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D=slgn Envelope ID:6F7B4A9g.B4iF-4FB2.BB7&6EC278F1g6D9 CaIGEM recommends that any well forwhich access is impeded or built over,against CaIGEM's advice, should be evaluated by a qualified petroleum professional for compliance with the statutory objectives of isolating all hydrocarbon-bearing strata; protecting underground and surface wafers;prevention of subsequent damage to life,health,property,and other resources; and prevention of loss of oil,gas, or reservoir energy.CaIGEM recommends that wells that do not meet these standards are abandoned or re-abandoned prior to construction. The well information can be accessed through CaIGEM's Well Finder database mentioned above.PRC section 3208, subdivision (a), provides the primary statutory authority for CaIGEM to oversee adequate abandonment of wells. Additionally, CaIGEM has developed the regulatory guidance for operators to be followed during well abandonment, which are listed within California Code of Regulation, title 14 (CCR) section 1723 and associated sub-sections (for onshore wells),and section 1745 and associated sub-sections(for offshore wells). There is no guarantee that a well abandoned in compliance with current Division requirements as prescribed by law will not start leaking in the future. Due to the inability to predict ail subsurface conditions or changes,it always remains a possibility that any well may start to leak oil,gas,and/or water after abandonment,no matter how thoroughly the well was plugged and abandoned. CaIGEM acknowledges wells plugged and abandoned 10 the most current Division requirements as prescribed by law have a lower probability of leaking in the future, however there is no guarantee that such abandoned wells will not leak. CaIGEM advises that all wells identified on the development parcel prior to, or during, development activities be tested for liquid and gas leakage.Surveyed locations in Latitude and Longitude, NAD 83 decimal format, and leak testing results should be provided to CaIGEM. CaIGEM expects any wells found leaking to be reported 10 CaIGEM immediately. PRC section 3208.1 gives CoIGEM the authority to order or permit the re-abandonment of any well where it has reason to question the integrity of the previous abandonment. Responsibility for re-abondonment costs may be affected by the choices made by the local permitting agency, property owner,and/or developer in considering the general advice set forth in this letter.The PRC continues to define the person or entity responsible for re-abandonment as: 1. The property owner - If the well was plugged and abandoned in conformance with Division requirements of the time of abandonment,and in its current condition does not pose an immediate danger to life, health, and property, but requires additional work solely because the owner of the property on which the well is located proposes construction on the property that would prevent or Impede access to the well for purposes of remedying a currently perceived future problem, then the owner of the property on which the well is located shall obtain all rights necessary to re-abandon the well and be responsible for the re-abandonment. 2. The person or entity causing construction over or near the well-If the well was plugged and abandoned in conformance with Division requirements at the time of plugging and abandonment, and the property owner, developer, or local agency permitting the construction failed either to obtain an opinion from the supervisor or district deputy as to whether the previously abandoned well Is required to be re-abandoned, or 10 follow the advice of the supervisor or district deputy not to undertake construction that impedes access,then the person or entity causing the construction over or near the well shall obtain all rights necessary to re-abandon the well and be responsible for the re-abandonment. 3. The party or parties responsible for disturbing the integrity of the abandonment -If the well was plugged and abandoned in conformance with Division requirements at the time of Page 2