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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />81 <br /> <br />• Gas Capture Plan[s] (GCP): <br />o Forces gas capture planning prior to drilling <br />o GCP may include at the discretion of NDIC: <br /> Location map gathering system connection, processing plant(s) <br />identified <br /> Flowback strategy (rate, duration, plan for multi-well start up) <br /> Current system capacity and utilization <br /> Time period for connection <br />o At the discretion of NDIC, penalty for failure to comply <br /> Failure to submit GCP <br />• New wells – suspension or denial of permit <br />• Existing wells – curtail production where no detriment <br />to well or reservoir <br /> Failure to comply with GCP <br />• Curtail production <br />• Not meeting flowback strategy <br />• Mitigating circumstances may allow extension (i.e., <br />economic evaluation, operator’s overall capture rate, <br />ROW, safety, weather, work crews, etc.) <br /> <br />• Midstream Planning and Tracking <br />o Midstream companies meet with NDIC on a regular basis (i.e., annual, <br />bi-annual) to status operations and updates <br />o Suggested reporting to include: <br /> Percent gas captured by gathering system <br /> Gathering forecast by gathering system <br /> Status plant processing capacity and gathering capacity with <br />future obligations and capture targets <br /> Utilization and downtime/interruptions of service <br /> Field compression downtime / Plant downtime/maintenance <br /> <br />Based on these alternatives, Conservation Groups believe that capturing methane <br />emissions is just the first of the UFO’s duties in regards to GHG emissions and waste. The UFO <br />must also ensure that methane will be used beneficially in the field or enter a sales gas line and <br />make it to market, as opposed to simply being vented or flared and wasted. As an alternative to <br />venting, flaring, and waste, UFO must take a hard look at these planning tools, which are <br />alternatives available to ensure either field use of the resource or that gathering, boosting and <br />processing infrastructure is in place prior to development activities. Further, we believe that <br />public disclosure of the results of such planning should be required. <br /> <br />Finally, Conservation Groups also take issue with the notion that “adaptive management” <br />is a viable approach to addressing methane emissions and waste. According to the draft <br />RMP/EIS, at 4-20: <br />