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Home My WebLink About1.05 Garfield County Pre-Application Conference Request MaterialsCPX Piceance Holdings, LLC 34 S. Wynden Drive, Suite 240 Limited Impact Review Garfield County, Colorado Houston, TX 77056 TPR Well Pad 36A Article 9 Oil and Gas Permit Application Appendix F: Garfield County Pre- Application Conference Request Materials CPX Piceance Holdings, LLC 34 S. Wynden Drive, Suite 240 Limited Impact Review Garfield County, Colorado Houston, TX 77056 TPR Well Pad 36A Article 9 Oil and Gas Permit Application August 25, 2021 Garfield County Pre- Application Conference Request 34 S. Wynden Dr. Ste 240 Houston, TX 77056 Phone: 713-554-9031 August 25, 2021 Ms. Sheryl Bower, Director Community Development Department 108 8th St, Suite 401 Glenwood Springs, CO 81601 RE: Garfield County Oil and Gas Permit Pre-application Meeting Dear Ms. Bower, CPX Piceance Holdings LLC (CPX) would like to initiate a pre-application meeting with Garfield County in September 2021 for the continued development of two natural gas locations. The locations are on Tepee Park Ranch, which is owned and operated by CPX in Sections 25 and 36, Township 7 South, Range 94 West. The Pad 25A and 36A locations are shown on Figures 1 and 2 in Attachment A. The locations are being included in a proposed Comprehensive Area Plan (CAP) for Colorado Oil and Gas Conservation Commission (COGCC) approval for the continued development of Pads 25A and 36A and the proposed development of one new Oil and Gas Location, Pad 31. CPX intends to submit an Oil and Gas Development Plan (OGDP) and Form 2A for Pad 25A concurrent with its CAP application and intends to seek preliminary siting approval under COGCC Rule 314.b.(5) for Pad 36A and Pad 31. Pad 36A and 25A oil and gas locations are subject to the requirements of Article 9 of the Garfield County Land Use Code (LUC) for Oil and Gas Locations that require an alysis of alternative locations under COGCC Rule 304.b.(2).B [LUC 9-201.F.1]. COGCC requires analysis of alternative locations for, among other criteria, locations within the boundaries of, or immediately upgradient from, a riparian corridor [Rule 304.b.(2).B.vii] and locations within high priority habitat where the Operator did not obtain a waiver from Colorado Parks & Wildlife (CPW) [Rule 304.b.(2).B.viii]. Pad 36A is subject to the COGCC’s requirement to conduct an alternative location analysis (ALA) due to its proximity to aquatic high priority habitat for cutthroat trout and other native aquatic species and its location immediately upgradient from a riparian corridor. Pad 25A is subject to the ALA requirements because it is immediately upgradient from an intermittent waterbody riparian corridor. Proposed Pad 31 is not subject to the requirements of Article 9 of the LUC because it is not subject to the COGCC’s ALA requirements, and CPX is not requesting a variance from the COGCC noise or lighting requirements in Rules 423 and 424. CPX obtained waivers from CPW for Pad 25A’s proximity to high priority habitat and for the portion of Pad 36A between 300 and 500 feet of high priority habitat [Rule 309.e.(5).D.i]. And CPW has provided its recommendation for a variance granted by the Commission for the portion of Pad 36A that is within 300 feet of high priority habitat. The CPW waiver and variance letters are provided as Attachment B. Pads 25A and 36A were constructed in approximately 2008. COGCC permits were issued for 3 wells on Pad 25A. Two wells are producing. One well was spud but not completed. Permits were issued for 3 wells on Pad 36A. A portion of Pad 36A was historically within the prior 300-foot buffer for cutthroat trout. It is now partially in the new 300-foot buffer and partially in the new 500-foot buffer. Pad 25A was historically outside of a cutthroat trout buffer but now is partially in the new 500-foot buffer. CPX’s permit application will seek COGCC approval as part of a CAP for the Pad 25A and 36A locations and development of the new Pad 31, which is outside of high priority habitat. CPX purchased Tepee Park Ranch in 2015 and has been diligently preparing for the responsible development of the natural gas asset on the ranch. CPX moved Forest Service Road 824 further from Beaver Creek, constructed new stormwater controls and two new trailheads along the road, buried a previously above-ground pipeline, closed and reclaimed a former produced water pit, and constructed a new location outside of high priority habitat to house process equipment and avoid haul traffic during production. On May 27, 2021, CPX conducted an on-site pre-application consultation with representatives from CPW to review the proposed locations and the extensive controls at the locations to prevent potential impacts to surface water. CPW subsequently documented its waiver for Pad 25A and waiver and recommended variance for Pad 36A from restrictions in cutthroat trout high priority habitat (Attachment B). In its documentation, CPW stated that it incentivizes the use of already disturbed locations when no adverse impacts are anticipated. CPW further stated that construction of a new location, instead of continued use of the existing location, would cause more undesired disturbance and habitat fragmentation, and would pose more risk to high priority habitat and the watershed. Garfield County LUC 9-203.A anticipates a county pre-application process before the applicant initiates an application with COGCC. LUC 9-203.B.1 requires that the pre-application meeting request be accompanied by the information listed below and provided in Attachment C: • Proposed area of mineral development; • Information required by COGCC Rule 304.b.(2).C; • Each federal, state, or local government designated park or open space partially or wholly located within the proposed area of mineral development; • Each known area containing environmental contamination partially or wholly located within the proposed area of mineral development (as identified on COGCC, DRMS, and/or CDPHE databases); and • Each public road right of way. If you have questions regarding this letter, please contact me at nick@cpxpiceance.com or (713) 554- 9031. Thank you, Nicholas Kurtenbach, Principal CPX Piceance Holdings, LLC Attachments Attachment A – Figures Attachment B – Documentation of Waiver and Variance from CPW Attachment C – LUC 9-203.B.1 Pre-application Meeting Information Attachment A Figures Attachment A Figures Attachment A Figures Attachment A Figures !!!!!! ! ! ! !!!!!!! ! ! ! ! ! ! ! ! !!!!! ! ! !! ! ! !!! ! ! !!!!! ! ! ! !!!!!!!!!!!! ! !!!!! ! ! ! !!!! ! ! !!! !!! ! ! ! ! ! !!!!!!!!! ! !!! ! ! ! !!!!!!!!! ! !!!!!!!!!!! ! ! ! !!! ! !!!! ! !!!!!!! !!! ! !!!!! ! ! ! ! !!! ! ! ! !!!! ! ! ! !!!!! !!!!!ExistingPad 36A Pad 2Tanks ExistingTepeeParkRanchRoadF S8 2 4 CPX PICEANCE HOLDINGS LLC CPX PICEANCE HOLDINGS LLC White River National Forest White River National Forest BeaverCreekT e p e e C r e e k CR317 F S8 2 4 Old Reclaimed FS 824 Alignment B ea v er C re e k TERRA ENERGY PARTNERS MINERALS ExistingPad 25A ProposedPad 31A ExistingTepeeParkRanchLoggingRoad1 2 3 Alternative Location Alternative Location Alternative Location 14 13 2423 26 25 35 36 18 19 30 31 6 7 18 12 1211 14 13 T7S R94WT7S R93WT7S R94WT8S R93WT7S R94WT8S R94W T7S R93WT8S R93W T8S R93WT8S R94WWest Mamm CreekBrush Creek0 1,000 2,000500 Feet ³ LegendMineral Ownership BoundaryForest Service Road and AdjacentFlowlinesTepee Park Ranch RoadOn-Location FlowlinesExisting Pad LocationsComprehensive Area Plan Proposed LocationForest Service JurisdictionMineral DevelopmentRule 1202.c NSO HabitatsCutthroat Trout Designated CrucialHabitat National Hydrography Dataset Perennial Stream Intermittent Stream !!Ephemeral Stream Figure 1 CPX Piceance Holdings, LLCTepee Park Ranch Aota Technical, LLC Figure No. Compr ehensive Area Plan Boundar y 8/24/21 Date Data Sources:U.S. Geological Survey, National Hydrography Dataset.COGCC GIS Online. Notes:(1) Beaver Creek also designated as 1202.c Native Fish and Other Native Aquatic Species Conservation Waters.(2) Tepee Creek also designated as 1202.c Sportfish Management Waters.(3) Rule 309.e.(1) Other Consultation Habitat is not present. (4) Future underground gathering lines will be co-located adjacent to existing roads. Garfield CountySections 25, 36 T7S R94W 6th P.M. ExistingPad 25A Existin gPad 36ATepeeParkRanchRoadFS 824 CPX PICEANCE HOLDINGS LLCCPX PICEANCE HOLDINGS LLC White River National Forest BeaverCreekT e p e e C r e e k B e a v er C re e k TERRA ENERGY PARTNERS MINERALS FS824White River National Forest Propo sedPad 31A Alt. 1 Alt. 2 Alt. 3 24 23 26 25 35 36 19 30 31 6 7 12 12 11 T7S R94WT7S R93WT7S R94WT8S R93WT7S R94WT8S R94W T7S R93WT8S R93W T8S R93WT8S R94WBrush CreekWest Mamm Creek0 900 1,800450 Feet LegendMineral Ownership BoundaryForest Service Road and AdjacentFlowlinesTepee Park Ranch RoadOn-Location FlowlinesProposed On-Location FlowlinesExisting Pad Locations Comprehensive Area Plan BoundaryProposed LocationAlernative Pad LocationsForest Service JurisdictionRule 1202.d Density HabitatsElk Production AreaElk Winter Concentration Area Rule 1202.c NSO HabitatsCutthroat Trout Designated CrucialHabitat National Hydrography DatasetPerennial Stream Intermittent Stream Ephemeral Stream Buffer 300-foot BufferFigure 2 CPX Piceance Hol dings, LLCTepee Park Ranch Aota Technical, LLC Fig ure No . High Priority Habitat Buffers To po 8/18/21 Date Data Sources:U.S . Geological Surve y, National Hyd rography Dataset.COG CC GIS Online. Notes:(1) Beaver Creek also designated as 1202.c Nativ e Fish and Other Native Aquatic Species Cons ervation Waters.(2) Tepee Creek also designated as 1202.c Sportfish Management Waters.(3) Rule 309.e.(1) Other Consultation Habitat is not pres ent. Ga rfie ld Count ySections 2 5, 36 T17S R94W 6 th P.M. Attachment B CPW Waiver from Rule 1202.c.(1).R Restricted Cutthroat Trout High Priority Habitat (June 15, 2021) CPW Recommended Variance from Rule 1202.c.(1).R Restricted Cutthroat Trout High Priority Habitat (June 18, 2021) Archive d: Wednesday, June 16, 2021 12:04:13 PM From: Neumann - DNR, Danielle Se nt: Tuesday, June 15, 2021 1:58:31 PM To: nick@cpxpiceance.com Cc: Taylor Elm - DNR; ByBee - DNR, Travis; Bryan Clark; gwen.brodsky@aota.tech; Kent Rider Subje ct: Re: CPX - Variance Request Se ns itivity: Normal Hello Again, Here is CPW's statement regarding TPR Pad 25A. After reviewing the presentation you gave to us on May 27, I deci ded to type up the BMPs for easy reference. I know these will be detailed in your package but more documentation is better than less! Please let us know if you have any questions. This serves as CPW's written waiver for the continued use of Pad 25A, portions of which are affected by Rule 1202.c.(1).R (cutthroat trout designated crucial habitat). CPW staff visited this locati on on May 27, 2021, to determine if a waiver was appropri ate. C PW incentivizes the use of already disturbed locations when no adverse impacts are anticipated. Construction at a new location, i nstead of continued use of Pad 25A, would cause more undesired disturbance and pose more risk to High Priority Habitats and the watershed. Pad 25A’s location boundary and access road will not expand. CPX has proposed a list of 10 BMPs to avoid adversely impacting Beaver Creek, aquatic habitat, and the watershed. CPW may issue a waiver, with the appli cation of prescribed BMPs, per rule 309.e.(5).D. CPW expects these measures to be sufficient and supports the continued use of Pad 25A. Spill Protection To protect against spills from the well pad, existing well pad fill slopes have 2’ high earthen berms compacted to 95% soil/moisture density. The outside slopes of the berms have 80% vegetative cover. The berms are stable with high structural i ntegrity. To protect against spills from tanks, steel secondary containment is sized to 150% of the largest tank. The secondary containment liner is sprayed in to optimize its seal. Spill response material is permanently stored on Pad 25. TPR has not experienced a spill to date. Stormwater Protection To protect against runoff, there is no uncontrolled stormwater on the well pads. Well pads have 6” drai ns i n the center. The drain is piped outside of the berm to a lined trench. The trench drains to a lined catchment. Solids settle in the catchment for removal. The stormwater evaporates. To protect against erosion, the road has a borrow ditch on the upslope side. Stormwater is diverted to 18”-24” culverts spaced at 600’ intervals. Frequent culverts prevent erosion by avoidi ng long runs of stormwater and slowing velocity. Stream Protection To protect Beaver Creek, the road crossi ng was designed in consultation with the USACE. It is an open bottom arch with concrete footers to maintain the streambed integrity. To protect Beaver Creek, process equipment and tank loadout were relocated to Pad 2, approximately 3 mi les away. To protect Beaver Creek, the water pipeli ne was designed to be bidirectional. Delivering freshwater to TPR by pi peline eliminates haul traffic for water delivery. To protect Beaver Creek, no proppant i s anticipated for future well development, which eliminates haul traffic for proppant. Inspections To minimize potential for undetected spills, runoff, and pipeline leaks, personnel are on site approximately 5 days/week. Field staff live within 15 minutes of the well pads, which faci litates consistent on-site presence. Pipelines are monitored for pressure loss and are tested annually. Thank you, On Tue, Jun 15, 2021 at 1:20 PM Neumann - DNR, Danielle <danielle.neumann@state.co.us> wrote: Hi Nick, Here is CPW 's s tatement regarding TPR Pad 36A . I apolo gize for ho w lo ng it to ok! Thi s s erves a s a wri tten recommenda ti on from CPW to the COGCC Commi s s i on i n s upport of CPX’s reques t for a va ri a nce from Rul e 12 02.c.(1).R on Pa d 36A. Pa d 36A i s pa rti a l l y s i tua ted wi thi n 300 feet from the des i gnated c utthroa t trout ha bi ta t (Bea ver Creek). However, Pa d 36A i s wel l -es tabl i s hed, a s i t wa s cons tr ucted i n 2008 a nd r ec ei ved a n excepti on to i nteri m recl a ma ti on requi rements . CPW i nc enti vi zes the us e of a l rea dy di s turbed l oca ti ons when no adver s e i mpa cts a r e a nti ci pa ted. CPW s ta ff toured Pa d 36A on Ma y 27, 2021 to veri fy tha t thi s l ocati on wa s a ppr opri a te for a va r i a nc e. A va ri a nce woul d a l l ow CPX to conti nue the us e of a n exi s ti ng l oc a ti on, a c c es s roa ds , a nd off-l oca ti on fl owl i nes . The fol l owi ng i tems provi ded CPW s ta ff wi th confi dence i n thei r s upport of the va ri a nce: a l i ned s teel s econda ry c onta i nment wi l l a voi d the potenti a l for s pi l l s & l ea ks to i mpa ct s urfa ce wa ter, a n engi neered dr a i n fr om the pa d to a l i ned peri meter trench, a ca tchment s ys tem to a voi d s tor mwa ter runoff a re i n pl a c e, a nd no er os i on i s a nti ci pa ted due to the ma turi ty of the pa d s urfa c e & es ta bl i s hed vegeta ti on. Addi ti ona l l y, CPX i ndi ca ted tha t the exi s ti ng terti a ry c onta i nment peri meter berm coul d be rei ns ta l l ed a fter i nteri m recl a ma ti on a nd agreed to dus t s uppr es s i on mea s ures tha t wi l l a voi d i mpa cts to Bea ver Creek. An al terna ti ve l oca ti on for Pa d 36A wa s cons i dered; however, cons tructi on a t thi s l ocati on woul d c a us e more undes i r ed di s turba nc e a nd pos e more ri s k to Hi gh Pri ori ty Ha bi ta ts a nd the wa ter s hed. Pl ea s e rea c h out wi th a ny ques ti ons . Al l the bes t, Da ni On Fri, Jun 4, 2021 at 1:24 PM <nick@cpxpiceance.com> wrote: Dani, In a previ ous emai l , CPX Pi ceance Holdings, LLC ex pressed our appre ci ati on for the recent CPW pre-consultation and si te visit to Te pe e Park Ranch (TPR) in Garfield County on May 27, 2021, to discuss CPX’s pl ans for the conti nue d deve l opme nt of natural gas wells on TPR. CPX’s prior emai l re que sted a wri tten waiver of Colorado Oi l & Gas Conservation Commi ssi on Rule 1202.c.(1).R for de velopment activi ties be twe e n 300 and 500 fe e t of de si gnated cutthroat trout habitat on two e xisti ng well pads on TPR: Pad 25A in Secti on 25 T7S R94W and Pad 36A in Secti on 36 T7S R94W. Rule 309.e.(5).D allows CPW to waive the application of Rul e 1202.c.(1).R for ne w ground disturbance between 300 f e e t and 500 feet from de si gnated wate rs. CPW may not wai ve the application of Rule 1202.c.(1).R withi n 300 fe e t of de si gnated waters. Development activitie s wi thin 300 feet of designate d wate rs under Rule 1202.c.(1).R require a variance from the Commi ssi on under Rule 502.c. The Commi ssi on, however, will consi de r CPW’s wri tte n re comme ndati on on whether to grant a variance re que sted from any of the Rul e 1202.c.(1) high pri ority habitats. Accordi ngly, wi th this e mail, CPX is separately re que sting a written recommendation f rom CPW for the Commission to grant CPX’s request for a variance from Rule 1202.c.(1).R for the affe cted porti on of Pad 36A that would require a vari ance from the rul e to al l ow de velopment wi thin 300 feet from designate d cutthroat trout habi tat. CPX’s request for a wri tten waiver from CPW applies to the northe ast portion of Pad 36A, which i s between 300 fee t and 500 feet from de si gnated cutthroat trout habi tat. CPX intends to request a vari ance from Rule 1202.c.(1).R, as part of i ts application for a Comprehensive Area Plan (CAP), for the southwest portion of Pad 36A, which is within 300 f e e t of de si gnated cutthroat trout habitat. Rule 309.e.(5).E allows CPW to make a written re comme ndati on to COGCC on whether a variance request should be granted, unde r what condi tions, and the reasons for the re comme ndati on. The Commission will consi der CPW’s recommendati on whe n dete rmining whe ther to grant the requested variance. During the pre -consultati on and site visit, CPX and CPW di scusse d CPX’s proposed de velopment plan for Pad 36A, re viewe d cri teri a by which COGCC may approve a vari ance request, and toured the Pad 36A location, surroundi ng topography, and best management practices. Attache d is the presentati on that CPX provi de d to CPW duri ng the May 27 site visi t. The presentati on descri be s, among other items: the chronology of natural gas de velopment on TPR si nce 2008; the e nvironme ntal improvements CPX has made on TPR and adjace nt U.S. Forest Se rvi ce land since acquiring the prope rty i n 2015; CPX’s propose d plan of deve l opme nt; and CPX’s conformance with cri teri a for a vari ance from provisions of Rul e 1202.c.(1).R. The May 27 fi e l d re view helped to demonstrate that Pad 36A i s we l l established si nce its constructi on in 2008. It repre se nts continued use of an ex i sting location, access, and off-location flowlines. Line d ste e l secondary containment wi l l avoid the potenti al for spills and leaks to i mpact surface wate r. The we l l pad surface and berms have l ong been stabi l i ze d and ve getate d to avoid e rosion. The e ngineered drain on the well pad, l i ne d peri me ter trench, and catchment system avoi d stormwater runoff. New buri e d fl owlines would be located withi n the exi sting road corridor, whi ch is approvabl e under Rule 1202.c.(2).C wi thout a waiver or variance. An alte rnative location southeast of Pad 36A that was reviewed with CPW is onl y i mme di ate l y outside of Rul e 1202.c.(1).R habi tat. It i s in heavy timber on stee p te rrain with no e xisti ng access. Continued development of the existi ng l ocati on is anti ci pate d to avoid adverse impacts while also preventing the new di sturbance and potenti al for erosi on and stormwater runoff from relocating the we l l pad, acce ss, and fl owlines to the alte rnative location. Thank you for your atte ntion to this matter. Please do not hesitate to contact me with any questions CPW has regarding the re que sted variance . I can be re ached at nick@cpxpi ceance.com or (713) 554-9031. Gwe n Brodsky, Aota Te chni cal, i s knowledgeable about this informati on and al so is availabl e for any questi ons at gwe n.brodsky@aota.tech or (303) 818-4462. Best, Nick Nicholas Kurtenbach CPX Pi ce ance Holdings LLC -- Da nielle Neumann Land Use Spec ialist No rthw est Reg io n C: 970-366-1223 0088 W ildlife W ay Glenw ood Springs CO 81601 danielle.neumann@state.co.us | w w w .cpw .state.co.us ◉ ◉ ◉ ◉ -- Da nielle Neumann Land Use Spec ialist No rthw est Reg io n C: 970-366-1223 0088 W ildlife W ay Glenw ood Springs CO 81601 danielle.neumann@state.co.us | w w w .cpw .state.co.us ◉ ◉ ◉ ◉ Grand Junction Service Center Northwest Regional Office 711 Independent Ave. Grand Junction, CO, 81505 P 970-255-6100 | F 970-255-6111 Dan Prenzlow, Director, Colorado Parks and Wildlife • Parks and Wildlife Commission: Marvin McDaniel, Chair  Carrie Besnette Hauser, Vice-Chair Marie Haskett, Secretary  Taishya Adams  Betsy Blecha  Charles Garcia  Dallas May  Duke Phillips, IV  Luke B. Schafer  James Jay Tutchton  Eden Vardy CPX Piceance Holdings 6/18/2021 34 S. Wynden Dr. Suite 300 Houston, Texas 77056 Dear CPX Piceance Holdings, Colorado Parks and Wildlife (CPW) has a statutory responsibility to manage all wildlife species in Colorado and consultation obligations for certain oil and gas operations regulated by the Colorado Oil and Gas Conservation Commission (COGCC). As a result of CPW consultation, detailed in COGCC Rule 309.e.(5).E, “CPW may also make written recommendations on whether a variance pursuant to Rule 502 should be granted, under what conditions, and the reasons for any such recommendations, including requests for variances from Rules 1202.c.(1)Q-S. The Commission will consider the written recommendations of CPW…” This serves as CPW’s written recommendation in support of CPX’s request for a variance from Rule 1202.c.(1).R on Pad 36A. Pad 36A is partially situated within 300 feet of Beaver Creek, which is cutthroat trout designated crucial habitat and native fish and other native aquatic species conservation waters. However, Pad 36A is well-established. This location was constructed in 2008 and received an exception to interim reclamation requirements. CPW incentivizes the use of already disturbed locations when no adverse impacts are anticipated. CPW staff toured Pad 36A on May 27, 2021, to verify that this location was appropriate for a variance. A variance would allow CPX to continue the use of an existing location, access roads, and off-location flowlines. The following items provided CPW staff with confidence in their support of the variance request: A lined steel secondary containment will avoid the potential for spills & leaks to impact surface water An engineered drain from the pad to a lined perimeter trench A catchment system to avoid storm water runoff is in place No erosion is anticipated due to the maturity of the pad surface & established vegetation Dust suppression measure will be taken to avoid impacts on Beaver Creek Additionally, CPX indicated that the existing tertiary containment perimeter berm could be reinstalled after interim reclamation. CPX has agreed to all operating requirements listed in Rule 309.e.(5)D.i.aa-ee to obtain a waiver in 1202.c.(1).R habitats. Considering this, CPW issues a waiver for portions of Pad 36A that are outside of the variance zone. An alternative location for Pad 36A was considered; however, construction at an alternative location would cause undesired habitat fragmentation and pose more risk to High Priority Habitats and the watershed. Colorado Parks & Wildlife values the opportunity to provide comments on this proposal. If you have any questions or concerns, please reach out to Taylor Elm, Energy Liaison, at (970) 986-9767. Sincerely, Kirk Oldham Area Wildlife Manager Cc. Travis ByBee, District Wildlife Manager Taylor Elm, Northwest Region Energy Liaison Danielle Neumann, Northwest Region Land Use Specialist File. Attachment C LUC 9-203.B.1 Pre-application Meeting Information Attachment C LUC 9-203.B.1 Pre-application Meeting Information Attachment C LUC 9-203.B.1 Pre-application Meeting Information LUC 9-203.1.B.1 Pre-application Meeting Information The information below addresses the Garfield County Land Use Code (LUC) 9-203.B.1.a through e requirements to provide information accompanying a pre-application meeting request. a. Proposed area of mineral development The proposed area of mineral development is shaded on Attachment A, Figure 1. b. Information required by Colorado Oil and Gas Conservation Commission (COGCC) Rule 304.b.(2).C 1. Rule 304.b.(2).C. and C.i – Narrative and Analysis that Identifies all Potential Alternate Locations from which the Targeted Minerals can be Accessed. Figure 1 in Attachment A shows the area of mineral development, CPX Piceance Holdings, LLC’s (CPX’s) proposed locations, three technically feasible alternative locations, proximate existing and permitted locations, and relevant jurisdictional boundaries [304.b.(2).C.i.aa -ee]. The alternative locations would provide access to CPX and federal minerals. Each alternative location would require new disturbance. Colorado Parks and Wildlife (CPW) stated in its May 27, 2021 field review of high priority habitat that construction of a new location, instead of continued use of the existing location, would cause undesired disturbance and habitat fragmentation, and would pose more risk to high priority habitat and the watershed. There are no disproportionately impacted communities within 2,000 feet of each oil and gas location [304.b.(2).C.i.ff]. Reference coordinates for each location and alternative are listed in Table 1 [304.b.(2).C.i.gg]. Table 1. Reference Coordinates Existing Proposed Alternative Locations Pad 25 Pad 36 Pad 31 Alt 1 Alt 2 Alt 3 Lat/Lon 39.404591, -107.83277 39.394825, - 107.832016 39.406147, -107.825079 39.410036, -107.831515 39.401108, -107.834757 39.3929, -107.8304 The Rule 304.b.(2).B criteria met for existing Pad 25A and 36A is Rule 304.b.(2).B.vii (location immediately upgradient from a riparian corridor). Additionally, a portion of Pad 36A is subject to Rule 304.b.(2).B.viii (high priority habitat). 2. Rule 304.b.(2).C.ii – Table Showing Information Required by Rules 304.b.(3).A and B. Tables 2 and 3 provide the Cultural Distance data required by Rules 304.b.(3).A and B. There are no municipal or county boundaries within 2,000 feet of the locations [Rule 304.b.(2).C.iii.cc]. Table 2. Cultural Features (Distance and Bearing) Existing2 Proposed Alternative Locations Cultural Feature1 Pad 25 (ft) Pad 36 (ft) Pad 31 (ft) Alt 1 (ft) Alt 2 (ft) Alt 3 (ft) Surface Water 310 S 60 W 560 NE 550 S 510 N 500 W HPH – aquatic 0 0 50 NE 20 SE 20 N 20 W Elk Production HPH 4320 E 5380 NE 2120 E 3910 E 5130 E 5350 E Elk Winter Conc. HPH 6320 NE 8300 NE 4130 NE 5220 NE 7360 NE 8360 NE Building 8830 NW 9210 E 7360 SE 7010 NW 9820 E 8860 NE Residential Building 8830 NW 9210 E 7360 SE 7010 NW 9820 E 8860 NE U.S. Forest Service 2070 N 1840 S 1460 N 110 N 3360 N 1090 S Property Line 2070 N 1840 S 1460 N 110 N 3360 N 1090 S Public Road (FS 824) 2540 NE 5870 N 1650 NW 920 NE 3870 NE 6390 N HOBU2 5280+ N 5280+ N 5280+ N 5280+ N 5280+ N 5280+ N School 5280+ N 5280+ N 5280+ N 5280+ N 5280+ N 5280+ N Above-ground Utility 5280+ N 5280+ N 5280+ N 5280+ N 5280+ N 5280+ N Railroad 5280+ N 5280+ N 5280+ N 5280+ N 5280+ N 5280+ N Designated Outside Activity Area 5280+ N 5280+ N 5280+ N 5280+ N 5280+ N 5280+ N Disproportionately Impacted Community 5280+ N 5280+ N 5280+ N 5280+ N 5280+ N 5280+ N 1Measured from the edge of the Working Pad Surface. 2High Occupancy Building Unit. Table 3. Cultural Features within 2,000’ of Working Pad Surface of the Existing, Proposed, and Alternative Locations Cultural Feature 0-500’ 501-1,000’ 1,001-2,000’ Building units, residential building units, high occupancy building units, school properties, school facilities, designated outdoor activity areas 0 0 0 c. Each federal, state, or local government designated park or open space partially or wholly located within the proposed area of mineral development The existing Pads 25A and 36A, proposed Pad 31, and alternative locations are all surface locations on CPX private land. The private surface would be used to develop CPX minerals and federal mineral leases. d. Each known area containing environmental contamination partially or wholly located within the proposed area of mineral development (as identified on COGCC, DRMS, and/or CDPHE databases) There are no identified areas containing environmental contamination. e. Each public road right of way Access to CPX oil and gas locations on Tepee Park Ranch is provide by County Road 317, National Forest Service Road 824, and CPX private access. CPX Piceance Holdings, LLC 34 S. Wynden Drive, Suite 240 Limited Impact Review Garfield County, Colorado Houston, TX 77056 TPR Well Pad 36A Article 9 Oil and Gas Permit Application October 21, 2022 Garfield County Pre- Application Meeting Request 34 S. Wynden Dr. Ste 240 Houston, TX 77056 Phone: 713-554-9031 Sent via Electronic Mail October 21, 2022 Ms. Sheryl Bower, Director Community Development Department 108 8th St, Suite 401 Glenwood Springs, CO 81601 RE: Garfield County Oil and Gas Permit Second Pre-Application Meeting Dear Ms. Bower, CPX Piceance Holdings, LLC would like to initiate a second pre-application meeting with Garfield County regarding an Oil and Gas Permit application. The meeting will follow up on the initial pre-application meeting between CPX and Garfield County on September 15, 2021. We would like to propose that the meeting be conducted in early November by conference or video call. The meeting will be specific to continued development of CPX’s existing TPR Well Pad 36A (Pad 36A). Pad 36A is owned and operated by CPX in the SW¼NE¼, Section 36, Township 7 South, Range 94 West. Pad coordinates are 39.395017, -107.831908. Pad 36A is an existing well pad. The Pad 36A disturbance is complete. The pad is stable. It will not be expanded. CPX plans to submit an Oil and Gas Development Plan (OGDP) application to the Colorado Oil and Gas Conservation Commission (COGCC) to: (1) develop and produce 32 new natural gas wells on Pad 36A; and (2) use Pad 36A as a frac support pad for natural gas wells drilled on other locations on TPR. Pad 36A is subject to the requirements of Article 9 of the Garfield County Land Use and Development Code (LUDC) for Oil and Gas Locations that require analysis of alternative locations under COGCC Rule 304.b.(2).B. See LUDC 9-201.F.1. An alternative location analysis is required for Pad 36A because a portion of the pad is located within 300 feet of Rule 1202.c.(1).R designated cutthroat trout high priority habitat (HPH) and it is immediately upgradient from, a mapped visible, or field-verified wetland or riparian corridor. See COGCC Rules 304.b.2.(B).vii–viii. On June 18, 2021, Colorado Parks & Wildlife (CPW) issued CPX a waiver from Rule 1202.c.(1).R for the portion of the pad with 500 feet of cutthroat trout habitat and made a written recommendation for a variance pursuant to Rule 309.e.(5).E for the portion of the pad located within 300 feet of cutthroat trout habitat. CPW reaffirmed its findings in writing on July 13, 2022. The CPW letters are provided in Attachment B to the Pad 36A Alternative Location Analysis accompanying this pre-application request. 2 In its documentation, CPW stated that it incentivizes the use of already disturbed locations when no adverse impacts are anticipated. CPW further stated that construction of a new location, instead of continued use of the existing location, would cause more undesired disturbance and habitat fragmentation, and would pose more risk to high priority habitat and the watershed. Separately, CPX submitted an OGDP and Form 2A application to COGCC on March 31, 2022, for additional natural gas wells on CPX’s existing Pad 25A. CPX submitted an OGDP and Form 2A application to COGCC on August 2, 2022, for a temporary water support pad, Pad 25B. Garfield County received notice for both applications. Neither location required an Oil and Gas Permit under LUDC Article 9. COGCC approved the TPR Pad 25A OGDP and TPR Pad 25B OGDP on September 21, 2022. Garfield County LUDC 9-203.A anticipates a pre-application process with the county before the applicant initiates an application to COGCC. CPX and Garfield County had an initial pre-application meeting regarding CPX’s proposed development plans on TPR and Pad 36A on September 15, 2021. Given the passage of time, CPX believes a follow-up meeting is warranted and would be beneficial. LUDC 9-203.B.1 requires that the pre-application meeting request be accompanied by an Alternative Location Analysis that includes the information required by COGCC Rule 304.b.(2).C. The Pad 36A Alternative Location Analysis accompanies this letter. CPX prepared the Alternative Location Analysis in accordance with COGCC’s Operator Guidance for Rule 304.b.(2) Alternative Location Analyses (December 15, 2020). In addition to the Rule 304.b.(2).C Alternative Location Analysis, LUDC 9-203.B.1 requires that the applicant submit the following information with the pre-application meeting request:  Proposed area of mineral development: The proposed area of mineral development is shown in the figures included in Attachment A to the Pad 36A Alternative Location Analysis.  Each federal, state, or local government designated park or open space partially or wholly located within the proposed area of mineral development: There is no state or local government designated park or open space partially or wholly located within the proposed area of mineral development. Pad 36A will laterally develop federal minerals that underlie federal surface managed by the United States Forest Service. There is no proposed surface disturbance on Forest Service lands.  Each known area containing environmental contamination partially or wholly located within the proposed area of mineral development (as identified on COGCC, DRMS, and/or CDPHE databases): There are no identified areas containing environmental contamination.  Each public road right of way: Pad 36A does not require public road rights-of-way. Access to Pad 36A uses CR 320, CR 317, FS 824, and the private Tepee Park Ranch Road. 3 If you have questions regarding this letter, please contact me at nick@cpxpiceance.com or (713) 554-9031. We look forward to scheduling a time to meet and discuss CPX’s proposed development. Thank you, Nicholas Kurtenbach, Principal CPX Piceance Holdings, LLC Enclosure: TPR Well Pad 36A Alternative Location Analysis TPR Well Pad 36A Alternative Location Analysis CPX Piceance Holdings, LLC 34 S. Wynden Drive, Suite 240 Houston, TX 77056 October 2022 Alternative Location Analysis Narrative CPX Piceance Holdings, LLC TPR Well Pad 36A COGCC Location ID #334460 Overview CPX Piceance Holdings, LLC (CPX) has prepared this Alternative Location Analysis (ALA) for TPR Well Pad 36A (Pad 36A) to comply with requirements in Colorado Oil and Gas Conservation Commission (COGCC) Rule 304.b.(2).B. Pad 36A is an existing well pad located on CPX’s privately owned Tepee Park Ranch (TPR) in Garfield County. CPX plans to request approval from COGCC to (1) develop and produce 32 new natural gas wells on Pad 36A and (2) use Pad 36A as a frac support pad for natural gas wells drilled on other locations on TPR. COGCC Rules 304.b.(2).B.vii and viii apply to Pad 36A and require that CPX submit this ALA as part of the Pad 36A Oil and Gas Development Plan (OGDP) application. Specifically, the ALA is required by: Rule 304.b.2.(B).vii The proposed Oil and Gas Location is within the boundaries of, or is immediately upgradient from, a mapped visible, or field-verified wetland or riparian corridor. Rule 304.b.2.(B).viii The proposed Oil and Gas Location is within High Priority Habitat (HPH) and the Operator did not obtain a waiver from Colorado Parks & Wildlife (CPW) through a pre-application consultation. The ALA describes the five locations summarized in Table 1. Attachments to the ALA include figures illustrating each location (Attachment A) and a detailed matrix of alternatives (Attachment B). COGCC’s tier system to rank alternatives is provided in Attachment C. The analysis was conducted in accordance with COGCC’s Operator Guidance for Rule 304.b.(2) Alternative Location Analysis (December 15, 2020). Table 1. Alternative Locations 1See explanation of COGCC tier system in Attachment C. 2 Each well pad can typically contain 32 to 36 wells. The number of reachable bottom holes represents the flexibility and opportunity to select among minerals and bottom holes from a location. Location COGCC Tier1 Surface Ownership 304.b.(2).B.vii 304.b.(2).B.viii Reachable Bottom Holes2 Proposed 36A V-A Private CPX Yes Yes 32 Alternative 1 I-A Private CPX No No 49 Alternative 2 I-A Federal No No 50 Alternative 3 I-A Private CPX No No 57 Alternative 4 II-A Private CPX No No 64 Alternative Location Analysis CPX Piceance Holdings, LLC 2 TPR is located at an elevation greater than 9,000 feet. The steep topography on TPR and the surrounding area limits feasible alternatives to construct an Oil and Gas Location. The alternatives identified in Table 1 and described in this analysis are based on the available area outside of Rule 1202.c.(1).R HPH for cutthroat trout that can feasibly support a well pad while also accessing the Mineral Development Area. 1.0 Proposed Use of Existing Pad 36A Pad 36A is an existing well pad located on TPR private property owned by CPX. The location is: Section 36, Township 7 South, Range 94 West 39.395017 / -107.831908 CPX proposes to develop 32 new natural gas wells from the existing Pad 36A. 25 of the proposed wells will develop CPX fee minerals and 7 wells will develop federal minerals leased by CPX. Pad 36A is at an elevation of 9,355 feet. It is greater than 1 mile from any cultural features (e.g., residential building units). Pad 36A was constructed in 2008. The Oil and Gas Location is 5.45 acres. The Working Pad Surface is 2.06 acres (Figure 1, below). There are three previously permitted wells on Pad 36A (Figure 2, below). They are: #132-36 (API #05-045-16949) Conductor and casing set DG (Spud/Not Completed) #143-36 (API #05-04516950) Conductor set EP (Expired Permit) #112-6 (API #05-045-16951) Conductor set EP (Expired Permit) Pad 36A is not within terrestrial HPH. It is upgradient of a riparian corridor and is within both 500 feet and 300 feet of Rule 1202.c.(1).R HPH for cutthroat trout designated crucial habitat and native fish and other native aquatic species conservation waters. CPW granted CPX a waiver for the portion of the pad within 500 feet of cutthroat HPH on June 18, 2021. A smaller portion of the pad is within 300 feet of cutthroat HPH. CPW provided CPX with a written recommendation for a variance for the continued use of this portion of Pad 36A on June 18, 2021. CPW reaffirmed its findings on July 13, 2022 in documentation restating the June 18, 2021 letter. CPW documentation is shown in Attachment D. Prior to granting the waiver and variance recommendation, CPW conducted a pre-application formal consultation and on-site review of Pad 36A on May 27, 2021. In its June 18, 2021 documentation, CPW stated that “Pad 36A is well-established” and that “CPW incentivizes the use of already disturbed Figure 2. Existing Pad 36A Figure 1. Pad 36A Permitted Wells Alternative Location Analysis CPX Piceance Holdings, LLC 3 locations when no adverse impacts are anticipated.” CPW added that the “following items provided CPW staff with confidence in their support of the variance request:  A lined steel secondary containment will avoid the potential for spill & leaks to impact surface water  An engineered drain from the pad to a lined perimeter trench  A catchment system to avoid storm water runoff is in place  No erosion is anticipated due to the maturity of the pad surface & established vegetation  Dust suppression measures will be taken to avoid impacts on Beaver Creek.” CPW concluded that: “An alternative location for Pad 36A was considered; however, construction at an alternative location would cause undesired habitat fragmentation and pose more risk to High Priority Habitats and the watershed” (Attachment D). 1.1 Advantages  Pad 36A will reuse an existing Oil and Gas Location and Working Pad Surface.  Using the existing Oil and Gas Location supports CPX’s development plans to minimize new surface disturbance on TPR and rely on existing well pads, the existing TPR access road, and existing buried pipelines to the maximum extent practicable to support new natural gas development.  Pad 36A is on low-angle topography, which minimized cut and fill slopes and the disturbed area at the time the pad was constructed.  Vegetation removal, soil disturbance, earth moving, and grading are complete.  Disturbed soil is compacted and stabilized.  The Working Pad Surface, fill slope, and cut slope have high structural integrity. This is demonstrated by the 14 years that the location has avoided stormwater runoff and contamination of surface water.  The pad has 2-foot earthen berms compacted to 95 percent soil/moisture density. The berms are vegetated with 80 percent vegetative cover.  There is no uncontrolled stormwater on Pad 36A. The pad has a 6-inch drain at the center. The drain is piped outside of the berm to a lined trench. The trench drains to a lined sediment basin. Solids settle in the sediment basin for removal. The stormwater evaporates.  Access road construction is complete. CPX uses the existing private TPR road to access Pad 36A. The road has an engineered borrow ditch on the upslope side to protect against erosion. Stormwater is diverted to 18-inch and 24-inch culverts spaced at 600-foot intervals to avoid long runs of stormwater and to slow stormwater velocity.  During production, CPX plans to use buried flowlines located adjacent to the existing TPR road. 1.2 Disadvantages Pad 36A was constructed before the COGCC’s initial cutthroat trout HPH designation went into effect. During the 2019 Mission Change rulemaking, COGCC expanded the cutthroat HPH buffer to 500 feet and revised the requirements around the 300-foot buffer . The pad is now bisected roughly as shown Alternative Location Analysis CPX Piceance Holdings, LLC 4 here in red in Figure 3. The northeast portion of Pad 36A is within 500 feet of HPH. The southwest portion of Pad 36A is within 300 feet of HPH. 1.3 Potential Impacts to Public Health, Safety, Welfare, the Environment, and Wildlife Resources The pad’s proximity to Beaver Creek and cutthroat trout HPH creates potential for impacts to the environment and wildlife resources. Potential impacts are avoided or minimized by the BMPs listed above, with concurrence from CPW. 1.4 Permitting Considerations The continued use of the portion of Pad 36A within 300 feet of Rule 1202.c.(1).R HPH will require a variance under COGCC Rule 502. CPW provided CPX with a written recommendation for a variance for the continued use of this portion of Pad 36A and granted a waiver for the portion of the pad between 300 and 500 feet of cutthroat HPH on June 18, 2021. CPW reaffirmed its findings on July 13, 2022, in documentation restating the June 18, 2021 letter (Attachment D). 1.5 Availability The location is constructed and available for development with no additional disturbance. 1.6 COGCC Tier Classification Tier V-A: Under the COGCC’s December 15, 2020 Operator Guidance, the location is classified as Tier V-A because a portion of the location is within 300 feet of Rule 1202.c.(1).R HPH, which requires a variance from COGCC, and because the location can fully develop the minerals proposed by the Form 2A. 2.0 Alternative 1 Alternative 1 would be a new Oil and Gas Location on CPX’s private surface on TPR. The alternative location is: Section 36, Township 7 South, Range 94 West 39.391355 / -107.830500 The location could reach up to 51 bottom hole locations for directionally drilled natural gas wells: 31 wells in CPX fee minerals and 20 wells in federal minerals leased by CPX. The location is at an elevation of approximately 9,700 feet. It is outside of HPH. It is greater than 1 mile from any cultural features. The Oil and Gas Location would be 5.3 acres. The Working Pad Surface would be 2.8 acres. The location would require an approximate 80-foot cut slope with approximately 120,000 cubic yards of disturbed soil. The location would repurpose a historical logging road located on TPR (Figure 4, below). The road requires improvements to make it accessible to support well development. They include removal of mature stands of trees, road widening, installing switchbacks, adding surface material, and installing stormwater controls and armoring. The road would be approximately 4,421 feet long with an approximate 520-foot elevation change. Road grades are approximately 7 to 21 percent. The road would cross the U.S. Forest Service Battlement Trail. Figure 3. 300' v. 500' Cutthroat Trout HPH Buffer on the Pad Alternative Location Analysis CPX Piceance Holdings, LLC 5 Portions of the road would cross HPH for cutthroat trout and require agreement from CPW with BMPs under Rule 1202.c.(2).C. 2.1 Advantages  The alternative is on CPX private property.  The boundary of the nearest 500-foot HPH buffer for cutthroat trout is 130 feet south of the Working Pad Surface.  The nearest residential building unit is greater than 1 mile northeast.  The nearest terrestrial HPH (Elk Production Area) is approximately 5,220 northeast.  The nearest downgradient water is a drainage mapped as intermittent by the USGS, approximately 630 feet south. 2.2 Disadvantages  The location would be new disturbance requiring removal of stands of trees and the understory of vegetation.  The location fragments undisturbed habitat in mature aspen and Engelmann spruce forest.  The area’s steep terrain would require expansion of the location size to provide tie into existing grades for cut and fill slopes.  The location requires an approximate 80-foot cut slope and approximately 120,000 cubic yards of disturbed soil.  Steep cut and fill slopes are difficult to stabilize and revegetate. They are more prone to erosion and stormwater runoff.  Approximately 4,421 feet of access road reconstruction would be required. The road would be widened and surfaced.  The access road would have slopes of approximately 7 to 21 percent. The steepest cut slopes along the access would require rock armoring, rather than revegetation.  Access road stormwater culverts would divert runoff under the road. Drainage from the culverts would run downslope toward Beaver Creek.  The grades and tight switchbacks on the access road introduce a safety risk for drivers and loads. The risk increases during wet weather and winter months. Under similar conditions, in 2018 CPX designed and financed the removal of steep grades and tight switchback on U.S. Forest Service Road 824 to eliminate the safety risk for CPX and public traffic.  The access road would cross the Battlement Trail.  Additional haul traffic is required for construction of the location, access, and flowlines. Figure 4. A historical logging road would require tree removal, widening, switchbacks, surfacing, and stormwater controls. Alternative Location Analysis CPX Piceance Holdings, LLC 6  Surface frac lines would run cross country from the permitted Pad 25A to the location to support well completions. The remote location of the frac lines would introduce new disturbance and complicate monitoring for integrity of the frac lines.  Additional engines would be needed for horsepower to maintain pressure for frac lines in steep terrain.  A new flowline trench and construction disturbance would be needed for natural gas, condensate, and produced water flowlines to run cross country from the location to a tie in at CPX’s existing Pad 25A. 2.3 Potential Impacts to Public Health, Safety, Welfare, the Environment, and Wildlife Resources Potential impacts from the construction and development of Alternative 1 include new disturbance in an undisturbed area of forest for pad construction, road construction, and flowlines. There is potential for erosion and stormwater runoff from clearing and grading in steep terrain. The access road introduces further potential for erosion. Stormwater would divert under the access road and drain downslope toward Beaver Creek. There is a safety risk to drivers and loads from road grades as high as 21 percent, particularly during wet and inclement weather. 2.4 Permitting Considerations Portions of the road construction and flowline corridor clearing would require agreement from CPW with BMPs in accordance with Rule 1202.c.(2).C. The alternative would require Forest Service agreement for the access road and flowlines to cross the Battlement Trail. 2.5 Availability The location is on private property owned by CPX. Subject to coordination with CPW and the Forest Service for road construction and flowline corridor clearing, the location is available for development by CPX. 2.6 COGCC Tier Classification Tier I-A: Under the COGCC’s December 15, 2020 Operator Guidance, the location is classified as Tier I- A because no Rule 304.b.(2).B ALA criteria are met and the location can fully develop the minerals proposed by the Form 2A. 3.0 Alternative 2 Alternative 2 would be a new Oil and Gas Location located on U.S. Forest Service land adjacent to TPR. The alternative location is: Section 36, Township 7 South, Range 94 West 39.386676 / -107.829265 The location could reach up to 48 bottom hole locations for directionally drilled natural gas wells: 32 wells in CPX fee minerals and 16 wells in federal minerals leased by CPX. Alternative 2 would be located on Forest Service land. A location on Forest Service land fulfills a request from Garfield County in September 2021 to consider an area outside of CPX’s private TPR surface. The location is at an elevation of approximately 9,720 feet. It is outside of HPH. It is greater than 1 mile from any cultural features. Alternative Location Analysis CPX Piceance Holdings, LLC 7 The Oil and Gas Location would be 5.3 acres. The Working Pad Surface would be 2.8 acres. The location would require an approximate 80-foot cut slope with approximately 160,000 cubic yards of disturbed soil. The location would repurpose the historical logging road. The road requires improvements to make it accessible to support well development. The road would also require new road construction to the south, across additional HPH buffer to reach the location. The road would be approximately 5,831 feet long with an approximate 780-foot elevation change. Road grades are approximately 7 to 22 percent. The road would cross the Battlement Trail. Portions of the road would also cross multiple mapped HPH buffers for cutthroat trout and require agreement from CPW with BMPs under Rule 1202.c.(2).C. The alternative location is designated “No Surface Occupancy” per the terms of a mineral lease issued to CPX by the Bureau of Land Management (BLM) (COC-79154). The alternative location is designated by the Forest Service as part of the Mamm Peak Roadless Area. Under lease COC-79154 there are no exceptions to the No Surface Occupancy designation. According to the lease, the No Surface Occupancy designation may be modified only if an environmental analysis determines that the boundary of the roadless area has been modified. The Forest Service and BLM may grant a waiver only if an environmental analysis determines that the entire leasehold no longer contains portions of a designated roadless area. 3.1 Advantages  The boundary of the nearest 500-foot HPH buffer for cutthroat trout is 50 feet north of the Working Pad Surface.  The nearest residential building unit is greater than 1 mile northeast.  The nearest terrestrial HPH (Elk Production Area) is approximately 5,590 feet northeast.  The nearest downgradient water is a drainage mapped as intermittent by the USGS, approximately 550 feet north. 3.2 Disadvantages  The alternative is located on Forest Service land designated as No Surface Occupancy.  The location would be new disturbance requiring removal of stands of trees and the understory of vegetation.  The location fragments undisturbed habitat in mature aspen and Engelmann spruce forest on federal land (Figure 5, below).  The area’s steep terrain and narrow land availability between cutthroat trout HPH buffers would expand and elongate the location size to provide tie into existing grades for cut and fill slopes.  The location requires an approximate 80-foot cut slope and approximately 160,000 cubic yards of disturbed soil.  Steep cut and fill slopes are difficult to stabilize and revegetate. They are more prone to erosion and stormwater runoff.  Approximately 5,831 feet of access road reconstruction would be required. The road would be widened and surfaced.  A portion of the access would require new road construction to the south in Roadless Area to access the location.  The access road will have slopes of approximately 7 to 22 percent. The steepest cut slopes along the access require rock armoring, rather than revegetation. Alternative Location Analysis CPX Piceance Holdings, LLC 8  Access road stormwater culverts would divert runoff under the road. Drainage from the culverts would run downslope toward Beaver Creek.  The grades on the access road introduce a safety risk for drivers and loads. The risk increases during wet weather and winter months.  The access road would cross the Battlement Trail.  Additional haul traffic would be required for construction of the location, access, and flowlines.  Surface frac lines would run cross country from the permitted Pad 25A to the location to support well completions. The remote location of the frac lines would introduce new disturbance and complicate monitoring for integrity of the frac lines.  Portions of the frac lines would be surface lines across Forest Service land.  Additional engines would be needed for horsepower to maintain pressure for frac lines in steep terrain.  A new flowline trench and construction disturbance would be needed for natural gas, condensate, and produced water flowlines to run cross country from the location to a tie in at CPX’s existing Pad 25A. 3.3 Potential Impacts to Public Health, Safety, Welfare, the Environment, and Wildlife Resources Potential impacts from the construction and development of Alternative 2 include new disturbance in an undisturbed area of forest for pad construction, road construction, and flowlines. There is potential for erosion and stormwater runoff from clearing and grading in steep terrain. The access road would introduce further potential for erosion. Stormwater would divert under the access road and drain downslope toward Beaver Creek. There is a safety risk to drivers and loads from road grades as high as 22 percent, particularly during wet and inclement weather. The location, new access, and portions of the flowlines would also be on Forest Service land designated as Roadless Area and No Surface Occupancy. The federal designation is intended to avoid habitat fragmentation and human activity. The location, road, and flowlines would impact the wildlife and habitat resource values of the federal Roadless Area. 3.4 Permitting Considerations Portions of road construction and flowline corridor clearing would require agreement from CPW with BMPs in accordance with Rule 1202.c.(2).C. The alternative would require Forest Service agreement for the access road and flowlines to cross the Battlement Trail. Figure 5. View of mature Engelmann spruce forest Alternative Location Analysis CPX Piceance Holdings, LLC 9 The location cannot be approved by the Forest Service as an exception or waiver without a change to the Roadless Area boundary or the Roadless Area designation under the leasehold. 3.5 Availability The location is designated as No Surface Occupancy by the Forest Service and is not presently available for development. 3.6 COGCC Tier Classification Tier I-B: Under the COGCC’s December 15, 2020 Operator Guidance, the location is classified as Tier I- B because no Rule 304.b.(2).B ALA criteria are met, and the location cannot fully reach and develop the minerals proposed by the Form 2A for Pad 36A. 4.0 Alternative 3 Alternative 3 would be a new Oil and Gas Location on CPX’s private surface on TPR. The alternative location is: Section 6, Township 8 South, Range 93 West 39.393592 / -107.824613 The location could reach up to 55 bottom hole locations for directionally drilled natural gas wells: 45 wells in CPX fee minerals and 10 wells in federal minerals leased to CPX. The location is at an elevation of approximately 10,100 feet. It is outside of HPH. It is greater than 1 mile from any cultural features. The Oil and Gas Location would be 4.8 acres. The Working Pad Surface would be 2.8 acres. The location would require an approximate 15-foot cut slope with approximately 20,000 cubic yards of disturbed soil. The location would repurpose the historical logging road. The road requires improvements to make it accessible to support well development. The road would also require reconstruction to the east for additional elevation gain and multiple newly constructed switchbacks. The road would be approximately 8,513 feet long with an approximate 900-foot elevation change. Road grades are approximately 6 to 21 percent. The road would cross the Battlement Trail. Portions of the road would cross multiple mapped HPH buffers for cutthroat trout and require agreement from CPW with BMPs in accordance with Rule 1202.c.(2).C. 4.1 Advantages  The alternative is on CPX private property.  The boundary of the nearest 500-foot HPH buffer for cutthroat trout is 100 feet west of the Working Pad Surface.  The nearest residential building unit is greater than 1 mile northeast.  The nearest terrestrial HPH (Elk Production Area) is approximately 3,450 feet northeast.  The nearest downgradient water is a drainage mapped as intermittent by the USGS, approximately 600 feet west.  The location uses a ridgetop area that is flatter than Alternatives 1 and 2. 4.2 Disadvantages  The location on a ridgetop at approximately 10,100 feet increases exposure and the effects of winter conditions on equipment and personnel. Alternative Location Analysis CPX Piceance Holdings, LLC 10  The ridgetop environment makes it more difficult to mitigate impacts from noise and light during well drilling and completions.  Approximately 8,513 feet of access road reconstruction would be required. The road would be widened and surfaced.  The access road will have slopes of approximately 6 to 21 percent. The steepest cut slopes along the access require rock armoring, rather than revegetation.  Access road stormwater culverts would divert runoff under the road. Drainage from the culverts would run downslope toward Beaver Creek.  Multiple newly constructed switchbacks would need to be constructed to make the road accessible for haul traffic. The switchbacks would be in HPH for cutthroat trout.  The grades on the access road introduce a safety risk for drivers and loads. The risk increases during wet weather and winter months.  The safety risk from the road grades is sufficiently high that certain haul loads would require snubbing. This is the practice of hitching an additional piece of equipment, such as a bulldozer, to a haul load. The additional equipment adds wheels or treads and braking to the haul load to avoid a runaway.  The access road would cross the Battlement Trail.  Additional haul traffic would be required for construction of the location, access, and flowlines.  Surface frac lines would run cross country from the permitted Pad 25A to the location to support well completions. The remote location of the frac lines would introduce new disturbance and complicate monitoring for integrity of the frac lines.  Additional engines are needed for horsepower to maintain pressure for frac lines in steep terrain.  A new flowline trench and construction disturbance would be needed for natural gas, condensate, and produced water flowlines to run cross country from the location to a tie in at CPX’s existing Pad 25A. 4.3 Potential Impacts to Public Health, Safety, Welfare, the Environment, and Wildlife Resources Potential impacts from the construction and development of Alternative 3 include new disturbance in an undisturbed area of forest for pad construction, road construction, and flowlines. There is potential for erosion and stormwater runoff from clearing and grading in steep terrain. Road construction would be significant because of the distance to the location and required switchbacks. There Figure 6. Illustration of the remote area where flowlines would run cross country Alternative Location Analysis CPX Piceance Holdings, LLC 11 is high potential for erosion and stormwater runoff from the road. Stormwater would divert under the access road and drain downslope toward Beaver Creek. There is a significant safety risk to drivers and loads from extended steep grades and multiple switchbacks. Certain haul loads would require snubbing to prevent accidents and spills. The ridgetop exposure of the location increases potential for noise and light to impact wildlife. 4.4 Permitting Considerations Portions of road construction and flowline corridor clearing would require agreement from CPW with BMPs in accordance with Rule 1202.c.(2).C. The alternative would require Forest Service agreement for the access road and flowlines to cross the Battlement Trail. 4.5 Availability The location is on private property owned by CPX. Subject to coordination with CPW and the Forest Service for road construction and flowline corridor clearing, the location is available for development by CPX. 4.6 COGCC Tier Classification Tier I-A: Under the COGCC’s December 15, 2020 Operator Guidance, the location is classified as Tier I- A because no Rule 304.b.(2).B ALA criteria are met, and the location can fully develop the minerals proposed by the Form 2A. 5.0 Alternative 4 Alternative 4 would be a new Oil and Gas Location on CPX’s private surface on TPR. The alternative location is: Section 6, Township 8 South, Range 93 West 39.390927 / -107.825075 The location could reach up to 62 bottom hole locations for directionally drilled natural gas wells: 50 wells in CPX fee minerals and 12 wells in federal minerals leased to CPX. The location is at an elevation of approximately 10,170 feet. It is outside of HPH. It is greater than 1 mile from any cultural features. The Oil and Gas Location would be 4.9 acres. The Working Pad Surface would be 2.9 acres. The location would require an approximate 25-foot cut slope with approximately 30,000 cubic yards of disturbed soil. The location would repurpose the historical logging road. The road requires improvements to make it accessible to support well development. The road would also require reconstruction to the east for additional elevation gain and multiple newly constructed switchbacks. The road would be approximately 8,667 feet long with an approximate 960-foot elevation change. Road grades are approximately 6 to 22 percent. The road would cross the Battlement Trail. Portions of the road would cross multiple mapped HPH buffers for cutthroat trout and require agreement from CPW with BMPs in accordance with Rule 1202.c.(2).C. 5.1 Advantages  The alternative is on CPX private property.  The boundary of the nearest 500-foot HPH buffer for cutthroat trout is 450 feet northwest of the Working Pad Surface. Alternative Location Analysis CPX Piceance Holdings, LLC 12  The nearest residential building unit is greater than 1 mile northeast.  The nearest terrestrial HPH (Elk Production Area) is approximately 3,910 feet east.  The location uses a ridgetop area that is flatter than Alternatives 1 and 2 and more consistent with Alternative 3. 5.2 Disadvantages  The nearest downgradient water is a drainage mapped as intermittent by the USGS approximately 320 feet east. It is in the Mamm Creek drainage, which is east of TPR. The proximity has potential to meet Rule 1202.a.(3) criteria.  The location on a ridgetop at approximately 10,170 feet increases exposure and the effects of winter conditions on equipment and personnel.  The ridgetop environment makes it more difficult to mitigate impacts from noise and light during well drilling and completions.  Approximately 8,667 feet of access road reconstruction would be required. The road would be widened and surfaced.  The access road would have slopes of approximately 6 to 22 percent. The steepest cut slopes along the access road would require rock armoring, rather than revegetation.  Access road stormwater culverts would divert runoff under the road. Drainage from the culverts would run downslope toward Beaver Creek.  Multiple newly constructed switchbacks would need to be constructed to make the road accessible for haul traffic. The switchbacks would be in HPH for cutthroat trout.  The grades on the access road introduce a safety risk for drivers and loads. The risk increases during wet weather and winter months.  The safety risk from the road grades is sufficiently high that certain haul loads would require snubbing.  The access road would cross the Battlement Trail.  Additional haul traffic would be required for construction of the location, access, and flowlines.  Surface frac lines would run cross country from the permitted Pad 25A to the location to support well completions. The remote location of the frac lines would introduce new disturbance and complicate monitoring for integrity of the frac lines.  Additional engines would be needed for horsepower to maintain pressure for frac lines in steep terrain.  A new flowline trench and construction disturbance would be needed for natural gas, condensate, and produced water flowlines to run cross country from the location to a tie in at CPX’s existing Pad 25A. 5.3 Potential Impacts to Public Health, Safety, Welfare, the Environment, and Wildlife Resources Potential impacts from the construction and development of Alternative 4 include new disturbance in an undisturbed area of forest for pad construction, road construction, and flowlines. Alternative Location Analysis CPX Piceance Holdings, LLC 13 Road construction would be significant because of the distance to the location and required switchbacks. There is high potential for erosion and stormwater runoff from the road. Stormwater would divert under the access road and drain downslope toward Beaver Creek. There is a significant safety risk to drivers and loads from extended steep grades and multiple switchbacks. Certain haul loads would require snubbing to prevent accidents and spills. The ridgetop exposure of the location increases potential for noise and light to impact wildlife. Potential for the mapped feature east of the location to be considered an intermittent waterbody under 1202.a.3 would require consultation with CPW and potential for mitigation and BMPs. 5.4 Permitting Considerations Portions of road construction and flowline corridor clearing would require agreement from CPW with BMPs in accordance with Rule 1202.c.(2).C. Potential for the mapped feature east of the location to be considered an intermittent waterbody could require consultation with CPW under Rule 1202.a.3 for staging or chemical storage within 500 feet of a mapped intermittent. The alternative would require Forest Service agreement for the access road and flowlines to cross the Battlement Trail. 5.5 Availability The location is on private property owned by CPX. Subject to coordination with CPW and the Forest Service for road construction and flowline corridor clearing, the location is available for development by CPX. 5.6 COGCC Tier Classification Tier I-A: Under the COGCC’s December 15, 2020 Operator Guidance, the location is classified as Tier I- A because no Rule 304.b.(2).B ALA criteria are met, and the location can fully develop the minerals proposed by the Form 2A. 6.0 Conclusion CPX plans to request COGCC approval to use CPX’s existing Pad 36A on TPR for development and production of 32 natural gas wells. Soil disturbance and haul traffic for construction are complete. Pad 36A is approximately 14 years old. It is well constructed and stabilized. Its structural integrity is demonstrated by the 14 years the Location has avoided stormwater runoff and contamination of surface water. The pad has three layers of control for stormwater and potential leaks or spills: steel secondary containment; a 2-foot compacted earthen berm; and an engineered stormwater system with a drain, lined diversion ditch, and lined sediment basin. Use of Pad 36A reuses existing infrastructure. It avoids new disturbance in undisturbed forest. It helps realize CPX’s 5 years of development planning, coordinated with COGCC, Garfield County, the Forest Service, and BLM in which CPX rerouted FS 824 away from cutthroat trout HPH; built stormwater diversions and armored culverts along FS 824; buried natural gas, condensate, and water flowlines; and built a new pad for condensate and produced water loadout off of TPR. The improvements were conducted with the goal of developing TPR in the least impactful and most efficient manner possible by relying on the existing well pads already constructed on TPR. Alternative Location Analysis CPX Piceance Holdings, LLC 14 CPX already has a waiver and a recommendation for a variance from CPW for use of Pad 36A. The findings from CPW address Pad 36A’s location in cutthroat trout HPH and its location immediately upgradient of a riparian corridor. CPW found that Pad 36A is well established; its BMPs will address any concerns from development; and reuse of the existing location is preferred to new disturbance. Pad 36A does not meet any other criteria under Rule 304.b.(2).B. CPX identified four alternative locations that are outside of Rule 1202.c.(1).R HPH for cutthroat trout, can support a well pad, and can access the proposed Mineral Development Area. Every available alternative location represents greater potential impacts than Pad 36A. In each case, the alternatives are still within 50 to 450 feet of the boundary of the HPH buffer for cutthroat trout because the prevalence of mapped habitat buffers, steep terrain, and access prevents greater distancing. The soil disturbance to construct the locations ranges from 30,000 to 160,000 cubic yards. For comparison, a typical bulldozer moves approximately 2,000 cubic yards of soil per day, and a typical tandem dump truck holds just 9 to 10 cubic yards of soil per load. Consequently, the construction haul traffic to replace Pad 36A with a new location is significant. New soil disturbance from constructing an alternative location and access road represents potential for erosion and runoff, in contrast to the stability and well-vegetated berms on the existing Pad 36A and the established TPR road. Runoff potential from new road construction is increased by the stormwater culverts that would, by necessity, drain downslope toward Beaver Creek. Beaver Creek is the habitat that the alternative analysis is intended to protect. The alternatives fragment undisturbed forest or ridges. They require logging, salvage, timber sale, and then brush hogging and grubbing for the understory. Civil design in steep terrain requires that cut and fill slopes tie into existing grades, which expands the disturbance needed for the pad. Revegetating steep cuts is sometimes infeasible and requires rock armoring, instead. The existing Pad 36A avoids each of these disturbance concerns. Additional disturbance and habitat fragmentation are required for flowlines for the alternative locations, both from temporary surface frac lines and buried flowlines during production. The flowlines would be routed cross country because it is impractical to follow access road switchbacks. In contrast, the flowline trench connecting existing Pad 36A to existing Pad 25A on TPR will be adjacent to the existing TPR road. The alternatives would require that haul traffic during well development and production traffic drive past Pad 36A on the existing TPR road and then turn onto a newly constructed access road that is repurposed from a historical logging road. New access would be 4,421 to 8,667 feet long. It would have between 520 and 960 feet of elevation change. It would require construction of multiple switchbacks in cutthroat trout HPH. Certain haul traffic is anticipated to need added safety measures on the steep road and switchbacks to minimize the risk of accidents that could result in spills and injury. The existing Pad 36A actually has the potential to reach fewer bottom hole locations and provides CPX with less flexibility and opportunity to select among the developable minerals and bottom holes than any of the alternatives. Development of one of the proposed alternatives would provide CPX with additional flexibility and allow CPX to pursue a more economical development by drilling more wells in CPX’s fee minerals instead of leased federal minerals. Accordingly, there is a purely economic argument for developing one of the alternative locations. Instead, CPX believes, and CPW provided its concurrence, that use of existing Pad 36A is the most protective of public health, safety, welfare, the environment, and wildlife resources. Alternative Location Analysis CPX Piceance Holdings, LLC 15 Attachments Attachment A Figures Attachment B Alternatives Matrix Attachment C COGCC Tier System Attachment D Written documentation from CPW ATTACHMENT A FIGURES ATTACHMENT A FIGURES ATTACHMENT A FIGURES ATTACHMENT A FIGURES TepeeParkForestServiceRoad824White River National Forest RanchRoadWhite River National Forest (Private)39.395017, -107.831908 CPXExistingPad 36A Alt. 3 Alt. 4Alt. 1 Alt.2T7S R94W T8S R94W T7S R94WT8S R93WT7S R94WT7S R93WT8S R93W T7S R93W 26 25 36 30 31 6 712 Legend Working Pad Surface Oil and Gas Location Forest Service Road Private Road Mineral Development Area White River National Forest Lands CPX Piceance Holdings, LLCSurface Ownership CPX Piceance Holdings, LLCMineral Ownership 100% Fee Parcels CPX Picean ce Ho ldin gs, LLCTep ee Park Ran ch Pad 36A Aota Technical, LLC Alter native Location Analysis 10/7/22Date Garfield CountySW1/4NE1/4 Sec. 36, T7S R94W, 6th P.M . 0 250 500 750 1,000 FeetMap 1Figure No. TepeeParkForestServiceRoad824White River National Forest RanchRoadWhite River National Forest (Private)39.395017, -107.831908 CPXExistingPad 36A Alt. 3 Alt. 4Alt. 1 Alt.2 CPXExistingPad 25A CPX PermittedTemporary Water Support Pad 25B T7S R94W T8S R94W T7S R94WT8S R93WT7S R94WT7S R93WT8S R93W T7S R93W 26 25 36 30 31 6 712 Legend Working Pad Surface Oil and Gas Location Forest Service Road Private Road White River National Forest Lands Parcels CPX Picean ce Ho ldin g s, LLCT epee Park Ran ch Pad 36A Aota Technical, LLC Alter native Location Analysis 10/7/22Date Garfield CountySW1/4NE1/4 Sec. 36, T7S R94W, 6th P.M . 0 250 500 750 1,000 FeetMap 2Figure No. TepeeParkForestServiceRoad824White River National Forest RanchRoadWhite River National Forest (Private)39.395017, -107.831908 CPX ExistingPad 36A304.b.(2).B.vii and viii Alt. 3 Alt. 4 Alt. 1 Alt.2 T7S R94W T8S R94W T7S R94WT8S R93WT7S R94WT7S R93WT8S R93W T7S R93W 26 25 36 30 31 6 712 LegendWorking Pad Surface Oil and Gas Location Forest Service Road Private Road White River National Forest Lands Parcels CPX Picean ce Holdin g s, LLCT epee Park Ran ch Pad 36A Aota Technical, LLC Alter native Location Analysis 10/7/22Date Garfield CountySW1/4NE1/4 Sec. 36, T7S R94W, 6th P.M . 0 250 500 750 1,000 FeetMap 3Figure No. Plan CPX Piceance Holdings, LLC Tepee Park Ranch Area Alternate Locations for Pad 36A Existing Location of Pad 36A With Reachable Williams Fork BHLs on 10 ac Spacing BHLs Reachable from Existing Pad 36A: 32 CPX Min: 25 Fed Lease: 7 Pad 25A (Existing) Pad 36A (Existing) Pad 25B (Approved) Legend CPX Surface and Mineral Ownership USFS Surface/Federal Lease Proposed Bottom Hole Location from Alt Pad Loc Maximum Rig Reach from Pad (3,500’) Topographic Contours, 40’ Contour Interval High Priority Habitat- Cutthroat Trout Township Lines Section Lines Former Logging Road Access Battlement Trail TPR Ranch Road Pad 36A Mineral Development Area Plan CPX Piceance Holdings, LLC Tepee Park Ranch Area Alternate Locations for Pad 36A Alternate Location #1 With Reachable Williams Fork BHLs on 10 ac Spacing Alt Loc #1 vs Current Pad 36A Loc Additional CPX Fee Locations: 7 Additional Federal Locations: 10 BHLs Reachable from Alt Loc #1: 49 CPX Min: 32 Fed Lease: 17 Pad 25A (Existing) Pad 36A (Existing) Pad 25B (Approved) Loc #1 Legend CPX Surface and Mineral Ownership USFS Surface/Federal Lease Proposed Bottom Hole Location from Alt Pad Loc Maximum Rig Reach from Pad (3,500’) Topographic Contours, 40’ Contour Interval High Priority Habitat- Cutthroat Trout Township Lines Section Lines Former Logging Road Access Battlement Trail TPR Ranch Road Pad 36A Mineral Development Area Plan CPX Piceance Holdings, LLC Tepee Park Ranch Area Alternate Locations for Pad 36A Alternate Location #2 With Reachable Williams Fork BHLs on 10 ac Spacing Alt Loc #2 vs Current Pad 36A Loc Additional CPX Fee Locations: 8 Additional Federal Locations: 10 BHLs Reachable from Alt Loc #2: 50 CPX Min: 33 Fed Lease: 17 Pad 25A (Existing) Pad 36A (Existing) Pad 25B (Approved) Loc #2 Legend CPX Surface and Mineral Ownership USFS Surface/Federal Lease Proposed Bottom Hole Location from Alt Pad Loc Maximum Rig Reach from Pad (3,500’) Topographic Contours, 40’ Contour Interval High Priority Habitat- Cutthroat Trout Township Lines Section Lines Former Logging Road Access Battlement Trail TPR Ranch Road Pad 36A Mineral Development Area Plan CPX Piceance Holdings, LLC Tepee Park Ranch Area Alternate Locations for Pad 36A Alternate Location #3 With Reachable Williams Fork BHLs on 10 ac Spacing Alt Loc #3 vs Current Pad 36A Loc Additional CPX Fee Locations: 21 Additional Federal Locations: 4 BHLs Reachable from Alt Loc #3: 57 CPX Min: 46 Fed Lease: 11 Pad 25A (Existing) Pad 36A (Existing) Pad 25B (Approved) Loc #3 Legend CPX Surface and Mineral Ownership USFS Surface/Federal Lease Proposed Bottom Hole Location from Alt Pad Loc Maximum Rig Reach from Pad (3,500’) Topographic Contours, 40’ Contour Interval High Priority Habitat- Cutthroat Trout Township Lines Section Lines Former Logging Road Access Battlement Trail TPR Ranch Road Pad 36A Mineral Development Area Plan CPX Piceance Holdings, LLC Tepee Park Ranch Area Alternate Locations for Pad 36A Alternate Location #4 With Reachable Williams Fork BHLs on 10 ac Spacing Alt Loc #4 vs Current Pad 36A Loc Additional CPX Fee Locations: 26 Additional Federal Locations: 6 BHLs Reachable from Alt Loc #4: 64 CPX Min: 51 Fed Lease: 13 Pad 25A (Existing) Pad 36A (Existing) Pad 25B (Approved) Loc #4 Legend CPX Surface and Mineral Ownership USFS Surface/Federal Lease Proposed Bottom Hole Location from Alt Pad Loc Maximum Rig Reach from Pad (3,500’) Topographic Contours, 40’ Contour Interval High Priority Habitat- Cutthroat Trout Township Lines Section Lines Former Logging Road Access Battlement Trail TPR Ranch Road Pad 36A Mineral Development Area Plan CPX Piceance Holdings, LLC Tepee Park Ranch Area Alternate Locations for Pad 36A Pad 36A Alternate Locations #1-#4 With Former Logging RoadFormer Logging Road Access High Priority Habitat-Cutthroat Trout Legend Elev 9,360’ Terra Pad Elev 8,230’ Elev ~10,200’ View looking North Plan CPX Piceance Holdings, LLC Tepee Park Ranch Area Alternate Locations for Pad 36A Alternate Locations with Access Roads Loc #4 Pad 36A (Existing) Loc #1 Loc #2 Loc #3 8 ac for scale 5 ac for scale Loc #1 2.8 ac 5.3 ac 80’120,000 cy Loc #2 2.8 ac 5.3 ac 80’160,000 cy Loc #3 2.8 ac 4.8 ac 15’20,000cy Loc #4 2.9 ac 4.9 ac 25’30,000cy Working Pad Size O&G Location Legend Working Pad Surface Location Size Cut Est Cut Volume Loc #1 39.391355 -107.830500 Loc #2 39.386676 -107.829265 Loc #3 39.393592 -107.824613 Loc #4 39.390927 -107.825075 Latitude Longitude ATTACHMENT B ALTERNATIVES MATRIX ATTACHMENT B ALTERNATIVES MATRIX ATTACHMENT B ALTERNATIVES MATRIX 2 ATTACHMENT B ALTERNATIVES MATRIX Latitude Latitude Latitude Latitude LatitudeReference Point39.39501739.39135539.38667639.39359239.390927Distance to nearest Cultural Feature: Distance Distance Distance Distance DistanceBuilding 260' 1,620' 3,210' 2,290' 2,650'Residental Building Unit 5,280'+5,280'+5,280'+5,280'+5,280'+HOBU 5,280'+5,280'+5,280'+5,280'+5,280'+Designated Outside Activity Area 5,280'+5,280'+5,280'+5,280'+5,280'+Public Road 5,280'+5,280'+5,280'+5,280'+5,280'+Above‐ground Utility 5,280'+5,280'+5,280'+5,280'+5,280'+Railroad 5,280'+5,280'+5,280'+5,280'+5,280'+Property Line 1,830' 530' 650' 1420' 420'School Facility 5,280'+5,280'+5,280'+5,280'+5,280'+Child Care Center 5,280'+5,280'+5,280'+5,280'+5,280'+Boundary of DIC 5,280'+5,280'+5,280'+5,280'+5,280'+RBU, HOBU, or School Facility within a Disproportionately Impacted Community within 2000'5,280'+ 5,280'+ 5,280'+ 5,280'+ 5,280'+Number of cultural features within: 0‐500 feet501‐1,000 feet1,001‐2,000 feet0‐500 feet501‐1,000 feet1,001‐2,000 feet0‐500 feet 501‐1,000 feet1,001‐2,000 feet0‐500 feet501‐1,000 feet1,001‐2,000 feet0‐500 feet501‐1,000 feet1,001‐2,000 feetBUs 1 0 0 0 0 1 0 0 0 0 0 0 0 0 0RBUs 0 00 0 00 0 0 0 0 00 0 00HOBUs 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0School Properties 0 00 0 00 0 0 0 0 00 0 00School Facilities 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0DOAAs 0 00 0 00 0 0 0 0 00 0 00304.b.(2).B Criteria Met(include as many lines as needed, and provide a brief description of each criteria met)Location within DIC or within 2000' of DIC? YES or NODistance Distance Distance Distance DistanceIf YES, distance to nearest BU:If YES, distance to nearest HOBU:If YES, distance to nearest School:If YES, describe community outreach efforts per 304.b.(2).C.iiiNumber Number Number Number NumberDistance Distance Distance Distance Distance304.b.(2).C.iii.ccNameIf YES, the number and description of existing Oil and Gas Locations, Facilities, and Wells within 2000' of any RBU, HOBU, or School within 2000' of the proposed locationName NameDistance to municipal or county NameSNNEEDescriptionDescriptionDescription DescriptionNNNENE NENE NENN304.b.(2).C.iii.bbNo No No NoDirectionDirection304.b.(2).C.ii ‐‐> 304.b.(3).ADirectionDirectionDirection DirectionNW NWNWNENEProposed Location Existing Pad 36A Alt Loc 1 Alt Loc 2 Alt Loc 3Longitude Longitude LongitudeLongitude‐107.831908‐107.830500‐107.829265‐107.824613Direction DirectionEEEEEE304.b.(2).C.ii ‐‐> 304.b.(3).B|Rule 304.b.(2).B.vii ‐ The proposed Oil and Gas Location is within the boundaries of, or is immediately upgradient from, a mapped, visible, or field‐verified wetland or riparian corridor.Rule 304.b.(2).B.viii ‐ The proposed Oil and Gas Location is within HPH and the Operator did not obtain a waiver from CPW through a pre‐application consultation.None None NoneNNSS NNNNNN NNNNNNENE NENE NENNNERule 304.b.(2).B.viiNoAlt Loc 4Longitude‐107.825075DirectionNWNENENENCPX Piceance Holdings, LLCALTERNATIVE LOCATION ANALYSIS - Tepee Park Ranch Existing Well Pad 36ADirectionDescriptionNameNNSNNE None None None None NoneRelevant Local Government NameRLG land use or zoning designationRLG permitting processStatus of RLG permit if applicableCurrent Land UsePlans for future use at LocationDistance Direction Type Distance Direction Type Distance Direction Type Distance Direction Type Distance Direction Type60' to 223' W Perennial 630' S Intermittent 550' N Intermittent 600' W Intermittent 320' E IntermittentDistance Direction Description Distance Direction Type Distance Direction Type Distance Direction Type Distance Direction Type0' W 1202.c.(1).R 130' S 1202.c.(1).R 50 N 1202.c.(1).R 100' W 1202.c.(1).R 450' NW 1202.c.(1).RAnticipated method of RTCSurface Ownership604.a considerations604.b considerationsAny variance or other relief requiredTier ClassificationDescription of potential impacts to health, safety, welfare, wildlife, and the environment related to the development of this locationDescription of advantages and disadvantages associated with this locationPermitting considerations for this locationConditions or factors that make the location unavailableAny other considerationsReachable Bottom Hole LocationsCPX mineralsFederal leaseAdditional InformationCompliant Compliant Compliant CompliantOperator owns surface Operator owns surface Federal Surface LeasePermit Not Required Permit Required Permit Not RequiredOperator owns surfaceOperator Operator U.S. Forest Service Operator304.b.(2).C.iii.ffDistance to nearest wetland, surface water (Waters of the State), surface water supply area, or PWS supply well (Type III aquifer or GUDI) based on public data304.b.(2).C.iii.ggDistance to nearest HPH304.b.(2).C.iii.hh304.b.(2).C.iii.eeOil and Gas DevelopmentForest / RangelandR ‐ RuralU.S. Forest Service Garfield CountyR ‐ Rural Federal Surface Lease R ‐ Rural304.b.(2).C.iii.ddGarfield Countyboundaries within 2000', and names of the Proximate Local Government(s)Garfield CountyExisting and formerly permitted O&G Location Requires new disturbance in forest habitat with new road building in HPH. The area is designated by the U.S. Forest Service as the Mamm Peak Roadless Area. The BLM mineral lease designates it No Surface Occupancy.Requires new disturbance in forest habitat and steep terrain with new road building in HPH.See ALA Narrative See ALA NarrativeSee ALA Narrative See ALA Narrative See ALA Narrative See ALA NarrativeSee ALA NarrativeThe following items should be answered in a written narrative format and attached to the Form 2A as "ALA Narrative Summary" (PDF format)See ALA Narrative See ALA Narrative See ALA Narrative See ALA NarrativeSee ALA NarrativeSee ALA NarrativeSee ALA Narrative See ALA NarrativeSee ALA NarrativeCompliantCompliantTier I‐A Tier I‐ACompliant CompliantRule 309.e.(5).E ‐ CPW may make written recommendations on whether a variancerequest pursuant to Rule 502 should be granted, under what conditions, and thereasons for any such recommendations, including requests for variances from Rule1202.c.(1).Q–S. The CPW recommendation was granted on 6/18/21 and reaffirmed by CPW on 7/13/22.None The area is designated by the U.S. Forest Service as the Mamm Peak Roadless Area. The BLM mineral lease designates it No Surface Occupancy.NoneTier V‐ATier I‐AForest / Rangeland ForestOil and Gas Development Forest / Rangeland Forest Forest / RangelandOil and Gas Permit RequiredSubmittedNARequires new disturbance in forest habitat and steep terrain with new road building in HPH.Garfield CountyR ‐ RuralPermit Not RequiredNAForest / RangelandForest / RangelandOperator owns surfaceOperatorCompliantCompliantNoneTier II‐ASee ALA NarrativeSee ALA NarrativeSee ALA NarrativeSee ALA NarrativeProjected Well Development327491750175711641325 32 33 46 51 ATTACHMENT C COGCC TIER SYSTEM ATTACHMENT C COGCC TIER SYSTEM ATTACHMENT C COGCC TIER SYSTEM 3 ATTACHMENT C COGCC TIER SYSTEM Tier Which 304.b.(2).B criteria does the alternative location meet? Rules 604 (setbacks) and 1202 (HPH) considerations:Siting-related Variances or other Relief considerations: Can the alternative location fully develop the minerals proposed by the 2A? Tier I No criteria met •Complies with 604.a setbacks •604.a.(2) exception avoided •604.a.(4) consent avoided •604.b conditions avoided •Complies with 1200-series No variance required Yes: Tier I-A No: Tier I-B Tier II One criterion met: iii, iv, v, vi, vii, or ix •Complies with 604.a setbacks •604.a.(2) exception avoided •604.a.(4) consent avoided •604.b conditions avoided •Complies with 1200-series No variance required Yes: Tier II-A No: Tier II-B Tier III (Note:If CPW waives ALA per 304.b.(2).B.viii, criterion viii is not met) One criterion met: i*or viii† *HOBU is not a school or child care center. †HPH is 1202.c.(1).R, S, or T, and CPW waives the application of the rule, or HPH is 1202.d. •Complies with 604.a setbacks •604.a.(2) exception avoided or satisfied •604.a.(4) consent avoided or satisfied •604.b conditions avoided or satisfied For criterion viii: •If HPH is 1202.d: CPW-approved Wildlife Mitigation Plan and Compensatory Mitigation required No variance required For criterion viii: •If HPH is 1202.c.(2).R, S, or T: Director’s exception required Yes: Tier III-A No: Tier III-B Tier IV Two or more criteria met: i*, iii, iv, v, vi, vii, viii†, ix, or x* *HOBU is not a school or child care center. †HPH is 1202.c.(1).R, S, or T, and CPW waives the application of the rule, or HPH is 1202.d. •Complies with 604.a setbacks •604.a.(2) exception avoided or satisfied •604.a.(4) consent avoided or satisfied •604.b conditions avoided or satisfied For criterion viii: •If HPH is 1202.d: CPW-approved Wildlife Mitigation Plan and Compensatory Mitigation required No variance required For criterion viii: •If HPH is 1202.c.(2).R, S, or T: Director’s exception required Yes:Tier IV-A No: Tier IV-B Tier V Criteria i**, ii, viii‡, or x** met, or, any Location that requires a variance for siting considerations **HOBU is a school or child care center. ‡HPH is 1202.c.(1).A-T and CPW has not waived Varies For criteria i, ii, or x: variance required for 604.a.(3). For criterion viii: variance required for 1202.c. Any Location that requires a siting- related variance. Yes:Tier V-A No: Tier V-B TIER CLASSIFICATION SYSTEM FOR QUICK ASSESSMENT OF PROPOSED AND ALTERNATIVE LOCATIONS BASED ON 304.b.(2).B CRITERIA, SITING CONSIDERATIONS, VARIANCES, AND MINERAL DEVELOPMENT DRAFT 12/15/2020 ATTACHMENT D WRITTEN DOCUMENTATION FROM CPW ATTACHMENT D WRITTEN DOCUMENTATION FROM CPW ATTACHMENT D WRITTEN DOCUMENTATION FROM CPW 4 ATTACHMENT D WRITTEN DOCUMENTATION FROM CPW Grand Junction Service Center Northwest Regional Office 711 Independent Ave. Grand Junction, CO, 81505 P 970-255-6100 | F 970-255-6111 Dan Prenzlow, Director, Colorado Parks and Wildlife • Parks and Wildlife Commission: Marvin McDaniel, Chair  Carrie Besnette Hauser, Vice-Chair Marie Haskett, Secretary  Taishya Adams  Betsy Blecha  Charles Garcia  Dallas May  Duke Phillips, IV  Luke B. Schafer  James Jay Tutchton  Eden Vardy CPX Piceance Holdings 6/18/2021 34 S. Wynden Dr. Suite 300 Houston, Texas 77056 Dear CPX Piceance Holdings, Colorado Parks and Wildlife (CPW) has a statutory responsibility to manage all wildlife species in Colorado and consultation obligations for certain oil and gas operations regulated by the Colorado Oil and Gas Conservation Commission (COGCC). As a result of CPW consultation, detailed in COGCC Rule 309.e.(5).E, “CPW may also make written recommendations on whether a variance pursuant to Rule 502 should be granted, under what conditions, and the reasons for any such recommendations, including requests for variances from Rules 1202.c.(1)Q-S. The Commission will consider the written recommendations of CPW…” This serves as CPW’s written recommendation in support of CPX’s request for a variance from Rule 1202.c.(1).R on Pad 36A. Pad 36A is partially situated within 300 feet of Beaver Creek, which is cutthroat trout designated crucial habitat and native fish and other native aquatic species conservation waters. However, Pad 36A is well-established. This location was constructed in 2008 and received an exception to interim reclamation requirements. CPW incentivizes the use of already disturbed locations when no adverse impacts are anticipated. CPW staff toured Pad 36A on May 27, 2021, to verify that this location was appropriate for a variance. A variance would allow CPX to continue the use of an existing location, access roads, and off-location flowlines. The following items provided CPW staff with confidence in their support of the variance request: A lined steel secondary containment will avoid the potential for spills & leaks to impact surface water An engineered drain from the pad to a lined perimeter trench A catchment system to avoid storm water runoff is in place No erosion is anticipated due to the maturity of the pad surface & established vegetation Dust suppression measure will be taken to avoid impacts on Beaver Creek Additionally, CPX indicated that the existing tertiary containment perimeter berm could be reinstalled after interim reclamation. CPX has agreed to all operating requirements listed in Rule 309.e.(5)D.i.aa-ee to obtain a waiver in 1202.c.(1).R habitats. Considering this, CPW issues a waiver for portions of Pad 36A that are outside of the variance zone. An alternative location for Pad 36A was considered; however, construction at an alternative location would cause undesired habitat fragmentation and pose more risk to High Priority Habitats and the watershed. Colorado Parks & Wildlife values the opportunity to provide comments on this proposal. If you have any questions or concerns, please reach out to Taylor Elm, Energy Liaison, at (970) 986-9767. Sincerely, Kirk Oldham Area Wildlife Manager Cc. Travis ByBee, District Wildlife Manager Taylor Elm, Northwest Region Energy Liaison Danielle Neumann, Northwest Region Land Use Specialist File. Grand Junction Service Center Northwest Regional Office 711 Independent Avenue Grand Junction, CO 81505 P 970.255.6100 Heather Dugan, Acting Director, Colorado Parks and Wildlife • Dan Prenzlow, Director, Colorado Parks and Wildlife Parks and Wildlife Commission: Carrie Besnette Hauser, Chair  Dallas May, Vice-Chair  Marie Haskett, Secretary  Taishya Adams Karen Bailey  Betsy Blecha  Gabriel Otero  Duke Phillips, IV  Richard Reading  James Jay Tutchton  Eden Vardy CPX Piceance Holdings 7/13/2022 34 S. Wynden Dr. Suite 300 Houston, Texas 77056 Dear CPX Piceance Holdings, Colorado Parks and Wildlife (CPW) has a statutory responsibility to manage all wildlife species in Colorado and consultation obligations for certain oil and gas operations regulated by the Colorado Oil and Gas Conservation Commission (COGCC). As a result of CPW consultation, detailed in COGCC Rule 309.e.(5).E, “CPW may also make written recommendations on whether a variance pursuant to Rule 502 should be granted, under what conditions, and the reasons for any such recommendations, including requests for variances from Rules 1202.c.(1)Q-S. The Commission will consider the written recommendations of CPW…” This serves as CPW’s written recommendation in support of CPX’s request for a variance from Rule 1202.c.(1).R on Pad 36A. Pad 36A is partially situated within 300 feet of Beaver Creek, which is cutthroat trout designated crucial habitat and native fish and other native aquatic species conservation waters. However, Pad 36A is well-established. This location was constructed in 2008 and received an exception to interim reclamation requirements. CPW incentivizes the use of already disturbed locations when no adverse impacts are anticipated. CPW staff toured Pad 36A on May 27, 2021, to verify that this location was appropriate for a variance. A variance would allow CPX to continue the use of an existing location, access roads, and off-location flow lines. The following items provided CPW staff with confidence in their support of the variance request:  A lined steel secondary containment will avoid the potential for spills & leaks to impact surface water  An engineered drain from the pad to a lined perimeter trench  A catchment system to avoid storm water runoff is in place  No erosion is anticipated due to the maturity of the pad surface & established vegetation  Dust suppression measure will be taken to avoid impacts on Beaver Creek Additionally, CPX indicated that the existing tertiary containment perimeter berm could be reinstalled after interim reclamation. CPX has agreed to all operating requirements listed in Rule 309.e.(5)D.i.aa- ee to obtain a waiver in 1202.c.(1).R habitats. Considering this, CPW issues a waiver for portions of Pad 36A that are outside of the variance zone. An alternative location for Pad 36A was considered; however, construction at an alternative location would cause undesired habitat fragmentation and pose more risk to High Priority Habitats and the watershed. Colorado Parks & Wildlife values the opportunity to provide comments on this proposal. If you have any questions or concerns, please reach out to Taylor Elm, Energy Liaison, at (970) 986-9767. Sincerely, Kirk Oldham Area Wildlife Manager Cc. Travis ByBee, District Wildlife Manager Taylor Elm, Northwest Region Energy Liaison File.