HomeMy WebLinkAbout20201401.tiffINVENTORY OF ITEMS FOR CONSIDERATION
Applicant: Sandra Miranda, Scott E. Gillis, Jill Marie & Milton Esteban Vega
Case Number: CO720-0001
Submitted or Prepared
Prior to
Hearing
At
Hearing
1
HOSE MINERALS LLC LETTER OF OPPOSITION
WELBrRN
SULLIVAN MECK & TOOLED', P.C.
April 23, 2020
Weld County Planning Commission
Weld County Administration Building
P'0 Box 758
1150 0 Street
Greeley, CO 80631
Weld County Planning and Building Department
155 N. 17th Ave
Greeley, CO 80631
Re: Objection of Mineral Owner Hobe Minerals, LLC to Applications ons of Sandra
Miranda, Scott E. Gillis, Jill Marie Vega and i I ton Esteban Vega for khan +� �
of Zoning, Re -Subdivision and Site Plan, for proposed stora- e facility
in the NE/4 ofSection=
1 -Township 2 North -Range 63 West of e P.M., Weld
County Colorado, 35929 I-76 Frontage Road, Roggen, CO 80652
Dear Planning Commission:
We represent Hobe Minerals LL ("1 -lobe") who owns the fee
minerals in the NE/4 of
Section 1-T2N-R63W N -R63 and the appurtenant right to make reasonable onable use of the surface to develop
oil and gas.
Hobe desires to reach an agreement with Applicants for the
mineral andcompatible development of the
surface estate but to date Hobe and the Applicants icants have not
The Applicants' i+cants' proposed pp reached an agreement.
p surface development, coupled with increased setbacks for `
� ! 1 s which the r�o os �d development ell and. gas
proposed may cause, may impact two of the available
windows for the Greater Wattenberg established
berg Area e.stabi ished by Colorado Oil and Gas Conservation
Co��n�ission's. Rule 318k 8the 800' 800' drilling the
i I i � g window in center of the NE/4 and the 400'
x 400' drilling window in the center of the NENE,Section
Applicants' � +on 1 �T.-�.�' Insofar as the
Aproposed project ect would impinge on these drilling windows,
directional drilling of it would require the
wells from other locations to access bottom -hole locations
established drilling windows at in these two
significantly increased costs. In addition, the ro
development may adversely impact �o proposed
p' b 's ingress and egress s rights across the property
potential well site locations to develop such n�ineralsp p to reach
.
(00791856,1 }
P25 17th Street, Suite 2200 ' Denver, Co 80202 159 N. Wolcott, Suite 22O •
Casper, WY 82601
303,8 30.7500 307234.6907
wsmtlaw.com
April 21, 2020
Page
While Hobe recognizes the proposed surface development"qualifying is not a surface
development" under C.R.S. 45. -102 (5.7(defined to bea surface devcloprnentof at least
160 acres) under which the County would be required under C.R.S. 24-653-I 03.3(1)0)011) to
condition approval on the applicant's certification that it has. .
�h
deposited incremental drilling costs
described in C.R.S. 24-65-5-103.7 ($87,500 per well, adjusted ,.
� by the y �� index) in all escrow
account with an approved commercial financial institution to defray the • E
additional costs of having
to directionally drill wells to a bottom hole location within the established ..
stabllsl�ed GWA drilling windows,
the proposed development may cause l -lobe the same harm the •designed is to protect against.
Hobe has contacted the Applicants' consultant. Western Engineering
>�>�C end Consultants, Inc
Applicants' attorney and desires to reach an agreement with the Applicants,
but to date
Applicants have not extended any offer of accommodation
as to road access, waiver of and
setbacks more than 200 feet from the proposed development
_ (such as the new 1,000 foot setback
from Building Units) or any other accommodation. Hobe therefore objects to the applications and
requests that any approval be conditioned on the Applicants l i cants reaching
at least making p� ��n an agreement with lobe or
a good faith effort to do so.
Hobe requests that this letter be included as part of the
field County Planning -. record for the hearing before the
Commission and that it also be included aspart of
subsequent hearing before Board • the record for any
the of County Commissioners.
Sincerely,
frei
r
Brian S. looley
cc: Maxwell Nader, (via email -- rnnader@weldov.com
)
Planner I, Weld County Planning and Building Department
1 555 1 7rh Ave
Greeley, CO 80631
Sandra Miranda, Applicant (via email — titleliconsin curr'
� reryahoo.00rri.)
Chad in F. Cox, (via email shad in.cox@western `
e+ci.eorn.)
Senior Project Manager and Consultant for Applicant
Western Engineering Consultants, Inc.
Hello