BEFORE THE OIL AND GAS CONSERVAT
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 |
)
)
)
) |
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