HomeMy WebLinkAboutReponse to Comments^JbEQe?eofJohn Plano
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Attachments:
Lisa Click <lclick@caerusoilandgas.com>
Tuesday, February 20,2024 9:01 AM
John Plano
Glenn Hartmann
RE: Pipe Line Comments
Letter from Vegetation Manager.pdf; Letter from Engineer.pdf; MF to Williams 16in
Pipeline-WetlandEvaluation-022024.pdf; CDPS General Permit COR400000 Admin
Continued Letter (1).pdf
I t", don't often get email from lclick@caerusoilandgas.com. Learn whv this is important
Good Morning John!
Thank you for the review of this permit apptication. Letter from Engineer items of concern are addressed below:
1. Addressed in the attached 'MF to Wittiams 16 in Pipetine-WettandEvaluation-022024.pdt'
2. Addressed in the attached 'MF to Wittiams 16 in Pipetine-WettandEvatuation-022024.pdt'
3. We have the bond in hand in the requested amount of $15,510. WiLt detiver as soon as all items of the
permit apptication are addressed and sufficient.
4. Addressed in the attached 'CDPS General Permit COR40000 Admin Continued Letter.'This is the permit
continuation letter from CDPHE stating our permit renewal application has been reviewed and is deemed
complete which extends our permit coverage until April L,2024. The Division of Water Quality will issue a
renewal certification upon the effective date of the renewal of the general permit. Once we receive the
Renewed Permit Certification, Caerus will provide to Garfield County.
Ptease tet me know if you need anything additionat to approve of this grading permit.
I appreciate your hetp!
Thank you,
Liss Click
Regulatory Analyst
Caerus Oil and Gas LLC
143 Diamond Ave
Parachute, CO 81635
P:970-986-0594
TAERUS
From: Joh n Pla no <jpla no@garfield-county.com>
Sent: Wednesday, February L4,2024 2:35 PM
To: Lisa Click <lclick@caerusoilandgas.com>
1
Cc: G len n Ha rtma nn <gha rtma nn @garfield-county.com>
Subject: Pipe Line Comments
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Hi Lisa,
I believe you have already taken care of the County's Vegetation Manager's concerns.
Please see the letter from the County's Consultant Engineer. #3 in his letter appears to be addressed
We will need the other items addressed prior to issuance of the permit.
Sincerely,
John Plano
Garfield County
Chief Building Official
108 8th Street, Suite 401
Glenwood Springs, CO 81501
(970) 94s-1377 (1s60)
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2
MOUNTAIN EROSS
ENGINEERING, INC.
Givll and Environmental Consulting and Design
February 14,2024
Mr. John Plano
Garfield County Planning
108 8th Street, Suite 401
Glenwood Springs, CO 81601
RE: Grading Permit, Caerus - Williams to Middle Fork 16'o: GRAD-02-24'8514
Dear John:
This offrce has reviewed the documents provided for the Grading Permit application of the
Williams to Middle Fork 16" Pipeline of Caerus Piceance, LLC. The submittal was found to be
thorough and well organized. The review generated the following comments:
1. The Applicant proposes to bore beneath the Middle Fork. This is understood to avoid any
distui'bance to the riparian area. However, the Consultant based their vegetation analysis
on previous studies and local knowledge that is to be verified in the spring. The Applicant
will need to veriff that the limits of the boring will extend beyond any impacts to water
bodies andlor wetlands prior to beginning construction.
2. Similarly, the Applicant should verifu the limits and/or extents of any 10O-year Floodplain.
Floodplain permitting may also be necessaty.
3. The Applicant should provide a cost estimate for security of revegetation and reclamation
effofis.
4. The CDPHE Stormwater Discharge permit is expiring in March 2024. The Applicant
should provide a copy of the renewed permit to Garfield County once obtained.
Feel free to call if you have any questions ot comments
Sincerely,
Cross Inc
Hale, PE
826% Grand Avenue, Glenwood Springs, CO 81601
P: 970.945.5 544 F : 970.945.5558 www.mountaincross-eng.com
CAERUS OPERATINGO LLC
MIDDLE FORK TO WILLIAMS 16.INCH PIPELINE
WETLAND EVALUATION
Prepared for:
Caerus OperatingrLLC
143 Diamond Ave.
Parachute, CO 81635
Prepared by:faa ffiEngineedng
2516 FOnE$GHT C|RCLE, #1
qRAilD JUHCNON, COLOHADO 81505
Phone: 970-241-7076
February 2024
INTRODUCTION
At the request of Caerus Operating, LLC (Caerus), WestWater Engineering (WestWater) has performed a
review of potential wetlands and Waters of the U.S. as identified on the National Wetland Inventory for
their proposed Middle Fork to Williams 16-inch Pipeline project. The results of the evaluation are
presented in this report. The proposed pipeline would be located in Garfield County, Colorado on private
lands in Sections 25 and 30, Township 5 South, Range 96 West (Figure l). Caerus plans to bore the
Middlc Fork of larachutc Crcck as dcpictcd on Figurc 2.
WestWater biologists completed a wetland evaluation of the proposed pipeline alignment, including the
bore locations, on February 16,2024. The purpose of,the wetland evaluation was to determine whether or
not wetlands and/or Waters of the U.S. (WOUS) and Waters of the State (WOS) occur with the identified
bore staging areas or any other areas along the alignment.
PROJECT AREA DESCRIPTION
Thc proposcd pipclinc would be located in the vicinity of existing oil and gas infrastructurc including
access roads, pipeline alignments, and well pads. Elevation within the project area ranges from
approximately 5,700 feet to 6,000 feet. The pipeline alignment is located in the bottom of the Middle Fork
Parachute Creek and is relatively flat, and the surrounding cliffs and steep hills rise quickly from the
valley ofParachute Creek. The project area is located near thejunction ofthe East Fork ofParachute
Creek and the West Fork of Parachute creek.
Vegetation communities within the proposed disturbance area where the bore staging areas are planned is
composed of dryland pasture grasses at the eastern bore staging location and sagebrush shrublands
intermixed with rabbitbrush at the western staging area. No hydrophlic (wetland) vegetation was
observed within the staging areas or where the pipeline will be open-trenched.
WETLAIIDS AND WATERS OF THE U.S./WATERS OF THE STATE EVALUATION
Waters of the U.S. (WoUS) include wetlands and drainages that fall under the jurisdiction of the U.S.
Army Corps of Engineers (ACOE). Perennial, intermittent, and ephemeral streams and drainages, as
indicated on U.S. Geological Survey mapping, are considered WoUS if they exhibit evidence of flow (i.e.
ordinary high-water mark - OHWM) and are hydrologically connected to a perennial sheam. In addition
to hydrology, a wetland will also demonstrate the unique soil and vegetation characteristics that result
from inundation or saturation.
Methods
WestWater biologists performed a wetland evaluation of features as indicated on the National Wetland
Inventory NWD database (USFWS 2024) for potential wetland areas along the proposed pipeline
alignment; specifically, where Caerus intends to locate the bore staging areas, as shown on Figure 2.
Determinations on the presence or absence of wetlands were based on the U.S. Army Corps of Engineers
(ACOE) standards included in the "Corps of Engineers Wetland Delineation Manual, January 1987" artd
Regional Supplement to the ACOE Wetland Delineation Manual: Westem Mountains, Valleys, and Coast
D..-'-:..-- /1f ^---:--- a n af,^--tnln\.r.sBrurr ( v sr srulr z.v, rvLdy zv Lv ).
Observations
WestWater biologists field-verified NWI wetlands as depicted on Figure 2. Based on WestWater's
review, only the banks of the Middle Fork of Parachute Creek contained wetland features. The proposed
bore staging locations would be located entirely within uplands. No hydrophytic vegetation, hydric soils,
or hydrology were observed at the proposed bore locations. In addition to determining the
presence/absence of wetland features at the bore staging areas, WestWater biologists also reviewed the
WestWater Engineering Page I of7 October 2023
NWl-mapped wetland channel where Caerus intends to open-trench cut to the east of Middle Fork of
Parachute Creek. This channel is an abandoned channel, and no hydrophytic vegetation, soils, or
hydrology was present, as shown in Photo 1. This channel is indicated on Figure 2 as "field verified non-
wetland".
Photo I : Abandoned channel field verified as "Non-Wetland " .
In addition to the surveys for wetlands, a review of the 100-year flood and floodway information provided
by the Federal Emergency Management Agency (FEMA) (FEMA 2024)was completed for the proposed
project. No mapped flood zones occur within the project area.
Recommendations
In order to protect the integrity of downstream waterways, riparian areas, and wetlands, Best Management
Practices (BMPs) and erosion control measures, including adequate barriers and filtration methods,
should be used to prevent soil erosion and sedimentation from leaving the construction site. With the
implementation of an appropriate Stormwater Management Plans for this project, the potential for
contamination and increased sedimentation to downstream waterways is considered low.
REFERENCES
ACOE. 1987. Corps of Engineers Wetlands Delineation Manual. U.S. Army Corps of Engineers
Waterways Experiment Station. Vicksburg, MS.
ACOE. 2010. Regional Supplement to the ACOE Wetland Delineation Manual: Western Mountains,
Valleys, and Coast Region Version 2.0. U.S. Army Corps of Engineers Environmental
Laboratory. Vicksburg, MS.
WestWater Engineering Page2 of 5 February 2024
FEMA. 2024. FEMA. Flood Map Service Center. Available online at:
https://msc.fema.gov/portal. Federal Emergency Management Agency, U.S. Department
of Homeland Security.
NRCS. 2024. Natural Resources Conservation Service Web Soil Survey. Available online:
http : //websoilsurvev.nrcs.usda. gov/appAlomePage.hbnl.
USFWS. 2024. National Wetland lnventory. Available online:
https ://www. fivs. gov/wetlands/datal\4apper.html
WestWater Engineering Page 3 of5 February 2024
,f/
'.-.i
Caerus Oil & Gas
Figure'l
Middle Fork to Williams 16 lnch Pipeline
Wetlands Evaluation
Location
<l:\Nestt,Yater En gi n eeri n g
A Consulling Engineers & Scientists
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February 2024
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Wotlands Evaluation
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February 2024
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Guffield County
Vegetution Management
February 13,2024
John Plano
Garfield County Community Development Department
RE: GMD-02-24-8514 Grading Permit for Caerus Middle Fork to Williams 16" Gas Pipeline
Dear John,
The Applicant has submitted a Reclamation Plan that is different than the original plan that was included in the materials
that you originally sent over.
For clarification, I am including with these comments the new Reclamation Plan and new seed mix that Caerus proposes
to use the lrrigated Seed Mix.
The proposed seed mix is an lrrigated Meadow Seed Mix. The site description states that part of the project is a meadow
pasture in the middle of the ROW. To the west, the project area is shrublands, to the east it is rocky outcrops- I do have
concerns about the appropriateness of the proposed mix in areas outside of the meadow area where there is no water.
However, there are no invasive species or noxious weeds in the mix. Caerus did remove the invasive species
"Sweetclover" from this mix. The latest mix will be on the last page.
Revegetation Security
The applicant has quantified the area to be reseeded as 5.17 acres.
Staff requests a security in the amount of $15,510. This at a rate of $3000 per acre (5.17 acres x $3000 = $15,510).
The security may be in the form of a bond, letter of credit, or cash through a Treasurer's Deposit Agreement. lf Caerus
uses a bond for security, it will be their responsibility to make sure that the bond is kept current and renewed untilthe
vegetation has been successfully reestablished according to the Reclamation Standards section in the Garfield County
Weed Management Plan. The Standards at the date of permit issuance are cited in Sections 4.06, 4.07 and 4.08 of tte
Plan.
Please provide the County Attorney's Office with bond continuation certificates when there is a renewal.
Once the vegetation has become established, the applicant shall contact the Vegetation Management Department to
arrange for an inspection. lf the vegetation has been successfully established the Vegetation Management Department
will bring the security release request to the Board of County Commissioners for their consideration.
Sincerely
Steve Anthony
Garfield County Vegetation Manager
195 W. 14rh Street, Bldg. D, Suite 310
Rifle, GO 81650 Phone: 970-945-1377 x 4305 Moblle Phone: 970-379"4456
tr
Caerus Piceance, LLC - Operator # 10456
Reclamation Plan
Williams to Middle Fork 16" Gas Pipeline
Section 25 & 30, T5S R95&96W
Garfield County
Site Description:
The proposed pipeline is located on private lands in Sections 25 and 30 of Torunship 5 South, Range 95 and 96
West. The reach spans from existing pipeline infrastructure within the canyon bottom of West Fork Parachute
Creek to the existing Middle Fork Compressor Station. The project area has south, east, and west aspect w1h
slopes ranging from tto 22%. The Right-Of-Way (ROW) has limited slope and topography through the West and
Middle Fork Parachute Creek valley bottom and encounters steeper slopes {less than 4:1) as it exits the vatley
bottom toward the compressor station. Elevation ranges from 5,840 feet to 5,970 feet. Current land uses include
rangeland, wildlife habitat, and natural gas production.
Following pipeline construction, all surface disturbance associated with the project will be reclaimed to stabilize
soils and reestablish desirable perennial vegetation. The planned reclamation area is approximately 5.17 acres to
replace soils as near as practicable to their original relative position and contour.
Soils Description:
The United States Department of Agriculture (USDA) National Resource Conservation Service TNRCS) Web Soil
Survey was used to identify Soil Map Units within the proposed pipeline ROW. Four Map Units were identified
within the project area:
Map
UnitSymbol SoilName Description
46
Nihill channery loam, 1to 6
percent slopes
Occurs on valley sides and alluvialfans between 5,000
and Q5fi)feet. Parent material is alluvium derived from
sandstone and shale.
47 Nihill channery loam, 6 to
25 percent slopes
Occurs on valley sides and alluvialfans between 5,000
and 6500feet. Parent materialis alluvium derived from
sandstone and shale.
62 Rock outcrop-
Torriorthents com plex,
very steep
Occuls on hillslopes, escarpments and plateaus
between 5,800 and'&500 feet. m. Parent material is
very stony colluvium derived from calcareous shale.
6q Torrifluvents, nearly level Occurs on distributaries, rivers, and flood plains
between 5,0fi) and 7,000 feet. Parent material is
alluvium.
These soils typically have non-saline to moderately saline properties, have water table depths greater than B0
inches, anci the ciepth to iithic bedrock typicaily ranges 0 to 60 inches. Topsoil depth will vary widely within the
project area, with areas in the eastern ROW reach having little to no topsoil and areas of the valley bottom
potentially containing up to 11 inches of viable topsoil.
All available topsoil will be stripped and stockpiled during construction. ln areas with no topsoil present, the top
5 irrehes u[ soil will Lre salvaged.
.rffi
ru"Reclamation Plan - Williams to Middle Fork 16" Gas Pipeline
Reference Area And Pre-Disturbance Veeetation Composition:
The pipeline is within Ecological Site Upland Loam {Wyoming Big Sagebrush). The project area is primarily
composed of sagebrush and sumac shrublands in the valley bottom to the west, meadow pasture through the
middle of the ROW, and rocky outcrops through the eastern section of ROW. Common plant species include
sagebrush, serviceberry, sumac, western wheatgrass, smooth brome, and Arizona fescue.
Known Weed Occurrences:
Musk thistle was treated near the project area in 2023. Annual weeds (Russian thistle kochia) can occur along
roadsides in the area.
Recla mation Operations
Soil Preparation and Recontouring:
Following completion of pipeline construction reclamation operations will commence. All regions with compacted
soils (ROW driving surfaces) will be ripped to a depth of 18 inches or to bedroc( whichever is shallower, to
alleviate compaction.
Recontouring will occur to replace soils to their original relative positions and level ripped soils. Recontouring will
include all edges of the disturbance to blend them with the adjacent landscape. Topsoil will be spread evenly
across the recontoured ROW. The finalsurface will be left rough to promote micro catch depressions for additional
water retention,
Re-establishment and Stabilization of Hvdroloeic Features:
The pipeline creek crossing will be completed through directional boring methods to prevent any surface
disturbance within the riparian corridor. Any irrigation ditches or roadside ditches disturbed during construction
will be reestablished in their original paths to preexisting specs.
Site specific erosion control measures will be installed before the start of construction to prevent erosion channel
formation, topsoil loss, and sediment discharge from the ROW. Long-term stormwater best management practices
include land-forming and revegetation with perennial plant species to prevent excessive erosion, soil instability,
su bsidence, or slumping.
Seedbed Preparation. Seedins. and Mulchine:
lf seeding can be completed directly following recontouring operations, no seedbed preparation is necessary.
However, if the soil surface has hardened before seeding operations can be completed, the seedbed will be
prepared via disk, harrow, or chisel plow to have the topsoil of loose enough to allow for root growth and firm
enough on the surface for proper seed to soil contact. The soil surface should also be relatively free of debris and
dirt clods greater than 3 inches in diameter, as too much debris and clods will inhibit proper seed placement. lf
possible, the soil surface should also be free of rocks greater than 3 inches in diameter, though this may not be
feasible based on soil types on the proposed location.
500 lbs./acre Richlawn 3-6-3 with mycorrhizae and humates '" pellet organic fertilizer will be applied prior to
seeding and mulch application.
Seed will be applied using a range type drill seeder throughout the reclamation area. Areas inaccessible with the
drill will be hand seeded and raked in. All seed will be calculated in pounds per acre and certified weed free with
pure live seed rated per applicable jurisdiction standards. Seed tags will be reviewed by Caerus before application
and seeding will be documented through a report form completed by the contractor. The below-detailed seed
mix will be used throughout the reclamation area,
Page 2 of4
.(#.n
--.@jlru Reclamation Plan - Williams to Middle Fork 16" Gas Pipeline
Following seeding, certified weed-free straw mulch will be applied at a rate of 3,5@ lbs./acre to cover t0p;Ya ot
the seedbed. Straw will be crimped to properly anchorthe mulch and ensure maximum soil moisture retention
and stormwater stabilization. A natural fiber mulch (hydraulically applied! may also be utilized on steeper slopes
or a reas of concentrated stormwater flow to ensure stabilization.
Reclamation Seed Mix:
Grasses
Management of lnvasive PJants:
During construction phases, the ROW is inspected for stormwater compliance on a weekly or biweekly schedule.
Following reclamation operations.. the ROW is inspected monthlry- Through these rsutine slte vlsits, any noxlous
and invasive weeds within the disturbance boundaries will be identified, inventoried, and treated by licensed
contracted herbicide applicators or mechanically removed through mowing line-trimming, or hand tools. The
treatment method is determined based on weed species, growth stage, season, and distribution. Caerus will
monitor, control, and reduce the spread of noxious and invasive weed species within Caerus' disturbances per
state and county regulation and rules pertaining to the administration and enforcement of the Colorado Noxious
Weed Act.
NPR Mountain Wildlife/lrrigated Meadow Seed Mix
Plant Drilled Pounds PerAcre Broadcast Pounds Per Acre
Timothy 3 5
Meadow Brome 3 5
Orchard Grass 3 5
Perineal Ryegrass 3 5
Tall Fescue 3 5
Grass Total #15 23
Forbs
Small Burnett 4 6
Cicer Milkvetch 4 6
Alfalfa, Ladak or Ranger 2 3
Sainfoin 4 6
sweet clover ---.-5 D p la |e d 2 3
Red Clover 2 3
Forbs Total #18 27
Cover Crop
Oats (spring Plantine) or Triticale (Fall Plantinsl 10 1"5
Hairy Vetch 5 7.5
Tillage Turnips or Radishes 2 3
Total fnvercrop t7 26
Total Pounds Per Acre 50 75
Page 3 of 4
re Reclamation Plan - Williams to Middle Fork 16" Gas Pipeline
Reclamation Monitorins:
Caerus Best Management Practices require routine site visits and active management over construction activities,
along with annual reclamation reporting requirements. For compliance with Colorado Department of Public
Health and Environment (CDPHE) Storrnwater rules, the location will be visited for stormwater inspections every
7 or t4 days during active earthwork and monthly following completion of reclamation untilthe vegetation has
reached 70o/o cover of pre-disturbance levels, with the focus on stabilizing soils, preventing erosion and site
degradation, and monitoring for and treating invasive species. Annual inspections (at a minimum) willthen take
place until the reclaimed disturbance is deemed successful and a self-perpetuating perennial plant community
has been reestablished.
Establishment of a Desirable Self-Perpetuating Plant CommuniW:
Caerus knows that reclamation maintenance, including greater than one seeding event, may be necessary to
ensure the reclamation achieves uniform cover of a desirable, self-perpetuating, plant community. Monitoring,
subsequent planning, and implementation of site-specific maintenance plans willensure revegetation efforts are
successful, topsoil is stabilized, and wildlife habitat and forage is reestablished.
Page 4 of4
lrrigated Meadow Seed Mix
Broadcast Pounds Per Acre
5
5
5
5
5
2?
6
6
3
6
3
A
15
7.5
3
26
72
Drilled Pounds Per Acre
3
3
3
3
5
15
4
4
2
4
2
15
10
5
2
L7
48
Scientific Name
Grasses
Phleum pratense
Bromus biebersteinii
Dadvlis glomerata
Lalium perenne
Festuca arundinacea
Grass Total #
Forbs
Sanquisorba minar
Astragalus cicer
Medicqqa sativa
0nabrychis viciifoliu
Trlfulium pratense
Forbs Total fl
Cover Crop
Ave na sativo, Tri ricu mx Seca le
Vicio villosa
Brassica ropa, ftaphanus sotivus
Total Cover Crop
Total Pounds PerAcre
Plant
fimothy
Meadow Brome
Orchard'5rass
Perennial Ryegrass
Iall Fescue
SmallBumett
Gcer Milkvetch
Alfalfa, Ladak or Ranger
Sainfoin
Red Clover
Oats (sprine Plantins) or Triticale (Fall Plantins)
Hairy Vetch
rillaee Turnips or Radishes