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uocuaign tnveiope iu: /Z1004r 1 <br /> CEQA Project: SCH # 2020010176 <br /> Lead Agency: San Joaquin County <br /> January 28, 2020 <br /> following comments and are provided by CaIGEM for consideration by the local <br /> permitting agency, in conjunction with the property owner and/or developer, on a <br /> parcel-by-parcel or well-by-well basis. As stated above, CaIGEM provides the above <br /> well review information solely to facilitate decisions made by the local permitting <br /> agency regarding potential development near a gas well. <br /> 1. It is recommended that access to a well located on the property be maintained <br /> in the event abandonment of the well becomes necessary in the future. <br /> Impeding access to a well could result in the need to remove any structure or <br /> obstacle that prevents or impedes access. This includes, but is not limited to, <br /> buildings, housing, fencing, landscaping, trees, pools, patios, sidewalks, and <br /> decking. <br /> 2. Nothing guarantees that a well abandoned to current standards will not start <br /> leaking oil, gas, and/or water in the future. It always remains a possibility that <br /> any well may start to leak oil, gas, and/or water after abandonment, no matter <br /> how thoroughly the well was plugged and abandoned. CaIGEM acknowledges <br /> that wells abandoned to current standards have a lower probability of leaking <br /> oil, gas, and/or water in the future, but makes no guarantees as to the <br /> adequacy of this well's abandonment or the potential need for future re- <br /> abandonment. <br /> 3. Based on comments 1 and 2 above, CaIGEM makes the following general <br /> recommendations: <br /> a. Maintain physical access to any gas well encountered. <br /> b. Ensure that the abandonment of gas well(s) is to current standards. <br /> If the local permitting agency, property owner, and/or developer chooses not to <br /> follow recommendation "b" for a well located on the development site <br /> property, CaIGEM believes that the importance of following recommendation <br /> "a" for the well located on the subject property increases. If recommendation <br /> "a" cannot be followed for the well located on the subject property, then <br /> CaIGEM advises the local permitting agency, property owner, and/or developer <br /> to consider any and all alternatives to proposed construction or development on <br /> the site (see comment 4 below). <br /> 4. Sections 3208 and 3255(a)(3) of the Public Resources Code give CaIGEM the <br /> authority to order the abandonment or re-abandonment of any well that is <br /> hazardous, or that poses a danger to life, health, or natural resources. <br /> Responsibility for abandonment and or re-abandonment costs for any well may <br /> be affected by the choices made by the local permitting agency, property <br /> owner, and/or developer in considering the general recommendations set forth <br /> in this letter. (Cal. Public Res. Code, § 3208.1.) <br /> 5. Maintaining sufficient access to a gas well may be generally described as <br /> maintaining "rig access" to the well. Rig access allows a well servicing rig and <br /> associated necessary equipment to reach the well from a public street or access <br /> way, solely over the parcel on which the well is located. A well servicing rig, and <br /> any necessary equipment, should be able to pass unimpeded along and over <br /> Planning Commission Staff Report 11age-1 '1 ' 35 <br /> PA-1900240 (SA), PA-2000014--(ER), PA-200001-9 (DA} - - - -- -- <br /> Response Letters <br />