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O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Table of Contents Garfield County Zoning Resolution of 1978 1 5.03 Conditional and Special Uses 1 Section 5.03(1) Utilities 1 Section 5.03(2) Street Improvements 1 Section 5.03(3) Impacts to Adjacent Land Uses 2 5.03.08 Industrial Performance Standards 3 Section 5.03.08(1) Sound Volumes 3 Section 5.03.08(2) Vibration Generated 4 Section 5.03.08(3) Emissions of Smoke and Particulate Matter 4 Section 5.03.08(4) Emissions of Heat, Glare, Radiation and Fumes 4 Section 5.03.08(5) Storage Area, Salvage Yard, Sanitary Landfill and Mineral Waste Disposal Areas 5 Section 5.03.08(6) Water Pollution 5 9.03.01 Application 6 Section 9.03.01(1) Supporting Information 6 Section 9.03.01(2) Vicinity Map 6 Section 9.03.01(3) Letter to County Commissioners 6 Land Use and Development Code 2013 6 Division 1. General Approval Standards 6 Section 7-101. Zone District Use Regulations 6 Section 7-102. Comprehensive Plan and Intergovernmental Agreements 7 Section 7-103. Compatibility 13 Section 7-104. Source of Water 13 Section 7-105. Central Water Distribution and Wastewater Systems 14 Section 7-106. Public Utilities 14 Section 7-107. Access and Roadways 15 Section 7-108. Use of Land Subject to Natural Hazards 16 Section 7-109. Fire Protection 16 Division 2. General Resource Protection STandards 17 Section 7-201. Agricultural Lands 17 Section 7-202. Wildlife Habitat Areas 17 Section 7-203. Protection of Waterbodies 19 Section 7-204. Drainage and Erosion 19 Section 7-205. Environmental Quality 21 Section 7-206. Wildfire Hazards 23 Section 7-207. Natural and Geologic Hazards 23 Section 7-208. Reclamation 25 Division 3. Site Planning and Development Standards 26 Section 7-301. Compatible Design 26 Section 7-302. Off -Street Parking and Loading Standards 27 Section 7-303. Landscaping Standards 28 Section 7-304. Lighting Standards 28 Section 7-305. Snow Storage Standards 29 April 28, 2017 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Section 7-306. Trail and Walkway Standards 29 Division 10. Additional Standards for Industrial Uses 29 Section 7-1001. Industrial Use 29 April 28, 2017 ii O\OLSSON® ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Article 7 — Standards Analysis GARFIELD COUNTY ZONING RESOLUTION OF 1978 5.03 Conditional and Special Uses Section 5.03(1) Utilities Ursa's water requirements for the proposed land use are temporary in nature. After the well pad enters the production phase, sources of non -potable water for drilling and completions activities and potable water for employees will not be required. The facility will not be manned on a regular basis and will not require fresh water distribution and a wastewater system to properly function. Workers will provide their own potable water in their trucks. Ursa will provide bottled or potable water to personnel at their field office. A source of water will not be required for the production operations of the facility. Water will not be required for the operation of sanitary facilities. Portable toilets will be used, and all wastes will be hauled to a licensed treatment facility. Copies of "Will Serve" letters from Redi Services and Western Colorado Waste are included in the Wastewater Management Section of this submittal. Per details included in the SUA between Ursa and the landowner, no landscaping is proposed for this project location. Thus, there are no requirements for water for irrigation purposes. Ursa has entered into a Water Service Agreement (WSA) with the Battlement Mesa Metropolitan District (BMMD) to obtain non -potable water for use in drilling and dust control. A copy of the contract is included in the Water Supply section. A letter confirming legal and adequate water supply is provided, also. During drilling operations, potable water will be provided at this facility by Stallion Oilfield Services via their existing water contract(s). A copy of the will serve letter is included as part of this application in the Water Supply Section. Letters from the Town of Silt confirming legal and adequate water supply are provided. Section 5.03(2) Street Improvements A Detailed Traffic Study performed by Olsson Associates is included in this submittal. Based on the expected trip generation rates discussed in the report, the increase in average daily traffic is expected to be up to 20 vehicles per day during the construction phase near the site, which is anticipated to increase traffic by approximately 7% on some of the impacted roadways. Daily traffic is anticipated to increase by approximately 7% on County Road (CR) 307. At the end of construction, site traffic contributions will decrease to 10 vehicles per day. All movements at the access are expected to operate at acceptable levels of service throughout construction. The addition of site traffic, even in the height of construction, does not increase the existing volumes to amounts required for auxiliary lanes where they are not already provided. Once construction is complete, the daily volumes will reduce to approximately ten vehicles per day for the well pad site. Based on the results of the analysis, no mitigation is recommended for the site. Ursa will adhere to Garfield County Road and Bridge criteria for securing heavy haul permits as well as permitting truck traffic along CR 300W and CR 307 within Battlement Mesa. April 28, 2017 1 O\OLSSON® ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Section 5.03(3) Impacts to Adjacent Land Uses The well pad will be visually buffered from adjacent residences through topography, distance, and vegetation. Ursa may install a sound wall during drilling and completion operations to mitigate for sound and some visual impacts. Any lighting will be directed downward and inward away from adjacent properties. All equipment that remains on the pad after drilling and completions will be painted a neutral color to blend into the landscape. The proposed well pad has one access point off River Bluff Road at the eastern end of the project site. The site will be organized to provide safe access to and from the site and parking off the public right-of-way. It will not disrupt solar access to adjacent properties, pedestrian access, nor access to common areas along River Bluff Road. The operations of activities on the site will be managed to avoid nuisances to adjacent uses relating to hours of operations, parking, service delivery, and location of service areas and docks. All parking and service areas will be on-site. No street activities will be allowed, except in cases of emergency. According to Ursa's Fugitive Dust Control Plan, dust control may consist of water, surfacing materials, or non -saline dust suppressants as appropriate for road conditions. Per the SUA, no flaring will be allowed within 2,000 feet of an occupied dwelling, except in an upset condition. Production equipment will comply with applicable Colorado Department of Public Health and Environment (CDPHE) and Colorado Oil and Gas Conservation Commission (COGCC) regulations governing VOC emissions. Ursa uses enclosed combustor type flares with little to no visible flames. Ursa will be in compliance with the applicable CDPHE Air Quality Control Commission regulations, including Regulation No. 2 requirement that no oil or gas operation may cause or allow the emission of odorous air from any single source that is detectible after the odorous air has been diluted with seven or more volumes of odor -free air. Ursa has implemented a compliance program to address Regulation No. 7 requirements regarding emissions from tanks and other facilities. Ursa has developed and implemented a Leak Detection and Repair (LDAR) emissions monitoring program with infrared cameras to detect and repair any fugitive emissions. In addition, they have implemented a Storage Tank Emissions Monitoring (STEM) program to monitor and repair any fugitive emissions associated with condensate and produced water tanks. These programs have been developed in compliance with CDPHE Regulation 7 requirements. Ursa's LDAR program is set-up to inspect all facilities at least monthly during drilling and completion and quarterly during production. If a leak is discovered, the first attempt to repair the leak shall be made as soon as reasonably possible and per COGCC and CDPHE rules. Drilling and completion operations are subject to the maximum permissible noise levels for industrial zones. During the production phase of the well, Residential/Agricultural/Rural zone maximum noise levels will apply, per the SUA and COGCC Rules. Stationary engines and their exhausts will be located and oriented to direct noise away from the homes closest to the well pad. Ursa will evaluate noise generation from equipment and require April 28, 2017 2 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 contractors to refit mufflers, etc., in situations where the volume of sound produced exceeds noise levels for Residential/Agricultural/Rural zones. Engine braking will be prohibited by Ursa for its personnel and contractors. Per the SUA, there will be no time of day restrictions for drilling, completing, re -completing, workover, or reservoir fracture stimulation operations. However, Ursa will limit completions and routine ongoing maintenance and production operations activities to the hours of 7:00 am to 7:00 pm as an added BMP. The topography, distance, and vegetation mitigate visual and sound impacts. The SUA with Battlement Mesa Land Investments does not require landscaping at this pad site, due to its location next to the storage area and wastewater treatment plant. Production tanks and well head facilities will be low profile. Tanks, buildings, and equipment will be painted to blend in with the surrounding landscape. If a nuisance complaint is received on a location for noise, odor, dust, or other nuisances, Ursa's standard operating practice is to respond to each complaint as soon as possible. The person receiving the complaint, usually the Landman, gathers as much information (such as wind direction, time, duration, strength, nature of odor or noise, etc.) about the issue as possible. This information is relayed to the operations lead who begin to determine the source of the issue and what may be causing it. Once the root cause of the issue is found, the team determines mitigation efforts that will help remedy the concern(s). The land team follows up with the stakeholders on the effectiveness of the mitigation efforts and adjustments are made as necessary. All complaints are logged and tracked to improve Ursa's overall best management practices (BMP) performance on existing and future assets. Ursa has implemented a Stakeholder Hotline for concerns and complaints that will be answered 24 hours a day, seven days a week by a designated Ursa staff member. The number is 970-620-2787. Ursa also has a 24/7 emergency hotline, 855-625-9922. 5.03.08 INDUSTRIAL PERFORMANCE STANDARDS Section 5.03.08(1) Sound Volumes Drilling and completion operations are subject to the maximum permissible noise levels for industrial zones. During the production phase of the well pad, Residential/Agricultural/Rural zone maximum noise levels will apply, per the SUA and COGCC Rules. Stationary engines and their exhausts will be located and oriented to direct noise away from the homes closest to the well pad. Ursa will evaluate noise generation from equipment and require contractors to refit mufflers, etc., in situations where the volume of sound produced exceeds noise levels for Residential/Agricultural/Rural zones. Engine braking will be prohibited by Ursa for its personnel and contractors. Per the SUA, there will be no time of day restrictions for drilling, completing, re -completing, workover, or reservoir fracture stimulation operations. However, Ursa will limit completions and routine ongoing maintenance and production operations activities to the hours of 7:00 am to 7:00 pm as an added BMP. April 28, 2017 3 O\OLSSON® ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Section 5.03.08(2) Vibration Generated During the production phase of the proposed well pad, ground vibration will not be measurable at any point outside the property boundary. Section 5.03.08(3) Emissions of Smoke and Particulate Matter During the production phase of the proposed well pad, adjacent lands will not be impacted by the generation of vapor, dust, or smoke beyond the normal impacts of activities occurring around the adjacent properties. Ursa will apply the appropriate level of controls to accommodate potential impacts via adherence to CDPHE Air Quality regulations and the implementation of industry BMPs included in the SWMP and Ursa's Fugitive Dust Control Plan. The proposed well pad and access road will be graveled to reduce fugitive dust, which will be controlled using water or other dust suppressants. Section 5.03.08(4) Emissions of Heat, Glare, Radiation and Fumes During the production phase of the proposed well pad, adjacent lands will not be impacted by the generation of heat, glare, or fumes beyond the normal impacts of activities occurring around the adjacent properties. Ursa will apply the appropriate level of controls to accommodate potential impacts via adherence to CDPHE Air Quality regulations and the implementation of industry BMPs included in the SWMP and Ursa's Fugitive Dust Control Plan. Ursa commits to using carbon blankets over hatches on temporary tanks to reduce odors. Ursa has in place a program to immediately respond to odor complaints via their Land Department. Other best management practices to control emissions include limiting the idling of vehicles while on site and the use of green completion techniques. Ursa has developed and implemented a Leak Detection and Repair (LDAR) emissions monitoring program with infrared cameras to detect and repair any fugitive emissions. In addition, they have implemented a Storage Tank Emissions Monitoring (STEM) program to monitor and repair any fugitive emissions associated with condensate and produced water tanks. Ursa's LDAR program is set-up to inspect all facilities at least monthly during drilling and completion and quarterly during production. If a leak is discovered, the first attempt to repair the leak shall be made as soon as reasonably possible and in accordance with COGCC and CDPHE rules. Ursa has an active nuisance reporting program for stakeholders to report odors or noise complaints to Ursa. Ursa is committed to addressing any complaints quickly. Naturally occurring radioactive materials are not expected to be an issue at the proposed well pad. Colorado oil and gas operations are not known to have a significant problem with naturally occurring radioactive materials (NORM) or technologically enhanced naturally occurring radioactive materials (TENORM); however, there have been some instances where pipe scale has contained radium and associated radon gas. April 28, 2017 4 O\OLSSON ® ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Section 5.03.08(5) Storage Area, Salvage Yard, Sanitary Landfill and Mineral Waste Disposal Areas No storage areas, salvage yards, or sanitary landfills are associated with the proposed well pad. The standards regarding these uses do not apply to the proposed well pad use. Temporary mineral waste disposal areas will exist on the proposed well pad. All materials and liquids will be stored per accepted standards and laws and will comply with the National Fire Code. Any materials or wastes kept on the site will be deposited in such a manner that they will not be transferred off the property by any reasonably foreseeable natural causes or forces. No materials or wastes which might constitute a fire hazard or which may be edible by or otherwise be attractive to rodents or insects will be stored outdoors. Cuttings Sampling and Stabilization: Both surface and production hole drill cuttings will be generated at each well pad. Raw cuttings (not stabilized) will be sampled and profiled at the location of generation per Ursa's Waste Management Plan. Once the raw cuttings are sampled, they will be stabilized (absorption/removing liquids) in a temporary area on the well pad. The cuttings will be stabilized using either native soils (preferable) or a commercially available inert adsorbent (sawdust, Stabil EZ, etc.). In some cases, relocation of cuttings to another location during drilling would be required due to the small pad size permitted by the previous operator. If the volume of cuttings on the well pad during drilling exceeds the capacity of the on-site temporary area, limits operational capabilities to complete drilling, or creates safety concerns, a COGCC Sundry Notice (Form 4) will be submitted for approval to move the cuttings to another location pending the results of sampling analytical results. Cuttings Management and Disposal: If sampling results for either surface or production hole cuttings meet COGCC Table 910-1 standards, they will be treated as non -waste (essentially soil material) and will be managed under one or more of the following options: 1) remain on site for pad stabilization/reclamation; 2) be relocated to another location for beneficial reuse; 3) made available as fill material to the general public; 4) be relocated to a COGCC approved cuttings management facility; or 5) disposed of at an approved waste facility. Options 2 — 4 would be in accordance with a COGCC approved Sundry Notice (Form 4). Disposal at an approved waste facility would be managed for Item 5 under an approved waste manifest per CDPHE regulations. If cuttings don't meet standards, then Ursa will implement one of two options: continued mixing to meet Table 910-1 standards for beneficial reuse/relocation or transport to an authorized waste facility in accordance with Federal and State (COGCC/CDPHE) regulations, including manifesting. Final decisions will be based on site-specific operations logistics. Section 5.03.08(6) Water Pollution The proposed well pad does not fall within the Town of Parachute's Watershed Protection Area. Ursa will follow all applicable CDPHE Water Quality Control Standards. A copy of Ursa's Battlement Mesa Field Stormwater Management Plan and Permit is included with this application. Ursa will implement a range of BMPs to assure the protection of water quality during construction, interim reclamation, operation, and final reclamation of the proposed well pad. April 28, 2017 5 O\OLSSON® ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 9.03.01 Application Section 9.03.01(1) Supporting Information All supporting information and plans are included in this application package. The approved Stormwater Permit is included in Section 4-203.E.16. CDPHE is developing a new permit and associated certification for the above permitted facility. The development and review procedures required by law have not yet been completed. The Construction Stormwater General Permit, which "expired" June 30, 2012, was administratively continued and will remain in effect under Section 104(7) of the Administrative Procedures Act, C.R.S. 1973, 24-4-101, et seq (1982 rept. vol. 10) until a new permit/certification is issued and effective. The renewal for this facility was based on the application that was received 5/14/2013. Ursa will obtain utility permits and oversize/overweight load permits as required from Garfield County Road and Bridge, prior to construction. Ursa will file the applicable COGCC forms and permits including, but not limited to Form 2 and Form 2A. Section 9.03.01(2) Vicinity Map A Vicinity Map is included in Section 4-203.C. Site Plans for the proposed well pad are included in Section 4-203.D. An Adjacent Property Owners Map can be found in Section 4-203.B.3. Section 9.03.01(3) Letter to County Commissioners This application package, in its entirety, serves as the letter to the County Commissioners explaining in detail the nature and character of the Special Use requested. LAND USE AND DEVELOPMENT CODE 2013 Division 1. General Approval Standards Section 7-101. Zone District Use Regulations Ursa Operating Company (Ursa) and Battlement Mesa Land Investments (BMLI) proposes to pursue natural gas drilling activities in the Battlement Mesa Planned Unit Development zone. Table 3-403: Use Table shows that Oil and Gas Drilling and Production is a permitted use in all zones in Garfield County. Garfield County Resolution 82-121 lists extraction of natural resources as a special use within the Battlement Mesa PUD. This resolution says that: Where preceding general standards or the following supplemental regulations do not adequately describe what is permitted or required, reference shall be made to the officially adopted Garfield County Zoning Resolution of January 2, 1979, including the zoning amendment, opted October 15, 1979, (79-132) and to the officially adopted Garfield County Subdivision Regulations of January 2, 1979, and amendments of October 15, 1979. Thus, the County requires a Special Use Permit to extract natural resources within the PUD demonstrating that the proposed extraction activities comply with the standards and criteria of the county's 1979 zoning code. April 28, 2017 6 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11- BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Section 7-102. Comprehensive Plan and Intergovernmental Agreements The BMC A well pad development generally conforms to the Garfield County Comprehensive Plan. The Battlement Mesa community was originally planned and constructed to accommodate oil and natural gas development in the Piceance Basin. The Future Land Use Map from the Comprehensive Plan illustrates the subject property as Planned Unit Development (PUD). The site is in the Public, Semi -Public, Recreation, and Injection Well (PSRI) subzone within the PUD. The existing use is not within an area governed by an intergovernmental agreement. The following sections of the Garfield County Comprehensive Plan apply to the BMC A well pad development and further substantiate that natural gas well pads located in appropriate areas of Garfield County are in compliance with the Comprehensive Plan. Ursa has invested significant time and effort towards stakeholder and community involvement. Ursa has held local meetings to assure that the Battlement Mesa property owners as well as the Battlement Mesa community at large are fully apprised of Ursa's proposed project activities, compliance with regulatory framework, compatibility with all PUD zone districts, and mitigation of impacts. Overall Vision - Future Land Use Garfield County is dedicated to managing and directing growth to dedicated Urban Growth Areas and other areas that can accommodate growth cost effectively, in order to create thriving communities while promoting a diverse, sustainable and healthy economy, protecting wildlife, maintaining or improving the quality of our natural environment, and preserving the county's rural and western heritage. The Ursa application submittal goes into detail in various reports and narratives as to how the proposed drilling operations will operate in conformance with multiple regulatory agencies. Ursa's adherence to regulatory policies and rules will result in limited, short- term impacts to the surrounding properties while infusing economic benefits, promoting a thriving community, and minimizing impacts to wildlife. Land Use Table LAND USE DESIGNATION Industrial (1) DESCRIPTION Indoor manufacturing, outdoor equipment storage, business parks, energy processing and uses that produce odor, noise, Tight, and/or emissions. COMPATIBLE ZONING Industrial (1) Planned Unit Development (PUD) Density of residential uses: None Example: April 28, 2017 O OLSSON ASSOCIATES 7 Battlement Mesa PUD Phase 11- BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Ursa's application submittal conforms to the portion of the Land Use Table from the Garfield County Comprehensive Plan shown above. Section 4 - Economics, Employment and Tourism Policies: Garfield County will encourage the development of a diversified industrial base recognizing physical location -to -market capabilities of the community, and the social and environmental impacts of industrial uses. Ursa's application submittal conforms to this policy. The development of natural gas resources in Garfield County contributes to a diversified industrial base. The physical location of the proposed drilling locations will take advantage of a broad system of pipelines in the Piceance region which route natural gas to sales points thus capitalizing on location -to -market capabilities. By adhering to the Garfield County and Colorado State regulatory criteria for the development and production of natural gas, Ursa will mitigate social and environmental impacts to the highest practical level. Strategies and Actions: Ensure that commercial/industrial developments are compatible with adjacent land uses and preserve the visual quality of the county. Ursa's application submittal conforms to this strategy. By adhering to the Garfield County and Colorado State regulatory criteria, Ursa will ensure the post -development locations are compatible with adjacent land uses and will preserve the visual quality of the county. Compliance activities that accommodate these strategies and actions include: • Compliance with COGCC rules regarding interim and final reclamation • Use of Best Management Practices (BMPs) in all areas of operations • Compliance with Ursa's agreement with the landowner requiring visual mitigation of the well sites to preserve the visual quality of the Battlement Mesa area • Compliance with Garfield County Conditions of Approval regarding general operations of the well pad. Section 8 - Natural Resources Goals: Ursa's application submittal conforms to the following goals: 1. Ensure that natural, scenic, ecological, and critical wildlife habitat resources are protected and/or impacts mitigated. April 28, 2017 8 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 By adhering to the Garfield County and Colorado State regulatory criteria, Ursa will ensure that natural, scenic, ecological, and critical wildlife habitat resources are protected and/or impacts mitigated. Specific compliance activities accommodating this goal include: • Consultation with the Colorado Division of Parks and Wildlife. • Development and implementation of a Wildlife Mitigation Plan. • Preparation of a Garfield County Wildlife and Vegetative Analysis for each development location. • Implementation of Ursa's comprehensive inspection and corrective action plan(s). 2. Preserve natural drainage patterns so the cumulative impact of public and private land use activities will not cause storm drainage and floodwater patterns to exceed the capacity of natural or constructed drainage ways, or to subject other areas to an increased potential for damage due to flooding, erosion or sedimentation or result in pollution to streams, rivers or other natural bodies of water. By adhering to the Garfield County and Colorado State regulatory criteria, Ursa will ensure the preservation of natural drainage patterns and mitigate potential stormwater impacts from construction activities. Specific compliance activities accommodating this goal include: • Preparation of Stormwater Management Practices and securing Stormwater Management Permits as required Colorado Department of Public Health and Environment (CDPHE) criteria. • Preparation of a Garfield County Grading and Drainage Plan for each development location. 3. Protect existing access to natural resources. Ursa's proposed development will have no significant impact to existing access to natural resources. Please also see the response to Section 8 - Natural Resources Goals, Item #1 above. 4. Ensure the appropriate reclamation of land after extraction processes. By adhering to the Garfield County and Colorado State regulatory criteria, Ursa will ensure the appropriate reclamation of land after extraction processes will be performed. Specific compliance activities accommodating this goal include: • Preparation of Stormwater Management Practices and securing Stormwater Management Permits per the CDPHE criteria. • Preparation of Reclamation Plans and securing bonding per the COGCC criteria. April 28, 2017 9 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Policies: 1. The county will encourage and cooperate with the protection of critical habitat including state and federally protected, threatened, or endangered species. Ursa's proposed development will accommodate this policy. Please see the response to Section 8 - Natural Resources Goals, Item #1 above. 2. Garfield County will encourage the protection of watersheds, flood plains, and riparian areas. By adhering to the Garfield County, Colorado State, and Federal regulatory criteria, Ursa will ensure protection for watersheds, flood plains, and riparian areas. Specific compliance activities accommodating this goal include: • Compliance with local Watershed Protection rules and policies. • Preparation of Stormwater Management Practices and securing Stormwater Management Permits per the CDPHE criteria. • Review and document potential impacts per the criteria identified by the US Army Corps of Engineers (USACOE). • Preparation of a Garfield County Floodplain Analysis as well as Grading and Drainage Plans for each development location. • Preparation of a Wildlife and Vegetative Analysis that includes an assessment of riparian areas for each development location. Section 9 - Mineral Extraction Vision - Mineral Extraction Resource extraction, including oil and gas development, has been encouraged to operate in the county due to the contribution the industry makes to the county's overall goal of having a diverse and stable economy. While resource extractive industries are welcomed in the county, they are expected to mitigate negative impacts that result from their operations. The Ursa application submittal demonstrates Ursa's commitment to minimizing and mitigating the negative impacts of their natural gas development within Garfield County and Battlement Mesa. Ursa conducted many meetings with local stakeholders to discuss logistics, methods, and typical impacts associated with their natural gas development operations. Ursa has made every effort to reduce the total number of drill pads in proximity to the Battlement Mesa community. April 28, 2017 10 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Issue Garfield County has significant mineral resources that have, and will continue to have, a considerable benefit to the economic health of the county. Despite the current downturn in natural gas development, Ursa is committed to developing their natural gas leaseholds which provides an economic benefit of Garfield County. Goal 1. Ensure that mineral extraction is regulated appropriately to promote responsible development and provide benefit to the general public. Ensure that mineral extraction activities mitigate their effects on the natural environment, including air quality, water quality, wildlife habitat or important visual resources. As noted above, by adhering to the Garfield County, Colorado State, and Federal regulatory criteria, Ursa will mitigate their effects on the natural environment, including air quality, water quality, wildlife habitat or important visual resources. Ursa has created and implemented a cross-reference matrix to address the broad range of regulatory criteria which apply to the proposed project. In working with mineral extraction projects, the county will protect the public health, safety and welfare of its citizens. Ursa is aware that the Garfield County BOCC has deemed it appropriate to address concerns raised in the Health Impacts Assessment (HIA) as part of the land use approval process for natural gas development in the PUD. Ursa has provided a document correlating the relevant components of the HIA against Ursa's regulatory compliance activities with this application. Policy 1. Garfield County recognizes that surface and mineral owners have certain legal rights and privileges, including the right to extract and develop these interests. Private property owners also have certain legal rights and privileges, including the right to have the mineral estate developed in a reasonable manner and to have adverse impacts mitigated. The property rights of mineral lessees must be balanced with the rights of private property owners and the general public. Ursa has negotiated in good faith with the property owners of the PUD, local land owners, Battlement Mesa community organizations, and other stakeholders to locate the natural gas well pads in areas that will minimize and mitigate impacts to the surface owner and adjacent land owners while accommodating Ursa's right to develop the resource(s). The Surface Use Agreement with the surface owner outlines various details to mitigate surface impacts. April 28, 2017 11 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 2. Mineral resource extraction activities will protect critical wildlife habitat as identified by state and federal agencies. Development within these designations that cannot be designed, constructed and conducted so as to have a minimum adverse impact upon such habitat or these wildlife species, shall be discouraged. Ursa's proposed development will protect critical wildlife habitat in the PUD so as to have a minimum of adverse impacts upon such habitat or these wildlife species. All proposed project areas were evaluated for threatened and endangered species; none were found. Please also see the response to Section 8 - Natural Resources Goals, Item #1 above. Ursa has an approved Wildlife Mitigation Plan with Colorado Parks and Wildlife. 3. Natural drainage patterns will be preserved or mitigated so the cumulative impact of mineral extraction activities will not cause storm drainage/floodwater patterns to exceed the capacity of natural or constructed drainage ways, or to subject other areas to increased flooding, erosion or sedimentation or result in pollution to streams, rivers, or other natural bodies of water. Ursa's proposed development will preserve or mitigate natural drainage patterns and minimize the cumulative impacts to drainages, waterbodies and watersheds. Please also see the response to Section 8 - Natural Resources Goals, Item #2 above. 4. Facilities that are appurtenances to oil/gas development activities (compressors, etc.) are considered appropriate in all land uses so long as they meet the respective mitigation requirements of the ULUR to maintain compatibility with surrounding land uses. Appurtenant facilities anticipated for this well pad include a small injection well and pipeline infrastructure. The injection well will allow for disposal of produced water once it is no longer needed for drilling and completions activities within the Battlement Mesa Field. The pipelines will allow for the transport of natural gas and produced water. All facilities will be permitted per the requirements of the ULUR and Land Use and Development Code (LUDC) and will adhere to the appropriate Garfield County, Colorado State and Federal regulatory criteria. Any emergent appurtenant facilities will be permitted according to the criteria detailed above. This submittal goes into great detail in the various reports and narratives as to how the development of the natural gas resources will be conducted in an environmentally responsible fashion. The importance of the oil and gas industry to the economic health of the Garfield County economy is noted in the aforementioned Vision, Issue, Goal and Policy statements taken from the Comprehensive Plan. The proposed drilling and production locations are needed by Ursa to assure that natural gas can be moved from source to market and, ultimately, the consumer. The economic benefits provided by Ursa and other oil and gas operators are clear from the many investments made in communities and other community benefits derived from the industry. April 28, 2017 12 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Section 7-103. Compatibility The BMC A well pad is located in the Battlement Mesa PUD zone district Public, Semi -Public, Recreational, and Injection Well (PSRI). Garfield County is a "Right to Mine" County guaranteeing mineral rights owners the right to extract minerals in all zone districts of the county. Visual and sound impacts will be mitigated according to the existing Surface Use Agreement (SUA) with Battlement Mesa Land Investments, Garfield County Conditions of Approval, and COGCC Rules and Conditions of Approval. Section 7-104. Source of Water Ursa has entered into a Water Service Agreement (WSA) with BMMD to obtain non -potable water for use in drilling and dust control. A copy of the agreement is included in the Water Supply section. A letter confirming legal and adequate water supply is provided, also. During drilling operations, potable water will be provided at this facility by Stallion Oilfield Services via their existing water contract(s). A copy of the will serve letter is included as part of this application in the Water Supply Section. Letters from the Town of Silt confirming legal and adequate water supply are provided. These water requirements are temporary in nature. After the well pad enters the production phase, sources of non -potable water and potable water for employees will not be required. The facility will not be manned on a regular basis and will not need fresh water distribution and a wastewater system to properly function. Workers will provide their own potable water in their trucks. Ursa will provide bottled or potable water to personnel at their field office. A source of water will not be required for the production operations of the facility. Water will not be needed for the operation of sanitary facilities. Portable toilets will be used, and all wastes will be hauled to a licensed treatment facility. Copies of "Will Serve" letters from Redi Services and Western Colorado Waste are included in the Wastewater Management Section of this submittal. Per details included in the SUA between Ursa and the landowner, no landscaping is proposed for this project location. Thus, there are no requirements for water for irrigation purposes. A. Determination of Adequate Water Ursa has entered into a Water Service Agreement (WSA) with BMMD to obtain non -potable water for use in drilling and dust control. A copy of the contract is included in this section. Supply may be suspended at any time due to inadequate water capacity or water pressures in the system or emergency and fire. A letter confirming legal and adequate water supply is provided, also. During drilling operations, potable water will be provided at this facility by Stallion Oilfield Services via their existing water contract(s). A copy of the will serve letter is included as part of this application in the Water Supply Section. Letters from the Town of Silt confirming legal and adequate water supply are provided. April 28, 2017 13 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Section 7-105. Central Water Distribution and Wastewater Systems A. Water Distribution System During drilling operations, potable water will be provided at this facility by Stallion Oilfield Services via their existing water contract(s). Fresh non -potable water for drilling and dust control will be supplied by the BMMD via the WSA. A source of water for the operation of sanitary facilities is not required. Portable toilets will be used and all wastes will be hauled to a licensed treatment facility. During the production phase, the facility will be unmanned with personnel onsite only for short intervals. Potable water will not be needed for daily operations. Personnel will provide their own potable water carried in their vehicles. Ursa makes potable water available at their field office to staff and contractors. Sanitary facilities will not require a source of water and will be provided by portable toilets. Water for landscaping will not be required for this proposed well pad pursuant to the SUA. B. Wastewater System During the Drilling Phase, sanitary facilities will be provided via a vault and haul system by Stallion Oilfield Services. A will serve letter is included in the Wastewater Management Section. After drilling is completed and the rig is removed, staff will not be assigned to the facility on a regular basis. Personnel will be at the facility for short periods of time only. Workers will be performing routine facility maintenance and inspections. Sanitary facilities will be provided by portable toilets placed on site. Redi Services and Western Colorado Waste will maintain these portable toilets. All waste is hauled to a licensed treatment facility. Will Serve letters are included in the Wastewater Management section, documenting the maintenance of these sanitary facilities. Section 7-106. Public Utilities A. Adequate Public Utilities Adequate Public Utilities are available to serve the land use. Ursa is working with Holy Cross Energy to provide electrical service to the pad. Other public utilities are not required. A copy of Holy Cross's will serve letter is included at the end of this section. B. Approval of Utility Easement by Utility Company Ursa has not finalized their agreement with Holy Cross Energy to provide electrical service to the pad. All appropriate easements will be secured as part of this process. C. Utility Location Utility easements will be located per the LUDC and Surface Use Agreement in consultation with Holy Cross Energy. D. Dedication of Easements Ursa has not finalized their agreement with Holy Cross Energy to provide electrical service to the pad. All appropriate easements will be dedicated to the public as part of this process. April 28, 2017 14 O\OLSSON® ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 E. Construction and Installation of Utilities Ursa has contracted with Holy Cross Energy to provide electrical power to the site. A copy of the will serve letter is provided at the end of this section. Utilities will be installed in a manner that avoids unnecessary removal of trees or excessive excavations and will be reasonable free of physical obstructions. F. Conflicting Encumbrances Ursa has not finalized their agreement with Holy Cross Energy to provide electrical service to the pad. All appropriate easements will be free from encumbrances. Section 7-107. Access and Roadways The road is expected to function adequately as proposed and is typical of existing roads providing access to natural gas production in Garfield County. -1. Access to Public Right of Way Legal access to the site is gained from CR 307, River Bluff Road, through a surface use agreement with Battlement Mesa Land Investments and an easement agreement with Battlement Mesa Metropolitan District. B. Safe Access For sight distance, the sight distance from the access road to the east has revealed that the entire 772' of roadway to the intersection with Battlement Parkway to be clear of obstructions. Likewise, at least 500 feet of sight distance exists to the west towards the Battlement Mesa Water and Wastewater District Facilities. For a 35 -mph speed on River Bluff Road, the minimum stopping sight distance would be 275 feet thus the sight distance available exceeds the minimum. For the access road to the pad itself, the entire roadway is visible to traffic flows on the access road so sight distance is not an issue. From a structural standpoint, the access road for the pad is to be constructed of 8" of class 6 aggregate base course over 18" of scarified and compacted native soil subgrade. With the given construction, and in-situ soil conditions consisting of an R value of at least 15, the road section will adequately support the 20 -year projected EASL's from production traffic. For the existing roadway (River Bluff Road), we have found the roadways to be in an aged, but fair condition. Given the road bond that Ursa has in place with the County Road and Bridge department, any funding necessary to repair damages directly resulting from Ursa's activities and on River Bluff Road are already in place. Maintenance for the access road to the pad is to be performed by Ursa contractors sufficiently tooled to adequately maintain not only access roadways, but the pad facilities as well. Anticipated maintenance is snow plowing, borrow ditch grading, storm water BMP maintenance, weed/vegetation control (mowing and spraying), re -surfacing and compaction. From well pad construction through completion operations, necessary personnel and equipment will be on site or on nearby facilities to perform the needed maintenance. Through production, Ursa production April 28, 2017 15 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11- BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 personnel will monitor maintenance needs and direct the Ursa contractors to perform such on an as needed basis. C. Adequate Capacity Traffic congestion is not anticipated as a result of the proposed Ursa BMC A oil and gas development activities. The access road for Ursa BMC A is being constructed at a standard that generally exceeds the County's standard except for the cross slope being 2% versus 3%. D. Road Dedication The access road is a private road. No rights-of-way will be dedicated to the public. E. Impacts Mitigated Based on the expected trip generation rates discussed in the Basic Traffic Study, the increase in average daily traffic is not expected to increase on County Roads such that a modification of the existing access permit would be required. The total traffic volumes will remain very low and are anticipated to be accommodated by the existing roadway. Additionally, the majority of existing traffic on this road is associated with the natural gas industry and/or the maintenance personnel for the Battlement Mesa Water and Wastewater District facilities. F. Design Standards The Ursa BMC A Access Road is proposed to be constructed to a standard that exceeds most of the Garfield County's Semi Primitive Driveway standard. A waiver to the cross slope standard is requested. Section 7-108. Use of Land Subject to Natural Hazards The Geologic Hazard Report indicates that potential geologic hazards of slope area, corrosive soils, and expansive soils have been identified in the area of the proposed BMC A well pad. A copy of this report is included in this submittal. The Arvada loam and Ildefonso stony loam soils are shown to be corrosive to uncoated steel and low to moderately corrosive to concrete. The subsoil has a high shrink -swell potential. Appropriate engineering and design of the well pad facilities will mitigate these hazards. Ursa will have a geotechnical analysis performed prior to construction of the well pad. Section 7-109. Fire Protection A. Adequate Fire Protection The proposed well pad is located within the Grand Valley Fire Protection District. The District is aware of the well pad location and can provide adequate fire protection and response. Ursa has participated in emergency training programs such as the Parachute/Battlement Mesa Hazard Disaster Planning exercises with Grand Valley Fire Protection District. They will continue to support these programs. April 28, 2017 16 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 B. Subdivisions The proposed well pad is located within the Battlement Mesa PUD, but outside a platted subdivision. Ursa is willing to consult with Grand Valley Fire Protection District regarding access, fire lanes, water sources, fire hydrants and maintenance provisions. Division 2. General Resource Protection STandards Section 7-201. Agricultural Lands A. No Adverse Affect to Agricultural Operations The proposed well pad is not located in an area being used for agricultural operations, therefore, there will be no adverse effect or impacts to agricultural operations and production. B. Domestic Animal Controls The operation of the proposed facility will comply with this standard. No domestic animals are allowed on the site. All features on the proposed facility that could present an entrapment hazard to animals will be screened or otherwise mitigated for safety. C. Fences The proposed well pad will not generate a potential hazard to domestic livestock or wildlife. No open storage of hazardous materials or attraction will be conducted on the site. The site will be enclosed with a visual and sound buffer during drilling and completions operations. After drilling is completed on the site and all wells are in production, the visual and sound buffer will be removed. The well pad will not be fenced after it is placed into production. Well cellars and any other site features that present a potential entrapment hazard will be screened or otherwise secured. D. Roads The access road will be located so that normal maintenance of the road, including snow removal, will not damage fencing on adjacent parcels. Dust control will be utilized, both during and after construction, to minimize adverse impacts to livestock and crops. Dust control may consist of water, surfacing materials, or non -saline dust suppressants as appropriate for road conditions. A copy of Ursa's Fugitive Dust Control Plan in included in the Air Quality section of this submittal. Irrigation Ditches No irrigation ditches are adjacent to the proposed well pad site. Implementation of the engineered grading and drainage plan and conformance with stormwater best management practices will assure that any irrigation ditches near the subject parcel will not be impacted by the facility. Section 7-202. Wildlife Habitat Areas A. Buffers Topographic, vegetative, and other visual and sound buffers will be used to screen the activity of the proposed well pad from habitat and residential areas. April 28, 2017 17 O\OLSSON® ASSOCIATES Battlement Mesa PUD Phase 11- BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 B. Locational Controls of Land Disturbance No CPW mapped migration corridors will be affected by the proposed well pad. Human presence and activity may affect animal distribution by creating avoidance areas and increasing stress on wintering big game. Over time, deer and elk that winter in this area have become habituated to the considerable human activity and the indirect effects of avoidance and displacement have decreased. Interim reclamation will be focused on erosion and sediment control and native vegetation. Foraging activities for raptors are unlikely to be disrupted and any effect would be very small given the abundance of foraging habitat available. No nests were observed within the survey area around the BMC A well pad. Ursa's policies do not allow the feeding of wildlife. Trash will be kept in bear proof trash containers and removed on a regular schedule during drilling operations. After the proposed well pad has been placed into production, any trash generated during routine maintenance and inspection visits will be removed by personnel as they leave the site. Low speed limits already in place on area roads will be enforced. Equipment is outfitted with bird cones to prevent perching. C. Preservation of Native Vegetation 1. Per the SUA, no landscaping is required for the proposed well pad. Reclamation activities will focus on native vegetation and erosion and sediment control. 2. Application of the Integrated Vegetation and Noxious Weed Management Plan (IVNWMP) and Ursa's Noxious Weed Management Plan will provide a degree of mitigation for the native vegetation that has already been removed. Ursa will comply with COGCC Rules regarding revegetation and control of noxious weeds. 3. Vehicles and equipment traveling from weed -infested areas into weed -free areas could disperse noxious or invasive weed seeds and propagates, resulting in the establishment of these weeds in previously weed -free areas. Several simple practices will be employed to prevent most weed infestation. The following practices will be adopted for any activity to reduce the costs of noxious weed control through prevention. The practices include: • Prior to delivery to the site, equipment should be thoroughly cleaned of soils remaining from previous construction sites which may be contaminated with noxious weeds. • If working in sites with weed -seed contaminated soil, equipment should be cleaned of potentially seed -bearing soils and vegetative debris at the infested area prior to moving to uncontaminated terrain. • All maintenance vehicles should be regularly cleaned of silt. • Avoid driving vehicles through areas where weed infestations exist. April 28, 2017 18 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11- BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 D. Habitat Compensation Fencing is not proposed for the project after drilling and completion activities are finished on the site. Weed management best practices will be implemented to further reduce potential loss of habitat. The development of the proposed well pad is not expected to significantly affect any critical environmental resources or habitat to an extent where habitat compensation would be required. Ursa will comply with their approved CPW Wildlife Mitigation Plan for the Battlement Mesa area. Domestic Animal Controls Livestock and big game will likely avoid the proposed well pad. Dogs and other domestic animals are not allowed on site. Section 7-203. Protection of Waterbodies A. Minimum Setback 1. The well pad disturbance is more than 35 feet from the Ordinary High Water Mark (OHWM) of the Colorado River. The northeastern edge is approximately 760 feet from the nearest wetland. 2. There is a potential Water of the US (WOUS) on the northeastern edge of the well pad. There is also a potential WOUS just off the northwest corner of the well pad. There do not appear to be any entrenched or incised streams on or adjacent to the proposed project area. Ursa will evaluate the potential WOUS and obtain permits from the Army Corps of Engineers, if necessary. Ursa will protect WOUS through appropriate stormwater and environmental controls as outlined in their Storm Water Management Plan and SPCC Plan. 3. No hazardous material will be stored on the project site. See the SPCC Plan included in this submittal for measures to protect surface and ground water from spills. B. Structures Permitted in Setback No structures will be located within the 35 -foot OHWM setback. C. Structures and Activity Prohibited in Setback No structures will be located within the 35 -foot setback. No work of any kind will occur within the 35 -foot setback. D. Compliance with State and Federal Laws The proposed well pad will be designed with the use of erosion and sediment controls and adherence to Ursa's stormwater management plan and SPCC plan to not impact any Waterbody of the US. Section 7-204. Drainage and Erosion A. Erosion and Sedimentation The proposed well pad is covered under Ursa's CDPHE Battlement Mesa Field Wide Storm Water Management Plan (SWMP). The Certification Number is COR03K566 and was Administratively April 28, 2017 19 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Continued at the time of issuance. The SWMP and permit are included in the Stormwater section of this submittal. BMPs such as straw wattles, inlet and outlet protection, sediment traps, vehicle tracking pads, and vegetative buffers will be utilized to ensure the continued protection of water bodies from stormwater runoff during construction and operation of the facility. COGCC and CDPHE regulations require that well pads and roads are monitored for erosion and sediment control through the production phase and final abandonment and reclamation of pad. Site specific plans (i.e. diagrams) will be developed and inspected against at the frequency required by CDPHE regulations, to include 14 day, 30 day, and major storm event inspections until 70% reclamation is achieved. Corrective actions and maintenance will be tracked and implemented. The post -construction stormwater program will be managed in accordance with COGCC. Inspections and corrective actions will be conducted through 80% interim reclamation and annually thereafter. These inspections are also tracked and corrective actions implemented. Native soils will be used whenever available to construct stormwater BMPs, supplemented by non-native materials based on site-specific conditions. The estimated cost of installation and maintenance of the erosion and sediment control measures is approximately $5,000 to $15,000. B. Drainage 1. This standard requires that lots be laid out to provide positive drainage. Lots are not proposed as part of this land use application. The proposed well pad will be graded so that existing drainages will not be impacted. 2. Via the implementation of the Grading and Drainage Plans included in this submittal, the proposed facility will not impact residential development or natural drainage patterns. C. Stormwater Run -Off The site has been designed to COGCC standards for stormwater management to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation. BMPs will be maintained until the facility is abandoned and final reclamation is achieved pursuant to COGCC Rules. The proposed well pad may create 10,000 square feet or more of impervious surface area. 1. Avoid Direct Discharge to Streams or Other Waterbodies. Stormwater Runoff from project areas will be controlled by use of BMPs such as straw wattles, inlet and outlet protection, vehicle tracking pads, and vegetative buffers. If undetected springs or water sources are encountered, appropriate discharge permits will be obtained. 2. Minimize Directly -Connected Impervious Areas. The site design may create more than 10,000 square feet of impervious surface area. The impervious surface area will not be directly - connected. It will be broken up in areas of less than 6,000 square feet. 3. Detain and Treat Runoff. Ursa has incorporated stormwater detention facilities into the design for this site. Stormwater runoff will be controlled via a combination of sediment traps, top soil berms, and wattles. April 28, 2017 20 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 a. The maximum calculated detention necessary to capture the stormwater runoff volume generated from a 25 year, 24-hour storm is approximately 2,855 cubic feet. A detention pond with this capacity and drainage features to convey water to the pond will be provided on site. See the Grading and Drainage drawings and report included in the Grading and Drainage section. b. The project site is above the 100- and 500 -year floodplain of the Colorado River, therefore a 100 -year storm event should not cause property damage. c. Channels downstream from the stormwater detention pond discharge have been designed to prevent increased channel scour, bank instability, and erosion and sedimentation from the 25 -year, 24-hour storm event. d. The main goal of the site design is to provide detention and sedimentation control for the project. The only area where a significant increase in runoff coefficients occur is the gravel pad and road. A detention pond will be sized appropriately and provide a location for sedimentation of the stormwater runoff generated from the developed site. The remaining site will remain in native vegetation and provide historic flow patterns and characteristics. Temporary erosion control measures will be required for the duration of construction. A CDPHE Stormwater Permit for Construction activities is required and will be obtained prior to the onset of construction activities. Best Management Practices will be utilized during construction to control the stormwater runoff. Key temporary erosion control measures include installation and maintenance of run-on controls, ditches, straw wattles, inlet protection, a stabilized construction entrance and all necessary acceptable best management practices that would relate to this project. e. All culverts and drainage pipes utilized at this facility are designed and constructed according to the AASHTO recommendations for a water live load. Section 7-205. Environmental Quality A. Air Quality The CDPHE requires that an air permit be submitted no later than 90 days following the date of first production. This allows operators the ability to accurately calculate actual emissions from new facilities. Ursa will prepare and submit permit applications to CDPHE within the allotted time frame. Ursa ensure compliance with air quality regulations. Ursa will comply with COGCC green completion practices and the EPA's natural gas STAR program to reduce VOC emissions to the lowest level technically possible for the wells on the BMC A pad. To this end, Ursa will apply a low emissions flow back process for well completions and will route tank venting emissions through an enclosed combustor. Enclosed combustor type flares will be employed to burn off emissions at a 95+% efficiency. These flares have little to no visible flames and will not be visible beyond the boundaries of the oil and gas location. Use of VRUs will be determined on a case-by-case basis due to the dry nature of gas in the Battlement Mesa area. A temporary VRU may be used for newly completed April 28, 2017 21 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 wells during the peak flow back period. The VRU will allow for the capture of additional vapors instead of burning them. This allows Ursa to use lower tank pressures. Additionally, Ursa commits to using carbon blankets over hatches on temporary tanks to reduce odors. Ursa has in place a program to immediately respond to odor complaints via their Land Department. Other best management practices to control emissions include limiting the idling of vehicles while on site and the use of green completion techniques. Ursa has developed and implemented a Leak Detection and Repair (LDAR) emissions monitoring program with infrared cameras to detect and repair any fugitive emissions. In addition, they have implemented a Storage Tank Emissions Monitoring (STEM) program to monitor and repair any fugitive emissions associated with condensate and produced water tanks. These programs have been developed in compliance with CDPHE Regulation 7 requirements. Ursa's LDAR program is set-up to inspect all facilities at least monthly during drilling and completion and quarterly during production. If a leak is discovered, the first attempt to repair the leak shall be made as soon as reasonably possible and in accordance with COGCC and CDPHE rules. Pumpers are on location daily and will inspect equipment every day. Pumpers also complete Audio, Visual, Olfactory (AVO) inspections weekly. Potential dust impacts will be mitigated as directed in Ursa's Fugitive Dust Plan using water or other dust suppressants as appropriate. During construction, truckloads of dirt, sand, aggregate materials, drilling cuttings, and similar materials will be covered to reduce dust and particulate matter emissions during transport. Remote monitoring during the production phase will be used to reduce truck traffic and fugitive dust to the extent practical. If a nuisance complaint is received on a location for noise, odor, dust, or other nuisances, Ursa's standard operating practice is to respond to each complaint as soon as possible. The person receiving the complaint, usually the Landman, gathers as much information (such as wind direction, time, duration, strength, nature of odor or noise, etc.) about the issue as possible. This information is relayed to the operations lead who begin to determine the source of the issue and what may be causing it. Once the root cause of the issue is identified, the team determines mitigation efforts that will help remedy the concern(s). The land team follows up with the stakeholders on the effectiveness of the mitigation efforts and adjustments are made as necessary. All complaints are logged and tracked to improve Ursa's overall best management practices (BMP) performance on existing and future assets. Ursa has implemented a Stakeholder Hotline for concerns and complaints that will be answered 24 hours a day, seven days a week by a designated Ursa staff member. The number is 970-620-2787. Ursa also has a 24/7 emergency hotline, 855-625-9922. B. Water Quality No hazardous materials will be stored on site. An SPCC plan will be in effect for the tank batteries associated with the well pad production and injection well operations. A copy of the plan is included in the SPCC section of this submittal. April 28, 2017 22 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11- BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Section 7-206. Wildfire Hazards A. Location Restrictions The proposed well pad is located in an area designated as having low wildfire hazard according to the Garfield County on-line GIS map resources. It is not located within a fire chimney as identified by the Colorado State Forest Service. B. Development Does Not Increase Potential Hazard The proposed well pad will not increase the potential intensity or duration of a wildfire, or adversely affect wildfire behavior or fuel composition. Should a fire start in the area of the well pad, the wells will be shut in and the tanks protected to keep the fire from creating a catastrophic event. C. Roof Materials and Design Roof materials for any proposed structures will be made of noncombustible materials. Any proposed construction will comply with requirements of the 2009 International Fire Code. Section 7-207. Natural and Geologic Hazards A. Utilities Above -ground utilities are not expected to be required at the proposed facilities. The determination to locate utility facilities above ground will be based upon the recommendation and requirements of the utility service provider and approved by the County. Except for potential flash flooding, above -ground utilities, such as transformers, are not expected to be affected by geologic or other natural hazards. Trenches for water pipelines and natural gas pipelines are expected to be associated with the proposed development. The slopes of the Arvada loam and Ildefonso stony loam may pose technical challenges to the installation of these utilities; however, it is expected that these limitations can be overcome with proper design and installation. B. Development in Avalanche Hazard Areas Avalanches are not expected to affect the proposed natural gas well site or pipelines located at elevations of approximately 5,100 amsl. Development in Landslide Hazards Areas The Site is located on alluvial terrace, fan gravel, and mudflow deposits of Pleistocene - Quaternary age. According to the Garfield County Natural Hazard Mitigation Plan, the overall relative risk ranking due to landslides in Area 5 is 10% or a hazard index of 0.33. There are earthflow and soil creep deposits mapped to the south of the Sites in southern half of Section 19, but these deposits are not mapped in Sections 16 or 18, Township 7 South, Range 95 West. Movement of the extensive earthflow and soil creep slopes has ceased, except for local occurrences of very recent slumps and mudflows. The site will be engineered to protect against slides from the bluff to the south of pad site. April 28, 2017 23 O\OLSSON® ASSOCIATES Battlement Mesa PUD Phase 11- BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 D. Development in Rockfall Hazard Areas The site is not located within areas that are prone to rockfall or potential for rockfall. Potential rockfall areas are present along the steep drainages incised by Monument Creek to the south and southeast or at higher elevations to the south on Battlement Mesa. Development in Alluvial Fan Hazard Area The Sites are not mapped within the alluvial fan hazard area according to the Garfield County Surficial Geology, 2007. However, the Sites are located on an alluvial terrace underlain by fan gravel deposits and mudflow according to the Preliminary Geologic Map of the Grand Valley Quadrangle. Any potential hazards will be mitigated by appropriate engineering and design of the facilities on the site. F. Slope Development According to the Garfield County Natural Hazard Mitigation Plan, the overall relative risk ranking due to slopes in Area 5 is 31% or a hazard index of 1.17. Any risk ranking above 1 is considered high risk. The Arvada Loam soils are found on 6% to 20% slopes, while Ildefonso Stony Loam soils are found on 6% to 25% slopes. Engineering, design, and construction practices of the proposed development are expected to mitigate the limitation of slopes at the site since the site is located within an area developed for other land uses, including development of natural gas well pads. The site may require mitigation for slope, and will be graded and constructed for this purpose. The site is in an area near the Colorado River with slopes that are not as steep as surrounding areas. Ursa will conduct geotechnical studies of the area prior to site construction. The pad site will be engineered to protect the pad site and the bluff on the south edge of the site. G. Development on Corrosive or Expansive Soils and Rock The Arvada loam and Ildefonso soils are corrosive to steel and low to moderately corrosive to concrete, and the subsoil has a high shrink -swell potential. Corrosive and expansive soils are potentially present in the vicinity of the proposed BMC A Pad site which is a limitation for some site development. Any potential hazards will be mitigated by appropriate engineering and design of the facilities on the site. H. Development in Mudflow Areas The site is located in an area of mud flow and fan gravel deposits partially overlain by alluvial terrace deposits. The site is located on a terrace near the Colorado River drainage. These deposits are Holocene in age and future mud slides are a potential hazard if the area were to receive heavy rains. These flows are expected to originate from higher elevations to the south and would follow the drainages to lower elevations closer to the Colorado River floodplain. Any potential hazards will be mitigated by appropriate engineering and design of the facilities on the site. April 28, 2017 24 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 1. Development Over Faults There are no major faults shown in the Grand Valley area on the Geologic and Structure Map of the Grand Junction Quadrangle, Colorado and Utah. There are no mapped faults shown on the Preliminary Geologic Map of the Grand Valley Quadrangle, Garfield County, Colorado in the immediate vicinity of the Sites. Section 7-208. Reclamation A. Applicability The proposed well pad will be a COGCC approved location. Ursa will abide by all reclamation requirements set out by the SUA, Garfield County's COAs, COGCC's COAs, and Ursa's Reclamation Plan. Ursa's surface disturbances are covered under a statewide bond held by the COGCC. A copy of the bond is included with this submittal. 1. Installation of ISDS. No ISDS will be installed. 2. Driveway Construction. All areas within the Construction Easement of the access road will be reclaimed according to Ursa's Reclamation Plan once road construction is completed. Reclamation will be in association with the implementation of the appropriate stormwater BMPs. 3. Preparation Area. All areas disturbed during development that do not comprise the longer- term functional areas of the site but are those areas used for the short-term preparation of the site will be reclaimed on an interim basis per COGCC Rules. B. Reclamation of Disturbed Areas A copy of Ursa's Reclamation Plan is included in the Reclamation Section of this submittal. Areas disturbed during development will be restored or landscaped per the Surface Use Agreement (SUA) with Battlement Mesa Land Investments. 1. Contouring and Revegetation. Areas disturbed by grading will be contoured so they can be revegetated as appropriate for interim and final reclamation per the SUA. At the end of the productive life of the well pad, all equipment will be removed, and the surface will be contoured and seeded with an appropriate seed mix. Inspection and necessary maintenance will continue until desirable vegetation is established and with 70% surface coverage as compared with the original on-site vegetation. Typically, 70% coverage is achieved within two to four growing seasons of reclamation, using weed -free species and plant cover typical to that site as noted in the Reclamation Plan and agreed upon with the Owner of the property. 2. Application of Top Soil. Top soil will be utilized in berms and/or used in landscaping around the well pad. 3. Retaining Walls. There will be an engineered soil nail wall on the southern edge of the well pad to stabilize the cut at the toe of the bluff. A boulder wall will be installed along the access road to stabilize the cut slopes of the road. 4. Slash Around Homes. No residences will be part of the proposed project. April 28, 2017 25 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 5. Removal of Debris. Within 6 months of substantial completion of soil disturbance, all brush, stumps, and other debris shall be removed from the site. 6. Time Line Plan. Per the SUA, no landscaping is required for this well pad. Interim reclamation will occur once drilling and completion activities are finished, decreasing the size of the well pad. The site will enter final reclamation in 20 to 30 years, at the end of the life for the natural gas wells on the well pad, and within 12 months after plugging the wells on the site per the SUA and COGCC Rules. Division 3. Site Planning and Development Standards Section 7-301. Compatible Design Operation of the proposed well pad will be consistent with nearby uses and the Planned Development Unit as set up in Garfield County Resolution 82-121 recorded October 20, 1982. During the production phase of the wells, the facility will be unmanned, except during times of maintenance and load out and transportation of condensate from the pad. The well pad will be visually buffered from adjacent residences through topography, distance, and vegetation. Ursa may install a sound wall during drilling and completion operations to mitigate for sound and some visual impacts. Any lighting will be directed downward and inward away from adjacent properties. All equipment that remains on the pad after drilling and completions will be painted a neutral color to blend into the landscape. The SUA with Battlement Mesa Land Investments does not require additional landscaping at this pad site, due to its location next to the wastewater treatment plant. a. Site Organization The proposed well pad has one access point off River Bluff Road at the northern end of the project site. The site will be organized to provide safe access to and from the site and parking off the public right-of-way. It will not disrupt solar access to adjacent properties, pedestrian access, nor access to common areas along River Bluff Road. B. Operational Characteristics The operations of activities on the site will be managed to avoid nuisances to adjacent uses relating to hours of operations, parking, service delivery, and location of service areas and docks. All parking and service areas will be on-site. No street activities will be allowed, except in cases of emergency. 1. According to Ursa's Fugitive Dust Control Plan, dust control may consist of water, surfacing materials, or non -saline dust suppressants as appropriate for road conditions. Per the SUA, no flaring will be permitted within 2,000 feet of an occupied dwelling, except in an upset condition. Production equipment will comply with applicable CDPHE and COGCC regulations governing VOC emissions. Ursa uses enclosed combustor type flares which have little to no visible flames. Use of VRUs will be determined on a case-by-case basis due to the dry nature of gas in the Battlement Mesa area. A temporary VRU may be used for newly completed wells during the peak flow back period. The VRU will allow for the capture of additional vapors instead of April 28, 2017 26 O\OLSSON® ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 burning or venting them. This allows Ursa to use lower tank pressures. A combustor has a 95+% efficiency rating to reduce VOCs. Ursa will be in compliance with the applicable CDPHE Air Quality Control Commission regulations, including Regulation No. 2 requirement that no oil or gas operation may cause or allow the emission of odorous air from any single source that is detectible after the odorous air has been diluted with seven or more volumes of odor -free air. 2. Drilling and completion operations are subject to the maximum permissible noise levels for industrial zones. During the production phase of the well, Residential/Agricultural/Rural zone maximum noise levels will apply, per the SUA and COGCC Rules. Stationary engines and their exhausts will be located and oriented to direct noise away from the homes closest to the well pad. Ursa will evaluate noise generation from equipment and require contractors to refit mufflers, etc., in situations where the volume of sound produced exceeds noise levels for Residential/Agricultural/Rural zones. Engine braking will be prohibited by Ursa for its personnel and contractors. 3. Per the SUA, there will be no time of day restrictions with regard to drilling, completing, re - completing, workover, or reservoir fracture stimulation operations. The construction of the BMC A well pad will be limited to the hours of 7:00 am and 7:00 pm, except for emergencies and episodic events beyond Ursa's control. Per the SUA, there are no time of day restrictions regarding drilling, completing, re -completing, workover, or reservoir fracture stimulation operations. Drilling will occur continuously 24 hours a day. Well completion activity will be limited to between 7:00 am and 7:00 pm as an added BMP. Once the wells are in production, vehicle trips to the pad will be limited to the hours of 7:00 am to 7:00 pm, except for emergencies and episodic events beyond Ursa's control. C. Buffering The topography, distance, and vegetation mitigate visual and sound impacts. The SUA with Battlement Mesa Land Investments does not require additional landscaping at this pad site, due to its location next to the storage area and wastewater treatment plant. D. Materials Tanks, buildings, and equipment will be painted to blend in with the surrounding landscape. Section 7-302. Off -Street Parking and Loading Standards Adequate parking will be made available to accommodate Ursa personnel during regular operation, inspection, and maintenance of the well pad facility. All activities on this site will be conducted out of any public right-of-way. General parking standards for industrial uses do not apply, because the public is not permitted on the site for safety reasons. All off-loading and loading will take place on the well pad out of the public right-of-way. See the Site Plan for truck circulation related to water delivery and the production phase of the well pad. Loading and unloading of vehicles will take place in a manner that will not interfere with the flow of traffic on River Bluff Road (CR 307). April 28, 2017 27 O\OLSSON ® ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Parking and loading surfaces have been designed to ensure proper drainage of surface and stormwater. See Grading and Drainage Plan section of this submittal. Due to safety concerns, handicapped or accessible parking is not appropriate for this land use. Traffic circulation patterns on site will be such that no vehicle will be required to back on to the public right-of-way. The access driveway for the proposed well pad runs to the south off the well pad to River Bluff Road. The apron off River Bluff Road is constructed to accommodate drilling rigs and tanker trucks typical for hauling produced water. The driveway has a clear vision area of 300 feet in both directions of River Bluff Road. The minimum width of the access road is 22 feet to facilitate the access and egress of drilling rigs to the well pad and provide maximum safety of pedestrian and vehicular traffic on the site. Due to the topography of the parcel for proposed well pad site, landscaping is not planned for the proposed project site. Any illumination will be downcast and shielded per Garfield County standards. For more information, see the Traffic Study and the Road Assessment Report included in this submittal. Section 7-303. Landscaping Standards This type of industrial use is typically exempt from the landscape standards of the Development Code, but given the fact that the requested land use is within the Battlement Mesa PUD, consideration has been given to provide landscaping that is consistent with the character of development and agreed upon with the Owner. The SUA does not require landscaping for this proposed well pad due to its location away from most residences within the PUD. Section 7-304. Lighting Standards A. Downcast Lighting During drilling operations, Ursa and its subcontractors will align the lighting equipment to minimize the proportion of the lights that are directed toward dwellings and will install lighting shield devices on all of the more conspicuous lights. Lighting will be directed inward and downward except as deemed necessary for safety reasons. After drilling and completion operations, any lighting will be directed inward and downward, towards the interior of the site. B. Shielded Lighting Exterior lighting shall be shielded so as not to shine directly onto other properties. C. Hazardous Lighting Light from the site will not create a traffic hazard to be confused as traffic control devices. April 28, 2017 28 O\OLSSON® ASSOCIATES Battlement Mesa PUD Phase 11- BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 D. Flashing Lights The facility will not contain flashing lights. E. Height Limitations There will be no permanent light sources exceeding 40 feet in height on the site. Section 7-305. Snow Storage Standards Snow will be stored in a vacant section of the proposed well pad. The site will be graded to accommodate snowmelt to insure sufficient drainage. Section 7-306. Trail and Walkway Standards A. Recreational and Community Facility Access The proposed well pad is located on private property within the Battlement Mesa PUD. A connection to public facilities is not appropriate or feasible. Division 10. Additional Standards for Industrial Uses Section 7-1001. Industrial Use A. Residential Subdivisions The proposed well pad is not located in a platted residential subdivision. B. Setbacks The northern edge of the well pad is approximately 56 feet from the property boundary with the Battlement Mesa Metropolitan District's waste water treatment facility. Temporary water storage tanks will be located on the northern edge of the well pad during completions activities. Once the well pad is placed intro production, the temporary tanks will be removed. The remaining equipment and tank batteries will be more than 100 feet from all property boundaries. A waiver of the setback standard is requested. C. Concealing and Screening Per the SUA, Ursa agrees to construct the proposed well pad to mitigate visual impacts to adjacent properties through the use of topographic and vegetative buffers. Aboveground facilities will be painted to blend in with the environment. D. Storing All products will be stored in compliance with all national, state, and local codes and will be a minimum of 100 feet from adjacent property lines. _. Industrial Wastes All industrial wastes will be disposed of in a manner consistent with federal and state statutes and requirements of CDPHE and COGCC. Cuttings Sampling and Stabilization: Both surface and production hole drill cuttings will be generated at each well pad. Raw cuttings (not stabilized) will be sampled and profiled at the April 28, 2017 29 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 location of generation in accordance with Ursa's Waste Management Plan. Once the raw cuttings are sampled, they will be stabilized (absorption/removing liquids) in a temporary area on the well pad. The cuttings will be stabilized using either native soils (preferable) or a commercially available inert adsorbent (sawdust, Stabil EZ, etc.). In some cases, relocation of cuttings to another location during drilling would be required due to the small pad size. If the volume of cuttings on the well pad during drilling exceeds the capacity of the on-site temporary area, limits operational capabilities to complete drilling, or creates safety concerns, a COGCC Sundry Notice (Form 4) will be submitted for approval to relocate the cuttings to another location pending the results of sampling analytical results. All cuttings will be covered when removed off-site. Cuttings Management and Disposal: If sampling results for either surface or production hole cuttings meet COGCC Table 910-1 standards, they will be treated as non -waste (essentially soil material) and will be managed under one or more of the following options: 1) remain on site for pad stabilization/reclamation; 2) be relocated to another location for beneficial reuse; 3) made available as fill material to the general public; 4) be relocated to a COGCC approved cuttings management facility; or 5) disposed of at an approved waste facility. Options 2 - 4 would be in accordance with a COGCC approved Sundry Notice (Form 4). Disposal at an approved waste facility would be managed under an approved waste manifest in accordance with CDPHE regulations. If cuttings don't meet standards, then Ursa will implement one of two options: continued mixing to meet Table 910-1 standards for beneficial reuse/relocation or transport to an authorized waste facility in accordance with Federal and State (COGCC/CDPHE) regulations, including manifesting. Final decisions will be based on site-specific operations logistics. . Noise Drilling and completion operations are subject to the maximum permissible noise levels for industrial zones. During the drilling and completions phase, an appropriate sized sound barrier may be erected and would remain in place through completions of the natural gas wells to minimize noise. During the production phase of the well, Residential/Agricultural/Rural zone maximum noise levels will apply, per the SUA and COGCC Rules. Stationary engines and their exhausts will be located and oriented to direct noise away from the homes closest to the well pad. Ursa will evaluate noise generation from equipment and require contractors to refit mufflers, etc., in situations where the volume of sound produced exceeds noise levels for Residential/Agricultural/Rural zones. Engine braking will be prohibited by Ursa for its personnel and contractors. Ursa's noise mitigation strategies have been fully described in other parts of this application package. G. Ground Vibration During the production phase of the proposed well pad, ground vibration will not be measurable at any point outside the property boundary. April 28, 2017 30 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 H. Hours of Operation Per the SUA, there will be no time of day restrictions with regard to drilling, completing, re - completing, workover, or reservoir fracture stimulation operations. The construction of the BMC A well pad will be limited to the hours of 7:00 am and 7:00 pm, except for emergencies and episodic events beyond Ursa's control. Per the SUA, there are no time of day restrictions regarding drilling, completing, re -completing, workover, or reservoir fracture stimulation operations. Drilling will occur continuously 24 hours a day. Well completion activity will be limited to between 7:00 am and 7:00 pm as an added BMP. Once the wells are in production, vehicle trips to the pad will be limited to the hours of 7:00 am to 7:00 pm, except for emergencies and episodic events beyond Ursa's control. 1. Interference, Nuisance, or Hazard During the production phase of the proposed well pad, adjacent lands will not be impacted by the generation of vapor, dust, smoke, noise, glare, or vibration beyond the normal impacts of activities occurring around the adjacent properties. Ursa will apply the appropriate level of controls to accommodate potential impacts via adherence to CDPHE Air Quality regulations and the implementation of industry BMPs included in the SWMP and Ursa's Fugitive Dust Control Plan. The proposed well pad and access road will be graveled to reduce fugitive dust, which will be controlled using water or other dust suppressants. This proposed use will comply with Colorado Revised State Statutes and COGCC Rules regarding noise impacts at all times. If a nuisance complaint is received on a location for noise, odor, dust, or other nuisances, Ursa's standard operating practice is to respond to each complaint as soon as possible. The person receiving the complaint, usually the Landman, gathers as much information (such as wind direction, time, duration, strength, nature of odor or noise, etc.) about the issue as possible. This information is relayed to the operations lead who begin to determine the source of the issue and what may be causing it. Once the root cause of the issue is identified, the team determines mitigation efforts that will help remedy the concern(s). The land team follows up with the stakeholders on the effectiveness of the mitigation efforts and adjustments are made as necessary. All complaints are logged and tracked to improve Ursa's overall best management practices (BMP) performance on existing and future assets. Ursa has implemented a Stakeholder Hotline for concerns and complaints that will be answered 24 hours a day, seven days a week by a designated Ursa staff member. The number is 970-620-2787. Ursa also has a 24/7 emergency hotline, 855-625-9922. April 28, 2017 31 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 This page is intentionally blank. April 28, 2017 32 O\OLSSON® ASSOCIATES March 20, 2017 Ursa Operating Company LLC. Attn: Mr. Honeycutt 792 Buckhorn Drive Rifle, CO 81650 3799 HIGHWAY 82 • P.O. DRAWER 2150 GLENWOOD SPRINGS, COLORADO 81602 (970) 945-5491 • FAX (970) 9454081 RE: BMC A Pad Dear Mr. Honeycutt: The above mentioned development is within the certificated service area of Holy Cross Energy. Holy Cross Energy has existing power facilities located on or near the above mentioned project. These existing facilities have adequate capacity to provide electric power to the development, subject to the tariffs, rules and regulations on file. Any power line enlargements, relocations, and new extensions necessary to deliver adequate power to and within the development will be undertaken by Holy Cross Energy upon completion of appropriate contractual agreements and subject to necessary governmental approvals. Please advise when you wish to proceed with the development of the electric system for this project. Sincerely, HOLY CROSS ENERGY dd., .4..2 Allen Goad, Engineering Department agoad@holycross.com (970) 947-5433 AG:MM Goad/Honeycutt Letter 1 A Touchstone Energy® Cooperative