FIRST SUMMER SESSION 1981
ENERGY REGULATION
GEOTHERMAL ENERGY
An Overview of Technology, Legislation,
Regulation and Litigation
Presented to:
By:
Professor Ahrens
Sandy Livengood
July 10, 1981
GEOTHERMAL ENERGY
AN OVERVIErJ OF TECHNOLOGY, LEGISLATION, REGULATION AND LITIGATION
I.
Introduction
Geothermal means heat from the earth.
This heat comes from
several sources, the most prevalent is that from the fiery core
of the earth which reaches an estimated 2000°c.
This molten core
is knovm as the magma and is believed to have been caused by a
buildup of insulated heat from radioactive decay over an extremely
long period of time.
Another theory accounts for the molten core
by postulating that it never cooled after the original formation
of the planet.
Other high heat sources have possibly been caused
by the action of the earths plates and the friction caused between
them as they move.
Heat flows from the magma to the earths surface
over its entire surface, though over most of the surface the insulating. qualities of the earth rock and material allow only a fraction of the heat to escape.
In certain areas the solid rocks have
faulted and allowed the magma to rise closer to the surface, resulting in volcanic action where it actually reaches the surface.
In other areas it reaches a point relatively near the surface.
These areas then become areas of potential geothermal energy due
to a much higher thermal gradient.
Over most of the surface in
the United States the average thermal gradient (temperature
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increase) is about 25°C for each kilometer in depth, after passing about 100-250 meters from the surface.
00260
II.
Types of Geothermal Energy Available
The primary potential of Geothermal Energy is that which is
recoverable from steam-and hot water.-
Generation of electrical
energy by using the steam and hot water in turbines has been the
primary focus of the successful commercial and experimental
research.
Of present usage a very large majority is used in manu-
facturing of electrical power, due to the high loss of heat when
used as a direct source of heat for home and business heating.
Even though Iceland, Hungary, USSR and New Zealand are presently
making extensive use of non-electrical applications it is not
expected that this \till prove to be a feasible use in the great
maiority of cases in the United States.
In the United States there are four primary types or sources
available for potential geothermal energy exploitation.
Dry steam
is presently being utilized for electrical generation at The
Geysers in California.
This site is presently producing 500MW or
more, this amount is considered adequate to supply the electrical
needs of a city of at least a half-million inhabitants. 1 As water
seeps from the surface through faults,down-ward toward the molten
magma it becomes super heated, and converts to a very high pressure
steam which then attempts to escape and sometimes become trapped
in pockets within the earth.
These pockets of superheated super-
pressurized steam are then capable of being tapped by wells from
the surface.
Recovery of the dry steam is most economical and
conversion to electricity is fairly inexpensive and technologically
•
simple.
•
The most important problem with this resource is its
relative rarity.
Wet Steam reservoirs are perhaps more common and more readily
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exploited.
The formation of this asset involves primarily that
of seepage of ground water into the natural faults and its downward movement for long-periods of time till the encounter with
a heat source.
After being heated to temperatures of 320°C or
higher it is normally pushed back upward in the form of superheated water or as highly pressurized steam.
Reservoirs are
formed when the super heated substance is trapped under a layer
of impervious caprock.
If the reservoir is located near enough
to the heat source with resultant reheating, the natural tendency
of water to circulate in columns also reduces the dispersion of
heat into the surrounding rock strata. 2 This resource is usually
recovered from wells and is flashed into steam upon reaching the
surface.
Geopressured reservoirs are found along the Texas and Louisiana
Gulf Coast.3
These deposits were laid down primarily as sedimentary
waters and as magmatic and conate waters.
As the water was covered
by layers of clay the pressure of the overlying sediment caused
additional water to be squeezed from the clay, which in turn formed
an impervious shale which acted as a caprock, retaining the water
in the strata.4
Since both water and shale are very poor conduc-
tors of heat and have a high heat storage value, the natural conduction of heat from the underlying magma and the direct heating
by the tremendous pressure created by the overburden has increased
the temperature of the formations to as high as 200-300°C.
The
quantity of water in these reservoirs is believed to be enormous,
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lying in multiple layers, each as much as 1200 feet thick and
covering as much as several hundred square miles.5
This asset
is unique in that there are at least three sources of energy and
possibly fresh water and in some cases even paying quanti ties of
minerals to be recovered.
The very high pressure of the water
may be sufficient to provide direct recovery of energy and conversion to electrical pov1er vvith as high as a 9096 efficiency. 6
Vfuile the water may not be as hot as that found in other geothermal
areas, the heat is believed to be sufficient to account for as much
as half the energy available in the deposit.?
The water in the
reservoirs located thus far, are saturated vvith dissolved methane
gas which may be recovered after the water has performed its
geothermal task. 8
Vfuile the area in question has been extensively
drilled and the geological conditions fully developed and maped
li t_tle actual analysis was made for geothermal energy purposes,
since the pressurized water deposits were considered only a danger
and a nuisance to the function of drilling and developing the
underlying oil and natural gas deposits.
The most common but probably least efficient of the known
geothermal sources is the dry hot rock deposit.
Rock in the earth's
crust ,overlying an upthrust or pocket of magma is heated to ternperature of 300°c.+, normally without~an association of water or
with water in very small quantities.
In other cases the heat source
may be the radioactive decay of granite or other decaying rock.
The later action while more vddespread is much less efficient in
terms of electrical generation due to the much lower temperature
available, usually not exceeding about 90°C.
Recovery of the resource involves the drilling of wells,
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fracturing the heated rock, and using a water circulation to
withdraw the available energy.
Numerous areas in the Western
United States and along the western area of the Texas Big Bend
area are believed to be sources of this type of energy.9
Certain
areas along the eastern seaboards may also be found to be productive of this
res?ur~e.
R~covery
of this resource where the
available temperature is below the optimal temperature, (90-150°C.)
for direct use in steam turbines vall require a more sophisticated
and costly technology using a binary closed system.
In this system
the heated fluid will in turn be used to heat a fluid with a boiling
temperature much lower than that of water.
The fluid, such as
freon or isobutane vdll then be used to drive the generating turbine, cooled and recompressed for reuse.
While the heat of the earth's interior seems to be, at least
in the prospective age of man, an inexhaustable resource, the knovm
deposits of Dry and \Vet Steam and geopressured water have been
estimated to last variously, if produced to their hypothetical
maximum, to be able to produce the extrapolated electrical needs
of the nation from 20 or 40 to 200 years. 10 The use of Hot Rock
resources technology would appear to have economical value almost
to infinity.
Perhaps with the further development of drilling
techniques, to develop deeper and hotter resources and the recharg--ing of steam reservoirs they too might be useful for even longer
periods.
III.
Environmental Considerations
The production and use of geothermal energy is by and large
considered to be a non-polluting source of power, and hence has
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generated a great deal of enthusiasm for its development.
Compared
to the pollution, land destruction and other environment degrading
aspects of fossil fuel generating facilities, this is undeniably true.
However there are several aspects which must be considered in the
geothermal field.
Among these are "possible land subsidance,
seismic activity, air pollution resulting from the discharge of
non-combustible gases such as hydrogen sulfide, high noise levels
of drilling and poner plant operation, and mineral or thermal
pollution of surface and ground waters." 11
The possibility of land subsidence appears to be a function
of the type of production and to a greater extent the geological
formations overlying the deposit.
As in certain oil fields where
the production was not accompanied by reinjection of water or
other fluids to maintain pressure, some evidence of subsidence
hac-occured.
In The Geysers field and at the Landerello Field in
Italy no subsidence has been observed, 12 in these fields the aquifier
appears to be fractured rock.
Where the aquifier is a porous
medium such as in the field at Waireikei in New Zealand1 3 the
subsidence has amounted to as much as 3.7 meters (12 feet) between
1956 and 1978. 1 4 The subsidence has appeared not only in the
immediate area of production but also has extended to large areas
overlying the entire deposit.
Seismic activity has occured in and surrounding most of the
producing geothermal installations, including The Geysers and the
field in the Imperial Valley of California.
Microearthquakes
measured both before and after production began, usually 1uere on
the order of
4.0 or less on the Richter scale, seemingly occurred
more frequently than in the surrounding areas.
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magnitudes in the surrounding area may be
Even though the
4.5 or higher on the
scale the effect of these quakes do not seem to enter the actual
reservoir area. 1 5
In Colorado when fluids were pumped into a deep
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well located in the Rocky Mountain Arsenal Area, an apparent
increase of minor activity was recorded,l6 but no major movement
was thereafter recorded equivalent to that which had previously
been recorded.
The danger of seismic activity by other than
subsidence appears to be rather slight in areas where the normal
activity is normally low.
Air pollution has occured at The Geysers due to hydrogen
sulfide, the effects of this pollutant have been confined to a
slight discomfort due to the odor (rotten eggs) and to eye irritation when the levels reached a higher level during early periods
of the operation.
The effects could, if the concentration were
to become high enough, result in sickness and even death.
This
hazard has not been found to date and the minor concentrations
rapidly disappear since it converts readily into other compounds
of sulfur and particulates. 1 7
Ammonia is found in geothermal steam at levels too low to
constitute a hazard directly but may be a hazard if combined with
other .~ompounds to produce a toxic substance. 18
Carbon Dioxide is sometimes present in undiluted geothermal
steam in levels at twice the normal deadly level if breathed
directly.
However it too is readily dispersed in the atmosphere
and does not constitute a threat outside a confined space, other
than to workers within the plant.
Mercury and Radon are also found in some geothermal steams.
the steam poses a danger to the environment
Mercury when found
,. in
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when not removed from the steam prior to being released into the
atmosphere.
Radon even though it has a short half life of 3.82
days may breakdo\m into another radioactive substance which is
0026G
suspected of causing cancer.
The state of California has set a
maximum standard for Radon-222 releases into the atmosphere. 1 9
During certain -periods of the day and year some increase in
fog has been noted, at The Geysers, due to an increase of humidity
in the atmosphere.
Dust during the drilling and construction
period may also be considered a problem in inhabited areas.
Pollution of ground water in the United States has not posed
a significant problem in the areas being utilized to this time
due to appropriate sealing of the strata and proper disposal of
the spent geothermal fluids.
In the case of the new Zealand plant
the spent steam has been discharged into a stream after being only
slightly cooled and has resulted in a significant increase in the
temperature of the water and an increase in the amount of fog near
the plant. 20 This aspect of the geothermal system could pose a
serious problem if the fluid itself contained large quantities
of non-recoverable toxic substances or minerals.
However most
of the reservoirs discovered to date appear to contain either
fresh water or relatively low levels of noxious substances which
are readily recoverable.
The relatively large amounts of thermal
fluids have been disposed of by use of cooling towers and evaporating ponds.
Noise pollution may be divided into two distinct phases,
drilling and production or generating.
During the drilling phase
of a dry steam well only a relatively slight portion of the well
is
nor~ally
completed by the usual mud method as used in oil and
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gas wells.
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The deeper phases are completed by the use of com-
pressed air cooling and clean out.
The air drilling phase results
in sound levels as high as 120 dB(A).
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After completion of the
dry steam well it usually is allowed to "blow" from 3 to 6 days
as a clean out process and may produce sound levels as high as
118 dB(A).
Drilling noises are a problem for two to three months
on a 24 hour a day basis.
The wet steam well however, may be
completed using the usual mud drilling process which mru{es considerably less noise and usually is completed in 30-45 days. 21
The second phase of noise pollution, the production and
generation phase, is normal for an electrical generation facility
vdth the addition of various occasions of released steam and a
few other type specific maintenance additions.
With the exception of those plants constructed near or within populated centers the effect of noise pollution should be
minimal except for the required ear protection for the employees
of the facility and the apparent problem of scaring the wildlife.
Other environmental considerations which are common to all
industrial development should also be considered prior to any
program of licensing, permitting or development, as well as site
specif~c
IV.
considerations.
Legislation and Regulation
A large percentage of the knovm and prospective sources of
geothermal resources are located in the western states (60;6 or
more) and Alaska.
Of these locations many are to be found on land
which is still ovmed by the federal government or in which the
22
government has retained the mineral estate.
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In an effort to encourage a rapid and orderly development
of geothermal resources in the above mentioned areas the congress
passed the Geothermal Steam Act 2 3 in 1970. Initially, implementation
00~63
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and regulatory authority was granted to the Secretary of the
Interior, later upon organization of the Department of Energy the
secretary of that department shares in the regulation of development and distribution of energy obtained from geothermal sources.
Leasing of public lands is
by the Bureau of Land
l1anagement and is primarily divided between Competi tive 24 and Non
Competitive 2 5 leasing. Competitive Leases are required in Knovm
ad~inistered
Geothermal Resource Areas (K.G.R.A.)
The requirements for appli-
cation bid and priority are simililar to those in the mineral,
oil and gas leasing process.
The Director of the Bureau of Land
Management has the final authority of acceptance or refusal of
all bids 2 6 however as vdth all administrative discretionary
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actions the decision is subject to appeal in this case to the Interior Board of Land Appeals (IBLA). A KGRA is determined by the
Director, Geological Survey 2 7 on the basis of: (1) Geological
and technical evidence, (2)
discoveries of geothermal resources
nearby and (3) non-compGtitive interest in a particular area.
An area may be designated as a KGRA vdth an effective date
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retroactively on the basis of any of the above enumerated evidence.
Therefore in case of non-competitive interest in an area the director
may declare the location a KGRA which requires competitive leasing
procedures.
The limitation on maximum acreage in each non-competi-
tive lease is set at 2560 acres (4 sections) in a reasonably compact shape not more than 6 miles long or wide, and must include
all of the acreage in each section which is available for lease. 28
•
This acreage limitation may exceed by
lO~j
whenever the rule of
approximation applies due to an irregular survey or non ovmership
of an entire section.
00-269
As noted above the size of each lease is limited, each person
or leasing entity is additionally limited to a maximum of 20,480
acres (32 sections)· in-each state.
Conversion of previously
obtained mineral leases avvarded under prior legislation is limited
to a maximmn of 10,240 acres (16 sections).
Leasing terms and procedure are similar to those of a normal
government oil and gas lease concerning environmental protection,
production, use and abandonment, the normal term is for 10 years
vli th preferential terms on renewal.
On a competitive lease the rental will be determined by the
maximum bid.
While no minimum bid is prescribed it should be
assumed that the Director, BL:t-1 would refuse any bid which is below
that required in a non-competitive lease, which requires a minimum
of $1.00 per acre per year. 2 9 Royalties of 10% minimum and 15%
maximum are required on the value of the steam produced from the
lease.
A 5% royalty is required on the value of any by-product,
including de-mineralized water sold off the premises.
In an effort
to encpurage early production by the 1 essee the yearly lease rate
is subject to a waiverable escalator clause.
In the event of prod-
uction the yearly rental is automatically raised to the greater
of $2.00 per acre or the royalty percentage as stated above.30
After exploration has been completed and production of steam
or other geothermal resource has begun, and prior to usage in a
power production facility the operator must secure a permit from
the area Geothermal Supervisor,
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u.s.
Geological Survey for use
of acreage on which to build and maintain a power production
facility, in any case in which the facility or lease will produce
more than 10 NW maximum. 3l
Where the lands in question are under
00270
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the control of an agency other than the BLH the regulations of
that agency must be met as well as the rules of the Federal Energy
Regulating Commission (FERC).3 2 Once issued the license is normally
granted for a period of 30 years with a preferential right to
renewal.33
In 1974 Congress, during a period of oil and other energy
shortages, noted the lack of progress and development in the
geothermal energy area.
Realizing that difficulty in gaining
adequate development capital was one of the primary problems slowing the potential development in the field, Congress passed the
"Geothermal Energy Research Development and Demonstration Act. u34
ImP-lementing authority was given to the Geothermal Energy Coordination and Management Project acting under joint supervision of
the Department of the Interior, National Aeronautics and Space
Administration, The Atomic Energy Commission and the National
Science Foundation.
After establishment of the Department of
Energy the sole responsibility was transferred to that department.
One of the key provisions in this act was the Loan guaranty program. 35
"The objective of the federal geothermal loan guaranty
program are:
(a) To encourage and assist the private and public
sectors to accelerate development of geothermal resources vdth
environmentally acceptable processes by enabling the Secretary
in the exercise of reasonable judgment to minimize a lenders
financial risk that is associated with the development of nev1
geothermal reservoirs and with the application of new technology;
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(b) To develop normal borrower-lender relationships which \till
in time encourage the flow of credit for geothermal energy projects
without the need for Federal assistance; and (c) To enhance
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I
competition and encourage new entrants into the geothermal
market.n3 6
In order to accomplish the above described objectives the
Secretary of the Department of Energy is authorized to guarantee
loans from private lending institutions for the development of
geothermal energy.
These guarantees are basically in an amount
not to exceed 75% of the total aggregate of the estimated costs
of the project and guaranteeing an amount not in excess of
$100,ooo,ooo.oo
for any one project or
$20o,ooo,ooo.oo
for any
single borrower when that borrower is engaged in a multiple of
projects.
The guaranty application and supervision is subject to the
normal bureaucratic stipulations and requirements, which include
the requirements for the filing of plans, environmental impact
statements, health and safety requirements, equal employment
opportunity agreements, etc.
After filing of all the above plans
and paperwork the application is still the subject of preferential
considerations.
Priorities include in descending order:
those areas which
show the most promise of success, projects utilizing new technology,
areas only partially developed vdth subsequent lower priorities
for exploration, and aquisition of land or leases.
Priorities
within the above priority categories are those in which a lender
is lending \dthout a guarantee for the full authorized amount and
those applications which are submitted by small public and private
•
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entities, and probably most important, where the Federal government vdll receive a royalty pa~nent upon production.37
Probably the most important portion of the body of Federal
law and regulation to the developer are §263 and §?805 of the
Internal Revenue Code.3 8 This portion of the code allows the
developer to treat his-expenditures in exploration similar to
that allowed the oil and gas industry.
The Developer/Taxpayer
has the option of claiming most of his non-salvageable cost in
the entire process as either expenses or of making them a part
of his capital investment and amortizing the expense over a period
of years.
Great care should be used in making the determination
ho·wever since some i terns must be expensed and some must be capitalized and on those which are optional, it appears that the
decision once made is irrevocable.
In 1975 the Texas legislature enacted the Geothermal Resources
Act39 giving general supervisory powers over development and conservation to the Railroad Commission.
The act required the
Commission to enact regulations in conjunction with the
Quality Board and the Air Control Board.4°
~Yater
The act additionally
empovrered, without directing, the Commissioner of the General Land
Office to lease Public School Land to persons or entities desiring
to explore and develop potential geothermal resources.41 Wildlife
refuges and recreational facilities were specifically excluded
from this authority.
Competitive bidding is required except in
cases involving public entities, both state and federal, desiring
to perform exploratory or experimental research in the geothermal
field of technology.
In Texas the only other pertinent legislation apparently,
•
presently in for;e is the Energy Development Act of 1977.42 The
act established the "Texas :Energy and Natural Resources Advisory
Council" composed of 21 members named in the act or appointed by
I
various named parties.
Some of the more important duties of the
council are to administer the Energy Development Fund (no more
than $5 million) established by the act and to receive and administer gifts and donations to the fund.
The stated purpose of the
fund includes development of sources of energy sufficient to meet
the needs of the state within the succeeding 25 years and thereafter.
v.
Litigation
The landmark case concerning ovmership of geothermal energy
resources is United .States v. Union Oil Co, 43
The question before
the court was ownership of the geothermal waters below land which
had been patented under the Stock-Raisers Homestead Act of 1920.44
The Stock-Raisers Homestead Act contained a clause requiring the
United States to retain title to "all the coal and other minerals
in the lands, u45
The court found that while the term minerals
did not normally imply water, that the dominant use of the waters
in question
was not for the usual use of water, i.e. as water for
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livestock or for human consumption, but rather should be viewed as
a substance providing power.
The court ruled in favor of the
retention of the rights in the United States, in effect, deciding
that the reserv·ation of minerals in the original patent included
geothermal water as sui generis v1hen included as an extention of
coal as a power producing medium.
Expostulating
. from the decision in Union Oil Co. a potential
•
lessee of privately
o\~med
lands would expect to find that in any
case where a prior O\mer had reserved all or any portion of the
minerals or where the minerals had been previously leased, the
(
geothermal waters would also be subject to an encumberance based
on the dominant use of the product.
In Texas the rule-would have been toward private ownership
in most cases unless public ownership could be proven in the case
of a defined water course under the Texas Water Code.46
Under
decisions in Acker v. Guinn47 and Reed v. Wylie48 the courts were
concerned in classifying the substance as either surface or mineral when the substance was not specifically mentioned in the deed
or lease.
The court further looked to the intent of the parties
at the time the conveyance was signed, the disruption of the surface estate in developing the mineral estate and the nature of
th~
substance to be recovered.
It appears that on the basis of this reasoning that the
geothermal waters or geopressured waters in Texas would be held
to be a mineral on the strength of their dominant use.
However
the land owner (surface estate) would most likely be compensated
for the disruption of the surface estate by power generating
facilirties, noise, etc.
The latest decision in Sun Oil Co. v.
Whitaker49 would, if followed, possibly deny the surface ovmer
even that compensation.
VI.
Concl usiori
\
A unique and normally very clean source of energy \Vhich has
the potential to greatly increase the amount of electrical power
available to the nation and reduce reliance on other depletable
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resources, which has an extremely long potential life, is in the
position of being regulated to a much greater extent than any other
source of power was regulated in its infancy with the exception
002¥3
of nuclear energy.
This regulation if accomplished rri th a
thoughtful and encouraging attitude \rill allow geothermal development to prosper and- become a major s·ource of power.
On the other
hand it can be regulated by unthinking bureaucrats to the point
of uneconomical extinction.
Even though Congress had good inten-
tions and the Texas Legislature's intentions were probably directed
toward rapid development of this resource, whether significant
economic development occurs will be a matter of time, emphasis
and bureaucratic efficiency in processing and granting the necessary
permits and licenses.
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00276
.,
END NOTES
1.
Collie, H.S. Geothermal Energy - Recent Developments, Noyes
Data Corporation, Park Ridge, New Jersey 1978 at 2.
2.
Dutcher, L.C. et • .§l., Preliminary Appraisal of Ground Water
in Storag8 '·vi th Reference to Geotherm~ Resources in
he Im eriaJ_ Val e Area California. Washington, D. C.:
u.s. Geological Survey (1972 •
I d.
-Note
5·
6.
-I d.
1 supra at
7.
at 8.
-
!d. at 9.
-!d.
8.
Id,
9.
Wilson, J.S. ~.al., An Analysis of the Potential Use of
Geothermal Energy for Power Generation AJ ong the Texa~
Gylf Coast, The Texas Division of Dow Chemical, U.S.A,
for the Governor's Energy Advisory Council, The State
of Texas (1974) at 4·
10.
54 Or. Ia R,ev 623 (1973) at 627.
11.
Note
12.
Lindsey, M.K. and Supton, P., Geo~hermal Energy, Legal Proble~s
of Resource Develoument, Stanford Environmental Lav;
Society, Stanford, Californ~a, (1976) at 29.
-13.
1 sunra at 35-36.
1lh.
1 supra. at 43·
14.
Note
15.
1 supra. at 45·
Note 12 supra, at 38.
16.
17.
18.
Note
11 sunra. at 59·
Note 11 supra. at 60.
Note
19.
-
20.
-I d.
at
65.
21.
I d.!-. at
56.
22.
43 u.s.c.A. §292.
•
I d.
oo?·-~
I o'•
. '
•
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23.
Pub. L. 91-581, 30 u.s.c. §1001-1025.
24.
43 CFR §3220.
25.
43 CFR §3210.
26.
43 CFR §3220.6(c).
27.
43 CFR §3200.0-5(k).
28.
43 CFR §3203.2.
29.
43 CFR §3205.3-5.
JJ.
&.
31.
43 CFR §3250.4-2.
32.
43 CFR §3250.5-2~
33•
43 CFR §3250.6-2.
34·
?fJ usc §1121-1147·
35.
10 CFR §790 Effective December 18, 1979.
36.
10 CFR §790.2.
37.
10 CFR §790.4(b).
38.
26 CFR §5a.
39.
Tex. Rev. Civ. Stat.~rt. 5421 now codified as Natural
Resources Code s~41.
40.
42.
-I d. at 141 •071.
I d. at 141.077.
-V.A.T.S.
art. 4413(47b)
43.
549 F.2d 1271, U.S. Ct. of Appeals, Ninth Circuit (1977).
44.
43 u.s.c.A. §292.
45.
.I.9..r.. at §499.
46.
Texas Vlater..... Code Ann. §5.001 and §5. 301.
47.
464 SW2d
48.
554 SW2d 169 (Tex. 1977).
49.
483 SW2d 808 (Tex. 1972).
41.
348~·
,
(1981 Supp.).
(Tex. 1971).
0( ~~f")
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t