February Arapahoe County permits one click

Please use this form to send this letter below. If you wish to include more please use the Additional comments section. A copy will be sent to the email address provided.

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Dear Arapahoe County staff,
I am writing you regarding the following applications:

(UASI23-001) State LaPlata application
(UASI23-002) State Harvard/Yale
(UASI23-003) State Wetterhorn/Handies

As a concerned community member, I would like to urge you to reject these applications for the following reasons:

– In 2022, this was presented to the Energy and Carbon Management Commission and the public as a Comprehensive Area Plan (CAP). The operator splitting this CAP into separate applications seems questionable and not in good faith with the community. All levels of government need to consider the cumulative impacts of this plan.

– These locations are in the ozone non-attainment area. In 2022, the state of Colorado identified that oil and gas operations were the most significant contributor to ozone. These sites would directly perpetuate non-compliance with federal air quality standards if permitted. Considering each application separately only exacerbates the degraded air quality and defeats the purpose and effectiveness of a Cumulative Impacts approach.

– Two oil and gas pads are within a mile of Proposed Reservoirs B and C. When a site is selected, elevations may change as foundation preparation and grading would occur during the reservoir construction. Therefore, we must determine if they are downgradient from the proposed pad locations after construction. The Use By Special Review (USR) Process to argue protection would be "substantially equivalent" would be only a theoretical exercise at best. We request that any pad location within a mile of these proposed reservoirs be subject to the complete 1-mile setback to protect these critical resources.

– State La Plata was an exploratory location and did not go through the entire review process. The public needs the opportunity to engage in public comment on the risks. Expansion of this location must go through a full review and comply with all current regulations.

– State La Plata will be boring under both proposed Reservoir B and the Aurora Reservoir. We request that the operator, County, and state address our seismicity concerns with operator-funded independent seismic studies of the risks.

– The Arapahoe County Energy Specialist is retiring. The County should not rush these applications through, especially without knowing when phase 2b of the county regulations will begin. We request that the County start updating its oil and gas regulations with phase 2b and that the new energy specialist be involved with these applications.

– Approving this would completely disregard various baseline testing requested from the community, including air quality, shallow and deep fault geological, and other studies. We ask that baseline measurements be taken for the Aurora reservoir and the superfund site to include seismicity.

– Arapahoe and the state lack air monitoring, which is necessary to detect VOC releases and spikes. We request that the County or state install air monitors along the neighborhood perimeter and within at the operator’s expense. These well pads also require more monitoring at the sites themselves to provide adequate early warning of excursions. We also ask that Arapahoe has a functioning air quality department before any operations occur near residentially plated areas.

– These applications are also located within High Priority Habitat. These locations would increase noise, light, and truck traffic and disturb the wildlife, including, but not limited to, pronghorn, eagles, and owls.

In conclusion, I urge you to reject these permits at this time. We demand that the County review these applications as a comprehensive area plan. Reviewing these applications as a CAP will ensure the County and various state agencies address cumulative impacts. Please reject this permit at this time to give the state and EPA adequate time to establish a baseline.

Thank you for your time and consideration,
[Your Name]