BILL ANALYSIS                                                                                                                                                                                                    

                                                                  SB 4
                                                                  Page 1

          Date of Hearing:  July 1, 2013

                                Wesley Chesbro, Chair
                      SB 4 (Pavley) - As Amended:  June 25, 2013

           SENATE VOTE :  28-11
          SUBJECT  :  Oil and gas:  well stimulation

           SUMMARY  :  Establishes a comprehensive regulatory program for oil  
          and gas well stimulation treatments (e.g., hydraulic  
          fracturing), which includes, among other things, a study, the  
          development of regulations, a permitting process, and public  
          notification and disclosure. 

           EXISTING LAW  :

          1)Requires DOGGR to supervise the drilling, operation,  
            maintenance, and abandonment of wells and the operation,  
            maintenance, and removal or abandonment of tanks and  
            facilities attendant to oil and gas production, including  
            certain pipelines that are within an oil and gas field, so as  
            to prevent, as far as possible, damage to life, health,  
            property, and natural resources; damage to underground oil and  
            gas deposits from infiltrating water and other causes; loss of  
            oil, gas, or reservoir energy, and damage to underground and  
            surface waters suitable for irrigation or domestic purposes by  
            the infiltration of, or the addition of, detrimental  

          2)Requires the operator of any well, before commencing the work  
            of drilling the well, to file with DOGGR a written notice of  
            intention to commence drilling.  Prohibits the commencement of  
            drilling until approval is given by DOGGR.  If DOGGR fails to  
            give the operator written response to the notice within 10  
            working days from the date of receipt, requires that failure  
            to be considered an approval of the notice.

           THIS BILL  :

           1)Well Stimulation Treatment.   Defines "well stimulation  
            treatment" as a treatment of a well designed to enhance oil  
            and gas production or recovery, including hydraulic fracturing  
            and acid well stimulation, but not including steam flooding,  


                                                                  SB 4
                                                                  Page 2

            water flooding, or cyclic steaming. Defines "hydraulic  
            fracturing" as a well stimulation treatment that, in whole or  
            in part, includes the pressurized injection of hydraulic  
            fracturing fluid (i.e., fluid mixed with physical and chemical  
            additives) into an underground geological formation in order  
            to fracture, or with the intent to fracture, the formation,  
            thereby causing or enhancing the production of oil or gas from  
            a well.  Defines "acid well stimulation treatment" as a well  
            stimulation treatment that uses, in whole or in part, the  
            application of one or more acids to the well or underground  
            geologic formation with the intent to cause or enhance the  
            production of oil or gas from a well.  

           2)Study.   On or before January 1, 2015, requires the Secretary  
            of the Natural Resources Agency to have a comprehensive  
            independent scientific study conducted on well stimulation  
            treatments.  Requires the scientific study to evaluate the  
            hazards and risks that well stimulation treatments pose to  
            natural resources and public, occupational, and environmental  
            health and safety.  Requires the Secretary of the Natural  
            Resources Agency to notify the Legislature on the progress of  
            the study starting April 1, 2014 and every four months  
            thereafter until the study is completed.

           3)Regulations.   On or before January 1, 2015, requires DOGGR, in  
            consultation with the Department of Toxic Substances Control  
            (DTSC), the State Air Resources Board (ARB), the State Water  
            Resources Control Board (SWRCB), the Department of Resources  
            Recycling and Recovery (Cal Recycle), and any local air  
            districts and regional water quality control boards in areas  
            where well stimulation treatments may occur, to adopt rules  
            and regulations specific to well stimulation treatments.   
            Requires these regulations to include (1) revisions to the  
            rules and regulations governing construction of wells and well  
            casings to ensure the integrity of wells, well casings, and  
            the geologic and hydrologic isolation of the oil and gas  
            formation during and following well stimulation treatments,  
            and (2) full disclosure of the composition and disposition of  
            well stimulation fluids as specified.

           4)Delineating Regulatory Authority.   On or before January 1,  
            2015, requires DOGGR to enter into formal agreements with  
            DTSC, ARB, SWRCB, Cal Recycle, and any local air districts and  
            regional water quality control boards in areas where well  
            stimulation treatments may occur, that clearly delineate  


                                                                  SB 4
                                                                  Page 3

            respective authority, responsibility, and notification and  
            reporting requirements associated with well stimulation  
            treatments and well stimulation treatment-related activities,  
            including air and water quality monitoring, in order to  
            promote regulatory transparency and accountability. 

           5)Well Stimulation Treatment Permit.   Requires the operator of  
            an oil and gas well who wishes to perform well stimulation  
            treatments to first apply for a permit with DOGGR to conduct  
            such treatments.  Requires the permit to include the well  
            identification number and location; the time period during  
            which the treatment is planned to occur; an estimate of the  
            amount of water to be used in the treatment and its source;  
            specific information related to the chemicals used in the  
            treatment; the planned location of the treatment on the well  
            bore; the estimated length, height, and direction of the  
            induced fractures; the location of existing wells, including  
            plugged and abandoned wells, that may be impacted; a  
            groundwater monitoring plan; and a waste and waste water  
            disposal plan.

           6)Pre-Well Stimulation Treatment Notification.   

             a)   Within five business days of issuing a permit to perform  
               a well stimulation treatment, requires DOGGR to provide a  
               copy of the permit to the appropriate regional water  
               quality control board(s) and to the local planning entity  
               where the well, including the subsurface portion, is  

             b)   Within five business days of issuing a permit to perform  
               a well stimulation treatment, requires DOGGR to post the  
               permit on a publicly accessible portion of its Internet Web  

             c)   Requires DOGGR to provide a copy of the approved well  
               stimulation permit and information on the water sampling  
               and testing available through the regional water quality  
               control board (see #7 below) to every tenant of the surface  
               property and every surface property owner whose property  
               line location is within a 1,500 foot radius of the wellhead  
               or within 500 feet from the horizontal projection of all  
               subsurface portions of the designated well to the surface.   
               Allows well stimulation treatment to commence 30 days after  
               the permit copies are provided to the appropriate surface  


                                                                  SB 4
                                                                  Page 4

               property tenants and owners.

             d)   Requires the operator of the oil and gas well to provide  
               DOGGR at least 72 hours' notice prior to the actual start  
               of the well stimulation treatment in order for DOGGR to  
               witness the treatment.

           7)Water Quality Sampling.   Requires the regional water quality  
            control board or its contractors to perform water quality  
            sampling and testing if requested by a property owner who  
            receives a well stimulation treatment notice.

           8)Post-Well Stimulation Treatment Disclosure.   Within 60 days  
            after the cessation of well stimulation treatment, requires  
            the operator of the oil and gas well to post to an Internet  
            Web site designated or maintained by DOGGR and accessible to  
            the public, all of the well stimulation fluid composition and  
            disposition information required to be collected, including  
            well identification number, well location, and collected water  
            quality data.  Requires DOGGR to have its Internet Web site  
            operational on or before January 1, 2016.  Requires DOGGR's  
            Internet Web site to organize the reported information in a  
            format, such as a spreadsheet, that allows the public to  
            easily search and aggregate each type of information required.  
             Authorizes DOGGR to direct reporting to in the  
            interim.  Requires DOGGR to allow the public to search and  
            sort the well stimulation and related information by at least  
            the following criteria: (1) geographic area; (2) additive; (3)  
            chemical constituent; (4) Chemical Abstract Service number;  
            (5) time period; and (6) operator.

           9)Trade Secrets.   Allows a supplier of well stimulation  
            chemicals to claim trade secret protections for the chemical  
            composition of additives; however, the supplier must still  
            provide the trade secret information to DOGGR.  Requires a  
            supplier to substantiate a trade secret claim, which is  
            reviewed by DOGGR.  If the supplier legitimately claims a  
            trade secret, requires the supplier to publicly disclose where  
            trade secret information has been withheld and provide  
            substitute information as specified.

            If DOGGR receives a request for release of the trade secret  
            information to the public, requires DOGGR to notify the  
            supplier of the request and give the supplier 60 days to  
            commence a court action to prohibit the release of  


                                                                  SB 4
                                                                  Page 5


            Allows disclosure of trade secret information to a government  
            officer or employee in connection with his or her official  
            duties or to a contractor with a government entity if, in the  
            opinion of DOGGR, disclosure is necessary and required for  
            satisfactory performance of a contract or to protect health  
            and safety.

            Authorizes disclosure of trade secret information to a health  
            professional if the health professional has a reasonable basis  
            to suspect all of the following:

             a)   The information is needed for purposes of diagnosis or  
               treatment of a patient;

             b)   The patient being diagnosed or treated has been exposed  
               to one or more chemicals subject to trade secret  
               nondisclosure; and 

             c)   Knowledge of the specific chemical identity of the  
               chemical or chemicals will assist in diagnosis or treatment  
               of the patient.

            To protect public health, requires a supplier to provide trade  
            secret information to a health professional, toxicologist, or  
            epidemiologist who is employed in the field of public health  
            and who provides a written statement of need and  
            confidentiality agreement.  Requires the written statement of  
            need to include the public health purpose and the reason the  
            disclosure of the specific chemical and its concentration is  
            required in lieu of information describing the properties and  
            effects of the chemical.

           10)Annual Reports.  Requires annual public reports from DOGGR  
            containing data and information on well stimulation as  

           11)Penalties.   Authorizes a civil penalty between $10,000 to  
            $25,000 per day against a person who violates the well  
            stimulation requirements in this bill.

           12)Fee Authority.   Subject to appropriation by the Legislature,  
            authorizes DOGGR's fee authority to be used to fund a public  
            entity's costs associated with well stimulation treatments  


                                                                  SB 4
                                                                  Page 6

            including scientific studies required to evaluate the  
            treatment, inspections, and any air and water quality  
            sampling, monitoring, and testing.

           FISCAL EFFECT  :  Unknown.  A number of substantive amendments  
          have been made to the bill since the Senate Appropriations  
          Committee analysis.

           COMMENTS  :

           First of Its Kind.   In a white paper developed last year by the  
          Natural Resources Defense Council (NRDC), NRDC stated that "no  
          state can boast a comprehensive disclosure rule [regarding  
          hydraulic fracturing]."  NRDC concluded that adequate hydraulic  
          fracturing rules should contain the following key elements: (1)  
          prior notice of hydraulic fracturing to landowners and  
          residents, and disclosure of the chemicals to be used, at least  
          30 days before fracking commences; (2) complete disclosure  
          concerning the geological and environmental context of the well;  
          (3) chemical identification of all substances used in fracking,  
          including the Chemical Abstract Service numbers and actual  
          concentrations; (4) disclosure of other important information  
          about the hydraulic fracturing treatment, including the volume,  
          source, and type of the base fluid, the maximum pressure used, a  
          record of all annulus pressures, and the fracture length; (5)  
          information concerning the waste generated, its contents, and  
          the methods of waste storage and disposal; (6) requirement that  
          confidential information is provided to state regulators and a  
          process for the public to challenge confidentiality claims; and  
          (7) immediate access for medical professionals and first  
          responders to confidential information in order to diagnose and  
          treat patients.

          SB 4 contains essentially all the key elements outlined by NRDC  
          as well as additional requirements, such as ground water  
          monitoring plans and water quality sampling.  Moreover, this  
          bill applies to all forms of well stimulation (e.g. acid well  
          stimulation treatment), not just hydraulic fracturing.  Industry  
          statements suggest that acidization may be more important to the  
          development of the unconventional reserves in California's  
          Monterey Shale than fracking.  For example, in a November 2010  
          interview with the Oil & Gas Financial Journal, former Venoco  
          Inc. CEO (now Executive Chairman) Tim Marquez said, "[w]e think  
          our primary completion method will be big acid jobs" in the  
          Monterey Shale.


                                                                  SB 4
                                                                  Page 7

          With all of this considered, and in the words of the California  
          League of Conservation Voter's support letter for this bill, "if  
          passed, SB 4 would be the first of its kind..."

           Background on Well Stimulation.   According to the Western States  
          Petroleum Association (WSPA), hydraulic fracturing (a.k.a.  
          fracking) is a form of well stimulation used to obtain oil and  
          natural gas in areas where those energy supplies are trapped in  
          rock (i.e., shale) or sand formations.  Once an oil or natural  
          gas well is drilled and properly lined with steel casing, fluids  
          are pumped down to an isolated portion of the well at pressures  
          high enough to cause cracks in shale formations below the  
          earth's surface. These cracks or fractures allow oil and natural  
          gas to flow more freely.  Often, a propping agent such as sand  
          is pumped into the well to keep fractures open.

          In many instances, the fluids used in hydraulic fracturing are  
          water-based. There are some formations, however, that are not  
          fractured effectively by water-based fluids because clay or  
          other substances in the rock absorb water.  For these  
          formations, complex mixtures with a multitude of chemical  
          additives may be used to thicken or thin the fluids, improve the  
          flow of the fluid, or even kill bacteria that can reduce  
          fracturing performance.

          Another form of well stimulation is called acid matrix  
          stimulation, which involves the injection of acid-such as  
          hydrochloric or hydrofluoric-into an oil and gas well to create  
          or enhance channels for the oil and gas.  Unlike hydraulic  
          fracturing, acid matrix stimulation injection pressures are not  
          high enough to fracture the formation.

          In 2005, Congress enacted what is colloquially referred to as  
          the "Halliburton Loophole," which exempts hydraulic fracturing  
          (except when involving the injection of diesel fuels) from the  
          federal Safe Drinking Water Act.  As a result of this action,  
          the U.S. Environmental Protection Agency (US EPA) lacks the  
          authority to regulate hydraulic fracturing activities that do  
          not use diesel fuel as an additive.

          Around the same time that Congress exempted hydraulic fracturing  
          from the Safe Drinking Water Act, the country experienced a boom  
          in the production of shale oil and gas.  From 2007 to 2011,  
          shale oil production increased more than fivefold, from  


                                                                  SB 4
                                                                  Page 8

          approximately 39 million barrels to about 217 million barrels,  
          and shale gas production increased approximately fourfold, from  
          1.6 trillion cubic feet to 7.2 trillion cubic feet.  This  
          increase in production was driven primarily by technological  
          advances in horizontal drilling and hydraulic fracturing that  
          made more shale oil and gas development economically viable.

          But with this boom comes various issues with regard to  
          environmental health and safety, which has caused enormous  
          public anxiety.  Cases of environmental contamination attributed  
          to hydraulic fracturing have been reported in Wyoming, Texas,  
          Colorado, West Virginia, and Pennsylvania.  Consequently,  
          governments at all levels across the country are looking to  
          regulate the practice and address these concerns.

          The risks associated with shale oil and gas development.    
          According to a recent report from the U.S. Government  
          Accountability Office (GAO), which is an independent,  
          nonpartisan agency that works for Congress, "[d]eveloping oil  
          and gas resources?poses inherent environmental and public health  
          risks, but the extent of risks associated with shale oil and gas  
          development is unknown, in part, because the studies we reviewed  
          do not generally take into account potential long-term,  
          cumulative effects."  The GAO's report categorizes the  
          environmental risks into the four major categories: air quality,  
          water quantity, water quality, and land and wildlife.

          With regard to air quality, the risks are "generally the result  
          of engine exhaust from increased truck traffic, emissions from  
          diesel-powered pumps used to power equipment, intentional  
          flaring or venting of gas for operational reasons, and  
          unintentional emissions of pollutants from faulty equipment."   
          The GAO report also explains how silica sand, a proppant  
          commonly used in hydraulic fracturing, and storing fracturing  
          fluids and produced waters in impoundments can cause air quality  
          issues.  Silica sand, if not properly handled, can become  
          airborne, lodge into a person's lungs, and cause silicosis,  
          which is an incurable lung disease.  Impoundments (i.e., ponds)  
          containing fracturing fluids and produced waters (i.e., the  
          water produced when oil and gas are extracted from the ground)  
          pose a risk because the evaporation of the fluids has the  
          potential to release contaminants into the atmosphere.

          With regard to water quantity, water is used for well drilling  
          operations to make drilling mud as well as to cool and lubricate  


                                                                  SB 4
                                                                  Page 9

          the drill bits.  Water is also the primary component of  
          hydraulic fracturing fluids.  According to the GAO, "the amount  
          of water used for shale gas development is small in comparison  
          to other water uses, such as agriculture and other industrial  
          purposes.  However, the cumulative effects of using surface  
          water or ground water at multiple oil and gas development sites  
          can be significant at the local level, particularly in areas  
          experiencing drought conditions."  It should be noted that the  
          oil and gas industry and DOGGR both assert that the amount of  
          water used for hydraulic fracturing in California is a fraction  
          of what is used in other states.  This assertion is based on  
          information voluntarily provided by oil and gas operators.  It  
          is not clear whether this information is representative of all  
          hydraulic fracturing in the state.  Additionally, with the  
          potential for an oil boom in the Monterey Shale (which is  
          explained in more detail below), it would be too speculative to  
          determine the type and amount of well stimulation that will take  
          place in the future and how much water will be needed.

          With regard to water quality, the GAO explains that shale oil  
          and gas development pose risks from contamination of surface  
          water and ground water as a result of spills and releases of  
          hydraulic fracturing chemicals, produced water, and drill  
          cuttings.  Spills and releases of these materials can occur as a  
          result of tank ruptures, blowouts, equipment or impoundment  
          failures, overfills, vandalism, accidents, ground fires, or  
          operational errors.

          The potential for the spill and release of chemicals involved in  
          hydraulic fracturing has received a great amount of public  
          attention.  According to a recent congressional report, between  
          2005 and 2009, oil and gas companies throughout the United  
          States used hydraulic fracturing products containing 29  
          chemicals that are known or possible human carcinogens;  
          regulated under the Safe Drinking Water Act for their risk to  
          human health; or listed as hazardous air pollutants under the  
          Clean Air Act.  As for produced water, it can carry a range of  
          contaminants, including hydraulic fracturing chemicals, salts,  
          metals, oil, grease, dissolved organics, and naturally occurring  
          radioactive materials.  Drill cuttings (i.e., the broken bits of  
          solid material removed from drilling) may contain naturally  
          occurring radioactive materials, as well.

          The potential for underground migration is also a potential risk  
          to water quality.  The GAO explains that "[u]nderground  


                                                                  SB 4
                                                                  Page 10

          migration can occur as a result of improper casing and cementing  
          of the wellbore as well as the intersection of induced fractures  
          with natural fractures, faults, or improperly plugged dry or  
          abandoned wells.  There are also concerns that induced fractures  
          can grow over time and intersect with drinking water aquifers."   
          It should be noted that the oil and gas industry has provided  
          information claiming that hydraulic fracturing typically occurs  
                                                              thousands of feet below the earth's surface and that the well  
          casing for these wells extends below an impervious layer of rock  
          "that would prevent any migration of fluids up into the drinking  
          water supply."  Assuming that the industry is correct, there is  
          still the problem with well casing failures.  A 2000 Society of  
          Petroleum Engineers article regarding an oil field in Kern  
          County explained that "the well failure rate, although lower  
          than that experienced in the 1980s, is still economically  
          significant at 2 to 6% of active wells per year."  In  
          Pennsylvania, poor cementing around a well casing allowed  
          methane to contaminate the water wells of 19 families.   
          Moreover, little data exists on fracture growth in shale  
          formations following multistage hydraulic fracturing over an  
          extended time period; the frequency with which refracturing of  
          horizontal wells may occur; the effect of refracturing on  
          fracture growth over time; and the likelihood of adverse effects  
          on drinking water aquifers from a large number of hydraulically  
          fractured wells in close proximity to each other.

          With regard to land and wildlife, the GAO explains that  
          "clearing land of vegetation and leveling the site to allow  
          access to the resource, as well as construction of roads,  
          pipelines, storage tanks, and other infrastructure needed to  
          extract and transport the resource can fragment habitats?[which]  
          increases disturbances?, provides pathways for predators, and  
          helps spread nonnative plant species."  Noise, the presence of  
          new infrastructure, and spills of oil, gas, or other toxic  
          chemicals are other risks that can negatively affect wildlife  
          and habitat.  There is also the issue of earthquakes and  
          hydraulic fracturing.  According to the GAO report, well  
          injections, especially the injection of produced water, have  
          been connected to seismicity.

          Ideally, the environmental risks referenced above would be  
          analyzed by the lead agency under CEQA.  However, according to a  
          complaint in a recent lawsuit filed against DOGGR by a number of  
          environmental groups, the agency has been "approving permits for  
          oil and gas wells after exempting such projects from  


                                                                  SB 4
                                                                  Page 11

          environmental review or? issuing boilerplate negative  
          declarations finding no significant impacts from these  

           Well Stimulation in California.   According to the oil and gas  
          industry, hydraulic fracturing has been used in California for  
          decades.  The industry claims that over 90% of hydraulic  
          fracturing occurs in Kern County, in areas with no potable  
          water, no surrounding population, and no other significant  
          business interests.  However, reports from various sources  
          suggest that hydraulic fracturing in California will likely  
          increase significantly in the upcoming years, spreading to areas  
          throughout the state.

          A recent report from the University of Southern California (USC)  
          explains that "California boasts perhaps the largest deep-shale  
          reserves in the world.  Those reserves exist within the Monterey  
          Shale Formation, a 1,750 square mile swath of mostly underground  
          shale rock that runs lengthwise through the center of the state,  
          with the major portion in the San Joaquin Basin."  The U.S.  
          Energy Department estimates that the Monterey Shale contains  
          more than 15 billion barrels of oil, accounting for  
          approximately two-thirds of the shale-oil reserve in the United  
          States.  Additionally, according to a 2008 paper published by  
          the Society of Petroleum Engineers, "it is believed that  
          hydraulic fracturing has a significant potential in many  
          Northern California gas reservoirs."

          DOGGR, although having statutory authority to regulate well  
          stimulation, has not yet developed regulations to address the  
          activity.  As explained below, the agency is currently focused  
          on developing regulations that require oil and gas operators to  
          take certain protective measures and provide information about  
          hydraulic fracturing operations.  Additionally, as referenced  
          above, DOGGR may not be conducting adequate environmental review  
          through the CEQA process to determine if there are significant  
          impacts from hydraulic fracturing.

           DOGGR's Draft Regulations.   On December 28, 2012, DOGGR released  
          a pre-rulemaking discussion draft of regulations on hydraulic  
          fracturing-this draft does not address other forms of well  
          stimulation, such as acid matrix stimulation.  The proposed  
          hydraulic fracturing regulations attempt to impose requirements  
          on operators aimed to improve transparency and safety.   
          Specifically, the proposed regulations would require an operator  


                                                                  SB 4
                                                                  Page 12

          to (1) submit information to DOGGR at least 10 days prior to  
          beginning hydraulic fracturing operations and notify DOGGR at  
          least 24 hours prior to commencing hydraulic fracturing  
          operations (advance disclosure of hydraulic fracturing chemicals  
          is not required); (2) prior to operations, test the structural  
          integrity of wells and casings to prevent fluid migration; (3)  
          store and handle hydraulic fracturing fluids in a specified  
          manner; (4) monitor a specified set of parameters during  
          hydraulic fracturing operations and, in case a breach occurs,  
          terminate operations and immediately notify DOGGR about the  
          breach; (5) after the conclusion of operations, monitor wells  
          for up to 30 days and maintain data for a period of 5 years; and  
          (6) disclose data to a Chemical Disclosure Registry (such as  
 that is not a trade secret, unless a health  
          professional submits a written statement of need stating that  
          the trade secret information will be used for diagnosis or  
          treatment of an individual exposed to hazardous hydraulic  
          fracturing chemicals and the health professional also executes a  
          confidentiality agreement.

          These proposed regulations will be vetted through a year-long  
          formal rulemaking process beginning the summer or fall of 2013.   
          In the meantime, DOGGR has conducted public workshops in Los  
          Angeles and Sacramento about the proposed regulations, with more  
          planned in California cities like Bakersfield and Santa Maria  
          through July 2013.

           Suggested Amendments and Developing Issues.  

           The committee and author may wish to consider amendments that  
          allow DOGGR's fee authority to fund the development and  
          implementation of the multi-agency formal agreement required in  
          this bill to regulate well stimulation treatments.   While this  
          may be implied in the bill's current fee authority language, it  
          would be best to expressly state this to ensure that the  
          regulatory agencies have adequate funding to perform their  
          duties under the bill.

          In addition, there are on-going discussions about ensuring the  
          most scientifically accurate and effective methods to conduct  
          ground water monitoring.  While this bill provides ground water  
          monitoring plans and allows surface land owners to require water  
          quality sampling and testing, there may be better ways to  
          establish water quality baselines and to detect water  
          contamination.  Preliminary discussions have occurred between  


                                                                  SB 4
                                                                  Page 13

          the author's office, committee staff, and the administration to  
          explore these alternatives.  

          Similarly, there are on-going discussions with regard to  
          strengthening the trade secret language in the bill.  


          Alameda County Water District
          American Lung Association
          Association of California Water Agencies
          California Association of Professional Scientists
          California Coastal Protection Network
          California League of Conservation Voters
          Citizens for Responsible Oil & Gas
          City of Malibu
          City of Moorpark
          City of Oxnard
          City of Ventura
          Clean Coalition
          Clean Water Action
          Environmental Defense Center
          Environmental Defense Fund
          Environmental Working Group
          League of Women Voters of California
          Los Angeles Community College District
          Los Angeles County Board of Supervisors
          Natural Resources Defense Council
          Nature Conservancy
          Paw Pac
          San Francisco Baykeeper
          Santa Cruz County Board of Supervisors
          Senator Gil Cedillo, 22nd District (retired)
          San Fernando Valley Young Democrats
          South Coast Air Quality Management District
          Ventura County Board of Supervisors

          American Chemistry Council
          Black Women for Wellness (unless amended)


                                                                  SB 4
                                                                  Page 14

          California Business Properties Association
          California Chamber of Commerce
          California Department of Finance
          California Independent Petroleum Association
          California Manufacturers & Technology Association
          Center for Biological Diversity (unless amended)
          Center for Environmental Health (unless amended)
          Center for Race, Poverty and the Environment (unless amended)
          Citizens Coalition for a Safe Community
          Del Amo Action Committee (unless amended)
          Environmental Health Coalition (unless amended)
          Esperanza Community Housing Corporation (unless amended)
          Food & Water Watch
          Just Transitions Alliance (unless amended)
          Los Angeles Community Action Network (unless amended)
          Physicians for Social Responsibility - Los Angelese (unless  
          Physicians for Social Responsibility - Sacramento (unless  
          Science and Environmental Health Network (unless amended)
          Sierra Club California
          Southwest California Legislative Council
          Western States Petroleum Association
          Worksafe (unless amended)
          1 Individual

          Analysis Prepared by  :  Mario DeBernardo / NAT. RES. / (916)