CIPA Submits Detailed Feedback on SB 1137 Implementation Regulations
- Randle Communications
- Apr 2
- 2 min read
Last week the California Independent Petroleum Association (CIPA) submitted formal comments to the California Department of Conservation’s Geologic Energy Management Division (CalGEM) in response to its updated SB 1137 First Implementation Regulations, released for public review on February 21, 2025.
In its letter, CIPA expressed strong concerns with SB 1137's underlying assumptions, reiterating its opposition to the law’s foundation and imposition of arbitrary “Health Protection Zones.” The association emphasized that the submission of its comments should not be interpreted as acceptance of the law’s premise, which CIPA maintains is based on false claims about oil and gas operations near sensitive receptors.
Key objections outlined by CIPA include:
Arbitrary Property Line Measurement: CIPA criticized the revised rule’s method for measuring the distance from sensitive receptors, arguing that basing this measurement on the property line, rather than the actual location of equipment or activities unfairly broadens the scope of regulation without scientific justification.
Lack of Clarity in Key Definitions: The draft regulations remain vague on critical issues such as the definition of “surface waters” and the precise methodology for measuring distances. CIPA contends that this ambiguity creates confusion for operators and regulators alike and undermines regulatory certainty.
CIPA also submitted Attachment A, which includes line-by-line suggestions to improve clarity, eliminate duplicative language, and provide more precise definitions. CIPA stated that additional revisions are essential to reduce regulatory overreach and offer a viable path for permitting.
The letter concludes by warning that CalGEM’s current approach risks further discouraging oil and gas permitting in California, worsening the state’s growing reliance on foreign energy imports.
CIPA urged the Department to revise the proposed regulations to align with existing regulatory frameworks and ensure California’s energy producers can continue operating under clear, consistent, and practical guidelines.