my comment to cogcc financial assurances rulemaking hearing january 20, 2022

Good evening, Commissioners

My name is Edward Behan, and I am a resident of Fort Collins, Colorado. I am here to express my concern about proposals for financial assurance requirements to be exercised on oil and gas operations in Colorado.

I think it is very important to require sufficient bonding from an oil and gas operator to cover the costs of plugging a well at the end of its service life, and to restore the land upon which it was operated. This is a concern to me whether it is a new drilling operation, or if a company is taking over an existing site for further exploitation. I am also seriously concerned about those wells that are simply abandoned by some operators if they have financial difficulties. It is clear that some outfits are more meticulous about their responsibility for these costs than others. It is not right that the State of Colorado and its taxpayers should pick up the bill for reclaiming any drilling site that has been abandoned without proper closure and restoration. Nor would that be fair to any operator who does execute their final operations responsibly.

Before my wife and I moved back to Colorado in 2016, we lived for fifteen years in the Gulf Coast region of Texas and Louisiana. The last eight years in Baton Rouge were particularly instructive. We were there at the time of the BP oil spill, and in the aftermath of that tragic accident, there was much discussion about other elements of how the industry had been acting in that area for decades. Plugged and abandoned wells both onshore and offshore, that were supposedly sealed, were leaking. Pipeline tracks and canals that had serviced the drilling operations throughout Louisiana’s fragile wetlands had never been restored to their original condition, and that damage has contributed to the loss of coastal wetlands. The regulatory agencies and the legislature seemingly had no interest in holding the oil companies to the requirements of the agreements that they had signed regarding restoration of the land.

Colorado has a different sort of environment, but one that is equally fragile. The effects of improperly closed out drilling sites will have impact on our air and water quality. The Commission has a unique and weighty responsibility in this, especially under your newer mandate to protect the health, safety and environment in supervising the oil and gas industry.

 I ask that you pay attention to those calling for full cost bonding of individual wells. Those costs may vary, but they need to be calculated to ensure that we taxpayers are not subsidizing their operations, and that proper care is taken of our precious Western environment. Thank you.

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