Tonight the Ojai City Council has the following item on their agenda:
And in response to that letter, Citizens For Responsible Oil and Gas (who will be presenting to the City of Ojai tonight - agenda item #8 at the meeting which begins at 7:00 p.m.) issued the letter posted below.
To: Rob Clark, Ojai City Manager
On Tuesday, Citizens for Responsible Oil and Gas, will encourage the Ojai City Council to approve a measure asking Ventura County to postpone a hearing regarding new oil wells off of Koenigstein Road in Upper Ojai.
Update: BREAKING: CFROG members interviewed on video by Supervisor, Steve Bennett & his staff member Steve Offerman, video will be posted soon on County website.
Story in the Ojai Valley News CLICK HERE
On January 7, Planning Director Kim Prillhart sent a letter to Ojai City Manager, Rob Clark:
This morning at 10:00 a.m. Ventura County Planning is holding the Planning Director hearing for a request from TEG Oil and Gas USA Incorporated (here is information from earlier this year about TEG being purchased by Hawker Energy, and the plans for the TEG assets).
TEG has applied for a modification to their Conditional Use Permit for "continued operation of existing oil and gas facility." located at or near 4142 E. Guiberson Road, Piru.
PL15-0070 - the requested changes is an extension for an additional 30 years to CUP 1994-2. The permit is set to expire on December 15, 2015. "Existing oil and gas operations will remain unchanged. No additional wells or structure or changes in boundaries are being proposed as part of this permit.
The planning director hearing is the first opportunity for the public to comment on the project and to mention concerns or issues the County should consider when examining the applicants request.
Citizens for Responsible Oil and Gas (CFROG) is expected to be present to submit comments on the project. Written comments which have been submitted to the County from CFROG include:
- "CFROG suggests a shorter term both to protect the nearby streams, rivers and wetlands from catastrophic failure and to allow regulators to impose needed and mandated greenhouse gas reductions. " The written statements refer to this weeks California Supreme Court decision regarding the Newhall Ranch Development, which stated "there was a failure to fully study and reduce the impact of Green House Gases from the proposed Newhall Ranch Development," according to CFROG.
The court decision stated the Environmental Impact Report (for the Newhall project) did not measure "the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional or local plan for the reduction or mitigation of greenhouse gas emissions. Such requirements must be adopted by the relevant public agency through a public review process and must reduce or mitigate the projects incremental contribution of greenhouse gas emissions."
CFROG believes this ruling has an impact on this TEG application, and others with County Planning.
The Center for Biological Diversity, Citizens for Responsible Oil and Gas and Los Padres ForestWatch have announced they are filling a joint lawsuit today against the County of Ventura for their failure to properly study environmental impacts of a recently approved project to add 19 new oil wells at existing oil fields along the Punchbowl hiking trail in Santa Paula Canyon behind Thomas Aquinas College.
The groups are being represented by Hermosa Beach based law firm Chatten-Brown & Carstens. The groups have exhausted the county appeal process and are now asking the courts to halt the project until full environmental review is conducted.
“Everyone knows oil and water don’t mix,” says Ileene Anderson, a senior scientist with the Center for Biological Diversity., “The last thing endangered steelhead, recovering California condors and downstream farms and homes need is an oil spill. Ventura County ought to be protecting these incredible places, not turning them over to become industrial oil sites.”
California Resources Corporation (formerly Vintage Petroleum) a spin off of Occidental Petroleum, requested a modification of their Conditional Use Permit, allowing them to extend their permit for another 30 years, and add the 19 new oil wells over that time. The groups say it has been too long since the last environmental study was conducted and the conditions have changed in the canyon enough to warrant a new study.
Here is the complaint filed Tuesday, November 17 with Ventura County Superior Court:
Ventura County Planning now reports all zoning clearance approvals in the County. These reports includes simple conversions of rec rooms to living space, swimming pools, stone walls and oil wells.
These approvals are done with no public notice, no public hearing.
parcel # 6150020015
Conditional Use Permit 23
Location: Torrey Canyon Oil Field, North of the City of Simi Valley
California Resources Corporation granted a zoning clearance to drill one oil and gas well "Torrey 118." Exact location of the well will be verified when DOGGR issued Notice of Intent to Drill. Drilling will take about 45 to 60 days, 24 hours a day, 7 days a week.
"CUP 23 has no well quantity restrictions"
That permit covers "approximately 218 active and idle wells" operated by CRC.
The CUP expires on Oct. 28, 2033.
The County reports all conditions of the permit are being met at this time.
Conditional Use Permit 26
Location: South Mountain Oil Field,
California Resources Corporation granted request to drill one oil and gas week on existing pad in the Santa Paula lease.
The CUP covers about 169 active and idle wells.
CUP 26 "has no well quantity restrictions" and "does not have an expiration date"
County reports all permit conditions are being met at this.
According to well records with the State this well sustained a leak in 2012. Records state "packer is leaking. Packer must be repaired and casing." That document is dated May, 3, 2012. A handwritten note in the record states "No survey conducted because actively leaking backside when injecting, Seneca will re-work then resurvey, oil is generated from backside." Then there is a document/report showing repair work was completed on November 11, 2012. All tubing was replaced. Then the DOGGR inspected signed off on the well on April 4, 2013.
The record also contains a notice from DOGGR in Dec. 2011 notifying Seneca the well is noted as Active in the records, but the company has failed to report the injection pressures as required. Then before that in July of 2010, DOGGR had sent another document to Seneca notifying them the mechanical integrity test (MIT) survey as required was "overdue." The record does contain emails from an engineer with Seneca dated May 2009, where he states tests are being scheduled and he confirms which tests are required. He notes that this well requires a "water injection survey."
The record shows in 1991 there were issues with the hydrostatic pressure and the well was to be shut in by Jan. 1 1992. Other information in the well involves fresh water in the area.
The well record also contains documents showing at that time notices were printed in the local paper when a well was going to be converted. The notice was to seek public comment and input
Here is the letter dated Oct. 15 regarding the permanent closure of the injection wells:
Top state oil and gas regulator says to notify Sacramento of any deficiencies seen in coordination with local Ventura County agencies. Putting transparency and oversight at the forefront of their Renewal Plan, the California Division of Oil, Gas and Geothermal Resources (DOGGR) is aimed at fixing recognized gaps in oversight of oil and gas operations in the State.
“The Division (DOGGR) hasn’t owned up to its responsibility as regulator in the past,” said Steven Bohlen, State Oil and Gas Supervisor with DOGGR. He said DOGGR is “now moving towards doing that.”
The renewal plan is subtitled “Changing past practices to usher in a new era of oil and gas regulations.” Bohlen also said the local district deputies “work hard to maintain contact” with the local governing bodies who issue the land use permits and zoning approvals for oil and gas activity in cities and counties. Bohler said he has seen evidence of DOGGR District 2 (Ventura County) Deputy, Bruce Hesson, working closely with the Ventura County Planning department, he said “but if deficiencies are seen in that local coordination, bring that to our attention.”
“The Renewal Plan is an ongoing, four year effort to correct past problems and to create a regulatory program that ensures public health and the environment are protected while we produce oil in California,” said David Bunn, Director of the Department of Conservation (DOC). DOGGR is a division of the DOC.
Bohler and Bunn emphasized some aspects of the plan are in progress, and may take a few years to fully implement. According to the Renewal Plan document presened to the Legislature there are four main themes DOGGR will be focusing on as it revamps it’s regulatory procedures – “regulatory overhaul, new regulations for new realities, modernized data management, ensuring a high quality workforce.”
The internal audit was conducted as mandated by Senate Bill 855, which required a report be presented each January until 2015. The last time the report was provided was 2011. This report includes the “past due” data and pursuant to SB 55 focuses on the Underground Injection Control (UIC) program operated by DOGGR.
DOGGR regulates Class II injection wells in the State. These wells are used to inject fluids “associated with oil and natural gas production operations.” According to the DOGGR website “most of the injected fluid is brine that is produced when oil and gas are extracted from the earth.” These wells can be designed as disposal wells only, simply to dispose of that produced water, or to enhance oil and gas production from a nearby well. In Ventura County there are about 400 injection wells under private operation and one commercial injection disposal well located in Oxnard.
One aspect of the Renewal Plan is to ensure the project approval letters (PAL) issued by DOGGR, which govern the operation of injection wells, are complete.
“Project Approval Letters are supposed to be all inclusive about what is and what is not allowed in each project,” said Bohlen. The internal audit found these PAL’s often lacked “clarity as what operations were approved and under what conditions the project is required to operate.”
The audit also identified gaps in regulations pertaining to permitting and enforcement, inadequate staffing, poorly organized records, inconsistent permitting, monitoring and enforcement of well construction and operation. And it found the need for updated “methods to ensure injected fluids are confined to a project area,” and not leaking into geologic zones not targeted by the project.
This renewal plan is presented in the wake of a RICO racketeering lawsuit filed by Kern County farmers and residents naming former heads of DOGGR and the Governor. The lawsuit claims those named created an Enterprise aimed at helping the industry get done, what they wanted to get done, and setting public health and environmental protection aside. Mark Nechodom, the former head of the DOC, is named in the suit. He resigned the day after the suit was filed in June of this year. Here is more information on that lawsuit and a link to the full complaint is at the bottom of the story: http://globenewswire.com/news-release/2015/06/03/741916/10137097/en/Kern-County-Group-Files-RICO-Lawsuit-Against-Governor-and-Oil-Companies.html
“We analyzed past and present regulation of underground injection and find that the permitting unit – which was created over 50 years go – has struggled and sometimes failed to embrace a transparent enforcement process. We need change,” said Bunn. “Our Renewal Plan goes beyond fixing the problems of the past and creates and adaptive, effective program that puts first California’s public safety and environmental health.”
The plan document can be viewed at: ftp://ftp.consrv.ca.gov/pub/oil/Publications/Renewal%20Plan%2010-08-2015.pdf
The report letter:
On Wednesday at 4:00 and then on Thursday at 2:00 Ventura County Planning is processing two different applications for Mirada Petroleum of Santa Paula. They are a relatively small oil and gas operator with a few dozen wells in and around the Upper Ojai Valley.
Project 1- LU15-0060 (Nesbitt lease) Mirada has applied to "reactivate" three wells they promised to abandon in 2013 (and for use of K road). Abandoning those wells was a condition of a permit they were granted (in 2013) for more wells in another spot.
That scoping hearing for a Subsequent EIR is set for
Wednesday, October 7 at 4:00 pm
in the Santa Cruz Conference Room
at the Government Center on Victoria.
NO decision is made at this meeting. Here is a link to the info on that meeting/project:
link to notice of preparation and scoping hearing: http://www.ventura.org/rma/planning/pdf/nop/PL15-0060_NOP_KB.pdf
Link to CUP from 2013, with Condition 27 showing wells MUST be abandoned : http://vcportal.ventura.org/rma/planning-archives/pdf/meetings-agendas-archives/PD/2013/04-25-2013/LU11-0041.pdf
Project 2: PL13-0158 (Agnew Lease) Mirada has applied for three new wells, one redrill of an existing well, 25 more years, and use of Koenigstein Road.
The Planning Director hearing is set for
Thursday, October 8 at 2:00 pm.
in Santa Cruz Conference Room
at County Government Center
staff report: http://www.ventura.org/rma/planning/pdf/meeting%20agendas/PD/2015/10-08-15_KB_PL13-0158.pdf
The County planner for both projects is Kristina Boero, she can be contacted at: firstname.lastname@example.org, ph# 805/654-2467
In early September 2015 the California Department of Conservation announced they were levying civil penalties of $4,500 on each of the 30 oil and gas operators who are active in the State and failed to report water usage as required under new rules from SB 1281.
The full list of all 30 operators is posted below.
While most of the operators are located in the Bakersfield area, three operate in Ventura County.
SB 1281 by Sen. Fran Pavley (27th District) "requires operators to submit on a quarterly and well by well basis about 250 pieces of data related to the water used" in their oil and gas production. This includes the source of water used, any treatment, and the ultimate disposal of the water. The first reporting was released in August and is available HERE for public information.
According to the press release issued on Sept. 3 The Division of Oil, Gas and Geothermal Resources (DOGGR) may issue larger penalties on companies who continue to fail to meet reporting deadlines.
433 operators are registered as active in California and are required to report this information. Of that number 329 "attempted to comply." But only 242 operators provided complete and "compatible" data. DOGGR is working with those operators who tried to comply but had issues with properly formatting their data.
Operators in 2014 brought up more than 205 million barrels of oil and with that 3.3 BILLION (with a B) barrels of water. A barrel is about 43 gallons. That produced water is trapped underground with the oil and gas, and when brought up must be separated from the oil and gas, and then disposed of.
Below is a list of the 30 operators who have been fined -
The California Department of Conservation is holding a series of public workshops as part of the rule making process regarding the state Underground Injection Control (UIC).
Next THURSDAY, September 10, 9:00 am to Noon
2055 Harbor Boulevard
Below is the Press Release dated September 4
DEPARTMENT OF CONSERVATION SETS WORKSHOPS
FOR UNDERGROUND INJECTION REGULATIONS
SACRAMENTO – The California Department of Conservation (DOC) will conduct three workshops this month to receive public input on plans to update oil and gas regulations. The regulations implement the Division of Oil, Gas, and Geothermal Resources’ Underground Injection Control (UIC) Program.
“We are making a concerted effort to bring our UIC Program into full compliance with the federal Safe Drinking Water Act to ensure public health and safety and environmental protection,” State Oil & Gas Supervisor Steven Bohlen said. “These workshops are part of an informal, pre-rulemaking process to update the regulations.”
The workshop schedule is as follows:
Los Angeles -- September 9, 1-4 p.m., Ronald Reagan State Building, 300 S. Spring Street Suite 1726.
Ventura – September 10, 9 a.m.-noon, Beach Marriott, 2055 Harbor Boulevard.
Bakersfield – September 15, 1-4 p.m., Four Points by Sheraton, 5101 California Avenue.
The Division also is inviting written input about the issue (more background can be foundhere). Comments can be mailed to the Department of Conservation, Attention: UIC Workshop, 801 K St. MS 24-02, Sacramento, CA, 95814. The Division strongly encourages comments to be submitted by September 15. Comments submitted at a later date will be considered for the development of draft regulations if time permits. The Division’s intent is to commence a formal rulemaking process by the end of this year or the beginning of 2016. Additional comment periods and public hearing will be a part of the rulemaking process.
The Division will provide a brief presentation regarding the UIC Program and its goals for this rulemaking at each workshop, but the primary purpose of the meetings is to receive input from the public on the six major regulatory goals outlined in the discussion paper linked above:
♦ Clarifying the standards for ensuring zonal isolation of injection projects (zonal isolation means keeping various materials, such as oil and groundwater, separated).
♦ Expressly defining the quality of water to be protected when constructing wells.
♦ Codifying best practices for well construction.
♦ Establishing permitting and regulatory requirements specific to cyclic steam operations.
♦ Establishing requirements specific to cyclic steam in diatomite formations. This effort will include a regulatory framework for responding to surface expressions (oil leaking to the ground’s surface) and clarification regarding injection above fracture gradient (that is, at a high enough pressure to break the surrounding rock in the underground formation).
♦ Clarifying the process and standards for establishing maximum allowable surface pressure for injection operations.
Members of the public who wish to be on the mailing list for UIC-related rulemakings can utilize the following link to join: http://www.conservation.ca.gov/index/Pages/MailingLists.aspx.