Battlement residents deal with concurrent review process for Ursa’s Phase II

Well pad with sound walls located across the river from Battlement Mesa [Photo by Emily Hornback/Western Colorado Congress]

While the COGCC considers Ursa’s Phase II drilling plan for another 55 wells on 2 well pads plus another injection well, all located within Battlement Mesa, the Garfield County planning department is simultaneously considering the same application. It’s not supposed to work that way. The way it’s supposed to work is the county reviews the application first, then passes it on to the COGCC for recommendations and/or conditions of approval.

Matt Sura, attorney for Battlement Concerned Citizens and former task force member, protested via letters to the county and state that the concurrent review process violates “both the spirit and language” of the new large urban mitigation area drilling rules. He added that the public would be forced to comment on an incomplete state application prior to the county being able to come up with conditions of approval intended for incorporation into the state permit.

Dave Kubeczko, a location specialist for the COGCC, assured Battlement residents and the commissioners that the state will not issue any final approvals on Ursa’s proposal until after the county has determined the proposal to be sufficient through its review process.

And so it came to pass in June at the behest of Ursa, the COGCC convinced Garfield County commissioners to look the other way and let the concurrent review process go forward.

While Battlement residents ought to be enjoying these last days of summer, they are studying application docs, holding meetings, making phone calls, and writing letters.

And just as Bob Arrington warned the COGCC last month about the hazards of Ursa’s drilling plan, he submitted a letter to Garfield County which included his previous warning. The full text of his letter is published below. Click on the title of his presentation to view.

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To: Glenn Hartmann, Senior Planner
Garfield County Community Development

I am submitting this letter and a pdf file to comment on Ursa’s L Pad, F pad , and A pad applications to the Planning Commission and Board of County Commissioners.

L Pad
L Pad is sited very tenuously, greater than the 1000 foot setbacks that would trigger more requirements from the COGCC. If some fall within the county’s purview, they should be required. This should include water supply for landscaping. L Pad may require some longer “reaches”, and Ursa should be using a larger rig on any “reaches” requiring them to exceed their stated 45 degree inclination angle limit cited in the past. Using a larger rig could have prevented pads in the PUD. In Cause No. 400, Docket No. 170700502, Type: Pooling, before the COGCC, they missed a required 100 foot setback on the top 2 of 10 stages. They “inadvertently” completed those stages and ended up in otherwise owned minerals and the COGCC is requiring pooling. They are supposed to know where thier downhole location is and inadvertent completion of those stages should have been avoided. It would appear they can’t handle the locating of their downholes with their smaller rig.

M Pad
M Pad has not been applied for and should never be considered for the future.

F Pad
This pad is to be a water handling/storage layout. The county should require spill prevention rules to protect spills from reaching soils and detection of ANY tank seepage under any and all storage and adequate liner protections to prevent ANY spillage from contaminating soil.

A Pad
A Pad is a pad that took rezoning to be placed where it is and should have been rejected on that basis. Because it is close to occupied sites, it is a LUMA site. As a site it is dangerous to home owners, a water supply river, homes, and a water storage reservoir. While surface grade is downhill from reservoir to pad, ground spills can migrate at a level in the soil that could reach the reservoir. Bentonite lining of the reservoir won’t necessarily prevent hydrocarbon seepage into the water reservoir. County Health inquired of this situation, while others were extolling the pad being “downhill” of the reservoir. Then there is a plan to put an Injection well on that pad. My “Presentation 1a.” addresses the problems and considerations this has in explanation of geological problems, rule violations, and absence of actual necessity of that location.

Ursa has made, and County O&G Liaison has touted their claim, that truck traffic would be expanded. That is not a true situation resulting from injection relocation as I also spell out in the Presentation. Because there is a pipeline network established between wells and water treatment, if truck traffic were possibly required, it could be from a terminal at Speakman pad and never require traffic in the PUD. Ursa has had one temporary pipeline from Watson Ranch to Speakman and could put it back again, but connected to F Pad.

Respectfully,

Robert L. Arrington, P.E.*

Presentation 1a: A Very Bad Place to Try an Experiment? Ursa Pad “A” Injection Well

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If you would like to comment feel free to contact:
Glenn Hartmann, Senior Planner
970-945-1377 x1570
ghartmann@garfield-county.com

The applications are available for viewing at the Garfield County website: Applications under review

For more information about Ursa’s Phase II drilling plan see: Submit comments now for Ursa’s Battlement Mesa Phase II application

*Bob Arrington, PE, is a Battlement Mesa citizen representative on Garfield County’s Energy Advisory Board (EAB). He also represents the Grand Valley Citizens Alliance and the Battlement Concerned Citizens.

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