On Tuesday, November 16 a comprehensive webinar sponsored by 350 Colorado and the Colorado Sierra Club provided insight into the permitting process at the Colorado Oil and Gas Conservation Commission (COGCC). The conveners reported that the Commission has basically been approving all the permits put before them since the election of Governor Polis and the passage of SB19-181, in spite of many not meeting the requirements of their own newly enacted regulations. The great bulk of these were on existing wellpads, but the trend is not encouraging. New permits are now coming before the COGCC, and the need to monitor the process closely is not to be dismissed.
Presenting during the webinar were:
- JoAnn Hackos, Evergreen Audubon Conservation Board Member, Wildlife and Biological Resources Coalition member, member of the Audubon Colorado Council, and Chair of the Sierra Club Oil and Gas Committee
- Brad Klafehn was a participant in the Mission Change rulemaking; he comes from the Sierra Club Oil and Gas Committee, Colorado Native Plant Society, and the Wildlife and Biological Resources Coalition.
- Katessia Robertson, Intern with 350 Colorado, student at the Graduate School of Social Work at the University of Denver
- Kate Christensen, 350 Colorado Oil and Gas Campaign Coordinator
- Alexis Schwartz, Organizer with the Colorado Sierra Club
A detailed presentation on how to navigate the COGCC website provided valuable insight into how things look and function. A video of the webinar has been made available by the Colorado Sierra Club , which will include that presentation. A toolkit that summarizes those procedures was presented and can be viewed below. It may help in conjunction with viewing the full presentation in small bites!
To say the process is obtuse is an understatement, and there is little doubt that has been the bureaucratic imperative, because who wants that pesky citizenry weighing in on major industrial developments in their communities and environment? But these are valuable tips for making sure the record is complete by getting your own input registered on permits of concern to you. Thanks, 350 Colorado!
COGCC Public Comment Toolkit
What is the COGCC?
COGCC stands for Colorado Oil & Gas Conservation Commission. The purpose of the COGCC is to protect public health, safety, welfare, and the environment of Colorado from adverse impacts related to oil and gas natural resources. See their mission here.
What does this have to do with us?
The COGCC has a process for approving oil and gas development plans(OGDPs) from oil & gas operating companies(also known as operators) looking to drill or build oil and gas wells in Colorado. After an operator completes this plan, the application is considered complete and the application is then in the review process. This process includes an opportunity for the public to make comments. These comments will be taken into consideration when the COGCC approves or denies an OGDP. Although this process is complicated, the goal of this toolkit is to make it easier and more accessible to the general public to make comments.
Oil & Gas Development Plans (OGDP) and Location Applications
Oil & Gas Development Plans (OGDPs)
Oil & Gas Development plans are an Operator’s plan to develop oil or gas resources from one or more locations. Pending applications include a hearing application, 2A forms(OGDPs can have multiple 2A applications), a 2B form, and an oil and gas location assessment. Form 2C has already been approved for OGDPs.
*OGDP applications do not have a space for public comment
Oil & Gas Location Assessments (Form 2As)
Pending applications are for a specific well location that corresponds to an OGDP application. Form 2A must be completed for an OGDP application to be considered. The 2A form contains important information that the public can read about and comment on.
*2A forms have a space for public comment
Making a public comment
Steps:
- Go to COGCC website
- Click on “Permits”
- Click on “Go!” icon next to the “Oil & Gas Location Assessment Permits (Form 2A)” under “Pending Permits”
- Click on the “Document Number (Public Comment Link)” that corresponds to the permit you want to comment on
- Click “Make Comment” button
- Fill out the comment and click “Submit Comment”!
Making a public comment (with screenshots)
- Go to COGCC website
- Click on “Permits”
- Click on the “Go!” icon next to the “Pending Oil & Gas Location Assessment (Form 2A)” under “Pending Permits”
- Click on the “Document Number (Public Comment Link)” that corresponds to the permit you want to comment on
- Click “Make Comment” button
- Fill out the comment and click “Submit Comment”!
What to look for on the 2A forms
- Residential Building Units (RBUs) in the area (supposed to be at least 2,000 ft away)
- Apartment buildings (HOBUs) in the area (supposed to be at least 2,000 ft away)
- School Facility in the area
- Child Care Center in the area
- Exemption requests
- Floodplain
- Water supply area
- Upgradient from a wetland
- High Priority Habitat (HPH) for wildlife
- Wildlife habitat (500 ft from wildlife habitat)
- Rivers, streams, lakes
- Disproportionately Impacted Communities
- There is a summary section towards the bottom of the 2A forms that is helpful & consolidates all concerns mentioned in the form. It is titled “Operator Comments and Submittal”
The Link to the Oil and Gas Development Plans page as referenced above: https://cogcc.state.co.us/permits2.html#/OGDP