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New Oil and Gas Citizen Complaint Response and Tracking System
The City and County of Broomfield is launching a new citizen complaint response and tracking system for oil and gas related issues at
Broomfield.org/oilandgas. This
system will ensure your concerns about odor, noise, lighting, dust, traffic, water, air, spill, wildlife, waste or other general issues will be addressed, assigned and investigated in a timely manner.
Air Quality Testing Program
On August 28, 2018, City Council approved an air quality testing agreement with Ajax Analytics for air quality testing near the Extraction well sites and in nearby neighborhoods, as well as for the development of a webpage to report air quality monitoring results. The air quality testing program is a combined proposal of Colorado State University and Ajax Analytics. Through Colorado State University's canister testing and analysis, and Ajax Analytics sensors, the data generated will be able to identify trends and monitor air emissions at well sites and in neighborhoods, to identify changes in volatile organic compound emissions the potential sources and age of the emissions. Ajax and CSU will validate and analyze the data.. The total cost of the proposal for three years is $1,762,768 for an annual average cost of $587,589 per year.
You're Invited: Air Quality Testing Program Open House
Citizens are invited to an Air Quality Monitoring Study Open House on Wednesday, October 24 from 5-6:30 p.m. at the City and County Building in Broomfield to learn more the air quality study and testing starting near the Extraction well sites and nearby neighborhoods this Fall.
Air quality is a main focus of the Oil and Gas Chapter of Broomfield's Comprehensive Plan as well as the Extraction Operators Agreement. These documents address specific action steps and Best Management Practices (BMPs) related to oil and gas development, operations, and concerns expressed by the public related to air quality impacts.
Contracting for air quality monitoring will support several of the stated policies and associated action steps, as well as inform long-term strategies that may be adopted by Broomfield to address concerns expressed by the public. Attendees can learn more about how the air quality monitoring and testing will be conducted, what tools and sensors will be used and how results will be accessed and reported to the public. Representatives from the partnership between Colorado State University's Department of Atmospheric Science and Ajax Analytics will also be available to discuss the monitoring network and data analysis platform for Broomfield.
Additionally, learn about the various ways Broomfield will use this air quality data including the following:
- Information supporting emergency response actions
- Follow-up information to respond to citizen complaints and concerns
- Information supporting follow-up inspections
- Data and trend analysis to support health decision and possible regulatory and statutory changes
Soil Gas Testing at Plugged and Abandoned Well Sites
Soil gas testing of a plugged and abandoned wells help to identify any leakage in plugging or cement. If leaks are identified, they would be reported to the appropriate the Colorado Oil and Gas Conservation Commission for follow-up. There are 72 plugged and abandoned wells in Broomfield. (
View the map of plugged and abandoned wells.) Forty-three of these plugged and abandoned wells are 500 feet or less from residences. ERO, a consulting firm that Broomfield has worked with the past, will perform the soil gas testing in accordance with the appropriate standards.
ERO made a presentation to the Planning Subcommittee of the Oil and Gas Comprehensive Plan Committee on soil gas testing around plugged and abandoned wells and the subcommittee recommended the use of this consultant for this purpose and for water testing. The cost per plugged and abandoned well for soil and gas testing is $1,500 for a total cost of testing all plugged and abandoned wells of $108,000 and for testing the 43 plugged and abandoned wells that are within 500 feet or less from residences is $64,500.
In addition, Extraction will pay for plugged and abandoned well testing for those plugged and abandoned wells within one quarter mile of the projected track of the borehole of any new well that it drills.
Recent Meetings
- Council adopted new oil and gas regulations on July 10, 2018. A link to the new oil and gas regulations is here.
- Council discussed draft amendments to its oil and gas regulations on August 14, 2018 and September 25, 2018. A link to the September 25, 2018 draft of the amendments and associated Council memo is here.
- On August 14, 2018, City Council approved a process for requesting COGCC hearings on Forms 2 and 2A and Spacing Unit Applications.
- Council approved an agreement with Ajax Analytics for an Air Quality Testing Program on August 28, 2018.
Future Meetings
- Council will consider amendments to Broomfield's oil and gas regulations concerning citizen hearing process and setbacks for new construction from existing wells later this year.
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Extraction Announcement
Beginning Wednesday, Oct. 3, Extraction Oil and Gas will be conducting preliminary utilities location through a process called "pot holing." View notice of scheduled potholing.
Extraction Comprehensive Drilling Plan (CDP) Update
- Broomfield's Operator Agreement with Extraction requires a Comprehensive Drilling Plan (CDP), which contains 23 plans on topics ranging from air quality, to noise control, and emergency and risk analysis. The CDP will control activities on the 6 well pads and 84 wells that are allowed under the Operator Agreement. The CDP is subject to Broomfield's approval.
- The City and County Manager approved the final CDP on August, 2018, by this letter.
Extraction's State Form 2A Location Assessment Permits
- Of the 84 wells that Extraction intends to drill, the Colorado Oil and Gas Conservation Commission (COGCC) has approved the following Form 2A locations assessment permit applications for the six well sites in Broomfield:
Extraction Applications for Public and Private Improvement Permits for Pipelines
Broomfield negotiated with Extraction to have all gas, oil, and produced water piped off of the proposed Extraction well sites. Pipelines are safer and result in less emissions because it avoids the retention of oil, gas, and produced water on the well sites. Pipelines also greatly reduce the amount of truck traffic to and from a well site. Broomfield insisted that pipelines be in place to Extraction well sites prior to completion of the drilling and removal of oil, gas, and produced water from the sites. A map of the pipeline route can be viewed
here.
The estimated schedule for the installation of the pipelines is set forth below, with the section referenced those indicated on the map.
An updated Tentative Schedule Forecast will be provided as soon as it is available. Section 13 of the Operator Agreement with Extraction requires pipelines to be built in accordance with specific protections like the highest class of pipeline for safety and durability and continuous monitoring systems. In exchange, Broomfield agreed to grant easements over City owned property for the pipelines. The pipelines, as contemplated by the Operator Agreement, are subject only to the issuance of a PPIP by the City Engineer. (A link to Broomfield's permit form can be found here.) The primary purpose of the permit is so that any pipelines or utilities crossing public or private lands are built to engineering specifications, do not interfere with public utilities, and address associated environmental issues.
As can be seen from the map of the pipeline linked above and the schedule set forth above, the next sections of the pipeline that will be reviewed and are subject to approval through the PPIP process are the pipelines serving the Livingston Pad and then moving east through the Northwest A&B Pads and the Interchange A&B Pads.
Crestone Peak Oil and Gas Update
Staff met with Crestone on May 7th to discuss its pending application for two well pads in northeastern Broomfield, the Gottl well pads. Staff provided Crestone with a first round of
comments on these applications. Crestone has begun working with the North Metro Fire & Rescue District and the Broomfield's Emergency Manager within the Police Department on the details of its Emergency Management Plan. Staff sent a letter to Crestone on July 13, 2018 that included Broomfield's new oil and gas regulations and indicated that Crestone would have to comply with these regulations. A link to that letter is
here. On July 31, 2018, COGCC approved Crestone's spacing applications for the Gottl well pads. (
Click here to read the COGCC Report) Crestone's Form 2A permit for these pads is currently pending at the COGCC. Broomfield's comments on the Form 2A permit are linked
here.
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Proposed State Rulemaking on Financial Assurances
Staff and outside counsel have worked with member of the Oil and Gas Comprehensive Plan Committee to prepare proposed changes to the COGCC's 700 series rules on financial assurances for oil and gas operators. (A letter to the COGCC regarding the proposed changes can be viewed here.) Outside legal counsel, staff, and the member of the OIl and Gas Comprehensive Plan Committee met with the Director of the COGCC to discuss this proposal.
The Governor has directed the COGCC to review its current financial assurance requirements. Pursuant to that direction, the Director has convened a technical working group to discuss potential rule revisions. A Broomfield citizen and former member of Broomfield's Comprehensive Plan Task Force will be participating in this working group and will propose a suite of revisions to the COGCC rules related to bonding and general and environmental liability. The Governor has directed the COGCC to report back on its findings at the end of this year. We anticipate a rulemaking next year.
Proposed State Rulemaking on COGCC Procedural Rules and Forced Pooling
COGCC has initiated a revision to its procedural rules governing hearings before the Commission, as well as to implement a recent statutory change to pooling rules. The rules revise a number of procedural requirements and implement changes that limit the liability of non-consenting mineral owners who are force pooled. Broomfield is participating in this rulemaking along with a number of other local governments from the Front Range. The hearing is scheduled for October 3.
Proposed State Rulemaking on School Setbacks
COGCC has scheduled a hearing to consider proposed changes to its setback requirements for schools, pursuant to a citizen petition. Specifically, COGCC will consider whether to change the point at which the current setback from schools to a new well site is measured. The proposal would use the boundary of the school property rather than the location of the school itself to measure the setback distance to an oil and gas facility. Broomfield will receive direction from Council on its participation in this hearing, scheduled for December.
Colorado Department of Health and Environment Mobile Air Quality Unit
A location for the placement of CDPHE's Colorado Air Monitoring Mobile Laboratory or CAMML in Broomfield to measure air quality in proximity to the Extraction well pads has been selected. That location is northwest of the Livingston Pad and south of the Northwest Parkway. Staff has finalized access, pad, and electrification issues for the site. At this time, CDPHE anticipates doing baseline testing at the selected location and then follow-up testing during hydraulic fracturing and flowback.
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