HomeMy WebLinkAboutWildlife Mitigation Plan 08-26-21Caerus Piceance, LLC
Wildlife Mitigation Plan
August 2021
Prepared by:
Caerus Piceance, LLC
&
C-K Associates, LLC
In Cooperation with
Colorado Parks and Wildlife
Contributors
Lindsey Rider - Caerus Piceance, LLC
John Andrews - Caerus Piceance, LLC
Keith Nichols - CK Associates, LLC
Brian Reilly - CK Associates, LLC
Taylor Elm – Colorado Parks and Wildlife
Danielle Neumann – Colorado Parks and Wildlife
Table of Contents
Introduction and Signatory Page .................................................................................................................. 1
Wildlife Mitigation Plan Following the New January 15, 2021 Protection of Wildlife Resources 1200
Series ............................................................................................................................................................. 3
1201.b.(1)-(4) Wildlife Mitigation Plan ......................................................................................................... 3
(1) Pre-Application Consultation and Alternative Location Analysis ................................................. 3
(2) Description of Best Management Practices .................................................................................. 3
(3) Description of 1202.b Operating Requirements ........................................................................... 8
(4) Description of 1203 Mitigation Commitments to Offset Unavoidable Adverse Impacts to
Wildlife Resources ...................................................................................................................... 10
1203. Compensatory Mitigation for Wildlife Resources ............................................................ 10
Direct Impacts .................................................................................................................... 10
Indirect Impacts .................................................................................................................. 10
Caerus Mitigation Projects ................................................................................................. 11
List of Figures
Figure 1 Caerus Overall Management
Figure 2 Five Primary Migratory Corridors
List of Attachments
A. Record of Modification
B. Wildlife Resource Matrix
List of Appendices
A. Caerus Piceance LLC Development 1 – Compensatory Mitigation Plan Expanded Liberty Unit
(ELU) Development Plan
1
Caerus Piceance LLC
Wildlife Mitigation Plan
Introduction and Signatory Page
To meet the requirements of the new Colorado Oil and Gas Conservation Commission (COGCC) 1200
Series Rules (effective January 15, 2021), Caerus Piceance LLC (Caerus), has developed a revised North
Piceance Wildlife Mitigation Plan (WMP) that will cover operations by Caerus on Caerus’ North Parachute
Ranch property (NPR) and the properties owned by Caerus Cross Timbers LLC (previously owned by XTO),
and any additional asset(s) acquired in the future operated by Caerus. This WMP will address each of the
required elements listed within the COGCC 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. Caerus 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 by agreement of both CPW and Caerus. 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 COGCC
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 COGCC.
This WMP is intended to be an overarching document that will encompass future Caerus 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.
2
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:
Caerus Piceance, LLC
__________________________
Lindsey Rider Date
EHS Manager
Colorado Parks and Wildlife
__________________________
J.T. Romatzke Date
Northwest Region Manager
Expiration Date: 8/26/2024
Effective Date: 8/26/2021
8/26/20218/26/20248/26/21
3
Wildlife Mitigation Plan Following the New January 15, 2021 Protection of Wildlife Resources 1200
Series
The purposes of this WMP are to state that Caerus will adhere to Rule requirements under 1201.b.(1)-(4),
1202 and 1203.
CPW will consult with Caerus 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
Caerus 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. Caerus will continue to engage CPW in pre-
application consultation and alternative location analysis. As a proactive step, Caerus worked with
CPW to develop a Wildlife Resource Matrix that helps assess, avoid, minimize, and mitigate impacts
to wildlife. The wildlife matrix methodology is found in Attachment B. Project specific consultation
will be detailed in the compensatory mitigation plans, found within the Appendices.
(2) Description of Best Management Practices
The BMPs implemented by Caerus represents 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 Caerus to reduce disturbance. These BMPs
provide multiple natural resource benefits and promote adaptive management of the landscape (Caerus
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.
4
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 Caerus employees and contractors from carrying projectile weapons (including bows) on
Caerus property, except during company-organized events. (HW)
j) Prohibit pets on Caerus 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 the staging/storage yard at
the TLQ and the Caerus gravel pit (TS5 R96W section 34). (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 Caerus roads.
(WQ, HW)
n) Caerus has volunteered to be a member of One Future and The Environmental Partnership. These
voluntary programs require a commitment to reduce methane emissions. Caerus will report
reduction targets and annual metrics through the Caerus ESG Report. (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) Project Canary 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)
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)
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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 Caerus. (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)
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)
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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) Use the Wildlife Resources Matrix (Attachment B) and Caerus' wildlife resources database and
maps 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. The Wildlife
Resource Matrix reflects a prioritization of species habitat sensitivity as agreed upon by CPW and
Caerus. (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)
Caerus will consult with CPW consistent with the Wildlife Resource Matrix in Attachment B. (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 Caerus' 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: Caerus will adhere to the following best practices for GrSG mitigation and
monitoring for Caerus 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
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)
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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 Caerus' 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
Caerus 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
Caerus 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
Caerus 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. Caerus 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
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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.
• 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.
Caerus 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, Caerus 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.
Caerus and CPW agreed on the value of project types for wildlife resources on Caerus
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)
Caerus 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 and 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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Caerus and CPW will meet each year to confirm project credits generated and used, in addition to
any new projects for consideration and implementation. Caerus 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. Caerus will mechanically treat 196 acres of habitat by removing mature
serviceberry/gamble oak stands, while maintaining existing sagebrush vegetation using a hydro-
axe and heavy equipment. This is a onetime 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 Caerus have 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 currently retains 1,083 AUMs and CPW retains 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 Caerus to exchange the Square S grazing AUMs. Following the finalization of this agreement,
Caerus and CPW staff will complete the necessary paperwork with the Bureau of Land
Management to transfer the base AUMs into CPW’s ownership. This is a onetime project receiving
954 credits with no expiration.
Middle Fork Meadows – This is a 30-acre tract located on Parachute Creek. Caerus 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 Caerus operational boundary. To maintain wildlife movement and sustainability of
vegetation, water source spacing is part of Caerus’ 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. Caerus and CPW have agreed to the following water management
projects and credits:
• Spring and/or Guzzler – Caerus may improve a natural spring or install a guzzler to improve
wildlife habitat where water is needed. Caerus and CPW agree each spring improvement or
guzzler project will generate 80 onetime credits with no expiration.
13
of approval.
Additional mitigation credits from access agreements can be added via amendment at the time
access on a case-by-case basis depending on the type of access, location, and duration.
Caerus recognizes the need for CPW access and will determine the credits associated with the
CPW Access – CPW requests access to Caerus property for scientific studies and special hunts.
12-month lifespan.
game. While the Ranch Manager position if filled, Caerus will annually generate 300 credits with a
area. Grazing monitoring reports will be provided to CPW to assist in the management of big
utilization baskets to determine when livestock should be removed from a geographical
fence inspections, periodic range checks for trespass livestock or unexpected issues, and grazing
Document, and (5) implementation of other habitat management practices. Monitoring includes
consistent with the North Parachute Ranch Integrated Vegetation Management Guidance
manage the use of salt blocks to protect vegetation, (4) identify any weed treatment operations
new lease agreements include provisions to (1) limit AUMs, (2) prevention of overgrazing, (3)
boundary to ensure livestock utilization does not impact other wildlife resources. Existing and
resources. The ranch manager oversees grazing lease agreements within the Caerus operational
guidance, Caerus implements a holistic management approach between operations and wildlife
that provides oversight and ensures that BMPs are monitored. Under the Ranch Manager’s
Grazing Monitoring and Ranch Manager – The ranch manager is a fulltime Caerus professional
generates onetime credits with a 3-year lifespan.
present to CPW the acres sprayed for conversion into credits using the 2.5 multiplier. The project
2020 data, Caerus would have earned 95 credits with a 3-year lifespan. Each year Caerus will
completed weed control on 1,000 acres while spraying a total of 38 acres of weeds. Based on the
control. The total area sprayed will change each year based on need. For example, in 2020 Caerus
physically sprayed with a 2.5 multiplier to account for the larger area benefiting from weed
on weeds to eliminate patches and seed source. The credits for this project are based on area
associated with oil and gas operations. A team may traverse 1,000 acres to spray herbicide
Off ROW Weed Management – Caerus conducts annual weed control treatment in areas not
no expiration.
maintenance. Caerus and CPW agree each new well will generate 160 onetime credits with
needed. Wells can be more reliable than a spring or guzzler but require ongoing
• Water Well – Caerus may install a water well to improve wildlife habitat where water is
Attachment A - Record of Modification
Record of Modification
Section/Page
Reference Description Modification
Attachment B - Wildlife Resource Matrix
Caerus North Parachute Ranch Wildlife Mitigation Plan 2
Updated October 31, 2019 Species/Habitat Concern Rating 1 6 5 4 3 2
2 7 6 5 4 3
3 8 7 6 5 4
4 9 8 7 6 5
5 10 9 8 7 6
5 4 3 2 1
Potential Impact Rating
1) Using the NPR Wildlife Map, identify intersects between the proposed drilling operation,
location of a completions operation, or construction of roads, pads or pipelines, and the
spatial/temporal concerns related to each known wildlife resource concern (use
Worksheet 1 or the NPR WMP Wildlife Matrix Analyses spreadsheet).
2)Use the above matrix to calculate the Rating Total (Species/Habitat Concern Rating +
Potential Impact Rating).
3)If the Rating Total ≥ 6 and cannot be reduced through avoidance of the specified
temporal/spatial concerns, further evaluation is needed. Caerus EHS staff will be
consulted.
4)If the Rating Total ≥ 8 Caerus’ Development Lead should be notified.
5)If the Rating Total ≥ 8 specific input will be sought from CPW and documented on
Worksheet 2.
Caerus North Parachute Ranch Wildlife Mitigation Plan 3
Updated October 31, 2019
CAERUS PICEANCE, LLC
Wildlife Matrix Potential Impact Rating Guidelines
Species/Habitat Concern Concern
Rating Timing of Disturbance
Potential
Impact
Rating
Sage Grouse:
Within 1.0 mile radius of active lek site 5
March 15 to May 15 (breeding season) 5
After May 15, before March 15 4
Surface Structures 5
Subsurface structures 4
Within occupied habitat 4
April 15 to July 15 (nesting/brood season) 4
December 15 to Mar 15 (wintering) 4
After July 15, before December 15 3
Within unoccupied potential habitat 3 2
Raptors:
Note: Pre-construction surveys will be needed starting in March.
Within 0.25 miles of a Coopers Hawk (COHA)
nest 4
April 1 to August 15 (breeding/nesting
season) 3
After August 15, before April 1 2
Within 0.33 miles of a Red-tailed Hawk
(RTHA) nest 4
March 1 to July 15 (breeding/nesting season) 3
After July 15, before March 1 2
Within 0.25 miles of a Sharp-shinned Hawk
(SSHA) nest 4
April 1 to August 15 (breeding/nesting
season) 3
After August 15, before April 1 2
Within 0.5 mile of a Golden Eagle (GOEA) nest
complex 5
December 15 to July 15 (breeding/nesting
season) 4
After July 15, before December 15 3
Within 0.25 miles of a Northern Harrier
(NOHA) nest 4
April 1 to August 15 (breeding/nesting
season) 3
After August 15, before April 1 2
Within 0.5 miles of a Peregrine Falcon (PEFA)
nest complex 5
March 15 to July 31 (breeding/nesting season) 4
After July 31, before March 15 3
Caerus North Parachute Ranch Wildlife Mitigation Plan 4
Updated October 31, 2019
Species/Habitat Concern Concern
Rating Timing of Disturbance
Potential
Impact
Rating
Within 0.25 miles of a Great Horned Owl
(GHOW) nest 3
March to August 2
After August, before March 1
Within 0.25 miles of a Long-eared Owl (LEOW)
nest 4
March 1 to July 15 (breeding/nesting season) 3
After July 15, before March 1 2
Within 0.25 miles of a Northern Pygmy Owl
(NOPO) nest 4
March 15 to July 15 (breeding/nesting season) 3
After July 15, before March 15 2
Within 0.25 of any inactive nest of an
undetermined species 4 3
May require removal of nest 5 4
Riparian Habitat:
Colorado River Cutthroat Habitat: Disturbance
within 300 feet of the natural high water mark 5 3
Colorado River Cutthroat Habitat: Disturbance
within the natural high water mark 5
June 1 to September 1 (spawning season) 5
After September 1, before June 1 4
Big Game (Deer and Elk):
Within mapped production areas 3
April 15 to July 15 4
After July 15, before April 15 3
Within winter range areas 4
After April 15, before January 1 3
January 1 to April 15 4
Within key migration routes 4
Permanent surface structures 4
Subsurface structures 4
Caerus North Parachute Ranch Wildlife Mitigation Plan 5
Updated October 31, 2019
CAERUS PICEANCE, LLC Wildlife
Resource Matrix Worksheet 1
Project Name:
Project Description:
Date:
Participants:
Recorder:
Title/Source of Map used for analysis:
List Species/Habitat/Timing Concerns Identified Concern
Rating
Potential
Impact
Rating
Total
Rating
Can this
concern be
avoided?
Caerus North Parachute Ranch Wildlife Mitigation Plan 6
Updated October 31, 2019
CAERUS PICEANCE, LLC Wildlife
Resource Matrix Worksheet 2
Project Name:
Project Description:
Date:
Participants:
Recorder:
Title/Source of Map used for analysis:
List each Species/Habitat/Timing Concern from
initial Project Analysis sheet that is
UNAVOIDABLE and RATES ≥ 6:
Identify project adaptations to reduce impacts
and/or applicable mitigation
Appendix A
Caerus Piceance LLC Development 1 – Compensatory Mitigation Plan
Expanded Liberty Unit (ELU) Development Plan
1
Caerus Piceance LLC Development 1
Compensatory Mitigation Plan
Expanded Liberty Unit (ELU) Development Plan
Caerus Piceance, LLC (Caerus) has developed this Compensatory Mitigation Plan (Plan) to meet the objectives of
the Colorado Oil and Gas Conservation Commission’s (COGCC) Rule 1203.b. – Compensatory Mitigation for
Wildlife Resources. This Plan was developed in coordination with Colorado Parks and Wildlife (CPW) and the White
River Field Office Bureau of Land Management (WRFO BLM). The Plan covers development that will fall within the
Expanded Liberty Unit (ELU), on private surface, owned by Conoco Philips.
Within the ELU, Caerus is proposing three new well pads (O13, M12, A18) with a total of 98 APDs and a Central
Delivery Point (CDP) pad (G13). The O13, M12, and A18 well pads would be centrally located around the proposed
G13 CDP which would be used to support drilling, completions and well production operations for the proposed
wells. Total disturbance for the ELU development can be found below in Table 1 - Estimated Surface Disturbance
in the Expanded Liberty Unit. Caerus has received approved Federal APDs for the ELU wells. Caerus will be
submitting COGCC Form 2’s and 2A’s, that meet the new COGCC permitting requirements.
All pads are located on private surface (overlying Federal minerals) with an estimated total new surface
disturbance of 80.9 acres. Location maps can be found in Appendix A.
Table 1. Estimated Surface Disturbance in the Expanded Liberty Unit
Project Component
Total Disturbance
During the
Construction
Phase (acres)
Direct Long-Term
Disturbance During the
Production Phase -
After Interim
Reclamation (acres)
Direct Interim
Disturbance –
Disturbance that
will be Interim
Reclaimed (acres)
Disturbance After
Abandonment/
Final Reclamation
(acres)
O13 Well Pad* 7.2 (existing) 2.2 (existing) 5.0 (existing) 0
Access Roads 1.0 (existing) 0.6 (existing) 0.4 (existing) 0
Pipelines 7.3 0 7.3 0
Subtotal for the O13 Location 7.3 0.0 7.3 0
A18 Well Pad 11.3 3.2 8.1 0
Access Roads 6.2 6.0 0.2 0
Pipelines 9.3 0 9.3 0
Subtotal for the A18 Location 26.8 9.2 17.6 0
M12 Well Pad 11.2 2.5 8.7 0
Access Roads 2.8 2.4 0.4 0
Pipelines 9.1 0 9.1 0
Subtotal for the M12 Location 23.1 4.9 18.2 0
G13 CDP Pad 10.4 10.4 0 0
Access Roads 0.2 0 0.2 0
Pipelines2 13.1 0.2 12.9 0
Subtotal for the G13 Location 23.7 10.6 13.1 0
Total for the Expanded Liberty Unit 80.9 24.7 56.2 0
* The O13 pad and access roads would be constructed completely within an already existing, much larger
disturbance. Therefore, those portions are not being counted as new disturbance.
1203.b.(1) A. Plan Objective/Mitigation Goal
The Plan objective and mitigation goal is to provide a project combined with adaptive management features that
is equivalent or greater than the Direct and Indirect Impacts. Mitigation project selection criteria should provide
2
multiple benefits to wildlife resources in areas of disturbance to reduce behavioral changes and maintain wildlife
presence and movement. In cooperation with CPW, Caerus seeks to identify mitigation projects that are durable
over time and that meet wildlife resource needs through multiple benefits.
For this planned development, Caerus will mitigate the direct habitat loss by implementing 196 acres of brush
removal in and adjacent to high priority habitat for elk, mule deer, and greater sage-grouse (GrSG), on Caerus
owned surface. The 196 acres of hydro-axe treatment of mature serviceberry/Gamble oak stands will expand
existing breeding/brood-rearing habitat, increase native forb composition, increase forage, reduce corvid perches,
etc. This mitigation project can be quickly implemented and provides years of multiple benefits while increasing
connectivity of habitat.
The WRFO BLM Environmental Assessment (EA) completed in November 2020, provides additional supporting
information for the mitigation objectives for the ELU development. (BLM Environmental Assessment DOI-BLM-
CO-N050-2020-0052-EA.)
Avoidance and Minimization
Avoidance and minimization were both used in the planning of each location. Caerus has agreed to avoid Barnes
Ridge where there are several active GrSG leks. The ELU development is located to the East of Barnes Ridge with
a distance greater than one mile and natural terrain features (valleys and ridges) separating the locations from
the active lek sites. As an additional mitigation measure, Caerus has agreed to construct sound barriers by
berming soil between applicable pad locations and lek locations to the north and west.
Caerus consistently looks to minimize impacts by reoccupying existing locations. The O13 has been located entirely
within the existing TLQ Site. No new disturbance will be required for construction of the O13.
Compensatory Mitigation
Unavoidable impacts that cannot be mitigated through avoidance and/or minimization are accounted for through
additional mitigation efforts. As discussed in the Compensatory Mitigation for Wildlife Resources section of the
overarching Caerus Wildlife Mitigation Plan (WMP), a credit ratio has been 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.
· 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
Direct Impacts
As shown in Table 1 - Estimated Surface Disturbance in the Expanded Liberty Unit, Direct Impacts from the four
ELU locations, total 24.7 acres for Direct Long-Term Disturbance acres. At a ratio of 4:1, the project credits required
to offset impacts, total 98.8. The Direct Interim Disturbance acres totaled 56.2. The calculated Direct Impacts for
the ELU development project, total 155 acres. These totals are depicted below in Table 2 – Mitigation Acres to
Disturbance Acres.
Indirect Impacts
The Caerus WMP details the Proximity Analysis Methodology (PAM) that was used to calculate the Indirect Impact
acres for the ELU developments. Figure 1 provides the 0.425-mile buffer with removal of all boundary overlaps
for pads M12, G13 and A18. This figure also provides a depiction of topography and elevation changes associated
with the pads. Figure 2 provides the removal of buffer acres below the 100-foot elevation drop from the edge of
the pad disturbance. Figure 3 depicts the remaining Indirect Impact acres for compensatory mitigation prior to
applying BMP percent reduction.
Imagery: Vivid Maxar 4/3/2018 (ESRI)
¨
Buffer Distance (Mile)
0.043
0.085
0.128
0.17
0.213
0.255
0.298
0.34
0.383
0.425
P:\A-F\Caerus Oil and Gas - Parachute, CO - CA6702\P18720 - Caerus WMP Valuation\IMAGES AND MAPS\CA6702-18720-12_Indirect_Impact_0_425mi_Buffer_Analysis_with_Elevation.mxd8/2/2021 12:52:48 PM
Indirect Impact 0.425 Mile Buffer Analysiswith Elevation
Rio Blanco County, Colorado
2021 Wildlife Mitigation Project
Parachute, Colorado
Caerus Piceance, LLC
Figure 1
Checked:
Approved:
Drawn:
Date:
BKR
KEN
CAL
8/2/2021
Dwg. No.:CA6702-18720-12
New Pads A18, M12, and G13
Total Indirect Impact Acres = 599.63
Edge of Disturbance Direct Impact Acres = 33.35
Buffer Distance (mi) Total Acres
Indirect Impact Percent Indirect Impact Acres
0.043 53.92 100%53.92
0.085 74.14 90%66.73
0.128 97.92 80%78.34
0.170 117.17 70%82.02
0.213 141.70 60%85.02
0.255 156.37 50%78.19
0.298 156.29 40%62.52
0.340 151.04 30%45.31
0.383 158.26 20%31.65
0.425 159.46 10%15.95
M12
G13
A18
A18
G13
M12
Imagery: Vivid Maxar 4/3/2018 (ESRI)
0 1,000
Feet
¨
Buffer Distance (Mile)
0.043
0.085
0.128
0.17
0.213
0.255
0.298
0.34
0.383
0.425
Edge Of Disturbance (33.35 acres)P:\A-F\Caerus Oil and Gas - Parachute, CO - CA6702\P18720 - Caerus WMP Valuation\IMAGES AND MAPS\CA6702-18720-13_Indirect_0_425mi_Buffer_Impact_Analysis_with_100ft_Elevation_Adjustment.mxd8/2/2021 1:05:35 PM
Indirect Impact 0.425 Mile Buffer Analysiswith 100 Foot Elevation Adjustment
Rio Blanco County, Colorado
2021 Wildlife Mitigation Project
Parachute, Colorado
Caerus Piceance, LLC
Figure 2
Checked:
Approved:
Drawn:
Date:
BKR
KEN
CAL
8/2/2021
Dwg. No.:CA6702-18720-13
New Pads A18, M12, and G13
Total Indirect Impact Acres = 311.64
Edge of Disturbance Direct Impact Acres = 33.35
Buffer Distance (mi) Total Acres
Indirect Impact Percent Indirect Impact Acres
0.043 51.93 100%51.93
0.085 57.79 90%52.01
0.128 58.86 80%47.09
0.170 57.06 70%39.94
0.213 62.56 60%37.54
0.255 65.28 50%32.64
0.298 60.63 40%24.25
0.340 51.65 30%15.50
0.383 39.90 20%7.98
0.425 27.65 10%2.77
A18
G13
M12
Imagery: Vivid Maxar 4/3/2018 (ESRI)
0 1,000
Feet
¨
Buffer Distance (mi)
0.043
0.085
0.128
0.17
0.213
0.255
0.298
0.34
0.383
0.425
Edge Of Disturbance (33.35 acres)P:\A-F\Caerus Oil and Gas - Parachute, CO - CA6702\P18720 - Caerus WMP Valuation\IMAGES AND MAPS\CA6702-18720-14_Indirect_0_425mi_Buffer_Impact_Analysis_with_Noise_and_Line_of_Sight_Adjustment.mxd8/2/2021 1:06:26 PM
Indirect Impact 0.425 Mile Buffer Analysiswith Noise and Line of Site Adjustment
Rio Blanco County, Colorado
2021 Wildlife Mitigation Project
Parachute, Colorado
Caerus Piceance, LLC
Figure 3
Checked:
Approved:
Drawn:
Date:
BKR
KEN
CAL
8/2/2021
Dwg. No.:CA6702-18720-14
New Pads A18, M12, and G13
Total Indirect Impact Acres = 271.33
Edge of Disturbance Direct Impact Acres = 33.35
Buffer Distance (mi) Total Acres
Indirect Impact Percent Indirect Impact Acres
0.043 50.98 100%50.98
0.085 57.17 90%51.45
0.128 58.16 80%46.53
0.170 50.35 70%35.25
0.213 51.24 60%30.74
0.255 49.16 50%24.58
0.298 40.14 40%16.06
0.340 31.72 30%9.52
0.383 24.03 20%4.81
0.425 14.24 10%1.42
3
Caerus has established a BMP percent reduction range between 60% to 85%. The habitat and wildlife
benefits from the BMPs have been established jointly with the CPW into a percent reduction that is applied
to Indirect Impact acres. The Indirect Impact acres calculated from PAM are 271.33 acres. In agreement with
CPW, an 85% BMP reduction is applied to the 271.33 acres resulting in 40.69 acres requiring compensatory
mitigation for the ELU development.
Table 2. Mitigation Acres to Disturbance Acres
Disturbance Type Total Acres Ratio for Mitigation Total Mitigation Acres
Direct Long-Term Impact Acres 24.7 4:1 98.8
Direct Interim Impact Acres 56.2 1:1 56.2
Indirect Impact Acres 40.69 1:1 40.69
Totals 114.25 195.69
General Schedule
Table 3 summarizes Caerus’ proposed construction and drilling schedule; however, the exact timeframes may
change based on factors such as construction of supporting infrastructure, market conditions and weather. The
brush treatment project will be completed in 2021, therefore the habitat improvements will be in place before
the construction of the ELU locations.
Table 3. Estimated Construction and Drilling Schedule
Unit Pad Name Construction Start Date Drilling Start Date
Expanded Liberty
O13 Well Pad (existing) September 2022 July 2023
G13 CDP Pad September 2022 N/A
A18 Well Pad September 2023 July 2024
M12 Well Pad September 2024 July 2025
1203.b.(1) B. Coordination and Concurrence with CPW and BLM
Caerus has maintained a long-standing working relationship with CPW and places high value on the mitigation
projects that have been conducted to offset wildlife impacts in the Piceance Basin. Caerus and CPW have worked
together under the North Parachute Ranch Wildlife Mitigation Plan (NPR WMP) since 2009. Caerus worked with
CPW to develop a wildlife matrix that helps assess, avoid, minimize, and mitigate impacts to wildlife. Caerus has
and will continue to employ the BMPs within the NPR WMP.
When Senate Bill 181 passed, Caerus applied the Director’s Criteria Review to all locations. Even though Caerus
and CWP had pre-existing agreements and robust procedures in place for location evaluation, Caerus consulted
with CPW on every single location regardless of habitat type.
For the ELU development project, Caerus held on-sites for each location. Caerus, CPW, and BLM were in
attendance. The on-sites occurred on the following date:
• ELU O13 496 Well Pad - 06/02/2020
• ELU A18 495 Well Pad - 06/02/2020
• ELU G13 496 CDP Pad - 06/02/2020
• ELU M12 496 Well Pad - 06/02/2020
COGCC was unable to make the initial on-site and went with Caerus to each location on 6/10/2020. Avoidance,
minimization, and mitigation were discussed at each location. Dave Kubeczko - COGCC Location Assessment
4
Specialist, Danielle Newman - CPW Land Use Specialist, Diane Mastin Dixon – CO BLM Sage-Grouse Natural
Resource Specialist, Shawn Wiser – BLM Wildlife Biologist, and Tim Barrett – BLM Natural Resource Specialist,
attended and participated in wildlife discussions for each of the proposed locations. The group agreed that the
best option for offsetting direct impacts was to employ a brush removal project to open up areas in an effort to
improve and expand high priority habitat.
Follow-up meetings occurred 12/8/20, 5/12/21, and 6/16/2021 to discuss the specific details of the Brush
Treatment Project. Taylor Elm – CPW Northwest Region Energy Liaison, Danielle Newman, Diane Mastin, Shawn
Wiser and Caerus representatives participated in the discussion. The project scope is defined below.
1203.b.(1) C. Treatment Area Selection
The treatment area was selected based on the following criteria:
• The treatment areas must be within elk and mule deer habitat, and greater sage-grouse High Priority
Habitat.
• The treatment area must be located on areas with less than 30% slope.
• The treatment area will be selected in higher value breeding and brood rearing habitat as well as areas
that can promote expansion of currently occupied habitat.
The treatment area was field verified by the Caerus, CPW and BLM representatives listed above. The large ridge
tops located within Township 4S, Range 96W, Sec 24, 25 and 26, and Township 4S, Range 95W, Sec. 19, 30, and
31 were identified as the primary target areas for the brush removal. A total of 196 acres has been delineated for
treatment. The Brush Mitigation Area Map can be found as Appendix A.
1203.b.(1) D. - Site Protection Instrument
The treatment areas are located on Caerus owned and controlled surface. The treatment areas will be logged and
maintained in the Caerus GIS database and GIS files will be shared with CPW. The treatment areas will be inspected
annually to assess re-growth and to monitor for noxious weeds. The treatment area will be included in the Caerus
Grazing Utilization Monitoring Program and data collected will be shared with CPW during the annual meeting.
1203.b.(1) E. - Baseline Information on Wildlife Resources
The ELU locations fall within the following High Priority Habitats listed in COGCC Rule 1202.D.
• 1202.D(2) Elk production and winter concentration area
• 1202.D(3) Mule deer winter concentration and severe winter range
• 1202.D(5) Greater sage-grouse priority habitat management area
The brush treatment areas fall within these same high priority habitats. Baseline imagery maps of the treatment
areas can be found in Appendix B. Photos will be taken prior to treatment and maintained with all records
associated with this Compensatory Mitigation Plan.
1203.b.(1) F. - Mitigation Schedule and Workplan
Upon construction of the BJU B26-496 well pad, Caerus will mow/masticate 196 acres of brush within the
identified treatment areas. The entire 196 acres of mitigation will be completed in 2021, prior to the construction
of the ELU well pads listed in this Plan. Caerus will re-treat the areas at the time of final reclamation. Records for
treatment will be maintained with this plan in Appendix C.
5
1203.b.(1) G.- Maintenance Plan
The brush treatment areas will be added to the Caerus Weed Management Program. The brush removal areas will
be inspected annually, and noxious weed treatments will be employed as required. Pesticide application records
will be maintained and will be made available upon request.
1203.b.(1) H. - Performance Standards
196 acres will receive hydro-axe and mowing treatment of mature Serviceberry/Gamble oak stands adjacent to
existing high-value habitats. Existing sagebrush vegetation will be left undisturbed, to the maximum extent
possible. The treated area will expand existing breeding/brood-rearing habitat, increase native forb composition,
increase forage, reduce corvid perches, etc. The treatment areas will be monitored annually, and noxious weeds
will be treated accordingly.
1203.b.(1) I. – Monitoring and Reporting Requirements
The brush treatment areas will be included in the Caerus Grazing Monitoring program. Transect data and photo
documentation will be collected annually. Annual reports will be presented in the annual CPW meeting. All
pesticide application records will be maintained and made available upon request.
1203.b.(1) J. – Long-term Management Plan
The brush treatment areas will have the initial treatment complete in 2021. The treatment areas will be monitored
and treated for annual weeds. The treatment area will be retreated at the time of final reclamation. All records
will be maintained with this Plan.
1203.b.(1) K. - Adaptive Management Plan
Caerus, CPW and BLM agree that flexibility is needed as these mitigation requirements are carried out over the
lifetime of this plan. The results of this mitigation project may influence future mitigation requirements based on
the following criteria:
1. Monitoring results of initial treatments
2. New information/data from CPW research and/or field staff
3. Climatic events/changes (e.g. fire, drought, etc.)
4. Changes to wildlife population status or BLM disturbance thresholds
1203.b.(1) L. – Financial Assurances
Caerus will be financially responsible for all costs associated with this brush removal project. This includes the cost
for the initial and final brush hydro-axing and mowing, annual monitoring, weed control, and any costs associated
with the maintenance of this compensatory mitigation plan.
Appendix A - Location Maps
K24CDP
L24
C19
WolfRanchCS
A24 4S 95W4S 96W23
2
7
25
1
12
30
6
14
11
24
18
19
13
OIL SHALECORPORATION
CAERUSPICEANCELLC
BUREAUOF LANDMANAGEMENT
CAERUSPICEANCELLC
M12
O13
A18
G13CDP
N23CDP
.
0 0.1 0.2 0.3 0.4Miles
Projected Caerus Access Route
Projected Caerus Pad
Oil and Gas Units
County Parcel
Township
Section403401 4 0 1
SURFACE USE DISTURBANCE SUMMARY
UELS, LLC
Corporate Office * 85 South 200 East
Vernal, UT 84078 * (435) 789-1017
ENGINEERING & LAND SURVEYING
EXHIBIT
SURVEYED BY
DRAWN BY
SCALE
1" = 100'
BART HUNTING, D.S.03-18-20
T.L.L.06-12-20
BJU M23A 496 PAD
W 1/2 SW 1/4, SECTION 23, T4S, R96W, 6th P.M.
GARFIELD COUNTY, COLORADO
Caerus Oil & Gas LLC
Topsoil Stockpiles & Secondary Stormwater Containment Berm ±1.751N/A
Well Site Pad (including cuts/fills)±7.054N/A
Approx. Acres of DisturbanceLength (ft)
SURFACE USE DISTURBANCE SUMMARY (SUDS)
Total Acres of Disturbance ±19.847
Proposed Access Road
N/A
±2,550'
Width (ft)
N/A
Proposed Water Pipeline (In Pipeline Corridor)
±124'
±1.350
Proposed Secondary Access Road ±2,117'30'
Remaining Area (In Surface Use Area)N/AN/A ±2.313
Proposed Gas Lift Line (In Pipeline Corridor)
±129'
N/A
Proposed Gas Lift Line (On B26 496 Pad)
±2,579'
N/A
±126'
Proposed 3-Phase (In Pipeline Corridor)
±2,571'
N/A
±1.458
±1,960'30'
Proposed Gas Pipeline (In Pipeline Corridor)
Proposed Gas Pipeline (On B26 496 Pad)
100'±5.921
Proposed Water Pipeline (On B26 496 Pad)
Proposed HP Frac Pipeline (On B26 496 Pad)
Proposed HP Frac Pipeline (In Pipeline Corridor)
Proposed Surface Flowback Pipeline (On B26 496 Pad)
Proposed Surface Flowback Pipeline (In Pipeline Corridor)
±1,645'
±2,563'
±127'
±2,556'
±128'
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
UELS, LLCCorporate Office * 85 South 200 EastVernal, UT 84078 * (435) 789-1017
ENGINEERING & LAND SURVEYING
EXHIBITSURFACE USE DISTURBANCE SUMMARY
SURVEYED BY
DRAWN BY
SCALE
1" = 100'
DAYTON SLAUGH, K.H.03-09-20
T.L.L.07-08-20
BJU B26 496 PADNE 1/4 NW 1/4, SECTION 26, T4S, R96W, 6th P.M.GARFIELD COUNTY, COLORADO
Caerus Oil & Gas LLC
Topsoil Stockpiles & Secondary Stormwater Containment Berm ±1.094N/A
Well Site and Frac Support Pads (including cuts/fills)±7.151N/A
Approx. Acres of DisturbanceLength (ft)
SURFACE USE DISTURBANCE SUMMARY (SUDS)
Total Acres of Disturbance ±16.201
Proposed Access Road
N/A
±458'
Width (ft)
N/A
Proposed Water Pipeline (In Pipeline Corridor)
±480'
±0.127
Proposed Secondary Access Road ±842'30'
Remaining Area (In Surface Use Area)N/AN/A ±2.370
Proposed Gas Lift Line (In Pipeline Corridor)
±481'
N/A
Proposed Gas Lift Line (On Pad)
±1,829'
N/A
Proposed 3-Phase (On Pad)
±481'
Proposed 3-Phase (In M23A 496 Pipeline Corridor)
±1,828'
N/A
±0.580
±185'30'
Proposed Gas Pipeline (In Pipeline Corridor)
Proposed Gas Pipeline (On Pad)
100'±4.199
Proposed Water Pipeline (On Pad)
Proposed HP Frac Pipeline (On Pad)
Proposed HP Frac Pipeline (In Pipeline Corridor)
Proposed Surface Flowback Pipeline (On Pad)
Proposed Surface Flowback Pipeline (In Pipeline Corridor)
±942'
±122'
±646'
±481'
±638'
±481'
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
±296'Proposed Gas Lift Line (In Pipeline Corridor)100'±0.680
UELS, LLCCorporate Office * 85 South 200 EastVernal, UT 84078 * (435) 789-1017
ENGINEERING & LAND SURVEYING
SURVEYED BY
DRAWN BY
SCALE
1" = 100'
DAYTON SLAUGH, D.P.03-17-20
T.L.L.05-20-20
BJU P25 496 PADSE 1/4 SE 1/4, SECTION 25, T4S, R96W, 6th P.M.GARFIELD COUNTY, COLORADO
Caerus Oil & Gas LLC
EXHIBIT 1SURFACE USE DISTURBANCE SUMMARY
Topsoil Stockpile & Secondary Stormwater Containment Berm ±1.584N/A
Well Site Pad (including cuts/fills)±7.032N/A
Approx. Acres of DisturbanceLength (ft)
SURFACE USE DISTURBANCE SUMMARY (SUDS)
Total Acres of Disturbance ±16.070
Proposed Gas Pipeline (In Pipeline Corridor)
N/A
±618'
Width (ft)
N/A
Proposed Surface Flowback Pipeline (In Pipeline Corridor)±1030'
Proposed Water Pipeline (In Pipeline Corridor)
Remaining Area (In Surface Use Area)
30'
Proposed 3 Phase Line (In Pipeline Corridor)±2070'
Proposed Surface Flowback Pipeline (Outside Pipeline Corridor)±25'
Proposed Access Road 30'240'
N/AProposed Gas Lift Line (In Pipeline Corridor)
Proposed Secondary Access Road
N/A
531'±0.366
±0.165
N/A ±1.754
N/A
±458'N/A N/A
±636'N/A N/A
100'
N/AN/A
Proposed HP Frac Pipeline (In Pipeline Corridor)±1058'N/AN/A
50'±0.029
Proposed Gas Pipeline (Outside Pipeline Corridor)±169'100'±0.388
±4.752
UELS, LLC
Corporate Office * 85 South 200 East
Vernal, UT 84078 * (435) 789-1017
ENGINEERING & LAND SURVEYING
EXHIBIT 1SURFACE USE DISTURBANCE SUMMARY
SURVEYED BY
DRAWN BY
SCALE
1" = 100'T.L.L.07-23-20
Caerus Oil & Gas LLC
DENNIS PETTY, C.R.05-13-20
BJU N23 496 CDP PAD
SE 1/4 SW 1/4, SECTION 23, T4S, R96W, 6th P.M.
NE 1/4 NW 1/4, SECTION 26, T4S, R96W, 6th P.M.
GARFIELD COUNTY, COLORADO
Topsoil Stockpile & Secondary Stormwater Containment Berm ±0.264N/A
CDP Pad (including cuts/fills)±1.339N/A
Approx. Acres of DisturbanceLength (ft)
SURFACE USE DISTURBANCE SUMMARY (SUDS)
Total Acres of Disturbance ±2.365
N/A
Width (ft)
N/A
Remaining Area (In Surface Use Area)N/A
Proposed Access Road 30'29'±0.020
N/A ±0.742
NOTE:
PROPOSED PAD IS ON EXISTING DISTURBANCE
SURFACE USE DISTURBANCE SUMMARY
EXHIBIT
CAERUS OIL & GAS LLC
ELU O13 496 WELL PAD
W1/2 SE1/4, SECTION 13, T4S, R96W, 6TH P.M.
RIO BLANCO COUNTY, COLORADO
NORTH
SURFACE USE DISTURBANCE SUMMARY
EXHIBIT
NORTHELU M12 496 WELL PADW1/2 SW1/4 SECTION 12, T4S, R96W, 6TH P.M.
RIO BLANCO COUNTY, COLORADO
CAERUS OIL & GAS LLC
SURFACE USE DISTURBANCE SUMMARY
EXHIBIT
NORTHELU A18 495 WELL PAD
LOT 3 (NW1/4 NW1/4),
SECTION 18, T4S, R95W, 6TH P.M.
RIO BLANCO COUNTY, COLORADO
CAERUS OIL & GAS LLC
NORTHCAERUS OIL & GAS LLC
G13 CDP SITE
LOTS 2 & 3, SW1/4 NE1/4, & THE SE1/4 NW1/4
SECTION 13, T4S, R96W, 6TH P.M.
RIO BLANCO COUNTY, COLORADO
SURFACE USE DISTURBANCE SUMMARY
EXHIBIT
4S 95W4S 96W23
36
25
35
30
14
24
26
18
19
31
13
ELU GrSG Brush Mitigation.
0 1,000 2,000 3,000 4,000Feet
Potential GrSG Mitigation (~218ac)
Township
Section
Appendix B - Brush Mitigation Area Photos
Appendix C - Brush Mitigation Area Records
Figures
456
7 8 9
161718
19 20 21
282930
31 32 33
1234
5
6
7 8 9 10 11 12
131415161718
19 20 21
22 23 24
252627282930
31
32
1234
56
7 8 9 10 11 12
161718
19 20 21
282930
31 32 33
123456
7 8 9 10 11 12
131415161718
19 20 21 22 23 24
25262728
2930
31 32
33
34 35 36
123 3456
7 8 9
10456
7 8 9 10 11 12
13
1415161718
19 20 21 22 23 24
252627282930
31 32 33 34 35 36
33 34 35 36
123456
7 8 9 10 11
12
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15161718
19 20 21 22 23 24
252627282930
31 32 33 34 35 36
123456
7
8 9 10 11 12
1314151617
18
19 20 21 22 23 24
252627282930
31 32 33 34 35 36
123
456
7 8 9 10 11 12
131415161718
19 20 21 22 23 24
2526
27
282930
31 32 33 34 35 36
123
4
9
10 11 12
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1516
21 22 23 24
25262728
33 34 35 36
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456
7 8 9 10 11 12
1234
9 10 11 12
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 1. Caerus Overall Management
Figure 2. Five Primary Migratory Corridors on the NPR