Request for 2011 draft regulations for cyclic steaming of oil fields

Judith Lewis filed this request with the Department of Conservation (Division of Oil, Gas, and Geothermal Resources) of Sacramento, CA.
Due July 25, 2019
Est. Completion Sept. 30, 2019
Status
Awaiting Response

Communications

From: Judith Lewis


To Whom It May Concern:

Pursuant to the California Public Records Act, I hereby request the following records:

I am requesting documents, including e-mails, letters and memos regarding regulations for cyclic steaming that were drafted by Derek Chernow, Elena Miller and/or Rob Habel at DOGGR between 2010 and 2012. I am also requesting to see the draft of the regulations themselves. These regulations were related to how often and where oil companies in California could use cyclic steaming to draw up oil from certain fields where the oil is too viscous for ordinary processes.

The draft of the regulations I'm requesting were put together and ready to distribute to stakeholders in 2011. They never went out because Chernow and Miller were fired from their positions at the Department of Conservation.

I am requesting all available communication related to these regulations and the reasons they were never distributed to stakeholders. This communication may be between oil executives or oil company employees and agency staff, between members of DOGGR and/or Department of Conservation staff, and may extend beyond 2011 into 2012.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 calendar days, as the statute requires.

Sincerely,

Judith Lewis

From: Department of Conservation (Division of Oil, Gas, and Geothermal Resources)

Dear Ms. Lewis (via MuckRock.com):
On behalf of the Division of Oil, Gas and Geothermal Resources, the California Department of Conservation legal office responds to your request for public records dated July 15, 2019, pursuant to California Government Code section 6253, subdivision (c), with the Division's determination regarding the requested disclosure of records in the possession of the Division.

Your request seeks records regarding draft regulations for "cyclic steaming that were drafted by Derek Chernow, Elena Miller and/or Rob Habel at DOGGR between 2010 and 2012." The Division will review its records to determine whether such records exist and, if so, whether they are disclosable.

In the interim, please be aware that regulations imposing stricter requirements for cyclic steam and other injection operations associated with oil and gas production became effective April 1, 2019. Records and information relating to the drafting and promulgation of these regulations may be found posted under the Underground Injection Control Regulations rulemaking process. Please see the 2019 Underground Injection Control (UIC) rulemaking documents available here: https://www.conservation.ca.gov/dog/Pages/Oil,-Gas,-and-Geothermal-Rulemaking-and-Laws.aspx. There you will find records and information concerning the Division's years-long rulemaking process, including those addressing cyclic steaming.
Government Code section 6253, subdivision (c), requires public agencies to provide an estimated date regarding when disclosable records will be provided. A comprehensive review of historic records may take some time, and may not be completed until September 30, 2019. Updates on this process will follow as necessary.

If you have questions, please write to me at James.Pierce@conservation.ca.gov<mailto:James.Pierce@conservation.ca.gov>.

James Pierce

Senior Staff Counsel

CA Dept. of Conservation

From: Department of Conservation (Division of Oil, Gas, and Geothermal Resources)

Dear Ms. Lewis and/or MuckRock-

In response to your highlighted inquiry in your August 9th email below, a response was sent to you on July 25, 2019. That response is set forth below, and also attached as a courtesy.

As for when you might expect responsive documents, if any, that estimated date was also included in the July 25th response.

I will be in further communication with you as needed in the interim.

Thank you,

James Pierce
Senior Staff Counsel
CA Department of Conservation

From: Department of Conservation (Division of Oil, Gas, and Geothermal Resources)

Dear Ms. Lewis and/or MuckRock-

With the arrival of September 30th, I am writing to provide an update concerning this Public Records Act request.

Department of Conservation staff have searched available databases for records which may be responsive to the language of your July 15, 2019 request(s). Your request(s) seeks records which constitute communications concerning draft regulations regarding cyclic steaming dating from the 2010-2012 time frame. Some records have been located which may be responsive, but review of these records for responsiveness and any exemption from disclosure is not yet compete.

I will provide a further update to you when review of the potentially responsive records is complete.

If you have questions, please write to me at James.Pierce@conservation.ca.gov<mailto:James.Pierce@conservation.ca.gov<mailto:James.Pierce@conservation.ca.gov%3cmailto:James.Pierce@conservation.ca.gov>.

Thank you,

James Pierce

Senior Staff Counsel
CA Dept. of Conservation

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