HomeMy WebLinkAbout1.08 Alternative Location AnalysisCPX 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 I: Alternative Location
Analysis
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 51
Alternative 2 I-B Federal No No 50
Alternative 3 I-A Private CPX No No 57
Alternative 4 I-A Private CPX No No 64
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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 1. Existing Pad 36A Figure 2. Pad 36A Permitted Wells
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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 on the well pad. The
drain is piped outside of the berm to a lined trench. The trench drains to a lined catchment basin.
Solids settle in the catchment 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
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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
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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 grades 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.
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• 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 50 bottom hole locations for directionally drilled natural gas wells: 33 wells
in CPX fee minerals and 17 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.
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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.
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• 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
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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 57 bottom hole locations for directionally drilled natural gas wells: 46 wells
in CPX fee minerals and 11 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.
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• 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
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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 64 bottom hole locations for directionally drilled natural gas wells: 51 wells
in CPX fee minerals and 13 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.
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• 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.
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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
26
25 T7S R94W
T8S R93W
NN SSAX4 \
36 v ; ~x<
== cex //_): eS ee ww ii / eho Existing 'S/, ola
Pad 36A — L cae
a oo 6 39.395017, -107.831908 JL Alt.3
AI. a A
fe / Alt. 4
T7S R94W ae
T8S R94W
Z
Aota Technical, LLC Legend
CPX Piceance Holdings, LLC Cc] Working Pad Surface | White River National Forest Lands
Tepee Park Ranch Pad 36A 1 = Oiland Gas Location >) GPX Piceance Holdings, LLC N
~~ . Surface Ownership Alt ti L ti A I . == Forest Service Road ernative Location Analysis A CPX Piceance Holdings, LLC Garfield County y Private Road Cc] Mineral Ownership 100% Fee |
SW1/4NE1/4 Sec. 36, T7S R94W, 6th P.M. Mineral Development Area CI) Parcels
Date Figure No. 0 250 500 750 1,000
10/7/22 Map 1 Feat
26
25 T7S R94W
T8S R93W
NN SSAX4 \
36 v ; ~x<
== cex //_): eS ee ww ii / eho Existing 'S/, ola
Pad 36A — L cae
a oo 6 39.395017, -107.831908 JL Alt.3
AI. a A
fe / Alt. 4
T7S R94W ae
T8S R94W
Z
Aota Technical, LLC Legend
CPX Piceance Holdings, LLC Cc] Working Pad Surface | White River National Forest Lands
Tepee Park Ranch Pad 36A 1 = Oiland Gas Location >) GPX Piceance Holdings, LLC N
~~ . Surface Ownership Alt ti L ti A I . == Forest Service Road ernative Location Analysis A CPX Piceance Holdings, LLC Garfield County y Private Road Cc] Mineral Ownership 100% Fee |
SW1/4NE1/4 Sec. 36, T7S R94W, 6th P.M. Mineral Development Area CI) Parcels
Date Figure No. 0 250 500 750 1,000
10/7/22 Map 1 Feat 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: 6
Additional Federal Locations: 13
BHLs Reachable from Alt Loc #1: 51
CPX Min: 31
Fed Lease: 20
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
2
ATTACHMENT B
ALTERNATIVES MATRIX
CPX Piceance Holdings, LLC
ALTERNATIVE LOCATION ANALYSIS - Tepee Park Ranch Existing Well Pad 36A
Proposed Location Existing Pad 36A Alt Loc 1 Alt Loc 2 Alt Loc 3 Alt Loc 4
Latitude Longitude Latitude Longitude Latitude Longitude Latitude Longitude Latitude Longitude
Reference Point 39.395017 -107.831908 39.391355 -107.830500 39.386676 -107.829265 39.393592 -107.824613 39.390927 -107.825075
304.b.(2).C.ii --> 304.b.(3).A
Distance to nearest Cultural
Feature: Distance Direction Distance Direction Distance Direction Distance Direction Distance Direction
Building 260' NW 1,620' NW 3,210' N 2,290' NW 2,650' NW
Residental Building Unit 5,280'+ NE 5,280'+ NE 5,280'+ NE 5,280'+ NE 5,280'+ NE
HOBU 5,280'+ NE 5,280'+ NE 5,280'+ NE 5,280'+ NE 5,280'+ NE
Designated Outside Activity Area 5,280'+ NE 5,280'+ NE 5,280'+ NE 5,280'+ NE 5,280'+ NE
Public Road 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N
Above-ground Utility 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N
Railroad 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N
Property Line 1,830' S 530' S 650' N 1420' S 420' S
School Facility 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N
Child Care Center 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N
Boundary of DIC 5,280'+ E 5,280'+ E 5,280'+ E 5,280'+ E 5,280'+ E
RBU, HOBU, or School Facility 5,280'+ E 5,280'+ E 5,280'+ E 5,280'+ E 5,280'+ E
within a Disproportionately
Impacted Community within 2000"
304.b.(2).C.ii --> 304.b.(3).B
Number of cultural features 0-500 feet 501-1,000 1,001-2,000 0-500 feet 501-1,000 1,001-2,000 0-500 feet 501-1,000 feet 1,001-2,000 0-500 feet 501-1,000 1,001-2,000 0-500 feet 501-1,000 1,001-2,000
within: feet feet feet feet feet feet feet feet feet
BUs 1 0 0 0 0 1 0 0 0 0 0 0 0 0 0
RBUs 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
HOBUs 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
School Properties 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
School Facilities 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
DOAAs 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
|
304.b.(2).B Criteria Met Rule 304.b.(2).B.vii - The proposed Oil and Gas None None None None
(include as many lines as needed, _| Location is within the boundaries of, or is
and provide a brief description of _ |immediately upgradient from, a mapped, visible,
each criteria met) 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.
304.b.(2).C.iii.bb
Location within DIC or within 2000" No No No No No
of DIC? YES or NO
Distance Direction Distance Direction Distance Direction Distance Direction Distance Direction
If 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. iii
If YES, the number and description Number Description Number Description Number Description Number Description Number Description
of existing Oil and Gas Locations,
Facilities, and Wells within 2000' of
any RBU, HOBU, or School within
2000' of the proposed location
304.b.(2).C.iii.cc
Distance to municipal or county Distance Name Distance Name Distance Name Distance Name Distance Name
CPX Piceance Holdings, LLC
ALTERNATIVE LOCATION ANALYSIS - Tepee Park Ranch Existing Well Pad 36A
Proposed Location Existing Pad 36A Alt Loc 1 Alt Loc 2 Alt Loc 3 Alt Loc 4
Latitude Longitude Latitude Longitude Latitude Longitude Latitude Longitude Latitude Longitude
Reference Point 39.395017 -107.831908 39.391355 -107.830500 39.386676 -107.829265 39.393592 -107.824613 39.390927 -107.825075
304.b.(2).C.ii --> 304.b.(3).A
Distance to nearest Cultural
Feature: Distance Direction Distance Direction Distance Direction Distance Direction Distance Direction
Building 260' NW 1,620' NW 3,210' N 2,290' NW 2,650' NW
Residental Building Unit 5,280'+ NE 5,280'+ NE 5,280'+ NE 5,280'+ NE 5,280'+ NE
HOBU 5,280'+ NE 5,280'+ NE 5,280'+ NE 5,280'+ NE 5,280'+ NE
Designated Outside Activity Area 5,280'+ NE 5,280'+ NE 5,280'+ NE 5,280'+ NE 5,280'+ NE
Public Road 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N
Above-ground Utility 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N
Railroad 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N
Property Line 1,830' S 530' S 650' N 1420' S 420' S
School Facility 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N
Child Care Center 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N 5,280'+ N
Boundary of DIC 5,280'+ E 5,280'+ E 5,280'+ E 5,280'+ E 5,280'+ E
RBU, HOBU, or School Facility 5,280'+ E 5,280'+ E 5,280'+ E 5,280'+ E 5,280'+ E
within a Disproportionately
Impacted Community within 2000"
304.b.(2).C.ii --> 304.b.(3).B
Number of cultural features 0-500 feet 501-1,000 1,001-2,000 0-500 feet 501-1,000 1,001-2,000 0-500 feet 501-1,000 feet 1,001-2,000 0-500 feet 501-1,000 1,001-2,000 0-500 feet 501-1,000 1,001-2,000
within: feet feet feet feet feet feet feet feet feet
BUs 1 0 0 0 0 1 0 0 0 0 0 0 0 0 0
RBUs 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
HOBUs 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
School Properties 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
School Facilities 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
DOAAs 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
|
304.b.(2).B Criteria Met Rule 304.b.(2).B.vii - The proposed Oil and Gas None None None None
(include as many lines as needed, _| Location is within the boundaries of, or is
and provide a brief description of _ |immediately upgradient from, a mapped, visible,
each criteria met) 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.
304.b.(2).C.iii.bb
Location within DIC or within 2000" No No No No No
of DIC? YES or NO
Distance Direction Distance Direction Distance Direction Distance Direction Distance Direction
If 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. iii
If YES, the number and description Number Description Number Description Number Description Number Description Number Description
of existing Oil and Gas Locations,
Facilities, and Wells within 2000' of
any RBU, HOBU, or School within
2000' of the proposed location
304.b.(2).C.iii.cc
Distance to municipal or county Distance Name Distance Name Distance Name Distance Name Distance Name
Latitude Latitude Latitude Latitude Latitude
Reference Point 39.395017 39.391355 39.386676 39.393592 39.390927
Distance to nearest Cultural
Feature: Distance Distance Distance Distance Distance
Building 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 feet 501-1,000
feet
1,001-2,000
feet 0-500 feet 501-1,000
feet
1,001-2,000
feet 0-500 feet 501-1,000 feet
1,001-2,000
feet 0-500 feet 501-1,000
feet
1,001-2,000
feet 0-500 feet 501-1,000
feet
1,001-2,000
feet
BUs 1 0 0 0 0 1 0 0 0 0 0 0 0 0 0
RBUs 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
HOBUs 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
School Properties 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
School Facilities 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
DOAAs 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
304.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 NO
Distance Distance Distance Distance Distance
If 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.iii
Number Number Number Number Number
Distance Distance Distance Distance Distance
CPX Piceance Holdings, LLC
ALTERNATIVE LOCATION ANALYSIS - Tepee Park Ranch Existing Well Pad 36A
Direction
Description
Name
N
N
S
N
N
E
E
None
No
Alt Loc 4
Longitude
-107.825075
Direction
NW
NE
NE
NE
NN
N
N
N
NE
NE NE
NE NE
N
N
NN N
S S N
N NN
N N N
Direction Direction
E E
E E
E
E
304.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 None
Proposed Location Existing Pad 36A Alt Loc 1 Alt Loc 2 Alt Loc 3
Longitude Longitude LongitudeLongitude
-107.831908 -107.830500 -107.829265 -107.824613
304.b.(2).C.ii --> 304.b.(3).A
Direction DirectionDirection Direction
NW NW NW
NE NE
DescriptionDescription Description
N
N
NE
NE NE
NE NE
N
N
304.b.(2).C.iii.bb
No No No No
Direction Direction
S
N
N
E
E
Description
304.b.(2).C.iii.cc
Name
If 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 location
Name Name
Distance to municipal or county
boundaries within 2000', and
Name
None None None None None
Relevant Local Government Name
RLG land use or zoning designation
RLG permitting process
Status of RLG permit if applicable
Current Land Use
Plans for future use at Location
Distance Direction Type Distance Direction Type Distance Direction Type Distance Direction Type Distance Direction Type
130' to 223' W Perennial 630' S Intermittent 550' N Intermittent 600' W Intermittent 320' E Intermittent
Distance Direction Description Distance Direction Type Distance Direction Type Distance Direction Type Distance Direction Type
0' 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).R
Anticipated method of RTC
Surface Ownership
604.a considerations
604.b considerations
Any variance or other relief
required
Tier Classification
Description of potential impacts to
health, safety, welfare, wildlife, and
the environment related to the
development of this location
Description of advantages and
disadvantages associated with this
location
Permitting considerations for this
location
Conditions or factors that make the
location unavailable
Any other considerations
Reachable Bottom Hole Locations
CPX minerals
Federal lease
Projected Well Development
32
7
51
20
50
17
57
11
64
13
25 31 33 46 51
Compliant
Compliant
None
Tier I-A
See ALA Narrative
See ALA Narrative
See ALA Narrative
See ALA Narrative
Requires new disturbance in forest habitat and
steep terrain with new road building in HPH.
Garfield County
R - Rural
Permit Not Required
NA
Forest / Rangeland
Forest / Rangeland
Operator owns surface
Operator
Forest / Rangeland Forest
Oil and Gas Development Forest / Rangeland Forest Forest / Rangeland
Oil and Gas Permit Required
Submitted NA
Compliant Compliant
Tier I-A Tier I-B
Compliant Compliant
Rule 309.e.(5).E - CPW may make written
recommendations on whether a variance
request pursuant to Rule 502 should be granted,
under what conditions, and the
reasons for any such recommendations, including
requests for variances from Rule
1202.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.
None
Tier V-A Tier I-A
The 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 Narrative
See ALA Narrative See ALA Narrative
See ALA Narrative See ALA NarrativeSee ALA Narrative
Existing 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 Narrative
See ALA Narrative See ALA Narrative See ALA Narrative See ALA Narrative
See ALA Narrative
R - Rural
U.S. Forest Service Garfield County
R - Rural Federal Surface Lease R - Rural
304.b.(2).C.iii.dd
Garfield County
boundaries within 2000', and
names of the Proximate Local
Government(s)
Garfield County
Additional Information
Compliant Compliant Compliant Compliant
Operator owns surface Operator owns surface Federal Surface Lease
Permit Not Required Permit Required Permit Not Required
Operator owns surface
Operator Operator U.S. Forest Service Operator
304.b.(2).C.iii.ff
Distance to nearest wetland,
surface water (Waters of the State),
surface water supply area, or PWS
supply well (Type III aquifer or
GUDI)
304.b.(2).C.iii.gg
Distance to nearest HPH
304.b.(2).C.iii.hh
304.b.(2).C.iii.ee
Oil and Gas Development Forest / Rangeland
ATTACHMENT C
COGCC TIER SYSTEM
3
ATTACHMENT C
COGCC TIER SYSTEM
TIER CLASSIFICATION SYSTEM FOR QUICK ASSESSMENT OF PROPOSED AND ALTERNATIVE LOCATIONS BASED ON 304.b.(2).B CRITERIA,
SITING CONSIDERATIONS, VARIANCES, AND MINERAL DEVELOPMENT
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:
DRAFT 12/15/2020
Can the alternative location
fully develop the minerals
Tier |
Tier Il
Tier Ill
(Note: If CPW waives
ALA per 304.b.(2).B.viii,
criterion viii is not met)
Tier IV
Tier V
No criteria met
One criterion met:
iii, iv, v, vi, vii, or ix
One criterion met: i* or viiit
*HOBU is not a school or child care center.
THPH is 1202.c.(1).R, S, or T, and CPW
waives the application of the rule, or HPH
is 1202.d.
Two or more criteria met:
i*, iii, iv, v, vi, vii, viiit, ix, or x*
*HOBU is not a school or child care center.
THPH is 1202.c.(1).R, S, or T, and CPW
waives the application of the rule, or HPH
is 1202.d.
Criteria i**, ii, viiit, 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
° Complies with 604.a setbacks
e 604.a.(2) exception avoided
¢ 604.a.(4) consent avoided
° 604.b conditions avoided
° Complies with 1200-series
° Complies with 604.a setbacks
° 604.a.(2) exception avoided
° 604.a.(4) consent avoided
° 604.b conditions avoided
° Complies with 1200-series
° Complies with 604.a setbacks
° 604.a.(2) exception avoided or satisfied
e 604.a.(4) consent avoided or satisfied
° 604.b conditions avoided or satisfied
For criterion viii:
e If HPH is 1202.d: CPW-approved Wildlife Mitigation
Plan and Compensatory Mitigation required
° 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:
e If HPH is 1202.d: CPW-approved Wildlife Mitigation
Plan and Compensatory Mitigation required
Varies
No variance required
No variance required
No variance required
For criterion viii:
e If HPH is 1202.c.(2).R, S, or T:
Director’s exception required
No variance required
For criterion viii:
e If HPH is 1202.c.(2).R, S, or T:
Director’s exception required
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.
proposed by the 2A?
Yes: Tier I-A No: Tier I-B
Yes: Tier II-A No: Tier II-B
Yes: Tier III-A No: Tier III-B
Yes: Tier IV-A No: Tier IV-B
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
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:
DRAFT 12/15/2020
Can the alternative location
fully develop the minerals
Tier |
Tier Il
Tier Ill
(Note: If CPW waives
ALA per 304.b.(2).B.viii,
criterion viii is not met)
Tier IV
Tier V
No criteria met
One criterion met:
iii, iv, v, vi, vii, or ix
One criterion met: i* or viiit
*HOBU is not a school or child care center.
THPH is 1202.c.(1).R, S, or T, and CPW
waives the application of the rule, or HPH
is 1202.d.
Two or more criteria met:
i*, iii, iv, v, vi, vii, viiit, ix, or x*
*HOBU is not a school or child care center.
THPH is 1202.c.(1).R, S, or T, and CPW
waives the application of the rule, or HPH
is 1202.d.
Criteria i**, ii, viiit, 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
° Complies with 604.a setbacks
e 604.a.(2) exception avoided
¢ 604.a.(4) consent avoided
° 604.b conditions avoided
° Complies with 1200-series
° Complies with 604.a setbacks
° 604.a.(2) exception avoided
° 604.a.(4) consent avoided
° 604.b conditions avoided
° Complies with 1200-series
° Complies with 604.a setbacks
° 604.a.(2) exception avoided or satisfied
e 604.a.(4) consent avoided or satisfied
° 604.b conditions avoided or satisfied
For criterion viii:
e If HPH is 1202.d: CPW-approved Wildlife Mitigation
Plan and Compensatory Mitigation required
° 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:
e If HPH is 1202.d: CPW-approved Wildlife Mitigation
Plan and Compensatory Mitigation required
Varies
No variance required
No variance required
No variance required
For criterion viii:
e If HPH is 1202.c.(2).R, S, or T:
Director’s exception required
No variance required
For criterion viii:
e If HPH is 1202.c.(2).R, S, or T:
Director’s exception required
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.
proposed by the 2A?
Yes: Tier I-A No: Tier I-B
Yes: Tier II-A No: Tier II-B
Yes: Tier III-A No: Tier III-B
Yes: Tier IV-A No: Tier IV-B
Yes: Tier V-A No: Tier V-B
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
4
ATTACHMENT D
WRITTEN DOCUMENTATION FROM CPW
COLORADO
Parks and Wildlife
Department of Natural Resources
Grand Junction Service Center
Northwest Regional Office
711 Independent Ave.
Grand Junction, CO, 81505
P 970-255-6100 | F 970-255-6111
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:
e A lined steel secondary containment will avoid the potential for spills & leaks
to impact surface water
e An engineered drain from the pad to a lined perimeter trench
e Acatchment system to avoid storm water runoff is in place
e No erosion is anticipated due to the maturity of the pad surface & established
vegetation
e Dust suppression measure will be taken to avoid impacts on Beaver Creek
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 e Charles Garcia ¢ Dallas May ¢ Duke Phillips, lV e Luke B. Schafer ¢ James Jay Tutchton ¢
Edan Viarchs
COLORADO
Parks and Wildlife
Department of Natural Resources
Grand Junction Service Center
Northwest Regional Office
711 Independent Ave.
Grand Junction, CO, 81505
P 970-255-6100 | F 970-255-6111
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:
e A lined steel secondary containment will avoid the potential for spills & leaks
to impact surface water
e An engineered drain from the pad to a lined perimeter trench
e Acatchment system to avoid storm water runoff is in place
e No erosion is anticipated due to the maturity of the pad surface & established
vegetation
e Dust suppression measure will be taken to avoid impacts on Beaver Creek
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 e Charles Garcia ¢ Dallas May ¢ Duke Phillips, lV e Luke B. Schafer ¢ James Jay Tutchton ¢
Edan Viarchs
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.