Energy and Carbon Management Commission cites six Rule violations and initiates enforcement action
June 26, 2025 — Today at a public hearing the Energy and Carbon Management Commission (ECMC) announced the issuance of a Notice of Alleged Violation (NOAV) to Noble Energy, Inc., a subsidy of Chevron, regarding the loss of well control incident at the Bishop Well that occurred in Galeton, CO, on April 6, 2025.
ECMC issues NOAVs when there is reasonable cause to believe that a violation of any Commission rule, order, or permit has occurred. The issuance of a NOAV is a legal enforcement action.
ECMC is the state agency with statutory regulatory authority to investigate the Bishop well incident. On June 10, 2025, ECMC received and posted Chevron’s Accident Report (form 22) and attached Root Cause Analysis of the incident. ECMC used the Root Cause Analysis, as well as many other factors, to investigate the incident.
Based on the investigation, ECMC determined that enforcement action is warranted. ECMC alleges that the incident violated six Rules:
- Rule 428 - WELL CONTROL
- Rule 602.c. - GENERAL SAFETY REQUIREMENTS
- Rule 608.e. - OIL AND GAS FACILITIES
- Rule 902.a.b.c. - POLLUTION
- Rule 902.d. - POLLUTION (Water)
- Rule 903 - VENTING OR FLARING NATURAL GAS
These citations are listed in the NOAV. The NOAV (#404256913) is posted publicly on ECMC’s webpage devoted to the incident.
The NOAV process is described in Rule 523 to 525. Upon receipt of an NOAV, the operator has 28 days to file an Answer in response to the NOAV. Thereafter, the ECMC Enforcement Unit and the Attorney General’s Office commences an enforcement action by filing an application for a hearing with the ECMC Hearings Unit.
ECMC expects that this NOAV will take time to resolve and there is no estimated timeline for when the Enforcement Hearing will be scheduled. That said, ECMC continues to prioritize this incident and strives to schedule the hearing as soon as is feasible. Because an NOAV is a legal matter, no other information can be shared during the enforcement process outside of what is posted to the publicly available eFiling System or what is discussed at public hearings.
“I am optimistic that Chevron will work with us through the enforcement process to bring a timely resolution. And I am grateful to the many folks at Chevron who are working diligently to remediate the significant impacts of this incident,” said ECMC Director Julie Murphy. “To be clear, the remediation work to date has been in compliance with our protective standards. Nonetheless, our job is to hold operators accountable for noncompliance with our Rules, and our team’s thorough investigation determined that the incident violated our Rules. Of utmost importance is safety, and our investigation of this incident allows us to collectively advance and further improve safety protocols.”
In addition to ECMC’s enforcement duty to hold operators accountable for noncompliance with Rules, ECMC also has regulatory authority to oversee environmental remediation. ECMC environmental remediation standards are the most protective in the country and are described in the 900 Rule Series. In particular, Table 915-1 outlines the contaminants of concern that must be remediated.
The Spill/Release scout card for the Bishop well incident is on ECMC’s public database, COGIS, is a repository for all remediation documentation. ECMC assigned Spill/Release ID #489797 to the Bishop incident. ECMC also posts the corresponding data that supports the implementation of these plans. As of 6/26/25, ECMC has received and posted more than 1,000 analytical reports from field sampling activities conducted by Chevron and overseen by ECMC as part of the ongoing investigation. Plain language summaries of the data are available online.
ECMC regulates oil and gas operations in a manner that protects public health, safety, welfare, the environment and wildlife resources. Key documentation pertaining to the ways in which ECMC is overseeing the Bishop incident includes:
- ECMC posted Chevron’s Environmental Sampling and Analysis Plan on 4/17/25. This document describes the ways in which Chevron must take samples to investigate impacts from the spill. Subsequently, ECMC posted Chevron’s Analytical of Source Material documentation on 4/24/25. This document analyzes the data provided by initial samples.
- ECMC posted Chevron’s Site Investigation and Remediation Workplan (Form 27) on 5/1/25. The Workplan describes the ways in which impacts from the incident will be investigated, delineated, and remediated and how the remediation will be monitored and validated.
- The numerous impacts are being segregated into ~300 specific remediation sites (referred to as T-parcels) spanning just over a 1.5-mile radius from the Bishop well due to the variety of environmental impacts. In turn, the site-specific remediation and completion timelines for each T-parcel is unique.
- ECMC issued a Notice to Operators (NTO) on 5/2/25 to minimize the likelihood of the incident occurring again. The NTO required operators to conduct an assessment of their processes and wellhead procedures during the time period between drilling rig release and start of production and to report that assessment to ECMC. The goal of the NTO is to ensure proper application of technical, operational, and organizational processes, specifications, and solutions to reduce risk to health, safety, wildlife and the environment during pivotal times in the development of a well. ECMC assessed the submittals of the NTO and presented the findings at today’s hearing.
About the ECMC
The mission of the Colorado Energy & Carbon Management Commission (ECMC) is to regulate the development and production of the natural resources of oil and gas, deep geothermal resources, the capture and sequestration of carbon, and the underground storage of natural gas in a manner that protects public health, safety, welfare, the environment and wildlife resources. Visit the ECMC website for more information.