On Friday, May 18th Shell Western Exploration and Production, Inc. (SWEPI), a unit of Royal Dutch Shell, filed 8 Applications for Permit to Drill (APD's) for 4 well locations in Huerfano County stretching from north of Gardner to Major's Ranch/Yellowstone Road (see blog post below SHELL WELL ALERT: 4 APDs IN GARDNER AREA
for location maps). COGCC Public Input DEADLINE: June 7th Unless John Galusha requests the 10-day extension! > Sign the PETITION HERE for Galusha to request more time!
HOW TO ACCESS APD DOCUMENTS:
GO to the COGCC website : http://cogcc.state.co.us/
1) Click the PERMITS link in the left menu bar.
2) Enter "HUERFANO" in "All Pending Applications for ______________ County" (Click 'Go!').
This will pull up all 8 well applications. The 8 applications are actually only for 4 wells. The names of the wells are, from north to south: Fortune 4-9, State 2-36, Seibert 3-8, Freeman 3-24. There are 2 applications for each well because SWEPI is drilling two different holes in each well and did an application for each hole (each drilling plan) separately. The two holes are the Pilot Hole going straight down (Drilling Plan) and the "Toe Up" Hole which goes down and then outward and hooking upward (kind of like the toe of an elf's boot
?) (Deviating Drilling Plan).
3) Click on the Well Name/Number (Document Link)
to pull up all well documents.
Well documents include Form 2 Applications, Basic Maps, and Drilling Plans. Be sure to scroll to the bottom of each document because many have multiple pages. For example, at the end of all of the DRILLING PLANs and DEVIATED DRILLING PLANs is a statement by Shell that they won't be fracking these wells
. Can we believe it?
In addition to permits, there are Location Assessments. To view the Location Assessments
4) Again, click the PERMITS link in the left menu bar.
5) Enter "HUERFANO" in "All Pending Location Assessments for ______________ County" (Click 'Go!').
6) Click on the Location Name/Number (Document Link)
to pull up all location documents.
Location documents include Form 2A Application (Location Assessment), Hydrology/Road/Reference Maps, Pictures, Construction Plans, Location Drawings, Correspondence, and Other.
Note, if these applications are approved, they will be moved on the PERMITS page from Pending to Approved for HUERFANO County.
HOW TO COMMENT
Where should I post my comments? The COGCC provides a space for Public Input on their website, which takes a bit of navigation to get to. If you have comments or information on a specific location, put them on the Location Assessment for that well or wells. If you have general comments or concerns on the Drilling, put them on the Permit for that well or wells.
To get there:
1) Follow the steps above except instead of clicking under the Document Link column, click under the Status or Status (eForm Link) column.
2) A Login page will come up. Do nothing, it will automatically log you in if you wait.
3) To see the permitting tasks in process click the colored bar under "Tasks"
4) To comment, click on the "Comment" button.
5) Click "New Comment".
6) Enter the weird stuff you see in the box and click "Verify Text".
7) The Comments page should come up and allow you to comment.
8) Be sure to click "Save" before leaving the page!
Hint: Copy and paste your comment and save it separately before you click "Save" on the site. When you click "Save" on the site, it will disappear, and not appear on the site until the COGCC posts it.
Email or Fax a copy of your comments to the COGCC Acting Director, Thom Kerr
Be sure to reference the specific well or wells by Name/Number (above) you are commenting on.
Postal Mail will probably not arrive by deadline, but here is the address:
Thom Kerr, Acting Director
Colorado Oil and Gas Conservation Commission
1120 Lincoln Street, Suite 801
Denver, CO 80203
WHAT TO SAY
We recommend speaking about what you know, think, or feel, in your own words. Personal knowledge from people who live in the area is valuable.
That said, here are some points CHC emphasizes and you should feel free to include in your comments as you see fit.
In keeping with CHC’s mission to protect the health, safety, welfare and environment from the effects of oil and gas development in Huerfano County, please write and/or email the COGCC and ask:
1. Before oil and gas permits are granted in the Huerfano river drainage,
a thorough hydrogeological study of the area
, including field work (not just a literature review) shall be accomplished. Oil and gas drilling permits shall not be granted until it has been determined that drilling and fracking will not adversely impact water resources, as has already happened in the other three Raton Basin
drainages (Cucharas, Purgatiore and Apishapa).
2. Attach as a condition of approval (COA) to all permits to drill in Huerfano Park, No Hydraulic Fracturing
. On the applications (Drilling Plan last sentence) and in communications with the public - SWEPI has indicated that hydraulic fracturing will not be used on the proposed wells: "Frac'ing or additional reservoir stimulation methods will not be applied"
Due to its complex and unique geology, Huerfano County is a high risk environment. Fracking in these locations has a high probability of resulting in unintended consequences including irreversible impacts on surface and groundwater resources. Please make the claim a condition of approval.
3. Attach as conditions of approval (COA) to all permits to drill in Huerfano Park
, that only closed-loop, pitless drilling and pitless operations
with non-toxic drilling and fracking chemicals and green completions
shall be allowed.
4. Attach as conditions of approval (COA) to all permits to drill in Huerfano Park, that raw produced water from drilling, fracking, completion or production shall not be stored in ponds, spread on roads or grounds.
5. Attach as conditions of approval (COA) to all permits to drill in Huerfano Park,
that air emissions be controlled to the maximum extent technically possible
. For example, that all air emissions shall be controlled by a device capable of 95-100% control efficiency of VOC. The device(s) shall be maintained to allow maximum efficiency during operations.
6. Attach as conditions of Approval to all permits to drill in Huerfano Park,
that baseline water samples
shall be taken, at least 60 days prior to activity at any well site, of all domestic, community and livestock water wells and springs, of the intake to all municipal waterworks, and of all other creeks and surface run-off areas, within 5 miles in all directions
. The water samples shall be gathered according to the COGA protocols and analyzed according to the Tier 2 analyte list published in the Colorado Water Institute’s Water Well Testing Program for Huerfano County.
7. Attach as conditions of approval (COA) to all permits to drill in Huerfano Park, that the applicant shall post a bond, escrow account or liability insurance policy of sufficient monetary value to fully compensate local citizens and communities for any damage to their air, water, health, safety, environment or property values.
8. Additionally, Huerfano County is well known for its unique and complex geology, including numerous radial dikes that extend for miles through multiple geological strata (and are not all visible on the surface). Dikes, sills, faults and fractures are deep, transmissive, and the details of their connections to aquifers are not known except possibly through 3-D seismic data Shell may have collected. CHC requests COGCC examine the data to establish that there is NO possibility of connection between SWEPI well-bores or fractures and natural fractures or dikes that communicate with aquifers.
9. Additionally, because of its close proximity to the Huerfano River and the Gardner Community drinking water wells, the area surrounding Fortune 4-9 should be given protection under Rule 317B, Public Water System Protection criteria.