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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 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 1. Existing Pad 36A Figure 2. 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 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 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 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. 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 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. 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 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. 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 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. 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 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.