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Bill Barrett Drilling Pine Ridge #2 and #3

Wetlands, Floodplains, Municipal Supply Watersheds, Impaired Waters [gl There are no wetlands in the project area. D There are wetlands in the project area, but no adverse effects are anticipated.

D There are wetlands in the project area, adverse effects are possible.

D There are no floodplains or flood-prone areas in the project area.

[gl There are floodplains or flood-prone areas in the project area, but no adverse effects are anticipated.

D There are floodplains or flood-prone areas in the project area, adverse effects are possible.

Municipal supply watersheds (FSM 2542) include surface supply watersheds, sole source aquifers, and the protection zones around wells and springs.

[gl There are no municipal supply watersheds or drinking water source areas in the project area.

D There are municipal supply watersheds or drinking water source areas in the project area, but no adverse effects are anticipated .

D There are municipal supply watersheds or drinking water source areas in the project area, adverse effects are possible.

Is it likely that the degree of potential effect of the proposed action on wetlands, floodplains, or municipal supply watersheds constitutes an extraordinary circumstance.

[glNO DYES

Is the project area adjacent to or tributary to a water quality limited stream segment or lake (from current 303(d) list or a TMOL)?

[glNO DYES - complete at least Section A, Clean Water Act Worksheet.

[gl The proposal complies with Executive Order 11988 (Floodplain Management).

[gl The proposal complies with Executive Order 11990 (Protection of Wetlands).

[gl The proposal complies with the Clean Water Act.

[gl The proposal complies with the Safe Drinking Water Act.

[gl The proposal complies with Forest Plan management direction including the following : maintain satisfactory watershed conditions; provide favorable conditions of water flow (quality, quantity and timing); protect soil and water productivity so that neither will be significantly or permanently impaired; and protect and enhance riparian areas including dependent resources.

[gl The proposal complies with R4 soil quality guidelines.

Hydrologist, Soil Scientist, and/or District Watershed Staff signature: ul-L/­Date: 10 ) fV Ic.- j .:'" -. ;-­COMMENTS: see attached report

(?/;c/ )'1

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Project Proposal It is the Forest Service's proposal to authorize Bill Barrett Corporation (BBC) to conduct surface operations associated with accessing, drilling, testing, and completing the Pine Ridge #2 and #3 (BBC Project) natural gas wells, as described in the Surface Use Plan of Operations (SUPO) portion of BBC's APD for these wells.

BBC is proposing to drill two exploratory natural gas wells named Pine Ridge #2 and #3, in Sections 22 and 23, T28S, R25E in San Juan County, Utah in the summer of 2010 (#3) and 2011 (#2). The Proposed Action for this project would require the construction of a 1.8 acre well pad for #2, a 2.2 acre well pad for #3 and construction of 2400 feet of new road for #2 and 250 feet of new road for #3. New roads are proposed to be constructed to a width of 32 feet, with a final running surface of 18 feet. In association with this project is the Pine Ridge #1 drilling that was started in 2008, but due to problems encountered during drilling, the project will be completed in 2010. There will be no new disturbance with this work. The testing of the well will take approximately 60-90 days or through the winter of 2010. The company's next course of action will depend on whether any or all of these wells are successful.

The proposal is to drill a vertical exploratory well to formations within the Cutler group. Drilling operations would take place 24 hours a day for a period of 20-25 days (weather permitting - if problems arise during the project, operations may be delayed until the next summer) until a depth of approximately 9,500 feet is reached for #2 and 9107 feet for #3. Completion of the wells would take another 45 days and they may be subject to testing for up to 12 months after completion . If the wells demonstrate the potential for production, subsequent proposal(s) would be necessary for construction of production facilities, pipelines, and year-round access. If the wells prove to be incapable of producing natural gas in commercial quantities, they would be plugged and abandoned and the location reclaimed according to Forest Service standards.

Analysis Methods and Consideration of A vailable Science This report has been developed for the Bill Barrett Drilling categorical exclusion to evaluate the project's compliance with the Manti-La Sal Forest Plan soil and aquatic ecosystem direction, standards and guidelines, potential effects upon floodplains, wetlands and municipal supply watersheds, and compliance with the Clean Water Act. The project is located primarily within the La Sal Creek Watershed. The relevant science considered for this analysis consists of several key elements:

• Site Visit in 2007 • Review of area using aerial photographs. • GIS information streams and wetlands. • Integration of the professional knowledge on the part of the Hydrologist with the collective

knowledge of the project area by 10 Team members.

Rationale in Support of Categorical Exclusion Executive Order 11988 of May, 1977

This requires the Forest Service to provide leadership and take action to 1) minimize adverse impacts associated with occupation and modification of floodplains and reduce risk of flood loss; 2) minimize impacts of floods on human safety, health, and welfare; and 3) restore and preserve the natural and beneficial values served by floodplains.

Floodplains have not been mapped in this project area. The drill pads would be designed and constructed to prevent or diminish overland flow from entering the site during precipitation events.

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Design features and application of the attached SWCPs would ensure that the proposed activities would not result in occupation or modification of flood-prone areas. The proposal meets the intent of the Executive Order.

Executive Order 11990 of May, 1977 This requires the Forest Service to take action to minimize destruction, loss, or degradation of wetlands and to preserve the natural and beneficial values of wetlands.

There are no wetlands in the project area. The proposal meets the intent of the Executive Order.

Municipal Water I Drinking Water Source Area FSM 2542.05 defines a municipal supply watershed as one that serves a public water system as defined in Public Law 93-523 (Safe Drinking Water Act); or as defined in State safe drinking water regulations. The definition does not include communities served by a well or confined ground water unaffected by Forest Service activities. The 1996 Safe Drinking Water Act (SDWA) Amendments established a new emphasis on preventing contamination problems through source water protection and enhanced water system management. Formal agreements approved by the Chief of the Forest Service are appropriate only when intensified multiple-use management fails to meet the needs of the water user and use restrictions are necessary. Drinking water is not one of the beneficial uses of the waters in the project area designated by the State. There are no municipal water/drinking water source areas in, or downstream from, the project area. The proposed project is located close to private lands that may have associated wells developed for drinking water. The dnlling would go through the aquifers associated with the following formations: Dakota, Morrison/Entrada, and Kayenta.

Recommendation: Set the surface casing in the upper Chinle, then cement casing string all the way back to surface, thereby isolating any porosity zones between the surface and the upper Chinle.

Clean Water Act The Clean Water Act requires each state to implement its own water quality standards. The State of Utah has identified the following beneficial uses for tributaries to the Dolores River:

• 2B - protected for secondary-contact recreation, such as boating, wading, or similar uses; • 3A - protected for cold water species of game fish and other cold water aquatic life, including

the necessary aquatic organisms in their food chain. • 4 - protected for agricultural uses, including irrigation of crops and stock watering.

This river segment has been determined to be fully meeting water quality standards for the classified beneficial uses. No stream segments within or downstream from the analysis area in Utah have been designated as impaired or requiring a TMDL (total maximum daily load) analysis (Utah DWQ, 2006). Within Colorado, the Dolores River from Little Gypsum Valley bridge to the Colorado/Utah border is on the 2004 303(d) list as impaired due to Fe (iron) concentrations (CDPHEWQCC, 2008). La Sal Creek is tributary to this section of the Dolores however past water quality sampling at various sites along La Sal Creek (including at the State Line) did not detect iron at any of the sites. La Sal Creek does not appear to be contributing to the iron exceedances in the Dolores River. In addition, the proposed activity is not expected to increase iron in the water column.

In additional to the beneficial use classifications, all surface waters, irrespective of ownership, that are geographically located within the outer boundary of a National Forest are designated as Hi!=Jh Qualitv

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level of water quality (UT DEQ, 2008). The Forest Service is the designated Water Quality Management Agency for National Forest System lands in Utah. A 2009 memorandum of understanding (MOU) between the Forest Service and the Utah Division of Water Quality defines the roles and responsibilities of each agency relative to water quality management on National Forest System lands (MOU, 2009).

To comply with the antidegradation policy and State water quality standards, the Forest Service must implement or ensure the implementation of practices that maintain the current, high level of water quality. These include practices in Forest Service Handbook 2509.22, Soil And Water Conservation Practices; State best management practices; or specialized, site-specific practices. All these types of practices are designed to fully protect and maintain water-related beneficial uses, and to prevent or minimize nonpoint source pollution.

Forest Plan/R4 Soil Quality Guidelines (FSH 2509.18, Chapter 2, R4 Supplement) The disturbance associated with this proposed project is detailed in the following table:

Well pad (acres) Access road (acres) Total (acres)

Pine #2 1.8 1.8 3.6

Pine #3 2.2 0.2 2.4

Total disturbance (acres)

6.0

The general direction under the Forest Plan for soil resource management includes the following: maintain or improve soil productivity and watershed qualities within the ecological site capabilities; minimize adverse, man-caused impacts to the soil resource including accelerated erosion, compaction, contamination, and displacement. Specific practices include:

• protecting or conserving topsoil when conducting surface disturbing activities;

• providing adequate drainage and revegetation on areas capable of supporting vegetation disturbed during construction or other surface disturbing activities to stabilize the area and control soil erosion;

• stabilizing and/or closing and rehabilitating non-system roads where significant resource damage is occurring;

• adding mulch, fertilizer, and other sOil amendments as necessary to reduce soil erosion and increase vegetative growth;

• controlling livestock and big-game grazing so plant cover is not reduced to less than the amount needed for soil and watershed protection.

Recommendation: topsoil piles would be placed in long shallow windrows and seeded to maintain biotic activity rather then piled in one large heap. This is consistent with the guidelines in the Utah Reclamation Guide.

Recommendation: for final reclamation, dimpling the reshaped surfaces is more successful than smoothly graded slopes. The dimples or pocks should not go to the depth of the subsoil.

Soil quality guidelines provide for the maintenance of soil properties that affect soil productivity and hydrologic function. During project planning the soil quality guidelines are used to design and mitigate activities. FSH 2509.18, the Soil Management Handbook, defines an activity area as "An area impacted by a land management activity, excluding specified transportation facilities, dedicated trails, and mining excavations and dumps." The activity area for this proposal includes the individual proposed well pads and the immediate surrounding area where possible incidental equipment use is foreseeable during pad construction. Because the proposed well pads will be at least partially reclaimed in the short-term, it is not considered an excluded mining excavation area in this analysis.

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Based on the above definition of an activity area, approximately 50% of each activity area will be disturbed in the short-term. This exceeds the guideline for detrimental soil disturbance, but is allowable as long as the guideline would be met upon project completion. Because surface restoration would redistribute the topsoil and add amendments as necessary to achieve seventy percent (70%) vegetation and crown cover over the entire disturbed area and 60% ground cover (vegetation, rock, litter), the activity area is expected to be sufficiently reclaimed to meet the guideline of 15% by project completion. If the wells were transitioned to a production facility, the portion of the activity area that is retained for the facility will be considered to be dedicated to that use and would no longer be subject to the soil quality guidelines.

The proposed activities including industry best practice, recommendations and SWCPs would meet the soil quality guidelines. Detrimental soil disturbance would not exceed the 15% guideline in the long-term.

References CDHEQ, 'WATER QUALITY LIMITED SEGMENTS STILL REQUIRING TMDLS'. Colorado's 2008

303(d) List and Monitoring and Evaluation List. Water Quality Control Division 2008.

http://www.cdphe.state.co.us/op/wqcc/SpeciaITopics/303(d)/303dtmdlpro.html

USDA-FS. 1988. R1/R4 Soil and Water Conservation Practices Handbook, FSH 2509.22.

Utah Department of Environmental Quality, Division of Water Quality. 2008. Utah Administrative Code R317-2 . Standards of Quality for Waters of the State. Available at the time of this report at http://www.rules.utah.gov/publicat/code/r317/r317-002.htm.

Utah Department of Environmental Quality, Division of Water Quality. 2006. Utah's 2004 303(d) List of Waters. Available at the time of this report at

http://www. waterquality .utah.gov/documents/Utah305b_2006VoI1_6-30-06.pdf

Utah Division of Oil, Gas, and Mining. Date Unknown. The Practical Guide to Reclamation in Utah. Available at the time of this report at https://fs.ogm.utah.gov/pub/MINES/Coal Related/RecMan/Reclamation Manual.pdf

Western Governor's Association. 2004. Coal Bed Methane Best Practices. Available at the time of this report at http://www.westgov.org/new/CoaIBedMethane.pdf

Hydrogeologic Map of the Manti-La Sal National Forest, USFS 2007

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Soil and Water Conservation Practices (SWCP's) and Best Management Practices (BMP's)

The Forest Service is the designated Water Quality Management Agency for National Forest System lands in Utah. A 2009 memorandum of understanding (MOU) between the Forest Service and the Utah Division of Water Quality defines the roles and responsibilities of each agency relative to water quality management on National Forest System lands (MOU, 2009).

To comply with the antidegradation policy and State water quality standards, the Forest Service must implement or ensure the implementation of practices that maintain the current, high level of water quality. These include practices in Forest Service Handbook 2509.22, Soil And Water ConseNation Practices; State best management practices; or specialized, site-specific practices. All these types of practices are designed to fully protect and maintain water-related beneficial uses, and to prevent or minimize nonpoint source pollution (MOU, 2009).

SWCPs applicable to the planning phase of the proposed project include:

SWCP SWCP OBJECTIVE CONSIDERATIONS FOR IMPLEMENTATION

11.05 WETLANDS ANALYSIS AND EVALUATION ­ To maintain wetlands function and avoid adverse soil and water resource impacts associated wit the destruction of modification of wetlands.

No wetlands within the project area

11 .07

OIL AND HAZARDOUS SUBSTANCE SPILL CONTINGENCY PLANNING ­ To minimize contamination of water from accidental spills by prior planning and development of Spill Prevention Control and Countermeasure Plans

A SPCC Plan is required if the total, above-ground storage of oil, petroleum products, or other hazardous materials exceed 1320 gallons, or any single container exceeds a capacity of 660 gallons.

Each construction crew or piece of heavy equipment must have sufficient supplies of absorbent and barrier materials on-hand to allow the rapid containment and recovery of any spills.

11.14

MANAGEMENT OF SNOW SURVEY SITES - To protect snow courses and re lated data sited from effects by land management activities

There are no snow courses or SNOTEL sites the project area.

14.05

PROTECTION OF UNSTABLE AREAS - To protect unstable areas and avoid triggering mass movements of the soil mantle and resultant erosion and sedimentation.

No unstable areas located within the project area.

15.02

GENERAL GUIDELINES FOR THE LOCATION AND DESIGN OF ROADS AND TRAILS - To locate and design roads and trails with minimal soil and water impact while considering all design criteria.

New roads locati ons have been reviewed by Forest Service pe rsonnel and alignments have been altered to minimize impacts to soil and water. Cross-drainage spacing will vary by erosion hazard rating and other soil characteristics.

SWCPs applicable to the implementation phase of the proposed project include:

SWCP SWCP OBJECTIVE CONSIDERATIONS FOR IMPLEMENTATION

11.09 MANAGEMENT BY CLOSURE TO USE ­ To exclude activities that could result in damages to facilities or degradation of soil and water resources.

Construction would be allowed when rutting of soils does not occur. Gates would be installed to control public use of the roads accessing the well sites.

CE Checklist •• SWCP SWCP OBJECTIVE CONSIDERATIONS FOR IMPLEMENTATION

11.11 PETROLEUM STORAGE AND DELIVERY FACILITIES AND MANAGEMENT ­ To protect surface and subsurface soil and water resources from petroleum fluid contamination resulting from leaking delivery systems and storage facilities.

Note that this also applies to other hazardous materials, including drilling fluids

The SWCP states that delivery and storage facilities will be located, designed, constructed, and maintained in a manner that minimizes the potential for contamination of surface and subsurface soil and water resources from leaking flowlines, pipelines, and storage tanks.

Well pads will be shaped to drain all surface runoff to the lined, reserve pit. See also SWCP16.07

11.13

SANITARY GUIDELINES FOR CONSTRUCTION OF TEMPORARY LABOR, SPIKE, LOGGING , AND FIRE CAMPS AND SIMILAR INSTALLATIONS ­ To eliminate water pollution and other potential environmental and health impacts trom the disposal ot human waste and wastewater trom temporary camps ot all types.

Porta-potties will be required at each well site during drilling. Over-night camping will not be allowed without permission tor a Forest Service representative.

13.03

TRACTOR OPERATION EXCLUDED FROM WETLANDS, BOGS, AND WET MEADOWS ­ To limit soil damage, turbidity, and sediment production resulting from compaction, rutting, runoff concentration, and subsequent erosion.

Note that this SWCP applies to all heavy equipment operations.

The SWCP states that application of the SWCP is mandatory for all vegetation manipulation projects, including mining operations. The agency project administrator or project supervisor is responsible for identifying wetlands and meadows not previously recognized in the NEPA process and for following or developing management controls to protect wetland and meadows. Protection of wetlands (mapped and unmapped) should be included in pre-work briefings.

No wetlands present within project area.

13.04

REVEGETATION OF SURFACE DISTURBED AREAS ­ To protect soil productivity and water quality by minimizing soil erosion

Surface soils will be salvaged to a minimum depth of 6 inches. It topsoil depths are greater than 6 inches, the entire depth will be salvaged, stockpiled, and protected from erosion or other damages during operations.

Salvaged topsoil will be spread over areas from which the topsoil was slripped. The surface should be left rough/pitted (with surface variations of 6­12 inches) to limit rilling and to provide tor water retention to enhance seed germination. Topsoil will not be spread when the ground or topsoil is frozen, wet, or powdery.

All disturbed areas will be seeded with seed mixtures developed for the project. The seed will be certified weed free and should contain a minimal quality of other weeds, especially invasives. The proponent should have an independent test of seed purity, germination, and weed content prior to seed application. Seed all disturbed soils within 6 working days ot tinal grading, weather and soil conditions permitting. If the soil surface is crusted, take appropriate measures to break up the crusted areas prior to seeding.

Mulch will be applied on areas with highly erodable or droughty soils, slopes greater than 40 percent, visually sensitive areas, and other areas as specified by the agency project administrator.

13.05

SOIL PROTECTION DURING AND FOLLOWING SLASH WINDROWING - To prevent removal or severe disruption of the productive surface soil and to minimize losses from erosion

Note that this SWCP applies to all ground-clearing operations where woody material is windrowed or stockpiled.

Material removed during site clearing should be stockpiled or spread over the topsoil pile. During reclamation, stockpiled material will be randomly scattered over areas of soil disturbance with preterence given to those areas where topsoil was replaced.

CE Checklist •• SWCP SWCP OBJECTIVE CONSIDERATIONS FOR IMPLEMENTATION

13.06

SOIL MOISTURE LIMITATIONS FOR TRACTOR OPERATION ­ To minimize soil compaction, puddling, rutting, and gullying with resultant sediment production and loss of soil productivity.

Note that this SWCP applies to all heavy equipment operations.

The normal operating season on National Forest land is from July 5th to October 15th. Construction and other activities outside the normal operating season will require supplemental plans addressing temporary shutdown and erosion control measures. If temporary erosion control measures are not effective, activities will be suspended until condit ions improve.

Rutting will be used as an indicator of wet conditions. Vehicle traffic and equipment operation will be restricted to prevent rutting in excess of one inch on gravel roads, 2 inches on native surface roads and 4 inches in other work areas. Proponent(s) will provide maintenance equipment to repair rutting as soon as ground conditions permit.

During extended periods of dry weather, additional measures including vehicle and equipment restrictions may be necessary to prevent powdering of soils, to maintain firm working surfaces, to limit fugitive dust, and to maintain appropriate moisture conditions to protect topsoils during reclamation.

Follow R4 Soil Quality Standards and Guidelines for detrimental puddling and compaction.

14.05

PROTECTION OF UNSTABLE AREAS -To protect unstable areas and avoid triggering mass movements of the soil mantle and resultant erosion and sedimentation.

No unstable areas were located within project area.

14.06

RIPARIAN AREA DESIGNATION ­ To minimize the adverse effects on riparian areas with prescriptions that manage nearby logging and related land disturbance activities.

Note that this SWCP applies to all heavy equipment operations.

No riparian areas within project area.

14.18

EROSION CONTROL STRUCTURE MAINTENANCE - To insure constructed erosion control structures are stabilized and working effectively.

Soil erosion control structures constructed for the well pad will be maintained until the site is reclaimed. Roads, new and reconstructed, will be maintained, including drainage and surfacing.

15.04

TIMING OF CONSTRUCTION ACTIVITIES ­ To minimize erosion by conducting operations during minimal runoff periods.

The normal operating season includes the time period that typically has suitable soil moisture and runoff conditions for most Forest activities and operations.

The proponent should schedule and conduct most operations within the normal operating season. The proponent shall conduct all activities to prevent erosion and sedimentation. Temporary erosion control measures may be required to prevent, control, and mitigate erosion and sedimentation. Temporary and permanent erosion control work must be kept current with ongoing operations, especially when constnuction occurs outside of the normal operating season. See SWCP 13.06 for soil moisture criteria.

15.05

SLOPE STABILIZATION AND PREVENTION OF MASS FAILURES - To reduce sedimentation by minimizing the chances for road-related mass failures, including landslides and embankment slumps.

Note that this SWCP applied to any temporary working trave/way.

No unstable areas present within project area. The proponent will avoid undercutting road-side slopes. Slumped or sloughed material will not be side-cast; it may be incorporated into the travelway or end-hauled to an area deSignated by the project administrator.

15.06

MITIGATION OF SURFACE EROSION AND STABILIZATION OF SLOPES ­ To minimize soil erosion from road cut slopes, fill slopes, and travel ways.

Newly constructed and reconstnucted roads will be surfaced with a stable aggregate to a depth of at least 4 inches.

15.07

CONTROL OF PERMANENT ROAD DRAINAGE ­ To minimize the erosive effects of concentrated water and the degradation of water quality by proper design and construction of road drainage systems and drainage control stnuctures.

No more than 200 feet of ditch will lead into perennial or intermittent stream channels. Spacing may vary by up to 10% to outlet water in favorable locations.

CE Checklist •• SWCP SWCP OBJECTIVE CONSIDERATIONS FOR IMPLEMENTATION

15.08

PIONEER ROAD CONSTRUCTION - To minimize sediment production and mass wasting associated with pioneer road construction.

The SWCP states that construction of pioneer roads will be confined to the roadway construction limits unless otherwise approved by the agency project administrator or engineering representative. Construction will be conducted to prevent undercutting of final cut slope, prevent deposition of materials outside the designated roadway limits, and accommodate drainage with temporary culverts or log crossings unless otherwise approved. Erosion control work will be completed concurrent with construction activity.

The project proponent is responsible for submitting an operating plan that includes erosion control measures.

15.09

TIMELY EROSION CONTROL MEASURES ON INCOMPLETE ROADS AND STREAM CROSSING PROJECTS ­ To minimize erosion of and sedimentation from disturbed ground on incomplete projects.

The SWCP states that temporary erosion control and other protective measures will be kept current on all disturbed areas. Areas must not be abandoned for the winter with remedial measures incomplete.

15.10

CONTROL OF ROAD CONSTRUCTION, EXCAVATION, AND SIDE-CAST MATERIAL ­ To reduce sedimentation from unconsolidated excavated and side-cast material caused by road construction, reconstruction, or maintenance.

Protective measures must be applied to all disturbed, erosion-prone areas. Material will not be side-cast.

15.11

SERVICING AND REFUELING EOUIPMENT ­ To prevent contamination of waters from accidental spills of fuels, lubricants, bitumens, and other harmful materials.

Note that this SWCP applies in all areas where heavy equipment is operated.

The proponent will designate the location, size, and use of service refueling areas for the approval of the agency project administrator or engineering representative. Refueling areas will be more than 200 feet from perennial and intermittent stream channels, seeps and springs, wetlands, lakes and reservoirs, stock water developments, and other water features.

All heavy equipment and service vehicles will have a supply of absorbent and other cleanup materials on hand for initial containment of spills.

All projects will adhere to the Hazardous Substance Spill Plan in case of accidents.

15,12

CONTROL OF CONSTRUCTION IN RIPARIAN AREAS - To minimize the adverse effects on riparian areas from roads.

Note that this SWCP applies in all areas where heavy equipment is operated.

No construction in riparian areas is proposed with this project.

15.13

CONTROLLING IN-CHANNEL EXCAVATION - To minimize stream channel disturbances and related sediment production.

No construction in or across riparian areas is proposed with this project.

15.18

DISPOSAL OF RIGHT-OF-WAY AND ROADSIDE DEBRIS - To insure debris generated during road construction is kept out of streams and prevent slash and debris from subsequently obstructing channels.

Debris will not be placed in the stream channel or floodplain; incidental debris from tree felling will be removed. Streamside willows may be removed in clumps, set aside, and replaced during cleanup/shaping of the disturbed area. Other debris will be disposed of in adjacent upland areas. Disposal method will be specified by the engineering representative or the agency project administrator.

15.21

MAINTENANCE OF ROADS - To maintain all roads in a manner which provides for soil and water protection by minimizing rutting, failures, side-cast, and blocking of drainage facilities.

See rutting standards

Road maintenance requirements will be specified in the road use permit.

15.22

ROAD SURFACE TREATMENT TO PREVENT LOSS OF MATERIALS ­ To minimize the erosion of road surface materials and, consequently, reduce the likelihood of sediment production.

Road segments associated with the proposed activities will be graveled and may be treated with some type of dust abatement material. Additional measures will be required if activities occur or continue outside the normal operating season.

CE Checklist • • SWCP SWCP OBJECTIVE CONSIDERATIONS FOR IMPLEMENTATION

15.23

TRAFFIC CONTROL DURING WET PERIODS - To reduce the potential tor road surface disturbance during wet weather and reduce sedimentation.

The SWCP states that roads that must be used during wet periods should have a stable surface and sufficient drainage to allow such use with a minimum of resource impact. Road not constructed for all weather use should be closed during the wet season. Where winter operations are planned, roads may need to be upgraded and maintenance intensified to handle the traffic without creating excessive erosion and damage to the road surfaces. Road closures and traffic control measures should be implemented on all roads when damage would occur as a result of use during wet weather.

During the normal operating period, vehicle traffic and equipment operation will be restricted to prevent rutting in excess ot one inch on gravel roads , 2 inches on native surface roads and 4 inches in other work areas. Proponent(s) will provide maintenance equipment to repair rutting as soon as ground conditions permit. Road restrictions and trattic control measures will be implemented on all roads when damage occurs. The decision to restrict a road is made by the agency project administrator or engineering representative.

Outside the normal operating period, additional measures may be necessary to protect road surfaces and subgrades and to prevent erosion and sedimentation.

15.25

OBLITERATION OF TEMPORARY ROADS - To reduce sediment generated from temporary roads by obliterating them at the completion of their intended use.

The well site access roads are considered temporary roads and will be obliterated when no longer needed. Obliteration will include removal/salvage of gravel, recontouring or reshaping of sideslopes and/or construction of waterbars, construction of access controls, application of salvaged woody debris, and revegetation.

16.06 RECLAMATION OF OIL AND GAS WELL SITES ­To protect soil and water resource through the development of reclamation plans prior to the approval of an APD.

The SWCP states that reclamation should begin within the first growing season following completion of drilling activities. Reclamation must include drainage or erosion control structures necessary to prevenf erosion and degradation of water quality. Revegetation should include native species that provide short and intermediate term ground cover and allow for the reestablishment of desirable species of the long-term.

16.07 RESERVE PIT LOCATION, DESIGN, OPERATION, AND RECLAMATION ­ To protect the quality of surface and ground water from degradation by physical and chemical contaminants originating from the construction and operation of reserve pits and drilling sites.

The SWCP states that reserve pits should be located in the cut portion of the drill pad and not at the edge of steep slopes. Special measures, including pit liners or use of a closed mud system, will be required to insure the containment of drilling ftuids if the reserve pit must be places in a sensitive location or in porous materials. The use of nontoxic drilling fluids is encouraged. Dumping trash in the reserve pit is prohibited. Reclamation methods must ensure protection of soil and water quality. Reserve pits should not remain open and full all winter unless there is sufficient capacity to contain meltwater. Contents of the reserve pits will be disposed of ott ­ forest at an approved location when drilling procedures are concluded.