Author: Staci Taruscio, CEO

Last week I wrote about the three questions every buyer should ask before purchasing a well-plugging carbon credit. The response to that article made it apparent that this market is ready to have a harder conversation.

Today I want to add one more question to the list of questions a buyer should ask. While this question is less obvious than the first three, it might matter more.

Who is doing the work?

In my transition from oil and gas to carbon markets, I noticed a critically important component of this conversation is not being discussed. Everyone is talking about methodology, additionality, permanence, and ratings, but it feels like nobody is talking about safety. Nobody is asking whether the people physically approaching these wells (and the people evaluating the credits those wells produce) are actually qualified to do what they are doing.

I am genuinely proud to have built a company for this moment, and as the broader market learns more and more about plugging orphan wells, we cannot skip safety.

Some companies newly entering this market have leadership with a facet of oil and gas experience, but it seems that very few, if any, have the full range. That gap is not only a safety issue, but it is also a quality problem and ultimately a question about market integrity.

The quality of a well-plugging carbon credit is only as good as the work that produced it. That work happens in the field, on facilities that in many cases have not been touched in many years, in conditions that are genuinely hazardous. Who shows up to that well, as well as what they know about the well when they get there, determines everything downstream: the measurement, the plug, the credit, the rating, and the ultimate defensibility of your purchase. Oh, and also whether this project ends up in the news for catastrophic reasons.

So, it reasons to ask: Who should be doing this work, and what are their qualifications? Here’s what I think.

First: The field crew

Orphan wells are more dangerous than operated wells. The common assumption is that a well that isn’t producing must be quieter, lower pressure, or less active. That assumption is wrong and it can (and does) get people killed.

Contrary to an orphan well, an operated well has people touching them daily or weekly to ensure the surface equipment is up to standard and specifications to securely and safely hold back the internal dynamics at play in the subsurface. In short, when an operated is approached, there is context, and in this industry, context means safety.

Little to none of that is available to the project developer approaching an orphan well. It is not that the data never existed, it’s that much of it is lost with the operator(s). Because of this, a team doesn’t know if the mechanical integrity of the well is compromised, if the equipment on site is rated for the energy it is intended to hold, or if the composition of the fluids is hazardous, among many, many other factors.

The dangers of this situation are specific, and these are just a few of the documented hazards:

• Derated wellheads and surface equipment from years without maintenance.
• Flammable or toxic hydrocarbons that can kill with very little catalyst. For example, a single ignition source near a leaking well can cause an explosion or wildfire.
• Overpressure that can kill upon impact. The energy contained in a pressurized system that has been building without monitoring or relief is not theoretical: It takes only 100PSI of force to a human torso to give you a 95% chance of death, and the wells we work on are often sitting at multiples of 100PSI.
• Naturally occurring radioactive material can exist in wellhead components and associated piping, which requires specialized handling and waste management that a general field crew is not equipped to perform.

We want to underscore that these are the documented hazards of orphan well sites and not edge-cases, and they are the reason that the field crew approaching them must include people with legitimate safety training, well control certifications, and deep experience with well sites.

Beyond the safety of it all, a field crew without that experience is not just a liability for the workers, but a liability for the credit and the buyer who holds it. We hold this responsibility at the center of our business and day-to-day operations in order to keep our crew safe and to de-risk our project for buyers and the industry generally. Not every company does this.

Second: The production engineer

What happens after safely getting to and accessing the well itself determines the quality and accuracy of everything the credit is built on.

Measurement on an orphan well with unknown history requires assessing emissions on facilities of uncertain condition, in likely hazardous conditions, using methodology and internal best practices that must meet carbon market quantification standards rigorous enough to survive third-party audit.

And that high quality measurement requires engineers who can read what they are measuring in real time and adapt without diminishing the quality of those measurements. They must understand what is being measured, what variances indicate, how to conduct stability assessments, and the timeframe for which a measurement must continue in order to produce a highly certain predictive tool. They must also understand corrosion and what it does to equipment integrity, how it affects readings, and how to account for it in the data.

An experienced, trained team ensures that two major risks- safety and crediting- are reduced dramatically. The production engineer is a degreed professional with experience in drilling, completion, production, and facilities, this is a person who understands the full mechanical context of what they are measuring and why it matters. That background separates a defensible measurement from one that looks clean on paper but does not reflect what the well is actually doing.

Third: The reservoir engineer

If the production engineer tells you what the well is doing right now, then the reservoir engineer tells you what it will do over the next twenty years.

Reservoir engineers must take all of the data available to them including historic, measured, observed, contextual, analogous, and model emissions through the crediting period. This requires understanding decline curves, type wells, field study, and the full range of subsurface variables that determine how a well behaves over time. A reservoir engineer work closely with geologists who provide the contextual and analogous data that grounds those models in the actual geology of the formation. It is as complex as it sounds.

Critically, this is where uncertainty gets quantified and managed. A defensible crediting model can account for the range of possible outcomes over a twenty-year period, and building one that can do this requires reservoir engineering depth that most carbon market entrants simply do not have on staff.

Reservoir engineers are doing some of the most technically demanding work in this entire project space.

The full bench

All of these disciplines (and they must all be present) have to work together to build the complete picture that a legitimate well-plugging credit requires.

The full bench includes a landman who understands title, mineral rights, and the regulatory landscape. A regulatory specialist. A safety professional. A field crew that includes a plugging specialist. Degreed petroleum engineers covering production. And the geological context that grounds the modeling in actual reality.

That is not a large team by oil and gas standards but in the carbon market, it is almost unheard of. Which brings me neatly to the part of this conversation that has to be said directly.

The rating agencies

A rating agency with expertise in nature-based solutions is not necessarily equipped to evaluate an orphan well plugging project. Those are different project types with different field conditions, different hazard profiles, and different technical requirements. A strong rating in one space does not translate to a credible rating in the other.

True rigor when evaluating a well project requires field presence, industry know-how, and site-specific context. A desk review of a well-plugging methodology alone is a grossly incomplete evaluation.

Getting the wrong expertise to rate these projects is not just a problem for individual buyers, it is dangerous to the integrity of the entire market. A rating that signals quality where quality has not been truly demonstrated misleads every buyer who relies on it and ultimately undermines the credibility of every legitimate project in the space. We should all be aware of this risk.

The people and the land

I will end my list where the work actually ends, which is not with the credit, but with the land itself.

Orphan wells sit on someone’s land. Often that someone has lived next to a leaking, neglected well for years or decades, keenly aware of its affect on the soil, the water, and the air around their home or their ranch. The plugging of that well and its subsequent restoration, which not all developers do, is the full lifecycle of returning something valuable that was taken from the landowner when an operator disappeared.

The field workers who approach that well deserve a safety culture that treats their lives as non-negotiable, and the landowner deserves a restoration process that goes beyond simply plugging. At Rebellion, that work is done in partnership with SnapLands, a group that brings land stewardship expertise that turns a plugged well site into a recovering native landscape.

And last but not least, the mineral owner deserves to have their rights understood and respected. I wrote about this last week, but it bears repeating: a project that ignores the mineral owner’s stake is legally exposed.

A project that gets all of this right (safety, measurement, modeling, restoration, stakeholder relationships) is a project that holds up. When scrutiny comes, and in this market it will as it always does, those are the projects that survive it.

So, I encourage you to ask: who is doing the work?

Ask for the full bench! Ask for names and disciplines and site experience. Ask whether the rating team has stood on a well site like the ones they are evaluating. Ask what the project does for the land and the people on it after the plug is set.

The orphan well market is having its moment, let’s make sure everyone actually know what they are doing.