Last week, CIPA and CalGEM held their regularly scheduled monthly coordination meeting to continue programmatic dialogue on key regulatory and operational topics. These standing meetings serve as a productive and mutually beneficial forum to promote regulatory compliance, improve permitting processes, and support best practices among California’s independent oil and gas operators.
Idle Well Management Plans (IWMP) vs. Two-Year Testing Plans (TWP)
Discussion at last week’s meeting focused on clarification of expectations for well placements under the IWMP. CalGEM confirmed that not all wells are required to be placed on an IWMP. Instead, IWMPs are a forward-looking tool to eliminate idle wells according to state prescribed minimums with planning horizons of up to eight years.
Key clarifications included:
Wells not on the IWMP must follow the two-year fluid testing plan.
Return-to-use wells must adhere to scheduled testing; exemptions from testing are only granted when wells are actively scheduled for plug and abandonment.
Operators retain discretion in identifying return-to-use candidates, although CalGEM may request abandonment if a well poses a risk.
IWMPs should be submitted annually to reflect updates and new entries.
Operators may request additions to IWMPs, and as long as annual abandonment targets are met, there is flexibility in determining which wells to abandon.
New staffing updates were provided: the IWMP program is now led by a newly designated official, and a new supervisor has been appointed to the Sacramento office for the Northern District.
Witnessing – Remote and After-Hours
CIPA and CalGEM will launch a joint working group next month to explore processes and protocols for after-hours and remote witnessing. The goal is to increase efficiency and provide flexibility while maintaining compliance integrity.
Lynch Canyon Aquifer Exemption Package
The EPA received the long-awaited shapefile associated with the Lynch Canyon AE package on March 3 and promptly issued a request for additional information. CalGEM has already prepared the response and sent a draft letter to the Water Board for review. A final response to EPA is expected by the end of April, with no additional operator circulation anticipated.
CalGEM is also reviewing EPA feedback on the Sespe and Holser AE packages, but a timeline for those responses is still pending. CalGEM will follow up.
SB 1137 Regulations, Permitting, and Energy Security Concerns
Discussions continued regarding the regulatory and economic impacts of delayed permits for new wells. The lack of timely permits is contributing to production declines, undermining compliance with Idle Well Management requirements and threatening energy reliability. Operators have highlighted the downstream consequences to refiners and consumers, raising California Energy Commission (CEC) concerns.
CalGEM acknowledged:
The CEQA unit process has undergone major changes and improvements, aided by industry input.
Initial focus was placed on lower-complexity projects to build processing momentum.
Current staffing levels (three staff members and one contractor) remain a challenge, and the agency lacks full capacity to act as lead agency for the volume of demand.
There is recognition that permit processing must be consistent and predictable, and internal efforts are now focused on higher-complexity projects.
The CEQA unit confirmed there are currently 19 projects under active review, with approximately half tied to SB 1137 requirements. CalGEM is evaluating options to securely share status updates, including a password-protected SharePoint portal, which will be discussed in upcoming meetings.
General Updates
The new Director of the California Department of Conservation was introduced and has expressed a clear focus on understanding operator needs, improving permitting certainty, and aligning regulatory capabilities with expectations.
Standing Meetings
These collaborative meetings will continue to be held on the third Thursday of each month, supporting ongoing coordination between independent producers and California’s oil and gas regulator. CIPA members are welcome to attend in person or via zoom.