Columbine Ranger District San Juan National Forest

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1 United States Department of USDA Agriculture 2?::75 Forest Service Columbine Ranger District San Juan National Forest POB Pearl Street Bayfield, CO Voice: FAX: File Code: 195/282 Date: June 23, 214 Dear Interested Party, The Forest Service is proposing to authorize a Surface Use Plan of Operations (SUPO) for two gas wells proposed by Petrox Resources Inc. and a SUPO for five gas wells proposed by Elm Ridge Resources for natural gas wells on existing leases located in the Bull Canyon and Goose Creek areas (respectively) of the eastern HD Mountains on the Columbine Ranger District of the San Juan National Forest (SJNF). The proposed natural gas wells would drill to and produce gas and water from the Fruitland geologic formation. The existing leases are within Petrox's Fosset Gulch Unit and Elm Ridge's Bull Creek Unit in Archuleta County. Please refer to the attached maps. Introduction Petrox and Elm Ridge have submitted SUPOs as part of Applications for Permit to Drill (APD) to the Bureau of Land Management (BLM). BLM forwarded the SUPOs to the Forest Service because the surface locations are on National Forest System lands. Forest Service is reviewing the SUPOs and will decide what conditions of approval are appropriate. The SUPOs and conditions of approval will be transmitted to the BLM, and APD decisions will then be made by the BLM. Pursuant to the Mineral Leasing Act of 192, as amended, the decision to be made is not to determine whether to drill, but rather, in what manner drilling would occur. We are asking for your input regarding the Proposed Action (described below). Based on a preliminary assessment, we intend to categorically exclude the proposed projects from documentation in an environmental impact statement or environmental assessment using Category 3 under Section 39 ofthe 25 Energy Policy Act. Category 3 is described as: "Drilling an oil or gas well within a developed field for which an approved land use plan or any environmental document prepared pursuant to NEP A analyzed such drilling as a reasonably foreseeable activity, so long as such plan or document was approved within jive (5) years prior to the date of spudding the well. " The Proposed Action is tiered to the Final Environmental Impact Statement for the Final San Juan National Forest and Proposed Tres Rios Field Office Land and Resource Management Plan (LRMP), September 213, and the Final Environmental Impact Statement for the Northern San Juan Basin Coal Bed Methane Project (NSJB FEIS), July 26, and the associated Decision Documents: San Juan National Forest LRMP, Record of Decision (ROD), September 213; San Caring for the Land and Serving People Printed on Recycled Paper,. '-'

2 Petrox and Elmridge SUPO Scoping Juan National Forest Oil and Gas Leasing Availability, ROD, September 213, NSJB ROD, April27. The seven gas wells and associated access roads were identified and analyzed as known locations in the 26 NSJB FEIS. The 27 NSJB ROD generally approved the locations pending completion of site specific reviews and designs; these requirements have been completed. The seven gas wells were included in the reasonably foreseeable development scenario for the 213 LRMP. We intend to complete two separate categorical exclusions (CE), one for the Petrox SUPO and one for the Elm Ridge SUPO. These CEsare not subject to Forest Service Notice, Comment, and Appeal or Objection procedures. We are informing you of a 3-day scoping period for the Proposed Action in order to identify all possible issues. The scoping period ends on July 25, 214. Background Two of the Elm Ridge SUPOs in the Goose Creek area were originally scoped from March 3 to May 6, 211. Scoping input was received as a result of a public field trip, letters, and s to those who had previously expressed interest in the project, a legal notice, and a press release. At the time, the SJNF proposed to complete an Environmental Assessment because the NSJB FEIS and ROD were being litigated and there was a need for stand-alone environmental analysis for the two wells. Since that time, the litigation has been resolved and a new LRMP and associated Oil and Gas Leasing Availability analysis have been completed. Gas field development in the Northern San Juan Basin can proceed in accordance with this new guidance and the NSJB FEIS and ROD. Input received during the 211 scoping period will be considered along with any new scoping input received during the current scoping period. Cumulative effects have been analyzed in the NSJB FEIS and ROD. The project will be analyzed and implemented using LRMP direction. Purpose and Need for Action The purpose and need for the Proposed Action is to further develop valid and existing federal oil and gas leases by approving the SUPOs listed in Table 1 below in a manner consistent with the lease; including lease stipulations, federal law, the current approved LRMP, the NSJB FEIS and ROD, appropriate Best Management Practices, and SUPO-specific mitigation measures. Proposed Action The Proposed Action is for Elm Ridge and Petrox to construct seven approximately 25' x 25' gas well pads (1-2 acres per pad total disturbance for cuts, fills, and clearing limits) and drill to the Fruitland Formation to produce natural gas from their leases. Access roads, gas, and produced water pipelines would be co-located within a generally 4-foot wide corridor. All areas not required for well operations or access would be reclaimed and seeded upon completion of construction and drilling activities. 2

3 Petrox and Elmridge SUPO Scoping Table 1- Lease and SUPO Information (acre and mileage calculations approximate) SUPOName Location (all in New Proposed Proposed Total Total Mexico Prime SUPO SUPO Access Proposed SUPO Meridian) Well Pad Road Acres SUPO Acres Access Acres Road Miles Petrox 16-3 T34N, R5W, Sec and 16U-4 16U, S1 /2 Elm Ridge 28-1, T34N, R5W, Sees , 28-3, 28- all, and 34, NW1/4 4, and 34-4 Preliminary Issues SJNF representatives visited the proposed well pads and access roads with either Petrox or Elm Ridge personnel, depending on locations. During field visits, issues were reviewed related to potentially impacted resources including geology, topography, archeology, hydrology, visual impacts, vegetation types, and threatened/endangered/sensitive species. These issues were addressed during the location and design of the proposed well pads and access roads. In addition to internal issues raised, the public raised issues during the first scoping period. These include: Old growth vegetation - was analyzed in NSJB FEIS. An updated inventory has been completed documenting more acres than previously identified. The Proposed Action avoids old growth where possible, while avoiding steep unstable slopes and arch sites and minimizing impacts to Water Influence Zones. Water Influence Zones - the Proposed Action balances putting roads in the WIZ while avoiding erosive soils, steep slopes, and old growth. Big game winter range - SUPOs will have Conditions of Approval restricting winter activities, including public motorized access. Poor soil types - will be addressed with erosion control and revegetation Best Management Practices. Roadless Values -these leases pre-date roadless rule making; therefore the Colorado Roadless Rule (CRR) does not apply. Closed loop drilling - is a Standard in the new LRMP and will be required. Directional drilling - in addition to vertical well construction, many of the Petrox and Elm Ridge SUPO well pads will be utilized for horizontal and/or directional wells. Elm Ridge needs to develop their leases in the core of the HD Mountains CRR area. Well locations in T34N, R5W, Section 28, Wl/2, are needed to accomplish this by horizontally drilling to bottom hole locations under the core CRR area. This will minimize overall impacts to roadless values by reducing the need for additional and more impacting roads in the CRR area. These issues have been identified and will be considered and mitigated. It would be most helpful if you provide input about other issues you may be aware of that we are not already considering. 3

4 Petrox and Elmridge SUPO Scoping How Do You Provide Input? Written input may be submitted by July 25, 214, to the Columbine District Ranger by: US Postal Service to: PO Box 439, Bayfield CO FAX: (97) to: Hand delivery to: 367 S. Pearl Street, Bayfield, CO. Hand delivered comments will be accepted on weekdays between 8:am and 4:3pm, excluding holidays. Input received, including names and addresses, will be part of the public record and available for public inspection. Input submitted anonymously will be considered. If you have any questions related to these SUPOs, please contact Walt Brown at (97) or Anthony Madrid at (97) Sincerely, :NTHO MADRID Acting District Ranger Columbine Ranger District, San Juan National Forest 4

5 .,. c...,.., Elm Ridge and Petrox General Location Scoping Map --r:::::=== Miles v. ' - 'J.... \ itfiln 11, ** -c:\ i., : \...,. I I Legend Proposed Elm Ridge Wells * Proposed Petrox Wells - Proposed Elm Ridge Access Roads Proposed Petrox Access Roads Roads Open to All Vehicles. Roads Open to Highway Legal =Vehicles Only, --State or US Highway Trails Open to Wheeled Vehicles... Only < 5" or Less in Width. N W.E s 'i::j g ;>< ti'l &- en r:n r:n (").g JJ".. The USFS attempts to use the most current and complete geospatial data available. Geospatial data accuracy varies by theme on the map. Using this map for other than their intended purpose may yield inaccurate or misleading results. The USFS reserves the right to correct. update or modify geospatial inputs without notification. z J.' ill( JER UTM 13N, NAD 83 June 23, 214

6 Petrox Scoping Map --c=:==----miles \ Legend *Proposed Petrox Wells Proposed Petrox Access Roads Proposed Petrox Well Pads Trails Open to Wheeled Vehicles... Only< 5" or Less in Width, Ponderosa Pine Old Growth (None in this area) HD Mountains Colorado Roadless Rule Area Township Range and Section W. E N s ttj.. r:/) e r:/) n.g... ::s (1Q The USFS attempts to use the most current and complete geospatial data available. Geospatlal data accuracy varies by theme on the map. Using this map for other than their intended purpose may yield Inaccurate or misleading results. The USFS reserves the right to correct, update or modify geospatial inputs w"hout notification. JER UTM 13N. NAO 83 June 18, 214

7 Elm Ridge Scoping Map ---===::::: Miles Legend * Proposed Elm Ridge Wells - Proposed Elm Ridge Access Roads D Township Range and Section c:j Proposed Elm Ridge Well Pads Roads Open to All Vehicles. Trails Open to Wheeled Vehicles - - Only < 5" or Less in Width. HO Mountains Colorado Roadless Rule Area Ponderosa Pine Old Growth W.E N s '"' g ;.<.. m.. (/) c:::: '"' (/) () " JJ' The USFS attemjm tc> usc 111 mosi eutrcnt ancl Cc>n!9l«C geospatlal data available. Goospabal data accufllcy varies by theme on l.he map. USO!lQ this map lor c>lller than tllcll lntonclod purpc>so may yleld Inaccurate or mi$1cadlng rcs\111$ The USFS rosorvo$ tile right to correct. update or modify gcospabal inp<lla Wrlhoul not i licatc>n. JER UTM 13N. NA83 June

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