Public Input of Virginia Palacios Before the Railroad Commission Open MeetingTestimonies

Our staff has been reading the Draft Monitoring And Enforcement Plan for FY 2024, and we’re happy to see that some of the new goals in the plan this year appear intended to respond to the comments we’ve made in prior years. Thank you for listening and working to communicate with the public. We will be providing written comments by the deadline on May 26th.

Last week, Commission Shift held a virtual meeting for members of the public to explain the RRC’s Draft Monitoring and Enforcement Plan for FY 2024. We gave attendees time to discuss their impressions of the plan and their experiences with the RRC’s enforcement process during the meeting. We will summarize the feedback we heard in our written comments.

One area we have some questions about is the section that explains barred operators. The plan explains that when operators are noncompliant with the inactive wells requirements, “the Commission suspends the authority of the company, the officers listed on the company’s organization report, and any other company regulated by the Commission that has common officers listed on its organization report from conducting Commission regulated activities. Noncompliant officers are barred from renewal for seven years. Non-compliant entities are barred indefinitely.”

We analyzed the list of inactive wells posted on the RRC’s website and current as of February 9, 2022. These are NOT supposed to include orphaned wells, only wells that have been inactive for more than 12 months. From the inactive wells list, we noted which operators were also on the RRC’s barred operator’s list, which is current as of May 5, 2021.

Just over 5,300 wells (5%) on the inactive wells list are attributed to these barred operators. Most of the operators appear to have been on the barred list for several years. Most of the wells (3,306) are listed as having had a problem with their H-15 fluid level test or mechanical integrity test.

I have a few questions about this:

  1. What is the commission’s process for moving wells from the inactive wells list to the orphaned wells list?
  2. Should inactive wells of barred operators end up on the orphaned wells list? If not, why not?
  3. Are barred operators expected to plug their inactive wells?

Summary analysis of inactive wells attributed to barred operators

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