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PROPOSED ACTION

North Fork Mancos Master Development Plan

for

Oil and Gas Exploration and Development

Gunnison and Delta Counties, Colorado

DOI-BLM-CO-N040-2017-050-EA

Prepared by

Gunnison Energy LLC

1801 Broadway, Suite 1200

Denver, Colorado 80202

Phone: 303-296-4222

Fax: 303-496-4555

Prepared for

Bureau of Land Management

Colorado River Valley Field Office

2300 River Frontage Road

Silt, Colorado 81652

Phone: 970-876-9000

Fax: 970-876-9090

January 2017

Left blank for two-sided copying.

Gunnison Energy LLC

Proposed Action, North Fork Mancos MDP


i

Table of Contents

1.0 INTRODUCTION ................................................................................................................................ 1 2.0 PROJECT LOCATION AND ACCESS .............................................................................................. 5 3.0 EXISTING AND APPROVED DEVELOPMENT AND INFRASTRUCTURE ............................... 5

3.1 EXISTING DEVELOPMENT AND INFRASTRUCTURE ........................................................................... 7 3.2 APPROVED DEVELOPMENT AND INFRASTRUCTURE – NOT CONSTRUCTED ..................................... 7

4.0 PROJECT COMPONENTS ................................................................................................................. 7 4.1 CONSTRUCTION .............................................................................................................................. 21 4.2 OPERATIONS ................................................................................................................................... 26 4.3 WATER SUPPLY, USE, AND DISPOSAL ........................................................................................... 27 4.4 WASTE HANDLING ......................................................................................................................... 29 4.5 SAFETY ........................................................................................................................................... 30 4.6 SCHEDULE ...................................................................................................................................... 31 4.7 WORKFORCE .................................................................................................................................. 31 4.8 TRAFFIC.......................................................................................................................................... 32 4.9 RECLAMATION ............................................................................................................................... 34 4.10 REPRESENTATIVE APPLICANT-COMMITTED MEASURES ............................................................... 37

Tables

Table 1. GELLC Existing and Approved Development .............................................................................. 6 Table 2. Proposed Disturbance for Project Components ............................................................................. 8 Table 3. Proposed Well Pads by Lease and Surface and Mineral Ownership ........................................... 20 Table 4. Estimated Annual Water Usage during Construction, Drilling, and Completion ........................ 28 Table 5. Estimated Workforce for a Single Well ....................................................................................... 32 Table 6. Estimated Vehicle Round-Trips per Activity for Construction of a Single Well ........................ 33

Maps

Map 1 General Location ............................................................................................................................... 2 Map 2 Proposed Action ................................................................................................................................ 3 Map 3 Proposed Action and Previously Approved GELLC Well Pads ....................................................... 4 Map 4 Detailed Location of Proposed Federal 1090 #30 Well Pad ............................................................ 10 Map 5 Detailed Location of Proposed Federal 1190 #20 Well Pad ............................................................ 12 Map 6 Detailed Location of Proposed Federal 1190 #29 Well Pad ............................................................ 14 Map 7 Detailed Location of Proposed DGU 1289 #20-23 Well Pad .......................................................... 16 Map 8 Detailed Location of Existing IPU 1291 #13-24 Well Pad ............................................................ 18

Figures

Figure 1 Preliminary Layout for Federal 1090 #30 Well Pad ..................................................................... 11



Figure 4 Preliminary Layout for DGU 1289 #20-23 Well Pad ................................................................... 17

Figure 5 Preliminary Layout for Existing IPU 1291 #13-24 Well Pad ....................................................... 19

Left blank for two-sided copying.

Gunnison Energy, LLC


DOI-BLM-CO-N040-2017-0050-EA

1

1.0 INTRODUCTION

Gunnison Energy LLC (GELLC) proposes to drill, complete, and operate 35 horizontal wells from four

new well pads and one existing well pad and to construct associated access roads and gathering lines over

a 3-year period in Gunnison and Delta counties, Colorado (Map 1). The distribution of proposed well

pads and horizontal wells would be designed according to unit obligations for the four Federal units (Trail

Gulch, Sheep Park II, Iron Point, and Deadman Gulch) within the North Fork Mancos Master

Development Plan (NFMMDP) project area. The Trail Gulch Unit is currently awaiting Bureau of Land

Management (BLM) approval. Although some locations would be on Fee lands (private surface

overlying private minerals), all of the wells at those locations would access Federal minerals. GELLC is

therefore required to comply with U.S. Forest Service (FS) and BLM standards (as applicable) at all

locations regardless of surface ownership.

For analysis purposes, eight Mancos shale gas wells are proposed for each new well pad, and three

Mancos shale gas wells are proposed for the existing well pad, for a total of 35 new wells. Proposed

wells would access Federal minerals using horizontal drilling technologies. Map 2 shows the distribution

of the four proposed well pads and one existing well pad across the four Federal units composing the

NFMMDP project area, which includes a total of 34,906 acres. Map 3 shows the Proposed Action along

with existing, approved, or previously analyzed well pads and related facilities. Three of the proposed

new well pads (Federal 1090 #30, Federal 1190 #20, and Federal 1190 #29) would be constructed on

National Forest System (NFS) lands with underlying Federal leases, and one new well pad (Deadman

Gulch Unit - DGU 1289 #20-23) would be built on Fee surface with underlying Fee minerals but would

access Federal minerals. The one existing well pad (Iron Point Unit – IPU 1291 #13-24) is located on Fee

surface with underlying Fee minerals but would also be used to access Federal minerals as shown on

Maps 2 and 3. No new disturbance is proposed for this existing well pad. Construction, drilling, and

completion activities for the NFMMDP would occur over a 3-year period and would allow for production

of up to 700 billion cubic feet of natural gas over the life of the project, estimated at 30 years.

The NFMMDP project area lies within the administrative boundaries of the FS Grand Mesa,

Uncompahgre, and Gunnison National Forests (GMUG) Paonia Ranger District and the BLM

Uncompahgre Field Office (UFO) in Montrose, Colorado. Although the NFMMDP project area lies

within the UFO administrative boundaries and contains existing oil and gas infrastructure approved by

that field office, the Federal fluid mineral leases, and existing and proposed oil and gas developments, are

managed by the BLM Colorado River Valley Field Office (CRVFO) in Silt, Colorado, as part of an oil

and gas consolidation program. Consequently, the BLM-CRVFO and the FS-GMUG Paonia Ranger

District are the responsible offices for National Environmental Policy Act (NEPA) analysis and project

implementation. The BLM-CRVFO Field Manager would be the approving official for the Applications

for Permit to Drill (APDs) for Federal oil and gas wells situated on both NFS and private lands.

This project is the first phase of a potential 13-pad development by GELLC within the NFMMDP project

area. At present, however, potential development of beyond the initial five well pads is only conceptual

and too speculative in location, timing, scale (number of pads and wells), intensity (number of drill rigs),

and perhaps drilling technology to allow detailed planning and analysis. The uncertainty regarding

potential future development also reflects that the design of any future development would be based in

large part on results of the initial five-pad project represented by the current Proposed Action. Other

factors affecting future development may include natural gas prices, continued advances in drilling and

completing technologies, and additional constraints associated with air quality, water depletions, or other

environmental issues. The potential future development will be addressed as cumulative impacts in the

current EA and, when uncertainties are more fully resolved, analyzed in a subsequent EA.

Federal 1090 #30

IPU 1291 #13-24 DGU 1289 #20-23

Federal 1190 #20

Federal 1190 #29#*

Somerset

McClure Pass

UV265

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Gunnison GorgeWildernessStudy Area

White RiverNationalForest

GunnisonNationalForest

CollegiatePeaks

Wilderness

MaroonBells-Snowmass

Wilderness

RaggedsWilderness

WestElk

Wilderness

PaoniaReservoir

Grand MesaNationalForest

NavalOil ShaleReserve

UV347

UV348

UV13

UV92 UV135

UV82

UV65

UV330UV133

£¤6

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Basalt

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BattlementMesa

Carbondale

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Rifle

Silt

Crested Butte

Olathe

Aspen

SnowmassVillage

Delta County

GunnisonCounty

Mesa County

MontroseCounty

Eagle County

GarfieldCounty

Pitkin County

10 0 105Miles MAP 1

General Location


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Deadman Gulch Federal UnitIron Point Federal UnitSheep Park II Federal UnitTrail Gulch Federal UnitNFMMDP Project Area

Forest ServiceDepartment of DefenseBureau of Land ManagementNational Park ServiceBureau of Reclaimation

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Clear Fork Rd

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IPU 1291#13-24

DGU 1289#20-23

Federal1090 #30

Federal1190 #20

Federal1190 #29

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611 616

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Pipelines / Gathering LinesBull MountainExistingProposedNFMMDP Project Area

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Jacobs1290 #6-32

Allen1291 #12-13

IPU1291 #13-24

Sheep-BullConnector Pipeline

Option 2 AccessOption 1 Access

Federal 16-4

Federal 21-7

Federal1090 #33Federal

1090 #31

HotchkissFederal18-43





HotchkissFederal18-22D

Federal1190 #7

Allen12-24

HotchkissSec 18 Pad

Henderson8-14

Spadafora20-21

Lone Pine #1A

Hotchkiss1290 #1-34

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Proposed Action andPreviously Approved GELLC Projects


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Gunnison Energy LLC



5

2.0 PROJECT LOCATION AND ACCESS

The NFMMDP Federal units are located in the northwestern corner of Gunnison County and on the

eastern edge of Delta County in the North Fork of the Gunnison River Basin of west central Colorado

(Map 1). The NFMMDP project area is located approximately 10 miles northeast of Paonia, Colorado,

and approximately 20 miles southwest of Carbondale, Colorado.

Legal descriptions for the NFMMDP project area are as follows:

6th Principal Meridian, Mesa County, Colorado

T. 10 S., R. 90 W., All of Sections 16-21, 28-33

T. 11 S., R. 90 W., All or parts of Sections 3-10, 16-22, and 27-31

T. 12 S., R. 89 W., All or parts of Sections 17-20

T. 12 S., R. 90 W., All or parts of Sections 3-11, 1314, 18-19, 24, and 30

T. 12 S., R. 91 W., Parts of Sections 11-14, 23-26

Proposed well pad locations and surface ownership are shown on Map 2. Surface ownership within the

34,906 acre NFMMDP project area is NFS lands (25,790), BLM-administered lands (468 acres), and

private lands (8,648 acres). The NFMMDP project area includes 46 Federal leases totaling 30,972 acres

of which 4,714 acres are “split estate” (private surface with underlying Federal minerals). The status of

each Federal unit is described below:

Trail Gulch Unit – Received designation on 10/18/2016; currently awaiting BLM approval. After

final BLM approval is granted, GELLC would have 6 months to drill the unit obligation well.

Sheep Park II Unit – Approved by the BLM on 4/30/2015. The unit and the leases are currently

in suspense until drilling of the unit obligation well can be resumed in spring 2017.

Iron Point Unit – Effective date of the unit is 8/9/2014. A participating area has been established.

The unit will enter the continuous drilling phase on 8/9/2019.

Deadman Gulch Unit – Effective date of the unit is 9/15/2012. A participating area has been

established. The unit will enter the continuous drilling phase on 9/15/2017.

Colorado State Highway 133 (SH 133) is the main access to the NFMMDP project area (Map 2). From

the Town of Carbondale, access to the NFMMDP project area follows SH 133 south for 25 miles to

McClure Pass and then another approximately 10 miles from McClure Pass to County Road (CR) 265.

CR 265 is followed for approximately 5 miles to the NFMMDP project area boundary. Inside the

NFMMDP project area, unpaved NFS and County Roads, and private roads, would be used to access the

individual well pads.

3.0 EXISTING AND APPROVED DEVELOPMENT AND INFRASTRUCTURE

Table 1 provides a listing of existing or approved GELLC wells pads, wells, and associated infrastructure

in the NFMMDP project area (also see Map 3). The general project vicinity shown on Map 2 and Map 3,

but outside the NFMMDP project boundary, includes existing or approved wells and other infrastructure

with various operators. The BLM is currently awaiting publication of the Final Record of Decision

(ROD) for the Bull Mountain Unit MDP/EIS (Environmental Impact Statement), which proposes

development of Federal and private fluid minerals from private lands immediately east of the NFMMDP

project area.

Gunnison Energy LLC



6

Table 1. GELLC Existing and Approved Development

Project Component Unit Year Constructed and Status 1 NEPA Approval

Federal 1090-31

Trail Gulch

1977 – one producing gas well

Approved by FS

Federal 1090 #33 1977 – one producing gas well

Federal 16-4 1981 – one producing gas well

Federal 1090 #30-4 1981– one producing gas well

Federal 1090-32 1983 – one producing gas well

Federal 21-7 1993 – one shut-in gas

Federal 1190 #17

Sheep Park II

1976 – one shut-in gas well Approved by FS

Federal 1190 #7 1977 – one plugged and abandoned

gas well Unknown

Jacobs 1290 #6-32 2007 – one shut-in coal seam well No NEPA (Private)

Spadafora #20-21 2016 – two approved gas wells CO-S050-2015-0029-EA

Henderson #8-14 2016 – one approved gas well

Lone Pine #1A

Iron Point

2004 – one shut-in coal seam well

No NEPA (Private)

Allen #12-24 2005 – one producing coal seam well

Allen 1291 #12-13 2007 – one shut-in water disposal

well

IPU 1291 #13-24 2011 – one producing shale well, one

shut-in coal seam well

Hotchkiss Federal 17-13

Deadman Gulch

2005 – one producing coal seam

well, one APD pending drilling CO-150-2005-45-EA

DGU Federal 1289 #18-

43

2006 – one producing coal seam

well, two APDs pending drilling CO-150-2006-022-EA

Hotchkiss Federal 20-12 2006 – one producing shale well

Hotchkiss 1290 #1-34 2006 – one producing coal seam well No NEPA (Private)

Hotchkiss Federal 18-31 2006 – one producing coal seam well CO-150-2006-022-EA

Hotchkiss 1289 #18-22D 2006 – one active water disposal well

Hotchkiss Federal 17-11 2009 – one producing shale well, two

APDs pending drilling CO-150-2008-35-EA

Hotchkiss #18 Pad

2014 – two producing shale wells;

two coal seam wells awaiting

completion

DOI-BLM-CO-S050-2014-

009 CX (390)

Hotchkiss Water Storage

Facility 2010 – Active No NEPA (Private)

Sheep Gas Gathering line

(also water line) Various Constructed 2008 and 2009

EA, Paonia Ranger District,

June 2007

Sheep-Bull Connector Non-Unit Approved – not constructed CX – Forest Service,

October 2010

1 Includes gas wells (conventional wells), coal seam wells, and marine shale wells.

Gunnison Energy LLC



7

3.1 EXISTING DEVELOPMENT AND INFRASTRUCTURE

Currently, GELLC operates 21 well pads within or adjacent to the NFMMDP project area (Map 3).

These include six in the Trail Gulch Unit, three in the Sheep Park II Unit, four in the Iron Point Unit, and

eight in the Deadman Gulch Unit. GELLC currently operates 15 producing wells (12 Federal and three

Fee), including five coal seam wells. An additional seven wells (four Federal and three Fee) are shut-in,

including three coal seam wells. GELLC operates two disposal wells, including the Hotchkiss 1289 #18-

22D in the Deadman Gulch Unit, which is an active Federal well, and the Allen 1291 #12-13 in the Iron

Point Unit, which is a shut-in Fee well (Map 3 and Table 1).

In 2008 and 2009, GELLC installed the Sheep Gas Gathering System throughout the project; this system

also includes a water pipeline. In 2010, GELLC constructed the Hotchkiss Water Storage Facility in the

Deadman Gulch Unit. These facilities allow for water used during drilling and completion, along with

produced water originating from the targeted formations, to be treated and transferred in the Sheep

Gathering System for re-use. The Bull Mountain Pipeline (50% owned by GELLC and 50% owned and

operated by SG Interests) was constructed in 2009 and transports produced natural gas to markets. The

Bull Mountain Pipeline was analyzed in a multi-agency Environmental Impact Statement (EIS) approved

in January 2008.

3.2 APPROVED DEVELOPMENT AND INFRASTRUCTURE – NOT CONSTRUCTED

In 2015, the FS and BLM approved the Dual Operator Proposal (DOI-BLM-CO-S050-2015-029-EA)

addressing wells to be developed by GELLC and SG Interests and allowing for construction of the

Spadafora and Henderson well pads (eight natural gas wells) in the Sheep Park II Unit (Map 3 and Table

1). The Spadafora #20-21 well pad was constructed in 2016 on private land. The Henderson #8-14 well

pad proposed on NFS land was approved but has not been constructed. The Sheep-Bull Connector

Pipeline, to be operated by GELLC, was approved by the FS in October 2010 (Map 3).

4.0 PROJECT COMPONENTS

Project components include four new wells pads (eight wells each), one existing well pad (three wells),

and associated access roads and gathering lines. Table 2 provides estimates of initial and long-term

disturbance for the well pads, access roads, and gathering lines. Initial disturbance includes all new

disturbance occurring during construction of the four new well pad locations, access roads, and gathering

lines. Once constructed, the well pads would be stabilized until the last well has been drilled on the pad,

at which time interim reclamation would occur (discussion in Section 4.9, below).

Long-term disturbance is that portion of the initial disturbance that would remain during production of the

wells (after interim reclamation) and would include the production facilities and access roads. Production

would continue as long as economic quantities of natural gas are produced, and could persist over and

estimated 30-year productive life. A portion of the access road disturbance and all disturbance for

gathering lines would be reclaimed immediately after construction or within the next growing season.

The estimates in Table 2 include the proposed disturbances on Federal lands (NFS lands and BLM-

administered lands) and private lands. Approximately 60% of the initial disturbance would occur on

Federal lands and 40% would occur on private lands (Table 2).

Gunnison Energy LLC



8

Table 2. Proposed Disturbance for Project Components

Well Pad Surface

Ownership

Number or

Length (feet)

Initial

Disturbance Acres

(Federal/Private)

Long-term

Disturbance Acres

(Federal/Private)

WELL PADS

Federal 1090 #30 Federal 1 2.64/0 1.28/0

Federal 1190 #20 Federal 1 4.28/0 2.44/0

Federal 1190 #29 Federal 1 3.81/0 1.10/0

DGU 1289 #20-23 Private 1 0/5.11 0/1.09

IPU 1291 #13-24 Private 1 0.0 0/0

Total (Federal/Private) 3/2 10.73/5.11 4.82/1.09

ACCESS ROADS 1

Federal 1090 #30

road reroute Federal 684 0.47/0 0.38/0

Federal 1190 #20 Federal 3,579 2

1.07/1.39 3 0.86/1.11

3

Federal 1190 #29 Federal 5,636 3.88/0 3.11/0

DGU 1289 #20-23 Federal/Private 4,226 4

0.42/2.49 0.33/2.00

IPU 1291 #13-24 Private 0 0/0 0/0

Total (Federal/Private) 8,484/5,641 5.84/3.88 4.68/3.11

GATHERING LINES 5

Federal 1090 #30 Federal 54 0.04/0 0/0

Federal 1190 #20 Federal 166 0.11/0 0/0

Federal 1190 #29 Federal 0 0/0 0/0

DGU 1289 #20-23 Federal/Private 4,219 6

0.45/2.45 0/0

IPU 1291 #13-24 Private 0/0 0/0 0/0

Total (Federal/Private) 879/3,560 0.60/2.45 0/0

Grand Total (Federal/Private) 17.17/11.44 9.50/4.20 1 Access road width is 30 feet for initial disturbance and 24 feet for long-term disturbance (14 feet plus ditches).

2 Length is for Option 1 (Map 2), including 1,560 feet on NFS lands and 2,019 feet on private lands. Option 2

(Map 2) would include 15,067 feet on NFS lands, of which 2,700 feet would be outside the Sheep Park II Unit. 3 Under Option 2, initial disturbance would be 10.38 acres, and long-term disturbance would be 8.30 acres.

4 Includes 604 feet on BLM land and 3,622 feet on private land; access road and gathering line are collocated.

5 Gathering line width is 30 feet for initial disturbance, to be reclaimed promptly.

6 Includes 659 feet on BLM land and 3,560 feet on private land.

Multi-Well Pads

Estimated initial and long-term disturbance for four new well pads is listed in Table 2. Table 3 lists each

well pad and provides surface and mineral ownership, leases, and lease stipulations. Three new well pads

(Federal 1090 #30, Federal 1190 #20, and Federal 1190 #29) would be constructed on Federal

surface/Federal minerals with a total disturbance of 10.73 acres. One new well pad (DGU 1289 #20-23)

Gunnison Energy LLC



9

would be constructed on Fee surface/Fee minerals but would access Federal minerals and would disturb

5.11 acres. An existing well pad (IPU 1291 #13-24) located on Fee surface/Fee minerals but accessing

Federal minerals would not require new disturbance. As described above, each new well pad would

accommodate up to eight wells, and the existing well pad may accommodate up to three new wells, for a

total of 35 wells. Note that the proposed Federal 1190 #20 well pad actually consists of two separate

pads. This was done to better fit with topography and reduce the height of cut-and-fill slopes.

Maps 4 through 8 show proposed pad sizes and shapes in relation to site topography; associated access

roads and gas gathering pipelines are also shown on the maps. Figures 1 through 5, presented

sequentially with the analogous maps, are layouts depicting the limits of disturbance in greater detail

along with areas of cut-and-fill. Once the final design for each pad is achieved during the EA process, the

final versions of Figures 1 through 5, and additional plats, would be attached to the APDs submitted by

GELLC for each proposed well. Final design of the pads may differ from the preliminary layouts to

reflect minor refinements arising from additional field surveys.

Access Roads and Gathering Lines

The EA will analyze two road options for accessing the Federal 1190 #20 and 1190 #29 well pads,

depending on GELLC’s ability to use existing access across private land. This is shown as Option 1 on

the Maps 2 and 3; Option 2 would require a new access road to be constructed entirely on NFS lands.

Table 2 lists the estimated length and disturbance for proposed new access roads (Maps 4 through 8).

Under Option 1, an estimated 2.68 miles (14,125 feet) of new access roads would be required, of which

1.49 miles (7,880 feet) would be on NFS lands, 0.12 mile (604 feet) would be on BLM land, and 1.07

miles (5,641 feet) would be on private lands. Under Option 2, and estimated that 4.85 miles (25,613 feet)

of new access roads would be required, of which 4.04 miles (21,387 feet) would be on NFS lands, 0.12

mile (604 feet) would be on BLM land, and 0.69 miles (3,622 feet) would be on private lands. Initial

disturbance width for new access roads would be 30 feet, with a long-term disturbance of 24 feet (14 feet

of driving surface and 5 feet for ditches on each side). All road construction shown in Table 2 is for new

roads; no upgraded or reconstructed roads are proposed. All new roads would be constructed within the

Federal units except for 2,700 feet of the access road leading to the proposed Federal 1190 #20 well pad,

north of the Sheep Park II Unit. This portion of road would require authorization from the FS.

Table 2 also lists the estimated combined length and proposed disturbance for natural gas and water

gathering lines. It is estimated that 0.84 mile (4,439 feet) of new gathering lines would be required, of

which 0.17 mile (879 feet) would be on Federal lands and 0.67 mile (3,560 feet) would be on private

lands. Of the gathering lines on Federal lands, 0.04 mile (220 feet) would be on NFS lands, and 0.13 mile

(659 feet) would be on BLM lands. The gathering lines would be buried, constructed of welded high-

strength steel (12-inch diameter for natural gas and 6-inch diameter for water), and installed concurrently

in the same trench. Pipeline construction would typically occur concurrently with road construction,

especially when buried lines are collocated with a road (Maps 4 through 8).

The internal surface of the steel pipe would be protected with corrosion inhibitor chemicals and cathodic

protection, and would be monitored with corrosion coupons and water analyses. The outside of the pipe

would be wrapped and protected. Poly pipe would not be used due to its limited pressure rating. Initial

disturbance for gathering line installation would be 30 feet. No long-term disturbance is attributed to

pipelines, because all disturbed surfaces would be reclaimed immediately after construction or as soon as

practicable in the following growing season. However, several years would typically be required for

revegetation efforts to establish a self-sustaining community of native species, or of desirable non-natives

(e.g., pasture grasses, alfalfa, clover, etc.) if specified by the private landowner.

COC 013600

COC 013601

COC 013602

8600

8500

8400

8100

8000

8900

8800

8500

8400

8400

8300

83008200

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7900

8700

8500

8100

8400

8400

8300

8200

8400

Battle Creek

Spri ng Creek Littl e Muddy Creek

1,000 0 1,000500Feet MAP 4

Detailed Location of ProposedFederal 1090 #30 Well Pad


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Figure 1

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Option 2 Access

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Figure 2



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COC 064169

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Table 3. Project Well Pads and Attached Stipulations

Well Pad/ Unit/

Location

Surface

Ownership/

Lease/Date

Bottomhole

Federal

Leases

Lease Stipulations

Federal 1090 #30

(New Pad)

Trail Gulch Unit

T10S, R90W

Sec. 30, SWSE

FS

COC013600

11/1/71

COC013600

COC013601

COC013602

COC013600: No occupancy of the surface of the

following areas is authorized by this lease. The lessee

is, however, authorized to employ directional drilling to

develop the mineral resources under these areas

provided that such drilling or other works will not

disturb the surface area or otherwise interfere with their

use by the Forest Service. It is understood and agreed

that the use of these areas for National Forest purposes

is superior to any other use. Areas to be excluded from

direct drilling occupancy are:

1) Within 500 feet on either side of the centerline of

roads and/or highways within the lease areas.


trails within the lease area.

3) Within 500 feet of the normal highwater line of

lakes, ponds, and reservoirs within the lease area.

4) Within 500 feet of the normal highwater line of

streams within the lease area.

5) Within 400 feet of springs within the lease area.

6) Within 400 feet of any improvements owned,

permitted, leased, or otherwise authorized by FS.

The distances indicated it items 1 through 4 may be

reduced when agreed to in the operating plan.

Federal 1190 #20

(New Pad

Sheep Park II Unit

T11S, R90W

Sec. 20, NESE

FS

COC013483

11/1/1971

COC070004

COC013483: No occupancy of the surface of the

following areas is authorized by this lease. The lessee is,

however, authorized to employ directional drilling to

develop the mineral resources under these areas

provided that such drilling or other works will not

disturb the surface area or otherwise interfere with their

use by the Forest Service. It is understood and agreed

that the use of these areas for National Forest purposes

is superior to any other use. Areas to be excluded from

direct drilling occupancy are:


roads and/or highways within the lease areas.


trails within the lease area.

3) Within 500 feet of the ordinary high water mark of

lakes, ponds, and reservoirs within the lease area.

4) Within 500 feet of the ordinary high water mark of

streams within the lease area.

5) Within 400 feet of springs within the lease area.

6) Within 400 feet of any improvements owned,

permitted, leased, or otherwise authorized by FS.

The distances indicated it items 1 through 4 may be

reduced when agreed to in the operating plan.

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Well Pad/ Unit/

Location

Surface

Ownership/

Lease/Date

Bottomhole

Federal

Leases

Lease Stipulations

Federal 1190 #29

(New Pad)

Sheep Park II Unit

T11S, R90W

Sec. 29, SWSE

FS

COC070004

6/1/2007

COC070004

COC069066

COC070004: No Surface Occupancy for slopes greater

than 60%, high geologic hazard, and wetlands,

floodplains/riparian areas.

Controlled Surface Use for slopes 40% to 60%,

moderate geologic hazard, and elk winter habitat.

No surface use is allowed from December 1 through

April 30. This stipulation does not apply to operation

and maintenance of production facilities. For the

purpose of protecting critical elk winter ranges.

DGU 1289 #20-23

Deadman Gulch

Unit

T12S, R89W

Sec. 20, NESW

Fee

COC065106

COC065107

COC065108

COC068350

COC064169

Surface location overlies Fee lease; Federal lease

stipulations are not applicable. Operator abides by

executed Surface Use Agreement with private

landowner, subject to FS/BLM conditions of approval.

IPU 1291 #13-24

(Existing Pad)

Iron Point Unit

T12S, R91W

Sec. 13, SWSE

Fee

COC065112

COC065113

COC065120

COC065534

Surface location overlies Fee lease; Federal lease

stipulations are not applicable. Operator abides by

executed Surface Use Agreement with private

landowner, subject to FS/BLM conditions of approval

relative to Federal resources.

4.1 CONSTRUCTION

The following subsections present Design Features and Applicant-Committed Measures intended to avoid

or reduce impacts to surface and certain subsurface resources. Section 4.10 lists some of the features

described below and additional features to which GELLC has committed. Additional operator-committed

measures, and agency-applied conditions of approval, are expected to arise during preparation of the EA.

All of these constraints on the method, location, and timing of development would be enforceable

measures during implementation of the project.

Proposed Well Pads

The proposed well pads would be constructed from native soil and rock materials present onsite using a

bulldozer, grader, front-end loader, and/or backhoe. The pads would be constructed by clearing

vegetation, stripping and stockpiling all available topsoil and suitable subsoil to a depth of 12 inches, and

leveling the pad area using cut-and-fill techniques. The tops of the cut banks and pad corners may be

rounded to improve their appearance. The topsoil would be windrowed around the well pad perimeter.

On well pads with heavy fuel loadings, brush or trees would be hydro-axed to eliminate the mass of

material to be cleared. The well pad would be fenced stock-tight using a four-strand and sheep-restricting

wire fence using a design approved by FS/BLM and Colorado Parks and Wildlife.

During winter, a snowcat mounted with a snowplow or blower would be used to push or blow all but the

2 or 3 inches of snow closest to the well pad surface off the location. The remaining few inches of snow

would be left behind on the well pad to be driven on, eventually absorbed into the surrounding location,

or slowly evaporated away throughout the season.

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Access Roads

GELLC proposes to use approximately 26 miles of existing unpaved roads. None of the existing unpaved

roads would require upgrading or widening. GELLC has an agreement with Gunnison County to apply

magnesium chloride on CR 265. New resource roads in width would be constructed concurrently with

new well pads. Road construction and upgrades would comply with Surface Operating Standards and

Guidelines for Oil and Gas Development, also known as the Gold Book (USDI and USDA 2007).

In accordance with standards, drainage control would be ensured over all roads through the use of

drainage dips, in-sloping and ditches, natural rolling topography, ditch turnouts, armored crossings, or

culverts. Site-specific road design measures would consider grades, soils and local hydrology. Where

culverts or drainage crossings are needed, they would be designed for a 25-year storm frequency, unless

FS or BLM specify a larger culvert, and without development of a static head at the pipe inlet. Details of

road design and construction would be provided with each APD.

GELLC would implement the following measures on existing and constructed roads on all lands unless

directed otherwise by the landowner and deemed by FS or BLM to meet safety requirements:

All roads used in conjunction with this project would be maintained in a condition as good as or

better than pre-project condition. Timely routine maintenance of roads would be provided.

Regular maintenance would include dust, but not be limited to abatement; reconstruction of the

crown, slope, or water dips/bars; blading or resurfacing; clean-out of ditches, culverts,

catchments; and other Best Management Practices (BMPs).

Roads would be crowned or sloped, drained with ditches, culverts and/or water dips and

constructed, sized, and surfaced in compliance with Gold Book standards.

Water outlets and roadside ditches would incorporate BMPs such as rip-rap, sediment

catchments, and anchored check structures to slow water velocity and prevent erosion and

sediment transport. Ditches may be revegetated and/or include large rocks or other BMPs to slow

water and settle sediment. Ditch revegetation may also be required in erodible soils. All drainage

ditches and culverts would be kept clear and free-flowing and would be maintained in good

condition.

Road use and construction would halt under conditions of undue damage and erosion to soils,

roads, and/or locations. When saturated soil conditions exist on access roads or location, or

rutting deepens past 4 inches, construction and travel would halt until soil material dries out, is

frozen sufficiently, or is otherwise brought to standards that provide for resource protection.

Where applicable, initial road base/gravel application would be of Colorado Department of

Transportation (CDOT) Class 6 aggregate or equivalent, to a minimum depth of 6 inches.

Where roads are located near drainages, vegetated buffer strips would be left between surface

disturbances and drainages.

Gravel would be placed on roads where and when required to maintain the surface integrity.

Periodic road blading would be conducted throughout the road system to re-gather gravel and

place it within the roadway.

All cut-and-fill slopes for roads would be protected against erosion using BMPs such as soil

texturing and seeding or other measures. Measures may include geotextiles, weed-free straw

mulching/wattles/matting, as needed or as detailed in GELLC’s Stormwater Management Plan

(SWMP). BMPs would be monitored and maintained in functional condition.

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Roads accessing active construction and drilling sites would be posted with warning signs to alert

hunters and recreational vehicle users to project personnel and vehicles in the area. Project

personnel would restrict activities and travel to permitted roads and sites.

Speed limits on unpaved access roads would be posted to minimize dust created during travel;

where speeds are not posted on unpaved access roads, speeds would not exceed 25 mph.

Gates may be installed at the entrance of new access roads to limit access based on surface owner

desires.

Cattle guards would be installed at locations where range fences are bisected on the new access

roads.

Where construction occurs on NFS lands, final design of road construction would be reviewed

and approved by the District Ranger and/or FS engineer.

On NFS lands, all road design packages for roads open to public would conform to AASHTO

Guidelines for Geometric Design of Very Low Volume Local Roads (Average Daily Traffic -

ADT <400).

In coordination with the FS, a pre-use road conditions assessment would be conducted for

affected NFS roads. GELLC would obtain and/or modify FS special use permits and road use

permits.

If any roadwork is required, a work schedule would be submitted to the Paonia District Ranger

before any work is started. Repairs would be made under agency specifications and terms in the

Road Use Permit.

Culverts would be placed/replaced where necessary in roadways and be sized to handle a

minimum 25-year flood event subject to larger sizes on a case-by-case basis.

Operations would cease, excepting emergencies, during periods when mud and silt cannot be

contained within the road prism, when construction specification cannot be achieved because of

wet or frozen ground conditions, or for any occurring or imminent resource damage.

FS/BLM approved dust abatement measures (e.g., fresh water, driving speeds of 10 mph) would

be applied as appropriate to road and pad locations. Chemicals such as magnesium chloride

would not be utilized without approval from the FS/BLM.

Any project-related damage to roads would be repaired as soon as possible to avoid adverse

impacts on other authorized road uses, provide for continued safe operations, and protect surface

resources on other authorized road uses on the Forest.

The vehicle weight load on FS roads would be no greater than 120,000 pounds (60 tons) unless

otherwise authorized under the road use permit.

GELLC would plow or blow snow when snow cover exceeds 6 inches in depth to maintain access

to the well pad. Access to the well pad is necessary even with remote telemetry.

Gathering Lines

During construction of the gathering lines, topsoil would be salvaged and windrowed separately from the

underlying subsoil and stored along the road until the trench is backfilled. Gathering lines would not be

constructed during frozen conditions. Frozen soil would not be used to backfill the trench. All gathering

lines would be buried to a minimum depth of 3 feet from surface to top of pipe (or greater where needed

to avoid freezing in winter). The gathering line trench would be excavated mechanically; pipe segments

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would then be welded together and tested, lowered into the trench, and covered with excavated material.

After burial, each gathering line would be pressure tested with compressed air or nitrogen to locate leaks.

To reduce the potential effect on surface water and groundwater resources, gathering line construction

would occur at times of year when the water table is lower, generally May and June.

Drilling

Drilling would be conducted in compliance with all Federal Oil and Gas Onshore Orders, as well as all

other applicable rules and regulations. If economic natural gas resources are identified, additional testing

(evaluation of drill cuttings, geophysical logging, and/or drill stem testing) would occur to ensure casing

strength in preparation for casing perforation and stimulation (by hydraulic fracturing with nitrogen

foam). GELLC anticipates that to the extent possible, annual drilling programs would be conducted with

one drilling rig. However, due to wildlife timing limitations, it is possible that two drilling rigs would be

used outside the seasonal exclusion period to facilitate project completion within the overall project

timeframe. All drilling and completion rigs would be powered by Tier 2 engines or better. During

preparation of the EA, emissions inventories would be entered into the BLM Colorado State Office

Emissions Tracking Tool and an air quality impact analysis would be conducted to ensure that State and

Federal ambient air quality standards are met.

The Williams Fork, Iles, and Mancos formations would be targeted during drilling. The target zone for

the wells is between 5,000 and 10,000 feet true vertical depth. The length of horizontal sections is not

known but generally would not exceed 8,000 feet in length.

Usable water zones encountered during drilling would be protected in accordance with the Federal

Onshore Oil and Gas Orders and the 43 Code of Federal Regulations - CFR § 3100 by installing surface

or intermediate casing as approved by the BLM Authorized Officer (AO) and reported. All usable water

zones, potentially productive hydrocarbon zones, and valuable mineral zones would be isolated.

A closed-loop drilling system would be used which eliminates the requirement for reserve pits. In the

proposed closed-loop system, a series of storage tanks are used to separate liquids and solids. This

equipment minimizes the amount of drilling waste muds and cuttings that require disposal and maximizes

the amount of drilling fluids that are recycled and reused in the drilling process. The disposal of drill

cuttings is discussed below in Section 4.4, Waste Handling.

Drilling would be performed with circulation of an inert bentonite and potassium chloride water-based

mud, with various viscosity and density-adjusters such as polymers and barite. Density would be adjusted

to lift cuttings and suppress formation fluid pressure. Other additives may be used to stabilize borehole

wall expansive clays. Drilling mud lubricates and cools the bit and flushes cuttings to settling tanks at the

surface. Drilling mud would be displaced from the well bore in each separate casing setting and

cementing event (surface, intermediate, and production casings).

Water based drilling mud and cement would be used to spud wells and set surface casing from ground

level to the depth needed to protect fresh water aquifers, as determined during the review of individual

APDs. Up to four casing strings would be installed in every borehole. Blowout Preventer Equipment

(BOPE) would be attached to the top of the surface casing to contain unexpected fluid blowouts. Prior to

drilling below the surface casing, both the BOPE and the surface casing would be tested for pressure

integrity. The BOPE and related equipment would meet the minimum requirements of Federal Onshore

Oil and Gas Order No. 2, and the BLM would be notified in advance to witness all pressure tests.

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During continued drilling, intermediate casing would be set for the protection of gas, usable quality water

zones (if encountered), and prospectively valuable minerals deposits; for protection against abnormal

pressure zones and lost circulation zones; or when otherwise required by expected well conditions. The

casing string would be cemented with a sufficient volume of cement to cover and/or isolate all

hydrocarbon zones or other mineral deposits; to isolate abnormal pressure intervals from normal pressure

intervals; and to contain any fluids with a potential to migrate and/or isolate formation fluids.

After drilling the initial hole to its final depth, logging tools would be run into the well to evaluate the

potential hydrocarbon resource. If the evaluation indicates that adequate hydrocarbon resources are

present and recoverable, steel production casing would be run and cemented into place in accordance with

the well design as approved by the BLM. The entire casing and cementing program would be designed to

protect and/or isolate all usable water zones, potentially productive zones, lost circulation zones,

abnormally pressured zones, and any prospectively valuable deposits of minerals.

Following drilling, green completions would be utilized to clean the well bore. In a green completion,

excess natural gas is captured rather than being flared or released to the atmosphere. Natural gas would

be directed immediately into the gathering lines and transported to sales lines.

All equipment would have sound- (noise-) control devices no less effective than those provided by the

manufacturer. All equipment would have muffled exhausts. Engine braking by trucks would not occur

on Federal lands. Generator(s) serving drilling rigs would be installed and operated at the site in a

manner that, at a minimum, meets the COGCC’s Noise Abatement regulation No 802b (1) and (2).

Completions

Wells would be drilled and completed (fractured) sequentially, using up to two completion rigs. Drilling

of one well and completion of another well on the same well pad at the same time (referred to as

simultaneous operations or “simops”) may occur.

After production casing has been cemented in place, the drilling rig would be removed and a completion

rig and associated equipment would be moved in. Well completion would consist of running a cement

bond log to evaluate the cement integrity and to correlate the cased hole logs to the open hole logs. The

casing would be perforated across the hydrocarbon producing zones, and the formation would be

stimulated to enhance the production of natural gas. The typical method used for stimulation consists of a

hydraulic fracture treatment in which sand and fluids or foam are pumped into the producing formation

with sufficient pressure to fracture the rock formation (Section 4.3 below for Water Use). The sand

serves as a proppant to keep the created fracture open, thereby allowing reservoir gases and fluids to

move more efficiently into the well bore.

Fracture stimulation fluids are custom-engineered to accomplish various objectives, including:

Pressuring the formation through perforations in the production casing to fracture the rock, and

propagate those fractures some distance into the formation;

Carrying proppant particulates, sand, ceramic or plastic (to prop fractures open when the pressure

is released), and small rubber balls to block perforations and hold injected fluids outside the

casing for a short time; and

Carrying other chemicals to “break” the foam suspending the proppant, disinfect the hydraulically

fractured zone, and retard microbial growth which can sour the well, and finally flush general

residual chemicals.

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Most constituents used in hydraulic fracturing are either inert materials (sand), biodegradable, or

consumed in the treatment (acid, pH buffers). Biocides are commonly introduced into the wellbore to

slow microbial growth until the fluid can be produced in flowback water. Types of chemicals used in the

hydraulic fracturing process will be provided in the EA.

Due to the remoteness of the proposed well pads, the project would not limit use of lighting during

nighttime drilling or completion activities. Well pads and access roads would be kept orderly and as

clean as practicable at all times. Well site cleanup would be concluded after completion.

4.2 OPERATIONS

Existing Facility Locations

Existing facilities that would support the Proposed Action include the Sheep Gathering System and

existing gathering lines leading to existing wells pads, the Hotchkiss Water Storage Facility, two water

disposal wells (Hotchkiss 1289 #18-22D in the Deadman Gulch Unit and Allen 1291 #12-13 in the Iron

Point Unit), and the Bull Mountain Pipeline. Water storage is described below in Section 4.3, Water

Supply and Use and the water disposal wells are described below in Section 4.4, Waste Handling.

Gas Gathering and Water Production

The wells would produce natural gas and produced water during normal operations. Natural gas would be

used to fuel equipment located on the well pads. GELLC estimates that natural gas production from a

single shale well could be up to 10 million standard cubic feet per day (MMSCFD) and could total 20

billion standard cubic feet over the life of the well. Condensate is not expected and sour gas has not been

encountered and none is expected. Natural gas and water would be transported in separate gathering lines

(either existing or installed under this proposal) from the well pads to the Sheep Gathering System. The

Bull Mountain Pipeline would transport the natural gas to the Divide Creek Treatment Facility and final

markets. Initial water production would be a few hundred barrels per day reducing to 1 to 10 barrels per

day after the first year and would continue to decline. Although the shale does not produce much water

on its own, it does slowly return water from drilling and completion over time. Existing water lines

would transport produced water to GELLC’s existing Hotchkiss Water Storage Facility.

Production

Once wells are drilled and completed, they would be placed into production and operated for an estimated

30 years, or until no longer economic. After all wells have been drilled on a well pad, interim

reclamation of the pad would occur. Equipment and facilities located on the production well pad would

include the wellhead, vertical treater, re-circulating pump, two-phase separator building, line heater,

generator, and two 400-barrel water tanks. Where more than one well is located on a single well pad,

production equipment would be shared to the greatest extent possible. Wellhead equipment would be

fired by natural gas. Solar powered remote telemetry would be installed at each well pad. The telemetry

system would transmit data on gas and water production flow rates and pressures and on operating

temperatures of various wellhead equipment.

Produced water and fluids would be pumped from the wellhead, separated, and stored in tanks onsite until

sufficient volume is collected to send via gathering line for recycle at the Hotchkiss Water Storage

Facility or disposal at the Hotchkiss 1289 #18-22D or Allen 1291 #12-13. If recycled, the produced water

would eventually be filtered and used for drilling and completing additional wells.

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All installed production facilities with the potential to leak or spill produced water, glycol, or other fluid

which might be a hazard to public health or safety would be placed within an appropriate impervious

secondary containment structure that would hold 110% of the capacity of the largest single container

within it for 72 hours. Secondary containment would consist of lined corrugated steel containment or

compacted earthen berms. Compaction and construction of earthen berms would be performed to prevent

lateral movement of fluids through the utilized materials. All load-out lines would be placed inside the

containment structure or berm.

On NFS lands, all facilities or structures would be painted BLM Standard Environmental Color in a non-

reflective finish (as specified in the individual APD) that blends with the background landscape.

Workovers and Recompletions

Workover or recompletion of individual wells may be required periodically (estimated once every 5

years) to ensure that efficient production is maintained. Workovers can include repairs to well bore

equipment (casing, tubing, rods, or pump), a wellhead, or production facilities. Workover activities

would usually be completed during daylight hours.

4.3 WATER SUPPLY, USE, AND DISPOSAL

During construction, water would be required for drilling, well completion (includes hydraulic fracturing

with nitrogen foam), and dust control. Net consumptive use of fresh water (i.e., not including re-use of

treated and recycled water) would be reported to the BLM, and by the BLM to the U.S. Fish and Wildlife

Service. This reporting is a requirement of a Programmatic Biological Opinion relative to effects of

depletions in flows in the Upper Colorado River Basin on four species of endangered Colorado River

fishes.

Drilling

Anticipated water use for drilling a single horizontal shale well is approximately 3,000 barrels (1 barrel is

equal to 42 gallons). Of this total, approximately 1,000 barrels would be fresh water and 2,000 barrels

would be recycled water obtained from the Hotchkiss Water Storage Facility by continuous transfer via

the Sheep Gathering System. Annual water use for all wells is shown in Table 4.

Completion

GELLC expects that well completion (using hydraulic fracturing with nitrogen foam) would require

approximately 30,000 barrels of recycled water for a single horizontal shale well. The actual amount of

water required to complete a well would not be known until the well is successfully drilled, however,

30,000 barrels is considered to be a reasonably conservative estimate. The Hotchkiss Water Storage

Facility, which provides recycling and storage for GELLCs production operations is expected to provide

all water required for well completions. Annual use for all wells is shown in Table 4.

Dust Abatement

GELLC would use fresh water control dust on unpaved FS, county, and private roads (approximately 26

miles) and in construction areas. After turning onto CR265 from SH 133, the road surface is typically

graveled. GELLC has an agreement (LI#10-241) whereby Gunnison County will grade and apply

magnesium chloride to CR265 annually. GELLC assumes that dust control would require 40 barrels of

water per mile per day and that water would be applied to roads 122 days per year (for 4 months from the

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beginning of June through September). Under these conditions, 126,880 barrels of water would be

consumed annually for dust control during the 3 year period for well pad construction, drilling, and

completion. Magnesium chloride would not be utilized to reduce dust without approval from the

FS/BLM or private landowner.

Table 4 summarizes the annual estimated water requirements for the Proposed Action during the 3-year

development period. Annual water requirements for drilling and completing 12 wells per year is

estimated to be 522,880 barrels (67.40 acre-feet); however, only 138,880 barrels (17.90 acre-feet) of fresh

water would be required. Recycled water from the Hotchkiss Water Storage Facility would provide the

balance of the water needed.

Offsite sources would provide fresh water for dust control and drilling the surface casing. Fresh water

would be obtained from one of three sources (commercial or GELLC’s existing water rights): Oxbow

Mine (Section 8, T13S, R90W), Farnsworth Construction & Gravel Company (175 Highway 133, Paonia,

CO), or West Muddy Creek (either during free water conditions or water transfer at Section 20, T12S

R89W). Water from West Muddy Creek would be pumped from the pumping station adjacent to an

existing well pad in the Deadman Gulch Federal Unit (HKF DGU 1289 #20-12). Water obtained from

these sources would be trucked to the project area via SH 133, CR 265, and NFSR 851. The use of all

fresh water would be approved by the Colorado Division of Water Resources.

Table 4. Estimated Annual Water Usage during Construction, Drilling, and Completion

Type of Water Drilling Completions Dust Control Total

Fresh Water 12,000 barrels

(1.55 acre-feet) None

126,880 barrels

(16.35 acre-feet 138,880 barrels

(17.90 acre-feet)

Recycled Water 24,000 barrels

(3.09 acre-feet)

360,000 barrels

(46.40 acre-feet) None

384,000 barrels

(49.49 acre-feet)

Total 36,000 barrels

(4.64 acre-feet)

360,000 barrels

(46.60 acre-feet)

126,880 barrels

(16.35 acre-feet)

522,880 barrels

67.40 acre-feet

1 barrel = 42 gallons

GELLC’s existing Hotchkiss Water Storage Facility would provide the recycled water used to drill

intermediate and horizontal sections and for well completions, including hydraulic fracturing with

nitrogen foam. Tanks would be placed on well pads to store the volumes of water needed for completion.

Recycled water from these storage facilities would be delivered to and from individual well pads via

collocated water lines associated with the Sheep Gathering System, which would reduce the project’s

need for trucks to supply and dispose of recycled water, unused fresh water, and immediate flowback

water.

The Hotchkiss Water Storage Facility has a holding capacity of approximately 450,000 barrels. Water

stored in this facility is from GELLC’s permitted non-tributary Coal Bed Methane Wells, HKF 1289 #18-

31 (SEO Permit #68075), HKF 1289 #17-13 (SEO Permit #68076), HKF 1289 #18-43 (SEO Permit

#68074) and HK 1290 #1-34 (SEO Permit #68073) located in the SWSE of Section 1, T11S, R90W).

Water would be continually transferred via the collocated, buried water lines of the Sheep Gathering

System and would not be treated prior to use at the wellhead. Water returns from drilling and completion

as well as produced water during operations may be filtered and returned to the storage facilities via the

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Sheep Gathering System for possible re-use. If the water is not needed, it would be disposed of in

GELLC’s existing permitted Class II waste water disposal well (HK 1289 #18-22) located in the SENW

of Section 18, T12S, R89W.

4.4 WASTE HANDLING

GELLC would conduct drilling using closed-loop drilling systems and would not construct reserve pits.

Cuttings would exit the well bore and would be centrifuged to remove liquids which would be reclaimed

for drilling. The cuttings generated during drilling would come off the mud management equipment and

into a roll-off cuttings bin. Several cuttings roll-off bins would be onsite at all times to ensure sufficient

volume is available during variable drilling conditions.

Cuttings would be transported to a State-approved offsite commercial disposal facility. Approved

disposal facilities near the project area include the Delta County Adobe Buttes Landfill located at 12211

Trap Club Road, Eckert, Colorado or CB Industries, 11289 Doughspoon Road, Austin, Colorado, or

ECDC Environmental Landfill in East Carbon, Utah. Hauling of the cuttings to the disposal facility

would commence within 2 days of generating cuttings.

Drilling mud liquids collected after being processed through the closed-loop system may be transported

by truck to other GELLC drilling locations for recycling if drilling elsewhere is underway. Should no

wells be available, an alternative commercial disposal for drilling mud liquids is utilization of the Deer

Creek Disposal Facility at 5180 US Highway 50 in Whitewater, Colorado.

During flowback following the fracture stimulation on a well, produced fluids and gases would be flowed

to a flowback tank, where any solids (usually only sand proppant) may settle out. The solids are then

physically removed from the flowback tank and disposed of in an approved landfill. Flowback of fluids

and gases from the well is closely monitored and controlled to minimize the production of sand used in

the completions process.

All flowback fluids and produced water would either be stored on the well pad in tanks (if water

production is not sufficient to support continuous pumping) or piped directly to the Hotchkiss Water

Disposal Facility and eventually filtered and used to drill and complete additional wells. Water not

suitable for re-use would be disposed in GELLC’s existing wastewater disposal well (HK 1289 #18-22),

which has a remaining permitted disposal capacity of approximately 3.2 million barrels of fluid.

Portable latrines would be provided by service companies onsite for human wastes. The service company

would also remove the portable latrines and properly dispose of the wastes.

Trash and garbage would be placed in appropriate caged containers equipped with bear-resistant opening

and the container and contents would be transported to an approved disposal site, (e.g., Delta County

sanitary landfill). Waste oils from equipment would be stored onsite in lined containment areas sufficient

to contain 110% of the single largest container. Upon drilling and completion equipment demobilization,

these wastes would be disposed at an approved offsite facility. Waste oils would be recycled by Safety-

Kleen Systems, 368 Bonny Street, of Grand Junction, Colorado.

Signs would be posted onsite to identify potential hazards including chemical hazards. For all treatment

chemicals, Safety Data Sheets (SDS) files would be maintained onsite during drilling and completion.

Spills related to project activities would be handled in accordance with the GELLC’s Spill Prevention,

Countermeasure and Control (SPCC) Plan. All releases of any substance to soil or water would be

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immediately reported to the BLM and, as appropriate, the FS Authorized Officer, as well as the COGCC.

GELLC would prevent gasoline, diesel fuel, oil, grease, or any other petroleum products and drilling

fluids from migrating off the location or from entering any live stream or riparian area. No refueling or

lubricating would take place within 100 feet of wetlands and other water bodies or drainages. Hazardous

materials, chemicals, fuels, etc. would not be stored within 100 feet of wetlands or surface waters. A spill

kit would be available on all active locations. Spills of any kind would be cleaned up, reported, and

disposed of as required by Federal, State, and local regulations. Containment of the spill would occur

immediately, clean up of a spill would occur as soon as practicable, and a report would be provided for

the record. Any hazardous substances or contaminated soils would be removed and disposed in

accordance with applicable Federal, State, and local regulations.

Upon demobilization of the drilling rig, the drilling pad would be cleaned of all excess materials, debris,

and any other fluids encountered and disposed of in an approved manner. The same process would be

repeated upon demobilization of the completion rig and equipment. Immediately upon well completion,

the well location and surrounding area(s) would be cleared of all debris, trash, and materials or equipment

not required for production.

4.5 SAFETY

General

Firearms and dogs would not be allowed on the access road or location during any phase of the project.

Mapped locations of the proposed well pads, including GPS location (lat/long) would be provided to

appropriate emergency services personnel.

GELLC would coordinate with range permittees to minimize safety risks associated with use of ranch

roads for construction, drilling, and completion activities.

Fire

The drilling crew would have sufficient fire equipment on hand during fire season for suppressing fires on

the well pad, access road, and gathering line route.

GELLC would comply with any fire restrictions in effect at the time of proposed operations and

understand that the FS reserves the right to suspend operations during periods of high fire potential.

GELLC would be able to contact emergency services, including Montrose Interagency Fire Dispatch at

all times. Fire prevention measures for all equipment would be in place prior to post drilling operations

on GELLC's equipment.

Fire extinguishers, at least 5 lbs., ABC with an Underwriters Laboratory rating of 3A-40BC, or greater,

would be maintained on or near each internal combustion engine.

GELLC would be responsible for damage and suppression costs for fires started as a result of operations,

to the extent permitted by Federal and State law. Fires would be reported to the FS/BLM as soon as

possible.

All gasoline, diesel, and steam-powered equipment would be equipped with effective spark arresters or

mufflers. Spark arresters would meet FS specifications discussed in the "General Purpose and

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Locomotive (GP/L) Spark Arrester Guide, Volume 1, April, 1988"; and "Multi-position Small Engine

(MSE) Spark Arrester Guide, April, 1989". In addition, all electrical equipment would be properly

insulated to prevent sparks.

Signage

All construction signage would be in compliance with the Manual of Uniform Traffic Control Devices.

GELLC would post signs on CR 265 to alert the public of heavy truck traffic.

GELLC would provide for the safety of the public using State Highway 133 during construction. This

includes, but is not limited to, posting of appropriate signs to alert traffic on SH133 of potential stops or

delays when construction equipment is either using the highway or turning off or on to the highway to

access the project area. GELLC would also post warning signs, at locations designated by the FS, to warn

the public of increased traffic on roads resulting from project activities.

GELLC would use flaggers as necessary during drilling and related equipment moves on and off the drill

site when utilizing public roads.

4.6 SCHEDULE

Under GELLC’s desired schedule, the Federal 1090 #30 well pad would be built as soon as all approvals

are obtained (2017) and the initial well for the Trail Gulch Unit, would be drilled within 6 months of APD

approval. The Federal 1190 #20 and Federal 1190 #29 well pads would be constructed and the initial

wells drilled once all approvals are obtained (2017). The DGU 1289 #20-23 well pad would be built once

all approvals are obtained and the access road to the well pad is built (2017); however, the initial well

would probably be drilled in 2018. The three shale gas wells proposed on the existing IPU 1291 #13-24

well pad would be drilled once all approvals are obtained. Well completions would immediately follow

drilling, subject to weather conditions. Two to three additional wells (up to eight total) would be drilled

on each of the four new well pads in subsequent years until the well pads are fully developed. One or

possibly two drilling rigs and completion rigs would be operating at any one time during the currently

proposed project. Wells are expected to remain in production for up to 30 years.

4.7 WORKFORCE

Construction of a single well is estimated to require 81 workers over approximately 91 days (Table 5).

The drill rig would operate with two shifts, 24 hours per day, 7 days per week. The completion rig is

expected to operate with one shift working during daylight hours, 7 days per week. Although

completions may be conducted 24 hours per day depending on the selected contractor; activity levels

during completion are expected to vary. During long-term production of the well(s), two workers would

be required: one pumper visiting the well daily and one maintenance worker conducting two routine

maintenance (5 days each) per year.

Workforce levels during construction (including drilling and completion) are estimated to include 152

workers assuming that two wells are being drilled and two wells are being completed. Based on the

assumption that one pumper can visit approximately 30 wells per day, the workforce in subsequent years

of production is estimated to include seven workers: four pumpers and three maintenance workers.

GELLC expects that, with the exception of well completion crews, the workers required during

construction would reside in Gunnison and Delta counties. Overall, GELLC expects that approximately

57% of the construction workforce would be local (residents of Gunnison and Delta counties) and that the

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remaining 43% would be non-local (residents of other counties). Local workers are also expected to

comprise the small operational workforce.

Table 5. Estimated Workforce for a Single Well

Project Phase and Workforce Category Duration

(days)

Number of

Workers

Construction

Well Pad, Road, and Gathering Line Construction 171 7

2

Drilling 30 to 45 363

Well Completion 28 to 364 35

5

Interim Reclamation 3 2

Dust Control 916,7

1

Total 81

Operations

Pumper daily 4

Maintenance 108 3

Total 7

1 Based on the concurrent construction of well pads, roads, and gathering lines. Includes 3 days for equipment and

pipe mobilization and demobilization. 2 Includes one bulldozer operator, one blade operator, one track hoe operator, one welder, one two-man gathering

line crew, and one supervisor. 3 Based on two drilling shifts per day, with 18 drilling workers per shift. Includes 10 days for drill rig mobilization

and demobilization. 4 Includes 20 days for rig and hydraulic fracturing tank mobilization and demobilization and 16 days for hydraulic

fracturing. 5 Includes one completion shift per day. 6 Assumes that road dust is controlled during well pad construction, drilling, completion, and interim reclamation on

an as-needed basis between June and October. 7 Ten days of mobilization of completion equipment would overlap with drilling. 8 Includes two 5-day maintenance periods per year.

4.8 TRAFFIC

Construction of a single well is estimated to require 1,702 vehicle round-trips over approximately 88 days

of construction (Table 6). Three events would occur during construction: well pad, road, and gathering

line construction (135 vehicle round-trips over 17 days or an average of 7.9 vehicle round-trips per day),

drilling (725 vehicle round-trips over 45 days or an average of 16.1 vehicle round-trips per day), and well

completion (842 vehicle round-trips over 36 days or an average of 23.4 vehicle round-trips per day).

Mobilization of the completion rig and delivery of hydraulic fracturing tanks for 10 days would overlap

with drilling of the first well. Approximately 3 days would be required for interim reclamation of well

pads.

Stabilization of the well pad would occur if additional wells on the pad are planned within a timeframe

that would preclude prompt interim reclamation. However, interim reclamation would normally occur

within 6 months of drilling and completion activities. This would occur over a 3-day period and would

require one heavy vehicle trip in at the beginning of reclamation and one out at the end of reclamation and

one light-vehicle in and out daily.

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Table 6. Estimated Vehicle Round-Trips per Activity for Construction of a Single Well

Activity Number

Of Days

Light

Vehicle

Round-Trips

Heavy

Vehicle

Round-trips

Total

Vehicle

Round-Trips

Well Pad, Road and Gathering Line Construction

Equipment Mobilization/Demobilization 2 0 61 6

Pipe Delivery 1 0 14/day 14

Construction 14 6/day2 1/day 98

Dust Control3 17 0 1/day 17

Total 135

Drilling

Drill Rig Mobilization/Demobilization 104 6/day 25

1 85

Well Drilling 35 14/day

5 1/day 525

Supply, equipment, miscellaneous deliveries 35 1/day 1/day 70

Dust Control3 30 to 45 0 1/day 45

Total 725

Completion

Completion Rig Mobilization/Demobilization 66 6/day 10

1 46

Hydraulic Fracturing Tank Delivery 14 0 20/day7 280

Sand and Nitrogen Delivery 16 0 17/day 272

Hydraulic Fracturing 16 10/day 1/day 176

Supply, equipment, miscellaneous deliveries 16 1/day 1/day 32

Dust Control6 28 to 36 0 1/day 36

Total 842

Single Well Construction Total 1,702

1 Vehicles enter the project area once, remain onsite, and leave the project area once.

2 Includes two crew trucks, two welding trucks, and two miscellaneous trucks.

3 Assumes that road dust is controlled during pad/road/gathering line construction, drilling, and completion on an as-

needed basis for 122 days between the beginning of June and the end of September. 4 Includes 5 days for drilling rig set-up and 5 days for drilling rig-take down.

5 Includes two worker vans and five additional light vehicles per shift with two shifts per day.

6 Includes 3 days for completion rig set-up and 3 days for completion rig take-down.

7 Includes 140 hydraulic fracturing tank deliveries/removals over 7 days before and 7 days after well completion.

Once the drilling and completion rigs have been brought into the NFMMDP project area, average daily

traffic during construction is estimated to include approximately 37 vehicle round-trips per day during the

3-year project duration. Following construction, average daily traffic associated with long-term

production of the wells is estimated to include four pumper vehicles per day. Additional maintenance

visits to well pads would also be required on an intermittent basis.

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4.9 RECLAMATION

On NFS lands, reclamation activities and standards would be guided by the Gold Book, GMUG Forest

Plan Standards, and the FS Manual 2840. The FS and BLM would be contacted at least 48 hours prior to

planning and pre-construction onsite meetings and prior to commencement of any reclamation (interim

and final) activities, and within 48 hours of completion of reclamation work and mobilization of heavy

equipment onto NFS lands. Appropriate reclamation bonds on NFS lands related to the project would be

posted according to 36 CFR § 228.109.

In consultation with the FS/BLM, a reclamation plan would be prepared in order to effectively manage

the interim or final reclamation of lands disturbed by the project. All surface disturbance would be

reclaimed to a condition that is consistent with forest and resource management plans, as well as any site

specific stipulations or conditions of approval. Disturbed areas would be reseeded in accordance with

BLM or FS standards, or with specific requirements of the landowner for pads on private surface.

Reseeding would occur as soon as possible after construction activities have been completed. The

objective for interim reclamation is to achieve stability, visual, hydrological, and productivity objectives

set by the GMUG Forest Plan and prescribed in the decision documentation and assurance that long-term

reclamation objectives would be reached through natural processes. The long-term objective for final

reclamation is to return the land to a condition approximate or equal to that which existed prior to the

disturbance.

Erosion control would be deemed sufficient when adequate vegetation cover is reestablished, water

naturally infiltrates into the soil, the site complies with the approved SWMP and when gullying,

headcutting, slumping, and deep or excessive rilling is not observed. Proper site preparation would be

ensured by spreading of stored and salvaged topsoil or topsoil replacement to an adequate depth and by

ripping, tilling, disking, harrowing, and dozer track imprinting where appropriate.

Revegetation efforts on Federal lands would include the use of FS- or BLM-approved native seed mixes

that are certified weed-free, timing the seeding operation to occur as soon as possible following

recontouring and spreading of topsoil while minimizing soil loss, monitoring revegetation within the site,

and controlling noxious weeds. Annual reports to the FS and BLM would provide information on

disturbed acres, interim-reclaimed acres, and final-reclaimed acres on NFS lands.

Woody debris that can be used for reclamation would be salvaged for use in constructing erosion and

sedimentation control devices, as directed by the FS or BLM, based on site conditions and if allowed by

the terms of any timber harvest permit (if required).

Stabilization and Interim Reclamation

Once a well is drilled on a well pad and if the next well would not be drilled for 6 months, the well pad

would be stabilized. All disturbed surfaces, including stored topsoil, would be roughened and seeded

with an approved see mix to maintain soil stability and viability. All stormwater BMPs would be

monitored and maintained. The area would be graveled for all-weather conditions and the well pad would

be fenced to exclude livestock. All cuttings would be hauled off.

Once the last well is drill on a well pad, interim reclamation would occur. During interim reclamation,

the footprint of disturbance would be minimized through reclamation and revegetation of all disturbed

areas not needed for future drilling and production operations (e.g., cut/fill slopes, borrow ditches, areas

temporarily disturbed along access roads). This reclamation would consist of returning topsoil to these

areas, seeding with weed-free seed, and using any salvaged woody debris for surface roughening. All

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areas outside the work area would be reseeded according to the FS/BLM, or private landowner

recommendations for seed mixture.

The topsoil would be seeded to prevent erosion and to preserve its integrity. Requirements for seedbed

preparation, seed, seeding procedures, mulching, erosion control, fencing, security and monitoring would

be as specified for interim reclamation. Prior to interim reclamation, GELLC would meet with the

FS/BLM and the adjacent private landowner (when applicable) to inspect the disturbed area, to review the

existing reclamation plan and agree upon any revisions to the plan.

Well Plugging and Abandonment

New wells that prove unproductive or non-economic would be plugged, abandoned, and reclaimed within

90 days of well completion, weather permitting. During abandonment, each borehole would be plugged,

capped, and its related surface equipment removed. Subsurface lines would be purged and plugged at

specific intervals. A Sundry Notice would be submitted to the BLM proposing the engineering, technical,

and/or environmental aspects of final plugging and abandonment. This notice would include final

reclamation procedures and mitigation measures. Plugging and abandonment of wells would use industry

BMPs and comply with all applicable rules and regulations set forth by the BLM and/or the COGCC. A

configuration diagram, a summary of plugging procedures and a job summary with techniques used to

plug the wellbore (e.g., cementation) would be included in the Sundry Notice.

Final Reclamation

A well pad that no longer has a producing well or associated facilities would undergo final reclamation

following plugging and abandonment of the final well on that pad. Final reclamation within 1 year

following plugging and abandonment of the final well on that pad. Prior to final reclamation of the well

pad, a review the existing reclamation plan would occur and any changes agreed to by FS/BLM, unless

private landowner dictates otherwise.

If necessary, a revised reclamation plan would be submitted to FS/BLM with the Notice of Intent to

Abandon.

Final reclamation and restoration would include monitoring, revegetation with native species, and control

of noxious weeds and other undesirable plant species. All road surfacing gravel and other 'non-native' fill

materials would be removed from public lands or buried deep in the recontouring so that it would not

reemerge. Final reclamation restoration would include salvage and reuse of all available topsoil.

Buried gathering lines would be reclaimed to final reclamation standards at the time of installation (e.g.

surface recontouring, covered with salvaged topsoil, surface roughening, seeding, and redistribution of

salvaged woody debris).

Final reclamation of the well pad would consist of stripping topsoil and interim vegetation from portions

of the site that are not at the original (or restoration) contour, recontouring of material storage piles,

cut/fill slopes and SWMP features, spreading stripped topsoil over the entire disturbed site, and ensuring

successful revegetation as specified in the final reclamation plan or final reclamation plan approved by

the FS/BLM, or private landowner.

As part of final reclamation processes, all equipment, facilities, and trash would be removed from the

location; each borehole would be plugged, capped, and its related surface equipment removed; subsurface

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gathering lines would be purged and plugged at specific intervals; dry hole markers would be subsurface,

to prevent their use as perching sites by raptors.

Final reclamation of new roads associated with the proposed action no longer needed for operations

would either be: turned over to the appropriate authority such as surface management agency or private

landowner for continued use; or decommissioned by obliteration, recontouring, and seeding.

Final reclamation progress would be monitored (including roads and vegetation) through development

and implementation of aggressive and adaptive weed management and monitoring plans and protocols,

and comply with prevention measures for noxious weeds; "noxious weeds" shall be those undesirable

plant species designated to be "noxious weeds" pursuant to the Colorado Noxious Weed Act.

Reclamation – Seedbed Preparation

The seedbed would be prepared by scarifying (roughening) the spread topsoil prior to seeding, unless

seeding takes place immediately following spreading is drilled. Seedbed preparation may include

pocking, ripping, disking, or other soil roughening techniques. Drilling of seeds is the preferred method,

although broadcast seeding may be approved under certain circumstances.

Revegetation efforts would consider the ecology of the site, such as elevation, slope, aspect, and soils, and

identifying native plant communities present prior to disturbance. This would be done in consultation

with FS/BLM personnel or as per the project conditions of approval. Site preparation would be planned

to occur during the appropriate season to avoid frozen or saturated soils and weather delays. Exclusion of

livestock may also be considered, as may possible adjustment of reclamation measures to ensure

successful revegetation of the site.

Seeding would be conducted no more than 24 hours following final seedbed preparation. Subsequent

reseedings would be implemented if interim revegetation is unsuccessful.

Reseeding would be completed using a certified weed-free seed mixture using methodologies and rates as

approved by the FS/BLM and in consultation with the private landowner (where applicable). Weed-free

certification, seed tags, and Subsequent Report Sundry Notice describing the reclamation would be

submitted to the FS/BLM within 30 days of seeding. Disturbed areas would be seeded with a seed

mixture approved by the FS/BLM or the landowner. Seeds would contain no noxious, prohibited, or

restricted weed seeds and contain no more than 0.5% by weight of other weed seeds. Only viability-

tested, certified seed for the current year, with a minimum germination rate of 80% and a minimum purity

of 90% would be used.

Final revegetation would include use of certified weed free straw mulch or other approved mulch,

particularly on all slopes greater than 3:1 (33%). In certain situations, FS/BLM may require the use of

soil testing and, potentially, the application of soil amendments.

The FS/BLM would be notified of areas where final reclamation appears successful. GELLC would

regularly monitor for reclamation success and for invasive species and would submit annual monitoring

reports to the FS/BLM by December 1 of each year. The annual reports would document whether

attainment of reclamation objectives appears likely. If objectives appear unlikely to be achieved, the

report would identify appropriate corrective actions.

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4.10 REPRESENTATIVE APPLICANT-COMMITTED MEASURES

The project design by GELLC, as incorporated into individual APDs as the Surface Use Plan of

Operation (SUPO) and described in previous parts of this Proposed Action, includes a variety of design

features intended to avoid or minimize impacts to surface resources. These applicant-committed

measures, including but not limited to those listed below or described earlier for the Proposed Action,

would be supplemented by additional measures identified by the FS/BLM during preparation of the

project EA. All applicant-committed measures and additional conditions of approval identified GELLC

in the SUPOs accompanying individual APDs, or identified and applied by the FS/BLM under their

respective regulatory authority as conditions of approval, would be monitored and enforced during project

implementation.

Air Quality

Gunnison Energy would provide data to produce an emissions inventory and facilitate a project-

level air-quality impact analysis. Results of the air quality analysis may require mitigation, such

as adjustments to the project design.

Gunnison Energy would apply fresh water as necessary for dust abatement on access roads.

Portions of the access roads would be graveled, reducing fugitive dust.

Following drilling, green completions would be utilized, which would capture excess natural gas

rather than flaring or releasing it to the atmosphere. Natural gas would immediately be placed in

the gathering lines and transported to sales.

Cultural Resources

All GELLC employees and contractors working in the project area would be informed that any

person who, without a permit, injures, destroys, excavates, appropriates or removes vertebrate

fossil, historic or prehistoric ruin, artifact, object of antiquity, Native American remains, Native

American cultural item, or archaeological resource on public lands is subject to arrest and penalty

of law (16 USC 433, 16 USC 470, 18 USC 641, 18 USC 1170, and 18 USC 1361).

If newly discovered historic or archaeological materials or other cultural resources are identified

during construction, work in that area would stop and the FS/BLM would be notified immediately

If inadvertent discovery of Native America Human Remains or Objects of Cultural Patrimony

occurs, activity would stop in the area of discovery and a reasonable effort would be made to

protect the item(s) discovered. The FS/BLM would be immediately notified.

Water Quality

In order to detect and determine water quality impacts from future oil and gas activities, GELLC

would continue to conduct a baseline water quality study for the area. In addition, GELLC would

follow Water Resources Monitoring Plan that has been developed for the area. This monitoring

plan would include pre- and post- drilling water monitoring of springs and streams. In

accordance with Rule 609, Statewide Groundwater Baseline Sampling and Monitoring, water

quality monitoring of existing groundwater wells would occur. Up to four initial baseline

samples and subsequent monitoring samples would be collected from water sources within a one-

half mile radius of the well pad location. Initial sampling would be conducted within 12 months

prior to setting conductor pipe in the first well on the pad.

All areas that are disturbed during construction would be included in a state-mandated General

Construction permit for stormwater discharges from the Colorado Department of Health and

Environment (CDPHE). The federal units are currently permitted and a Stormwater Management

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Plan is in place for each of the permitted areas. The plan would be updated as necessary to

include all new construction. BMPs as required by the permits and plans would be installed

before, during, and maintained after construction until the location reaches final stabilization

following reclamation. All other requirements of the permits would be followed, such as the bi-

weekly and post-precipitation event inspections and reclamation of disturbed areas, to stabilize

them.

Well pads would be designed as zero discharge areas and any accidental releases at these sites

would be contained. GELLC would follow measures outlined in their Spill Prevention

Countermeasure and Control Plan (SPCC Plan).

Construction activities at perennial, intermittent, and ephemeral drainage crossings (e.g. burying

pipelines, installing culverts) would be timed to avoid high flow conditions.

Crossings of drainages deemed to be jurisdictional wetlands or other Waters of the U.S. pursuant

to Section 404 of the Clean Water Act may require additional culvert design capacity. Due to the

flashy nature of area drainages and anticipated culvert maintenance, the U.S. Army Corps of

Engineers (USACE) recommends designing drainage crossings for the 100-year event for Waters

of the U.S. Pipelines installed beneath stream crossings would be buried at a minimum depth of 4

feet below the channel substrate to avoid exposure by channel scour and degradation. Following

burial, the channel grade and substrate composition shall be returned to pre-construction

conditions.

GELLC would restore areas of temporary or permanent disturbance to wetlands or riparian areas,

with restoration design developed in consultation with the FS/BLM and USACE. The operator

shall consult with the BLM Colorado River Valley Field Office to determine appropriate

mitigation, including verification of native plant species to be used in restoration

Weed Control

Noxious weeds would be controlled on lands disturbed during development of a well pad, access

road, or pipeline. The FS/BLM would be consulted regarding appropriate noxious-weed control

methods.

Prior to mobilizing onto NFS or BLM lands, all equipment would be washed and cleaned to

minimize spread of noxious weeds.

Prior to ground-disturbance, surveys would be conducted to document noxious weeds within

proposed disturbance areas. State-listed A and B noxious weeds would be treated prior to ground

disturbance.

Prior approval from the FS/BLM would be obtained before beginning any herbicide treatment on

project-related areas. Pesticide Use Proposals and pesticide application records would be

submitted to FS/BLM as appropriate.

Herbicides would be selected based on recommendations by local weed control district, the

FS/BLM, and subject to landowner approval where applicable. All herbicides would be applied

in accordance with applicable laws and regulations on NFS and private lands.

To minimize weed establishment on disturbed surfaces, GELLC would seed temporarily

disturbed surfaces on well pads, conduct interim reclamation within one year after the last well is

drilled on a well pad, and revegetate pipeline-related disturbance promptly upon completion of

construction.

Gunnison Energy LLC



39

No soil from weed-infested areas would be salvaged until the infestation has been treated to

control the infestation. Soil from an infested area would not be used in any area other than where

it was collected.

At locations where new weed populations have been identified or pre-existing populations have

expanded, control measures would be taken to eradicate the populations or control their spread.

The selection of control methods would be based on the available technology and information on

the weed species and its control.

Occurrences of noxious weeds and other invasive non-native species would be monitored for the

life of the project. Surveys would be conducted concurrent with reclamation monitoring and

would occur as early in the year as feasible to identify and control noxious weeds before they

produce seed. Monitoring data collected would include species, location, and extent of the

infestation. An annual report would be provided to the FS regarding the results from monitoring

including adaptation to control protocols.

Wildlife

If vegetation clearing is planned to occur during the core breeding period for migratory birds

(May 15 to July 15), GELLC would conducting surveys 2 weeks prior to the clearing to identify

presence or absence of nesting migratory birds. If one or more active nests are found within 30

meters (100 feet) of the proposed vegetation removal, the FS/BLM may require that the activity

be delayed until fledging is complete.

Screening or other devices would be installed on stacks and on other openings of heater-treaters

or fired vessels to prevent entry by migratory birds.

GELLC would survey for the presence of active raptor nests within 0.25 mile of proposed well

pads or road/pipeline construction areas prior to initiating construction, drilling, or completion

activities during the raptor nesting season (approximately March 1 to July 31). If an active nest is

found within the buffer distance, GELLC would delay development activities until the young

have fledged or the nest has failed due to a natural cause.

No construction, drilling, or completion activities, or use of roads to support those activities,

would occur during the period December 1 to April 30 in areas mapped as winter range, severe

winter range, or winter concentration areas for deer, elk, or wild turkeys.

No construction, drilling, or completion activities would occur during the period May 15 to June

15 in areas mapped as elk production (calving) areas.

Documents

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