Sierra Club | Univ. of Denver
[From Introduction] On behalf of the Sierra Club, student attorneys at the University of Denver’s Environmental Law Clinic (the Clinic) conducted a review of Oil & Gas Location Assessment Permits (Form 2As) submitted to the Colorado Oil and Gas Conservation Commission (COGCC) since August 1, 2013 – the date the new COGCC setback regulations were implemented. Specifically, the Clinic reviewed industry applications and decisions of the COGCC to determine if they were in compliance with the mandate that new multi-well production facilities proposed within 1,000 feet of a home or commercial building be located “as far as possible” from those building units.
In summary, the legal analysis of the Clinic determined that during a 14-month approval period nearly 200 applications were incomplete. COGCC staff neither required nor had information necessary to determine if the locations were meeting the requirement that well operations be located as far as possible from homes. In addition, the student attorneys advise broadening opportunities for the public and local government to participate in the permit review process. The students also recommend that the COGCC website be updated to make it more user friendly for the average citizen to access permit information and to provide feedback.