Draco OGDP Chair Robbins Testimony and Final Deliberations

Below is a transcript of Chair Robbins’ testimony during the March 26, 2025 deliberations on the Draco Oil & Gas Development Plan (OGDP). Please excuse any transcription errors.

Chair Robbins: Thanks to all my fellow Commissioners for the deliberative thoughts. I think if anything this should demonstrate once again to the 139 people listening in that we really work hard to make the appropriate determination for the state of Colorado with regard to these sorts of things. I too am in favor of the application for the reasons as articulated by my fellow Commissioners. I believe it addresses the avoid, minimize, and mitigate hierarchy. I appreciate the best management practices and I too want to echo Commissioner Akerman’s points that I think this process has demonstrated to us and to the communities we serve the opportunity to ensure that even relevant approximate local governments can have an ability to be at the table and I think that’s what we’ve done here.

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Draco OGDP Commissioner Oeth Testimony

Below is a transcript of Commissioner Oeth’s testimony during the March 26, 2025 deliberations on the Draco Oil & Gas Development Plan (OGDP). Please excuse any transcription errors.

Commissioner Oeth: This is a really tough one, and I really appreciate my fellow Commissioners Cross and Messner starting us out and really doing a very thorough job of laying out so many of the complicated factors and considerations on all sides of this. This really does highlight the really challenging nature of this application—both the things that are really positive about it and those that are potentially concerning about it, and all those things that we have to take into consideration. So thank you for that.

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Draco OGDP Commissioner Ackerman Testimony

Below is a transcript of Commissioner Ackerman’s testimony during the March 26, 2025 deliberations on the Draco Oil & Gas Development Plan (OGDP). Please excuse any transcription errors.

Commissioner Ackerman: I appreciate my fellow Commissioners and their thoughts. I appreciate all the significant efforts on all sides, as has been expressed by others on this application. I particularly appreciate the thoughtful consideration of local jurisdictions, the staff, the director, and my fellow Commissioners.

I’ll be relatively brief as well. This application is a good illustration of why our deliberative process is so important to addressing ECMC’s mission, which is really simple to understand but complex to execute: protecting public health, safety, welfare, the environment, and wildlife resources. That’s the purpose of the Act, and the method of executing that is generally promulgating and enforcing rules pursuant to that mission.

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Draco OGDP Commissioner Cross Testimony

Below is a transcript of Commissioner Cross’ testimony during the March 26, 2025 deliberations on the Draco Oil & Gas Development Plan (OGDP). Please excuse any transcription errors.

Commissioner Cross: I think initially I’ll start off saying I’m in favor of this application. I think there’s a lot of good things about it. I’ll start with the benefits of the location as applied for. I think when you look at the alternatives that were provided, this is definitely the best alternative. I’ll go into a little bit more detail on alternative 4 and 4.1 as it’s being called later, but just to talk about the overall benefits of this location.

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Draco OGDP Commissioner Messner Testimony

Below is a transcript of Commissioner Messner’s testimony during the March 26, 2025 deliberations on the Draco Oil & Gas Development Plan (OGDP). Please excuse any transcription errors.

Commissioner Messner: Thanks, Mr. Chair. I’m going to have a little different perspective, I think. You know, we’ve been doing this a while now, and there’s a point—and we’ve been seeing it—where oil and gas development and subdivisions are colliding with one another. I think this is a really good example of where that’s happening, and I think we’re starting to see it more often. It’s certainly a challenging situation for all sides. You know, I think you can argue chicken or the egg on these, but the fact is that significantly sized new development, both on the housing side and the oil and gas side, are colliding with one another right now. The areas around the town of Erie is one of those places.

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ECMC Approves Draco OGDP

Erie resident Christiaan van Woudenberg stands near the site of the Draco Pad project on Aug. 9 in unincorporated Weld County. Photo by Cliff Grassmick/Daily Camera Staff Photographer
Erie resident Christiaan van Woudenberg stands near the site of the Draco Pad project on Aug. 9 in unincorporated Weld County. Photo by Cliff Grassmick/Daily Camera Staff Photographer

During a regularly scheduled meeting on Wednesday, March 26, 2025, the Colorado Energy and Carbon Management Commission (ECMC) approved the Draco OGDP in a 4 to 1 vote, with Commissioner Messner the only no vote. Extraction had previously been directed to investigate Alternative Site 4 at the conclusion of a November 15, 2024 meeting; they deemed AL4 and an additional AL4.1 site unsuitable and proposed moving forward with the original Draco pad location.

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Draco Prehearing Statement Analysis

The Draco Oil & Gas Development Plan (OGDP) hearing has been rescheduled for March 13th, 2025. Extraction Oil & Gas submitted an updated 127 page prehearing statement, which we’ve analyzed below.

TL;DR (Too Long, Didn’t Read)

“Extraction believes that AL 4 and AL 4.1 are objectively infeasible alternatives to the Draco Pad,” citing 200+ homes within 2,000 ft, difficulties with rezoning to heavy industrial, an inability to procure an oil & gas permit from the Town of Erie, and uncertainty in negotiating with the Town Council. They propose moving forward with the original Draco Pad location just north of the Crestone Hub northwest of CR6 and CR7 just outside of Erie, Colorado.

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Opening Pandora’s Box: The Draco Debacle

After 8 hours of testimony and deliberations over two days last week, the Colorado Energy and Carbon Management Commission (ECMC) voted unanimously on Friday to indefinitely stay a decision on the Draco Oil & Gas Development Plan (OGDP) in unincorporated Weld County, less than 500 feet outside of the Town of Erie.

The proposed Draco wellbores extend over 5 miles west through Erie and into Boulder County, and will hydraulically fracture and extract minerals underneath 4,500 homes. These wellbores also threaten 72 existing wells in the drilling & spacing unit (DSU) and many more nearby, prompting concern, outrage, and action from local residents. The Draco stay decision is cause to celebrate … right? Right?

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Extreme Reach Wellbores Require Extreme Water Use

Or, the march to the first billion gallon frac pad in Colorado

To understand the massive quantities of water that may be consumed to hydraulically fracture the 26 extreme reach wellbores at Draco, let’s look at the water used by the 394 hydraulic fracturing treatments logged thus far in 2024 to FracFocus, courtesy of the data wizards at Open FF who have made extensive inroads to sanitize and extend the FracFocus data.

Actual Water Use is Twice Estimated for Extreme Reach Wellbores

Let’s start with the upper extremes, as shown in the graph above. From the Cumulative Impacts analysis for the Blue Pad in Adams County, Crestone estimated they would consume between 102.9 and 147 million gallons of water to frac the 7 wells at Blue.

Crestone Peak Resources used a median of 47.7 million gallons of water per well and permanently poisoned 304 million gallons of water, more than twice their upper estimate!

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My, how you’ve grown! An investigation of wellbore lengths.

In the face of unprecedented 5 mile laterals proposed by Extraction for the Draco Pad, it’s an appropriate time to analyze the maximum measured depths as reported to the ECMC for wells in Colorado to answer the question, “Have 5 mile laterals ever been drilled in Colorado before?” Let’s not bury the lead; according to the data reported to the ECMC, the answer is a resounding NO!

The longest laterals we’ve ever seen in Colorado are 4 miles long; the vast majority are less than 3 miles. The 5 mile laterals proposed at Draco are 25% longer than the longest laterals ever drilled in Colorado, and the proposed wellbores are 70% longer than any wells completed before 2024.

Christiaan van Woudenberg, Erie Protectors
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