Comparison of MOU BMPs to COGCC Rules, 7 7 17
Comparison of BMPs among various MOUs and COGCC rules for the oil and gas industry, highlighting selected BMPs that directly reference COGCC rules. This table serves as a guide for comparing BMPs, with links to additional resources for accessing MOU documents and the BMP Database.
Content article
The comparison of Best Management Practices (BMPs) among various Memoranda of Understanding (MOUs) and Colorado Oil and Gas Commission (COGCC) rules is detailed across multiple categories, including noise, traffic, air, water, setbacks, and pipeline regulations.
Noise Management
The noise management BMPs reveal significant contrasts between COGCC rules and various MOUs. COGCC Regulation 802.b mandates that upon receiving a complaint, the Commission must conduct an on-site investigation and take sound measurements, setting maximum permissible noise levels based on land use categories. For example, residential/agricultural/rural areas have limits of 55 dB(A) during the day and 50 dB(A) at night, while commercial zones allow for 60 dB(A) during the day and 55 dB(A) at night. In contrast, the Adams County MOU requires operators to provide a 24-hour contact for noise complaints and mandates noise mitigation measures along edges of operation sites adjacent to residential areas. Similarly, the Arapahoe County MOU also emphasizes a 24-hour contact for complaints.
Brighton, Adams County, specifies that operators must prepare and implement a noise mitigation plan, adhering to COGCC Regulation 802.b, which allows for temporary increases in noise levels. The plan must consider site-specific characteristics such as adjacent development and prevailing weather patterns. In Broomfield City, Sovereign Operating Co. and Extraction Oil & Gas, Inc. are required to construct noise mitigation measures along edges of operation sites near residential areas and comply with COGCC noise regulations. Notably, the Encana Oil & Gas MOU with Erie stipulates that operators must provide a noise mitigation plan before commencing drilling, ensuring compliance with COGCC Regulation 802.
Traffic and Road Management
Traffic management BMPs highlight the obligations of operators to minimize impacts on local roads and communities. Specific measures include the requirement for operators to maintain road conditions and provide traffic management plans. For instance, the Adams County MOU mandates that operators must repair any road damage caused by their operations and coordinate with local authorities. The Broomfield City MOU includes provisions for traffic routing to minimize disruption, while the Brighton MOU emphasizes the need for operators to notify local authorities of expected traffic increases.
Air Quality Management
Air quality BMPs focus on emissions control and monitoring. The COGCC rules require operators to comply with air quality standards, including limits on volatile organic compounds (VOCs). Various MOUs, such as those from Broomfield and Erie, include additional measures to reduce emissions, such as using electric-powered engines and implementing dust control measures during operations. The Encana Oil & Gas MOU with Erie specifies that operators must submit air quality monitoring plans to ensure compliance with both local and state regulations.
Water Management
Water management BMPs address the protection of water resources during oil and gas operations. COGCC regulations require operators to prevent contamination of surface and groundwater. The Adams County MOU includes provisions for spill prevention and response plans, while the Broomfield MOU mandates that operators conduct water quality testing before and after operations to monitor any potential impacts. The Erie MOU requires operators to provide a detailed plan for water use and disposal, ensuring compliance with COGCC regulations.
Setbacks
Setback regulations are crucial for minimizing the impact of oil and gas operations on nearby communities. COGCC rules specify minimum setback distances from occupied structures, which vary based on the type of operation. The Brighton MOU, for instance, includes stricter setback requirements than those mandated by COGCC, reflecting local community concerns. Similarly, the Broomfield City MOU requires additional setbacks in high-density areas to further protect residents from potential impacts of oil and gas activities.
Pipeline Regulations
Pipeline BMPs focus on the safe and environmentally responsible installation and operation of pipelines. COGCC regulations require operators to adhere to safety standards for pipeline construction and maintenance. Various MOUs, including those from Adams County and Broomfield, emphasize the need for operators to conduct regular inspections and maintenance of pipelines to prevent leaks and ensure public safety. The Brighton MOU includes specific requirements for pipeline routing to avoid sensitive environmental areas.
This comprehensive overview of BMPs across various MOUs and COGCC regulations illustrates the commitment to balancing oil and gas development with community and environmental protection.