We request that the City Council reject the Amended Agreement with Extraction Oil and Gas. We request that the City complete the unresolved items from the City Council Adopted Resolution No. 2017-29 "declaring the intent of the City and County of Broomfield to engage in a comprehensive planning process for oil and gas operations within the City and County". The fulfillment of this Resolution will create a process that is applicable to all operators in Broomfield, rather than a patchwork of operator agreements.

Several requirements from this Resolution have not yet been resolved including:
• Adoption of the Completed Draft Chapter as work continued after Council Adopted the Initial Draft Chapter;
• Regulations have not yet been enacted;
• Interjurisdictional Coordination has not been completed;
• Significant concerns regarding the well pad locations still need to be addressed;
• A “Quantitative Risk Assessment” has not been completed which would identify and quantify the health and safety concerns; and
• Implementation of a process that is applicable to all operators.

The current Amended Agreement with Extraction is not protective of the health, safety, and welfare of the residents of Broomfield, nor is it fiscally responsible. It appears as though the city is rushing through the process. We are concerned about Extraction’s past performance and future plans; financial implications; health and safety risks; impacts on neighboring communities; intent to withdraw spacing unit applications; timing of COGCC Rulemakings; liability; unfulfilled quantitative risk assessment; enforcement (including penalties); need for outside legal-council; and superseding the will of the citizens of Broomfield.

The proposed amendment includes 84 wells to be drilled and hydraulically fractured in Broomfield near our homes, boulevards, schools, playground, and drinking water reservoir, and also homes in neighboring Adams County. Despite the hard work of the Council Appointed Task Force to date, there remain health and safety concerns. The setback distances determined by the Task Force are protective of some incidents, but not all. The setback distances were determined through mutual compromise. The Task Force and Council have both indicated the need for a “Quantitative Risk Assessment”. This type of assessment would quantify the cumulative risk of the numerous health and safety risks that come with large-scale hydraulic fracturing, thereby providing a more accurate determination of what truly is a safe distance. Until such an analysis is complete, we do not know the full potential of the assumed risk that is being forced upon residents. Families in the most impacted areas will be forced to determine whether they can accept this level of risk or if they will ultimately bear the burden of relocating their families.

As part of the agreement to reduce the proposed well count on the Livingston Pad to 19 wells by the elimination of the proposed Phase II wells, the City made a significant financial sacrifice. Concerns still remain regarding even drilling 19 wells at this location, but now the City has voluntarily given up their royalties and surface use income (estimated from $8.4 million to 20 million). This leaves the City and residents with the risks and burdens of the wells, but with no source of income to pay for expenses the city will undoubtedly incur including inspections, enforcement, air quality monitoring, road maintenance, property value impacts, and more. These costs will then need to be paid with our tax dollars, rather than money from the operator.

We request that you do NOT sign the Amended Agreement, and instead ensure that Resolution No. 2017-29 is completely resolved, as intended, to create a process that is protective of the health, safety, and welfare of Broomfield and is applicable to all operators.