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6.05 Roadway Waiver Narrative
Caerus’s North Parachute Operations Areas Access Roads Waiver Request Policy 01-14 Waiver for Roads and Demonstration of Compliance Garfield County Roadway and Design Standards Article 7 Section 107 Access and Roadways North Parachute Operations Area Access Roads Article 7 Section 107 Roadway and Design Standards Narrative Administrative Review Caerus Piceance LLC Garfield County, Colorado 1001 17th Street, Suite 1600 2022 Denver, CO 80202 In accordance with Policy 01-14 Waiver for Roads and Demonstration of Compliance, Caerus requests a waiver for the Roadway and Design Standards, Section 7-107 of the Garfield County Land Use and Development Code for Caerus’s existing private access roads, hereby referred to as the network of existing North Parachute operations area access roads. Like many of the historical roadways in Garfield County, Caerus’s private access and roadways were established prior to the Garfield County’s roadway standards. Caerus’s roadways are maintained to provide safe access to sites and are inspected for stormwater compliance. Roadways were designed for oil and gas transportation vehicles and equipment. These roads are not intended for or allow public access. Caerus’s enforces reduced vehicular speeds and specific safety driving measures. All private roadways located on Caerus owned parcels are maintained by Caerus and its contractors to achieve optimal safety, including speed restrictions (25 M.P.H.), regular road maintenance, dust controls, stormwater BMPs, erosion control features, and snow maintenance. The roadway is composed of three sections: Colony Road, Divide Road, and the N23 CDP Access Road. The N23 CDP is located within Caerus’s North Parachute operations area. The site is located approximately 7 miles from the public road, County Road 215. To access the site, vehicles will travel on Caerus’s privately owned and maintained network of existing access roads. These existing private roadways are safe and adequate for oil and gas associated vehicular access. The following Waiver Request addresses Policy 01-14 Waiver for Roads and Demonstration of Compliance and Access and Roadways Standards under Article 7, Division 1 of the Garfield County Land Use and Development Code for the North Parachute operations area access roads (see Access Road Map) route to the N23 CDP. A Professional Engineer (P.E.) from KLJ assessed the private roadways and determined that the roadways are safe and adequate for the proposed and current industrial traffic. The P.E. Assessment Letter (Policy 01-14), which includes photos and cross sections, compares the existing roadways to Table 7-107 Roadway Standards. Caerus’s North Parachute Operations Area Access Roads Waiver Request includes: 1. P.E. Assessment Letter – Policy 01-14 Waiver for Roads and Demonstration of Compliance 2. Roadway Standards Narrative - Roadway and Design Standards, Section 7-107 1601 Riverfront Drive, Suite 204 Grand Junction, CO 81501 (970) 450‐7476 KLJENG.COM January 25, 2022 Jason Eckman Surface Regulatory Lead Caerus Operation, LLC 143 Diamond Ave. Parachute, CO 81635 Re: Policy 04‐01 Waivers for Roads and Demonstration of Compliance Dear Jason: The purpose of this letter is to address Garfield County’s Policy 01‐14 Waivers for Roads and Demonstration of Compliance for the access to Caerus’s proposed N23 CDP Pad. This letter covers the private access roads required to reach the N23 CDP Pad. These private roads start at the Access Control Gate located at the north end of County Road 215 and go through approximately 7 miles of private roads on various private parcels owned by Caerus Piceance LLC. These private roads have controlled access points (via electronic card reading gates) located at the end of County Road 215 and at the upper (north) end of the Colony Road. The posted speed limit is 25 mph and is strictly enforced. Those who violate traffic rules (including speed limits) can be removed from the site and banned from returning (typically resulting in employment termination). Accordingly, traffic violations are rare on these roads. These roads are private low speed access roads that serve the Oil and Gas Industry and are not intended to be public roads or highways. Nearly all of these roads were constructed prior to Policy 01‐14. The roads that were constructed after were constructed as per standard oil & gas road practice (i.e., BLM Gold Book). Over time these private roads have been improved by Exxon Mobil Corporation, Encana, Chevron, ConocoPhillips, Caerus, and others to provide better and safer service and access to the Oil and Gas Industry. These improvements have included widening, surface treatment, alignment adjustment (e.g., placement of switch backs to decrease vertical grades), and drainage improvements. These roads are in challenging hilly terrain which require significant cuts and fills, switchbacks, and portions of road with steep grades. However, these features have been implemented and constructed such that the functionality and safety of the road are acceptable given the low speeds, low traffic volumes, and types of vehicle using the road. Garfield County Policy 01‐14 requests a description of how said road does not meet the design standards in Table 7‐107 and a map of the road. Table 7‐107 of the Garfield County Land Use and Development Code provides design standards for various types of public roads (i.e., Collectors, Secondary and Rural Access, Semi‐Private, Primitive/Driveway, and Public Land Access). It is my professional opinion that the access roadways to the N23 CDP Pad do not “fit” into any of the generic road categories in Table 7‐107. More suitable design standards (and the guidelines that are typically used for design of said roads) can be found in guidance documents such as the BLM “Gold Book” which details surface operating standards and guidelines for oil and gas exploration and development. However, for the purpose of this exercise the column for a Garfield County “semi‐primitive” roadway was retained for comparison purposes. This does not imply that “semi primitive” design standards apply to this road. They are included for reference purposes only as per the Policy 01‐14 guidance documents. Maps showing the access roads in plan view are attached to this letter. Observations were taken along Colony Road and Divide Road on May 14, 2014 and re‐confirmed on January 20, 2022. The N23 CDP Road was observed on January 20, 2022. Map level survey data was collected along the road to assist with the generation of the maps attached to this letter. The cross‐ sectional geometry data was collected at locations that were representative of the road and at critical sections/locations. The cross‐section data collected consisted of analysis of available survey data and where data was not readily available a measuring tape, hand level, and inclinometer were used. No obvious safety issues or obvious signs of structural failure of the road were observed on any portion of road during any of the site visits. These private roads are maintained by Caerus, who uses various contractors to maintain and improve the roads on their property. Regular maintenance operations include, but are not limited to: • Grading to remove washboard; re‐establish crown, cross slope, & drainage; maintain ditches; and remove low spots that collect water. • Watering to help with dust control and maintain road material compaction within an optimal density range. • Magnesium Chloride Treatment helps bond the road material and creates a more durable surface. This treatment helps with dust control, reduces sediment transport from the road surface, and reduces the need for other maintenance activities such as grading. Traffic counts on these roads vary significantly depending on the activities taking place within this area (e.g., drilling operations). The traffic count numbers at the Main and Upper Gates range between 20‐100 ADT. The Upper Gate numbers are less because this area serves a much smaller area and far fewer vehicles. The Main Gate provides access to a much larger area that includes many other private roads. The distribution of traffic from the Upper Gate is a three‐way split. The direction of the traffic varies depending on the location of active projects. Regardless, the actual traffic count numbers on any of the upper roads will be less than the count at the Upper Gate. Common vehicle types include pickups, water trucks, and construction equipment. These roads are also used for rig moves and to transport equipment. Larger equipment and transports have escort vehicles to warn drivers and assist with navigation. Based on historical use of this route the horizontal and vertical elements of the road are adequate for all vehicles using the road (including the large rig moving and similar sized vehicles). Non‐ construction traffic on the actual N23 CDP Pad access spur road will be just a small fraction of the overall traffic. Descriptions of the various sections of the access roads to the N23 CDP Pad are described below. Colony Road Colony Road (aka the Middle Fork Road) starts at the end of County Road 215 and continues in a northerly direction to Divide Road. There is a main access control gate at the end of County Road 215 and at the start of Colony Road. This road is entirely on property owned by Caerus Piceance LLC and the roadway is maintained by Caerus by their contractors. The original primary purpose of this road when it was constructed in the 1980s was to facilitate the construction and operation of the Colony Mine Project. The road has served as an access corridor for the oil and gas industry since its construction in the 1980s. The current routing of the road strikes a balance between horizontal curvature, vertical grade, and cut/fill. This section of road has served oil and gas operations for 40 plus years. Divide Road Divide Road Runs across the top of the predominate east to west ridge within the Piceance basin. The ridgeline serves as the topographic “divide” between the Parachute Creek and Piceance Creek. This road was originally a public access “two‐track” road that came from the north. Starting in the 1980s this road has been continually improved to better suit oil and gas development and operations. The Divide Road has served oil and gas operations for the past 30 plus years. N23 CDP Pad Access Road Access to the N23 CDP spurs north off the Divide Road and follows a “finger ridge” to the north. This road consists of a portion of road installed to an existing pad and new road constructed to the newly constructed N23 CDP Pad. This section of road is the most recent in terms of construction and appears to have been constructed as per BLM Gold Book Standards. As such this road is adequate for the purpose of facilitating access to and from the N23 CDP Pad. This spur road will be maintained under the direction of Caerus by the same Contractors who maintain Colony and Divide Roads. In conclusion, the proposed route from the end of County Road 215 to the N23 CDP Pad has been adequately constructed for the anticipated traffic and vehicles associated with construction of these pads. Caerus, like their predecessors, have done a good job maintaining and improving their private roads. Accordingly, it is anticipated that these private roads are adequate for the long‐term operation and maintenance of the facilities and equipment on the pads. These roads are adequate to allow emergency vehicles to reach the pad should the need ever arise. This letter does not express or imply any warranty as to the remaining life of the road, the absence of non‐obvious geotechnical or structural issues, or that the road will meet the needs for future uses or users. These roads are under constant maintenance and are graded when conditions warrant. The cross‐ section data presented may change over time as grading operations may modify the cross slope, or even road width. However, it is not anticipated the basic horizontal and vertical geometry will change significantly as a result of the maintenance operations. Please let us know if you have any additional questions, comments, or concerns. Sincerely, KLJ Marc Kenney, P.E. Senior Engineer Attachments: Road Geometry Tables and Road Plan and Profile Sheets Project #: 2107‐00252.16 cc: N/A Geometry of Road The following table compares this access road to the Garfield County Roadway Standards found in Table 7‐107 of the Land Use and Development Code for Primitive Roadways and Driveways. Table 7‐107: Roadway Standards Design Standards Garfield County Semi Primitive X‐Section A X‐Section B X‐Section C X‐Section D X‐Section E X‐Section F Design Capacity (ADT) 20‐100 N/A N/A N/A N/A N/A N/A Minimum ROW Width (Feet) 40 N/A N/A N/A N/A N/A N/A Lane Width (Feet) 8 14.75 10.75 12 19 12.5 19.5 Shoulder Width (Feet) 2 (Note 1) (Note 1) (Note 1) (Note 1) (Note 1) (Note 1) Ditch Width (Feet) 4 N/A N/A N/A N/A N/A N/A Section Type Not Specified Crown Crown Crown Crown Inslope Crown Cross Slope RT 3% ‐ Gravel ‐2.4 ‐6.0 ‐3.3 ‐4.2 1.4 ‐2.6 Cross Slope LT 3% ‐ Gravel ‐4.1 ‐3.7 ‐1.3 ‐2.6 ‐1.4 ‐2.8 Shoulder Slope 5% (Note 1) (Note 1) (Note 1) (Note 1) (Note 1) (Note 1) Design Speed N/A N/A N/A N/A N/A N/A N/A Minimum Radius (Feet) 50 250 500 300 185 185 150 Maximum % Grade 12 4 7 9 9 10 10 Surface Gravel Gravel Gravel Gravel Gravel Gravel Gravel Notes: 1) Shoulder width and slope are included in the lane width and slope. 2) The road surface width is two times the lane width. Geometry of Road The following table compares this access road to the Garfield County Roadway Standards found in Table 7‐107 of the Land Use and Development Code for Primitive Roadways and Driveways. Table 7‐107: Roadway Standards Design Standards Garfield County Semi Primitive X‐Section G X‐Section H X‐Section I X‐Section J Design Capacity (ADT) 20‐100 N/A N/A N/A N/A Minimum ROW Width (Feet) 40 N/A N/A N/A N/A Lane Width (Feet) 8 17 12 14 9 Shoulder Width (Feet) 2 (Note 1) (Note 1) (Note 1) (Note 1) Ditch Width (Feet) 4 N/A N/A N/A N/A Section Type Not Specified Crown Crown Crown Inslope Cross Slope RT 3% ‐ Gravel ‐2.4 ‐3.3 ‐2.4 2.5 Cross Slope LT 3% ‐ Gravel ‐2.6 ‐1.7 ‐3.1 ‐2.5 Shoulder Slope 5% (Note 1) (Note 1) (Note 1) (Note 1) Design Speed N/A N/A N/A N/A N/A Minimum Radius (Feet) 50 150 200 150 75 Maximum % Grade 12% 4 11 4 9 Surface Gravel Gravel Gravel Gravel Gravel Notes: 1) Shoulder width and slope are included in the lane width and slope. 2) The road surface width is two times the lane width. CROSS SECTION:BSTATION: 105+67LAT: N039° 36' 07"LONG: W108° 06' 18"CROSS SECTION: ASTATION: 27+79LAT: N039° 34' 55"LONG: W108° 06' 45"CROSS SECTION:CSTATION: 153+34LAT: N039° 36' 51"LONG: W108° 06' 27"CROSS SECTION:DSTATION: 187+88LAT: N039° 37' 08"LONG: W108° 06' 29"CROSS SECTION:ESTATION: 222+82LAT: N039° 37' 18"LONG: W108° 06' 29"CROSS SECTION:FSTATION: 283+00LAT: N039° 37' 50"LONG: W108° 06' 10"COLONY ROADCAERUS OIL & GAS, LLC© KLJ 2022 CROSS SECTION:GSTATION: 340+00LAT: N039° 37' 54"LONG: W108° 06' 53"CROSS SECTION:HSTATION: 508+22LAT: N039° 40' 20"LONG: W108° 07' 26"COLONY ROADCAERUS OIL & GAS, LLC© KLJ 2022 CROSS SECTION: JSTATION: 22+70LAT: N039° 40' 37"LONG: W108° 08' 22"CROSS SECTION: ISTATION: 26+40LAT: N039° 40' 20"LONG: W108° 07' 38"DIVIDE ROAD AND N23 CDP PAD ACCESSCAERUS OIL & GAS, LLC© KLJ 2022 Profile View of Colony RoadCAERUS OIL & GAS, LLC© KLJ 2022 Profile View of N23 CDP Pad Access RoadProfile View of portion of Divide RoadCAERUS OIL & GAS, LLC© KLJ 2022 North Parachute Operations Area Access Roads Article 7 Section 107 Roadway and Design Standards Narrative Administrative Review Caerus Piceance LLC Garfield County, Colorado 1001 17th Street, Suite 1600 2022 Denver, CO 80202 Caerus’s North Parachute Operations Areas Access Roads Caerus is requesting a waiver to Standard 7-107. Access and Roadways. Caerus’s roadways are maintained to provide safe access to sites and are inspected for stormwater compliance. Roadways were designed for oil and gas transportation vehicles and equipment. These roads are not intended for or allow public access. Caerus enforces reduced vehicular speeds (25 M.P.H. on Caerus property) and specific safety driving measures. All roads located on the subject parcel are maintained by Caerus and/or a contracted company to achieve optimal safety, including speed restrictions (25 M.P.H. on Caerus property), regular road maintenance, dust controls, and snow maintenance. The roadway is composed of three sections: Colony Road, Divide Road, and the N23 CDP Access Road. The N23 CDP is located within Caerus’s North Parachute oil and gas operations area. The site is located approximately 7 miles from County Road 215. To access the site, vehicles will travel on Caerus’s privately owned and maintained access roads. Road Location Caerus’s private access road begins at the intersection of County Road 215 and North Parachute operation areas’ guard shack and security gate and continues north to the proposed N23 CDP facility. The entire route from the parcel entrance to the proposed facility is zoned Resource Lands. The private access road begins in the valley floor (Resource Lands – Gentle Slopes and Lower Valley Floor (RLGS)) and gradually increases in elevation through the Resource Lands – Talus Slopes (RLTS) zone district, then Resource Lands – Escarpment (RLE) until reaching Resource Lands – Plateau (RLP). This roadway is typical of roads traversing the Talus and Escarpment Zones providing access to natural gas well pads and production facilities within the Plateau Zones located in Garfield County, Colorado. The private access road is located on five (5) Caerus owned parcels. Existing private roadways allow for Caerus vehicles to access numerous well pads and facilities located on private property owned by Caerus, reducing vehicular traffic on public roads. North Parachute Operations Area Access Roads Article 7 Section 107 Roadway and Design Standards Narrative Administrative Review Caerus Piceance LLC Garfield County, Colorado 1001 17th Street, Suite 1600 2022 Denver, CO 80202 Caerus Owned Parcels – Existing Private Access Road Route to BJU N23-496 CDP Parcel Number Parcel Acres Township and Range Zone District Sub-Zone District – Route Access Road 217104100021 958 T5S, R96W Resource Lands RLGS 213527300015 26,442 Intertwines the border of T5S, R96W and T5S, R95W Resource Lands RLGS 213308400006 8,553 Intertwines the border of T5S, R96W and T5S, R95W Resource Lands RLGS, RLTS, RLE 213501200013 320 T5S, R96W Resource Lands RLP 191727400012 9,332 T4S, R96W Resource Lands RLP Caerus’s existing network of access roads were designed to allow safe access throughout the North Parachute operations area. These roads were designed to facilitate oil and gas vehicular traffic and were not designed and constructed for public access. Caerus prevents public access to private roads with security features, including. Only authorized personnel and contractors may access the existing network of North Parachute operations area private roads. Safety/Structural Issues and Maintenance Existing access roads have been designed to provide access for drilling and completions equipment, large transportation vehicles, and daily access for the oil and gas industry. These roadways are not intended for public use and Caerus enforces restricted access. Road grades may be steep, and the travel rate is generally very slow. Caerus is committed to ongoing inspection and maintenance of any private roadways on Caerus’s owned property. Caerus’s currently contracts Moody Construction and Sons, Inc. of Loma, Colorado to perform road maintenance on private access roads with the North Parachute operations area. Caerus reviews road maintenance contracts annually. Travel Demand Caerus estimates that the travel demand falls within the Semi-Primitive roadway classification of 21-100 Average Daily Traffic (ADT). Operational activities such as pumpers visiting production phase well pads, inspections, and facility maintenance are daily activities. Pre-production and construction activities may result in increased traffic for short durations. Access roads within the North Parachute operations area facilitate vehicular access to numerous well pads and support facilities owned and operated by the Applicant. North Parachute Operations Area Access Roads Article 7 Section 107 Roadway and Design Standards Narrative Administrative Review Caerus Piceance LLC Garfield County, Colorado 1001 17th Street, Suite 1600 2022 Denver, CO 80202 Article 7 Section 107 Roadway and Design Standards Narrative 7-107. A. Access to Public Right-of-Way. All lots and parcels shall have legal and physical access to a public right-of-way. The proposed site has legal access from an existing network of private roads which is accessed by County Road 215 and/or County Road 401. The site will use the adjacent existing private access road maintained and owned by the Applicant. The Access Road Map, detailing the access route, is provided with this waiver request. Caerus’s North Parachute operations area consists of several adjacent parcels owned by the Applicant, Caerus. North Parachute operations area access roads are a network of existing private access roads that connect and are constructed on several Caerus owned parcels. 7-107. B. Safe Access. Access to and from the use shall be safe and in conformance with applicable County, State, and Federal access regulations. Where the Land Use Change causes warrant(s)for improvements to State or Federal highways or County Roads, the developer shall be responsible for paying for those improvements. Caerus’s existing network of access roads were designed to allow safe access throughout the North Parachute operations area. These roads were designed to facilitate oil and gas vehicular traffic. These roadways were not designed and constructed for public access. Caerus prevents public access to private roads with security features, including a guard shack and security gate. Only authorized personnel and contractors may access the existing network of North Parachute operations area private roads. The proposed N23 CDP site does not warrant improvements to County Roads, State, or Federal Highways. All roads located on the subject parcel are maintained by Caerus (and its contractors) to achieve optimal safety, including speed restrictions (25 M.P.H. on Caerus property), regular road maintenance, and snow maintenance. 7-107. C. Adequate Capacity. Access serving the proposed use shall have the capacity to efficiently and safely service the additional traffic generated by the use. The use shall not cause traffic congestion or unsafe traffic conditions, impacts to the County, State, and Federal roadway system shall be mitigated through roadway improvements or impact fees, or both. The site will be accessed by a private lease road currently owned and maintained by Caerus, the Applicant. The site is located on a 9,333-acre parcel, surrounding by public land and other resource lands parcels. North Parachute Operations Area Access Roads Article 7 Section 107 Roadway and Design Standards Narrative Administrative Review Caerus Piceance LLC Garfield County, Colorado 1001 17th Street, Suite 1600 2022 Denver, CO 80202 The total maximum trips generated on public roads from 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 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. 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. 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 accessed 2-3 times a week. Production and inspection activities will be conducted by personnel performing similar activities at other Location in the operations area; therefore, these trips would currently be accounted for within the background traffic volumes. Long-term traffic impacts to public roads are not anticipated from the development of the N23 CDP. The N23 CDP will not impact capacity of private access roads maintained and owned by Caerus (Applicant and Parcel Owner). The network of private roadways in Caerus’s North Parachute operations area are maintained to be safe and adequate for current and future oil and gas associated traffic. The proposed N23 CDP will provide a centralized location for natural gas separation activities for three well pads rather than separation equipment being installed on each individual well pad location. This will reduce overall vehicular traffic on Caerus’s private access roads. 7-107. D. Road Dedications. All rights-of-way shall be dedicated to the public and so designated on the Final Plat. They will not, however, be accepted as County roads unless the BOCC specifically designates and accepts them as such. The proposed site is located on private land and is accessed by a private road owned by the Applicant. The site will not allow public access, nor is the site adjacent to any public right-of-way or public road. A right-of-way road dedication is not applicable to the site. 7-107. E. Impacts Mitigated. Impacts to County roads associated with hauling, truck traffic, and equipment use shall be mitigated through roadway improvements or impact fees, or both. Impacts to County roads are not anticipated. Expected trip generation rates discussed in the traffic summary are based on existing CDPs in the North Parachute operations area. Utilizing vehicular trip projections, the site will not result in an overall significant increase North Parachute Operations Area Access Roads Article 7 Section 107 Roadway and Design Standards Narrative Administrative Review Caerus Piceance LLC Garfield County, Colorado 1001 17th Street, Suite 1600 2022 Denver, CO 80202 to current traffic during the lifespan of the proposed facility. Average daily traffic will increase on CR 215 for 40 days in 2022. CR 215 will see only an increase in traffic during the initial development in 2022 (0.1% average increase for vehicles per day in 2022). 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 with the operations area; therefore, these trips would currently be accounted for within the background traffic volumes. Long-term traffic impacts are not anticipated from the development of the N23 CDP. 7-107. F. Design Standards. Roadways, surfaces, curbs and gutters, and sidewalks shall be provided as follows: Ongoing construction and maintenance activities are completed by Caerus’s construction contractors. Continuous maintenance of these roads ensures that Caerus provides safe and adequate access for employees and contractors utilizing private roads within the North Parachute operations area. Please refer to the P.E. Assessment Letter for comparative design details regarding Table 7-107. 7-107. F. 1. Circulation and Alignment. The road system shall provide adequate and efficient internal circulation within the development and provide reasonable access to public highways serving the development. Roads shall be designed so that alignments will join in a logical manner and combine with adjacent road systems to form a continuous route from 1 area to another. The site will be accessed from a private road owned and maintained by the Applicant. North Parachute operations area access roads were designed to provide efficient and safe access to the numerous oil and gas locations and facilities within Caerus’s operating field. Many of the access roads were previously constructed prior to Caerus ownership. The site-specific N23 CDP access road was designed and graded to allow adequate and efficient internal circulation for the construction of the CDP facility. 7-107. F. 2. Intersections. No more than 2 streets shall intersect at 1 point, with a minimum of 200 feet between off-set intersections, unless otherwise approved by the County. No more than 2 streets will intersect at 1 point. The site access and the private network of access roads, maintained by the Applicant/Surface Owner, will be the only streets at the subject intersection. 7-107. F. 3. Street Names. Street names shall be consistent with the names of existing streets in the same alignment. There shall be no duplication of street names in the County North Parachute Operations Area Access Roads Article 7 Section 107 Roadway and Design Standards Narrative Administrative Review Caerus Piceance LLC Garfield County, Colorado 1001 17th Street, Suite 1600 2022 Denver, CO 80202 A street name will not be given any of the existing North Parachute operations area access roads. North Parachute operations area access roads do not allow public access and are intended for oil and gas industrial traffic only. 7-107. F. 4. Congestion and Safety. The road system shall be designed to minimize road congestion and unsafe conditions. Existing private access roads were designed and are maintained to provided safe conditions and minimize road congestion. Only authorized personnel and contractors may access the network of existing private roads. By limiting access, Caerus can regulate vehicular traffic. The site has been designed to minimize road congestion and unsafe conditions. The site will be accessed from a private access road and not a county or public road. The site will not be accessed daily after construction and interim reclamation activities are completed. 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 would currently be accounted for within the background traffic volume. The Traffic Summary report is provided in the Impact Analysis tab. The site-specific N23 CDP access road was designed to facilitate construction and operations are the N23 CDP. The N23 CDP access road was constructed in 2021. Photograph of the current site-specific access road is located in the N23 CDP Roadway Waiver document. The constructed N23 CDP access road is graded and stabilized. North Parachute Operations Area Access Roads Article 7 Section 107 Roadway and Design Standards Narrative Administrative Review Caerus Piceance LLC Garfield County, Colorado 1001 17th Street, Suite 1600 2022 Denver, CO 80202 BJU N23-496 CDP Access Road 7-107. F. 5. Continuation of Roads and Dead-End Roads. Roads shall be arranged to provide for the continuation of major roads between adjacent properties when appropriate and necessary for traffic movement, effective fire protection, or efficient provision of utilities. The existing North Parachute operations area roadways connected the subject parcel owned by the Applicant to adjacent parcels owned by the Applicant. This reduces the need for oil and gas traffic to access public roads. The subject parcel is designated as Resource Lands zone district and the parcel not adjacent to populated area. The 9,333 subject parcel is located at the end of County Road 215. The existing private access roads do not impede the traffic movement on public roads, but in fact, reduce traffic on public roads. 7-107. F. 6. Relationship to Topography. Streets shall be designed to be compatible with the topography, creeks, wooded areas, and other natural features. Combinations of steep grades and curves should be avoided. When, due to topography, hazards or other design constraints, additional road width is necessary to provide for the public safety by cut and/or fill area, drainage area, or other road appurtenances along roadways, then dedication or right-of way in excess of the minimum standards set forth in this Code shall be required. Many of the access roads were previously constructed prior to Caerus ownership. The network of existing access roads is located on Caerus’s private property. Existing access roads have been assessed certified by a P.E. to provide safe and adequate access. North Parachute Operations Area Access Roads Article 7 Section 107 Roadway and Design Standards Narrative Administrative Review Caerus Piceance LLC Garfield County, Colorado 1001 17th Street, Suite 1600 2022 Denver, CO 80202 7-107. F. 7. Erosion and Drainage. The road system shall minimize erosion and provide for efficient and maintainable drainage structures. The private access roads have been designed to minimize erosion and have been constructed with drainage features. The existing access roads are maintained to minimize erosion including regular road maintenance, stormwater BMP installation and inspection, and snow removal. Operational phase 14-day stormwater inspections and post-precipitation stormwater inspections are conducted along the entire roadway to ensure the roadway is in good operational condition. Maintenance and construction items are completed based on the stormwater inspections conducted. Site access will minimize erosion and has been designed with drainage features throughout the site. The site has been designed with stormwater and drainage controls to be constructed on the site. Stormwater mitigations have been implemented in the overall design of the site. The drainage plan was designed to allow proper drainage for site features, including access road. The N23 CDP Site Plan and Stormwater BMPs Figures, detailing drainage features, are provided in the Grading and Drainage tab. 7-107. F. 8. Commercial and Industrial. The roads and access in commercial and industrial developments shall be designed to minimize conflict between vehicular and pedestrian traffic. The proposed industrial site will not create conflict between vehicular and pedestrian traffic. The site and access roads are located on private property and are operated and maintained by the Applicant. Roadways were designed to eliminate potential hazards to personnel and will allow safe and efficient flow for oil and gas vehicular traffic. 7-107. F. 9. Emergency Access and Egress. Roads shall be designed so as to provide emergency access and egress for residents, occupants, and emergency equipment. Emergency access shall comply with provisions of the International Fire Code and requirements of applicable emergency services, such as fire protection, ambulance, and law enforcement. The network of private roads have been designed to provide emergency access and egress for personnel and emergency equipment. Caerus’s Incident Response Plan is provided in the Maps and Plans tab. 7-107. F. 10. Traffic Control and Street Lighting. Traffic control devices, street signs, street lighting, striping, and pedestrian crosswalks are to be provided as required by the County Road and Bridge Department or other referral agencies. The existing access roads will not require traffic control devices or street lighting. The site is located on private property and is access by a private road operated and maintained by North Parachute Operations Area Access Roads Article 7 Section 107 Roadway and Design Standards Narrative Administrative Review Caerus Piceance LLC Garfield County, Colorado 1001 17th Street, Suite 1600 2022 Denver, CO 80202 the Applicant. The subject parcel is in the Resource Lands zone district and not a populated area. The 9,333-acre subject parcel is located at the end of County Road 215. 7-107. F. 11. Drainage Structures. 7-107. F. 12. Roadside Ditches. The private access roads have been designed to minimize erosion and have been constructed with drainage features throughout the North Parachute operations area. The existing access roads are maintained to minimize erosion including regular road maintenance, stormwater BMP installation and inspection, and snow removal. Operational phase 14-day stormwater inspections and post-precipitation stormwater inspections are conducted along the entire roadway to ensure the roadway is in good operational condition. Maintenance and construction items are completed based on the stormwater inspections conducted. Access roads are maintained in accordance with Caerus’s Oil and Gas Master Stormwater Management Plan: North Parachute Ranch (SWMP). Roadside ditches have been installed were deemed necessary to mitigated stormwater. The site has been designed with stormwater and drainage controls to be constructed on the site. The N23 CDP access road was designed and constructed to meet a 25-year, 34-hour storm event The site will not require ditches along access roads and stormwater mitigations have been implemented in the overall design of the site. The N23 CDP was designed to allow proper drainage for site features, including access roads. The N23 CDP Site Plan and Stormwater BMP Figure, detailing drainage features, are provided in the Grading and Drainage tab. North Parachute Operations Area Access Roads Article 7 Section 107 Roadway and Design Standards Narrative Administrative Review Caerus Piceance LLC Garfield County, Colorado 1001 17th Street, Suite 1600 2022 Denver, CO 80202 Best Management Practices Caerus has implemented the following Best Management Practices (BMPs) to aid in providing adequate and safe access. • Restricted access from public and only allowing authorized personnel to utilize the road • Speed limit signs (25 M.P.H. on Caerus property) are posted throughout the North Parachute operations area. • Switchback number signage to aid in roadway identification • Uphill traffic has the right of way. This aids in reducing the amount of congestion along the roadway and allows for more efficient passage during inclement weather or busy times of the day. • In most areas where steep slopes are adjacent to access roads, Caerus has installed barriers (including but not limited to, jersey barriers, K rails and berms) along the outside edge of the road to aid in safe passage. These sections of barriers are mainly installed through less visible, narrow, or steep sections of road. The entire road is not edged with barriers to allow for snow removal and blading operations to have adequate locations for snow and gravel storage. Barriers are also installed in some sections to allow stormwater to flow into sediment basins. • Caerus conducts 14-day stormwater inspections as well as post-precipitation inspections along access roads. Road and stormwater feature condition and document road maintenance issues needed for repair on a regular basis. • Caerus completes regular maintenance to include grading, snow removal, maintaining stormwater BMPs, and upgrading or improvements to the roadway identified during operation. • During dry periods and windy events, Caerus completes dust suppression using water and chemical suppressant (i.e. magnesium chloride) spreading to ensure safe visibility is not impaired during wind events.