xylenes, and 1,3,5 -trimethylbenzene measured at the Parachute, Rulison, and Rifle sites in Garfie ld County were higher than le ve ls measured at most of the other sites, incl uding Grand Junction. These high meas urements in Garfield County may indicate more Part One Page 3 3 • • • Draft Battlement Mesa HlA, Revision 1 February 2011 Conducted by Colorado School of Public Health localized sources for these air contaminants, which have primarily gasoline and diese l combustion sources that include motor vehicles, oil and gas development activities (such as drill rigs and compressor engines) as well as oil and gas production equipment such as condensate tanks2 8 . Antero has specified that they will use combustors to control VOC emissions from production tanks6 to achieve a 95% VOC control efficiency in compliance with COGCC rules5 . Applying a 95% control efficiency to the potential VOCs emissions estimated for the Watson Ranch pad (Appendix E, Antero comment A34) results in 3.4 to 20 tons per year of VOC emissions from the production tanks on all 9 proposed well pads combined. Production tanks are only one of a number of potential sources of VOC emissions from natural gas operations. Some sources , such as flow back operations, are likely to cause a higher emission rate of VOCs , while others, such as glycol dehydrators, may have VOC emissions similar to the production tanks. Monitoring of production sites is needed to assess the long term emi ss ions and how these emissions affect long term exposures to nearby residents . It is important to note that there is a tradeoff when using combustors versus not controlling condensate tanks at all. Combustion of fugitive VOC emissions generates carbon monoxide, carbon dioxide, and nitrogen oxides , whereas venting results in VOC emissions. Therefore, vapor recovery is preferred over venting or combustion for controlling fugitive voe emissions We know that well completion operations emit the higher levels of contaminants than drilling operations . The 2008 Garfield County Air Toxics Study which monitored four sites undergoing drilling activities and four sites undergoing well completion activities concluded that the well completion activities emit larger volumes of VOCs than drilling activities. The report indicated that the high concentrations of organic VOCs could b e of great concern, as many of the well pads are located close to populated areas in Garfield County . In addition, the report indicates that local wind speeds, directions and surrounding topography are important factors in influencing levels of pollutants at any one sampling site . The report called for further research into how pollution concentrations are affected by these variables and concluded that research is needed to understand the local effects that such drilling and completion activities can have on the public at large29 . Furthermore, statistical comparisons of ambi ent air to well completion sample results for benzene and other contaminants demonstrate that short-term exposures to air pollutants during well completion activities have the potential to be significantly greater than overall ambient air exposures (Appendix D Table 2-12). We know that the COGCC's 350 foot setback for hi gh density areas was based on a 100 meter setback distance established by the Alberta Energy and Utilities Board to decrease the likelihood of death from exposure from an accidental release o f hydrogen sulfide gas 30 (Stuart Ellsworth, Engineering Manager COGCC, January, 18, 2011 ). The 350 foot setback does not address short and long term health effects that may be associated w ith periodic or continuous exposure to other air pollutants , noise exposure, and accidents. At this time there are no known studies that document the safe distance between wells and hom es, schools and other places where people congregate . Part One Page 34 Draft Battlement Mesa HlA, Revision 1 February 2011 Conducted by Colorado School of Public Health We know that there are several COGCC rules to address air emissions. Rule 324A requires operators to take precautions to prevent significant negative impacts to air; Rule 317 requires that any gas escaping during drilling must be directed a safe distance from the well and burned (flared); and Rule 805b requires that gas facilities and equipment shall be operated in such a manner that odors and dust do not constitute a nuisance or hazard to public welfare. Rule 805b also requires emission controls and permitting for production tanks with the potential to release 5 or more tons per year of VOCs (uncontrolled emissions) and located with '.;,! mile of an occupied structure. However, recent odor complaints to COGCC and the Garfield County Oil and Gas Department from Battlement Mesa residents in July 2010 suggest that, in some situations, natura l gas development and production may have some impact on localized air quality at residences within Yz mile of the well pad 5• 31 • The odor complaints occurred during flow back operations at Antero's Watson Ranch Pad located on the southeast border of the PUD, within approximately Yz a mile from several residences , and resulted in COGCC issuing a notice of alleged violation (also known as NOAV) to Antero on 7/14 /2010. Grab samples taken in the 2005 to 2007 Garfield County Ambient Air Study, when residents noticed odors (thought to be from natural gas development and production) indicate that odor events could represent a health hazard. These samples contained levels of benzene, ethylbenzene, toluene , and xylenes that were greater than EPA regional screening levels for residential ambient air 16 • EPA Regional Screening Levels are health-based levels above which health effects may oc cur. • We know that many homes within the Battlement Mesa PUD are located within a Yz mile of one or more of the proposed wells pads, as shown on Figure l. For example, homes in Stone Ridge Village and Monument Village are within Y2 mile of pads A , B, and D , and homes in Willow Creek Village and Fairways Village are within Yz mile of pads D and M. Antero's project is expected to last up to 30 years and have approximatel y 200 wells on 9 well pads . The process of well development and completion is estimated to las t from 2 to 5 years , depending on the price of natural gas and availability of subcontractors . Therefore due to proximity of the proposed well pads to residences it is likely that both periodic short-term and longer-term exposures to emissions will occur. • We know that diesel exhaust from heavy truck traffic, truck idling and generators has the potential to impact air quality within the PUD. Di esel exhaust includes PM, nitrogen oxide, carbonyls, alkanes and PAHs , all of which are kno wn to have health impacts32 . Estimates of yearly emissions can be found in Table 4 in the Part Two of the HIA. Levels of acetaldehyde and crotonaldehyde were higher in grab samples collected by Antero in August 2010 than in any of the ambient air samples collected in Garfield County since 2008 (Appendix D, Table 2-7). The Antero samples were collected along the truck access road to the south of the Watson Ranch pad during flow back and hydraulic fracturing activities. This information indicates a need for pollution controls on diesel engines . Since each of the proposed truck routes is near at least one of the Battlement Mesa housing areas, further informat ion is needed to better characterize the level of exposure for residents to carbonyls emitted during natural gas development and production operations and efforts are needed to reduc e exposure to truck traffic. Part One Page 35 • • Draft Battlement Mesa HIA, Revision l February 2011 Conducted by Colorado School of Public Health We know that several of the air pollutants associated with natural gas development and production can negatively affect human health. Benzene is a known human carcinogen, and ethylbenzene, acetaldehyde, formaldehyde, and crotonaldehyde are classified as possible human carcinogens by the U.S. EPA. Furthermore, toluene, xylene, and benzene may also cause other non-cancer health effects, such as birth defects. Many of these air pollutants cause short-term neurological effects, such as dizziness and headaches, and short and long term respiratory effects, such as nose and throat irritation and decreased lung function. Seniors, children and those with medical conditions are more susceptible to chemical exposures. Battlement Mesa is different from many other Colorado communities in that almost half of the community is either under 18 or over 65 years of age. We know that there are many other sources of air pollution not being measured. We know that fugitive emissions from pipes, valves, pneumatic devices, wellheads and from maintenance operations have the potential to impact Battlement Mesa air quality and can do so over the life of the project, estimated to be at least 30 years. COGCC rules require that no bleed valves be used on pneumatic devices, where technically feasible and Antero has agreed to specific requirements for pipelines in the Surface Use Agreement. Further efforts may be needed to control all sources of emissions. We know that road and construction dust from natural gas operations can impact air quality. The dust from the Antero project has the potential to impact the air quality in Battlement Mesa. As noted earlier, PM10 concentrations measured in Parachute in 2009 surpassed the NAAQS standard, likely due to natural gas industry construction activities. What We Do Not Know We do not know how and to what extent potential air pollutants from Antero's project will be transported within the Battlement Mesa PUD. While levels of air pollutants generally are expected to decrease with distance from a fixed source, actual emission distribution maybe more complex due to varying emission rates and topography and weather conditions. The distribution of air pollutants also will depend on the physical and chemical properties of individual pollutants. Some pollutants, such as ozone require very specific conditions for formation . At this time, there is insufficient measurement and modeling information to determine air pollutant movement from well pads and truck routes to people's homes. We do not know how much of each air contaminant Battlement Mesa residents will be exposed to during Antero's project because there is little information on the concentrations of air contaminants in and around residences. The only information currently available is that from the 15 second outdoor grab samples collected by Garfield County residents when they noticed odors attributed to natural gas development and production activities. This information is limited in that ( 1) data was not collected to identify a specific source; and (2) the sample was a 15 second grab and therefore did not represent a 24-hour exposure and may have missed the peak level. Part One Page 36 • • • Draft Battlement Mesa HIA, Revision 1 February 2011 Conducted by Colorado School of Public Health We also do not know how much of a particular contaminant to which an individual is exposed comes from natural gas operations and how much comes from other sources . We do not know the toxicity of most of the chemicals measured in Garfield County air samples. Health-based toxicity guidelines are only available fo r about 20 percent of the contaminants that have been identified in ambient air samples collected in Garfield County. For most of the remaining air pollutants , adequate studies to determine health effects have not been done . We do not know the level of many potential air pollutants in ambient air that may be associated with natural gas development and production, inc luding polycyclic aromatic hydrocarbons (PAHs), heavy metals, radon and chemicals used in natural gas industry (e.g ., hydraulic fracturing fluids, biocides) . These pollutants hav e not been measured in Garfield County relative to the natural gas industry. We do not know if health effects will occur as a result of the interaction of the mixture of air pollutants present in Garfield County. The current state of the science is limited in ability to assess exposures and health effects of mixtures of air pollutants , especially interactions at relatively low levels. We do not know how long people will reside in Battlement Mesa and how much time they spend in Battlement Mesa and at their homes . This type of information is used in determining how much an air contaminant a resident would be exposed to during Antero 's 30 year project. Specific data on how long residents live in the area and how many days and hours they spend in their homes is not currently available . Because mo re retirees live in Battlement Mesa than in more typical suburban/rural areas, data from other areas and studies may not apply to Battlement Mesa. These time activity studies also may not account for individuals that work out of their homes. We do not know what the levels of emissions will be after Antero implements all of the ir pollution control measures . Antero's general best management practices indicate Antero is committed to reducing air pollution. Documentation of the effectiveness of the pollution control measures is needed. 5.1.4 Human Health Risk Assessment To develop a risk assessment, scientists need to ident ify three main things : • Hazards: identities and toxic properties of the chemicals to which people are exposed. • Exposure Levels and Routes: depend on the amount of exposure, length of exposure, and whether people are exposed through their lungs , digestive track or skin. • Health Outcomes: the potential for health risks , including cancer risk, is the focus of risk assessments. Part One Page 3 7 • • • Draft Battlement Mesa HIA, Revi s ion l February 20 1 1 Conducted by C o lorado School of Publi c Health We used availab le relevant information to conduct a screening leve l Human Health Risk Assessment to evaluate the potential impacts to the public health from chemical exposures due to Antero's proposed project. A Human Health Risk A ssessment cannot predict what and how many health outcomes will occur as a result of Antero 's project. It only provides an estimate of the potential for health outcomes to occur given the information available and is a tool for ranking the relative seriousness of risks from different sources and pathways. It is important to emphasize that the estimates from the Human Health Risk Assessment may be either over or under estimated because of the uncertainties associate d the risk assessment Erocess . The Human Health Risk Assessment was conducted according to EPA guidance33 - 4 using data from Battlement Mesa and other locations in Garfield County . A baseline risk for Battlement Mesa was estimated, as well as risks to child, adu lt, and e lderly receptors from Antero's project for five possible exposure scenarios. Appendix D contains the details of the Human Health Risk Assessment. The Human Health Risk Assessment concluded the following: • For Battlement Mesa residents living farther from the well pads (i .e. more than Yi mile), the long-term health risks is similar to the background risks estimated in the baseline risk assessment for Battlement Mesa (i .e. the risk w ithout Antero 's project). • There is a significantly greater potential for exposure to chemicals in air during well completion activities than during production act ivities , especially for child, adult , and elderly residents living within Yi mile of the well pads . • For Battlement Mesa residents living within Y2 a mile of a well pad , the long-term health risks from chemical exposures are greater than the long -term health risks for residents living farther from the well pads and are in the ra nge of concern. These health effects include an increased cancer risk, decreased lung function, anemia, and birth defects. • For Battlement Mesa residents liv ing within Yi m ile of the well pads , the subchronic and short-term health risks to may be expected to occur. These health effects may include respiratory effects such as upper airway irritation and decreased lung function and neuro logical effects, such as headac h es and dizziness. The Yi mile distance is based on the distance at which Battlement Mesa residents reported odors and health effects to COGCC in July 2010. Previou s C DPHE human health risk assessments and the Saccomanno Study also concluded that residential long -term and short term exposure to air pollutants may result in an increased risk of cancer and non-cancer health effects . 5.1.5 Antero's Best Management Practices The Human Health Risk Assessment was performed without consideration of Antero's best management practices because there has been no data collected with these best management practices in p lace. Implementation of Antero 's best management practices for its Battlement Part One Pag e 38 • • • Draft Battlement Mesa HIA, Revision 1 February 2011 Conducted by Colorado School of Public Health Mesa project should reduce air emissions during several activities and should reduce the risk of health effects from chemical exposures . Antero's bes t management practices that are most likely to reduce air emissions include: • Auto-igniters on all production tank combustors should reduce long term emissions of VOCs. Combustion increases nitrous oxide emissions. • Low emissions flow back process (currently under development) for all well pads in the PUD should reduce VOC and other chemical emissions associated with flow back activities. • The centralized water storage facility and pipe line network will decrease truck trips and therefore decrease truck emissions . • Well pad telemetry and remote monitoring will reduce maintenance trips to well pads and decrease vehicle emissions. • Closed tank hatches on hydraulic fracturing and flow back tanks should reduce VOC emissions during well completion activities. • Hydrocarbon absorption blankets on hydrau lic fracturing and flow back tanks should reduce voe emissions. • Batch biocide treatment of hydraulic fracturing and flow back tanks after they have received some water should reduce biocide emissions. • Replacement of diesel generators with electric generators should reduce diesel exhaust em1ss10n • Tier 2/3 diesel engines should reduce diesel exhaust emissions . Tier 4 engines would further reduce diesel exhaust emissions. • Low bleed valves and routine maintenance per the EPA Natural Gas Star Program should reduce fugitive voe emissions . While Antero's best management practices have the potential to reduce air emissions, in many cases, the effectiveness of the practices are unknown. We strongly encourage Antero to demonstrate the effectiveness of their best management practices. In addition , without specific permits or plans , it is unclear the extent of the best management practices will be used in Battlement Mesa. The objective of many of our recommendations assessment is to ensure Antero's best management practices are implemented in the PUD in order to reduce air emissions and protect public health. Antero's air monitoring study at the Watson Ranch pad has added valuable information for evaluating air emissions from natural gas development operations and further monitoring is recommended. In addition to the best management practices, other Antero plans will reduce em1ss1ons in Battlement Mesa. Antero has stated that it will not have a centralized compressor stations in the PUD 6 . Compressor stations are sources of fugitive emissions and noise. Antero has committed to several dust control measures in the Surface Use Agreement6 . With these control measures in place, project dust from construction activities, well pads, and access roads is not expected to significantly impact Battlement Mesa air quality. As noted earlier, Antero has committed to Part One Page 39 • • • Conducted by Draft Battlement Mesa HlA, Revision 1 February 2011 Colorado School of Public Health installing a water storage and management system, which will reduce truck emissions, dust and noise in the PUD. 5.2 Characterization of the Air Quality on Health The impact of air quality due to the Antero project in Battlement Mesa on the health of local residents can be characterized as follows: Impact Direction of Geographical Vulnerable Duration Frequency Likelihood Magnitude health Extent of populations of of of health of health effects exposure exposure exposure effects as a effects result of Project Air Negative Local to Yes Long Frequent Likely Low to Quality Community-High wide *For an explanation of the ranking system, see the chart at the beginning of Section 4. When considering anticipated air contaminant exposures associated with the Antero development within the Battlement Mesa PUD, impacts to air quality will likely produce negative health effects. These health effects are most likely to occur in the localized areas near well development areas (defined as less than Yi mile) and in areas near truck haul routes . Much of the community will be within Y2 mile of sources of air contamination . Declining ambient air quality will affect the entire community. Children, seniors and , residents underlying health problems are more vulnerable to the air pollutants. Air qualit y degradation may last for the duration of Antero's 30-year project, from well pad preparation through well abandonment, and therefore could be long in duration. The highest levels of air contaminants are expected during the 5 year development period, but long term emissions from producing wells will also compromise air quality. The impacts to air quality are expected to be frequent and occur constantly and/or reoccur. If pollution prevention measures are not implemented it is likely that contaminant concentrations in residential air will be high enough to cause short-term and long-term disease, especially for residents living near wells. Health effects may include respiratory disease, neurological problems , birth defects , and cancer. Some health effects could be managed without medical attention, while some effects will necessita te medical attention some of these effects may not be reversible. Therefore the impacts are rated as low to high . For these reasons , air quality impacts are prioritized as high. 5.3 Assessment of Water and Soil Quality on Health in Battlement Mesa "What will be the effect of chemicals on the water supply?" June 15 stakeholder mee ting The impact of natural gas development and production on water and soil quality and the water supply is a major concern to Battlement Mesa residents. Surface run-off, and infiltration from Part One Page 40 Priority High* • • • Draft Battlement Me sa HlA, Revi s ion 1 February 2011 Condu cted by C ol orado School of Public He a lth drilling cuttings and produced water stored in pits on well pads or off-site locations ; well installation errors; and uncontrolled well developm ent (kick backs, blow outs , and well fire s) could result in emissions of contaminants to groundwater, sub surface soil , surface soil and surface water. Spills of hydraulic fracturing fluids , drilling mud s, condensate , and diesel could result in contamination of surface soil. Run-off and in filtration then could re sult in subsequent contamination of surface waters and of groundwater and subsurface soil , respectively. Exhaust from diesel engines (through dry deposition of particulates) and wind ero sion from drill cuttings could contaminate surface soils (through depositio n of particulates). If the groundwater or subsurface soil is contaminated , VOCs could infiltrate and accumul ate in th e air of building s. Sources of contaminants include the natural gas resource itself, chemicals used in well production activities, wastes from well production act iv ities , and exhaust from machinery us ed in well production and maintenance . 5.3.1 Water and Soil Quality Impacts on Health Natural gas development and production and the di ese l engines u sed to support them have th e potential to release metals , salts, hydrocarbons, carbonyl s, and other contaminants to groundwater, surface water, and soil. People can be ex posed to th ese contaminants through ingestion of water, incidental ingestion of soil and pu rposeful in gestion of soil (i .e. individuals with pica), dermal absorption from water, inhalatio n of soil particulates , inhalation of voes released from water during activities such as showering, and inhalation of VOCs in building air . Some of these contaminants , such as benzene35 , and several of the P AH s, are hum an carcinogens. Others, such as the carbonyls, alkan es , and 1,2,4-trimethylbenz ene , can act as irritants of the eyes and skin or cause neurologic effects 23 . Specific health effects of several potential contaminants are described in the in the Human Health Risk As sessment (Appendix D). Significant contamination of water suppli es with sa lts, such a s those containing chlorid e, can make the water unsuitable for human consumption and stress water treatment facilities . The water requirements for natural gas development and p roduction are large, with the potential to tax local water supplies , particularly in the event of a drought. However, many natural gas operators in Garfield County have installed water tre atment system s w ith the purpo se of treating and recycling produced water used in hydraulic fracturing, and it is Antero 's intent to do so for its project in the Battlemen.t Mesa PUD . With adequate treatment to eliminate harmful chemicals, it is possible that produced water can be recycled. This has the potentia l to significantly reduce the consumptive wate r use in natural gas development. 5.3.2 Water and Soil Quality and Natural Gas Operations The Mamm Creek field, located approximately 20 miles to the ea st of Battlement Mesa in Garfield County, has experienced exten sive natural ga s development and production, with over 1100 gas wells installed between 2000 and 2007 . The two phase hydrogeologic study conducted between 2006 and 2007 on the Marum Creek fi eld 21-22 provides data that is useful in estimating potential impacts from natural gas develop ment and production on water quality in Part One Page 41 • • • Draft Battlement Me sa HlA, Re vis io n I February 2011 Conducted by Co lorad o Sch o ol of Public He a lth Battlement Mesa . An increasing temporal trend of methane and chloride groundwater concentrations coincident with the increasing number o f gas well s installed was observed in the hydrogeologic study21-22 , 44 . The isotopic methane data indicate a thermogenic origin of methane, which may be attributed to the Willi ams Fork gas . The increasing chloride concentrations are attributed to Williams Fork production water. In the Mamm Creek field hydrogeologic study, chloride concentrations did not exceed regulatory limits and there is no regulatory limit for methane . Benzene was only detected in groundwater and surface water samples collected in proximity to the West Divide Creek seep and the Amos well. Many of the benzene concentrations in these sam p les exceed ed the 5 µg /L regulatory limit and the 0.41 µg /L EPA Regional Screening Level for ta p water. At the West Divide Creek seep, a faulty cement job on the casing of the Schwartz well resulted in the mi gration of natural ga s and BTEX over 2 ,000 feet southeast of the well and seepage into Divide Creek. At the Amos well, Williams Fork gas from poorly installed well s ar e believed to be responsibl e for the contamination. Pavillion Wyoming, a community of approximately 16 6 residents located in Fremont County, also experienced intens ive natural gas development and production , with 211 acti ve gas well s, 30 plugged and abandoned wells , 20 "shut-in" wells , and 37 production pits in an 8 square mile area . In response to complaints from Pavillion res idents of odors and off-tastes in domestic water, EPA conducted sampling of both domestic and monitoring wells in the area between 2009 and 2010 . The sampling results indicate that domesti c wells are contaminated with low levels of petroleum hydrocarbons and thermogenic methane and tha t the shallow groundwater is heavily contaminated with petroleum hydrocarbons and BTEX. Natural gas development and production are the most likely source of the petroleum hyd roc arbons and BTEX. Several inorganic compounds, such as sodium, sulfate , and nitrate , also were detected which could have sources other than natural gas development and production . The hydrologic connection between the drinking water aquifer and shallow groundwater is not well characteriz ed . In their health consultation based on EPA's results, ATSDR found the quality of the drinking water in several of the domestic wells was not acceptable and concluded that expo s ure to some of the contaminants could result in health effects 36-37 . While the groundwater contamination that occurred in Pavillion is not directly comparable to Battl ement Mesa because of differences in the natural gas resource and state regulations , it does indicate that natural gas development and production can adversely impact groundwater quality . Review of water quality data in the USGS and COGCC databases indicate that groundwater and surface water contamination from natural gas deve lopment and production at levels with the potential to impact water quality and exceed re g ulato ry levels re sults from incidents such a s loss of well control during development, well installation errors , and spills from produced water pits, as described in the Accidents and Malfunctions Ass ess ment. Available routine monitoring data in these databases indicate routine natural gas dev elopment and production (i.e . without incidents) may not be a significant source of water contamination, however, routine monitoring is limited and may not be representative of all instanc es of gas development and production. It is Part On e Page 4 2 • • Draft Battlement Mesa HIA, Revision 1 February 2011 Conducted by Colorado School of Public Health noted, that samples are most often collected in response to a complaint or incident or as part of a remedial action. There is very little data for routine monitoring of impacts to water quality at gas wells or exploration and production (also known as E&P) waste pits, with the exception of required monitoring in the 3-mile perimeter of Project Rulison . This small amount of data limits the ability to make a true estimate of exposures from groundwater and surface water. 5.3.3 Current Conditions of Water and Soil Quality The primary source of drinking and domestic water in Battlement Mesa is the Colorado River. The Battlement Mesa Water Treatment Plant draws water from two intakes located in the middle of the river for treatment. The available baseline groundwater and surface water data specific to Battlement is Mesa is limited to the annual testing of the surface water intake and back-up groundwater wells at the Battlement Mesa Water treatment facility. These results indicate that there is no voe, herbicide, or pesticide contamination of either drinking water supply. In addition, a domestic well at the Historic Battlement Mesa Schoolhouse was sampled on May 17 , 2010 in response to an anonymous request from a landowner in the vicinity of Antero 's Watson Ranch Well. The COGCC concluded the laboratory analysis did not indicate any impacts to this domestic water well from natural gas production operation38 . Garfield County has conducted several hydrogeolo g ic investigations over the past 5 years, including two completed studies and one on-going s tudy of Mamm Creek, and the Piceance Phase IV Baseline Water Quality Study of the area no rth of the Colorado River up to the Grand Hogback between Rifle and New Castle completed in 2007. In addition, the COGCC conducted hydrogeologic studies associated with the Rulison blast site, southeast of Battlement Mesa in the 1990s . While the hydrological information from these studies do not apply directly to Battlement Mesa, water samples collected in these studies are useful for overall background assessment. The inorganic results, obtained from the 70 groundwater samples collected in the Piceance Phase IV Baseline Water Quality Study2° are not applicable to Battlement Mesa, because the water chemistry between these two areas could be quite different. However, the BTEX and methyl-tert-butyl-ether (also known as MTBE) results could be somewhat representative of Battlement Mesa, because they are not naturally occurring at detectable levels in groundwater. No measureable concentrations of BTEX, methyl-tert-butyl ether, or methane were detected in any of the samples. Antero collected groundwater samples from 18 domes tic wells surrounding the Watson Ranch Pad in July 2009, prior to drilling (David Simon Antero personal communication January 27 , 2011). The results from these samples are applicable to Battlement Mesa and appropriate for estimating baseline water quality in domestic wells. No measureable concentrations of BTEX, methyl-tert-butyl ether, methane, nitrite, sulfide, boron, cadmium, chromium, manganese, selenium, or silver were detected in any of these samples . Arsenic, barium, chloride, lead, nitrate, and fluoride levels were all below national drinking water standards . Only a few sulfate concentrations exceeded the 250 mg/L secondary national drinking water standard with concentrations ranging from 29 to 930 mg/L. Part One Page 43 • • • Draft Battlement Mesa HIA , Revision I February 2011 Conducted by Colorado School of Public Health There is no baseline data for surface soil or subsurface soil within the PUD so current conditions are unknown . The Colorado Department of Labor & Employment's Oil and Public Safety Division has permitted ten underground storage tanks within the PUD, summarized in the following table. Permit Holder Fuel Tank Capacity (gallons) Battlement Mesa Service Gasoline 1,000 Battlement Mesa Service Diesel 1,000 Battlement Mesa Golf Course Gasoline 2,000 Battlement Mesa Golf Course Diesel 1,000 Kum and Go, Stone Quarry Road Gasoline 20,000 Kum and Go, Stone Quarry Road Gasoline 12,000 Kum and Go, Stone Quarry Road Diesel 12,000 Kum and Go, Tamarisk Trail Gasoline 10,000 Kum and Go, Tamarisk Trail Gasoline 10,000 Kum and Go, Tamarisk Trail Gasoline 8,000 These underground storage tanks have the potential to leak and contaminant subsurface soil and groundwater with fuel contaminants, including benzene. The permit holder is required to perform weekly leak tests on the underground storage tanks and the Oil and Gas Public Safety Division performs an annual inspection of the underground storage tanks. Review of the Oil and Gas Public Safety Division files on August 18, 2010 indicated no leaks or contamination of soil or groundwater associated with these underground storage tanks. There also are natural gas production operations occurring on the border of the PUD that could potentially impact the water and soil quality within the PUD, as well as the water supply. Other potential sources of contamination to groundwater and soil are the golf course and landscaping operations (e.g. application of fertilizers, herbicides and pesticides). In the event that the Battlement Mesa Water Treatm ent Plant was shut down, drinking and domestic water for Battlement Mesa residents would be supplied from four groundwater wells along the south bank of the Colorado River. These wells are not directly supplied with water from the Colorado River and the source of water in these wells has not been established (Roger Bulla personal communication July 7, 2010). There could be a hydrologic connection between these wells and the aquifer on Battlement Mesa, allowing for a conduit of natural gas extraction activity contaminants to the secondary drinking water source, although this has not been verified . Part One Page 44 • • Draft Battlement Mesa HlA, Revision 1 February 2011 Conducted by Co lorado School of Public Health 5.3.4 Antero Drilling Plans in Battlement Mesa and Water and Soil Quality In the two samples collected by Antero during completion activities at the Watson Ranch pad in 2010, levels of chemicals were very similar to pre-drilling levels with one exception (David Simon Antero personal communication January 27, 2011). In a sample from the domestic well _nearest the well pad at the west perimeter, the manganese level of 0.085 mg/L exceeded the secondary national drinking water standard of 0 .05 mg/L. Manganese levels were less than 0 .0 1 mg/L in the sample collected from this well prior to drilling . Manganese is listed on several of Antero's material safety data sheets as a chemical used in pipeline excavation. This one sample result is not sufficient to indicate that Antero's drilling and well completion activities were the source of the elevated manganese and further sampling is necessary to confirm the result and the identify the source of the manganese. Antero has contracted an evaluation of groundwater monitoring data from approximately 500 wells in and around its Gravel Trend leasehold position . However, the results of the evaluation were not available at the time of the HIA (Personal communication, Jerry Alberts, Antero February 15, 2011). The Mamm Creek field hydrogeologic study results and USGS and COGCC databases indicate that natural gas processes could impact water quality in Battlement Mesa, although the likelihood is low. Increasing chloride concentrations could eventually affect the potable groundwater. As previously discussed, incidents resulting from well in stallation errors, loss of well control during well development, and spills could affect the potable groundwater and water quality to extent that causes exceedence of regulatory standards and trigge rs regulatory action. These types of incidents also could affect soil quality in Battlement Mesa. The assessment of Accidents and Malfunctions in Section 4.8 discusses the likelihood of such incidents. While there is no permanent surface water body in th e PUD, there are intermittent drainages and creeks that could discharge to the Colorado River. Mon ument Creek, one of the major drainages off of Battlement Mesa discharges to the river downstream of domestic water intakes. It still is possible that surface run-off could introduce contaminants from upstream well pads into the river. However, the Colorado River has a high volume of water and it is most likely that any contamination would be diluted to non-harmful concentra tions. The annual surface water quality results have not indicated any detectable levels of contamination from natural gas development and production at the intakes. In addition, natural gas operators must inform the Battlement Mesa Water Treatment Plant of upstream spills or incidents affecting the river (COGCC rule 317B)5. In the event of such a spill or incident, the intakes to the treatment plant can be shut down . The treatment plant routinely stores a w eek 's supply of water allowing time for remediation of spills. The Battlement Mesa Metropolitan District is subject to the protections of COGCC Rule 317B , which regulates natural gas operations in surface water supply areas. Antero is proposing to employ pit-less drilling systems on the well pads within the PUD and to distribute and store production water at a centrali zed water storage facility , within the PUD . Part One Page 45 • • Draft Battlement Mesa HIA , Revision I February 2011 Conducted by Colorado School of Public Health COGCC rule 904 requires liners for pits at centralized water storage facilities and has a provision5 , at the discretion of the director, for the ins tallation of leak detection systems in sensitive areas such as the PUD. COGCC rule 908 requires that centralized water storage facilities be permitted5; the geologic and hydrogeologic characterization of site; control of public access; fire lanes; surface water diversion systems, waste characterization profiles; an operating plan; baseline groundwater sampling and analysis; groundwater and surface water monitoring (at the discretion of the COGCC director); and groundwater and soil sampling when a pit is closed and the site remediated. Adherence to these rules, including the discretionary leak detection and monitoring, will significantly reduce the potential for impacts to water and soil quality from produced water and other exploration and production waste stored in the centralized pit. However, leaking pipelines and spills from chemical and production water-hauling trucks could still create the potential to impact surface water quality . COGCC rules do not specifically address water pipeline leaks. Any spills that occur on the pads could potentially impac t water and soil quality by surface run- off and infiltration during precipitation events. This potential is evidenced in a sample of snow melt collected from a project Rulison well pad that contained levels of benzene greater than regulatory lirnits 39 . COGCC rule 603 specifies that in high density areas, such as the PUD, berms (or other secondary containment devices) capable of containing 150 percent of the fluid in the largest tank within the berm be constructed around produced water and condensate tanks 5 . However, this rule does not provide for containment of spills that may occur outside the berm perimeter, such as during transfer of chemicals and materials to and from trucks and at well heads . Wind erosion and surface run-off from drill cuttings stored on Antero's pads could impact surface water and surface soil quality. The COGCC rules do not specifically address drill cutting stored on well pads 5 . At time of preparation of this HIA, it was not known if Antero is planning for deep injection of exploration and production wastewater within the PUD. COGCC rules require written permission from the COGCC director prior to construction of an injection well. The HIA would need to be updated to include potential impacts to public health, if injections wells are proposed. The Battlement Mesa Metropolitan District has a capacity of 6 million gallons of water per day . Currently, 3-3 Yz million gallons per day are used, allowing for the accommodation of Antero's water needs during well development operations. If water capacity were to significantly decrease, the needs of Battlement Mesa would take precedence to Antero's needs. It is unlikely that Antero's proposed project will have a significant impact on the primary domestic water supply for Battlement Mesa. The potential for a significant impact to the secondary water supply may exist. If the potable groundwater is impaired, Battlement Mesa may not have a back up source of domestic water. In addition, there is the potential for the Antero 's project to impact the water quality of intermittent streams, creeks, and puddles, as well as soil Part One Page 46 • • Conducted by Draft Battlement Mesa H!A, Revision 1 February 2011 Colorado School of Public Health quality. Finally, it is possible that shallow aquifer contamination could cause VOC off gassing into Battlement Mesa homes, but since the hydrology of the area is not well understood, the likelihood of such an occurrence is not clear. 5.3.5 Characterization of the impact on Water and Soil Quality The impact of water and soil quality due to the Antero project in Battlement Mesa on the health of local residents can be characterized as follows: Impact Direction Geographical Vulnerable Duration Frequency Likelihood Magnitude of health Extent of populations of of exposure of health of health effects exposure exposure effects as a effects result of Project Water Negative Community Yes Long Infrequent Unlikely Low to High and Soil wide Quality *For an explanation of the numerical ranking system used, see the chart at the beginning of Section 4. When considering anticipated water and soil contaminant exposures associated with the Antero development within the Battlement Mesa PUD, water and soil quality may produce negative health impacts in the areas in close proximity to the development areas and community wide. If the domestic water supply were to be contaminated, the health effects would be community wide. Effects of wind erosion and surface run-off could be more localized, and could impact children more than adults. Children, older adults, and individuals with pre-existing disease may be more vulnerable to water and soil contaminants and are considered a vulnerable population. The duration of water quality degradation could be long and may last through the life of the Antero's project, from well pad preparation through well abandonment. The impacts to water quality are expected to be infrequent and it is unlikely that contaminant concentrations in water and soil will be high enough to cause short-term and long-term disease because the current supply of domestic water is the Colorado River and the COGCC has extensive rules to protect this resource. If exposure were to occur, health impacts may include skin and eye irritation, neurological problems, and cancer. It is likely that medical attention would be necessary for some of these impacts and that some of these impacts will not be reversible. Therefore the health impacts, if exposure were to occur, are rated as low to high magnitude. For these reasons, water and soil impacts are prioritized as medium compared to other potential stressors. 5. 4 Assessment of Transportation and Traffic on Health in Battlement Mesa Will there be motor vehicle accidents and related injury and death? February 3, 2010 stakeholder meeting J. QJ.l. _ ........ ~b ..... ...,., Priority Medium* • • • Draft Battlement Me sa HIA , Revi s ion 1 February 2011 Conducted by Colorado School of Public Health Increases in transportation and traffic can impact health and safety of a community by increasing the risk of motor vehicle accidents, release of hazardous pollutants , creation of road dust , and impediment of walking and biking routes. Development of natural gas wells can cause significant increases in a variety of traffic , especially large truck traffic . Increases in large truck traffic may place residents at greater risk for severe injury or death with the risk increasing with vehicle speed. Residents living in Battlement Me sa have expressed concerns that traffic associated with the Antero gas project will impact the health and safety of those living in the community. This assessment will address traffic impacts to the safety of Battlement Mesa citizens . Air quality, noise, and quality of life impac ts due to increased traffic are addressed in other sections. 5.4.1 Traffic and Safety Vehicular traffic is a known hazard to safety. Increas es in traffic are associated with increased risk of motor vehicle injury and death, due to vehicle-vehicle, vehicle-pedestrian, and vehicle- bicycle accidents . Motor vehicle accidents can be associated with speeding , poor traffic management at intersections, and heavy vehicle mo vement. Numbers of injuries/fatalities are directly related to vehicle volume and severity of injury is directly related to vehicle speed40 - 4 1 . Large trucks of l 0,000 or more pounds are much more likely to be involved in a fatal multi- vehicle crash than passenger vehicles42 . 5.4.2 Current Traffic Conditions Currently, large truck traffic within the PUD is mainly from delivery trucks supplying the local businesses, including gas stations and convenience and grocery stores, and natural gas operators servicing well pads outside the PUD. There are established county approved haul routes along the perimeter of the PUD, while most roads within the perimeter are limited to small vehicles . There are two entries into Battlement Mesa. The main entrance is just south of Exit 75 off of Interstate-70 . A traffic analysis conducted by Schmues er/Gordon/Meyer, Inc . (SGM) for Antero in September 2009 32 found that this entrance had the highest traffic count in Battlement Mesa with 8,662 vehicle trips per day (vt/d). The second entry into Battlement Mesa is from Exit 75 via US 6 west to County Road (CR) 300 (CR 300/Stone Quarry Road) on the southwest side of Battlement Mesa. Traffic counts at the US 6/CR 300 intersection were 2,300 vt/d, but were only 648 vt/d on CR 300 where it enters the PUD west of the recreational vehicle (RV) park. Other counts indicate that on West Battlement Mesa Parkwa y there were 5,340 vt/d and on CR 307 (River Bluff Road) there were 371 vt/d. Since there is no current industrial activity and very few retail stores, it is assumed that the large majority of these vehicle trips were passenger cars and light trucks , although this is not specifically stated in the traffic report. The report also projects an increase of 2.3% vehicle trips annually unrelated to the Antero drilling plan, based on average annual growth of Garfield County. Part One Page 48 • Draft Battlement Mesa HIA, Revision I February 2011 Conducted by Colorado School of Public Health Motor vehicle accidents in Garfield County are handled by the county sheriffs office, local municipal law enforcement and the Colorado State Patrol. When looking at accidents handled by the state patrol, Garfield County had the 9th highe st number of motor vehicle accidents in the state in 2008, with 1,09 1 accidents total (14 fatal crashes, 116 that resulted in injury and 961 that resulted in property damage)4 3 . Data from the county sheriffs office and data specific to Battlement Mesa are not currently available. Top 10 Colorado Counties 2008 Fatal, Injury, and Property Damage Crashes by County as Covered by the Colorado State Petrol (not all Colorado Crashes) htto://cso.state.co.us/TS CrashStat.html County Fatal Injury Property Damage Grand Total Jefferson 19 395 2,530 2,944 El Paso 20 278 1,953 2,251 Adams 13 233 1,773 2,019 Mesa 7 211 1,188 1,406 Larimer 14 275 1,080 1,369 Weld 28 258 1,065 1,351 Eagle 6 132 1,073 1,211 Douglas 10 145 1,032 1,187 Garfield 14 116 961 1,091 Boulder 14 182 860 1,0 56 Grand Total 290 3,895 23,028 27,213 Children attending school in Battlement Mesa arrive and leave via passenger car, school bus , walking, or bicycle. Underwood Elementary (grades 1-3), St. John El ementary (grades 4-5) and Grand Valley Middle School (grades 6-8) are in Battlement Mesa. The Early Childhood Center (PreK-Kindergarten) and Grand Valley High School are in Parachute . Some students are not offered bus service if they live within a "Walk" zone. Specifi cally, students attending Underwood Elementary and living in Saddleback Village, Tamarisk Village, Tamarack Meadows are not offered bus service; children attending St. John Elementary and living in Willow Ridge, Willow Park, Valley View, Monument Creek Village, Canyon View, and Stone Ridge are not offered bus service; and children attending Grand Valley Middle School and living in Mesa Ridge, Eagle's Point, Willow Ridge , Willow Park, and Valley View are not offered bus service. (Battlement Mesa early childhood students and high school students are all offered bus service and ride together.) School hours in Battlement Mesa schools are 8:40 am -3:40 pm at Underwood (early release at 2:10pm); 8:25am-3:25pm at St. John (early release at 1:55pm); and 7:50am-7:15pm at Grand Valley Middle School (1 :45pm early release). A map detailing Antero's planned haul routes and school bus stops will be included in the final report. Part One Page 49 • • Draft Battlement Mesa HlA, Revision 1 February 2011 Conducted by Colorado School of Public Health 5.4.3 Antero Drilling Plans in Battlement Mesa and Traffic Traffic associated with natural gas development is related to earth moving construction of well pads; movement of materials and waste to and from the well site; installation of pipelines ; long term production; maintenance operations; final reclamation of the site after production is completed; and travel of workers to /from work. The most traffic intensive phases involve pad construction, drilling and well completion and pipeline construction. Antero has described a three phase development plan for the Battlement Mesa project as described in presentations at the public meetings. Phase 1 will develop the Stierberger Pad, Pad E , Pad G, and the water storage facility (Pad F) on the south side of the PUD. Phase 2 will develop the Parks and Rec Pad, Pad A, Pad B , and Pad D on the north side of the PUD. The Parks and Rec pad replaces the Pad C originally planned. Phase 3 will develop the Land M pads on the northeast side of the PUD. Each phase will involve access road, pad and pipeline construction needed to develop the wells and tie them to the water movement system and the gas gathering lines at the eastern edge of the PUD. The traffic analysis conducted by SGM used estimates from previous Antero development sites in the Mamm Creek area to project average and maximum trips per day, for the Battlement Mesa project. Trips per day range from 2 (production phase) to 280 or more (intensive construction phase). Drilling completion, light construction, and pipeline installation range from on average 16-31 vt/d and a maximum of 30-46 vt/d. The duratio n of the pad construction ranges from 10- 30 days and the other phase durations per well are drill ing (18 days); completion (30 days); pipe installation (60 days / mile); duration of each phase per pad was not calculated but efficiencies associated with drilling multiple wells sequentially on a pad will reduce the time of each phase on a pad . Production is projected to last 20 years. Reclamation after production is expected to have 7-10 vt/d for 11 days per pad. Although initial presentations to the public describe well development phases to last 3-4 years, more recent estimates in the traffic analysis indicate that well development is expected to occur for at least five years, maybe longer, depending on economic and regulatory conditions. Antero has indicated that it will consider on public input regarding the duration of the well development phase of the the project. Well development phases w ill overlap on different well pads so that while pad construction is occurring on one pad, drilling is accomplished on another and completion may be occurring on another pad . Therefore, traffic will be overlapping as well, with trucks associated with construction, drilling, pipeline and completion using the haul routes simultaneously. Trips per day for each of these phases are added to e stimate the number of trips per day expected during the first five years when well development is occurring. The number of trips per day is estimated to be 90-120 vt/d when light construction is occurring. When more intense well pad construction is occurring (during the Phase 2 well pad construction) traffic is projected to be 340 vt/d for approximate ly 120 days. Well drilling will occur 24 hours a day and the vehicle trips will be spread throughout the day and night. Antero has stated they will limit Part One Page 50 • • Draft Battlement Me sa HlA, Re vis ion 1 February 2011 C onducted by C olorado School of Public He a lth truck hauling to hours outside of school zone hours . The majority of these trips are expected to be heavy trucks . Antero plans to use county haul routes for traffic. During all phases entrance and exit from Battlement Mesa will be via the US 6/ CR 300 route (Stone Quarry Road), on the southwest side of the PUD. Phase 1 also will utilize CR 303 , CR 30 8 and CR 302. Phase 2 will utilize CR 303 , CR 308, East Battlement Mesa Parkway, South Battlement Mesa Parkway, and CR 307 (River Bluff Road). Phase 3 will utilize CR 303, CR 30 8, East Battlement Mesa Parkway, North Battlement Mesa Parkway, and West Battlement Mesa Parkway. The county restricts hauling on CR302 , CR 307, South Battlement Mesa Parkway, and West Battlement Mesa Parkway. It is assumed that Antero will be required to obtain special permits to use these roads . School buses for all the schools use and cross Antero haul routes . Although all children in the PUD may be impacted by crossing the haul routes while going to and from school, middle school age children may be the most impacted since the middle school is near two haul routes and children this age are more likely than younger children to be walking or bicycling on their own. According to the traffic analysis plan, Antero has decided to avoid any heavy truck hauling during school zone hours. Children going to /from school outside of school zone hours may be crossing haul routes while truck traffic is occurring. Antero has planned mitigations to decrease impacts of traffic on the Battlement Mesa Community, as evidenced in its best management practices (Appendix E). Of significance, Antero has committed to building a water managem ent system comprised of water distribution pipes going from the well pads to the water storage site on the south side of the PUD . This water management system is intended to decrease movement of water by trucks and it is estimated that there will be fewer trips during the development phas es because of this system . Antero estimates that there will be 50 ,000 fewer trips (Appendix E). In addition to heavy truck traffic, there will be workers coming into Battlement Mesa and traveling within Battlement Mesa in passenger cars and light trucks . It is estimated that there will be an average of 120-150 workers in Battlement Mesa during the five year development period. Antero intends to house some workers in Battlement Mesa to decrease worker movement into and out of the PUD. Workers exceeding speed limits can put other vehicles and pedestrians at risk for injury and fatality. . Antero management emphasizes safe driving but a formal safe driving program does not exist. It is expected that the increase in heavy truck volume from negligible to tens or hundreds per day within the PUD may compromise road integrity and needs for increased road maintenance is anticipated. County funds will be needed to maintain haul routes as well as installation of road and pedestrian safety mitigations if needed. 5.4.4 Characterization of Traffic Impacts on Safety Part One Page 51 • • • Conducted by Draft Battlement Mesa HIA, Revi s ion 1 February 2011 Colorado School of Public He a lth The following table summarizes the characterization of impacts from traffic. Impact Direction Geographic Vulnerable Duration Frequency Likelihood Magnitude of health extent of populations of of of health of health effects exposure exposure exposure effects as a effects result of Project Traffic and Negative Community-Yes Lon g Frequent Possible Low to high Transportation wide *For an explanation of the ranking system used, see the chart at the beginning of Section 4. When considering public health to residents of Battlement Mesa , the increased traffic within the PUD is likely to create negative health effects due to increased safety risks. Because the haul routes include the entire circle of the Battlement Mesa Parkway as well as other roads within and on the perimeter of the PUD , the impact of the traffi c is likely to be community-wide. There will be certain parts of the community that will be greater impacts for the duration of Antero's project (those homes next to CR300/Stone Quarry Road) while others will be impacted by very high volume traffic during the construction of the Phase 3 pads (those along River Bluff Road). Because children often walk and ride bicycles and are not as safety conscious, they are more vulnerable than most adults to the impacts of traffic wi thin the PUD . Antero has committed to limit heavy truck traffic during school zone hours which will decrease risk to children traveling to and from school at those times. Children staying after school for sports and other activities may be at risk for traffic incidents related to truck traffic outside of those hours. Furthermore, truck 'traffic is likely to continue on weekends and ho lidays and children may be crossing haul routes at those times. The duration of exposure to increased traffic will be long, spanning the entire duration of the development of all three phases, at least five years. The traffic will be frequent, in some cases (River Bluff Road), up to 280 trucks may be be passing some days for several months. Along Stone Quarry road , there will be 45 to 113 trucks passing a day for approximately five years . Increased traffic is known to be associated with increased risk of traffic accidents and it is possible that there will be traffic related accident as a result of the Antero project. The magnitude will depend upon how well the traffic is controlled, how well mitigation efforts are adhered to, and to unrelated or perhaps chance factors. Traffic can cause minor to severe/fatal injuries and as such, the magnitude of the impacts will be low to high. For these reasons, traffic impacts are prioritized as hi gh compared to other potential stressors. 5.5 Assessment of Noise, Vibration, and Light Pollution on Health in Battlement Mesa "I am concerned that noise and vibration will affect my sleep. Will these be addressed?" June 15 stakeholder meeting Priority Hi g h* • Draft Battlement Me sa HlA, Revision 1 February 201 1 Conducted by Colorado School of Public Health Increased noise, vibration, and light are common concerns for citizens near construction and industrial sites. At natura l gas sites noise and vibration can occur in the construction phase , drilling and completion phases, and due to truck traffi c. Light pollution can occur due to 24 hour lighting d uring development and production operations. Because of these sources, noise , vibration, and light concerns have been expressed by Battlement Mesa residents at stakeholder meetings. COGCC Rule 80244 , based upon the State of Colorado Noise Ordinance45 , states that pad construction operations are considered industrial sites and site noise may not exceed 80 decibels (dB) in the day and 75 dB at night at 350 feet from th e we ll. In residential zones, during normal production operations noise at 350 feet from the well must not exceed 55 dB in the day and 50 dB at night. The rule does not address noise levels at a home either during we ll development or production phases . The noise rule does not address w ell development noise leve ls for residents in areas where development activities are expected to occur for extended periods of time , such as is being proposed in Batt lement Mesa . In such cases , the COGCC rule may not be protective of hea lt h . COGCC Rule 803 4 6 states "si te lighting shall be directed downward and internally so as to avo id glare on pub lic roads and building units within seven (700) hundred feet." COGCC does not have a ru le limiting ground vibration , but according to the US Department of Transportation ground v ibration is generally not felt below 65 VdB and annoyance can be experienced at 70 VdB47 . According to EPA research , construction equipment can produce noise ranging from 80-89 dB at a dis tance of 50 feet and 60-69 dB at 500 feet48. Heavy construction equipment can cause vibration of 85 VdBA 50 feet from the source4 7 . Becau se th ere is a potential for no ise, light and vibration to exceed COGCC ru les and background levels, a review of po tential noise, vibrati on and light impacts is warranted . 5.5 .1 Noise, Vibration , Light pollution an d Health Both ac ute loud noise and chronic lower leve l noi se have been associated with a variety of negative health effects. Hearing loss and impairment are known to occur as a result of exposure to ac u te, h igh decibel noise (greater than 85 dB). The odds of hearing loss increase as the decibe l leve l increases. A dose re lationship between noise level and hearing loss exists49 . Studies looking at the re lationship between noise and cardiovascular disease, hypertension, psycho logical symptoms, and respiratory impairment are numerous. Reviews and meta-analysis of these studies conclude that no ise has the potential to impact these health outcomes50 - 53 . Part One Page 53 • • Draft Battlement Mesa HlA, Revision I February 2011 Conducted by Colorado Schoo l of Public Health Cardiovascular risk factors have been shown to be imp ac ted by noise levels in the range of 51-70 dB in persons with several years of exposure 54 . Noise annoyance can lead to stress related impacts on health such as feelings of displeasure, interference with thoughts, fee lings, and activities and disturbed sleep and can have impacts on mood, performance, fatigue , and cognition55 . Studies indicate that noise levels which produce these impacts can vary: annoyance can occur at 55dB ; school performance can be impacted at 70 dB; and sleep can be impacted by as little as 35-60 dB. Ground vibration and low frequency noise may cause health impacts simi lar to those associated with noise annoyance. Establishment of causal relationships between noise/ vibration and health impacts is complicated by the fact that noise annoyance in particular can vary with pi tch, frequency, and duration. In addition, individual adaptation to noise can vary and complicates subjective reporting as well as expected outcomes . Nevertheless , the studies suggest that some persons may experience impacts at noise levels that meet the permissible COGCC and State of Colorado reg ulations. Preliminary research suggests that light at night may affec t health by disrupting normal circadian rhythms 56-57 . The International Agency for Research on Cancer has listed shift work a Class 2A (probable) carcinogen based on epidemiologic link s to breast cancer. Mechanisms for the health effects of li ght at night are actively being studied and include altered melatonin and other hormone release58 . 5.5.2 Current Noise, Vibration, and Light Conditions Residences in Battlement Mesa are located approximate ly one half mile or more from lnterstate- 70 and most homes are not likely to have noise impacts from this source. There is not any baseline/ background noise monitoring data available for Battlement Mesa . In 2002, La Plata County, Colorado conducted noise sampling in rural, residential , traffic corridors and light industrial areas59 . Twenty-four hour residential subdivision noise ranged from 37-53 dB, with an average of 42-45 dB . Traffic corridors ranged from 55-65 dB , with an average of 57 on a state highway and 45 on a collector road . Although it is not possible to know if the La Plata information is representative of all of Battlement Mesa, it is reasonable to expect that noise for most of the homes in Battlement Mesa is similar to tha t measured in the residential subdivision in La Plata. Likewise, night time light is like ly to be si milar to other residential areas, consisting of municipal street and outdoor home li ghting. Base line lighting measures for Battlement Mesa do not exist. Some residences in Battlement Mesa, however, may already be proximate to natural gas production sites located outside the PUD and maybe ex periencing or have experienced noise and light trespass elevated above background in relation to this development. There does not appear to be any significant sources of vibration within the PUD. Part One Page 54 • • Draft Battlement Mesa HIA , Revision 1 February 2011 Conducted by Colorado School of Public Health 5.5.3 Antero Drilling Plans in Battlement Mesa and NoiseNibration/Light Interpretation of Antero Noise Monitoring and Noise Modeling: Antero provided the CSPH with documentation of noise monitoring conducted at the Watson Pad on 8/29 /2010 through 9/2/2010 . Antero also provided CSPH with reports of noise models for a drilling scenario at the Watson Pad and a fr acturing scenario for the D-pad. CSPH interpretation of these reports is as follows: 1) Noise monitoring conducted during drilling operations on the Watson Pad on 8/29/2010- 9/2/2010 indicate that noise at 625 feet (residence is 925 feet) to the northwest and 540 feet (residence is 655 feet) to the south east, was measured below industrial noise limits of 75 and 80 dBA (night and day time, respe ctively). While these measurements do not constitute a violation, the measured noise w as above levels that may cause health impacts. In addition, the results of this report indicate that noise levels can vary as much as 25 dBA . 2) A second report documents noise monitoring conducted on 8/30/20 l 0 through 8/31/2010 before and after the rig floor b lankets , draw works brake shroud were installed . The results of the study indicate these mitigations can decrease noise levels . 3) Noise mitigation effectiveness may be in part determined by local topography and meteorology. 4) There was no measurement of background/ baseline noise levels in Battlement Mesa or on the Watson Pad when the noise monitoring was conducted. 5) A third report provides results from use of a model to predicted noise levels during a drilling scenario at Watson Ranch. Compari son between the model's predicted noise levels and the average of the measured noise levels suggest the model may be within 10 dBA of the measured noise . This suggests that modeling may be a reasonable tool for planning mitigation efforts. However, because noise levels can vary by as much as 25 dBA, it is still necessary to monitor noise so that mitigation efforts can be documented and improved upon should noise levels exceed COGCC rules or exceed levels that may impact health. 6) A fourth report provides results from use o f a model to predict noise levels during a fracturing scenario at the D pad within the PUD . The model indicates that noise levels would be above the levels that may impact health, although they meet permissible COGCC rules . Two proposed mitigations ("Option A" and "Option B") could reduce noise to levels that are sti ll within range o f health impacts but are improved over unmitigated scenarios . Again, it is necessary to monitor noise during these activities to ensure that noise achieves levels that are les s likely to impact health, even if then noise levels meet COGCC rules . Additional miti ga tion efforts may be necessary to protect health . Part One Page 55 • Draft Battlement Mesa HlA, Revision 1 February 20 1 1 Conducted by Colorado School of Public Health Antero data indicate that noise associated with could range from approximately 40 -70 dBA at 350 feet during drilling activities and models suggest that unmitigated noise during fracturing could be over 85 dBA at 350 feet. According to the models, mitigation is expected to reduce noise from these activities to the 50 -63 dBA range. In community meetings, Antero has described possible noise abatement strategies, including hay bale walls, blankets, brake shrouds and berms . According to meetings documents and the Surface Use Agreement, Antero is not planning centralized compression (a significant noise source). Well head compression if utilized will be housed with noise suppression equipment. It is unclear how well these strategies will reduce noise below leve ls that impact health. Simple attainment of the COGCC permissible limits may not be sufficient to protect from health impacts due to noise from the extended well development period. It is important to note that other noise sources will include large truck traffic; road and well pad construction machinery; diese l engines used during drilling; hydraulic fracturing and completion stages; d ri ll rig brakes, pipeline construction activities and possibly other activities. Antero has stated it is possible that they will use electric engines for some drilling operations within the PUD but that diesel engines wi ll be used for all completion activities. Noise is expected to range from intermittent (traffic and drill rig brakes) to continuous (diesel engine use during drilling and hydraulic fracturing) for several weeks to months. Drilling noise will occur around the clock. Fracturing is conducted during daylight hours, however other completion operations may contribute to nighttime noise. Although specific distances from truck haul routes to schools is not avai lable , rough estimates indicate that schools are roughly 1,000 feet or more from truck routes and may not experience significant noise impacts, although this should be verified with school staff. Residents living less than 500 feet from truck ro utes, such as along CR 300 (Saddleback Village) or West Battlement Mesa Parkway (Willow Creek Vi ll age), are close enough to experience noise that could be between 65 and 85 dB when trucks are passing, at times 9-12 times per hour or more. These areas could experience some associated intermittent vibration as well. Because drilling operations occur round the clock, the well pad is lighted and may contribute to light intrusion at nearby residences throughout the drilling operations for each pad. In addition, security li ghting may be in place for the duration of the well pad life. Antero has also proposed light abatement strategies, including sodium vapor lights, light shie lds, and rig p lacement modifications. Antero modeling indicates that these measures will adequately reduce light intrusion to residents. It will be important for Antero to respond with further mitigation if residents report impacts from noise or li ght. 5.5.4 Characterization of Noise, Vibration and Light Impacts Part One Page 56 Impact Noise, Vibration, Light • • Draft Battlement Mesa HlA, Revision I February 2011 Conducted by Colorado School of Public Health The impact of noise due to the Antero project in Battlement Mesa on the health of local residents can be characterized as follows: Direction Geographical Vulnerable Duration Frequency Likelihood Magnitude of health Extent of Populations of of of health of health effects exposure exposure exposure effects as a effects result of Pro_ject Negative Local Yes Long Frequent Possible Low- Medium When considering anticipated noise, vibration, and light exposures associated with the Antero development within the Battlement Mesa PUD, noise , vibration and light may produce negative health effects . Of the three, noise is likely to have the most impact on health . While all or most parts of the community may be proximate to noise sources at different times, it is not likely that the entire community will be affected by noise during the development of an individual pad or by truck traffic . There are some residents close to haul routes that may experience elevated noise due to truck traffic for five years or more . Noise impacts will therefore be local to areas in close proximity to the development areas and areas close to truck traffic routes. The elderly may be more vulnerable to noise annoyance and may experience more health impacts due to noise due to underlying cardiac disease and/or other stress conditions. The elevated noise is expected to be associated with construction and development phases and with truck traffic on haul routes. The pad development phases will last several months, while nearby truck traffic may last several years for some residents, and so, duration of expo s ure is expected to be long depending on location. Significant noise levels are not expected during normal production phases in the years subsequent to well development. Should reworking of wells be conducted, noise levels are expected to increase, again for several months, during the reworking phase. When noise occurs is expected to occur frequently as it will be constant and/or frequently reoccurring. It is unlikely that residential noise will be loud enough to cause noise induced hearing loss or long enough in duration to impact cardiovascular disease. In general , health impacts are likely to result from annoyance due to noise above background and may c a use sleep disturbance, displeasure, fatigue, etc . It is not likely that medical attention will be nec essary for most people, although some may seek medical assistance. Therefore the health effects are rated as low-medium magnitude. It is possible that in some individuals, noise levels will produce significant annoyance and may produce larger health effects . 5.6 Assessment of Impacts on Community Wellness Will the development have impacts on education? What will be the mental health impacts? Will there be more or less services in the community? February 3, 2010 stakeholder meeting Rank Medium • • • Draft Battlement Mesa HIA, Revision 1 February 201 1 Conducted by Colorado School of Public Hea lth R esidents of Battlement Mesa are concerned that the Antero project may affect the we ll -being of their social and community environment. Current epidemiologic literature cites a myriad of challenges in understanding the specific effects of the community and social environment on individual physical and psychological health. Largel y, this is due to the difficulty in analyzing the separate and complex processes through which community and individual factors work together to influence health60 -6 1. Never the less, it is widely accepted that societal factors contribute to the health status of individuals through either the promotion or hindering of healthy choices and behaviors, and it is the collective health of individuals which contribute to the broader sense of community well-being among residents62 -63 . While there is no single determinant or definition of a healthy community, we assessed current quantitative community wellness conditions through societal-based factors which were expressed as concerns by Battlement Mesa citizens . School enrollment, crime rates, prevalence of substance abuse, prevalence of sexually transmitted infection, and social service availability were assessed as surrogate measures of community hea lth. Other measures of quality of life, such as the avai lability of and participation in recreational activities and the depth and breadth of active social networks that lead to the experience of community were also considered. Many resident statements made during stakeholder meetings and comments to the draft HIA serve as examples of ways that the experience of community can influence an individual 's experience of well -being. 5.6.1 Community Wellness and Health Many factors contribute to community wellness and health as follows: Comm u nity Experience: Well-planned combinations of built and natural environments promote social interaction and pride in community living, which are in tum determinants of mental health and well -being62 . Strong social support and community networks have generally positive effects on physical and menta l hea lth of individuals64 . Changes to a community can result in positive, negative or mixed impacts to the hea lth of a community64 -80 . There is limited data available to directly assess the functioning level of social capital and cohesion in any community. Monitoring access and use of p ublic health and socia l services may serve as measurement of some of the outcomes re lated to community health. As population of an area changes or grows, it is expected that the infrastructure of services rendered to that community may need to adapt to meet increasing or changing demands Edu cation : Inherent with changes in popu lation come changes to school enro ll ment; increased pop ul at ion may lead to an increase in the class siz e , and possibly an increase in the ratio of students-to -teachers. Larger class s izes can a lso put a strain on the physical aspects of Part One Page 58 • • Draft Battlement Mesa HIA , Revision I February 2011 Conducted by Colorado School of Public Health educational faci lities. Influx of a semi-permanent or long-term work force coupled with a booming local economy can increase local school enrollments beyond capacity and expected annual growth rates. High turnover of students can also disrupt classrooms and lead to compromised learning environments. In Colorado , if students are present when school counts occur, increased schoo l enrollment may lead to increa sed funds, which can improve educational services and options. However if students arrive after the count date, the school does not receive extra funding for new students. Menta l H ealth and S u icide: Treatment for mental health conditions and suicidal tendencies is condu cted predominantly in the outpatient setting. As such, hospital discharge data for these and related conditions generally do not reflect the true burden of these issues in any given community. Additionally, due to their highly sensitive nature, outpatient data for these issues at the local community level is not publicly available . Studies of the community impacts of industries such as natural gas do not offer clear evidence for direct impacts to mental health, other than to suggest that changes in other measures may add or subtract from the levels stress, worry, and satisfaction experienced by individuals in the community73 • 78 . S exually Transmitted Infection: In any population, sexually transmitted infections (STI) are an important public health prevention priority7 . In addition to a variety of fertility problems caused by STI, syphilis and HIV/AIDS cause substantial health problems in all those infected. In addition to long-term health effects of acquired sexually transmitted infections, there are the daily consequences of pain, discomfort, and often embarrassment. Loss of worker productivity is a lso a concern with sexually transmitted infection , due to time required away from work to access testing, and received results and treatment, a process which may involve two days off work depending on travel distance to the nearest confidential testing/treatment center76 -77 . 5.6.2 Natural Gas Industry and Community Wellness B oomtown s Ch anges: There are a small number of case studies available relating community impacts to boomtown effects of the natural gas indu stry . Some of the available studies provide evidence that exposure to natural gas development and production can have negative psycho- social health implications7 1 ' 78 -80 , while a few others find positive effects 70 . Additionally, there are a few studies that find no association at all b etween natural gas development and production and social and psychological hea lth 15 • 70 . Social p rob lems of mental health, criminal activity, divorce, suicide and alcoholism are said to occur at disproportionate rates in boomtown natural gas economies7 1 ' 78 - 80 . This literature also describes disruptions in social cohesion due to population influx and opposition that arises between the "new comers" (both temporary and permanent new residents) and the "old timers"7 1 ' 78 -80 . Both groups are likely to be vulnerable to combination of positive and negative community impacts. Part One Page 59 • Draft Battlement Me sa HIA , Rev is io n 1 February 2011 C on d ucted by Co lo rad o Schoo l of Public Health Crime: Several research studies have correlated increased crime rates with communities involved in natural gas development and production, includin ~ crim es s uch as domestic violence , rape , prostitution, assault , child abuse , and hom ic ide66-9 . Because jobs in natural gas development and production often involve a tra nsient workforc e, resident s in affected communities often attribute increasing crime rates to the industry workers . On the other hand , there has also been some literature reporting lower crime rates aft er the commencement of natural gas development and production 65 and some res earch arguing that there is no association at a ll between natural gas dev elopment and product io n and social and psychological health outcomes 15' 70 . S ubstan ce abuse: Several studies have reported a n increased burden of substance abuse behaviors in communities involved in natural ga s dev elopment and production, w ith primary emphasis being that substance abuse is prevalent a mong worker s in th e oil natural ga s deve lopment and production 65 ' 69 • 72 . In some cases, in c reased illegal sub stance activ ity has been associated with seasonal increases in natural gas deve lopment and production 73 . Mental h ea lth: Studies of the community impacts of boomtown indu stries do not offer cl ea r evidence for direct impacts to mental hea lth , other tha n to suggest that changes in other measures may add or subtract from the levels stress , worry, and satisfaction experienced by individual s in the community73 • 78 . • Sexually Transmitted Infection: Increases in th e co mmunity burden of sexually transmitted infection have be en identified as a hea lth effect of extraction indu strie s in many low-and middle-income countries 76 -77 . Although literature re garding STI and the extraction industries in North America does not exist, this is an area which should be monitored. Key factors perceived to increase the spread of sexuall y transmitted infecti on within the extraction-industries include the transient nature of the in-migrant worker population who are away from social controls of their home community, the long and difficult work days po s sibly fo s tering desire for drug and alcoho l binges during time off, and high salaries and dis posable income in a young work-force 76 - 77. These factors contribute to the difficulties exp eri enced in providing sexually transmitted infection prevention and treatment for an itinerant natural gas development and production workforce. In addition to the inherent stigmas ofte n as sociated with sexuall y transmitted infection testing/treatment, workers cite lack of acce ss to sexually transmitted infection services due to geographic iso lation from sexua ll y transmitted infection services , lack of available walk- in testing and sexuall y transmitted infection clinic hours overla pping with their own working hours76-77 . 5.6.3 Garfield County and Battlement M e sa during the Garfield County 2003-08 Boom The 2008 Saccomanno Study reported several soci al and community concerns, including increase in spouse and child abu se , child neglect and stressed family relationships ; increase in Pa rt One Page 6 0 • Draft Battlement Me sa HIA, Revi s ion 1 February 2011 Conducted by C olorado School of Public Hea lth alcohol abuse and drug abuse (especially methamphetamine); high suicide rates ; increase in sexually transmitted infection (related to increase in te mporary workers); access to health care and mental health services, availability of housing, cu ltural clash between longtime residents and industry workers ; and traffic and public safety'. Conc erns of the Battlement Mesa residents are similar to those reported in the Saccomanno report and reflect the county 's earlier experience with the natural gas industry during the 2003-08 boom . Primary data on several baseline community health characteristics were collected and described below. These baseline characteristics are described in detail in Appendix C , including data on school enrollment, criminal activity, mental health and substance abuse , and sexually transmitted infections . The years 2005-2008 appear to be a period of increase for se veral of the measures observed. Education: During 2005-08 , school enrollment in Garfield County 's District 16 increased by 37.4%. There was a change in the racial/ethnic distribution of students enrolled during this time , demonstrated by the decrease in the proportion of Caucasian/non-Hispanic students accompanied by a rise in the percentage of Hispanic children. Comments received from local education professionals indicate that classroom turnover of children of transient workers led to classroom disruption and diminished educational experience for all children . While the Antero project by itself will not likely cause a severe increase in the number of students, it is possible that the project could attract transient workers with families to Battlement Mesa and which may lead to some classroom turnover and subsequent educational disruption . • Crime: Crime data is not available for Battlement Mesa, so data from near-by Parachute Colorado is reviewed. Criminal activity was elevated during 2005-08 , with a calculated average of over 300 arrests per year during that time, an inc rease of 50% over previous years. Crime rates decreased to previous levels of approximately 200 per year in 2009 . It is unclear if the increase number of crimes simply reflects an increased population or is linked to the nature of the population of transient workforce . In any case, it is important to consider additional policing needs when there is a rise in criminal activity . • Sexually Transmitted Disease: Chlamydia and gonorrhea counts in Garfield County steadily increased during the 2005-2008 time period. In Battlement Mesa the largest number of cases occurred in 2007 and 2008 . For the purposes of community health monitoring , it is important to review these data prospectively to evaluate future changes and trends. Mental Health: Longitudinal data on mental health , substance abuse and suicide were not available for similar analysis . Results from a 2006 public health survey conducted by the Garfield GCPH found that upwards of 17% of resid ents were burdened by at least one of these conditions. Further, in many cases, when respondents reported experiencing mental health problems (defined as experiencing depression or stress), they also reported difficulties coping with substance abuse issues and engaging in physical activity8 1• A 2006 study of hospital discharge data for Garfield County regional hospitals found that 275 persons had been hospitalized for alcohol/substance abuse or suicidal behavior during the period 2003-05 . Of Part One Page 61 • • Draft Battlement Mesa HIA, Revision I February 2011 Conducted by Colorado School of Public Health those 275, 47 (17.1%) had an alcohol/drug abuse diagnosis and 228 (82.9%) had a diagnosis of suicidal behavior 82 . Data from before or after this time period was not identified. Substance Abuse: A 2006 survey of EnCana subcontractors working in Colorado, conducted by White River Counseling, reported that 66.3% of subcontractors were concerned about methamphetamine use among their employees, and 68 .9% were concerned about heavy drinking. Concern was rated primarily with respect to productivity and workplace safety, however questions about community impact were also assessed . Notably, the respondents who reported higher levels of concern about the potential impact of employee substance abuse affecting the local community also had stronger feelings about be ing proactive to prevent alcohol and drug abuse74 . While not a conclusive study, this indicates that workers may be receptive to substance abuse prevention and intervention efforts presented as part of a community health initiative. For these reasons, it is important to monitor whether drug and alcohol use among community residents shifts with the introduction of gas drilling. 5.6.4 Current Battlement Mesa Community Amenities and Services Community Experience: Battlement Mesa is a residential community with very little current commercial activity and no industrial activity within the PUD. The focus of the community has been on providing high quality residential experience . The community has been on the periphery of natural gas development during the county's 2003-08 boom and is currently experiencing natural gas development in several areas just outside the PUD boundaries. This past and current experience with the natural gas industry has influenced many citizens' perceptions of how the industry will impact the experience of li ving in Battlement Mesa. Lifestyle/ Outdoor Amenities: Bike trails, golf course, community center, open space, visual vistas, Public Health Services:_To meet area community health needs, Garfield County operates a comprehensive Public Health Departm ent (the GCPH) with locations in Rifle and Glenwood Springs83 . Battlement Mesa residents are eligible for all services provided by the GCPH. Some services relevant to the community health measures d iscussed include: • • • • • • • • General health education and screenings Communicable disease surveillance STD/HIV screening Crisis support hotlines for domestic violence, suicide and mental health Tobacco prevention Emergency service and assistance Adult education programs Human services, including employment, food and housing assistance programs Part One Page 62 • • • Draft Battlement Me sa HlA, Re vis ion 1 February 2011 Conducted by Colorado School of Public Health • Services of a designated environmental health department , including the C .A.R.E .S . project for responding to community concern about environmental health issues 5.6 .5 Current and Possible Anticipated Impacts to Community Wellness from the Antero Project Pos itive Commu n ity I mpacts : It is possible that the increased workforce could help support new business within the community, such as a restaurant or coffee shop , which could enhance the community experience. Other positive economic impacts are included in the Economic Assessmen t. Additional students would bring new funds to the schools , which could improve the educational experience for all Battlement Mesa children . Students wou ld need to be present on "count day" (usuall y in early October) for the school to receive additional funds . Rapid turnover of students may decrease the positive impact of additional funds. Antero has pledged one million do ll ars to the community, however, it is not known how these funds will be used but it is possible that this money could be used to enhance the community in some way . Negative I mp acts to Quality of L ife: Citizen statements and comments indicate that some residents view the impending natural gas developm ent as a change that already alters their experience of the Battlement Mesa community for the worse . According to several residents ' comments, Batt lement Mesa represents an active choice of lifestyle and the industrial nature of the Antero project invalidates this choice. Furthermore, just the anticipation of near future deve lopment has altered the experience of community . Many resident comments and statements suggest that the shift of commu nity focus from residential to industrial decreases the importance and infl uence of the residentia l life within the Battlement Mesa . Residents express concern that a rise of indu strial influence , at the expense of residential influence, will lead to red uced quality of life experience . Uncertainties regarding many aspects of the development also serve to influ ence the experience of community for some residents . Some citizens report that the anticipation of natural gas deve lopment has led to anxiety and depressive symptoms . One former resident stated that the anticipation of the project led to loss of quality of life and the subsequent associated symptoms were a primary rea son for leaving Battlement Mesa . Residents also report that uncertainty regarding the project contributes to anxiety and other symptoms . Diminished access to outdoor recreat ional space , limited by industrial traffic and well deve lopment, is possib le. In addition, the quality of outdoor recreational pursuits such as walking, biking, and golfing may be diminished by increased traffic, noise , air po ll ution, and other industrial activities . Such activities may also serve as constant reminders of the changed community focus . For examp le, the presence of many trucks can change the quality of a walk or bike ride , in addi ti on to being a safety hazard and re le asing pollutants into the air. If industrial traffic cau ses residents to feel the need to leave Battlement Mesa for a peacefu l wa lk rather than Part One Page 63 • • • Draft Battlement Me sa HIA, Re vis ion 1 February 2011 C onducted by Colorado School of Public Health go out their door, then the quality of life has been impacted. Such unquantifiable , yet valued aspects of community appear to be at risk for some Batt lement Mesa residents. Negative Impacts to Social Capital/Social Cohesion: Perhaps the biggest contributor to the social cohesion of Battlement Mesa is its status as a "planned community'', where business , schools, and facilities and access for recreation are cohesively integrated with residential living9 . As such, effects on the social cohesion of Battlement Mesa residents may be determined and intertwined with physical effects to the community its elf, such as damaged or neglected roads , neighboring homes and businesses, public lands and parks . The Antero project seems to have already led to changes to social capital and cohesion. Whether further disruption to social cohesion takes place will depend on the extent to which the Antero project disrupts planned nature of the Battlement Mesa community, particularly during the 5 years of well development. It is possible that traffic, noise, truck emissions, well si te emissions may disrupt the interaction of community and environment, providing a means for decreased social cohesion. Boomtown Effects: The proj ected workforce of 120 -150 is not expected to produce boomtown effects in Battlement Mesa . However, some impacts may occur on a smaller scale, therefore , consideration should be given to potential impacts of this relatively small workforce on this community. Education : At this time it is not known how many students may be associated with the Antero workforce in Battlement Mesa, however, it is not lik ely that this workforce will increase school enrollment beyond capacity. However, children o f transient workers may enter the school system in Battlement Mesa and frequent turnover may disrupt classrooms. In addition, it is possib le that students entering school throughout the sc hool year could burden school resources. If additiona l students are present at the time of "count'', the school would receive additional funds for these students. If, however, students enter the school after the "count" day, no additional resources are allocated from the state for those additional students . Crime: Crime rates in Parachute during the last natural gas boom suggest that if the population of Battlement Mesa increases as a result of the Antero workforce, additional law enforcement may need to be considered . 5.6.6 Characterization of Community Well ness Impacts As described above, community wellness is characterized by qualitative factors such as quality of life , social cohesion and the general experience of community, as well as quantitative factors such as school enrollment, rates of sexually transmitted infection, incidence of criminal activity, burden of substance abuse . For the purposes of this project, the impact due to the Antero project in B att lement Mesa on the community wellness of local residents was calculated in terms of both positive and negative impacts as fo ll ows : Positive Health Effects Part One Page 64 • • • Draft Battlement Mesa HIA, Revision I February 2011 Impact Direction Geographical of health Extent of effects exposure Community Positive Community Wellness wide Populations Duration that Benefit of exposure Yes Long Conducted by Colorado School of Public Health Frequency Likelihood Magnitude of of health of health exposure effects as a effects result of Project Frequent Possible Low *For an explanation of the ranking system used, see th e chart at the beginning of Section 4 . Priority Low* The Antero project could support positive community change by supporting businesses that enhances community cohesion, such as a coffee shop or restaurant. The community would be enhanced by increased school funds, if additional students are present on school count days. In addition, the one million dollar contribution to the community could be used in such a way as to enhance the experience of community for Battlement Mesa residents. Positive community impacts would be expected to be community-wide, affecting residents throughout the Battlement Mesa PUD. Improved school funding would positively impact youth in particular. Positive community effects associated with the Antero project would be expected to last during the five year development phase and therefore b e considered long in duration. Positive community effects are likely to frequent if they occur. However, whether there will be a positive health impact to the community is uncertain , particularly because it is unknown how much the workforce will support existing or future local business or whether children will be enrolled in the schools on count day. It is also unkno wn how the one million dollar contribution to the community will be used . Therefore, it is estimated that positive health impacts is possible. The magnitude of positive health effects are expected to be low. Part One Page 65 • • Draft Battlement Mesa HIA , Revision 1 February 2011 Negative Health effects Impact Direction Geographical of health Extent of effects exposure Community Negative Community Wellness wide Vulnerable Duration populations of exposure Yes Long Conducted by Colorado School of Public Hea lth Frequency Likelihood Magnitude of of health of health exposure effects as a effects result of Project Frequent Po ssib le Low to High *For an explanation of the ranking system used, see th e chart at the beginning of Section 4 . Priority Medium- High* Negative health effects that may be experienced include changes to social cohesion and declining quality of outdoor experience associated with the shift of residential to industrial community. In addition, stresses associated with perceived or real increased threat of crime, heavier industrial traffic , visible impacts to natural environment and recreation areas , rapid influx and possibly turnover of newcomers to the community, exposure to STI and substance abuse, and stress on schools. Much of the anticipated concern is rooted in the previous experience of the community with the 2003-08 natural gas boom . Many of these stressors may be felt by citizens throughout the Battlement Mesa PUD and therefore impacts would be community wide. Elderly and children may be more vulnerable potential negativ e to the community. The elderly may be more susceptible to crimes of theft or burglary, and may be most affected by changes in social cohesion and community experience. Children would be most affected by changes in school enrollment and classroom stability. They may also be affected by changes in outdoor areas used for play, which may overlap with areas prone to more industrial activity or along roadsides used more frequently for hauling drilling materials. We expect the community impacts to continue for the duration of Antero 's project (five years), and therefore be long. Even though the Antero project is relatively small, its location within the community will have more impact on community than development located outside the community boundaries . Therefore, it is expected that exposure to negative effects will be frequent. The likelihood that health impacts will occur as a result of negative effects to the community is probable. The overall magnitude of health effects is expected to be low to medium for most residents , however, some residents may experience high magnitude effects. We have prioritized community stress as medium but recognize that the impacts to the community depend in a large part on the mitigation of other stressors . If mitigation of air, traffic and noise are not sufficient then the sense of community will be negatively impacted, associated stress will increase, and steps to protect the community should take a high priority. 5. 7 Assessment of Economic and Employment Impacts on Health in Battlement Mesa Part One Page 66 • • Draft Battlem ent Mesa HlA, Revis io n 1 February 2011 Cond ucted by Co lorad o School o f Public He a lth Will a boom and bust cycle occur? We are now in a bust and the food banks drying up. What will happen to the property values? Fe bruary 3, 2010 stakeholder mee tin g Economic conditions of a region can have important impacts on the health of the population. Employment status can impact individual health and well-being and economic uncertainty can impact health by increasing stress. Economic deve lo pment of poor and rural areas is often credited with bringing resources that support heal th ; however natural gas development in Garfield County and other parts of the West have had mixed economic impacts in the past. On the positive sid e, the natural gas industry brings jobs to a region and the increa sed economic activity supports other commercial and industrial bu sinesses. On th e other hand , the value of private property where natural gas development occurs has been shown to decline. In addition there are anecdotal reports of residents moving out of areas of natural gas development. Residents of Battlement Mesa have expressed conc erns that sudden economic growth within their community may negatively impact the community by causing housing and goods inflation, and impacting services . Others in the community are concerned that gas industry development will decrease the appeal of the community and cause a decrease in home value s, leading to physical and emotional stress and impacting community unity. A review of economic and employment impacts of the Antero gas project in Battlement Mesa is warranted . 5.7.1 Ways Economic Activity can Influence Health Income and employment influence many central determinants of health and wellbeing , including quality of housing , education, diet, lifestyle, and access to health services . In develop ed countries, employment is directly related to positive health outcomes84 . In the United States , stress related to job loss , unemployment , and job in sta bility is strongly correlated with self-report of poor health85 . Also in the Untied States , health insurance access is directly related to employment for those under the age of 65. Los s of in surance can lead to decreased health care access and poorer health . Increased economic activity of a region can increase jobs and tax revenues which can support public services , th ereb y enhancing community wellne ss . On the other hand , if the economic activity leads to a decreas e in land valu es, resulting psychological stress may impact health . Boom and bust cycles of an industry can al so lead to community stress and cause disruption of public services , which may impact health . Prolonged stress can impact overall physical and mental health, including impacts to cardiovascular disease , immune system effects, depression, and anxiety8 6 . 5.7.2 Past Natural Gas Economic Impacts in Garfield County Employment: The 2007 Socio-Economic Impact study, commissioned by Garfield County and conducted by BBC Research provides a breakdown of economic acti v ity in the county during the 2003-2008 natural gas boom. In 2005 , industry contributions to total county employment included regional services, tourism , external household funding (retiree and non/wage income) Pa rt One Page 6 7 • • • Draft Battlement Mesa HIA, Revision 1 February 2011 Conducted by Colorado School of Public Health gas development, government services, net out-commuting (to jobs in neighboring counties) manufacturing and agriculture . External monies brought to the county by retiree/non-wage income ranked 3rd highest in total jobs supported , while the natural gas industry ranked 4th highest in total jobs in the county87 The subsequent global economic slowdown and national decline in natural gas prices in 2009 led to a rap id decline of jobs and economic activity associated with the industry. Property Values: Housing prices may be adversely affected by proximate natural gas development activities. The Garfield County Land Values and Solutions Study, conducted in 2006 by BBC research determined that property values decreased when a natural gas well was developed on the property. The value of the property was lowest during the drilling phase and began to recover during the completion phases. While the value continued to rise as time since drilling increased, the value of a property did not achieve the same level of appreciation as similar properties without a well. The report also states that increased property value as a whole may occur as a result of increased demand due to natural gas industry worker influx, but the increase is diminished in instances when the prop erty has a well on it. The authors used interview information to determine that possible causes of decreased value include uncertainty and risk adverse behavior on the part of buyers, realtors, and lending institutions88 . Boom/Bust: Natural gas development has created bo om/bust economies in Wyoming, Colorado and other regions of the West over the last decade, with mixed economic impacts to local residents and workers. A case study conducted in Wyoming indicates that many high paying industry jobs require particular skill sets and these jobs are often filled by itinerant industry workers. There were local residents that directly b enefited from increased economic activity. On the other hand, some local residents experienced negative economic impacts associated with inflation, increased property taxes and decreased services7 1• 80 . Some local businesses benefit from an increase in commerce, but other businesses were not able to expand to meet demand . Increased commerce may bring " big box" stores and other new businesses, which put strain on longtime local business, and some ended up closing . Some local residents not earning high industry wages were not be able to keep up with rising cost of living, housing prices, and property taxes . While those working for the industry and related service industries may have less stress and better health related to the economic activity, a local, inflationary economy can cause psychological stress to local workers and residents 79 . Because the gas well development phase is very labor intensive, boom economics associated w ith worker population influx predictably cycles to bust economics when the development phase for the area is over and development moves on to other regions . Economic changes associated with natural gas development may improve health for some due to individual improvement in job status . Others may b e at risk of increased stress associated with declining property value. In addition, changes could bring job insecurity to some residents , thereby increasing stress. 5.7.3 Antero Drilling Plans in Battlement Mesa Part One Page 68 • • • Draft Battlement Mesa HlA, Revision 1 February 2011 Conducted by Colorado School of Public Health Employment: The number of workers involved in well development can vary widely according to pad site topography and geology, number of wells per pad, characteristics of the gas, etc. Most workers are employees of companies subcontracted to perform very specific development jobs and remain on a given pad only as long as needed, sometimes only days, weeks or a few months. Antero plans to use two rigs to develop approximately 200 wells in the PUD over the course of approximately five years. Antero estimates that this kind of serial operation will keep approximately 120-150 workers working within the PUD. Once all the wells in the PUD are developed, the workforce needed to maintain the wells over the 20 years of production is relatively small. Industry workers will realize direct economic benefits of high wage industry jobs. Tax revenues from the Antero project will be realized at a county level. The presence of 120-150 workers in the PUD will provide indirect economic benefits to some local businesses . However, there are very few businesses in the PUD, therefore this trickle down effect is not likely to have a substantial positive impact on most of the Battlement Mesa citizens. Local residents not employed by the industry or supporting businesses may not benefit from economic growth but may be at risk for negative impacts of decreased housing values, goods price inflation, and potentially compromised services. Property Values: The impact of job growth to the economy of Battlement Mesa is likely to include some demand for local housing. Some workers may live in Battlement Mesa, thereby creating demand for housing, although it is not clear if this will be primarily in the rental or sales market., Some workers will live outside of the Battlement Mesa community. The 2006 Garfield County Land Values and Solutions Study focused on rural properties with a well on the property. The natural gas development project in Battlement Mesa is different in that there will be 200 wells within the PUD, but none on any individual residential property. In Battlement Mesa, the development period, which was noted to have the most profound impact on land values, will be at least 5 years. This development period will be longer than development period for wells in the study. It is likely that Battlement Mesa citizens will see decreased property values as a result of well development within the PUD and the impacts could affect most of the properties in Battlement Mesa. Furthermore, the impact may be substanitial given the prolonged development period. While the recent economic downturn has also universally impacted property values, properties close to natural gas development are likely to be additionally impacted by the development as well as the economy. Once the development is over and the sites are undergoing only production activities , land values may recover, although the Land Values Study suggests that values may not ever become equivalent to properties not impacted by natural gas. Boom/Bust: It is not likely that the two rig operation will create a boom or bust economy in Battlement Mesa. Part One Page 69 • • • Draft Battlement Mesa HIA, Revision 1 February 2011 Conducted by Colorado School of Public Health 5. 7.4 Characterization of the Economy, Employment and Property Values Impacts on Health Positive Health Impacts The positive health impacts on the economy, employment and housing values due to the Antero . t . B ttl t M h h l h f l l . d b h . d fl II proJec m a emen esa on t e eat 0 oca res1 ents can ec aractenze as 0 ows: Impact Direction Geographic Populations Duration Frequency Likelihood Magnitude Priority of health extent of that benefit of of of health of health effects exposure exposure exposure effects as a effects result of project Economy, Positive Community Few Long Infrequent Unlikely Low Low* employment wide and property value *For an explanation of the ranking system used, see the chart at the beginning of Section 4. Positive health impacts could be expected in relation to less stress associated with employment for workers living in Battlement Mesa, as well as increased economic activity for those operating some businesses within the PUD. The positive impact of employment and economic activity may be felt community wide should businesses and services increase as a result of the workers presence. Children and families of those employed by Antero and the subcontractors and local businesses are likely to benefit by decreased stre ss associated with economic security and possibly by increased access to health care if health insurance is offered with their job, but these are likely to be few relative to the entire Battlement Mesa Community. The duration of the economic benefits is likely to occur during the 5 year development period, therefore be long in duration. The economic benefits of this small operation are likely to be distributed throughout the county, therefore the frequency of economic benefits in Battlement Mesa are likely to be infrequent. However, because the economic gains to the Battlement Mesa residents will be small, the likelihood of positive health impacts resulting from the small economic gains m Battlement Mesa is unlikely. The magnitude of the health impacts are expected to be low . Negative Health Impacts The negative health impacts on the economy, employment and housing values due to the Antero project in Battlement Mesa on the health oflocal residents can be characterized as follows: Impact Direction Geographic Vulnerable Duration Frequency Likelihood Magnitude Priority of health extent of populations of of of health of he alth effects exposure exposure exposure effects as a effects result of project Economy, Negative Community Yes Long constant Likely Low to Low* employment wide high Part One Page 70 • • Draft Battlement Mesa HlA, Re vis ion 1 February 2011 1 •nd pwporty value Conducted by Co lorado School of Public Health *For an explanation of the ranking system used , see th e chart at the beginning of Section 4 . Economic impacts, and subsequent stress and related health effects are likely to be negative for those not directly employed by the industry. The adverse economic effects of decreasing property values are likely to increase stress for man y residents of Battlement Mesa . Negative economic impacts , including decreased property values, may be experienced community-wide . Those on fixed incomes may be more vulnerable to the loss of property value. The decline of property value is likely to be long lasting: at least as long as the development period, which is expected to be at least 5 years. It is unknown how long property values may be impacted after the end of the development period . The frequency of having stress and related symptoms as a result of declining property value may be constant. It is possible that the severe stress could worsen underlying disease. The magnitude of health im pacts would be related to the degree of stress felt by the individual and may be low to high. 5.8 Assessment of Impacts to Health Infrastructure in Battlement Mesa "What will be the impacts to health care in Battlement Mesa? February 3 stakeholder meeting Health infrastructure can include private and public medical services, hospitals , and emergency transport services. Availability, access and quality of local clinical and public health services can be limited in small communities, due to small populations, low rates of insured patients , and limited public resources . New industry can lead to positive and /or negative impacts on the health care infrastructure. Industrialization of a rural community can increase the insured population and local revenues , which may provide resources for expansion of local clinical and public health care services. On the other hand , without substantial investment in health infrastructure, population and employment changes may increase both clinical and public health care utilization, stretching already limited resource s. The citizens in the rural community of Battlement Mesa have expressed concerns that dev elo pment of natural gas resources in their community may negatively impact available medical resources . Because the Battlement Mesa health infrastructure may be exposed to utilization changes, a review of potential health impacts is needed . 5.8.1 Private and Public Health Services and Health Availability, access and quality of medical health services can have direct impacts on individual physical health . Research demonstrates that resident s of rural communities often have decreased clinical health care services available to them, negatively impacting health 39 -92 Limited Part One Page 71 • • Draft Battlement Mesa HlA, Revision 1 February 2011 Conducted by Colorado School of Public Health availability can be due to a combination of small population and low health insurance coverage, both of which limit the financial viability of both cl inical and public services. As a result, residents of rural communities may need to travel long distances for care. Increased economic activity in a community may bring more patients and insurance coverage which can support increased and diversified clinical medical services. On the other hand, a rapid increase in population, particularly uninsured population, can increase utilization of services beyond capacity and may strain the finances of small medical facilities and decrease incentive to increase services 78 . Public health programs provide services to the general community and can fill some gaps for the un-insured 93-9 . Vaccination programs, health screenings, and communicable disease clinics provide limited clinical health care to uninsured populations. Public health programs that focus on food safety programs and health education programs benefit the community at large. When the local population increases, particularly an uninsured population, local public health services may experience increased utilization while capacity may lag or never catch up . Cyclical economic conditions may also cause intermittent strain on public health programs while making it difficult to adjust capacity to need. On the other hand, local revenues may be able to increase public health services, should tax and royalty structures and community priorities permit it. In some cases, severance taxes from extractive industries are sent to state agencies, with little benefit to the localities where the industrial activity is occurring78 . 5.8.2 Current Health Infrastructure Conditions Currently, primary clinical health services in Battlement Mesa include a primary care clinic administered by the Grand River Hospital District, staffed five days a week by family medicine providers and visiting specialists. The clinic also pro vides physical therapy services three days a week. There is also separate chiropractic, orthopedic, and dental services in Battlement Mesa. There are four hospitals within 60 minutes of Battlement Mesa. The closest hospital is Grand River Medical Center in Rifle, 20 minutes away . This is a 12-bed hospital with an emergency room, surgical, acute care facilities, and outpatient c linics. Grand River Medical Center is a Level 4 trauma center; it does not provide have obstetric (baby delivery) services. Valley View Hospital in Glenwood Springs, 46 miles away, has 80 beds, a 24 hour emergency department, and obstetric services. Community Hospital in Grand Junction, 48 mile away, has 78 beds and does not provide obstetric services. St. Mary 's Hosp ita l in Grand Junction, 49 miles away, is a Level 2 trauma center and has obstetric services. The closest Level l trauma center is 4 hours away in Denver. Patients needing such services may be airlifted. Emergency response and transport is provided by the Grand Valley Fire Protection District. There is an occupational health clinic operated by Grand River Hospital District in Battlement Mesa that sees work related injuries five days a week. Part One Page 72 • • Draft Battlement Me sa HlA, Re v is ion l February 2011 C onducted by C olorado School of Public Health There is a 40 room assisted living facility in Battlement Mesa . The closest skilled nursing facility is in Rifle and there are other nursing facilities in the county. Meals on Wheels is offered in Battlement Mesa and a senior center in Parachute o ffers lunch daily . Public Health services for Battlement Mesa citi z ens are offered by GCPH . Services include vaccination clinics , communicable disea se surveill ance , health education programs , safety programs , health screening for Medicaid patients , and programs for underinsured children and low income families. The Environmental Health Pro gram serves the public by evaluation and education regarding environmental health risks re lated to air and water quality, sewage treatment, mosquito control, and environmental susta inability. The GCPH offices are located in Rifle and Glenwood Springs . Insurance coverage rates for Battlement Mesa re sid ents are not availabl e. According to the Colorado Household survey conducted in 2008-9 by the Colorado Departm ent of Health Care Policy and Financing95 , 14 % of Colorado re sident s w ere uninsured and in the fiv e county region that included Garfield County, 21% of the population w as uninsured (the hi ghe st in the state). In Colorado , 15 % of employed adults were uninsured. Insurance status for natural gas industry workers is unavailable. 5.8.3 Antero Drilling Plans in Battlement Mesa and Healthcare Infrastructure The development of natural gas wells requires se vera l labor intensive phases , which can last several years for large natural gas projects. Mo s t he alth infrastru cture impacts relate to the expanded workforce during the well development pha se. Antero estimat es an average of 120- 150 workers will be working in Battlement Mes a. Workers associated with natural gas developm ent and production projects can increase utilization of emergency services due to increased work related and tran sportation related accidents associated with the injury78 . Insured natural gas workers utilizing the health care system could provide positive support to the system as long as the utilization does not exceed capacity. Should utilization exceed capacity, then th e availability of services may be negati v ely impacted. Uninsured workers strain the health care sys tem . Public health programs may see an increase of utilization as a result of an increase the insured and uninsured population. On the other hand , pubic health programs may benefit fr om increased local revenues , as long as utilization does not exceed capacity. Should thi s hap pen without increase d supporting revenue dedicated to public health , then services may be compromised . The cyclical nature of the natural gas development and production, which is depend ent upon market influences, technological advances and regulatory forces, can make both clinica l and public health infrastructure planning difficult and lead to a mismatch between needs and se rv ices. Some workers and their families are expected to ut ilize clinical and public health services in Battlement Mesa and other local services . According to Antero representatives , Antero workers are offered health msurance; however, information regarding health insurance coverage for Part One Page 7 3 • • • Draft Battlement Mesa HIA, Re v is ion 1 February 2011 C onducted by C olora do School of Publi c Health subcontracted workers (the majority) is not availabl e. Some clinical services may see an increase in utilization, including emergency, urgent ca re and trauma services and services related to pediatric care for young families. Depending on the insurance status of the workers , these services may or may not be directly supported by the industry. Utiliz ation of health services by insured gas workers will support the health system. C linical and emergency providers may be negatively impacted by uncompensated care, and public health services m ay see an increase in local needs without increased funding . Revenues to Garfield County could be used to support public health services , depending upon prioritization o f needs . 5.8.4 Characterization of Healthcare Infrastructure Impacts Positive Effects on Healthcare Infrastructure The positive health impacts on healthcare infrastructure due to the Antero project in Battlement Mesa on the health of local residents can be characteriz ed as follows Impact Direction Geographic Benefited Duration Frequency Likelihood Magnitude of health al Extent of populations of of exposure of health of health effects exposure exposure effects as a effects result of Project Health Pos itive Community-Yes Long Infrequent Unlikely Low Infrastructure wide *For an explanation of the ranking system used , see the chart at the beginning of Section 4. Positive impacts to the health care system are anticipated to be small given Antero 's project involves 120 to 150 workers, spread into a community of approximately 5,000 in Battlement Mesa and 55,000 in Garfield County. Positive health impacts could b e expected in relation to increased utilization of health care services by insured patients . Any insured workers or family members utilizing health care services in Battlement Mesa provide clinic support, necessary for continuing clinical operations . However, the extent o f such support may not be sufficient to lead to increased availability, quality, or diversity of services . Local tax revenues from the Antero project will contribute to the overall county fund which may be used to support public health services, but are not likely to be large enough to directly impact public health services in Battlement Mesa . Should health services be supported in Battlement Mesa, the improvements would be beneficial for the entire community. Those that utilize health care services most frequently such as the elderly, young children and disabled may derive the most benefit of expanded services. Should health service impacts occur, they are likely to be noted during the development period lasting approximately 5 years . Given the relatively small number of workers and families associated with the Antero proj ec t the frequency of positive effects on the health care system in Battlement Mesa are likely to be sporadic, occurring when an insured worker or family member utilizes the health care system . Not all workers /families are expected to utilize Battlement Mesa health services it is unlikely that Battlement Mesa citizens will Part One Page 7 4 Priority Lo w • • Draft Battlement Mesa HIA, Revision 1 February 2011 Conducted by Colorado School of Public Health experience positive impacts as a result of positive changes to the health care infrastructure related to the Antero project. The magnitude of positive health effects due to health infrastructure impacts are expected to be low . For these reasons, the health care infrastructure is prioritized as low compared to other potential stressors. Negative Effects on Healthcare Infrastructure The negative health impacts on healthcare infrastructure due to the Antero project in Battlement Mesa on the health of local residents can be characterized as follows Impact Direction Geographic Vulnerable Duration Frequency Likelihood Magnitude of health al Extent of populations of of exposure of health of health effects exposure exposure effects as a effects result of Project Health Negative Community-Yes Long Infrequent Unlikely Low Infrastructure wide *For an explanation of the ranking system used, see the chart at the beginning of Section 4 . Negative impacts to the health care system are anticipated to be small given Antero's project involves 120 to 150 workers, spread into a community of approximately 5,000 in Battlement Mesa and 55,000 in Garfield County. Negative impacts to local health infrastructure could occur if uninsured workers utilize local health services without the ability to pay for the services, however, the extent of such a strain may be small enough that it is unlikely to lead to decreased availability and quality of services. Impacts of uninsured workers are likely to be noted by providers, but it is unclear that this would reach a level that would negatively impact either clinical or public health services . Should health services be affected in Battlement Mesa, the effects would involve the entire community, a lthough those that utilize health care services most frequently such as the elderly, young children and disabled may be more vulnerable to negative impacts such as decreased availability. Should health service impacts occur, they are likely to occur during the 5 years of we ll development. Given the relatively small number of workers and families associated with the Antero project the frequency of negative effects on the health care system in Battlement Mesa are likely to be sporadic, occurring when an uninsured worker or family member utilizes the health care system. It is possible that large financial strain to local providers, particularly emergency care providers, could occur should expensive emergent care become necessary for an uninsured worker, but this is anticipated to be an infrequent event. It is unlikely th at Battlement Mesa citizens will experience negative health impacts as a result of changes to the health care infrastructure related to the Antero project. The overall magnitude of health effects due to health infrastructure impacts are expected to be low . For these reasons, the health care infrastructure is prioritized as low compared to other potential stressors. 5.9 Assessment of Accidents and Malfunctions Impacts on Health Is there a plan to prevent pipeline leaks and explosions? February], 2010 stakeholders meeting Priority Low* • • Draft Battlement Mesa HIA, Revision l February 2011 Conducted by Colorado School of Public Health Accidents and malfunctions can occur as a result of a variety of causes, including equipment failure, human error, and environmental hazards. Identification of potential sources of accidents and malfunctions can lead to effective prevention efforts, while recognition of potential health, community, and environmental effects can direct response strategies which can decrease impacts should an incident occur. COGCC addresses accid ent prevention (fire, explosion, hazardous materials release, pipeline maintenance) throughout the Rules Document5 . The 600 series rules address safety regulations. For example, setbacks for pad locations are 150 feet in low population density areas, 350 feet in high population areas and 1000 feet for other facilities such as schools, hospitals, etc. Rule 906 specifies reporting , prevention and clean up requirements for spills and releases. Pipeline regulations are found in Rules 1101-1103, however, there is not a designated setback for pipelines in the COGCC rules. According to the Denver Post, there were over 1,000 spills statewide and over 230 in Garfield County reported to the COGCC between January 2008 and June 2010 96 . There were 21 fires, loss of well control (including gas kicks), and explosions in Garfield County that were reported to the COGCC from January 1997 to August 2010 (COGCC database). The Battlement Mesa citizens have expressed concerns regarding the potentia l for accidents and spills and the potential for related health and safety impacts. Because incidents of this nature happen with low, but predictable, regularity, an assessment of potential health impacts is warranted. 5.9.1 Accidents, Malfunctions and Health Accidents and malfunctions can occur as a result o f well installation errors, material failure, construction and operations accidents, equipment accidents and failures, third party activities, and environmental episodes. Incidents can manifest as fires, explosions, hazardous material losses, and/or spills. Fires and explosions may result from well blowouts, gas kicks, pipeline leak or rupture, ignition of flammable materials during storage, transportation or transfer. Hazardous materials spills/loss may be due to transp ortation accidents or equipment failure, during material transfer, leaking valves, fittings, etc in storage equipment, well blowouts, and improper disposal of hazardous materials. Environmental conditions such as wildfires, tomados, lighting, blizzards, and extreme heat and cold may cause or exacerbate incidents . These incidents may result in release of contaminants into surface water, ground water, soil, and air. Releases associated with significant accidents and malfunctions are likely to be acute, high level emissions . Releases of produced water into soil and water sources contain salts, metals, VOC/BTEX, drilling fluids, and hydraulic fracturing chemicals . Spills of drilling and hydraulic fracturing materials could include a variety of chemicals such as diesel fuel and other hydrocarbons, VOCs, acids, glutaraldehyde, and other proprietary chemicals. Releases of natural Part One Page 76 • Draft Battlement Me sa HIA, Revi s ion 1 February 2011 Conducted by C olorado Sc hool of Public He a lth gas into water or air contain VOCs . Combustion products of hydrocarbons released during fire s contain PAHs, including naphthalene , sulfur oxides , nitrogen oxides, PM and other chemicals. Examples of potential health effects of chemicals given sufficient exposure: Chemical Acute health effect voe Irritant, neurological Benzene Neurological, anemia Naphthalene Anemia Combustion Products Respiratory, cardiovasc ul ar, irritants Hydrochloric acid Irritant Glutaraldehyde Irritant, allergic reactio ns In addition to chemical exposures, accidents and malfunctions can expo se nearby persons to injury or death. Although outcomes are potentially sev ere , these exposures are generally short- term, infrequent, and only those in close vicinity at the time of the accident are at risk . Employees on the well pad during a fire or explosion are at most risk for injury. Although the likelihood of an explosion involving a pipeline is small , persons in the community may be at risk for serious injury or death should such an incident occur. For example, an explosion occurred in a rural area of Johnson County Texas on July 7, 201 0 when crews installing a communications pole hit a 36-inch gas transmission line. Newspaper rep orts indicated that one worker was killed , and seven injured. The fire was reported to be 400-600 feet in circumference and intense heat was felt 900 feet away. The gas line valves were shut off 1.5 hours after the explosion, and the fire stopped. A more recent explosion of a 30 inch gas distribution line in San Bruno , California on September 9, 2010, destroyed 150 homes and kill ed four people . The cause of this explosion is still unknown. Other accounts of explosions related to natural gas development, production, and distribution can be found in newspaper accounts throughout the country. 5.9.2 Current Conditions for Accidents and Malfunctions According to the Denver Post, 236 spills in Garfi eld County were reported to the COGCC between January 1, 2008 and June 15 2010, involving 66,386 barrels of fluids (primarily drilling liquids and produced water)96 . During that time, Ant ero submitted approximately 5 percent of the gas permits in Garfield County, reported 15 spill s to the COGCC (6 percent of the spills). Antero 's contribution of 1707 barrels of fluids to the total barrels spilled in Garfield is small (2 .6 percent). Five of Antero 's 15 spills have required remedial action and one resulted in a notice of alleged violation (also known as NOA V) because of fai lure to report the spill to COGCC per the oil and gas rules . The number of spills reported to COGCC may not capture the total number of spills that have occurred because COGCC only requires reporting of spills involving five or more barrels . It is not known how many spills of less th an five barrels have occurred in Garfield County. However, it is reasonable to assume that there have been some spills involving less than five barrels that have not been reported to COGCC . Part One Page 77 • Draft Battlement Me sa HlA, Rev is ion 1 February 2011 C onducted by C olorado School of Public He a lth Antero has received four other Notice of Alleged Vio lations since January 1, 2008. The lastest on July 27, 2010 was in response to the release of an unknown quantity of water and hydrocarbons to a seep on the Eastern wall of Grant Brothers Gravel pit as a re sult of a faulty pipe joint weld on a pipeline. Another Notice of A ll eged Violation on July 14, 2010, was in response to several odor complaints filed during flow back operations on the Watson Ranch well pad. Another Notice of Alleged Violation issued on January 04, 2010, resulted from lack of secondary containment of condensate from hydrauli c fracturing tanks and observation of condensate lying on the ground around hydraulic frac tu ring tanks and separation units . COGCC issued a fourth Notice of Alleged Violation becaus e Antero spudded a well prior to permit approval in June 2009 3 1. Local newspapers and COGCC databases have re co rded numerous incidents of well fires, blowouts, tanker spills, condensate tank emissions and pit discharges in Garfield County. These incidents have resulted in contamination of surface and ground water with BTEX, and other chemicals. Residents have reported a variety of he a lth effects, including acute and long term neurological complaints, upper respiratory issues , h eadaches and fatigue, and nausea . There have been no reported fatal injuries related to accidents or malfunctions in Garfield County reported to COGCC. As noted in comment CIT61 on the September 2010 Draft HIA, there m ay well be more of these types of incidents than are re fle cted in the local media and the COGCC database . • 5.9.3 Antero Drilling Plans in Battlement Mesa and Accidents and Malfunctions • Applying Antero's spill rate of 15 spills per 252 permit applications (6 percent) and rate of 5 remediations per 15 spills to the 200 wells proposed for Battlement Mesa it is estimated that approximately 12 spills of 5 barrels or more may be ex pected in Battlement Mesa over the life of the project. It can be expected that at least four of these spills may have some impact to soil , groundwater, or surface water requiring remediation and have the potential to impact public health. As discussed in the Water and Soil Quality Asses sment, Battlement Mesa residents use a municipal water system that draws water from the Co lorado River. Secondary water supplies include four shallow ground water wells which were u sed prior to the establishment of the water treatment plant. These wells are monitored once a yea r for quality. The Surface Use Agreement between Antero and T he BMC specifies a temporary 50 foot easement for pipeline construction and a permanent 2 5 foot easement for gas gathering lines. Antero also plans to build a wastewater pipeline system along the same easements. The Surface Use Agreement states that the gas gathering lines will be 48 inches below the surface . The gas gathering lines in Battlement Mesa will be 12 inches in diameter. According to maps provided at community meetings , the pipelines primarily follow haul routes, however, there is one pipeline that will cross an open space in a residential area between Valley View Village and Fairways Village and another that crosses open space to the north of Stone Ridge Village . In addition, the Part One Pa ge 78 • • • Draft Battlement Mesa HIA , Revision I February 2011 Conducted by Colorado School of Public Health proposed pipelines for the Parks and Recreation pad, A pad, and B pad appear to be very close to some homes in Stone Ridge Village and Tamarisk M eadows . It is unclear from available maps exactly how far this pipeline, or any other pipeline on the map , is from residences , schools and other buildings. Although the COGCC rules allow for 350 foot well p ad setbacks in densely populated areas , the Antero well pads in Battlement Mesa are all at least 500 feet from the nearest residence. Antero has proposed measures in addition to those required in the COGCC oil and gas rules to prevent well blow outs. These measures include used of blo w preventers rated to 5000 psi and surface casings set to an average of 2,200 feet. However, preventative measures do not rule out the possibility of a catastrophic event arising from a pipeline explosion, well fire , or major spill in the Battlement Mesa PUD as a result of Antero 's p roject. There also is the possibility for catastrophic events as a result of vandalism and sabo tage of Antero's project. In the comments on the original version of the HIA , the Battlement M esa Concerned Citizens raised the concern of well pad locations at the base of steep slopes with dry vegetation that could increase the risk of a well pad fire spreading rapidly up slope towards homes . 5.9.4 Characterization of the Impact from Accidents and Malfunctions Impact Direction Geographical Vulnerable Duration Frequency Likelihood Magnitude of health Extent of populations of of of health of health effects exposure exposure exposure effects effects Acc idents Local or Yes Sh ort In fr equent Po ss ible Low to and Negative Community high malfunctions wide *For an explanation of the ranking system used, see the chart at the beginning of Section 4 . When considering the possible health impacts due to an accident or malfunction of Antero gas operations in Battlement Mesa, the health effects are likely to be negative. Depending upon the size and nature of the incident, health and safety impacts may be felt only in close proximity (local) or throughout the PUD (community-wide). Again, depending upon the nature of the incident, certain populations may be more vulnerable to health impacts. For instance, elderly or frail and those living in the assisted living facility, may have difficulty evacuating an area quickly. Children in school may also be slower to evacuate. Those with underlying medical conditions such as pulmonary or cardiovascular dise as e, may have negative health effects from fires or air emissions at levels that are may not have s ignificant impact to others . Accidents and malfunctions are likely to be short in duration and infrequent. Given the 6% rate of incidents in the industry and within Antero's other operations in Garfield County, incidents are likely to occur and it is possible that health impacts will occur. The health effects will be low to high in magnitude, potentially ranging from minor irritation to severe injury or death. For these reasons , accidents and malfunctions are prioritized as high compared to other potential stressors mainly because of the possibility for severe injuries and death in the event of a catastrophic event. Part One Pa ge 7 9 Priority High* • • • Draft Battlement Mesa HIA, Revision 1 February 2011 6 Conclusions Conducted by Colorado School of Public Health In May, 2010, the Garfield County BOCC engaged the CSPH to perform a HIA to respond to citizen concerns about natural gas drilling in Battlement Mesa, Colorado . We worked closely with the GCPH to ensure the scope of the HIA addres sed the concerns outlined by the citizens in their letter to the BOCC as well as those voiced in citizen meetings. Throughout HIA process , we held several meetings with various stakeholders (the BCC and other residents, COGCC, the CDPHE, Antero, Colorado Hospital Association and West Slope Colorado Oil and Gas Association) to ensure that everyone with pertinent dat a and information had an opportunity to be involved in the HIA process . This revised draft of the HIA takes into account stakeholder comments received during the comment period and di scussed in January and February 2011. The stakeholder process identified eight areas of concern associated with natural gas operations that have the potential to impact health. These areas of concern include air emissions, water and soil contamination, industrial traffic, noise/vibration/light, community wellness, economic and employment changes , health infrastructure stress, and industrial accidents and malfunctions. Using the medical and social health literature, we rev iewed the links between these stressors and health and then applied current conditions and Antero 's natural gas development and production plans and best management practices to assess the p otential future impacts of these physical , psychological and social stressors . We conducted a longitudinal review of multiple Gar field County air and water monitoring studies as well as COGCC reports of water contaminat ion in the county. This information was used to conduct a Human Health Risk Assessment. We also obtained demographic, physical and social health outcome data and used it in a comprehe nsive review described in the Battlement Mesa Baseline Health Profile. We reviewed all publicly available information on Antero's plans to drill in Battlement Mesa, as well information made available to us by request from Antero. In the revised HIA we included references to Antero's b est management practices where applicable and where we had sufficient information about the u se of the best management practices in Battlement Mesa. The key findings of our study are that health of the Battlement Mesa residents will most likely be affected by chemical exposures, accidents or emergencies resulting from industry operations and stress-related community changes . We found that chemical exposures will occur primarily through air emissions during well development activi ties . Increased truck traffic will be a safety risk to Battlement Mesa residents ; contribute to increased air and noise pollution; and impact quality of life. Increased noise may be a problem for some residents, but mitigation efforts by Antero to bring noise levels below COGCC permissible levels should decrease risk of health impacts. The impacts to community wellness will in part be determined by the success of mitigation of other concerns, such as air emissions, traffic and noise. It is not likely that the Part One Page 80 • • • Draft Battlement Mesa HIA, Revision 1 February 2011 Conducted by Colorado School of Public Health primary water supply for Battlement Mesa will be contaminated by Antero activities; however, efforts to monitor and protect the secondary drinking water supply are needed. Industrial accidents and malfunctions occur in the industry and are likely to occur in Battlement Mesa. Most are expected to be minor incidents; however each incident should be considered a near- miss and evaluated to prevent more significant events. The Antero project will provide benefits for some Battlement Mesa citizens. The project may provide jobs for some residents and will provide increased economic activity for local businesses, including health clinics. This increased economic activity can be positive for the community. Other aspects of community wellness may be negatively impacted; opportunities for recreation could decrease. Residents currently report decreased social cohesion and quality of life as a result of the proposed project and this could be worse once the project begins. Property values are likely to decline. While the positive effec ts of employment and increased economic activity will be important for some residents, it is not likely that the project will have large economic benefit for the most of the community. On the other hand, negative impacts to outdoor amenities may and other quality of life compromises, as well as decreased property values, will likely have broader impact throughout the community. Although the HIA identified numerous information gaps, there was sufficient information to justify the key recommendations of pollution prevention, protection of public safety and increased communication through the development of a Community Advisory Board. In Section 3, we provide over 70 specific recommendations aimed at decreasing negative impacts or improving positive impacts. Central to decreasing air pollution is continued efforts to decrease all possible emission sources. To bring emissions to the lowest possible level, it is important that the best available current technology be utilized, and new technologies be developed, tested and adopted. In addition, continued ambient and well pad monitoring of emissions is needed to determine if mitigation efforts are sufficient or additional measures are needed to protect health. For the full benefit of the water storage and distribution system to be realized, the system should be fully operational before any well development activity occurs. Traffic mitigation should also be a priority and we recommend that alternate haul routes for industrial traffic be developed to remove truck traffic off residential roads and out of the PUD. In addition, a spur off Stone Quarry Road should be developed to move industry traffic away from homes backed on to that road. The development of alternate routes will address the issues of safety, air pollution, noise and quality of life related to industrial traffic on residential roads. Noise associated with Antero's project should be monitored and efforts to decrease cumulative noise due to development activities, including truck traffic, pipe installation, well maintenance, and other activities should be undertaken. Finally, efforts should be made create an active Citizen Advisory Board, which will provide all stakeholders an opportunity to bring forth and find solutions for future concerns. The Community Advisory Board will also provide Antero a means to communicate to the citizens in a timely manner. The HIA process identified many information gaps, which limited our ability to provide precise predictions of rates and types of disease. Some gaps may have also precluded our ability to Part One Page 81 • • • Draft Batt lement Me sa HlA, Re vis ion 1 February 2011 C onducted by Colorado School o f Public Health anticipate all possible mitigations . The CSPH investigators and the BOCC recognize that further investigation is needed to document environmental ex posures and subsequent health effects of the natural gas industry. To that end, the BOCC has provided funding to CSPH to design a long term Environmental Health and Monitoring Study (EHMS) in Battlement Mesa and/or Garfield County to address these issues . This long term study w ill: 1) further characterize air emissions associated with natural gas production; 2) characterize air emission exposure level s for persons living in close proximity to natural gas production; 3) further characterize emission sources during development and production phases; 4) dev elo p m ethods to characterize surface and ground drinking water contamination; 5) conduct health surveillance of residents in areas impacted by natural gas and in similar compariso n populations not a ffected by natural gas development and production; 6) conduct social and community health surveillance of areas impacted by natural gas development and production. 7) conduct studies to investigate health effects of ambient air quality on the general populatio n In Colorado , recent legislation will compel Front Range electrical plants to switch to natural gas . On the W estem Slope, there are plans for several natural gas fu elin g stations . These and other market enhancing projects and policies will mean C olorado natural gas development and production projects will continue to grow. The rec ently updated COGCC rules included provisions to protect health and environment. These rules should undergo regular review and update in order to reflect new understanding and technologies as they emerge as well as develop regulations that further protect public health . The COGCC should consider rules that can be tailored to particular situations , such as residential natural gas development. The HIA team supports the CDPHE role in their consultative role to the COGCC and encourages all parties to continue efforts to address public health concerns . Part One Page 8 2 • • EXHIBIT I JS~ AESTHETIC AND NOISE CONTROL REGULATIONS 801. INTRODUCTION The rules and regulations in this section are promulgated to control aesthetics and noise impacts during the drilling , completion and operation of oil and gas wells and production facilities. Any Colorado county, home rule or statutory city, town, territorial charter city or city and county may, by application to the Commission, seek a determination that the rules and regulations in this section, or any individual rule or regulation, shall not apply to oil and gas activities occurring within the boundaries, or any part thereof, of any Colorado county, home rule or statutory city, town , territorial c ha rter city or city and county, such determination to be based upon a showing by any Colorado county, home rule or statutory city , town, territorial charter city or city and county t hat, because of conditions existing therein, the enforcement of these rules and regulations is not necessary within the boundaries of any Colorado county , home rule or statutory city, town , territorial charter city or city and county for the protection of public health, safety and welfare . 802. NOISE ABATEMENT a. The goal of this rule is to identify noise sources re la ted to oil and gas operations that impact surrounding landowners and to implement cost-effective and technically- feasible mitigation measures to bring oil and gas facilities into compliance with the allowable noise levels identified in subsection c . Operators should be aware that noise control is most effectively addressed at the siting and design phase, especially with respect to central ized compression and other downstream "gas facilities" (see definition in the 100 Series of these rules). b. Oil and gas operations at any well site , production facility , or gas facility shall comply with the following maximum permissible noise levels . 800-1 ZONE Residential/ Agricultural/Rural Commercial Light industrial Industrial 7:00 am to n ext 7:00 pm 55 db(A) 60 db(A) 70 db(A) 80 db(A) 7:00 pm to next 7:00 am 50 db(A) 55 db(A) 65 db(A) 75 db(A) The type of land use of the surrounding area sha ll be determined by the Director in consultation with the Local Governmental Designee taking into consideration any applicable zoning or other local land use designation . In the hours between 7:00 a .m . and the next 7:00 the noise levels permitted above ma y be increased ten (10) dB(A) for a period not to exceed fifteen (15) minutes in any one (1) hour period . The allowable noise level for periodic, impulsive or shrill noises is reduced by five (5) dB (A) from the levels shown. (1) Except as required pursuant to Rule 604 .c .(2)A., operations involving pipeline or gas facility installation or maintenance, t he use of a drilling rig, completion rig , workover rig, or stimulation is subject to the maximum permissible noise levels for industrial zones . As September 30 , 2014 • (2) In remote locations, where there is no reasonably proximate occupied structure or Designated Outside Activity Area, the light industrial standard may be applicable . (3) Pursuant to Commission inspection or upon receiving a complaint from a nearby property owner or local governmental designee regarding noise related to oil and gas operations, the Commission shall conduct an onsite investigation and take sound measurements as prescribed herein . 802.c . The following provide guidance for the measurement of sound levels and assignment of points of compliance for oil and gas operations: (1) Sound levels shall be measured at a distance of three hundred and fifty (350) feet from the noise source . At the request of the complainant, the sound level shall also be measured at a point beyond three hundred fifty (350) feet that the complainant believes is more representative of the noise impact. If an oil and gas well site, production facility, or gas facility is installed closer than three hundred fifty (350) feet from an existing occupied structure, sound levels shall be measured at a point twenty-five (25) feet from the structure towards the noise source . Noise levels from oil and gas facilities located on surface property owned, leased, or otherwise controlled by the operator shall be measured at three hundred and fifty (350) feet or at the property line, whichever is greater. In situations where measurement of no ise levels at three hundred and fifty (350) feet is impractical or unrepresentative due to topography, the measurement may be taken at a lesser distance and extrapolated to a 350- foot equivalent using the following formula : db(A) DISTANCE 2 = db(A) DISTANCE 1 -20 x log 10 (distance 2/distance 1) (2) Sound level meters shall be equipped with wind screens , and readings shall be taken when the wind velocity at the time and place of measurement is not more than five (5) miles per hour. (3) Sound level measurements shall be taken four (4) feet above ground level. (4) Sound levels shall be determined by averaging minute-by-minute measurements made over a minimum fifteen (15) minute sample duration if practicable . The sample shall be taken under conditions that are representative of the noise experienced by the complainant (e.g ., at night, morning, evening, or during special weather conditions). (5) In all sound level measurements, the existing ambient noise level from all other sources in the encompassing environment at the time and place of such sound level measurement shall be considered to determine the contribution to the sound level by the oil and gas operation(s). 802.d . In situations where the complaint or Commission onsite inspection indicates that low frequency noise is a component of the problem, the Commission shall obtain a sound level measurement twenty-five (25) feet from the exterior wall of the residence or occupied structure nearest to the noise source, using a noise meter calibrated to the db(C) scale . If this reading exceeds 65 db(C), the Commission shall require the operator to obtain a low frequency noise impact analysis by a qualified sound expert, including identification of any reasonable 800-2 As September 30, 2014 • control measures available to mitigate such low frequency noise impact. Such study shall be provided to the Commiss ion for consideration and possible action . 802.e. Exhaust from all engines, motors , coolers and other mechanized equipment shall be vented in a direction away from all Buildin g Units . 802.f. All Oil and Gas Facilities with engines or motors which are not electrically operated that are within four hundred (400) feet of Building Units shall be equipped with quiet design mufflers or equivalent. All mufflers shall be properly installed and maintained in proper working order. 803. LIGHTING To the extent practicable, site lighting shall be directed do w nward and inward and shielded so as to avoid glare on public roads and Building Units within one thousand (1000) feet. 804. VISUAL IMPACT MITIGATION Production facilities , regardless of construction date , which are observable from any public highway shall be painted with uniform, non-cont rasting, non-reflective color tones (similar to the Munsell Soil Color Coding System), and with colors matched to but slightly darker than the surrounding landscape . 805. ODORS AND DUST a. General. Oil and gas facilities and equipment shall be operated in such a manner that • odors and dust do not constitute a nuisance or ha zard to public welfare. b . Odors. 800-3 (1) Compliance. A. Oil and gas operations shall be in compliance with the Department of Public Health and Environment , Air Quality Control Commission, Regulation No. 2 Odor Emission, 5 C .C .R. 1001-4, Regulation No . 3 (5 C.C .R . 1001-5), and Regula t io n No. 7 Section XVll.B .1 (a-c) and Section XII. B . No violation of Rule 805.b .(1) shall be cited by the Commission , provided that the practices identified in Ru le 805 .b .(2) are used . (2) Production Equipment and Operations. A. Crude Oil, Condensate, and Produced Water Tanks. All crude oil, condensate, and produced water tanks with uncontrolled actual emissions of volatile organic compounds (VOC) of five (5) tons per year (tpy) or greater, located within 1,320 feet of a Building Unit, or a Designated Outside Activity A rea shall use an emission control device capable of achieving 95% control efficiency of voe and shall obtain a perm it as required by Colorado Department of Public Health and Environment , Air Pollution Control Comm ission Regulation as set forth in 805. b . (1 ). As September 30 , 2014 • B. Glycol Dehydrators. All glycol dehydrators with uncontrolled actual emissions of voe of five (5) tpy or greater, located within 1,320 feet of a Building Unit , or a Designated Outside Activity Area shall use an emission control device capable of achieving 90% control efficiency of VOC and shall obtain a permit as required by Colorado Department of Public Health and Environment, Air Pollution Control Commission Regulation as set forth in 805 .b.(1 ). C. Pits. Pits with uncontrolled actual emissions of VOC of five (5) tpy or greater shall not be located with in 1,320 feet of a Building Unit, or a Designated Outside Activity Area . For the purposes of this section , compliance with Rule 902 .c is required. Operators may provide site-specific data and analyses to COGCC staff establishing that pits potentially subject to this subsection do not have a potential to emit voe of five (5) tpy or greater. D. Pneumatic Devices. Low-or no-bleed pneumatic devices must be used when existing pneumatic devices are replaced or repaired, and when new pneumatic devices are installed . (3) Well completions. A. Green completion practices are required on oil and gas wells where reservoir pressure, formation productivity, and wellbore conditions are likely to enable the well to be capable of naturally flowing hydrocarbon gas in flammable or greater concentrations at a stabilized rate in excess of five hundred (500) MCFD to the surface against an induced surface backpressure of five hundred (500) psig or sales line pressure, whichever is greater . Green completion practices are not required for exploratory wells, where the wells are not sufficiently proximate to sales lines , or where green completion practices are otherwise not technically and economically feasible . B. Green completion practices shall inc lude, but not be limited to, the following emission reduction measures: i. The operator shall employ sand traps, surge vessels, separators, and tanks as soon as practicable during flowback and cleanout operations to safely maximize resource recovery and minimize releases to the environment. ii . Well effluent during flowback and cleanout operations prior to encountering hydrocarbon gas of salable quality or significant volumes of condensate may be directed to tanks or pits (where permitted) such that oil or condensate volumes shall not be allowed to accumulate in excess of twenty (20) barrels and must be removed within twenty-four (24) hours . The gaseous phase of non-flammable effluent may be directed to a flare pit or vented from tanks for safety purposes until flammable gas is encountered. iii. Well effluent containing more than ten (10) barrels per day of condensate or within two (2) hours after first encountering hydrocarbon gas of salable quality shall be directed to a 800-4 As September 30, 2014 • • iv . combination of sand traps, separators , surge vessels, and tanks or other equipment as needed to ensure safe separation of sand, hydrocarbon liquids, water, and gas and to ensure salable products are efficiently recovered for sale or conserved and that non-salable products are disposed of in a safe and environmentally responsible manner . If it is safe and technically feasible, closed-top tanks shall utilize backpressure systems that exert a minimum of four (4) ounces of backpressure and a maximum that does not exceed the pressure rating of the tank to facilitate gathering and combustion of tank vapors . VenUbackpressure values, the combustor, lines to the combustor, and knock-outs shall be sized and maintained so as to safely accommodate any surges the system may encounter. v . All salable quality gas shall be directed to the sales line as soon as practicable or shut in and conserved. Temporary flaring or venting shall be permitted as a safety measure during upset conditions and in accordance with all other applicable laws, rules, and regulations . C. An operator may request a variance from the Director if it believes that using green completion practices is infeasible due to well or field conditions, or would endanger the safety of wellsite personnel or the public . D. In instances where green completion practices are not technically feasible, operators shall employ Best Management Practices (BMPs) to reduce emissions. Such BMPs shall consider safety and shall include measures or actions to minimize the time period during which gases are emitted directly to the atmosphere , and monitoring and recording the volume and time period of such emissions. 805.c. Fugitive dust. Operators shall employ practices for control of fugitive dust caused by their operations. Such practices shall include but are not limited to the use of speed restrictions, regular road maintenance, restriction of construction activity during high-wind days, and silica dust controls when handling sand used in hydraulic fracturing operations. Additional management practices such as road surfacing , wind breaks and barriers , or automation of wells to reduce truck traffic may also be required if technologically feasible and economically reasonable to minimize fugitive dust emissions . 800-5 As September 30 , 2014 • • • EXHIBIT I C"' COLORADO Division of Wa t er Resources Department of Natural Resources 1313 Sherman Street. Room 821 Denver. CO 80203 MEMORANDUM Date: To: From: Re: September 14, 2015 Fred Jarman, Garfield County, Director Community Development Department Megan Sullivan, P.E., Water Resource Engi neer Battlement Me sa BMC D Well Pad, MIPA-06-15-8341 Battlement Me sa BMC B Well Pad ,MIPA-06-15-8342 Phase I Pipelin e, PDPA-08-15-8378 This office has reviewed the three land use applications for the development of two natural gas well pads fo r the development of 24 -28 wells on each pad and to construct three co-located pipelines (one gas and two water) of approximately 2 .5 miles length servicing both proposed well pads on properties located in the Battlement Mesa P la nned Unit Development (PUD) in Garfield County , just south and adjacent to the Town of Parachute . During drilling and completion operations, potable water will be provided via an existing water agreement wi t h the Town of S ilt. Non-potable wa ter for use in drilling and dust control will be prov ided by the Battlement Mesa Metropolitan District. During the produ cti on phase , potable water will not be required for daily operations and sanitary services will be handled by portable toilets. A watering system is not require d to maintain any propose d planting . Produced water from the operation of the natural gas we lls will be transported via pipe li ne away from the well pads for dispos a l at permitted water d isposal facilities . The applicant d id not indicated in the submitted information from which formati o n or formations the wells would produce water. For wells completed in formations that a re determined to be non -tributary pursuant to the Produced Nontributary Ground Water Ru le s, non-CBM (coal-bed methane) wells producing non-tributary g round water are not subj ect to administration in the prior appropriation system and ma y operate without a plan for augmentation or a substitute water supply plan. These wells are not required to be permitted so long as the water is used only by the operator in the same geologic basin to facilitate or pe rmit the mining of minerals. If, however, a non-CBM well produces tributary ground water that impacts an over-appropriated stream, the well must operate only according to a water court-approved plan for augmentation or a substitute water supply plan approved pursuant to 37-92-308(4) or 37-92-308(5). This office has no objection to the application . The appl ica nt shou ld refer to the Produced Nontributary Ground Water Rules and the Well Permits and Substitute Waters Supply Plans Submittal Process Memorandum dated 3/24/2010 for further guidance (links to both of which can be found on our webs ite under Ground Water Admin istrat ion). Please note , the locations of these land use applications do overlay nontributary format ions which can be found in the map series A-7 and A-8 of the Produced Nontributary Ground Water Rules. If you or the applicant has any questions, please co ntact me at this office . 1313 Sherman Street. Room 821, Denver, CO 80203 P 303 .866.3581 F 303 .866.3589 www .water.state.co .us Fr ed Jarman ------------------------------------------------------------.. • m· nt: To : Cc: Subject: Mr Jarmen, Hoyer -DNR, Scott <scott.hoyer @state .co .us > Monday, September 14, 2015 9:11 PM Fred Jarman Michael Warren -DNR Re : Garfield County Land Use App lication Referral EXHIBIT j DJ) I Thank you for the opportunity to provide comments on the proposed well pads and pipeline to be built by Ursa Resources in the vicinity of Battlement Mesa. After reviewing the application materials , CPW has concluded that the locations and scope of development are accounted fo r in the Wildlife Mitigation Agreement between Ursa and CPW. Therefore, CPW is not providing additional comments at this time. Please feel free to contact me if you have any questions at 97 0 250-0873. Scott Hoyer On Thursday, August 20 , 2015 , Fred Jarman <fiarman @ garfield-county.com> wrote : • Greetings Everyone, The Garfield County Community Development Dep artment has received three land use applications for the development of two natural gas well pads for the development of 24 -28 wells on each pad and to construct 3 co-located pipel ines (1 gas and 2 water) of approximately 2.5 miles length servicing both proposed well pads on properties located in the Battlement Mesa Planned Unit Development (PUD) just south and adjacent to the Town of Parachute, CO. As the attached form will provide, the three separat e applications are defined as follows: MIP A -8341 (Battlement Mesa BMC D Well Pad) MIPA-8342 (B attement mesa BMC B Well Pad) PDPA-08 -15 -8378 (Phase I Pipeline) • 1 • • EXHIBIT f IG September 14 , 2015 Mr. Fred Jarman Garfield County Planning 108 8111 Street, Suite 401 Glenwood Springs , CO 81601 RE: URSA, Battlement Mesa PUD Phase I, Pipeline Grading Permit: PDPA-08-15-8378 Dear Fred: This office has performed a review of the documents provided for the Battlement Mesa PUD Phase I Pipeline Grading Permit Application of Ursa Operating Company, LLC. The submittal was found to be thorough and well organized. The re view generated the following comments: 1. The Applicant should include fittings or transition necessary to transition from a 12 " pipe to a 16" pipe at station 47+00. 2 . There are two horizontal bends proposed in an area of pipeline that is proposed to be bored beneath Stone Quarry Road , station 59 + 3 7 to station 61 +87. The Applicant should discuss the feasibility of constructing 45° and 87° bends in borings . 3. The Applicant should provide a detail for the propo sed valve sets. 4. The typical trench section should be revised to match the Garfield County conditions for pipeline installations. The note on the cover sho ul d be revised to reference these conditions also. 5. The "Integrated Vegetation and Noxious Weed Management Plan" prepared by West Water Engineering identified locations along the pipeline that had riparian areas and wetlands . The Applicant should identify if any permitting was obtained and /or neces sary and the mitigation that was implemented. Specific construction miti gation necessary should be included on the plan sheets . Feel free to call if you have any questions or comments . Sincerely, Mounto ,n O:ss Enine rin!A Inc . 826 'lz Grand Avenue , Glenw ood Spring s, CO 81601 P: 970 .945.5544 F: 970 .9 4 5 .5558 www .mounta incross-eng .com • • EXHIBIT l~P GRAND VALLEY FIR E PROTECTION DISTR 124 STONE Q UARR Y ROAD September 15, 2015 Fred Jarman Community Development Director 108 8th Street, Suite 401 Glenwood Springs, CO 81601 PARACHU TE , CO 8 1635 PHONE: 285 -91 19 , FAX (9 70) 285 -9 748 Subject: URSA Drilling Applications, Battlement Me sa Mr. Jarman, The Grand Valley Fire Protection District ha s reviewed the applicant's request for drilling permits in the Battlement Mesa PUD and has no obje ctions to the applicant's request . The District has rev iewed the Emergency Response Plans, the haul route s and the proposed pipeline routes . The District does not anticipate any safety or environmental incidents based on the applicant's experiences on other sites in the are a. Traffic and noi se appear to be the bigge st concerns th at may be associated with this proj ect, but the applicant has made commitments to the commun ity that they have a mitiga tion plan for these events and will work with the community in the event of any other unforeseen operational issues . As far as safety and environmental concerns, the District has not been called to any of URSA's sites for any incidents that I'm aware of, other than routine site familiarization visits . We believe that there should be no change in the way th ey conduct the operations planned for the PUD sites . If anything, we anticipate a heightened se n se of "operational situational awareness" during these activities because of where they will be working and the communities expressed concerns and involvement in the process . If you have any further questions regarding this letter, I can be reached at 250-9851 (cell). Don't hes itate to call. Respectfully(]::) David A. Blair Fire Chief, GVFPD i\'il,~i t lll ~;f:tft'll l<'llf \.\'c th c· 111 c 111li c 1:. 1•l"tlw (1rn 11 d v~ill n 1 ~i r c l 1 1"\llL"l:l io11 D i sl1 icl. d c d i c:11L' \llll" t.:lfo r l ~ l\I i lil' pn11 vc li1>11 lll i ltL· l i l'c:,_ prnpl'!"I \ :rnd L'lll'iro11111 c 11 11)1 the ci l i Ll'll'; 11 !". .ind vi ,itor~ to Ill\' (j r;111d Va li n f"irL' l'r ull:Ll i o n llis1 1irl EXHIBIT I 55 • Utl!ltYJJ. Battlement Mesa Metropolitan ... <::::::::;::: # 401 Arroyo Drive I Parachute, CO 81635 • Tel: (970) 285-9050 /Fax: (970) 285-9631 September 14 , 2015 Mr. Fred Jarman Director, Garfield County Community Development Department 108 81 h Street, Suite 401 Glenwood Springs, CO 81601 RE: MIPA -06-15-8341 (Battlement Mesa BMC D Well Pad) MIPA -06-15 -8342 (Battlement Mesa BMC B Well Pad) PDPA -08-15-8378 (Phase I Pipel ine) Dear Mr. Jarman , The Battlement Mesa Metropolitan (BMMD) hereby submits the attached comments, detailed by Colorado !Uver Engineering on behalf of the BMMD, in reference to the URSA development application referenced above. T he BMMD would request that these comments be addressed as the application moves through the permitting process. Sincerely, ct::~rr; District Manager Battlement Mesa Metropolitan District *SERVING THE COMMUNITY * WATER & WASTE WATER OPERATIONS *ACTIVITY CENTER *ASSOCIATION MANAGEMENT • • • CQLO~ADO ftIVEft EN51KEERING 1ic o n r o1t Ar1 o Board of Directors September 14, 20 15 Battlement Mesa Metropolitan District 401 Arroyo Drive Battlement Mesa, CO 81635 Via Email: Steve Rippy <srippy@acsol.net> RE: JOB #1097 -URSA APPLICATIONS GARFIELD COUNTY-BMC PAD B, BMC PAD D, BMC PIPELINE Dear Board of Directors: Colorado River Engineering, Inc. has reviewed the subm ittal applications by URSA to Garfield County for the BMC-B Well Pad, BMC-D Well Pad, and the BMC B Pipeline Phase 1 project. We have prepared th is letter to briefly summarize our recommendations concerning primary issues associated with the projects and its potential impacts t o the Association's infrastructure. 1. The BMC Pad Bis directly adjacent to and just upstream of the intake to water supply for the Battlement Mesa Services Association (Association) on the Colorado River . Due to the proximity and large population served, we bel ieve measures should be developed to further protect the health, safety, and welfare of the citizens receiving their water supply from the Association . a. Water Quality Monitoring -Future continuous source sampling for water diverted from the river is recommended to serve as an early warning tool. Water quality parameters could be monitored for hydrocarbons, pH, and other parameters to provide immediate indicators of changes in the water quality. Alarms or controls could alert the Association in the event that monitored parameters exceed alarm levels . b . Spill Prevention Control and Countermeasure (SPCC) Plan -The existing field wide SPCC does not include any contact information or include any direct actions for notifying the Association in the case of an event. The SPCC has placeholders for a site specific plan and an emergency response plan (Appendix A & B) but our copy of the application does not include these documents . The SPCC should be revised to include the contact information, protocols, and emergency actions associated with protecting the water supply inta ke. An emergency action plan should be developed to identify specific actions, equipment, and protocols to provide protections to the existing water intake and alternative supply. Alternative supply options could include providing a pump and pipeline diverting from the river upstream of the pad site . • • ENGll\EERING 1x c oa.r o u At r!.n c. COGCC Rule 317.B -In the Article 7 Sta ndards Analysis (Section 5.03.08(6) Water Pollution) the application states that th e site does not fall within a COGCC 317 .B Buffer Area . We bel ieve the pad site is w it hin the boundary, based on the on-line COGCC GIS mapping tool. The attache d map from the COGCC shows the buffer zones and approximate pad location w hich fall w ithin the "intermed iate zone". Attached is Rule 317 .B with Section (d) highlighted for the intermed iate zone rules. We recommended that site include Ru le 317 .B approval from the COGCC. The rule does address the SPCC and eme rgen cy response issues presented earlier in our comments . The rule also requ i re s water quality testing for baseline and periodic quarterly monitoring. d. Drainage Plan -We recommend that t he outlet system for the detention pond include engineered inlets, des igned t o provide better storm water quality treatment than currently provided . The current design only involves open ended pipe culverts . The inlets should be multi-tiered inlets with the lowest in let designed for Water Quality Capture Volume to provide slow release discharge rates for higher frequency small storms (See Garco LUR 7-204-C-3 .d.). The inlets should include a sump and hooded outlet for oil and water separation . Engineering calculations should be prov ided to show the routing times through the detention ponds . 2. BMC Pad D -Same comments as BMC Pad B w ith only noted difference is that Pad Dis i n the external buffer zone fo r COGCC Rule 317.B . 3 . BMC Pipeline -The pipeline engineering draw in gs show approximate locations for some of the Association's water and sewer lines. URSA should update the design drawings to accurately depict existing utilities. The design drawings also should provide any details on the plans, profiles, or detail sheets to show construction details related to crossing or paralleling the Association's infrastructure. Fo r example, details should be provided to show how the pipeline will be constructed at water line crossings. The scale provided on the design drawings makes it difficult to review in detail the construction plans related to the Associat ion's infrastructure . We recommend that the design include improved scaled drawings, show separation distances, provide details for crossings or any other engineering design criteria, and incorporate any engineering specifications for relevant design details into the drawings . The submittal set should also include technical specificat ions for all materials, materials testing, and installation requirements . Once the details and specifications are provided, we req uest the opportunity to rev iew and provide comments. All of these documents will also be required for the applicant's third party engineer who must certify the construction (QA/QC) as per County regulations . • • CQJL01 ~ADQ ftKVE,ft ENGIKEERING JJ'c o a.ro n ATr o If you have any questions, please feel free to call o u r office at (970) 625 -4933 . Sincerely, Christopher Manera, P.E . cc: M :\CREjobfi les\1097 -BMMD\Word Files\2015 -9-14 BMMD Comments Letter .docx • • • ('~i.l~. ,~ .. 't'... , .. -~·t •• -;__ ~-., -~ 4 , • t . .,_ .;~_·-e~_~- ... ~·~. > ''- ~ . --. --~ Rule 3178 areas tlJ!JJJU!j7[R ,,.,,P .--,,,..,. -i l ~~~~~OGCC GIS CRE 9/11/2015 • 3178. PUBLIC WATER SYSTEM PROTECTION a. Definitions. For purposes of this Rule 3178: (1) Drilling, Completion, Production and Storage {"OCPS") Operations shall mean operations at {i) well sites for the drilling, completion, recompletion, workover, or stimulation of wells or chemical and production fluid storage, and {ii) any other oil and gas location at which production facilities are operated. DCPS Operations shall exclude roads, gathering lines, pipelines, and routine operations and maintenance . (2) Existing Oil and Gas Location shall mean an oil and gas location, excluding roads, pipelines, and gathering lines, permitted or constructed prior to the later of May 1, 2009 for federal land or April 1, 2009 for all other land or the date that the oil and gas location becomes subject to Rule 3178 by virtue of its proximity to a Classified Water Supply Segment. (3) New Oil and Gas Location shall mean an oil and gas location, excluding roads, pipelines, and gathering lines, that is not an existing oil and gas location. (4) New Surface Disturbance shall mean surface disturbance that expands the area of surface covered by an oil and gas location beyond that initially disturbed in the construction of the oil and gas location . (5) Non-Exempt Linear Feature shall mean a road, gathering line, or pipeline that is not necessary to cross a stream or connect or access a well or a gathering line. b. Applicability Determination . (1) Rule 3178 is applicable to DCPS Operations within Surface Water Supply Areas . The applicability of Rule 3178 will be determined by reviewing the Publ ic Water System Surface Water Supply Area Map, attached as part of Appendix VI, or by entering information into the Public Water System Surface Water Supply Area Applicability Determination Tool, also located on the Commission website . (2) The Public Water Systems subject to the protections of this Rule 3178 are those listed in Appendix VI. Any additions or deletions to the Public Water Systems listed in Appendix VI or the Public Water System Surface Water Supply Area Map, also located in Appendix VI, shall be by Commission rulemaking, as provided in Rule 529. (3) DCPS Operations at New Oil and Gas Locations within a Surface Water Supply Area will be subject to the requirements in Rules 3178.c, 3178 .d, or 3178 .e based on the buffer zones defined in Table 1, below. DCPS Operations at Existing Oil and Gas Locations within a Surface Water Supply Area at which no new surface disturbance has occurred after the date Rule 3178 became applicable to that oil and gas location will be subject to the requirements in Rule 3178.f.{1) based on the buffer zones defined in Table 1. DCPS Operations at Existing Oil and Gas Locations within a Surface Water Supply Area at which new surface disturbance has occurred after the date Rule 3178 became applicable to that oil and gas location will be subject to the requirements in Rule 3178.f.{2) based on the buffer zones defined in Table 1. (4) For Classified Water Supply Segments that are perennial and intermittent streams, buffer zones shall be determined by measuring from the ordinary high water line of each bank to the near edge of the disturbed area at the oil and gas location at which the DCPS Operations will occur. • • • (5) The buffer zones shall apply only to DCPS Operations located on the surface . The buffer zones shall not apply to subsurface boreholes and equipment or materials conta ined therein . The buffer zones sha ll not apply to DCPS Operations located in an area that does not drain to a classified water supply segment protected by this Rule 3178 . TABLE 1. Buffer Zones Associated with DCPS Operations. Zone Classified Water Supply Segments (ft) Internal Buffer 0-300 Intermediate Buffer 301 -500 External Buffer 501 -2,640 c . Requirements for DCPS Operations Conducted at New Oil and Gas Locations in the Internal Buffer Zone. DCPS Operations conducted and Non-Exempt Linear Features located at New Oil and Gas Locations within a Surface Water Supply Area may not occur in whole or in part within the Internal Buffer Zone identified in Table 1 unless a variance is granted pursuant to Rule 502 .b and consultation with the Colorado Department of Public Health and Environment occurs pursuant to Rule 306.d and a Form 2A or Form 2 with appropriate conditions of approval has been approved, or the Director has approved a Comprehensive Drilling Plan pursuant to Rule 216 that covers the operation. In determining appropriate conditions of approval for such operations, the Director shall consider the extent to which the conditions of approval are required to prevent impacts to the Public Water System . (1) The Commission shall grant a variance if the ope rator demonstrates that: A. The proposed DCPS Operations and applicable best management practices and operating procedures will result in substantially equivalent protection of drinking water quality in the Surface Water Supply area; and B. Either: i. Conducting the DCPS Operation outside the Internal Buffer Zone would pose a greater risk to public health , safety, or welfare, including the environment and wildlife resources, such as may be the case where conducting the DCPS Operations outside the Internal Buffer Zone would require construction in steep or erosion-prone terrain or result in greater surface • disturbance due to an inab il ity to use infrastructure already constructed such as roads, well sites , or pipelines; or ii. Conducting DCPS Operations beyond the Internal Buffer Zone is technically infeas ible and prevents the operator from exercis ing its minera l rights . (2) At a minimum , for any DCPS Operation at a New Oil and Gas Location within the Internal Buffer Zone , the Director shall include as co nditions of approval in the Form 2A , Form 2 , or Comprehensive Drilling Plan , the require ments of Rule 317B .d. - - • .. - a ---·- e . Requirements for DCPS Operations at New Oil and Gas Locations within the External Buffer Zone. The following shall be required when DCPS Operations are conducted at New Oil and Gas Locations within a Surface Water Supply Area and in the External Buffer Zone as defined in Table 1 . (1) Pitless drilling systems or containment of all d rilli ng flowback and stimulation fluids pursuant to Rule 904; and (2) When sufficient water exists in the Classified Water Supply Segment, collection of baseline surface water data consisting of a pre-drilling surface water sample collected immediately downgradient of the oil and gas location and follow-up surface water data consisting of a sample collected at the same location three (3) months after the conclusion of any drilling activities and operations or completion . The sample parameters shall include : A. pH; B . Alkalinity; C. Specific conductance; D . Major cations/anions (chloride, fluoride , sulfate, sodium); E. Total dissolved solids; F. BTEX/GRO/DRO; G. TPH; H. PAH's (including benzo(a)pyrene); and I. Metals (arsenic, barium, calcium, chromium . iron , magnesium , selenium). • Current applicable EPA-approved analytical methods for drinking water must be used and analyses must be performed by la boratories that maintain state or nationally accredited programs . Copies of all test results described above shall be provided to the Commission and the potentially impacted Public Water System(s) within three (3) months of collecting the samples . In addition, the analytical resu lts and surveyed sample locations shall be submitted to the Commission in an electron ic data deliverable format. (3) Notification of potentially impacted Public Water Systems within fifteen (15) stream miles downstream of the DCPS Operation prior to commencement of new surface disturb ing activities at the site. (4) An emergency spill response program that includes employee training, safety, and maintenance provisions and current contact information for downstream Public Water System(s) located within fifteen (15) stream miles of the DCPS Operation, as well as the ability to notify any such downstream Public Water System(s) with intake(s) within fifteen (15) stream miles downstream of the DCPS operations . In the event of a spill or release, the operator shall immediately implement the emergency response procedures in the above-described emergency response program. If a spill or re lease impacts or threatens to impact a Public Water System, the operator shall notify the affected or potentially affected Public Water System(s) immediately following discovery of the release, and the spill or release shall be reported to the Commission in accordance with Rule 906 .b.(3), and to the Environmental Release/Incident Report Hotline (1-877-518-5608) in accordance with Rule 906 .b.(4). f. Requirements for DCPS Operations at Existing Oil and Gas Locations. (1) Existing Oil and Gas Locations and DCPS Operations at Existing Oil and Gas Locations within a Surface Water Supply Area and within zones specified in Table 1 shall be subject to the following requirements instead of the requirements of Rules 3178 .c , 3178 .d, or 3178.e provided that no new surface disturbance at the Existing Oil and Gas Location occurs after the later of May 1, 2009 for federal land or April 1, 2009 for all other land or the date Rule 3178 became applicable to the oil and gas location : A . Collection of surface water data from a Classified Water Supply Segment consisting of a sample collected immediately downgradient of the oil and gas operation will occur by the latest of June 1, 2009, within six (6) months after the date Rule 3178 became applicable to the oil and gas location, or when sufficient water exists in the stream: i. pH; ii. Alkalinity: ii i. Specific conductance: iv . Major cations/anions (chloride , fluoride, sulfate , sodium); v. Total dissolved solids ; vi. BTEX/GRO/DRO; • • • vii. TPH ; viii. PAH's (including benzo(a)pyre ne); and ix . Metals (arsenic, barium, calcium , chromium, iron, magnesium , selenium). Current applicable EPA-approved analytical methods for drinking water must be used and analyses must be performed by laboratories that maintain state or nationally accredited programs. Copies of all test results described above shall be provided to the Commission and the potentially impacted Public Water System(s) within three (3) months of collecting the samples . In addition , the analytical results and surveyed sample locations shall be submitted to the Commission in an electronic data deliverable format. B. An emergency spill response program that includes employee training, safety, and maintenance provisions and current contact information for downstream Public Water System(s) located within fifteen (15) stream miles of the DCPS Operation, as well as the ability to notify any such downstream Public Water System(s) with intake(s) within fifteen (15) stream miles downstream of the DCPS Operations . In the event of a spill or release , the operator shall immediately implement the emergency response procedures in the above-described emergency response program . If a spill or release impacts or threatens to impact a Public Water System, the operator shall notify the affected or potentially affected Public Water System(s) immediately following discovery of the release, and the spill or release shall be reported to the Commission in accordance with Rule 906.b .(3), and to the Environmental Release/Incident Report Hotline (1-877-518-5608) in accordance with Rule 906 .b.(4). C. Operators shall employ and maintain Best Management Practices, as necessary, to comply with this rule . (2) Existing Oil and Gas Locations and DCPS Operations at Existing Oil and Gas Locations within a Surface Water Supply Area and within zones specified in Table 1 for which new surface disturbance occurs on or after the later of May 1, 2009 for federal land or on or after April 1, 2009 for all other land or the date Rule 3178 became applicable to the oil and gas location shall be subject to the requirements of Rule 3178.f.(3) instead of the requirements of Rules 3178.c, 3178 .d , or 3178.e where the additional new surface disturbance is addressed in a Comprehensive Drilling Plan accepted pursuant to Rule 216 , or if: A . The new disturbance from the DCPS Operation will not increase the exist ing disturbed area prior to interim reclamation by more than one hundred (100) percent up to a maximum of three (3) acres, and B. The new surface disturbance occurs in a direction away from the stream or no closer to the stream if moving away from the stream would result in more damaging surface disturbance such as location on a steep slope , in an area of high so il erosion potential, or in a wetland . (3) Where the provisions of Rule 3178.f.(2) apply, the following zone requ irements shall apply: • • • A. For all zones, the requirements of Rule 3178.f.(1 ), except that the sampling parameters in Rule 317B.f.(1).A shall occur no later than six (6) months after commencing the DCPS Operations at the Existing Oil and Gas Location . B. For External and Intermediate Buffer Zones : pitless drilling systems or containment of drilling, flowback, and stimulation fluids with impervious liners, as provided in Rule 904 . C . For Internal Buffer Zones : i. Pitless drilling systems ; ii. Flowback and stimulation fluids contained within tanks and placed on a well pad or in an area with downgradient perimeter berming; iii. Berms constructed in compliance with Rule 603 .e.(12) around all crude oil, condensate, and produced water tanks; and iv . Notification of potentially impacted Public Water Systems within fifteen (15) stream miles downstream of the DCPS Operation prior to commencement of new surface disturbing activities at the site . EXHIBIT LA w OFFICE OF l\'lA T THEW Sun.A I# JJ • Matth ew Sura LL C • 42 9 1 Pra do Dri ve, Bo uld e r, CO 80 30 3 • Pho ne : 72 0-5 63-1 866 • ma tt s ura. law@ g ma il.com To: Garfield County Planning Commission Fred Jarman, Director of Garfield County Community Development From: Matthew Sura, Esq. RE: BCC Comments on the Ursa Applications: MIP A -8341, MIPA-8342 , PDPA -08 -15 -8373 Via email: Fred Jarman fiarman({4gar(ield-co11ntv. com September 14 , 2015 Dear Director Jarman and the Garfield County Planning and Zoning Commission, These comments are being submitted on behalf of the Battlement Mesa Concerned Citizens (BCC). For more than a decade, BCC has worked with citizens and operators in Garfield County to provide education about the benefits and risks of oil and gas development as well as to develop solutions to conflicts between the rights of th e surface and mineral estate in the Piceance Basin. BCC has a combined membership and support of hundreds of people in Garfield County. BCC appreciates the opportunity to comment on Ursa 's three proposals for large-scale oil and gas development within the Battlement Mesa Planned Unit Development. The applicati'ons for two well pads with 52 wells, production facilities, disposal wells and pipelines are file numbers MIPA-06-15-8341 , MIPA-06-15-8342, and PDPA-08-15-8378. We will be responding to all three of the related applications in these comments . SUMMARY The state will require Ursa to prepare an "alternative location analysis " that could impact the siting of the wells and production facilities . Prior to making a recommendation on the Ursa applications , the Planning Commission should reques t Ursa to prepare an alternative location analysis . The Planning Director can also request that additional information in his staff report as allowed under 4-10 l.D .3 of the Garfield County Land Use and Development Code ("LUDC"). By state law , COGCC Rule 604 .c(2)E , a multi-well production facility must be "as far as possible from homes". When a multi-well facility is proposed near homes or neighborhoods , the Colorado Oil and Gas Conservation Commission (COGCC) requires that the operator submit an "alternative location analysis" to show that other surface locations , farther from homes , were unavailable or not practicable. Garfield County may also ask for an alternative location analysis . An alternative location analysis should be a prerequisite to any additional action on this permit. Because the alternative location analysis has not been provided by Ursa, this entire application is premature. Ursa is proposing a large-scale industrial use within th e Battlement Mesa residential community. The scale and intensity of its proposed oil and gas op erations are incompatible with the existing residential use of Battlement Mesa and therefore , we recommend that the proposal be denied. • • In addition to the alternative location analysis , Ursa 's proposal is also lacking important information about the location of the Class II injection well(s) it is planning for the area; a Noise Mitigation Study; Visual Mitigation Plan; and a response to the 78 recommendations of the draft Health Impact Analysis conducted by the University o f Colorado School of Public Health about the proposal for oil and gas activity within Battlement Mesa. The Community Development Director should require this information before the application goes to public hearing. BCC members have also offered comments about best management practices (BMPs) that are being used around the state to better protect public health, safety and welfare. The Ursa proposal is lacking the best management practices that are commonly required by other county and city governments throughout the state. We ask that Garfield County require Ursa to meet or exceed industry best management practices before they are allowed to develop oil and gas in the heart of Battlement Mesa PUD. DETAILED COMMENTS 1) ALTERNATIVE LOCATION ANALYSIS SHOULD BE REQUIRED BCC strongly encourages the Community Development Director to request an alternative location analysis from Ursa before proceeding with a public hearing on this application. The 1982 Garfield County Zoning Code(" 1982 Code") requires that Ursa prepare an impact statement that will demonstrate that the proposal is "in compliance with all applicable laws and regulations of the County, State and Federal Governm ents ... " 1982 Code 5.03 .07(1). One or both of the proposed locations within the PUD should be relocated because state law requires that the oil and gas facilities be sited as "far as possible" from existing homes. COGCC Rule 604c.(2)E . states, i. Where technologically feasible and econom ic ally practicable , operators shall consolidate wells to create multi-well pads, including shared locations with other operators. Multi-well production facilities shall be located as far as possible from Building Units . We encourage the Planning Commissioners to determ ine if the location is as far as possible from homes by compelling Ursa to prepare an "alternative location analysis ". The alternative location analysis will determine if alternative locations, farthe r from homes , are technologically feasible or economically practicable . Because of the tremendous technological advances in the past two decades, directional drilling is economically feasible and therefore, drilling outside of the PUD should be required. In fact, other operators in the immediate area routinely drill wells directionally for over 3,500 feet. The widely-used technology of directional drilling should eliminate the need for one or both of the pads proposed within the PUD. 2 • • Commission members will not be setting a precedent with this request. Throughout the state, there have been several proposed multi-well locations that have been moved after being required to provide an alternative location analysis. 1 Some local governments are now routinely requiring an alternative location analysis as a prerequi site for being able to go through the local permitting process .2 Garfield County should also require that industrial-type oil and gas development is located as far as possible from homes by requesting an alternative location analysis. BCC respectfully requests that the analysis be conducted, and the results made public, prior to the Planning Commission issuing any recommendation on the Ursa application . 2) URSA PROPOSAL IS INCOMPATIBLE WITH ADJACENT LAND USES AND THEREFORE SHOULD BE DENIED The proposal for a large-scale oil and gas development site to be drilled and hydraulically fractured within the Battlement Mesa PUD is incompatible with adjacent residential uses within the PUD and should therefore be denied . The Garfield County LUDC requires that the design of the proposed development "must be compatible with the existing character of adjacent land uses."3 It must not create "dust, odors, gas, fumes and glare that are reasonably objectionable to adjacent property." The hours of operation shall be established to minimize impacts to adjacent land uses. Although Ursa proposes to mitigate these impacts, they cannot prevent them from adversely affecting Battlement Mesa residents. As recorded by the county's oil and gas liaison , traffic congestion, odors, loud noise, and poor air quality have prompted Battlement Mesa citizens to complain about surrounding oil and gas development. Battlement Mesa is a residential area that has, for many years, been promoted as a retirement community. The Battlement Mesa covenants clearly state that "no portion of any residential Site, or commercial site shall be used for the purpose of mining, quarrying, drilling, boring or exploring for or removing oil, gas, or other hydrocarbons ... "4 Therefore, Battlement Mesa residents had the reasonable expectation that industrial uses would be prohibited near residential areas within the PUD. Now these citizens are facing a major industrial development of 52 wells, which, by Ursa's own estimates , will take at least 2.3 years to complete. 5 We are additionally concerned that Ursa is NOT proposing limiting its hours of operations to be more compatible with adjacent land uses. Ursa is proposing 24-hour a day drilling and completion activities for over two years. The noise alone produced by a 24-hour a day drilling 1 Examples include the Extraction Oil and Gas location proposed near Frontier Elementary School in Greeley, the Synergy well site near an apartment complex in Gilbert, and the Great Western wellsite near a neighborhood in Windsor. 2 In additional to the examples list above, the City of Brighton Land Use Code requires an alternative location analysis is a well is proposed within 1,000 feet of a home. Last month, Adams County requested an alternative location analysis for the Wadley Farms location in response to neighborhood concerns . 3 Garfield County LUDC, (Rev. 2013) Art. 7-301 . 4 "AMENDED AND RESTATED DECLARATION OF COVENANTS, CONDITIONS AND RESTRICTIONS FOR BATILEMENT MESA" Art. 8 .11, Page 29 Recorded on August 13, 1991 at the Garfield County Cle r k and Recorder at Rec# 426419 Book 811page41. 5 Ursa estimates 5 days of drilling and 10 days of completion work per well plus 21 days for each well pad in their Project Description, Art. 4-203.B.4 page 4. Combined, it will take 837 days to complete the project -barring no unforeseen delays. 3 • • and completion activities for over two years could sig nificantly reduce quality of life, and home values, for nearby residents . Ursa's proposal is also in violation of state law . The COGCC Rule 802 allows for industrial levels of noise during drilling and hydraulic fracturin g (8 0 dB -day and 75 dB -night). However, Rule 604 .c. states that the noise level must b e reduced to li g ht industrial (70 dB -day and 65 dB -night) if there is a home or other "buildin g unit" within 1,000 feet of an oil and gas location. Because there are homes within 1,000 feet o f the proposed location, Ursa must meet the lower threshold of 65/70dBs . Because decibels are on an exponential scale , 80 dBs is twice the amount of noise of 70dBs. According to their app lication , Ursa is planning to produce twice the amount of noise as is allowable by state law. Ursa claims that it will employ best management practices to control noi se. Unfortunately, Ursa 's noise mitigation practices are far from the "be st". Encana Oil and Gas recently agreed to meet a standard of 60dB s for its operations within the T own of Erie . Ursa is propo s ing to emit four times the noise that Encana will be emitting in Erie . (See Bes t Mana gement Pra c ti ces below). If the COGCC complaint log is any measure, Ursa will likely have more odor complaints than noise complaints. Over the past two years , there have been five complaints ag ain st Ursa in Garfield County that have been registered with the COGCC .6 Four of the complaints were for "toxic odors" that were so strong they could not open th eir windows or tum on their swamp cooler . At the public hearing , Battlement Mesa re s idents will a ttest to Ursa 's regular violations of state air quality regulations that prohibit creation of offensiv e odors . In its application, Ursa does not propose any new best management practices to address past odor complaints . They simply state that odor complaints will be addressed by Land Department personnel immediately.7 Ursa 's proposal will create noise and odors that are incompatible with adjacent residential land use . In its application, Ursa even admits that its industrial o perations are "less compatible" with nearby residential uses .8 Ursa acknowledges that the construction, drilling and completion operations are "beyond normal industrial uses of the parcel " durin g the production phase. Once the drilling and fracking are accomplished , the site will revert to "normal industrial " operation s . Any heavy-industrial uses are not compatible within a residential community. Proposing 2 .3 years of "beyond normal industrial uses " makes it clear that this proposal is in violation of the requirement that the new use be compatible with existing adjacent u ses. The Garfield County LUDC is unequivocal -the Planning Commission is required to put forward a Recommendation of Denial if the applicatio n fails to satisfy any one of the applicable requirements and compliance cannot be achieved through conditions of approval. In this case, 6 COGIS Database -https://cogcc.state .co .us click "COG IS Database) the n "inspection I incid e nt" then search for complaints for Ursa . 7 Impact Ana lysis Art. 4-203 .G -D Pad , page 9. 8 Impact Anal ys is, Art. 4-203 .B.4 page 3 . 4 Ursa 's 24-hour a day industrial-scale oil and gas devel opment proposal within Battlement Mesa fails to meet the requirement that the proposed land u se is compatible with the existing character of adjacent land uses. Ursa 's past behavior and its current proposal make it clear their proposal will lead to odors, fumes , and noise that are reasonabl y objectionable to adjacent property owners . 3) THE URSA PROPOSAL IS MISSING KEY INFORMATION The Ursa proposal may have been deemed "technicall y complete'', but it does not contain the information reasonably necessary for the Community Development staff or Planning Commission to make an informed decision as to whether or not it should be recommended for approval. In addition to the missing alternative location analysis, th e Ursa proposal also lacks adequate information on the issues that are most likely to be of concern to residents-including the issue of whether either of the well pads will have a Class II injection well , a Noise Mitigation Study, a Visual Mitigation Plan, or any response to the recommendations within Garfield County's draft Health Impact Analysis . a. Class II Injection Wells The proposal assumes that a Class II waste water injection well will be appro ved within the PUD -although they have not applied for it yet -and then references three potential locations for the waste injection well. Ursa 's traffic study and pipeline plans assum e approval of the injection well within the PUD . BCC believes that the Class II injection well applicati on should be a part of this application . These three applications are incomplete without more information about the location of the injection well and its potential impacts to residents . b. Noise Mitigation Study Another glaring omission is the lack of a "Noise Miti gation Study". Ursa 's "Sound Study" simply reports on what sound levels Ursa recorded at a single location and then makes the assumption that sound walls "have been found to be an effective mitigation ." Even if a sound wall was effective in one location, that success will not necessarily translate to other locations . For example, the proposed B Pad is close to the Colorado River and well below most homes in elevation . Will a sound wall be effective in containing noise for the benefit of the homes that are located above the facility? Ursa should be required to submit an actual Nois e Mi tigation Study that would consider the noise levels, distance , and topography to make estimates of whether or not the noise would be a concern for nearby homes. Once they have an estimate of the potential noise levels , they could design noise mitigation measures to ensure the facilit ies are not a nui sance to nearby residents . The proposal states that the location "may" be surrounded by a sound wall , if necessary .9 Waiting until there are noise complaints to erect a sound wall is certainly not a best management practice and is not in compliance with the Garfield C o unty LUDC . 9 Standards Analysis Art . 7 - D Pad , page 2. 5 • • • c. Visual Mitigation Plan The application is also completely lacking a "Visual Mitigation Plan ." The application states that the "well pad will be visually buffered from adjacent residences through topography, distance, and vegetation through landscaping agreed upon by the owner."10 However, the proposal neglects to state what the landscaping the site would contain. Simply installing the landscaping "agreed upon by the owner" does not rea ssure the adjacent land owners that they will not be looking at a large tank farm for the next 30 years. In most jurisdictions, the applicant submits a site plan that detailed the expected equipment on site, as well as a Visual Mitigation Plan that includes a graphic ·visual simulation of what the site will look like when the landscaping is complete. The Landscaping Plan for D Pad is insufficient to describe what the facility would look like to nearby residents. The Community Development staff requested more information about proposed visual mitigations in the letter of Non-Technical Completeness. But Ursa 's response was still incomplete.11 The Community Development staff and Planning Commission should require Ursa to submit a full Visual Mitigation Plan. d. Compliance with Recommendations in the Draft Health Impact Analysis The letter of Non-Technical Completeness stated that , "During the pre-application conference there was much discussion on the importance , as evidenced by the Board of County Commissioners , of addressing the 78 draft recommendations contained in the non-finaliz ed draft Health Impact Assessment (HIA) commissioned by Garfield County through the University of Colorado School of Public Health . Please provide a response to the recommendations provided in that document." BCC shares the Garfield BOCC opinion that response s to the recommendations in the draft HIA deserve a full response . For example, there are many health and safety recommendations that have not been incorporated in Ursa's application: 12 1. Require periodic maintenance review of water and gas gathering lines to highest industry standards to reduce accidents and malfunctions. 2. Periodically test emergency communications systems. Consider siren, reverse 911, or other system of other mass alert to protect the public health and reduce injury. 3 . Institute mechanism for reporting safety concerns, near-misse s, etc to the appropriate designated county agency or department to reduce accidents and malfunctions . Ensure timely follow up of all concerns. 4 . Review procedures for utility permissions to dig near line location to reduce accidents and malfunctions. 5. Require permanent gas line markers in th e field, and other standard practice safety procedures to reduce accidents and malfunctions. 6 . Review pipeline system for routes that avoid proximity to homes, schools or other areas used by residents to protect the public health and reduce injury. 10 Standards Analysis Art. 7 - D Pad, page 2. 11 See NTC Responses - B Pad , page S. 12 Witter, et al. Draft Battlement Mesa Health Impact Assessment. Colorado School of Public Health, University of Colorado at Denver. 2011. Available at: http://www.garfield-county.com/public-health/battlement-mesa-health-impact-assessment- draft2.aspx 6 • • 7. Place an inlet protection system, similar to the system in place for Rifl e and planned for Parachute, on the two intake s for the Batt lement Mesa water treatment plant that would shut off the intakes if contaminants are detected to protect public health. In response to Antero's previous plans to drill within the PUD , the HIA provided objective information and 78 evidence-based recommendations tha t were based on observation of oil and gas development near Battlement Mesa . Many of the reco mmendations of the HIA have already been adopted by the state COGCC or local governments throughout Colorado. Ursa's dismissive statements that they intend to respo nd to the HIA by submitting a "matri x" during the Planning Commission hearing should not have been accepted by the Community Development staff. Neither the Planning Commission members, nor the public , will have the opportunity to review the "matrix" prior to the Planni ng Commission hearing . The Community Development staff should require full responses to th e draft HIA recommendations prior to any hearing before the Planning Commission. 4) BEST MANAGEMENT PRACTICES Throughout its application, Ursa reassures the County that it will be employing "best management practices" ("BMPs") to protec t public heal th , safety, and welfare and th e environment. But Ursas proposal does not contain m any of the bes t management practices now being commonly used in the industry. BCC encourages Garfield County to require adoption of the best management practice listed below . These BMPs come from a number of sources. These BMPs are found in COGCC permits , in local government land use codes, and in Memorandum s of Understandin g ("MOUs") between local governments and industry. Links to some of th e documents are provided for your review . Please contact BCC if you would like copies of any of the documents listed below. "Brighton" -City of Brighton Land Use and Development Code, Adopted April 7 , 2015.13 "Broomfield" -Broomfield Municipal Code Chapter 17 -54 "Oil and Gas Land Use Regulation s" adopted in 2013.14 "Erie "-Town of Erie Ordinance 21-2015, 2015, Erie , C O . Adopted September 8 , 2015; Also Erie Resolution No . 15-98 -Operator Agreement with Encana. Adopted August 26 , 2015 . "Gunnison County" -Gunnison County Re so lution No. 2012-25, Gunnison County, CO . Adopted August 28, 2012 15 13 City of Brighton , Colorado . City of Brighton Land Use and Developm en t Code, Adopted April 7, 2015 . Available at: http://www.brightonco.gov/DocumentCenter/View/6180 14 City of Broomfield, Colorado . Ordinance No . 1986 "An Ordinance Amending Chapter 17-54, Oil And Gas Land Use Regulations , Of The Broomfield Municipal Code " As amended September 24 , 2013 . Available at: http://www.broomfield.org/DocumentCenter/View/5772 15 Gunnison County, Colorado . Gunnison County Resolution No . 2012 -25,. Adopted August 28, 2012 . Available at : http://www.gunnisoncounty.org/DocumentCenter/View/108 7 • "La Plata" -La Plata County Code or Ordinances , Chap ter 90 . Adopted Augu st 20 , 2013 .16 • • "Timnath" -Timnath MOU, signed on March 10, 201 5 betw een the Town of Timnath and Peterson Energy . a. Air Quality Protections In addition to the air quality requirements under Colorado Air Qua lity Control Pro gram, Title 25 , Section 7, C .R .S ., oil and ga s production facilities loca te d near homes should m eet the se additional requirements to ensure that the dust and harmful air em iss ions (emanati on s) inherent in oil and ga s dev elopment do not harm nearby residents. Local gove rnments have explicit authority ov er air quality issues and can go beyond the states regulations. 17 1. Require an a ir quality ass urance plan for rev iew and appro val for all monitorin g specified in the se recommendati on s to assu re monitoring info rm ation w ill be adequate for informing public health deci s ions. (Bro omfield, HIA , Timna th , Bri ghto n) 2 . Ambient Air Sampling I Monitoring Program . The Operator agrees to cooperate with the implementation of an ambient air sampling program to be completed by the local government using criteria being developed in conjunction with Colorado State University. The local government shall conduct testing in accordance with requirements of the COGCC and Operator shall contribute a specified amount. (Broomfield, Timnath) 3 . Require adherenc e to EPA natu ra l gas ST AR program to reduce VOC emissions to the low est level technically po ss ibl e. (Broomfie ld , HIA, Timna th) 4 . Electric-grid powered motors. R equire u se of electricity fr om th e grid in place of di ese l powered generators for well drilling and trac king operatio ns to r educ e VOC , PAH , and PM emissions . If electricity from the gri d is not available, the operator shall use propane or natural gas to power pump s and motors , if feasible . (Eri e, Broomfi eld , Timnath, Extraction Oil and Gas BMP , HIA , La Plata , CDPHE) 5 . Fu g itive Dus t suppress ion. Dus t associate d w ith on-site acti vitie s and traffic on acces s roads shall be minimized throughout construction, drilling and op erational activities such that there are no visible du st emissions from access roads or the site to the extent practical given wind conditions . (COGCC permit requirements in City of Greeley, CDPHE recommendations in Windsor, Broomfield, Timnath, La Plata, Battlement Mesa SUA, HIA , Brighton) Ursa has stated that it will have a water truck located on the pad during drilling and completion operations . This should be stated in the application and a condition of the permit. 6 . To the extent practicable, exhaust from all engines , motors , co o lers, and other mechanized equipment shall be vented in a direction away from occupied buildings . (HIA , Broomfield , Brighton, Timnath, La Plata) 7. Subjected to an instrument-based leak det ec tion and repair (LDAR) inspection at least once a year-even for equipment emitting les s than 2 tons ofVOCs per year; (Brighton) 8 . voes destruction or control technologi es with at least 95 % efficiency must be 16 La Plata County, Colorado . La Plata County Code or Ordinances, Ch apter 90 . Adopted August 20, 2013 . Available at: http://www.co.laplata.co . us/sites/default/files/departments/planning/chapter 90 2-7-14 revision.pdf 17 C.R.S. § 25 -7-128(1 ) 8 employed on all tanks capable of emitting over 2 tons of VOCs annually; (Brighton) 9. If a leak is discovered the first attempt to repair the leak shall be made no later than 24 hours after discovery. If a repair is not possible within 24 hours, the well should be shut down until a repair can be made. If shu tting down the well will not stop the leak, efforts should be made to minimize the leak within the first 24 hours and it shall be reported to the Local Government Designee. (Brighton, Erie) b. Emergency Prevention and Response Garfield County should require detailed emergency re sponse plans in all cases, but certainly within and near the Battlement Mesa PUD. Local governments have exclusive legislative authority to regulate some aspects of oil and gas development such as transportation and emergency response . In the late 1990 's two boys playing with matches in Monument Creek started a fire that led to the destruction of nine homes. Battlement Mesa residents know the threat of wildfire is serious. The Emergency Response Plan provided by Ursa appears to adequately provide for the safety of its own employees. However, Ursa is planning major industrial facilities in the Battlement Mesa PUD -home to approximately 4,500 people. Ursa should have a plan in place to notify and evacuate the neighborhoods closest to the B and D Pads. Ursa should also have foam units onsite or at least a portable foam unit in the area so it is better able to handle fire at its facilities . • Emergency response plans should include the following: • 1. Require emergency respons e plan that sets out procedures for evacuation, shelter in place and air intake plans for all locations with high concentrations of persons, such as the schools, the assisted living facility, and recreation center to protect the public health and reduce injury. Allow these entities an opportunity to comment on Ursa and community emergency response plans. (Broomfield, HIA, Gunnison County, Timnath, La Plata, Brighton) 2 . Require a foam fire suppression system be located at the well site (CDPHE) 3. Detailed information showing that the op erator has adequate personnel, supplies, and training to implement the emergency response plan immediately at all times during construction and operations. (Broomfield , Timnath, Brighton) 4. A process by which the operator notifies the surrounding neighbors to inform them about the on-site operations and provide sufficient information for surrounding neighbors to communicate with the operator. (Broomfield, Timnath , Brighton) 5. Require emergency responders to review evacuation and shelter in place plans for Battlement Mesa community and Ursa emergency response plans to protect public health and reduce injury . (HIA, Timnath, Brighton, Broomfield) 6 . Require telemetry system to notify the operator of upset conditions with remote well shut-in capability (CDPHE, Brighton) 7. Use Geographical Information System te chnology to overlay pipelines , pigging stations, well locations within Battlement Mesa community to determine relationship to residences, schools, assisted living facility, etc . (Broomfield, HIA, 9 • Timnath) c. Transportation Like Emergency Response, transportation is an issue in which the COGCC has conceded that local governments have jurisdiction. The COGCC does not h ave transportation regulations and expects that regulations of oil and gas transportation will be take n on by the rel e vant local government. The traffic estimate provided by Ursa is unreasonably low. Garfield County should conduct its own traffic analysis to ensure that Ursas propo sa l will not harm traffic flo ws or lead to unreasonable road damage within the Battlement Mesa PUD . 1. Tran sportation Plan and Circulation. The applicant should include detailed descriptions of all proposed acc ess and ha u l routes for equipment, water, sand, waste fluids , waste solids, mixed waste, and all o ther material to be hauled on the public streets and roads of Battlement Mesa . The d isposal of water used on site shall also be documented in detail by the operator, incl u ding anticipa ted haul routes , approximate number of vehicles needed to supply and d is pose of water and the final d e stination for water used in operation. (Broomfield, Erie, T imnath, La Plata, Brighton) 2. Wa s te Management Plan. A Waste Management Plan that describes the handling and storage, transportation, treatment, recycling and disposal of waste generated by the Operation, including exploration and produc tion (E & P) waste . (Erie, Brighton) 3. Roadway Imp act Analysis . An analysis of the impacts of the Operation to the public roadway system within the County. (Gunniso n) 4 . Ch a in s. Traction chains from heavy equip ment shall be remo v ed before e ntering a street or right-of-way. (Broomfield, La Plata, Timnath, Brighton) 5 . Mud Trackin g. The operator shall take all p racticable measures to ensure that vehicles do not track mud or debris onto the stree ts and rights-of-way. If mud or debris is nonetheless deposited on the streets , in exces s of de minimus levels, the streets shall be cleaned immediately by the operator. If fo r some reason this cannot be done, or needs to be postponed, the local government shall be notified of the operator's plan for mud removal. (Broomfield, Timnath, Brighton) 6. Wat er Management. Water necessary fo r drilling and hydraulic fracturing shall be piped to the location if practicable . The availability and u se of Battlement Mesa water shall be at the sole discretion o f Battlement Mesa. (Brighton , Erie) d. Noise Mitigations Erie's recent "Operator Agreement" with Encana C orp . set a new best management standard for Colorado . Encana agreed to limit its noise to 60 dBs -half the noise that the COGCC allows in residential areas during drilling and frac king. Garfield County should afford the residents of Battlement Mesa the same protections the Town of Erie provided its residents . 1. The operator to meet commercials -level 6 0 dBs (Erie, Brighton) 2 . A nois e mitigation plan (Erie, Broomfield, Timnath, La Plata, Brighton) 3. Where the well and well site are in an area of particular noise sensitivity, additional 10 • • noise mitigation may be required . An area of particular noise sensitivity includes, but is not limited to, the following: hospitals, dwelling units, nursing homes, hotels, churches, and designated wildlife preserves. (Broomfield) 4 . Additional noise abatement measures may be required . The level of required mitigation may increase with the proximity of the well and well site to areas of particular noise sensitivity or the level of no ise emitted by the well and well site. One or more of the following additional noise abatement measures may be required: (1) Acoustically insulated housing or cover enclosing the motor or engine; (2) Noise management plan identifying hours of maximum noise emissions, type , frequency , and level of noise to be emitted, and propo sed mitigation measures (Broomfield, La Plata) 5. The Ursa proposal should require that no J ake brakes be allowed within Battlement Mesa. e. Water Protection Local governments have adopted numerous ways to p ro tect domestic water supplies and reduce the potential for water pollution. In Battlement Mesa, this issue should warrant particular attention since the Proposed Ursa B Pad is located in cl o se proximity to the Battlement Mesa water intake on the Colorado River. 1. Identification and plan for protection of all domestic water supplies. (Gunnison, Timnath, Brighton) 2. Require the berming of the down gradient w ell pad perimeters, as well as surface water diversion ditches for each well pad to prevent pollution of water and soil. (HIA, Gunnison) 3. The Ope rator sh a ll u tili ze s tee l-ri m b e rm s arou nd tanks and separators a t th e W e ll Sites w ith s u ffic ient cap ac ity to con tain 1.5 times th e vo lum e of th e larges t ta nk e nclosed by the b erm plu s s u ffi c ient fr eeboa rd to preven t overfl ow. (B room fi e ld , Timnath) 4. There w ill be no C lass II inj ec ti o n w e ll s within the C ity limit s (Eri e, Bri g ht o n) f. Visual Mitigations Visual Mitigation Plans are especially prevalent in municipalities or densely-populated residential areas like Battlement Mesa. The City of Greeley, for example, requires a set number of trees to be planted around the perimeter of every well pad . Greeley also requires that the Visual Mitigation Plan contains a graphic visual simulation of what the site will look like once the landscaping is established. Garfield County can a nd should require Ursa to submit a Visual Mitigation Plan utilizing the BMPs below. 1. A Visual Mitigation Plan should be required. (Brighton, Broomfield, Timnath, La Plata, Greeley) 2 . To the maximum extent practicable, Operator shall comply with the following aesthetic provisions: (Broomfield, Brighton, La Plata) a. Oil and gas facilities shall be located away from prominent natural features such as 11 • • • distinctive rock and land forms , vegetative patterns , ditch crossings , community open space areas, the golf course, and other approved landmarks ; b. Structures shall be of minimal size to satisfy present and future functional requirements ; d. Applicant shall locate facilities at the b ase of slopes to provide a background of topography or natural cover; e . Replace earth adjacent to water crossings at slopes less than the normal angle of repose for the soil type of the site; and f. Align access roads to follow existing gra des and minimize cuts and fills . g. In Urban Mitigation Areas and Useable Open Spaces, one or more of the following landscaping practices may be required by the local government where reasonably practicable, on a site-specific basis : 1. Establishment and proper maintenance of ground covers , shrubs , trees ; 11. Shaping cuts and fills to appea r as natural forms ; 111. Cutting rock areas to create irregular forms; iv. Designing the facility to utili ze natural screens; or v . Construction of fences for us e with or instead of landscaping . 3. A plan for light mitigation (Broomfield, Timnath, Brighton) 4. For operational activities requiring additional lighting, downlighting is required, meaning that all bulbs must be fully shielded to prevent light emissions above a horizontal plane drawn from the bottom of the fixture. (Broomfield, Timnath, La Plata) 5. City may determine fencing materials around facility taking into account aesthetics, cost, and functionality . (Brighton, Erie) g. Planning and Siting Local governments are beginning to require that oil and gas operators engage with Community Development staff far earlier in the planning process . This has allowed local government planners to steer oil and gas development to areas where it will have the least impact on residents and future development. Ursa's predecessor, Antero Resources, had committed to prepare a Comprehensive Drilling Plan for the Battlement Mesa area. Garfield County should require Ursa to prepare a Comprehensive Drilling Plan as a transparent method to disclose the cumulative impacts of all of Ursa 's proposed development on the community. 1. Comprehens ive Development P lan . The Opera tor ag rees to subm it a Co mp re hens ive D eve lo pment Pl an (CDP) to th e loca l government desc ribi ng its p ro posed o peration s w ithin or imm ed iate ly co nti guo us to th e loca l gove rnm e nt bo unda ri es fo r th e nex t fi ve (5) yea rs, to m ax imiz e pl ann in g and m in im ize th e imp acts o f th e pl anned op era tio ns. The a ffec ted area includ es th ose s ites w ithin or imm edi ate ly co nti guo u s to the loca l gove rnm e nt bo und a ri es as th ey the n ex ist w here the Operato r intend s to co nduc t ex plorati on o r produc ti o n ac ti vit ies and in sta ll s up p o rti ng in frast ru cture (compressor stations, waste water treatment facilities , roads , pipelines, etc.) for a period of five (5) years . (Timnath, Broomfield, Brighton and Erie) 12 • • • 2. 1,000 foot setbacks or "'best e ffo11s" to maximize distance s from homes to the greatest ex tent possi b le (T imnat h, Broomfie ld , Erie, Brighton) BCC encourages Garfield County to consider all of th e siting tools available to direct oil and gas development away from residential areas. Local governments all over the state are partnering with oi l and gas industry operators to address impacts to air quality, emergency prevention and response, transportation , noise mitigation, water protection , visual mitigations , and planning and siting of oi l and gas fac ilities . BCC understands that the industry is important to our economy, but so is providing safe and peaceful places for reside nts to live . Fortunately, we do not hav e to choose. As has been demonstrated throughout the sta te , we can have both . ·Sincerely, Douglas Saxton Co-chair Battlement Concerned C itizens Matt Sura On Behalf of Battl e ment Concerned C iti zen s Figure 1. Ursa's two proposed we ll sites within the Battlement Me s a PUD . 13 EXHIBIT Fred Jarman I~~ • m· nt: To: Cc: Subject: Charles Hall <cdhall149@gmail.com> Sunday, September 13, 2015 9:34 PM Fred Jarman Bernita Grove; Chuck Hall; Don Mumma; Frances Rose; Lynn Shore Garfield County Land Use Applicat ion Referral for Battlement Mesa PUD In general all of the documents are very complete and describe the planned Land Use for the Battlement Mesa PUD . Several comments relating to each of the documents: • • MIPA-06-15-8341 (Battlement Mesa BMC D Well Pad) • o 4-118_202 Waiver Request -Support the waiver request for a 2% grade. o 4-203.B.3 Adj Landowners_Mineral Owners -Wells BMC B23D 18-07-95 and BMC B24A 18-07- 95 down hole locations seem to be under house located in Monument Ridge Village. Should these be included as Adj Landowners? o 7-1003.C ERP -Update contact information were applicable; specific Landman John Doose. MIPA-06-15-8342 (Battlement Mesa BMC B Well Pad} o 4-118_202 Waiver Request -Support the waiver request for a 2% grade . o 4-203.B.3 Adj Landowners_Mineral Owners -List of land owners stretches farther than the downhole locations. Why are so many landowners listed? o 4-203.E Grading_Drainage -Drainage Report Cover Page has an incorrect pad location o 4-203 .G.4 Geohaz Report -Important note of no significant faults in Pad B location o 7-1003.C ERP -Update contact informtion were applicable; specific Landman John Doose. • PDPA-08-15-8378 (Phase I Pipeline) o 6-17-15 Grading Permit -Under the Noxious W eed Management Plan; on pages 197 &199 the graphic of the pipeline(s) connecting Pad B & Pad D does not show the bore between the two. Regards, Chuck Hall Chairman, Oil & Gas Committee Battlement Mesa Service Association 1 EXHIBIT 1.:r.:! To: Fred Jarman, Community Development Director Garfield County Planning Commission, Bob Fullerton, Chair • RE:BCC and GVCA Comments on the Ursa Applications: MIP A -8341, MIP A -8342, PDPA -08 -15 - Via email: Fred Jarman .fiarman (c~gar{ield-co u ntv.com September 14, 2015 We want to introduce three organizations which will be actively involved with the Planning & Zoning Commission proceedings regarding the Ursa application: Grand Valley Citizens Alliance (GVCA) is a non-profit, civ ic-action organization founded in 1997 to empower and mobilize Garfield County residents to protect the ir health , environment, and well-being during oil-and-gas exploration and development. ~ Battlement Concerned Citizens (BCC) and th e Rifle-Silt-Peach Valley-New Castle (RSPN) groups are sub-committees of GVCA. Under the umbrella of non-profit Western Colorado Congress (WCC,) GVCA shares information and resources in educating community members about the health, social , and environmental effects from residential drilling . In 2009, Battlement Concerned Citizens organized to mitig ate large-scale industrial development in their neighborhoods --proposed close to homes and schools --especially when they were already impacted by a heavy concentration of drilling/fracking operations surrounding their community. GVCA has also been involved with statewide COGCC rulem aking and has hosted countywide public events. BCC members meet monthly to study potential drilling impacts, sometimes with industry reps . Both groups are represented on the Garfield County Energy Advisory Board. Our members successfully advocated for the county 's "Health Impact Assessment" --and subsequently, now believe that drilling sites should be at least • 2,000 feet away from homes to eliminate health impacts . GVCA members hav e long voiced a need for a local governmental "comprehensive drilling plan" for in-and-around Battlement Mesa to better mitigate the cumulative impacts of large industrial operations in a residen tia l area . At the "public comment" segment of the application review , members of the Grand Valley Citizens Alliance and others will be supporting these actions : Drilling inside a PUD -community of 4,500 people requires great care, thought and planning a.) large-scale industrial O&G production sites proven to be as far from homes/schools/dwellings , as possible, with alternative sites identified; b.) Comprehensive Drilling Plan for in and around Battlement Mesa to plan for the accumulative impacts from multi-company drilling currently in production or proposed ; c .) consideration of cumulative community and socio-economic impacts ; d .) emergency response plans in place (not proposed); e .) increased air & water monitoring; Companies come and go; a community does not a.) residents will have to live with legacy of natural gas development b.) their ideas/concerns should be paramount in thi s process Members and supporters of GVCA look forward to expressing their concerns to commission members and county staff during the application review process. Because so many of our Battlement residents are senior citizens, we hope that special time accommodations for your "public hearing " segments will be considered. e Sincerely, Leslie Robinson, Chair, Grand Valley Citizens Alliance • • • Garfield County 195 W . 14th Street Rifle , CO 81650 (970) 625-5200 Garfield County Community Development 108 81h Street Glenwood Springs, CO 81601 Attn : Fred Jarman Public Health Re : Ursa BMC B and D Well Pads and Pipeline Appli cation September 141h , 2015 Hello Fred , EXHIBIT I I<-~ 2014 Bl ake Avenue Glenwood Springs , CO 81601 (970) 945-6614 Thank you for the opportunity to review this applicatio n and provide referral comments from an Environmental Health perspective. We support many of the statements and conditions of approval already made by Garfield County Community Development , particularly those relating to the Health Impact Assessment (HIA) and that relate t o air and water quality monitoring and protection measures. While the Health Impact Asses s ment is somewhat outdated due to regulation changes from the COGCC and CDPHE as well as modifications to Ursa 's drilling plan, its recommendations can be a useful guide. Ma ny of our comments are in support of these recommendations, particularly those that are not already covered by existing regulations or incorporated into Ursa's standard operating proce d ures . Ursa has demonstrated in their application and community outreach that they are goi ng beyond what is required for compliance with standards on normal well-pad operations. Given the sensitivity of the location of these sites, we would expect that an energy development co mpany work diligently with citizens and permitting agencies to be sure that their impact is min imized to the fullest extent possible . Our specific comments for the Ursa BMC B and D pa d s are as follows : Air Quality Garfield County 's Environmental Health Department has been mon itoring air quality in Battlement Mesa since fall of 2010. In the fall of 201 2, monitoring was expanded to include ozone, particulate matter, nitrous oxides , and total voes in addition to the 90 speciated voes that were already being monitored. Our mobile moni toring unit is located in Glenwood Springs for the calendar year 2015, but will be relocated back to Battlement Mesa in February 2016 . Air quality impacts related to oil and gas operations rem ai n a concern for many citizens in the Battlement Mesa area and Ursa's efforts to minimize impacts are critical. Thanks to Ursa for the work they are already doing to minimize these impact s and outlining best practices in their application. 1. Nuisance conditions a . Ursa states in their Impact Analysis th at the point-person for receiving complaints related to dust , noise , odor, or glare w ill be the Landman . This person 's contact info should be made available through several avenues to adjacent landowners who may experience impacts related to the wells . This person or team should also continue to make efforts throughout the drilling and production process to partner with citizens and other organizations who operate in the area. They Garfield County Public Health Department -working to promote health and prevent disease • • should attend citizen meetings and work with existing groups , and provide transparency throughout their operations. b. Ursa should work very closely with the ir contractors to be sure they are operating to the same high standards as Ursa employees, including reducing vehicle idling whenever possible (per HIA recommendation 3.1 .19). c . Proper dust mitigation during construction and operation of the pads should be used at all times given these well pads ' proximity to homes and the sensitive population groups who may live in them. 2. Air quality monitoring Garfield County has seen statistically s ignificant decreases in many of volatile organic compounds (VOCs) since we began our current monitoring program in 2008, including at the Battlement Mesa site. This indicates that our air quality is improving. However, the intent of our p rogram is collect data on ambient air quality for a region , and does not focus on site-specific or source-specific a ir quality which could contain elevated le vels of some pollutants that may pose a health concern to both industry employees and citizens . Therefore, we believe it ·Would be beneficial for Ursa to further a ir monitoring efforts at their Battlement Mesa operations. This is addressed in HIA recommendat ions 3 .1.1 , 3.1.4, 3.1 .11, and 3 .1.14. The methods we suggest for this are: Water Quality a . Partnering with Garfield County's air quality monitoring program to make us aware of activities that may temporarily increase air emissions so that we can watch for them in our monitoring data. b. Continuing to work with CSU on their natural gas air emissions study. We know that Ursa has already participated in several experiments with CSU, and encourage making CSU aware of all possible opportunities to collect data . We also encourage Ursa to consider making a greater financial contribution to the study should the need arise , as the study is currently not fully funded. c . Collecting voe samples at the well pad during operations and upon completion for a greater understanding of air emissions at the source . This is suggested in recommendation 3.1.11 , with data reporting in recommendation 3.1.14 . Ursa does state in their comments on th is recommendation that "all air emission monitoring and records are required by the CDPHE". However, it is my understanding that the monitoring and records they are referring to are related to throughput and not actual emissions monitoring. Garfield County Environmental Health staff are more than willing to partner with Ursa on developing a sampling plan including the methods, equipment , frequency , and data management. Ursa is already doing many of the recommendations related to water and soils monitoring in the HIA (such as the use of tanks rather than pits, and pi pelines to reduce truck traffic). Some of the recommendations also no longer apply given the fact that there will not be a centralized E&P waste facility or produced water impoundment. 1. Given the proximity to domestic water wells and the Battlement Mesa drinking water intake , Environmental Health supports Community Development in their requirements regarding water quality sampling . In regards to recommendation 3.2 .9 on groundwater sampling , Ursa should report to Community Development the locations of wells they plan Garfield County Public Health Department -working to promote health and prevent disease • • • to sample from . If there are sufficient existing wells in close enough proximity to the well pad , Ursa may be able to use these to collect sa mples and report the results to Community Development. If not , Ursa should drill wells to test wate r quality on a regular basis . We suggest use of the Colorado Depa rtm ent of Public Health and Environment- Lab Services Division 's "Drilling Baseline Package " or something similar from a different lab . https://www.colorado.gov/pacific/cdphe/water-testing . This is particularly critical at the BMC B pad given its close proximity to the C olorado River. 2. When Battlement Mesa Metro District begins developing their Sou rce Water Protection Plan, Ursa should be a key member of the stee ring committee . This will facilitate good communication with the drinking water operator and allow community members to provide input into protecting their water source . 3. Ursa has already outlined the measures they pl an to use at the BMC B pad to prevent any spills from entering the Colorado River. T hi s should be of the upmost importance and we appreciate their efforts. Thank you , fl~~,cf /L 1/i fkfJ: Morgan Hill Environmental Health Specialist Ill Garfield County Public Health 195 W. 14th Street Rifle , CO 81650 (970) 665-6383 Garfield County Public Health Department -working to promote health and prevent disease • • • EXHIBIT I LL September 14, 2015 Garfield County Development Frad A. Jarman, Director 108 8th Street, Suit 401 Glenwood Springs, CO 81601 Dear Mr. Jarman, The attached package contains a petition from citizens of Battlement Mesa (BM) concerning the request for a Special Use Permit (SUP) to drill inside the BM Planned Unit Development (PUD). We are requesting your planning organization include the petition packet in the your final recommendation package to the Garfield County Commissioners concerning this subject. In addition, the citizens of BM request you hold hearings on this important issue in Battlement Mesa. The logistical issues associated with so many of the BM citizens driving to and parking in Glenwood are significant. Besides, many of our citizens are elderly and the drive to and from Glenwood presents a hardship. By holding the hearings in BM many more of the citizens will be able to attend and participate. Thank you for these considerations. Sincerely, Donald Gray 156 Roan Creek Drive Parachute, CO 81635 • • • September 16 , 2015 Battlement Mesa Petition Garfield County Board of County Commissioners 1081h Street, Suite 101 Glenwood Springs, CO 81601 Dear Commissioners. Over Four hundred-sixty citizens of Battlement Mesa are requesting your support. These Battlement Mesa citizens have signed the attached petition asking that you deny the Special Use Permit that would allow Ursa to drill for natural gas inside the boundaries of the Battlement Mesa Planned Unit Development (PUD). This petition is not about stopping drilling; we believe our country needs the energy and we need the related jobs. However, we also believe the majority of natural gas beneath Battlement Mesa can be extracted by drilling around the outer periphery of the PUD, instead of drilling inside the PUD and damaging our beautiful community and our quality of life. The Health Impact Assessment (HIA) conducted by the Colorado School of Public Health stated there would likely be health impacts associated with drilling inside the PUD. At the time funding for completion of the HIA was withheld, Commissioners stated the HIA recommendations would be considered when making future decisions concerning oil and gas drilling. The future is now, and the citizens of Battlement Mesa are asking you to govern in a manner that avoids the risks found in the HIA .. The issue boils down to more financial profit for Ursa on one hand, versus health risks , life disturbances , damage to our community image, and potential property value impacts for BM home owners on the other hand. Many of our citizens have worked and saved most of their lives to be able to own a nice home in the great Battlement Mesa environment. Many will also rely on their home equity to sustain them in later years of their lives. In addition to the health risks identified in the HIA, we also urge you to consider these financial realities , and make deci sions that will protect the people you represent. Should Battlement Mesa residents be expected to endure the above noted health and financial risks for the benefit of Ursa's financial gain? Decidedly not. Please deny the Special Use Permit for drilling inside our community and direct Ursa to drill from outside the PUD. It is the Right Thing to do! Respectfully submitted on behalf of petition signers by: Donald Gray 156 Roan Creek Drive Parachute, CO 81635 Phone: 970-285-9632 i' l' __, \ 'tetition to Deny Special Use Permit for Dril~ with! Battlement Mesa Community • This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed r esidents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside th~ periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) Signature Date Street Address & Zip Email , ) ~~ /C,41J ,'5T@f15jt},Q:JJ1 1 _j<,.;_j} _____ Qf:!.t.._l2..T..e.!!!5-f?._t::::.._-::-:= ____ ' ------~ _!?:!Z:'.£~1 ___ _7P-___ t.~_<:;!.f£K _l!.t!.JLe.._t..1rr1.Jl!A C2 ____________________ _ 2 ~n_~-fr: ___ Cbti ~5---i&J __ ~---------__ ??_~~------0~1~::i>l2 tf _____ 1_Q __ l(__~~-G..wL_~~JW:~ G __ lt;0_d_.~;d_t.,_~~-'2~ ~ 3 --~~?~-'..~':: ___ J~_i,.t;:).\~~-----------(' ('..,. , J\ )J r · \ -j .,---(<. ' ,.., \ _J.sn~~S.S..!~~\:-~ \"v~ ~ ~h?vtv-w6/\ l\0ti rrvi--~ 4 -:------------------------~--~j-----------~~~c::~~jj_-s_q:__J';~ --~~~-~---~~~--\..,.-----~.d.J~--------1~------~~~-'::~---~...;,~_.:.:::::-:. _______________ _ _::ilur.1w2a _li_~3c=:;5!ir J2:.~2:L:L 1-t___l _(,_z. ____ t;;.i_e1.LL~~1-e1~_!d.r:; ____ _ s l2(h,_jJ ___ 13_(£~{zJ.:f.i~----------- ~}}r_u;_j~-l~-t~~---------- . -~-~-!!:-~~---j_-:J..:~:~'!"----~-'if.--~~-~: ___________________________ _ LZ::.l:_l!:!. -j;{._ __ {_{1L.:f __ t_-(LI 7 -~---<;..Da..1iJllJ;.t1.JLL _~_ --¥3/.1;; ___ !_j_ts:_ __ ;:k_ __ ~ __ C!d:::_______ Rr:::!!..~_'?._!__{JJL'::-@, s _--!l:tz},']_'J_: ___ !!__:_'l_:_'Y::_____________ ~--~A~ / ?l!_:kr: ____ f:~---~-~--'"-!:l _________________ -r:~'.=-~--~,o;::: 9 _____ _&:~/!!:!_ __ ~f-~ITL _____ ~~-W!j~-1 -~f-f _ _j_Q~-~li~~-{!~-Jf__~----L ri::::!!:':!_~~'!!_~ tP e '\ 10 __ /f ftl:I_, '._JJ1aL?.L?f_;j_____ ----· ----If~ -'l/i-2)~ :;-,1:?__fj_~_g_~0J_~~-!::_: _____________ fll_ru.ttJ _e}(dk.,Jg.aJ !'if ,J \ ,( ~~ ,,,c. ~-1-_ _ -I ~------] , {)Jr1 ~~~ 11---------------------------------~--~----------.. ______ -_':::::. ____________ ~--L_ ~ _____________ M.. ___ t ___ fi-Jd( ___ 1._ ____________ ~.11_11.z_~~-c.!..(!f._ f!J r, ~ , ~ , --. . ,-1... I p ~~ic .rc~~ 12--~-8~~1-----L~!.:'~'f.?..~-------~--------~d:2~~.Zi..l____ _ _______ 1Z __ ~Q.~/~'L_____________ --f---}_(O_ __ :::~ ~ . -/!<, ~ i:: -j ~ 71;3 )5/ u.; j~ c· }/~ / Ka~f,.,,(-wc.f f4,qNAJ/) £J 13 __ '::!.._~-"!..~-~----------'!J..L§.!5.:-------c __ 9-:".:~_-::.:i_h __ y.r------~;i::L_ _ __ /.!:._____ _ ___________ : ____ o_::: ____ C~f..!_\_ ___ t._~:.t::.._________ ~.J7-_c.§.:~~.l __ ,._ ___ ¥f /- 'T' flj ~ -,J.----v \ f Ii 3 f_ ie --<---(. / <: 14 _: _ _:?_~:::-~----------.::!:~_::.::';7_s;,.. __ ~------~---~------~~~----1~-------~-------Y.il.:kS.1 _!!:..~1'...::.-i.~-':i.:2------~1~--------------------------- 15--------------------------------------------• • • 1.3 ~ Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community fhis petition is not about stopping drilling, it is asking for drilling to be done responsibly. fhe following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside th~ Jeriphery of Battlement Mesa; thereby preserving our beautiful commtmity. Name (printed) /) Signature ( . Date Street Address & Zip -Email 1 __ ;;.s _~i5£1_(l. __ s;_~~lli-----------. k~-~~0~--1_:t:!.f/_l:21 l/ ____ -2k~J:i_ __ 4i d-j t-----~±_.; __ ~J_ti} _ _?____ _ _____________________ _ ,,.. r ~--, I : :::~;.;:~:~r~t~~~;~~/ ~:~~ ::~~~~~~~t~~~~~:t~ -:::::::::=::=::=::: ' ----~~-~~----~-~::'-~~~~-~~~~--------------~~-----!~--------~-:l~-l ~-~---~-~~----~~~1::.-~--:~.t:! __ ~_l~~----~~b-~~l:.------------------------ 5 _Jl1 :~.h0..:U.:_t...::L __ :r.: __ ~L1~{._§J:L~~ _J<:f ~:.1::.it{~t -!..<-..L·-fa.L !L(<:jJ£ __ L:5..~: _____ f-_<J.Y..bE.:.~_Q.JJ __ s_.;; __ ';f Lf£.}$ -----------------------, v ' • f I I I ' . ~ . .r I/ I /1! -I ,,,,. 5 __ 'll.:'iL~-t ~_r_ry __ e_ ____ ~_J.L::!.::.___________ -.. ~-~~~-:.-:::::~---~.!-:.~,~~----:._~:~.U?..__ _ ___ 1 __ ~-----!:~~:_~~--;:;. ___ g_J:_J:~~--~-~ ----------------------- '~ -.'~: ' I\ N · .._. , 0 . . f'-7 · ) " ~ 1 .2_-..!L:.a _L_tLJ.1d_2L/1.__ "_____ _fJ~~.il. __ .1..2ldi , · · __ _ l:1..t~l6 -~?/._f C2kl:._z.~:.L!Li~----0../z ___ ~f.<:_i 5 ----------------------- -~, -r \ --\ . 0 · ...) 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The following signed residents are asking Garfie ld County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. 'Name (printed) e ignflu 'e Date Street Addr•ss & Zip Email 1 -~~-~~:--~"~~~r ----------------------~-~~--~ ____ _______ ______ 11~f3J~!:I..---~~~-1:!.:Lt.J..i.~~!f:?..~.t,,.""~-~~--~L(z.:;;.~ ______________________ _ 2 e2.v:::~_c::£8:~&:_}______ ~---------------~----, ------------l!~~r:-~1..-~~-f~-~-~~-Q~~-~-=------------------------- 3 -li(!:t a.~'*--CQQ_k_______ _ _ 6:'~--~-_up~¥ SJa -~~!llaJau!_rklBL-1112 7ii_ ____________________ _ 4,: __ dtl: __ Y-i~~tt ____ _L.,f12J ____ ,_ __ !rJ _ _ · ~-::-::: : ___ ~LL?.~!'J ___ ,2!:::_2 ___ _8-~<t:J:=::l:c:f '..._f?_:::_!__?::~ :,~=------------------- ~ &,b_e_{_±_(]:f.Jf-{JJ_!!_~± --. ---" _ _ __ J _141~/Lf 2Jb'1si~lJi.cR&~-~9 ___ B_!~:>( ___________________ _ 6 --!.~Y./J..Jl _:t:t: ___ -::.....JJ L_LL<_;,____ "C/"~-·-_ _ _ '1.d~-L_/£;.:l:.1 __ ;_;;L.;L£J. ______ t J __ 1Prfl_JLY._____________ -----------------------' n <c_ ~ J L :£'-/~ . .fl-.11. . I J/J . -!/.J . .U '-<.) +.J... 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I _11?/!_.f' _Jiff. __ J:idlf.'-J::m_l~~-W_f!:/----------------------------- __ lL~(?Jj':> --~~2 ____ s~~~~--~~:\.J.___________ _ ____________________ _ ---~~:.:"---------------- -----"~=-"~--------_.\..:J_~:_J'.? --~~----..'::iJ.J.!J'.:lC:..~: ___ ~'.\::: ______________ _ v I s { e i ~ v r /) 11 t ' r7 f l1~ .' t [,V •rl( t;__c:-·;;J I -i (Jt~ ! >" ), I ( 0 tf &1/' W?rv &I ( 'f b --1 o _J ___ ei~ __________ )_Q_tJ _~).S.C~L2\._ _-.-__.erz.o M ( .:J 11 ~ Vl1. \LW 11-------------------------------------------- 12---]~-;'.:'~_0.S..L Z)~-~-~-\~~-c-____ _ \ a~·· '\ocllf"(\~ c CV · '-·· \· . 13 _..;-_~-----l - ------~·j).f?_ (f'_ ·~------------------- 14 -----,--------------------------------------------·------------------------~------------------------------------------------------·------------..lv I ,· I ·' ,; ' ..., , '! ! ' /,-" . I ' . t .. I .(',.' ~ ' ,'· "\ \ 1. ~ , ' ' I I) ~ \..... /1 ~ ! .... 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Date 4 ~~~-Li:~.L~~~--.::..<:;~~...:=-!'.1 ~2~~~!::!, ___ _ , ,...-- -%°/t'J.-, . .7 /µ ~ &-Vl' :.i <:.;> ' -------------------------------~------------- l/J /1<£ /£1~1'<-S s --------------------------~----~-~~,-;~--,. 7 _l!la.:~b. .l -~-1~--~---~ . l "' ~ -~~ ·;"'i_JJ, _____ 1....Lilj------ Street Address & Zip H_ __ l?_~-~---r_{_leJ_~-------- -~~--(!//.f-__ (2C _______ ~~~~~J_ ____ _ '. ;, Email -c::> -----------------------' -~ -lil!1b_--~-~----------- 1 ;::i:_~~!.~Cfu!L'.t!!!!:r.Jf'.. ___ i:lcf L-!.~:L?_~~?§--_'.j;:JY-}!.__'£,:;:,.-f:_/:::c_<!._C._:__~!_:'£.i!.J..:= ---------------------- 11--.JJJ..2..-'i_d __ :f JJ _t!.)_£1_.lf__.s____ Z..-:t.'6."!~-~TJk..L~--~f_tj;_t _____ L'[.. __ f:.Uft.1_,_, ___ (~<&L___________ --------------------- 12-~E~:-:-0!J~j_1.££.:----~~-~--~-----~--"~;~-+ ---;,!~~~2:::<-<--~-~---: -------------------- 13 ~-"-------:t:1::----~-!.I..---~~~-~~ ----~-~-'-'!----------------l~--~'--------~~~~s::.__. ---------------------- 14 :3la.J).11_d _f __ ~_f_£u.1 li-~r-~--------_____ 2,:J:. ___ fu:.k.~L~,_-f__________ ---------------------- _____ .__2__.i_d__({ia.~-~--------------------------. /)!) ltll-f------15--<-+t ; -~~--------• • v? ,.. Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special U se P ermit and direct Ursa to drill from outside th ~ periphery of Battlement Mesa; thereby p re serving our beautiful community . Name (printed) 1 -~a'A:?..~ __ {:; __ (Jy_ai_. _________ _ '--J1e(:>1-Jn t l(l\/\'c i0 2 --------------------------_) ____ ( ________ _ 9 3 ------- 4 __ /'J.fz.f2..?...I-;f;_1;::._.,:i./"-~tL't!..c.::.£.?.. ________ _ s _ _[)_~_l~ F.. 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'\ ~ ' ~-/ ·;/ Iv ~5-Pil~ T-11---------~~~f ____ t~-~-~-t-}.1-Qt::'______ ~~--------1}2.iJ..-;:-__ J __ 'f.._lJ..:&i1.tJ_n_d_5L _;_~..,f.gk -=---------~------- 12--;J;__~~--£~u_d_____________ 9 &t.._;f,.:d_________ 1_:__z/I_c _____ '{_~_!{ ___ &~ ___ ct_~--------j-£<,o;s_~y_ej'_e.15 eo""' 13 -~~~~r:~~~--tY-:----;---~~~-----~l'.:!I:_ ----~~~'.~~~~~--~~----------------------~-;~~;~--------a; .. 14 --Y -------Ll-'-~---6 -v~l~~~ ---~7~ __ !~L----~-i/u-t1 ______________________________________ :/_Lf.a 35 __ Co ttt __________ ~_<:t..!11 / .:1 . h<1,, . . y '-"~ 1s--·j_[NM61_~----~.a112rJ _____ _ _________________ ~---u-~_-::___ tJ~~-J7 __ i_'7-~---~9-L~---~-1f:: __ ~He_~~ ______________________ I • • - ' vs Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside th~ periphery of Battlement Mesa; thereby preserving ~autiful community. Name (printed) Signa re ) Date Street Addr,~ss & Zip Email 1 ----~.:}__ -----------~ ------------------------------~~~~-~ ----~~--~---~--~ ----------------------- 2 _J6_ _ _z__f<'::_____ ___ l~::-:.._&fZ!<di kili« ___ y __ f».d.!:~-a..---~ _____________ . 3---~!.!:!--J.t'L~.:?_I_____ _f.¥.~~ .!.JJ£/Jt. _2./L ~ -~_5_~ ~::;_ 4 ____ Qb'-t~X~---~-!!~_L __________ __}J -----__ ___ -------.lJ.}l:il!f:. __ J_6Q.~-~-~-~------------------------- s --~~~-~~ ----~--------.l!.J.t~.L'i _J~~~~~J?.L__ _____ ~----------------- ----~-------~ -------_ -----------. -----------.U .:!;2_~_L4-___ l_~_5 __ ~_0_~E~----~~.:-r!- 1 ----------,· ~~217~--:2,f,f2PLJ/fr.L. 2_!1_~ __ (J.Jff/(I __ d61. .. &1!/o.Y!._Cc.i1El.::__ ----~-~------------. ____ ~ • 1 Kt.ft~ , . / /!'J~ · -:--Kcvco~hLd£f S-tisd- 8 _____ 1)__ :Ju..Cc.o~1.klf~1' ______ .i.y0iWJ/.iJ.il_t.: _(/_~!_'I _1 _~.!:}}_:_f.fg'!.J..~!.<:.r:l._Lt:L _ Gt .'1-~-,r~~ A o]I ,/ L --ro Ll1 )./£:;I { [_ . I~ 11'-f 54 LJ-) ~,{) <Ue. ") _ __.!..l/-2.J/J L/.---f.~d..kf __ &/..~ __ fl~ __ fil:_ ___ _ ___ j_-)._e._~~-~--_5---L"--~-.? JJ.l!._~JJ Lf ______ L~ __ i __ ~...J...~\o-~12 __ ~¥-_:fJ __ _ 12-----~~~S.I:t-:::_-::: __________________ _ 13 -----!~-~~-if_[' I ___ ~d-~~5-11-! ____ _ ,, f /, } Jr ·1 L..;J 14 ---------------1 ~-r _____ ..... ___________ _ is---l'..lt_w __ t.Q . .flrc -.. ~---::-::::~--------~-~-----____ c~J-~--~-~ ~.::.:: ____ s __ t:_ ___ .s._'2: __ _ 11/.?::.kf J_ ~ ____ f._~l_ ___ tlP..L1-1P.d.£1!..1f---f:._I _________ _ l 1/ )-l. .)11~ I ( 'Pr c-'~'='.'-.1;;'-,f ,,..,,_ ( L -------~--------------------------------~L{(.2 _kl Lf-~--~/1_ ____ £_~Dt1~-- • -J -\-'.{'-L"i .~~~'ir;;\ __ ;vfo I ••»•-------------- r-1 4 --------i -----r -------- • a D Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special U se Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) Date Street Address & Zip Email 1 ____ tl ~-'!:.~li:l _l-::-_~f2-t:.".:::: _____________ _ ---~-----R~d=r ~w~~f~M.£._______ ~~~~~c;;_:_~~- 2 __ gt.?_~U.L:Cf_'?:. ___ J__J.~f -~lS:----- 'V \£~"N \ ~ ~-~...>~\<...I;!. 3 --------------------------------------------- .~A ..... ~~G'_'t:?,.lf'J:_e:_~--~•-...-------­ ~ \... \'IJ~ \l."t ____ g~~:t _~~.\---------- ____ t _'f!! ___ ~~~'::..~-~~!:~--~~ ... ---------------- __ .,_'fX_M _Lf fll.Jj _ftk..:._~± _______________ _ --~~'..~~~:-~:}~ 4 ___ :f_C{Y-L _Wj_li.~----------------_/!~-~-------!!/-f--'1-- s __ £kJ±q, __ L15Ji1-__________ __R~-fld:t------ub.L1. 6 ___ _(~_it_1::_ __ ~_: __ 1_~q_x.t-:~--~------_1?_q__-!__~---!~~/_2:/.~'! ___ 7_L _/!diJJ~Cc_4-__ ~f:_: ____________ _ 1 ____ l{]e"Bg;a_ _ _s~~&!._____ ~--J~ 11~2:!.i __ (d_1i;d7:1-_V1~J.!:1_ ____________ _ s ---~1_1_~E __ 01~-~~t----------__ iZ,,~LrJP-kr-J:~--~ Hf-:d1'! _ _J!f ___ ,g~-~-~--u-~~~--~-------- 9 _{~-!h<.>:&'.1'£€::~:~1P--~Q'll?___ ty-!fl/11-__ JlLg_1k_fiiill~----------1o2f b ___ LLt:.~~--~--_ __ __U__~ 111-'611'1-___ LLR~Lda-~--v.~~l-ltl_(.L ______ _ 11--L>f-lld..s:e,.+ __ L..-n~0l'..x _;?d.JJ ~ _u.µ/L<.J _J__Li(,d~ _ _/f,.&.1._f.lf:R_c;_g_ 12---vltSt12 _____ ~.t1J?.._{?t_l~-----___ _ -------=--------~ 1!:t:-:.!_i/ --~_( ___ Bkl~_f(J_~!l_C?_{:_k: __ 13 ---~di)J£4-&:r.xzaj____ ;;4~ ________ , ¥--En!Jd~ DJJ/!dr~~ 14 ________ (pfll~_JL_,_____ -!'__/!u'l -~ -----------__ 2£:)_~-~-11--------------4~~~ Q E:~K ~~~\~""' ~lltfj, lr5h"fRJ•4.,/ ----------------------~ I I" - ~~~-"'7 1S._£k&::t~ __ <f_?9-g; ..l- C6/)) c~+· I\"'-\ ~1~0_~~~~; l.UJ7'1 -~~'1-~dl.s_e_~d\ c ~!.~t(~_1__<i2_~( Lt · ·j ~ 11'. [J.f--}f Ul:,.l --~J..d. f"1 hK -~J..U.£..i'_!..J.P..--• (! ,vV Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside th~ periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) Date Street Address & Zip Email 1 J2(t2 i;~-~-------_ ----------(i:~:L29 __ f&~f1l~t;;_f-_9je_ __ Q_r______ l!xJJkCjJ/{fjl~nC'.K) 2 _£1._~~'l;i_~-----~----.iJ:21..-:r:i ~-led'(! f'C'LeCJ..c ______ J:UH}Y2£2f..~~'o~ 3 ~'1,Lcl-£.._QJ .. L~F'--::iJ'.f~l:JJ.Li.M-Ll?.i:J:> _3_:?.:L_~~-''9 hn ~ ~//!, (\J ~ A -....._ ' I~ ~-~ • ~ 4 _1.f-tQ:.O..'?:~-~---\...:W--).flQ__ 7": ---------------------_l_l.j2.Cj/.l !.-\..---------------~~-------------------GkLcl.5::.:?_~.:-&?n n ~ (; i ~ a:·4/j/hf / 'l1 ~ h o+~,/ ... s .iP Ji!.."-d.£..itt.~~ L_ v.· 4~_'.!µ:zdt -PJ..i .. .b.P..~~-Lc.E!:.~ 10.l.~.dk~.!s/,."::J. 6 _!-:~~~-:.:_:~~---0:!_~-~!=____ --~ f1.~~----~-----------~'i~~d ( f_ ___ _:;_~ __ 't(_~c:_if_:t_~!\. __ 0~::-~~. ----------------------- ~ili__0J1£_~,,i~_7 . ----------t.d.l:/..Lt-2-~-~l!=!!!.:.i _l~~--~~. 8 -~~~"'~J'!i..'.l.~~----~~-------!..~~ --~----~~tl::::_~-~~--------~--------- 9 ---~-tCil __ k_au_r-f?.--------_ __ ~ _ _ _ ______ ~3j_qJir --~--dLi_c:?.:. ___ Q~!:_t____________ &...~-~~~!-~ € /!1 ~11 • 10 -±J_tf_f:. __ t/fi.!_~L}d______ -~----~ ~7/_c,/;_t: .. #i.£4.~!1 .. __ <!__T.7._____________ ---·------------------O f'A l l--.l;.:1~.!..~ti2.. ___ k.:. . .i:-l&.1.1.!f.!'7 - -------.r:..:./J.ld:!:!f... ~~ £:2..2£._7c:J'l~.i~-fVL--{;.._ ___________ _ 12-/.lJ!i.!f/~LM..0.____ _ _ ~-~...> ..tk.2..zk~..2IL12L_ _____ _ 13 ~-.._£(i~_'i:(_~JfJ.:fj_?__1__6!_____ ---~-------~/tL~i:______ ---~0£ _ _[_?._ ___ !___~!l__~(._t:~l}___}_~::l!. ____ _ - 14 ~lLll..~.t.:..G:.t~!'!_L~-~-~ ~~.r~~ c(_!/.!td1 'i.' ___ ~_2-__ I~.'1-~~-~r-~~-.: _____________ _ ~-'-:tt9:.i:iL~_'l£'.Mi\ctat t ..... 1s-lh .. ~J:.!..ld--~----~t3~.ld ~~-~/.!_~/.~ -----~_?_ ___ e.?,_ __ 9_.!1._j __ fC:.!:.. ... ~--~-: _____ _ • • • ~5 Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside th~ periphery of Battlement Mesa; thereby preserving our beautiful community . . Name (printed) Signature Date Street Address & Zip Email 1 _f!8r!fA __ ~-~-~~~-~Q~T~ ___ (h~-~~ _JL-1-i1 ----~Q __ L~~~-C_tr..________ ------~~~---------- 2 ·:S_Q~c..~Q,.c.±l~1ru..~._w__________ -~-~J:)~~----1~~:~:_1_~ ___ l .ft_y__L_ilh~.i?.(-~-G.r..·-----------------____ .:N.;.! ___________ _ 3 J.2.1_<:L~J3*i±£fr!.?2!':0:L ____ ,!.f ~£..~::2 !!..:_f!_~(f_ _(_~?:.l::..'?!f!..?'f'!_'!..~ __ 0_6_ ________________ _ 4 _':&_ ___ ~~~-------------E!t! ______ t}~~-c~~----!/_:__s:_::_t ____ !!_f!.!!-_~~-i_~;t1.~-~--0:.~!..~ _____________________ _ s _l:f.._q,r_1[J _tZ..r..c..-f_ __ Ja;:..i:.?2..?.. P lf.---~4~J{_7$'_-::1;: __ ]_2-_b_i _~er-112µ~--9.!::c/_E-.JL~------ 6 __ £J __ ~tL ---~--~-l>.-7-~e_t4-_______ _ __ O ,£. __ lli ,~W------------~-~.b:kf~--~----s__~~h;(fl..~~--~!__q__ · · k-~~--( 1\ i .. u LIJ;,, Co·~, ~c.L <l.tJi-.,.,eMr)1.c-f--. 7 -~~-::~-~-~--~-s-~~~~~:~-~~--_____ 0~~<::::---~~ _:~=--~-~------------------~.:.2.~-t~~-=-----------------& <; h.~~-=-':!P-?_~-- '-IJJ.'6;.,.,;;,,,,, AA .'J / µ--..,/} . .,.0, V O •V1C(\J.)+~J'UJ: s --~-~.!:~L~J_\.~~--s±_~-9.~~-------'.Jfv-~;_, _ _i~:_r.~~~------------~-1--~~-a_________ ~-/--~---------- ~~---------------/__~ __ t)_~~----~------? _/:?!:________________ ~-~ l ~~h J_~~-.¥----£..e._.J _J~.l\J -.~ ~ _'.!is/;:: _;}__<,f .• ----------------~~ __ }!/It __________ _ . -/. ~. 0 i1--~,,z~:.~-------4~r_~L0_________________ _-f ~Jl'f_ _ __ Q_'L ___ &JLKSf-uL:t:L _____________ /Yi!L __________ _ 12-L---,2_9 __ J>..0~~~-~----------~tl~----------------LL~:.J}j_ __ ?_i__bB!J.':O:'?-\'-~----~!_,_________________ 9..,i.!&&_~5-H -IV ._l-- 13 --e~c_ry_\~~-~~~~ -1~~~-7;~~:;-~ ---~~~---J:-t::~f:!-2~~--~:_c _ !~~~~7itfi~ 14 ________________________ t __________________ -------------------------------~~~ ------------------~----------11 -------f------------------_______________________ ,/~ .----.:; (" 15 ___ B_d6 ~J3-..~~-----~ _ ----------------l/~i.:::/_1/_ _ __ d .::z _<Laz/iec,i:)J.LJ..::e.__________________ /Ll'/.~L0:.<it-j'aJ-<Ji I .cc~ I~ N'E .J3 A5 Com f/p_/t'-f Z7 Lt/7'6-evp_;~--0 '• / 1 \ 1 ~,i\ox\,( Con@.\{)( \\\~\IL\ ,7 L\1Y\"cl<~\N GfLlL I ' I JJ S Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside th~ periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) Date Street Address & Zip Email 1 -~0::.~~~-~~~~~-~~------------------- 2 _! f ~~rf:t-~--(l_'r:_-!!Y..~:--11-~~~---!.L3 G 2 ;_.sdx_~.k:fi;z;j_~d,,J!_l(lA ------------- 3 -----. ___ Q_ _____ /3-~--.--------.-J:~--~.-----__ LU. t -J.i ____ {,__$. -----/!-~IJ5. __ -:_5fY.-_ _f!_~ ---------------,~-Gt ~I I ~--']$ ~~S •. -. ~ , " c, ··7 ·· ~ 4 -:c -L---'-~l..~~ ---]J--~~-_:_,._~7 ~:~--___'.:.:~'.-~--~".}-~-~~~---~ ~---------- 5 --;;;~~-1=~~~;---~----¥--~l~~ -:L~!J-!1~~~=--~~;~------{ 6 ___ _.1:__ ____ ~~_!.: __ \l'.'.._J:!__ ~~----~-____ 'f-~~--~--------------------'~~ 1 ---~~:i-frt->:-~ --:l_~---~L --~__::Q -/.K _7-i<,,_G:£_~-;/E_:~l_!,_~ ---------------- s ---------~---------~-----------~.s:.. -------------------------;---~-l~-------'----------~~-------~--~~~~--______________________ _ j(--;Z{f -~-l)_-~~~~!.f::.!.L __ 2f : __ _r_~f __ 2_'------- (~ 9 1-~!.ib.[f.z'!.!:.tdo.JS.il t £ _ _ ~ _#/11. L{1_1.:?._ __c3..t_.d!.i.~J!..J/.1..~.w.._f!/q_~~ ----------------------- 10 _ ... ifi.&..!11§~L11£fi._____ --~t--~J 1_g_:~f__ _ __ ff__!fJ_P-/!:!f.._~£&.tl~------------------------------ b o'-"--ct LCL S Sa.Jc.~ ~~~ 1 /.2 -17 ~I /<1 D c.£ U1 €~ fl. 11-----------...J.______________________________ --------------------------------------------------- _j 'Z(rLJ ~'-;l-6 12----------------l.-=t--------------------- 13 __ J_~!J._";;_ __ g~±kt-7---- .. j <t l-1 N )"' ? L t/ c / N f If f 14 ------------------------------------------- ~o L+N 6MlCic-N1 15------------------------------------------- -rt?~----------L:..1-1~L5 _f_b..3_Ylc1i_ilcj!__t}.r:_4x. .JJ.~~.c~i\t&ef: ·~fl-~---_(:_t!..:1£ __ L!..L ___ 6)}Jfa.k.J.. __ ~ __ U:_f:________ ----------------------IL d _ ?'VOINSkt~~, ¥-~4-~:~-/~ ~~~~:::_~-:__~~~:_=~ ~:~::~~GI • • • ?? Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community fhis petition is not about stopping drilling, it is asking for drilling to be done responsibly. fhe following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the Jeriphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) 4A7//qfi, / lU f::A v €R, L ---------------------------------------------/ P 1tlf/f-1c!v ]? ?l Elff/L--~ ? __ .!J.._: _____________________________________ _ l _!._ __ '!':'::_':_'!.::rf..._@ ~f_~- t ___ !B~ttf:=_Q. ___ K~'-::_'-:::!..tt:t. _____ _ 5 -¥-a)_ __ j~----------- 5 --~-~_J __ L~-~---~~-1~.Y.l1-~]'-~t ____ _ ·r rtN >7J 7 Afz_f~_er"' 7 __ ..!::! ___________ ~-~------------------------- ~ --~~---<:'J------~-~-~_/:5 __ ~!~---------~ ~1?--~--~-~&~~~i1t _____ _ L 0 --~'::_~---:::!_~~-~~-::.= __________ _ //, \=' L 1-~~-~::-·i.b~~:-:.:} ______ ~-~-~----- , b1 . L2--G _?_p_4::_~--~~-~-----f:!.-~~Y-..tJ_T_ L3 -~Q{!fi,z:_/[_fis_1~mz_c;/f __ _ -/""\. Signature Date Street Address & Zip Email ____ i?':..~'!:S-...--__ '/:_if.:i-7 _____ (.i:.__!:f.!L~~i.;i~--t;t_ ______ C:.!..t>..:X;.______ ----------------------- --=~--------/-rj'r _____ !_~-~~~!..=-::_~ ____ t:Lf.n __ -______________________ _ _ __ :~~~-----_:_:__':!.(; tt-----~:C..E_&i_9£_~!.._t!_ef ___________________ _ __ . ___ .,_ .. ___ ~ ;_d!:_t_I.! r ____ 1__~-~~.!XV_JJ_(l:_~_(;r;__f!_~-~~ ---------------------- --~!A __ lf.£¥5lf_U.~---_!d#fi± ---~t::_ __ fd __ ~r:L ~ _______ ?_f.{g_}_?:__ ----------------------- ---------~~?~~--!!__~------___ L _:~~L1 t ___ LB-J ____ ):.:B~-J~e,. ______ f 1~ __ 1:..:=__ ----------------------- ~~--~'-! ____________ '.!_:~J_:'"'----~-~-~---~--'--~~i _t,,~-~ -------------------- _1.3.:p_ ____ ~~----------~!_:_)}.-!_ 11 ----~--~--~---~-: __ !!: ___ 2!_~_<!:!:__~-~-~--~?: --------------------------t--/ /( ~ ( ' ( ..... ~ I . -· <7 /'} " I _ __, I -.) ----~~~-:-_. __ 1=:.{ __ ~ I ~-!!_:_?J:._~ d __ zr:_Jf_ __ ?ll L~tfl~~cz _~--~q_l_<f?.~-~ -==--~------------- --~~-------___________________ L~~~L :!-1 __ :f:_~--~--~1J?5E--~± ____ 8_1@~-------------------------- ~}:l<l_.:;-4-k _________ 11_:_~~~i __ L~t ?_~-~ffi ___ Q-_\l'.JM __ ~t __ SL<. j l_ ________________ _ _-19-=!::1£J1=·~d.~'---L!:2ut-__ !:!!!L _~ ___ JL~!l __ ~:_______ _ __________________ _ __&~--~/y_1':~ 11:·2 -~=-~t/ __ ::!_f~~~-~---~f2___ ----------------------- . -.-'\ ~-'-~--. _:_• -!:'J-"•----~!'.:-2:.t~iLL --'L..-~ __ 1 l!.:1 .JJ~~--S~:~: .c ---~--------15--'\-~:J'.~-~1_/~J}~!;-¥--.)~-~-~=~ ;2u_t' _;f_j~A'.!E:!::;_: ____________ _ • L \ \ (5 'vv Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) 1 __ A_~\g_'!::{ _____ Y._~\f;_~----- ~ L /wk 2 --------------------------------------------- 3 ---~l~-l ----~~iJ-~_.l::L~------------ n 1 I C l'-<-11 ( ~ rC\h (.{ IJt\ 4 ------------------------~------------------I 5 --------------------------------------------- 6 --------------------------------------------- 7 --------------------------------------------- 8 --------------------------------------------- 9 --------------------------------------------- 10 -------------------------------------------- 11-------------------------------------------- 12-------------------------------------------- 13 ------------------------------------------- 14 ------------------------------------------- 15--------------------------------------------• Date __ 1_V.J.5~L 1z<; LLJ_ ------- ¥25/JI L ·j_; s _( _!k,-__ _ • Street Address & Zip Email --~~-:?_-:z ____ ~(?-~~f:.~(:2,l~-----~-~.::= _____ _ __ :!.f?_~--~~':i-~~------~~---------- " __ f2~-~E-fj.-~l -~ __ c__/_£ ____ _ ---~_t;;?, ___ ~'=:!:.-"::_!..Jt:_t:.J::.. _____ ~!:-~------------ • f ,., G , .... --... /) Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community fhis petition is not about stopping drilling, it is asking for drilling to be done responsibly. fhe following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside th~ Jeriphery of Battlement Mesa; thereby preserving our beautiful community. Signature Date Street Address & Zip Email AP.~~A1_4.!:~:-~~-----IL :;L-J.Y ___ 5..Y-.. __ )..L_~A~f-________ ~-J~i~nslg.fiJ fp--0.~f . v -u ,,,.__, ~, ,, -c_/---~-':Ld/. ... _Ji;J..t.~----_l~~J _:_l~ _"2~ __ 1'.j_.£.~:t ---~-~----~-~--------------______ -:::::. _____________ _ Name (printed) l __ 'l?.. _J?kL ~ __ .,)_~kla.kl..S:.k .1 ------ 1 • -J ? _.;:::.J:£>_':J_~-----~~!'.':.~-9-~--------------- ~ --~L J.~:b+---~fo.LK.e..r:: ____________ _ -~k.L _L0.~-~ . .cL __ t2..:sr.:J.:i _!z __ w~.t-~i~iJ-? ___ cr ___ s_c~-?~2-----_____________________ _ ' •\ l , J I ' ) " rl ·/J,, -'J b s ---··..\..!J..-':i...,.~~------L~.-::.~-~J L£ _____ .J.1...1..~--+~-~------~-L ---~---------------------------- -~~~~ ~~""'----~~--:::: _______ ~:.:---~-:_ ___________ !:'._______ ---------------------- _, __ :~_(ML Lj/-f/l¥' _____ J._3 __ ~-~d.::, __ ~,S ----------------- , (\. . i !"") ; . ., 17 . ~ 7 __ (o..~-~-t1..Y\e...~~'{~~~'!.:----~W..1 .. ~~~S2n~\-.i~\ .!~}_~~L!::\ ---~~-~-~-?..~.!~~---~-~-----------------------------------~ ----~~---~-~~--------------------~f?._f:j ___ ~'::!,~_C:.:-.:fi:.~~---~~=-~~:£~ -----~{_.::::, __ ~.::!--~-~~~-~--------------------------- ~ f.J.fl _fl=_!-:;_f;. ___ s.__c]..r.:J.._D_f::R:J. ______ _ ; ___ &~~-£_--~~----------- 5 _Q}_~tL __ {).Le__e _______ _ ~ _f}_f _(:t_~,_i!_ ___ .£.1.-::_!J.· __ fJ __ f~----------f ~----i::h_~.ie:__ _!)._)$/!. ::/. ____ [Q ____ !:!}__j~f _t?/_£:.td. ___ CJ:-r-~L(~_(__ -----~-----------------[]~ ,., ~) • I'"\ // 7 --. . ~ ,,. (.., ,") . . ,..., I • to_ iLlG~~----------~ . ----:{ff~-if f ~~ ~l~f ~-;f f~,__ci ___ ,__________ -------------------11~~------------------~------~----~-----------,,,-~-----------,-----------------------~s.: ___ ~,------------------------------- 12 J1Ul.&l __ f._ __ jlJ _ _Lf::}:~-~----__ Yl~~(lL~-1-----iafl./_lf ___ LP-f_~J: ___ (}f;_______________ -------------------- 13 -;5_(nJc.£_M_~_crrL 1_____ ~M_11L:~---i'-='i:i_" 1 __ 1 __ 1 __ n_~4~_e-L _____ ~---------_____________________ _ 14 --~ilfafj-1'------:b~-n.-~e-e--l2 -'~-~ \L\ _____ s::r: __ ~_L hL~-~------____________________ _ 15---fAfLL~_LA_ ___ I_ ___ ~Q_i;l_~--__ {?~11-~-P _:LJj __ s_L_J{J__~ __ <;;±:_$Jhl~ ------------------ • • • Jc~ Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from out side the periphery of Battlement Mesa; thereb y preserving our beautiful community. Name (printed) Signature Date Street Address & Zip Email w»1\\G\.~ J" d e\,J\•l~("\'l C'\,J.._....) Jt(\J,~'> 1cbo\·~>l'L/ \\ R\\)~~ V1E~J ~lc\tE ~J1 <1(-\C'~Ci~@V·i~·i-.. to'1, 1 --:~~-~~~--~----~--~;-----,----~ ~-~-~--~~-~--~-------~,-;---,-;-~~--i~---------~-----~-~--~:::-----------~~------------~------------------ 2 ~-----"i -~-~----:~ ~~:~::.<~----~ -~~ -'~---\ ___ l ----~-~---------~------~~---~-~-(~ --------------------:-- 3 G:&~~L.,,,J.tL.Jc"-"'-~~±k~-fr:~.!'.':L'T-'-~1_~/7 __ filklLLf"!:'-_(K _c&u.l: _______________ f: '-"~:!!_L~J::1~1 !.'.LC;_ .,_ 4 :_~/:J,j~--~~~'-~-~~_j,f_______ ~-~~~--~~<'!_'f'._~~----~-~~~--~~-~~------------------------------ 5 ____ :2E1£Q~ __ :LEME_Lfi._______ --~~~ __ (.°-(.~'.'f { ____ ±_! ___ S_.2-~----~-=------------------------- 6 __ J32&E£:-.Z-k'..-4£&Ci:.~.ti/ /-~~~ _.!~~j4-_ ______ t:_(2 _____ £{/f_ld./2t!/__~_g;____ ----------------------- / . 81<:,3 7 -L~I~_f:_t(;.Q_ ___ -;[g_fit9_:: __ ~!:;2_____ _..<.::~~------I • .J._f~~----J 1T_l/L<t _LdL -~6.1. _.:u..~Q':.{f_.:...t~t _Zl~J_::::___ ----------------------- .-· f · . . 77--7 ;U . , . u.ilo -n -- 8 __ J~l i::Ji.._~.;;:_~--"~--:'?..t~----------~~--~------~--------~ _[~~~J_'.l -~~---~'fl4J'--~'''~J_::_ _____ ~---~~----------~------------------ " 4(_, J,~ clt A i _I(} " l a , t-CR.Ll<Lc Ca Ua,,. l'UJ!,,_j--LlJ_&./_c~! __ .k± ___ ~(.L,D._t<..D: ____ ]5_[_~~~------------------------- 10 -f ~/_i£Lh ~Kj~~~------~ u ----~;--~!t~!t~1:--:c H~~T-----------------------11-------------~ __ g_.tz~ ___ £._________ ~L% -----------------_:/J4__lf__ ------~1~M~1!!£_J _C1reL _Lt:~_L _____ ---------------------- 12 "'ll~~ _iJ;!tj __________ c _____________ !ffe;Jf --~L~-~/l__i#./-_ffi~?;;__d!P.Aic~ 13 ----, ----11 --~--~r=----~~--,------LVf f 1 j_1_~~L__________ JJ:r~fi}JJ~ 14 f11~.\U!Jn.LQ&Lt.li.\.~-,~~'-"-'-: : _ _ !2td.,_ PA~f __ Jj_'LQ!I,iti£1J~~.'.J __ ~_fy-j ______ OJ,';!t0~!!l!~!~j~f e ~~~ 15----J\~\-~'--~-~:_~~'.:\-----____ j~S{ ___________ -__ \:i:\\_\ l\ __ ~_11:: __ ~~'.-_~--~~-~~~------~-~-~~-~~~~-::\~-~ ' • • • .. Cf) Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners t o deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) ~·gnature Date Street Address & Zip Email • c_ ------. ' i _fllqr_~--~L~t--~,-~~~-------_____ ~------------------.!..~_;:~_!/: _!!e:.._s..'.:~~~--~~-~--~-----------------.1o_~~::0_~'-'~~-~~-~ --:.;,_, 2 __ fJA c_Q_i.. ___ 6!..fuf_,;,.z:i.________ {!_¥ezd-_4-fL___ ¥"'-~!' _____ 4 __ 1l.121e/:.:ce.. __ C,_c.,______________ ~-f-c,:z~:e~~i!:\r,_s:0""7 3 ---~~---fu-~2!}_______________ ~-~-------~f(p_/_!j___ _ __ <j_~0 ___ f?EiMJJS9~ ___ C:_ir:____________ ---------------------- 4 ~~---J:l~_a _____________ ~L ._ 5 ---~~!]_-~_[!]_):;_______________ -~---~ , L c.---,.., , , 6 --L .... .r.l.._..: -----.~--Z..;!...;}.~s::_~~:J'?:~--------- 7 ___ f= __ : __ E_Q _B_Z}_1_.f±d_ _____ _ '--1:7,~~~ ------------------------~----------- _J J_)~Jl :t._ --'---~i[JP.,,.. __ ~o..(l.g,_ _______ ::t>_L _~~~--------------------------- _i !_[l€#-~ ---~~---~~~~~----'?::._L~_:;.,_~---------------------- · 11, I "' _.-. f ) _ / -r -Q ·. ..-----t-l ~!J.:? ___ ":J_L , --j--;~4..Qf...LcJSJ.::1: .... .?_L~..>-) ----------------------- ____ !_=-~(b -----~3_"] __ 7-t?!:!..lr!~?.f:ff __ ~:~~-:..r::.1:::.._ ----------------------- . -\-('. . . s _c_~~-~-:~::..~--~~---tg~(_l~-~=--:. ____ _ ' ,., --r-11l1L~--_J ~LE.5J_~~:.~~J1-_!~L_____________________ _ _____________________ _ 9 ~1 L~e. ____ u-1 ~t1o _____________ _ ~~!t.:..l-1~ ~-~~:l __ tf._L ~~~,;:_~_:::;i:~--(_~~-:;:"-~~--------------------------------- 1 o __ '0_~~~-~B:_ __ (ic_:._~-~~tt!~L§_~-- [ l 111./ ({. .j o t-: 1-1 NE 0 11------------------------------------!~---- ~~-~--f -~----~-~Y-'-~~~ --~I _Q:::~ __ k_o_~J_t _____________________ _ ----~Q_(2:~----__ 0_£/-!_r --~~---~~----~-~t-_t ______________________ _ 12--b..A _~t:Lb_f;. _____ £.tJ:.LL..1..1._w ______ _ 13 --~~e::l..L-2~-~~~t:.-~-d:!::::-.f.: ________ _ 14 _·J.1-g,,Y-.b_S:u:_~l__m_~.;.~J-~1;}_ 15 ___ ffi:-ft?..Lt.LB __ J~---Ku~- !/.7£/;_{.._ tJJ ___ ~---~~---.IL~..l..~---A //'~ {7 . -___... _ ____ A _-,14_a.~k '4 ----1-Ji11:1.JJ _____ 2.!~ __ G.._Ld..~!1-..LU:,L ___ <Z..s._ -J~'!~~~.· ~--~f).s---~(2 CJ._l1.k::p.Ja. __ !,;;,gf--------<f...!.9..~ v~~~-4 ;._§}15. __ f.J_JJ,_~£1.y--~-l:_ ______________ _ • • • µ4 Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the p eriphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) Date Street Address & Zip Email 1 ------~-k'_f.'. ____ LL1J.d._au_f.'.v.:::___ __t?;v_V!_ __ ~~-----_____ _112/!..lf..l~ 1 ___ .f,tt~4f-~-~t-l~_&.:_________________ JY..f.."f.:t.._~~J1!_~ 2 --~{~~--!:!_~::~~_:{___ ---------------~ ----____ --~0'? ___ 2_E__~-::_~:5_-~f---!!..~~?£ ~-~~?P~ 3 ---"=~~J:~~~---5-~--->Mi --------------~=t:_g_-.!_$IJ_LJ /!f.. ________ 1f_J-____ f:_p_ __ <:_~r__-~ __ "'): I t_~~-==~~~~ 4 :.~~-a.:x ___ n _~J:-~ __ QQ'i?--------------~-"\&\--~~~@~----l OlI2LL~ -1 L~ ___ 1-Ylu~L~1:~~-5E'-11 10JJL .2 ___ ~1 ~ -~1~1J 2L~s)oD ___ _ \ \ ~ U" C.OM<:.. A .>J-:. /\) t )- 5 _!.<:!L:!..~_c:._~~--.!"..!:.:r:..!_:~_'..!..-2_(!!z ___________ _ 'b/i/ ~-4.//-..-' 0 -2.7-i· l_f.]';,_~~~-~:::::._!q:.::::::::::c:. __ ::::!?:~'?:!.'f:j;~~-C;.-"'!::.J:f!.t:;::'( ------------------------a -:=? ~ ~ 6 .!-~~--~~~----------. -~--£·_b10 __ 4~~0fQ;;.,~.[L _ 7 f'ij!_d ___ t;;;L._ _____ _ {Q :_;;[t__ cY~~~--!~~~K~C! __ C[:-}5 __ ~~-~~~~~~~~~-l~_6 f-1Q ¥;JJ iY-~ __ c 01·, 1 /r"""<·h "' ~ J.2/t.;_t_~t!:.:.f;.-:::.C!:-.. _~.f.:..-------£~--::~~1-~-~--- s b.A~lldW~£. __ !lf.. __ cf.tRx~-----­ ~;stu dL tJJr1 /-<-r 9 --------------------------------------------- 5?:1../if£~~£1j~.f:.4 ___ ~/_~.f5. _______ L::_ljf_~~-l'..~~~s=6,,~ J ~ ' I);; ----~~--~~.1_-::,_t;J;.~---~~~-~-~------------------------ 10 ~-i.::1~d--'-~-1..~_q1_~y_ _________ ~~ . . . I /) · . . '~"'ct.'.\'-<..'k.. 11 _!?._t_~":"::_d __ fL~s.L.~-~---------/!..~L~ _1__~!..~L! Lf __ !_'l_&,._lL~-~--c;c -~~Ls_s..~t.:.t.:.._~_l p_~_.1 _J:;t-~u~_<..k.L.i:iQ._~" c..c ""' c 'f'C--'~<Jk B<i3.q -~ :~ ~~tj l t:>kcf1 fJ. 'TI Y<; 'I -z...1 \l1' a<:.~ ~,Dr <:_:..._t'C.,. 15' I (e 36"' b -<:..---1-;s 1-<e~") @r'-'5 .-.,.,VI"\'\ _______ i;:_r~----;--------~--------------------1 -----------------------------------------~------------------------------- L ~-!L_~---------LEJif:t2l!.H ___ 'f;,J___:f}2 t_Ufar:?2?.E..,_C Y.::______ _42QS:_l l@1.1.9 l1i'J (0> (/, ' . . . ~d/~ ( /!,µ~f~A £_ -~~~~~;~~j ~~z~Z;~i{g=~~~ ~~=~~~=~~~~/ 12--I=~~-i~~~~-~~~:~L 13 --:::,::::.:; _______________ L ________________ _ 14 __ t..L_/:Y:Jf:)_ ___ b ____ t/_~!![_ ___ _ 15- __ ._Jj __ E:!__jjp__~L«-£_t(L _&~z..:2 ---------------------- • • • ~4 Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside th~ periphery of Battlement Mesa; thereby preserving our beautiful community. ~ature /? B-ate Street Address & Zip . /t~~ d (-/~ 111.:rµt11f cf<FJ f3~Y</~f~t?12f ~'g/fR3~ ---------__________ ;(.,______________ --------------------------------------------------------------------------------------- Name (printed) 1 _!::.!~~---~~--~'!_Q~-~---------- Email 2 ~--~-~Q~-~-__ 7 r:. _________________________ d@~-~ __ [j _~--u~_et~~--'.Q1@_______ _ _____________________ _ 3 _f2chD ___ ~Jki:nf--~-~.0________ 1Wf-1_J~-----19J1;)2£!_'1 i~_fl.lf.¥Jl!'.c,JAJ:{_fi~q_~f':!:f:: ____ '?!!!.!..;? r.::~~'..1..::!5:.~:~!'.~'~co.c,;11 4 -~~~-------------~\;,~~------!~:l_'?_,'li)/~ ___ J_~_!~~-~"~'------~J.J;'.)'.['._ ---------------------- 5 --~.Y-'!Si:2 __ ~~L__________ ----~J:l_ __ ----!:?_::~~~I~ ____ i,}f,__{~~_±.f_h_';'_~_!'±_~~--~~) k 1?~-~-Q.h~±~.:! I.(; 3) 6 ___ ,,'./JJj__e;_(!_'-___ _J[Oj_ffg;Jl;r ~ -----/~ ~!.!_Jo_tj_ __ f;_Jt.e.l&JP.£1{9-?_tft!!; _________ '!:: _ZL_0~;L ____ _ 7 __ J ~1J)_ _____ i;_ __ 8_~4~f (___________ ___g?±:: __ ~---~---{~:!1::1:1 -~~_[}!:}!j~J_~-~~-1%_8_6f:fj_~@±)ku <?_ ______ r;_~ff_~f?rf 8 ____ k.fi..AJ~ .. £~ ___ J.Jd:L..~£_tf:: _____ _ 9 ------~~~-----~{j_f.J._L~_.b:_~::/ __________ _ ~ I ,. w 1 o ____ Q _ctl'f----~---q_a!l_¥-,---------- 11 ~~--4Jf L~f ---- 12-_____ JJcQL _________ ~-~~--l ------ 13 __ [J_filLti!;JJ_E~~ff_[_ __ _ 14 ---J-t -~--~· 1s-----~12.1.7_a_l~--~!~-~-t..2:.£21_/" ____ _ --~<!_-~-f.f_~!S· ---~--tLc..1~1:"'-~'"".c.-,., ____ -@_k_3 _2 0 C3fb?<; J_r} __ :L~_-__1 '-f ____ ~J.._2 ____ eQ..f)_J _e...r_Q.;i..f.i ___ c. __ ~_c_J_~---G'. ,,,..~,, ;( 3 Cl of. c. (... ,Y} ___ ._:t_'/_J_f _f..£_}_~------¥-1_1_3_£______ ---------------------- .1~/J:tk::/ ---~~~-~-~.~~Jf ~~=-~}:::_?:_'(_~,..,. ·C#>• !_<2/.d ~ -~e~ ___________ ! _ _c~~r:~~f-~~ 4 _Ll!J/;.bi ___ {H_l_-l ______ .6-_§!f L1!.~-~f:-~_~f_____ _JL~}_[_ _______ _ _J~--~ _J_:/_~L-·if:Y ____ 5__[_ __ ~':!~ __ !__:~-~--~-1=-~-:~-~-C !.f-:___ _J__!_~-~::-~------- _tr/2(/!..~'(z(~(Zt:f.;zt_______ 1.!!i!t!'!..c1 ____ J_</_!.._l_1.'aJl:0:2~~1: ___ c ~~cL.._ __ !_'(jJ} ---------------------- I • • • J.f • e e Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community . · -..!.· • This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa ; thereby preserv ing our beautiful community. Name (printed) Date Street Address & Zip Email 1 -4tn.J.g,,~e.x1.de.c-Jq_J _ /. ___ ~--: ____ /_4-:J.:.!i _2,.2_?,j<_c_,_._JJ&c._£._~_!lt;..]if f { t1f-ceJ:.lJ_qf5£.1J1 057'_,," 2 __ !?~~~---&~~~------------------- ------------------~-q(_7_(Ly ---~--~tl..t::t~~-Q({~f-~-----.5_c(_'!9f_~~-!f~_'l{-:7P·A61 3 _ _t:bnj-1Jhy gc:c-4------~~~~t&___ LOJL5j.i1 1RMj_~~b'Sr-r:u~~~-~f, ____________ _1 , tt~!j-l'm/~~cm~0 ef,;-1- 4 S!<._b_L _li i_JJ______________________ ---~'. __ Jf1J!__________ I Q_j _?..::L '/ L~-~-/__~1:_~_f..!..<5.LSp:1 t1f-~-(~'.t d.f. J_!':!:jj~'fl_{j_J..i -e , co hi 5 __ l{Q..<..J-1.1-'.\_-£.H~':\----------,----*7f J..-~!_(_-1'k.':fr ------I:::_~:~'!_ y_z__~;_'!_~_!?f_~o..!!!lf-_ __ r._<}EJ---i(j~ MH'!.!:.f-JJ _q_-;:_~q j/1' 7 6 __ B£~_6-P._~'ll2d_ _ _ _!~-~--L?_f ~f' _L :Z_]__j~_0o:~ ___ c;5:: __ ~-------~~S'::~~f° D. ___-,--. \ ~. . \t'-~\~ } 0 \' p ~~ G LIM 7 --. _.\.\l-_'>fl..:U."----~-&~-\(:,_~_\!1 --'-'\'~-:i..:.l"'-~ 1-lf t/.L!t _[,,_o __ ~'J'--"-&WK...--t-----------------___ 1Jfl ______________ _ s ___ r:~~~J~-----:--------~~ --;p:f-J ---:/f :_----~~l!;;r;9 ;~4:::~~~-1-:::-----------d-~----=--;----~ a_o • 9 -~-~------:t::?..~--~.il!l-.J::t.c::.r:;=----------------------------------------~-~------------~------------~---------------------_____ l:! ____ fJ_ ___ 'f:.~~--( 1 o _D __ _f-).4J _£,:c~---------:-----------~~---19-}~:1.{ ti -~-~--!'1~f-'-~-h _________________________ l\"d-i>..t_;;;_d:::iau~~» tel" 11--.d__+-~~-ild::! __ (l;_Q _'iS-f-:£ ___ J_j/.J; ~:ti/!__'/ Ji 1_l_-1EjL!A:__________________________ ----------------------. 12---0 '-_f!__f!:._'j_ ___ f!__,_ft_!__~-~ _72f:::<:c ::z:l: __ '/!:::_~f ___ 1 __ ~:~~1! ( _____ ~_:_ _____ L!_"'J-_'!:2::::________________ ---------------------- 13-::\:)-~~1-~l~~--~:i.~~)::i _______ ~~~------------~-/;;i~j Jl; ___ ".§;.::'.! ___ ~~~<:)_________________________ ----------------------- 14 ___ J__~<.2 _l1:J _____ lt1J.~s_t_______ __ _______ c_M:l?Ldl}________ IP/21/l Y ____ ::2.2:. .. J3_tJ.i!kn1.eJ.z/.cj::._______________ ----------------------- 1 s-~li-'-------~~-St ______ ~-~~st !9)2k::L~ ______________ :_~-----~-~-----------------------____________________ _ • • • 72:J Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The follow ing signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) Date Street Address & Zip Email K~'.:'lEi ___ T!}-x§_~'::_~--------~-----------------~---~~~~---~~--------:---------~------------- 3 J'_~ ___ t;_! __ C: __ ~-~~~(_~----6-..G_L~------------!__{!_!:fk_-I Y__/_b __ -;_ ___ {Y-~,_-~j_~~-~-!_<(_ __ !!_ 63 : ____________________ _ ___ c:__~~-:3 t>/ ~------:L_'i_!::::-_t,_~_:__q__'-!:-__ 5;_1.J3_t:_j:J;_ __ £!..J:.. __ 0.k. J ;: _____________________ _ 10 ~-11 t -.;01?< I w Y< l ~ .,-e t\ <t \ Cr: 1J S- ----------------------------------~---------------------------------------------------- ;J!q_/}:_d_~.-Cd!Ld._J:.~ic-.~ ~~4&!_~ .!:f::ff._:(• _,£_,2;;?_ __ 02~~J1Jr.._Q4_.,_ ---------------------(-'' . \~ ' 1 ~ J'l/.3J s ---~_J3 __ ~-~EL _____ t=J--~-~!:.._L_Y-J. ~~t:~-~-~-------:_______ _1_q_~1-~ ( ,_ __ 1..i_Y.._JJ..:z..!.~t~'::.=-~'--~-c~-:~--~-~:..:.~1.. 1~~~~~~~-~-tj_~?..~! 1, Cd~ L ,//~ J<it-3 .. r ~P-k'" · to-,;...<-r4 1c:Xf 1Z t ~l'.C~ C4-t--£ (-b'M__ ------~~ --------------------------------------..,--~--------------------------------------------------------- 7 _c_JA/J!.L'f-___ $._!o,_9_c;_"2d..______ _lfl~~--!_q_:<d'fd _ f _d.iL"J.._(ic:g_[ef.eJ:.fi!i<J..f_IJ:!.. __ f:.!..?_}5_ _____________________ _ 8-12;~~~-~~;-R--rt~~~~--------ett:: l~~~~-~-9--~~--~~-?;~5:,;-~-~;~--~~~ 9 -----------------------------------------------------------------------------------.-------~-------Zf------------------L _____ :;____ -~ 10 //f::~~~~=~---------~---i;&;:;-~;~~~:;~;;-:t:[Y::-~~~.,.~~ 11---------------------------------------------.----,-------u -1,-------__ -f.:)__ --------~-----------------------L_____ _ ____________________ _ ~b.~--P~L1~ _Lu_ ____ ?:__ -~(}d__~J;l---01!-c~-------1 r!fi1f!L 4 (!?f!:.i._(_k£'.f d'._Dl.!.!...5:.!Jc..3? __ --J., ff!-~~olE!:tLSf-'JJ"' I ,,,J 1 "''' \1 fa p. 1< ~ /\J · 7--j < ~ 13 ----'==--+-1d1Z-______ ---'..{}..-xi..~ -----~i.f---____ 'fJ.._~..C::::-__ J_~j_~Ll <i ___ L_-:;_;;: ____ ~_:. __ Ji!...Ld:f~-~-C--~~b C ___________________ _ 14 _Jy_~i!.c.E:_i:J--1J_q __ i3.f:_e_!:! ___ (!)__7,_?:!..~ --~!/..!)Le! ___ nx __ $.J.. __ ,gL~"i:'fc ___ r.;,f.._c5f..!!::.:<.( ____________________ _ 15 ___ E_1_~~-f: __ q_~_~if1 __ (t] ____ o_~-~1-r,-~~----JJ_P.:~~ _1!J.i_~_cf ___ :£'l= __ flt-.r--:r ____ :-_r_ _____ f!..~i!:_!_-5--=-------------------- • • • ~-{}- Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. T he fo llow ing signed r esidents are a sking Garfield County Commis sioners to deny the Special U se Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) Signature Date Street Address & Zip Email -rJ., <.) m , 'f ~ 1 <> V\ e ,, v ') 1 --------------------------------------------- ::1 .-~JJ~ :~-=-~~-=! 1----~-~-!::'..C_~:_:.__~_: _______ ~-~-~-:_?~----------t < _:_~-:~-~:_~-~-2._1 ___ c., .... 2 __ ('6_¥-_£._9..c_~ __ L{~-~iz -~J __________ __£~~--~-~~~ _l_{'-rf.!2 !.!.:-: _J_] __ f!J)_:._IP..:E:~f.1..,_,_6 __ (r;,1_._J._te-._&.!__,J.2 c:lu.r.1~_<::.!~~LL.v·:... <, .t{ J3:; 1/J , ~ ~ /~)l?- 3 :J£e _f:5..x::i.. _______ ~_2'J._Yl:s:._f_f.: ~--L2~4..t??!:..?:} 'f.. ____ "1.s_J!:::,_-(_3=="-"=~-~'---r..:----------------------- 4 __ !_~b._L~1~ __ ffag_~d£_ __£~L _f:::~_(._~~-r----~s:_/0L_~-----!::~z£:___ _ ___________________ __ T . n &~s s -'!-5-J1A ____ 2-lA __ iJ5-______ _y~--~--{:t:!J-'t ___ $__~-~--~-g~~ --:------------------- 6 __ J__ea__a __ bJ.A~bari ___ 9;~-~--££i[r;/ __ l_g __ ~~~~-~~~n~<f,eom 1 _£k~[_ __ Q _~-~0~~----~~-~ __ !..c:./..~-~Lt '-< ____ !__f.._£.i:!..c{/_t_:..c.::_?..'!_~--:. __ ~y:.J-1_/?..~~--___ r.t~_c.:.:-_c:-_~~~-'=-~'t.,c.0 '"'- t..-'7· . [/ { ?.>-_(i:d'_,f"LL_f'~AL .. 'f4.1:J ./-_.C:.o/..:Z-z... __ L?LL._~./.LV.R'.Lf.4_4.__P'.,EL/..A--k...5'..--<;:..L'.. ~~~--,£9 e;.. ~-i~_':J___ /Lc2_01_/!g_!J:)_Q_{~(]_f_ __ /yz_LL~~~~ F -----------------------. L I (_ 7' rt 3 .I/ . J.oj..~1::.___ __/j__~ __ (b_~~b.(f:!!::: _____ tt_~-------------~~.1:_.2.l_Xf2L _9-~~~ ·' 1 {;j :cLO<iJ:J=Qa.e_\.:i _k.~ P¥=<l.e,,S:dc...J.6Lo":J_'.::/:.2o . 12--5..J:.!::-_{_t;_ __ K!::i _,,,_tl_________ '6-:d..~-------!_q/~_6__ /__{.2_)1.~.J.i---{e_~J:..-12'-'---~(-Q~ ji:.':'J::.f-'-t"-'-i:;i _ 1 .c·"' 13 ---~Slildtl ___ :K.D_~f b __ ~AY!l01 __ ffn~~----Lf?L~~---t;__5-~_i!fM-€~ __ (t!i_~_n_!!_{}_r -------------"-------- 14 ~~~~~-:~J~:t~---~1-":\:f:f L----f----1-~l~---~0-~;:~~J_L~F ~j~~~~t~~~ 15 ~----~~---------------------------------------------------------~ ~-------------------------------------------~-L------__________ j_ _________ _ 5<:;??, 1'1 LJ-~1..V (> ~ -e.. \L ~·-. q \ lt ~clo.c..'n. \ ~hl\~@<jYXl..., I• ---------------------------------------------------------------~--------(...ol,, • • e t:1i Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. T h e follo w ing signed r e sidents are as kin g Garfield County Commissioners to deny the Special Use Permit and direct U rsa to drill from outside the p eriphery of Battlement Mesa; thereby preserving our beautiful community . Name (printed) Signature Date Street Address & Zip Email 1 ___ ,J_Q_~Ehi.L .\£~~30----------t~-:r:---~--) Q}_Q:_~Q I (_~)-~~~-Q9:i:__(;[)tg_/j _____ ~J~~~---;rl!9-'.'f--=-~ff9 W\ 2 _f._~"[ ___ Jl~,,_ltJ.J'}._f;_&__________ _ __ J_f_~LJ1._J~ ___ tPj.1.tJj1J/_ ___ _£..{:t_~J.J:::_S:L~~------------------------ 3 J..am&a __ L_Sif21f:.._______________ ~-L_Jat______ LCJjLo/_d d.fe. __ ?1f.Ja __ ~j_p.fJb.L ___ 8}_(f;J.s.: ---------------------- 4 _ ... l£f.f-___ B_(?..eQ~-------------------_j - ---------_(Q_jl:l~--__ 1fi:.:tY..\f~iL2i\Sr..i:\. __ £.;...: _______ ~!k3s:-___ ---------------------- 5 ---~-Eff.:_i:r\Sl ___ l'.!2_~~~--------_ _ ---. _ ------_ -J_Q_:l!!.'! --~-?:::_-~_t_q_i;._1-~L~--------~_[{??._~ ~Sr;..t;:.'f.@~ ~ 6 __ _/l!i\!,)_\[.j ___ ~-~~_!I];:_~-----------------~~~--~,~~--_!'!...:!!.:_!~ __ !i_-:: __ ':'..~_!!'.!..~-~'----------~t:':.-~~-------------------------- 7 -----~~-~_';'. __ [~~~-~-~-f!:_____________ ----~-~-----.!_q_:!1-:.!.':f --~~~-~ _____ /f#j_f:.~~------------------------ 8 --~'u-~---1~~---~d~eR JfL __ !1w_~1_12_:-J.1::t_y _2 _Ae~.l.'.l -~~-~LL_QK, __ ~1ili;-----------~--------. 9 __ /YJa_c__~e_"'{J_-:f_q11e_._ __ fS_1'k t il./l ___ ----------· __ La~1.1..7 f_ ____ '/.6 _____ dt.__£4..c._ __ G{_j11,z J-~-1-~cc_l!..~f e {j c.o11i 10 'ffi.)jqf_~ ____ r?.£:.u_~_0_-:i 1ti,~-----~--F2#1------cg_;, ___ flLc/._Y:: __ <;±_E_c,_3s: ____ ~-----. 1 l-~~~~--If~----Gtl~----1~---~f?!J3) I r-____ 3__9_ __ J3-tl~$_f{f__(_9_;1g __ c;t~-~!~ 35-___________________ _ -1 ~ Cl f .1. 12 ..£--'ifd.MtL:-L"1 ~:--:i~-----. 732!-!!'._~_'!:_ __ _(J_(]j_ff!: //)f $/f ;/_ ___ d,1') ___ it!_i_/j;_!:i!_ ___ {£]2:tJ,f, !,5-________________ _ 13 _:,.e.:;-«'!if-L_d.::'~-~~~~ ~j4hL_j_Z!__~_4 __ f'l'3S---------------- 14 -~!~:_":'._f_ __ l!_~:!:!_!{~-~ __________ -:_'fP:_~--_'.!__:!~:!! ___ ?!_!____02!.!_<±~~-<E!:-~_f!::__ 'j !l2f ______________ _ 1s-~-r!_:!!'!_Y ___ <iEEE~!:.._'!__ ---fl-bt------------------_'._~J!.:!'/ ___ !__'.7_ ____ ~_S:._!:::::_ !!~2-~-------• • • f';f Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly . T h e fo llowing sign ed r esid ents are a sking Garfield County C ommissioners t o deny the Specia l Use P ermit and dire ct U r s a to drill from outside the periphery of Battl em en t M esa; thereby p r eserv ing our b eau ti ful c o mmunity. 1 y ame (print ~d ~ (; f\ d I l 'V'\ rt O f\;\ I 'cJl 1 -----~r -------------------------------------- ., 5;_~~-~~-S-------- 3 -______ !_~-~----{~~.!:'_ ___________ _ 4 --~-+-~-6_~-----~-&.~--------- 5 __ b _1n4~_b __ ~s~-~~------ 6 --.r--~lr~C_t~---1~~1LlL(_~_C~..;? _______ _ 7 _,_Ja _(l{tft\!21~l --~-l2.~2 __ _ v otA-v ( ciL Y1f1_ovy t/0 > 8 -------------------------------------:------- 9 ~~-~-~- _) oh .n ~ £Ac 1...( 4 iZ r <l..S 10 -------------------------------------------- /~(( ~ '"-{ //-c-/_ "-f ( •' - 11-------------------------------------------- 1,. ,,., ) J //.~ ~!Q 15 ~. ' -#--C L/_ / { ~ G°L L 12-------------------------------------------- ::._,/ 0 -~ L/ -' ·"-o._· -e (' 13 _____ (2,6j ___ -1 ----~----------------------- . / Signatur,,e . J Date Street Address & Zi ~ ----~-;-----------------------------/ '!}6/?.11/ ____ 2f_?:::_ __ ~~~-{l-:__i__~:~:_:~-~~-----'-!..t-i[_ ____ ,,~\:-__ _ __!..J:/llY-1~-S,-~r --__ /j_]___~!lff:c!if__lli_~ __ lJ -~-------~~---f-o__t(f.__ 2 _[5-_ __ f___I~1c~_9:f _~I~---, ~ -------;~--~--------------------l_~~~!t_~_j_~ ___ ;;}:_~-~-~--~-""'~/;;---~-------~~-!.-~ !Q_Ll§_f!_f ---~~--~~~-04--1?~~£__§_~-~~~- Email ~~!-~~LL:!_ _{£1f _?__f?_0?.]J~1i..11r _G.LL k _~c ______ _ 111.L __ fr~~!-~L ~~ _0J1t2 __ f2~1b.c1'.~~~~--Q1 __ ~~------- I' ~• ~~ 1~( 1'1{1'--( f:,-G s LJ(zP.._.-( L'-c-.Jc ce._c: ( ---_________ J_____________________ ---------------------------------------------------------------- _-;[_~_rf__f:-_ __ &J_<;_fi/)_l?!_(J ~-1_u}!_5f//:_ __ <f_f: ___ !l_C!_lj_~--~--i}g~------------ -6~MQ;&-_~~ '-'=-!~_;i{~ ___ 'Z3._{~-~~-!:: __ ~J:::_ __ : __ _ r u, ~ ./ -------~=-~-:::_:: ___ =::-_~-~~~-~ ~ -~--::=-!::0<-/.. _____ ~i:t ___ ~~-~-::_:~:.~-~--_:_!_~~~------- l c lr-/,.1 cf-(( /t.~,rf>"' Ci.IL 'ii.... ,, l , h-~·- ----------~-"-~ - ___ LL!~s/_q71_l2_Y-J-;f_ __ .!_~~~~-f!f?::::l_j_f_"::j!Jfi:'J.._5_~L ~----.;:_-~_{_______ ----------------------- 14 _(._C.LLl..1..7 _/!..~u_-=. __ Z:L!_!?__!f ~ __ _ 15 ,,,Q-k+-~d_q __ ,Q _, ::_1!.*-__ f _Z~2 ___ 6:_-;_lf-f~_@_d:_ __ Li__(__ ______________________ _ __:!kf P-1 ____ f&_/_ __ /2_0!!_-4.:t_ __ _ • I • • C o >IA... I J:) t{ Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) Signature Date Street Address & Zip Email 1 --~I221~1.c.:[ ___ ~_r:.~-~--------------Q_ rL{1_/;.i ______ /_~j_.6_[_~~7:. __ {[~~i)_r.__!_!_t;_~!_ __ &->:~_'/_:!_~-~-;( C)"- 2 _&~-~--GC?.tt¥-------------------__ _)~_ A-.YL/'~ 3 h:__c.:.1!/JBl? _ _{'(_'.._{£E._!..(!:.!..~---------- 5A 1vP If AC. Cerrr=!l , 4 ----------------------------------------------( . s _J_~-~~--b-_s._~-11.._i.co_s __ t:._ __ _ f(d :_/_~_i:I ___ .1..~(,._t!.f ect_&. __ Ci:_~ __ ))..lf.._'[_~~-?_C._ @A14d..~_@_42~_c.om · '6 r ~ )S IJ ---· 1J0._f.._ _'-.'1.._£EAt..£~!::.. __ 0..0ff!.._Jl·!..~:f..____ !l.!_cf..'!..'I~~-~~~!;; ~J.~?5' -~{Jl?/..t_{ --~!__.,JJ.~cJ_fl_~_t:!;~ __ (}_(!_~{{!{ __ /l!S!J!~--g~_t!..c::'!~?E~c!..{;}[j..~; f ,<c J CJi:ZLLY _s:~ ___ Q,,_s.Lc __ et __ fL _;~~~~-~----~ s-~~12.Lc.Q .~Ll.i?_~ ,:o ! 6 --~\!-~~--J~~---'==~.Y.!-~;.:: ______________ _ _ _ _l?f7L1!:!.. ___ 2_·1f. ___ f?:ff..l!:-~~L6-_:.e:l; ___ J_~:_'/.._____ 4l~!:?.t-~E.Y-B_ ____ _ <! tJ i'>'?c -vs.I -n e 1 J]zAJ _____ G.__5-J.Llfl _c_q)1E__ __jJ~...:1A:~ /{!_:J ::L/ _r1_ __ f.):t:-_L:::f __ f2_q;;_J( __ _t_~-----------T.t:."fk.D~f~. cc;~ s _f}_2J_tl ______ ()__b__Q_1t__<.._f:________ _ __ Q_~i.1 ____ ~--:f'..__ /£~-~:_:!..':i -~-~}: __ L7-@::..1.._C..1 __ f)_!J__________________ Q~L11_cj_g_1£~G~(Q; J c-o4 9 ~,.Z-9-'.'.2q.:::zL;_,,__q!{-q_.-::___ ~;:/&,z,~""'-&_-Z:-L't ~~-~---~-{;4---~'fA«L __ ----------------------- 1-Jf_1:;_']_,_/;_;;}Z_~_0!::.::./_2~ _ ---¥-e __ r&.,_g, ,=!_?.._:_ )-_~'/__--~~~-~':&1:..~,,~--·---------------- , If) ~h r . 1 ~~ __ l_Jn.u(C11lg£___________ ~a l!lb.nCG.au ue___ ~?_~-~~~~--~~-~a:t __ eL________________________ _ ____________________ _ 12-~~~~~-------------~~Jr -----~_:_I'.!~ _2'2'._?5-____ kC?~':\--~~-~-~~~~ lo_¥-:-fl1W~ co"'- ::~~~~d::~:~:~: ~~~=:: ~~~~~;:~~d~;~2~:zA::::: ~d;;~:~~ 15--~-"""~---~~ --~.Q.--~ .. -:!O:':Y-=J .Q _:!.'i: I ~--2--~ __ S:,,-,_Q.""'_\;,_~---~\:___ h -~~'.:'.'.:~X:Te_ t- (_ 0 VY\(._ o..>'". (\" • • • -,°J-Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community fhis petition is not about stopping drilling, it is asking for drilling to be done responsibly. fhe following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside th~ :>eriphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) :(CL--y{~c.e A • l<'o..y L --------------------------------------------- ? ..L~-~ __ q_b_~f-_____ ])__f!__Q( ____ _ J _!f:..tJd __ f1fJ_~A~ __ °>_ ___________ _ i ____ .1]1-t}~~~--./?21 __ /S_.:!.J-J!..':::~-------- 5 .L/~~~---l.i.)-~.2,..~-------------~--- J) 1 LI< 5/v/ 1Tl / 5 --------------------------------------------- /-1 EL£ /J ·)p11Tl/ 7 ---------------------------------------------~ ___ Q'2f._?.._c: __ -!:_ ___ 0.J_J_ _ _£_~_'1, _____ _ Signature Date C\_ ~ · a, KCY/ r -;.-t!;- _ .. _~------------f----------------- ' a __ ,., -·- ,,_/\___/_.7\J/ -I ./--I '.:I Stre~t Address & Zip /t><f r!.,,t>f«-lVl •L'""'"-t..a..,~ ~-~---~~~~----~~ Email ~ ~-------J__~;{jJ_-_2._;_s:._ __ ~_LJ./.!:!..&-~./.!kf:c:.:K--__ c_~/J..~.171 ---------------------- ---------~-& _1_:1;.L~ __ 22i _$.Lf-f-.&~U~_Qg. __ #_1_ ____ ~ ;e ll~-~-t~------- -~l .:.~~ ___ .s._~~-~-~,--~~~~------------------------------ C(/., I //__; ~5... ---------9~-F _?'/~L2_ _ ___ f:fi.._£ __ !:!.e:Jf!'..~¥-'--i!2~.;-____________ _ --~4 ----~E__t;_~_~/:2 _(.{_0_ __ _ ~ ______ f fi _f.ity_ __ ~1cL!i~----------------~--k _x~--------------__ ?/._~-------~-'!.._!d_~Z~!:!..~_Ylr:.._f_~~---~-u:· __ s_c~3.f:_ LO~-fr{[_0(: ___ r__f!!_~-~!:~~---------_lf~---~--glz_l'.£: 3 ~_((_~-~-Q1_ ___ Q~~i_~_:_ ~---------------- • ll---~~:--~!-~--7#~--1/l;;---~:-:---~~;~~~;~~»------------------L2------------------~----~----------------------------------------------------------------------------------------------------------------------------------------- '<J ~J e-~ ez. -~ · t 3~!i_st __ :2gf0._~zs.::s:____ ~-~ _q;:._ __ L ________ =q~~Z_?.i_~ ----------------------- L 4 ~-h .4.t.:.((L_m _~bin D-_~_?___ 13:.~1!J1..:0!..~ __ 9..:_~_:L ~ __ 1 _?.._8-_J::.jL~J!J..--~O-O.a __________ §J..la.3-S ----------------------- ! -,.......__ I (,<,# t/ i ~J~~-~!..':J __ ~..@t4 _~ , ) (, r a-,,. /$ /0 c_,~ /11E'""~"01-C/lt"1f7 ~Ei..L I j I Xv ,/"JZ-/~.£. -~ [t {,. '.3 J-• j\ Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. l ? ~; Name (printed) ~ p Signature ~ Stree~ddress & Zip cy,, 1 _aizrH _~--:::i1-(___ ~iI?fi:Jlt!p?!_-==-______ <?1__9-___ A_Ld~ __ (;t_.____ __ _________________ ___ 2 __ <f::__~_~;_t~------------------a~-, __ :_______________ obi!:_ _[~!_{~'!f_C:~':!_ __ q_'::±,:_~l~-:.:~!_~(:, _r:_e:_ ___ ~(_~::_~--- Email 3 --------------------------------------------- 4 --------------------------------------------- 5 --------------------------------------------- 6 --------------------------------------------- 7 --------------------------------------------- 8 --------------------------------------------- 9 --------------------------------------------- 10 11-------------------------------------------- 12-------------------------------------------- 13 ------------------------------------------- 14 ------------------------------------------- 15--------------------------------------------• • • Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. Signature Date Street Address & Zip <J 1C J) Email Ct ti '; t/ _____ &:_:w~----$f 2ff!{_ _________ !_(!_} ____ f!_~_i::_ __ f~~~~-{~ ---~:~~'.e~~~. i ;~ ~~---__ z@ I = ____ i2 ___ 0:_4.0_! __ 1t: ________ '§_~-~-~ _b_LLi:_clt.._~<e_q ~ ~-l-~ Name Cprinted) C l-i r r > W a./ U e( 1 --------------------------------------------- 2 ------~-~-t:-~~ __ "!_ ____ _ , .-==:::::: ---=- 5 --------------------------------------------- 6 --------------------------------------------- 7 --------------------------------------------- 8 --------------------------------------------- 9 --------------------------------------------- 10 -------------------------------------------- 11-------------------------------------------- 12-------------------------------------------- 13 ------------------------------------------- 14 ------------------------------------------- 15--------------------------------------------• • • Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) 1 --~~-~~-.. r:.~----~~1~----------- 2 _sk7t-~1l:f-LD__}~------- 3 ___ J]_etf:;I'_~.b. __ }±KS.tb..a..d-. _____ _ 4 --------------------------------------------- 5 --------------------------------------------- 6 --------------------------------------------- 7 --------------------------------------------- 8 --------------------------------------------- 9 --------------------------------------------- 10 -------------------------------------------- 11-------------------------------------------- 12-------------------------------------------- 13 ------------------------------------------- 14 ------------------------------------------- 15--------------------------------------------• Street Address & Zip J ~Email A·~) }l;l 2L _A~~6-_Z:21_~1!0_~-~~:~-~~l--------~~--~ {Al~----~~~~~~~---~--- Date .. ~ ( t.~~--7-::.?f::L5 _Q,/j{.p__g_[~_1_kL _'<:.rLsk_cJ_k: ____ __ -~-,--.. ·-~--~ __ 9Jl~dLs __ L'f.3._.&d.._~~__fLi1:tle.. __________ _ • _::J..~-~------ fr\. ~i lttn ~$flA.C:U.. 13 _..bo.,.<;S~,n_ .. ~ • J; /\ Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) 1 ____ 6-((1:t_/__ __ !i.f'J!.M11 ________ _ ~ti~ Vf!:J:1::z;;z~ __ .f __ Date Street Address & Zip --~IJ~q/~-----~--'--~~o. Email c_~_f !°_0_1_1!._<f!/!!!'? I/, ( Ol?j 3 __ !::7li ___ !;j __ y_::J _~_!_ ____________ _ ----~~3~-----------------4 --- ' r ~~-z~· ?[_~~L~_::. Is-- 5 ___ f.:_'-!_~-t ~~Q---~~-~f.:_!~_Tr_ __ S 7 IJ I Irr-I <;; &e11 /().f5(;._ f<L ' ?oJ:..C £1 ule ---------------------------------------------------------------- ~rn e 1 r L ~-t 8 ~,+ n-1c.L~ l. -----------------------C'"c. f'v\._ 6 ___ 2-~a __ .K>t~----------------~~-------------!l!!l!.r__ __}_6-___ ff-kuc ___ 'd/,,_:_____________________ _ _____________________ _ 7 __ 141~-~~----------efL________ _ __ _ ______ -~-----~)_?_![{_~_ -~~--Jl1d~srJ.:f-______________________ ~~'-"9:~~¥'"& s i..:_~1~=~£~ dt:::,Z, -~ --~t~--~t-:;~--~rc;;.--~::;.J~-D ~-;--:~~=-~-=:-:-1~~u"' 9 ------------------~---------------------------------r;r ------------------------------------~---------------;~------------------~~~ ---~------,_:i;.-><if.:_ 1 o _l1'2. _____ V2__v::.h.~-(±~iL ______ d-~--________ b:l-_ _ __ 8 il!/6..~--!::f _t:::!'5..f f:._~t!----?:1ri~~~~--L1r2_f2td_Lf1£iL ').,,. o. 11-Cl~-~ ~~_(l ___ .thn±~--------__ (J {:fin__~ _____ _____ -~~-~LL'i.. _L Q _~ __ C_f..9ltL~--~1J:_cJr.. ___ 81~-~~ .ceh~~rt:?£_b+1 c~ ~ ~-L ~ I ; .f.:!: ' tna...1 ,c.:<..l>>t 12---------U.D.d.q__~i~-------_ ~ __ fl.VAi ________ -nJ-a05---~~---G:r.raJ._J!:\~J'.i..c __ ~l .6S' -~-11it1~_&s.:qt-. net- 13 Jtte!:)'._~§f-:l~f-----_ __________ ~ _?1#1/b M?f_/1,l811~Ad!fl.BrJ, __ ~laf~(f;e ~ ;;_M~'>--'.!:i·"A!4 ---~ -~~~s _ _1s -J±+,.,lli:. _________ ~-------------------------~ __ _Jt:6sU-.1J. __ ..L3b __ .td;.J1f-!': ;tu..._*-__ w_,l____ -~lc!) . .L?.. JD.3.. __ l\a.wJ-bgLtl.~-~---21Lt~.2_____ 3~~-1Qt2E..lli".!-.I .Gol 0 e • • I : ( ;\ Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done respons ibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside th~ periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) Signature Date Street Address & Zip Email ;; ci Ei f' -~ I c) I -l 1 ---:'~-----~~~~--------------- __/~ <7 .-, ~:£1£_-~(vd::J.--------------------------_u[{_µ _______ q_:1-__£_ _ _{2q_1::::_?:_~-==~~-~-~----------------------------- 0.l -A . ·QI I I ;.· . --f; -If-II ,J )J , 2 _____ ;;s_~ll..er:.._·n:u1Le._t:!.. ___ __ VlR G-1 (l.h A w l-b EL--L-I\ -1)_ ei ·· ----(J~~cfi:.. __ y_~-v-__ l_~!d _j ~----d-.__?_ __ ~_L!Lfl!::2..?:f::Y-:--WfY-j ----------------------- l.J . -. ' '\ . ~·~/I , . /"J YI I 5 T ' I n n , \ . 3 --b.L~LL~ _.1...&..Q.P__> ___________ _ -----~~--Ud-~-----+-1---r---------____ -i:;JftW.~_w_T ______________________ ---------------------- ----~~ .. ___ ti-Jr~~ t::.2:.t..::J.S: _g_£~--~~-~-.ll.~_?...:i _2.L.a..s_~-------------------------------4 _Ji.i.kk.A:.11:d..A_£~?.:fz. _________ _ 5 ------~~!~--~-~~--'::!..~-------------­ /// 7 r /.., ,,...-:-1 f' _ , /, ~ u~"--' Cl rl()VY v 6 --------------------------------------------- _ ____ j~:r~ __ .£J_t!..?~---------_1_l_11i~ 'i ___ .f .f.L __ r!_:. __ ~D _ _t.2~ __ 6_l-L~U~--~~!_\.~.=:~ ___ V_QU __ ~{~Jz~-~Y-;ift_ ~_(_qx_ __ ~<::::_tu~-------- 1 _1,£.TA.T£P-.i.E~--------------fr,~----J~/_µ __ ?i:i__t;_, __ ~ __ <!J __________________ _ s _bf_ffRb_tJ __ !/-8~:~if_L __________ ~--L.1a17.Jd ___ }?§y~------~:~~ L_c~~-i~t:-i-~~-~~;:-------------- 9 --~-1'.'.';iY-__ _bf ______ ~~-----------~~~-------~~~~ _ _,(_ ______________________________________________ _ i o __ J{~lht--H~_J-l 1 L ___________ ~-~------_1-LJS_i_,;; _:_10_1fdf;_W,;;_.;,.t_fc:.md.JdL -~-- 11-"--~~:\0~L~_lQ!J_L ________ _ ;----------__________________ ~-5-/JS ~L H:Jl~----~-Odj------------------- 12-~~~~-------------Ls-iif ft!-------~~ ~:!4-;::·t;=-;~----------13 ~-------------------------------------~-----------------------------------------------~------------------------------------ 14 7-..{P-LJ£~£_fi::__P-_::_::/_ _________ _ (~.__ 15--------------------------------------------• • b:.h .:i.iJ~.1 ~~BLGib.1; \ • ,/3 Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) Signature Date Street Address & Zip Email "i'f'bv;'Y\-?5 Jl"S-l"if!/?/'> ~}J~ <a}3tl1~-&,{,, L"f "~l,,., <c./~':,') t e -:,/'5VIC..rrr, €_41/c.__.a .,,.. 1 -[:;~1-:~------------------------------------------------------------------------____ j_~-------------------------------------------------------------------------------- 2 _?~LZa./_f,__lji6..~lfi~c~---4/if/4CL.r/f7/~4--------Y-l!::..-::c2 .kL.k!.L~,,z. __ ~?.J::: ________________ a,..------·--~-41 /3/<,re_ \, [!, u ,IChCtrf-t~ /I; ;1~ ~I-;;(, -z1 ea~ i-~~ a ""' , 3 -----~-----~~..:'---~~--~----------------------------:-----------~------------~-------------------------------------------------~-i::;-~(5"~------------------------ 4. _Q:i~t~-~~.-~~:~-~. ~ -~-~~.-~~L~ -~~-'.-'.:'.-~~---~'.:?. :~------~0-t~~-~. Qj. LI· f'L)[J"lf £~ C!> I · p(\ (, 1 ~j ~t !i frPr 8~ '-.J d..<Yn ~~~--tJ!J/J. ·_ -----------------'0;-.1.-~7;:; _'9:i_t/__1&2.f3ifIJlill!L~--fKW:f_______ fj_r£.f_1;JJ..'f_::i!/f2·f::ilf~ 6 --~-~r_:._~---~-~~-~!::-~---------. ~--------~----~--~!-~~-----~.!..--~~~-~~~~--~!: ____ ~_l_lti__~~:::______ -~-~-~-~ __ !]_<;!._~~('' lv{/2- 7 (};_~_ef_&L!L~-~_fi.JJ12. __________ . P-~-~ ?:J..L-:1-.> _!_(fd~_6-_r:!:!::_~cf_-~::!_ __ J_{_H!t____ L_~'-"-J..<£~_kc2i@ ·~~~ 8 -~CJ..{j_~~-S---~-f:~l;;;:~~-?:_ ________ ~~--Q ~~-----------------------~~~~/_~ ~.2,~_l~liJJg~--~@z):;_J'.r.:~----------~~t?_?_~---;l \J .;{.. :;ri_ " , ~' 9 z:_~L~~-~uJ ___ ~: __ '.!:~d. __ 10 ~--1-:bf];-,fyd ______ _ -/ {)' ' 11--J~d,~---L.~ct.k'::' _____ _ !/:!{/:_~~ _!i~--~~-~!J_ __ q~!:_!!:!._.£((}~--- ?l_~J_M9 -5 _L1_1 __ 1~}1~~-1 i:eu!..L __ fl._U.c.3-~---­ l.AJ..l.U.:'l -~ f_:~L::~rJ.. __ :)Q_&fl-LfLgUL _<!t .&111 .. <fl.~2L -~ J . _________ ~:..~L :_~_ / f f J!:J~ 1 J :V., ff Bw-JI <a~ 12 .. 15.ef.!~~-~-~~ntt@_~---------- ¥f 3 ua~.f)---~~i~v1::1 ___________ ~~~--:::: ~:D..:1{__ iirc-:Cba:.J1'd.: .. bt:. ~~~--~ 15--------------------------------------------• • • Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community . . NJ'me (printed) 1 ---~~~dJ __ ._t!J~~ Date Street Address & Zip ____ ?j}!L{~ ___ l1 L gJc-J2..J)~_ft __ Jl!..~~-~-------- Email K c+ca...-t--9 :JD ~CCY'l1ca<ft ~ -----------------------~ 2 ----\.--::'-lA-~1~-f-~~-~['-~:?..1:i __________ _ __ !_(_~)_!? ___ LL~--~~~~--8-:----~~~'2 __________ _ ~-~t~2~~~T.'l\tl f 3 ____ !?._!:_!!_~---~~-~~!:!:!__'}_ ____ _ 4 -----~~-~~~~~~~------------­? 5 --------- ~::t.~~~----------- __ Ef f)~--- \ f}'l/J.5-Cf>uJ, I~ Lu,_· --~----------------------------------------------------------!!_~~s: __ q;::z_k!ift-<lt:!!!<d£_'c _________ _ // // -~~1.2 _ti&p. C4Y' 6 --------------------------------------------- 7 --------------------------------------------- 8 --------------------------------------------- 9 --------------------------------------------- 10 -------------------------------------------- 11-------------------------------------------- 12-------------------------------------------- 13 ------------------------------------------- 14 ------------------------------------------- 15--------------------------------------------• • • ./J Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) !~~-~-~~~~-------------- • '4En;fi~5'~ --2:~_,_c;~~ ' ._.]!.-~ltf_et~C>CoA .........-- r Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to den y the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community . . <#.\)'Name (printed) .. W,ignature ---_D•~: _ Street ~ddress & Z~p ' . _Em~il ~ 1 __ V_Qll~-"'-~_q ____ Gc.y.J-q_fe.z__ -------~#---------------1/_1:1f-1 -23%_JQtfLg_~ __ (;f_~!:_t:!,If.. __ J!.L~§§ _f5.t-tpi"2Zf __ _ 2 _ _fo_e_t;;._?.:_t_p_:::\--/J..£..t::J._&..L __ :::!_(!_~p________ _?f_~_i)__r.?_b!Jf.._~J-~E_u/_ __ )::-£d.1!.:r.LLL'li:!? J £_ __________________ _ ~'"~~a __ illli~--:----------___________ ~--==%*"_ ~-~t-1_L~0:S __ E~_!J~13.1_G~t:~ ~-------------------- 4 --~-~-~~L~~ __ j ___ : __ sk~-~:!frc -----~~~1s~----~ ~}~_D_ __J_~---~:\~~~---~-~~~--£~~---------d~~0~~2~~-~-~V1 s __ ,,_,_>.;._~ __ _in ,_dd.LJ i_~1!'£____ 4taa,}j-------rbA~--__ 11__~j{gi.J ___ &.e.________________ __:~------------------ 6 .#Li£--~.d-dJY2-cd_-#_L~~~ U.~~-~;f;_d,_ ---------------------- 1~~~_;_#: ___ t,_J.':1l-i"-'-d _____ /~---t1~ ¥*1-C bf.._iJi'1k~Q.ri:_?..t.__<;:.,_y__ _______ jlA,,,,/.,/,.,,_.,_~J-~\. s _J:j2t/..Wif£J!f/_i~J __ T --lif~~-;l(f/{:£!___ ~-~'-!_? _3~----~~~_@__(J2ff..~ __ (c________ 'llk!1_Z'f1f..'(-~· , ~w.t.~-t~1&'1k _ _ ~ yP~---<3::21.-:1? 2:1__?.li.!le![}J'_J1:=_________________ :2/-tJ>_y,[fA..~-J~I,,.;, 10 ---------------------------------------------------------------------------------------------------------------------------------------------------------------------- 11-------------------------------------------- 12-------------------------------------------- 13 ------------------------------------------- 14 ------------------------------------------- 15--------------------------------------------• • • iU :; . 0 · Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community fhis petition is not about stopping drilling, it is asking for drilling to be done responsibly. fhe following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside th~ :ieriphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) Signature Date Street Address & Zip Email ..:;, ' \..· ..., " \ \...i L ----~-:..-·~.c.:.~.!:.. •• ~---;:,.J.-.~-~'.:'...a~---- , z /. 7 c·Lf · l :.s 1· I • ._,,, I ? --·---·------_.;. ___ ..;___ ., ___ t:,!. ______________ _ ___ _f.~~.c:~~-~!.~ .. _'='.: ___ ~~-b.? '~---------?._J _~~--0-~i.1~.¥..~:... .. G.t ... :~J_tq_!z5 --------~----------_/.:fY-~---·---···-· l..Ji__ !l.i--:..L1.i2t!LC . .G:..J:.1;_,,'-'1.:11;,£.Z.di.! 4 ····-·-·-·-··---··-· J --~~-~::-~-==--~::~~:~------------------ i -----~-::.1::.~~-!-f-tr ____ H_Q.l±<2xL 5~~~:.?_~~~~~:~---~-r::.::!/--~--- 1 • 1 ~ s --~~--~---i.---~-----l --~.!.'..>..Ci::l~--------- 1 _____ b.':!::.:...~-~-~-~-:_?. ___________ _ ~ ---~~~~-~~-:?s.1.~.i~----- 1 ___ mr.tb..¥'.e.--'~\C'..{'...Lh_...e LO-~-~~---------- -~~~-t -· .:?...:.!~:L .\2 .. ~-£i~-"(.--f"I ___ 1J_~~--~~ ______ !!_ ___________ _ ~~ p u '/ J_p_ . . . ~ ~ 1:.~-:b. .. -~ ~---1:.-~ .. --(.fRtl, _~--~~---____ :11&~ ___ 0..-:r1£'0.:; ____ C.t~------------~L!J_g_lfEI2~ '-N 1 t6 _/ 7 . .J7 G;c ix_ r jV"n~t ,Qi wt -~-~ --------~~----------~~--'!:-::-~---------~----C',_J;?~L:f::::. __________ r;________________ -----~---------~------- ___ 0::;:-~~h~b~-----~~f ?f ff .1-~:··--;~---··· ~\~:-~:~-~ ~--~-~:'.':::::::".________ ~~~ ----·-:···-:··------------~-------------------·---~;;:;;:;;;:;,--;;~-:;;~ ---~~~--------~~::J.:.. ----~_s:_!\:l.~~~----~~~-------------------------------------~~--~~~~~~~-~-~----·-----------------------------------~----~----~~~~ -----~~----~~--~~{!_---~~-------------------------------------- ll---------------------------------------------------------------------------------------------------------------------------------------------------------------------- L2-------------------------------------------- L3 ------------------------------------------- L4 ------------------------------------------- l5--------------------------------------------• • • Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community fhis petition is not about stopping drilling, it is asking for drilling to be done responsibly. fhe following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the :>eriphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) Signature Date Stre~t Address & Zip Email I C.J/ff. ____ &!__'t_~q:______ r~----f_2_{.::: ?_ _ _2,2__€.__!!.::~~~:!./!_ ___ ~?:_?._[ __________________ _ ! __ _)_J .. £_./,. .. ~_J/.e_j_k__c,,_______ --7:,,4-~~_i:r.:; _ __2~_i..fiq.LJ_'J:.IJ..2-.Sc//?._<i_(.'_f::J_r:, _____________ _ i __ ).f!:J:tt_§. __ l/).(!J?..f !._'f!::j.__ --rf ~_d_~f--i.!!Z_:,;;-__ :f;f:../.!_1?2!:_~!.:.l!!!d.._L _ll:__t_ __ §_!..f.:?..5 ------------------ ' __ J}_t;:_Q~_;_~~::'~~-~L L -_: ______ ~~ ~7t!~ __ £_if!_f:...1e2 _!::!:::£!..'.::?.£ __ {f::r:..~! '-_?.__?._ _____________ _ 5 ~-:::6E .<4 --0D-~.w.i--LEE.!::?----------~------~~ ~&._?j~-_ ___ (_~?:_ __ ~;~~@~~__<b_g __ §j_f_~J_ _____________________ _ 5 atl!::.6!2::.!7:..0.!Y.~c!:[___________ ~~--?k.@: _(_~ __ Q~~-~-~--eL ___________ 9_1_!:_~------------------------- 1 Jitl71J_~L f.t:_jt ___ 2ttLb ____ -.a.~.2~--Jr/?:_ufL~ _9_Q _f-!_0..S.CJ.8.lJ~-~--~Jis..,. _____ 5fl_~-~-~ ·-tt.~~6£J.eZ~f..~-- ~~~, ~~ ~ --------------------------------------------- ) --------------------------------------------- LO-------------------------------------------- ll-------------------------------------------- l2-------------------------------------------- l3 ------------------------------------------- l4 ------------------------------------------- l5--------------------------------------------• • • ~s Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Pennit and direct Ursa to drill from outside th~ periphery of Battlement Mesa; thereby preserving our beautiful community. - Name (printed) Signature Date Street Address & Zip _Email i ----r=!!G..!~----~..c.a_ ______ l/f.1/..2 1.@_~~~-.£!LJl/r~.:::f..~.!.:- 2 --t;-41~-~e~-----~-~ t.:JJ:L.r: .iLR.w.!Li.~.IL~L.. ~~ 3 ___ \/~-----~~-_ __ _ ___ ---~~---/l4.~E _et1! __ <_: __ ~1.:..!F ____ L_?:_ __ Cd:_~!::. __ t!:/_(:[!_(! ____ (__t.._____ fl!':L<f!!..~~f!..~J/d;,*" 2 . ~Co vc--- 4 --1rt~~,;-;·~t]_ [;~ lii/-""1~-t:'-~--J.~~ -1~~~ :--~~=f'Ll~~-~~ 5 -----------------------------------~-----~---------------------------------~------~----~ 6 __ Q]_J).f iJ-_f_-d4L___ ------. t~ !.: .. D.::C2 __ 5_!i_~-~e:_'f3l_ ----------~ 1 ---~/;J?JQ?.:;L_ -----_ L.{!_:!. :_-z~ ~~_&_;oz_~_t'~---------- s -~ !_(__!:_~------__ .:._ __ ~~::, ___ !§_~~_}J_r_~fl______ --g-;;~;:;::;;;)-m-<!_{:< 9 __ sS/:.¥-i.i..~_(;._~r1Lfd~adJ __ ~-l..::~CL~-L-~l:~L~----~-L_i::.._l.f..iJ:kl11:2:z:.l-JL:·_t-fi ___________________ : cJ~ ...---. ~ /~ I 10 ~:f:L __ ,}~L>ili --J~ --~~ ~ t --jr--: _____ "7i!T .!.7{f·---. ____ !_!_ __ _ 11 ~LU:~~1il'IS D \., , · 1__ --1 .il rfliflt-<;'y_(jiB_~fJJi;J: ----------12 ~~z.~ _L:._!Mf.)_ --~..:;_il/.1£_ _jj __ (!& i id£!c..U....._L.------------- 13 £dst-----J..~_b_______________ -, -~---------------:J.i:.~::L?: ..3...LJ.._c.l!~L!..C.. __ kL1f ------------------------------------ c-='L ' .J -\ , VJ/ "'. r\1 ll/l JJ )r~/( &<J' c JI' '<l ~ la 14 ~~---~l~~-------~::~----~------+~-~ _____ t). ________ IJ-f.-ic..iJdj)~----l~t--------------------------- 0 ~ Y\ ~ t ~ A . l<o...'f ., d t; -J s -/) ~ I 0 'i {!_ #I IA V<\ b ~"'" ~ L (),, Y1. e,. 15-------------------------------------------------------------------------------------------------------• • • c,.~ ; Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly . The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) Signature Date Street Address & Zip Email • 1 __ <;~t_£_(_,f_J(f:.± __ 2!Vh ----·~---&~ _!3:_-:J1t-t_ ___ ~-~-~-~-~-~~-e R4 '-:>P ;e 1 ,,-/6 L ({. · I 7 ,___... °' u~,,., ,,,../ ' C " -----___ L¥-...,.J---~----~-~---:.:_:"'°_.w <J' -~ -'\ =~i:i1~:~-r;;__~~=~~-~;;;~--P --?--11/ l.:?"-~'--~k., 3:~~:::::~~~~9 --~~ _f'o:'l::N t!;;;,lAitY:._filf_~t. ·~s c:9, . _._L-11 / 4 {]:~_c::zd:La.~ '-:::~(!..!:!?L _f!h_f)o_tf=____ 1__2. __ d/Jy_eR.._c..cL/.. __ <;~ /' _ _________________ p~_ie_3->--=--------------------PC? ,r-C? cA De~ s --~~ ___ (}__Jaa.._i --~_f}_J<..<a~ _____ _Sl_.J.ifiJ..L / /,&ul-'f'(t/'J ____ c_f3_J2..D_L __ A . _L_f±m_6_______ p {')_A_/1~. <to g I & 3 5 - I \ -> \ \ '"( G-O O\) ~-~ --~_)J_ ____ --~--~-~~~/~-----~~-~--~-~~--~R~l ~i"'" R \N 6 S 6 --·~ •. U:'j_j_ ____ _\±_t\ _______________________ ---~ ~ ~~-v .:=: __ f_E\S_fr~ij)_T~--~o ----~--~~-3-2_____ JAY H c. --r c;, o o ~Cl) McA, ST N rr- 7 ---------------------------------------------------------------------------------• Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mes?; thereby preserving our beautiful community. Email ., ~-~;,~ 3 --.. · 4 --------------------------------------------- 5 --------------------------------------------- 6 ------------------------------------------··-- 7 --------------------------------------------- 8 --------------------------------------------- 9 --------------------------------------------- 10 11-------------------------------------------- 12-------------------------------------------- 13 ------------------------------------------- 14 ------------------------------------------- 15--------------------------------------------• _____ ., • • . ,, Petition to Deny Special Use Permit for Drilling within Battlement Mesa Community This petition is not about stopping drilling, it is asking for drilling to be done responsibly. The following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the periphery of Battlement Mesa; thereby preserving our beautiful community. Name (printed) Signature 1 ~_l~h~_,D,._~Ai.e.hfi.ill2f' ~--- 3 -----~~~~'.~~~ ~-----------------------~12f ~ ~~~~~---~-~:-~~~: __ i:-~---------~- 4 -~'::i.b ______ ~s;i ______________ ~--~~ 9]1./i ____ --=-------Px.fi!.:.ui..J4 _;-~-2!-=--- s --~g-~-:::_~_9(.._§__~~-:f._S/_~------\ ___ .;_ -------------------------9-=Z-::!_~ j~_f__0!..f?..1:.m.:.t£1J_<;1!::;r:fl.5_'i __ fi_L0_§. ___ _ 6 _:;;]_a_l__J3_~--------------/ ------------------------------_:'f/f 15 __ f_?L__~t../!?ZL _(i_(; ______ §_!_~-~-------- Date Street Address & Zip ?_/3-1J2_9 1S: ___ QQ=t __ !Q~ __ ft.~'. ?l_~{l~1 ___ ~2-S! __ Gl ___ f2~_ttf_f_~Y-:t_EX'_~~--:' r<-/0 3 Email klxJ~..CJ.a.Je.DSU~fV'RJ ~ w9~.~S!~g~Q.@_f:'9 hlX:\, ca11 /?OC....,<ljr ~c:~::.:~~~-~~ 7 --------·------------------------------------- 8 --------------------------------------------- 9 --------------------------------------------- 10 -------------------------------------------- 11-------------------------------------------- 12-------------------------------------------- 13 ------------------------------------------- 14 ------------------------------------------- 15--------------------------------------------• • • '- P etition to Deny Special Use Pern11it :for Drilllilllg within Battlement Mesa Community fhis petition is not about stopp1ing drilling;, it is ~1ski111g for dri111ing to be donie responsibly. fhe following signed residents are asking Garfield County Commissioners to deny the Special Use Permit and direct Ursa to drill from outside the Jeriphery of Battlement Mesa; thereby preserving; our beautifu l communi~y. Name (printed) Signature ][)aite Street Address & Zip Email L •• D.~-~~J...9.. •••. L .-~s..';;..Q.£.. •• ':1.:.-1..... . .• ~( ••. G .. ~ ... 2.1.L.~11 .. s-•. 1.::L.2 ... lt.9.Y..':.9..£ft _[{1.!?.C:.5. •• £.~~-V:.--------------------------- ! __ C!:/./i,!'!..5.:f.-/..51:::/2<;:__0!Lj.. _!l/~d-~-.!l!..0/L-;-dl'i.b2€.!ll~i?LlJ.fi£ .. /!~U!..<J!lq:__-?._-C_ _____ _ ~ .££~1.1.t.:l.s .. ~--·-!.?.~!:::~~----... Z~~-·-1.k.__ .. 2 .. J/ff .22_r:__!f_~~1!1f..-'~--tr!_{J_§J.. ___ 12r::_!_r1~~ ~--------------------- 1 .!::..~'!.!~~--E__E~E_q_t_55.______ .. £.~.?-~--------·---1-)f-l.£ .2.2.!!..&.~e.1::P.£..r;, __ F?._i./2.9..!:....i2i..f:!P )£ ___________________ _ s ____ r)_.\_t~J:'5!'.: .. ~}.ci... ..2'2~--~-~~------------CJ./.t£f _t_! .. Cf.Cl . .J.: .. f.L /_'1-L(j_f..:___________ --------------------- N'i ' l ' I :JA-A -I ~ ( o •.• .LU.Oi.S:"b.~-.£1[Jfo-(Q_·¥----··------~ !ti1.U1. -------.7/l;Q/JJ: ------------------------------------'.~-------------------------------- 1 _;d_S5.ti. ... J.~.WL .. _______ . _,;_ __ :_ ~----~#.s .... :1.:?E}!l.a!i:~L:t..t!t.ei!!.«£ --------------------- ~ _</:;!.!iLlt)_~---~~-QdL~---·--·----" -----_·_.:_I ---..... _Z1£. .. __ .?IL:f/ct? __ ..}_r_f._~g_k~.--?.!.~_66 ______________________ _ I _/j_g._c!j-=.e±__-$12.r::f.fti~PL ---~~~t:!.!.f.s_ ___ _l;J._ddtp!~-~~.!iL---------- / )'} ' -~ --1' / [ ~ /Y) ·1 .I ~ / ,,-, fl . d ~ to ---..::...1...:Z::::~s.. ____ w--LL. --··-... .:.~(r.:.-.r.:.~ ___ _,;.1::/5./..£&~.--·-----·· iJ..7£...:: _ _ _______ ;._; __ '21"2'~-----~----~ .. a=-------------------------11--~~'? ___ (-£!_(?P._t)!_C(__~1id4: .. i :Lf.-J~ ___ f.ZJ.if'~~-ffe2:..ffi.~g!J,~?:- L 2------------------------------·--··-------·· --·· l 3 --------------------------··----··--··-------·· L 4 --------------------------·-----··--· .. ----· --·· ... --... -----·--· .. --... -----·--· .. --.. ----··--·-----------··-... ··--------------... ----------~----------------.. ··------------------------------ L5-----------------------------··--··-------··--·· • • • • • • Garfield County 195 W . 14th Street Rifle, CO 81650 (970) 625-5200 Garfield County Community Development 1 08 81h Street Glenwood Springs, CO 81601 Attn: Fred Jarman Public Health Re: Ursa BMC B and D Well Pads and Pipeline Application September 141h, 2015 Director Jarman, EXHIBIT I ,+1,., 2014 Blake Avenue Glenwood Springs , CO 81601 (970) 945-6614 Thank you for the opportunity to review the applicatio n materials and provide referral comments . My specific comments for the Ursa BMC B and D pads SUP are based around the 2010 HIA, Ursa's response to certain recommendations made in the 2010 HIA , are non binding and are as follows: 1. 3.1.1. In general, more site specific and/or source specific air sampling capabilities need to be invested in. GCPH 's current air sampling program is focused on ambient air quality only. Ursa did decide to participate financially in the CSU study as a partner, however they chose to contribute only $100,000 of the original $200,000 that Anadarko agreed upon contributing . While their contribution was very welcome, this has left the CSU study short in funds, which has forced CSU and Garfield County to spend extra time and resources seeking alternative funding sources to complete th is mission. The CSU study will be critical in determining how to go about further air sampling and study design to monitor industry specific activities potentially affecting air quality. Preliminary data from the CSU study has been unava ilable. 2. 3.5.1 . This is currently accomplished through the existing Energy Advisory Board, of which these groups are participating members. 3. 3.5.4. The GCPH will be conducting a Community Health Assessment (CHA) over 2016 and 2017, which will inform priorities that will be set in the Garfield County Public Health Improvement Plan (PHIP) set to be adopted for 2018 thru 2022. In the past the CHA has been for the whole of Garfield County, if specific municipalities or PUD's are to be evaluated separately, this will require additional funding and county resources to accompl ish. 4. 3.7.2. It is my opinion that Ursa's response is incorrect. Under meaningful use and done with proper methodology to prot ect direct patient information (name, address, other personal identifiers, etc .), the recommended study, as well as Garfield County Public Health Department -working to promote health and prevent disease • • • other population based health studies, can be accomplished with adequate funding and time. 5. 3 .8. (full section) could be tied to Ursa 's participating in the Garfield County Health Care Coalition/Emergency Support Function #8 group, including planning and exercises, possibly sponsoring trainings, safety briefing and industrial education to the group dedicated to public health and medical emergency response for Garfield County. Thank you, Joshua S . Williams Environmental Health Manager Garfield County Public Health 195 W. 141h Street Rifle, CO 81650 (970) 665-6383 Garfield County Public Health Department -working to promote health and prevent disease • • • September 11, 2015 Community Development Department 108 81h Street Suite 401 Garfield County Plaza Building Glenwood Springs, Colorado ~l &O I RE: Special Use Permit To All, .)fp ; S Z01 5 GARFIELU COUNf )MMUN iTY 01-vr:i OPM;:N EXHIBIT INN Per the attached letter on the proposed Land Use Change Permit for a Pipeline Development in the Battlement Mesa area. I am a property owner and am sick and tired of all these towers and sub-surface destruction. I vote an absolute NO NO NO NO! Enough is enough. My property assessment has already FALLEN SIGNIFICANTLY AND ANOTHER TOWER IN THE VICINITY WILL MAKE PROPERTY VALUE GO DOWN EVEN MORE. It's time to stop the rape of the land. This was beautiful country. That is why my father moved to this area over 25 years ago, now it is being ru i ned by GREED. We don't want to look at vistas littered with stupid gas towers that light up at night. The ones already in place are an eye sore. 98 Dogwood Lane Battlement Mesa • • • O\oLSSON @ ASSOCIATES 8/21/2015 Arthur Frank Hewwitt , Jr Trust 2400 NW 80th St Seaiti e, WA 98117 -4449 SENT VIA CERTIFIED MAIL ------ Subject: Special Use Permit and a Land Use Ch a nge Permit for a Pipeline Development Per the enclosed public notice, Ursa Operating Com pany and Battlement Mesa Land Investments has applied for a Special Use Permit an d Major Impact Review from Garfield County. As a surface owner of record of property wi thi n two hundred fee t (200 ') of the property or an owner of mineral interest in the property that is t he subject of this application , we are hereby providing you with the enclosed notice . Plea se note that the Planning Commission hearing date for this application has been set for Wednesday , September 23 , 2015 at 6 :00 P.M. in the County Commissioners Meeting Room , Garfie ld County Administration Building, 108 8th Street, Glenwood Springs, Colorado. If you have any questions regarding this matter, plea se contact me at 970-263 -7800. Sincerely, Lorne Prescott Senior Scientist Olsson Associates Encl : Public Notice 760 Horizon Drive, Suite 102 Grand Junction, CO 81 506 TEL 970.263.7800 FAX 970.263.7456 www.olssonassociates.com . ' . \ • • • PUBLIC NOT ICE TAKE NOTICE: that Battlement Mesa Partners . LLC & URSA Operating Company has applied to the Planning Commission, Garfield County, State of Col orado, to request a recommendation of approval for a Special Use Permit on a property situated in th e County of Garfie ld , State of Colorado ; to-wit: Legal Description : Practical Description : East Y:! of the NW % of Section 18, Township 7 South , Range 98 West within the Battlement Mesa Planned Unit Development, a parcel having 1248.87 acres . PIO : 2407-081-00-152 Section: 8 Township : 7 Range : 95 ALL THAT PROPERTY LOCATED IN SEC 5, 6 , 7 , 8 , 9, 10, 16 , 17, 18, 19 IN 7-95 . ALSO THAT PROPERTY LOCATED IN SEC 13 & 24 7-96 ALL WITHIN THE BATILEMENT MESA PUD. EXCEPT A TR CONT 6.20 AC DESC IN REC #502259 . EXCEPT TOWN CENTER FL #5 AS DESC IN RE C #513419 CONT 22.370 AC. ALSO A TR OF LAND CONT 18.574 AC +/-AS DESC IN BNDY LINE ADJ BK 1703/327, 330 EXCEPT A TR OF LAND C ONT. 37 .65 AC +/-AS DESC ON THE FINAL PLAT, STON E Q UARRY CO MM ONS,/!... RE-SUB OF LOTS 5-1 & 5-2 O F BATILEMENT MESA PUD R EC #691907 . EXCEPT A TR OF LAND CONT 35.461 AC +/-AS DESC IN W D BK 1877/16 EXCEPT A TR OF LAND CONT 35 .33 AC +/-AS DESC IN SWD BK 1947/706. EXCEPT A TR OF LAND CONT. 11.81 AC+/-AS DESC IN THE TOWN CENTER, FLG #6 , BATILEMENT MESA PUD, REC# 743233 & GWD #743971. EXCEPT FOR 6 TRACTS OF LAND -PARCE L 1, 57 .68 AC+/-: PARCEL 2 , 76 .26 AC+/-: PARCEL 3, 52.80 AC+/-: PARCEL 6, 35.67 AC+/-: PARCEL 7, 56.17 AC+/- AND OLD HIGH SCHOOL PARCEL , 41 .35 AC +/-AND DESC IN SWD REC #740298 , & TOTALING 319 .9 3 AC+/- The proposed D Pad loca t ion is on a 7 acre portion of the 1248.87 acres adjacent to and south east of River Blucc Road (CR 307) in the Battlement Mesa PUD . The proposed site is west of the Valley View Village residential area and south of the will o w Creek Village residential area . Description of Request: This is a Special Use Pe rmit application for Extraction and Production of Natura l Resources to develop a natural gas well pad (called the "D Pad ") to contain a total of 28 ga s wells . The overall pad location will comprise approximately 5 acres . T he property is zones "Low Density Residential " within the Battlement Mesa PUD . A ll pe;son s affected by the propo5ed p la n a re invi ted to a ppe ar an d si ate th eir views , protest or support. If you cannot appear personally at such hea ring, then you are urged to state your views by letter, as the Planning Commission will give conside ration to the comments of surrounding property owners , and others affected , in deciding wheth e r to recommend that the Board of County Commissioners grand to deny the request. The application may be reviewed at the office of the Community Development Department located at 108 8th Street, Suite 401, Garfield County Plaza Building, Glenwood Springs, Colorado between the ho urs of 8 :30 a .m . and 5:00 p.m ., Monday through Friday. A public hearing on the application has been scheduled for Wednesday, September 23, 2015 at 6:00 P.M. in the County Commissioners Meeting Room, Garfield County Administration Building , 108 8th Street, Glenwood Springs , Colorado . Community Development Department Garfield County EXHIBIT .~:· COLORADO Department of Public Health & Environment I oo Dedicated to protecting and improving the health and environment of the people of Colorado • • September 8, 2015 Fred A. Jarman, AICP Director, Garfield County Community Development Department 108 8th Street, Suite 401 Glenwood Springs , CO 81601 Re: MIPA -8341, 8342 and PDPA -08-15 -8373 Referral s Dear Mr. Jarman , !ii At this time, the Colorado Department of Public Health and Environment (Department) is unable to provide comments for th e Battlement Mesa BMC Band D well pads and Phase 1 pipeline project. The Department does not have adequate staffing to assess potential water quality or environmental impacts for the numerous local planning agency project referrals received an nually. However, if consultation with the Colorado Oil and Gas Conservation Commi ssion is requested the Department may consult on the BMC B, BMC Dwell pads or Pha se 1 pipeline project and provide recommendations related to protection of public he alth , safety, welfare or the environment to the Commiss i on. Sincerely , Kent Kuster Environmental Specialist Colorado Department of Public Health and Environment 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692 -2 000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk , MD, MSPH, Ex ecutive Director and Chief Medical Officer • • • 9/11/2015 TO: Garfield County Commissioners FROM: Fred & Cynthia Burdick 37 Willow Creek Ct Battlement Mesa, CO, 81635 Subject: Drilling in Battlement Mesa EXHIBIT I pp We are writing to you, our elected voices, about stopping the potential drilling in the residential community of Battlement Mesa. We moved to Battlement Mesa from the Denver Metro area to get away from traffic congestion, air, noise and light pollution . Battlement Mesa in Garfield County seemed to really fit our needs. But alas , we are now faced with the potential of having HEAVY INDUSTRIAL activity which, includes, multiple gas wells drilled in a RESIDENTIAL COMMUNITY. The potential problems with noise, light and air pollution are what we moved away from. We will now be faced with having 50+ GAS WELLS, heavy trucking and major pipelines as our neighbor impacting our health and safety for years to come . We do not have any endangered species living he r e. Therefore YOU are the only hope the 4000+ residents of Battlement Mesa have in making sure this community keeps the high quality of life we have now. The negative impact will last many years and this area is struggling to maintain a positive outlook even now. We do not oppose environmentally safe and sound drilling practices but not HEAVY INDUSTRIAL USE in a RESIDENTIAL COMMUNITY. Thank you for your service and considering the effect this Special Use Permit will have on our beautiful community and area. -11/6~ Fred Burdick ~~~ Cynthia Burdick • • • William and Eleanor Nelson 35 Locust Way Battlement Mesa, CO 81635-9569 Tel. 970-285-9806 E-Mail: welshman2@comcast.net September 21, 2015 Garfield County Board of County Commissioners : John Martin, Mike Samson and Tom Ja n kovsky 108 3th Street Glenwood Springs, CO 81601 Re: Ursa Application to Drill in Battlement Mesa Planned Uni t Development -Drill Pad "B " Gentlemen : EXHIBIT We have been supporters of the oil and gas industry since m oving to Battlement Mesa in 1998 and recognize the need to become an energy-independent country. But at what cost to its cit izens? We will support drilling activities wherever they have the least adverse impac t on the quality of human life . Exxon 's original Surface Use Agreement called for 14 pads . When we purch ased ou r lot in 1997 the maximum number of wells per pad was one . Consequently, we would only have suffered a very brief period of drilling. There would have been a total of 14 wells in the entire PUD . Now Ursa is propos i ng 197 -an increase of 1,307%. Our immediate concern is strictly with Drill Pad B, where Ursa is proposing to drill 25 natural gas wells on 15 acres. We would like to strongly point out that not all drill pad locations share the same characteristics . Our home is located in Stone Ridge Village and is situated less t han the required 1,000-foot setback, which is not adequate to protect public health . Our home is the closest t o the proposed Pad "B", directly opposite and about 200 feet above the well pad site . Stone Ridge Villag e Subdivision is sited along the bluff overlooking the Colorado River and the town of Parachute. The impacts from drilling for us will be much different than from those living on the same level as a drill site . Ursa's application does not even mention Stone Ridge Villa ge -the closest residential community within the PUD to the proposed B Pad . This cannot be an oversight, so one must assume it was an intentional exclusion. The drill pad location is mistakenly identified on pages 8 an d 10 as being 850 linear feet from the nearest residential area (Monument Creek). In fact, the closest res ide ntial neighborhood is Stone Ridge Village - directly opposite the B pad and across River Bluff Road . Th e i mpact to abutting properties (page 15) fails to consider the eight homes overlooking the site, which purposely minimizes the impact. Ursa conveniently excludes the impact on Stone Ridge Villa ge residents (page 19), mentioning only that "the Burke residence is impacted due to its close proximity to th e pad". The Burke residence is outside of the PUD and is a 924 square foot mobile home while Stone Ridge Vi ll age homes are site -built custom homes averaging 3,000 square feet with current depressed market values ra nging between $314,000 and $372,000. The Comprehensive Plan and Intergovernmental Agreemen ts (pp . 17 -18) state a strategy of ensuring that commercial/industrial developments are compatible with adj acent land uses and preserve the visual quality of the county". 1 • • Let us provide a depiction of those who will be affected by t he location the "B " pad location . There are eight homes that will be immediately and directly impacted by dri l li ng activities at th is site because of their higher elevation and "bird 's eye view" of the proposed pad . All of these homes are two-levels , with walk-out basements and decks providing sweeping views below and beyond their immediate boundaries. We all paid a premium for the lots in order to build our custom homes . These eight homes have an average 2015 taxable assessed value of $230,800, and most of the owne r s are ret i red voting citizens -ranging in ages from 65 to 85. Other homes within Stone Ridge Village will not be as d i rectly impacted by drilling operations to the extent the ones on the bluff (or ridge) will. We are not add re ssing water quality here since others have already done so . We have already been adversely impacted by decreased pro perty values and the potential for further reductions due to Antero's then Ursa 's prolonged drill plan application . Now that Ursa has finally submitted their application, we have several comments we wish you t o consider. All property purchase documents after the Exxon Surface Use Agreement was recorded in 1999 included a vague disclosure about a "mineral estate being conveyed ". Does anyone really understand the significance of this disclosure without consulting with an attorney? We d id not receive any such disclosure when we purchased our lot in 1997, so if you have heard this same comment from others, please conside r it to be the truth. Loca l realtors have a poor reputation because of om itting this insider information to potential buyers . Ursa's application focuses on the "light industrial zone " rath e r than on the impact drilling will have on neighboring homes . In addition to the air quality, no ise, lig hts, traffic and safety impacts, there are visual impacts as well. We res idents in the eight homes facing Pa d B will be subjected to a view of water storage tanks and po rtable toilets in addition to the rig . Air Quality-Age is an important factor when determining health risk . There will be localized air quality impacts on residences nearest a well pad , and this sect ion of Stone Ridge Village has been noted to be the windiest spot within Battlement Mesa . What ar e Ursa's pla ns for drilling and flaring of gases during high - wind events? Chemical odors and soil disturbances during drilling activities at ground level will become airborne and affect many homeowners in addition to just those in Stone Ridge Village . (Example : The Battlement Mesa Metro District has a water treatment pla nt immediately to the west of the "B" s ite . Twice a year the outdoor aeration beds at the wastewat er fac ility a re cleaned of refuse, to be used as fertilizer fo r agricultural purposes. The offensive odor from these opera tions usually lasts several weeks). Access to this "B" pad will be along River Bluff Road , locate d directly behind the eight homes mentioned . With the increased traffic volume, how can fumes from die sel trucks be mitigated? The construction route to the pad is simply too close to homes . Noise/Haul Routes -A 350-foot noise buffer is i nadequate . The Ursa application again speaks only to the Burke residence and purposely excludes the Stone Ridge ho mes at the higher elevation . We would recommend restricting noise from loud operations to dayli gh t hours only. How can Ursa reduce noise levels for homeowners living at elevations higher than their operat ions? The types of noise ba r rier walls currently in use not will suffice . (Example: Williams has a drill pad at a site along 1-70 just west of Parachute . Noise from frocking could be heard for two weeks, especially duri ng their nighttime operations.) Noise emanates from increased traffic volume as well as from construction an d drilling operations . Lights -While lights will not be shining down on our homes , thei r gla r e will be highly visible when viewed from above. Will shielding really suffice for this type of ligh t pollution? 2 • Safety -(Example : You may remember that many of us expe rienced a damaging fire in 1999 caused by a juvenile playing with matches during one of the windiest da ys of the year.) Si nee fire creates its own wind , we are greatly concerned about the use of flammable mate ri als and the effect potential flaring will have on homes situated at a higher elevation than the drill rig itself. We also fear that hydraulic fracturing operations will adversely impact our soil stability. (Example: Trains roll along the railroad tracks near 1-70 several times a day and we can feel the vibrations from the movement.) Fracturing will only add to this soil stability concern . There is very strong evidence that fracking can cause earthquakes. In view of the extremely steep slope on which our home was built, we have a serious concern for the safety of our home. Summary -We feel it is morally wrong to drill in a residenti al community in locations that are in such close proximity to homes where most of the residents are retired and virtually held hostage by drilling operations . It is one thing to affect our beautiful views -it is quite anot her to diminish our quality of life. Concerning mineral extraction , page 18 states that "the county will pro t ect the public health, safety and welfare of its citizens. The property rights of mineral lessees must be bal anced with the rights of private property owners and the general public." We would also request that Ursa provide a landscaped ren dering of the "B" pad as it will look after completion . Every effort should be made to conceal the industrialized operation from the homeowners overlooking the site . Ursa states that "the heavy existing m at ure vegetation provides significant screening as a visual mitigation" (page 10). Perhaps it is if viewed only at ground level, but not when viewed from above . The only "heavy vegetation" is along River Bluff Road . Hills ide vegetation below Stone Ridge Village is not tall enough to screen anything . Prior to ruling on Ursa's application for the "B" pad, we invi t e you to visit our home and stand on our deck to view the proposed drill site and traffic route. If you were to "walk in our shoes " you could better determine the perceived impact of drilling inside a PUD. Ideally, we re q uest that Ursa's Special use Permit for its "B" pad be denied . Otherwise, the Planning Commission and Garfield County Commissioners should at least require them to consider an alternative location with a higher setback for its "B" pad in order to minimize the impact on residents . Thank you for your consideration . Sin cerely, (signed) (signed) William Nelson Eleanor Nelson cc : Fred Jarman, Director of Garfield County Community Development 3 Fred Jarman ------------------------------------------------------------------------ • m· nt: To: Subject: Mr. Fred Jarman, Director Elaine W <wintzhome@hotmail.com > Tuesday , September 22, 2015 11 :32 AM Fred Jarman Special Use Permits Battlement Mesa Garfield Co. Community Development 108 8th Street, Suite 401 sent via email Glenwood Springs, CO 81601 Re: Special Use Permit and Land Use Change Permit for a Pipeline Development Battelement Mesa, CO Dear Mr. Jarman: EXHIBIT I ~2... In June, 2015, I moved to Battlement Mesa, CO from Minnesota. I do not wish to see the special permits approved for further extraction and production of Natural Resources to develop natural gas pads near my residence. It appears, from what I can tell, there are plenty of other open areas to permit more natural gas pads away from our housing and water areas in Battlement Mesa . • ing new, I don't completely understand all the processes of natural gas development, however, this proposed area/development appears much to close to a beautiful housing and water area in Battlement Mesa, CO. Respectfully, Mark Winter Mark T. and Elaine C. Winter 190 Limberpine Circle Parachute (Battlement Mesa), CO 81635 • 1 •, >. C) 0 0 (]) (.9 c ·-en ro en (]) (.) c ro (]) (.) ·-a_ +-' CJ) >. ·o, '"' Q) 0 .... ,, --~ 0 0 0 0 Q) N o <.9 LO Q) s.... ~ ~ 0 ......_ ::J ·c: <O 0 Q) (/) EXHIBIT I SS • Asset Location and Geology Basin Continental Positioning • /" • lli'ursa l fi~';! I BASINS DGASPLAYS D OIULIOUIDS PLAYS 0 2 Asset Location and Geology Basin History 1990-1995 1995-2000 i.~i l ;;.-"--: ,._ 9" :~: ' , •• 2000-2005 2005-2010 r:- 2010 -Present (1) Sou rce : Wood Mackenz ie "'C .......... -2 u ~ ~ :wr-• ,...... ..... ·~ •• ~ .rit".'...li . ....-v ...... -.-.. ~"'1 "-. • ' :.1 ..... ---~ ~ lli'Uirsa Piceance Basin Production1 1l 4,500 4,000 3,500 3,000 2,500 2,000 1,500 1,000 500 0 ~~~~ RRRR • Niobrara Hz ~~R~~~ RRRRRR • Mesaverde TGS ~-" Mancos • Mesaverde High Weber More than 12,000 wells drilled 800 700 600 500 "'C .......... Q) 400 ° ca ~ 300 200 100 0 4 .0 Tcf (113 Bern) cumulative recovery to date from Williams Fork 3 ~ • Asset Location and Geology Piceance Basin Statistics(l) ~ 5.8 million acres in 5 counties (Mesa, Garfield, Rio Blanco, Delta and Gunnison) ~ Estimated Gas-in-Place of 300 Tcf (8.5 Tern) ~ An unconventional resource, basin- centered gas play with approximately 2,000 feet to 3,000 feet of vertically stacked productive sands in the M esaverde Group (William Fork and lies) 10.1-100 MMcf , _ I 100.1-1,000 MMcf I I 1,000.1-10,000 MMcf 10,000.1-100,000 MMcf > 100,000 MMcf Basin Outline (1 ) Source: Adapted from the DOE, Energy Informati on Admi nistr ation Maps 0 • WY UT J CO I ~ • UC>ursa "'O .r ~ -?>~ ·t • ~ \ .1'1 nl-1-n l Fl' l' k , · \~ --· ~F 'h~~ ltd l\ f\\. X S·i ftt Ruli so n Field 0 4 Asset Location and Geology Stratigraphic Column » Primary production target is the Mesaverde Group • Williams Fork Formation • lies Formation Formation Depth Ranges ~.a sallc h II 3\000'' -4t;.OOG'' Will iams Fork 4,000' - 7 ,500' Cameo Coals ,Cdzzefte Co'tico r;ar.i Mancos Shale 10,00 0'+ Dakota1 S'S antlt b·0l d'eri Characteristics > );> 1Co fit inental sa rt ds,) shal es, a'nd 1t oals . Fl uvial sand bodies are l'e nt icular,.small p·oint bars » Avg. siz e 300' x 700 ' );> ~ .);> O'ffsflo r:e1 sandbar1 0fr ma i;i n ~·ori gi·~ .)ii · W!a1ff ne1sner.eli rn e- );> Marine shale·; secondary source ~ ("(I .f ~ Cl) ::::s 0 cu u "' .... cu '-u iltr'Uirsa EJur~rn Pic~nc~ Basin Compo•lr. 1)1p< log and Srrar/grapltlc Nam•nclaru,. > i::: '" ... II) :s 0 Q1 u ra ... ~ E ..... c.t~ 5 ,& ~·!~ C1' ·-~ 1 ~ 1==~ i:; ~ ~I :? r i u I j ... ... 'Qj Q1 1 2-1 c.1 ·~~ ... Q. '"'I ::::> .... , 51 , ___ ~ ... d> (.!:) 'i5 : Ill "O ·, 0 -v ~ c n:s :?, -W I~ 5 • • Asset Location and Geology Mesaverde Group -Williams Fork & lies Formations w Dovtdas C'rHk Ard! ~~ ~- c:e. •I • j- ,. -4 -" ., -.... ml Mwlneand l..Kustifte di-ah E3 ~ Md cuboMlcltous ah.le f<: ] Fl~ aal'Mit.tone ~ 1.aai11r111-. 11'11~ ml<N, ~ and of'Wlon nndttone •10~ ........ --Surlaoe of e.qual vftrinltt 1"tflect1ncie _,, 0 • IO 11 ~ .. ~ 6 ,., -v~""'~~·10. -u -u I =: : ... -:" 0 • iU>U1rs.a Couette Corcoran UpJI« Fluvlal I l.9W«T Fluviol I CoaMa/ Mancos Shale 0 6 Asset Location and Geology Paleogeography of the Williams Fork Formation )io-The Sevier Orogenic Belt uplift was the sources of sediment that was eventually transported and deposited into the seaway Uinta Gr een River Wa satc h Q. ~ :i .... 0 0 .... LI-~ VI Cl> E "Cl .... -~ Cl> > ~ nl VI Cl> ~ -* E ~* lies ==-* Mancos lli''Uirsa ;'.,1; Meandering ,_,-..__ ,,,~~\I..);_ . --®· . /,~~...._. (C •• .-;-·/ ,...::'I"\ •' ..-:,:-.I i • ·".;--..,, _,,;? 1 .. '. .· .. \1;:'~. \.-c ... ·:;,, '·~~!_)) ~~:f) .. B_··-.. gt:::~;;;;.7 q ; ..• ~~ ;;/ ~··2ff' ;'.1; Anastomosing 7 • Asset Location and Geology Cross Section ~ Main pay is 3,000' {1,000m) of vertically stacked Mesaverde Group (Williams Fork ... QI and lies QI -0 formations) 0 00 > Qi ~ ... Cretaceous Age ru E continental ·;;c 0 ... Q. sands , shales and Q. < coals ~ Fluvial interbedded sand bodies are Q. lenticular, small 0 ... IU .... point bars :::s 0 ru :::s ... IU < 0 • • {Q>·u 1rsa 0 8 Asset Location and Geology Modern Analog-Meanders and Point Bars in the Mississippi ~ Hundreds of point bars (small, discontinuous sand bodies) Uinta Green River Wasatch c. .::ie. :::II I-c: 0 0 0 ... u.. ·-~ II) 'fa ~ ~~ ... = 0 cu = u.. ~ ~. II) cu ~ Mancos Ui'Uirsa 9 • • Asset Location and Geology Schematic Cross Section of the Ma mm Creek Area 0 c: ~2 o~ :;, :;, §rt; § (/") () Cl) CJ Land Surface Gas Migration Up Pervasive Fractures Caused by Overpressuring 1' "-Gas Migration 'I Up Fault- Fracture Zones....../'"+ I ~ ~~ J t • i.U>U1rsa Top Continuous Gas 0 10 Top Gas Asset Location and Geology Battlement Mesa: Southwest -Northeast Cross Section 05-045152350000 Wlll.W.t9 PROO RllT CO PUCKETT 9G 41·23 05045 ~20000 URSI\ OPER CO U.C BAT 126-24-07-95 T7 050454 500000 URSA OPER CO U.C BAT 326-24-07-IHI T7 05045Jli.40000 URSA OPER CO U.C BAT 32().24-07-96 T7 05045~0000 URSA OPER CO llC 8'.T '.l<f}.18-07-95 0504520~340000 URSA OPER CO LLC BAT 34C-18-07-95 050451 ~70000 Al'IT ERO RES PICE>NCE BAT 141).17-07-!15 0504516'1150000 ANTERO RES P!CEmCE 8AT2413-17-0HS 62'U1rsa 050451 !soooooo EN CANA OW (USA) INC \'l!U.WAS GARONER 17-11 (PL16j!.l.TIL8JENT M T79 Rll5W S16 11 'l"'"i ... • • Williams Fork Development 0 • lli'U'rsa )-A 30 analogy for the Williams Fork Formation is a bowl of potato chip )-Chips represent sandstones, open space represents mud stones )-If you stuck a straw vertically into the bowl you would penetrate many chips at all depths throughout the bowl )-If you stuck the straw through the side of the bowl you wouldn't penetrate as many chips and the chips are already touching along that horizontal depth 0 12 Directional Drilling c t! 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" 24 AAT 320·24-07-96 4- BAT JlA-2U7-!tG 0 BAT 13A-24-Q7-36 "'-- •. ' ,, " / / ·------'~ --BAT1l8-2A-079S -'~ BAT1X2~7~-------/ : j ----..___ ,,... / -·. "\, BAT 130·24-(17$ ...-- BAT 14A~~4-8'f$ BAT 1'8-241-07-96 BAl" 1.,ec.2..:.01 96 BAT 1.W-24-07-SS ,l ;I I BAT 2AA-!!4-07 96 ... MT248'24-07-96 "" BAT 2•C..2'-07-% BAT 2AQ.2,-07 '6 BAT llS-2.t-07-96 _,,. SAT JJC .24-07·9G ------._ --.BAT 330-2-t-07-96 --·-4 Q)."f-a.f,A.24-07 96 ..,,, BAT3"4~2'-07-96 SAT J.4C 24-07 -96 -~ BAT 341)..24-07-96 ·' • l&i'U1rsa 0 14 • Asset Location and Geology Niobrara Type Log Battlement/Orchard Type Log 0 0 0 ~ 5.'.3Q'l009 Niobrara Formation 200'Targetlnterval Frontier Formation Ui'u1rsa Niobrara • Technical learnings include stress/fracture orientation , geomechanical properties and horizontal targeting • Niobrara drilling targets a "'200' thick interval 15 • ~iobrara Horizontal Drilling -- ~-=1»"9 - us. Conventtonal non-associated gas Sandstone artm ... llODnlidmm:mamn u S GWq;JrW ~ • Seal ------~------. • U?u,rsa -----== l ~------~ Coal:bed methane ~ Horizontal drilling targets thin (200' vs. 3000' of Williams Fork) laterally continuous intervals 0 16 U'» cu "'C ·--V) a. :::s ~ u RS co • • • c 0 +.J u QJ V> V> V> 0 > L.. bl) u 0 +.J -V> o ro Q) UJ C1 .I -a "tn c QJ tU $ c 0 ·-""C ~ c e QJ o~ ..... _ ~ QJ Q) > "' ro Cl) L.. <C (!) 00 rl 0 0 Injection Interval Top of injection interval = 6727', 1.27 Miles, or 5.3 Empire State Buildings The UIC injection interval is the Cozzette and Corcoran members of the 1 les Formation uru. · CP:RATN:; . rsa I cc1~·\r,ANV GR ILD Poros ity --I I I -I m:=. RO LLI NS [DC] I ~ L8 ~ I tr I ' ~ 1co zzETT E (oc1 I ~j I £ I <"F l c o RCORAN (DCJ '3· Jl•tl •"'•·Ground Level Wasatch Fm ~I LL IAM S_FORK [DC] Williams Fork Producing Interval OLLI NS [DC} OZZE TT E [DC ) ·~u .... ORCO 'RAN [DC ) • J -~ " " , - ''lt...;_f• r~·~ .... .r ~~..,.. : t ·-..... ,~ ............ .. ' . ·_1_ /_-~ In g/l 8 E"rthqut1ke lo cntio ns pro>ided by t he USGS SINO locati ons pro>ided by COGC C Earthquake Notification Service lv'OFFAT C:C?JNT'Y - The Earthquake Nohfication Serv ice (ENS) is e free service that 1'71 sends you eulomaled nollfice t1011s to yolK email or ca ll phone when L~j • J earthquakes hoppen . ~ , • • ..! .... • .t_t . • Legend Inje cti on We ll Earthqua ke M esa Ve rd e Outc rop All recorded seismic activity from 1975-Present Seismic events are localized at ~dge of basin . . r~~; - Indicates that se1sm1c events \-~ • . SUN1MfT are related to natural tectonic :,. .. i;:·puNrY . ,Y"J _,... \ ~,/ events q:,T ... ' ~ ~N3 LE-~,,,-~..;. ;;-'~,'."'~?r COUNTY & .. ~, ,P ~ 0 .z I" "" J http:// earthquake. u sgs. gov I earthquakes/feed 0 ~ '• r :5. a OP F.RAT. IN. G r , CQf,1\P/\Nr/ · Battl :e.rne .nf·M resa Area. & ,,.,, ·,' . . •' . . -,.· . . p].a:.nni:~a .: u;h1t ·De .. ve.l:opment -· ~ ~ . .•• . . Update July ~ 1.3, 2015 • .. Wel'c:ame ("Jotin · f>·~osel • • lli'ursa > we·1ccl,.n,-e.1 tQ _:.the ·z lnd, QfJ .5:1 c;;_qmrm.~:riti.itY·' fo .cu_s -.m·¢~tings to. discuss· u,rsa ~s !·p,~·n~ 1:1Jl'P.vi~g:· t~tQ;i d :~.~etopment ·o·f :Phase · i ·of the PU _D. > wur·11i1clud 1eJ di:scussi ·o.m· ·a,fj·a .cti¥..i.ties ::o.u~side·,~pu.o. > l~:vo~.·h .~ye ::·in·~:ivi~~:a~ ·q~.~stJ :9n .~, feel free to .,~ontact me ~t ~~Y· tim ·Ef ·or ~after:the · m ·eeting·s. > We loo.k fo·~w~r~f to working with ·the . Battlement Mesa Conimwnity··:t~i en _s·ure a·n,yr«::o.r:l€e ·[n·s .. are. addressed. rl 2 ~ • "·~ c ·ommu.ni 1t_y Me.etJng Sch :e .clt1 1l:e > 1V19riday, June l!S · • ·· Geology of the Piceance Basin •· Basic orientation, including PUD locations > 'Monday, July 13 • -· ·Overview:of Comprehensive Developmente/an •· Battlement Mesa/PUD permitting process •· Operation_ phases and ,proposed schedule •· Re.gulato,.Y/Environmental related permitting questions ~ Monday, August 3 • ···operations ~ The Construction Phase • Regulatory related Health Impact Assessment questions (HIA) ~ Monday, August 17 •= · · Operatibns -. The Ori/ling ({rid,.· Completions Phase - . • , Regulatory related Healtl:I . Impact Assessment.questions (HIA) ~ Wednesday, September 2 • Operations -.·The Production . Phase • Regulatory related Health Impact Assessment questions (HIA) All Meetings 6:00 .p.m. I Battlement Mesa/Grand Valley Fire House "' U?ursa 3 • • p·revioms Ii lfo:d,~.v·~~ 1Vt .e:eti .i ng~ .~:~1 0 .hfr't .D··~;9 .s·¢·) ~ Today's M .eeting:·f);~jec~i.ve,~. • af'Ursa -::-' , . "I , • cti~11rrE!he~$ht~ ci ·~veJqi:lm·gJliti ~1-~h .O~~r.~iew (Story e·oard 'si .. · · . • -QV.e~vieV\f. ... -a:f~-Qp .~,rrati..'qrfls 1 ·Bliases • 'ov.e~Vi :ew;,aftlfi '~:BM )J?.l!JD t Perlf:litti~·g 'Processes r U?ursa Ug!nd 1. lf'h:ase t So.bmittal (B & D Pads. Pipeline Segment•· 4',.~ Ill~ "t!lnqu151>ed whiCtJ•inclucM!s:ihe Bore> N -1 Pipeline 2. TompbtsfBiQhardson .~@ ·Segment lbmplln5tl&lt-P~ ~I 3. 'Pipeline S~ R~shed 4. •PIKIS•to be Eiminated PNM!'t'P- LJ F'acl5 Ill h E~ ~!114!nlftll Mew POD 8oUftcl¥Y ;:e----~.-· .. ·'"~~,s: 6r ... "'-+ "''t. t ~-·~ ~·~~. -':. . .:.;:~~ ""~~ 0 "'·' . ,;,"1',~"'i'"-r--...---. . -..-~ 0 & ~o ~-ti. ICP" -'II ·~· .... • ·-· dl-::1" '· I)~·-'· ;:J-Q) c-oo ~'i -o .. :::J 11J r 1 ~a ... ~. . .... ~I'~ ~ .... r-~ ...... -•. -~ r ..,, JtJJ~a,nn"_A_M: '··=-,-o;g, ~· ~ ii ;;£ oi ,. ''dla. ~ txJ · ......._ . --: ~= .... -V,,J!"--~ -~-,,,,-··~·;;< a;=>. =i -•~ .. m ..,., --~ .~ -·~ ·~, -· · · ~ ~ g ,,. -=-~ __ _... _ _.,---~-.:1· '1'6";;: :? II> ~ ii' aa. i!: ,,. ~~ II> ·1· --0 11>1 - s~ ~~ ~ --II> ~3 ~.~ il?Ursa Battlement Mesa PUD EXHIBIT OPER."ifJNG COl.'1 P1\NY 105ll 11Wl--lG °""""'·co 11121i5 (7lllj.SOH3R1 PHIASE 1 & TOM.PK1NSJRICHAROSON PIPELINE SEGMENT URSA OPERATI NG COMPANY. lLC 1~=2.000~ A t,aao. ~ ... .... • fi?I ~~I CP:k'ATN=: } ;;;;JC;I CC/-~FAN'' •• Battlemont Mesa Semi-Annual Updato Mooti ng 3-10-2015 URSA OPERATING COfAPA.NY. LLC #~~-f'O# ~tl•l l.CATtON i f'JtDJl;Ul.O. •;1-•JU'T r4 .:111.NOl ... i -.... ...... ---....: PUD/Comp.rrgh.e.nsiv~ De.¥elgpment: Pl 'a.n ~119h .n :·.o9ose) · fi2'Ursa F.A€1\§~.e~~t :~1 ~ev.g~.1Qpnlent in:-P.UD 'lF.J/. • #·:.Pad '.s·~·6M~1 a;. aMP o~ 8-MP .. A,,. BMP1 L, a:MP ··M ' , .. • ~ ,, . ' . #Wells.·~ a~pr9x.·i_f:':l,~-~~-'-Vi ... ,197· w.gll ·~. to drill ~ o.ut the P.U.D. #~.weus: ~~·orilled to) Date ~-4-s ~ Wells •;,.& ~ --._::J" __ • H .. u." ~~ ••• ~ ~...a-.L, •• I 'J. 1 •· t ~ ~ < • , # w.el15 -~~:ir oa-~~P~1j :t>b wells i'w.ill '· be d -~illed :·t:r.o.m :outside the .... '' ' .. -.• ---~ .•.... _,.. --· •. · . ' '.' ·1···~ -«-, .. i 1: _ • •. I _ 1 ~ • ... 1 i .p~u 1 .o. furrent:.Clps Activities (:cQJlStru~ti 'qn, ·.drilling, comple .tion~) Rob Bleil will discuss permitting status in other slides 7 • -~- > Once air Federal, state, co·unty, tOWlil 1,perr:nits are approved > Ali .4. maJQJJ Q,p.era~i ·ons P~h-~ses _iJfcl :~,de ... the following -·. • > Regul~tory.· Release Package of all: Permits/COAs/SUA COAs > N~.ti 1fi.icati :0n 's to 1·andowners, colillmynity, community counts, GARCO EAB, agenci ·es, etc. > P:reconst rr uctiq~r)_ meetings with Contractors > All E·mvironrtient,.:·1t1 ·&S plans & permits in place -. > Regular/inspections by:=tJrsa and agencies > c ·onstructi9n.-9fthe Pad and Access Road (2 - 3 weeks) > Drilling (Avg 31 ~ 4 days /~Well; excluding Niobrara) > Com .pletions {Avg 4 ~.s days /_well; includes all stages) > Production includes produced water management, injection wells, etc. > Future meetings;·will:'dis.t:uss these phases in detail () 8 ii • .. ~ ©verV:iew1 •. o _f -·tti.e BM f ~U .. D' Pe·rmitting-.~to~esse~·1 ·(.R ~, e~·eil) fa2'Ursa ~Pads and WeU '~ Faciliti·es and -~-'i i pelrhes Req .~Jire Federal,. S..~~lt~J,f,e§:un t·y .. and t pwn 11 infrastructure" permits. All also re .quJre n~um·erous environme,ntal plans a!'na permits. . ~ "· .. ~Ursa h-as implemented rrm,C}~D.¥·-of t ITT .e· Governor's task force J • ' ~~co rm m·~Lndati,Q-r1s .. !~·rrJg .rr t@ · the t~sJ~ force being formed. , . ,. ~ -·~ •, ,j ~. ;· ~~ ,, -• '' ,. J r ~. . .:. • . J ~ Pads j.·amd :·Well ~s ~ ... • .... c···~ -~·-• ·"' ..,.. '• ··~ ,., •. -•. • ' -.. " l · ~Federq J ~.Permits req ·u..ired for FederaJ mi~erals or split ... •. . .. _, estate ~-State -C.0 ,6CC ··permits ,req~t1 ·ired '.· on all la ·nds includi·ng Federal :._W·ith CDPHE;·cpw and : county input ~ ,. • # ,. ~ .. ~ County...: Ga r.co pu ,o. Resolution requires permits inside the P.-UD ... but not outside the PUD ' .. . ·-. . ~ To,wn··of Pa·rachute -Watershed permits required :. 9 •• • ~ FacHi.1~i :e~s -· ,. .-: •. ~Facilities i m:el lt1 ·.de road·s, inJection wells, tank batteries, was;t~e ~ m-an·age ·ment faci .Ht.ies, etc. ' . · · · )-State~ CO~G;t 1e. ·.p.er.rrlits req ,·u)ii red [~J'.n all,.lan .ds including Fed ~era I.; ·. ··· , ·: , ·· ~. '• t. t ~· Ge1 ~il'ty 7:~G~~rco ·.·1?.·p 1 p , Resolution and tU .C requires ·, permits both:tnsi.de(ancd ou'tsi ·de t .he P.lJD for.vario·us i :n~trastr·uctt1re including roads, injecti.on Wells, .tanks ,_ ... batteries;:1·.waste facilities~ etc. (exc.ludes Fed lands) • ' • z ' ' ' . ~Town ~:of Parachute ....:.'Watershed permits required. 10 Overview·o.f the B_M f P-·UD~ Prermitti.ng ~:rr9ce~~~s -·(R. Bleil) ~Ursa > Mid:strearm 't.~~-:-· . ..... ~.·-... -~ > lf!i:cludes pipelil nes, compressor stations, pigging stati·o.ns M •, • > State. -Th .. e-CO/. R.i \!J:C. re ·g14 J ate~~-m6".st pi _p~lin·es, COGCC doesn't regula~iQ ITT 1 p.l:pelines. I •• :• ' > Cou11ty .. ~i Garco 'l~ .. u..1~. Res.o.lutiqn and l~U~ requires _permJts.:.lioth inside a -n€1 ~ 0 .. lLlt~id .e · th_~:,,Pl).D for· pipelines ~lgase(:J 'on size and .·distance) "an ·d comp.ressor:stations (ex ~:t yQes Fed lands) . ,. > To_w1 n ~ o_f P·a,rachute -Watershed permits required. AS 'YO.U· CAN SEE,· THERE ' ARE MU.lTIPLE LEVELS OF AGENCY P-ERl\lilTS, AGE~CY INTERACTl .ON, OVERLAPPING . REGU .i lATIONS 11 • • • . . REGUt.Ali'O,RY· S:1fRU,'C;l"\Ll_.RE 1 /: CRO~S_S_WAl.K (R. Bleil) 41?.Ursa Ursa's Key 0Reg Str~cture eQ.tDpQnents • .• !·1 , ~ Tracking and Implementing all Fed/State/Cour:lty/local legislation, regulations, guidance and policies. (Regulatory Summaries -Ursa tool) ~ Develop internal systems, policies, procedures, checklists ~ Manage all Fed/State/County Local Infrastructure permits . . ~ Manage 16 Ehvironmental Program surveys, plans, permits, and inspections Air/Odors Chemicals Noise :·· ·_ ·_ " " __ · · ". ~ · :Reclamation Spills/Incidents/Complaints Visual Resources Water Quality Wildlife Waste Water Use NEPA Cultural/Paleo Noxious Weeds Transportation Water Protection Spill Prevention ~ Manage all agency inspections, potential violations, corrective actions _-, 9) ,,._, I ...: ~ ~ , REG:UtATO.RY srrR.UCTU ,RE: l 1 ' ~RC»S-S.WALK (R~· B.1,e .. ilJ Ul'u·rsa , • A matrix of all Fed/State/County/local regulations that integrates all regulation requrrements to permit irrifrastructure and ensures consistency with overlapping jurisdictions. -· • ·. A crosswalk was developed for, the 6M PUD • The crosswalk also services as the basis to address issues raised by the communities and stakeholders, including the Colorado School of Public Health "Health Impact Assessment" (Feb 2011) ... aka HIA •· A matrix has also been developed to address all HIA issue·s that will be discussed in future community meetings, and prior to the first GARCO Planning Commission hearing in Sept 2015 . . ' QU~Sl;.1 ,~N~/COMMENTS ·~. • Cl • • u r rsa . ~6~~~~~ , '. B:attl. e:m e Flt M·esa · Are ·a & , I , t ' · · · Pla .n fred . ·u.n it . .,._ -.• . . ,. . . . D;evel:opme ·nt U·pdate Au .g:ust 3.; ·20 ·1"5 • Welcome •• ~ Wel<:·o .m :e·.~o the 3rd of 5 co rrm munity focus ·meetings :1 r • ' • · · U.:pdate statu·s. of P-th9 .se 1 in th _e W:-~1 _p • ·U _;p~date status ~f .. ~.perati'o~ns · outs rd ·e~:,c)f the PUD • ucursa ~ We ,,-l.00,k . foifward to NYe·~Ki l rng with the Battlement Mesa CommunitY·'and addr~ssing conce rr ns: • ·uu~st .io·n ·naires & F.1 ·y~rs at the sign-ir,.·ta :ble •···contact John Doose at any time John · Doose, 'Field Landm·an 970.329~4390 direct I 970 ~379.0008 cell jd_oose@ursaresources.com 2 "' Com ~muni :t.Y.' M~·eetlng, Sc·~le.dule »-·Monday,:Jun.e 15 •-Geology of the Piceance Basin •. Basic orientation, including -PUD 1 locations »-Monday, July 13 • ·Overview of C()mprehensive Development: Plan • · Battlement Mesa/PUD permitting process • Operation phases and proposed schedule • Regulatory/Environmental rel'ated permitting questions )lo-Monday, August 3 •·· · ·operations ~ The ·cphstructioh Phase ,~, _ Regulatory related 1 Health Impact Assessment questions {HIA) )lo-Mo .nda~y, .. August 17 •·· Operations --TJJe .iiril/ing ~fla1 iJompletions Phase · •, Regulatory related Health Impact Assessment questions {HIA) )lo-Wednesday, September 2 • Operations -The Production Phase •. Regulatory related Health Impact Assessment questions {HIA) All Meetings 6:QQ ·p ~m -~ I Battl~~ent Mesa/Grand Valley Fire House 3 • •• . . . To .day·~~:. 'M :~:~~i.·ng ~ Meeting. ~bjecti -ves _, l :,i- •. 'Ctirn :pi~e he nsiMe : II1eve 1·0 p:n1 e nt:_P I an ~·©V,er~view ~,.Ill I ~ -I • ~ -., • • lli'ursa • .Review-· prevlo.us C.Q.ITTJJfm_"t.tn1lty .. ~t1estiqns (Jqh ·rt .Poose) '~ •" -. • 'I -• • Status of PUb 1 Permittirlg fRoQ ;;Bleil) . . . l' •. ~ '. • ' 4 4 • · O ,~:e,~(~1ttons S<;filed !~!l.~e.'~~--P~reseeab.le (Matt·Honeycutt) J '1 1:) .I' -• .~ 'I :.1 JI -. I I •· Key -'r;i ·ete: (:onstructio.r1·_.Activities I • l t . ' -l ;• ' ~ • -"' ~ • • ~ -•• • •:"Pad ·s -~8(··P·i 1 peli.'.hes (Matt Honeycutt) · . . . . • ,Construction ·H·&s>concern .s (Tara Mall) • Environmental Concerns ~{Dwayn ·e Knudson) 4 • ~· ' ' . -·-. - Puo.:·~cam~rehe.,ns.i.ve Deve .1.~oPni,.e .n1: Plan 40,• pip.llM v De R~ .,.tlleh .includes~ Bore~ r Ugend 1. ,P.t)ase 1j Submittal (B & D Pads .~ N ~ r Plpelne 2. Tompkinsff'lfCtlardso" ~e Segme<rt , N 11>mptln&lf'ICll-Plp8M ~t 3. Pipeh'S4!Qmeats Renquished .... :..:.N" '.· ,, TJ po· ... ;,";.ti!~·~ -~._ . { "b. l ,--, Pb 4 : fads to ~ Elmlnated ~·ll '-'·"1t.>· .· J' .• "~1!0,,~ P:tt;I:>· • · •.· · .~,.., C f; ~ 1.-.J At t ~ L '\-, . . .}_ . ii ~··.. . .. "" le-:····•• .... ~1 ~-.i. -°" ," ·~ _ • ;.,~· (3 W l D P~IODeE~ I. i..r ~ ..• ~ .. ~ .'iJ'~.,..· .. ,1 .. :~ ...... -'·ii ·. . . ":. .. r---'i r"'· . . . QI ·~ ; ~IM!Mnt fileU POD eounci.y ' ! ' . f '7,.:._ .... \ i-1•11· ... .;· . "'. t:r. 'f:'' ~ ;_ . .~ " .. ·J" . I J. - --0 Z'.. . ....-:!-A•lo'· __,,,l ~ ~[J .·• w-.. Clif cB -on ~~ li " ---~ .. ......._..._ 11• 111 ~--~-· 'Cliw. woi .. : 8 ~ m l»f(>,X V~c'! '!!l"et :ts ~.,v .... ri.-7;,! .. ii!l · •• ~dM ~,~:ffi; ''· r .. lfl r'i q~... ,. I· \;'.·:.·JI~ ii~ . ~ .· .•• , ·-«' .....:.. .... .·. <Ill . . .. L.. "" tl• .,..,. • ' . ·-11 .•. , •. ~ Q, OJ . • b4i~.,2,~, "!;!.\., ~,.:.i;;s f°I' '},; . 11 ~· ~ '. ~• ~-. ,;s ..... '*·•·' '.JL-r ~ :;,1f~ . ~~-:. -,,,,__ . ,.< m ~ ::::; .. ~)~~-....... "'··-~-~;£!°.t. _/~_.-.. ....... __ _-· . I. .\.I._ . --~ •,. --..-_,_ II • • Q) (I--, i;;a::t> 3 Q. ~i S::l> tl~ ~l Al • 3"~ (D ..... ... C1'I Cll -• Q) ~3 I ~ 1 t_· -.&"·;; -'RS'~~ . ..; ~i )lt,fi/l . ·, .". cY.' ·~~. ~. .;[ -"' '.' · "I. -"'~L· '!r.:.E ~E~R~,--s. ;tJti'.fb"tl) ·:G.· .. jet~. :-'•·,,,~,, ... _ _,.....:it ;., •·"Praj\ "'"~· ,,...""·' . . "('k ~--.... -i ' "'............ ~-, <ZS ~, .. " 4'J '.:.Jt..[t~i~_ ~;.....__ :..._-i::.~-__ a..._~ ,.~ ·~--11 -"''~ u *f: lffo~.-# ,._, ..-..-,~~--.--.·~·-·~.-:a. --~.., DPER/\TING CO ·.~ P .~.NY IQg) .,,.,_-:MOD DaMr. co 111255 maJ SOHl91 PH'A.SE 1 & TO:MP ,KfNS/RICHARDSO'N PlPELINE SEGMENT URSA OPERATING COMPANY. LLC , nch = 2.000 ti.et l!'O/J IPf ... EXHIBIT A 5 • ·--·· ·FA·~-T~She,et ~~·o·eve1 lop;m,e ,n it: ir;1 R-lJJD 11.i ~ l ' ~ 'tVelt'l?~ds (5·)-BTVl.Q.k\,_I B,MC s:, 61\/lC:~o·,·s~M .C L, BMC M ~Wens , .._: ~.....-•" I"'--1_ ~- ~ A:~~~t~(E)xirnat'e -ly 19(·1 wens ~-o,: fully drill the p·uo ~ 52 of 197· weU~~: drilled fro:m o.Lltside -the P·UD to date (26%f ,. ~ Appr6 ~i~;t~1 ~\d:B:.:of 197 ~:~~1is ~ilFb~· drilled from . ' .... _. o'l:.ttside .. the p .. u.o (52%) .. . ~ ;-. :. ~ All locatrons i·n.side th-e eU.D are pursuant to the Community Develo·pment .Plan Battleme ·n~ _Mesa:_·permitflfilg Statw·sl ~e.P.tJ.D:P-hase I BMC B & BM 'C ·D Pads ~ County Permit submitted -June 22, 2015 ~ Finalizing response for Permit Completeness ~ Anticipate Planning Commiss ·ion hearing late September ~ COGCC pending submittal -Late Sept/Early Oct Phase I Pipeline ~ County Permit submitted -June 22, 2015 ~ Finalizing response for Permit Completeness Tompkins Pipeline ~ County submitted .....; July 1, 2015 ~ County hearing August 17, 2015 ~ Town of Parachute Watershed Permit -June 23, 2015 ~ Town of Parachute hearing August 20, 2015 fi?ursa • Batt 1·e'rrl.e'.1t . M'.e sa. Jie·r-1rdtt iLn·g: "St~.·t,W ~~~/Q.~-~-~ i'.tl"e .:·p u b Mo.n·um~erit Ri.drge 1 B:1 p·a.d ~ Pending COGCC approval ~ Input from: • . . . . U?ursa ~ Colorado Department of Public Health & Environment {CDPHE) »-Colorado Parks and Wildlife ~ Landowner/Community M ,eetings · ~ Garfield County 0 8 ~-~ ••' ~ Current 'Op.erati:o.ms ·. S~chedul ~e ~ ~Q;17 eseea ·b.l'e >-WelFPad Coritstructio·n,.~(~J!J:rrentl.¥·1 no activ _i~ylr.i . the area. Upcoming construction of the Mon.l1Jment Ridge B pad. An.ticipate 4-5 weeks · of construction activity~ >-Drilling: Currently.· cJriUing ahead on the Yater pad, anticipate comp~leting tnls drilli.ng occupati~n at.,t he end of August. >-Comp.letioris~t lust finished a 4 well occupation on the Monument Ridge ·13ad, we-lls are currently on flowback and are being tubed up by ~the ·workover rig. Completions continue at the Watson Ranch B pad, followed .by; the Yater pad -. >-Pip.eline: Currently ri _o constructiqn activities in the area. Upcoming constructiqn1_ of the Tompkins pipeline tentatively scheduled foJ late Fall/early Winter. • • • . -. '" lli'Ursa Step ~ ~r P.reco ·n .s,t r ~c;:ti~Q .. 111 • ..;. .. ' ... 1' ' . . ' ~ > Review alt Perm ;l it.$/~.Q-f/s/Specifi :~, 'Req 1~ests. ' . ' > Sched lt;.1le an.d holcl_,.p re-Const ~uctior:1 Meeting. ~ Partie~ i ~,v.&ht-ed: · .. -.-. ·, . ·" ··· · · ·· ' -. La n 'c:f,~ Qp .er ati·ons, Regu latbry /En V.i·rq ·n menta I, Contra et ors, On-site S,~pervisors. > N ·~ti f i~ati~n·s ·: ·.,, ·· . . .. ,, ,· • • 1' Commu -n··ity.·~~Cou .nts/EAB . ; Local residents Lpcal Agencies Coh ·s.trr[l ·.e.ti ·e:.n. ~·a.el".s:, ~ eonthnued· U?ursa Ste·p ._2::-;·,cgnstructiQrrJJ 'b.egi·ns 9 I t.· .:.:. -•• ~ 'l ll ~ (i'Q·nduct daily Jcib Safety Analysis (JSA}/~afety Meeting ·" ...... : .• 1 '.\ ·-i ~ Perrin i~ .. ej});~tocati:'on for-review -~. . i' ;,"i ~ C)p.era~i'(.:l;ns Ch:e.¢.~l !i '.s ~ ' '~ .. . . :. ,ii., ,, ·' " fl ... r:. .. ~ Storm1W,·a_¥gr ~~.ntrols/t~;~st JM a nagem~Jf'l 1t(Pract.ices (BM Ps) ' • -. , I ' ;,, .. installeo ~·-"~irrt(D·r ttd: a:isturbi fr1_'g '·any dirt . • ,..._ • --!l, -".,._ •_;.." jj ... • ,• _, .. ~ Fcillow constructio~--site pta,m ~ loterna·n :~s~ectlbns . · ,.• " . ' ~ I , • •-•. -.. ~ N:otify/Co.mrn .uriicate ariy chaUenges with current plan • •• Constt.u .e.ti :a:.n·. P ·a ~d ·sJ ~ .. co.:n·tim 1u:ed Step 3: ·fi.r:ti 'sli1 1 e·a~nstrructi«:>Jl ~ Mo;q:!11.:ize e·quipment 0.ut .. -i •. j " " • . . U?U~a ~ Seeding occurs, temporary;· .~'.l}llt Ps removed : .d.uring temporary . ' ~' .... . recl<frrn ~a 1tJ(5~1 ~. . -. ·. · ·. · .. -. . ,.,, ~ " ;: ' • •: • .i ' • • ~ • '·1Kree/~·hases d .. f ~~·eclamation ,-. -' • Terri.pprarY : '> : .. •· · J • l:nterim '" . ' ' ... F.fnar · • l ,) ,._ • ' ... ~ • • •• ~ : • • • ... j '• . . ~ Final inspection by team prior to hand off to· DriUing/or next ' event. -· -· • • 0 ... 0 .J: a. c co ·-~ g ::s • Ii. ...., "' c 0 u I -a RI a. al s::. ~ c: RI a: • ~ 0 ·-+ii u :s ii. +--' "' c Q u GJ c ·--• CIJ a. ·-~ ·--cu Cl ·-Cl;. I -a ta Qi.. ra .c: \:ii c ta 0:: c G) en ...., ta ~ • • Qj · . a.· 00 .-I 0 -· C1J ..., C1J -a. c co u Cl ::J I ~ 0 0 :c • -~,--"· • »-S.ite Specific Emerg~.IJl :eyi· _Response Plan »-full Hsting of em~r g .. §-fJlCY an_.~ pers~~nel n~mbers »-11:)..rri.Y.ling dJrectio.ns »-lD.esTgnated · H ·au i l !~Routes »-District l l.6.1 Academ i·c Scho_oJ Yea .r »-M ·uster·.Area ' ' ~ s'P.eeifiC:·arrecti'or:i forJire, 7well control,· medical em ·ergency, th .e~·ic·a1 spill, severe weather »-Incident· Notification & Management Protocol (_, • • •• Site Details: Lal 39.43333~ ....... ~ .... . · .. .. .............. ii' . . : .. ~! • i -" ._,. •" .;/ ./ .. ,._..-._ ...... ? ;''/~ ./ ,_ ) { / -) ' -·--. '... ·-l':'lln!mm:mb!li -...... \_, f· ... =·= '->---~-,<I ·:~-~~"..-~.~.~-.. ~ 0 .._ , .... ..... • .......... ,_.:d .• ·~ .:,.,,·• •'• .. . . . .... -__,,. ... ,,,...,,;---.. _ t 1 . . . .. :_,,.,.-<~ ...... -. ( :.-__ ... ... ~_ \_. ~:"' 'f- Ha_ut Rq qt e. Map Wl!SOO R:i.Deb B (Exit 71 ) !t 4J33jj. -tOU:?HfJ ~ 17 T<-ti~ 7 s-11. Rllt9f '' Wnt .•. Pad Location Approved Haul Roule • U?Ursa 22 .. I I) \ / I • . I • ! -· -- -, __ • '~ ~....... ~J I I ,_,..> : ' t J • • CONS:TR~U;C.'J l :0:1 N • GARFII.LD COUNTY SCHOOL DISTRICT NO . 16 lOlS-2016 SCHOOL YEAR ,,,._,_,__""' la.Zl ·?J-~!bll Dc.?1-..IM.t -.... 8-t •11--t.uo.KnJ ... File: ICA-E O...• -· ..... ~~~-CR.ll!JE m&Ooly-lbn bbt °"""""' ~-......---~ ' CR &E..CWSOllll'-R:us biaDlll!rilH Alqml2 IuMw~~& Wqt.dm "'9n1n.14.TJ.1 1,tt.nJ1r-.....~ ~5.n r .... ~ -lS.11 CFl---- ....... rt .. ==--o.: ... ! M Corilraur -. W4l Otaiibllra Pff~#M:M-CJL.8UE.C\.'115Dnlf- "'-" IM1¥1lrt.11 -· -· -· ..._ .. fttlnilrJl.ll _ ,. ...... Airi• ""'" ii.,1 ...,,, CW\i1S.W.W. , __ --CfL~f-~0.,-IU-Cfl°"' __ , __ -"'-' --,_ ... _ PrT """"'-'-Dimct- Pl'fCrdM!w:n-OL £lE. CWS~­ ~il514um --==---~ Smilti!"'R!om4D$1Gmmt~ rna.,d-........... r-nrO.,dSdm -~ ~' r .. ()uowEnZ ~~-"""" s.c.cnlQw[nitJ/ .;:.:~·Dlys ~~-"'""' ----.. ~' ' auu:~-a~ f owttbw ErdJ ..,, • . --crt.IUJCWS-• o.,. ,. GV15-Jt0.,,. r..i.rs-AntJ Ld~ ~n:1111yn _........,.r .. !llJ .....,, A-...~Ll•n., .tnt =r:1:1 "-ll::~=· :::t:r.~ fnblblr '"ans d ~ .,.. ~ a.J ~...,.nms • li?ursa 24 • Manage 16 Environmental Program surveys, plans, permits, and inspections Air/Qdors Noise Chemicals Reclamation N6PA ; --.. · .. ~ -,---Transpor.tation Visual Resources Waste •. w., Wat~:r Quali.t:y -_ .· -· Water Use Spills/Incidents/Complaints Cu ltu ra I/Paleo Noxious Weeds Wildlife Water Protection Spill Prevention · > Manage all agency inspections, potential violations, corrective actions • ·-•• t" .• fi?.Ursa CONSTRUCTION ENVIRONMENTAL ISSU.ES Air/Odors ~ Dust -equipment Noise __ . . .. ,. ~Equipment will cause n·oise ~.-·l fr,nited hours of operation Recla ·mation ~Temporary-Interim ~ Final Noxious Weeds .. ~Noxious weed program - 3 sprays annually Spills ~Fuel and equipment fluids -program in place 26 CONSTRUCTION ! E,NVIHON·M·ENTAL ISSUES Continued lncid:ents/.CQrrit ._pJaJnts )-Program. in place to track and 1 manage Wate ~. ~t:o.te ·ttio·n/·(\u ·a I ity· ! ... ' < . . .. )-609 sampling -water well samples )-3178 sa ·m.pling -public water protection Wil 'dlife )-Plan in place developed with Colorado Parks & Wildlife • ·---• U?Ursa ./ Remember tcffi 111 ·out questio ·nnaire~ with concerns, comments or topics tp, a_;ddress in1 future meetings ~ Monday, August l~'.7 • ·CJperations _:The Drilling and;,"c;;t:impletions Phase .~. Regulatory related Health Impact Assessment questions (HIA) ~ Wednesday, September 2 • · qperations -The Production Phase • · Regulatory related Health Impact Assessment questions (HIA) John Doose,: Field Landman 970.329.4390 ditect I 970~379.0008 cell jdoose@ursaresources.com 28 • rsa OP E·R·,·ATING . · CQf,1\PANY B,attle·m.e·n:t :M:esa Area & ... -. . . .). . ' . ' . -. . . ~ .. .• . . • -• I • -o • ~ I ' Planried.:-u n:it . ' .-. D·e\1eJOp ·m:.e.nt .u ·pdate August ·1.7; 2015 ---.• •' • we·1co.me U?ursa )-Welcome to the 4t.h of 5 c_~.rrm mur\i ~¥. focus meetings " 'i ' 1 ~· ;· ~. ' • = U :~-~1 ate sta,1tus of.Phase l i1ni the-f->,lJ,'Q, • Upd;a_te status e,,f operations olltside of the PUD )-We l~,Ei.k,·:;f~rwar~ 'to JAt~o:rklng wit.,h the Battle merit Mesa Comt:n .un!ity and addressing GOncerns: ' . ' . •, ·Questionnaires &·:Flyers at .the ?ign -in table •·~contact John [loose at any time John Doose, Field Landman 970.329.4390 direct I 970.379.0008 cell jdc;»ose@ursaresources.com • 2 ~ • • ~ p ,· ., . • - conl'JnUF:iitY·.' Meetiir\g Schedule ~ Monday,)J,1ne 15 ·, • ·Geology of the Piceance Basin ' • · Basic orientation, including PUD locations ~ Monday, July 13 · • ·overview of eomprehensive Development Plan • · Battlement Mesa/PUD permitting process •· ' Operation phases and proposed schedule • Regulatory/Environmental related permitting questions > Monday, August a ., r€Jpeiations ..-. The · Construction; Phase -t - ·•· Regulato..Y related Health Impact Assessment .tj.uestions {HIA) > Monday, August 1,7-_ •· · Operations -The -'Drilling aiid Completions Phase • Regulatory related Health Impact Assessment questions {HIA) > Wednesday1 .• September 2 • Operations -The Production Phase • Regulatory related Health Impact Assessment questions {HIA) All Meetings &:00 p .. rii .. "I ·e.~ttlement Mesa/Grand Valley Fire House • 3 • . . . Tod a;y~ s ~' .. ~IVJ ~.:~!ti rrlg· • •• fi2>ursa )-M.eeting Objectives •. Corm,19rehensive Development Plan ~.overview ' - •· Revfew p.rg.'6i'ous corm:rnunity.: q1uestions tJohn Doose-Landma.n) • -Special Guest ~-Michael Warren, CO Parks and Wildlife • Status of PUD Permitting (Rob Bleil ·-Regulatory and EnViironmental Manager) • .· Qperations Schedule -Foreseeable (Matt Honeycutt-Operations S~perintendent) • Keynote: Drill.ing & Completions . - • -Drrlling (Hans Wychgram -Dri_lling Manager) . . .. • · Con,.pletions (Pake · Younger~ CoJ11pletions Manager) .. . . • Health & Safety ·concerns (Tara Mall -·H&S Manager) • Environmental Concerns (Dwayne Knudson -Sr. Environmental Specialist) 4 • • -_:~ li?ursa l•P>llMI 1 I 'MY. 1 !'lllllf17l r::d t I ~~ I I I 'll~ i f •1r "'1...., M"'!)'""'fl,t ,..._. ~iO<l,C'» &< Hclft~u.::l'JC<I ~'i'ir.l\,U"<!'.llld~ r[\~ nn~> N ,.1.._, "'~·-· "J '"'lVl!r;1<w,1~r.oa.-,1~.nn Pl r~I! snorn~.r ,.,n,~..,..,...,,,,.,.n F~lt">C •<•"""" J_ Pll>Cllnc $Cj<J:I C\'1t.t'Rol:f\Qlll:)l:00 4 l":ltl'\ IO\h"' -wnlnllll""' c ~ 1.11--:s -c:r.,~-. -.-,,-~s;,.;(--, .. ~.,,. ' "»:i~ 11 ..;;' :;-+ ri ,::;i'iU!i"--:r.(,;A,.:..--_,....11 -.T.t --, -._-=.il"\~.,--_-:n-:r-· ""'.',,-ri:;..,....·---·~-::!!&1!:"'_4~, ...... .-.....:1_~.I~~~-._ · r ----'fl:: ·: ~3?.~ ~ ~ fi.?Ursa CftRim~.:; COMP,\~v r!.A1H1._,_1 ~,. .. ntt1 ::.tA..c r.CO ·~ V·~~l:>J ~-~ ~o GI -~ ffi <O -g~ 3 ;ll vs· II) -~ to = ;:~ ........ --~ tMF·~ ~~II~~ o-...m II) t6 x d4~Et ~C'<')VNTr: C~C G Battlement Mesa POD PH.t.SE 1 & TOM'.P -KI N S/RIC HARDSON PIPELJNE SEGME NT UR=AOPERAllNG c m.Pb.N Y, LLC . ~(;;._ -='i' . ' 1 -VM -7 flJH ~~ .,~ "'" -.. ~ii\* a. l'J OJ i' ~ ~ aa> (!) 0. ~~ :? 2. ~J> (IJ-;;i 40 ~. II) - -0 ti) - ~~ ~ Ui \I>- -l:j ~3 G> 0 :-tB L XI llO iT A 5 -· • . . . . . PUD ,' Co:;ffl 1P~e·fi~;Os.~Ve li)~v~lppm :erl~::Pla n FAC~!·~:lheet .;... ·li:)·e.veJ=oprm :ent i1rri 1 ~;U_!D !. • 1. l )-Well :Pads (s)·.~, a~MC A, B'1JVlC s·, l~JVl.CJ.ID~ BMC L, BMC M ' . )-Wells ~ App :rr~~irn ··ately .. ·197: wells to fuJ My drill the PUD ~ T6dat~:-!)Q ,Q~1971 (28%} Wells drilled from outside the .1 • p:u. D . . ,,. t c .. ~ A~pmximately103of19? (52%} wells will be drilled frbri1 ·outside the PU 1D ·.··--- ~ AU .. locations inside the PUD are pursuant to the Community· Development Plan 6 Battlem.e·nt Mes_a· ·permitting· Status ~/PU.D..: P·hase I BMC. B & BMC D Pads » County Permit submitted -June 22nd » County Notified all ParUes that the Permit Application is Complete on August 13th » Anticipate Planning Commission Hearing September 23rd in Glenwood Springs » COGCC pending submittal -Early October P ha se .. l ·Bi pe Ii n e » County Permit submitted -June 22nd » County Notified all Parties that the Permit Application is Complete on August 13th » Anticipate Planning Commission Hearing September 23rd in Glenwood Springs Tompkins Pipeline » County submitted -July 1st » County Hearing held today -August 17th » Town of Parachute Watershed Permit submitted -June 23rd » Town of Parachute hearing -August 2Qth 7 • •• Mo ·num :·e;n ~.'Bltl ·.ge B:.Pa"d > Received COGCC approval ~,August 15th > Input from ·: > Colorado Department of Public Health & Environment (CDPHE} > Colorado Parks and Wildlife > Landowner/Comimunity Meetings > Garfield County 8 • ~ l. 1 '. c ·urrent ©p.erati1ons Stfrl .edul··e :·.~ .. Fa-rese·e·a·t>:le )> WelrP.a_d1·C·onstru.cti<in ::· Currently he:·.a_ctivity in the· area. Upcoming ~· ' . constructi·on of the Monument Ridge 6 pad. Anticipate 4-5 weeks of construction a:ctiv;i.~v~ )> o:rilli 'ng: Currently drrllin.g ahead on the Yater pad, anticipate c0mpleting thls drilling occupati.on atthe end of August, with the drilling rig leav..ing the are~ for a period of time. )> Co·rijpl'e..tlons: ~M.1 cin,.ument Ridge currently on flowback. Completions . ... . continue at the Watson Ranch B pad, followed by the Yater pad. )> Pipeline: Currently no construction activities in the area. Upcoming construction of the Tompkins pipeline tentatively scheduled for late Fa 11 I early.· .. Winter. • ·-~· ·-*~n ~~-~ ~ . DRILLING:·. OVERVIEW· U?Ursa P re~.o·~l 1.1.h:ig );;:-Re~i~w a 11 1· Pe rm it~/eOA's/Specifi ,q J'{eq uests. . ,·. _, . ..,. );> Schedule and hoJ 'd ·Pre-SptJd Meeting. . ' . . . ' .• );> Partie ·s fmv .o.:l :ved ;: ··. · · · ---• ···~-·t"'\:--"'.I• " • -."~ 'l'"' •-I"' -, .:-"' •• • ·~ 1 . ' Safety,. CYpera·t ions, .Regulatory/Environmental, Contrac~ors, On_;site. S_u!pervisors. . ~ -. , ' . . . .. , . : );> N·otifications: · ,: .. · . , . ~ . -~ •' .. . ·• • I·· ', , , • Community Counts/EAB Local residents Local Agencies 10 • DRILLING'·.o .v ·E;1RVl ,EW· ~rillh:1g rig: • · VerY unique!· Super single style with a short derrick. ·--- • Small footprint allows us to· drill maximum· number of wells from each pad. • Hydraulic walking system allows us to.1 move: between wells without trucks ~ 1-60! ··--.,-- . . h?u·rsa Typical : Piceal!l~~ .. ·are~., .~ig, 12 Depth Hole ' · Casing Cement Formation I Dia cram " Mud Directional Subs;urfaee ·d:etails: MD TVD Size. Specs Temp Condudor I 60 ' 60 ' 24" 16" Fully Cemented None Vertical Bu il d @!I 3:5"/100' ~ Steel conductor set at 60'. to requlretf Fre sh Inclination 1 ·. -Provides structural stability of water based mud 12·1/4"1 8·5/8" I Full y Cem ented 11 ,, I ~ -loose material near the -r ~ Hold tangent In c I surface. ~ Steel surface casing set at Top 011~·m•nt 1· l :~;"'.,. I _ · 1, 700'. Cement is pumped l .soo· ~ ·;~ Fh"1,tr -'L .--between the rock and the Fresh I I ... casing, providing a hydraulic seal and protecting groundwater. Drop @!I 3.5"/100 ' ~ Steel production casing set at back t o vertical 7-7/8" I 4·1/2" I ~;...,l """i '-f I byT'!pofGas 7,100'. Cement is pumped between the rock and the j -:..w"''" · casing. This casing is what all · -. ·.: _ ._ · produced fluids travel through . 6,3oo'ls,9oo'I I i'ITJL I •. !1:1 1' I • , .1 ' , .,·. :tj:" ~ Directional drilling allows the . Rollins J 6,800' 16.400" •-• ' ' .. '. ' ' " ' -I •_ £ ' Hold ve rti cal I well bore to b~. placed precisely. Production 7 ,100 ' 6, 700' I I ' !}-,.>( I I I 200 " F I 10.0 PPB • • • la?ursa Di re·ctio lit al Drilling c ~ ~ ::I· D-j I I I j d1-'-' --+-~~-+--~+----l---+--" 1000 -1---~-t 2000 8 300{) ~ ..c. i ~~ - 0 ~ = ! ~ 50-00 1111---i--,_.__,--1------+-~ I ~ ' .= 6-000 -j 11-L...-J. -_..J !..,.. 7000-j ., " .l 13A-17-0i'-Q5. BHL sooo -J <J·o ,,1 .7311.1< -2000 -1000 0 10-00 2000 3000 4000 5000 Vertical Section at 36 .06° (2000 usft/in) 14 • -..J • ..J -ct: D • ·- Ii m·e .n .rfl :e~ / N,,oti'~i -'(::a 1t:i©;n 1 s 1 ~ .,. ·, 'I .~ ' .. •-. I -~-,- ; > Md.b.ilizatren :·betweenLpads: 1.5 days •· COGCC notification 2 days in advance • Community .. Counts notifi~CJtJon, etc. ~· ., . . "·. •.. ; -' .. . . > D<rill sur fi a·ce hole, run an ~:I" cement surface casing: l.s· days/well •:·. COGCC ,~~.o l ification 2 days in advance ~. Dril C p ~o.~l J i::tiGn hole, run and cement production casing: 3.0 days/well . . . ' ' . ··.,_.CQ .G'C:t notification 1 day..in advance . .. . > Typically dril.1 8-14 wells before moving the rig to the next pad •• . . • • ~ .. c ,·OMPLE"Jl.ONS· o.v·.E:·RVl ·~·W.· lli'ursa Wh.~t.:tlfl .·g '° b.e.~k~·i.s "Gorm.pleti.o:ns;?." • ~· . I • ·~ f' - ~ Wh .~.f~.We.·turn a:n isol·a-ted weHb.ore into a Pro,ducing asset ~ oi-,'p J~~ess otco.nr:iectl~g th-e w~llfu.ore to the formation -~ .,..__, __ __.._. • • • ·--• .. . . ' . . . la?Lirsa S. -. •.·•,· .... , .. ,. '· . ' ~ • • . I-.. , .. '_d t .' k ~·t'tl 'e h --. I " I (" ('· . ~--·-· .. ~ . . . -· -' . ., . I ,.. ' I -. -• . I . . • ev~.r-~. p rF ~·C:e ·s..sJ~:.S; Y!S.e -._: _9'. rri~i a e >~ .. :·· 11s _a-ppe.n. • ,-"' ,. _.,, t l • ~ ca·~~CJ I Hole, l((>:gg·i,'m.g:: to determin·e ~lr:9ducing 'intervals (Geo l,:ogy) and' ceme·nt to.p - ~ Pad P.-iiep·: lnstall. su_rface safety equi ,pment (frac valves), pressure tes t , inst_a1[ll water han·qling,_ permane.nt Production equipment .. ~ Per·fo·r:ating: .P'a_~cture .. the cas _ing at exact depths ~ . .. . . ~ ~y:d·raullc .Fracturing·-:-.. :lrid"u·ce fractures i;nto the· rock ~ Drillqu_f:_ :·:~Jt_il_iz~·:wp~k~ver rig to'. rem .o\/e frac plugs . . ~ G'ree ·n .·i=10Wback: "Return flU Jd:s to the surface at high rate • • '• ' -., ' .f • ~: • • • • I C:OM -PiJ.J~·Tl 'Q .. N·s: Q.VER\llEW· U?ursa Ca '.sed! _:fiJ ~rl'~! tolg~gj r n_g,:; r • . --• ~'i::..-·~ ... . . . . )-Use .d '·to.=d .etermi'n.e two. itppprtant -t~h1gs.;. -' ---'L ., ·-G 'eoJogv;-~ W .ll~t i_-~··sandstox1e, wh.at is.· .. oi.wdstone (recall: ILE!-rlticUlar st~~ked $,~ti!~s, th~ ~ag gf potat9 chips) ' ·~ ·we ~Qmplete tb ·~~ -~~~.r~Bear:i~g San~dst9_nes ·-r ' • , I~ -I~ • ) . ._ ·I' I ~ "' • • " L I : ... ·AvoJ~ tlfle:· IVl_udstQnes -_-·toQ ;d ·uctile~-nQt productive • To.p· oH:enlent: Nee.d: gOod ;cemeniforcfO:rmation isolatioi:i 19 • • COMPLE1 l"lO.NS~ OVERVl!E·W ,·- ----·--···-I_ - ' --;---·· I I -'-----·-1---------'>--<-------+---< -----· -· -' ·-'-·--' -···-- i -I. I -----.--:__ I L --·1 -~ :t ,_ ..L --~__..__+ I ' 1 1' I -· : I --1- '---~·-· .. _,_ ---------.--i:._: •· J --~--.--=-:---=-:-:-:~-+---=-·.:i,.::,:: ----·-+------+-- . :--+-----~--+----- 11370 TRAVEL TIME (usec ) 170 l ---------------------------------------1 -5400 Collar Locator 600 0 ; f o Gamma Ray (GAPI) 200 1 HALLIBURTON 6800 LTEN . 1 .. r 1 • , ='.~t~~~~~~r -=~_-;;;1~~ , I ·-1·-1 ·---~-±~.-':.;-_______ [ __ ~---1---- ---.. ---~-----'-7··· -~ - -I -___ , -. : _J -:t·.-L -:1.=_ ~-I -i _: __ --'-· ' -~--~: -~-- --' I I , I ., ' -" I \ 1 . ! . ._ -• --.,--~ \ -t I ! , ' --~ ---=--~ __ J :j;::_:, :.:L-:.:::~: __ :.. -;' --t----1-----i----'.-·r:-:-.:i1;· ____ ...., :----r=--:·--·--L : -:- 0 AMP AMPLITUDE (mV) 10 1200 (lb3000 IO AMPLITUDE (mV) 100 MAIN LOG SECTION 5" = 100' • MSG 1200 1 ' 20 • • '--" ,CO.MP.LEll,QNS .. O.V6]~~·Vl ·EW1 lli'ursa P·~·d ~ .p·r~·p.:; ' . . ' > 1n~t~lr;.Ft~(;) Val~e-~ (\~r:egsJ ~,. P~es.s~re.I Test. t _o ssoo · psi -'f .. "-.J -•. i" • ~ fr1~a1f water-handling eq!J_ipmerit .-."tiiliRl<-TANKS! - : . • • I •-" ,..J ... • •• ~ • .,_ < > lnsta·n··a,ur Perro~.ne.n:~ ·Prod ·uQtiQn 1 ~q :~ipm.ent > Pr~p.are fQr ~P~rforr~ting: t ·I M¥dr~~u:c Fra¢turrng Operations •• • -· .._ ., .... "1 U?ursa Pe rf o.1 rat :iin_1 g~; f l il.:l ~ .i , 'l . ...-- )-"Shaot" t:i ·ates: in, the ca:slo·g . ./ ~· ~ '\ ._ L · > Why ;:~_9l~s? Ag~·hil1.. th.iiJl:I{: ~~~_q:.~Jt:ectin·g" tHe . case ,~/cemented •)' '·' • ~· I . ·, ... , ·• f #" ~ ' I l ' wellb,ore ta:-tlJle ·, far'm.ati·o.e.s • . " ,~,'-;._ -..'"..;,, _..,, __ ,· .. l.(,;.,1 :.·r ,!' :_l ~~-.. ~-: .. J'·,~, ....... ~ ~ Shoot .· th .~; ~:~'~d~~:'a ~~)i.~;'t~.'~•'r,e(JstC>nes ' , ~ Perfb~a i'i d:H ,: d ·e ~tfi~·:a ~e ·:~C 9~i~l ~'.t ed: ~~ the "log ~ .. we can shoot withi'n 6"~.-·o:r-les·s, bf desired i':d~pth .. •I , -t > Also /we m·ay set a ternpa.r~~Y .Plug for lsolatio:n1 between -• • • -< •• stag~s -·to -be latet -'df.ilh~d ·~o·ut 22 c 0 . "' ~ ~ c 0 ·-~ ns ... cu . a. 0 till c m N •• • • . . . •. ' . h?ursa · HY.dra1 tJ r l i i i ~1 ~rae~u:~lng: );--Na~:'that: we h~,v~, hQI.~~' i@ , th~: €~~i 'og~'. wEi Cari :,produCe on ':j gas't:'~~terr .... 8~~.t~._the pathways~ a·re m·iriirtlal )-We ·:,m.:eed. to "Sth~l!ltt·l.·~ie .u, t 1he; F eser·v~i F ~· ~·h~~ ·is,, create. a pat.bWaJv~<lr al rl.:e.tWior1< tor~.oJt/ ga .s·._t · .. wa_t er ~.to : ti -1·ow trom -the forrtl ,~tl-c>.n ;._~tQ :·c~he W._e·~l~.~~¢~.·'·t~-~ t).~!,~~-~9~-~-t;~·.d. );--Purn·p High : v01µm~J High .:~r·e·s~U ·~~.· '11tate~·. 1:0 Jipen natural fractures ·. -·" · · ·· · , · . · • 'NO •P~oppa'1tn~eded 'in :B·attlement Mesa • .. Only th~ee additives fo . ih~. wa·te.r (< 0.6% Of volume): • • • • 1 ' • • • • . • biocide to neutralize naturally occurring bacteria ··: scale.'inhibitor. •· frictio .rn "redueer 24 • • C .OMP.t&Jl.ONS. o~ve·R\f'l6W' Hyd ::F~)~·IJ i i c.1 F ra c.t_~,1 ri i ng, ca1n1trn1u:ed b J " • I ' ·• : ~ • • > Its all l a boat. tfile 1.WAtER > s ~:-io ·.~t,~ges per w~U 1,. ·~l3.5 ~00Q.1 ~_bJ~. per we'll > 3,sod~OQQr + ~Sbl .~. p 'lJ_OJp.~~·i tt-·13attl.eJrl@tll Mesa ,v-ro -, ~ .. -~~ ,. ' ~, ~ .. , r _:: l. ..-.. •• li2'Ursa • · IV50% Fresh : Water:1 Fire ; frf ¥.d .rr ~.nt~,:·BM ·M ·etro D.istrict •·~ ·~~0% Recy~led i :F-~o ~! Fl.q .\M b~cw /.~Pf~.d lJttioo ·~,perations • 1/Jl.(ll :,Qf 1% o,f Col«).1ia.d'.o :.'f rr ~·$:h 1.wate .rr is used for oil & gas opera'thins -. ' . 26 ~.-~-~-•... . . .· . .~ . .. . ~. . . •i . ' ~-. . 1 ~ -~ .. '·· . ·~ t I • ~.· . . . . . . .. . : . . . C:OMPt~BTl .:O~.S . OVERVIEW O.ri 110::.u.t·: . ' ~ All '"~,t~ges ~ no.w .. ·perforated! a!nd l S.tim .ul1ated I ~ Ti .me tQ "DrillQ,~t" pl1:1g~ ar1d.1·~~d ~t.~bi.riJg >--T~iSjS,fh,e. fi ·oal ~QW'1tl.Q.l1~ oPeratioO · ··~ >--UtiUZes .Wci>rkoverJiig arlcl Ffowbcick Crew Dr.illout oper.ation on Speakman A Pad ~ fU>ursa 27 • ·-··-·· ,. . , . . . . li?ursa G re :.e.n ·:FH .o!wtiya .ck ·: .. ... . -... ,,.. ~ .. -. > Coinpl .~~Joos · are alm.'QS~' w.rragp.ed : up! ~ ; ... a ••" c ' > Flowback i.s flowing·-back th~1 _W.ell 1 ~.tJ:tery high :hii~ial rates. of gas and ·water • :.'pe~man~rlt Ptod~cti~n,:t!,g ,~ik'merit ' .j5,· no.t· SiZeCfta ' handle these 1.arge vol.umes · · • ·-.Instead·~, \Ne ; bti .~g:~=;a:m.,.la.'~g~';ri·t~~~ilPra r~; a·n i~.S : ~ nd . 24/7. on sit~ personnel · · · · -·· · · > W·hy· .. d~.~!they ... call' it:Green: ~lq .wba~k? ··,·Refers to secondary. low ·p~essure vaporcapture and combustion · •··CONVENTIONAL: .. :.iso ··psi "."> Atm· = Gas· is breaking out of solution, .and is vented • GREEN :: _ 180 psi -> 30. psi -> Atm =.Solution gas is captured and! thermally ·oxidized 28 • • ~ w ~ w > 0. "' z () -~ w ..J Q. :E 0 0 "'t'J ~ ca .c u c ns ~ c 0 Cl) .... ~ c 0 c 0 ·-.... ~ cu 0 ~ u ns .a ~ 0 -LI.;. c cu ~ (.!l • • OVe ra ill· t ·i1 rile ·l!"i"l'ITT!e.·: •• ' ' I L -' ~ ·• ' ~ • • ·• • ""1· I' ~ Ca .Sed H~ole ~oggi ·ng:: 3:,.4 d ~1ys . /.Pad I , , i ' 1 '"' ' I ~ ~ ' ~ Pad ; :fh re:p:: .. 7.,,14. dtil ¥S . / pad · · · ··· · • ai>Ursa ~ P ·eriQfafi:rig:::-:4 .:~[~1¥~,j WeU.;~ in ·¢0hjunction with • ' ... c f ·-I i --;. I • '' frat ' ~ : f' ,~ I , ~ , 1 • C '-~ • 1 , • : "I' ,_ ; ' ~ H.Ydr-aulit: FraCtudn.g:" 4 days"/ well . . . . . . ~ Drillout: · 1-2 days/well ~Gree ·n Flowback: .~2 ·wee.ks after final frac /'") 30 -.~ -___......._.---'~. ~ . :, . . '·. -'' ' -' . -.. ' , '. • ~ -l • . ,, • • ' • -~ • ' ' l-h • • COM,PlETl.O.NS -OVERVIEW U?ursa ·r·. h· :·1 :~n-·:·f1t ~ w ·/El d· A t~o ~-aln f·t:l ··d··u· ,lf"!t .. Q ·1 ·m· ·pact• • I .. ,:t).~• _:_J·~ -~~~· .'. lf"l~ ·~,' ·~ ~~~ .. l·' .•.. 1 \.-~ ,, • • . I . __.· -.. ' ~ ~ Da\f Hght Qpe1mfiorris · .. . . ~ R··;e··~·-u··. ced w 0 ek 0 n· ·d 1 a-1 c·-t~·1 ·v··1 ·t·y· ~ :.. .a . •I,• • ··.: ... /~ -~.:~'., .. ~ ·, • .: ··~ ... • • ... > _' :.' . . . -· ;.. • -=-'. ;_ •:._ ~ .--I -.I -.. ,_~ ':~..] :.... :;: • .' :: - : • • ·~ • • - ~ So.und w:a.us to-_reduce i:m,p,.gcc;;ts (no.i1se, light) ~ . t' ' ll . • I •. ~ Pro,p.pa:n~"less fracs .(less tfaffi:c, noise, dust, • ! Ji em 1iss.i:otls) . ' • •. OJ.; r ·~ ~"Green Flowback" -secondary vapor capture 31 • • • s: w --~ w > co r.n z 0 -~ w ...I CL. . :E 0 0 m ("I") ~ 0 .., u {! .., c 0 u + 0 0 M • • • DRlll.INGLCOMP·LE1'1:<1lNSft. HEALJr'IHi ·& SAFETY . ili'ursa > Conduct Pre ~Rig Move Meeting > JoJ:> Safety Ana..lysis conducted with contractors and visitors > Traffic Management > Inspections conducted for operational integrity and to ensure · compliance wJ ~h:·.necessary agencies > Site Specific Emergency Response Plan > Full listing of emergency and personnel numbers > D.riving directions > Desig.nated Haul Routes > District 16 Academic School Year > Muster Area > Specific direction for fire, well control, medical emergency, chemical exposure, severe: weather > fncident .Notification & Management Protocol 34 -..J ..J -a:: c LI} m • • • DRILLINGtCOMP-ILE::Tl:OJ~S:~, HEALTH .& SAF·ETY lli'ursa / ; Site Details: L~t' 39.'3333_, :"-... .... j ,, ,,_v .. ~ q r ,/ .~.­_,, ' ' / " ./ .. -.-., I -.I ,., Ji mxmml!tmi:ll!i ..... -.. ----... .!:~~~·~"":·~~ -.. : /.- -...... ,,..,-= .. . ,..... .. ......... ~ ..... ·~· -_; _,.--· .. - <Iii; ,. •• • : l ,, •• •• T . .:/ •"'r..,..•••• . . ····~ . _,, , . ' f_ .. 1,2,.; Olmi ,. I/ Haul RQute Map \\'J uoo Ranch 8 (Ex.it n) "·"ll.JS ·U...C1)3';l !l«-toon •r, ,.__,.7~R ~UWr.ot ,, Pad Location Approved Haul ROUie ~, ' -~~--- ~EF~ Oa!lt ?IT~" 36 - ·~ A~--== .!~- ' /-r~J -._ ~············ .. .•" .. ........... : •.. / i . . : : . ~4:. . ' -1$. ;.../ -·,_, mmimlltm:Om 5 /< ' ... \_, ... _ ~ -·~Mo ~... : .~ .... ~ : ............... .. . . . ~ .. ' .... {" ,../ . _,,,. _ _,,,-·~- u~ "~ '-. - Haul Route Map Wanon Rancb B (Extt 75) Jf•.l»l!l ·KlfCtZJXJ S.C:-1 7.~7.SNdl.~t!IW~ .•. Pad LocaOon ••• • • APPf'oved Hot~ Route ' o ~ ~ ~ 11-c--.. J.. .. ,-1 .. .-..... ... E-.f.04lfJ'lf 11----------j--j-I \!"!'/ ·----. ''-""' 0...2ft.l701' / • li?ursa 37 • • •• DRILL·IN 'G /C.'O~MP·:LE·1Fl :OJ~S:'-HE,~l TH i·&:sAi=ETY lli'ursa GARFIELD COUNTY SCHOOL DI STRICT NO . 16 2015·2016 S CHOOL l<""E.AR. File: ICA-£ ~'1r-~- CR.!IULC<'IB<fty-Han bbo-- ~-kn.S bto---! CR..&:JE.Q1150Ny-~ll)bt~ _,, Tuol!or~~&Wqlo4m ~n.w.n.ll.'1'1.11 ~~ Aiqnl?t.?1 i-at 'W~ k.q#ta.lf CFllDJiw'11"W'~--11 .... ~\l:'tt'"'•""'"""' Octiiblt'! Medn:nr -En?m.'!tt.;. <hDlrt M Cd..-cn -CfLiUE.C\'MSCJnit' -...... N...t.t.• ·-.. CVRSft~ ,_,.,.,.,., -.--al.-~0.,-.._m.c..., -... ... -1..a.w~ ~= JtlC!w~ Pil <:cramm-ODRtW.; MCo*mo-Cfl. SIE,C'MS~­ CYK'S ills.-.,, -----~--~ rni~d~~\sO!nml W:1n!Ulion r .. lllf d Sdall-~ ~, rnio...ttr&m ,.aaaa..........._ ~ alAl.D:\tf!!-ndl1' """'·"'""' """"°'""""""' ~~~ --l!Doy. ---_,, .. "' Crt.E.lE~m-aD.eyt-1,....._trds ..., .. -UlAIEC\tlS -• U. ' cws •• ,,.,. ~fN J l.dDly ~ll l MayD A-...~ Fnteiy ,...,...1 A--.~ l.11111:0., .bwt =[!':= ·~~=:~ttri.1 ~t ~~ C~'"Clttstl<!IK" IU)l.1 (\4:.»aAl -ApiZl ZOIS 38 • . DRILLING k CClMPLE1'1QN'S' -_ENVIRO.NMENTAL lli"ursa Manage 16 Ef)¥ironmenta l Program surveys, plans, permits, and inspections Air/Odors Noise Chemicals Rec l amation NEPA .-,_~··· · -~ .' -· ,-~=~Transportation . . Visual Resou .rces · -':: Waste _. }, 1'" Water Quality ·,... · ·. · Water Use Spills/Incidents/Complaints Cultural/Paleo Noxious Weeds Wildlife Water Protection Spill · Prevention );o-Manage all agency inspections, potential violations, corrective actions 39 • • DRILUNGJ'CO.MPLETIONS:. -· ENVIR0NMENTAL a?ursa );;;-Air/Odors -Drilling • ·'Equipment on location: drill rig, trucks, loader{s), etc. · • Equipment is in compliance wi1th manufactures' specs. • Odor complaint process in place to address immediately. );;;-Air/Odors -Completions • Completion Equipment and flowback · • Equipment is in compliance with manufactures' specs. • Odor complaint process in place to address immedjately. • Green completions includes: Use of carbon blankets on all water storage tanks Low emissions flowback process , Secondary vapors captured and combusted at 95% efficiency or better );;;-Drilling/Completions equipment is compliant with state/fed regulations );;;-County has performed air emission monitoring in Battlement Mesa with results showing decreasing emissions. );;;-Ursa has participated in CSU air quality study program 40 •• DRlll.ING: f ·Q.o,M·P .. LET.ION _S ENVIRONMENTAL l.i?ursa Drill Rig 1 'L·. . .... . Nitrous Oxide.s JL 4.6 I~ 28 ----~~ I "1 , J .~ .----.-----'!-~• ··;ra.;··•flF:l!!!!! ;··rm._.,..----~~'""""'°"':;A.;;;.,;;.-~~~~ .. ~-.·:;.."''~''"'r.; ••. ,.;....~•~ ~. Drill Rig voe Negligible N/A ·-Drill Rig · Green House Gasses Data Unavailable Completion Fluids2 voe 0.74-3.7 4 Completion Engines 3 Nitrous Oxides Negligible N/A Completion Engines 3 Green House Gass-es 217 35 1. Russell, J., Pollack, A., & Yarwood, G. (n.d.). An Emission Inventory of Non-point Oil and Gas Emissions Sources in the Western Region. Retrieved August 10, 2015. From !1t1.r:. t \VW1\:epa. g<~r.:, 1.t}Jchi.9 ·_: c.ont1:_t£!!£§. c1l 5/:"1CS:it0r: 1 ~. russelLndf 2 . Office of Air Quality Planning and Standards, US EPA. (2014, April 1). Oil and Natural Gas Sector Hydraulically Fractured Oil Well Completions and Associated Gas during Ongoing Production. Retrieved August 10 , 2015 , from 3. Emission factors based on or derived from Ursa's 2014 EPA Green House Gas Reporting. 41 • • • DRILLIN :G·.J' COM-P.LETl :ON:S !"' ENMIR .ONMENTAL 6'r'Ursa ~ Che·micals · -Dr _iJli'.ng . . . • DrilU_ng fluid i a·d'ditives r . ··.··Fuel for eq ~µiprrnent ~ ChemJcals\~--C_QrirlPl 1etion_s • ; t I .. • I p . , -., , , 1 ca 1 • • com:pletions chemicals, account.for only a small percentage of comple'tio.ns flu .ids : (IV0.6% of total volurne). ' '" ·-. •.· Secondary containrneif.lt used around tanks . ~-· Safety,· Data She.ets onsite for~erl :Y .(MSDS) • Proper Personnel Protective Equipment (PPE) and train ·ing for all personnel . . . •.Chemicals rep.orted through FracFocus and Sara Title Ill 42 • . -.. --~-·-:: ; : .. " ··. -~-. :.-.,-_ . .--_-_ -'~ -~ ··-:-.-.. ~' -~-·-:::---"' '"'.'~.~~~-c~~-~~....---,,-~:~-.,-~,'."----~·~~~...-,,-,...,,-...,..........,.,-.,.--. ~ .. -_·· " ~. '. .• . l • ,. • • ·: ~: -, • ' • .., •: ~ .,. r D.RILLIN:G .1' COMPLETIONS: ~ ENVIRONMENTAL lli'Ursa ~ ·Noise --Drilling • Equipment will cause noise, 24 hour ops -shorter term occupations {4.5 days/well) · • Sound walls used to help mitigate • Noise surveys completed regularly using equipment identical to state agency inspectors • Performed third party continuous surveys to identify noise levels and identify mitigation. measures where needed. • Lessons learned: timing of maintenance activities, material delivery, truck traffic, etc. ~ Noise -Completions • Equipment will cause noise, daylight operations with lim ited weekend activity 43 • • • DRILLING;.,[ C.'©,MP·LETl '.O~S E·NVIRONMENTAL U?ursa C OMMON OUT DO<>tt NOlSl: LEVf. L SOUNO LEYFl,S d8 I A I ·- um 9CI 6 0 70 f ' 0 0-.. ._ Dllyttnw so """"" 0 ..... , R~9-0 lllllid9_3~ V.C:Ut#n c-ft 10 ft -·l~M 3 ft Otoad<-.-.1 & R °"'~~ 3-lu • "' meaMJ..0 aJOf\O t ,,_ t.tt..-!Mtrl 2 ..,.._ rr-.... the onl'fttatwt e...s 6t "'9 ,_,...., 44 .• ~. -~-.._.--~-.~-\"'--·---. '<-:---·. . -·· ~ . ~· t .• ' ' -'" " -. ~J ~ , " ' ' ., . ; . , .. , -. ·_ . 'I .. , y .".. ~ .... · . . . DRILLING/" COMPL~TIONS1 --· ENVIRONMENTAL ll?ursa > Spills...;. Prilljng/Cotr1_p.letions • Fuel, equipment and drilling fluids -program in place to track and manage-:--includes reporting processes. > tncid·ent's/.C<:nr1plaints ~. Qr;illing/CQDJ.Pl 'etions • Program in place to track and manage. Complaints are addressed immediately and solutions or mitigation efforts implemented and communicated back to stakeholder(s). · •. CaUJohn · Doose, 9}70~379 ~0008 > Water Protection/Quality ...;:,.Drilling/Co-inpletions • 609 sampling -water well samples • 3178 sampling...;. public water protection •. See example of well bore diagram _ 45 ..... ~- ~ z w ~ z co • ~ > z ~ I V> z 0 -~ w ..... CL. ~ 0 u " ~ z •. ::; -~ -~ c • ~ l •• •• " • ". • -• •·•• _. • ~. • • ' •• , DRILLIN'G. f'. COMP,IJ,.J;'Tl .ONS, ~· ENVIRONMENtAL h?ursa ). Sto t ~water .. ~ Program, permits and inspections iA ~·p,1ace to manage ~ Traffh: ~ H :'&~S previously ad 1dressed ). VisuarEffects -D.riilling . . . ~ Lights are shrouded and pointed downward when and where possible ~ Capstar rig ~as reconfigured to· minimize light impacts ~ So ·und walls used ). Visual Effects -Completi·ons ~ Daylight completions only with limited weekend work (off Sundays) ~ Sound walls used~ equipment is typic~llY below sound wall 47 • • • 0R1L:t=1N :G'· t coMPLET1 :o:~s: .~ ENM1RoNMENTAL lli'ursa ~ Waste Management.~ p·J?lUing » Plan in place to manage waste .. . .. » Cuttings are hauled1 to a landfill for commercial disposal -no open pits used. ~ Waste t=IY1 ·~1:1a ·gement ~-~ Comp.letions ·» Plan in place to manage waste » Produced water and completions fluids are recycled and reused (field wide) when and where possible » Water lines transport large volume of fluids -significant traffic reduction ~ Wildlife -Drilling/Completions » Plan in place developed witb Colorado Parks & Wildlife 48 • U?ursa ~ Remember to fiU 0.ut questio.rlnaires: w :itlrl concerns, comments or topics t .Q. address ,in future meetings. Next meeting; )-.Wednesday, Sept~mber 2 ··.: Operations -.;fhe,.·ProductiotJ'Phase • ·· Regulatory related Health Impact Assessment questions (HIA) John oo·ose, Field Landman 970.329.4390 d .irect 1· 9:70.379.0008 cell ' jd_oQse@ursaresources.com 49 • • • 0 '--""'. .Welcom.e lli'ursa > Welcome to the 5th of 5 community focus meetings • Update status of Phase 1 in the P.U.D. • Update status of operations outside of the P~U.D. > We look forward to continuing to working with the Battlement Mesa Community and . addressing concerns:,_. • At the sign-in table. -Number of questionnaires received to date: 06. -· Number of community meetings over the past 2 years: 50+. -Future Battlement Mesa Meetings (Monthly/Quarterly, please provide feedback). -Initial oil and gas development plan submitted in 2009 by Antero Resources. Documented public record. •· Contact John Doose at any time. ~ • John Doose, Field Landman 970.329.4390 direct I 970.379.0008 cell jdoose@ursaresources.com • • 2 ' ,. Com,~~~":1-,·it~y.: Me.e~i,_n:g.I -S·'c;lfte.d :u ~le ' ~ Moriday,·.:Jiine 15 •· . Geology ·of th'e· Piceance Basin ., , Basic .orientation, including PUD locations ~ MOnday; July 13 • (J)verview of Comprehensive CJevelopmen f: Plan • Battlement Mesa/PUD permitting process • Operation phases and proposed schedule •· Regulatory/Environmental related permitting questions ~ Monday" August ~ _ • · Operations ~·The Constructlorf Phase .. • Regulatory related Health Impact Assessment questions (HIA) ~ Monday, August 17 • ·.· Operatibns -·The Driliing an-d ·'Completions Phase • Regulatory related Healtf:l Impact Assessment questions (HIA) ~ Wednesday, September 2 • . Operations -The Production Phase • Regulatory related Health Impact Assessment questions (HIA) U?ursa All.Meetings 6:0Q P•.m_. t. B~ttlement Mesa/Grand Valley Fire House •. 3 Jc)'day's M:eeting lli'ursa > Meeting Objectives • Comprehensive Development Plan Overview • Review previous community questions (John Doose-Landman) • Special Guest -Eric Schmela -(Special Use as pertains to the P.U.D./Authority to drill) ., Status of P.U.D. Permitting (Rob Bleil -Regulatory and Environmental Manager) • · Operations Schedule -Foreseeable (Matt Honeycutt-Operations Superintendent) • Keynote: Production Phase & Ops, Health, Env. Concerns Wrap-up • Production Operations (Shane Vaughn -Production Superintendent) • Health & Safety Concerns (Tara Mall -H&S Manager) • Env i ronmental Concerns (Dwayne Knudson -Sr. Environmental Specialist) • Phase I Summary/Wrap up , • Community concerns summary (John Doose) • Operations summary (Matt Honeycutt) • Health and Safety summary (Tara Mall) • Environmental summary (Rob Bleil) • •• • 4 PUD Cori11 prefi ·~nsive _·o··~velo-p ·ment ·P.l ia·n aP'ursa IA~ 1 1 •ni.:¥. 1 :·:trtmu;RI 1n I'. ll l'R~~ t 'i!"-""-t:'"-'11>1"-t'lt ;-..· ,.. .. <,,• ,,, b< Hc1to:1111""ed ,\tk:b i.-itcnld~ r r.~ n n·~) - ,.,,,,~1 ...--1 F'-t-'i...-7 <"wTf~klnrl=?lr.Jt.:t~·l1 ~nn J::i ft~'l~ ~~~~.r.r 'D~·<J<-..,.'14"·-=·· FIO CTl."!c •<==r~. l. Ptpeltoo S~·Jncn~ROfrlQUl.$t.C<l 4 f'All~ In to!\ ·~~ 1 ·~"'"1 1 ·,,,:i , ::J F...J. 1:. ~""' EG·.•ti ·, ... t.wJ c ~ .. SJ "'n II> :::r o g_ ~--0 !!!. :T !I' CJ '° -~'~ i 5 ' ;J r ~I'll 03: •1 --· ~ ..... ·..-..c . "· ---~·1 r 0 ~· ' '' ' --~.=.!I ,.. ...., 0 '.?.:•iii ID ltl X fi?Ursa CllP.i'JlNG (Ofv1P,\'iv r ... "iA 1 ~1 "-1 ·,.,-e .. ~s.-~ :C11..:r co ~xt'U b l~~hJ Battle1nent Mesa PUO PH.a.SE 1 & TOMPKINSi RIC HA R DSON PIPELfNE SEGMENT UR S.~ OPEP.ATI NG CO MP.ANY. LL C ·4~· I '""li -/1110 ...,, 1 __ .... -... -:I &. g tii 11?~2 -~ .y (!) n. ~~ 3. 0. :.: :t> fl> '";;J ti.)~. S) - "'O ., . ~ t:l ~-;J t.l'I -... ~ :3 II> 0 :--t8 CX l l lOIT A 5 \ ~ p;u o ~ Go 1nt·pre .h ·e·rifsiv~. Dev-~lop.rn'.enrt . Pian i.i?ursa FA'C:r .. Sheet -Development ht PlJD •I • . \, )-V\Je~It Pads (5) ~ B1MC AJI , ~:M :c: ·B ~ BM .c :·o, ·s-~c L, BMC M . . I . , , ~ \ ~ I ·. .. ,.,· -_~· . , ' . . )-Wells )-App'roxrmately 19'7: wells to f b.d[y,-'~l.rill the PUD ' . , )-Te date 56 :·of 19.;7~· {·28%) Wells , ·arilled"from outside the fl'LJ :[) ' ' ' ' . I . )-j\:p-proximately 103, of 197"•(52%) wells will be drilled from'· .outside the P'tJ D '. . -· ... )-All . locations inside the PUD are pursuant to the c ·ommunity Development Plan 6 • B1attle·me·nf M:esa 1 Per~mltth1g Status· __. PU :Di. Phase I la?ursa ______;_ BMC .. B & BMCJJ: Pads ~ County Permit submitted -June 22nd ~ ·County Notified all Parties that the Permit Application is Complete on August 13th ~ Planning Commission Hearing September 23rd in Glenwood Springs ~ COGCC pending submittal -Early October Phase r P·ipeline ~ County Permit submitted -June 22nd ~ County Notified all Parties that the Permit Application is Complete on August 13th ~ Planning Commission Hearing September 23rd in Glenwood Springs Tompkins Pipeline ~ County submitted -July 1st ~ County Hearing held -August 17th ~ Town of Parachute Watershed Permit Approved August 20th -,_ -· 7 \....._.,/ Cur~e~t\0 .perath:>ti's·: S1cheduu~-: ~-Fo:·r.eseeable la?ursa ~ Well· ·pa·a Constr.'t1ctio·m·1:: l~ronument Ridge B:-pad under construction'.-~Began ~Sept 1. Afil \ticipate 4-5 weeks. ~ Drillif:l·g.:. Currentl .y .-ri"~ drilling ·a·.€tjvity. ~ Ccim .. pJe.tj'~m$~ ,Watsorf.'Ra nch a ·-~-ri n ish ihg completions, • ·-' ' •• I • . trarrsi .ti.6n to flowback. Yater completfons .. to begin September 5th . .°13 wells to be completed -through .November. ~ Pipeline: Currently no construction activity. • • • .. 8 PRODU:GTION QV15.RVIEW' Pre ~p··r.oa11etio ·n ~' !i ... II. )-~eyiew ~uJ·· Permits/COA's/Specific Requests . .:. . ~; . . ' )-Parties involved:-,, Safety~ O:pera 'ti·ons, Regu il1a_to-:r:·y/E.ri¥i 1r·o·nme -ntal, . _. ~t)f'it:ra.et¢>-~s, On:~·s ·iite Su p·ervisors. )-Notifica:t:f©ns: ·· · . - ~ -; ' . ' -. ~ -c~ m ITTi .w :r:lit~i Co~ nts/.EA:l3 local residents . . Local Agencies .____ __ I. • aP'ursa · 9 .._.:, PRO ·D .tJG;:t:·l .e>·N ~ O\f.E~RV-1 EW at>ursa KEY ASPECTS . .. . ·-. ·' 1 ..... -' )-~very pad · is rnonito:fed 2;4/7 by automation including flow rates, pressures aYrit 8 t~·l nk levels. Alarms are sent out to o,perators in·1 case an y-'~i·pset con ·dition occurs .. > bperatO t svisit eaG ijS l:t e every day cOrlducting routine , .. •·· ~ 1. j-• J I mainten ~ance and · inspections C>.f all production equipment and pad cohd~ti 1 ons ~· optimiz·ing we ·11 ~·:performance and managing ·water/1Q.H \-producti0n b\{_scheduling trl:Jcking or.pumping. . - )-Field 'personnel continuously monito.r 1atmospheric conditions for hydrogen :s_ulfide or any other harmful· organic compound. If anything is detected U_rsa has ·procedures in · place to mitigate and remove .any hazards to any health or environmental concerns. • • ~O . 8 j j u -0 • WELLHEAD . " . • . : ' ' ' . ' . ' ' il&Pursa .: · Gas (w/water & oil) delivered from the wellhead to Separators via "flowlines" • Each wellhead is equipped with automation equipment to monitor all associated . pressures 24/7. (tubing, casing and braden head pressure) .12 SEPARATORS La?ursa Separators break out water and oil from the gas. The gas gets metered and then flows to the custody transfer station. Water and oil is sent to the production tanks via flowlines. .13 ~') PRODUCTION ' TANKS : . ' -- ' ' ' ' ll&Pursa • • · Minimal volumes of product are ~ contained in the tanks until either hauled off by trucking or pumped out via water lines to be injected in injection wells or to be recycled in -well completions. Specially engineered containments are installed to contain a minimum of 150% of the largest tanks capacity. •· Each tank battery is equipped with PRV's {Pressure Relief Valve) and thief hatches that meet or exceed all agency requirements. Windsocks are utilized to monitor wind direction for safety purposes . .14 €0MBUSJIORS ~ :., ' . ' U?ursa •' Combustors installed to control excess emissions from tank batteries. •· 98% or greater emissions reduction, which meets or exceeds CDPHE requirements. •· Combustors are equipped with electronic ignition (auto lgnitors) systems that monitor run time and ensure the pilot is burning at all times. 15 I\ • 0 ~~-~• l'njectiori Well Tanks and Containments 62'ursa •: Water that has not been recycled for Completion Operations is pumped through a pipeline, or trucked to the injection site, then offloaded into the tanks. • Level controls {high/low} are in place to eliminate spills. • Visuar checks are performed . ~very offload , and inspected by . pump operator. •-· Tank battery and surroundings are kept clean and secure. • Tank batteries are designed to contain 1.5 times the largest tank capacity (same as production sites). • Water is then drawn from the tanks to the injection skid. . 16 • lfij~ctiorf P'ump-house U?ursa t.0 _........._•~~~--~. ...___.. ____ _ • Water brought into the pump house, where it is filtered and injected. • Produced water is injected down the tubing string into the permitted injection interval"'6,S00-7,000 feet below surface. • Skid meets and exceeds resolution 35 standards. (Strict housing, electrical, and mechanical State regulations and County codes) • Fully insulated to assist with sound mitigation, outside temps. Fully automated controls with safety and emergency shutdowns • Staffed -and checked often. • Injection Skids/Facilities help by cutting down truck traffic. . 17 •' ~-~ --..---- .. ~ ~~~• Inside of lnjectiort Pui'r,ip Hculs~' ·-Cl¢an,' Ql)iet. U?ursa Pumps are engineered to be extremely quiet, virtually no outside dB changes during operations. •· Quintiplex {5} compared to older triplex pumps {3}. • · Automated warning systems - pressures, temps, shutdown controls, etc. • Ensure that all facilities are kept clean, organized, and spill-proof. • All injection facilities are under 24 hour Surveillance!!! 18 • P.Ro·D'UCJrl '()"N : • H :EAL~TH ! & .. SAF~TY li?ursa > Job Safety Analysis conducted with contractors and visitors. > Traffic Management. > Safety i"nspections are conducted for operational integrity and to ensure compliance with all agency requirements. > Site Specific Emergency Response Plan. {SSERP) > Full .listing of emergency and personnel numbers. > Ddv_ing d·lrections. > Designated1 Haul Routes. > District 16 Acad ·emic Schoo·1 Year . > Muster Area. > Specific direction for fire, well control, medical emergency, chemical exposure, severe weather. > Incident Notification & Management Protocol. •' ....______ ' 19 :c I- ~ <( w ::c I z 0 -~ 0 ::::> c C) 0 0:: ~ 0 N • • • PRO·D.'.UGTlON -H;EAb TH &. SAFEi·TY Site Details: lat: 39.43313;5 Lano: -t <M."23363 .............. . ....... ~ . . .. . .... --.. • :·1 ..... ti • ,.._ . . . . : ... . . ... is.... ...:t'··· ........... . .._,, ~~,.. "' ... .. ;-·-... ·~········ . . . . ·· . . . . . , · ..... _, ,._.. ... _..,_1',.E:tiln .... t .. •S....Olr9')'111! ·~---! .. --~ .... ,· 1 ) I i _ _,,,~ -!.....- ---·-'" Q ~ .... J .. lf!:03mlm:mll ID ' ..... -.. .....__ .. , :~~~·~~~·.-:-. -: .z .. • •••• r1-..... -.•·· ..,,--. - /· fi?ursa 1 ;_·:,:~ Haul Route Map Wauoo Ranch B (Exu 71) lt •J»3' -ffifll'!')XJ Sfto-*'"l7,10wtw,.7 ~1f.~"Wftf .·~ Pod Location • •• • • Approved Haul Route 11 Oft '.t,l<lt,_ •' ~'-_ __.._,....-~":.,, U?ursa 21 \___; P'R 0 ··1r>.tJ 'Clf l:O·N - • H;f!A.L liH ~ & s ·A.F:ETY ~== ~ ~::." " ,/ ............... \ •" .. ·.......... : { J . . . : ~4: . . • I -~ . ./ ............. , --\..... ... __,., : rnnmmmllm : ; .. :·: : ~· ,,,.-,':::'1"-'1.. ~.,_ ,_ -·. . . ......... ., /'' _/ .. -... -.. ' -~_.,,--_ (;~ ... , ... .... .... ...... ~Ursa ·'"'"" ~ ('"\V''"""' Hau• Rout e Map Watson R.aocb B (Exu I;) J!OJJ.l.'.Klf01:JJIJ S«b f1 ~7Sotl!'i.Rlfllt.1",,W ... r·: Pod Location ••• •• Appfoved Haul Route " .... (i.) 11 ... c-.~ ... 5 .. .,_ I I """"""" E, Four '=" .. ----· ... -.... : ·-. I U?ursa 22 • .• , ' ~-~---~ GARFIELD COli'N TV SCHOOL DISTRICT NO. 16 2015-2 016 SCHOOL YEAR File : ICA-E ,,,..,.i..n.y lhr.ZS·lf-~&'t• Dlt.n-hn.1-.,_.6tul ,,._,. __ ..._""'..,. O.W.• -· ..... ... "U.trr fet'~ CR.6UE.C\'lotSIJoty-"-""'- ontid ..... Mews b •~ CR.BIJE.C\'llSDoo,·lblrsl>bo-- -n Ty!m,.,,,,,~&Wqlodm ~Tl.U.J1.f .. 1'J1 ~~ .,,.,. .. ,, , _ _,. Augolll!S.zt CFL----_,, .. '%=.:.~._,-°""""' ""~-.w. °""'*' M~-CR.~C\'llSOnfJ- ~ .. -·,. -· -· -· -" .......,,,, _,.,. ..... ..... .\;rill ""' """ G\ll<S!o-1-w-, --Cll.~r~Doy-.:........=..... r.-W""°"f -----1--Pn~-OMitl W'~t m~-CR.llUE.G\'llS~­cwsinSrubl ---=::-..._,.~ ... Cf~S-.aDl!ys •. Miy a ~· " - .... ~--CftllYVC\'6 -•~· t...min•fttt Uol(Ory ---0.,. GWS-nDly:r -u/..,.ZJ -· ~==u.ti!!l -!MIO., ~'"CitH r:I JN ... _ .... Z1.ZI!! -· --~l """""" 6-..IUir-iD Tt K.S...bll • lloJ•<-..U U?ursa 23 G PROD:U.'.GTl.ON · ~ ·eNVIRClNME,N1TAL U?ursa Manage 16 Environmental Program surveys, plans, permits, and inspections Air/Odors Noise NEPA Visual Resources Chemicals Reclamation . Transportation Waste Water Quality ·.·_':.·':: .. Water Use Spills/Incidents/Complaints Cultural/Paleo Noxious Weeds Wildlife Water Protection Spill Prevention )-Manage all agency inspections, potential violations, corrective actions ... • • • 24 p,R:oou .c ·11€lN ~ .• ENVIR:ONMENTAL. U?ursa ~ Air/Odors • Emissions from tanks are captured and combusted on location. •! CDPHE air permits required. •· Combustors are standard equipment on all Ursa Battlement Mesa locations to achieve 98% or greater emissions reduction. voe 8.54 51 voe 0.6 4 25 PRODUCTION I --ENVIR(lNMENT'A(!; lli'ursa ~ Air/Odor Continued ~ Table below shows uncontrolled emissions compared to controlled emissions {current technology/processes} ~ Pipelines.transport a large majority of fluids reducing the emissions substantially. Reduced traffic accounts to "'25 tons per year (equivalent to 150 cars annually}. Monument Ridge (16)=·~ voe · ~ so 2.5 ·- Speakman A (24)------~ voe · 111 8.54 Watson Ranch (12) voe u 1s 0.73 Yater (8) voe ·-. · ·:-_·.. · 12 0.6 • ~ -· -:. -·~ -"' .. ' .. ' . -~ ·, •. :...'." • u ~ ~•r:..,, '1~ •• >i. _; •. ~ r f 'Ul r: " . -•-lo-1, '> .elt-."rL-. •· .•. •••• ..--#•" -<-~ ~--•· •• L --h • 26 o ta tile O rg e nds Benzene Garfield County Annual Average Trends 0 .9 ~~~~~~~~~~~~~~~~~~~~~~~- '> 0.8 ---t,'11-------------------------1 .0 c. 0.7 .!; c 0 .6 i 0 .5 :: c 0 .4 ~ ~ 0.3 0 0.2 0. t ~,,_~~~~-....,,....~~~~~~~~~·~~~~~~~ ,_ .. . ·-I 0 a -... , ,I. l & -n .. ,. 6 ..f n m ... .,. I '.+-Ir i,' 'F d Carbonda le 2008 •2009 •20 10 1'1 2011 t'1 2012 *:20 13 et 2014 ff 0rm :a'l1d·ehyd ·e = .Ur1ban a1n\d ·0 1&G 'Related ·C' ~1 ·Ar'~1 rn;,.} .. 1mr\r ·"'»i:-:"• > ..0 0.. .9: c 0 ..., .,, ... c Q u c 0 0 -1,.__<}ur.[i"ld County ] c ·o s Benzene= Urban and O&G rel·ated (HA·P) Formaldahyde Garfield County Annual Average Trends 1.8 . "' -~----·-------~----~--------.-..---.... - 1.4 ~ ,, ______________ . 1-2 -- 1 - 0 8 • 0 .6 0.4 02 0 -- 2008 •2 009 0.2 01 0 Q 2011 "'l 2 01 2 JI 2 01 3 0 2 014 .... ca ny Significant downward trends sho~ ~n blue (5 years required to calculate ~nrl ) PRODUCTION -ENVIRONMENTA~ U?ursa ~ Air/Odor Continued ~ Table below shows vehicle emissions, pollutants and annual emissions anticipated. {30,000 -50,000 cars in 24 hrs. pass through Battlement Mesa on I:-70) Vehicle Type --------·--------------------- Passenger Car 1 ~-. -~ --- Light Truck, SUV 1 Heavy-Duty Truck2 --------·--~------------·-· --------··--·-·-------~--------------- Pollutant NOx, CO, and Hydrocarbons NOx, CO, and Hydrocarbons "'"'ri"""ri"' ""'l"f'ff -S."t- N Ox, CO, and Hyd roca rbo ns Annual Emissions 295.25 lbs. 372.13 lbs. 0.0323 lbs. per mile 1. Office of Transportation and Air Quality, US EPA. (October 2008). Average Annual Emissions and Fuel Consumption for Gasoline-Fueled Passenger Cars and Light Trucks. 2. Office of Transportation and Air Quality, US EPA. (October 2008). Average In-Use Emissions from Heavy- Duty Trucks. 28 • •• • ,. PRODUCTION ~-ENVIRONMEN'TAL >-Colorado Department of Public Health and Environment (CDPHE) new Regulation 7 requires: • Leak Detection· and Repair (1!.DAR)'. This regulation requires operators to use Approved Instrument Monitoring Methods -(Infrared Camera). ~ Forward Looking Infrared Radiometer inspections involve a camera . •· Storage Tank Emissions Monitoring (STEM) ~ STEM inspections are required frequently and are conducted by the pumpers. G?ursa 29 .Lj PRODUCTION :.;;. ENVIRONMENTAL; fi?ursa ~ Ch :e.rnJcals tJ ised ! du:ri ·n'g1:·prc;id t Jcti ·o:r.1 ·+n£1ude: • Biocides • Scale/Corrosion inhibitor •· Foaming agents (To help deliquify wellbores) • ·"P:rod ll:ct;io ·n ·"ch·:em~icals used : ·.onsite are inside ··.c. '• " .::::, I. ".: secon~ta ·f.~ Cbil ·tc=.i ii,h:rrient .. a 1 n .~ clre inspected by . ~ . ::'. ; t .. ·~ .• .. -·i...· > .. ~ ·~ ... s. .:... ~~. ~. • •. ' • . -. PJJm _p~rs qany. • • 30 -.;-·~-~T~<-~-·---· ,; PRO'DlJCTlQ·N. ~-E-.NVl ;R.QNME ·N:TAL U?ursa ~ No.i:se • , I -. ' 11 ' ·~a ,Se'd €H1 su'rv:eys, no.j.Se iS · the ~' lowest of any of the fol.Ir phases {cbnstruc.t.i'on:, d_ri~~:ing, completions, di "·· ··· . )-, . ' . pro· u:c-tr~tt .. . . ' ... --;;"-... ;;. ___ ~.::. •· WfH:~:n ryecesS~fr'y;· equi~lil':ent f?affling, smaller sound walls ahtf 'straW bale. barti~rs are options used to !· • -.• •• • m:itigate-· agai :~st equ i prne:nt . noise. · -·---~·-~----· ~~~~-~~-~•------·-.31 ...J ~ z w :E z 0 a:= -> z w I z 0 -...... 0 ::> c 0 0::: ~ • • p,ROD ~lJGTION : ~--. ENVIR€lN :MEN .TAL U?ursa ~ Reclamation • 0, 1 • Once the location is in production phase and wells are drilled, it will be put into interim reclamation and later final reclamation. •·~· lfnterim reclamatioh is when the sloped are pulled back and the operating area is reduced to a tear drop typically.. •: ·if·rna ·I reclamation occurs once the wells are Plugged and Abandoned. lihe location is re-contoured and seeded. ~ Noxious Weeds . ; . • Weeds are sprayed and managed bv a ttiird party expert. Sprayings are typicplly 3 times per year. Inspections and monitoring occurs frequently. 33 PRo-o ~UGTl 'CJ.N : .. 'ENMl ·RO "NMIEf.J 1TAL U?ursa ~ Spills •· Ursa has a spill management plan. •-·All spills are reported to Ursa (not just agency reportable). • Spills are tracked and reviewed for lessons learned. • Findings are shared with contractors during the Bi-Monthly meetings. ~ Water.':Pt.ofe'cztibn/Quality • Stormwater permits/plans in place include Best Mgmt. Practices. •·· 609/317B sampling programs in p·lace include periodic sampling of wells and water .features . . . . • ·Special Containment Protection· Near Public Water Supplies, Water Wells, Watersheds, Floodplains, UMAs, etc. • Wells and Flowlines are periodically tested as per the Agency requirements (MIT--Mechanical Integrity Testing) . •• • • 34 PRQI~lJ'CTIO'N • ENVl ·RONME:NTA-L U?ursa ~ StormV\fater ' -. -~ ... ~ Stornt water pertnits in place. ' ".' ~ -.. ., ~ l ~rfspections are co··rri -~··1 '¢ted regularly With repairs completed J. c . ~ • • • as necessary. ~ Traffi "t: .. ·1·' • Tr ucks vs. -water lines. ~ vi·sual -Effe'cts • Vegetative buffers, low profile tanks, mounding are emp19·yed to. minimize effects. 35 P-RO ·D.U.GTION _ • E:N1VIRQ'NME-N :TAIL fQ'ursa ~ Waste'i Management • · Recycle produced water. m. · Injection wells I water lines. ~ WUdlife ~ Plan··. in place develope~d with Colorado Parks & Wildlife . • • 36 PROElU.GTION • ENVIR.ONMENTAL fi?Ursa )-ltrci ·d-ehts/Co·trfplarnts _. I • •·· Ursa takes a=l1I incidents and complaints seriously. Please call if a !nything~ out of the o·rdlr.i ·a-r\l occurs. ALlk -CONCE~R=N ·S =-l ·:~~OM.i PLAINT~ are ad :dressed, ~-. . -... --~ tracked and !.' .. re:s·pon~~·d·. to irilm·ediately. ALL .LANDOWN ,E·R.CONCE'.RNS SHOU.LD BE DIRECTED TO John· Doose 9 ~7,Q-379-000.8 37 • z 0 -~ 0 ::> c 0 0::: a.. (\.· V) c 0 ·-....., V> Q) ~ Cf 00 ('(') • • • p,HAS:E ·1 !~S·~lJ .MMARY .~ .P'AS·:T _5, ME:fi.TINGS U?ursa ~ KEY CO.MMtJNlTY CONCER·.NS (JOHN UJ(J(l,SE) • 0 .1perati:ng i8side tt:le p~ .. u· ... D. ~ OPER··AT:l:ONS. (MATT .HONEYCUTT) ' . • • 1 Constrticti0h, Qti:IJrng, Compl'e .tiens, Production. ~ HEA·bl"H :. &. SA.FETV ·(TA~A MALL) • ...; II ) -::' I~ ;· ,-" '. • •·-Haul : RoCi.ltes ·,·-·cemmunity Safety ·Co~cerns. ~ R'EGULATORY / ENYIRONMENTAL (ROB BLEIL) • _Environmental .Concerns Addressed in the Health Impact Assessment (2011). ••••• \..,,r ....._......._·. 39 KEY . C'"C):MM iUNIT-'f CCl"N .G'ERNS U?ursa ~ o ·rilli.ng~ iii'; :the P~u ~o.-:.why here, why nowi -W.hy these locations? • •· Battlement Mesa was built as an energy community in early 80's. •· GA .RCO authorized Oil & Gas Development ,'under 1982 Resolution. •· Ursa has an obligation to our mineral interest holders to develop our gas resources. •· Ursa has an obligation to our investors to develop our assets. •· Locations were reduced from 14 to 5 and are located based on ability to reach bottom holes. . . • Alternatives were considered and some locations were moved outside P.U.D ·. · • · Considerations include proximity to homes, golf course, haul routes, watersheds, water supplies, provisions of the Surface Use Agreement, visual impacts, air quality, noise/odors, prevailing winds, short-term vs. long-term potential nuisances . • • 40 OP-ER"ATIONS· SUM "M"AR-Y' (1Past 4 .. Presentatia11s) U?ursa » €onstruction • Timing dependent upon project. • Mobilize equipment in and out -traffic considerations. ~ Seeding occurs during construction phase. • Dust suppression (gravel, fresh water, mag chloride) hours of operations, special considerations. • Three Phases of Reclamation. •; Temporary -during construction. •· Interim -after drilling and completions. • Final -after production phase of operations. » Drilling • · Mobilization between pads: 1.5 days. • Drill sutface hole, run and cement surface casing : 1.5 days/well. • Drill production hole, run and cement production casing: 3.0 days/well. ~ Typically drill 8-14 wells before moving the rig to the next pad. • Noise mitigations, light mitigations, special considerations, hours of operations. 41 OPERAJIQNS1 ,SU '.M ·M~R·'l: U?ursa )-: · ·ca·mpletions • Cased Hole Logging: 3-4 days I pad. • Pad Prep: .7-14 days I pad. • Perforating: 4 days I well, in conjunctior:t with frac. • -Hydraulic Fracturing: 4 days I well. •· Drillout: 1-2 days/well. ·- • · Green Flowback: "'2 weeks after final frac. •: Noise mitigations, lights mitigations, odor mitigations, special considerations, hours of operations. )-=·.·. ·Completions Water ·Use ~ 8-10 Stages per well, "'135,000 Bbls per well. • · "'50% Fresh Water: Fire Hydrants, BM Metro District. • "'50% Recycled: From Flowback I Production Operations. • · 1/10 of 1% of Colorado fresh water is used for oil & gas operations. • • • 42 • .,.. ...... ~ O:PER:ATIONS · . .'SW 1 MM~R·Y U?ursa ~ J>ro.ductio·n •. ! t \;.. • • , Average WeU l life =.,2·0 ~ 30 !years. , • :! • ' -._ •· Dail¥ traffic co U!nt s. =~ t .i:;ickli~; trUck, ±-2 trucks per pad I . per we:ek. ' •-Au fb matfon/mq .~ile mo·nitoring. ,• .. ., ;, ..,. • 1 • Operators on pads daily. •! .odor rlli.tigation,:s,pecial consid 'eration-s, hours of operations. 43 0 '\, H EALTf.I .~&:. s:AF1ETY ::c"t\JN :C~RNS·· StJ 'i M :MARY U?ursa ~ Haul Routes and Traffic M ·anagement! • Ursa contractors only encompass designated haul routes approved and implemented by the B.O.C.C. and Garfield County Ro~d and Bridge. D.epartment. • Ursa provides notification of upcoming operations that may include the utilization of oversize/overweight commercial vehicles and pilots to assist the potentiall,y affected area/residents to Community Counts, GARCO Road and Bridge and GARCO Oil and · Gas Liaison. Included in the email are maps of all designated, approved haul routes with turn by turn directions that our contractors will encompass. • Ursa's Health and Safety Manager stays in direct contact with Garfield County District 16 School Bus Transportation Department to ensure all OS/OW operations stand down during school bus operation hours. Do to the proximity of the Grand Valley Middle School and current construction operations, contractors have been advised and are cognizant of additional bus activities including field trips and athletic bus activities. • During high traffic operations certified traffic management and engineered safety measures are staged throughout the approved designated haul routes to assist affected residents and passers-by with safer travels. · ~ Driving Safety: • Ursa utilizes GARCO Sheriff's Department and/or other certified law enforcement agencies to mitigate and manage unsafe driving practices being conducted on Garfield County thoroughfares. We value and support their ability to legally utilize their discretion and we support their decisions{s) for violators of all engineered/implemented traffic management processes associated with Ursa's operations. • Ursa has a "Zero Tolerance Policy" for employees and contractors operating a passenger and/or commercial vehicle in an unsafe manner. Once verification of the concern{s)/report(s) are verified, immediate actions are taken. • All Ursa employees and contractors operating a passenger and/or commercial vehicle have in their possession their primary state of residence state issued driving credentials. All operators of commercial vehicles have a C.D.L. (Commercial Driver's License). • • 44 R,EGtJLA:TO 'R,Y CC>N -CERN :S SUMMAR-Y U?ursa ~ _Oil and Gas one of most heavily regulated industries in the U ~S. ~ Provided a Crosswalk of arl Agency Requ'irements (15+ Agencies/Divisions). ~ Discussion Ursa's 16+ Environmental Programs {ISO 14000 approach). · ~ Discussed 40+ notifications to agencies, landowners and the community (required) and Ursa voluntary meetings, etc. to include Community Counts, GarCo EAB, COGCC NW Forum, Battlement Concerned Citizens, etc. ~ Discussed the potential impacts by operations phases and Ursa's compliance -structure to' comply wit~. regulations ... and BMPs. (Best Management Practices). ~ Met the spirit and intent of the Gav's Task Force on Community Engagement ~ Agency officials have attended meetings {COGCC, CDPHE, CPW, GARCO). ~ Discussed in detail' potential environmental concerns and the number of plans, actions and inspections required to conduct business within the PUD. ~ Per Mr. Sura's letter (6/15/15) submitted on behalf of Battlement Mesa Concerned Citizens, he acknowledges the number of mitigation actions already in place through regulations, technology, Operational SOPs, and mitigation BMPs. -~------------• -'-~~-~ .. ~-.. -~=-- 45 REGULATORY CO'.l~!CERNS~. SlJ 'M :MA'R·V. la?ursa KEV ,LAWSi;':Re'Cii\JtAfll°t)l\~ls,:·APPLICABl~E .fiQ~BAiFliLEMENT MESA OIL AND GAS OPE .RAf°li)N-S: ~ ... D Clean Air Act (air emissions sources) D Clean Water Act (floodplain, wetlands, stormwater, SPCC, etc.) D . Colorado Oil and Gas Conservation Act (surface/mineral extraction) D Endangered Species Act (Wildlife and 1 Plants) D Federa ·1 Land Policy Management Act (federal minerals/split estate) D Fungicide, Insecticide, and Rodenticide Act (weed Mgmt.) D Migratory Bird Treaty Act (protected raptors/other species) D National Environmental Policy Act.(fed minerals/split estate) D Noxious Weed Act (All listed weeds by state and county) D Resource Conservation & Recovery Act (all oil, gas industrial waste) D · Safe Drinking ~ater Act (water supplies and injection wells) D Superfund Amendments/Reauthorization Act (SARA Title Ill) D County and Municipal Land Use. Codes and Ordinances (land us.es) -'~~~• •• 46 • ENVl ·RQ~MBN ·TAL co·NCER:NS'! 'StJ :MMARY U?ursa KEY ISSUES:· Traffic, Odors, Noise, Emissions (TONE) & Visua l, Water based on Health Impact Assessment (2011) All potential impacts are addressed ht Ursa's Environmental Program Plans and Operational p~ocedures to1 mitigate in accordance with all Federal, state, county and municipal regulations. Air/Odors ~ Construction -primarily dust managed with suppressants and _ graveling roads/pads. ~ Drilling -engine emissions/minimal if any odors (short-term}. - ~ Completions -air pollutants managed by Green Completions/odors managed and tracked (short-term). ~ Production -air emissions managed through Leak Detection/emission monitoring/infrared inspections conducted by third party. CHEMICAL MANAGEMENT ~ Drilling/Completions -Chemicals used for fracing reported/disclosed through Frac Focus and annual reporting to the state and EPA. 47 E-NVIR:Q~MEN 1JAIL co:NCERN 'S·· s·uMM1ARY REClAMATION/N0~10tJS WEEDS ~ Construction -temp and interim reclamation (short-term). ~ Production:..._ interim reclamation/weed management (long-term). la?ursa 48 • .. ENVl'R .. ONMIEN 1J .Ab-CONGE-RNS·.s~uM :MAR~v 4U'ursa STORMWATER/WATER PRQT;ECTl .ON AND. Q~ALITY. ' . ~ Construction -sediment associated with dirt moving equipment. ~ Drilling -potential impact to water supplies mitigated by multiple layers of casing/cementing program·. (conductor, surface, p r oduction casing strings) ~ Completions -potential impact to water suppl i es mitigated by state of art technologies, continual monitoring during the completion processes - pressure and pump rates, any abnormalities are reported immediately per COGCC rules/guidance. ~ Production -potential impact to water supplies mitigated by production tank liners, steel rings, remote monitoring and shut in equipment, tank alarms, operators conduct daily inspections. SPILL MANAGEMENT , · ~ All operational phases managed under state and Federal regulations and Ursa's spill plan to protect soil and water. ~ Ursa responds to, mitigates and tracks all spills including those not agency reportable. .49 E·NVl .RClN ·1 MENJAlb _,C!_O ·Nc·E.R~N ·S SUMM~·RY U?ursa ' SEISMIC AC::TIVITY POTENTIAi:: > Extremely limited based on ,geology/fault structures in the Piceance Basin. > Several county/municipal hearings and presentations have been held. INSPEO"FION/INCIDENT PROG .R.AM > Ursa conducts agency mandated inspections for air, SPCC, stormwater, flowlines, etc. > Ursa conducts voluntary site inspections at higher frequency than required by regulations. > Ursa's incident program · captures and tracks responses to complaints, nuisances, etc. > Ursa has conducted over 3000 inspections YTD in 2015. > Agency conducted inspections= 98 YTD vs. 110 in 2014. > Ursa is in good standing with state agencies. CDPHE performed a Battlement Mesa Field Wide inspection in April 2015. WILDLIFE > Potential impacts to sensitive/game species managed by timing restrictions. > Potential impacts to game species also managed in accordance with Ursa's Wildlife Management Plan in consultation with CPW. • 50 ENVl :RO:NM:E~N !TAb c·oN-CER-NS1 S'tJ.MMARY U?urscl · ALTERNATIVES ANALYSIS )-Impact analysis. initiated in July 2014 based on 5 pads in P.U.D. )-Ursa discussed key tools for alternatives analysis (SO+ criteria) _in previous meetings to include: •· Geology Evaluat.ions • Ability to reach bottom holes outside/within P.U.D. • Reducing number of pads/pad footprints by maximizing wells per pad. •· · Land Assessments • Lease rights, agency setbacks , lease and property setbacks and existing easements . • Landowner preferences, community concerns to reduce disturbance and nuisances. • · ·operational and Safety Assessments • · Pad size, topography, cuts/fills, access roads and facility layouts. • Haul routes and traffic. 51 • Environmental Site Assessments • Air quality, noise, water wells, public water supplies, wildlife and noxious weeds. NOTE: WCC/BCC Presentation on 8/31 showed Ursa's Site Assessment (July 2014). NOTE: Current COGCC setbacks of 500 to 1000 feet are based on COGCC study. ... 0 •. \:: ,· _\:'.:: t ·: 1' ~ ..... _ • \i j_, "'. ' •• • ' I • :ii f t,: ENv1RONM,E°NTAk _c:i6:N,GliRNs SUMMARY U?ursa IMPACT ANALYSIS (KEV CONCERNS) ~ Potential impacts: existing background conditions and activities, time, space, size of disturbance, duration, weather, season, existing human medical conditions and behaviors, etc. ~ Many HIA issues are outside of Ursa's control: vehicle emissions, STD's, enforcing speed limits and are therefore are not addressed in this summary. Air Quality-Has been Improving in Garfield county over past several years despite increasing well density. Garfield county is in an "attainment area" for EPA primary air pollutants. Minimal cum~lative impacts would be anticipated based on all air ·sources from industry, residential development, municipal · and commercial sources, gas stations and vehicle traffic. Odors -May occur during completions and production operations, which are generally short- term. These are mitigated through: green completions/flowback, water treatments, carbon-fiber blankets and other operational practices. · All reported odor concerns are addressed, tracked and followed-up 52 ~~----·· • ENV·IR:QN iM'·ENTAb. C.CJNC·ERNS SU .·M·MARY IMPACT ANALYSIS Noise/lighting··;.;.. Concerns are primarily during the evening hours. Even when noise is within permissible levels, it may still create a short-term nuisance. Noise and lighting concerns have been primarily associated with drilling and completion operations. Ursa has implemented various mitigation practices to include sound walls, hay bales, directional lighting, equipment baffling, etc. Noise and lighting pose minimal nuisances once the pads are in the production phase. Ursa is currently conducting background noise surveys in the BM community, and has made changes during operations to reduce noise potential. Recent background studies ht.Battlement Mesa indicate a range of 24 -69 dB (with NO URSA ACTIVITIES). Win~ direction and distance a key variable. All reported noise concerns are add.ressed, tracked and followed-up 53 & ENVIRONMENTAL ·c ,ONCERNS· s:U1MMARY lll'ursa IM PACT ANAll-V.SIS ~ater : Ptotection -Protection of water resources to include public water supplies, water wells, floodplains, wetlands is heavily regulated by Federal , state and ~unicipal agencies. Throughout the U.S. industrial and commercial facilities are located adjacent to major waterways due to commercial transportation, In Colorado, hundreds of well pads are located within watersheds , floodplains and in close proximity to water supplies. In the area of Battlement Mesa, dozens of pads are located within these same areas. Due to the sensitivity and proximity to these resources, enhanced and aggressive BMPs are mandated by regulation and permit conditions. Very few incidents have been recorded given new technologies for drilling, completions, and production practices. Concerns have been expressed with the BMC B pad ... next slide ~ .• • 54 " • •• • . ". .. ENVIRO:N M'E.N·lAL C©.;NCERN.S'. Sl J..M .MAR·Y · ·n?ursa IMPACT ANAtYSIS Traffic . .!.. Traffic analysis is a key component of the county permit. Traffic associated with construction, drilling and completions is a concern when moving heavy equipment to and from the locations. These impacts are short-term and consider haul routes that minimize disturbance to communities and ensures safety. Traffic during production typically doesn't required larger vehicles, with the exception of an occasional workover rig. Pickup trucks are typically used by operator pumpers to visit locations daily. However, remote telemetry reduces vehicle traffic through remote monitoring. Fewer vehicle trips associated with hauling fluids/produced water are possible through the use of pipelines that move fluids between well pads, and to injection wells. These practices reduce traffic by up to 90%, as compared to conventional_ · water transport methods. ,. • ~··"' ,_ . ~ ,,. i, • '°'.,t •/.· r,, _I] T :·.: 1 J _, • "' _ E·NMIRO'NM ·E'NTAL CONCE·RN ·S. S:tJ!MM :AR:Y· U?'Ursa IMPACT ANALYSIS Visual 1·mpacts .. ~ Visual concerns associated with drilling and completions are short-term while the drilling rig {associated lighting), completions ' equipment and sound walls are being used. tonger term concerns are associate_d with separators and production tanks. Concerns will be mitigated through .the use of mounding, native vegetation and l~·ndscapin -g that will shield the production equipment on the BMC D Pad. No ·visual mitigatioA is proposed for the BMC B-. pad based on its location and proximity to adjacent development. •)ii • • • • r : •. • ! .. r •·•· \ " • • , 1 ·~ • . . QU .ESl];ONS.t? . . , •. • n?ursa ~ Remember to fill out questiohnaires with concerns, comments or to.pies to ensure all issues have been addressed. ~ Garfield Cou:nty OJ the Colorado Oil and Gas Commission can be ·contacted for regulations,,_. requirements, public comment opportunities. ~.-.Ursa's contact for any additional information regarding Ursa's . ·Comprehensive Development plan is: -j()'h-.n · o·o·ose,I F~eld Land -man 970 -.3-29.~4390 · direct·, I .'9 ·70~379.0008 .cell . ' jdo()se@ursaresa.urces~com 58 EXHIBIT .. I 1:< URSA RESPONSES TO BATILEMENT MESA HEALTH IMPACT ASSESSMENT {HIA) "Colorado School of Public Health " {Feb 2011) NOTE : All referen ces to Antero changed ta Ursa . s Meetings Content : 6/15 -Geology 7 /13 -Regulatory/Permitti ng/Ops Overview 8/3 -Constru ct ion Phase 8/17 -Drilling/Completions Phase 9/2 -Product ion Phase ~.1 Findings and Specific Recommendations from Air Quality Assessment • Video Link HIA Reference Asse ssment & Recommendations GARCO Appl ication Agen cy Comments Presentation/Comm u nity Mtg Date All links located on Battlement Mesa Services Association Number Reference Page Number Yo uTube Chan nel www .youtube .com/channel/UCH89vs82WUL8zK_e6x09_gQ ·-· 6/15 7/13 8/3 8/17 9/2 Prior to approval of Special Use Permit (SUP), Colorado School of Public Health (CSPH) recommends BOCC require Ursa to : Garfie ld County and Ursa have been partici pating in the CSU ambient air qua lity An effective demonstration would show that leve ls of air pol l utants, such as benzene, as measu red in 24-hour ambient stud y . Air quality has been shown as improving in Garfield County. In additio n, 1 air samples at 350, 500, 1000, 2000 and 3000 feet and in each ca rd i nal direction, from t he well pad perimeter, are not N/A CDP HE new CDPH E Regulation 7 now requ ires both Sto rage Tank Emission Monitoring v v 8/17: www.youtube.com/watch ?v=r6pypD61kFg (STEM) and Leak Detection and Repair (LDAR) plans. Ursa implemented both of higher than those measured at the Battlement Mesa monitoring station. thes e plans months in advance of the effective date of January 2015. Inspections are co nducted routi nely at each well pad. •Standards Analysis (SA) Pg 5, All c ~.e mica l s are disclosed within 90 days of fracking operations, which consist of Disclose al l chemicals that will be used on its well pads within the PUD. We recommend GARCO to keep a list of these 7 ,10 99.5 % sand/water/proppant mix. Ursa discloses chemicals used per COGCC 2 COG CC regul ations on the FacFocus website, also via annual EPA Tilte 3 reporting . In the v v 8/17: www.youtube.com/watch ?v=r6pypD61kFg chemicals on its website and/or on a publicly accessible website approved by the Battlement Mesa Community. •Emergency Response Plan (ERP) even t of a health issue, the COGCC regulations r equire immed iate disclosure to the a p propriate medical professionals. Establish a system for immediate response to odor complaints that includes options for ceasing operations, notificatior •Impact Analysis (I A) Pg 6-7 Ursa h as systems in place to respond to any type of complaint including odors, 7 /13: www.youtube.com/watch ?v=4390N r 69y9U 3 of affected residents and temporary relocation of residents until t he source of the odor is ident ified and resolved . We •SA Pg 13 NA noise . lighting, etc . The community is updated on the status of activities via v v v v 8/3: w ww.youtube.com/watch ?v= HZKOch hj h08 encourage Ursa to communicate the timing of well completion activities to Battlement Mesa residents, which could •SPCC sever31 channels including community meetings, Community Counts, Energy 8/17: www.youtube.com/watch ?v=r6pypD61 kF allow for voluntary shutting of windows and air intakes or temporary relocation . Advi so ry Board (EAB), etc. Submit a quality assurance project plan (OAPP) to GCP H and GCOC for review and approval for al l monitoring specified Ursa has several plans and systems in place that address monitoring of all issues 7 /13: www .youtube .com/watch ?v=4390Nr69y9U 4 in these recommendations to assure monitoring information will be adequate for informing public health decisions N/A All v v prior to any activities in the PUD. includ ed in the HIA . 8/3: www.youtube .com/watch?v=HZKOchhjh08 As a condition of the SUP , CSPH recommends that the BOCC require Ursa to: I ' •Project Desc ri ption (PD) Pg 1, TherE> are currently no plans fo r a centralized water storage faci lity. However, 5 Complete the installation of a fully functiona l water storage faci l ity and water pipeline network prior to any drilli ng 3 COGCC/ Ursa !1as insta l led severa l water l ines around the PUD, to date, that are v v 7 /13: www .youtube .com/watch ?v=4390N r69y9U within the PU D to realize the full ai r pollution p r evention benefit. GAR CO asso c iated with injection wells. Additional water lines wi ll be added to reduce 8/17 : www .youtube.com/watch ?v=r6pypD61kF •Pipeline SUP traffi c, odo rs, noise and a i r emissions. Use pe r mitted tanks rather than a pond at the centra lized water storage faci l it y . See recommendations fo r Water and COG CC, No centralized wate r storage fac i lity is p lanned. All o n pad tanks requ ire 6 Soil Assessment for further details of w ate r storage fac ility recommendations. N/A CDPH E, perm itting through the COGCC, CDPHE (air emissions), and depending on v GAR CO volun.!e, Ga rfie ld County. 7 Use an effective and validated low emissions flow back process for all well complet ions within the PUD. •PD Pg 7 •IA Pg 7 COG CC Ursa h as t his in place as a standa rd ope r ating practice. v v 8/17 : www.youtu be .com/watch ?v=r6pypD61kFg 8 Route production tank venting emissions through a voe combustor operated with auto-ign ite rs on all well pads within •IA Pg 7 CDP HE Ursa 11as this in place as a standa rd operati ng practice . v the PUD . •SA Pg 13 - 9 Use vapor recovery technology w hen available, rather than combustion, to further r educe air pol l ution. •IA Pg6-7 CDP HE Emis si ons reductions ar e managed in acco rdance with the Air Pe r mit. v v 8/17: www.youtube .com/watch ?v=r6pypD61k Fg Obta in an emissions permit from CDPHE for eac h well pad production tank within the PUD, per COGCC rules. The COGCC r ules require pe r mitting for production tanks within Y. mile of an occupied structu r e with the capacity for 5 ton per year of voe emissions, which is the case for most of Ursa's proposed well pads. Our recommendation may be •PD Pg 5 10 beyond the COGCC ru le at one or two well pads. This recommendat ion is nec essary, however, for the protection of •I APg6-7 CDP HE Ursa '1as this in place as a standard operating practice . v v 8/17: w ww.youtube.com/watch ?v=r6py pD61 kFg public health because odors have been noticed up to Y, mile fro m the Watson Ranch pad. T he Y. m i le dist a nce in the •SA Pg 10, 13, 17 ru le is not based on a health-based ai r pollution standard, and the permit p rovides a mechan ism for t he establishment of inspection and m onitoring r equi r ements. Wo rk with GCP H to implement an air monitoring program for all we l l completion activities w ithin the PUD and at the •I A Pg 7 11 cen t ra li zed water storage faci lity. At a minimum, this program should include collection of 24-ambient air samples and CDP HE See r esponse to HIA #3.1.1 above. v v 8/17 : ww w .youtube.com/watch ?v=r6pyp D61kFg grab samples, real-time VOC mon itoring, odo r monitoring, and coi1ection of grab samples when odors are noticed. •SA Pg 13 Annua l ly disclose al l chemica ls and volumes used on its well pads within the PUD and include any chemica ls that are •SA Pg 5, 7, 10 12 voes in the ai r monitoring program. We recommend Garfield County to keep a list of these chemicals on it s website COG CC See r-e sponse to HI A #3.1.2 above. v v 8/17: www.youtu be .com/watch ?v=r6pypD61kFg and/or a publicly accessible website approved by the Ba t tlement Mesa Community. •ERP Implement the system for immediate response to odor comp lai nts that includes opt ions for ceasing ope r ations . I ~ Implement a system for notification of affected residents, and temporary relocation of residents unt il the source of thE •IA Pg 7 COG CC/ 7 /13: www .youtube.com/watch ?v=4390 Nr69y 9U 13 odor is identified and reso lved . We encourage Ursa to communicate the timing of we l l completion activities to •S A Pg 13 GA R CO See r esponse to HIA #3.1.3 abo v e. v v v v 8/3: w ww.youtu be.com/wa t ch?v=HZKOchhjh 0 8 Battlement Mesa r es idents, w hich co ul d all ow for voluntary shutting of windows and ai r i ntakes or temporary 8/17 : www.youtube.com/wat ch?v=r6py p D61k F r elocatio n . Page 1 " -- 3.1 Findings and Specific Recommendations from Air Quality Assessment HIA Video Link tReference Assessment & Recomme ndations GARCO Application Agency Comments Presentation/Comm unity Mtg Date All li nks located on Battlement Mesa Services Association Reference Page N umber YouTube Channel Number www .youtube.com /c hanne l/UCH89vs82WUL8zK _e6x 09_gQ 6/15 7/13 8/3 8/17 9/2 Make all air monitoring results within the PUD publically availabl e for posting on the Garfield County website and/or a CDP HE/ See r esponse to HIA 3.1.1. All ai r emission monitoring and records are required 14 publicly accessib le website approved by the Battlement Mesa Community, no later than 60-days following the N/A GAR CO by the CDPHE. Air emissions monitoring results are availab le on the Garf ield " " 8/17 : www.youtube .com/watch ?v=r6pypD6lkFg collection of samp les. Coun t y Publ ic Hea t h website, also. 15 Comply with COGCC green completion pr act ices and EPA 's natural gas STAR progr am to reduce VOC em issions to the •IA Pg6-7 COG CC/ Ursa compl ies with the requirements of the regulat ions r egarding green " 8/17: www.youtube.com/watch ?v=r6pypD6lk Fg lowest level technica ll y possible at al l well pads within the PUD . •SA Pg 13 GA R CO com pletions Elect r ical power will be used on the BMC B pad o nly for elect r ic pumps if an 16 Spe cify where in the PUD Ursa will use electric grid power for drilling and/or other operations. •SA Pg 3 NA inje ction we ll is deve loped on t he pad . No electrical power is required for the " " 8/17 : www.youtube.com/watch ?v=r6pypD6 1kFg BMC D pad. Once the pad has entered the production phase, all electric needs will b e provided by so lar power. •PD Pg 2 •Reclamation Plan (RP) Pg 4 •IA Pg6-7 COG CC/ Du st and traffic control measures are incorporated into Ursa's standard 7 /13 : www.youtube.com/watch ?v=4390N r69y9U 17 Adhe re to dust control measures and traffic measures specified in t~e Special Use Agreement. •Fugitive Dust Contro l Plan CDP HE/ envi ro nmental and health and safety practices, which meet or exceed the " " " " 8/3: www.youtube.com/watch?v=HZKOc hhjh08 (FDCP) •Water Supply Plan (WSP) Pg 1 GAR CO mea su res in the Surface Use Agreement and PUD Resolution . 8/17: www.youtube.com/watch ?v=r6pypD61kF •SA Pg 1, 5, 13, 17 •Traffic Study (TS) 4-203 .L Establi sh and implement a plan that ensures all trucks used for its plan within the PUD meet emission standards All vehicles used by Ursa and its contractors comply with vehicle emissions 18 specified in the Clean Fuel Veh icles (heavy trucks) fo r the Clean Fuel Fleet Program (CFR Part 88 .105-94) to reduce VOC N/A NA sta nd ards. In addition , emissions asso ciated with truck traffic will be further v v 8/3 : www .youtube.com/watch?v=HZKOchhjh08 PAH , and PM emiss ions . Th i s wi l l reduce air po ll ution in the PUD. redu ced thro ugh t he use of wate r lines and i njection wel ls. 19 Pr eve nt th e idling of trucks on well pads and al o ng road s in the PUD for longer than 10 min ut es. N/A NA Ursa Nill encou r age contract o r s t o turn engines off when not in use , or when v v 8/3: www.youtube .co m/watch ?v=H ZKO chhj h08 app ro pr iate, depend i ng up on the sco pe of w o rk bei ng perfo rm ed. -I ~ 20 Ensure truckloads of dirt, sand , aggregate materials, drilling cuttings, and sim il ar materia ls are cove r ed to reduce dust N/A COG CC/ Tru c ks tha t are not cove r ed and create dust, etc. shou ld be reported to Ursa . v 8/3: www.youtube.com/watch ?v=HZKOchhj h08 and PM em issions. GAR CO CSPH recommend that the BOCC: Assign a county i nspecto r to monitor Ur sa's compl iance wi t h t he special use pe rm it and that the special use permit COG CC/ COG CC and CDPH E have significantly increas ed t hei r insp ection staff. In addition, 7 /13: www.youtube .com/watch ?v=4390Nr69y9U 21 N/A Ursa conducted over 2000 inspections per yea r , ave rag i ng an i nspection at each v v v contain provisions for regulatory action if Ursa is found to be in non-compl iance. CDP HE locatio n at a min imum of every t wo we eks . 8/3: www . yo utu be .com/watch ?v= HZKOchhj h08 Ass ign an independent obse rver acting on their be half, to participate in the demonstrat io n of th e low em ission flow There ar e sufficient and robust CO GCC and CDPHE air regulat ions in place tha t 22 back tank described i n re comme ndation 1. The independent observer wou ld be responsible for confirming samp le N/A COG CC acco m plis h t his objective . Ursa has odor management SOPs in place i nclu d ing an " v 8/17 : www.yout ube .com/watch ?v=r6pypD61k Fg locations and timing as we ll as monit o r ing fo r odo r s. The independent observer w ould co ll ect grab samp les if odors arE noticed during the demo nst r ation for eva luation of possible short-t erm peak exposures. imnh 'dia t e response and t racking of the com pl aint. Finally, CSPH strongly encourage Ursa to: Assign an independent observer acting on thei r beha lf, to part icipate in t he demonstrat ion of t he low em ission flow 23 back tank descri bed in recommendation 1. The independent observer wou ld be respons ible for confi r m i ng samp le N/A COG CC See response to HIA 3 .1.22. Note t hat odors don't necessarily constitute locations and timing as we ll as monitor ing for odors . The in depen drnt observer w ould collect grab samples if odo rs ar E exposure or air em issions health r isks. noticed du r ing the demonstr ation fo r evaluation of possible short-term peak ex posures . • Page 2 URSA RESPONSES TO BATILEMENT MESA HEALTH IMPACT ASS ESSMENT (HIA} "Colorado School of Public Health" (Feb 2011} NOTE: All references to Antero changed to Urs a. Meetings Content: 6/15 -Geology 7 /13 -Regulatory/Permitti ng/Ops Overview 8/3 -Construction Phase 8/17 -Drilling/Completions Phase 9/2 -Produ ction Phase 3.2 Findings and Specific Recommendations from Water and Soi l Quality Assessment , Video Link HIA Reference Asse ssment & Recommendations GARCO App li cation Agency Comments Prese ntation/Com munity Mtg Date All links located on Battlement Mesa Services Association Number Reference Page Num ber YouTube Channel www.youtube.com/channel/UCH89vs82 WUL8zK_e6x09_EQ 6/15 7/13 8/3 8/17 9/2 As a condition of the SUP, CSPH recommend that the BOCC require Ursa to: 1 Dis close all chemicals that will be used on its well pads within the PUD. •SA Pg 5, 7, 10 COG CC •ERP See Response to HIA #3.1.2. v v 8/17: www.youtube.com/watch ?v=r6pypD61kFg •IA Pg 2, 3 COG CC Rule 908 doesn't apply to wel l pads, but rather centralized E&P waste •Natural and Geologic Hazards 2 Characterize the ge ology and hydrogeology within the Battlement Mesa PUD and the primary and secondary domestic Assessment Rpt (NGHAR) COG CC ma nagement facilities, which are currently not planned within the PUD . v v 6/15 : www.youtube .com/watch?v=hi9uwHf8w3Q water supplies, according to the specifications in COGCC rule 908. •SA Pg 4, 10 How ever, Ursa does characterize geology and hydrogeology as part of UIC 8/17: www.youtube.com/watch ?v=r6pypD61kFg •Figures Site Assessment Map perm itting in accordance with COGCC regulations . Submit a quality assurance project plan (also known as a QAPP) to GCPH and GCOG for review and approval for all 3 sampling and monitoring spe cified in these recommendations to assure monitoring information will be adequate for N/A COG CC See Response to HIA #3 .2.2 above. v v 8/17: www.youtube.com/watch ?v=r6pypD61kFg informing public health decisions . Complete the installation of a fully functional water management facility and water pipeline network prior to any •PD Pg 1, 3 In sta llation of a water management system including buried water lines co- 4 drilling within the PUD t o decrease potential of contamination of soil and surface water on individual well pads and •Pipe line SUP lo cated with gas lines was implemented in 2013. Several have already been v v 7 /13: www.youtube.com/watch ?v=4390Nr69y9U decrease potential for truck accidents to contaminate surface waters and soils in case of an accident. installe d to support locations outside the PUD. Before approval of the SUP, CSPH recommend that the BOCC requ ire Ursa t o: Com ply with COGCC rule 908, which pertains to non-commercial central ized E&P waste management facilities, for the centralized water storage facility, which will be handling E&P waste (i.e., recycling water used in well completions). Oni of t he best ma nag ement practi ces Ursa ha s proposed for it s Battlemen t M esa project is a cent ralized water storage 5 pond , which will allow for pit-less drilling on the pads, the recycling of water used in well completions, and reduced N/A No cen tral E&P facility is proposed v v 7 /13: www.youtube.com/watch ?v=4390Nr69y9U I~ potential for water and soil contamination at the well sites. We have recommended that this facility be installed prior to any drilling. COGCC rule 908 requires permitting, a hydrogeological characterization, groundwater, soil , and surface water testing for centralized E&P waste management facilities. Use permitted tanks, rather than a storage pond for water storage at the centra lized water sto rage facility. While tank~ No cen tral E&P faci lity is proposed, and production tanks located at the well pads 6 are not required by COGCC, the use of tanks reduces the potential for water and pol lution that could occur if a po nd/pi N/A will be used, in combination with wa ter lines to move water; hence significantly v v 7 /13 : www.youtube.com/watch ?v=4390N r69y9 U liner was compromised or if a pond/pit overflowed. Tanks also have the added advantage of reducing air pollution and minimize truck traffic during the production phase (following drill ing and reducing inadvertent wildlife and pet exposures . completions). Locate the ce ntralized water storage faci lity be located at least a mile from any residential st ructu re or sc hool as a 7 condition of approval of the special use permit. This is because the water storage facility will be handling E&P waste N/A No central E&P facility is proposed v v 7 /13: www.youtube .com/watch ?v=4390Nr69y9U (i.e. recycled water from well complet ions). Annually disclose al l chemicals and volumes used on its well pads within the PUD and include any chemicals that are •SA Pg 5, 7, 10 8 voes in the water monitoring program as a condit ion of the special use permit. We recommend Garfield County to See Response to HIA #3 .1.2 above v v 8/17: www.youtube.com/watch ?v=r6pypD61kFg keep a list of t hese chemicals on its website. •ERP Install at least one up-gradient and two down-gradient groundwater monitoring wells at each we ll pad as we ll as at t he centralized water storage facility, in addition to the vo luntary water well testing program specified in Ursa's best management practices . Ursa should also conduct baseline sampling for, at a minimum, the following: all major cations •SA Pg 5, 7, 10 COG CC/ COG CC allows the use of existing water wells to sample within 1/2 mile of the 9 and anions, tota l disso lved solids, iro n, manganese, nitrates, nitrites, se lenium, benzene, toluene, ethylbenzene, •ER P locatio ns. URSA has a monitoring well program plan t hat incl udes water well v v 8/17: www.youtube.com/watch ?v=r6pypD61kFg xylenes, methane, pH , specific conductance, and any chemical identified in the ful l disclosure of chemicals of potential •Monitoring wells N/A CDP HE samp li ng in place, w hich includes COGCC and CDP HE reg ulations and COAs. concern . This monitoring will ensure that drill ing, hydrau lic fracturing and ot he r operat ions do not compromise ground water. Conduct monthl y mon itoring of the wel l site groundwater we ll s fo r the parameters specified in the proceed in g recommendation during well drilli ng and completion activit ies, fo llowed by annua l monit oring for the du ration of Ursa's project. All resu lts of this monitoring shou ld be made available to the public within 60 days of samp le collection COGCC allows publ ic information, including water wel l sampling results to be and posted on Garfield County's website . If (1) benzene, ethylbenzene, toluene, or xylenes are detected at levels posted and distributed to the public via their website. This information is also 10 greater than the concentration levels specified in Table 910-1 of the COGCC ru les; (2) any cations, anions, metals, or •PD Pg 1, 4, 5 COG CC provided to t he affected landowners in accordance wit h COGCC regulations. Ursa v v v 7 /13: www.youtube.com/watch ?v=4390Nr69y9U total dissolved solids exceed 1.25 times background concentrations; (3) methane or any chemical identified as a 8/3: www.youtube.com/watch?v=HZKOchhjh08 concern from the full disclosure of chemicals exceeds 1.25 background concentrations; or (4) if pH or specific has a water qua lity program, which includes tracking ana lytical resu lts received I t conductance exceeds the limits specified in COGCC tab le 910-1, the BOCC should require Ursa to remediate as a from certified laborat ories. condition of the special use permit. This type of monitoring is the best way to ensure pollution control measu res are effective in prot ecti ng t he groundwat er reso urce . Page 3 3.2 Findings and Specific Recommendations from Water and Soil Quality Assessment HIA Video Link r.eference Assessment & Recommendations GARCO Application Agency Comments Presentation/Community Mtg Date All links located on Battlement Mesa Services Association Number Reference Page Number YouTube Channel www .youtube .c om/channel/UCH89vs82WUL8zK_e 6x09_gQ 6/15 7/13 8/3 8/17 9/2 Conduct baseline soil and surface water testing at all well pad locations and at the location of the centralized water Baseli ne water sampling is conducted at all well pads prior to drilling events . See 7 /13: www.youtube.com/watch ?v=4390Nr69y9U 11 facility for the parameters specified in COGCC Table 910-1, in addition to the wetland/drainage survey and mapping •PD Pg 1, 4, 5 COG CC v v v specified in Ursa's best management practices. re spo nse the HIA #3.2.10 above. No centralized faci li ty is planned. 8/3: www.youtube .com/watch?v=HZKOchhjh08 Perform monthly monitoring of any surface water bodies that are located within Yi mile of a well pad or the centralized See re sponse to HIA #3.9 -11 above. In addition COGCC regulations combined 12 water storage facility using the same parameters specified for the groundwater monitoring during well drilling and •PD Pg 1, 4, 5 COG CC with U rsa's BMPs , require cement and bond logs, mechanical integrity testing, v v v 8/3: www.youtube .com/watch?v=HZKOchhjh08 completion activities, followed by annual monitoring for the duration of the project . This type of monitoring is the best 8/17: www.youtube.com/watch ?v=r6pypD61 kFg way to ensure pollution control measures are preventing exposures through contamination of surface water. etc. Conduct soil testing at all well pad locations and at the centralized w ater facility during reclamation activities. All result of this monitoring should be made available to the public within 60 days of sample collection and posted on a publicly No ce ntral E&P facility is proposed accessible website approved by the Battlement Mesa Community website . If (1) benzene, ethyl benzene, toluene, or Soil t esting is required by COGCC as part of the fianl reclamation procedures. Test xylenes are detected at levels greater than the concentration levels specified in Table 910-1 of the COG CC rules; (2) an~ •PD Pg 1, 4, 5 13 cations, anions, metals, or total dissolved solids exceed 1.25 times background concentrations; (3) methane or any •RP Pg 5 COG CC result s are requuired to be sent to the COGCC within 60 days of receiving test v result s and are publically available on the COGCC website. chemical identified as a concern from the full disclosure of chemical s exceeds 1.25 background concentrations; or (4) if •SA Pg 8, 12-13 Soil testing is required by COGCC as part of remediation procedures for any pH or specific conductance exceeds the limits specified in COGCC table 910-1, the BOCC should require Ursa to reportable spills with the results sent to the COGCC which are publically available remediate as a condition of the special use permit . This type of monitoring is the best way to ensure pollution control measures are preventing exposures through contamination of soil . •PD Pg 1, 2, 4, 5 •IA Pg 1 Adhere to COGCC rules 317B , 603, 904 , and 908, including provisions in these rules that are at the discretion of the •Stormwater Mgmt Plan (SWMP) Pg3 Ursa has plans, sampling, tracking and monitoring programs in place that meet 7 /13 : www.youtube.com/watch ?v=4390N r69y9U 14 direct or, and identify any variances or exceptions to these rules and make any variances or exceptions publically •RP Pg 1-2, 4-5, 7 COG CC and go beyond what is being addressed as a concern for 317B, 609 and 904 v v v v 8/3: www.youtube .com/watch ?v=HZKOchhjh08 available (as posted on Garfield County website and/or a publicly accessible website approved by the Battlement Mesa Community) 2 months prior to submission of the special use permit . •SPCC Pg 6, 7, 8, 76, 77, 78, reg ul c•t ions. 908 regulations don't apply as a central E&P facility isn't proposed. 8/17: www.youtube.com/watch ?v=r6pypD61kFg Appendix B, C •SA Pg 6, 8, 9, 12, 13 , 14, 16, I~ 17 I , •SWMP Pg D21 15 Develop and implement plans to ensure removal of mud from vehicles leaving the well pads and access roads to •SA Pg 9 CDPHE Preve ntion of mud and sediment from leaving the well pad sites is part of Ursa's v v v 8/3: www.youtube.com/watch ?v=HZK0chhjh08 prevent tracking of mud onto Battlement Mesa and Garfield County roads. •Noxious Weed Mgmt Plan stomwater BMPs as required by CDPHE. 8/17: www.youtube .com/watch ?v=r6pypD61kFg (NWMP) Appendix G •SWMP Pg4 COG CC/ Ursa has implemented numerous Environmental Program Plans to include SPCC, Adhere to all its best management practices in Appendix E for spill prevention, control, and storm water control, and •SPCC 16 groundwater and surface water resources. •IA Pg 5 CDPHE/ spill , and stormwater management. Plans are made available to the COGCC, v v 8/3: www.youtube.com/watch?v=HZKOchhjh08 •SA Pg 6, 7, 8, 10 EPA CDPHE and other agencies upon request or as a result of agency inspections. •Site Plan Sheet BS •Drainage Report COG CC/ Create a berm for all down gradient well pad perimeters and surface water diversion ditches to prevent pollution of •SWMP CDP HE/ Berming is a standard BMP included in site and stormwater management plans v v 8/3: www.youtube .com/watch?v=HZKOchhjh08 17 water and soil. •S PCC required by the COGCC, CDP HE and GARCO. GAR CO •FD CP •SA Pg 7, 8, 9 Conduct monthly inspection of water and gas pipeline for leaks to prevent water and soi l pollution and that the results •SWMP Inspect ions are conducted by Ursa contract inspectors and agencies on a routine 18 basis; at least bi-monthly, in addition to the Operations Site and Water Manager v v 8/17: www.youtube.com/watch ?v=r6pypD61kFg of the inspections be posted on the Garfield County Website . •SPCC supervisors conducting dai ly and weekly inspections. Immediately Report to GCOG (in addition to COGCC) any sp ill of one or more bar r els. Notification should take place •SWMP COGCC spill regulations were revised to in clude the reporting of 1 bbl or more 19 within 24 hours and keep records of spill quantities, clean-up activities and preventive measures taken to avoid future •SPCC COG CC outsid e containment. Ursa's spill management plan addresses notification, v v 8/17: www.youtube.com/watch ?v=r6pypD61 kFg spi ll s. Notification should be immediate if water sources are impacted. •ERP Pg 6, 13, 22, 34 response and remed ial actions in detail. Drill cuttings are managed in accordance with Ursa's Waste Management Plan, •PD Pg 1, 2, 4, 5 and are sampled, stored, transported and disposed of in accordance with COGCC, 7 /13 : www.youtube.com/watch ?v=4390Nr69y9U 20 Cover all drill cuttings when stored on well pads to prevent wind transport and soil pollution. •IA Pg 1, 6 COG CC/ CDPH E, and county landfill requirements. Surface cuttings typically do not v v v v 8/3: www.youtube.com/watch?v=HZKOchhjh08 CDP HE exceed COGCC thresholds for standards for land disposal. Downhole (production •SA Pg 7, 8, 9 12, 13, 14,17 hole) cuttings have occasionally slightly exceeded land application standards, 8/17: www. you tu be .com/watch ?v= r6pypD61 kFg requiring disposal at State approved fac il ity/landfill. 1 CSPH recommend that the BOCC: ~ 21 Assign a Garfield County i nspector to monitor Ursa's compliance with the special use permit and that the special use N/A See response to HIA #3 .1.21-23 above. permit contain provisions for regulatory action if Ursa is found to be in non-compliance of the special use permit . Page 4 URSA RESPONSES TO BATTLEMENT MESA HEALTH I MPACT ASSESSMENT (HIA) "Colo rado School of Publ ic Health" (Feb 2011) NOTE: All ref erences to An tero changed to Ursa. Meetings Content : 6/15 -Geology 7 /13 -Regulatory/Permitting/Ops Overview 8/3 -Construction Phase 8/17 -Dr illing/Completions Phase 9/2 -Production Phase ~.3 Findings and Recommendations from Traffic and Transportation Assessment , V ideo Link HIA Refe rence Ass essment & Recomme ndations GARCO Appl icatio n Agency Co m ments Presentation/Com munity Mtg Date All li nks located on Batt lement Mesa Services Association Number Reference Page Number YouTube Channel www.youtube.com/channel/UCH89vs82WUL8zK_e6x09_gQ 6/15 7/13 8/3 8/17 9/2 As a condition of the SUP , CSPH recommend that the BOCC require Ursa to: 1 Insta ll a fully functional wate r storage facility and pipe line network before any development of well pads in the •PD Pg 1, 3 See r es ponse to HIA #3 .2.4 above . v v v 7 /13: www.youtube.com/watch ?v=4390Nr69y9U Battlement Mesa. •Pipeline SUP 8/3: www.youtube.com/watch ?v=HZKOchhj h08 Haul ro utes are determined by Ursa's Health and Safety Manager in consultation with the county to minimize t raffic and ensure safety to the community. A Site Safety and Emergency Response Plan (SSERP) is developed for each location . In Develop industrial haul routes outside the PUD to remove natural ga s development and production-associated traffic addi t io n, Ursa receives community input to work around special occasions, schoo 2 from residential roads prior to any well pad construction within the PUD . Industrial traffic should be diverted from •Traffic Study hours ond community events. Community Counts, the EAB and other v v v 8/3: www.youtube.com/watch ?v=HZKOchhjh08 •SA Pg 4, 15 o rga niz ations are also consulted and updated regarding heavy hauls, rig moves, 8/17: www.youtube.com/watch ?v=r6pypD61 kFg Stone Quarry Road to industrial haul routes at locations were homes are backed along the road. etc . Safety to workers and the community is a key aspect of Ursa 's Operations . In add itio n, designated haul routes can only be changed by the BOCC and/or on a case by case basis per GARCO Road & Bridge. We only utilize the Garfield County appro ve d haul routes during of our operations . If industria l hau l routes outside the PUD are not constructed t hen CSPH recommend the following conditions be met: See Response to HIA #3 .3 .2. Comply with and rely on implemented GARCO engin ee red safety measures and designated haul routes . In addition, notification Communicate and coordinate with the local school district to develop a plan for transportation and safety needs of all is initially sent to Community Counts, GARCO R&B, GARCO Liaison and 8/3 : www.youtube .com/watch ?v=HZK0chhjh08 3 children going to and from schoo l by car, bus, bicycle and walking du ring and outside of school zone hours to prevent •ERP distri b'-!ted by Community Counts to inform residents and the community v v v i nju ry to school children . affecte d by upcoming o peration s. Ursa Safety Manager and District 16 School 8/17: www.youtube .com/watch ?v=r6pypD61 kFg Syste m work together to ensure OS/OW vehicles are off of designated haul I~ route s during school bus operations . I While Ursa can't enforce speed limits, it encou rages all emp loyees, consu ltants and contractors to drive and observe traffic safety laws i n daily briefings, bi- 4 Enforce truck speed limits to 20 mph within the PUD for all areas for all truck traffic associated with the project to N/A month ly contractor meetings, and in pre-operations meetings . Any suspected v v v 8/3: www.youtube .com/watch?v=HZKOchhjh08 reduce the severity of injury should an acciden t occur. violati o ns or concerns should be d irected to Ursa immediately . Many of Ursa's 8/17: www.youtube.com/watch ?v=r6pypD61kFg team an d consultants l ive in the Battlement Mesa community . We are concern for eve ry one's safety . Mark pedestrian/bike high use rout es and estab lish safe crossing zones where they i nt ersect Ba t tlement Mesa Parkwa1 Ursa will lean on the use of t he app roved and impleme nted pedest r ian walks, 8/3: www.youtube.com/watch ?v=HZK0chhjh08 5 N/A bike pat hs, etc. that were engineered, approved and insta ll ed by BOCC and v v v or other haul routes to alert drive rs of potential pedestria ns and bicyclers . GARC O R&B. 8/1 7: www.you t ube.com/watch ?v=r6pypD61kFg Install safety measu res (i.e ., signa led cross walks, elevated sidewa lks , green space buffers) for pedestrians/bikes where Ursa w ill lean o n the use of t he approved and i mplemented pedest rian walks, 8/3 : www.youtube.com/watch?v=HZKOchhjh08 6 N/A bike paths, etc . that were enginee red, approved and ins t all ed by BOCC and v v v estab li shed wa lking/bik ing routes over lap/run along hau l routes to pre vent accidents. GARCO R&B. 8/17: www .youtube .com/watch ?v=r6pypD61kFg All Ursa employees and cont ractors operating a passenger and/or commerc ial 7 Require safe driver training for workers and subcontractors and Ursa implement pena lty system for unsafe workers, to N/A vehicle ha ve in their possession their primary state of residence State issued v v v 8/3 : www.youtube .com/wat ch?v=HZKOchhjh08 encourage sa f e driving. driving credentials . In the even t of a verified unsafe dr iving practice, a 8/17: www.youtube.com /watch ?v=r6pypD61kFg review/discipli na ry process is conducted. Ursa has a zero to lerance for ve rified unsafe drivers/driving practices . Processes 8/3: www.youtube.com/watch?v=HZK0chhjh08 8 Implement a system t o iden ti fy and remove unsafe drive rs to prevent accidents and injuries. N/A includ e reporting, invest igatio n and potential discip linary actions . May include v v v removal of service pro vi d er and/o r employee. 8/1 7: www.youtube .c om/watch ?v =r6pyp D61kFg CSPH recommend that Garfield County: W e will utilize GA RCO She ri ff's Department and/or othe r ce rtified law Provide She riff's Auxil iary Unit with autho rity to log speeding and unsafe driving i ncide nts and comp laints wit hin the enfo rcement agenc ies t o mitiga t e and manage unsa f e d riv in g practices. We value 8/3: w ww.youtube.com/wat ch?v=HZKOc hhj h08 9 PUD . Informat ion about incidents i nvo lvi ng t he Ursa workers or subcontractors can be provi ded to Ursa, subcontractor N/A an d su pport their abil ity t o legal ly utilize t heir discretio n, and w e support t hei r v v v and the Sheriff's department so that problems and unsafe conditions can be resolved . decision(s) for violators of all enginee red/implemented traffic management 8/1 7: www.youtube.com/watch ?v=r6pypD6 1kFg proce ss es working for and/or provid i ng a service to Ursa . Req uest that the Garfield County Sheriff's Depa rt ment o r ot her qualified entity rev iew Ursa's Traffic Impact An alysis N/A GARCO sent t he entire application to County agencies includ ing GARCO Road and 7/13: www.youtube.com/watch?v =4390N r69y9U 10 and request feedback on poss i ble safety m itigations and traffic hot spots t o ensu re t he plan is protective of pub li c GAR CO v v v I ~ hea lth. •Traffic Study Bridge and Sheriff's Depa rt ment as part of the agency rev iew process . 8/3: www.youtube.com/w atch?v=HZKOc hh j h08 SPH recommend that Ursa: Page 5 3.3 Findings and Recommendations from Traffic and Transportation Assessment HIA V ideo Link tReference Assessment & Recomme ndations GARCO Application Agency Comments Presentation/Com munity Mtg Date All li nks located on Battlemen t Mesa Services Association Reference Page Number YouTube Channel Number www.youtube.com/channel/UCH89vs82WUL8zK_e6x09_gQ 6/15 7/13 8/3 8/17 9/2 We will util ize GA RCO She r iff's Department and/or other certified law enforcement agenc ies to mitigat e and manage unsafe d r iving pract ices . We va lue Consider speed control measu res on w o r ke r i ngress and egress r outes with in the PU D (i.e. dec reased speed lim its, and support t hei r abi li ty t o legally ut ilize thei r disc ret ion, and we support the ir 11 signage , real time speed meas urement signs, photo speed ticket vans , speed bumps or other measures) to prevent N/A dec is ion (s) fo r vio lat o r s of al l engineered/implement ed t raffic management v v v 8/3: ww w.youtube.com/watch?v=H ZKOchhjh 0 8 •Tra ffi c Study proce ss es working for an d /o r providing a service to Ursa. On all Ursa access 8/17: www .youtube .com/watch ?v=r6pypD61kFg speeding. roads , w e have various post ed speed lim its rang i ng from 5-20 mph. All ver ified violato rs are subjected t o disciplinary processes. In addi t ion, speed bumps ar e not allowed on GARCO roa ds . • • Page 6 URSA RESPONSES TO BATTLEMENT MESA HEALTH IMPACT ASSESSMEN T (HIA) "Colorado School of Public Hea lth " (Feb 2011 ) NOTE: All referen ces to Antero changed to Ursa. Meetings Content: 6/15 -Geology 7 /13 -Regulatory/Permitt ing/Ops Ove rv iew 8/3 -Construction Phase 8/17 -Drilling/Comp letions Phase 9/2 -Productio n Phase ia.4 Findings and Specific Recommendations from Noise, Vibration and Light Assessment , Vi deo link HIA Refe ren ce Assess m e nt & Recomme ndations GARCO Appl ication Agency Comments Presen t ation/Com munity Mtg Date All li nks located on Battlement Mesa Services Associa t ion Reference Page Number YouTube Channel Number www .youtube .com /c hannel/UCH89vs82WUL8zK_e6x09_gQ 6/15 7/13 8/3 8/17 9/2 As a cond ition of the SUP, CSPH recommend that the BOCC require Ursa to: Improve sound mitigation to achieve noise leve ls be lo w 55 dbA in the day and 50 dbA at night during all we ll •PD Pg 2 Foll o w COG CC rules and GAR CO r ules regarding no i se leve ls. Ursa does 7 /13: www.youtube .c om/watch ?v=4390N r69y9U development and production activities at the distance of 350 feet from the noise source on the well pad . Require Ursa •IA Pg 6 COG CC/ ba ckgro und and operations noise monitoring and utilizes BMPs to mitigate noise v 1J v v 8/3: www.youtube .com/watch ?v=HZKOchhjh08 1 to monitor noise and to use best mitigati o n techno logy available to maintain these levels throughout the development •Sound Study GAR CO period. •SA Pg 14, 16-17 imp acts to the community . Ursa is developing a noise program plan . 8/17: www.youtube.com/watch ?v=r6pypD61kFg •PD Pg 2 7/13: www.youtube .co m/watch?v=4390Nr69y9U 2 Require best availab le noise reduction techno logy for heavy equipment, including trucks and truck brakes, to reduce •IA Pg 6 Se e HI A 3.4 .1. Ursa uses BMPs to mitigate noise impacts to the community . v v v v 8/3: www.youtube .c om/watch?v=HZK0chhjh08 noise levels. •Sound St udy 8/17 : www .yo utube .com/watch ?v=r6pypD61kFg •SA Pg 14, 16-17 Develop and implement Community Advisory Bo ard which can addres s the Battlement Mesa resident's concerns about Ursa participates in the EAB and Community Counts where residents can express their co ncerns regarding all types of nuisance impacts . Ursa encourages residents 7 /13: www.youtube .com/watch ?v =4390N r69y9U 3 noise. This can help prevent long-term nuisance noise levels, in cooperation with Battlement Mesa residents and N/A to co ntact their Land Department with complaints so they can be dealt with v v v v 8/3: www.youtube .com /watch ?v=HZKOchhjh08 Garfield County. For further details regarding the recommendation fo r a Community Advisory Board , see im med iately . Ursa has held five community meetings focusing on the Phase 1 8/17 : www .youtube.com /watch ?v=r6pypD61kFg recommendation for Community Wellness Assessment . devel opment. Alert residents of an t icipated noise, including time, duration, decibel levels, and machinery to be used to protect public Ga ve an overview of time frames and durations of all noise, odor and other 7 /13 : www.youtube.com/wa t ch ?v=4390Nr69y9U 4 •IA Pg 1 concern s related to all phases of development during community meetings, v v v v 8/3 : www.youtube .com /w atch?v=HZKOchhjh08 hea lth. includ ing land notifications for Move-In/Rig-Up operations during d rilling . 8/17 : www.youtube.co m/watch ?v=r6pypD61 kFg •Traffic Study Ursa only utilizes approved and implemented hau l routes des ignated by the BOO 7 /13: www.youtube .com/watch ?v=4390Nr69y9U 5 Develop industrial haul routes to remove truck traffic from the PUD and away from the homes on Stone Quarry road. GAR CO v v v v 8/3: www.youtube .com/watch?v=HZK0chhjh08 •SA Pg 4, 15 and GARCO R&B. 8/17 : www.youtube.com/watch ?v=r6pypD61kFg . If industrial haul routes are not developed then: I t Urs a w il l fo l low al l posted speed limits implemented by GARCO and/or loca l 7/13 : www.youtube.co m/watch?v=4390Nr69y9U 6 Reduce speed limits for trucks within the PUD to 20 miles per hour t o reduce no ise and vibration levels. N/A GAR CO governments in our operational areas. On Ursa access roads , the speed limits v v v v 8/3 : www.youtube .com/watch?v=HZKOchhjh08 vary fro m 5-20 mph depending on location. 8/17: www.youtube .com/watch ?v=r6pypD61kFg We manage what we can . We ut i lize noise mitigation on our ope rations/pads . Consider instal lat ion of t raffic noise barriers near t he St. John Elementary School and/or Grand Val ley Midd le School to Pla cing noise mitigations outside of our operations i mposes multi ple sa f ety 8/3 : www.youtube.com/watch?v=HZKOchhjh08 7 N/A GAR CO concerns/obstruction of line of view as t hese structures are located direct ly off of v v v reduce noise levels at schools if school staff indicates t hat the re are no ise impact s at the school . thorou ghfares . This could pose a poten t ia l issues for bus transportation, 8/17: www.youtube.com/watch ?v=r6p ypD61k Fg residents, emergency responders , etc. N/A We manage what we can . We uti lize noise mitigation on o ur ope rations/pads. •PD Pg 2 7 /13 : www.youtube.com/watch ?v=4390Nr69y9U 8 Ins t all permanent/semi-pe rmanent noise mitiga ti on structures (sound wa ll s) along ha ul rou t es CR300 and othe r routes •IA Pg 6 GAR CO Placing noise mi t igations outside of ou r operations i mposes m ul tiple sa f ety v v v v 8/3 : www.youtube .com/watch?v=HZKOchhjh08 whe re t rucks are anticipated to be passing throughout the development period to reduce noise le vels. •So und Study concerns/obstruction of line of view as these structures are located direct ly of 8/17: www .youtube .com/watch ?v=r6pyp D61kFg •SA Pg 14, 16, 17 thoroughfares . In addition, this poses various issues along CR 300. • Page 7 URSA RESPONSES TO BATTLEMENT MESA HEAL T H IMPACT ASSESSMENT (HIA) "Colorado Schoo l of Public Health" (Feb 2011 ) NOTE : All referen ce s to Ante ro changed t o Ursa . Meetings Content: 6/15 -Geology 7 /13 -Regulatory/Permitting/Ops Overview 8/3 -Construct ion Phase 8/17 -Drill ing/Completions Phase 9/2 -Production Pha se i.5 Findings and Specific Recommendations Related to Community Wellness , Vi deo Lin k HIA Refer enc e Ass es sment & Re commendations GARCO Appl ication Age ncy Comments Presentati on/Communit y Mtg Da t e All links located on Battlement Mesa Services Association Refer ence Page Number YouTu be Channel N umber www.youtube.com/channel/UCH89vs82WUL8zK_e6x09_gQ 6/15 7/13 8/3 8/17 9/2 CSPH recommends that U rsa, Battlement Mesa Citizens and Garfield County: Establish a Community Advisory Board to facilitate on-going community engagement between Ursa, Garfield County officials, Battlement Mesa Company and residents of Battlement Mesa for early identificat ion of impacts to communit) wellness. A Community Advisory Board can provide direct and frequent interactive communication between these Ursa participates in the EA and Community Counts where residents can express groups . It can provide an ongoing mechanism for citizens to report problems and concerns to Ursa and can allow Ursa their concerns regarding al l types of nuisance impacts . Ursa encourages residents 7 /13: www.youtube.com/watch ?v=4390Nr69y9U 1 to address concerns in a timely manner. It can also provide feedback to the county regarding success of residential •IA Pg 1 to contact their Land Department with complaints so they can be dea lt with v v v v 8/3 : www.youtube.com/watch ?v=HZKOchhj h08 natural gas development. A Community Advisory Board can also provide an opportunity for Ursa to apprise the imm edia tely. Ursa will continue to hold at least quarterly stakeholder meetings tc 8/17: www.youtube.com/watch ?v=r6pypD61kFg residents of current activities and changes to plans, which can help reduce uncertainty for residents and may decrease keep residents apprised of ongoing activities. anxiety. The Community Advisory Board can also provide input regarding the use of the one million do llar donation to ensure that the use of this money supports community and physical health. CSPH recommend that Garfield Cou nty : This process needs to be addressed via one's personal medical care provider, the Center for Disease Control or one's re ligious representative, etc. This is a very 2 Review sexually transmitted infection clinic access, outreach and education, with particu lar attention to i n-migrant N/A GAR CO personal situation and should be treated with the utmost discretion and ;J 8/3: www.youtube.com/watch ?v=HZKOchhjh08 workforce to reduce spread of sexually transm itted infections within the community. compas sion whi le allowing each individual to resource their option on guidance on such medical education. Garfield County BOCC response required. Per our Master Service Agreement (MSA), contractors are subjected to random , Identify operators and subcontractors that have implemented drug and alcohol free work-place programs and onsite, and reasonable cause drug testing, etc. All Ursa new hires must submit to I~ 3 encourage Ursa to do so and subcontract to companies that also do so. Provide Ursa with contacts to those that N/A drug testing: hair, urine and breath. Ursa and contractors have in place a v v 8/3: www.youtube.com/watch?v=HZKOchhjh08 educate employers regarding benef its of such programs. comprehensive Substance Abuse Program. We have a very stringent testing program in place. The expectations for a substance free env ironment is not taken lightly at Ursa. Garfield County BOCC response requi red. CSPH recommend that Garfield County and Ursa: Support baseline and ongoing studies to determine the impact of residential natural gas development on community health and the effects on individual health. This information will provide direct feedback t o the Ursa-Battlement Mesa Ursa has participated in CSU's air quality monitoring program since its inception . 4 project, allowing for improvements in community aspects as the project continues . It will also provide valuable •SA Pg 10 Ursa als o has an ongoing noise monitoring prog ram . If requested, Ursa is wil ling v v 8/3: www.youtube.com/watch ?v=HZKOchhjh08 information for other communities exper iencing or anticipating residential natural gas deve lopment. These studies to part;cipate in other stud ies if other oil and gas producers in Garfield County shou ld include measureme nts related to lifestyle and socia l cohes ion, educat ion, crime, sexua ll y trans mitted infection, participate as we ll. menta l health and suicide, and substance abuse. 7 /13: www.youtube .com/watch ?v=4390 Nr69y9U 5 Ensure recommendations to mitigate other concerns (air qua lity, t raffic, and noise) are impleme nted. N/A See previous comments . v v v v 8/3: www.youtube.com/watch?v=HZKOchhjh08 8/17: w ww.yo utube.com/wa t ch ?v=r6pypD61k Fg Recommendations to Support Benefits to Community Wellness CSPH recommend that Garfield County: Encourage use of local business, especia ll y t hose t hat enhance community co hesion, such as loca l restau rants and Ursa and it s em pl oyees l ive and w o rk in t he area. Support of local bus i nesse s is 7 /13 : www .youtube.com/w atch ?v=4390Nr69y9U 6 N/A part of bei ng a mem be r of the community. v v v v 8/3: www.yo utu be.co m/watch ?v=HZKOchhjh08 co ffee shops . Garfield Co un ty BOC C response required . 8/17: w ww.youtube.com/w at ch ?v=r6pypD6 1kFg 7 Util ize Ursa's o ne mil lio n dolla r dona ti o n to enhance community cohesion . N/A Acknowledged. Garfield Cou nty BOCC respo nse req uired. • Page 8 URSA RESPONSES TO BATTLEMENT MESA HEA LTH IMPACT ASSESSMENT (HIA) "Colorado School of Public Health " (Feb 2 011 ) NOTE: All references to Antero changed to Ursa . Meeti ngs Content : 6/15 -Geology 7 /13 -Regulatory/Permitting/Ops Overview 8/3 -Construction Phase 8/17 -Drilling/Completions Phase -9/2 -Production Phase ,..6 Findings and Specific Recommendations from Economic and Employment Assessment V ideo Li nk HIA Reference Asse ss ment & Re commendat ion s GAR CO App lica tion Agency Comments Pr es ent ati on/Com m u nity Mtg Date All links located on Battlement Mesa Services Association Number Reference Page Number YouTube Channel www.youtube .com/channel/UCH89vs82WUL8zK_e6K09_gQ Recommendations to Reduce Impacts from Economic Effects 6/15 7/13 8/3 8/17 9/2 CSPH recommend that before the project starts, the BOCC require Ursa to: Require that Ursa develop a reasonable and specific timeline for all activities associated with development and maintenance of the wells . Require that Ursa communicate changes to the plans at the earliest possib le time before an~ •PD Pg 4 Develo pment timeline was communicated during the five community meetings. 7 /13 : www.youtube.com/watch ?v=4390Nr69y9U 1 changes in the plans occur . This would address some concerns in the real estate market. If sellers and buyers can Ursa wi ll continue to communicate through community organizations and v v v v 8/3 : www .youtube .com/watch?v=HZKOchhjh08 confidently anticipate the steps and timing of the well development process , the real estate market may react less •IA Pg 1 meetings and updates. 8/17 : www.youtube .com/watch?v=r6pypD61kFg unfavorably to the project . CSPH recommend that Ursa, Battlement Mesa Citizens and Garfield County do the following before the Project starts: Establish a Community Advisory Board that meets regularly and frequently with Ursa (at least every month). Garfield County, citizens, Ursa and the Battlement Mesa Company should be a part of this board . The Community Advisory 7 /13 : www.youtube .com/watch ?v=4390N r69y9U 2 Board can actively interact with Ursa to facilitate communication to and from the residents and the county . Establish •IA Pg 1 See HIA 3.5.1 v v v v 8/3 : www.youtube .com/watch ?v=HZKOchhjh08 clear and timely communications methods to facilitate information regarding changes to the timeline and activities . Provide the Community Advisory Board with sufficient powers to allow for resident input, which can dem o nstrate that 8/17 : www.youtube .com/watch?v=r6pypD61kFg residents can voice their concerns . See HI A 3.6.1. Ursa uses multiple avenues to communicate with residents 7/13: www.youtube.com/watch?v=4390Nr69y9U 3 Consider multiple methods of communication to residents regarding development and maintenance activities . •IA Pg 1 includi ng required notifications and courtesy notification through Community v v v v 8/3: www.youtube .com/watch?v=HZKOchhjh08 Counts. 8/17 : www.youtube .com/watch ?v=r6pypD61kFg CSPH recommend that Garfield County: 4 Cont i nue to consider public hea lth as a high level priority when judgi ng uses of local government revenues derived N/A GAR CO Garfiel ~ County BOCC will respond . from the natural gas development and production to maximize protection of public health. •PD Pg 2, 5 7 /13: www.youtube.com/watch ?v=4390Nr69y9U t 5 Ensure recommendations to mitigate other concerns (air quality, traffic, noise and community wellness) are •IA Pg 6, 7 GAR CO Garfield County BOCC will respond. v v v v 8/3: www .youtube .com/watch ?v=HZKOchhjh08 implemented. •FDCP 8/17 : www.youtube .com/watch?v=r6pypD61kFg •SA Pg 1, 14, 16, 17 Recommendations to Support Benefits from Employment Effec t s CSPH recommend that Garfield County: 6 Supp ort loca l educational institutions that provide training for industry related jobs during the development period an N/A retraining for when industry jobs end after the de velopment period . GAR CO Garfield County BOCC w i ll respond. t Page 9 URSA RESPONSES TO BATTLEMENT MESA HEALTH IMPACT ASSESSMENT (HIA) "Colorado School of Public Health " {Feb 2011) NOTE: All references to Antero changed to Ursa. Meetings Content: 6/15 -Geology 7/13 • Regulatory/Permlttlng/Ops Overview 8/3 -Construction Phase 8/17 ·Drilling/Completions Phase 9/2 • Production Phase '1.7 Findings and Specific Recommendations Related to Health Care Infrastructure HIA Video Unk Reference Assessment & Recommendations GARCO Application Agency Comments Presentation/Community Mtg Date All links located on Battlement Mesa Services Association Number Reference Page Number YouTube Channel www.youtube.com/channelNCH89vs82WUl.8zK_e6•0!!...1Q 6/15 7/U 8/3 8/17 9/2 CSPH recommends that Garfield County: Ursa provides medical Insurance to thelr employees. The Patient Protection and 1 Monitor wh 1ch compan ies, including Ursa and subcontracting co mpanies, pr ov l d ~ hea Ith Insurance to emp toyees t o N/A GAR CO Affordable Care Act was signed Into law by President Obama on March 23, 2010. determine how the natural gas industry contri butes to health ca re Infrastructure. The federal law mandates coverage for all Americans and penalties for those wh c elect to waive coverage. Garfield County BOCC response required. Monitor health care ut lliz1t~11 In Garfield Co unty to determine If rates of un compensated care ar e associated M tura l This assessment is unobtainable as It could potentially violate one's billing priva q 2 gas Industry cycles. N/A GAR CO and access to any information revolving around medical care could potentially violate H.IP PA. Garfield County BOCC response r equired . 3 Ensure that county reve oou ec ntlnue to me et changes In county services, ~ncl udlng public health services . N/A GAR CO Garfield County BOCC will respond . ( Pa~lO URSA RESPONSES TO BATTLEMENT MESA HEALTH IMPACT ASSESSMENT (HIA) "Colorado School of Public Health" (Feb 2 011) NOTE: All referen ces to Ante ro ch a nged to Urs a . Meetings Content: 6/15 -Geology 7 /13 -Regulatory/Perm itting /Ops Overview 8/3 -Con st r uction Phase 8/17 -Dri lling/Completio ns Pha se 9/2 -Produ ction Phase i .8 Findings and Specific Recommendations from Assessment of Accidents and Malfunctions , V id eo Li nk HIA Reference Ass es sment & Reco mmenda t ion s GARCO App licatio n Agency Comments Pre sentation /Community Mtg Date All links located on Battlement Mesa Services Association N umber Refe r ence Page N u mber YouTube Channel www.youtube .com/channel/UCH89vs82WUL8zK_e6x09_gQ 6/15 7/13 8/3 8/17 9/2 CSPH recommends that as a cond ition of the SUP the BOCC requ ires Ursa to: Work with emergency responders in Battlement Mesa (e.g ., the sheriff and fire departments) and Battlement Mesa A comprehensive and thorough Emergency Response Plan is in place for Ursa's residents to establish a comprehensive emergency response plan that includes notification and communication Operations . It includes hospitals, air flight, fire stations, mustering processes systems, evacuation routes, plans for evacuating schools, the assisted living facility, and capacity of local emergency completP with coordinates. This has been provided to Grand Val ley Fire responders hospitals, and sheltering in place , accurate maps of pipeli ~1 es, shut-off valves, and well pads , as well as •SA Pg 5 Department and Grand Valley Police Department. It is revised as additional 8/3 : www.youtube.com/watch ?v=HZKOchhjh08 1 operational pads are constructed . In the event of an emergency directly affecting v v v identifying air intakes at the schools, assisted living facility, and recre ation center prior to any activity in the PUD . We •ERP 8/17: www.youtube .com/watch ?v=r6pypD61kFg recommend that the copies of the emergency response plan be kept at the sheriff department, fire department, all the we lfa re of the residents of Battlement Mesa, we will work with various EMS responding hospitals, and on a Garfield County website and/or a pub licly accessible website approved by the agencies/Battlement Mesa to ensure information is relayed accordingly . There Battlement Mesa Community . are limits to various communications as not all citizens utilize a computer, have cell phones and/or residential phones . Ursa has in place procedures included in the Site Specific Eme rgency Response Plan (S SERP) that addresses how Ursa representatives and our contractors are to Test the emergency response plan in cooperation with emergency re sponders by performing a drill pr ior to any natural •SA Pg 5 respond in the event of a fire , well control, medical emergency, chemical 8/3: www.youtube .com/watch?v=HZKOchhjh08 2 gas operations commence in the PUD and annual drills thereafter, as well as annual reviews and updates of the spill/exposure, and seve re weather response for our immediate operations . Ursa " v v •ERP 8/17: www.youtube .com/watch ?v=r6pypD61kFg emergency response plan . is willing to participate in emergency response drills if local emergency responders request. The GVFD Chief addressed this at the 9/2/15 community meeting. 3 Annually disclose all chemicals used on its well pads within the PUD and include a list of these chemicals in the •SA Pg 5, 7, 10 COG CC See HI~ 3.1.2. v v 8/17 : www.youtube .com/watch ?v=r6pypD61kFg emergency response plan. •ERP 4 Notify the sheriff and fire department one week prior to well dril li ng , hydraulic fracturing, flow back , and pipeline N/A We notify Community Co unts for rig moving operations and our Land " v v 8/3: www.yo utube .com/watch ?v=HZKOchhjh08 pigging activities . representative works with residents on other various ops . 8/17 : www.youtube.com/watch ?v=r6pypD61kFg I~ 5 Implement the emergency response provisions provided in Ursa 's be st management practices submitted as comments •SA Pg 5 Emergency response provisions have been included in Ursa's policies, plans, and v v v 8/3: www.youtube .com/watch ?v=HZKOchhjh08 to the September 2010 Draft HIA. •ERP procedu res. 8/17: www.youtube.com/watch ?v=r6pypD61kFg A comprehens ive and thorough Emergency Response Plan is in place for Ursa's Operations . It includes hospita ls, air flight, fire stations, mustering processes complete with coordinates . This has been provided to Grand Va l ley Fire Implement the well site and facility security provisions provided in Ursa 's best management practices submitted as Department and Grand Valley Police Department. It is revised as additional 8/3 : www.youtube .com/watch ?v=HZKOchhjh08 6 •SA Pg 4 operational pads are constructed . In the event of an emergency directly affecting v v v comments to the September 2010 Draft HIA . the welfa re of the residents of Battlement Mesa , we will wo rk with various EMS 8/17: www.youtube.com/watch ?v=r6pypD61kFg agen r ;es/Battlement Mesa to ensure information is relayed accordingly . There are limits t o various communications as not al l citizens utilize a computer, have cell phones and/or residential phones . Adhere to its best management practices for pipel i nes and all COGCC rules throughout the life of the project as a •PD Pg 1, 2, 4, 5 Ursa will utilize all industry standard practices and BMPs as represented in the 7 condition of the special use permit. •IA Pg 1, 6 application and its institutional documents. Ursa will comply with all applicable v v 8/3: www.youtube.com/watch ?v=HZK0chhjh08 •SA Pg 7, 8, 9 12, 13, 14,17 agency rules and regulations throughout the life of t he project . •PD4 Ursa complies with regulations imp lemented through COGCC , CDPHE , and Institute mechanism for reporting safety concerns, near-misses, and minor incidents to the appropriate designated •IA Pg 7 OSHA/HIPPA for all reporting processes . A comprehensive and thorough incident 8/3: www.youtube .com/watch ?v=HZKOchhjh08 8 county agency or department to reduce accidents and malfunctions . Reports of these concerns and incidents shou ld investigation/reporting process is conducted in house/with contractors to always v v v also be made to the Community Advisory Boa rd, along with plans for preventive and corrective actions. •SA Pg 5 properly mitigate and train on the prevention of reoccurrence or the prevention 8/17 : www.youtube .com/watch ?v=r6pypD61kFg •ERP of further Health & Safety risks. Develop an ongoing fire prevention program in coordination with the local fire department's community fire •SA Pg 5, 10 Ursa will utilize all industry standard practices and BMPs as represented in the 9 prevention program. This program should include routine inspection and implementation of wildfire mitigation plans applica t ion and its institutional documents. Ursa will comp ly with all applicable v v 8/3: www.youtube .com/watch?v=HZK0chhjh08 •ERP (for example, all areas surrounding we l l pads are kept clear of vegetation t hat could contrib ute to spreading). agency rules and regu lations throughout the li fe of the project. CSPH recommend that Garfield County: • Page 11 3.8 Findings and Specific Recommendations from Assessment of Accidents and Malfunctions H I A Video Link tReference Asse ss ment & Re comme nda t ion s GAR CO Application Age ncy Comments Presentation/Co mmunity Mtg Date All links located on Battlement Mesa Services Association Referenc e Page Number YouTube Channel Nu m ber www.youtube .com/channel/UCH89vs82WUL8zK_e6x09_gQ 6/15 7/13 8/3 8/17 9/2 All routes are clearly addressed in the SSERP provided to Ursa representatives and contractors on/off site. These routes are intended for Ursa and our contracto rs . For citize ns/residents, they shall receive guidance from designated 8/3: www .youtube .com/watch?v=HZKOchhjh08 10 Clearly mark primary and secondary evacuation routes from Battlement Mesa. •ERP GAR CO GVFD/G VPD/GARCO officials for their evacuation routes. Ursa will also follow any \I " " direct guidance on evacuation given on behalf of the mentioned responding 8/17: www.youtube.com/watch ?v=r6pypD6 1kFg official s/brigades. Garfield County BOCC response requ ired . All routes are clearly addressed in the SSERP provided to Ursa representatives and contractors on/off site. These routes are intended for Ursa and our GVFD/ contractors. For citizens/residents, they shal l receive guidance from designated 11 Perform quarterly tests of emergency notification systems within Bat t lement Mesa (e.g., sirens and reverse 911). N/A GVPD/ GVFD/GVPD/GARCO officials for their evacuation routes. Ursa will also follow any ,, " 8/3: www.youtube.com/watch ?v=HZKOchhj h08 GAR CO direct guidance on evacuation given on beha lf of the mentioned responding officials/brigades. This was addressed by the GV FD Fire Ch ief at the 9/2/15 community meeting. Request the Battlement Mesa fire department to inspect all proposed well pad locations and make recommendations Will rea ch out to GVFD Chief for guidance and assistance. GARCO and state 12 for the prevention of well pad fires spreading from the pads up to relocation of pads and that these recommendations •SA Pg 5 GVFD agencies dete r mine the appropriate local agencies to inspect locations. Ursa ,, " 8/3: www.youtube.com/watch?v=HZKOchhjh08 are incorporated into t he special use permit. wecomes safety inspections at any time. 13 Require all gas pipelines to follow established truck haul routes and allow no gas pipelines through the center of the PUD. SUA GVFD Gas pipelines were located per the SUA with Battlement Mesa Partners. " " 8/3: www.youtube.com/watch ?v= HZKOch hj h08 14 Assign a county inspector to ove r see and inspect all pipe line construction and maint enance in the PUD. •Pipe line SUP GAR CO Ursa will cooperate w ith all county departments as appropriat e during pipel i ne ,, " 8/3: www.youtube.com/watch ?v= HZKOch hj h08 construction . • • Page 12 EXHIBIT I \A '1 September23, 2015 Planning an Zoning Hearing 1 \ ~~,Fonnan 47 Locust Way, 999 feet from proposed Well Pad B (next to water supply for Battlement Planning Commission: In April 2014, Dr. McKenzie of the Colorado School of Public Health published a paper on birth outcomes and the pregnant woman's exposure to natural gas drilling in Colorado. Dr. McKenzie found that pregnant women who Jived closest to natural gas drilling were 30% more likely to have a baby with a congenital heart defect. This study was done with birth statistics that were collected between 1996 and 2009. This is hard evidence that gas drilling can damage human health. When Dr. McKenzie spoke in Parachute, she said that her next research was to study the effect of distance from a gas well on the concentration of toxic substances in surface water. Once the wells are drilled next to the water supply, we will have to deal with more toxic substances in the water. Please ask Dr. McKenzie whether drilling 25 gas wells next to our water supply is a good idea. Also, ask her to estimate how much distance would be needed to decrease the toxins in the water by 50% or 90%. Also, please ask an expert such as Dr. McKenzie to tell us whether living on a hill above the well pad would increase the exposure to toxic substances in the air. Reference: \ /' McKenzie, Lisa; Guo, Ruixin; Witter, Roxanna; Savitz, David; Newman, Lee; and Adgate, John. Birth Outcome and Maternal Residential Proximity to Natural Gas Development in Rural Colorado Environmental Health Perspectives 122 : 4 l 2-417 L. McKenzie, Department ofEnvirorunental and Occupational Health, Colorado School of Public Health, 13001 E. 1'7111 PL., Campus Box Bil9,Aurora, CO 80045; 303-724-5557; Email Lisa.McKenzie@ucdenver.edu '~(,!''\ ·Research I Olildren's Health All e-t?ainlcnt Is aa:osdblo lo indivldualswllh d iS'.lbililics. A fully ~bro (9)ctlon 508 c.t:ompfiant) HTML version of th ls11rt ich1 lsuvaifable at hJ.lp :lld~.d ol.oro/1 0.128()/ehp.1 :JO~. I' Birth Outcomes and Maternal Residential Proximity to Natural Gas Development in Rural Colorado / I Lisa M. McKenzie,1 Rulxin Guo,2 Roxana Z. Witter,' David A. Savitz,3 Lee S . Newman,1 and John L. Adgate 1 1Department of Environmental and Occupational Health, and 2oepartment of BiostatlsUcs and Informatics, Colorado School of Public Health, Aurora, Colorado, USA; 30epartment of Epidemiology, Brown University, Provide nce, Rhode Isl and, USA B.ICK etloUt.o: llii& dcfca~ l :· a leadin g cause of neonatal mortality. Nah1ral gas development (NGD) cmils scvcra.J potCI1~al ·1~atogcns, aod U,S. production of mllural g.'IS is expanding. ORJEC'l 'lV1~s ; We ~~amined o ~c)CiatiOn~ between maternal rcsidcntial proidmiLy to NGO and birU1 outcome.~ ir(a rctrospcCiivc coJiort 3tudy of 124,842 birth.~ between 1996 Md 2009 in n1ral Colorado. .:.: .. '-~: :· Mtmrons: \V c calfulatcd .in~ihustru1cc weighted un1.u1'11 gas well counL~ wilhin a 1 O·milc l'lldius of maternal rei;idcnc.e Lo estini#~ funtemal r-tp O:sme to NGn _ T..ogisiic regression, ildjusted for matemnl and infunfrovariales, \i.1i5 used to t:!.timali: <1SSO<.iations with ~posure tertiles for congeni - t'lll hc:iri: defects (Cl.-iDs), 1!eurai)l!Jledclix:ts(NTDs), onil defis, pretc:nn birth,-lltld term fow birth weighL 0 e as.wc1ai,icii1 ~ilh tm~ birth ·weight was in\-e.stigntcd using multiple linear regression . RESUI:r~: Prevaten¥of (:HDs ii1(;i~l with r.qioSl!re terttle, with nn odds rntio (OR) of. 1..3 for the highest tr.r1ile (95% Cl: .1 :~i },~); NTD ()rem!ei tce was associaLoo with the highest lertilc: of exposum (OR = 2.0; 95% CT: (0, '~.9. based on 59 cases), a.impnred wiUt tJ1e absence of any g;is well~ within a 10 milcrddiu.'i-~ji(1sure was negalivcly associated .'with prctcnn birth and positively assodntcd with fctnl grot,1.th, ·•tlthuuglt the magnitude of nssoci:iuon wa.> small. No as:;ociation was founil bclwa:n ~95ure and ora.1.:~~fis. CONCLUSION.>~ In 1:4is' ~vgc ~h~fo; :.\l<'C obscrvtxl an :issociat.ion between density and pro.timity of natunl g;~ wells withiti"a lO·milc rddi1L~ of qiaternm residence.and prcv:ilcqcc of CHDs and po~­ sibly N fDs. Grcatr.(ij}i:ci eti ty ii(¥i?osurc estimates is ncaicd to further explore these associations CnwrmN; McKen~~l.M, G1~~':jf:\Vitter RZ, SaVitz DA. Newmwt LS,_Ad~r.ucJL. 2014. Birth outromcs ilnd mntci'ijal rcsid<;!ltiiil ilj'oXimity to 1111rural g.is dc\IC!opmcut in rural Colorado. Environ Health Pcrspc:ct 122!f12 0ll7: h,t.!Qil~~.9hox!'!to.l2f!..2££hp.t3g672.f ~:;·· .•. ;:;-: ..•.. :-. . lntroou.ction · Approximately 3.3% of U.S. livc·born children have a major birth defect (Centers for Disease Control and Prevention 2013: Parker ct al. 2010); these defects account for 20% of infant deaths a.~ well as 2.3% of premature death and disability (McKcnna ct al. 2005). Oral clefts, nel1J'lll tube defects (NTDs), and congenital heart defects (CHD) aic 'the most common classcs 'ofbirtll defects (Parker et al. 2010). These defects are thoughl to originate in the Crst trimester ao; a result of polygenic inherited disea~ or geneC"tnvirooment interactions (Brent 2004). Suspected nongeoetic risk factors for these birth defects include fol:ne deO:iency (Wald and Sneddon 1991 ), maternal .smoking (Hancin et al . 2006), alcohol abuse and sol· \'Cnt use (Romitli et al. 2007), and exposure tu benzene (Lupo et al. 2010b; Wennborg et aJ. 2005), toluene (Bowen ct al. 2009), polycyclic aromatic hydrocarbons (PAHs) (Ren et al. 20 ll). and petroleum -based solvents, including aromatic hydrocarbons (Che\.Tier ct al . 1996}. M;ociations between air pollution [volatile organic compounds (VOCs). particulate matter (PM), and nitro- gi:n dioxide (NO:?)] and low birth weight and prctenn binlt have been reported (Ballester et al . 2010; Brauer et al. 2008; Dadvand ct al. 2013; Ghosh ct al. 2012; Llop et al . 2010). Many of these air pollutants are tmitted during development and prodµction of natur.d gas (referred to herein as NGD), and concerns have been raised that they may increase risk of adverse binh outcomes and other health effects (Colbom et al. 2011; McKenzie et al. 2012). Increased pre'ri!lencc of low birth ~ight and small for gestational age and reduced APGAR scores were reported in infants born to mothers living near NGO in Pcru1ylvania (Hill 2013). . Tccbnological advances in d ircctional drilling and hydraulic fracturing ha\'C resulted in a global boom of drilliog and produc- tion of natural gas reserves [U.S. Energy [nformation Administratioo (EIA) 201 la, 201 lb; Vidas and Hugman 2008]. NGD is an industrial proces.s resulting in poten· tial worker and community exposure to multiple environmental stressors (Esswein et al. 2013; King 2012: Witter et al. 2013). Diesel-powered heavy equipment is used for worksite development as \rell as transporting large \.'Olumes of water, sand. and chemicals to sites and for waste removal (Witter ·et al. 2013). It is increasingly conunon for NGO to encroach on populated areas, potentially exposing more people to air and water emis- sions as well as to noise and community-level changes that may arise from industrializa- tion [Colorado Oil and Gas Conservation Commission (COGCC) 2009). Studies in Colorado, Texas, Wyoming, and Oklahoma have demonstrated that NGD results in emission of VOCs, N01. sulfur d ioxide (502,), PM. and PAHs from either the well itself or from associated drilling procc.c;scs or related infra~ructurc (i.e., drilling muds. hydraul k fracturing C\.J ids, tanks containing waste water and liquid hydrocarbons, diesel engines, compressor stations, dehydrators, and pipclinC!i) (CDPHE 2007; Fra?icr 2009; Kemball -Cook et al. 2010; Olaguer 2012; Walther 20J l; Zielinska ct al . 2011). Some of thef-oe polhllants, such as toluene, xylenes, and benzene , :ire suspected teratogens {Lupo et al. 2010b; Shepard 1995) or mutagens (Agency for Toxic Substances and Disease Registry 2007) and are k.!10\\11 to <..Toss the placenta (Bukowski 2001), rJ.i~ing the po~. bility offdal exposure to these .and 0U1er pol~ lutantsre&1lting from NGD. Currently, there are fi:w studies on the eCects of air pollution or NG D on birth outcomes. In this anal)'Sis. \'re explural the amciation bctuwi mutcrn:~ exposure to NGD and birth outcomes, using a data sct with indh·idual·lcvcl birth data and goocxxlcd natural gas well loc-... tions. We conduc.1cd a ret rospective cohort study to investigate the association between density and proximity of natural gas wells within a 10-milc radius of maternal residences in rur.11 Colorado and three classes of birth defects. prctcrm birth, and fetal gro\\th. Methods Studypopulatiai'. We used infomlBl:ion .. avail · able io the publically accc.c;sib!e Colorado Oil and Gas Information System (COGIS) to Addccss corrcspondcucc to L McKenzie, Dcpnrtmcnt of Environmental and Occupational Hclllth, Colorado Schoo l of Public Hcahh, l.3001 E. 17th Pl, Campus Box Bl 19, Aurora. CO 80045 USA. Telephone: (303) 724 ·5557. E·mail : Lisa. McKen7ic<Gucdcn"'7.cxlu Suppkma1tal Material is av.iilablc online (http:// dx.doiorg/ I0 .1289/chp. 1306722). O is study was supported by the Dcpartma1t of Environmcntol aitd Occupat ional Health at the Colorado School of Pablic Health . The Colorado Department of ~4blic H calth and Environment's (CDPHEJ Hcalth Statistics 1111d Colorado Ri:sponds to Children with Special Needs pro \'ided outcome d:i1a for this stud)'. 0 e CDPHE spcciO:ally disclaims responsibility for any m1alysc;, intaprctatians. or condusi ons . D c llllthor. declare they have no aaual or pot cnti.:ll competing Cbll!lcial int~TC.ts. Rro:i\'l'd : 27 Fdiru:iry201J ; Aa:qital: 28 J;muary 2014; 1"1v.ma: Publication : 28 J:inuary 2014; F'anal Public:ttion : I April 2014 . 412 VOCJPAE 122 lllUtA1!514 I April 2014 t l?mironmc nt3l tle3 !l.h Pcrspcct.ivcs Natural gas development and birth outcomes build a geocodt'tl data sci wilh _latilude, Ion· gitude, and year of developmenl (l996~) for all gas wells in rum! Colorado (COGIS 201 J). Live birth data were obtained from the Colomdo Vital Birth Statistics (CDPHE. Denvc...-, CO). Gcocod<Xl matcmal addrc&iCS ut time of birth were linked to the well locations. Distanu: of ca:h maternal rcsidcn1.'C from all existing (not abandoned) natural gas wells within a l 0-milc radius W'clS then computed using spherically adjust<:d straight line dis· tan~ We conducted our analysis on the Chai de-identified database containing maternal and birth outcome data described below and diltancc to all wells \'tithin the 10.mile radius. D e Colorado Multiple Institutional Review Bourd reviewed and approved our study protocol. lnfonned consenl was aol required. We restrictc:d analysis to births occur· ring from 1996 through 2009 to fo1.i1s our analysis on growth of uaconventional NGD, characterized by use of hydraulic frnctur- ing and/or directional drilling (King 2012), which expanded rapidly in Colorado begin · ning around 2000 (COGIS 2011). We alw restrictcl our ar1al~is to rural areas and to'WllS wilh populations of< 50,000 (exduding tht: Dem·er metropolitan nrea. El Pa.so County, and the cities of Fort Collins, Boulder, Pueblo, Grauel Junction, and Greeley) in 57 countic.~ to reduce potential for cxpm.urc to other pollution sources. such as t raC c, tx,>n· gcstion, and industry. The final study area included locations with and without NGD. We conducted a retrospective study on the resulting cohort of 124,842 live births to explore a.Wlciations between birth outcomes and exposure to NGO operations. We restricted eligibility to singleton births and excluded the small proponion (<5%) of non- . white births because there were too few to analyze separately. ' . Birth rutcanes. ldeotiO!d birth outcomes were a) oral clefi, including cleft lip wilh and withoul clefi palaJ.e as v.1!11 as cleft palate [lnternatimal Cla!BCl::ttion of Di!l.'3S:S, Ninth Hevi!fon, Clinical M<XiiO.'atim (1CD·9-CM) code 749.xx] (National Center for Health Statistics 201 I); b) NTD, including anen- a:phalus, !.pina biGla without anc:cephaly. and eocephaloccle (ICD-9-CM 740.xx, 741.xx. and 742.0); c) CHD, including Lrnnsposilion of great \-esscls, tetralogy of l'allot, ventricular septa! defect, e:ndocardial cushion defoct, pul- monary valve atresia and stenosis, trkuspid valve atresia and stcnosis. Ebstcin's anomaly, aortic valve &tenosis, hypoplastic left heart S)ndromc, patent ductus aneriosis, coarcta· tion of aorta and pulmonary artery anoma· lii:s (codes 745.xx, 746.xx. 747.xx, c.~cluding 746.9, 747.5); d) pretcrm birth (< 37 Wt.'Cks romplctcd gestation); c) term low birtl1 wcight (0 37 wreks completed gestation and birth weight < 2,500 g); and O lcnn birth weight as a continuous measure. Births with an oral cleft, NTD. or CHD v.ere t"J1cluded from pn:- tenn birth und term low birth weight analysis. Prc:t:erm births were excluded from term birth v.-cight analysis. Oral cleft, CHD. and NTD ~s in the Colorado Rc:.'j>onds to Children with Spt'(..ial Need s {CRCSN) birth registry, obtained from hoi.pital records. the Newborn Genetics Sc.1'CCning Program, the Newborn Hearing Screening Progrnm, lnbonllorics, phy. siciam. and genetic, dcvclopmcntnl, mid other spcx..ialty clinics (CRCSN 1011) were matched with Colorado li\>c birth l'crti lhucs. Cases arc rcfrctivc of reporting as of 12 July 2012, were nor ncces>arily con CimcxJ by medical record micw, and arc rubjC(.t to ch;mge as CRCSN a'>CCrtains diagnosis up to 3 years of child"s <1ge and/or supplemenLs infom1ation by medi · cal record rc\iew. We aoal}?J!d birth defects in three heterogeneous groups lo inerea.~ statistical power. Dma set infom1ation WCI$ not su Ocient to distiugui.~h between multiple aod isolnred birth anomalies or to identify chromosomal birth anomalies. In an explor· atory analysis, we considered seven clinical diagnostic groupings of CHDs: a) conotrun.- cal defects (telralogy of Fallot ;md lr'dllsposi- Lion of great \.'l!&Sels); b) endocardial t11shion and mitrov.ilve defects (Ei\.10; enclocardial cushion defeLt ru1d hypoplast ic left heart syn- drome): t.) pulmonary artcty and va\\'c defuc:ts (PAV; pulmonary valve atrcsia and st~nosis ru1d puhn\mary artery anomalies); d) tricus- pid valve defects (TVD; tricuspid valve ~a and srcnosis and Ehstcin's anom:dy}; c) aortic artery and \'ahe defects (aortic v.tlvc &cnosis and marctation of aorta); f) \'Oltrirular septa! defects (VSD ); and g) paacnl ductus artcriosis in births> 2,500 g (Gilboa ct al. 2005). Exposure assessment. Djstribution of the wells within a 10-tnilc radius of mater- nal rc.~idcncc shows so% and 90% of wells to be within 2.3 and 7.7 miles of maternal residence, respectively. We used an inverr.e distance weighted (lDW) approach, com- monly used to estimate individual air pollut- ant exposures from multiple filled locatioas (Brauer ct al. 1998; Ghosh et al. 2012), to estim<Jte maternal ei-;posure. Our IDW well count aL'COUots for the number of wells '\\oithin the 10-mile rc!dius of the maternal residence, as well as diltance of each \\cll from the miller· nal residence, giving greater weight to wells closest to the maternal re~dcnce. For example. an IDW ~I count of 125 welWmile could be computed trom 125 wells each locatoo I mile from the: maternal residence or 25 wells c:ich located 0.2 miles from the mrucrmtl residtna.:. We calculated the IDW m:ll count of all exist· ing natural ga~ wells in the birth year within a 10-milc radius of each maternal residence ;is a continuous exposure metric: IDWwellcount =Sfc t~i• {J] Environmc11111l Health Perspe ctives 1 VOUJME 122 lrruMOCR4 IApril 2014 where IDW well count is the IDW count ( of e'isting wells within a I O·mile r-c!<lius of matemnl residence in the birth year; di is the distant-e of the ith individual well from maternal residence: and n is the number of existing wells within a IO·milc radius of maternal rcsidena: in the birth year. The IDW well count was calculated for each maternal residence with 0 l gas wells wichin 10 miles. 0 e [nal distribution then was divided into tcrlile.~ (low, medium, and high) for rubscqucnt logisti c and linear regres- sion analysis. Each tcrtilc was compared with the referent group (no natural gus wells \\ithin IO miles, IDW well COWlt = 0). Statistical analy~is. We used logistic re~ions to study ll\."iOCiations between C<Jch dichotomous outcome and IDW ex.po$ure group. We <Jlso con5idered term birth weight a~ a continuous outcome using mull iple linear regre.~sion. First, "c e.~imated the crude odds ratio (OR) a~wciated with IDW exposure tertile for each binary outcome, followed by a CochranD\rmitage test to evaluate linear trends in binominal proportions with incrl.'aS- ing IDW expo:;ure (none, low, medium, and high). We further investigatl'd ~illl.ions by adjusting li>r potential a:mfounders, as v1ell :ii. infant and maternal cuvJJ.iates selected ba!ietl on both a pricri .l11owledge and empirit."31 con · sideration of their association with exposure and an outcome. Spccifical~y. covariates in our analysis of all outcomes except ou~comcs with \'CT)' few events (i.e., NTDs. conotrun- cal defects, EMD s, and TVDs) included maternal age, education (< 12. 12, I 3Cl 5, 0 16 years). tobacco U£(smoka-, nonsmoker), ethnicity (Hlo;panic, non-Hispan ic white), and akohol use (yes. no). ar; well as parity at time of pregnancy (0, 1, 2. > 2) and infant sex. Gc&aiional age war; afro included in the ani'.ily- , sis of term birth \\eight. Elevation of maternal residence nlso was considered io the analy- sis bc!cause most wells are< 7,000 feet. and ele\-ation has bl!01 ~dated wi1·h both pre- 1erm hinh and low birth weight (N ienneyer et al. 2009). For 272 births where elevation of maternal residence wa'i missing, elevai:ion was impuled using meaa elevation for mwer- nal ZIP code. For outcomes with very few events, only elevation was included io the multiple logistic modeling to avoid unstable estimates. G e ORs and their 95% Cis were used to approximate relati\e risks for each out· come a.ssociatcl wilh IDW cuunt exposure tcrtilc (low. medium, :md high) compared with no wells within I 0 miles. which is rca· oonablc because of the rarity of the outcoml!S. We considered the statistical signifi cance of the as;i.iciation, as well as the trend. in evaluat· ing results, at an alpha of0.05. We evaluated the confounding potential of the 1998 intro- duction of folic add forti O:at ion on the birth defect outcomes and found only a dccrea.c;c in 413 ) II· McKenz;eet al. / I NTD pre\'alence after 1998 (see Supplc:mc:ntal .Material, Table Sl ). Jn a senstivity anal;~ we explored reduc- ing exposure to 2-and 5-milc buD.:rs around the maternal residence. as wcll as n:..'itricting the cohort to births oca.ming bcrween 2000 and 2009 to exclude births before the c.~pansion of NOD. We report estimated associations with 95% Cls. llll statistical anal~ \\-U'C con- ducted using SASOsoft\lt'llIC version 9.3 (SAS Institute Ioc., Cary, NC). Results Births were approximately evenly divided between exposed and unexposed groups (0 wells in a 10-mile radius \'CCSUS 0 I well in a 10-mile radius) (Table I). &timatcd expo- sure, rcprer..ented by IDW ~II counts, tended to he higher for births to mothers \\ith resi- d~nce addre.~ at lo\lt~r elevations (< 6,000 feet), and among nonsmoking and Hispanic mothers (fable 1). Both crude and adjusted estimates indi- cate a monotonic increase in the prc:valenc:e of CHDs \liith increasing e.~oli.Jre to NGD, as represented by IDW well counts (Table 2). Births to mothers in the most exposed ter- tile (> 125 wells/mile) had a 30% greater prevalence of CHDs (95% Cl: 1.2, 1.5) tban births lo molhm with no wells wilhin a 10-m ilc r.Klius of their rc:;idcncc. Prevalence of NTDs w.i.~ positivt:ly as..-.o- ciatcd with only the third· .exposure tertilc, based on crude and csrimatcd ooju~tcd ORs fur elevation (Table 2). Births in the highest · tcrtilc (> 125 wcllslmilc) were 2.0 (95% CI: 1.0, 3.9) times more likely to have a NTD than those \\ith no weUs within a 10-mile radius, based on 59 available caws. We observed no statistically significant associa- tions hctwecn oral clefts and NGD, b~d on trcqd analysis across categorical IDW well count exposure (fable 2). ' Both crude and adjusted estimates for preterm birth suggest a slight(< l0%) decreased ri~k of preterm birth with increa~­ in g exposure to NGD (Table 3). Crude term low birth weight measures suggested decreased ri.~ of term low birth weight with increasing exposure to NGO. A weak. non - linear trend remained after adjusting for elevation and other covariates. 0 is associa- t iou is consistent with the multiple linear regrC$ion results for continuons tem1 birth weight, in which mean birth weights were 50!4 g greater in the higher IDW well count c.~osure tertilcs than the rcfi:rcnt group. We obs:nt:d a monotonic increase in th e prcV'.ilcnce of NTDs with increasing expo - sure to NOD in our sensitivity analyres u~ing 2· and 5-mile exposure radii as well as some attenuation in decreased risk fur pretam birth and term low birth wcigbt (see Supplemental Material, Tables S2 07). Re stricting births 414 lo 2000 through 2009, the period of most intense NGO in Colorado, attenuated the positive association between NTDs in the highest tert ile and did not alter observed relationships for other binh outcomes (see Supplemental Material, Tables S21:S7). Exploratory analysis of CHDs by clini- cal diagnostic groups indicates increased prevalence of PAV defects by 60% (95% Cl: I.I, 2.2). VSDs by 50% (95% CI: I.I, 2.1), and TVDs by 400% (95% CI: 1.3, 13) in the most exposed tertilc compared with those with no wells within a 10-mile radius (Table 4). Discussion We found positive associations belween density and proximi1y of natural gas wdls v.ithin a 10-mile radius of maternal residence and birth prevalence of CHDs and possibly NTDs. Prcvalenre of CHDs increased mono- tonically from the lowest to highest exposure tcrtile, although even in the highest tcrtilc tbc magnitude of the association was modest. Prevalence of NTDs was elevated only in the highest tcrtile of exposure. We also obsen'Cd small negative associations between density and proximity of natural ga~ wells within a 10-milc radius of maternal residence and TableCl. Study population characteristics for uneicposed and exposed subjects from rural O:>lorado 1~ Rtemtga.p (O..Wtslhittin LD..v Ma1Lm H[fl Malara! er irta1 ctmr:taistic Tdd 10rrile;) (!JS tat11er (sea:ni teititer ~tirtl tatlle}l Tda n{o/o) 124,842 00,&5(53) 19,214(15) 19,311(15) 19,793(16) Medan 'Zl 'Zl a5 'Zl 'Zl :ahpaartDe 22 22 21 22 23 75lhpercstile ~ ~ 3} 31 31 Malaml ettridty ("/o)ll l\tnH~cv-.tite 73 74 72 76 m ~\%) Mae 51 51 51 51 51 Malara ~rg ("/o'f 9rdes 11 11 14 13 8 Matarel alcxtd (."/o'f N:> 9!l 93 m 00 00 Rrity(%) 0 .. 33 33 31 ~ 32 1 23 23 .24 24 25 2 19 19 3) 19 al >2 25 25 a5 25 24 Fesiartial el!Ml!i01 ~eel) Medai s,cxm;,9'9 6,COXE,9'9 <5,CXD s,cro.::5,9'9 • <5,00) :ahpaartile <:'5,o:X> 5,CXXXS,9'9 ..:5,00> <5,00> <5,00> ?ah pmrtile 7,rnrY,<m 7,II1X1.9'9 5,0::0.:S.'m 6,CXD.."l),!m 5,00XE,'m Malaml aicllicn (."lo) <12}9¥5 21 3) a5 19 .22 12~ 3} 3} 3'3 29 , 28 13'.JIS~ '23 22 25 25 24 Ol6}-EalS a; :18 I 18 a5 'Zl •mt teltilc, 1CllG!wclls/rrllc; scconcltenilo, 3.GlJ1'5well!>'IT'ilc; third lcftllc, 1'5Jl,40Jwc!l:w'1Tilo. ttrclooes bolhNoo- Hspanc and H5JlQric wl'itc. '0.6ing prognarcy. Table!Z AssocJaUoo between Inverse distance weighted well count within 10.rrile radus of rratemal resid«ice ard OiJs, Nm;, and oral defis. ln.esed&aml Oweils\-\ittin LD..v Medun Hg, QrlraO'mit<g3119"d wagaoowa1 a:ul" 1001ile; (ostiIB'lite) (sEm"d.tatlle) (Iii nitl!ti I e) testp-...al.9' U..e tirtl's [I} ffi,S:E 19,214 19.all 19,'im Qi); ci9es(n) ffil 281 3D 355 Ouilo:t 1 1.1 12 13 <D.OX>l Kfl.Eilooo=i~1aaf 1.1~ro.1.3) 12 (1.0, 1,3) 1.3 {1.2. 1.5) NTO; .. CB.!s(ti) 'Zl 6 7 19 Oui!CR 1 0.77 aoo 2.4 O.Q1 pqu;tooCR~kO~ 0.. ddls O.ES p.25. 1.7) 0.00 (0.34, 1.9) 2.0 (1.0. 3.9) CB.!s(n) 13i:l 31 41 40 ou:BCR 1 0.77 1 0.97 0.9 Kf l.Eile:J CFlf.B'k ay: O.ES (0.43, 0,00) 0.00 (0.61, 1.3) 0.82 (0.55, 1.2) "first tcrtilo, !CB62 well&'rrilo; second tertlle, 3633'5welll>'mlc; third tatlkl, ta:ct,«Xlwcll!in'ilc. ~rform:d as two- tlilcd test on ~ustcd IOgistlc rGfJ"csslon. •Aqusted for natcmal ago, C!Mc ity, srrdling, lllcoh:JI uso, educQtfCJ\ and elcvaUoo of residence. as wcll liS Infant parity and sex. ~ustcd only for residence clcvntfm boeouso of fow nurri:Xlrs. VWJMfi 122 trruMS:il4 tAprll 2014 l Environmental Health Perspectives ( Natur~ gas d<Welopment and bi•h outcomes ·II preterm birth mid tenn low binh ~~ight, and a small positi\'e association with mean birth weight. We found uo indication of an as;ocia- tion between densily and proximity of natural gas wells within a I 0-milc radius of matcrnru rcsid'-1\CC and oral cleft prcvalcm:c. Nongcnetic risk factors for CHDs and NTDs possibly attributable to NGD include maternal exposure to benzene (Lupo ct al. 2010b; Wcnnborg ct al . 2005). PAHs (Rm et al . 2011), solvents (Brender cl al. 2002; Chc\Ticr ct ul. 1996; Desrosiers ct al. 2012; McMartin ct al. I Cl98), and air pollutants (NO i_ SOz, PM) (Vrijhckl ct al. 2011). NGD emits multiple air pollutants. induding bcn- J£nc and toluene, during the CWell t'Omple- tion D pha.i;c (when gas and water flow back to the surface after hydraulic fracturing) a~ wt'll as from related infrastructure (CDPHE 2o69a. 2009b; GarCbkl County Public rie<dth Department 2009; Gilman et al. 2013; Mc:Ken1Je et al. 201.2; Prirou el al. 2012). Ambitnt bcn?£nc levels in areas with active NGD in Nonhcast Colorado nmgcd from O.o3 to (i p.irts per billion by volume (ppbv) (CDPHE 2012; Gilman ct al . 2013; P et ron ct al. 2012). Furthcnnorc, 24-hr a\.~agc ambi- ent air benzene levels near ucti~ well develop- ment ~itcs in wcstcm Colorado r"Jn!,>cd from O.o3 to 22 ppbv (McKcniie ct al. 2012). Two previous caseU:ontrol studies have reported as.'iOCiations between m:ucmal cxpo- S\ltc to bcn~nc and birth prcvalcocc of NTDs and/or CHDs (Lupo ct al. 2010b; Wcnnborg ct al. 2005). :: e study by Lupo ct al. (2010b} of 4,531 births in Texas found that mothers Tallef3. Association between Inverse dlslance weighted well count within 1C>-rrile radius of rraternaJ residence aro preterm birth and lerm tow arth wei!jlt. ln.esedstam Oweilswiltin lo.v Me:iun weigtmweil a:ut" 10.ltil e; { IS:letile) (seonltatile) Retemtirth Uva tirth; (n) O!ses(n} £5,9)5 4,&19 1 1B,al4 1B,ffi4 1,:BI 1,aB 0.97 0.!12 Cl:dlal.":'Amit<g:! Hg. tra-d te;t ~tin:itt=Jtile) p-wlu:P 19,361 1,274 0.88 <O.OC01 ou:ea=i hfl&Ed01($"k 0f O.!E '1W, 1.0) 0.00 (0.87, 1.0) 0.91 (O.as, O.!:S) Tamlo.v tirthwagt R.11-tam rave t:.irtl"s (n) Cs;s(n) ou:ea=i . hfwoorn~~af MEEn dffEnn:e In tirth weigt(ff W,€53 2,257 1 0 17,525 525 0.79 1.0(0.9, 1.1) 5((22, 13) 17.ffiS 1S.1M 471 432 0.70 0.62 4lOC01 0.£6~.77. 0.95) -0.9(0.S. 1) 24(17,31) 22(15,29) •nrst tertlle, 1rasz wells.'rrile; second lerme, lro.::Jl25 wefls/rrile; tlird tertlle, 12601,400 wells/rrile . 'f'erlorrred as two-tailed test on 1Jl8djusled IOgistlc reges.slon. C.Adjusled for tmtemal age, elhnlcily, smoldng, alcohol use, education, ard elevation al residence, GS wel ~ as Infant parity and sex. dAdjusted for JTalei:nal llge. ethnicity, smoking, alcohol use, educa!IOI\ and olcvallon of rosldcrcc. ns well as lnlillll parily, sex.~ gestational ago. · Tablem. Association between inverse distan::e weighted well count within 1~rrile radius of rmtemal residence am 0-llJ diagnostic groops. Owellsv.ittin lo.v Mmllll HtJ lm:rse dSa'm weigtal weil Cl1J1ll 10rtiles ' (Ost:tstile) (~tatile) (ltirtitatile) On:tnrm ctia:ts Cas(n) 40 14 13 15 hf l.15la::I Cfl('H/o Of 1 \trtrlaJar ~al d;fects 1.1(0.57,22) 1.1 (0.55,2.0) 1.2(0.6, 22) c:l51s(n) 210 Ea EB 84 ,llcfl&alCR($"1oOf Ero:mdi:I a..Etiaia-d nitrcwalwcEta:ts 1 1.3(0.95, 1.8) 1.1 (0.81, 1.5) 1.5(1.1,2.1) Cas(n) 31 14 12 12 hfl&a::I Cfl('H/oO)b 0.81 (0.42. 1.6) O.ED (ll41, 1.5) 0.67 (0..33, 1~ RJmnry ..tuy onf v.ilw liiEds Cas(n) . 137 52 62 Eli hfl.15la::1Cfl(93%0f 1 Tria..q:jd vavedefa:ts 1.3(0.00, 1.8) 1.5(1.1,2,1) 1.6(1.1.~ c:l51s(n) 9 5 8 B P<f wm CR($% ap 1 Patlc artuy ar'd wlw dete::ts 2.6(0.75, 9.1}; 3.9 (1.3, 11) 4.2(1.3, 13,) c:l51s(n) 75 22 21 24 hfwedCfl~oOf 1 Al!Elt ctmsateiais 1.1 (0.68, 1.9) 1.0 (1162, 1 8) 1.2 (0.7J. 2.1) CasOi) 5} 18 17 15 hfl&a::ICR{9S%0f 1 1.0 (0.56, 1.8) 0.96lQSS. t.7) 0.83 (0.44, 1.5) "Rrst tertlle, 1Cll6i! wellslrrile; second tertile, :163".!125 wellslrrile; third tertile, 1~,400 wells/rrile. t>Adjusted cny for reslderce elevallon of beeause of low n.JITtlers. "AdJUSled for rmte~ age, el/Y1elty, srroldng alcohol use. educatlCJl, ardetevaUonol residence, as well es lnlmtparltyard se.v. f:nvironmentnl Hcnlth Perspectives r VOUJME 122 fN'JLrnm4 IApr U 2014 thing in census tracts \•ith the J1ighe:.1 ambi-(- enl beniene levels (0.9 Cl .33 p[!bv) were 2.3 I times more likely to ha~ oespring \•ith spina bi ala than mothers living in remus tracts with the lowest ambient benzene lc\ds (95% CI: 1.22, 4.33). An occupational study of Swedish laboratory emplo)'L'CS fuund a signi!J:ant a.cro- dation between CApOSUrc to 0001patim1al lev- els of bcnzx:nc in the critical window between conception, organogcncsis, and neural crest formation rutd acural crest malformations (Wennborg ct al. 2005). Children born to 298 mothers exposed to ben1.cne had 5.3 tim~ greater prcv.ileacc of neural crest mal - fonnation; than children born to mothers not exposed to bcmcnc (95% CI: 1.4, 21.1). Other studies of maternal CJqlOSUrcs to organic solvc:nts, some of which contain benzene, have reported ac;sociations between m:llemal occupational e~posure to organic solvents and maj1)r birth defects (Brender et al . 2002; ))~~osiers et al 2012; Mc."lartin et al. 1998). Although exposure to ben7.ene is a plausible l".xplanation for the obsc:rved ~ations, fur- ther research is needed to examine whether these as.<-0ciations ;ire replicated imd whether benit'.ne speci ']:ally explains U1ese ass.x:iations. Air pollntants emitted from diesel engines used extensively in NGD also may be as.soci · ated with CHDs and/or NTDs. Trucks with diesel engines arc uf.C() to transport ~upplics, ( water, and waste to m1d from gas wells, with 40 to 280 truck trips per day per well pad du1·ing dc\-clopmcnt (Witter et al. 2013). Generators cc1uippcd with diesel engines arc uSl,'d in both drilling wclls and hydraulic frac- turing. Air pollutants in dic:rl exhaust include N02. S02• PM. and PAHs. A meta-analysis of four studies ruggcstcd a<rociations of mater· nal N02 and S02 exposures with coarctation of the aorta and tetralogy of Fallot, and of · maternal PM 10 czj'losure with arterial septa! defects (Vrijbeid ct al . 2011). Two ca.~LJ control studies in China reported positive aswciations between PAH c:onreotrations in mat.emal blood and tile placenta and NTDs (IJ et al. 20 II; N aufal et al. 2010). Several CHDs were associaled with traDc rela!ed car- boa monoxide and ozone pollution in a case rontrol studyofbirlhs from 1987 to 1993 in Southern California (Rit-zet al. 2002). O c small negJlive asoocintions ~ith term low: birth weight and preterm birth in our study population were une1tpected given that other studies have reported postive as.socia. tions between there outcomes and urban air pollution (B:dlcstcr et al. 2010; Brauer ct al. 2008; De1dvand ct al. 2013; Ghosh ct al. 2012: Uop ct al. 2010) and proximity to natural gas wells (Hill 2013). It is possible that rural air quillity near oatur.11 gir; wells in Colorado is not os romproma'tl as urban air quality in these studies. and cxpo!iltrc repre- sented as ID W well counr may not adequately 415 Ill· McKenzie et al. ," ( { { ( ( represent air qualit). lo addition, the power of our large cohort increases lhe likelihood of false positive re.suits :for small associaLions close lo the null. AIU1ough associations were consistent across measures of birth weight (i.e., reduced risk of rctm low binh weight and inc..Tcasc in mean birth weight), th ey auenuatcd toward the null in sensitivity analy- sis for 2· and 5-mile radii (~ Supplemental Material. Tables S6 CS7 }. If causal, stronger asso ci ations would be expected with more stringent cxporurc dcOlions. Our incomplete ability to Dd.iust for socioeconomic status, health, nutrition, prenatal care, and preg- nancy romplications likely ;ic;counts for these unexpected Codings. This study has several limitations inher · ent in tbe nature of the availahle data. Nol all binh defects were confirmed by medical record review. Also , birth defects are most likely undercounted, because stillbirths, ter- mina1ed pregnancies, :ind later-life diagnoses (after 3 years of age) are not included. Birth weight ;md geslational age were obtained from birth certiD.otc:.5, which are generally accurate for birth weight and useful but less accurate for gestational age (DiGiuseppe et al. 2002). Data on covariates wt:re obtained from birth certificates and were Limited 10 basic demo- J,µ"aphic, educatiou, and bd1avioral infomia - tion available in the \.ital record.~ Di.moution ,of covariates runong exposure tcrtilcs and t11c uncxpo!l!rl group was similar; ncvcrthclcs;, ow· incomplete ability to adjust fur socioeconomic status. health. nutrition, prenatal care. and pregnancy complications may ha\e resulted in · residual confounding. In addition, low event outcomes (e.g.. NTDs) were adjusted only for clc\'atioa. The data set did not contain infonnation on matcmal folate amsimption ai,d genetic anomalies, both !ndepcndent ptcdictors of our outcorpcs, which may have confounded these results. We did observe a large d~ in the prevalence of NTDs after the introduction of folic acid in 1998. and small increases in lhe prevalence of CHDs and oral defis, although none of the e&imate.c; :ire statistiC!lly signiO:ant (see Supplemental M:iterial, Table Sl). Further study is needed to detennine "'hether uoaa:ounted folale cou- fouoding is auenualing our results toward the null. 0 ere is no evidence indicating genetic auomalies would differ "by IDW well count around maternal residence. B~ause of the rarity of specific birth dcfi..-cts in the study population, birth defects were aggregated into three general groups. This limited our study in that associations with specific birth defects may ha~·e been obscured. fin explomtory analysis of CHDs by clinical diagnostic groups indicates increased prevalence of specific diagnostic groups (i.e., PAV, VSD, and TVD) compared with aggrcg:tted CHDs (Table 4 ). 416 Another limitation of this study is the lack of temporal and spatial specificity of the exposure ~tent. Because we did not l11M: mHtemal residential history, we assumed that maternal address at time of delivery was the same as maternal address during the Qst trimester of prcgnancyO the critical ·time period fur formation of birth defects. Srudics in Georgia and Texas estimate that 22 0l0% of moth ers move residence during their pregnancy. and mo!it mothers move within their local ity (I.1lpo ct al. 20 I frJ; Miller ct al. 20 J 0), potentially introducing some expo- sure mLo;clac;si::r&ion for the early pregnan cy period of interest. However, these studies found little difference in mobility betw'""Co cases and rontrols a.upo ct al. 2010a; Miller et al. 2010), and maternal mobility did not signiO:antly in Lll ence tile as•;essment of hen- 7.ene e:1porure (Lupo et nl. 2010a). We were able to dt:tennine only whether a well existed withio the calc::ndar )'t!ar of birth (e.g., 2003) :ind did not have suOcient dara to ddennine if a well existed within the Ctst trimester of the pregnauc.-y. 0 erefore, some nondi O!ren · tial exposure misclil$iCbttion is likely and the owr.tll eO:ct of this is unknov..n. Similarly, wt had cousisteut infonnation only on exi~1enl.'e of a well in the birth year . Ulck of information on natural gas weU activity levels, sud1 as whether or not wells \\ere pro - ducing or undergoing developll}cnt, may have rcs.1,1ltcd in citposure miscl~Cl:ation. Actual exposure to natural g-.is!lclatcd pollutants likely varies by intensity of development activi- ties. Lack of temporal and spatial specificity of the ciq>osure as;cssmcnt ·would most likcl y · have tended to \wakct as&Jciations (Ritz ct al. 2007; Ritz and Wilhelm 2008). To addrcs.~ spatial and temporal variability, additional air pollution measurements and . modeling will be needed to improve c:<postire estimates at siiecific locations. List, infonnatlon on the mother's activities away from her residence, such as mirk and recreation , ac; well as proxim· ity of these activities to NGO w:is not avail· able and may have led to further exposure mis:la~ll:<ltiou and residual confounding. Conclusion This study suggests a positive association between greater density and proximity of natur.il gas wells v.ithin a 10-rnile radius of maternal residence and greater prevalence of CHDs and possibly NTDs, but not oral clefts. prctenn birth, or reduel'd fetal growth. Furiher studies incorporating information on specific ac tivities and production lt:vels near homes over the course of pregnancy would improve exposure assessments nnd provide more re01cd erect estimates. &cent data indicate that exposure to NGD acfr.i- tics is incrca.~iogly common . The COGCC estimates that 26 % of the> 47.000 oil and gas weils in Colorado are localed within· l 5001,000 feet of a home or other type of building intended for human occupancy (COGCC 2012). Taken tog::lhcr, our results and current trends in NGD underscore the importance of conduct ing more compcchcn· sivc and rigorous research on the potential health cO.'Cts ofNGD. Agency tor Toxic &Jlstancu 11nct Disease Algistry. '2lt1T Tadcologlc:al Ft<()e for BeruEne. Av~e: hltp"//\WNI. a rsdr .WC.gc;,//Toxfl'o:J~ .asp'lf!MQllfd-14 [accessed ZZMa'/IDlJI. Ballester F, Estarflch M, lnlguez C. Uop s. RmlDn I\ E"spfugues~. et Cl/. :mo. 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Av.iililllle: tttp:JJwww.cdot~I~ elllleilllobccf=trldala&llfolXleademarrel:O>nlent·Ois positlon&bl~oade~ent-Type&blob'leade IV31ue1=inllno~filenarre%1"'.22A!comnendedi&­ +HcuiO!cne•Areat ceslgnalio"IS#0~ottieadesva 1~1ca11on'.'3lx1f&bloblu!y:ttl\blot:eble=M~ cb;&tic:Q.\tie~1Zil~[acccsscd ~May2l1:1 . CDPHE (Co lorado Doparlmont of Publi c Health and 9Mronmcnt). 2012. />Jr &risslons Cnso Sludy A:llllled to Of and <:as ~c:pm;'fll In Bfo, OllOflldo. AvaJJ<lljc: ltttp'//w...w.color.ido.p /alfQ!Dlity/tcctLdocJeposlloiy. osp11(occ=cd2'2Ma( ~. Centers for Dlsoaso Cklntrol and l'fevcnlion. 2013. Birth Oofccts. Avalloble: http ://www.cdc .gov/ncbdddf !:(~ (occessedZZMoy all~. Olevrler C, Dananche B, Bahu<lu M. Netva A, He~ narc::me1ce1~. l!lliQ:cl.4Jlllicrllf ezpsoue 1oor9Jic sCllvert mldires cbirg preg;rcy !rd Iha Iha r isk of rm- S)ofd'QTic aal cf81s. Q:ap frNtt01Med61617i:&!l cx:a:::c (Cbiorado 01 Md Ills Olnservlltlon CanniSSf()'I). am Slalemn ct Basis. ~a: s.tuory Atlhcriy, ;n1 ~: New F\.les rid Amen<tnnls to Onent f\Jes DI the Qilorado 01 el1d Gls O:roservatlon camisslon. 2 ccr ~ l Avallatf e: lttp"//cogcc stale.co.us/ (accessed ZZMay all~. VWJ1,1E 122 IHU~·eCR4 IAp rh 2014 t En vironmental Heal th P<!rs pccliv c:s a:a:c (~craoo 01 ord Gas O:nserv.Jl/a1 Cmmssic:n). a>t2. Slaff Fllpcn. 0:.Clfalb Oepal1lrerl d Natural Riscuces. Avallable: ltt17//cog:c.slale.CQIS' [ai:ce!EEd 22 May 3)13j crGS (Colorat1:l 01 and Gls lnfonmtlon 9,'stem). 3>11. Well Production cetabase. Vol. 2011 . Avallable: hl!17//cogcc . sta!e.CQust [ace~ 22 May 3:113). Olitxrn T. Kwlallo.•sld C. S::hlitzK. 8acllran M. 2Jll. Nal17al gas cperalia'ls Iran a pittoc l'ealtll perspeciive.1-lm ECQI Fl'ikAo;ses 17:11llOtBl CK'SN (O'.llcmro ~to O"liliten with Spocl.11 Needs). 2011 . 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Q:e upatlonal exposure to resplrable crystnlllno sllic:i durif9 hydraulic 1raclwlng. J Cl:ct.p Eilvllon I lf!I 11X7}:317'.:Im;ctt101WY~210l7lll:m rrnzier A. l100l. AmiJysfs ot Data ~nlned for the ~rlleld O>w1ty Alr Toxics StudyO Summer 2000. Available. http;~'www.garfleltkolny.com'alr-QISllty/~nenl!/ ai rquallly/2008_ Taroeted OLancU~1s_ Moni1orlng_ A!pal.pdl [accessed Z! May 3l1Jl. Garf1eld O>irrty Public Heallh Department. a:m. Garlleld Qu4y 2001 AJr QJal~y Monitoring Sunrary Available: ht1p;l/www.gar11elc!-coi.nty.corn'alr·quallty/docunents/ alrqualtty/3Xl9 .Alr~Monltorlng_Feport.pdt (accessed Z?Mayall:J). C!hosh Ji<C. Wilhetm M, Su J , Goldberg 0, Oxl<l>urn M , Jetrell!M , el!lll. 2012. ·llsse;;.<;ing Iha k'IW!nee d trafiJ:· related air pclil.Clnnon risko/ lennlow tirthweq. on ttie tmsi5ol Jand.use-tmed r~a1 rrcxlels andrre.'1.'IU'e5 ofalrtadcs.Am.I epdenial 17!i13roZ74. Glhoa SM, Meodala P, Oshan AF, Langlois PH, 5.1~11z DA. llXni.~ 0, el::il. am ~ation lllltween antienl Dir CJ,oilty and selected birth delccts. Seven Cbuty SltDf, Tei<:\9, 1!117ilm>. MIJ q,ide<T'la 1GZ(3):ZRPS?. Olrmn JB, lolllCr RM, Ki.eler WC. do <:aw J 20!3. Soiree slynahro of vclalllc ay;v'ic CClfrpoi.nds (\/Oll) ln;rn oil lllld natural gos opcrallons k1 northoostcm COtorado. 8'>1il0l,Sc1Toctnd (1{3l:1297D13li. Hll a 201:1 UiccnvcntiOllOI, Natural Cas Oovt..fqm:nl and lnfilfll ti(.'Utth: Evidence from Pcnm.j1vanl11. IU111c c1, NY.Oiartus Dyson School of Applied Econarics and M<n11,j(JrU1, Ccmcll U1lv<nity. AWllllblo: http'//clyson. comell .edulrcsoarch/rosoarcl1pdt/wp/2/J121Comcll· ~1212¢[acceS00<17MWl3M]. Henein M, f\lsml.men S, Aaefhuts J , R:mttl P, lan'm!r E. Soo l, el!l!J. a::m MOlemal sirdllng and envl~lll Natural gas development and bi rth outcomes ll . tobaccosroka exposure and the risk al aofaclal clelts. et::al. 20!2. l+jdtocattlon emlsslc:ns characlerimllon In ( Ej:Jldeniolcg'f 18:l!21iEJ. -the Q:iorado front range: a pita SIW/. J (;eopl1fs Fbs Kemball·CbQk s, Bar·llan A, Gr:llll J, Parker L. Jung J. 117:J:Oml;dd:I0.1cm':<D11J0016Jn Santamaria W, el l ~. 3:110. Ozcne frrpat:ls ol natl.Jal gas Ftn A, OuX,J'nL MaJ, UZ. 2hang L ellll.2llt. Assoclallon U!velcprert In the H.l)nesvilk! shale. Ehtlron Sci Techlol ol selecled perslsletll organic polluants in the placenta 44:9357'.JIEl with the risk of relllll tube deteets. Fl'oc Natl Aced Sci King Ge. :c!OI:?. Hydraulic Fracturing 101: What Every USA 1<R'1277!U2775. Fepresenatlve, Effltrcmientallst , R?gulat04', R!porter, Rti: B, Wiiheim M . axe. Millen! air pol ll.Clon and IKtlerse lnl!eSlor, Ullversny A'lsearchet, NelQtbor and Eilgioeer birth ot.lcoi~ Melhod:lo!jc Issues In 1111 em!l!#rg Qlld ShotAd Knov.-1\txlul ES!broling ffac Rsk and lfTP'OVlng ea..;c ~ A~lmncclT(Jl(lcol 1<21£.l!D. Frae Pertom1a11ee tn Unconvent nn.11 G:is end Oil Atz B, Wilhelm M. Ha!JIJ;ltl Kl, <:hlAll Jiq:;, 2001. Ar!Dent air Wells. /\l'llll:itlle: htlp:/lfmclocus.01)fsltesldelnult/lfl~ pollution and i:relemi birlh In lhe fflviram?nt ancJ preg· publicnllons/hydra111lc _t rachirlng_J01.pdf [accessed narcy oiJcorres sttdf al the UWoC$ily ol Ollifoni.i, Im GMall:hal14J. An(Jeles. Am ,I d Ejjderriol 1ffi1()1S;!Cli2. U Z. 2l~'lfl{l l. Ye A. All l, Uu ,I, 21-eng X, el:!ll 2111. IM:xr air Alz B, Vu F, Fruin S. O!Jpa G. Sh.1w t'M, Harns JA 2002. po111fon fran coal r.arb.J;tlnn nnd thn mk ol newal tlbe llrrtierc air polh.llon and risk d hirlll <klfllCts in sa~m clcfcx:ts inn Mai pqiUa!ion In 9a11ci Frotircc. Olina. .Am OllllCJri3. AmJ ij)icbriol 155:17i.P.i J E"Ji00rri<ll 174:451re A;mttl r, an L., lblan M, Rxlllllis J, 0m::a A. Rlsrrt£scrtS. Uc.ip s. Ballc:.1~'1 F. E>tarllch M, Elplugucs A, R:mgktto M, 'lOOI. Malcmill pc.-ricalc~wl nlcchll coni;wµo1 aotl l!J!µ:z C ro10. Pr~1cnn t:lrth and ciposurc to nir pol'-1.C· risk cf orcf..:l;j clch hnJ Ej:li\brial 116.Tr:iJ!li antscl.rfrgpr0!1'GlllC)'· lilvin:il ~ 11Cl7i&Jm. 9-qErdT 1!m Ag:rlslll.11 Cllll>Q birthctefOCls. Yu'6C!Mcd:t Lupo PJ, Symanski E. Olitn W, Mllchcll 1.E, Wal er D<, ~ Ovil:llld MA. ct:a!. a>llh. Offcren:cs in C!lllllUO ass~ U.S BA (U.S 1'i-aw lnfC11r'lllion Sf.>!an~ :<U11a. lrtcrnallonal met• bctwoon conccptlar1 and delivery lho fnµict cl E'ncrgy C:Ulookro11 . OCGElA-0484(2011), Wnshlngtm, nulcrr~~ nd.Jilily. rtmair r\.'finm f'pcilrriol :!4axr.roi tcU.S BA. upo P, ~ E. Wnllllf 0. Chan W, lln;llosf P, Qin~~d.M, U.S. BA (U.S. fnergy lnfonrallon ~stem). 2011b. lbvlew etlal. 20Uli. Malernal exposure to ambient levels of cf Emerging fesa17ces. U.S. Sh<lle G.ls Ollld Shale QI benmne and neural tube defec:ts among offspring, Rays. Avollot1e: httpJ:www.el:1.ge>1ianalysls/studfesl Te= 1!!lf'Jm1. Ln.iron He<llth l'llrspect 119:~ ISSl1al~pclll£Shalep~ pdf (;icc;essedZ! Mey201Jl. dol:1D.1aD'etp.100?212. Vidas II, 1-iugmnn B. 2W8. Ava lablllty, &:onomlcs , and Mcl<enna MT, Michaud CM , Murril)' CJL. Marl<s JS. 2W5. ""odU:tlcn Potential of North Amlrican lh:aiventkn:ll Assess~ the budEn of cbeme In the Oliled Sitm u;ing Natural Gis &.waes. Avallallle: tt.tp-J/wvtW Jngaa.org1 dsalilily-~usted Nie year,. M'IJ ft.,,. Med ::B.•tSJlZI. Ale~~cUlJJ'Ol-OOZ!MB'f 201~. Mc~el.M, Wiiies ~ Newmin IS,AdgeleJL 3)12. ftlTwl \ttjheic.f M, MartirezO.M3113la1esS. Cbdl:rd P,&::ne11tiari'A. heallh rlska,,sessrrert of air errissions frcrndevefqm!nl fbnl<Jn J , el'al. 2011. An1lient air potluUOll and risk of of tr.cal'lel1icn;il nattr.11 gas resout:es. Sci Taal eMrai congenilal anomalies: a sys1emat 'c review and meta· oG1:79:1!7. om1ys1s. &Mttl'l l-l?ailh f'lnpect 11~ dli:10. ian· McMartin Kl, 01U M, Kopecky E. 6narsm 'IF\ Koren G 1!91 dl), 1Cll91i Pre91ancy outcani following rrolemal organic &olvEnl Wald N, SnedcbJ J 1001 . Preventlcn cl neural hbe defects: CJ<pOSU'e' a rrela-analysis of epkbriologlc shoes. Arm Fhsutts of lhe medical researc11 co"1Cll vitnmn sludy. Jlnc1Med31:3B:m!. lsncet3:BIJ1, Miller A. Silte! c, Oirrea A. a:>IO. Alsfdenllal rrcbl Hy ming Walther E 2lll 1 Saeenlng Heallh Ask Assesstrrlr-. Stblette Plll!1'1'1Cy. p:llt<lml nuclco-rel:lleoi. MaternCh'lclHealJll!J Oxny, Wyarrirg. Sfml1·0Mn Avait:ible: htlp:fiwww. 14:t:l2&:ID\ Aublettewyo.C01n'Ooci.nentCenter/HomelView/431l Nallcn.'11 0 111ler la' Heallh Slalislics. 3)11 Oasstflcation of (ncc-122 May 3>1~. c:Hse.~es and Injuries. Avilllable: Up:/lltp.cdc.!JOV/Pl-f>' WelVlborg ~ Magnussai L.. BarJde J, OsmJ. 3X5 Olngetlltal Hoallh_Slatl~lic!!INOi..<;'PubllcallonsltCD-!Vucod .l.xt 1mlfClfrm1icm related to rmlemal axposure lo i;pecilic {accessedZ! May a:ll3J • agents In b aredical research laboralorles. J Occup Naulal Z. 2Jlfwen l., Zhu I., Zhou cm, Mr.COOald T, He L V. • e-Mron Med 47:11019. el elf. 2010. Blormrl<ers ot CJCP0517e to corrb.lst on ~-Winer f\ Mcl<tlru!a I. Sll1-son K, Scdt K, Ne.vrmn l., MJajef.I prcci£ts ii n huJt1n pCipUrcll<ll in SIOIOll, Olin:~ J &JX.19 2013. 1ho LISll a ho3lth lcrpllcl ilS$CSS1T'Cn! for 11 com- Sci &Mrc:n fPOOrriol :!(231CDJ19. 1TU1ity mdc•ycir>J l"Eil1r.il gas dfM:lopn:rd. Am J f'l.tlic NfCllTfll'CI' S. Araado Mollinodl r. 1-tJc:ho L 2XD. (!•1d l-eafff 1 tblth 1<Xl (6): d:i: 1021(lf AJF'Ha)12.3'1017. undtMngl!ll'st1ollittdo.ArchllsCl"ild~~1. 7.iol fnska B Fu:itn £ Ciu1'lboll D. 2011. Monitoring ol Onguor EP. 3l12. The polcnlia1.no:ir·sc:uce 1120"11 ~ erisslcnl from Bilrnett Slllllo Nat"31 Qis A-ockJcllon of i.pstrwn oil and~ lrU.Btry misslaa J /lir Wnsto P.K:ll lt os fClf Alp.iatlon &posuro Asscssrrent. CCsort Milm,I A_,;~-fl:oscarch lnst~ire. Alr.litable: t11ps//Slt\IJl1.cdiDICJWrd' Parlc:r SI; Mui CT, Cln!llld MA, Aclowd R W..r,i Y, MUJ'l.'I rE, attachmcnts/~1%:'t151lttle'!'a20Slucly%20Mnal~ atial. 2010. Upd.11~'<1 nalfonaJ birth prevalence cstirn:dcs R:pcrt .!Xf [occ~Z! May 2013J. for selected t:lr1h defects In tte u-iled 9ates, lID1llll.6. BinhC)!fects FbsAOln Mol leralol 001«XllJI016. POrcn G, HOSI G. Miiier BR l-lrscll Al, Mcroka ~ Kmlcn!A. Environm ent al Hc :t hh l'cr.;pcctivcs t vo 111t.1E 122 ltiuusrn 4 IApril 2014 4 17 (') EXHIBIT IVY Comments from Bob Arrington on Ursa Resources Pipeline Application, pg : This section is critical. The fresh water, produced water, and gas pipelines must be anchored in this bore. If anchors are concrete, steel or wood, they will be subject to a corrosive soil. This information is missing and needs to be part of the application. While the bottom joining is not clearly defined, it is a critical point of load without load relieving anchors in bore. These changes of direction in the gully must be smooth transitions to distribute load. There will be shear stress added to this because pipe in gully may be subject to buoyant lifting forces. For the bore tunnel and underground piping, water seepage can erode and weaken the entire ground and saturation can occur both inside and outside the soil covering. This could allow the entire profile, at least up to the bore setup area to flow into and across the gully onto the pad. This is comparable to the landslide that destroyed a WPX gathering line upstream under CR302 down to the bottom of the Morrisanna Mesa in the same type of hillside, This pipeline cluster would be more disastrous as there are three pipes with produced water, water, and NG. This would allow the water to flow into the Colorado River upstream of the Battlement water inlets with NO time for warning or shutdown of the inlets leading to contaminated drinking water storage lake. There are no plans submitted showing any automatic shutdown for URSA pipes. ~~~!~~!!1~3!fi~!J~!!li~i~~~!~!l t l ~~! OIMIZ vii N11H)l'"" ¥ ~ • Si· tt~ ~~ . -· -! --l . ' \ ', ----·~ I ~ ......... __. ......... \ >, - I I '. . ', I• • ! __ .,_ ) -< ,:;; 1, 'j I j ; . 0 *Referenced Note 0 0 Moving Pads Outside PUD Using existing Pads Using the Pads Tompkins, Stierberger, and B&V (possibly Yater) and the attached diagram of drilling, pads B, 0, L, and M would not be necessary. These pads coutd be used at 1 mile reach using a 30 degree reach. A new pad might be placed in the vicinity of the road take-off area (below Tompkins). Surface 700'" c""•l.n9 " lnc:li.n~ •ho wn at <1eolo"1Y n'lile:~t.1nQ --------~------~·­.- -· 5000/depth of formation JO doq. lnctino . -,. -,,. -.:.,...- 2800' Offset Offset Reachs for Format~on Depths A 30 deqr.e pi.tch dawn wou1d re•ult i.n a reaoh ol: -1 mi.1.• and an J.ncr-•• a t the 3900 • cs.pet> to reach -3500 ' . But dri.11 p.i.-to t.. yaed S.n lCi.obraza .. O\&l.d "'~"'• 1••• than th.i.• to go .i.n a ~o.,..t.i.on cU.ppi.nv 3 .5 devr--• or hori.aon ta1 . -------- for 3900' depth 1700' Ca5ing cal.led for in appl.ication 3900' depth of formati.on Sca1e un~t -1000' 5000 I Green line at 30° incline over 5000 foot offset. Red line representative of Geology presentation by URSA (45° incline 750 feet casing-not shown their example). Black line using 1700 foot straight line drilling with casing, 45° incline, resulting 2800 foot offset as shown in drill patterns of Pads B &D. Blue line shows offsets for the 3900 foot formation These are offset reach from various pads. All are approximately less than a mile, but do give complete coverage of the remainder of the PUD. Notice the line of reach points down the Golf Course zone. Stierburger is referred as Monument Ridge B in new plans. UNew Pad" is an alternate for Tompkins if that pad is unusable . Elimination of B. D , Land M pads. In the drawing above : The red close dotted lines are a representation of what URSA showed at their "Geology" meeting. They started their bend radius at a 750 foot level (45 degree incline) as opposed to the 1700 feet of casing* they stipulate in their application . But that is not to say they can not bend the casing pipe as they do drill pipe; however, bending at 1700', level they can reach a mile at the 30 degree inclination (green dotted line). If drill pipe drag is claimed as a problem , p ipe supports can be used as done in full horizontal drilling . .. Casing refers to a larger diameter pipe and outs ide cementing to add closure to water bearing formations tapped by surface users . Production piping is inserted into an open annulus below this casing . At the beginning , there is an even larger diameter pipe and outside cementing that allows valves and access called a "conductor". Submitted by Bob Arrington P .E. 0 ( ( Proposal for 53 gas wells in Battlement Mesa, Colorado Matthew Sura Attorney at Law (720) 563-1866 mattsura.law@gmall .com Additional reports requested by planning staff prior to Planning Commission recommendation 20. Prior to a recommendation by the Garfield County Planning Commission, the Operator shall develop a more formall;,;ed 24/7 fast-action complalnt receipt and response program that will ensure residents have Im mediate access to re port and begin resolution or nuisance or safety issues that may arise. Additional reports requested by planning staff prior to Planning Commission recommendation 21. Prior to a recommendation by the Garfield County Planning Commission, The Operator shall demonstrate a t horough r esearc hing of cur rent technologles available to control emissions and odors for all operational phases contemplated for the proposed locations and clearly describe mitigations and BMPs considered most opti mal and feasible to prevent Impacts to nearby residents . EXHIBIT I W 'W Additional rep orts requ ested by plan ni ng staff p r io r to Planning Com m ission recommendation 27. Prior to a recommendation by the Garfield County Planntng Commission, the Applicant should provide the site specific SPCC plan for Pad D. The Applicant should provide additional information on the storage tank sizes, how those tanks are to be interconnected, the volume of secondary containment to be provided including precipitation, the anticipated leak detection, and how the precipitation events would be safely drained from the secondary containment. Battlement Mesa Concerned Citizens' approach 1 Are there more appropriate locations? l If not, are there additional mitigation measures that can limit the impacts? Oil and gas development is a heavv industrial activity NOT compatible with residential areas 9/24/201 5 2 Industrial Performance Standards •Section 5.03.08 Industrial Performance Standards: All industrial operations in Garfield County shall comply with applicable County. State, and Federal regulations regulating water, air and noise pollution and shall not be conducted in a manner constituting a public nuisance or hazard. NUISANCE A substantial invasion of an individual's interest in the use and enjoyment of his property. D Pad Staff Report -Pa g e 19. "As menll oned above, lhe acllvlllu on the 0 pad will generate nuisances (noise, traffic, emissions, dust, and visual Impacts) In the short term (approximately 1 year); however, there Is no expected or anticipated physical damage to these adjoining propenles with 1he development of the O Pad so long as the proposed mitigations are properly Implemented.' 9/24/201 5 3 ( IMPACTS TO AIR QUALITY AND WELFARE Dust and emissions from heavy truck traffic 9/24/2015 4 Condensate Tanks Increased risk to public safety? Industrial accldencs 9/24/201 5 5 Six tank explosions and fires in two months in 2014 .chool 1old 10 ·1htltu 9/24/2015 6 9/24/201 5 7 Drilling near homes requires an ALTERNATIVE LOCATION ANALYSIS --~--· --... ----···-· COGCC Rule 604c.(2)E Any "multi-well production facilityn that is proposed near a residential area must prove it is located "as far as possible" from homes. 9/24/2015 8 For the siting rationale, please provide COGCC with m ore info rmation in regards to : Multiwell p roduction facilities shall be l ocated as far as possible from Building Units. The reasons for selecting or not selecting a locatfon may Include, butare not llmlted to: • Technical and economic reaslblllty, • Envlronmen~I and topographic considerations, • Right lo construct considerations, • Surface Owner and adjacent owner considerations, • Cultural concerns such as access, Infrastructure, pro•lmlty to Bulld ng Units, and ruture development plans, etc, • Public concerns, and ocat government Input. i I J-J !~!. i -· it~ i ,-~~ !. '1 I I .o. +•• t T • f -·· ·~ : • •i..i ....... ,~­ -~ -"'--··- -· ! : : .. .. ... 9/24/2015 9 Mineral Resources Midtown Directional Location 5/31 /13 Mld!own Dlrt<tlanal ~ 37 wells and assaclaled equipment have been appravod loss !han 400 feet frorn an apartment camplex 9/24/2015 10 -.. J. . ..,"! ... ,.,. .. ·.~ .. " I • Battlement Mesa Concerned Citizens' approach 1 Are there more appropriate locations? If not, are there additional mitigation measures that can lim it the impacts? 9/24/2015 1 1 9/24/2015 12 ( l t i.L TERNA TIVE ux:A TION ANAL VSIS . ~i. ~,,~-:i 4 ~ . ~.~ '- . ~ • . .. 9/24/201 5 t • 13 BEST Management Practices APPENDIX A BEST MANAGEMENT PRACTICES FOR PAD SITE LOCATIONS Dlilance lo Erle lulldlng Units. For the ldentlli•d Wtll P~cb, th• minimum dlsu1nce between ai well or surf.ace equlpmenl and rhe ne•rest e111tedor wall of iln e111btlng Ede BuUd•n9 Un•• (n of the Ellective Datel •hall noc be leu 1han the following • Osbrson 8, 990 feet • Morgan Hi ll 2, 190 fut • Woolley Beckey Sosa 1 ,0 Io feet • Woolley 2,450 feel • Erle Vessels 1, 17S feet • Cosslett 1, 150 feet • Wiiiiam Peltier 1,900 feet • Vessels Minerals I ,050 feet BMPs from the Erie and Encana Operator Agreement August 201 S 1. Distance to Erle Building Units-at least 1,000' 2. Noise mitigation -60dBs 3. Central Hub -comprehensive planning 9. No class II underground Injection control wells. 9/24/2015 14 ( Questions Planning Commission to ask Ursa •Where is the required Alternative Location Analysis? • Additional reports to define the "fast-action complaint response" and spill mitigation programs? Are you planning to have fire suppressant systems {foam) onslte? A plan to notify residents of an emergency? •Would you be willing to meet 60 db noise · · . standard that Encana agreed to in Erie? 9/24/2015 1 s EXHIBIT • STATEOF COLORADO I X. '/-. Milliken Investors doc no 400837985 Treitz -DNR, Rebecca <rebecca.treitz@state.co.us> To: Callie Fiddes <cfiddes@gwogco.com> Thu, Jul 9, 2015 at 1:54 PM Callie, Thank you for the revised 305.a. letter. Please provide a 306e certification for the Milliken location. Also, are there plans for the concrete flume to stay in place? This is considered a surface water body for the distance under the water resources section to be 0 ft. Otherwise the distance to the nearest surface water body on the 2A does not match the distances provided on the Location Drawing. Please confirm the distance to the nearest surf ace water body from the edge of disturbance. The distance provided on the 2A to the nearest water well appears to be from the reference point and not the edge of disturbance. Please confirm the distance to the water well located nearest to the oil and gas location. As indicated on the 2A, the location is in a water sensitive area. Please provide information on what type of tertiary containment will be used per Rule 604.c(3). B iii. For the siting rationale, please provide COGCC with more information in regards to: Multi-well production facilities shall be located as far as possible from Building Units. The reasons for selecting or not selecting a location may include, but are not limited to: a) Technical and economic feasibility, b) Environmental and topographic considerations, c) Right to construct considerations, d) Surface Owner and adjacent owner considerations, e) Cultural concerns such as: access, infrastructure, proximity to Building Units, and future development plans, etc, f) Public concerns, and g) Local government input. Supporting information to include on the Siting Rational attachment may include; Thank you, Rebecca a) Figures, not limited to: tax assessor map screen shots, flood plain maps, property surveys, aerial images, maps or aerial images showing Building Units and depicting radii showing the relative position of the Oil and Gas Location. b) Narrative descriptions of interactions with Surface Owners, nearby Building Unit owners, Local Governments and neighborhood organizations. Please let me know if you have questions. https ·lfmail.google.can/m aill?ui= 2&ik=5d53610199&view=pt&q=cfiddes%40gwogco.com&qs=true&search=query&th=14dda70487eecee3&sim I= 14dda70487e . . 115 t'. I APPENDIX A BEST MANAGEMENT PRACTICES FOR PAD SITE LOCATIONS 1. Distance to Erie Building Units. For the Identified Well Pads, the minimum distance between a well or surface equipment, and the nearest exterior wall of an existing Erie Building Unit (as of the Effective Date) shall not be less than the following: Oskarson 8,990 feet Morgan Hill 2,190 feet Woolley Beckey Sosa 1,010 feet Woolley 2,450 feet Erie Vessels 1,175 feet Cosslett 1,150 feet William Peltier I,900 feet Vessels Minerals 1,050 feet Compliance with this requirement shall be determined from the actual as-built locations of the well or surface equipment. Nothing herein shall be construed to grant Encana any surface rights on property owned by the Town or another person. No Pad Site will be located on Town property without authorization by the Town Board of Trustees. 2. Noise mitigation. Encana will comply with the following noise mitigation requirements at all pad sites: (a) For db(A) scale noise, Encana will insure that the noise level from operations subject to the light industrial zone noise standard under COGCC Regulations 802.b and 604.c.(2)(A) does not exceed sixty (60) db(A) and that the noise level from operations subject to the industrial zone noise standard under COGCC Regulations 802.b and 604.c.(2)(A) is reduced at least five (5) db(A) below the maximum level permitted by those Regulations. For this pwpose, the noise level shall be measured as set forth in COGCC Regulations 802.b & c, except no measurements shall be taken when traffic is passing the sound level meter, Encana shall be present during all measurements, and building units shall be limited to those units existing as of the Effective Date. As set forth in COGCC Regulation 802.b, the noise levels shall be subject to increase for a period not to exceed fifteen (15) minutes in any one (1) hour period and reduction for periodic, impulsive or shrill noises. (b) For db(C) scale noise, Encana shall comply with the requirements of COGCC Regulation 802, as such requirements may be amended during the tenn of this Agreement. ( ( ( 3. Central Hub. In an effort to reduce air emissions, Encana intends to construct a central gathering and storage facility at a location in IN-68W-Section 21 (the "Hub',) to receive liquids from the welJs which are the subject of this Agreement. As a result, Encana will not install hydrocarbon storage tanks at these pad sites, which will eliminate potential sow·ces of hydrocarbons from the sites. However, Encana will still install at the pad sites all other eqµipment and facilities necessary for the production of hydrocarbons, including wellhead equipment, separation equipment, electrical equipment, and temporary flowback equipment {including temporary storage tanks). Jn addition, this BMP is subject to Article IV, Sections 3 and 4 of the Agreement. 4. Well leak detection and repair (a) To identify leaks, Encana will perform audio, visual and olfactory inspections on a monthly basis at all of its new and existing wells and related facilities and equipment within Erie's Town Limits, provided that such related facilities and equipment are located on the pads for such wells, are part of adjacent tanks used for such pad sites, or are part of storage tanks for such pad sites authorized under Article IV, Section 4 of the Operator Agreement. Encana will also inspect each such well with an infra-red camera on a monthly basis. The initial baseline inspections will occur within sixty (60) calendar days after the Effective Date. After a well has produced for twelve (12) months, the frequency of such inspections shall decrease from monthly to quarterly. If Encana determines that any repairs are required based on these inspections, Encana will promptly initiate these repairs. (b) Encana will report to Erie on the inspection results and any associated repairs the month after the inspection or repair occurs. This information will be collectively reported on a monthly basis in the same format that Encana uses for reporting to the Air Pollution Control Division under Regulation 7, but that is specific to wells located within the Erie Town Limits. Erie will make this information publicly available. (c) This BMP will terminate five (5) years after the Effective Date, after which Encana will continue to comply with the leak detection, repair, and reporting requirements of Regulation 7, as such requirements may be amended. 5. Contact information. Encana shall include its contact information on both the mailed notice required by Article ill, Section 8 and the posted notice required by Article III, Section 9. This information shall include both a telephone number for Encana and the address and hours of Encana's Erie community office. Members of the public with concerns or complaints regarding the oil and gas development covered by this Agreement may use this information to speak with Encana. 6. Steel-rim berms. Encana shall use steel rim berms or some other state of the art technology that wiU contain fluids and other material instead of sand or soil berms. 7. Closed-loop systems. Encnna shall use closed-loop systems for drilling and completion operations. A-2 .7 0 l ·.: ( ( 8. Lighting. Encana will install down cast lighting or some other form of lighting that mitigates light pollution and spill-over onto adjacent properties; provided, however, that Encana may still use lighting that is necessary for public and occupational safety. 9. Class D underground injection control wells. Encana shall not develop any new Class II underground injection control wells within the Operator Agreement Area during the Term of this Agreement. l 0. Recycling and reuse. Encana will recycle and reuse water at the pad sites and otherwise minimize waste water production to the extent that it determines such recycling, reuse, and waste water minimiz.ation is technically and economically feasible. 12. Town water supply. To reduce truck traffic, Erie and Encana will encourage the use of nearby water resources for the drilling and hydraulic fracturing of wells at the pad sites, including the use of Erie municipal water when detennined technically feasible and economically practicable by Encana. 13. Traffic. Encana will implement the Traffic Management Plan required by Article III, Section 3, Subpart 10. 14. Road repairs. (n) Erie and Encana recognize that truck traffic accessing the Identified Well Pads may cause damage to Erie roads and that road repairs may be needed to mitigate such damage . To this end, Encana will arrange for a qualified outside consultant to perfonn a road impact study for all Erie roads that are used to access an ldentified Well Pad during the Term of this Agreement. The consultant wiH conduct the first part of the study prior to Encana's operations at such Well Pad and the second part of the study after Encana completes all drilling and hydraulic fracturing at such Well Pad. Encana and Erie will use these studies to detennine the extent of any damage accruing to the road during the study period. Encana will then promptly pay Erie to repair such damage or else arrange and pay the cost of such repairs itself whichever Erie prefers. (b) Encana shall maintain Financial Assurance to secure its road repair obligations under this Agreement. The amount of such Financial Assurance shall equal Erie's annual road maintenance budget as of the Effective Date multiplied by the percentage yielded by dividing the total number of Erie road miles as of the Effective Date into the number of such road miles that Encana will use to access the ldentified Well Pads. Encana shall select the form of such Financial Assurance and shall maintain such Assurance until Encana fulfills its obligation to repair road damage under Subsection (a). 15. Access roads. Access roads to well and production facilities that connect to a street within Erie shall be improved from the point of connection to a street within Erie a minimum distance of two hundred (200) feet on the access road as specified by the then current ( requirements of the Code. A-3 ( ( ( 16. Fencing. Oil and gas well facilities (above ground) within the Erie Town Limits shall be fenced as specified by the then current requirements of the Code. 17. Operations conducted in accordance with plans. Encana shall conduct all operations in accordance with the plans discussed during the Conceptual Review Process as updated from time to time. 18. Hydraulic Fracturing Responsible Products Program. Encana has developed and implemented a company-wide Responsible Products Program to manage the fluid products used in its hydraulic fracturing operations. This Responsible Products Program helps Encana evaluate the hydraulic fracturing fluid products it uses in its operations for safety, effectiveness and potential public health and environmental impacts. As part of this program, Encana has informed all of its hydraulic fracturing fluid product suppliers that any products containing diesel fuels (as defined by EPA 816-R-12-004), 2-Butoxyethanol (2-BE), benzene or heavy metals (i.e. lead, mercury, arsenic, cadmium and chromium) cannot be used in hydraulic fracturing at Encana operations. Encana will continue to conduct its hydraulic fracturing operations within the Erie town limits in accordance with its Responsible Products Program. 19. Revision of best management practices. Upon the request of either party, the Parties may revise one or more of these BMPs if they mutually agree such revision would better avoid or mitigate impacts the BMP(s) is intended to address. A-4 ( 0 APPENDIX B OPERATOR AGREEMENT AREA MAP -- ( EXHIBIT I t-1 ( ___ ...... LAND TITLB GOARANTBB COMPANY THANK YOU FOR YOUR ORDER September 24, 19.98 our Order No. : GW3098 OWNER: wn.L:tAM J. DEWINTER, :r:r:r AND SUE A. DEWINTER, as Joint Tenants ADDRESS: l.l RIVER 'nBW PLACE, PARACHUTE, CO Bl635 IFOR ANY FOLLOW-OP PLEASE RBFBR TO OCR ORDBR NUMBBR : GWJ0.98 DELETED! PARACfftJTB REALTY me. -3378 COUNTY ROAD 301. PARACHUTE , CO 81635 Attn: KATH MONEY Copies: 2 SOB DEWINTER -c/o ALPINE BANK AND TROST 2200 GRAND AVENUE GLENWOOD SPRJ:NGS, CO 81601 Attn: Copies : l ( ( Form AO 4/95 Order No. GW3098 1. Policy Date: 2 . Name of XDsured: SCHEDULE A Policy No. SV2148332 Amount $214,500.00 Address 11 RIVER v:CEW PLACE, PARACHtJTB, CO 81635 November 04, 1994 AT 4:06 P .H. WILLIAM J. DBWINTBR, IU AND SOE A. DEWINTER, as Joint Tenants 3. The estate or interest in the land described in this Schedule and which is covered by this policy ill: A Pee Simple 4. Title to the estate or interest covered by this policy at the date hereof is vested in: WILLIAM J. DE:WINTBR, III AND SOB A. DBWINTER, as Joint Tenants 5. The land referred to in this policy ill situated in GARFrBLD Cowity, Colorado, and is described as follows: LOT 8 BLOCK 3 W!LLOW CRBElt VJ:LLAGB, SBC'l'J:ON ONE THE PLAT OP WHICH IS RECORDED AS DOCUMENT NO. 321237. COUNTY OP GARFZELD STATE OF COLORADO I ( Form AO 4/95 Order No. GW3098 Policy No . SV2148332 SCHBD'OLE B This policy does not insure against loss or damage by reason of the following: 1. Rights or claims of parties in possession not shown by the public records. 2. Basements, or clai111a of easements, not shown by the public records. 3 . Discrepancies, conflicts in boUDda.ry lines, shortaga in area., encroachments, and any facts which a correct survey and inspection of the premises would disclose and which are not shown by the public records. 4. IUJ.y lien, or right to a. lien, for services, labor, or 111aterial theretofore or hereafter furnished, imposed by law and not shown by the public records . 5 • GENERAL OR SPBCD\L TAXES AND ASSESSMENTS RBQUIRED TO BE PAID IN THE YEAR 1'95 AND SOBSBQOENT YEARS. 6. DBBD OP TROST DATED November 04, 1994, FROM WILLI.AM J. DEWINTER, III AND SUB A. DEWINTER, as Joint Tenants TO THE POBLIC TRUSTEE OF GARFIBLD COONTY FOR THB OSB OF ALPDm BANK & TROST TO SECORB THE SOM OP $140,000.00 R3CORDBD November 04 , 1.994 , IN BOOlt 921 AT PAGE 440 UNDER RECEPTION NO. 470588 . SUD DEBD OF TROST WAS ASSIGNED TO DYCORP MORTGAGB INC. IN ASSIGNMENT RECORDED November 04, 1994, IN BOOK 921 AT PAGB 446 ONDER RECEPTION NO. 47058.9 . 7 • THB EPFBCT OF INCLUSIONS IN ANY GENERAL OR SPECIFIC WATER CONSERVANCY, FIRE PROTECTION, SOIL OONSBRVAT:ION OR OTHER DISTIUCT OR INCLUSION IN ANY WATER SBRVICB OR STRBET :IMPROVEMENT AREA. 8. lUGHT OP PROPRIETOR OP A VBIN OR LODE TO EXTRACT AND REMOVE HIS ORB THERBFROM SHOULD THE SAMS BB FOOND TO PENBTRATB OR INTERSECT THE PREMISES AS RESERVED IN UNITED STATES PATENT RBCORDBD October 06, 1902, IN BOOK 56 AT PAGB 462. ( Fo.t'111 AO 4/95 Order No. GW309B Policy No. SV2l4B332 SCHBDOLE B 11. EASEMENTS, lUGHTS OP' WAY AND OTHER HATTERS AS SBT PORTH ON THB PLAT OF WILLOW CRBBK vn.I.AGB, SBCTION ONB, RBCORDED NOVBMBBR 9, 1981. tJNl>BR RECEPTION NO . 321.237 . l.2. TBRMS AND CONDITIONS OP 'l'HB DECLARATION OF COVENANTS, CONDITIONS AND RBSTlUCTIONS OF wn.LOW CREEK VILLA.GB, SECTION ONB, AS RBCORDBD NOVBMBBR 9, 1981 IN BOOK SSS AT PAGE 532, AND AS AMBNDED IN INSTRUMBNT RECORDED .JANtmRY 12, 1989 IN BOOK 747 AT PAGE 348, WHICH DO NOT CONTAlli A FORP'BITORB OR REVBRTRR CLADSE . 13. RESTRICTIVE COVBNANTS, WHICH DO NOT CONTAIN A FORFBITCRE OR REVERTER CLAUSE, AS CONTAINED m INSTROMENT RBCORDBD August 13, 1991 , IN BOOK 811 AT PAGE 9. --