Southern District 5816 Corporate Avenue, Suite 100 Cypress, CA 90630 T: (714) 816-6847 F: (714) 816-6853 conservation.ca.gov December 19, 2018 VIA EMAIL Mr. Fred Shaffer Aragon (Toluca/Colton) Properties 126 Lomita Street El Segundo, CA 90245 fshaffer@aragon.ca Mr. Lawrence Quirante, Plan Check Engineer 201 North Figueroa Street Los Angeles, CA 90245 lawrence.quirante@lacity.org Division Reference Number: 5530 Assessor Parcel Number: 5160-011-015, 5160-011-016, and 5160-011-017 Project Address:1314 – 1320 West Court Street, Los Angeles, CA 90266 Property Owner: Aragon (Toluca/Colton) Properties Project Name: Court Apartments Dear Messrs. Shaffer and Quirante: The Division of Oil, Gas, and Geothermal Resources’ (Division) authority is set forth in Division 3 of the Public Resources Code (PRC), and Title 14 of the California Code of Regulations (CCR). PRC § 3208.1 establishes well reabandonment responsibility when a previously plugged and abandoned well may be impacted by planned property development or construction activities. Local permitting agencies, property owners, and/or developers should be aware of, and fully understand, that significant and potentially dangerous issues may be associated with development near oil, gas, or geothermal wells. The Division has received and reviewed the above referenced project application dated October 30, 2018. To assist local permitting agencies, property owners, and developers in making wise land use decisions regarding potential development near oil, gas, or geothermal wells, the Division provides the following well evaluations. The project is located in Los Angeles county, within the boundaries of Los Angeles City oil field. Our records indicate there are seven known oil, gas, or geothermal wells located within the project boundary as identified in the application. The proposed project is a 60-unit, 6 story apartment building with 2 level subterranean parking garage in Downtown Los Angeles on undeveloped land. Division Reference Number: 5530 Project Name: Court Apartments December 19, 2018 Page 2 of 6 The wells listed below are not abandoned to current Division requirements as prescribed by law, and based upon information provided, are projected to be built over or have future access impeded. The Division expects these wells to be abandoned or reabandoned in compliance with current Division requirements prior to development. Well Manley Energy Resources, LLC. MOC 5 (03719033) Status The record review process shows that the subject well is not abandoned consistent with current PRC and CCR as of December 18, 2018. Based on well records: 1. Upper hydrocarbon zone isolation plug is inadequate (CCR § 1723.1). 2. Hydrocarbon zone isolation plug is inadequate (CCR § 1723.1). Note: Well reported not leaking on 9/3/2004. Manley Energy Resources, LLC. No. 1 (03726246) The record review process shows that the subject well is not abandoned consistent with current PRC and CCR as of December 18, 2018. Based on well records: 1. The well is a buried-idle well. 2. Surface plug is not present (CCR § 1723.5). 3. Base of freshwater isolation plug is not present (CCR § 1723.2). 4. Upper hydrocarbon zone isolation plug is not present (CCR § 1723.1). 5. Hydrocarbon zone isolation plug is not present (CCR § 1723.1). Manley Energy Resources, LLC. No. 2 (03726244) Note: No well leak test reported. The record review process shows that the subject well is not abandoned consistent with current PRC and CCR as of December 18, 2018. Based on well records: 1. The well is a buried-idle well. 2. Surface plug is not present (CCR § 1723.5). 3. Base of freshwater isolation plug is not present (CCR § 1723.2). 4. Upper hydrocarbon zone isolation plug is not present (CCR § 1723.1). 5. Hydrocarbon zone isolation plug is not present (CCR § 1723.1). Note: No well leak test reported. Division Reference Number: 5530 Project Name: Court Apartments December 19, 2018 Page 3 of 6 Manley Energy Resources, LLC. No. 3 (03726245) The record review process shows that the subject well is not abandoned consistent with current PRC and CCR as of December 18, 2018. Based on well records: 1. The well is a buried-idle well. 2. Surface plug is not present (CCR § 1723.5). 3. Base of freshwater isolation plug is not present (CCR § 1723.2). 4. Upper hydrocarbon zone isolation plug is not present (CCR § 1723.1). 5. Hydrocarbon zone isolation plug is not present (CCR § 1723.1). Note: No well leak test reported. Mrs. J. Alderson No.1A (03725731) The record review process shows that the subject well is not abandoned consistent with current PRC and CCR as of December 18, 2018. Based on well records: 1. The well is a buried-idle well. 2. Surface plug is not present (CCR § 1723.5). 3. Base of freshwater isolation plug is not present (CCR § 1723.2). 4. Upper hydrocarbon zone isolation plug is not present (CCR § 1723.1). 5. Hydrocarbon zone isolation plug is not present (CCR § 1723.1). Note: No well leak test reported. Mrs. J. Alderson No.2 (03725728) The record review process shows that the subject well is not abandoned consistent with current PRC and CCR as of December 18, 2018. Based on well records: 1. The well is a buried-idle well. 2. Surface plug is not present (CCR § 1723.5). 3. Base of freshwater isolation plug is not present (CCR § 1723.2). 4. Upper hydrocarbon zone isolation plug is not present (CCR § 1723.1). 5. Hydrocarbon zone isolation plug is not present (CCR § 1723.1). Note: No well leak test reported. Division Reference Number: 5530 Project Name: Court Apartments December 19, 2018 Page 4 of 6 The well listed below is abandoned to current Division requirements as prescribed by law, and based upon information provided, is projected to be built over or have future access impeded. Well Manley Energy Resources, LLC. MOC 4 (03719034) Status The record review process shows that the subject well is abandoned consistent with current PRC and CCR as of December 18, 2018. Note: Well reported not leaking on 9/3/2004. The Division categorically advises against building over, or in any way impeding access to, oil, gas, or geothermal wells. Impeding access to a well could result in the need to remove any structure or obstacle that prevents or impedes access including, but not limited to, buildings, housing, fencing, landscaping, trees, pools, patios, sidewalks, roadways, and decking. Maintaining sufficient access is considered the ability for a well servicing unit and associated necessary equipment to reach a well from a public street or access way, solely over the parcel on which the well is located. A well servicing unit, and any necessary equipment, should be able to pass unimpeded along and over the route, and should be able to access the well without disturbing the integrity of surrounding infrastructure. There are no guarantees a well abandoned in compliance with current Division requirements will not start leaking 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. The Division acknowledges wells plugged and abandoned to the most current standards have a lower probability of leaking in the future, however there is no guarantee that such abandonments will not leak. The Division advises that all wells identified on the development parcel prior to, or during, development activities be tested for liquid and gas leakage. Surveyed locations should be provided to the Division in Latitude and Longitude, NAD 83 decimal format. The Division expects any wells found leaking to be reported to it immediately. Failure to plug and reabandon a well may result in enforcement action, including an order to perform reabandonment well work, pursuant to PRC § 3208.1, and 3224. PRC § 3208.1 gives the Division the authority to order or permit the re-abandonment of any well where it has reason to question the integrity of the previous abandonment, or if the well is not accessible or visible. Responsibility for re-abandonment costs may be affected by the choices made by the local permitting agency, property owner, and/or developer in considering the general advice set forth in this letter. The PRC continues to define the person or entity responsible for reabandonment as: 1. The property owner - If the well was plugged and abandoned in conformance with Division requirements at the time of plugging and abandonment, and in its current condition does not pose an immediate danger to life, health, and property, but requires additional work solely because the owner of the property on which the well is located proposes construction on the property that would prevent or impede access to the well for purposes of remedying a currently perceived future problem, then the owner of the property on which the well is Division Reference Number: 5530 Project Name: Court Apartments December 19, 2018 Page 5 of 6 located shall obtain all rights necessary to reabandon the well and be responsible for the reabandonment. 2. The person or entity causing construction over or near the well - If the well was plugged and abandoned in conformance with Division requirements at the time of plugging and abandonment, and the property owner, developer, or local agency permitting the construction failed either to obtain an opinion from the supervisor or district deputy as to whether the previously abandoned well is required to be reabandoned, or to follow the advice of the supervisor or district deputy not to undertake the construction, then the person or entity causing the construction over or near the well shall obtain all rights necessary to reabandon the well and be responsible for the reabandonment. 3. The party or parties responsible for disturbing the integrity of the abandonment - If the well was plugged and abandoned in conformance with Division requirements at the time of plugging and abandonment, and after that time someone other than the operator or an affiliate of the operator disturbed the integrity of the abandonment in the course of developing the property, then the party or parties responsible for disturbing the integrity of the abandonment shall be responsible for the reabandonment. The statutes and regulations related to oil, gas, and geothermal resources can be found here: www.conservation.ca.gov/dog/Documents/11.16.18_DOGGR-SR.PDF. No well work may be performed on any oil, gas, or geothermal well without written approval from the Division. Well work requiring written approval includes, but is not limited to, mitigating leaking gas or other fluids from abandoned wells, modifications to well casings, and/or any other abandonment or re-abandonment work. The Division also regulates the top of a plugged and abandoned well’s minimum and maximum depth below final grade. CCR §1723.5 states well casings shall be cut off at least 5 feet but no more than 10 feet below grade. If any well needs to be lowered or raised (i.e. casing cut down or casing riser added) to meet this regulation, a permit from the Division is required before work can start. The Division makes the following additional recommendations to the local permitting agency, property owner, and developer: 1. To ensure that present and future property owners are aware of (a) the existence of all wells located on the property, and (b) potentially significant issues associated with any improvements near oil or gas wells, the Division recommends that information regarding the above identified well(s), and any other pertinent information obtained after the issuance of this letter, be communicated to the appropriate county recorder for inclusion in the title information of the subject real property. 2. The Division recommends that any soil containing hydrocarbons be disposed of in accordance with local, state, and federal laws. Please notify the appropriate authorities if soil containing significant amounts of hydrocarbons is discovered during development. As indicated in PRC § 3106, the Division has jurisdictional authority over the drilling, operation, maintenance, and abandonment of oil, gas, and geothermal wells, and attendant facilities, to prevent, as far as possible, damage to life, health, property, and natural resources, damage to underground oil, gas, and geothermal deposits, and damage to underground and surface waters suitable for Division Reference Number: 5530 Project Name: Court Apartments December 19, 2018 Page 6 of 6 irrigation or domestic purposes. In addition to the Division’s authority to order work on wells pursuant to PRC §§ 3208.1 and 3224, it has authority to issue civil and criminal penalties under PRC §§ 3236, 3236.5, and 3359 for violations within the Division’s jurisdictional authority. The Division does not regulate grading, excavations, or other land use issues. If during development activities, any wells are encountered that were not part of this review, the Division’s construction site well review engineer in the Cypress district office is to be notified immediately, and an amended site plan with well casing diagrams for Division review shall be filed. After appropriate review, the District office will send a follow-up well evaluation letter to the property owner, applicant, and local permitting agency. Should you have any questions, please contact me at (714) 816-6847 or via email at dogdist1@conservation.ca.gov. Sincerely, Digitally signed by Grace Brandt DN: cn=Grace Brandt, o=DOGGR, ou=Construction Site Well Review, email=grace.brandt@conservation.ca.gov, c=US Date: 2018.12.19 10:49:28 -08'00' Grace Brandt Construction Site Well Review Engineer cc: Uduak-Joe Ntuk, City of Los Angeles Petroleum Administrator uduak.ntuk@lacity.org CSWR File Well File '9 UNIT I-.- EJPIr._ If l?I 312$- it'll .y,s?l/uENT JHWLI was-I 195: Matty-'er IDENTIAL HE ?hum; NH LINE OF RES FOOTPRIN DIP-TE-ZI-I - I: ZIPPVZICJI 3?1@@35* hr: gig-4:11} - [Ill-n: rm JEHM my: Site Map 1314 1320 W. Court St. Los Angeles, CA 90026 Legend Approx Property Boundary Approx Excavation Boundary Approx Well Location; visible Plugged Abandoned .. Su?de Sample Location FIGURE 7 Project Number:347018 Unknown Status; Unknown Location 0 Consultants Southern District 5816 Corporate Avenue, Suite 100 Cypress, CA 90630 T: (714) 816-6847 F: (714) 816-6853 conservation.ca.gov December 19, 2018 VIA EMAIL Mr. Fred Shaffer Aragon (Toluca/Colton) Properties 126 Lomita Street El Segundo, CA 90245 fshaffer@aragon.ca Mr. Lawrence Quirante, Plan Check Engineer 201 North Figueroa Street Los Angeles, CA 90245 lawrence.quirante@lacity.org Division Reference Number: 5531 Assessor Parcel Number: 5160-019-001, 5160-019-002, and 5160-019-003 Project Address:1315 – 1323 West Colton Street, Los Angeles, CA 90026 Property Owner: Aragon (Toluca/Colton) Properties Project Name: Colton Apartments Dear Messrs. Shaffer and Quirante: The Division of Oil, Gas, and Geothermal Resources’ (Division) authority is set forth in Division 3 of the Public Resources Code (PRC), and Title 14 of the California Code of Regulations (CCR). PRC § 3208.1 establishes well reabandonment responsibility when a previously plugged and abandoned well may be impacted by planned property development or construction activities. Local permitting agencies, property owners, and/or developers should be aware of, and fully understand, that significant and potentially dangerous issues may be associated with development near oil, gas, or geothermal wells. The Division has received and reviewed the above referenced project application dated October 30, 2018. To assist local permitting agencies, property owners, and developers in making wise land use decisions regarding potential development near oil, gas, or geothermal wells, the Division provides the following well evaluations. The project is located in Los Angeles county, within the boundaries of Los Angeles City oil field. Our records indicate there are five known oil and gas wells located within the project boundary as identified in the application. The proposed project is a 60-unit, 6 story apartment building with 2 level subterranean parking garage in Downtown Los Angeles on undeveloped land. Division Reference Number: 5531 Project Name: Colton Apartments December 19, 2018 Page 2 of 5 The wells listed below are not abandoned to current Division requirements as prescribed by law, and based upon information provided, are projected to be built over or have future access impeded. The Division expects these wells to be abandoned or reabandoned in compliance with current Division requirements prior to development. Well Manley Energy Resources, LLC. MOC 6 (03719034) Status The record review process shows that the subject well is not abandoned consistent with current PRC and CCR as of December 18, 2018. Based on well records: 1. Upper hydrocarbon zone isolation plug is inadequate (CCR § 1723.1). 2. Hydrocarbon zone isolation plug is not present (CCR § 1723.1). Note: Well reported not leaking on 9/3/2004. Manley Oil Co. No. 5 (03725909) The record review process shows that the subject well is not abandoned consistent with current PRC and CCR as of December 18, 2018. Based on well records: 1. The well is an idle well. 2. Surface plug is not present (CCR § 1723.5). 3. Base of freshwater isolation plug is not present (CCR § 1723.2). 4. Upper hydrocarbon zone isolation plug is not present (CCR § 1723.1). 5. Hydrocarbon zone isolation plug is not present (CCR § 1723.1). Note: No well leak test reported. Manley Oil Co. No. 6A (03725901) The record review process shows that the subject well is not abandoned consistent with current PRC and CCR as of December 18, 2018. Based on well records: 1. The well is a buried-idle well. 2. Surface plug is not present (CCR § 1723.5). 3. Base of freshwater isolation plug is not present (CCR § 1723.2). 4. Upper hydrocarbon zone isolation plug is not present (CCR § 1723.1). 5. Hydrocarbon zone isolation plug is not present (CCR § 1723.1). Note: No well leak test reported. Division Reference Number: 5531 Project Name: Colton Apartments December 19, 2018 Page 3 of 5 Manley Oil Co. No. 7 (03725905) The record review process shows that the subject well is not abandoned consistent with current PRC and CCR as of December 18, 2018. Based on well records: 1. The well is a buried-idle well. 2. Surface plug is not present (CCR § 1723.5). 3. Base of freshwater isolation plug is not present (CCR § 1723.2). 4. Upper hydrocarbon zone isolation plug is not present (CCR § 1723.1). 5. Hydrocarbon zone isolation plug is not present (CCR § 1723.1). Note: No well leak test reported. Manley Oil Co. No. 8 (03725903) The record review process shows that the subject well is not abandoned consistent with current PRC and CCR as of December 18, 2018. Based on well records: 1. The well is a buried-idle well. 2. Surface plug is not present (CCR § 1723.5). 3. Base of freshwater isolation plug is not present (CCR § 1723.2). 4. Upper hydrocarbon zone isolation plug is not present (CCR § 1723.1). 5. Hydrocarbon zone isolation plug is not present (CCR § 1723.1). Note: No well leak test reported. The Division categorically advises against building over, or in any way impeding access to, oil, gas, or geothermal wells. Impeding access to a well could result in the need to remove any structure or obstacle that prevents or impedes access including, but not limited to, buildings, housing, fencing, landscaping, trees, pools, patios, sidewalks, roadways, and decking. Maintaining sufficient access is considered the ability for a well servicing unit and associated necessary equipment to reach a well from a public street or access way, solely over the parcel on which the well is located. A well servicing unit, and any necessary equipment, should be able to pass unimpeded along and over the route, and should be able to access the well without disturbing the integrity of surrounding infrastructure. There are no guarantees a well abandoned in compliance with current Division requirements will not start leaking 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. The Division acknowledges wells plugged and abandoned to the most current standards have a lower probability of leaking in the future, however there is no guarantee that such abandonments will not leak. Division Reference Number: 5531 Project Name: Colton Apartments December 19, 2018 Page 4 of 5 The Division advises that all wells identified on the development parcel prior to, or during, development activities be tested for liquid and gas leakage. Surveyed locations should be provided to the Division in Latitude and Longitude, NAD 83 decimal format. The Division expects any wells found leaking to be reported to it immediately. Failure to plug and reabandon a well may result in enforcement action, including an order to perform reabandonment well work, pursuant to PRC § 3208.1, and 3224. PRC § 3208.1 gives the Division the authority to order or permit the re-abandonment of any well where it has reason to question the integrity of the previous abandonment, or if the well is not accessible or visible. Responsibility for re-abandonment costs may be affected by the choices made by the local permitting agency, property owner, and/or developer in considering the general advice set forth in this letter. The PRC continues to define the person or entity responsible for reabandonment as: 1. The property owner - If the well was plugged and abandoned in conformance with Division requirements at the time of plugging and abandonment, and in its current condition does not pose an immediate danger to life, health, and property, but requires additional work solely because the owner of the property on which the well is located proposes construction on the property that would prevent or impede access to the well for purposes of remedying a currently perceived future problem, then the owner of the property on which the well is located shall obtain all rights necessary to reabandon the well and be responsible for the reabandonment. 2. The person or entity causing construction over or near the well - If the well was plugged and abandoned in conformance with Division requirements at the time of plugging and abandonment, and the property owner, developer, or local agency permitting the construction failed either to obtain an opinion from the supervisor or district deputy as to whether the previously abandoned well is required to be reabandoned, or to follow the advice of the supervisor or district deputy not to undertake the construction, then the person or entity causing the construction over or near the well shall obtain all rights necessary to reabandon the well and be responsible for the reabandonment. 3. The party or parties responsible for disturbing the integrity of the abandonment - If the well was plugged and abandoned in conformance with Division requirements at the time of plugging and abandonment, and after that time someone other than the operator or an affiliate of the operator disturbed the integrity of the abandonment in the course of developing the property, then the party or parties responsible for disturbing the integrity of the abandonment shall be responsible for the reabandonment. The statutes and regulations related to oil, gas, and geothermal resources can be found here: www.conservation.ca.gov/dog/Documents/11.16.18_DOGGR-SR.PDF. No well work may be performed on any oil, gas, or geothermal well without written approval from the Division. Well work requiring written approval includes, but is not limited to, mitigating leaking gas or other fluids from abandoned wells, modifications to well casings, and/or any other abandonment or re-abandonment work. The Division also regulates the top of a plugged and abandoned well’s minimum and maximum depth below final grade. CCR §1723.5 states well casings shall be cut off at least 5 feet but no more than 10 feet below grade. If any well needs to be lowered or raised (i.e. Division Reference Number: 5531 Project Name: Colton Apartments December 19, 2018 Page 5 of 5 casing cut down or casing riser added) to meet this regulation, a permit from the Division is required before work can start. The Division makes the following additional recommendations to the local permitting agency, property owner, and developer: 1. To ensure that present and future property owners are aware of (a) the existence of all wells located on the property, and (b) potentially significant issues associated with any improvements near oil or gas wells, the Division recommends that information regarding the above identified well(s), and any other pertinent information obtained after the issuance of this letter, be communicated to the appropriate county recorder for inclusion in the title information of the subject real property. 2. The Division recommends that any soil containing hydrocarbons be disposed of in accordance with local, state, and federal laws. Please notify the appropriate authorities if soil containing significant amounts of hydrocarbons is discovered during development. As indicated in PRC § 3106, the Division has jurisdictional authority over the drilling, operation, maintenance, and abandonment of oil, gas, and geothermal wells, and attendant facilities, to prevent, as far as possible, damage to life, health, property, and natural resources, damage to underground oil, gas, and geothermal deposits, and damage to underground and surface waters suitable for irrigation or domestic purposes. In addition to the Division’s authority to order work on wells pursuant to PRC §§ 3208.1 and 3224, it has authority to issue civil and criminal penalties under PRC §§ 3236, 3236.5, and 3359 for violations within the Division’s jurisdictional authority. The Division does not regulate grading, excavations, or other land use issues. If during development activities, any wells are encountered that were not part of this review, the Division’s construction site well review engineer in the Cypress district office is to be notified immediately, and an amended site plan with well casing diagrams for Division review shall be filed. After appropriate review, the District office will send a follow-up well evaluation letter to the property owner, applicant, and local permitting agency. Should you have any questions, please contact me at (714) 816-6847 or via email at dogdist1@conservation.ca.gov. Sincerely, Digitally signed by Grace Brandt DN: cn=Grace Brandt, o=DOGGR, ou=Construction Site Well Review, email=grace.brandt@conservation.ca.gov, c=US Date: 2018.12.19 10:50:36 -08'00' Grace Brandt Construction Site Well Review Engineer cc: Uduak-Joe Ntuk, City of Los Angeles Petroleum Administrator uduak.ntuk@lacity.org CSWR File Well File EWZREQQJQ . - - gig/wowNEW PROPERTY LIN (POST DEDICATION .Colton 1 LINEOF RESIDENTIAL - .- FOOTPRINT LINE OF BASEMENT - I __G:olton 2 3372596315 Colton Street Site Map 1315 1323 W. Colton St. Los Angeles, CA 90026 Legend Approx Property Boundary Approx Excavation Boundary T-5 Approx Well Location; visible .619. Unknown Stan?s, FIGURE 4 Plugged Mbandoned Unknown Location 0 Project Number:347018 Su?de Sample Location -.- Colton 2