For Operators - Idle Well Program

The number of years a well has been idle is calculated from the idle start date to December 31 of the prior calendar year or the date that the well no longer meets the definition of idle well, whichever is lesser. The idle start date is the first month after the well has no reported production and/or injection for 24 consecutive months.

The 2020 Idle Well Fee Invoice will calculate the years idle through December 31, 2019.​

• If the idle well is plugged and abandoned during the prior calendar year, then the years idle is calculated from the idle start date to the plug and abandonment date.

Example: The well has an idle start date of January 1, 2010, and a plug and abandonment date of July 1, 2018. The years idle for the 2019 Idle Well Fee is 8.50 years. The idle well fee for the well is three hundred dollars ($300.00).

• If the idle well is returned to use for 6 consecutive months during the prior calendar year, then the number of years idle is calculated from the idle start date to the date the well is no longer idle.

Example: The well has an idle start date of January 1, 2010 and achieved 6 consecutive months of production between February 2018 and July 2018. The well no longer meets the definition of idle well on August 1, 2018. The years idle for the 2019 Idle Well Fee is 8.59 years. The idle well fee for the well is three hundred dollars ($300).

The invoice will be mailed to the agent of record In WellSTAR for the operator that was in possession of the well(s) on January 1 of the current calendar year.

If a transfer involving idle wells occurs between January 1 of the current year and May 1 of the current year, it is the responsibility of the operator in possession of the well(s) on January 1 of the current year to ensure payment is made to CalGEM.

Please ensure that all production and injection records are true and complete and that all records associated with the plugging and abandonment of a well have been submitted to demonstrate that the well is no longer idle.

Email CalGEMIdleWells@conservation.ca.gov with the information regarding the error. Please include the well(s) API number, whether the error is the “Fee” and/or “Inventory,” and a brief description of the error.

If an idle well on an approved IWMP is scheduled to be plugged and abandoned and the operator is in compliance with their IWMP, then the operator is not required to meet the testing requirements of CCR, title 14, sections 1772.1 and 1772.1.1 and the 15-Year Engineering Analysis requirements of CCR, title 14, section 1772.1.2 and 1772.1.3.

If an idle well on an approved IWMP is scheduled for return to use, then the operator must include the well on the operator's Testing Compliance Work Plan. If the well is due for testing during the six consecutive months of production for returning the well to use, the well must be tested in accordance with the requirements of CCR, title 14, sections 1772.1 and 1772.1.1 and, if applicable, a 15-Year Engineering Analysis must be conducted in accordance with the requirements of CCR, title 14, section 1772.1.2 and 1772.1.3.

If an idle well was initially scheduled to be plugged and abandoned as part of an approved IWMP, but the operator has amended its IWMP to schedule the well to return to use, and CalGEM has approved the amendment, the operator must submit a revised Testing Compliance Work Plan with the well included. The well must be scheduled for testing in accordance with the requirements of CCR, title 14, sections 1772.1 and 1772.1.1 and a 15-Year Engineering Analysis must be conducted in accordance with the requirements of CCR, title 14, sections 1772.1.2 and 1772.1.3.

A well is eliminated under an IWMP if the well is abandoned in accordance with PRC section 3208 or if the well maintains production of oil or gas or been used for injection for a continuous 6-month period. (PRC §§ 3008, subd. (d); 3206, subd. (a)(2)(A).)

Transferring idle wells to another operator does not eliminate the well.

Converting an idle well to an observation well does not eliminate the well.

Elimination must be completed within the calendar year, January 1 through December 31. CalGEM’s annual review is conducted at the end of each yearly cycle.

Wells being returned to production or injection must achieve 6 consecutive months of service within the IWMP calendar year - meaning the latest a well can be returned to production or injection and achieve the required 6 consecutive months of service within the IWMP calendar year is July.

The 2020 Idle Well Management Plan form is available for download. A paper copy may be mailed upon request.

There are three ways an operator may submit a completed IWMP form. The preferred method is to submit the completed form electronically through WellSTAR​ using the ‘Idle Well’ form. The completed Excel file may also be returned to CalGEM’s Idle Well Program via email at CalGEMIdleWells@conservation.ca.gov, or paper copies may be submitted to:

Geologic Energy Management Division
Attn: Idle Well Program
801 K Street, MS 18-00
Sacramento, CA 95814

With CalGEM’s approval, changes may be made to the wells scheduled for elimination during the year. Please contact the Idle Well Program at CalGEMIdleWells@conservation.ca.gov with the well(s) to be removed, added, or elimination method changed. When submitting a request to add or remove well(s), please include the API, well designation (lease name and well number combination), and the elimination method, either plugging and abandonment or return to use. Changes will be reviewed on a case-by-case basis and must be approved by CalGEM. Please be prepared to submit a revised Testing Compliance Work Plan.

CCR, title 14, section 1772.3, subdivision (b) requires operators to specify whether the long-term idle well(s) on an IWMP are being eliminated through plugging and abandonment or return to use. An operator may schedule long-term idle wells (LTIW) for elimination via plugging and abandonment for up to five years into the future. An operator who is using the IWMP form, may identify these wells and the proposed year of elimination on Tab ‘1D-Elimination Bank.’

An idle well that is projected to become a LTIW may be included on the ‘1D-Elimination Bank.’ However, the well must be a LTIW as of January 1 of the year the well is scheduled for elimination. An idle well eliminated before it becomes a long-term idle well does not count towards the elimination requirements for an IWMP.

A well scheduled on tab ‘1D-Elimination Bank’ must be scheduled for plugging and abandonment, and will not be required to meet the testing requirements of CCR, title 14, sections 1772.1 and 1772.1.1 and the 15-Year Engineering Analysis requirements of CCR, title 14, sections 1772.1.2 and 1772.1.3. Wells scheduled for elimination through return to use must meet testing requirements and may not be scheduled on tab ‘1D-Elimination Bank’.

If the base of the USDW is not known, the fluid level is presumed to be above the base of USDW.

After April 1, 2025, within 90 days of the first time that a fluid-level test indicates the well is, or is presumed to be above the base of a USDW, the operator will be required to conduct a casing pressure test.

A fluid-level test is not required if the operator demonstrates to CalGEM that the wellbore does not penetrate a USDW. Until an operator successfully demonstrates to CalGEM that the well does not penetrate a USDW, the well is presumed to penetrate a USDW.

Fluid-level test results may be submitted via WellSTAR using the Fluid Level form. The Fluid Level form allows operators to submit fluid level information for multiple wells at one time. 
Upload Test Result Guide for Operators​

Casing pressure test results are submitted via WellSTAR using the ‘Upload Test Results’ form. From the form information page, select the Test Subject of Well and then from the Test Type dropdown, select “Pressure Test – Casing Only.”
Upload Test Result Guide for Operators​

A traditional casing pressure test with liquid may be used to satisfy the casing pressure test requirement. An operator may conduct an inert gas depression test to satisfy the pressure testing requirement with CalGEM’s approval. However, the calculated pressure necessary to depress the fluid column to within 100 feet (MD) above the uppermost perforation, immediately above the casing shoe of the deepest cemented casing, or immediately above the top of the landed liner, whichever is highest, cannot be less than 500 psi. On a case-by-case basis, with CalGEM approval, an alternate mechanical integrity test method may be used to satisfy the pressure testing requirement. These alternate testing methods are required to be approved by CalGEM and to be at least as effective as a casing pressure test in demonstrating mechanical integrity. Examples of alternate testing methods that will be considered on a case-by-case basis include casing wall thickness inspection, employing such methods as magnetic flux, ultrasonic technologies, or a combination of an ultrasonic imaging tool and a cement evaluation log.

In addition to any other penalty or remedial requirement imposed by CalGEM, within 12 months of an idle well failing a casing pressure test, the operator must do one of the following:

• Bring the well into compliance;
• Partially plug and abandon the well in accordance with CCR, title 14, section 1752;
• Plug and abandon the well in accordance with PRC section 3208; or
• Schedule the well for plugging and abandonment under an approved IWMP or an approved Testing Waiver Plan.

To make amendments to your approved IWMP or Testing Waiver Plan, contact CalGEMIdleWells@conservation.ca.gov.

Clean out tag results may be submitted via WellSTAR using the Upload Test Results form. From the form information page, first select the Test Subject of Well, then from the Test Type dropdown, select “Clean out Tag.”
Upload Test Result Guide for Operators​

In addition to any other penalty or remedial requirement imposed by CalGEM, within 12 months of an idle well failing a clean out tag, the operator must do one of the following:

• Bring the well into compliance;
• Partially plug and abandon the well in accordance with CCR, title 14, section 1752;
• Plug and abandon the well in accordance with PRC section 3208; or
• Schedule the well for plugging and abandonment under an approved IWMP or an approved Testing Waiver Plan.

To make amendments to an approved IWMP or Testing Waiver Plan, contact CalGEMIdleWells@conservation.ca.gov.

The TCWP form is available. To request a TCWP form, please send a request to CalGEMIdleWells@conservation.ca.gov.

The preferred method is to submit the completed TCWP form electronically through WellSTAR using the “Idle Well” form. The completed Excel file may also be returned to CalGEM’s Idle Well Program via email at CalGEMIdleWells@conservation.ca.gov. Paper copies may be mailed to:
Geologic Energy Management Division
Attn: Idle Well Program
801 K Street, MS 18-00
Sacramento, CA 95814

The Idle Well Program has compiled a preliminary TCWP Inventory that is available for download in the “Idle Well Inventories” section below. The file is a Microsoft Excel file and may be filtered by operator. The file is formatted to be pasted directly into the TCWP form and only includes wells eligible to be on a TCWP over the six (6) years of the Compliance Period. Each idle well listed includes a yes/no value as to whether it is projected to and required to be scheduled for a casing pressure test, clean out tag, and a 15-year Engineering Analysis over the six (6) year period.

All wells that met the definition of idle well on or before April 1, 2019, are required to come into compliance with the casing pressure test by April 1, 2025. If a well has been an idle well for less than 2 years as of April 1, 2019, then completion of the clean out tag is not required during the compliance period. Once a well has been idle for 8 years a cleanout tag is required. While there is no penalty for conducting a cleanout tag early, a cleanout tag on a well idle for less than 2 years as of April 1, 2019, will not count toward clean out tag benchmarks.

The annual review of each TCWP will be conducted as of April 1 of each year. During the review, CalGEM will confirm that test results have been uploaded to WellSTAR for wells scheduled for testing. This includes, if applicable, confirmation that partial plugging and proper plugging and abandonment of wells has been completed in lieu of testing. CalGEM will document and notify each operator if the operator has met the annual benchmark.

If an operator has complied with the annual benchmarks, the operator will receive a letter documenting compliance and instructions for updating their TCWP for the next year.

If an operator has not complied with the annual benchmarks, in addition to any enforcement action CalGEM may take for failing to comply with the benchmarks, the operator will receive a letter documenting the number of tests the operator failed to complete to comply with their annual benchmarks. Each well that an operator fails to test constitutes a separate violation and is subject to the requirements of CCR, title 14, section 1772.1, subd. (b).

Operators may request an in-person review of the results by emailing CalGEMIdleWells@conservation.ca.gov.

With CalGEM’s approval, changes may be made to the wells scheduled for testing during the year. Please submit a revised TCWP to the Idle Well Program at CalGEMIdleWells@conservation.ca.gov with a narrative of well(s) to be rescheduled on the TCWP and well(s) to be moved to an approved IWMP or Waiver. When submitting a revised TCWP, please take care to ensure that the required number of wells are proposed each year to meet the annual benchmarks. Changes will be reviewed by CalGEM on a case-by-case basis and must be approved by CalGEM.

If an operator either transfers or acquires additional wells idle as of April 1, 2019, then both the transferring and acquiring operators must submit a revised TCWP to CalGEM within 90 days of the transfer or acquisition.

• The API number and name of the well
• Statement of the potential future use for the idle well
• Identification of each reservoir unit that might be accessed and the reservoir characteristics of each of the identified reservoir units
• A representative electric log to a depth below the deepest-producing zone, identifying all geologic units, formations, USDWs, freshwater aquifers, oil or gas zones, and each reservoir unit to be utilized
• Structural contour map drawn on a geologic marker at or near the top of each reservoir unit to be used, indicating faults, other lateral containment features, and area extent of the productive zone
• Casing diagram or flat file data set as specified in CCR, title 14, section 1772.1.3.

CalGEM may require the operator to include additional data in the engineering analysis on a case-by-case basis if CalGEM deems it necessary for the evaluation of whether it is viable to return the well to operation in the future.

If CalGEM determines upon initial review of the engineering analysis that it is not viable to return the well to operation in the future, CalGEM will inform the operator of the basis of that determination. The operator will be allowed at least 30 days to provide additional information to substantiate that the well is viable to return to operation in the future.

The 15-Year Engineering Analysis is a one-time submission due by the end of the month in which an idle well has been idle for 15 years.

For wells that as of April 1, 2019, have met the definition of an idle well for 9 years or more, the operator shall provide the Engineering Analysis to CalGEM by the later of the following:

• Within sixty (60) days after the date pressure testing on the idle well is scheduled in the operator’s Testing Compliance Work Plan; or
• By the end of the month in which the idle well has been idle for 15 years

Examples:
As of April 1, 2019, the well has been idle for 22 years. The casing pressure test is scheduled in the Compliance Work Plan for 2021. The engineering analysis is due within 60 days of the pressure test. As of April 1, 2019, the well has been idle for 10 years. The casing pressure test is scheduled for 2021, when the well will have been idle for 12 years. The engineering analysis is not due within 60 days of the pressure test; it is due by the end of the month in which the well has been idle for 15 years.

If a well is scheduled for plugging and abandonment on an approved Idle Well Management Plan or Testing Waiver Plan (described in next section), an operator is not required to submit an engineering analysis for the well. By the same account, if an operator plugs and abandons a well in lieu of testing, then a 15-Year Engineering Analysis is not required.

If an operator submits information for a 15-Year Engineering Analysis demonstrated to be applicable to multiple wells in the same field subject to the engineering analysis, the operator may reference the applicable information in subsequent engineering analyses and is not required to submit duplicate information.

All data required for the 15-year Engineering Analysis must be submitted to CalGEM in a digital format. The 15-year Engineering Analysis (Dylan: This may be available electronically without using WellSTAR. I need to confirm with Lauren) may be either submitted through WellSTAR using the “Idle Well” form or emailed to CalGEMIdleWells@conservation.ca.gov​.

For the purposes of the TWP, “plugging and abandonment” means plugging and abandonment in accordance with PRC section 3208, or partial plugging and abandonment in accordance with CCR, title 14, section 1752.

The TWP must include a list of idle wells to be plugged and abandoned, and the following information for each of the wells listed:

• The API Number and name of the well;
• The date by which is well is scheduled to be plugged and abandoned; and
• Documentation of any known wellbore integrity deficiencies associated with the well, including an explanation of the deficiency, when it became known, and a description of prior attempts to remediate or abandon the wellbore.

No, a TWP may be submitted for any number of years up to 8 (eight). However, in each year of the TWP, at least 10 percent of the idle wells covered by the TWP must be scheduled to be plugged and abandoned. If an operator lists less than eight wells on a plan, CalGEM will reduce the term length to be equal to the number of listed wells to ensure that a minimum of 10 percent of the wells covered by the TWP are plugged and abandoned each year of the plan.

After each year of adherence to a TWP, an operator may add additional wells and additional years to their TWP, provided the addition complies with the requirements of CCR, title 14, section 1772.2, subd. (b).

If an operator fails to complete plugging and abandonment of any well according to the schedule approved by CalGEM on the TWP, CalGEM may cancel the TWP. If the TWP is cancelled, the exemptions for testing no longer apply for any of the wells listed in the TWP. The operator will be required to comply with testing requirements of CCR, title 14, sections 1772.1 and 1772.1.1 and the 15-Year Engineering Analysis requirements of CCR, title 14, section 1772.1.2. within 90 days of the cancellation. When CalGEM cancels an operator’s TWP, CalGEM will not consider a new TWP from that operator unless the operator is in compliance with all of the requirements of CCR, title 14, sections 1772.1, 1772.1.1, and 1772.1.2. Operators concerned about meeting their TWP commitments should contact CalGEM immediately for assistance in managing obstacles to avoid having their TWP cancelled.

The annual review date for a TWP is the anniversary of the date CalGEM first approves the operator’s TWP. If an operator adds additional wells or extends the TWP for additional years, the annual review date will remain the anniversary of the date CalGEM first approved the initial TWP submitted by the operator. Each year, a minimum of 10 percent of wells on the TWP must be plugged and abandoned by the annual review date.

The compliance due date for a TWP is the date by which all the wells originally included on the Plan must be plugged and abandoned. This date will be dependent on the length of the TWP and the date CalGEM approves it. Upon approval, each well on the TWP will be given an elimination due date. The elimination due date is the date by which the well on the TWP must be plugged and abandoned. The elimination due date cannot exceed the term of the TWP and cannot exceed 8 years from the date the well was first added to the TWP. During each subsequent renewal of the TWP, newly added wells will receive a unique elimination due date and each existing well will retain its original elimination due date.

Example:
A Testing Waiver Plan is approved on June 1, 2019 to include 50 wells with an 8-year length.

• First annual review date is June 1, 2020, with a minimum of 5 wells plugged and abandoned.
• Compliance due date for all 50 wells to be plugged and abandoned is June 1, 2027.

A TWP form is available. To request a TWP form, please send a request to CalGEMIdleWells@conservation.ca.gov.
The preferred method to submit the completed TWP form is to send it electronically through WellSTAR using the “Idle Well” form. The completed Excel file may also be returned to CalGEM’s Idle Well Program via email at CalGEMIdleWells@conservation.ca.gov. Paper copies may be mailed to:
Geologic Energy Management Division
Attn: Idle Well Program
801 K Street, MS 18-00
Sacramento, CA 95814

CalGEM will either approve the TWP as submitted or return it to the operator contingent on revision. Potential revisions could include modifications to the length of the TWP, the dual listing of wells on the TWP and either a TCWP or IWMP, and corrections to the number of wells that must be plugged and abandoned to meet the 10 percent benchmark.

An operator may request to modify the idle wells listed in an approved TWP during the annual review. The request to modify the TWP shall be supported by:

• A justification for the change.
• Information required under CCR, title 14, section 1772.2, subdiv. (b)(1) for any idle wells added to the list.
• A work plan for expeditiously bringing any wells removed from the list into compliance with the requirements of CCR, title 14, sections 1772.1, 1772.1.1 and 1772.1.2.

​Amendment requests should be submitted to the idle Well Program at: CalGEMIdleWells@conservation.ca.gov.