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This report was prepared by the Center for Biological Diversity for
Californians Against Fracking and Dangerous Drilling December 2017.
This report is dedicated to the memory of Rosemarie Braz, August 4,
1961-May 3, 2017. As the Center for Biological Diversity’s Climate
Campaign Director and Co-founder of Californians Against Fracking
and Dangerous Drilling, Rose worked passionately to protect
Californians from oil industry pollution.
Design Credits:
Ariel Newman, Rootskeeper
For more information:
Candice Kim
Climate Campaign Director
Center for Biological Diversity
ckim@biologicaldiversity.org
Contents
I. Fracking and Dangerous Drilling in California: An Overview ................................................................ 1
II. Many Governments Have Banned Fracking ............................................................................................ 3
III. Brief History of Unrestricted Fracking and Broken Promises in California ............................................ 4
a. Senate Bill 4, California’s Weak Fracking Law ............................................................................... 5
b. The Statewide Scientific Study and Recommendations from the Panel ........................................... 5
IV. Fracking Fuels the Climate Crisis ............................................................................................................ 6
V. Fracking Threatens the Air We Breathe and Hits Overburdened Communities the Hardest ................... 8
VI. Fracking Threatens the Water We Drink ............................................................................................... 10
VII. Toxic Wastewater From Oil Production Threatens California .............................................................. 11
VIII. Fracking Poses Grave Risks in our Seismically Active State ................................................................ 12
IX. Fracking Threatens California’s Ocean and Coast ................................................................................. 14
X. Oil Money has Bought the Industry Special Treatment at the Expense of Californians........................ 14
XI. A Large Majority of Californians Oppose Fracking .............................................................................. 17
XII. Policy Recommendations ....................................................................................................................... 17
XIII. Californians Against Fracking and Dangerous Drilling Member Groups ............................................. 19
XIV. References .............................................................................................................................................. 22
Page 1
I. Fracking and Dangerous Drilling in California: An Overview
In California, hydraulic fracturing, or fracking, is defined by statute as one of several forms of
“well stimulation,” closely related to new extreme methods of oil and gas extraction.1 More
specifically, fracking is the high-pressure injection of water, proppant, and toxic chemicals into
the ground to crack open rock and release oil or natural gas. Proppants, typically the carcinogen
crystalline silica, are used to keep the newly created fractures open.
Other extreme methods used to extract oil in California include acid fracking, acid matrix
stimulation, and gravel packing. 2
Acid fracking is the injection of acid (usually hydrochloric and
hydrofluoric acid) at pressures high enough to fracture the formation.3 Acid matrix stimulation
injects these same acids but at lower pressures, using the acid to dissolve the formation. Gravel
packing involves placing gravel injected with a chemical mixture near the wellbore to form
filters that help prevent the buildup of sand or other debris and keep fissures in the formation
open.4 It can be combined with fracking for a process known as “frac-pack.”
5 Fracking and other
forms of well stimulation are used both onshore and offshore in state and federal waters.
In California, fracking brings both familiar and unique harms. This is because there are
similarities and differences between fracking in California and fracking in other states like
Texas, North Dakota, Oklahoma, and Pennsylvania. In the Golden State, oil operators use
fracking in three main ways.6
First, oil operators use fracking to target the unconventional shale oil in California’s Monterey
Shale (also known as “tight oil”). This shale oil, like that extracted in North Dakota’s fracking
boom, is distributed throughout fine-grained sedimentary rock and will only flow to the surface
after the rock is blasted apart with fracking. California’s Monterey Shale is more difficult to
develop than shale oil in other parts of the country. Fracking and drilling horizontal wells up to
two miles long can produce oil from North Dakota’s pancake-like layers of shale. California’s
geology is far more complicated, and oil companies have not yet “cracked the code” of the
Monterey Shale to produce it at scale. However, with oil companies experimenting every day
with toxic techniques throughout our state, this could change at any time.
The second major way oil companies use fracking, acidization, and related techniques is to
extract the remaining oil from California’s “conventional” deposits. After more than 150 years of
oil production, the “easy” oil is long gone. The remaining oil tends to be the heaviest, dirtiest,
and hardest to extract. Oil operators employ fracking and the other well stimulation methods as
well as other dangerous techniques like water flooding, steam flooding, and cyclic steam
injection to get the remaining oil.7
The third way that operators use fracking is to aid the storage of natural gas. Since 2001, gas has
been stored in 11 pools – underground reservoirs – near major urban areas in California,8 until
there is sufficient demand for its use. The injection wells are fracked both to increase the rate at
which gas can be injected, and to increase the withdrawal rate.9 The four storage reservoirs in
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which more than half of all new wells are fracked provide about a third of the total gas storage in
the state.10
Fracking introduces harms and risks to our state that are common to fracking booms elsewhere,
including air pollution, drinking water contamination, risk of induced earthquakes, industrial
disturbance, habitat fragmentation, and noise and light pollution. Fracking also poses unique
threats to our state. Unlike other areas where fracking occurs at great depths, much of the
fracking in California is “shallow fracking” and occurs within a few hundred feet or even
directly adjacent to protected underground drinking water.11
According to a key science panel
convened to conduct the first statewide study of the risks of fracking in California, the risk of
water contamination is much greater in our state and shallow fracking should be prohibited,
unless it can somehow be proven safe.12
California also contains a tremendous
amount of “neighborhood drilling”
where oil production occurs in direct
proximity to where people live, work,
and go to school. Millions of people in
California are exposed to dangerous
air pollution from fracking and urban
oil drilling. Moreover, drilling in
California occurs disproportionally in
low income communities of color
already suffering from some of the
worst air quality in the nation, exacerbating our state’s environmental justice problem.13
Other risk factors identified by the science panel include the advanced average age of
California’s wells and infrastructure, high levels of background seismicity, the use of unlined
pits for toxic wastewater disposal, and the use of wastewater to irrigate food crops.14
Each of
these topics is explored further below.
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II. Many Governments Have Banned Fracking
A number of governments around the world and in the United States have banned fracking. 15, 16,
17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28 The following maps show selected countries, states and local
bodies that have such bans. Only the U.S. states and California counties that have banned
fracking are shown. Many governments have imposed strict restrictions on the practice.
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III. Brief History of Unrestricted Fracking and Broken Promises in California
For more than 150 years, oil companies have been allowed to virtually drill at will in California.
The oil industry’s vast wealth and power has won the industry full or partial exemptions from
every federal environmental law, including the Clean Water Act, Resource Conservation and
Recovery Act (RCRA), Toxic Substances Control Act (TSCA), Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA, or Superfund), Safe Drinking Water Act;
Emergency Planning and Community
Right-to- Know Act (EPCRA).29
As Californians became increasingly
alarmed about the harms of fracking, state
regulators attempted to downplay the risks,
at first falsely claiming that fracking
occurs only infrequently in California.30
When pushed for more information, California officials
proclaimed a near total lack of knowledge about and absence of oversight of fracking in our
state.31
Given the total abdication of responsibility by Governor Brown and state regulators, it’s
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not surprising that California ranked dead last in a peer-reviewed study of state fracking
regulations.32
Figure 1: Comparison of Protection and Compliance Indices for State Regulation of
Unconventional Gas Development (Source: Zirogiannis 2016, supra note 32)
In 2013, faced with mounting public concern about the damages of fracking in our state, the
legislature considered and advanced multiple bills that would have banned fracking until and
unless certain conditions were met. In the end, Governor Brown negotiated a deal with the oil
industry for last-minute amendments to Senate Bill 4. This bill then passed the legislature and
was signed into law,33
despite opposition from virtually every conservation and environmental
justice organization in the state.
a. Senate Bill 4, California’s Weak Fracking Law
In passing Senate Bill 4, legislators acknowledged the completely unacceptable lack of
information on and oversight of fracking in California and promised that future decisions about
fracking would be guided by the best available science. To keep this promise, the state
established a scientific panel to complete the first-ever, statewide study of the harms and risks of
fracking in California. Following the study’s completion, the law also required state oil
regulators to prepare an environmental impact report pursuant to our flagship health protection
and community right-to-know law, the California Environmental Quality Act. State oil regulators
were also required to promulgate new fracking-specific regulations. Senate Bill 4’s fatal flaw
was that it authorized state regulators to allow fracking while this work was carried out.
Governor Brown and state regulators then proceeded to ignore and flout multiple provisions of
the law, breaking the promises made to the people and failing to rein in oil industry practices,
leaving Californians unprotected.
b. The Statewide Scientific Study and Recommendations from the Panel
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The statewide scientific study, coordinated by the California Council on Science and
Technology, was the first to evaluate the harms and risks of fracking in the state. It was supposed
to inform all future regulatory action. But the study was not completed by the deadlines set forth
in the law. This delay allowed Brown’s regulators to ram through new rules permitting fracking
to continue with little additional oversight. Regulators issued the new rules without considering
the statewide study, ignoring the Legislature’s intent that the rules would be informed by the
science.
When the statewide study was finally released, it included many critical recommendations from
scientists, including the following:
establishing a health and safety buffer zone around all oil wells, due to the health risks
from the air pollution;34
banning “shallow fracking,” a common practice in California that takes place in close
proximity to drinking water, unless it can be proven safe for water supplies;35
banning the disposal of toxic fracking wastewater into open pits, as other states have
done;36
To date, more than two years after the statewide study was released, none of these
recommendations has been implemented by Governor Brown’s oil regulators or even seriously
considered. The supposed assurance in Senate Bill 4, that future decisions about fracking in
California would be based on science, is a broken promise.
IV. Fracking Fuels the Climate Crisis
The climate crisis is driven primarily by fossil fuel production and combustion. California is the
nation’s third-largest oil-producing state. For decades, the oil companies that have done the most
to fuel climate disruption have been allowed to essentially drill at will in our state. They damage
our air, water and health, as well as our roads and other infrastructure, but do not have to pay for
any of it. To date, Governor Brown has ignored policies to curb California’s oil production and
has instead focused almost exclusively on measures to reduce consumption of oil while allowing
a drilling free-for-all to continue. California cannot help solve the climate crisis or claim climate
leadership unless the state addresses its own oil
production. According to a large body of research, the vast
majority of global and U.S. fossil fuels must stay in
the ground to avoid the worst dangers of climate
change.37
Globally, there are more than enough fossil
fuels in developed production fields to far exceed
targets to limit warming to 1.5°C or even 2°C.38
Thus, new fossil fuel development and infrastructure
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is unsafe and unjustified, and fossil fuel production must be phased out globally within the next
several decades.39
By increasing access to dirty fossil fuels, fracking and other dangerous
techniques worsen our oil dependence and threaten to undermine urgent greenhouse gas
reduction efforts.
Moreover, California produces some of the dirtiest and most climate-polluting oil on the planet.
Much of the remaining oil in California’s largest oil fields is extremely heavy and waterlogged,
making it very energy-intensive to pump out of the ground, make flow, and refine.40
In fact,
three-quarters of California’s oil production is as climate-damaging as Canadian tar sands
crude.41
Fracking is used to extract this climate-damaging oil, in conjunction with other extreme,
dangerous, and energy intensive techniques.
Governor Brown and other California politicians like to pretend that California’s oil production
is unrelated to our greenhouse gas reduction targets, and that the continued carte blanche to the
oil industry is justified by the large amount of oil our state uses for transportation. Nothing could
be further from the truth. The production and consumption of fossil fuels are interdependent, as
explained by economic principles of supply and demand. When oil production rises, prices tend
to fall, demand for and consumption of oil tends to rise, and renewable energy is placed at a
disadvantage. Global oil market economic analyses show that increasing oil production increases
consumption, while leaving oil in the ground decreases global oil consumption.42
The last
decade’s fracking boom caused a vast increase in North American oil production, which crashed
oil prices, stoked demand and consumption, and delayed the transition to renewable energy. The
Energy Information Administration estimates U.S. oil production will hit a record high 9.9
million barrels a day in 2018.43
It is absurd for politicians to pretend that oil policies, production,
and prices are unrelated to our ability to achieve our greenhouse gas reduction targets.
In 2013, twenty of the world’s leading climate scientists urged Governor Brown to halt fracking
in California because it fuels climate change and impedes California’s efforts to reduce
greenhouse gas emissions.44
The signatories included retired NASA climate scientist Dr. James
Hansen of Columbia University, Dr. Michael Mann of Penn State University, Dr. Michael
MacCracken of the Climate Institute, Dr. Ken Caldeira of the Carnegie Institution for Science,
Dr. Anthony Ingraffea of Cornell University, Dr. Paul R. Ehrlich of Stanford University and
other experts. Since that time, the
case to end fracking and dangerous
drilling in California has grown ever
stronger.
As noted above, the science shows
we must phase out fossil fuel
production globally in order to
avoid catastrophic climate
disruption. California is one of the
wealthiest places on the planet, with far greater resources to invest in a rapid clean energy
transition than most other governments of the world. California also produces vast quantities of
Page 8
some of the world’s dirtiest and most carbon-intensive oil. The case is clear that California must
act to reduce oil production within its borders. This must include a ban on fracking and related
techniques, a halt to oil field expansion and new fossil fuel infrastructure, and a rapid phase-out
of all oil and gas production within the next several decades as we complete a just transition to
100 percent renewable energy.
V. Fracking Threatens the Air We Breathe and Hits Overburdened Communities
the Hardest
Oil and gas production, particularly fracking, poses such grave health risks that scientists and
public health officials have recommended that, in the absence of an outright ban, health and
safety buffers be implemented around where people live, work, go to school, or are otherwise
exposed to this air pollution. Within these buffer zones, all oil production activities would be
prohibited.
Hundreds of chemicals are used in fracking and other oil and gas production techniques. More
than 300 different chemicals or chemical mixtures have been reported as being used in fracking
fluids in California.45
With a large volume of additional chemical use hidden under “trade secret”
claims, this number may be far higher.46
Over 90 percent of fracking treatments use chemicals
from the following categories: breakers to lower fracking fluid viscosity before fracking fluid
flows back, proppants to keep newly formed fractures open, gelling agents to pry open fractures,
biocides to prevent bacteria from degrading gelling agents, carriers for aiding in transport of
other fluids, and crosslinkers to increase viscosity of fluids to increase fracking effectiveness.47
Many of these chemicals are categorized as air toxics—also known as hazardous air pollutants—
that can cause serious health effects when inhaled.
Such chemicals, which include a variety of gases known as volatile organic compounds
(“VOCs”), can enter the air during the venting of gases during fracking or the evaporation of
chemicals from fracking and produced fluids, leading to dangerous human exposures. For
instance, ethylbenzene and formaldehyde are both known carcinogens, while methanol is linked
to reproductive harm, and hydrochloric acid and hydrofluoric acid can both cause eye irritation
and respiratory harm.48
Thus, being in the proximity of fracking operations can lead to serious
health effects. Since fracking operations use many of the same chemicals as conventional oil and
gas operations, some of the risks posed by fracking are posed by conventional methods as well.49
Besides risks from chemical additives, there are also emissions risks from other aspects of the
fracking process. For instance, the diesel equipment used to pump the fracking fluids into the
well produces nitrogen oxide (“NOx”) and particulate
matter (“PM”) emissions. Additionally, some VOCs
when exposed to light can transform into PM. When
gases are flared instead of vented, the combustion during
flaring may cause emissions of PM and NOx.50
NOx and
PM are both criteria pollutants regulated by the EPA
under the Clean Air Act. They both contribute to the
formation of ozone, another criteria pollutant.51
Ozone
Page 9
irritates lung tissues, interferes with breathing, and is linked to pneumonia, chronic obstructive
pulmonary disease, asthma, bronchitis, emphysema, and premature death.52
PM can enter a
person’s lungs and bloodstream, leading to respiratory and cardiovascular problems and an
increased risk of death.
Disturbing research findings continue to mount on the health risks of fracking, well stimulation,
and other oil and gas production activities.53
Research has found that people living near drilling
sites have a higher risk for developing cancer,54
increased asthma attacks,55
higher
hospitalization rates,56
and more upper respiratory problems and rashes.57
For pregnant women,
living closer to drilling sites is associated with a higher risk of having babies with birth defects,58
high-risk pregnancies and premature births,59
and low-birthweight babies.60
Millions of people in California are
exposed to air pollution from fracking and
drilling – and environmental justice
communities are hit the hardest. The health
harms from oil production are particularly
alarming because many of California’s
oilfields operate in densely populated
areas.61
Furthermore, drilling in California
occurs disproportionally in low-income
communities of color already suffering from some of the worst air quality in the nation.62
Analysis shows that 5.4 million Californians — 14 percent of the state’s population — live
within a mile of at least one oil and gas well.63
More than a third of these residents (1.8 million)
live in areas heavily burdened by environmental pollution.64
The two largest oil-producing
regions in California — the San Joaquin and South Coast air basins — are notorious for having
harmful levels of ozone65
and PM pollution.66
Moreover, our most vulnerable communities bear an unfair share of fracking and drilling
pollution while simultaneously suffering additional disproportionate impacts from climate
change itself. For example, environmental justice communities in California are more susceptible
to extreme heat events and lack sufficient access to basic necessities and healthcare. 67
It is thus
even more urgent to reduce pollution from fracking and drilling that both makes people sick and
fuels climate change.
To protect public health, California must prohibit oil and gas activities that create an acute
exposure risk for people.68
One of the top conclusions of the California Council on Science and
Technology’s statewide fracking review was that public health and safety buffers should be
considered around all oil and gas wells.69
Multiple studies provide support for this
recommendation, demonstrating that carcinogenic and toxic air contaminants travel two miles or
more from the point of production, and that harms and risks increase as distance from the
production sites decreases.70
For this reason, scientists are increasingly urging the immediate
adoption of such health and safety buffer zones.71
Because of the significant amount of urban drilling in Los Angeles, STAND-LA, an
environmental justice coalition of community groups that seek to end neighborhood drilling, has
Page 10
persuaded the Los Angeles City Council to commission a study of a 2,500 ft buffer zone around
oil and gas wells.72
When fracking was banned in New York in 2014, the Public Health Commissioner, who had
presided over a groundbreaking public health review of fracking, summarized the findings this
way: “I asked myself, ‘would I let my family live in a community with fracking?’ The answer is
no. I therefore cannot recommend anyone else's family to live in such a community either.”73
The people of California deserve as much protection from fracking and dangerous drilling as the
people of New York.
VI. Fracking Threatens the Water We Drink
Fracking poses grave and unique risks to our water supplies. In California, unlike the North
Dakota Bakken Shale or the Texas Eagle Ford Shale, fracking mostly occurs at shallow depths.
This is because much of the oil and gas in California has migrated from source rocks to
shallower formations.74
Our groundwater resources are also concentrated relatively close to the
surface. As a result, fracking in California frequently occurs in close proximity to, and
sometimes directly adjacent to, groundwater, posing a serious contamination risk. Considering
that about three quarters of fracked wells in California are within 600 meters of the ground
surface,75
and many at less than 305 meters below the ground surface,76
fracking may produce
fractures that intersect groundwater and surface water. These fractures are of great concern
because they provide a direct conduit for contamination of our water supplies.77
Many toxic and carcinogenic chemicals used in fracking and oil and gas extraction are water
soluble and pose a great risk to the water we drink. For instance, hydrochloric acid is used to
initiate rock fractures, ethylene glycol is used to prevent scale deposits in pipes, and
glutaraldehyde is used to eliminate bacteria from produced water.78
There are also chemicals that
are directly associated with fossil fuels and produced water, such as the well-studied BTEX
chemicals (benzene, toluene, ethylbenzene, and xylene).79
This suite of chemicals, both from
fracking fluids and fossil fuels, poses threats to virtually all systems of the body including the
sensory, gastrointestinal, immune, reproductive, cardiovascular, endocrine, and nervous
systems.80
Due to the risks of shallow fracking contaminating our groundwater supplies with
Page 11
these chemicals, the California Council on Science and Technology recommended that shallow
fracking be prohibited unless it can be proven safe.81
Finally, where the data exists, they show that the rates of well failure for oil and gas wells overall
are extraordinarily high.82
California regulators do not systematically collect data on well failure
rates in California.
VII. Toxic Wastewater From Oil Production Threatens California
Oil production in California brings vast quantities of water to the surface. This wastewater, also
known as “produced water,” is highly salty and can contain any of the hundreds of different
chemicals used in oil and gas production.83
It can also contain petroleum residue and other
contaminants from underground, including radiation. Produced water typically contains elevated
concentrations of numerous harmful chemicals, including VOCs like benzene, toluene,
ethylbenzene, and xylenes (“BTEX”), polynuclear aromatic hydrocarbons (“PAHs”),
radionuclides, petroleum hydrocarbons, heavy metals like arsenic, and harmful trace elements
like boron.84
Several of these pollutants are carcinogenic85
and persist for long periods of time in
the environment.86
There is no good solution to the problem of the vast quantity of produced water in California.
Much of it is re-injected underground for further oil production, through “enhanced oil recovery”
techniques including water flooding or steam flooding. The rest must be disposed of by some
other means. In California, shockingly, these methods include using it to irrigate food crops,
injecting it into special “waste disposal” wells, and dumping it into open, unlined pits.
Produced water is used to grow citrus fruits, nuts, grapes, root vegetables, and other produce in
the San Joaquin Valley.87
Waste fluid is lightly treated to remove some chemicals before it is
applied to crops. It is impossible, however, to monitor levels of many chemicals in the fluid
because the full list of chemicals that may be present is not disclosed.88
Additionally, the current
standards and testing methods are outdated, and do not account for the hundreds of chemicals
now used in oil extraction operations. There are also huge gaps in our knowledge about how
plants absorb chemicals found in oil wastewater, how soils accumulate chemicals over time, and
how chemicals might interact with each other in agricultural settings. For these reasons, in its
independent scientific study, the California Council on Science and Technology recommended a
ban on irrigating crops with produced water from fracked wells.89
Due to safety concerns regarding fracking chemicals, the State Water Board has not authorized
the use of produced water from fracking for irrigation.90
However, because produced water from
wells that have not been fracked is still typically highly toxic, and can contain many of the same
chemicals as wells that have been fracked, the
Board’s limited restriction only addresses one
part of the problem.91
Another method commonly used to dispose of
oil wastewater is to inject it into underground
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aquifers. The federal Safe Drinking Water Act prohibits injections of oil wastewater into aquifers
that are or may one day be used for drinking water. For decades, despite this prohibition, the
California Department of Conservation, Division of Oil, Gas and Geothermal Resources
(DOGGR) has allowed oil producers to inject oil wastewater into aquifers that are supposed to be
protected.92
To date, DOGGR has identified more than 2,500 wells injecting into non-exempt
aquifers.93
Even when the full scope of DOGGR’s failure to oversee these disposal wells was
revealed in 2015, DOGGR issued regulations allowing oil operators to continue dumping
wastewater into protected aquifers until February 2017.94
When the February 2017 deadline
came, DOGGR announced that it would allow more than 1,650 wells to continue injecting oil
waste into protected aquifers indefinitely.95
A third method of disposing of fracking and other oil wastewater is via percolation pits – open,
unlined pits that allow waste to evaporate and to percolate into the ground, where it eventually
reaches and mixes with groundwater. Although the disposal of fracking waste via percolation pit
is prohibited by regulation,96
it nonetheless continues to this day. The Central Valley Region
Water Quality Control Board has issued an order that it will allow operators to dump fracking
wastewater into unlined pits until 2020.97
Percolation pits have already contaminated several
groundwater resources in the Central Valley.98
Direct physical exposure to the contents of
percolation pits and the inhalation of fumes emanating from percolation pits can be extremely
harmful to humans and wildlife.99
Pit disposal disproportionately impacts low-income and
communities of color in the Central Valley that already suffer an extremely high pollution
burden. 100
California is one of only three states that allows the oil industry to dump toxic wastewater into
open, unlined pits for disposal.101
In response to the dangers that these pits pose to human health,
wildlife, water quality, and the environment, other states have banned this practice.102
The
California Council on Science and Technology has recommended that California follow suit, and
called for an investigation into the legacy effects of dumping oil waste into open pits.103
VIII. Fracking Poses Grave Risks in our Seismically Active State
Many oil and gas industry activities, including fracking, the underground injection of oil and gas
wastewater, enhanced oil recovery, and fluid extraction, can induce earthquakes.104
Earthquakes
induced by these activities are a particular concern for California because of our state’s high
seismic activity and dense network of faults.
Research on fracking-induced earthquakes in California is lacking, but studies in other regions
have linked fracking to induced earthquakes in Ohio,105
Oklahoma,106
British Columbia and
Alberta,107
including quakes ranging up to magnitude 4.6.108
Recent research indicates that
fracking can induce larger earthquakes than previously expected.109
The underground injection of oil and gas wastewater, often associated with fracking, has been
linked to the dangerous proliferation of earthquakes in many parts of the country, including
damaging earthquakes and some of the largest quakes recorded in those regions.110
To date,
induced earthquakes have been linked to wastewater injection in nine states, including
California. Damaging earthquakes induced by wastewater injection include a magnitude 5.8 near
Page 13
Pawnee, Oklahoma, in 2016 that injured one person and caused severe structural damage; a
magnitude 5.7 near Oklahoma City in 2011111
that injured two people, destroyed 14 homes, and
caused millions of dollars’ worth of damage to buildings and infrastructure;112
and a magnitude
5.3 induced near Trinidad, Colorado, in 2011113
and magnitude 4.8 near Timpson, Texas, in
2012114
that caused significant structural damage. A U.S. Geological Survey analysis found that
7 million people in central and eastern states live and work in areas vulnerable to damaging
injection-induced earthquakes.115
In California, recent research has linked earthquakes to wastewater injection. A 2016 study
linked wastewater injection in the Tejon oilfield near Bakersfield with a 2005 swarm of two
earthquakes reaching magnitude 4.7.116
These earthquakes occurred about five miles from the
injection wells linked to the seismic activity. In a related 2015 study, researchers identified at
least three other cases in Kern County where wastewater injection likely induced earthquakes,
including earthquakes greater than magnitude 4.117
The seismologists cautioned: “considering the
numerous active faults in California, the seismogenic consequences of even a few induced cases
can be devastating.”118
Despite these risks, Californians remain unprotected from
the dangers of injection-induced earthquakes. The majority
of California’s active oil industry wastewater injection wells
are very close to faults. A 2014 analysis found that nearly
one-third of active California wastewater injection wells are
within one mile of a fault (350 wells), while half are within
five miles of a fault (808 wells).119
As a result, millions of
Californians in major population centers, such as Los
Angeles and Bakersfield, are living where high densities of wastewater injection wells are
operating near active faults.
High volumes, high pressures, and long duration of wastewater injection can increase the risks of
induced seismicity,120
yet DOGGR continues to allow the oil industry to inject high volumes,
rates, and pressures of wastewater near faults.121
Many of California’s wastewater disposal wells
are injecting at rates associated with an increased risk of induced seismicity (e.g., greater than
100,000 barrels per month),122
and extremely high injection rates of 600,000 barrels per month
are common.123
Wastewater injection volumes in California more than doubled between 2000
and 2015, according to Department of Conservation data.124
More than 38 billion gallons (~917
million barrels) of wastewater were injected into California disposal wells in 2015 alone.125
The
use of extreme, water-intensive oil and gas recovery techniques, such as fracking, waterflood,
and cyclic steam injection, has contributed to this significant rise in wastewater production.
California’s high seismic activity also raises concerns that earthquakes—both natural and
induced—could cause significant damage to oil and gas wells and associated infrastructure. Such
damage could cause devastating leaks and spills that could contaminate water, soil, and air
quality. Oil and gas wells rely on the integrity of the well casing to prevent contamination.
Earthquakes may increase the likelihood of damage to the well casing or cementing, which can
allow contamination of underground sources of drinking through the leakage of hydrocarbons,
fracking and drilling chemicals, and produced water. Research suggests that well casing failures
Page 14
are common.126
A ProPublica nationwide review of injection wells found that between 2007 and
2010, there were 12 cases of groundwater contamination and 63 cases of significant leaks from
injection wells in California.127
However, the extent to which well casing failures are caused or
exacerbated by earthquakes remains unknown because DOGGR fails to track these data.
IX. Fracking Threatens California’s Ocean and Coast
Fracking and well stimulation are also used in the ocean off California’s treasured coast. Oil and
gas operations within three miles of the shore are regulated by the state, while operations more
than three miles out are regulated by the federal government. Oil companies have fracked at least
200 wells in state and federal waters off Long Beach, Seal Beach, Huntington Beach and in the
wildlife-rich Santa Barbara Channel.128
At least 10 fracking chemicals used in offshore fracking
in California could kill or harm a broad variety of marine species, including sea otters and fish.129
Current federal regulations allow oil companies to frack and discharge their wastewater —
including toxic fracking chemicals — into the ocean. Federal regulators instituted a moratorium
on fracking in federal waters in 2016 in response to a lawsuit challenging the government’s
failure to disclose the environmental impacts of fracking. More than 30 of the world’s leading
ocean and climate scientists including Drs. Sylvia Earle, Carl Safina, and Michael Mann urged
the federal government to continue the moratorium.130
Nevertheless, the federal government
lifted the moratorium in late 2016 after conducting a cursory environmental assessment.
Currently, litigation brought by the State of California and environmental groups is ongoing over
the federal government’s inadequate environmental review and decision to allow offshore
fracking to resume.
California regulators allow fracking in state waters subject to the lax requirements developed
under SB4, California’s fracking law. DOGGR, the State Lands Commission, and the California
Coastal Commission have jurisdiction over fracking in state waters. While wastewater discharges
into the ocean are prohibited within state waters,131
the risks of spills, air pollution and
earthquakes remain. Although fracking authorizations in state waters and along the coast are
subject to review by the California Coastal Commission,132
oil companies have in the past failed
to comply with this requirement. Our nearshore waters and coast will remain unprotected until
fracking and drilling are prohibited in state waters.
X. Oil Money has Bought the Industry Special Treatment at the Expense of
Californians
It is no accident that the oil industry has been allowed to drill at will in California. Big oil bought
its special privileges with lavish lobbying expenditures and campaign contributions.
Page 15
In the ten-year period from 2007 to 2016, the oil industry spent almost $133 million on lobbying
in California, and $81 million on campaign contributions in California. In the 2015-2016
legislative session, the oil industry spent $36 million on lobbying expenses and nearly $20
million on campaign contributions in California.133
The Western States Petroleum Association (WSPA) had the highest lobbying expenditure in
California in the 2015-2016 legislative session, at $18.7 million, and spent $62 million between
2007 and 2016. Chevron was the next highest oil lobby spender, having spent nearly $7 million
in the 2015-2016 session and $28 million from 2007 to 2016.134
Page 16
Governor Brown has also been the direct or indirect recipient of a staggering amount of oil
industry cash. As reported by Consumer Watchdog in 2016, “[t]wenty-six energy companies
with business before the state greased the skids via $9.85 million in political donations to
Brown’s gubernatorial campaigns, ballot initiatives, favorite causes such as the Oakland Military
Institute and Oakland School for the Arts, and the California Democratic Party since Brown’s
run for office in 2010, according to campaign reports.”135
While the millions of dollars expended sound like large amounts, they are but a tiny fraction of
the oil industry’s profits. And the expenditures have yielded extraordinary dividends for big oil.
In most other states, the oil industry pays a severance (or production) tax to help pay for the
damage they cause, however, the oil industry makes no such contribution in California, leaving
taxpayers holding the bag.136
In the state legislature, the oil industry routinely exercises its power to block measures that
would protect Californians, including multiple bills that would have limited fracking and the
reckless disposal of oil wastewater. In 2016 the oil industry crushed Senate Bill 350, which
would have cut oil use in vehicles by 50 percent by 2030.137
In 2017 the oil industry demanded
that the cap-and-trade bill, AB 398, include a measure exempting the industry from any
greenhouse gas regulation or limit outside of cap-and-trade.138
Page 17
XI. A Large Majority of Californians Oppose Fracking
A large majority of Californians already oppose fracking. The more people learn about this toxic
practice, the greater the opposition grows. The Public Policy Institute of California surveyed
support for fracking in California in five successive annual polls beginning 2012. As public
awareness of fracking increased over this time period, the number of Californians opposed to
fracking has increased steadily, from 46 percent in 2012 to 58 percent in 2016.139
Similarly,
opposition to more oil drilling off California’s coast grew from 59 to 69 percent between 2016
and 2017.140
XII. Policy Recommendations
California cannot meet its climate goals or protect our health and environment without banning
fracking and phasing out oil production. California must develop a concrete and enforceable plan
to end the state’s oil production within the next several decades.
Key components of this plan must include:
A ban on fracking and related extreme techniques used to extract the state’s most climate-
polluting oil and other reserves that must stay in the ground.
An end to new oil development in the state through a halt on permits for new drilling,
new fossil fuel infrastructure, and oil field expansion.
The creation of a health and safety buffer of at least 2,500 feet prohibiting oil and gas
drilling in communities.
The creation and implementation of a plan to phase out California’s dirty oil production,
starting with fields located in and near California’s most vulnerable communities already
overburdened with pollution.
Page 18
An inventory and elimination of subsidies for oil companies, which incentivize the
production of oil that would otherwise stay in the ground. These funds should instead be
used for the just transition to clean energy.
These key steps are essential components of the just transition to 100 percent clean energy we
urgently need. Without taking these steps, California cannot truly protect the climate or the
state’s most vulnerable communities.
With literally hundreds of laws and policies already in place to address climate change and
protect health and the environment, California has ample legal authority to enact the policy
measures recommended above. Governor Brown lacks the political will, not the legal authority,
to address fracking and dangerous drilling. With the exception of measures to eliminate subsidies
to the oil industry that may require legislative approval,141
the above steps can all be
accomplished through gubernatorial or executive agency action, without the need for new
legislation. The discussion below of the broad existing legal authority to enact the recommended
policy measures is illustrative, not exhaustive.
Multiple laws govern oil and gas operations in California. DOGGR’s most basic regulatory
mandate, pursuant to the California Public Resources Code, is to “prevent, as far as possible,
damage to life, health, property, and natural resources. . . .”142
Banning fracking, establishing
buffer zones around communities to protect public health, and other recommended measures all
clearly prevent damage to life, health, property, and natural resources, and as such fit squarely
within DOGGR’s regulatory mandate.143
Operators must obtain permits from DOGGR before undertaking activities including: drilling a
new well, re-working an existing well, fracking or conducting other well stimulation, conducting
steam injection or other form of enhanced oil recovery, and injecting wastewater underground
for disposal. DOGGR’s issuance of these permits is discretionary. That is, oil and gas operators
have no entitlement to receive a permit. To the contrary, DOGGR must ensure compliance with
all applicable laws, may deny any permit based on DOGGR’s evaluation of the environmental
and safety risks, and must decline to issue a permit if adequate environmental review has not
been conducted or the relevant legal standards for protecting the public have not been met.
Prior to issuing any discretionary permit, DOGGR must comply with the California
Environmental Quality Act (CEQA), our environmental protection and community right-to-know
charter.144
Pursuant to CEQA, DOGGR must fully analyze, disclose, minimize, avoid, and
mitigate all of the environmental impacts of issuing a permit, issuing a group of permits, or
taking other action. DOGGR may not lawfully issue any permit prior to full CEQA compliance,
which provides for public participation and functions as our most basic environmental safety net.
And as noted above, DOGGR may deny any permit on the basis that issuing it would damage
life, health, property, or natural resources.
Page 19
Moreover, under the Public Resources Code, DOGGR has the authority to “order or undertake
the actions he or she deems necessary to protect life, health, property, or natural resources”
where an emergency exists.145
The Governor has broad authority to proclaim a state of
emergency and “make, amend, and rescind” any regulations as needed to address an
emergency.146
This authority applies to circumstances where “extreme peril to the safety of
persons and property within the state caused by such conditions as air pollution . . . drought . . .,
or other conditions, . . . which, by reason of their magnitude, are or are likely to be beyond the
control of the services, personnel, equipment, and facilities of any single county, city and county,
or city and require the combined forces of a mutual aid region or regions to combat . . . .”147
Governor Brown has used his emergency authority on multiple occasions, including to
implement 20 emergency orders related to water usage in response to California’s historic
drought.148
These emergency powers provide an additional layer of legal authority to implement
the recommended policy measures, on top of that provided by California’s environmental and
natural resource laws.
XIII. Californians Against Fracking and Dangerous Drilling Member Groups
Californians Against Fracking and Dangerous Drilling is a coalition of more than 200 environmental
justice, business, health, agriculture, labor, political, faith, food safety and environmental organizations
working to win a statewide ban on fracking and other dangerous oil and gas extraction activities in
California.
350.org 350 Bay Area 350 East Bay 350 Marin 350 Sacramento 350 San Diego 350 San Francisco 350 San Luis Obispo 350 Santa Barbara 350 Silicon Valley AFSCME Council 57 Alameda Creek Alliance Alameda County Green Party Alliance for Democracy/Defending
Water Campaign Alliance of Nurses for Healthy
Environments Asian Pacific Environmental Network
(APEN) Association of Irritated Residents Baldwin Hills Oil Watch
Ballona Creek Renaissance Ballona Network Bay Localize Bees and Beyond Inc. Breast Cancer Action Burbank Green Alliance Butte Environmental Council California Coastkeeper Alliance California Environmental Justice
Alliance California Nurses Association
Cal Poly Biomimicry Club
Cal Poly Plant Science Club
Cal Poly Surfrider Club
California Public Interest Research
Group (CALPIRG)
CALPIRG UCSD
California State Grange
California Student Sustainability
Coalition
California Water Impact Network
Page 20
Californians for Western Wilderness
Californians Who Drink Water
Camp Nast Assocs. (CNA) LLC
Carpinteria Valley Association
Center for Biological Diversity
Center on Race, Poverty and the
Environment
Central California Environmental Justice
Network (CCEJN)
Central Coast Rising
Central Valley Safe Environment
Network
Citizens Action Network
Citizens Against Pollution
Citizens Climate Lobby
Citizens Coalition for a Safe Community
Clark Strategic Partners
Clean Water Now
Coalition for Grassroots Progress
Coalition to Protect San Benito
Coastal Environmental Rights
Foundation
CoFED
Comite Civico del Valle, Inc.
Communities for a Better Environment
Communities for Sustainable Monterey
County (CSMC)
Community Rights Network of
Mendocino County
Courage Campaign
CREDO
Decide Locally Carpinteria
Democracy for America
Earth Passages
Earth Justice Ministries
Earthworks
Ebbetts Pass Forest Watch
Ecological Farming Association
Elder Creek Center For The Land
Environment and Human Rights
Advisory
Environment California
Environmental Action
Environmental Action Committee of
West Marin
Environmental Protection Information
Center
Environmental Voices
Families Against Fossil Fuels
Family Farm Defenders
Food & Water Watch
Food Empowerment Project
Fossil Free UC
Frank Consulting Group
Fresnans Against Fracking
Frack-Free Butte County
Fractivist.org
Friends of the Earth
Friends of the Pogonip
Gage and Gage Productions
Garaventa Consulting
Global Alliance for Incinerator
Alternatives - GAIA
Global Exchange
Gray Panthers of the East Bay
Grayson Neighborhood Council
Green Festivals
Green Party of Alameda County
Green Party of Monterey County
Green Party of San Diego County
Green Planet Films
Green Retirement Plans, Inc.
Greenaction for Health and
Environmental Justice
Greenpeace
Heights Oil Watch
Humanist Association of the Monterey
Bay
Justified Cause
inNative
Klamath Forest Alliance
Klamath Riverkeeper
Klamath Siskiyou Wildlands Center
KyotoUSA
Label GMOs.org
Lasiewicz Foundation
Laytonville Grange
Local Clean Energy Alliance
Los Padres ForestWatch
Making Culver City Safe
Mainstreet Moms
Page 21
Marin Water Coalition
Martin Luther King Coalition of Greater
Los Angeles
Mercedians Against Fracking
Mill Valley Seniors for Peace
Model Neighborhood Program
Monterey County Against Fracking
Mothers of East Los Angeles
Movement Generation Justice &
Ecology Project
MoveOn.org
Mt. Diablo Peace and Justice Center
Naturegraph Publishers
Neighborhood Farmers' Model Markets
Nevada County Climate Change
Coalition
Northcoast Environmental Center
Northern California Recycling
Association
Oil Change International
Orange County Friends of Harbors,
Beaches, and Parks
Orange County Interfaith Coalition for
the Environment
Organic Consumers Association
Physicians for Social Responsibility SF
Planet Cruz Comedy with Richard
Stockton
Planting Justice
Presente.org
Preserve Wild Santee
Progressive Democrats of America
Protect Mustangs
Protect Our Water
Prunedale Preservation Alliance
Public Citizen
Radical Art For These Times (RAFTT)
Rainbow Grocery
Rainforest Action Network
Rootskeeper
Reconnect Nature
Residents Organized for a Safe
Environment (ROSE)
Restore the Delta
Rising Tide Monterey Bay
S.A.F.E. Students Against Fracking the
Environment
San Benito Rising
San Diego County Green Party
San Francisco Tomorrow
San Francisco Baykeeper
San Joaquin Raptor/Wildlife Rescue
Center
San Joaquin Valley Conservancy
San Joaquin Valley Latino
Environmental Advancement Project
San Luis Obispo Clean Water Action
San Luis Obispo Coastkeeper
Santa Barbara County Water Guardians
Santa Barbara "Frack Back" To Save
The Central Coast
Santa Monica Greens
SaveWithSunlight, Inc.
Shaleshock
Sierra Club Loma Prieta Chapter
Sierra Club San Francisco/ Bay Chapter
Don't Frack California
Sierra Club Tehipite Chapter
Small Planet Institute
Solar One
Stewards of the Earth
Stop Fracking Brea
Stop Fracking Long Beach
Students Against Fracking at U.C.
Berkeley
Sunflower Alliance
Sungevity
Tar Sands Action SoCal
Team Zissou Environmental
Organization
Teens Turning Green
The Action Hub
The Orange County Interfaith Coalition
for the Environment
The River Project
Topanga Peace Alliance
Transition Culver City
Transition
Transition San Francisco
Tri-City Ecology Center
Trinity County Progressives
Page 22
Turtle Island Restoration Network
Urban and Environmental Policy
Institute, OccideTrntal College
Union de Vecinos
United Native Americans
Valley Improvement Projects
Wellstone Democratic Renewal Club
Wetlands Defense Fund
WHOW - Whittier Hills Oil Watch
Wholly H2O
Wicked Good Food, LLC
Wild Equity Institute
Wild Heritage Planners
Wild Nature Institute
WiserEarth
Women Occupy San Diego
Women's International League for Peace
and Freedom-US/Earth Democracy
Group
XIV. References
1 Public Resources Code § 3157.
2 Public Resources Code §§ 3157, 3158.
3 California Council on Science and Technology, An Independent Scientific Assessment of Well
Stimulation in California, Vol. I (2015) (“CCST Study, Vol. I”),
http://ccst.us/projects/hydraulic_fracturing_public/SB4.php at 56. 4 South Coast Air Quality Management District rule 1148.2(c)(7).
5 CCST Study, Vol. I at 56-57.
6 Fracking is used also to enable fluid flow in geothermal reservoirs drilled to extract geothermal energy,
to dispose of municipal waste such as brine, digested sludge and wetcake, and experimentally for carbon
dioxide sequestration. See CCST Study, Vol. I at 43. 7 Water flooding involves injecting water into the oil reservoir to cause more oil to flow to the production
well. Steam flooding is similar, but uses steam injected into the reservoir to heat and thin the oil to
increase viscosity so it flows to the production well. Cyclic steaming alternates steam injection and oil
production from a single well. Source: CCST Study, Vol. I at 4. 8 CCST Study, Vol. I at 115-116.
9 Id. at 43.
10 Id. at 115.
11 California Council on Science and Technology, An Independent Scientific Assessment of Well
Stimulation in California, Vol. II (2015) (“CCST Study, Vol. II”),
http://ccst.us/projects/hydraulic_fracturing_public/SB4.php at 121, 406. 12
California Council on Science and Technology, An Independent Scientific Assessment of Well
Stimulation in California, Executive Summary (2015) (“CCST Study, Executive Summary”),
http://ccst.us/projects/hydraulic_fracturing_public/SB4.php at 11. 13
Natural Resource Defense Counsel (NRDC), Drilling in California: Who’s at Risk (2014),
https://www.nrdc.org/sites/default/files/california-fracking-risks-report.pdf (“NRDC Drilling in
California”) at 4; See also Liberty Hill, Drilling Down: The Community Consequences of Expanded
Community Drilling in Los Angeles (2015),
https://www.libertyhill.org/sites/libertyhillfoundation/files/Drilling%20Down%20Report%20-
%20Full.pdf (“Liberty Hill Drilling Down”). 14
CCST Study, Vol. II at 280, 126, 110-111, 114-115, 164.
Page 23
15 Shale gas: Parliament bans the use of hydraulic fracturing, Le Mond.fr, Jun. 3, 2011,
http://www.lemonde.fr/planete/article/2011/06/30/gaz-de-schiste-le-parlement-interdit-l-utilisation-de-la-
fracturation-hydraulique_1543252_3244.html#meter_toaster (last visited Nov. 3, 2017); Jolly, David,
France Upholds Ban on Hydraulic Fracturing, N.Y. Times, Oct. 11, 2013,
http://www.nytimes.com/2013/10/12/business/international/france-upholds-fracking-ban.html (last visited
Nov. 3, 2017). 16
Bulgaria bans shale gas drilling with ‘fracking’ method, British Broadcasting Corporation (BBC), Jan.
19, 2012, http://www.bbc.com/news/world-europe-16626580 (last visited Nov. 3, 2017). 17
Office of the [German] Federal Government, No Fracking in Germany,
https://www.bundesregierung.de/Content/EN/StatischeSeiten/Schwerpunkte/Nachhaltigkeit/2016-07-08-
fracking-gesetz_en.html (last visited Nov. 3, 2017); Gesley, Jenny, Germany: Unconventional Fracking
Prohibited, Library of Congress – Global Legal Monitor, Mar. 8, 2017, http://www.loc.gov/law/foreign-
news/article/germany-unconventional-fracking-prohibited/ (last visited Nov. 3, 2017). 18
O’ Halloram, Marie, Ireland joins France, Germany and Bulgaria in banning fracking, The Irish Times,
Jun. 28, 2017, https://www.irishtimes.com/news/politics/oireachtas/ireland-joins-france-germany-and-
bulgaria-in-banning-fracking-1.3137095 (last visited Nov. 3, 2017). 19
Scottish Government, Scottish Government says no to fracking, https://news.gov.scot/news/scottish-
government-says-no-to-fracking (last visited on Nov. 3, 2017). 20
New York State Department of Environmental Conservation, New York State Officially Prohibits
High-Volume Hydraulic Fracturing: DEC Issues Findings Statement Concluding Extensive Seven-Year
Review, http://www.dec.ny.gov/press/102337.html (last visited on Nov. 3, 2017). 21
Hurdle, John, With governor’s signature, Maryland becomes third state to ban fracking, National Public
Radio (NPR), Apr. 4, 2017, https://stateimpact.npr.org/pennsylvania/2017/04/04/with-governors-
signature-maryland-becomes-third-state-to-ban-fracking/ (last visited on Nov. 3, 2017). 22
Vermont first state to ban fracking, Cable News Network (CNN), May 17, 2012,
http://www.cnn.com/2012/05/17/us/vermont-fracking/index.html (last visited Nov. 3, 2017). 23
Cuff, Denis, Alameda County first in Bay Area to ban fracking, The Mercury News, Jul. 19, 2016,
http://www.mercurynews.com/2016/07/19/alameda-county-first-in-bay-area-to-ban-fracking/ (last visited
on Nov. 3, 2017). 24
Greene, Sydney, California Counties push for all-out fracking ban, Politico, Jun. 16, 2016,
https://www.politico.com/story/2016/06/california-counties-push-for-all-out-fracking-ban-224386 (last
visited on Nov. 13, 2017). 25
Ibid. 26
Rogers, Paul, Fracking ban: Environmentalist declare victory on Monterey Measure Z, The Mercury
News, Nov. 9, 2016, http://www.mercurynews.com/2016/11/09/fracking-ban-environmentalists-declare-
victory-on-monterey-measure-z/ (last visited on Nov. 3, 2017). 27
San Benito County voters pass fracking ban with Measure J, KSBW News, Nov. 5, 2014,
http://www.ksbw.com/article/san-benito-county-voters-pass-fracking-ban-with-measure-j/1055290 (last
visited on Nov. 3, 2017). 28
Hoppin, Jason, Santa Cruz County first to ban fracking, Santa Cruz Sentinel News, May 20, 2014,
http://www.santacruzsentinel.com/article/ZZ/20140520/NEWS/140527991 (last visited on Nov. 3, 2017). 29
The Clean Water Act, 33 U.S.C. §1251 et seq. (1972): Oil and gas exploration, production, and
construction facilities are exempted from stormwater permitting requirements; The Resource
Conservation and Recovery Act (RCRA), 42 U.S.C. §6901 et seq. (1976): Oil and gas exploration and
production wastes are not regulated as hazardous waste under RCRA; The Toxic Substances Control Act
(TSCA), 15 U.S.C. §2601 et seq. (1976): EPA does not currently require manufacturers and processors of
chemical substances used in oil and gas operations to submit information to the agency (but see below for
Page 24
ongoing rulemaking to close this loophole) (For further information see http://www2.epa.gov/laws-
regulations/summary-emergency-planning-community-right-know-act); The Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA, or Superfund), 42 U.S.C. §9601 et
seq. (1980): Exemptions from liability if the toxic substance is found in crude oil or petroleum, and other
provisions limit EPA’s ability to hold the oil and gas industry liable for pollution; The Safe Drinking
Water Act, 42 U.S.C. §300f et seq: Injection of fluid for the purpose of producing oil or gas is exempted
from key provisions of the Act; The Emergency Planning and Community Right-to- Know Act (EPCRA),
42 U.S.C. §11001 et seq. (1986): EPA has not added oil and gas facilities to the list of facilities required
to report data on releases and transfers of toxic chemicals to the Toxic Release Inventory. 30
Environmental Working Group, California Regulators: See No Fracking, Speak No Fracking (2012),
http://static.ewg.org/reports/2012/fracking/ca_fracking/ca_regulators_see_no_fracking.pdf at 5. 31
Letter from Elena Miller, State Oil and Gas Supervisor, DOGGR, to Hon. Fran Pavley, California State
Senate (Feb. 16, 2011), (“Miller 2011 Letter”) available at:
http://psbweb.co.kern.ca.us/UtilityPages/Planning/EIRS/mckittrick_landfill/Vol5/Miller%202011%20(Le
tter%20DOGGR%20to%20Pavley).pdf 32
Zirogiannis, N. et al., State regulation of Unconventional Gas Development in the U.S.: An Empirical
Evaluations, 11 Energy Research & Social Science 142 (2016) (“Zirogiannis 2016”). 33
Statutes 2013, chapter 313. 34
CCST Study, Executive Summary at 13; CCST Study, Vol. II at 44-46, 433; California Council on
Science and Technology, California Council on Science and Technology, An Independent Scientific
Assessment of Well Stimulation in California, Vol. III (2015) (“CCST Study, Vol. III”),
http://ccst.us/projects/hydraulic_fracturing_public/SB4.php at 13-14. 35
CCST Study, Executive Summary at 11; CCST Study, Vol. II at 406. 36
CCST Study, Executive Summary at 8; CCST Study, Vol. II at 110-113. 37
The IPCC estimates that global fossil fuel reserves exceed the remaining carbon budget for staying
below 2°C by 4 to 7 times, while fossil fuel resources exceed the carbon budget for 2°C by 31 to 50 times.
See Bruckner, Thomas et al., Climate Change 2014: Mitigation of Climate Change (2014),
http://ipcc.ch/pdf/assessment-report/ar5/wg3/ipcc_wg3_ar5_chapter7.pdf at Table 7.2. 38
Oil Change International, The Sky’s Limit: Why the Paris Climate Goals Require A Managed Decline
of Fossil Fuel Production (2016),
http://priceofoil.org/content/uploads/2016/09/OCI_the_skys_limit_2016_FINAL_2.pdf 39
A reasonable likelihood of limiting warming to 1.5° or 2°C requires global CO2 emissions to be phased
out by mid-century and likely as early as 2040-2045. Source: Rogelj, Joeri et al., Energy System
Transformations for Limiting End-of-century Warming to Below 1.5°C, 5 Nature Climate Change 519
(2015). 40
California is estimated to contain nearly one-half of the country’s heavy oil. Source: Independent
Petroleum Association of America (IPAA), The Story of California Crude, http://oilindependents.org/the-
story-of-california-crude/ (last visited on Nov. 3, 2017). 41
Wolf, Shaye et al., Oil Stain: How Dirty Crude Undercuts California’s Climate Progress (2017),
http://www.biologicaldiversity.org/programs/climate_law_institute/energy_and_global_warming/pdfs/Oil
_Stain.pdf 42
Erickson, Peter et al., Impact of the Keystone XL Pipeline on Global Oil Markets and Greenhouse Gas
Emissions, 4 Nature Climate Change 778. 43
U.S. Energy Information Administration (EIA), Short-Term Energy Outlook (STEO) (2017),
https://www.eia.gov/outlooks/steo/report/us_oil.cfm (last visited on Nov. 13, 2017). 44
Letter from Caldeira, Ken, Ph.D., Department of Global Ecology, et al, to Hon. Gov. Jerry Brown,
California State Governor, (Nov. 13, 2013) (“Letter from Scientists”), available at:
Page 25
https://biologicaldiversity.org/campaigns/california_fracking/pdfs/Letter_From_Scientists_to_Jerry_Brow
n_2013_11_13.pdf 45
CCST Study, Vol. II at 70. 46
CCST Study, Vol. II at 81. 47
Stringfellow, William et al., Identifying chemicals of concern in hydraulic fracturing fluids used for oil
production, 220 Environmental Pollution 413 (2017). 48
Agency for Toxic Substances and Disease Registry (ATSDR), ATSDR A-Z Index,
https://www.atsdr.cdc.gov/az/a.html (last visited on September 12, 2017) (“ASTDR A-Z Index”). 49
Stringfellow, William et al., Comparison of chemical use between hydraulic fracturing, acidizing, and
routine oil and gas development, 12 PLoS One 4 (2017). 50
California Council on Science and Technology, Advanced Well Stimulation Technologies in California
(2016) (“CCST 2016”), http://ccst.us/publications/2014/160708-blm-report.pdf, at 248. 51
United States Environmental Protection Agency (U.S. EPA), Criteria Air Pollutants,
https://www.epa.gov/criteria-air-pollutants (last visited on Sept. 12, 2017). 52
United States Environmental Protection Agency (U.S. EPA), Health Effects of Ozone Pollution,
https://www.epa.gov/ozone-pollution/health-effects-ozone-pollution (last visited on Nov. 3, 2017). 53
PSE Healthy Energy, The Science on Shale Gas Development, https://www.psehealthyenergy.org/our-
work/publications/archive/the-science-on-shale-gas-development/ (last visited on Nov. 3, 2017). 54
McKenzie, L.M. et al., Childhood hematologic cancer and residential proximity to oil and gas
development, 12 PLoS One 2 (2017). 55
Rasmussen, Sara G. et al., Association Between Unconventional Natural Gas Development in the
Marcellus Shale and Asthma Exacerbations, 176 JAMA Internal Medicine 9 (2016). 56
Jemielita, Thomas et al., Unconventional Gas and Oil Drilling Is Associated with Increased Hospital
Utilization Rates, 10 PLoS One 7 (2015). 57
Rabinowitz, Peter M. et al., Proximity to Natural Gas Wells and Reported Health Status: Results of a
Household Survey in Washington County, Pennsylvania, 123 Environmental Health Perspectives 21
(2015). 58
McKenzie, Lisa M., Birth Outcomes and Maternal Residential Proximity to Natural Gas Development
in Rural Colorado, 122 Environmental Health Perspectives 1306722 (2014). 59
Casey, Joan A., Unconventional Natural Gas Development and Birth Outcomes in Pennsylvania, USA,
27 Epidemiology 2 (2016). 60
Stacy, Shaina L. et al., Perinatal Outcomes and Unconventional Natural Gas Operations in Southwest
Pennsylvania, 10 PLoS One 6 (2015). 61
Czolowski, E.D. et al., Toward Consistent Methodology to Quantify Populations in Proximity to Oil
and Gas Development: A National Spatial Analysis and Review, 125 Environmental Health Perspectives
086004 (2017). 62
NRDC Drilling in California; see also Liberty Hill Drilling Down. 63
NRDC Drilling in California, at 9. 64
Ibid. 65
CCST Study, Vol. II at 183. 66
American Lung Association, 2016 ‘State of the Air’ Report Finds More than Half of Americans Live
with Unhealthful Levels of Air Pollution, http://www.lung.org/about-us/media/press-releases/2016-state-
of-the-air.html (last visited on Nov. 3, 2017). 67
Morello-Frosch, Rachel et al., The Climate Gap: Inequalities in How Climate Change Hurts Americans
& How to Close the Gap, College of Letters, Arts and Science, University of Southern California (USC)
(2009), https://dornsife.usc.edu/pere/climategap/
Page 26
68 Wong, Nicole, Existing scientific literature on setback distances from oil and gas development sites
(2017), http://www.stand.la/uploads/5/3/9/0/53904099/2500_literature_review_report-final_jul13.pdf 69
CCST Study, Executive Summary at 13; CCST Study, Vol. II at 433; CCST Study, Vol. III at 13-14. 70
CCST Study, Vol II at 418-420. 71
For instance, in a University of Maryland study, it was recommended that a minimum buffer zone of
2,000 ft should be enacted to ensure public safety. Milton, Donald et al., Potential public health impacts
of natural gas development and production in the Marcellus Shale in Western Maryland, Maryland
Institute for Applied Environmental Health, School of Public Health, University of Maryland, College
Park (2014). 72
Los Angeles City Council Motion (Apr. 19 2017), available at
https://cityclerk.lacity.org/lacityclerkconnect/index.cfm?fa=ccfi.viewrecord&cfnumber=17-0447 73
New York State Department of Public Health, New York State Department of Health Completes
Review of High-volume Hydraulic Fracturing, https://www.health.ny.gov/press/releases/2014/2014-12-
17_fracking_report.htm (last visited Nov. 13, 2017). 74
CCST 2016 at 26. 75
CCST Study, Vol. II at 406. 76
CCST 2016 at 36-37. 77
CCST Study, Vol. II at 406. 78
CCST 2016 at 381. 79
Yost, Erin et al., Estimating the Potential Toxicity of Chemicals Associated with Hydraulic Fracturing
Operations Using Quantitative Structure-Activity Relationship Modeling, 50 Environmental Science and
Technology 14 (2016). 80
ATSDR A-Z Index. 81
CCST Study, Executive Summary at 11. 82
Ingraffea, A.R. et al., Assessment and risk analysis of casing and cement impairment in oil and gas
wells in Pennsylvania, 111 PNAS 30 (2014) (“Ingraffea 2014”). 83
Kassotis, Christopher et al., Endocrine Disrupting Activities of Surface Water Associated with a West
Virginia Oil and Gas Industry Wastewater Disposal Site, 557-558 Science of the Total Environment 901
(2016). 84
California Regional Water Quality Control Board Central Valley Region, Order R5-2017-0036: Waste
Discharge Requirements General Order for Oil Field Discharges to Land (2017) (“CRWQCB Order
Order R5-2017-0036”),
http://www.waterboards.ca.gov/centralvalley/board_decisions/adopted_orders/general_orders/r5-2017-
0036.pdf, at 9. 85
National Toxicology Program, Substances Listed in the Fourteenth Report on Carcinogens (2016),
https://ntp.niehs.nih.gov/ntp/roc/content/listed_substances_508.pdf 86
Wild, S.R. et al., The Long-term Persistence of Polynuclear Aromatic Hydrocarbons (PAHs) in an
Agricultural Soil Amended with Metal-Contaminated Sewage Sludges, 101 Science of the Total
Environment 3 (1991) (finding residual PAHs in soil more than 20 years after discharge, suggesting
“significantly longer half-lives for PAHs in field soils than has previously been suggested”). 87
Environmental Resources Management (ERM), Development of Risk-Based Comparison Levels for
Chemicals in Agricultural Irrigation Water (2016),
https://www.waterboards.ca.gov/rwqcb5/water_issues/oil_fields/food_safety/data/studies/erm_riskassrpt.
pdf 88
In California, oil companies wishing to discharge wastewater must go through their Regional Water
Quality Control Board. These boards set limits for some pollutants (such as chloride and boron), but not
undisclosed chemicals due to their trade-secret status. Central Valley Regional Water Quality Control
Page 27
Board, Order No. R5-2012-0058: Waste Discharge Requirements for Chevron U.S.A. Inc. and Cawelo
Water District Produced Water Reclamation Project (2012) (“CRWQCB Order Order R5-2012-0058”).
http://www.waterboards.ca.gov/centralvalley/board_decisions/adopted_orders/kern/r5-2012-0058.pdf. In
addition, mandated monitoring does not include monitoring crops or soil where wastewater is applied. 89
CCST Study, Executive Summary at 9; CCST Study, Vol II at 115-116. 90
State Water Resources Control Board, Fact Sheet: Food Safety Expert Panel on Recycled Oilfield
Water for Crop Irrigation (2016),
https://www.waterboards.ca.gov/rwqcb5/water_issues/oil_fields/food_safety/data/fact_sheet/of_foodsafet
y_fact_sheet.pdf 91
Environmental Working Group, Toxic Chemicals May Contaminate Oil Field Wastewater Used to
Grow California Crops (2016),
https://static.ewg.org/reports/2016/og_wastewater/OG_Wastewater.pdf?_ga=1.68513745.1126224887.14
86191706 92
CCST Study, Vol. II at 113-114. 93
Letter from Steven Bohlen, State Oil and Gas Supervisor, Dept. of Conservation, Division of Oil, Gas
& Geothermal Resources, to Jane Diamond, Director, Water Division, U.S. EPA Region IX, (Feb. 6,
2015),
ftp://ftp.consrv.ca.gov/pub/oil/UIC%20Files/FINAL_Dual%20Letterhead_US%20EPA%20Letter.pdf at
4. 94
Title 14, California Code of Regulations, section 1779.1. 95
Letter from Kenneth A. Harris, Jr., State Oil and Gas Supervisor, Dept. of Conservation, Division of
Oil, Gas & Geothermal Resources, to Michael Montgomery, U.S. EPA Region IX (Jan. 17, 2017),
http://www.conservation.ca.gov/dog/general_information/Documents/L_Michael%20Montgomery_UIC
%20Well%20Review_01-17-17.pdf at 3, 4. 96
14 Cal. Code Regs., § 1786(a)(4); Department of Conservation, Division of Oil, Gas & Geothermal
Resources (DOGGR), Analysis of Oil and Gas Well Stimulation Treatments in California (2015),
http://www.conservation.ca.gov/dog/Pages/SB4_Final_EIR_TOC.aspx at 10.14-84. 97
CRWQCB Order R5-2017-0036 at 13. 98
CCST Study, Vol. II at 112. 99
Clean Water Action, In the Pits: Oil and Gas Wastewater Disposal into Open Unlined Pits and the
Threat to California’s Water and Air, (2014),
http://www.cleanwateraction.org/sites/default/files/docs/publications/In%20the%20Pits.pdf at 3; U.S.
Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and
Disease Registry, Interaction Profile for: Benzene, Toluene, Ethylbenzene, and Xylenes (BTEX) (2004),
http://www.atsdr.cdc.gov/interactionprofiles/IP-btex/ip05.pdf at 2 (“All of the BTEX chemicals can
produce neurological impairment, and exposure to benzene can additionally cause hematological effects .
. . .”). 100
California Environmental Protection Agency, Office of Environmental Health Hazard Assessment,
Maps and Data, http://oehha.ca.gov/calenviroscreen/maps-data (last visited May 24, 2016) (The top 25%
of CalEnviroScreen census tracts are characterized as disadvantaged communities, pursuant to Cal. Health
& Safety Code § 39711). 101
Zirogiannis 2016, at Table S.3; CRWQCB Order R5-2017-0036. 102
CCST Study, Vol. II at 110. 103
CCST Study, Executive Summary at 8. 104
Ellsworth, W.L., Injection-induced earthquakes, 341 Science 6142 (2013) (“Ellsworth 2013”);
Nicholson, C. et al., Triggered earthquakes and deep well activities, 139 Pure Applied Geophysics 3/4
Page 28
(1992); National Research Council, Induced Seismicity Potential in Energy Technologies, National
Academies Press, 2013. 105
Skoumal, R., et al., Earthquakes induced by hydraulic fracturing in Poland Township, Ohio, 105
Bulletin of the Seismological Society of America 1 (2015); Friberg, P.A. et al., Characterization of an
earthquake sequence triggered by hydraulic fracturing in Harrison County, Ohio, 85 Seismological
Research Letters 6 (2014). 106
Holland, Austin, Earthquakes Triggered by Hydraulic Fracturing in South‐Central Oklahoma, 103
Bulletin of the Seismological Society of America 3 (2013). 107
Farahbod, Amir Mansour et al., Investigation of regional seismicity before and after hydraulic
fracturing in the Horn River Basin, northeast British Columbia, 52 Canadian Journal of Earth Sciences
112 (2015); Atkinson, Gail et al., Ground motions from three recent earthquakes in Western Alberta and
Northeastern British Columbia and their implications for induced‐seismicity hazard in eastern regions, 86
Seismological Research Letters 3 (2015). 108
Schultz, R. et al., Hydraulic fracturing and the Crooked Lake Sequences: Insights gleaned from
seismic networks, 42 Geophysical Research Letters 2750 (2015); Schultz, R., A seismological overview
of the induced earthquakes in the Duvernay play near Fox Creek, Alberta, 122 J. Geophys. Res. Solid
Earth 492 (2017). 109
Atkinson, G.M. et al., Hydraulic fracturing and seismicity in the Western Canada Sedimentary Basin,
87 Seismological Research Letters 3 (2016). 110
Ellsworth 2013. 111
Keranen, K.M. et al., Potentially induced earthquakes in Oklahoma, USA: Links between wastewater
injection and the 2011 Mw 5.7 earthquake sequence, 41 Geology 6 (2013); Keranen, K.M. et al., Sharp
increase in Central Oklahoma seismicity since 2008 induced by massive wastewater injection, 345
Science 6195 (2014). 112
Yeck, W.L. et al., Oklahoma experiences largest earthquake during ongoing regional wastewater
injection hazard mitigation efforts, 44 Geophysics Resource Letter 711 (2017). 113
Rubinstein, J. et al., The 2001-present induced earthquake sequence in the Raton Basin of northern
New Mexico and southern Colorado, 104 Bulletin of the Seismological Society of America 5 (2014). 114
Frohlich, C. et al., The 17 May 2012 M4.8 earthquake near Timpson, East Texas: An event possibly
triggered by fluid injection, 119 Journal of Geophysical Research 581(2014). 115
United States Geological Survey, One year seismic hazard forecast for the Central and Eastern United
States from induced and natural earthquakes, Open-File Report 2016-1035 (2016),
https://pubs.er.usgs.gov/publication/ofr20161035 116
Goebel, T.H.W et al., Wastewater disposal and earthquake swarm activity at the southern end of the
Central Valley, California, 43 Geophysics Research Letter 43 (2016) (“Goebel 2016”). 117
Goebel, T.H.W. et al., An objective method for the assessment of fluid injection-induced seismicity
and application to tectonically active regions in central California, 120 Journal of Geophysical Research,
Solid Earth (2015) (“Goebel 2015”). 118
Goebel 2016 at 1098. 119
Earthworks, Center for Biological Diversity, and Clean Water Action, On Shaky Ground: Fracking,
Acidizing, and Increased Earthquake Risk in California (2014), http://www.shakyground.org/wp-
content/uploads/2014/02/ShakyGround-FINAL1.pdf 120
Rubinstein, J.L. et al., Myths and facts on wastewater injection, hydraulic fracturing, enhanced oil
recovery, and induced seismicity, 86 Seismological Research Letters 4 (2015); Weingarten, M. et al.,
High-rate injection is associated with the increase U.S. mid-continent seismicity, 348 Science 6241
(2015). 121
Goebel 2015.
Page 29
122 Id., at 7016.
123 Id., at 7022.
124 Department of Conservation, Department of Oil, Gas, and Geothermal Resources (DOGGR), Oil and
Gas: Online Data, ftp://ftp.consrv.ca.gov/pub/oil/monthly_production_reports (last visited on Nov. 6,
2017). 125
Ibid. 126
Ingraffea 2014. 127
Lustgarten, Abraham et al., State-by-State: Underground Injection Wells, ProPublica, Sept. 20, 2012,
http://projects.propublica.org/graphics/underground-injection-wells (last visited Nov. 13, 2017). 128
California Coastal Commission, Briefing on Offshore Fracking and Other Well Stimulation
Treatments (2014) http://docketpublic.energy.ca.gov/PublicDocuments/12-AFC-
02/TN202688_20140713T210346_Briefing_on_Offshore_Fracking_and_Other_Well_Stimulation_Treat
m.pdf at 7, 12. 129
Center for Biological Diversity, Troubled Waters: Offshore Fracking’s Threat to California’s Ocean,
Air and Seismic Stability (2014),
https://www.biologicaldiversity.org/campaigns/offshore_fracking/pdfs/Troubled_Waters.pdf 130
Letter from Ackerly, David, Ph.D., Professor, University of Berkeley, et al. to Brian Salerno, Director,
Bureau of Safety and Environmental Enforcement, Department of Interior, et al. (March 22, 2016),
available at:
https://www.biologicaldiversity.org/campaigns/offshore_fracking/pdfs/16_03_22_Offshore_fracking_scie
ntist_sign-on_letter.pdf 131
CCST Study, Vol. III at 32. 132
Public Resources Code, §§ 30600 (requiring coastal development permit for “any development” in the
coastal zone), 30106 (defining development); Edwards, Andrew, California Coastal Commission to weigh
in on fracking off Long Beach, Press Telegram, Jul. 23, 2015,
http://www.presstelegram.com/2015/07/23/california-coastal-commission-to-weigh-in-on-fracking-off-
long-beach/ (last visited on Nov. 6, 2017) (Commission asserting that fracking requires a coastal
development permit)) 133
Stop Fooling California, Big Oil in California Politics, http://stopfoolingca.org/oil-lobbying/big-oil-in-
california-politics/ (last visited on Nov. 6, 2017). 134
American Lung Association, CA Oil Lobby Spending 2015-2016 Legislative Session (2017),
http://www.lung.org/local-content/california/documents/Oil-Industry-Lobbying-2016-update-4_1-31-
17.pdf 135
Consumer Watchdog, Brown’s Dirty Hands (2016),
http://www.consumerwatchdog.org/resources/BrownsDirtyHands.pdf 136
Oil Change International, Dirty Energy Dominance: Dependent on Denial (2017),
http://priceofoil.org/content/uploads/2017/10/OCI_US-Fossil-Fuel-Subs-2015-16_Final_Oct2017.pdf at
19, 34. 137
Chabria, Anita, How Big Oil Spent $10m to Defeat California Climate Legislation, The Guardian,Feb.
5, 2016, https://www.theguardian.com/us-news/2016/feb/05/how-big-oil-spent-millions-to-defeat-
california-climate-change-legislation-sb-350 (last visited on Nov. 6, 2017). 138
Mulkern, Anne C, Businesses spent millions lobbying before cap-and-trade vote, E&E News, Jul. 26,
2017, https://www.eenews.net/stories/1060057923 (last visited on Nov. 6, 2017) 139
Public Policy Institute of California (PPIC), PPIC Statewide Survey: Californians and the Environment
(2016), http://www.ppic.org/content/pubs/survey/S_716MBS.pdf ; See also Public Policy Institute of
California (PPIC), Majority Say Global Warming Contributing to Drought: Most Support State Efforts to
Limit Emissions, But Partisan Divide Persists, http://www.ppic.org/main/pressrelease.asp?i=1824 (last
Page 30
visited on Nov. 6, 2017); Public Policy Institute of California (PPIC), PPIC Statewide Survey:
Californians and the Environment (2014), http://www.ppic.org/content/pubs/survey/S_714MBS.pdf ;
Public Policy Institute of California (PPIC), PPIC Statewide Survey: Californians and the Environment
(2013), http://www.ppic.org/content/pubs/survey/S_713MBS.pdf ; Public Policy Institute of California
(PPIC), PPIC Statewide Survey: Californians and the Environment (2012),
http://www.ppic.org/content/pubs/survey/S_712MBS.pdf 140
Public Policy Institute of California (PPIC), PPIC Statewide Survey: Californians and the Environment
(2017), http://www.ppic.org/wp-content/uploads/s_717mbs.pdf, at 20. 141
Following the passage of proposition 26 (2010), a two-thirds vote of the Legislature is required to
enact certain fees and taxes. See California Constitution, art. XIIIC, § 1(e). 142
Public Resources Code § 3106(a); the Government Code also allows for emergency rulemaking under
section 11346.1; see also, Water Code § 1058.5(a), authorizing State Water Resources Control Board to
adopt emergency regulations to protect water resources. 143
The oil industry has incorrectly argued that a second legal provision, Public Resources Code §
3106(b), admonishing DOGGR to otherwise utilize all methods and practices to recover oil and gas,
should be interpreted to override the law’s first mandate to protect Californians and our environment.
DOGGR itself has at times adopted this position. This argument is clearly wrong, but any dispute on this
point is irrelevant due to the additional regulatory authority discussed in this section. 144
Public Resources Code § 21000 et seq. 145
Public Resources Code § 3226. 146
Government Code §§ 8625 and 8567(a); see generally, Cal. Emergency Services Act, Gov Code §§
8550 et seq. 147
Government Code § 8558(b). 148
Office of the Governor, California, Governor Brown Declares Drought State of Emergency,
http://gov.ca.gov/news.php?id=18379 (last visited on Nov. 6, 2017) (citing Government Code §§ 8558,
8625 as legal authority to promulgate 20 Executive Orders in response to drought).
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