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