COGCC report is wrong on Initiative 97

August 15, 2018

Colorado, setbacks

On August 6, Colorado Rising turned in 171,596 signatures to Secretary of State Wayne W. Williams (D) in support of Initiative 97. Colorado Rising members pictured include Joseph Salazar, Russell Mendell, Micah Walker Parkin, Lauren Petrie, Trisha Garcia-Nelson, Suzanne Spiegel, Anne Lee Foster, Razz Gormley, Julia Williams, and Dan Leftwich. [Source: Joseph Salazar’s FB page]

Initiative 97 will appear on the November ballot as Proposition 112

Guest post by Bob Arrington, PE*

Initiative 97 would mandate that new oil and gas development, including fracking, be a minimum distance of 2,500 feet from occupied buildings, as well as public parks, public open space, irrigation canals, lakes, rivers, perennial or intermittent streams and any additional vulnerable areas designated by the state or a local government. Gov. John Hickenlooper recently said that this initiative could eliminate 90 percent of oil and gas activity in eastern Colorado and only slightly less than that in western Colorado. Initiative 97 is awaiting approval from Secretary of State Wayne Williams.

In the meantime, according to a breathless article in Colorado Politics on August 7:

“A recent analysis by the Colorado Oil and Gas Conservation Commission found that the measure would eliminate 54% of all surface land in Colorado to new production. But over 85 percent of all new oil and gas development has occurred within that area over the past 3-years.”

And with that line of thought the descriptions of the dire economic losses are put forth by industry front organizations and reviewed by academics in programs funded by them at a “prestigious” school.

The study Increasing the Oil and Gas Setback Requirement to 2,500-feet in Colorado: An Economic and Fiscal Impact Analysis, was conducted by the REMI Partnership.

The study’s projections go on to use the 85 percent figure as the basis to evaluate the losses assuming it would be totally lost:

“By losing over 85% of new production going forward, roughly $258 million in state and local tax revenue would be lost during the first year alone, according to the REMI Partnership study.”

The economic impact numbers were based on faulty or exaggerated assumptions and on development that has encroached on urban settings. It is also based on directional drilling that has been primarily in tight sands for gas and oil and some horizontal drilling of the deeper Niobrara and Mancos shale. The drilling is poised or started tapping these deeper formations which would be primarily horizontal drilled wells. That means the longer drilling reaches become the method and siting locations more flexible; and, to base future projections on past method and yields is erroneous.

But wait a minute that “85%” of the last 3 years development has already occurred. Matter of fact it has been the major part of development for the last 60 plus years. Initiative 97 would not erase that development. New development does not need to happen where development has already occurred. And the initiative stipulates only new oil & gas development, not existing facilities. Only if a well had been permanently shut down in the past would it be treated as new.

The irony of these dire claims, is they totally ignore that Initiative 97 excludes minerals on federal land representing the largest part of “yet to be developed;” albeit, it doesn’t have the well-developed support infrastructure that the industry has been using for the last 60 some years.

New production could occur in the remaining 46 percent; and even that number of 54 percent loss of surface land is suspect from methods used by COGCC staff to address metrics. Initiative 97 would not shut that down!

Not only that, but had the COGCC been doing their job as the Colorado Court of Appeals found, people would not have to organize and fight back against this travesty balancing of development against “allowable collateral damage” to the health, safety, and well-being of the people when there should be NO damage.

The study’s economic impact numbers were based on faulty or exaggerated assumptions and on development that has encroached on urban settings. It is also based on directional drilling that has been primarily in tight sands for gas and oil and some horizontal drilling in the deeper Niobrara and Mancos shale. The drilling is poised to start tapping these deeper formations which would be primarily horizontal drilled wells. That means the longer drilling reaches become the method and siting locations more flexible; therefore basing future projections on past method is erroneous.

Health studies have shown the health impacts go up within the 2500-foot proximity and up to a kilometer (3281 feet) or more, as shown in these studies:

Adequacy of Current State Setbacks for Directional High-Volume Hydraulic Fracturing in the Marcellus, Barnett, and Niobrara Shale Plays

Health symptoms in residents living near shale gas activity: A retrospective record review from the Environmental Health Project

Safety considerations are limited even with 1000-foot setbacks as a minimum as shown in my own report Ring of Safety: Oil & Gas Drilling Pad Setbacks. Fire, explosion, particulates, blowouts, hydrogen sulfide and other toxins can immediately affect people and property within that range and worsen with long term exposure. A 2500-foot setback allows for more time to evacuate, lessens property damages, and reduces human exposure to heat, fire, gases, particulates, and explosion debris.

On August 10, the Denver Post published a pro-industry OpEd by Krista Kafer:  Due diligence needed or voters will rue Initiative 97.

As a result it becomes even more important to put some perspective to the fog of war created around Initiative 97. First, the COGCC had staff prepare a report based of one they did in 2016. They used the same metrics, while making reports for the commissioners. They should not be allowed to use in the political arena without full and complete sources, methods, authors, and complete analysis of what is surface and what is underground. Historically, they should have been safeguarding public health and safety as the appeals court ruled which would have meant occupied buildings and vulnerable area would have been recognized an avoided.

For their new report, the COGCC took estimated occupied structural and estimated vulnerable areas together (-36.3M acres) to get the 85.4% of non-federal surface area and 54.5% of total surface area. They did NOT acknowledge the underground mineral developed area that is part of this “unavailable” acreage and in or nearly in production.

It is important to understand that a significant part of non-federal land that makes up the 85.4% area has already been developed. Yet the COGCC goes on to say, Weld County would be 78% unavailable and the top 5 producing counties collectively have 61% area unavailable due to Initiative 97 limits.

BTW in 2016, the COGCC issued a report using most of the same metrics and claimed it would eliminate 90% of the state. Also, it appears their number for federal minerals may be a bit low in their current report This federal area holds much of the Mancos and Niobrara shale yet to be developed.

After their scary analysis of land unavailable for development the COGCC fails to say that for any section of 640 acres on the surface, only about 5 to 10 acres are needed on the surface to develop the 640 acres because that “development” takes place underground, not on the surface. Only 1.5 percent of a 640 acre section is developed to access the subsurface.

Keep in mind a very important concept. It only takes about a 5 to 10-acre surface site to access a 640 acre section size of mineral area. That is about 1.5 percent of surface land for any given full section of size of mineral formations below ground. And can be for the development of tight sand lenses using directional drilling with a moderate maximum reach of 3,015 feet and 10-acre spacing of 64 well bores using 300 to 400-foot fracture length out of a possible 1000 foot fracture. In the sandstone they are working vertical track zones trying to place stages in gravel lenses they have penetrated. They frack the stages coming up the hole with focus on penetrated lenses.

Examples of Directional Vertical Tight Sand and Directional Horizontal Shale Drillings

Vertical Bottom Hole Fracking of Tight Sands

In the shale formations where horizontal drilling is the best, it can bemore mineral acreage available since runs of up to 5 miles have been made. However, with 8 wells going about one mile horizontal, after making a directional approach, they can frack and develop an entire section fracking in stages coming back each horizontal run.

Horizontal Bottom Bore Fracking in Red Block (4 well 1/2 Section)

For example, available area in a section with a 2500-foot radius taken out, it would leave 4 corners of 47.4 acres, or a total of 190 acres of accessibility in any given section as shown in this drawing.


Drawing of a Section & 4 sections reach by a horizontal run. Example Directional Vertical Tight Sand and Directional Horizontal Shale Drillings

The takeaway is that there is space for pad development as that footprint is small compared to the underground field development. Planning for pad locations becomes a more exacting process, but in providing better health, safety, and welfare of the established dwellers it is paramount. It should not be put aside from consideration that new population developments must be kept off of the areas that are or were used for pads and equipment until any remaining hazard is cleared. And it must be understood that present methods of sealing wells is NOT failsafe to surface or aquifers and is subject to time, geologic events, corrosion, cement failure, and lost history.

The final part of this “equation” has not been mentioned in the future scenarios and that is the effects of climate change. Basing an economic picture on fossil fuel is a folly that cannot be sustained. Our future economy must be built around implementing this absolutely needed conversion.

Dr. Anthony Ingraffea, Professor of Engineering Emeritus at Cornell University, outlined more precisely the role U.S. fracking is playing in changing the world’s climate.  At Ingraffea’s 10 to 15 years date, transition to renewable energy sources needs to be well on the way toward completion with all fossil fuels being phased out.

“Whereas the worst-case scenario brought us to 1.5 degrees Centigrade in 2040,” he adds, “we’re almost there today.”

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*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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