Loading...
HomeMy WebLinkAbout03 Alternatives AnalysisALTERNATIVES ANALYSIS O\OLSSON ASSOCIATES GL? UrsaM ot�l��lNG BMC L PAD LUMA Siting Rationale and Alternative Analysis (COGCC Rules 305A.a and 305A.b.(2)) COGCC Rule 305A.a. requires a 90 -day Notification of Intent (NOI) for a proposed location within a Large UMA (LUMA) oil and gas facility (herein after "location") prior to submitting an oil and gas location (i.e. Form 2A) application to the COGCC. Per COGCC Rule 305A.b.(2), this siting rationale is required as part of the NOI. The notification must be forwarded to (A) the local government with land use authority over the proposed location and (B) the landowner on whose lands the LUMA facility will be located, prior to finalizing the location with the landowner, unless exception criteria under 305A.e.(1) are met. BACKGROUND Battlement Mesa (Garfield County, CO), since the late 1970s, was planned as an energy community and initially built to support oil shale and oil and gas development. Following the slow -down of oil shale development in the 1980s, Battlement Mesa continued to be an oil and gas community for the development of the Piceance Basin. Since the 1980s, Battlement Mesa has also been promoted as a retirement community; however as of the 2010 census, the average age of a Battlement Mesa resident is 37.5 and a good portion of its residents support the oil and gas industry. The area surrounding the BM PUD has had historic (since 1949) and considerable oil and gas development, particularly within the past 10 years. At the time of the county resolution, 14 well pads were proposed within the BM PUD. Under Ursa's predecessor in interest, prior to December 2012, the number of pads and associated infrastructure was reduced to 10. Since that time, Ursa has reduced the number of proposed well pads within the BM PUD to five (5) and potentially four (4) as part of a comprehensive development plan to occur in two phases. Phase 1 included two locations (the BMC B and the BMC D), which were approved by the COGCC and Garfield County in 2016. Phase 11 will include the remaining three well pads (the BMC A and BMC L) and a temporary water storage facility (BMC F). Of the 197 wells Ursa proposes in the vicinity of the BM PUD, 107 are proposed to be drilled from the four (4) pads within the BM PUD, including the 31 gas wells to be drilled from the BMC L Pad. All pad locations within the BM PUD are subject to an amended Surface Use Agreement (SUA, 2009) executed between Battlement Mesa Partners, LLC (BM Partners) and Ursa Operating Company LLC (formerly Antero Resources). Said SUA establishes not only the BMC L pad location, but all four (4) of the pad locations for the overall development of the BM PUD. This also meets the intent of the Governor's Task Force and implementing LUMA regulations, as the oil and gas facility is proposed within a site specific development plan (via the SUA) that establishes vested property rights and which expressly governs the location of the wells and production facilities on the surface estate. It should be noted that in working closely with Battlement Mesa Partners over the past several years, the comprehensive development plan considered many complex factors, including long- term community development plans and complex operational considerations. 1 bPUrSaW SITING CRITERIA Several considerations and criteria weigh significantly in selecting locations to minimize potential impacts to human health, safety, and the environment (including wildlife). Proposed Best Management Practices (BMPs), developed on a site-specific basis provide an additional level of mitigation, in addition to Federal, state, county and local regulations, land use codes and permit conditions of approval. Potential criteria may vary on a site- specific basis and include (but aren't limited to) those listed below: Only those criteria applicable to the proposed location are addressed: Geology and Bottomhole Considerations • Number of Bottom holes and approximate depths • Rationale for selecting this location from a mineral development perspective Technical and Operational capabilities Issues • Topography and accessibility of locations • The ability to reach and develop bottom holes in an economic and technically feasible manner using proven technologies • Water availability, transportation and management options • Seasonal and weather constraints, and timeframe to develop (construct, drill, complete, produce) Existing Mineral Leasing, Surface Owner Contractual Considerations • Mineral leasing agreement(s) • Surface owner Surface Use Agreement (SUA) provisions and preferences (w/landowner conflicts) • Potential local/regional conflicts with future development by a landowner • Prior existing rights and encumbrances (both public and private) • State and county land and easement cultural setback requirements (i.e. COGCC exception/buffer zones) Community Health and Safety Concerns • Traffic safety including transportation and haul routes • Proximity to distance of the location from building units, schools, public buildings, etc. • Community events that may affect scheduling (if known) Regulatory Considerations Affecting Siting • Existing Federal, state, county and local regulations and land use codes (and conflicts) • Minimizing the level of disturbance associated with pads, roads, pipelines, etc. Environmental • Potential natural resource impacts to sensitive areas, public water supplies, wetlands, floodplains • Potential for nuisances including traffic, odors, noise, air emissions, etc. • Sensitive area, natural resource, environmental and wildlife concerns • Potential environmental and wildlife concerns 2 bPUrSagPw1NG PROPOSED LOCATION Geological, Technical and Operational Considerations Consideration was given to the location most likely available to reach all bottomholes from a single well pad vs. multiple pads to reach all bottomholes. The proposed oil and gas location has 31 bottomholes that would be accessed from this location. The farthest bottomhole from the locations is approximately 3,588'. Please note that an injection well is not proposed at this location at this time. The construction of the well pad location will have moderate cuts and fills. Access to the location would be via existing improved and unimproved existing roads. A shorter well pad access road will be constructed, approximately 350ft +/-. Based on the bottomhole locations in relationship to the location of the well pad, Ursa has determined that it is economically and technically feasible using proven technologies to reach all bottomholes and that the maximum drilling reach of 3,588' is reasonable and practical. Existing Mineral Leasing, Surface Owner Contractual Considerations Ursa has valid existing lease(s) to reach bottomholes from the proposed location. Communication with the surface owner has been in progress for the past several years and an agreement has been reached. The surface owner agreed to amend the surface use agreement to move the proposed location to the east farther from the subdivision to the north and away from the highly visible location near the golf course as proposed in the original SUA. The well pad is not anticipated to affect any prior existing rights, easements or encumbrances. There are no building units within exception zone (0 — 500') and nine building units and one commercial building located within the buffer zone (500 —1000'). Pending Loc Dwg confirmation Community Health, Safety and Nuisance Concerns Ursa's traffic and transportation (aka haul route) plans consider potential community and residential safety concerns. The proposed location doesn't appear to present any traffic or safety concerns that would adversely affect this location, nor present any greater concerns that other locations in similar settings. In addition, Ursa works with Community Counts, the Garfield Energy Advisory Board, and periodic community meetings to address upcoming rig moves, operations actions, etc. that would potentially affect the community. Haul routes were established by Garfield County to serve as primary routes for oil and gas development in the vicinity of this location. There is a potential for short-term noise and lighting nuisances associated with construction, drilling and completions for the 9 building units to the north of the well pad location. However, Ursa will work with the permitting agencies and the community to mitigate or eliminate potential nuisances through compliance with regulations, BMPs, and state and county permit conditions of approval (COAs). 3 Ut?Ursa i OPERATING COMPANY Regulatory & Environmental Considerations Ursa has conducted site reviews, onsites, and land assessments to ensure that the location would comply with existing Federal, state, county and local regulations and land use codes; including both cultural and environmental setbacks. No conflicts with laws and regulations have been initially identified in the assessments and onsites conducted by Ursa. Ursa and its third party consultants have conducted site environmental assessments including ecological surveys (e.g. noxious weeds, wildlife, waters of the state, etc.) for the BMC L Pad. The proposed location was evaluated for potential natural resource impacts to include (but not limited to) sensitive areas, public water supplies, wetlands, watersheds and floodplains. The proposed location is not located within the 100 -year floodplain, nor does it appear to be within the Parachute Watershed District or a designated 317B Public Water Supply Area. This location is located within key wildlife habitats, for which a Wildlife Mitigation Plan exists, so there are no issues affecting wildlife, which is primarily big game. Otherwise no potential environmental conflicts were identified during the site reviews and onsite. As a result of moving the proposed location to the east, there are no downwind residents within 1,000ft. ALTERNATIVE LOCATIONS CONSIDERED Geological, Technical and Operational Considerations Alternative locations were considered and evaluated over the past several years to reach bottomholes to meet lease commitments, without requiring two locations or more to reach bottomholes. Related limitations to alternative locations are addressed in sections below. Other adjacent locations were considered for construction, drilling bottomhole reaches and operations of the pad, access road and pipelines. However these options were eliminated due to landowner development plans and/or state, county, land use codes, and environmental compliance considerations. Existing Mineral Leasing, Surface Owner Contractual Considerations From both a mineral and the SUA with the surface owner, no other feasible alternatives exist. The well pad isn't anticipated to affect any prior existing rights, easements or encumbrances. Community Health and Safety Concerns Ursa's initial review of traffic and transportation haul routes found that no other options exist based on current infrastructure. No alternative location was identified that would create less traffic and safety concerns. Alternative locations to the north, south and west would place the location in closer proximity to homes, building units and the golf course and would likely result in a higher potential for short-term noise and lighting nuisances associated with construction and drilling in close proximity to the well pad location. The original pad location near the golf course pursuant to the 2009 SUA was not a preferred location due to difficult topography and drainages in the area as well as visual impact to the surrounding community. In 2016, Ursa was able to work with the surface owner and amend the SUA to relocate the pad out of the drainage area to a much preferred location further from homes and the golf course. Upon further technical review and discussion with COGCC staff, it was discovered that the newly relocated pad fell within 1000' of a High Occupancy Building Unit (HOBU), being the Grace Bible Church child care center. Ursa elected to postpone 4 Ursa i OPERATING COMPANY permit submittal in order to relocate the pad approximately 115' north of the renegotiated location in order to maintain a 1000' buffer to the HOBU. The proposed pad location now falls outside of the 1000' buffer from the HOBU as well as the residential building units located to the north. Regulatory & Environmental Considerations Alternate locations were considered as part of site environmental assessment, onsites, and land assessments to ensure that the location would comply with existing Federal, state, county and local regulations and land use codes. While other locations could potentially comply, those options were eliminated due to both cultural and environmental setbacks, and other reasons included in this siting analysis. Alternate locations were considered in evaluating potential natural resource impacts to include (but not limited to) sensitive areas, public water supplies, wetlands, floodplains and wildlife. SUMMARY Ursa has evaluated the proposed location and potential alternative locations to assess compliance with Federal, state and local regulations and land use codes, and the landowner's preference as documented in the SUA. In conducting the siting analysis, potential conflicting land uses and concerns were identified. The analysis included mineral lease obligations, SUA contractual obligations, existing and reasonably foreseeable land development uses, regulatory setbacks, community concerns, and potential impacts to natural resources, the environment, and wildlife. Based on the information provided in this siting rationale, alternative sites to the north, south and west aren't considered feasible for the location for reasons provided herein, and still have the ability to reach bottom holes. Ursa already has a location to the northeast approved by COGCC and Garfield County. Therefore, Ursa believes that the proposed location is the best option to locate the proposed well pad with appropriate BMPs and permit COAs. 5 URSA PICEANCE NAD83 - Ursa Operating Co LLC - Piceance Basin BMC L 11 '8-07-95 BMC L 11C - BMC L 11 BMC L BMC L 12B-0 8- 1 7-95 BMC L 12C -08 - BMC L 12D -08 -07 - BMC L BMC L 21D-08-07-95 MC L 22A-08-07-95 3A 07 -07- 3B -07- L 43C-07 . -95 L 43D-0 44A- i. BMC L 4B- -07- BMC L 44007-07-95 BMC D 4413-07-07-95 BMC L 14B BMCL14C u: -u -95 BMC L 14D 0..-07-95 BMC B 41B- 3-07-96 BMC B 41C- 3-07-96 MC D 11C-18-0 MC D 11D-1 I C D 21 B-18-07-95 OCD 21C 8-07- 1 B-18-07-95 41A -18 -07- 41B -18 -07 -95 1A -18-07-41B-18-07-95 C D 4 - 8-07-95 it 17 n7_QLi BMC B 32A-1 BMC B 3 BMC MC D 12 18-07-9 _1 kfla • 32A-18-07-95 12B-18-0 - 32B-18-07-95 2C-18-07-95 BMC • D-18-07-95 D E-18-07-95 C-1 BM ► 3 • -13-07-96e 3C A 33A- -6-96 BMC A33=- -07-•6 BMC// C-1 '7-9. BMCA 33D -13 - BMC A 34A13-07-9 BMC A 34B-13-67-96 BMC A 34C-13-0 BMC B 42D -13 - BMC B 43A-•. -96 BMC B 43B- •-07 •6 B"43C- -07-96 -13-07-96 MC D 22B :-07-95 BMC D 22 18-07-95 B B 22D-18-07-9 C = 23A-18-07-9 3B-18-07-95 M B 3C-18-07-95 MC B D-18-07-95 MC B 13: -18-07-9 MC B 13 1 -18-07-95 MC B 13 -18-07-95 MC B 14•-18-07-95 MC A 14B-18-07-95 14C-18-07-95 MC A 4D-18-07-95 BMC A :4D-1 7- 07-96 -07-96 BMC A31 BMCA31 B- i B A 31 -07 •6 4- -96 4-07-96 BMC A 41 4-07-96 BMC A 41 24-07-96 BMC A 41D-24-07-96 22IB-08-07-95 C-08-07-95 v-08-07-95 �4-08-07- L 23B-08-07-95 1 7 ORM PAD BMC A BMC B 11 BMC D BMC L 0 1,040 FEET PETRA 4/18/2017 4:22:03 PM