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BJU N23-496 Central Delivery Point
Impact Analysis Narrative
Article 4 Section 203.G.
DENVER CORPORATE OFFICE
1001 17th Street, Suite 1600,
Denver, CO 80202
PARACHUTE FIELD OFFICE
143 Diamond Ave.
Parachute, CO 81635
BJU N23-496 Central Delivery Point
Article 4 Section 203.G.
Impact Analysis Narrative
Administrative Review Caerus Piceance LLC Garfield County, Colorado 2 | Page 1001 17th Street, Suite 1600 2022 Denver, CO 80202
1.0) Introduction The following section addresses the requirements for the Impact Analysis under Article 4 Section 203.G. of the Garfield County Land Use and Development Code (LUDC).
1.1) Required Exhibits
The Impact Analysis shall provide a description of the impacts that this proposed land use change may cause, based upon the standards that the proposed use must satisfy. The application includes exhibits and descriptions of how Caerus Operating LLC (Caerus) will ensure that impacts will be mitigated, and standards will be satisfied in the development of the BJU N23-496 Central Delivery Point (N23 CDP).
2.0) 4-203 (G) 1. Adjacent Land Use
Existing use of adjacent property and neighboring properties within 1,500-foot radius. Existing use of adjacent property and neighboring properties are natural resources extraction, public lands, and agricultural. Adjacent parcels are zoned resource lands or public lands. No additional impact would occur to the abutting property owners from grading activities and/or operation of the N23 CDP. The proposed site is located on a 9,333-acre parcel.
2.1) 4-203 (G) 2. Site Features
A description of site features such as streams, areas subject to flooding, lakes, high ground
water areas, topography, vegetative cover, climatology, and other features that may aid in the
evaluation of the proposed development. The N23 CDP is located on the Roan Plateau. The proposed CDP would be located on a ridgetop east of the East Fork of Stewart Gulch. The ridgetop is divided by ephemeral drainages that typically drain west into the East Fork of Stewart Gulch or east into an unnamed tributary.). Terrain in the general vicinity is composed of rolling ridges divided by draws and drainages that flow north toward Piceance Creek. The proposed project would be located in an area composed primarily of sagebrush shrublands with an understory of native forbs and grasses. Aspen woodlands, mountain shrublands, and oakbrush shrublands are present along the side slopes and draws surrounding the project area. WestWater Engineering (WestWater)conducted a biological survey of the location. The Biological Survey Report, detailing plant, wildlife and wetlands surveys, is provided in the Impact Analysis tab. WestWater biologists surveyed the project area for aquatic resources including springs, seeps, wetlands and waters of the U.S. crossings that would fall under the jurisdiction of the
BJU N23-496 Central Delivery Point
Article 4 Section 203.G.
Impact Analysis Narrative
Administrative Review Caerus Piceance LLC Garfield County, Colorado 3 | Page 1001 17th Street, Suite 1600 2022 Denver, CO 80202
U.S. Army Corps of Engineers in conjunction with other surveys that were conducted for this report. No waters of the U.S features were observed by WestWater. The average annual precipitation for the area is approximately 16.45 inches a year. This data was collected from the Western Regional Weather Center at the Altenbern Colorado weather station, which is located west of the proposed site location. Precipitation data was collected from 1947 to 2016.
Table 1: Monthly Precipitation Average JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC Annual Average Annual Precipitation Average (Inches) 1.29 1.23 1.42 1.45 1.5 0.95 1.24 1.61 1.54 1.62 1.3 1.3 16.45
Evaporation rates were not collected at the Altenbern weather station. An evaporation rate approximately 40-45 inches a year was estimated using Map 3 of the “NOAA Technical Report NWS: Evaporation Atlas for the Contiguous 48 Unites States”. Weather Data Resources:
• NOAA Climatological Data Annual Summary: Colorado 2018, Volume 123 Number 13, ISSN 0145-0506.
• NOAA Technical Report NWS 33: Evaporation Atlas for the Contiguous 48 United States; Washington, D.C., June 1982.
• NOAA Technical Report NWS 34: Mean Monthly, Seasonal, and Annual Pan Evaporation for the United States; Washington, D.C., June 1982.
• ALTENBERN, COLORADO Period of Record Monthly Climate Summary; Western Regional Weather Center (Impact Analysis tab) There are no streams, areas subject to flooding, high ground water areas, and lakes within the perimeter of the site. No intermittent or perennial streams exists within 1,000 feet radius of the site perimeter. The only downgradient surface water feature within 1,000 foot radius of the project area is a drainage (ephemeral stream) 900 feet to the east. Stormwater and drainage control features were installed at the N23 CDP to mitigated potential surface run-off. The Surface Hydrology Map is located in the Grading and Drainage Plan tab.
2.2) Section 4-203 (G) 3. Soil Characteristics
A description of soil characteristics of the site that have a significant influence on the
proposed use of the land.
BJU N23-496 Central Delivery Point
Article 4 Section 203.G.
Impact Analysis Narrative
Administrative Review Caerus Piceance LLC Garfield County, Colorado 4 | Page 1001 17th Street, Suite 1600 2022 Denver, CO 80202
A soils report from the Natural Resource Conservation Service (NRCS) indicates that within the area of disturbance three soil types are present. NRCS Soils Report is provided in the Impact Analysis tab.
Table 2: Map Units Present within BJU N23-496 CDP Perimeter
Map
Unit Soil Type Percent
Slope
Description 38 Irigul-Starman channery loams 5 to 50 Percent Slopes Occurs on ridges and mountain sides from 7,800 to 9,000 feet. Parent material is marl and/or residuum weathered from sandstone. Not Prime Farmland 53 Parachute-Rhone loams 5 to 30 Percent Slopes Occurs on mountains slopes at an elevation of 7,600 to 8,600 feet. Parent material is colluvium over residuum weathered from sandstone and shale. Not Prime Farmland. 61 Rhone loam 30 to 70 Percent Slopes Occurs on ridges and mountain sides from 7,600 to 8,600 feet. Parent material is marl and/or residuum weathered from sandstone. Not Prime Farmland
Table 3: Profile of Soil Types Present
Map
Unit
Soil
Composition Typical Profile
38
Irigul (55%) H1 – 0 to 6 inches: channery
loam H2 -6 to 17 inches:
extremely channery sandy
clay loam H3 - 17 to 21 inches:
unweathered bedrock Starman (30%) H1 - 0 to 3 inches: channery
loam H2 - 3 to 13 inches: very
channery loam, extremely
channery loam H2 - 3 to 13 inches:
unweathered bedrock
53
Parachute (55 %) A - 0 to 5 inches: loam Bw1 - 5 to 18 inches: loam Bw2 - 18 to 29 inches:
extremely cobbly loam R - 29 to 59 inches: bedrock
Rhone (30%) A1 - 0 to 8 inches:
loam A2 - 8 to 28 inches: sandy
clay loam
C - 28 to 52 inches: very
channery sandy clay loam R - 52 to 60 inches: bedrock
Irigul (15%) A1 - 0 to 6 inches:
channery loam A2 - 6 to 13 inches: very
channery loam R - 13 to 60 inches: bedrock
61
Rhone (85%) H1 - 0 to 8 inches:
loam H2 - 8 to 28 inches: sandy
clay loam H3 - 28 to 52 inches: very
channery sandy clay loam H4 - 52 to 56 inches:
unweathered bedrock
2.3) Section 4-203 (G) 4. Geology and Hazard
A description of the geologic characteristics of the area including any potential natural or
manmade hazards, and a determination of what effect such factors would have on the
proposed use of the land.
BJU N23-496 Central Delivery Point
Article 4 Section 203.G.
Impact Analysis Narrative
Administrative Review Caerus Piceance LLC Garfield County, Colorado 5 | Page 1001 17th Street, Suite 1600 2022 Denver, CO 80202
The Geologic Hazards Assessment report, prepared by a P.G. at Entrada Consulting Group, INC., determined landslides, rockfall, collapsible soils, and avalanches are not a hazard at the location. The Geologic Hazards Assessment and site photos are located in the Impact Analysis tab.
2.4) Section 4-203 (G) 6. Environmental Impacts
Determination of the existing environmental conditions on the parcel to be developed and the
effects of development on those conditions.
WestWater Engineering, Inc. (WaterWater) conducted a Biological Survey Report and a Raptor Survey Report for the N23 CDP. Both reports are located in the Impact Analysis tab.
a. Determination of the long-term and short-term effect on flora and fauna;
WestWater concluded that no special status species (SSS) of plants were observed during field surveys. Plant species listed by the White River Field Office generally are confined to lower elevations or soil types that are not within the project area. Based on soil types and field survey, no SSS would be affected by the project. WestWater recommended the application of a weed management plan for this project site is recommended to: 1) prevent the invasion and expanded range of noxious weeds; and 2) promote the establishment of desirable plant life upon rehabilitation of the proposed CDP site.
WestWater developed an integrated vegetation and noxious weed management plan for the N23-697 Pipeline. Areas surveyed included the general area surrounding the N23 CDP. The N23-697 will connect the production facilities to the proposed N23 CDP. WestWater stated it was appropriate to utilize the N23-697 Pipeline Integrated Vegetation and Noxious Weed Management Plan in conjunction with Caerus’s Weed Management Plan for the Piceance Basin. Both plans are provided in the Maps and Plans tab.
b. Determination of the effect on designated environmental resources, including critical
wildlife habitat
WestWater conducted raptor surveys on May 15, 2021, within a 0.25 miles buffer of the project area. No raptor nests were observed in the area. The project footprint falls within a Greater Sage-grouse (GrSG) priority habitat management area on the edge of general habitat management area no use by Greater Sage-grouse was documented in the project area during surveys. WestWater recommended that Caerus adhere to the Best Management Practices (BMPs) outlined in their Wildlife Mitigation Plan for the North Parachute Ranch for sage-grouse. The subject parcel is managed by the CPW approved North Parachute Ranch Wildlife
BJU N23-496 Central Delivery Point
Article 4 Section 203.G.
Impact Analysis Narrative
Administrative Review Caerus Piceance LLC Garfield County, Colorado 6 | Page 1001 17th Street, Suite 1600 2022 Denver, CO 80202
Mitigation Plan. The proposed site location is within a CPW-mapped Greater Sage-grouse (GrSG) priority habitat management area on the edge of general habitat management area. In addition to adhering to wildlife BMPs, Caerus has agreed to wildlife timeframe stipulations for construction set forth by the CPW, COGCC, and BLM to mitigate impacts. Caerus will adhere to the following BMPs:
Best Management Practices for Greater Sage Grouse: • Caerus will complete pad construction, drilling and completion prep construction, and interim/final reclamation activities between July 15 and December 15, avoiding the greater sage grouse wintering, breeding, and nesting periods of December 15 to July 15. • Caerus has agreed to avoid development along the top of Barnes Ridge, an important resource for the greater sage grouse population. • Caerus will continue to provide access to CPW research personnel for ongoing greater sage grouse population research on the North Parachute Ranch (NPR) and other operator-owned property. • Caerus has completed 218 acres of brush mitigation approved by CPW and BLM for compensatory mitigation for direct and indirect impacts for six well pads and the N23 496 CDP. • Caerus utilizes 3-Phase gathering from wells to reduce truck traffic and to reduce footprint of well pads and allow more area to be interim reclaimed. •Remote monitoring and control to reduce truck traffic and reduce spills. •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 raptors or ravens. Perch deterrents need not be installed if they pose a safety issue (e.g., on the handrails of a tank battery). Caerus completed grading of the pad prior to December 15, 2021, to avoid the greater sage grouse wintering, breeding, and nesting periods of December 15 to July 15. The location of the proposed CDP is not located on top of the Barnes Ridge. The subject parcel is located within the North Parachute Ranch. Caerus is committed to engaging with CPW with concerns to the greater sage grouse.
c. Impacts on wildlife and domestic animals through creation of hazardous attractions,
alteration of existing native vegetation, blockade of migration routes, use patterns, or other
disruptions
The project is located outside of mule deer sensitive winter range, but the project is located within a CPW mapped elk production area. The proposed CDP is located on a parcel that is managed by the CPW approved North Parachute Ranch Wildlife Mitigation Plan. WestWater recommended that Caerus adhere to the Best Management Practices (BMPs) outlined in their Wildlife Mitigation Plan for the North Parachute Ranch for construction
BJU N23-496 Central Delivery Point
Article 4 Section 203.G.
Impact Analysis Narrative
Administrative Review Caerus Piceance LLC Garfield County, Colorado 7 | Page 1001 17th Street, Suite 1600 2022 Denver, CO 80202
activities occurring within big game elk production areas. Caerus will adhere to the following BMPs:
Best Management Practices for Elk: • Caerus will place multiple gathering lines into a single trench to minimize disturbance and construction; and will install escape trench ramps to allow wildlife or livestock to exit the trench. • Caerus will continue to provide access to CPW research personnel for ongoing mule deer and predator research on the North Parachute Ranch and other operator-owned property. • Caerus utilizes 3-Phase gathering from wells to reduce truck traffic and to reduce footprint of well pads and allow more area to be interim reclaimed. •Remote monitoring and control to reduce truck traffic and reduce spills. Caerus completed grading activities prior to December 15, 2021, to adhere to the timing stipulations as stated in the Elk. Pipelines associated with the proposed CDP were installed in a single trench to minimize disturbance. The proposed CDP does not conflict with the BMP requiring Caerus to maintain open space (no permanent surface structures) on 20 acres of the Parachute Creek property. Caerus is committed to engaging with CPW with concerns to elk within the North Parachute Ranch operations area.
d. Evaluation of any potential radiation hazard that may have been identified by the State or
County Health Departments.
The Geologic Hazards Assessment report, prepared by a P.G. at Entrada Consulting Group, Inc., concluded that no radiation hazard has been identified by the State or County Health Departments. The Geologic Hazards Assessment (Impact Analysis tab) states radioactive minerals are not anticipated in the geologic section exposed at the site location.
2.5) Section 4-203 (G) 7. Nuisance
Impacts on adjacent land from generation of vapor, dust, smoke, noise, glare or vibration, or
other emanations. Nuisance from noise, lighting, and dust is not anticipated. Smoke, vibration, and vapor is not expected to occur as a result of operations at the proposed facility. The N23 CDP is not located within one mile of any residential buildings units or designated outdoor areas. The nearest parcel boundary is 5369 feet from the proposed facility.
Lighting Lighting will be installed at the N23 CDP. All lighting will be down casted and inward towards the equipment. No lighting or utilities will be installed at the proposed site. All
BJU N23-496 Central Delivery Point
Article 4 Section 203.G.
Impact Analysis Narrative
Administrative Review Caerus Piceance LLC Garfield County, Colorado 8 | Page 1001 17th Street, Suite 1600 2022 Denver, CO 80202
lighting will adhere to the Lighting Standards stated in Article 7 of the Garfield County LUDC.
Noise Nuisance from noise is not anticipated at the site. The N23 CDP is not located within one mile of any residential buildings units or designated outdoor areas. The nearest parcel boundary is 5369 feet from the proposed facility. Noise generated at the site will be similar to other oil and gas activities in the area. Generators or noise generating equipment will not be installed or operated at the site.
Dust Caerus implements fugitive dust controls throughout the North Parachute operations area. Employees are trained to identify conditions and operate to minimize fugitive dust emissions. In order to prevent fugitive dust Caerus has incorporated several practices. Appropriate speed limits have been designated for vehicles on unpaved roadways. Restriction of land disturbance construction activity during high-wind days are also enforced. Field employees will notify operations if dust is observed. Water trucks are utilized to wet roadways, as needed, when natural moisture is insufficient to prevent airborne dust. Water trucks apply magnesium chloride or fresh water to roadways depending on location. Caerus’s access roads are treated with fresh water and/or magnesium chloride to reduce dust emissions and will adhere to applicable COGCC dust mitigation standards and rules.
Traffic The site will be accessed by a private lease road currently owned and maintained by Caerus. The site is located on a 9,333-acre parcel, surrounding by public land and other resource lands parcels. The N23 CDP is not visible from any public road. Currently, one structure (building) is proposed to be installed at the site. The total maximum trips generated on public roads the N23 CDP will be approximately 774 vehicles. The total of average trips generated over the lifespan of the N23 CDP facility is not an appropriate measure of traffic patterns since a majority of vehicular trips will occur during initial operations (40 days for construction and interim reclamation) and the site will operate for approximately 30 years. Based on the background traffic calculations, Caerus’s N23 CDP related traffic will have an average of 0.1% increase on daily traffic activity during operations of the facility in 2022 on CR 215. Production and inspection activities are not anticipated to increase traffic on public roads. During production phase after facility operations are fully established, the site will be access 2-3 times a week. Production and inspection activities will be conducted by personnel performing similar activities at other facilities in the field; therefore, these trips
BJU N23-496 Central Delivery Point
Article 4 Section 203.G.
Impact Analysis Narrative
Administrative Review Caerus Piceance LLC Garfield County, Colorado 9 | Page 1001 17th Street, Suite 1600 2022 Denver, CO 80202
would currently be accounted for within the background traffic volume. The increase in average daily traffic during the site’s lifespan is not expected to be significant on roads generally used by the public. CR 215 will see only an increase in traffic during the initial development in 2022. Long-term traffic impacts are not anticipated from the development of the N23 CDP.
2.6) Section 4-203 (G) 8. Hours of Operation.
The Applicant shall submit information on the hours operation of the proposed use.
The N23 CDP will not have personnel staffed at the site on a regular continuous basis with personnel only accessing the site 2-3 times a week after operations of facility are fully established. Personnel will be present Monday through Friday during the construction of the facility, which will last approximately 30 days. For the production phase of operations, the facility will have minimal personnel present accessing the facility for inspections and maintenance. The site is not located with a one-mile radius to any residential building units or parcel boundary line. Adjacent parcels are zoned Resource Lands or Public Lands zone district in Garfield County and Agricultural in Rio Blanco County. Adjacent parcel land uses include natural resource activities, limited agricultural, and public lands.