Oklahoma Corporation Commission Orders 347 Disposal Wells to Prove Non-Contact with Basement Rock After Earthquake Surge

In April 2015, after years of earthquake increases that scientists conclusively linked to wastewater injection from oil and gas operations, the Oklahoma Corporation Commission finally issued directives requiring 92 operators of 347 Arbuckle formation disposal wells to prove their wells were not in contact with granite basement rock. The directive represented the commission’s most aggressive response to date, but came only after Oklahoma’s seismicity had increased from 41 earthquakes exceeding magnitude 3.0 in 2010 to 903 such earthquakes in 2015—a more than 20-fold increase that transformed Oklahoma into the most seismically active state in the continental United States.

The directives, mailed on March 18, 2015, expanded the definition of “areas of interest”—locations with concentrated seismic activity—and gave operators until April 18 to demonstrate their wells were not injecting wastewater into basement rock, which scientists identified as a major trigger for induced earthquakes. Operators unable to prove compliance faced immediate 50 percent volume reductions. Commission spokesman Matt Skinner estimated the average cost per well for required modifications at approximately $100,000.

Scientific Consensus Versus Industry Denial

By April 2015, scientific evidence overwhelmingly demonstrated that wastewater injection from oil and gas operations caused Oklahoma’s earthquake surge. The U.S. Geological Survey concluded in March 2016 that the primary cause of Oklahoma earthquakes was “pressure on fault lines from cumulative effects of injecting oil drilling wastewater under high pressure underground.” In March 2013, University of Oklahoma seismologist Katie Keranen published peer-reviewed research linking wastewater injection to seismicity.

Despite this scientific consensus, the oil and gas industry publicly downplayed the connection and suggested earthquakes resulted from natural causes. This industry denialism delayed regulatory action for years while earthquakes increased in frequency and magnitude. Only in private meetings did industry representatives acknowledge the scientific evidence, while maintaining public positions that protected their disposal well operations.

Regulatory Capture and Delayed Response

The Oklahoma Corporation Commission, created when Oklahoma became a state specifically to oversee the oil and gas industry, demonstrated clear regulatory capture in its response to induced seismicity. The agency waited until 2015 to take meaningful action despite earthquake increases beginning in 2009 and scientific evidence emerging by 2013. This multi-year delay allowed the industry to continue profitable but earthquake-inducing injection practices while seismic risks to Oklahoma residents escalated dramatically.

The 2011 Prague earthquake, initially measured at magnitude 5.6 and later upgraded to 5.7, injured residents and damaged 200 buildings. Yet the commission’s response remained minimal for years afterward. The agency created an Induced Seismicity Department to monitor the problem but took limited regulatory action to address root causes. Rules implemented in September 2014 merely required more detailed volume and pressure reporting—information gathering rather than risk reduction.

Areas of Interest and the Arbuckle Formation

The April 2015 directives targeted disposal wells injecting into the Arbuckle formation, a deep rock layer underlying most of Oklahoma known for its ability to absorb and hold fluid. This characteristic made the Arbuckle a popular wastewater disposal target for the oil and gas industry. However, in many locations the Arbuckle sits directly on crystalline basement rock. When high-pressure wastewater injection reaches basement rock, it can trigger earthquakes by increasing pore pressure on pre-existing faults.

The commission’s “areas of interest” designation identified regions with elevated seismic activity where disposal well operations posed the highest risks. The 347 wells targeted by April 2015 directives represented only a fraction of Oklahoma’s disposal wells, but were located in zones where earthquake clusters indicated dangerous pressure buildup on basement faults.

Industry-Friendly Implementation

Even the commission’s April 2015 directives reflected regulatory capture through their implementation timeline and industry-favorable terms. Operators received only weeks to demonstrate compliance, but the burden of proof remained weak. Wells found injecting into basement rock could “plug back”—filling wells to shallower depths with cement—rather than shutting down entirely. This allowed continued operations at reduced volumes rather than eliminating the most dangerous disposal wells.

The commission’s approach prioritized maintaining industry profitability over earthquake risk elimination. Complete shutdown of basement-contacting wells would have been the scientifically sound response, but the commission instead allowed continued injection at reduced volumes. This compromise reflected the agency’s primary loyalty to the industry it was created to promote rather than protection of Oklahoma residents facing earthquake risks.

The Coordinating Council on Seismic Activity

In late 2014, Governor Mary Fallin created the Coordinating Council on Seismic Activity, bringing together corporation commission officials, energy industry representatives, and others to discuss seismic issues. Critically, the council operated as a non-public body, holding meetings without transparency or public participation. Many industry representatives who previously rejected scientific evidence linking wastewater injection to earthquakes joined the private council.

This closed-door coordination between regulators and industry exemplified regulatory capture. Rather than holding public hearings where affected citizens could participate, Oklahoma officials conducted seismic policy discussions in private sessions with the very industry causing the earthquake crisis. The arrangement ensured industry input shaped policy while excluding public voices demanding stronger protections.

Pattern: Profits Until Crisis Forces Action

Oklahoma’s induced seismicity crisis followed a familiar pattern where industry profits take precedence over public safety until crisis conditions force minimal regulatory response. From 2009 through 2014, earthquakes increased exponentially while the Corporation Commission gathered data but took little action. Only after earthquake rates reached crisis levels—903 magnitude 3.0+ events in 2015—did the commission impose meaningful restrictions.

This delayed response allowed oil and gas operators to maximize disposal well profits for years while transferring earthquake risks and damages to Oklahoma property owners and residents. The commission’s industry-protective approach meant companies enjoyed full profitability from high-volume wastewater injection until earthquake damages became so severe that regulatory inaction was politically unsustainable.

Limited Effectiveness and Continued Industry Protection

Following the April 2015 directives, more than 50 disposal wells touching basement rock plugged back to shallower depths, and another 150 wells cut volumes in half. These reductions, combined with additional restrictions in subsequent years, eventually decreased Oklahoma’s seismicity rates. However, the commission’s industry-friendly approach meant many dangerous wells continued operating at reduced capacity rather than shutting down entirely.

The commission’s disposal well restrictions proved that wastewater injection caused Oklahoma’s earthquakes—when injection volumes decreased, seismicity declined proportionally. This confirmed what scientists had been saying for years while the commission delayed action. The years of regulatory inaction demonstrated how agency capture by regulated industries can transform preventable public health and safety crises into prolonged disasters driven by profit maximization.