our demands

At the local public hearing and in its decision-making on the Century OGDP, we ask the Commission to acknowledge these community demands and require the following:

1. A tankless facility design with a dedicated produced-water pipeline. The Town of Windsor has asked for a produced-water pipeline in place of trucking to a disposal well 16 miles east, CDPHE recommends a tankless design, and recent Weld County final orders for other drilling projects (Draco, Yellow Jacket G23-12, and Apollo State G11-11) require tankless facilities with produced-water pipelines. Century should meet the same standard. If Verdad can’t, the application should be stayed until a more established operator in the region can meet this condition.
2. Public release of the full Practicability Assessment. The operator’s conclusion that a pipeline is not practicable was cited before the assessment was final, was accepted without evaluation by Weld County, and without public review. The complete analysis, including alternatives such as tying into existing regional produced-water gathering systems, must be made public and available for independent review.

3. No Class 7 or heavier truck traffic during peak hours. Limit heavy truck traffic to and from the site during morning and afternoon school and commute hours (7:00 to 9:00 a.m. and 3:00 to 6:00 p.m.), with no truck staging on road shoulders, similar to conditions imposed on the Draco Pad in Erie.
4. Delay of construction until after Harmony Road improvements are made. The Town of Windsor is in the design phase of the East Harmony Road Widening project, which “will improve traffic flow, reduce congestion in the area and provide better access for both locals and visitors.” Delay construction and completion activities at the Century pad until these improvements are made to Harmony Road, to increase safety and reduce disruptions of the large amount of traffic generated by the drilling project. 
5. A northbound right-turn lane at WCR 15 and Harmony Road, built before construction begins. The Town of Windsor asked for both a southbound left-turn lane on WCR 15 and a northbound right-turn lane at Harmony Road. Verdad committed to building both. Weld County’s Final Order made the southbound left-turn lane a firm requirement (Condition #31), but for the northbound right-turn lane it only requires “good-faith” Road Maintenance Agreement negotiations with Windsor (Condition #30). The Commission must require the northbound right-turn lane as a condition of approval, completed before construction traffic begins.
6. A required produced-water truck route. Verdad has said its truck route is “not mandatory.” The Commission must make the produced-water truck route a condition of approval.

7. Development in two occupations, with completions during summer break. Weld County’s Final Order (Condition #6) requires the heaviest completions work to happen during school summer break, but only if the ECMC approves Verdad’s two-phase plan. Without an ECMC condition, that protection could disappear. The Commission must require that the wells be drilled and completed in two separate occupations, with the heaviest completions work in each scheduled during school summer break.
8. Limits on Ozone Action Days. The Century pad is in the Front Range ozone nonattainment area, and there is a well-documented link between oil and gas emissions and the formation of ground-level ozone. The Commission must limit pre-production activities on CDPHE Ozone Action Days.
9. Public air quality monitoring through two years of production. Weld County’s Final Order only requires air quality monitoring for six months into production, and the data is only available to the County on request. The Commission must require publicly available, real-time air quality monitoring data from construction through the first two years of production, when emissions are highest.

10. Bonding and financial assurance scaled to the project, as requested by the Town of Windsor and deferred by Weld County to the ECMC.
11. Make Verdad’s hearing promises binding. At the Weld County hearing, Verdad promised quarterly neighborhood meetings, notice before each phase of work, more water well sampling, and an updated traffic study, but none of these made it into the Final Order. The Commission must require them, with notices sent to all residents within the Area of Evaluation (AoE).
12. Legacy wells plugged before fracking. To minimize potential issues with well cross-talk/communication, require the nearby PDC wells to be plugged and abandoned before Verdad begins hydraulic fracturing at the Century pad.