Q813. What are the optional delayed reporting requirements for wildcat wells and delineation wells?

A813. Subpart W specifies that reporting may be delayed by up to two years for certain data elements that are based exclusively on information from wildcat wells and/or delineation wells. The specific requirements differ for each reporting year. Details of the requirements for each year are described below:

1. Reporting Years 2011 and 2012. The annual reports for reporting years 2011 and 2012 were due on March 31, 2012, and March 31, 2013, respectively. The optional delayed reporting provision is moot for these reporting years because a 2-year delay would require reporting of the delayed elements on or before March 31, 2015, which is also the same as the required reporting date for all of the deferred data elements for these two reporting years. Thus, all subpart W data elements for reporting years 2011 and 2012 that were deferred from reporting must be reported by March 31, 2015, including the reporting requirements for wildcat and delineation wells. Note that because the delay option is not applicable for reporting years 2011 and 2012, there is no requirement to identify API well numbers for wildcat and/or delineation wells in the deferred data reporting form for those years.
   
   
2. Reporting Year 2013.  For reporting year 2013, a reporter may elect to delay reporting of 6 data elements by up to 2 years in situations where the data are derived exclusively from wildcat and/or delineation wells. Thus, reporting may be delayed until March 31, 2016, since the annual report for non-delayed data elements was due on March 31, 2014. The 6 data elements are:
   
   
   • Measured flow rate of backflow during well completion (40 CFR 98.236(c)(6)(i)(B));
   • Measured flow rate of backflow during well workover (40 CFR 98.236(c)(6)(i)(D));
   • Total number of days of backflow from all wells during completions (40 CFR 98.236(c)(6)(i)(E));
   • Total number of days of backflow from all wells during workovers (40 CFR 98.236(c)(6)(i)(F));
   • Total volume of oil from all wellhead separators sent to tank(s) in barrels per year (40 CFR 98.236(c)(8)(i)(F)); and
   • Total volume of sales oil from all wells in barrels per year (40 CFR 98.236(c)(8)(ii)(A)).

   If a reporter elects to delay reporting for reporting year 2013, the reporter must indicate in the reporting year 2013 deferred data element reporting form (due by March 31, 2015), for each delayed data element, that one of the two following situations is true for the data element that is being delayed:
   
   

   • For gas well completions and workovers with hydraulic fracturing, wildcat wells and/or delineation wells are the only wells in a sub-basin that can be used for the measurement; and
   • For onshore production storage tanks, wildcat wells and/or delineation wells are the only wells in a sub-basin.

   The 6 data elements themselves (or all that are applicable to your facility) must be reported by March 31, 2016. In addition, the API well numbers for the wildcat and/or delineation wells associated with the delayed data elements also must be reported by March 31, 2016.
   
   

3. Reporting Year 2014. The data elements associated with wildcat and/or delineation wells for which reporting may be delayed are the same for reporting year 2014 as for reporting year 2013. When complying with the delayed reporting option, the reporter must indicate in the annual report for reporting year 2014 (i.e., by March 31, 2015) which of the two situations described above in the discussion for reporting year 2013 apply to the delayed reporting elements. The 6 data elements themselves (or all that are applicable to your facility) must be reported by March 31, 2017. In addition, the API well numbers for the wildcat and/or delineation wells associated with the delayed data elements also must be reported by March 31, 2017.
   
   
4. Reporting Year 2015 and future reporting years. Beginning with reporting year 2015, additional data elements are required for wildcat and delineation wells. There are 12 data elements for which reporting may be delayed by 2 years in situations where the data are derived exclusively from wildcat wells and/or delineation wells. The 12 data elements are:
   
   
   • For each sub-basin with gas well completions/workovers with hydraulic fracturing, the cumulative flowback time (40 CFR 98.236(g)(5)(i));
   • For each sub-basin with gas well completions/workovers with hydraulic fracturing, the flowback rate for the measured well(s) (40 CFR 98.236(g)(5)(ii));
   • For each sub-basin with gas well completions without hydraulic fracturing and without flaring, average daily gas production rate for all completions without hydraulic fracturing in the sub-basin without flaring (40 CFR 98.236(h)(1)(iv));
   • For each sub-basin with gas well completions without hydraulic fracturing and with flaring, average daily gas production rate for all completions without hydraulic fracturing in the sub-basin with flaring (40 CFR 98.236(h)(2)(iv));
   • At the sub-basin level for atmospheric tanks where emissions were calculated using Calculation Method 1 or 2, the total annual oil volume that is sent to atmospheric storage tanks (40 CFR 98.236(j)(1)(iii));
   • At the basin level for atmospheric tanks where emissions were calculated using Calculation Method 3, the total annual oil throughput that is sent to atmospheric tanks in the basin (40 CFR 98.236(j)(2)(i)(A));
   • If oil well testing is performed where emissions are not vented to a flare, the average flow rate in barrels of oil per day for well(s) tested (40 CFR 98.236(l)(1)(iv);
   • If oil well testing is performed where emissions are vented to a flare, the average flow rate in barrels of oil per day for well(s) tested (40 CFR 98.236(l)(2)(iv));
   • If gas well testing is performed where emissions are not vented to a flare, average annual production rate in actual cubic feet per day for well(s) tested (40 CFR 98.236(l)(3)(iii));
   • If gas well testing is performed where emissions are vented to a flare, average annual production rate in actual cubic feet per day for well(s) tested. (40 CFR 98.236(l)(4)(iii));
   • Volume of oil produced in the calendar year during the time periods in which associated gas was vented or flared (40 CFR 98.236(m)(5)); and
   • Total volume of associated gas sent to sales in the calendar year during time periods in which associated gas was vented or flared (40 CFR 98.236(m)(6)).

In the annual report for reporting year 2015, reporters that elect to comply with the delayed reporting option must indicate in the annual report for reporting year 2015 (i.e., by March 31, 2016) that one of the following situations is true for each of the data elements for which reporting is to be delayed:

• • For gas well completions or workovers with hydraulic fracturing, wildcat wells and/or delineation wells are the only wells in a sub-basin that can be used for the measurement;
  • For gas well completions without hydraulic fracturing, wildcat wells and/or delineation wells are the only wells in a sub-basin that can be used for the measurement;
  • For onshore production storage tanks, wildcat wells and/or delineation wells are the only wells in a sub-basin or basin;
  • For well testing, wildcat wells and/or delineation wells are the only wells in a sub-basin that are tested;
  • For associated gas venting and flaring, wildcat wells and/or delineation wells are the only wells in a sub-basin.

All of the delayed reporting data elements for reporting year 2015 must be reported by March 31, 2018. In addition, the API well numbers for the applicable wildcat and/or delineation wells associated with each delayed reporting data element must be reported by March 31, 2018.