What is the Status of the Comprehensive Drilling Plan?

During the Attorney’s Report at the May 23 Council Meeting, CCOB Attorney Pat Gilbert told Council that they needed to have an executive session “to discuss legal matters on the Comprehensive Drilling Plan,” adding that it had to be soon and couldn’t wait until a review on June 12.  That Executive Session was hastily scheduled for 5 p.m. on Wednesday, May 30, preceding the study session on the oil and gas regulations.

The Comprehensive Drilling Plan (CDP) has not yet been approved by the City Staff but will begin Council review on June 12. The Oct. 24 Operator Agreement (MOU) between Extraction and the City requires that the City approve Extraction’s CDP before Extraction can begin drilling.

There have been many iterations in reviewing the CDP by both the City and Broomfield residents since it was first received from Extraction in a very rough form on December 15, 2017.  (These revisions are documented on the City’s Oil and Gas webpage here.)  Here are the latest steps in the process:

  • Extraction’s latest revision posted by the City on May 11 can be found here.
  • Extraction’s 61-page response to a lengthy period of citizen comments can be found here
  • The City’s request for enhancements to Extraction’s Risk Management information by June 4 can be found here.
  • The City Engineering Department’s email sent to Extraction on May 25 can be found here.

In a related issue, there have been many concerns raised that the State Colorado Oil and Gas Conversation Commission (COGCC) has not allowed all of the Best Management Practices (BMPs) from the CDP to be attached to the drilling permits.  In response to this, Extraction wrote in its response to Citizen Comments on the CDP on p. 50 of the 61-page document mentioned previously:

“Extraction submitted all of the BMPs that are in the Operator Agreement in its initial Form 2A and Form 2 submittal to the Colorado Oil and Gas Conservation Commission (“COGCC”).  However, as was explained during the negotiation of the Operator Agreement, many of the Best Management Practices (“BMPs”) which Extraction agreed to implement during the course of the project development in the Operator Agreement exceed the local, state and federal regulations and therefore the COGCC may not have jurisdiction and therefore, the COGCC requested that they be removed from the applications. To honor our commitment in the Operator Agreement that all applications on Form 2s and Form 2As to be submitted to the COGCC include all the BMPs in the Operator Agreement, Extraction has attached a copy of the Operator Agreement to the applications and has cited and referenced the Operator Agreement in the COGCC permit applications. We cannot control how the COGCC processes our applications.”

Residents are encouraged to continue to review the CDP and write of their concerns to Council and Staff.