Environmental

Current drilling operations are now fueled predominantly by cleaner burning natural gas rather than diesel fuel.	Air We began the implementation of dual-fuel and bi-fuel technologies in our development program starting in 2019 with dual-fuel drilling rigs. In 2022 we deployed our first natural gas powered frac fleet and in 2023 we deployed our first dual-fuel frac fleet. CO2e reductions as high as 20% have been realized with these innovative technologies. Recognizing that natural gas pneumatic devices and pumps have substantial contributions to methane emissions, we began implementing the practice of installing instrument air supply at our newly constructed sites, effectively eliminating those associated methane emissions at new sources all together. We have replaced natural gas driven chemical pumps with solar pumps at approximately 20% of our legacy well sites since 2021. We have an ongoing initiative to continue replacements as natural gas pumps reach the end of their service life. Comstock has been actively engaged in an LDAR program since 2016, when NSPS OOOOa was published as a mandate for certain sites. We have taken that a step further and implemented the LDAR program at all of our operated sites. Additionally, we’ve implemented aircraft flyover surveys to complement our optical gas imaging (OGI) surveys and to include our below ground pipeline assets. As part of our “green completion” practices, we ensure that pipeline infrastructure is installed ahead of completing our wells which eliminates the need to flare for well testing. As a member of The Environmental Partnership, Comstock teams up with other industry-leading oil & gas companies who share a commitment to continuously improve the industry’s environmental performance through innovation and best practices. Comstock has achieved independent certification for its operated gas production under the MiQ Standard for managing methane emissions. The MiQ Standard grades production based on how well an operator deploys integrated technologies to detect, measure, and abate emissions while also including a detailed assessment of the company practices and policies to abate future methane emissions.

Comstock is committed to protecting groundwater sources	Water Comstock is committed to sound engineering practices and recognized industry standards to ensure wellbore integrity is suitable to protect groundwater sources. Casing designs follow API standards to ensure mechanical integrity during the drilling, completion, and long-term production life of the well. Multiple casing strings, corrosion inhibiting treatments, and packer/tubing isolations are often used to manage and maintain wellbore integrity on a regular basis. Our field operators regularly monitor casing pressures to ensure proper and safe operation of our wells. Before drilling operations take place, we perform baseline water well sampling on our rig supply wells utilizing an approved, third-party company. To protect surface and ground water sources, Comstock has implemented the use of closed loop systems during operations involving oil based drilling fluids.
	Waste Oil based cuttings generated during the drilling process are diverted from a landfill to treating and recycling facilities where practicable. This has resulted in millions of gallons of recycled drilling fluid that would otherwise end up in a landfill.
	Emergency Response Comstock trains our employees on an annual basis to prepare them for emergency spill situations. We also maintain agreements with 3rd party emergency response contractors to ensure resources and manpower are available on a “turn-key” basis. Emergency shut down systems are utilized to quickly and remotely shut down operations in the event of a release. SCADA systems allow our operators to remotely monitor onsite conditions, such as pressures, tank levels, flow rates, etc., that may indicate upset conditions at facilities.
New sites undergo extensive wetland, endangered species, cultural and historical resource reviews	Land Wherever possible, Comstock employs multi-well locations and extends the lateral lengths of wells to minimize our above-ground footprint and reduce rig move traffic. This reduction in traffic means making the roads safer, using less fuel for transports, and less noise and activity in communities. We work closely with 3rd party subject matter experts who perform extensive reviews for wetlands, threatened/endangered species and historical cultural resources before construction can begin on a new site. We strive for timely pit closure in efforts to quickly reduce our long-term pad footprint.