HomeMy WebLinkAboutMINUTES - 10291985 - IO.1 -To.
TO: BOARD OF SUPERVISORS
Contra
FROM: INTERNAL OPERATIONS COMMITTEE
Costa
DATE: October 28 1985 County
SUBJECT: ,
Tax on Oil and Gas Wells
SPECIFIC REQUEST(S) OR RECOMMENDATION(S) & BACKGROUND AND JUSTIFICATION
RECOMMENDATIONS:
1. Acknowledge receipt of the report of our Committee.
2 . Take no further action regarding the imposition of a tax on
oil or gas wells.
3 . Remove this 'item as a referral to our Committee.
BACKGROUND:
On April 9, 1985, :the Board referred to our Committee the report
from the County Administrator on this subject. We have requested
additional financial information from the County Administrator' s
Office and have received reports dated September 6 and
October 22 , which are attached to this report.
These reports conclude that the potential costs of administering
a tax, and the probable legal costs probably exceed the possible
proceeds from such a tax, particularly since such a tax would
have to be placed on the ballot and receive a two-thirds
affirmative vote before it could be imposed. At the rate that
gas is presently being withdrawn, there will be little currently
known reserves left by the time a tax could be imposed. For
these reasons, we have reluctantly concluded that a tax is not
feasible given the currently known reserves, the rate at which
gas is being extracted, and the lead time necessary to get voter
approval and implement the tax.
CONTINUED ON ATTACHMENT: YES SIGNATURE:
RECOMMENDATION OF COUNTY ADMINISTRATOR CO MENDAT ON OF BOARD COMMITTEE
X APPROVE aT!MER
SIGNATURES) Tom Torlakson; T Power
ACTION OF BOARD ON C 0 er 29, 1985 APPROVED AS RECOMMENDED X OTHER
I
VOTE OF SUPERVISORS
X UNANIMOUS (ABSENT I ) I HEREBY CERTIFY THAT THIS IS A TRUE
AYES: NOES: ' AND CORRECT COPY OF AN ACTION TAKEN
ABSENT: ABSTAIN: AND ENTERED ON THE MINUTES OF THE BOARD
OF SUPERVISO,,RS�� ON THE DATE SHOWN.
County Administrator.
CC: County Assessor ATTESTED
County Counsel - - -- -- ------
PHIL BATCHELOR, CLERK OF THE BOARD OF
SUPERVISORS AND COUNTY ADMINISTRATOR
M382/7-83 BYE Ali k�� l/t-C�,,� DEPUTY
OFFICE OF COUNTY ADMINISTRATOR
CONTRA COSTA COUNTY
Administration Building
Supervisor Tom Torlakson Martinez, California
To: Supervisor Tom Powers Date:
INTERNAL OPERATIONS COMMITTEE September 6, 1985
From: Phil Batchelor �� Subject: Tax on Oil and Gas Wells
County Administrator
RECOMMENDATION•
Acknowledge receipt of this report and recommend that the Board
of Supervisors not impose a severance tax on oil and gas
production in this County at this time. We will continue to
monitor newly proven reserves and will make a further report to
the Board at the point that new information appears to justify
the imposition of a tax.
REASONS•
1. The potential revenue to be derived from the imposition of a
severance tax does not justify the administrative costs of
developing a ballot measure, placing the issue before the
voters, monitoring production of gas and oil, and collecting
the tax.
2. The substantial drop in proven reserves over the past year
against which a tax would be imposed and the time delay
before the tax would be imposed would not justify the
imposition of the tax.
3 . Substantial legal issues remain unresolved which would
require specialized and fairly expensive counsel to research
and provide the County with a firm legal footing on which to
proceed.
BACKGROUND:
Since 1981, the Board and County staff have discussed and
researched the feasibility of imposing a tax on oil and gas
extracted from wells operating within the County. The purpose of
this report is to review the information which has been gathered
over the last several years and to indicate some of the potential
ramifications of imposing such a tax.
Based on information obtained from the Community Development
Department in August, 1984, there are eight active oil/gas fields
in Contra Costa County: Brentwood, East Brentwood, Dutch Slough,
-2-
Knightsen, Oakley, ' South Oakley, Riverbreak, and Sand Mound
Slough. Our April 8 , 1985 report to the Board of Supervisors on
this subject indicated that at that time these fields comprised
90 gas wells , of which 61 were in production, and 46 oil wells,
of which 33 were in production. The estimated reserves as of the
1984-1985 lien date were 391,765 barrels of oil and
97 , 149 ,051 , 000 cubic feet of gas.
As of the 1985-1986 lien date, the estimated reserves were
389 , 617 barrels of ' oil and only 20 , 083 ,454 , 000 cubic feet of gas.
This represents a nearly 80o reduction in proven reserves of gas
in a period of one' year. In addition, the number of gas wells
was 77 , 74 of which were in production and 37 oil wells , 34 of
which were in production.
LEGAL CONCERNS:
It is clear that imposition of the proposed tax would require a
two-thirds voter approval as a "special" tax pursuant to
Government Code Section 50077 . According to County Counsel
because a special tax is defined as a tax where the proceeds are
earmarked for a special purpose, it can be argued that any voter-
approved special tax on oil and gas production should be
earmarked for a particular fund rather than the General Fund.
County Counsel has advised that the safest way to proceed would
be to implement a severance tax on the "privilege" of gas and oil
extraction, based on the volume of gas and oil extracted. As
pointed out in our April 8, 1985 report, there are legal
questions regarding the method used to measure gas and oil
production and that it would be essential for the County to hire
a consultant having special expertise in the gas and oil
extraction business to assist the County in drafting an ordinance
that would be practical and workable. County Counsel has also
advised that depending upon the details of the tax, an attorney
specially versed in oil and gas law may need to be employed.
Regardless of the details of any such ordinance, inasmuch as
Contra Costa would be the first county in the State of California
to impose such a tax, it would most assuredly be the subject of a
court challenge. County Counsel has advised that such litigation
would probably take many years and that during such time it may
be necessary for the County to impound the proceeds of such tax.
As an example, the voters in Sonoma County approved a tax on
geothermal wells in that county some five years ago. None of the
tax has been received yet because the issue is still involved in
litigation.
CURRENT TAXES:
It is important to note that gas and oil wells are presently
already subject to a property tax. The County Assessor values
the land at full value based on comparable land values in the
area, and assesses mineral rights based on the Net Income
projected over the remaining life of the well. For the 1984-1985
i
-3-
year,
3-year, the total full value assigned to gas and oil reserves was
$192 ,799 , 411 . The actual property tax dollars generated are
unknown because oil and gas wells are located in various tax rate
areas. For example, however, a 1% tax imposed on the assessed
value of the property and the gas and oil wells would generate
about $1. 9 million. For the 1985-1986 fiscal year, this value
was reduced to $61 , 933 , 109 due to the reduced proven reserves.
At this value, a 116 tax would generate $619 , 331 in property tax.
OPPOSITION:
Representatives from oil and gas interests have been alerted to
the fact that the Board is considering implementation of such a
tax and have stated their opposition. One of their arguments is
that no other business engaged in commercial enterprise in the
County is required to pay taxes on units of production in
addition to property taxes . Another argument is that the County
is currently receiving property taxes on the natural gas reserves
in place from the time of discovery to depletion. The proposed
tax would be deducted as a cost in the property tax computation
formula tending to reduce the property tax on natural gas. This
position is corroborated in a March 25, 1985 memorandum prepared
by the County Assessor in which he states as follows:
"Imposition of any type of additional tax may reduce future
projected economic net worth of reserves and results in a
reduction of reserve value, thus reducing the ad valorem tax" .
Another factor involves .royalty payments made to landowners.
Costs such as the proposed new tax would reduce royalty payments
because the royalty owners must pay their proportionate share of
production taxes.
SANTA BARBARA COUNTY:
Earlier this year, Santa Barbara County was contemplating the
imposition of a tax up to 10 cents per barrel of oil processed
within the county to mitigate the impact of oil development
activities. The Santa Barbara proposal applied to oil only.
Based on an estimate of 50 million to 200 million barrels of oil
processed per year, the potential revenue to the county, at 10
cents per barrel, would have been in the range of $5 million to
$20 million. Despite this substantial potential revenue source,
Santa Barbara County has deferred further consideration of this
tax, and has no plans to again consider this item in the
immediate future.
POTENTIAL REVENUE:
As of the lien date for the 1985-1986 fiscal year, the estimated
reserve of oil was; 389 , 617 barrels. At 10 cents per barrel, this
represents total revenue for all remaining reserves of $38 , 962 .
The estimated reserve of gas was 20,083 , 454 , 000 cubic feet. At a
tax rate of 1 cent; per 1 , 000 cubic feet, the reserves represent a
total potential revenue of $200,835 if every bit of proven
reserves are withdrawn.
PJB:clg j
OFFICE OF COUNTY ADMINISTRATOR
CONTRA COSTA COUNTY
Administration Building
Martinez, California
Internal Operations Committee October 22, 1985
To: (Supervisors T. Torlakson and Date:
T. Powers)
Phil Batchelor, Tax on Oil and Gas Wells
From : County Administrator Subject
On September 10, 1985 the Board of Supervisors, on recommenda-
tion of the Internal Operations Committee, directed the County
Administrator to obtain certain additional information related to
the feasibility of establishing a tax on gas well production.
Following are the specific questions asked by the Committee and
information obtained to date:
1. How much of the proven reserves of gas are
located in cities as opposed to the unincor-
porated area of the County?
Attachment A shows the number of producing oil and gas wells within
the County and the estimated reserves as of December 31, 1984.
Only one or two of the gas wells are located within the City of
Brentwood. It is estimated that 97% of the estimated gas reserves
are located in unincorporated area.
2. How much would a severance tax reduce property
taxes? (Is there a dollar-for-dollar offset
or only a fractional offset? )
Discussion with staff of the County Assessor revealed that it is
not possible to answer this question on a generalized basis. An
economic analysis of each well would have to be undertaken to
determine the effect of the imposition of a severance tax. First
of all, the proposed severance tax rate would have to be known.
Secondly, the total amount of the severance tax for each well would
be added to the deductible operating costs for that well thereby
resulting in a lower taxable value. Attachment B displays two
hypothetical cases of how a 5% severance tax could affect the
calculation of the mineral right taxable value.
3 . What is the trend in the discovery of new reserves
of gas?
Attached as Attachment C is a list of new oil and gas discoveries
in the State of California for the last five years. The number of
new discoveries has increased dramatically during this time. The
discoveries made were two in 1980, two in 1981, eight in 1982,
Internal Operations
Committee 2 . October 22, 1985
eight in 1983 , and 22 in 1984. The discoveries are categorized as
new fields, new areas, new pools, or extensions of sources. The
last discovery in Contra .Costa County was the extension of the
Oakley South Gas Field. Staff of the County Assessor' s Office has
advised that the existing reserves of gas within the County are
being depleted much more rapidly than new discoveries are being
made.
4. Do any comparable severance taxes exist in
other states and, if so, what has their
experience been in terms of the impact of the
severance tax on production and exploration?
Attached as Attachment D is a summary of severance tax practice in
other states. No information has been obtained on the impact of
such tax on production and exploration. In general, local juris-
dictions do not have authority to levy a severance tax and, if they
do, such tax is in-lieu of a property tax.
5 . What are the potential legal costs of putting
together a sound ballot proposition and
defending any potential legal challenges to
it? What are the potential costs of a technical
expert consultant in oil and gas law who would
assist in designing sound methodology for
imposing a tax?
Taking these two questions together, any answer is purely specula-
tive and subject to great variation. County Counsel has advised
that at least $10,000 would probably be required for assistance in
the development of a ballot measure. This includes development of
a methodology imposing the tax. The cost of defending legal
challenges is extremely difficult to estimate. County Counsel has
advised that there is no question that the oil companies would
mount a major legal offensive against this kind of tax and would
pursue the matter through the Appellate Courts. Cost of legal
defense would be at least $50 ,000 with a potential for going much
higher.
6. What are the likely administrative costs of
such a tax on gas well production?
Ongoing administrative costs of administering such a tax are esti-
mated at $8,000 to $10,000 per year, including the cost of staff
and computer time.
Internal Operations
Committee 3 . October 22, 1985
7 . How much in royalties are being paid to
owners of agricultural lands as opposed to
lands available for development?
No information has been obtained on this question inasmuch as it
would require a significant amount of staff time and the ability to
obtain accurate personal income data is questionable.
GEB/aa
ATTACHMENT A
CONTRA COSTA COUNTY OIL AND GAS
WELLS AND ESTIMA
TED RESERVES
Field No. Producing Wells Estimated Reserves @12/31/84
Oil Gas Oil (Mbbl) Gas (MMcf)
Brentwood 45 645 3 ,291
Brentwood East 9 5,518
Dutch Slough 19 10 ,545
Los Medanos 17 6,422
Oakley 2 2,994
Oakley South 11 20 ,070
River Break 10 2, 393
Sand Mound
Slough 2 1, 602
Rio Vista 1
TOTALS 45 71 645 52,835
Source: 70th Annual Report of the State Oil and Gas Supervisor,
California Department of Conservation
ATTACHMENT C
OIL AND GAS DISCOVERIES
1980 - 1984
Year County No. and Type if Discovery
1980 Monterey 1 - Extension
Kern 1 - New pool
Total 2
1981 Kern 1 - New pool
Contra Costa 1 - New area (Los Medanos)
Total 2
1982 Kern 1 - New pool
Los Angeles 1 - New pool
Colusa 1 - New pool
Contra Costa 1 - Extension (Oakley South Gas)
Glenn 1 - Extension
Sacramento 1 - Extension
San Joaquin 1 - Extension
Yolo 1 - Extension
Total 8
1983 Santa Barbara 1 - New Field
1 - New Area
Kern 2 - New pool
2 - Extension
Sonoma 1 - New field
Yolo 1 - Extension
Total 8
1984 Los Angeles 2 - New pool
4 - Extension
Santa Barbara 4 - Extension
Ventura 2 - Extension
Kern 3 - Extension
1 - New pool
1 - New area
San Joaquin 1 - Extension
Solano 2 - Extension
Sutter 1 - Extension
Yolo 1 - Extension
Total 22
SOURCE: 70th Annual Report of the State Oil and Gas Supervisor,
California Department of Conservation.
ATTACHMENT D
STATE COMPARISON OF OIL AND GAS SEVERANCE TAXES
The following information was obtained from a 1981 report prepared
by the American Petroleum Institute, entitled State and Local Oil
and Gas Severance and Production Taxes.
State Comments
Alabama The State levies a 4% tax on production of
crude petroleum and natural gas. The tax is
based on the gross value of the oil or gas at
the point of production. The tax is in-lieu of
ad valorem tax. Local severance taxes are
prohibited.
Alaska The state levies an Oil and Gas Regulation and
Conservation Tax and a Production Gas. The
Production Tax is in-lieu of other tax (e.g. ,
ad valorem) . Local severance taxes are
prohibited.
Arizona The state levies a 2-1/2 percent transaction
privilege tax on the production of oil and gas.
Arkansas The state levies a 5% tax on oil and a tax of
three tenths of one cent per 1, 000 cubic feet
on natural gas. The tax is based on the market
value of the product at the time and point of
severance. No other privileged or excise tax
in addition to the severance tax may be imposed
upon the rights to utilize natural resources.
California State levies a charge on oil and gas well
operators to support the State Division of Oil
and Gas. There is an additional charge on well
operators in subsidence areas. Several cities
levy oil and gas well production taxes.
Colorado The state levies an oil and gas conservation
tax and a severance tax upon the gross income
of crude oil, natural gas and oil. There is no
authorization for the imposition of local
severance taxes.
a.
State Comments
Florida The state levies a severance tax of 5% for gas
and 8% for oil on the gross value at the point
of production. State law provides that ad
valorem taxes shall not be increased because of
any producing oil or gas well or equipment
appurtenant thereto, situated on the land.
Local jurisdictions are prohibited from levying
any excise or license tax in addition to the
state state severance tax.
Georgia The state may levy a tax not to exceed 5 mills
per barrel of oil produced and one-half mill
per 1,000 cubic feet of gas produced. There
are no provisions respecting a local severance
tax.
Idaho The state may levy a conservation tax of up to
5 mills per barrel of oil or 50,000 cubic feet
of gas produced. There are no provisions
respecting local severance taxes.
Indiana The state imposes a tax of one percent on the
value of all petroleum products at the time of
severance. There are no provisions respecting
local severance tax.
Kansas The state levies a production tax on gas and
oil. There are no provisions respecting a
local severance tax.
Kentucky The state imposes a tax of 4. 5% of the market
value of all natural resources including gas
and crude petroleum. Authority for counties to
levy a tax of not more than. one percent of
market value of crude petroleum produced was
repealed in 1980 .
Louisiana The state imposes a variety of taxes on
petroleum products but with regard to the
imposition local taxes, the state constitution
provides that no severance tax shall be levied
by any local subdivision of the state and that
no further or additional tax or license shall
be levied or imposed upon oil or gas leases or
right, nor shall any additional value be added
to the assessment of land, by reason of the
presence of oil or gas therein or their
production therefrom.
3 .
State Comments
Maryland There are no provisions respecting state-wide
severance taxes. One county levies a 7% tax on
the business of collecting, distributing and
producing natural gas.
Michigan The state imposes a severance tax of 6. 6% of
the gross cash market value of the production
of oil and a similar tax of 5% on gas. State
law provides that the severance tax levied by
the state shall be in-lieu of all other taxes,
state or local.
Mississippi A tax of 6 cents per barrel or 6% of value at
the point of production, whichever is greater,
is imposed on the business of producing or
severing oil. There is a state imposed gas
severance tax at the rate of 6% of the value
thereof at the point of production. There are
no provisions respecting a local severance tax.
Montana The state levies a gas and oil severance tax
but there are no provisions respecting a local
severance tax.
Nebraska The state levies a tax on all oil or natural
gas at the rate of 2% of value at the time of
severance. There are no provisions respecting
a local severance tax.
Nevada The state imposes a conservation tax on
producers of 5 mills per barrel of oil and 5
mills per 50,000 cubic feet of natural gas.
There are no provisions respecting a local
severance tax.
New Mexico State imposes an oil and gas severance tax on 5
cents per MCF of gas and 45 cents per barrel of
oil. Also imposed are a conservation tax,
emergency school tax and an ad valorem tax.
North Carolina The state levies severance tax of not to exceed
5 mills per barrel of oil and not to exceed
one-half mill on each 1,000 cubic feet of gas.
Proceeds of the taxes are to be used solely for
administration of oil and gas conservation act.
There are no provisions respecting local
severance tax.
4.
State Comments
North Dakota The state levies a severance tax of 50 of the
gross value at the well upon all oil and gas.
This production tax is in-lieu of all ad
valorem taxes by the state or any of its
political subdivisions. There are no
provisions respecting a local severance tax.
Ohio The state imposes a tax for the severance of
natural resources of 3 cents per barrel of oil
and one cent per 1,000 cubic feet of natural
gas. There are no provisions respecting local
severance tax.
Oklahoma The state imposes a tax equal to 70 of gross
value of petroleum produced. State law
provides that the production tax shall be
in-lieu of all taxes by the state, counties,
cities, towns, townships, school districts, and
other municipalities.
Oregon State levies oil and gas tax not to exceed 6
percent of market value.
South Dakota State levies a severance tax of 4-1/2 percent
of the taxable value.
Tennessee A severance tax of 1-1/20 of the sell price is
imposed on oil and gas. The state and other
local political subdivisions are prohibited
from imposing other taxes on oil and gas.
Texas Texas levies a variety of taxes on oil and gas
production. No city, county, or other
political subdivision may levy a tax unless
specifically permitted to do so by the
Legislature of the State of Texas.
Utah The state levies an oil and gas severance tax
at 20 of value at the well. There are no
provisions respecting a local severance tax.
Virginia The state has no severance tax on oil or gas.
Counties and cities are authorized to levy
taxes up to one percent upon the gross receipts
from severing coal or gases in-lieu of an ad
valorem tax on minerals.
5 .
West Virginia State levies a conservation tax on oil and gas
leases of 3 cents per acre. Business and
occupation tax is levied based on the value of
oil and gas produced.
Wyoming State levies a severance tax of 40 of the value
of the gross product extracted on petroleum,
natural gas and any other fossil fuel minerals. .
There are no provisions respecting local
severance tax.
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