News & Alerts


In Day Two of Jost Energy Law’s “Did You Know?” Series, we continue to provide practical tips that serve to provide additional background on rules or processes that may otherwise not have been specifically addressed during the rulemaking or operator training meetings. The second set is below: 

~ Rule 201.b. – Compliance

  • When creating a plan to ensure compliance with the new COGCC Rules, please remember that: 
    • The Operator of any Oil and Gas Location, Oil and Gas Facility, Well, or any seismic, core, or other exploratory holes, whether cased or uncased, will comply with all applicable Commission Rules, and will ensure compliance by their contractors and subcontractors.
  • An Operator must include training and compliance steps in its internal programs for all contractors and subcontractors that will be performing work and services for such Operator. 

~ Rule 205 – Operator Registration

  • When creating a plan to ensure the Operator, among other entities, has the ability to conduct oil and gas operations in Colorado, please remember that: 
    • Prior to the commencement of their operations, all producers, Operators, transporters, refiners, gasoline or other extraction plant Operators, and initial purchasers who are conducting operations subject to the COGCC rules and governing Colorado Oil and Gas Conservation Act must file a Form 1, Registration for Oil and Gas Operations with the Director. 
    • Any producer, Operator, transporter, refiner, gasoline or other extraction plant operator, and initial purchaser conducting operations subject to the Act who has not previously filed a Form 1, will do so immediately. 
    • Any entity providing Financial Assurance for oil and gas Operators in Colorado will file a Form 1 with the Director.
  • The Form 1 and corresponding Form 1A are necessary to ensure that COGCC has the appropriate information for the Operator, among other entities, along with the appropriate financial assurance under the 700 Series Rules prior to commencing any oil and gas operations. 

~ Rule 223 – Confidential Information

When an Oil and Gas Development Plan, or any other interaction with the COGCC, requires the submission of confidential information, please remember that: 

  • Prior to submission of the confidential information (examples in Rule 223.b.), the Operator must confer with the Director to verify that it qualifies as confidential pursuant to the Commission’s Rules. 
    • If the Director determines that the documents or submissions are not confidential, the Operator need not submit the information after the conferral process, unless required to do so by a Commission Rule. 
  • If the Director determines that the documents or submissions are confidential, then:
    • The Operator must submit the confidential information on an attachment to the associated form, but do not include the confidential information on the form itself; and 
    • The Operator must submit a redacted and non-redacted version of the confidential information, unless the Director confirms that a non-redacted version does not need to be submitted. 
  • Any confidential information submitted to the COGCC must be marked as CONFIDENTIAL in a conspicuous location at the top of the document.