BEFORE THE OIL AND GAS CONSERVATION COMMISSION

OF THE STATE OF COLORADO

 

IN THE MATTER OF ALLEGED VIOLATIONS OF THE RULES AND REGULATIONS OF THE COLORADO OIL AND GAS CONSERVATION COMMISSION BY ASPEN OPERATING, LLC, DELTA COUNTY, COLORADO

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CAUSE NO. 1V

 

ORDER NO. 1V-368

 

 

ORDER FINDING VIOLATION

 

FINDINGS

 

Hamilton #32-1 Well

 

1.     On September 1, 2006, Aspen Operating, LLC (“Aspen”) (Operator No. 10182) received an approved Application for Permit-to-Drill (“APD”) for the Hamilton #32-1 Well (API No. 05-029-06097), which is located in the NE¼ SE¼ of Section 32, Township 13 South, Range 95 West, 6th P.M., for the production of oil and associated hydrocarbons from the Dakota Formation.  Documentation indicates that the well was completed to a depth in excess of 3,000 feet below ground surface (“fbgs”). 

 

2.     On January 28, 2010, COGCC Staff issued Notice of Alleged Violation (“NOAV”) #1769805 to Aspen for its operations at the Hamilton #32-1 Well for alleged violations of the Rules, including:

 

a.     Rule 206., which provides that all operators shall, from time to time, file accurate and complete reports containing such information as the Director shall require.

 

b.   Rule 319.b.(1), which provides that a well may be temporarily abandoned when completed, upon approval of the Director, for a period not to exceed six months.

 

c.   Rule 319.b.(3), which specifies that a well may be temporarily abandoned when completed, upon approval of the Director, for a period not to exceed six (6) months provided the hole is cased or left in such a manner as to prevent migration of oil, gas, water or other substance from the formation or horizon in which it originally occurred. If an operator requests temporary abandonment status in excess of six (6) months the operator shall state the reason for requesting such extension and state plans for future operation. A Sundry Notice, Form 4, or other form approved by the Director, shall be submitted annually stating the method the well is closed to the atmosphere and plans for future operation;

 

d.   Rule 326.b.(1), which requires that a mechanical integrity test must be performed on each shut-in well within two (2) years of the initial shut-in date; 

 

e.   Rule 706., which provides that prior to the commencing the drilling of a well, an operator shall provide financial assurance to the Commission to ensure the protection of the soil, the proper plugging and abandonment of a well and the reclamation of the site in the amount of Twenty Thousand dollars ($20,000) per well for wells in excess of 3,000 feet.

 

Said NOAV had an abatement date of June 25, 2010, and required Aspen to:

 

1.   Put the well back on production, or

2.   Perform a mechanical integrity test on the well, or

3.   Properly plug and abandon the well, and

 

Further, said NOAV required Aspen, by February 12, 2010, to:  (1) submit a Sundry Notice, Form 4, requesting temporary abandonment status and detailing both how the well is closed to the atmosphere and the plan for the future operation of the well, (2) submit a completed Drilling Completion Report, Form 5, with GPS data, cement tickets, (3) submit a completed Completed Interval Report, Form 5A, with initial testing information and formation depth, and (4) provide the Commission with the financial assurance required under Rule 706.

 

3.     The COGCC Staff asserts that the Hamilton #32-1 Well was drilled and completed on December 7, 2006, and has been temporarily abandoned without Director approval since that time.  Further, Aspen has not performed a successful mechanical integrity test on the well since its completion.  Aspen has not posted the required financial assurance for the well.

 

4.     Rule 523. specifies a base fine of One Thousand dollars ($1,000) for each day of violation of Rules 206., 319.b.(1), 319.b.(3), 326.b.(1), and 706.  Rule 523.a.(3) specifies that “the maximum penalty for any single violation shall not exceed Ten Thousand dollars ($10,000) regardless of the number of days of such violation,” unless the violation results in significant waste of oil and gas resources, damage to correlative rights, or a significant adverse impact on public health, safety or welfare or the environment. 

 

5.     Aspen violated Rule 206. because it failed to file accurate and complete reports as required by the Director.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 206. under these circumstances.

 

6.     Aspen violated Rule 319.b.(1) because it has temporarily abandoned the Hamilton #32-1 Well, without Director approval, for a period exceeding six months.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 319.b.(1) under these circumstances.

 

7.     Aspen violated Rule 319.b.(3) because it has temporarily abandoned the Hamilton #32-1 Well and not filed a Sundry Notice, Form 4, or other approved form stating the method the well is closed to the atmosphere and plans for the future operation of the well.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 319.b.(3) under these circumstances.

 

8.     Aspen violated Rule 326.b.(1) because it has failed to obtain a successful mechanical integrity test on the Hamilton #32-1 Well in a timely manner.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 326.b.(1) under these circumstances.

 

9.     Aspen violated Rule 706. because it has not posted the required financial assurance for the Hamilton #32-1 Well.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 706. under these circumstances.

 

10.   Base fines attributable to the Rule violations at the Hamilton #32-1 Well are set forth below, based on the maximum penalty per rule violation:

 

Violation

Base Fine

Rule 206.

$10,000

Rule 319.b.(1)

$10,000

Rule 319.b.(3)

$10,000

Rule 326.b.(1)

$10,000

Rule 706.

$10,000

Total Base Fines

$50,000

 

Hamilton #32-4 Well

 

11.   On September 1, 2006, Aspen received an approved APD for the Hamilton #32-4 Well (API No. 05-029-06101), which is located in the SE¼ SW¼ of Section 32, Township 13 South, Range 95 West, 6th P.M., for the production of oil and associated hydrocarbons from the Dakota Formation.  Documentation indicates that the well was completed to a depth in excess of 3,000 fbgs.   

 

12.   On January 28, 2010, COGCC Staff issued NOAV #1769804 to Aspen for its operations at the Hamilton #32-4 Well for alleged violations of the rules, including:

 

a.     Rule 206., which provides that all operators shall, from time to time, file accurate and complete reports containing such information as  the Director shall require.

 

b.   Rule 319.b.(1), which provides that a well may be temporarily abandoned when completed, upon approval of the Director, for a period not to exceed six months.

 

c.   Rule 319.b.(3), which specifies that a well may be temporarily abandoned when completed, upon approval of the Director, for a period not to exceed six (6) months provided the hole is cased or left in such a manner as to prevent migration of oil, gas, water or other substance from the formation or horizon in which it originally occurred. If an operator requests temporary abandonment status in excess of six (6) months the operator shall state the reason for requesting such extension and state plans for future operation. A Sundry Notice, Form 4, or other form approved by the Director, shall be submitted annually stating the method the well is closed to the atmosphere and plans for future operation;

 

d.   Rule 326.b.(1), which requires that a mechanical integrity test must be performed on each shut-in well within two (2) years of the initial shut-in date; 

 

e.   Rule 706., which provides that prior to the commencing the drilling of a well, an operator shall provide financial assurance to the Commission to ensure the protection of the soil, the proper plugging and abandonment of a well and the reclamation of the site in the amount of Twenty Thousand dollars ($20,000) per well for wells in excess of 3,000 feet.

 

Said NOAV had an abatement date of June 25, 2010, and required Aspen to:

 

1.   Put the well back on production, or

2.   Perform a mechanical integrity test on the well, or

3.   Properly plug and abandon the well, and

 

Further, said NOAV required Aspen, by February 12, 2010, to:  (1) submit a Sundry Notice, Form 4, requesting temporary abandonment status and detailing both how the well is closed to the atmosphere and the plan for the future operation of the well, (2) submit a completed Drilling Completion Report, Form 5, with GPS data, cement tickets, (3) submit a completed Completed Interval Report, Form 5A, with initial testing information and formation depth, and (4) provide the Commission with the financial assurance required under Rule 706.

 

13.   The COGCC Staff asserts that the Hamilton #32-4 Well was drilled and completed on October 31, 2006, and has been temporarily abandoned without Director approval since that time.  Further, Aspen has not performed a successful mechanical integrity test on the well since its completion.  Aspen has not posted the required financial assurance for the well.

 

14.   Rule 523. specifies a base fine of One Thousand dollars ($1,000) for each day of violation of Rules 206., 319.b.(1), 319.b.(3), 326.b.(1), and 706.  Rule 523.a.(3) specifies that “the maximum penalty for any single violation shall not exceed Ten Thousand dollars ($10,000) regardless of the number of days of such violation,” unless the violation results in significant waste of oil and gas resources, damage to correlative rights, or a significant adverse impact on public health, safety or welfare or the environment. 

 

15.   Aspen violated Rule 206. because it failed to file accurate and complete reports as required by the Director.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 206. under these circumstances.

 

16.   Aspen violated Rule 319.b.(1) because it has temporarily abandoned the Hamilton #32-4 Well, without Director approval, for a period exceeding six months.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 319.b.(1) under these circumstances.

 

17.   Aspen violated Rule 319.b.(3) because it has temporarily abandoned the Hamilton #32-4 Well and not filed a Sundry Notice, Form 4, or other approved form stating the method the well is closed to the atmosphere and plans for the future operation of the well.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 319.b.(3) under these circumstances.

 

18.   Aspen violated Rule 326.b.(1) because it has failed to obtain a successful mechanical integrity test on the Hamilton #32-4 Well in a timely manner.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 326.b.(1) under these circumstances.

 

19.   Aspen violated Rule 706. because it has not posted the required financial assurance for the Hamilton #32-4 Well.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 706. under these circumstances.

 

20.   Base fines attributable to the Rule violations at the Hamilton #32-4 Well are set forth below, based on the maximum penalty per rule violation:

 

Violation

Base Fine

Rule 206.

$10,000

Rule 319.b.(1)

$10,000

Rule 319.b.(3)

$10,000

Rule 326.b.(1)

$10,000

Rule 706.

$10,000

Total Base Fines

$50,000

 

Hamilton #33-2 Well

 

21.   On September 1, 2006, Aspen received an approved APD for the Hamilton #33-2 Well (API No. 05-029-06100), which is located in the NE¼ SW¼ of Section 33, Township 13 South, Range 95 West, 6th P.M., for the production of oil and associated hydrocarbons from the Dakota Formation.  Documentation indicates that the well was completed to a depth in excess of 3,000 fbgs. 

 

22.   On January 28, 2010, COGCC Staff issued NOAV #1769803 to Aspen for its operations at the Hamilton #33-2 Well for alleged violations of the rules, including:

 

a.     Rule 206., which provides that all operators shall, from time to time, file accurate and complete reports containing such information as the Director shall require.

 

b.   Rule 319.b.(1), which provides that a well may be temporarily abandoned when completed, upon approval of the Director, for a period not to exceed six months.

 

c.   Rule 319.b.(3), which specifies that a well may be temporarily abandoned when completed, upon approval of the Director, for a period not to exceed six (6) months provided the hole is cased or left in such a manner as to prevent migration of oil, gas, water or other substance from the formation or horizon in which it originally occurred. If an operator requests temporary abandonment status in excess of six (6) months the operator shall state the reason for requesting such extension and state plans for future operation. A Sundry Notice, Form 4, or other form approved by the Director, shall be submitted annually stating the method the well is closed to the atmosphere and plans for future operation;

 

d.   Rule 326.b.(1), which requires that a mechanical integrity test must be performed on each shut-in well within two (2) years of the initial shut-in date; 

 

e.   Rule 706., which provides that prior to the commencing the drilling of a well, an operator shall provide financial assurance to the Commission to ensure the protection of the soil, the proper plugging and abandonment of a well and the reclamation of the site in the amount of Twenty Thousand dollars ($20,000) per well for wells in excess of 3,000 feet.

 

Said NOAV had an abatement date of June 25, 2010, and required Aspen to:

 

1.   Put the well back on production, or

2.   Perform a mechanical integrity test on the well, or

3.   Properly plug and abandon the well, and

 

Further, said NOAV required Aspen, by February 12, 2010, to:  (1) submit a Sundry Notice, Form 4, requesting temporary abandonment status and detailing both how the well is closed to the atmosphere and the plan for the future operation of the well, (2) submit a completed Drilling Completion Report, Form 5, with GPS data, cement tickets, (3) submit a completed Completed Interval Report, Form 5A, with initial testing information and formation depth, and (4) provide the Commission with the financial assurance required under Rule 706.

 

23.   The COGCC Staff asserts that the Hamilton #33-2 Well was drilled and completed on October 17, 2006, and has been temporarily abandoned without Director approval since that time.  Further, Aspen has not performed a successful mechanical integrity test on the well since its completion.  Aspen has not posted the required financial assurance for the well.

 

24.   Rule 523. specifies a base fine of One Thousand dollars ($1,000) for each day of violation of Rules 206., 319.b.(1), 319.b.(3), 326.b.(1), and 706.  Rule 523.a.(3) specifies that “the maximum penalty for any single violation shall not exceed Ten Thousand dollars ($10,000) regardless of the number of days of such violation,” unless the violation results in significant waste of oil and gas resources, damage to correlative rights, or a significant adverse impact on public health, safety or welfare or the environment. 

 

25.   Aspen violated Rule 206. because it failed to file accurate and complete reports as required by the Director.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 206. under these circumstances.

 

26.   Aspen violated Rule 319.b.(1) because it has temporarily abandoned the Hamilton #33-3 Well, without Director approval, for a period exceeding six months.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 319.b.(1) under these circumstances.

 

27.   Aspen violated Rule 319.b.(3) because it has temporarily abandoned the Hamilton #33-3 Well and not filed a Sundry Notice, Form 4, or other approved form stating the method the well is closed to the atmosphere and plans for the future operation of the well.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 319.b.(3) under these circumstances.

 

28.   Aspen violated Rule 326.b.(1) because it has failed to obtain a successful mechanical integrity test on the Hamilton #33-2 Well in a timely manner.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 319.b.(3) under these circumstances.

 

29.   Aspen violated Rule 706. because it has not posted the required financial assurance for the Hamilton #33-2 Well.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 319.b.(3) under these circumstances.

 

30.   Base fines attributable to the Rule violations at the Hamilton #33-2 Well are set forth below, based on the maximum penalty per rule violation:

 

Violation

Base Fine

Rule 206.

$10,000

Rule 319.b.(1)

$10,000

Rule 319.b.(3)

$10,000

Rule 326.b.(1)

$10,000

Rule 706.

$10,000

Total Base Fines

$50,000

 

Hamilton #33-3 Well

 

31.   On September 1, 2006, Aspen received an approved APD for the Hamilton #33-3 Well (API No. 05-029-06102), which is located in the NW¼ NW¼ of Section 33, Township 13 South, Range 95 West, 6th P.M., for the production of oil and associated hydrocarbons from the Dakota Formation.  Documentation indicates that the well was completed to a depth in excess of 3,000 fbgs. 

 

32.   On January 28, 2010, COGCC Staff issued NOAV #1769802 to Aspen for its operations at the Hamilton #33-3 Well for alleged violations of the rules, including:

 

a.     Rule 206., which provides that all operators shall, from time to time, file accurate and complete reports containing such information as  the Director shall require.

 

b.   Rule 319.b.(1), which provides that a well may be temporarily abandoned when completed, upon approval of the Director, for a period not to exceed six months.

 

c.   Rule 319.b.(3), which specifies that a well may be temporarily abandoned when completed, upon approval of the Director, for a period not to exceed six (6) months provided the hole is cased or left in such a manner as to prevent migration of oil, gas, water or other substance from the formation or horizon in which it originally occurred. If an operator requests temporary abandonment status in excess of six (6) months the operator shall state the reason for requesting such extension and state plans for future operation. A Sundry Notice, Form 4, or other form approved by the Director, shall be submitted annually stating the method the well is closed to the atmosphere and plans for future operation;

 

d.   Rule 326.b.(1), which requires that a mechanical integrity test must be performed on each shut-in well within two (2) years of the initial shut-in date; 

 

e.   Rule 706., which provides that prior to the commencing the drilling of a well, an operator shall provide financial assurance to the Commission to ensure the protection of the soil, the proper plugging and abandonment of a well and the reclamation of the site in the amount of Twenty Thousand dollars ($20,000) per well for wells in excess of 3,000 feet.

 

Said NOAV had an abatement date of June 25, 2010, and required Aspen to:

 

1.   Put the well back on production, or

2.   Perform a mechanical integrity test on the well, or

3.   Properly plug and abandon the well, and

 

Further, said NOAV required Aspen, by February 12, 2010, to:  (1) submit a Sundry Notice, Form 4, requesting temporary abandonment status and detailing both how the well is closed to the atmosphere and the plan for the future operation of the well, (2) submit a completed Drilling Completion Report, Form 5, with GPS data, cement tickets, (3) submit a completed Completed Interval Report, Form 5A, with initial testing information and formation depth, and (4) provide the Commission with the financial assurance required under Rule 706.

 

33.   The COGCC Staff asserts that the Hamilton #33-3 Well was drilled and completed on October 17, 2006, and has been temporarily abandoned without Director approval since that time.  Further, Aspen has not performed a successful mechanical integrity test on the well since its completion.  Aspen has not posted the required financial assurance for the well.

 

34.   Rule 523. specifies a base fine of One Thousand dollars ($1,000) for each day of violation of Rules 206., 319.b.(1), 319.b.(3), 326.b.(1), and 706.  Rule 523.a.(3) specifies that “the maximum penalty for any single violation shall not exceed Ten Thousand dollars ($10,000) regardless of the number of days of such violation,” unless the violation results in significant waste of oil and gas resources, damage to correlative rights, or a significant adverse impact on public health, safety or welfare or the environment. 

 

35.   Aspen violated Rule 206. because it failed to file accurate and complete reports as required by the Director.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 206. under these circumstances.

 

36.   Aspen violated Rule 319.b.(1) because it has temporarily abandoned the Hamilton #33-3 Well, without Director approval, for a period exceeding six months.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 319.b.(1) under these circumstances.

 

37.   Aspen violated Rule 319.b.(3) because it has temporarily abandoned the Hamilton #33-3 Well and not filed a Sundry Notice, Form 4, or other approved form stating the method the well is closed to the atmosphere and plans for the future operation of the well.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 319.b.(3) under these circumstances.

 

38.   Aspen violated Rule 326.b.(1) because it has failed to obtain a successful mechanical integrity test on the Hamilton #33-3 Well in a timely manner.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 319.b.(3) under these circumstances.

 

39.   Aspen violated Rule 706. because it has not posted the required financial assurance for the Hamilton #33-3 Well.  In accordance with Rule 523., the base fine is Ten Thousand dollars ($10,000) for the violation of Rule 319.b.(3) under these circumstances.

 

40.   Base fines attributable to the Rule violations at the Hamilton #33-3 Well are set forth below, based on the maximum penalty per rule violation:

 

Violation

Base Fine

Rule 206.

$10,000

Rule 319.b.(1)

$10,000

Rule 319.b.(3)

$10,000

Rule 326.b.(1)

$10,000

Rule 706.

$10,000

Total Base Fines

$50,000

 

41.   Total base fines of Two Hundred Thousand dollars ($200,000) attributed to those wells involved in this action are:

 

Well Name/Number

Base Fine

Hamilton #32-1

$50,000

Hamilton #32-4

$50,000

Hamilton #32-2

$50,000

Hamilton #33-3

$50,000

Total Base Fines

$200,000

 

42. Payment of the fine pursuant to this Order should not relieve the operator from its obligations to complete corrective actions set forth in the NOAV, as may be amended or modified by COGCC Staff.

 

43.   Aspen, or its successors or assigns, should remain responsible for complying with this Order, in the event of any subsequent sale of property.

 

44.   On May 16, 2011, this matter was considered by the Commission.

 

45.   Due notice of the time, place and purpose of the hearing has been given in all respects as required by law.

 

46.  The Commission has jurisdiction over the subject matter embraced in said Notice, and of the parties interested therein, and jurisdiction to promulgate the hereinafter prescribed order pursuant to the Oil and Gas Conservation Act.

 

47.   At hearing, COGCC Staff made an offer of proof in support of the proposed Order Finding Violation, summarizing the key factual findings described above, and proposing a total base fine of $200,000 payable within 30 days of the entry of the order.

                                                                                                                     

48.  Representatives from Aspen did not appear to defend against the allegations brought by the request for an Order Finding Violations.

 

49.   Commissioner Cutright recused himself from this matter and did not participate in any manner.

 

50.   The Commission should accept the recommendation of the Enforcement Officer in this matter.

 

                                                                                    ORDER

 

NOW, THEREFORE, IT IS ORDERED, that Aspen shall be found in violation of Rules 206., 319.b.(1), 319.b.(3), 326.b.(1), and 706., for oil and gas operations at the Hamilton #32-1 Well (API No. 05-029-06097), which is located in the NE¼ SE¼ of Section 32, Township 13 South, Range 95 West, 6th P.M., for those acts alleged in this Order.

 

IT IS FURTHER ORDERED, that Aspen shall be found in violation of Rules 206., 319.b.(1), 319.b.(3), 326.b.(1), and 706., for oil and gas operations at the Hamilton #32-4 Well (API No. 05-029-06101), which is located in the SE¼ SW¼ of Section 32, Township 13 South, Range 95 West, 6th P.M., for those acts alleged in this Order.

                        

IT IS FURTHER ORDERED, that Aspen shall be found in violation of Rules 206., 319.b.(1), 319.b.(3), 326.b.(1), and 706., for oil and gas operations at the Hamilton #33-2 Well (API No. 05-029-06100), which is located in the NE¼ SW¼ of Section 33, Township 13 South, Range 95 West, 6th P.M., for those acts alleged in this Order.

                        

IT IS FURTHER ORDERED, that Aspen shall be found in violation of Rules 206., 319.b.(1), 319.b.(3), 326.b.(1), and 706., for oil and gas operations at the Hamilton #33-3 Well (API No. 05-029-06102), which is located in the NW¼ NW¼ of Section 33, Township 13 South, Range 95 West, 6th P.M., for those acts alleged in this Order.

 

IT IS FURTHER ORDERED, that Aspen shall be assessed a total fine of Two Hundred Thousand dollars ($200,000) for the Rule violations set forth above, which shall be payable within 30 days of the date the order is approved by the Commission.

 

IT IS FURTHER ORDERED, that this Order does not relieve the operator from undertaking and completing abatement or corrective actions that may be required by the Notice of Alleged Violations described in Finding Nos. 2, 12, 22, and 32, above, or any amendments or modifications thereto specified by the COGCC Staff.

 

IT IS FURTHER ORDERED, that the COGCC Staff is authorized to proceed with the plugging of and abandonment of the Hamilton #32-1, #32-4, #33-2, and #33-3 Wells that are subject of this enforcement matter and perform any necessary reclamation those well sites, with funds from the Oil and Gas Conservation and Environmental Response Fund as necessary.

 

IT IS FURTHER ORDERED, that under the State Administrative Procedure Act the Commission considers this order to be final agency action for purposes of judicial review within 30 days after the date this order is mailed by the Commission.

 

IT IS FURTHER ORDERED, that an application for reconsideration by the Commission of this order is not required prior to the filing for judicial review.

 

IT IS FURTHER ORDERED, that the provisions contained in the above order shall become effective immediately.

                       

IT IS FURTHER ORDERED, that the Commission expressly reserves its right after notice and hearing, to alter, amend, or repeal any and/or all of the above orders.

 

ENTERED this   25th   day of May, 2011, as of May 16, 2011.

                                               

                                                                        OIL AND GAS CONSERVATION COMMISSION

                                                                                    OF THE STATE OF COLORADO

 

                                        By                                                                            

                                                                                                Robert A. Willis, Acting Secretary

 

Dated at Suite 801

1120 Lincoln St.

Denver, Colorado 80203

May 25, 2011