A new oil and gas reporting bill, Senate Bill 1281, sponsored by State Senator Fran Pavley, was signed by Governor Brown on September 25, 2014.  The California Department of Conservation – Division of Oil, Gas and Geothermal Resources (“DOGGR”) issued a Notice to Operators containing important information on the new law’s reporting mandates on December 8, 2014.

Under Senate Bill 1281, Section 3226.3 was added to the Public Resources Code and requires the State Oil and Gas Supervisor to provide an annual inventory report of all unlined oil and gas field sumps to the State Water Resources Control Board and Regional Water Quality Control Boards.

Section 3227 of the Public Resources Code was also amended to require operators of wells to provide a monthly and quarterly statement disclosing the following information:

  • The source and volume of water produced from each oil field
  • The water used to generate or make up the composition of any injected fluid or gas
  • The volume of untreated water suitable for domestic or irrigation purposes
  • The treatment of water and use of treated or recycled water in activities, such as exploration, development, and production
  • The disposition method of all water used in or generated by oil and gas field activities – including water produced from each well reported
    • Also the identity of any temporary onsite storage of water and the ultimate specific use, disposal method or method of recycling, or reuse of the water

For each reporting requirement, if water is commingled, it must be assigned proportionately to each well.

DOGGR has provided an interim water reporting form on its website for use until February 2015, at which time a final version of the form will be made available.

The following requirements remain unchanged in Public Resources Code section 3227:

  • The owner of any well shall file a statement at the end every month with the Supervisor of the Oil and Gas Division, containing the following information:
    • Amount of oil and gas produced from each well,
      • along with the gravity of the oil,
      • amount of water produced
      • number of days during which fluid was produced from each well
    • Number of wells owned or operated by the person that are drilling, producing, injecting, or idle
    • Disposition of gas produced from each field:
      • if gas was delivered, identify names of persons
    • disposition of water production from each field, along with amount of fluid or gas injected into each well used for enhanced recovery, underground storage of hydrocarbons, or wastewater disposal
  • Producers who use mining or other unconventional techniques for oil production must also file an annual report, on or before March of each year, disclosing the amount of oil produced by these techniques.

For additional information regarding the new reporting requirements, contact Michael N. Mills (michael.mills@stoel.com) or Juliet H. Cho (juliet.cho@stoel.com).

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Photo of Mike Mills Mike Mills

Mike Mills is an experienced environmental attorney who represents his clients in complex regulatory, compliance and litigation matters. His scientific background in environmental toxicology, as well as his contacts within California’s state regulatory agencies, make him ideally suited to provide effective and practical…

Mike Mills is an experienced environmental attorney who represents his clients in complex regulatory, compliance and litigation matters. His scientific background in environmental toxicology, as well as his contacts within California’s state regulatory agencies, make him ideally suited to provide effective and practical solutions to environmental, regulatory and sustainability challenges that his clients confront.

Mike is a former co-chair of the firm’s Energy and Natural Resources Industry Group, and his deep connections within California’s oil and gas industry span over two decades. Oil and gas clients appreciate Mike’s experience as they manage business growth and risks in the challenging regulatory environment in which they operate in California.

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