Oil Well Maintenance Zoning Administrator's Interpretation(ENV-2025-3305-CE-1A)

2026050298

City of Los Angeles

NOE - Notice of Exemption

5/7/2026

5/7/2026

Edber Maceda

City of Los Angeles, City Planning Department

City Planning Associate

Lead/Public Agency

200 N. Spring St Room 763
Los Angeles, CA 90012

(213) 978-1318

edber.macedo@lacity.org

Citywide (City of Los Angeles)

Other

Section 15061 {b}(3}

The issuance of this citywide Zoning Administrator's Interpretation (ZAI) that defines "well maintenance" is not a "project" as that term is defined by California Environmental Quality Act (CEQA) Guidelines Section 15378 as it constitutes an administrative and procedure-making activity to memorialize the formal interpretation of the term "maintain" in the City's oil well regulations found in Los Angeles Municipal Code Section 13.01 . Even if this ZAI is determined to be a project for purposes of CEQA, it is exempt pursuant to CEQA Guidelines Section 15061(b)(3) (Common Sense Exemptions), because it can be seen with a certainty that there is no possibility that the project may have a significant effect on the environment; and that, if the ZAI is a project under CEQA, it is also exempt pursuant to CEQA Guidelines Section 15308 (Class 8), and that there is no substantial evidence demonstrating that an exception to a categorical exemption under CEQA Guidelines Section 15300.2 applies. Section 15308; Class 8: Consists of actions taken by regulatory agencies, as authorized by state or local ordinance, to assure the maintenance, restoration, enhancement or protection of the environment where the regulatory process involves procedures for protection of the environment. The Department of City Planning is one of the City's regulatory agencies which control oil drilling in Los Angeles by determining the methods, standards and conditions for oil drilling sites in the City. The Los Angeles Municipal Code (LAMC) contains several Zoning Code provisions that regulate oil and gas drill sites. These sites are primarily regulated by LAMC Section 13.01. LAMC Section 13.01-H of Chapter 1 states that any person desiring to "drill, deepen, or maintain an oil well. .. " requires a determination from the Zoning Administrator. The Zoning Code does not specify what activities qualify as "maintenance of an oil well." This ZAI memorializes the interpretation of well maintenance as applicable in LAMC Sections 13.01-H and I. More specifically, this ZAI interprets the term "maintain" in the LAMC Sections 13.01-H and I. In the past, the Office of Zoning Administration (OZA) defined this term on a case-by-case basis, and has been asked by operators, advocacy groups, and interested parties to standardize a formal interpretation as to what constitutes well maintenance as it appears in the Zoning Code. The ZAI standardizes the formal interpretation of what the term, well maintenance, entails as needed for the land use regulation of drill sites set forth in LAMC Sections 13.01-H and 13.01-1. The ZAI memorializes the formal interpretation of activities that are considered well maintenance as it corresponds to LAMC Sections 13.01-H and 13.01-1. The issuance of this ZAI that defines "well maintenance" serves as an administrative and procedure-making activity that standardizes an existing interpretation of what constitutes well maintenance and is exempt under the Class 8 and common sense exemptions. The ZAI provides a definition of oil well maintenance to implement a review process intended to minimize land use impacts, such as elevated noise levels, frequent odor events, increased emissions exposure, spill incidents affecting the public right-of-way, and truck traffic congestion, among others. Thus, the ZAI is an action taken by a regulatory agency, as authorized by local ordinance, to assure the maintenance, restoration, enhancement, or protection of the environment. Moreover, the ZAI only provides a definition and interpretation of preexisting language in the Zoning Code. The issuance of this formal interpretation in the ZAI does not have the potential for causing a significant effect on the environment. None of the exceptions to the Categorical Exemption(s) under CEQA Guidelines Section 15300.2, applies to the proposed project. As detailed in the administrative record, the proposed project will not result in significant cumulative impacts from successive projects of the same type in the same place. The project does not present unusual circumstances. The proposed project will not damage scenic resources in a state scenic highway. The project site is not on a list compiled pursuant to Government Code Section 65962.5 related to hazardous waste sites. The project will not cause a substantial adverse change in the significance of a historical resource. The ZAI also qualifies for the common sense exemption, Section 15061(b)(3), which applies when it is clear that an action has no possibility of causing a significant environmental effect. The ZAI does not in itself authorize or limit maintenance activity. The ZAI only interprets the term "well maintenance," in a way that is consistent with the City's long-standing practice of requiring review by the Zoning Administrator for these types of maintenance activities. There is no reasonable possibility that this interpretation will itself cause a direct or indirect environmental impact.

Categorical Exemption

Section 15308 / Class 8

The issuance of this citywide Zoning Administrator's Interpretation (ZAI) that defines "well maintenance" is not a "project" as that term is defined by California Environmental Quality Act (CEQA) Guidelines Section 15378 as it constitutes an administrative and procedure-making activity to memorialize the formal interpretation of the term "maintain" in the City's oil well regulations found in Los Angeles Municipal Code Section 13.01 . Even if this ZAI is determined to be a project for purposes of CEQA, it is exempt pursuant to CEQA Guidelines Section 15061(b)(3) (Common Sense Exemptions), because it can be seen with a certainty that there is no possibility that the project may have a significant effect on the environment; and that, if the ZAI is a project under CEQA, it is also exempt pursuant to CEQA Guidelines Section 15308 (Class 8), and that there is no substantial evidence demonstrating that an exception to a categorical exemption under CEQA Guidelines Section 15300.2 applies. Section 15308; Class 8: Consists of actions taken by regulatory agencies, as authorized by state or local ordinance, to assure the maintenance, restoration, enhancement or protection of the environment where the regulatory process involves procedures for protection of the environment. The Department of City Planning is one of the City's regulatory agencies which control oil drilling in Los Angeles by determining the methods, standards and conditions for oil drilling sites in the City. The Los Angeles Municipal Code (LAMC) contains several Zoning Code provisions that regulate oil and gas drill sites. These sites are primarily regulated by LAMC Section 13.01. LAMC Section 13.01-H of Chapter 1 states that any person desiring to "drill, deepen, or maintain an oil well. .. " requires a determination from the Zoning Administrator. The Zoning Code does not specify what activities qualify as "maintenance of an oil well." This ZAI memorializes the interpretation of well maintenance as applicable in LAMC Sections 13.01-H and I. More specifically, this ZAI interprets the term "maintain" in the LAMC Sections 13.01-H and I. In the past, the Office of Zoning Administration (OZA) defined this term on a case-by-case basis, and has been asked by operators, advocacy groups, and interested parties to standardize a formal interpretation as to what constitutes well maintenance as it appears in the Zoning Code. The ZAI standardizes the formal interpretation of what the term, well maintenance, entails as needed for the land use regulation of drill sites set forth in LAMC Sections 13.01-H and 13.01-1. The ZAI memorializes the formal interpretation of activities that are considered well maintenance as it corresponds to LAMC Sections 13.01-H and 13.01-1. The issuance of this ZAI that defines "well maintenance" serves as an administrative and procedure-making activity that standardizes an existing interpretation of what constitutes well maintenance and is exempt under the Class 8 and common sense exemptions. The ZAI provides a definition of oil well maintenance to implement a review process intended to minimize land use impacts, such as elevated noise levels, frequent odor events, increased emissions exposure, spill incidents affecting the public right-of-way, and truck traffic congestion, among others. Thus, the ZAI is an action taken by a regulatory agency, as authorized by local ordinance, to assure the maintenance, restoration, enhancement, or protection of the environment. Moreover, the ZAI only provides a definition and interpretation of preexisting language in the Zoning Code. The issuance of this formal interpretation in the ZAI does not have the potential for causing a significant effect on the environment. None of the exceptions to the Categorical Exemption(s) under CEQA Guidelines Section 15300.2, applies to the proposed project. As detailed in the administrative record, the proposed project will not result in significant cumulative impacts from successive projects of the same type in the same place. The project does not present unusual circumstances. The proposed project will not damage scenic resources in a state scenic highway. The project site is not on a list compiled pursuant to Government Code Section 65962.5 related to hazardous waste sites. The project will not cause a substantial adverse change in the significance of a historical resource. The ZAI also qualifies for the common sense exemption, Section 15061(b)(3), which applies when it is clear that an action has no possibility of causing a significant environmental effect. The ZAI does not in itself authorize or limit maintenance activity. The ZAI only interprets the term "well maintenance," in a way that is consistent with the City's long-standing practice of requiring review by the Zoning Administrator for these types of maintenance activities. There is no reasonable possibility that this interpretation will itself cause a direct or indirect environmental impact.