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Summary of the CIPA Comment Letter on CEQA Guidance


The California Independent Petroleum Association (CIPA) provided detailed comments on the California Department of Conservation’s (CalGEM) draft guidance for sidetrack project descriptions and the CEQA (California Environmental Quality Act) process flow chart. The letter aims to assist CalGEM in refining these documents to improve transparency, efficiency, and clarity for operators.


Key Sections and Recommendations


Sidetrack Guidance

  • Subsurface Disturbance: CIPA suggests that existing regulations and the WellSTAR system review should suffice for describing subsurface disturbance. They recommend removing or clarifying the checklist item requiring a detailed description of subsurface disturbance.

  • Recompletion of a Well: CIPA asks for a clearer distinction between "recompletion of a well" and related information requested in other checklist rows.

  • Sidetracking Purpose: Sidetracking is often used to improve production without expanding existing operations. CIPA requests that this be recognized if fluids are handled within current facility capacities.

  • Sensitive Species: CIPA requests more details on the data and level of detail required to meet the checklist item regarding sensitive species.


CEQA Flowchart

  • Box Adjustments: CIPA suggests adding a "Yes" between Boxes 2 and 2.2 and a "No" from Box 2 to Box 1.2. They recommend combining Boxes 6 and 6.1.

  • Intermediate Steps: Between Boxes 4.2 and 4.3, additional steps should be depicted to clarify the review process after CalGEM’s consultant signs off on the initial study. CIPA suggests a separate, detailed flowchart for these steps.

  • Queue Management: To expedite processing, especially for straightforward NOIs (Notices of Intent), CIPA recommends a process similar to that used for plugging and abandonment of NOIs.


High-Level NOI Processing Narrative

  • Queue Transparency: CIPA urges CalGEM to provide operators with more precise information about their position in the review queue and anticipated review timelines.

  • Status Updates: The WellSTAR system should include detailed and informative status updates covering each step of the review process, including when tribal consultation letters are sent out.

  • Lead Agency Analysis Steps: CIPA proposes clearer status update definitions for draft preparation and review stages, emphasizing the need for meaningful updates that reflect the document’s progress through CalGEM’s review stages.


For more information, contact Sean Wallentine.

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