SB 1281 - Oil and Gas Water Cycle Reporting
CCST's recent report to satisfy the requirements of SB 4 (Pavley, 2012) recommended that the state collect data on water in the petroleum industry in general, going beyond the water used for hydraulic fracturing. SB 1281 (Pavley, 2014) has already started the important work of increasing our knowledge of water use, production, storage, treatment, and disposal in the oil and gas industry. The mandate in SB 1281 can enable the state to understand critical water issues associated with the industry and form a basis for future policies.
The Division of Oil, Gas, and Geothermal Resources (the Division) within the Department of Conservation has requested for CCST to evaluate the water data the Division collects in accordance with SB 1281. The project will be carried out in two phases. During the first phase, CCST will identify important questions such data should address. In the second phase, CCST will perform a preliminary analysis of the data currently collected under SB 1281, and how it complements other available datasets, to assess its accuracy and suitability for answering key questions identified in the first phase.
CCST will conduct an early assessment of the data collection required by SB 1281 to be carried out in two phases. The intent of the study is to enable the state to implement the important provisions of SB 1281 in the most illuminating and efficient manner possible. Where improvements can be made, an early assessment of the data will allow a prompt correction to make the program as productive as possible in the long term.
The Division of Oil, Gas and Geothermal Resources (the Division) has instituted the mandated data reporting required by SB 1281. In collaboration with the Division, the State Water Resources Control Board (Water Board) and other relevant state agencies and entities, CCST will:
- Identify important questions for State decision makers about the water life cycle in California's oil and gas production
- Provide a description of the analyses required to answer these questions
- Clarify how this information may be used to inform decision making
This first phase will result in a document describing the questions that could be answered through mandated water reporting and the impact of various forms of data collection on the ability to answer the questions.
The second phase will carry out an early and preliminary assessment of the SB 1281 data set, along with other available relevant data, via quantitative data analyses of key questions identified from Phase I. The combination of evaluating the dataset by working toward answering these questions with a direct assessment of the raw data and reporting methods will help to determine whether the type of information reported is accurate, necessary and sufficient to answer the questions identified in Phase I. Where possible, CCST will make recommendations on how the data reporting can be improved and streamlined, and identify new questions that may arise through the preliminary data assessment.
It is quite likely that relatively minor adjustments in some data collection requirements would make it possible to answer some of these questions that could not be answered otherwise. For example, if operators report volumes of produced water without identifying enough information to track the eventual disposition of the water, certain questions about the risks of reuse could not be answered. It is also possible that some of the data being collected are not particularly useful or are redundant.