ECMC Coyote Trails Form 2 Testimony

On Wednesday, January 24th, the Colorado Energy & Carbon Management Commission (ECMC) made the unusual move of hearing an application to drill (APD) at the existing Coyote Trails facility in unincorporated Weld County, just northeast of the Vista Ridge development in Erie.

Below is the testimony given by Erie Protector’s Editor in Chief, Christiaan van Woudenberg.

I come to you as a battle-weary activist, a former Trustee for the Town of Erie, a directly-impacted resident, and a father of two amazing teenage girls. I have been an Erie resident for almost 17 years. I live 800 ft from the 6-well Pratt pad, 3,400 ft from the 7-well Waste Connections pad,  4,000 ft from the 27-well Coyote Trails pad, and 1 and a half miles from the proposed 26-well Draco pad at the Crestone Hub, which includes the 11 wells at the Windsock pad. Every single one of these wells was drilled after I moved into what I thought was my dream home. Like many of the other residents that provided comment for today’s docket, I was scared, angry, and terrified. We have 137 active wells and 238 plugged and abandoned wells within our municipal boundaries. I could go on, but I’m tired of telling you how fracked we are in Erie. We are the cautionary tale for other neighborhoods, one told about a heavy industry operating indiscriminately and with wonton disregard for health and safety in residential neighborhoods.

The temporary completions pad between the Pratt and Waste Connections drilling pads at Redtail Ranch, Erie, Colorado.
The temporary completions pad for the Pratt and Waste Connections drilling pads at Redtail Ranch in, Erie.

If you don’t remember the drilling at Pratt and Waste Connections, have a look at your complaint records. They logged the most complaints for any frac operation ever, over 900 in total. They are number one and two for total complaints logged, respectively. Coyote Trails is number six on the list with 123 complaints logged during the drilling, fracturing, and completion operations performed in 2018 and 2019. I could go on, but residents are either confused or tired of navigating the complex web of antiquated tools for submitting complaints about air quality, noise, odor, nosebleeds, and headaches to the CDPHE, the ECMC, the PUC, the local government, the county government, and the operator. It’s perplexing, demoralizing, and leaves residents feeling helpless against the oil & gas extraction industry.

But there is hope. You can deny these Form 2 permits based on a simple procedural violation. The Form 2A issued for the Coyote Trails pad expired on November 19th, 2020. They had their chance to submit additional Form 2s for three years. They used it to drill 27 wells under pre SB 19-181 regulations. If the operator wants to drill additional wells at this location, they must submit a new Form 2A. That’s the law. And that’s how the process is supposed to work. A Form 2A does not give an operator a license to drill in perpetuity, for this exact reason. Technology changes. Our understanding of the health, safety, and environmental impacts of hydraulic fracturing changes. You should evaluate a new Form 2A for Coyote Trails with this current understanding and against current regulations.

Then, you’ll see how there’s hundreds of homes within 2,000 feet of the pad, how the region is already over-burdened with the cumulative impacts of oil and gas extraction, and how this heavy industry does not belong in our neighborhoods. And then, you can properly deny the permit to drill additional wells at Coyote Trails.

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