| Reclamation Specialist | Form: (04)
404421412
11/06/2025 | Per email communication to Operator: "Commencement of the Operator’s requested construction activities may occur as soon as practicable with the adherence to the COAs within the attached document and as listed below".
COAs provided via Email 10/30/2025:
1) Field oversight by an Engineer should occur at every lift compaction test and include field discussion about how far down the slope the equipment can safely reach. This implies to ECMC that Oversight will occur throughout the entire construction process.
2) Upon completion of construction, Operator shall provide the on-site engineer's field report(s) and data; including all lift nuclear density test results and sample locations (including GPS coordinates and elevation) on the Location.
3) Appropriate erosion control blanket/matting shall be used for the slope angle, which should be thoroughly researched.
4) Loose material shall be removed from the drainage bottom channel and manually placed uphill. Operator shall be responsible for the safety of the workers. ECMC highly recommends that a full time spotter is used when workmen are at the bottom of the slope
5) Provide the Original CDPHE site-specific Stormwater Management Plan and the more current one provided within this email (dated 10-22-2025) on a Form 4 by Monday Nov 3rd, 2025.
6) Per Operator’s “Stabilization Plan”, a perimeter silt fence will be used downslope of the cut and fill areas to catch runoff during construction activities. Perimeter controls to manage runoff shall be installed per good engineering practice, and maintained pursuant to Rule 1002.f, until long-term stabilization of the slopes have been achieved. Silt fence should be reinforced silt fence given the slope circumstances. In the event that erosion logs will be used in lieu of silt fence, a minimum of 12 inch diameter erosion log is required. The Operator should thoroughly research the appropriate size of erosion control logs to determine if a larger diameter is necessary per good engineering practice, and should be prepared to defend their choice with data from the manufacturer.
7) Per good engineering practices, the storage capacity of sediment traps shall be reconstructed to have a capacity of at least 4,680 ft3 for the site’s conditions, and shall contain a spillway lower in elevation than the inlet to allow for proper discharge.
8) Construction short term BMPs: Erosion and stabilization controls shall be installed per good engineering practice, and maintained for construction purposes for management of runoff and stabilization of the slopes. In the event a specific BMP is insufficient to minimize erosion, degradation and sediment transport, or cannot be implemented per installation specification, or maintained in effective operating condition, then alternative BMPs that are better suited to meet the site’s conditions should be considered and applied, or used in conjunction.
9) Per Operator’s “Stabilization Plan” hydroseeding and tackifier will be applied to stabilize the “finished slope areas” of the Location.
10) Temporary erosion and sediment control measures such as erosion logs, blankets/matting, etc… shall consist of biodegradable materials.
11) Operator shall design stormwater controls and grade the working pad surface in a manner that prevents standing water on the Location.
12) All control measure outlets, and points of stormwater discharge from the Location shall be protected with properly engineered armoring, such as riprap material in conjunction with geotextile lining.
13) Vehicle and sediment tracking control measures shall be installed and maintained to minimize off-site sediment transport.
14) COAs per BLM Sundry 2877881 apply.
15) Pursuant to NOAV #404371349 Operator will submit both the “Geotechnical Investigation Report”, and the engineer-stamped “Location Stabilization Plan” to both the ECMC and the BLM for review, the Report and Plans will be attached together, and submitted via each respective agency's "Sundry Form". The “Geotechnical Investigation Report”, and the engineer-stamped “Location Stabilization Plan”, and all other ECMC required plans, documents or records shall be submitted attached to a Form 4 Sundry Notice.
16) Provide a Stamped Engineered Site Specific 50 year / 24 hour Stormwater Plan: You must hire a licensed Professional Engineer (PE) to design the stormwater plan. The PE will place their professional stamp/seal with the date on the final documents to certify that the plan is technically sound, meets all legal and regulatory standards, and that they take legal responsibility for its design. Site-Specific: The plan cannot be a generic template. It must be designed specifically for the unique conditions and characteristics of this location, including its size, soil type, and surrounding environment. The plan's design criteria shall be a "50-year 24 hour storm event. The plan must demonstrate that your stormwater management system can handle this storm event. Details on Best Management Practices (BMPs): The plan must include a comprehensive list of all the BMPs. Plan must include, at a minimum, all specific BMPs, each BMP sizing including width length, depth and cubic ft capacity, materials to be used, and all calculations. In addition, engineered stamped figures with BMP locations and specific BMP within the drawing shall be included. Provide the document no later than November 24th, 2025. ECMC recommends, time allowing, that the 50-year 24 hour Stormwater Plan components be installed during this construction season. |
| Reclamation Specialist | Form: (04)
404421412
11/06/2025 | After review of the control measure details/installation specifications for “SC-6” (Sediment Trap) and “SC-10” (Water Quality Capture Detention Areas, “WQCDA”) within Operator’s Construction Field-Wide SWMP, the sediment traps currently in place on the Location are significantly undersized for the site’s conditions; including the tributary runon surface area.
Operator is required to provide (attached to a Form 4 by EOD 11/10/2025) calculations and details as to how the sediment trap control measures will be re-constructed per Operator's site specific and Construction Field-Wide SWMP, and good engineering practices, during construction activities on the Location.
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| Reclamation Specialist | Form: (04)
404421412
11/06/2025 | Per Operator communication, construction activities on the Location have not commenced at this time.
Operator shall provide written notice to the ECMC two (2) business days in advance of commencing construction on a Form 42 - Notice of Construction or Major Change, pursuant to Rule 405.b
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| Environmental | Form: (04)
404499833
01/08/2026 | ECMC has processed this form as an update; and this approval of this form does not imply any agreement with comments or recommendations for the Soil Stabilization Plans, dates, and timelines. All ongoing/unaddressed comments/COAs from previous Forms remain applicable. |
| Environmental | Form: (04)
404499833
01/09/2026 | Should any Oil and Gas Facility permanently be removed or removed for relocation as part of implementing the Stabilization Plans, Per Rule 911.a.(1). Operators will obtain the Director’s approval of the Form 27 prior to conducting any investigation or closure operations. This pertains to the removal for relocation of ALL Oil and Gas Facilities, including flow lines.
By definition, OIL AND GAS FACILITY means equipment or improvements used or installed at an oil and gas location for the exploration, production, withdrawal, treatment, or processing of crude oil, condensate, E&P waste, or gas. |
| Engineer | Form: (04)
404499833
01/12/2026 | ECMC Engineering and Environmental Staff point out that the soil nails will be set in unconsolidated soils along the extent of the slope failure but will defer to the Soil Stabilization Plans provided by GeoStablization International.
Operator shall adhere to and follow the Soil Stabilization Plans provided by GeoStablization International (Pursuit Number 191998584 and Project Number 250679CON), signed and stamped by a Colorado Licensed Professional Engineer.
Operator shall notify ECMC should there be any changes to the Soil Stabilization Plans. |