TRC Operating Co. v. Shabazian
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The case involves the California Geologic Energy Management Division (CalGEM) and TRC Operating Company, an oil operator. CalGEM, tasked with overseeing the state's drilling operations, enacted new regulations requiring oil operators to cease operations when a "surface expression" exists, or when there is reason to believe a specific operation is causing a surface expression. The operations must remain dormant until CalGEM authorizes their resumption in writing.
TRC, having been issued a regulatory notice to cease operations, complied but never received authorization to resume. TRC sought an administrative appeal, which went unheard. Consequently, TRC sought judicial review, arguing that the regulations were invalid and CalGEM's actions were arbitrary and capricious.
The trial court agreed with TRC, ruling the regulations were invalid, and granted declaratory relief. CalGEM appealed, arguing the regulations were valid and did not abuse its discretion in issuing the notice to TRC. The court concluded that the regulations were valid as they were consistent with the overall statutory scheme and were supported by substantial evidence. The court vacated the trial court's writ, and remanded the matter to the trial court to consider in the first instance whether CalGEM's actions in this case were arbitrary or capricious.
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