L E T T E R F R O M C H I E F F I N A N C I A L O F F I C E R

\[Address to Regional Administrator of every Region in which injection
wells for which financial responsibility is to be demonstrated through
the financial test are located.\]

I am the chief financial officer of \[name and address of firm\]. This
letter is in support of this firm=s use of the financial test to
demonstrate financial assurance, as specified in subpart F of 40 CFR
part 144.

\[Fill out the following four paragraphs regarding injection wells and
associated cost estimates. If your firm has no injection well that
belong in a particular paragraph, write ANone@ in the space indicated.
For each injection well, include its EPA Identification Number, name,
address, and current plugging and abandonment cost estimate.\]

1\. This firm is the owner or operator of the following injection wells
for which financial assurance for plugging and abandonment is
demonstrated through the financial test specified in subpart F of 40 CFR
part 144. The current plugging and abandonment cost estimate covered by
the test is shown for each injection well: \_\_\_\_\_\_\_\_\_\_\_\_\_.

2\. This firm guarantees, through the corporate guarantee specified in
subpart F of 40 CFR part 144, the plugging and abandonment of the
following injection wells owned or operated by subsidiaries of this
firm. The current cost estimate for plugging and abandonment so
guaranteed is shown for each injection well: \_\_\_\_\_\_\_\_\_\_\_\_\_.

3\. In States where EPA is not administering the financial requirements
of subpart F of 40 CFR part 144, this firm, as owner or operator or
guarantor, is demonstrating financial assurance for the plugging and
abandonment of the following injection wells through the use of a test
equivalent or substantially equivalent to the financial test specified
in subpart F of 40 CFR part 144. The current plugging and abandonment
cost estimate covered by such a test is shown of each injection well:

\_\_\_\_\_\_\_\_\_\_\_\_\_.

4\. This firm is the owner or operator of the following injection wells
for which financial assurance for plugging and abandonment is not
demonstrated either to EPA or a State through the financial test or any
other financial assurance mechanism specified in subpart F of 40 CFR
part 144 or equivalent or substantially equivalent State mechanisms. The
current plugging and abandonment cost estimate not covered by such
financial assurance is shown for each injection well:
\_\_\_\_\_\_\_\_\_\_\_\_\_.

This firm \[insert Ais required@ or Ais not required@\] to file a Form
10K with the Securities and Exchange Commission (SEC) for the latest
fiscal year.

The fiscal year of this firm ends on \[month, day\]. The figures for the
following items marked with an asterisk are derived from this firm=s
independently audited, year-end financial statements for the latest
completed fiscal year, ended \[date\].

\[Fill in Alternative I if the criteria of paragraph (f)(1)(i) of
\'144.63 of this chapter are used. Fill in Alternative II if the
criteria of paragraph (f)(1)(ii) of \'144.63 of this chapter are used.\]

**Alternative I**

1\. (a) Current plugging and abandonment cost
\$\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

> \(b\) Sum of the company=s financial responsibilities under 40 CFR

Parts 264 and 265, Subpart H, currently met using the financial test

> or corporate guarantee \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
>
> \(c\) Total of lines a and b \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\*2. Total liabilities \[if any portion of the plugging and abandonment
cost is

included in total liabilities, you may deduct the amount of that portion

> from this line and add that amount to lines 3 and 4.\]
> \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\*3. Tangible net worth \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\*4. Net worth \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\*5. Current assets \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\*6. Current liabilities \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\*7. Net working capital \[line 5 minus line 6\]
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\*8. The sum of net income plus depreciation, depletion and amortization
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\*9. Total assets in U.S. (required only if less than 90% of firm=s
assets are

> located in U.S.) \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

[Yes]{.underline} [No]{.underline}

10\. Is line 3 at least \$10 million? \_\_\_\_\_ \_\_\_\_\_

11\. Is line 3 at least 6 times line 1(c)? \_\_\_\_\_ \_\_\_\_\_

12\. Is line 7 at least 6 times line 1(c)? \_\_\_\_\_ \_\_\_\_\_

\*13. Are at least 90% of firm=s assets located in the U.S.? If not,
complete

line 14. \_\_\_\_\_ \_\_\_\_\_

14\. Is line 9 at least 6 times line 1(c)? \_\_\_\_\_ \_\_\_\_\_

15\. Is line 2 divided by line 4 less than 2.0? \_\_\_\_\_ \_\_\_\_\_

16\. Is line 8 divided by line 2 greater than 0.1? \_\_\_\_\_ \_\_\_\_\_

17\. Is line 5 divided by line 6 greater than 1.5? \_\_\_\_\_ \_\_\_\_\_

**Alternative II**

1\. (a) Current plugging and abandonment cost \$
\_\_\_\_\_\_\_\_\_\_\_\_

> \(b\) Sum of the company=s financial responsibilities under 40 CFR
> Parts 264 and
>
> 265, Subpart H, currently met using the financial test or corporate
> guarantee \_\_\_\_\_\_\_\_\_\_\_\_

\(c\) Total of lines a and b \_\_\_\_\_\_\_\_\_\_\_\_

2\. Current bond rating of most recent issuance of this firm and name of
rating service. \_\_\_\_\_\_\_\_\_\_\_\_

3\. Date of issuance of bond \_\_\_\_\_\_\_\_\_\_\_\_

4\. Date of maturity of bond \_\_\_\_\_\_\_\_\_\_\_\_

\*5. Tangible net work \[if any portion of the plugging and abandonment
cost estimate

is included in Atotal liabilities@ on your firm=s financial statements,
you may add

> the amount of that portion to this line.\] \_\_\_\_\_\_\_\_\_\_\_\_

\*6. Total assets in U.S. (required only if less than 90% of firm=s
assets are located

> in U.S.) \_\_\_\_\_\_\_\_\_\_\_\_

[Yes]{.underline} [No]{.underline}

7\. Is line 5 at least \$10 million? \_\_\_\_\_ \_\_\_\_\_

8\. Is line 5 at least 6 times line 1(c)? \_\_\_\_\_ \_\_\_\_\_

\*9. Are at least 90% of the firm=s assets located in the U.S.? If not,
complete line 10. \_\_\_\_\_ \_\_\_\_\_

10\. Is line 6 at least 6 times line 1(c)? \_\_\_\_\_ \_\_\_\_\_

I hereby certify that the wording of this letter is identical to the
wording specified in 40 CFR 144.70(f) as such regulations were
constituted on the date shown immediately below.

\[Signature\]

\[Name\]

\[Title\]

\[Date\]