some coal in your christmas stocking: the potential of O&G well abandonment in colorado

As 2021 draws to a close, I wanted to add one last post to the blog here about an issue concerning the oil and gas industry that bears remembering for its possible effect on all citizens of Colorado: the potential of O&G well abandonment in Colorado, and the possibility of state taxpayers having to pay for it — instead of the O&G industry.

That possibility was made all too clear in an interview that the radio station KUNC did on November 19, 2021 with Andrew Forkes-Gudmunson, who is the deputy director of LOGIC, the League of Oil and Gas Impacted Coloradoans. This was part of the station’s excellent news show about local issues, the Colorado Edition that airs at 6:30pm. You can still listen to the interview on their website at

To get to the chase, after all of the state data was analyzed by LOGIC, using data from the COGCC website, LOGIC came to the conclusion that about 70 per cent of the active wells in the state produce less than one barrel of oil a day, and that the majority of those wells are owned by small operators, not by a major oil company. It is within reason to also infer that many of these low producing wells are never going to increase their production since they are “played out”; and then to conclude that the operators have not yet abandoned them because of the cost of doing so. When a well operator tells the COGCC that they are going to abandon a well, the well needs to be plugged before the operator can abandon it, i.e. cease to have any legal connection or obligation to it. And to plug a well carries a certain cost. Though it basically means pouring cement down the oil bore and letting it dry, it can be more or less expensive depending on the type of well, how deep it is, and other environmental factors that might entail additional measures.

Long story short, looking at the data carefully seems to indicate that the COGCC has allowed a lot of small operators to keep their played out wells in the “active” category simply because the operators don’t want to declare them to be in need of being plugged before abandoning them. This is, unfortunately, the sad end of allowing an industry to effectively self-regulate itself, going back over seven decades.

Thus, when looking at a range of estimates for plugging a well, there is an all-too-real possibility of the total price tag for plugging all these wells that should have been abandoned before now coming in at something like $7 BILLION! To put that figure in perspective, the 2019-20 state budget was about $32.5 billion; or that for 2021 state population, would be about $1,100 for every man, woman and child in the state.

It is because of this possibility that the COGCC is holding its final phase of rulemaking for SB-181 via public hearings about Financial Assurance during January and February. “Financial Assurance” basically means holding the O&G industry to account for the cost of plugging abandoned wells. See this other blog post for the calendar of events about that, and if you would like to express your opinion. The COGCC would love to hear from you! 🙂

Please keep this in mind as we enter 2022…Happy New Year, everybody!

Financial Assurance Hearings at the COGCC – A CRUCIAL STEP

The Financial Assurances rulings coming up in January and February of 2022 represent a crucial crossroads in statewide efforts to require responsible behavior from oil and gas operators. It’s not really too complex. What we are asking of the industry is the same basic life lesson that we all learned as children: if you make a mess, you clean it up! Unfortunately, the draft proposal, provided by COGCC staff to the commissioners, takes this simple idea and twists into a byzantine labyrinth that will provide O&G operators multiple options for gaming the system, leaving clean-up to the tax-payer.

Therefore, we are asking the COGCC to approve regulations that would require full cost bonding on all new wells, all transferred wells, and on all existing wells over a reasonable timeline. Wells on BLM land should be included in all of the above. And bonding should cover both plugging and reclamation costs.


January 20-21
1. Financial Assurance Rulemaking, Docket No. 210600097
1. Staff Presentation
2. Public Comment

January 25-28
1. Party Presentations Financial Assurance Rulemaking, Docket No. 210600097
2. Consent Agenda will be heard on 1/26

February 2-3
1. Party Final Presentations Financial Assurance Rulemaking, Docket No. 210600097
2. Consent Agenda will be heard on 2/2

February 7
1. Commissioner Deliberations Financial Assurance Rulemaking, Docket No. 210600097

February 9
1. Commissioner Comments
2. Public Comment
3. Consent Agenda

February 16 – Evening Hearing, starts at 6pm
1. Commissioner Comments
2. Public Comment

February 23
1. Commissioner Comments
2. Public Comment
(From the COGCC website under Tentative Commission Hearing Agendas.


Sign-up forms for the February meetings are not yet active, but there is plenty of time to begin preparing a statement. Remember, the outcome of this ruling will have significant consequences for Colorado into the foreseeable future. Our current system encourages operators to leave low producing wells sitting in the fields where they continue to emit methane and other toxins into the air. According to a Nov. 26 article in the Colorado Sun, “out of the approximately 52,000 wells on the books at the Colorado Oil and Gas Conservation Commission, 36,930 produce less than the equivalent of 15 barrels of oil a day. Of those, 17,285 produce less than 1 barrel.” These low producing wells amount to 71% of the wells in Colorado. All wells will eventually have to be plugged abandoned. If the operators don’t pay for it, then those costs will be left to the state.

Below is an excerpt from the comment I made in the Nov. 9, 2021 meeting of the COGCC:

I would like to begin by reading a quote from a previous COGCC meeting in which the following statement was made by a commissioner:

“We should not be held hostage to operators who can’t afford to do business in the state. If they can’t discharge their responsibilities to maintain their wells, they shouldn’t be approved to operate here. There should be some element of financial responsibility that’s required.”

I couldn’t agree more.
That meeting took place on March 19, 2018. Three and a half years ago. Three and a half years have gone by, and although SB-181 has given us a new legal framework which was not available to commissioners at that time, we’re still being “held hostage to operators who can’t afford to do business in the state.” Meanwhile, the COGCC continues to approve applications for more wells…and more and more operators — who have no financial incentive to do otherwise — and allow wells that should be properly plugged to spew emissions into the atmosphere. We’re talking about tens of thousands of low-producing wells–with little to no profitability…little to no contribution to energy demand — adding nitrous oxides, methane and other pollutants to the atmosphere…day after day after day.

Three and a half years have passed and we are still being held hostage.
All this within the context of a global climate emergency, in which Colorado plays a significant role. A climate emergency in which we have very little time to make the bold changes that are needed.

I ask that you require full cost bonding—full cost bonding on all new wells, all transferred wells, and on all existing wells over a reasonable timeline—if you will do that, then three and a half years from now we’ll be in a much better place.


The following is an email I sent on 12/14/2021 in response to an EPA Grant Competition offered to local communities to improve their air quality monitoring capabilities; I found out about it on the listserv for CCLC ( Colorado Coalition for a Livable Climate). Ms Archuleta is Cassie Archuleta, the head of the Air Quality Department in Fort Collins:

Dear Larimer County Commissioners and Ms. Archuleta: 

I would like to bring to your attention, if you were not already aware,  of this EPA Notification of a grant competition for $20 million for Community Air Pollution Monitoring; please find attached. The public meeting for it will be on January 11, 2022. It is targeted at “communities with health outcome disparities.” 

I think if the data on respiratory illnesses in Larimer County were summarized, I believe it would have communities that qualify. The bad ozone conditions here in the summer must certainly be having its effect. Just publishing that data would be useful in and of itself.

If the state air quality regulators were serious about discovering the sources of what’s causing all this ozone — instead of just installing ozone monitors to tell us how bad it is, and what days to stay indoors — they would have installed an array of BoulderAIR monitors from Wellington to Pueblo by now. Instead, the cities and counties have had to take on this job in piecemeal fashion, as you well know. It is no way to manage a regional air pollution issue.

If Larimer County were to coordinate with the five other BoulderAIR monitoring stations from Boulder to Erie, we would be able to find the real causes of our air pollution. And then, and only then, will we be able to start to managing this pollution problem with data driven results. 
I hope some staff can be directed to evaluate this opportunity; and hopefully take advantage of it. 

Best regards,
Rick Casey 

PS — This is the positive response from Commissioners Kefalas and Stephens in reply:

northeRn larimer county gets noticed…FINALLY

The residents who live in the vicinity of the oil and gas wells in northern Larimer County — such as the Hearthfire neighborhood and County Road 13 — know all too well all about leaking tanks, foul odors and unsafe air pollution; and finally this attracted some media attention. The Larimer Alliance is thankful for this story in the Coloradodoan that was published December 6, 2021:

Oil company hasn’t replaced leaking tanks near Fort Collins despite months of complaints

It was certainly a great effort by the reporter Jacy Marmaduke, the people she interviewed, and especially the videographic work by Earthworks’ Andrew Klooster.

As Ms Marmaduke accurately described, existing oil and gas wells and transmission facilities have fallen through the cracks of industry regulations. Even though SB-181, the 2019 law that dramatically reformed how oil and gas is regulated, and empowered local city and county authorities, in theory, to write their own regulations about oil and gas operations, these have only applied to new wells — leaving existing operations to continue to be regulated by the state. This has come as quite the disappointment of local residents who were hoping for some help and relief from the continuing air pollution.

As we’ve come to find out, when existing tanks start leaking, the state regulators have been slow to react; as the hapless residents having to endure the foul air have found out. It has taken months of effort by local residents complaining to the authorities responsible, the Colorado Department of Public Health and the Environment, to get them to inspect the sites.

Unfortunately, it will likely take many more months of efforts by citizens calling out for redress to fix the problem. Please show your support by either commenting here, sending your thanks to the Coloradoan for the above story, or contacting your city and county offices to express your concerns.