Energy and Carbon Management Commission approves administrative order on consent with Noble Energy over April well release

The Energy and Carbon Management Commission on March 18 approved an administrative order on consent (AOC) resolving enforcement stemming from an April 2025 uncontrolled release at a Noble Energy well, the commission said.

Director Julie Murphy told the commission the release began April 6, 2025 when well barriers failed and fluids were released from the wellbore; the release was stopped April 10 and the site secured April 11. Murphy said an operator root-cause analysis filed as a Form 22 identified improper assembly and setting of equipment as the cause. "This AOC represents a culmination of our enforcement efforts for an extraordinary event," Murphy said, asking the commission to make the negotiated AOC a full order of the commission.

Murphy and enforcement staff told commissioners the notice of alleged violation (NOAV) issued June 26, 2025 cited multiple rule violations, including provisions related to well control, general safety and pollution protections. Staff said they applied a "major impact" factor in penalty calculations because of the incident's adverse impacts, and that the director exercised discretion not to apply the usual duration matrix that can reduce daily penalties for long-standing violations.

Under terms described by staff, Noble agreed to submit two batches of Form 27 "no further action" requests to ECMC — 100 by April 1, 2026, and a second batch of 100 by June 1, 2026 — to move site closures forward. The AOC also commits operator funding for four public projects intended to support oversight, data review and records evaluation: $100,000 to Tetra Tech for project management and field oversight; $150,000 for a forensic review of roughly 3,400 lab reports submitted to ECMC by operators from 01/01/2020 through 2025; about $580,000 to a contractor to help process and reduce the backlog of Form 27 requests; and $200,000 for a systematic review of well records (COGIS) for wells plugged before 01/01/2008.

Jeremy Farren, ECMC enforcement manager, told commissioners that staff followed statutory authority, rules and the enforcement policy guidance when calculating penalties: "For long duration violations, anything over 10 days, we have the discretion to apply the duration matrix," he said, adding that the director chose not to use it in this case so the penalties remain at the higher rates consistent with the rules.

Matthew Lepore, representing Noble, said the company accepts the AOC terms and described the incident as "resulting from human error," while noting Noble's "robust" response and cooperation with first responders, local authorities and ECMC. "Noble accepts the terms of the proposed AOC," Lepore said.

After discussion and expressions of support for staff work from several commissioners, the chair moved approval of the AOC (order 1B1014, docket 260200039). Commissioners signaled assent and the motion carried. The commission recorded the AOC as approved and directed staff to ensure corrective actions are carried out and that funding for the public projects flows as required.

What happens next: ECMC staff said they will continue on-site oversight and monitor submission and review of Form 27 requests. The commission also indicated it will receive further updates on remediation status and project funding as staff implements the AOC.