As stated in the City’s May 4 update, at the request of the COGCC, Extraction prepared Best Management Practices (BMPs) to be included on the State Form 2A permits for the proposed 6 new well pads in Broomfield. Broomfield staff submitted comments to the COGCC on Extraction’s proposed BMPs for these State permits. The significance of having BMPs on the State Form 2A permits is that those BMPs will be enforceable by the State.
However, it does not appear that the State is allowing the City to include all BMPs as part of the COGCC Extraction filings. Citizens are invited to submit concerns by Thursday, May 24 about the COGCC permits or BMPs to the City at email@example.com and they will share them with the COGCC. Or you may write directly to the Executive Director of the COGCC, Julie Murphy, at: firstname.lastname@example.org.
Here is the letter that Broomfield resident Jean Lim wrote to the COGCC:
Many Broomfield residents were unpleasantly surprised and very concerned to learn that the COGCC has reneged on their public statements made at the COGCC hearing on October 31. This retraction by the COGCC is made evident by the COGCC forcing the City of Broomfield to accept narrowing of the focus of the Extraction Form 2A draft BMP language. This completely contradicts not only what was stated by the COGCC at the October 31 hearing, but also the COGCC’s prior encouragement of cities to enter into Operator Agreements in order to offload some of the work from the COGCC. We ask that the COGCC broaden the current directions given to the City and Extraction as to what is allowed in the Extraction Form 2A draft BMP language.
Over two days of the October 30 & 31 COGCC hearings, there was extensive discussion among the commissioners as to how to deal with the contingencies placed on Extraction’s spacing unit applications by Broomfield’s Operator Agreement with Extraction. On the second hearing day of October 31, Commissioner Bob Randall suggested compromise language for the spacing unit applications. The amended language stated,
The wells will be drilled from surface locations within the unit or at legal locations on adjacent lands. Any applications for Permits to Drill (Form 2) or Oil and Gas Location Assessments (Form 2A) filed by Extraction Oil and Gas, Inc in the unit on surface lands within the City and County of Broomfield will comport with the October 24, 2017 Amended and Restated Oil and Gas Operator Agreement between the Application and the City and County of Broomfield.
In the Operator Agreement referred to in this COGCC statement, the key component related to the COGCC Form 2As is that Extraction is required to complete a Comprehensive Drilling Plan (CDP) that is reviewed and approved by the City (Section 9). It is clear to many residents that the Extraction Form 2A draft BMP language falls far short of the current CDP. (Details of these deficiencies are listed in other citizen comments found here.)
The limitations that the COGCC is now placing on the Extraction Form 2A draft BMP language completely contradict the October 31 hearing statement of the COGCC. The residents of Broomfield recognize that the City and its citizens have spent countless hours and taxpayer dollars reviewing the CDP under the assumption that the COGCC would abide by its statement at the October 31 hearing. Again, we ask that the COGCC broaden the current directions given to the City and Extraction as to what is allowed in the Extraction Form 2A draft BMP language in order to uphold its own October 31 statements.
Thank you for your attention to this matter.