BILL ANALYSIS                                                                                                                                                                                                    



                                                                  SB 550
                                                                  Page  1

          SENATE THIRD READING
          SB 550 (Florez)
          As Amended  August 20, 2010
          Majority vote

           SENATE VOTE  :26-11  
           
           NATURAL RESOURCES   6-2         APPROPRIATIONS      12-0        
           
           ----------------------------------------------------------------- 
          |Ayes:|Chesbro, Brownley, De     |Ayes:|Fuentes, Bradford,        |
          |     |Leon, Hill, Huffman,      |     |Huffman, Coto, Davis, De  |
          |     |Skinner                   |     |Leon, Gatto, Hall, Norby, |
          |     |                          |     |Skinner, Solorio,         |
          |     |                          |     |Torlakson, Torrico        |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Knight, Logue             |     |                          |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :  Beginning January 1, 2012, requires an operator to  
          provide the surface rights owner with written notification and  
          legal documentation of any underlying oil, mineral, or gas  
          extraction operation agreement to the owner of the subsurface or  
          mineral rights within 10 days of execution of the agreement.  If  
          the owner of surface property cannot be located or determined,  
          the operator shall provide notice of that agreement by  
          publication.

           EXISTING LAW  :

          1)Requires the Supervisor of the Division of Oil, Gas and  
            Geothermal Resources (DOGGR) in the Department of Conservation  
            (Department) to supervise the drilling, operation, maintenance  
            and abandonment of oil and gas wells, production facilities,  
            and pipelines to prevent damage to life, health, property,  
            underground and surface waters, and natural resources, among  
            other things.

          2)Requires DOGGR to, by regulation, prescribe minimum facility  
            maintenance standards for all production facilities in the  
            state, which may include leak detection, corrosion prevention,  
            tank inspection, valve maintenance, secondary containment, and  
            other standards the Supervisor deems important for proper  
            operation of facilities and to prevent damage to life, health,  
            property, natural resources, groundwater and surface waters.








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          3)Requires a facility operator to file a spill contingency plan  
            at the time of initial production or within three months of  
            acquiring a production facility.

          4)Authorizes the Supervisor to require an operator with a  
            history of violating relevant oil and gas laws or that has  
            outstanding liabilities to the state to require a life-of-well  
            or life-of-production facility bond to ensure the proper  
            plugging and abandonment, safe decommission, financing of  
            spill response and clean-up.

          5)Establishes the Surface Mining and Reclamation Act of 1975  
            which was enacted to ensure the continued economic well-being  
            of the state and to the needs of the society, and that the  
            reclamation of mined lands is necessary to prevent or minimize  
            adverse effects on the environment and to protect public  
            health and safety.  

           FISCAL EFFECT  :  According to the Assembly Appropriations  
          Committee, minor absorbable costs, if any, to the Department.

           COMMENTS  :  There is currently no requirement that an oil and gas  
          exploration company have liability insurance in order to get a  
          permit from DOGGR to drill.  A small bond is required by DOGGR  
          to cover shut-in costs, but the bonds are not "lifetime of  
          facility" bonds and, in any case, the amounts are insufficient  
          to cover the clean-up of a large accident.

          This is very important to the surface rights owner in a  
          situation where the surface and subsurface/mineral rights are  
          owned by different parties and the mineral rights owner engages  
          in hydro-carbon exploration (directly or through a lease).  If  
          an accident occurs (spill, explosion, or groundwater  
          contamination) and the exploration company is insolvent or  
          under-capitalized, the surface owner could not only suffer  
          impairment of their investment in the surface, but also be  
          liable for the clean-up costs.

          According to the Office of Spill Prevention and Response (OSPR),  
          there are over twice as many inland oil spills as there are  
          marine spills, but the state responds to less than one third of  
          all inland spills reported (It is unclear how many spills were  
          from oil and gas operations supervised by DOGGR).  Recently,  
          spills have occurred on the central coast and in Suisun Marsh,  








                                                                  SB 550
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          impacting water supplies and sensitive marsh ecosystems.  In  
          Santa Barbara County, Greka Oil and Gas reportedly has spilled  
          more than 500,000 gallons of oil and contaminated material since  
          2002 due to a failure to adequately maintain its facilities.  In  
          2008 and 2009, OSPR reported 159 and 105 onshore spills (of 42  
          gallons or more), respectively, from oil exploration and  
          production activities most likely in DOGGR's jurisdiction.   
          Collectively, nearly 590,000 and 270,000 gallons of oil, drill  
          waste, or oily/water mixtures were spilled, respectively.  OSPR  
          data do not indicate whether there was a clean-up response, if  
          any, or the damage a spill may have caused.

          The author of this bill is primarily concerned about a scenario  
          in which surface and subsurface development rights are owned by  
          different parties (a common occurrence in the San Joaquin  
          Valley) and the latter party's capacity to shoulder the costs of  
          cleaning up a spill or compensating a landowner for surface  
          damage should it go bankrupt or otherwise be unable to pay.  In  
          this instance, the author is concerned that the costs and  
          liability would then fall to the surface right holder.   
          Additionally, the author is concerned about multiple cases of  
          drinking water contamination across the country due to new  
          drilling techniques like hydraulic fracturing, though it is  
          unclear if the technique is used much in California. 

          Since 1939, the Legislature has required well operators to  
          provide indemnity bonds whenever they drill, redrill, deepen, or  
          otherwise permanently alter a well.  Existing law requires these  
          bonds to secure the state against any losses or expenses it  
          incurs to bring an operator into compliance with all applicable  
          drilling laws and regulations, which include the prevention of  
          damage to life, health, property, underground and surface  
          waters, and natural resources.  Otherwise, unlike offshore  
          drilling or oil transport activities, there is no liability  
          insurance or financial assurance requirement (e.g., a  
          demonstration of the ability to pay any damages caused by a  
          worst-case spill) for onshore operators.

          California ownership of mineral resources was originally granted  
          to the individuals or organizations that owned the surface. In  
          this case, property owners had both "surface rights" and  
          "mineral rights".  A property owner has the freedom to sell,  
          lease, or gift these rights individually or entirely to others.   
          Subsurface mineral rights typically already include oil and gas  
          rights because the term minerals encompasses all hydrocarbons.








                                                                  SB 550
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          This bill requires an operator to notify an owner of surface  
          rights within 10 days of executing any agreement with a drilling  
          company. Given the bifurcation of surface and sub-surface rights  
          in certain areas of the state, the author contends that a  
          surface right owner should at least be notified of such an  
          agreement considering the potential for damage of drilling  
          operations to surface resources or groundwater.  In certain  
          agreements or leases obtained by the author, there is no mention  
          of the obligation to remediate contamination to soil or  
          groundwater.  While a surface right owner may not have any  
          leverage to influence such an agreement, notification, at a  
          minimum is reasonable.  
           

          Analysis Prepared by  :  Jessica Westbrook / NAT. RES. / (916)  
          319-2092 


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