Project Summary

GMT Exploration Company LLC is requesting to create the Secret Stash well pad and 20 wells within the Lowry CAP area. This proposed pad would be within a mile of the State Beaver pad that is proposed as part of Civitas' CAP application for the same area. This could result in drilling issues for both companies and regardless of issues would create an even more dense area of sources in our communities. In addition Civitas has secretly been negotiating with GMT and gave them permission to be in the CAP area BUT THE CUMULATIVE IMPACTS OF SECRET STASH HAVE NOT BEEN INCLUDED IN THE CAP PLAN.

Reasoning For Denial of Request

The proposed Secret Stash well pad and pipeline are sited within an area that is being considered for a large-scale project called the Lowry Ranch Comprehensive Area Plan (CAP). The Lowry Ranch CAP project will add approximately 156 wells and over seven pad locations in roughly a 65-square-mile area. If approved, the large-scale project would produce emissions that will degrade air quality and continue exacerbating the ozone issues.

Adding more oil and gas extraction projects to an area that has already been flagged by the United States Environmental Protection Agency for poor air quality is reckless. Cumulative impacts concerning safeguarding health and the environment should be considered for each and every oil and gas application in this area.

The Bennett-Watkins volunteer fire department, which is located more than 20 miles from the proposed site, is expected to handle any fire or hazmat issues that might occur from the well pad. Water access in the area is minimal and will compound fire issues. In this “water-poor” area, secondary fires are the biggest concern. The County should not approve a project when there is no infrastructure to safeguard residents from the dangerous fire hazards that commonly occur from such projects.

GMT proposes to evade baseline water sampling or subsequent sampling of water at or near the well pad. This baseline sampling must be performed in order to assess if a release of oil and gas and/or produced water has affected one or more of the groundwater aquifers located above the Location and horizontal well field.

The GMT plan is to inject over 500,000 million gallons of freshwater to develop the 20 proposed HF wells. It is not clear how many gallons of produced water will be generated from the total of 20 wells for the Location. The produced water will likely be injected into salt water disposal wells in Weld County, which has numerous active faults and a serious induced seismicity problem. GMT will simply move their produced water problem from one county to another in Colorado rather than recycling it.

Required wildlife surveys have not been conducted for the proposed pipeline area. Protected raptors are known to nest in the area and these nests have not yet been documented. The pipeline crosses a mule deer winter concentration area and a pronghorn winter concentration area, which are designated High Priority Habitats by Colorado Parks and Wildlife. High Priority Habitats require cessation of human activity from Dec 1-April 30 for mule deer and Jan 1-April 30 for pronghorns. 0.15 miles of pipe is within mule deer protected habitat and 3.5 miles of pipe are within pronghorn habitat. It would be impossible for this pipeline to comply with the requirements of the High Priority Habitat.

As presented in Table 3.12-8, there is potentially suitable habitat for burrowing owl in the Project area, which cannot be avoided. Additionally, occurrence data obtained from the State Land Board ARAPAHOE COUNTY PRE-SUBMITTAL NO. Q23-088 USR WITH 1041 APPLICATION Secret Stash Well Connect Project 50 December 2023 indicates that burrowing owls are present in the Project vicinity. The Applicant has not consulted with CPW regarding burrowing owls and potential measures that can be implemented to minimize impacts during construction. Burrowing owls’ nest from March 15 to August 31. CPW recommends no encroachment within 660 feet of a nest site during this time. It will be impossible for the pipeline to avoid encroachment if it travels along the path as proposed.

Additional features must be added to the pipeline proposal to allow access to existing public use areas. The exact location of the pipeline must be specified so that alterations to trails can be accounted for. This must be agreed on in advance so that financial responsibility for trail expansion falls to GMT and is not borne by the County.

The nearest known seismic fault is the Rampart Range, located approximately 28 miles southwest of the Project (USGS,2023a). Seismic studies should be done prior to new drilling to ensure public safety. These studies should be published for public access.

Action
We respectfully ask that the ECMC deny the project based on the fact that the totality of pending projects in the area have not been considered, nor have the proper baseline studies been completed.