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 a partner and chair of the firm’s Oil & Gas, Pipelines and Mining Industry Team.  Oil & gas, as well as mining companies, look to Mike to skillfully advise them on natural resources development issues, counsel them on federal and…

Mike Mills is a partner and chair of the firm’s Oil & Gas, Pipelines and Mining Industry Team.  Oil & gas, as well as mining companies, look to Mike to skillfully advise them on natural resources development issues, counsel them on federal and state hazardous waste cleanup matters, and help them successfully navigate property tax valuation disputes.

When necessary to protect his clients’ interests, Mike relies on his understanding of complex regulatory matters and his clients’ businesses to defend them in environmental litigation, defeat citizen suit claims, and reduce or eliminate fines and penalties. He has been listed in Northern California Super Lawyer® since 2013 in Environmental Law and Energy & Natural Resources.

Click here for Mike Mills’ full bio.

Photo of Juliet H. Cho Juliet H. Cho

Juliet Cho focuses her practice on land use, environmental due diligence, entitlements, the California Environmental Quality Act (CEQA) permit approval process, municipal law, and land use and environmental litigation. She has engaged in water projects, renewable energy projects, local government projects, and industrial…

Juliet Cho focuses her practice on land use, environmental due diligence, entitlements, the California Environmental Quality Act (CEQA) permit approval process, municipal law, and land use and environmental litigation. She has engaged in water projects, renewable energy projects, local government projects, and industrial and mixed use projects.