Colorado Coalition for a Livable Climate

Advocating strategies for reducing greenhouse gas emissions to a level supportive of a livable climate.

Colorado Candidate Questionnaire on Climate and Clean Energy

Posted on June 6, 2022

Ballots are now in the mail for Colorado’s 2022 primary election, and the last day to vote is June 28th.  The CCLC recently asked Colorado Gubernatorial and General Assembly candidates where they stand on issues related to climate protection and clean energy.  A total of 56 candidates who are on the ballot this month have responded.  We’ve posted the results, and hope they will be helpful as people make up their minds who to support in the primary election.

Click here for a link that will download an Excel file containing candidate responses to your device.  A link to find your Colorado House and Senate District is provided in that file.  Be sure to vote by June 28th!

Public Utilities Commission Filing Urging Immediate Closure of the Pueblo Unit 3 Coal Plant

Posted on May 8th, 2022

The Colorado Coalition for a Livable Climate has filed comments with the Colorado Public Utilities Commission urging the commissioners to close the Pueblo Unit 3 (“Comanche 3”) coal plant now, rather than waiting until 2031 to do so. Instead, Xcel and its ratepayers should stop wasting time and money on this mistake and start investing our time and money in resources, both demand side and supply side that will help build a truly reliable, low-carbon electrical system for Xcel’s Colorado customers.

View the filing here:

https://colivableclimate.org/wp-content/uploads/2022/05/21A-0141E-CCLC-Comments-on-Xcels-ERP-Revised-Settlement-May-6-2022.pdf

Selected Remarks Made at 2022 Earth Day Picnic, March and Rally in Denver

Posted on April 26th, 2022

The following remarks were made by Giselle Herzfeld and Kevin Cross at the Earth Day Picnic, March and Rally held at the Colorado State Capitol and the Denver Federal Reserve Building on Earth Day.

Giselle Herzfeld, 350 Colorado

If you had a choice between investing your money in destruction and pollution or investing it into a healthy and safe future, which would you choose?

American banks have been funneling our money into oil and gas projects that are contaminating our drinking water and our air, making us sick, and fueling the climate crisis. 

If only these banks had a referee that could stop them from making bad decisions.

Oh wait. Guess what? They DO! That referee is called the Federal Reserve and its job is to manage risk and avert catastrophes. But instead of doing its job, the Fed has allowed banks to fund fossil fuel companies to the tune of $1.2 trillion over the past 5 years since the Paris Agreement. 

If banks continue to fund fossil fuel projects, by 2050, we can expect $23 trillion in global economic losses as a result of the climate crisis.

Today on Earth Day, we’re mobilizing all across America to say enough is enough! Our lives matter, our health matters, our future matters. The Federal Reserve must immediately steer banks away from fossil fuels to avert climate catastrophe.

The Climate Crisis does not impact everyone equally. The painful truth is that the people who have contributed the least to the climate crisis are suffering the most from its impacts. Around the world, millions of people are being displaced from their homes every year due to natural disasters such as storms, floods, fires, droughts, and these disasters are increasing in number every year. A recent World Bank report predicts that over 200 million people are likely to migrate over the next three decades because of extreme weather events or environmental degradation. Here in Colorado, the Marshall fire destroyed over a thousand homes and displaced thousands of people. Today is the 18th consecutive day with a Red Flag Warning in Colorado. This is unprecedented, especially in April in what is meant to be one of the wettest seasons of the year. 

We are at a crucial point in history where we can still keep global warming under 1.5 degrees census and avert the worst of the climate catastrophe, but it will take a massive overhaul of the institutions that are driving this crisis to a breaking point. 

Thank you for joining me today, as we call on the Federal Reserve to treat the climate crisis as the emergency that it is, and to spend our money on a just transition and green new deal! 

Kevin Cross, Colorado Coalition for a Livable Climate

Props to Colorado Governors and to our legislature, who first acknowledged that we have a problem and set climate goals way back in 2008.  That’s when Governor Bill Ritter set a goal of 20% greenhouse gas pollution reductions by 2020 compared to 2005 levels.

Alas, we didn’t do so well on achieving that goal.  In 2019 – the last year for which data is available – Colorado’s greenhouse gas pollution was down only 9% compared to 2005 – about half of the reductions that Governor Ritter had committed to.

We can take comfort from the fact that our legislature and governor have approved numerous bills related to protecting the climate since 2019.  Yet much more needs to be done if we are to actually achieve the new goals adopted by our state government for 2025 and 2030.

That, of course, is where all of us come in.  Politicians at all levels are easily distracted by immediate crises, cash and threats from the fossil fuel industry, and media that by and large do not take the climate crisis as seriously as they should.  Here are some things you can do:

  1. Read Jan Rose’s weekly legislative updates – which are posted prominently on the Colorado Coalition for a Livable Climate website – and communicate your support for key climate bills to your legislators regularly.
  2. Tell your utility providers and the PUC that you want them to close coal plants now and prepare to transition away from using fracked gas to run power plants and heat buildings asap.
  3. Tell the COGCC that we need to end fossil fuel extraction in our state by 2030.
  4. Finally, tell your friends in other states what you’re doing, and encourage them to do similar things where they live.

We don’t have another decade to lose.  Incremental change won’t preserve a livable climate for our children or for ourselves.  We all need to think and act boldly to protect the climate.

Tell the Xcel Energy Board of Directors and Governor Polis to Close the Pueblo 3 Coal Plant Now!

Please send a short note to the Xcel Board of Directors and Governor Polis telling them to close the Unit 3 coal plant in Pueblo now.  Short and very short messages are fine.  You can either just send the message in all caps immediately below or use some of the talking points below that to add to your message.  E-addresses appear below the talking points.

CLOSE THE UNIT 3 COAL PLANT IN PUEBLO –NOW!

(This is the coal plant that Xcel insensitively calls “Comanche 3”–never mind that the Comanche people almost certainly don’t want a coal plant named after them!) 

  • Pueblo Unit 3 (PU3) is Colorado’s single largest source of carbon dioxide
  • Climate change is real and serious (Perhaps mention the IPCC report, the Southwest’s worst drought in over 1000 years, the Marshall Fire, etc etc).
  • The PU3 coal plant is down now–it doesn’t make sense to fix a coal plant given the seriousness of the climate crisis–just retire it now!
  • It doesn’t make sense to rely on an extremely unreliable coal plant for reliability reasons (Search Comanche 3 Unreliable for lots of stories…) 
  • It is BEYOND UNCONSCIONABLE to profit from a coal plant in the 21st century (Xcel seems to be largely driven by a desire to harvest as much profit as it can from their imprudent decision to build the Pueblo Unit 3 coal plant!!) 

Again–Short and very short messages are fine–we just need Xcel and Governor Polis to know that we are watching and don’t want this coal plant on our conscience!! 

Here are the e-addresses:

1) Xcel Board of Directors: boardofdirectors@xcelenergy.com

2) CC Governor Polis (who should use his position to ask Xcel to close PU3): Governorpolis@state.co.us

3) BCC Leslie Glustrom, who will pass your letters on to the other organizers of this campaign.

Rally for a Coal-Free Colorado – Let’s Retire Colorado’s Biggest Climate Polluter!

Any day now, the Colorado Public Utilities Commission will decide to approve or reject Xcel Energy’s latest proposal to burn coal at Colorado’s biggest coal plant for 12 more years! Colorado communities can’t afford 12 more years of coal pollution. Please join us in front of Xcel Energy’s Colorado Headquarters to tell Xcel Energy we need a coal-free Colorado ASAP!

What: Noon rally at Xcel HQ, speakers 12:30-1pm, followed by canvassing around Coors Field
Where: Outside Xcel Energy Headquarters, 1800 Larimer St., Denver
When: Rally 12-1pm, canvass to follow at 1pm, Friday, April 8th, 2022
Who: YOU! Wear red and drop in for any part of this important action.
RSVP: on Facebook or here on Mobilize – https://www.mobilize.us/climatactionco/event/450153/

Facebook Event page: https://www.facebook.com/events/394757435412900/

Rally flyer: https://tinyurl.com/CoalFreeCO

Urge President Biden to Invoke the Defense Production Act to Ramp up the Deployment of Renewable Energy

The war in Ukraine is a stark illustration of how fossil fuels directly enable global conflict and threaten democracy in addition to driving the climate emergency. Enormous earnings from oil and gas exports provided President Putin with the hard currency needed to fuel his invasion of Ukraine. President Biden took a necessary first step by halting imports of Russian oil, gas, and coal — but lasting peace and global stability demand bolder climate leadership.  

That’s why Build Back Fossil Free – alongside 200+ climate, Indigenous, social justice, religious, foreign policy, and progressive groups – is urging the Biden administration to continue to resist bad faith attempts to lock in future fossil fuel exploitation and dependence by invoking the Defense Production Act (DPA) to ramp up the deployment of renewable energy and stop existing fossil fuel infrastructure to ensure a just transition off fossil fuels. 

Amidst the backdrop of the latest dire Intergovernmental Panel on Climate Change (IPCC) report, the need to transition off of fossil fuels has never been more urgent. This is a critical moment to stand up to the false narrative being spread by the fossil fuel industry that we need to increase oil and gas production in response to surging energy prices, and demand that the President instead lead a just transition off fossil fuels once and for all. 

Biden can deploy his executive powers to weaken the geopolitical power of fossil fuels, address the climate emergency, and prevent further mass suffering by invoking the DPA to produce alternatives to fossil fuels, fight the climate emergency, combat Putin’s stranglehold on the world’s energy economy, and support the transition to a renewable and just economy.

For a list of actions you can take to suit your schedule, see this document.

No, Natural Gas Should Not be Part of our Energy Mix

Published in the Colorado Sun on March 10th, 2022

In their op-ed titled “Natural gas should remain a key option in Colorado’s clean-energy mix,” the authors would have us believe that, long-term, natural gas should be part of the mix for our state’s goals for ending the use of fossil fuels.

Let’s be clear: When we have ended the use of fossil fuels, natural gas must be just another old, discarded technology, replaced by newer, clean electricity. Natural gas is not clean, nor should it remain part of our energy mix.

First, natural gas, when it leaks (it is a leaky substance), sends methane — a prime precursor in ozone pollution — into the atmosphere. Ozone shortens people’s lives, causes breathing problems, and low birth weight.

Then, natural gas is a one-two punch of global warming gases. One: As methane it warms the atmosphere 84-86 times faster than carbon dioxide over a 20-year period. Two: When we burn natural gas, it emits carbon dioxide, the global warming gas that lasts for centuries.

The accumulations of global warming gases from our seemingly small contributions add up. They threaten our Colorado water resources, our ski slopes, our visible sky during fire seasons, and more. If we let it go, the resulting climate chaos will wreck crop yields and cripple the widespread civilization our families enjoy.

Natural gas is convenient, it works when we need it, but it is environmental poison. We can’t continue to use it, especially when we have good alternatives.

Evolved Energy, Gridlab, the National Resources Defense Council, and the Sierra Club comprehensively reported on what it will take to meet our state’s climate goals. On the subject of buildings, both residential and commercial, they say this:

One pathway to meeting the climate goals would require at least 55 percent of new homes to be all electric by 2025 and all new homes to be all electric by 2030 or soon thereafter. In this scenario, 2 to 3 percent of non-electric space heaters and 4 to 5 percent of non-electric water heaters in existing homes must be replaced with electric heat pumps each year [emphasis added].

Commercial buildings must follow a similar trajectory… Transformative electrification of stocks of space heaters and water heaters will take time, and the state must accelerate adoption immediately.

This necessity to replace equipment means that we ought to look at our stock of gas appliances as old, dirty, and temporary.

We can’t afford to change everything out at once. But given that the Front Range has a terrible ozone problem, and given that the climate has already changed and we throughout the state have tasted the smoke filling our lungs, we should eagerly adopt new technologies that allow us to lead better lives.

For individuals, we at Colorado Coalition for a Livable Climate urge readers of means to plan to replace their gas stoves, dryers, water heaters, and furnaces with electric. It may sometimes cost more upfront, but spending now to halt the advance of climate change will be less expensive than repairing the consequences of just letting it go. As more people adopt, costs will decrease, allowing for more people, including people with lesser means, to also adopt.

We also ask developers to simply stop laying gas lines to new construction. The cheapest way to convert to electric is to start with electric.

On a community level, we call upon local governments to change their building codes to ban the installation of new natural-gas burning appliances. We ask the state to set a date, as soon as practicable, to outlaw the sale of natural gas appliances.

And we ask each person to acknowledge that we are indeed in a crisis. With this acknowledgement, we ask the taxpayers to fund the transition to electric appliances for those who cannot afford to do so on their own.

The folks of the fossil fuel industry would have us delay, in part, we assume, to maintain their profits for as long as possible. But Colorado’s climate has changed now. It is causing pain now. And will only get terribly worse if we let it go. We need to act now.

Jeff Neuman-Lee, of Denver, is Legislative Team co-chair for Together Colorado‘s Climate Justice Committee.

Action Alert: Tell the COGCC to Make the Oil and Gas Industry Pay to Clean up After Itself!

Hello fellow Coloradans (or the 99.9% asked to pay for the mess of billionaires and multi-millionaires):

How’d you like to get a bill in the near future for $7.7 billion? That’s what it will cost to close the 52,000 unplugged oil and gas wells in this state. Why are you getting the bill you ask? Well, because, as Commissioner Bill Gonzalez said, drillers have better things to do with their money than clean up after themselves or give the state a deposit for this. Yep, the Polis administration and the Colorado Oil and Gas Conservation Commission (COGCC) are making you their sugar daddy, so they can pass on the costs of the 15 operators (including Exxon and Chevron) that produce 90% of the oil and gas in Colorado and the “small” operators producing the remainder, still making $7 million/year and up, as their representative shared.

You aren’t alone in recalling that the legislature passed a law several years ago that was supposed to protect the people and the environment with regard to all oil and gas activities. The legislature passed SB 181 three years ago. But the Polis administration has taken the side of the oily millionaires and billionaires and decided to not ask Chevron and all its smaller cousins for full bonding of all wells, yet another side step in this administration’s reluctance to carry out the expressed intent of SB 181 and HB1261 from spring 2019.

Holy Toledo, is there anything else I should know? Well, please be sitting down when we tell you that there are another 70,000 closed wells out there, some actually buried under people’s homes that belong to you or soon will. Many were capped decades ago before there were any engineering standards for well closings. Some of them leak. More will leak as the present seal breaks down over time. They are a gift to you from the oil industry. Research shows that even properly sealed wells crack within 20-30 years. Concrete cracks. Fumes are released. Each well bore is likely to require checking and maintenance forever. You’ve got to be kidding. What can I do? Contact the COGCC this weekend:

jeff.robbins@state.co.us;

bill.gonzalez@state.co.us;

karin.mcgowan@state.co.us;

john.messner@state.co.us;

priya.nanjappa@state.co.us;

scott.cuthbertson@state.co.us;

julie.murphy@state.co.us.

Please tell them we need full cost bonding for all wells now. More info is available at https://bit.ly/FullCostBondingIsEssential.

2022 State Climate, Energy, and Environmental Legislation

Following is the final bill summary of the 2022 State Legislature for the session ending May 11: 

Last year we had 59 climate bills, this year we had 41.  The following is the status of each bill at the end of the session:

Wildfire/Disaster bills:

  • HB22-1007 | Assistance Landowner Wildfire Mitigation – Passed ; HB22-1011 | Wildfire Mitigation Incentives For Local Governments – Passed ; HB22-1012 | Wildfire Mitigation And Recovery – Passed ;SB22-007 | Increase Wildfire Risk Mitigation Outreach Efforts – Passed ;SB22-206 | Disaster Preparedness And Recovery Resources | Passed ;HB22-1225 | Sunset (Continue) Colorado Resiliency Office | Passed

What you need to know: We need a CO Resiliency Office to manage our response to disasters. These bills hand out piles of money for various prevention strategies and consolidates our responses into a single location/office. Also, we’re willing to spend millions of dollars to address the consequences of climate change but comparatively little to prevent it.

Microgrid Bills

  • HB22-1013 | Microgrids in remote/isolated/at risk communities | Passed ; HB22-1249 | Electric Grid Resilience And Reliability Roadmap | Passed

What you need to know: 1013 is a restricted implementation bill with little funding; 1249 includes microgrids in our GHGs reduction roadmap which allows for broad expansion.

Commuting Bills

  • HB22-1138 | Reduce Employee Single-Occupancy Vehicle Trips | PI’d(Postponed Indefinitely) ; HB22-1026 | Alternative Transportation Options Tax Credit – Passed

What you need to know: Business refuses to take responsibility for traffic congestion (1138) and pollution so we bribed them with a 20% tax credit.

Buildings Bills

  • HB22-1218 | EV Chargers in multi-unit Housing – VETOED ;HB22-1362 | Building Codes Reduce GHGs – Passed ; SB22-051 – Reduce Building GHGs with Heat Pumps (air and ground) & lower-carbon building materials – Passed

What you need to know: Combined with last year’s legislation, this set of bills pretty thoroughly encompasses methods for reducing buildings/materials GHGs and sets aside lots of grant funding for low-income/EJ communities. Required future buildings to be EV/solar/heat pump ready and multi-unit housing to have charging stations. Includes money to inform/educate/train builders/developers on green energy codes.

Waste Bills

  • HB22-1355 | Recycling Producer Responsibility – Passed ; HB22-1134 | Measures To Reduce Use Single-use Meal Accessories | PI’d HB22-1159 | Waste Diversion And Circular Economy Development Center | Passed

What you need to know: 1355 is considered best-in-the-nation; the proof is in the pudding (will producers pay to fund the program or just pay fines for not participating?) Also extends the life of last year’s waste diversion program and includes the ability to recycle hard-to-recycle components (electronics/building materials etc)

O&G Tax Bills

  • HB22-1391 | Modifications To Severance Tax – Passed ; SB22-026 | Oil And Gas Operator Property Tax Procedures | Passed ;  SB22-198 | Orphaned Oil And Well Enterprise – Passed

What you need to know: Just a bunch of admin-related Dept of Revenue severance tax issues required by a task force last summer. Reduces ad valorem credit (against their property tax bill) from 87% to 76%; creates a separate entity to manage the $10M/year regulated a few months ago for orphaned well management and allows us to quality for $25M this year in federal funds

O&G Reporting Bills

  • HB22-1361 | Oil And Gas Reporting – Passed ; HB22-1348 | Oversight of Fracking ChemicalsPassed

What you need to know: Compares estimated to actual emissions, volumes of O&G reported to the COGCC v the DOR; annual reporting of enforcement; reporting chemicals used in downhole operations and attestation that no PFAS is used.

PFAS

What you need to know: Includes carpets, fabric, cookware, cosmetics etc., to encompass everywhere that PFAS is currently used with a no sale requirement beginning 2024 for everything but cosmetics, which will be 2025.

Air Quality

  • SB22-193 | Air Quality Improvement Investments | Passed ; SB22-138 | Reduce Greenhouse Gas Emissions In Colorado – Lost to a Republican filibuster! ; SB22-180 | Free RTD for 30 days during Ozone Season, Passed ; SB22-082 | Geographical Area Hazard Air Pollution Rule |  PI’d ;HB22-1166 | Incentives Promote Colorado Timber Industry | Failed via filibuster compromise

What you need to know: The 2 signature bills of this session were 193 and 138, both of which had multiple components. 138 failed but will be back next year.  193 includes ~$100M for electric schoolhouses (setting us up to receive federal funding from the Infrastructure bill) and e-bikes; reducing industrial emissions (but has programs like direct air capture, CCUS, and blue hydrogen – BOO), and aerial/ground monitoring of emissions. Replacing old diesel with new diesel trucks was removed, yay. 180 is for the month of August and only for 2 years, but includes Bustang, RTD, and light rail; if it’s not successful it will be abandoned. Last September the CO Energy Office announced the mountains have become a net emitter instead of a carbon sink, so the timber bill was going to pay half the wages of new hires and 20% of their equipment cost; better to convert to biochar in a future bill. 138 had agrivoltaics, climate risk assessments, soil carbon sequestration, injection well carbon storage, and phase-out of gas mowers/blowers/trimmers (2-stroke engines); again, will be back.

All of the Above Energy Bills

  • HB22-1140 | Green Hydrogen To Meet Pollution Reduction Goals | Failed in Committee ;SB22-073 | Alternative Energy Sources (little nukes) | PI’d ; HB22-1020 | Customer Right To Use Energy (ban on the ability to ban fracked gas) | PI’d ; SB22-118 | Encourage Geothermal Energy Use – Passed ; HB22-1381 | Colorado Energy Office Geothermal Energy Grant Program – Passed 

What you need to know: The signature goal of Republicans in the area of climate change is (always) all of the above energy.  Little nukes (SMRs) will be back cuz Xcel wants one in Pueblo; Green Hydrogen must come back next year to restrict/prevent the blue hydrogen boondoggle; geothermal supports ground-source heat pumps and common-coil for subdivision-wide heat pumps, 

Utilities bills

  • HB22-1018 | Electric And Gas Utility Customer Protections | Passed ;SB22-090 | Severe Weather Notifications To Utility Customers | PI’d

What you need to know: Xcel can’t turn off power to people after 5p Friday or on weekends, but they don’t need to warn us of the next TX snowstorm/brutal heat wave which jacks up our prices.

Just Transition Bills

  • HB22-1394 | Fund Just Transition Community And Worker Supports | Passed ;HB22-1193 | Fund Just Transition Coal Workforce Programs | Passed

What you need to know: Added another $15M (total now $30M) to compensate for reduced local taxes and provides $5M for coal workers to learn new skills

Pesticide/Pollinator Bills

  • SB22-131 | Protect Health Of Pollinators And People | PI’d ;SB22-199 | Native Pollinating Insects Protection Study | Passed ; SB22-158 | Species Conservation Trust Fund Projects | Passed

What you need to know: As with last year, the chemical and ag industries successfully fought off a neonics and Roundup-style potential ban, but at least we get to study how bad they are for Colorado’s native pollinators.

A detailed summary of each bill, divided into Energy, GHGs Pollution, and Climate Impacts is available at this link.

By Jan Rose, Legislative Analyst and Spokesperson

Action Alert

Tell the COGCC to protect taxpayers from the unscrupulous Oil & Gas Industry! Testify at the COGCC “Financial Assurances” Rulemaking Hearing.

Times available are:

Thursday, January 20th 1:00 pm – 5:00 pm,

Thursday,  January 20th 6:00 pm to 8:00 pm, and 

Friday, January 21st 9:30 am to 12:00 pm  

Click here to sign up for 2 minutes of public comment

The following is a breakdown of some of the issues at stake in this Rulemaking, along with talking points you can customize for use in your testimony.  The hearing will be on Zoom, so you can testify from the comfort of your home or office. Also attached is our ‘FA Team’ Response to the latest round of Draft Rules for more context.  The points below do not include the fracking pollution, the climate change impacts, the damage to public health, and so on. You all know those issues better than most people in the state. So please feel free to discuss the Commission’s requirement to prioritize Public Health, Safety, Welfare, the Environment, and Wildlife Resources over private profits when you make your statement.

Starting Monday, January 20, the COGCC will begin the hearing to put in place increased Financial Assurances for O&G Operators.  Sounds Great—what’s the problem? They’re not increasing our protection!  Here’s how they’re not:

  • The state has $185M on hand in bonding to plug and reclaim the sites of all the oil and gas wells in the state.  But the average cost to perform plugging and cleanup is $93K each and there are more than 52,000 wells, which means we need $4.8 BILLION to meet just the average obligation. We have a mere $581,917 on hand.

  • The current Orphaned Well Program (OWP) lists 799 sites with 410 wells on them.  We put 5 operators with 200 wells out of business last year—nearly doubling our total count—for not doing the bare minimum required to do business in this state, and that of course left us with all their wells.  That means our current obligations on average amount to over $50M in costs.

  • The COGCC lists more than 10,000 shut-in (SI) or Temporarily Abandoned (TA) wells right now.  How many of those will end up in the OWP?

  • There are more than 25,000 low-producing (Stripper) wells in the state.  How many of them will end up in the OWP?

  • The average life of a horizontal well—before it becomes a stripper well—is 4 years.  How many more wells will become Strippers (leading to Orphans) in the next 5 years?

  • This means there are hundreds if not thousands more abandoned wells in our state that simply haven’t yet been added to the Orphaned Well Program.

  • SB19-181 – the Regulate O&G Bill – requires Operators to meet EVERY financial obligation for its operations, and therefore discourages the use of Blanket Bonds (a single amount to cover all the Operator’s wells in the state) but the COGCC is retaining them at absurdly low rates!

  • The bright spot is the Commission has created a mechanism for full-cost bonding of single wells based on actual plugging and reclamation (cleanup) costs.  But here come the escape clauses:

    • Regardless of the $93K average cost, they can provide one blanket bond of only
  1. $15,000 per Well for less than 50 Wells;
  2. $10,000 ea for more than 50 Wells;
  3. $5,000 ea for more than 150 Wells;
  4. $3,000 ea for more than 1500 Wells; or
  5. $1,500 per Well if the Operator operates more than 4000 Wells;
  6. THIS FORMULA RESULTS IN FEWER BOND AMOUNTS THAN WE HAVE NOW!
  7. And they only have to pay 10% of the amount per year which means we’re just supposed to pray nobody goes bankrupt in the next 10 years.  How likely do you suppose that will be?
  • There are 11 types of ‘used or useful’ wells that operators can employ to change well status so they can avoid plugging them and also avoid paying the higher bond rates required if they have a certain percentage of ‘inactive’ wells! And there are 3 more types of wells that are Out Of Service but still don’t have to be plugged, because maybe—just maybe—they’ll be useful again someday!
    • AND for Inactive, or Transferred wells
  1. Inactive Wells. The Operator’s blanket bond will cover Inactive Wells up to 10% (excluding Out of Service Wells). The Operator must provide Single Well Financial Assurance for any Inactive Well exceeding the 10% threshold
  2. But of course, you can change the well status to one of 14 other types to avoid the 10% threshold
  3. Single Well Financial Assurance is based on the demonstrated plugging and cleanup costs, but that only happens if you don’t put them on a plugging list that can take years to complete
  4. You can transfer them to a new Operator, then the new guy has to provide Single Well Financial Assurance—unless he doesn’t want to—then he can ask for a hearing to determine a lower amount!
  • Are you confused?  That’s the point!
  • Can Operators basically submit a plan for any amount of bond amount they want? YES!
  • Every year we transfer around $4M from the General Fund to pay for the Orphaned Well Program.  This Rulemaking asks Operators to put up $200/well/year to pay for the Fund, for an annual amount of $10M. Last year we spent about $4M and completed plugging and cleanup of a mere 8 projects for that price.  
    • It will take 480 years fund the Program to cover just the wells we have today—and we keep on drilling new ones!
  • The Federal Government requires $25,000 in a blanket bond to cover all the wells on their land in our state, but O&G doesn’t want to pay the state any bond, citing ‘double bonding’.  This is BS! We have 50 Federal Sites on our cleanup list right now, with zero in bonds to cover them, unless we go through a lengthy bureaucratic process to claim about $2,200/well. 
  • We have 318 ‘Active Operators’ who each must submit their own bonding plans every year, but the Commission only meets once a week.  This means the Commission would need to hold 6 hearings/meeting every week in perpetuity.  This is not possible!
  • There is a ‘Single Well Financial Assurance’ requirement but it only kicks in when wells are transferred from one operator to another.  We need EVERY well to be fully bonded to the cost of cleanup.
  • We need every new permit for new wells to include a bond at full cleanup cost for every well on the pad. And we need every new well to be fully bonded.
  • We need every Operator to plug and cleanup at least 1 well in their inventory for every new well they want to drill, preferably 2:1.
  • We need every existing well to be fully bonded, not just the ones that are no longer producing.
  • If an Operator can’t afford to bond their operations then they shouldn’t be allowed to continue business until they can afford it!
  • No new permits for Operators who can’t pay full cost bonds.
  • We need to demand that Operators plug and clean up every inactive well in their inventory, and bond for every active well too!

The O&G Industry is packing the hearings with employees who are given pre-written talking points, most of which have to do with scaring people with threats of bankruptcy, orphaned wells and job losses, and a promise that we can trust them to clean up their mess.  We know better.  We need YOU to counter their puppets with the facts and the truth. 

Click here to sign up for 2-3 minutes of public comment

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