HomeMy WebLinkAbout1.02 Supplemental Application Materials1
QB Energy Operating, LLC
Wildlife Mitigation Plan
August 2024
Prepared by:
QB Energy Operating, LLC
&
C-K Associates, LLC
In Cooperation with
Colorado Parks and Wildlife
Contributors
Lindsey Rider – QB Energy Operating, LLC
John Andrews - QB Energy Operating, LLC
Keith Nichols - CK Associates, LLC
Brian Reilly - CK Associates, LLC
Taylor Elm – Colorado Parks and Wildlife
Danielle Neumann – Colorado Parks and Wildlife
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Table of Contents
Introduction and Signatory Page .................................................................................................................. 3
Wildlife Mitigation Plan Following the New January 15, 2021 Protection of Wildlife Resources 1200
Series ............................................................................................................................................................. 5
1201.b.(1)-(4) Wildlife Mitigation Plan ......................................................................................................... 5
(1) Pre-Application Consultation and Alternative Location Analysis ................................................. 5
(2) Description of Best Management Practices .................................................................................. 5
(3) Description of 1202.b Operating Requirements ......................................................................... 10
(4) Description of 1203 Mitigation Commitments to Offset Unavoidable Adverse Impacts to
Wildlife Resources ...................................................................................................................... 12
1203. Compensatory Mitigation for Wildlife Resources ............................................................ 12
Direct Impacts .................................................................................................................... 12
Indirect Impacts .................................................................................................................. 12
QB Energy Mitigation Projects ........................................................................................... 13
List of Attachments
A. Record of Modification
List of Figures
A. Figure 1 Overall Management
B. Figure 2 Five Primary Migratory Corridors
List of Appendices
A. Caerus Piceance, LLC Development 1 – Compensatory Mitigation Plan Expanded Liberty Unit
(ELU) Development Plan
B. ELU A18 495 -Supplemental Site- Specific Information to the Wildlife Mitigation Plan - 2022
C. ELU M12 496 -Supplemental Site- Specific Information to the Wildlife Mitigation Plan - 2024
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QB Energy Operating, LLC
Wildlife Mitigation Plan
Introduction and Signatory Page
To meet the requirements of the new Energy and Carbon Management (ECMC) 1200 Series Rules
(effective January 15, 2021), QB Energy Operating, LLC (QB Energy), has developed a revised North
Piceance Wildlife Mitigation Plan (WMP) that will cover operations by QB Energy on QB Energy’s North
Parachute Ranch property (NPR) and the North Piceance properties owned by QB Energy (previously
owned by XTO), and any additional asset(s) acquired in the future operated by QB Energy. This WMP will
address each of the required elements listed within the ECMC 1200 Series Rules. This WMP will detail the
methodology behind the percent reduction to Indirect Impacts, for the implementation of Best
Management Practices (BMPs). This WMP will also detail the established credit value for mitigation
projects to offset Direct and Indirect Impacts. QB Energy and Colorado Parks and Wildlife (CPW) have
cooperatively developed BMPs, mitigation projects and an overall process to value projects. This WMP
has a 3-year life span that can be re-established at the end of term.
The WMP may be modified with agreement from both CPW and QB Energy. Any such modification to the
WMP shall not be effective unless agreed to in writing by both parties in an approved Record of
Modification (Attachment A). This WMP is subject to such modifications as may be required by changes
in Federal or State law, or their implementing regulations. Any such required modification shall
automatically be incorporated into and be part of this WMP on the effective date of such change as if fully
set forth herein and the parties agree to take all actions necessary to comply with the changes to Federal
or State law, or their implementing regulations.
The term of this WMP expires on the date indicated below. Either party may terminate its agreement to
this WMP upon 30 days written notice to the other party. Upon expiration of the 30 days, all future
obligations of the parties under this WMP are terminated. However, and notwithstanding such
termination, the parties remain obligated and are required to continue to comply with the terms and
conditions of this WMP for operations conducted pursuant to an approved Form 2A or associated permit
that was approved during the effective period of this WMP.
It is expressly understood and agreed by the parties that, except for rights of enforcement by the ECMC
set forth above, nothing in this WMP shall give or allow any claim or right of action by any other third
party.
The waiver of any breach of a term or condition of this WMP by a party shall not be construed or deemed
a waiver of any subsequent breach of a term or condition, nor shall it impact in any way the rights of
enforcement by the ECMC.
This WMP is intended to be an overarching document that will encompass future QB Energy development
projects. Site specific mitigation requirements will be addressed for each project and added as an
appendix to the WMP.
This WMP is the complete integration of all understandings between the parties. No prior or
contemporaneous addition, deletion, or any other amendment thereto shall have any force or effect
unless embodied herein in writing.
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The signatories hereto warrant that they possess the legal authority to enter into this WMP and that they
have taken all actions required by the respective parties’ procedures, by-laws or applicable law to exercise
that authority, and to lawfully authorize the undersigned signatory to execute this WMP and bind the
party to its terms and conditions. The persons executing this WMP on behalf of the parties warrant that
such persons have full authorization to execute this WMP.
Signatures:
QB Energy Operating, LLC
__________________________
Lindsey Rider Date
Director of EHS
Colorado Parks and Wildlife
__________________________
Travis Black Date
Northwest Region Manager
Effective Date: 8/29/2024
Expiration Date: 8/29/2027
8/29/2024
8/30/24
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Wildlife Mitigation Plan Following the New January 15, 2021 Protection of Wildlife Resources 1200
Series
The purposes of this WMP are to state that QB Energy will adhere to Rule requirements under 1201.b.(1)-
(4), 1202 and 1203.
CPW will consult with QB Energy regarding proposed oil and gas operations in areas of High Priority
Habitats (HPH) associated with this WMP. Site specific consultation will be covered in the specific project
mitigation plans, found within the Appendices.
1201.b.(1)-(4) Wildlife Mitigation Plan
(1) Pre-Application Consultation and Alternative Location Analysis
QB Energy has maintained a long-standing working relationship with CPW and appreciates the
objectives set by CPW for protecting wildlife resources. This WMP and supplemental Compensatory
Mitigation Plans (CMP), represents that working relationship. QB Energy will continue to engage CPW
in pre-application consultation and alternative location analysis. As a proactive step, QB Energy
consults with CPW on every development project regardless of the requirement set by regulatory
thresholds. QB Energy will start with a desktop assessment using current CPW HPH mapping and any
other data available, to select an initial location. A team of experts will ground truth the location to
ensure that it is viable for multiple stakeholders. Natural Resource Surveys are initiated to collect
additional site-specific data that is used in the CPW consultation. Alternative locations are considered
at this phase and additional on-sites are scheduled with the landowner and applicable regulatory
agencies to further evaluate the location prior to a formal commitment to the location and steps
toward permitting.
(2) Description of Best Management Practices
The BMPs implemented by QB Energy represent a commitment to the ecological environment
through responsible energy development and management. BMPs provide minimization measures to
reduce Direct and Indirect adverse impacts. In consultation with CPW, several BMPs have been
recognized as benefits to the ecological landscape. These BMPs have been assigned a percent
reduction to be applied to indirect adverse impact acres (as calculated on page 13).
The following BMPs and percent reductions were developed jointly with CPW.
Best Management Practice Categories
Percent
Reduction
For Indirect
Impacts
BMP
Category
Abbreviation
For Tracking
Traffic Management (SCADA, Liquids Distribution, & Traffic Timing) 20% T
Drilling Technologies (high efficiency rigs, closed loop drilling & other) 5% DT
Greenhouse Gas/Emissions Management 5% GH
Water Quality Management 10% WQ
Habitat & Wildlife Management Practices 20% HW
Voluntary Measures for Additional Reduction:
Timing & Siting Considerations (e.g. seasonal & daily timing limits) 25% VTS
Total Percent Reduction Range: 60% - 85%
The following is a list of all BMPs, and other steps taken by QB Energy to reduce disturbance. These BMPs
provide multiple natural resource benefits and promote adaptive management of the landscape (QB
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Energy Overall Management Figure 1). The majority, if not all BMPs listed are voluntary and are outside
of the regulations that currently apply to Oil and Gas development. The parenthesized and bolded
abbreviations at the end of each BMP provides a correlation to the BMP categories agreed upon by CPW.
1) Operational BMPs
a) Three-phase gathering systems, where economically and technically feasible, to reduce footprint
remaining during production phase, eliminate traffic, and reduce venting and potential spills.
(WQ, T, GH, HW)
b) Remote well control and monitoring to reduce traffic through work/project prioritization and
increase emergency response efficiency. (WQ, T, GH, HW)
c) Solar panels as an alternate energy source for on-location production equipment. (T, GH)
d) Temporary surface water delivery lines to reduce truck traffic. (T, HW, WQ, GH)
e) Remote completions to reduce the size of pad needed for simultaneous operations. (T, HW)
f) Average well pad surface disturbance of 0.5 acres or fewer per well (well pad disturbance does
not include associated pipelines, access roads, or facilities) wherever possible. (HW)
g) Where feasible, electric power will be used at existing and future compressor stations to reduce
on-site emissions. (GH)
h) Use of gas lift to automate some production activities, reduces traffic to the well-site and reduces
gas vented to the atmosphere by reducing the frequency of the “blow down / unloading” of a
well. (T, GH)
i) Prohibit employees and contractors from carrying projectile weapons (including bows) on QB
Energy property, except during company-organized events. (HW)
j) Prohibit pets on QB Energy property. (WQ, HW)
k) Reduce traffic impacts by carpooling personnel to project locations, when appropriate and
feasible. (T)
l) When feasible, reduce additional surface disturbance by utilization of existing staging/storage
yards and gravel pit. (HW)
m) Strategically apply fugitive dust control measures on the NPR to reduce coating of vegetation and
deposition in water sources, including enforcing established speed limits on private QB Energy
roads. (WQ, HW)
n) QB Energy has volunteered to be a member of OGMP 2.0 and The Environmental Partnership.
These voluntary programs require a commitment to reduce methane emissions. QB Energy will
report reduction targets and annual metrics through Corporate Sustainability Reporting. (GH)
2) Pad Development
a) New directional drilling technology, such as longer reaches, shorter total depth times, and natural
gas-powered rigs, when possible. (WQ, T, GH, HW, DT)
b) Reoccupy existing pads if/when possible. (HW)
c) Simultaneous drilling and completions activities may be employed to shorten the disturbance
time necessary to drill, complete, and bring the pad to production. (T, HW, DT)
d) Green completions to reduce venting of natural gas to atmosphere during completions. (GH)
e) Continuous Monitoring Technologies will be used for fence line air monitoring during pre-
production operations on all new locations. (GH)
f) Toe berms of adequate size on all fill slopes facing and or adjacent to potential water to contain
any erosion from the fill slope. (WQ, HW)
g) Topsoil windrows on all new facility construction for perimeter control to divert to terminal
discharge points. (WQ, HW)
h) Hydraulic mulch or armoring on all exterior slopes adjacent to waterways. (WQ, HW)
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i) Follow the North Parachute Ranch Integrated Vegetation Management Guidance Document for
interim and final reclamation practices, including identifying appropriate seed mixes and invasive
weed control measures. Selection of seed mixes will be based upon the type of ecosystem
affected. (HW)
3) Pipeline Construction
a) Gathering line placement adjacent to roads wherever possible unless the existing road is adjacent
to waterways. (WQ, HW)
b) Multiple gathering lines placed in a single trench to minimize disturbance and construction times
for multiple lines. (T, HW, WQ)
c) Trench plugs (sloped to allow wildlife or livestock to exit the trench should they enter) at known
wildlife or livestock trails to allow safe crossing on long spans of open trench. (HW)
d) Pipelines installed at right angles to the drainages, wetlands, and perennial water bodies. (WQ,
HW)
e) Equipment bridges for pipeline construction made from either clean rock and flume pipes or
timber equipment mats with flume pipes. (WQ)
f) Horizontal directional drill techniques at perennial water bodies and wetland complexes. (WQ,
DT)
g) In-stream construction activity limited to 24 hours for waterbodies less than ten feet wide and to
48 hours for waterbodies greater than ten feet wide at locations where horizontal boring is not
feasible. (WQ, HW, VTS)
h) A minimum of five feet of soil cover maintained between the pipeline and the lowest point of the
drainage or water body channel. (WQ)
4) Road and Pad Construction
a) Existing roads used in lieu of new construction wherever feasible. (HW, WQ)
b) All access roads and facilities other than well pads seeded in a timely manner after construction
has been completed and seeding of all topsoil on pad construction. (WQ, HW)
5) Aquatic Resources
a) Water sampling to monitor for changes in water quality. Sampling will occur at a minimum
annually within areas of development activity. Existing and new water sampling data will be
maintained by QB Energy. (WQ)
b) Use two or more stormwater best management practices on new disturbance to control sediment
runoff and control or contain any potential spills, wherever surface disturbance must occur within
a riparian habitat, as defined by the presence of riparian associated vegetation. (WQ, HW)
c) Relocate temporary travel routes necessary for development (such as secondary access routes)
and long-term travel routes, wherever feasible, away from riparian habitat (as defined by
vegetation) at the time of interim reclamation. (WQ, HW, T)
d) Maintain spill response kits at strategic locations adjacent to riparian areas or other centralized
locations. (WQ, HW)
e) Install engineering controls (one-way valves, installed draw hoses with screened intakes,
overhead loading, and loading from tanks) on all water points from Parachute Creek to prevent
contamination. (WQ, HW)
f) Use voluntary timing limitations for cutthroat trout. (HW, WQ, VTS)
g) Block low water crossing at Light Gulch to eliminate unnecessary traffic through Parachute Creek.
(Completed 2010). (WQ, T, HW)
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h) Use existing head gates and analyze the strategic use of additional head gates on road culverts as
a tertiary containment (these are not the culverts in the waterway but draining to the waterway
during storm events). (WQ, HW)
6) Wildlife Resources
a) Perform biological site surveys (on-site) for each new development, using the most recent data
sets for wildlife and aquatic resources (the report format is based upon Federal on-site surveys).
(WQ, HW)
b) Perform pre-disturbance surveys when the on-site inspection and commencement of disturbance
occur in different field seasons (e.g., new raptor nests), using the most recent data sets for wildlife
and aquatic resources. (WQ, HW, VTS)
c) As a proactive step, QB Energy will consult with CPW on every development project regardless of
the requirement set by regulatory thresholds. CPW and ECMC HPH mapping data, QB Energy’s
wildlife resources database, and maps will be used to identify and document (where appropriate)
potential impacts or concerns during the project planning phase for proposed drilling operations,
new or existing locations to be used for siting completions operations, and construction of roads,
pads, and pipelines. (WQ, HW, VTS)
7) Black Bear
a) Conduct regular contractor and employee training with respect to wildlife awareness. (HW)
b) Reinforce training at worksite tailgate meetings, monthly safety meetings, and the Environmental
Health and Safety (EHS) hazard identification program, and through the use of signs. (HW)
8) Mule Deer and Elk
a) Avoid disturbance of big game production areas and winter range wherever possible, but this will
be a secondary consideration to preserving sage-grouse habitat. (HW, VTS)
b) Prior to construction of new surface structures within five primary migratory corridors (Figure 2)
QB Energy will consult with CPW. (HW, VTS)
c) Only essential traffic will be permitted to access sites throughout the NPR where no active
operations are occurring. (HW, T)
9) Raptors
a) New development will require raptor surveys if appropriate habitat exists per QB Energy’s Initial
Baseline Assessment (ISA) process. (HW)
b) Perform pre-disturbance raptor surveys prior to interim and final reclamation. (HW, VTS)
c) When feasible and appropriate, single pass presence/absence surveys may be conducted for high
priority species; this snapshot may not meet the standards of the nest occupancy survey. (HW,
VTS)
d) Schedule the commencement of development activity for the time of year outside of average
breeding seasons for the species of concern, if the duration of operations on a location prevents
seasonal avoidance (e.g., during drilling and completion operations that exceed 12 months per
location). (HW, VTS)
10) Greater Sage-Grouse: QB Energy will adhere to the following best practices for GrSG mitigation and
monitoring for QB Energy operations.
a) Where feasible, raptor perch deterrents will be installed on cross arms of power poles and other
documented raptor perches, such as radio towers, where birds are noted perching. Monitor all
structures exceeding six feet in height within occupied GrSG habitat for the presence of perching
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raptors or ravens. Perch deterrents need not be installed if they pose a safety issue (e.g., on the
handrails of a tank battery). (HW)
b) Locate new pads outside occupied GrSG habitat wherever possible or in habitat that is already
disturbed. (HW, VTS)
c) Implement three-phase-gathering on existing locations, where economically and technically
feasible, to reduce onsite facilities and increase the acreage put into interim reclamation. (T, HW,
DT)
d) Apply a 1-mile radius No-Disturbance buffer around active lek sites (documented activity by CPW
in the last five years) from 5:00 AM to 9:00 AM, March 15 through May 15. Where practicable,
traffic and other disturbances will be restricted during this date range after sunset when GrSG are
congregating around the lek until 9:00 AM the following morning when birds depart the lek. (HW,
T, VTS)
e) Restrict New Disturbance within nesting and brood-rearing habitat as much as possible from April
15 to July 1. (HW, VTS)
f) Site New Disturbance using topographic features to shield leks from new disturbance whenever
feasible. (HW)
g) Schedule cross-country pipeline construction and installation (not including lines along roads)
outside of the Critical Habitat Season. (HW, VTS)
h) Use interim reclamation to redevelop, as quickly as possible, ground cover that provides for
secure ground movements of GrSG and is an effective precursor to the reestablishment of
appropriate sagebrush cover. Detailed guidelines and practices for interim and final reclamation
are outlined in QB Energy’s North Parachute Ranch Integrated Vegetation Management Guidance.
(HW)
i) Reseed disturbances exceeding 15 feet in width in mapped occupied GrSG grouse habitat with
local sagebrush seed, where topography and weather conditions allow safe access to do so. (HW)
j) The following are approved exceptions to the above-described schedules and practices:
a. Well maintenance south of the Upper West Fork will not be considered New Disturbance
but will be minimized to the extent practicable during the Critical Habitat Season. (HW,
VTS)
b. Response to emergencies (an immediate threat to life, property, or the environment) will
not be considered New Disturbance and will be permitted without timing limitations.
(WQ, HW)
k) Definitions of Terms
a. “Critical Habitat Season” means the time period from March 15 to July 1 each year.
b. “New Disturbance” means any new activity that will cause or leave a long-term and
noticeable change to the landscape, including construction of access roads, gathering
facilities and pipelines, and any drilling or completion activities.
c. “Disturbance” includes, but is not limited to, noise, lights, vehicle traffic and New
Disturbance, as defined above.
Best Management Practices Reference Summary
T = Traffic Management = 15 references as BMP
DT = Drilling Technologies = 4 references as BMPs
GH = Greenhouse Gas/Emissions Management = 9 references as BMPs
WQ = Water Quality Management = 30 references as BMPs
HW = Habitat & Wildlife Management Practices = 53 references as BMPs
VTS = Voluntary Timing & Siting Considerations = 14 references as BMPs
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(3) Description of 1202.b Operating Requirements
QB Energy agrees to bore, rather than trench, any flowline and utility crossings of perennial streams
identified as aquatic High Priority Habitat unless the Operator obtains a signed waiver from CPW and
the Director or Commission approves a Form 4 or Form 2A documenting the relief. When installing
culverts or bridges, such structures will not impact or prevent the passage of fish unless otherwise
directed by CPW. 1202.a. Operating Requirements.
QB Energy acknowledges that all operating requirements that apply to the developments; wildlife,
habitat and geographical locations will be followed as described by the Rule, as follows.
(1) In black bear habitat, Operators will install and use bear-proof dumpsters and trash receptacles
for food-related trash at all facilities that generate trash.
(2) Operators will disinfect water suction hoses and water transportation Tanks withdrawing from or
discharging into surface waters (other than contained Pits) used previously in another river,
intermittent or perennial stream, lake, pond, or wetland and discard rinse water in an approved
disposal facility. Disinfection practices will be repeated prior to completing work and before moving
to the next water body. Disinfection will be performed by scrubbing and pre-rinsing equipment away
from water bodies to remove all mud, plants, and organic materials and then by implementing one of
the following practices:
A. Spray/soak equipment with a CPW-approved disinfectant solution capable of killing whirling
disease spores and other aquatic nuisance species defined by CPW; or
B. Spray/soak equipment with water greater than 140° Fahrenheit for at least 10 minutes. All
equipment and any compartments they contain will be completely drained and dried
between each use.
(3) At new and existing Oil and Gas Locations, Operators will not situate new staging, refueling, or
Chemical storage areas within 500 feet of the Ordinary High-Water Mark (“OHWM”) of any river,
perennial or intermittent stream, lake, pond, or wetland.
(4) To prevent access by wildlife, including birds and bats, Operators will fence and net or install other
CPW-approved exclusion devices on new Drilling Pits, Production Pits, and other Pits associated with
Oil and Gas Operations that are intended to contain Fluids.
A. Such fencing and netting or other CPW-approved exclusion device will be installed within 5
days after the cessation of active drilling and completion activities and maintained until the
Pit is removed from service and dried or closed pursuant to the Commission’s 900 Series
Rules.
B. The Director may require an operator to fence and net or install other CPW-approved
exclusion devices on an existing Pit if the Director determines that the installation is necessary
and reasonable to protect Wildlife Resources based on the analysis required by Rule 909.j, or
other information that demonstrates additional protections for Wildlife Resources are
appropriate.
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C. Operators will properly maintain and repair all fences, nets, and CPW-approved exclusion
devices required by this Rule 1202.a.(4).
(5) For trenches that are left open for more than 5 consecutive days during construction of Pipelines
regulated pursuant to the Commission’s 1100 Series Rules, Operators will install wildlife escape ramps
at a minimum of one ramp per 1/4 mile of trench.
(6) When conducting interim and final Reclamation pursuant to Rules 1003 and 1004, Operators will
use CPW-recommended seed mixes for Reclamation when consistent with the Surface Owner’s
approval and any local soil conservation district requirements.
(7) Operators will use CPW-recommended fence designs when consistent with the Surface Owner’s
approval and any Relevant Local Government requirements.
(8) Operators will conduct all vegetation removal necessary for Oil and Gas Operations outside of the
nesting season for migratory birds (April 1 to August 31). For any vegetation removal that must be
scheduled between April 1 to August 31, Operators may implement appropriate hazing or other
exclusion measures prior to April 1 to avoid take of migratory birds. If hazing or other exclusion
measures are not implemented, Operators will conduct pre-construction nesting migratory bird
surveys within the approved disturbance area prior to any vegetation removal during the nesting
season. If active nests are located, Operators will provide work zone buffers around active nests.
(9) Operators will treat Drilling Pits, Production Pits, and any other Pit associated with Oil and Gas
Operations containing water that provides a medium for breeding mosquitoes with Bti (Bacillus
thuringiensis v. israelensis) or take other effective action to control mosquito larvae that may spread
West Nile virus to Wildlife Resources. Such treatment will be conducted in a manner which will not
adversely affect aquatic Wildlife Resources.
(10) Operators will employ the following minimum Best Management Practices on new Oil and Gas
Locations with a Working Pad Surface located between 500 feet and 1000 feet hydraulically
upgradient from a High Priority Habitat identified in Rule 1202.c.(1). Q–S:
A. Contain Flowback and Stimulation Fluids in Tanks that are placed on a Working Pad Surface
in an area with downgradient perimeter berming;
B. Construct lined berms or other lined containment devices pursuant to Rule 603.o around any
new crude oil, condensate, and produced water storage Tanks that are installed after January
15, 2021;
C. Inspect the Oil and Location on a daily basis, unless the approved Form 2A provides for
different inspection frequency or alternative method of compliance;
D. Maintain adequate Spill response equipment at the Oil and Gas Location during drilling and
completion operations; and
E. Not construct or use any Pits, except that Operators may continue to use existing Pits that
were properly permitted, constructed, operated, and maintained in compliance prior to
January 15, 2021.
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(4) Description of 1203 Mitigation Commitments to Offset Unavoidable Adverse Impacts to Wildlife
Resources
1203. Compensatory Mitigation for Wildlife Resources
Direct Impacts
Direct Impacts will be calculated using the Direct Long-Term Disturbance acres (e.g., access route,
working pad surface) and the Direct Interim Reclamation Disturbance acres (e.g., pipelines,
interim reclaim area of pad).
A credit ratio is established between the projects towards the Direct Long-Term Impacts, Direct
Interim Impacts, and Indirect Impacts. Each credit is assumed to be an acre credit unless a
different metric is defined by the project. Ratios for Direct and Indirect Impacts have been
established jointly with CPW.
• 4:1 credit ratio is established for Direct Long-Term Impacts (4 project credits for 1 acre of
Direct Impact)
• 1:1 credit ratio is established for Direct Interim Impacts
• 1:1 credit ratio is established for Indirect Impacts
Indirect Impacts
QB Energy is using a Proximity Analysis Methodology (PAM) to determine indirect impact acres
for future pad development. This methodology was developed by CK Associates, LLC (CK) and
implemented in early compensatory mitigation agreements with CPW. QB Energy in consultation
with CPW has established the following methodology for this WMP. All Indirect Impact acres are
calculated jointly with CPW consultation.
Proximity Analysis Methodology:
• A 0.425-mile buffer (approximately 680 meters) is applied from the edge of the proposed
pad disturbance boundary (edge of direct impact). The buffer is segmented into 10 equal
distance rings, with the first ring measuring at 0.043 miles out to the tenth ring of 0.425
miles. The 0.425-mile buffer distance was selected based on avoidance distances for greater
sage-grouse and is also representative of the avoidance or “reduced use” distances applied
by CPW for calculating indirect impacts to big game species.
• Each ring has a percent acre total, the first ring measuring at 0.043 miles has a 100%-
acre count with the second ring at 0.085 miles having a 90%-acre count and sequentially at
the outer buffer distance of 0.425 miles the percent acre count is 10%. The reasoning for the
100% to 10% reduction of acres going out from the pad edge of disturbance is to recognize
disturbance to wildlife is higher in the near field and diminishes in the far field. The process
also considers the probability of wildlife presence. This step provides the Indirect Impact
acre baseline for each pad.
• Overlap of buffer area is eliminated from existing and/or proposed pads or other Direct
Impact disturbances, such as roads. This removes double counting of Indirect Impact acres.
• An elevation criterion is established within the analysis; (1) if a 100–foot elevation drop
occurs from the edge of the disturbance boundary, all acres beyond that point are removed
from the indirect acre baseline, (2) if a 10-foot elevation gain is achieved excluding an
immediate hill or ridge, all acres beyond that point are removed from the Indirect Impact
acre baseline. The 10-foot elevation gain will be applied in concurrence with CPW.
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• The remaining Indirect Impact acre buffer is reviewed jointly with CPW to apply a final
removal of acres based on the probability of adverse disturbance to wildlife. In the far field
of the 0.425-mile buffer based on topography and elevation changes, noise and line of sight
as a factor for wildlife disturbance is greatly diminished.
• The remaining acres become the Indirect Impact acres for compensatory mitigation
consideration, absent the application of BMP percent reduction to Indirect Impact acres.
Based on an operator’s BMP valuation with CPW (0-85%), the BMP percent reduction is
applied to the Indirect Impact acres to calculate the actual Indirect Impact acres for
compensatory mitigation.
• Project specific Indirect Impact acres will be detailed in the compensatory mitigation plans,
found within the Appendices of this WMP.
QB Energy Mitigation Projects
Direct and Indirect Impacts can be offset by a habitat mitigation fee and/or by implementing a
compensatory mitigation project(s). As part of the 3-year WMP, QB Energy in agreement with
CPW has identified projects and credit values (see table below) to be used to offset Direct
and Indirect Impacts. New mitigation projects can be added to the WMP with agreement
from CPW.
QB Energy and CPW agreed on the value of project types for wildlife resources on QB Energy's
property. Each project was assigned a credit value based on either scale of acres, wildlife use,
and/or agreement of value. All projects will have a lifespan criterion assigned depicting one or
more of the following credit categories:
• 1-time credit with no expiration
• 3-year lifespan upon implementation
• Annual accumulation for a 3-year running total
• Generated annually with no accumulation (i.e. must be used within the same calendar year
they are generated)
Mitigation Projects Credits
No
expiration
1-time
credits 1
3-year
lifespan
for annual
credits 2
Earn
annually
3-year total
forecast
Brush removal 196 Yes No No 196
Square S allotment 954 Yes No No 954
Middle Fork Meadows 30 No Yes Yes 90
Spring and/or Guzzler 80 Yes No No 80 4
Water Well 160 Yes No No 160 4
Off ROW Weed Management 95 No Yes Yes 285 5
Grazing Monitoring & Ranch Manager 3003 No No Yes 300
1. 1-time credit projects have no expiration date.
2. Annual credit projects have a 3-year lifespan upon implementation. These credits can rollover to next WMP agreement.
3. Designated projects may have annual credit lifespan (12 months).
4. Assumes one project completed in lifespan of WMP. Credits are allocated when project is constructed/implemented.
5. Assumes same number of acres are treated each year.
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QB Energy and CPW will meet each year to confirm project credits generated and used, in addition
to any new projects for consideration and implementation. QB Energy will maintain a working
spreadsheet that will track projects, credits, and debits to offset impacts from future
development.
Project Descriptions
Brush Removal – This project is site-specific within Greater Sage-grouse (GrSG), elk, and mule
deer habitat. QB Energy (previously Caerus) mechanically treated 196 acres of habitat by
removing mature serviceberry/gamble oak stands, while maintaining existing sagebrush
vegetation using a hydro-axe and heavy equipment. This was a one-time project receiving 196 no-
expiration credits. See Caerus Piceance LLC Development 1 – Compensatory Mitigation Plan for
the Expanded Liberty Unit (ELU) Development Plan for details regarding the project.
Square S Allotment – CPW and QB Energy (previously Caerus) agreed on a credit exchange for
animal unit months (AUMs) within the Square S grazing allotment in the Piceance Basin of Rio
Blanco County. CPW believes that full control of grazing rights within the Square S Allotment
would provide expanded range management options, reduce user conflicts, and enhance forage
and escape cover for wildlife. The acreage consists of approximately 79,630 acres with a total of
3,522 base AUMs. Caerus retained 1,083 AUMs and CPW retained 2,439 AUMs. As of July 8, 2021,
Caerus agreed to exchange their 1,083 AUMs for 954 mitigation credits through a letter of intent
agreement with CPW. The signing of this WMP document codifies the agreement between CPW
and QB Energy (previously Caerus) to exchange the Square S grazing AUMs. Following the
finalization of this agreement, Caerus and CPW staff completed the necessary paperwork with the
Bureau of Land Management to transfer the base AUMs into CPW’s ownership. This was a one-
time project receiving 954 credits with no expiration.
Middle Fork Meadows – This is a 30-acre tract located on Parachute Creek. QB Energy maintains
this acreage through vegetation maintenance and irrigation providing big game an annual and
reliable food source during migration. The area is within several CPW wildlife boundaries for elk
and mule deer. This is an annual project that receives 30 credits per year. The credits have a 3-
year lifespan that may extend beyond the expiration of the current WMP agreement.
Water Management Projects – Water source management is critical for wildlife and vegetation
within the QB Energy operational boundary. To maintain wildlife movement and sustainability of
vegetation, water source spacing is part of QB Energy’s adaptive management plans. The
objective of this project is to establish a water source at locations where water is lacking to
maintain animal movement throughout the range. Wildlife movement reduces over grazing and
provides seasonal vegetation recovery. It is recognized that mule deer will travel up to one and
half miles for water, but elk prefer to stay within a half mile of a water source. A half-mile radius
range is equivalent to 320 acres and a one-mile range is equivalent to 640 acre spacing for which
big game will travel for water. QB Energy and CPW have agreed to the following water
management projects and credits:
• Spring and/or Guzzler – QB Energy may improve a natural spring or install a guzzler to
improve wildlife habitat where water is needed. QB Energy and CPW agree each
spring improvement or guzzler project will generate 80 one-time credits with no expiration.
15
• Water Well – QB Energy may install a water well to improve wildlife habitat where water is
needed. Wells can be more reliable than a spring or guzzler but require ongoing
maintenance. QB Energy and CPW agree each new well will generate 160 onetime credits
with no expiration.
Off ROW Weed Management – QB Energy conducts annual weed control treatment in areas not
associated with oil and gas operations. A team may traverse 1,000 acres to spray herbicide
on weeds to eliminate patches and seed source. The credits for this project are based on area
physically sprayed with a 2.5 multiplier to account for the larger area benefiting from weed
control. The total area sprayed will change each year based on need. For example, in 2020 QB
Energy (previously Caerus) completed weed control on 1,000 acres while spraying a total of 38
acres of weeds. Based on the 2020 data, QB Energy would have earned 95 credits with a 3-year
lifespan. Each year QB Energy will present to CPW the acres sprayed for conversion into credits
using the 2.5 multiplier. The project generates one-time credits with a 3-year lifespan.
Grazing Monitoring and Ranch Manager – The ranch manager is a full-time QB Energy
professional who provides oversight and ensures that BMPs are monitored. Under the Ranch
Manager’s guidance, QB Energy implements a holistic management approach between
operations and wildlife resources. The ranch manager oversees grazing lease agreements within
the QB Energy operational boundary to ensure livestock utilization does not impact other wildlife
resources. Existing and new lease agreements include provisions to (1) limit AUMs, (2) prevention
of overgrazing, (3) manage the use of salt blocks to protect vegetation, (4) identify any weed
treatment operations consistent with the North Parachute Ranch Integrated Vegetation
Management Guidance Document, and (5) implementation of other habitat management
practices. Monitoring includes fence inspections, periodic range checks for trespass livestock or
unexpected issues, and grazing utilization baskets to determine when livestock should be
removed from a geographical area. Grazing monitoring reports will be provided to CPW to assist
in the management of big game. While the Ranch Manager position if filled, QB Energy
will annually generate 300 credits with a 12-month lifespan.
CPW Access – CPW requests access to QB Energy property for scientific studies and special hunts.
QB Energy recognizes the need for CPW access and will determine the credits associated with the
access on a case-by-case basis depending on the type of access, location, and duration. Additional
mitigation credits from access agreements can be added via amendment at the time of approval.
16
Attachment A - Record of Modification
17
Table 1: Summary of WMP Modifications
Section/Page Reference Description Modification
Modification Date: 11/21/2023
Colorado Oil and Gas Conservation
Commission (COGCC) changed its
name to the Energy and Carbon
Management Commission (ECMC)
in 2023.
The name COGCC was replaced
with ECMC throughout the
document.
The plan was updated on
11/21/2023.
Modification Date: 08/27/2024
QB Energy Operating, LLC acquired
Caerus Piceance, LLC.
The company name Caerus, was
replaced with QB Energy
throughout the document
The plan was updated on
08/27/2024
Page 5 - 1201.b.(1)-(4) Wildlife
Mitigation Plan and Page 8 –
Wildlife Resources BMPs
Replacement of Wildlife
Consultation Matrix with updated
process.
As a proactive step, QB Energy
consults with CPW on every
development project regardless of
the requirement set by regulatory
thresholds…
Figures
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4S 94W4S 95W
4S 96W
5S 94W5S 95W
5S 96W
6S 95W
6S 96W
6S 97W
7S 95W7S 96W7S 97W
~7947 ac.
~11452 ac.
~8504 ac.
~14995 ac.
~8968 ac.
~10941 ac.
~2582 ac.
N. Parachute WMP
WMP Subunits
Canyons
Colony
ELU Development
Girls Claim
Old Mtn & Long Ridge
Northwest NPR
Wheeler Parachute
.
Figure 2. Five Primary Migratory Corridors on the NPR
Page 1 of 2
Dedicated to protecting and improving the health and environment of the people of Colorado
CERTIFICATION TO DISCHARGE UNDER CDPS GENERAL PERMIT COG500000
DISCHARGES ASSOCIATED WITH SAND & GRAVEL MINING AND PROCESSING
(and other Nonmetallic Minerals except fuel)
Certification Number: COG502246
This Certification to Discharge specifically authorizes:
QB Energy Operating, LLC
to discharge from the facility identified as
Jackrabbit Gravel Quarry
to:
Unnamed Tributary of Bear Run
Facility Located
at:
County Road 215, Parachute, Garfield County, CO 81635
Center Point Latitude 39.611066, Longitude -108.183965
Defined Discharge
Outfall(s) to Surface
Water
Outfall(s)
Lat, Long Discharge Outfall(s) Description Receiving Stream
001 39.6111414,
-108.1855790
Stormwater Runoff from northern
sediment trap
Unnamed Tributary of
Bear Run
002 39.6097434,
-108.1841265
Stormwater Runoff from southern
sediment trap
Unnamed Tributary of
Bear Run
003 39.615262,
-108.183208 Stormwater Runoff from haul road Unnamed Tributary of
Bear Run
All discharges must comply with the lawful requirements of federal agencies, municipalities, counties,
drainage districts and other local agencies regarding any discharges to storm drain systems, conveyances, or
other water courses under their jurisdiction.
Stormwater Monitoring Requirements
Permit Limitations and/or Monitoring Requirements apply to outfalls 001, 002, and 003 as outlined in
the Permit in Part I.C.2 and Parts I.G through I.Q.
On the effective date of this certification, the Jackrabbit Gravel Quarry is subject to the monitoring
requirements identified below at each discharge point of stormwater from the facility.
A. Visual monitoring, Part I.I.1
Per Part I.I.1 of the permit, the permittee must collect a stormwater sample from each outfall (or a
substantially identical outfall pursuant to Part I.H.1 of the permit) and conduct a visual assessment
of each of these samples once each quarter for the entire permit term.
B. WQBEL/Water Quality Standards, Part I.I.3
Discharges authorized under this permit must be controlled as necessary to meet applicable water
quality standards.
Page 2 of 2
Stormwater Reporting Requirements
ICIS Code Description Due date Frequency
00308
The permittee shall submit an annual report to
the division for the reporting period January 1
through December 31.
February 28 Annual
Certification issued: 2025-12-18 Effective: 2025-12-18 Expiration Date: 2021-12-31
The general permit COG500000 expired 12/31/2021 and is administratively continued. This certification is
also administratively continued. It will remain in effect until the general permit is renewed or other actions
are taken.
This certification under the permit requires that specific actions be performed at designated times. The
certification holder is legally obligated to comply with all terms and conditions of the permit.
Approved by
Emily Mortazavi
Permits Unit 3 Work Group Leader
Water Quality Control Division