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Navigating the California Environmental Permitting Maze — Applying Lessons Learned from Various State Regulatory Agencies to Save Time and Money

Miyazaki, Brent *1
(1) AECOM, Los Angeles, CA.

Complying with environmental regulations represents potentially costly and time consuming efforts for the oil and gas industry. Permit applications and agency reviews may result in substantial project implementation delays. There are opportunities to apply lessons learned that “streamline” the process and reduce the permitting effort required.

In California, the Division of Oil, Gas and Geothermal Resources (DOGGR) regulates oil and gas field operations and practices. This regulatory oversight includes compliance with broad range of state laws and regulations, including the California Environmental Quality Act (CEQA). As with most regulatory compliance in California, the process continues evolving to address new issues and concerns. In addition, changes within DOGGR over time affects regulatory compliance requirements.

There is a long history of successfully permitting energy infrastructure project in California through other applicable state regulatory agencies, such as the California Public Utilities Commission (CPUC) and California Energy Commission (CEC). Both CPUC and CEC require that environmental assessment documents are filed with applications for new projects. These processes are well established and provide numerous examples of challenges and potential solutions to reducing permitting delays.

Lessons learned from preparing permit applications for CPUC and CEC provide potentially useful tools to address current DOGGR application requirements. These tools, including programmatic approaches, could dramatically reduce permit application and review time, thus resulting in substantial cost savings. Programmatic approaches are applicable to a wide range of activities, from injection well permit applications to and developing potential new “plays” such as the Monterey Shale.

For example, preparing a Program Environmental Impact Report (EIR) would meet CEQA requirements and allow for simple approval of many small projects with similar aspects and impacts. Following certification of the Program EIR, these projects could be approved with a simple Negative Declaration (ND) or Mitigated Negative Declaration (MND). Site specific application information required utilizing this approach is dramatically reduced, thus saving time, money and frustration.


AAPG Search and Discovery Article #90142 © 2012 AAPG Annual Convention and Exhibition, April 22-25, 2012, Long Beach, California