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Arapahoe County Board of Commissioners
5334 S Prince St.
Littleton, CO 80120

Dear Arapahoe County Board of Commissioners,

I am writing to express my deep concerns regarding the pending approval for the State Sunlight-Long well pad in our area. I urge you to carefully consider the following points:

1. Lack of Water Sampling Plans: Plans for water sampling, particularly in relation to the planned reservoir, are either nonexistent or inadequate. Civitas\’s track record of minimal water quality monitoring raises concerns about their ability to protect public health and the environment. New wells need to be installed around the proposed Pad location as well as other surface water and groundwater locations in order to determine \”baseline\” conditions prior to drilling and fracking as well as subsequent ongoing monitoring of wells and surface water during the lifetime of production.

2. Setback Requirements: The proposed well pad\’s proximity to the planned reservoir violates Arapahoe County rules, which mandate a minimum distance of one mile. Any waiver requests should be carefully scrutinized and not granted lightly.  This setback was established for a proposed/planned Reservoir B specifically and should be applied for this application.

3. Establishment of Vertical Setbacks: Vertical setbacks between the well pad and sensitive receptors such as residential building units (RBUs), reservoirs, and HPH wetlands must be established to prevent potential contamination and environmental damage. These receptors are situated directly over the horizontal wellbores and their associated fracture zones. Potential risks to homes and businesses located on the surface above the wellbore include the potential presence of high-angle faults; collision with older, abandoned oil wells; and produced water migration from fracturing operations flowing into reservoirs,  groundwater, and residential basements.

4. PFAS Sampling in Groundwater Monitoring: PFAS sampling should be included in the baseline groundwater monitoring and subsequent monitoring for all CAP well pads and areas above the horizontal wells. This is crucial for assessing water quality risks associated with drilling and production activities. These plans have been submitted with little or no sampling at all.

5. Inconsistencies in VOC Emissions Assessment: The significant reduction in assessed VOC emissions between October 2022 and the revised April 2023 report raises serious doubts about the accuracy of Crestone\’s assessments. This inconsistency must be addressed and explained before any approvals are granted.

6. Independence of HWA Wildlife Consulting, LLC: The characterization of HWA as independent is questionable, given their long-standing relationship with the oil and gas industry. Baseline data collection must be conducted by a truly unbiased third-party expert to ensure the integrity of the assessment, especially considering the threat to high priority habitat (HPH) in the well pad area.

These concerns highlight the need for thorough scrutiny and consideration before granting approval.   I urge the Board of Commissioners to prioritize the protection of our community\’s health, environment, and natural resources in all decision-making processes. I respectfully ask that the Board deny the use of the administrative review process and instead hold formal public hearings for this application and all applications related to the Lowry Ranch CAP.  The consideration of these applications should await the implementation of the County’s 2b regulations in progress.
Thank you for your attention to this matter.

Sincerely,

Urgent call to action: Sign our Sunlight-Long Petition.