Westchester-Grand Prairie Community Alliance (WCGPCA)

RECOMMENDATIONS FOR CHANGES TO THE GRAND PRAIRIE GAS DRILLING ORDINANCE Overall Recommendation:
We recommend a thorough review of the Southlake, Texas Gas Drilling Ordinance. Many members of our Alliance have cited it. We all agree that it is one of the best Ordinances in place in the Barnett Shale. We would also like to recommend production of a video for the City of Grand Prairie Web site. This video should thoroughly cover the process for permitting gas drilling in the City from beginning of the process (with the submission of requests by gas companies to the Texas Railroad Commission) to the Approval of a Permit by the City of Grand Prairie. A straightforward, stepby-step overview is highly recommended.

Critical Recommendation: Gas Drilling Advisory Commission (GDAC):

We recommend implementing a Gas Drilling Advisory Commission as follows: 1) One Council Member, Committee Chair 2) One Planning and Zoning Commission Member (Not an appointee of the GDAC Committee Chair). 3) City Attorney 4) Deputy City Manager (or his/her representative) 5) One Resident of Grand Prairie (South of I30). 6) One Resident of Grand Prairie (north of I30). 7) One Home Owners Association board member from one of GPs 52 HOAs.

NOW THE IMPORTANT HIGHLIGHTS WITH SOME DETAILS:

SUPS: SPECIFIC USE PERMITS will be required for all gas drilling permits submitted to the City. Properly scheduled hearings before the Planning and Zoning Commission will become the appropriate procedure for all requests for gas drilling. Proper notice of Public Hearings will be required for all Gas Drilling SUPs. (Important: See the City of Southlakes SUP Process for the Ideal Model for this process including Neighborhood Meetings known as Southlake Program for the Involvement of Neighborhood (SPIN) Meetings ~ the only one of its kind.) BASELINE TESTING: Baseline testing of air, water and soil will be mandatory before any gas drilling commences in Grand Prairie. During drilling and fracturing, additional testing will be conducted. Post-testing will conducted yearly or when problems arise. PROTECTIVE SETBACK: At Least 1,750 Foot Setback for all Gas Drilling Activities. No variances given, unless a 100% waiver from the neighborhood is obtained.
Westchester-Grand Prairie Community Alliance (WCGPCA) PAGE 1

NOW THE IMPORTANT HIGHLIGHTS WITH SOME DETAILS (CONTINUED):

Seismic Testing: Seismic Testing shall be defined in the Ordinance and require a Permit. (Currently, only Seismic Surveys are mentioned in the Ordinance and not defined.) The Ordinance states that Seismic Surveys shall not be permitted. But there is no mention of Seismic Testing, or a definition of it anywhere in the Ordinance. All homeowners and businesses targeted for Seismic Testing should be notified (in writing) and by certified mail with signature at least one month prior to testing. Specific details of the process will be included with the notice ~ including that 60,000 pound, dropweight thumper trucks will be traveling in tandem throughout the targeted neighborhoods. Property owners who do agree to the testing shall be compensated in an amount determined by citizen feedback during re-writing of the Grand Prairie Gas Drilling Ordinance. Information obtained through Seismic Testing belongs to homeowners and it is not the citys right to approve this procedure. Streets and neighborhoods where 5% of the citizens do not agree to Seismic Testing will NOT be part of the testing. Streets and neighborhoods where mineral leases have not been signed will NOT be part of any testing.

Communicating about Gas Drilling Activities in Grand Prairie:

All Grand Prairie Gas Drilling Activities will be found from a LINK clearly visible from the Front Page of the City of Grand Prairie, Texas Web site: www.gptx.org. SIGNAGE: Signs designating a Gas Drilling Permit under consideration by the City will be of a BOLD COLOR (Dark Blue is preferred) and of a size no smaller than 10 feet x 10 feet. All signs will be properly maintained by the gas company weekly including mowing weeds and being sure that the sign is clearly visible and not falling down. Fines will be assessed as necessary ~ $2,000 per incidence of improper upkeep. Notification Requirements: Letters to HOA Reps within 1 mile of the Corn Valley Pad Site well bore were never received even though these letters are in the Application documents. Signature should be required for all certified letter notifications from the City. Westchester HOA Reps were never notified about the Permits status. Timeline for Drilling Activities: Brick masonry walls shall be completed before drilling and/or fracking commences. This work should be completed during the construction phase. Green Completions: Green completions must be utilized in all gas drilling unless there is question about finding gas at a site. Green completions shall be MANDATORY for every well after the first is completed. FRAC Ponds: No Open Pits and/or Frac Ponds shall be allowed inside City Limits. If any Frac Ponds are permitted in Grand Prairie, they shall always be lined.
Westchester-Grand Prairie Community Alliance (WCGPCA) PAGE 2

NOW THE IMPORTANT HIGHLIGHTS WITH SOME DETAILS (CONTINUED):

Section 13-507. High Impact Gas Well Permit. Section K should come before Section A. This section is very poorly organized. *Pipelines*: All pipeline construction plans will be submitted as part of the Permit Application SUP Process and for public record. No Application will be approved without detailed pipeline plans for the gas well sites.

Deed Restrictions: Any gas well drilling in a residential neighborhood will follow deed restrictions in that neighborhood above and beyond the ordinances landscaping requirements ~ until the end of the wells life. This will ensure the integrity of our properties.

PIDs: Any gas drilling permitted in a residential community will require a contract with that neighborhoods PID to mow, edge, upkeep of the landscaping and maintenance of the irrigation system. If a PID in not available, the industry will be required to hire a third party company until the well is closed. This will help keep our property values high and ensure the integrity of our property. Trucks: More signage for truck routes going to and from the pad site. "No Gas Drilling Traffic" signs shall be placed in communities entrances going to and from pad sites. Violations of the Ordinance: A designated city employee shall travel to each site every 5 days to discover violations of the ordinance during the life of the well. Industrial Zoning: All gas drilling in Grand Prairie shall be zoned Industrial. Gas Drilling Logs: The industry must provide all gas drilling logs at each site to Gas Inspector/Designated City Personnel upon demand and while the pad is active. Public Notices: It is 2010, all public notices of gas drilling permits and activities shall be posted in both online and print editions of high profile newspapers including the Dallas News and the Fort Worth Star Telegram. Links to all online notices shall be clearly visible on the City of Grand Prairies Web site. All 52 HOAs in Grand Prairie shall receive written notification for publication in community newsletters. Fracturing: High-imact well communities shall be notified of fracture stimulation at least 120 hours in advance of the fracturing commencing. Highly visible signage at entry and exits of the neighborhoods shall be erected as well. Written notice via 1st class mail within 120 hours of fracturing shall also be provided for those properties within 600 feet of the well or wells being fractured. Parks: No gas well drilling shall be conducted in public parks with or without City Council consent. No variances allowed.
Westchester-Grand Prairie Community Alliance (WCGPCA) PAGE 3

NOW THE IMPORTANT HIGHLIGHTS WITH SOME DETAILS (CONTINUED):

Surface Water Conveyance: No gas well permit shall be issued for any well to be drilled within less than 2,000 feet of any type of surface water conveyance, including, but not limited to, creeks, streams, lakes, ponds, drainage ditches, or other constructed storm water conveyance systems. Recycled Water: Recycled water shall be used for drilling and fracking. Emissions: Ensure ZERO nox and voc emissions by using No Bleed Valves, No Truck Idling, Electric Drill Rigs and by using Vapor Recovery Systems. Seeps and Migration: Operators responsible for casing wells that are found to be associated with seeps and migration shall be investigated. Ensure that operators in violation will never be allowed to work as contractors in Grand Prairie, Texas.

### This document was prepared by the WESTCHESTER-GRAND PRAIRIE COMMUNITY ALLIANCE (WCGPCA) during the months of August and September, 2010. Contributors: Carl Dimon, Professional Engineer/Petroleum Engineer (Licensed in TX 1971-2008) Ben Grimes Joyce Gray Konstance Johnson Chris Koss Clay Newsome, President, Hills of Westchester HOA Susan Read Rosemary Reed, President, Westchester Association of Homeowners In Conclusion: We would like to recommend Drill Right Texas ~ a publication of the Texas
Oil and Gas Accountability Project. www.earthworksaction.org/Texas_OGAP.cfm.

"Never doubt that a small group of thoughtful, committed citizens can change the world. Indeed, it is the only thing that ever has." ~ Margaret Mead

Westchester-Grand Prairie Community Alliance (WCGPCA)

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