American Oil and Gas Reporter - May 2016 - 89

ConventionSection: California Independent Petroleum Association
Under current law, if an operator appeals an agency's order to shut in an injection well, the appeal operates as a
stay-unless it qualifies as an emergency
order-and injections are allowed to continue. SB 2756 removes the automatic
stay.
Thomas says the legislation also would
remove an operator's ability to document
government actions by prohibiting electronic recordings of appeals and emergency
order hearings. "DOGGR is saying it
doesn't want two records. From CIPA's
perspective, the more information, the
better," he counters.
Zierman adds that market conditions
should constitute a significant factor in
the state's political calculations. "In this
low-price environment, a small group of
legislators is pretending that oil is still
$100 a barrel and the state can pass expensive new regulations willy-nilly. CIPA
has been beating the drums on the fact
that industry is on its back, and costly
and unnecessary new regulations do not
make sense," he says.

from DOGGR to SWRCB.
"AB 1882 would result in long delays
for operators. Every day an operator is
not producing is a day of wages and production lost. This bill also delays the operations of any contractor," Thomas assesses. "AB 1882 has no additional regulatory nor environmental benefits. It
doesn't enhance oversight or accountability
within the UIC program. It does create
paperwork logjams and impedes DOG-

GR's ability to move projects that, in its
professional opinion, are viable and do
not negatively impact drinking or irrigation
water sources."
❒

Coming In June
The Official Convention Section
for KOGA's annual meeting, to be
held July 19-21 in Covington, Ky.

Underground Injection
Williams also is the author of AB
1882, which would require the State
Water Resources Control Board (SWRCB)
and designated regional water quality
control boards to review, comment on
and propose additional requirements on
all applications for aquifer exemptions,
Thomas says. He points out the proposed
bill is a repeat of AB 356, which Williams
sponsored in 2015. That bill failed to
gain enough support to pass out of the
California Assembly.
The new bill comes after the U.S. Environmental Protection Agency's audit
of DOGGR's Class II UIC program in
2010. That audit concluded the state had
allowed injections into aquifers that qualified as drinking water sources, but that
had not yet been exempted. DOGGR
later stated its intent to bring its UIC
program into compliance with the Safe
Drinking Water Act (AOGR, July 2015,
pg. 20).
While SWRCB now submits comments
on UIC projects, the legislative website
notes the board is requesting additional
information on some projects, and indicates it will work with DOGGR to incorporate groundwater monitoring requirements on others. AB 1882 also seeks to
codify joint reviews of UIC projects under
review, which the website says is an alternative to transferring the UIC program
MAY 2016 89

American Oil and Gas Reporter - May 2016

Table of Contents for the Digital Edition of American Oil and Gas Reporter - May 2016