What Contract? Unsigned Email Satisfies Signature Requirement under Texas Statute of Frauds

The Statute of Frauds is an age-old law requiring certain agreements be in writing and signed by the parties to be a binding contract. If you are thinking calligraphy, feathered pens and beautiful cursive signatures, think again. A Texas Court of Appeals recently ruled that merely having your name in the “From” field of an email constitutes a signature for purposes of satisfying the Texas Statute of Frauds. Khoury v. Tomlinson, 518 S.W.3d. 568 (Tex. App. 2017).

In the events that lead to the Khoury case, John Khoury had invested $400,000 in PetroGulf, Ltd., a company that purportedly had contracts to transport oil from Iraq to Syria and other Middle Eastern countries, in return for repayment of his investment with substantial interest. After no payments were made to Mr. Khoury, he met with Mr. Tomlinson, the President and CEO of PetroGulf, Ltd., who agreed to repay him the $400,000 over 4 or 5 years at a new interest rate. One week after the meeting, an email exchange ensued between Mr. Khoury and Mr. Tomlinson.  Read it here.

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Extension of Federal Oil and Gas Leases

Operators who do not regularly operate on federal lands may be surprised to discover that, unlike the typical private lands oil and gas lease, a federal lease does not contain a drilling operations clause that would extend the lease beyond the expiration of its primary term while drilling operations are being conducted. A recent decision of the Interior Board of Land Appeals (IBLA) drives home the importance of understanding exactly what facts are sufficient to extend a federal lease.

In Coastal Petroleum Company, 190 IBLA 347 (July 25, 2017), the IBLA upheld a decision of the Montana State Office of the Bureau of Land Management (BLM) which concluded that a lease had terminated at the end of its primary term because the lessee had not established that the well it had drilled and completed was capable of producing gas in paying quantities. Coastal’s lease would expire October 31, 2012. According to the decision, a well was spud prior to that date, the well was fracture treated on September 14, 2012, Coastal pulled two gas samples and determined that the well had good pressure and was able to flow on October 16, 2012, and Coastal received the gas analysis report on October 29, 2012. Based on these operations, Coastal concluded that at least two formations on the structure contained gas and that the well was capable of producing in paying quantities. But the BLM concluded that, without a flow test, BLM was unable to determine whether the amount of production would be of sufficient value to exceed operating costs; i.e., production in paying quantities. The IBLA agreed and noted that the burden is on the lessee to establish that a lease has been extended by a well capable of producing in paying quantities. The lesson for federal lessees is to plan operations that are intended to extend an expiring lease so that the well is completed for production and flow tested prior to the expiration date.

Another cautionary lesson from the Coastal decision is the need for a contingency plan in the event a well drilled near the end of the primary terms may not be completed as capable of producing in provable paying quantities prior to that date. Coastal argued in the alternative before the IBLA that it was engaged in testing and completing operations at the expiration of the primary term and so was entitled to a two-year extension of the lease under the "drilling over” provision of 30 U.S.C. §226(e). Coastal had not raised this argument in its request for State Director review of the BLM Field Office decision that the lease had terminated. It is not clear from the facts whether Coastal was actually conducting operations that would qualify as testing or completing under the regulation (43 C.F.R. §3100.0-5(g)) or whether Coastal had timely tendered the 11th year rental which is necessary in order to earn the drilling over extension. Instead, the IBLA refused to consider the argument at all because Coastal had not raised it before the State Director. The IBLA cited prior cases which establish that the Board will not consider issues raised for the first time on appeal except in extraordinary circumstances. The Coastal case appears to be a situation that easily could have been avoided by timing the drilling, completing and testing operations on the well to continue at the expiration of the primary term and by payment of the 11th year rental.

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Special Needs Trusts for Individuals with Disabilities

Special needs trusts are a helpful planning tool if a client has a disability or has family members or friends who are disabled. These kinds of trusts are designed to preserve a disabled person’s eligibility for government benefits. Monthly income and the value of resources in the person’s possession are evaluated to determine eligibility for certain government benefits. If disabled individuals receive public benefits, then it is possible that small inheritances or gifts may imperil their eligibility for public assistance. The goal of these trusts is to provide individuals with disabilities an option for supplementing their daily living expenses when the government benefits received are insufficient and to allow family and friends of individuals with disabilities to retain assets for accommodation of the individual’s comfort and well-being.

Special needs trusts are discretionary, spendthrift trusts. This means that the trustees of these trusts have complete control over distributions made to the beneficiaries to prevent depletion of trust funds, which could be caused either by overspending on the beneficiary’s behalf or beneficiary’s creditors reaching the trust monies. The trustee has the additional responsibility of ensuring that the amount of funds distributed to the disabled beneficiary does not render him or her ineligible for government benefits.

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Don’t Slay the Drones – New FAA Guidance for Recreational and Commercial use of Unmanned Aerial Vehicles

Lately, it seems like drones are everywhere. From flying over crowds at concerts to monitoring pipelines for leaks, drones are here to stay. As popular as drones have become, however, there is little consistent regulation from state to state, causing confusion and potential legal consequences for users, casual and commercial alike.

For example, in early 2017, a man using a drone to film elk on the National Wildlife Refuge in Wyoming spooked the herd, causing a stampede of over 1,500 animals; he was fined by the U.S. Fish and Wildlife Service for disturbing wildlife.1 Elsewhere, a suit filed in the Sixth Circuit against William Merideth, a/k/a the “Drone Slayer,” who shot down a recreational drone that was hovering over his backyard and invading his privacy, was dismissed for failing to raise a federal issue, not involving federal parties, and not being important to the federal system.2 The drone’s owner brought the suit after charges of criminal mischief and wanton endangerment against Mr. Merideth were dismissed in state court. The Federal District Judge felt that the case was more appropriately a state tort case concerning trespass and invasion of privacy. Unfortunately for Mr. Boggs, the drone pilot, Kentucky is one of several states that currently lack enacted legislation concerning Unmanned Aerial Vehicles (UAVs).3 The absence of such legislation makes it difficult for those who use drones, whether for commercial or recreational purposes, as well as those who disapprove of drones, to understand their rights when it comes to where, when, and how they may operate their UAVs.

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Colorado Legislature Protects Existing Recreational Water Rights

On May 25, 2017, the Colorado legislature passed House Bill 17-1990 addressing the 2015 Colorado Supreme Court decision of St. Jude’s Co. v. Roaring Fork Club LLC denying a private club’s ability to obtain an instream water right. Colorado, as a prior appropriation state, requires its water users to demonstrate that the water will be (1) diverted and (2) put to a beneficial use, in order to claim a water right. Beneficial use is defined by statute in C.R.S. §37-92-103(4), which by its terms does not allow private parties to appropriate instream flow rights.

In St. Jude’s Co., the applicant, Roaring Fork Club, was granted a new direct-flow appropriative right for aesthetic, recreation, and piscatorial uses. On appeal, the Supreme Court of Colorado held that a private club could not obtain a direct-flow water right for aesthetic, recreation, and piscatorial use because such uses are not beneficial uses of water under Colorado law. 351 P.3d 442, 445 ("the Club failed to demonstrate an intent to apply the amount of water for which it sought a decree to any beneficial use").

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The Complicated Consequences of a Simple Change

Colorado water law provides a simplified procedure to change a water right when the only change is in the point of diversion of a surface water right where there are no intervening diversions or inflows between the old and new locations. C.R.S. § 37-92-305(3.5). This simplified procedure makes it easier to replace old diversion structures by constructing new ones nearby without many of the risks involved in a full change of water rights proceeding.

In Select Energy Servs., LLC v. K-LOW, LLC, 2017 CO 43, 394 P.3d 695, the owner of a water right used the simplified procedure to change its point of diversion from an old ditch to a new pump downstream of the ditch. The water rights owner afterwards quit-claimed its remaining interest, if any, in the old ditch to the defendant. Id., ¶ 8. Because the water rights owner merely had an easement for the old ditch based on its water right and no ownership of the underlying land, the issue was whether it had any interest to convey to defendant after it changed its water right. Id.

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Colorado Supreme Court upholds retroactive tax assessment against oil and gas lessee

On June 19, 2017, the Colorado Supreme Court ruled against the petition of Kinder Morgan CO2 Co., LP -- the operator of oil and gas leaseholds -- disputing the Montezuma County Assessor's 2009 corrective tax assessment on leaseholds for the prior tax year which resulted in a retroactive assessment of over $2 million in property taxes. Kinder Morgan CO2 Co., L.P. v. Montezuma County Board of Commissioners; Colorado Board of Assessment Appeals; and Colorado Property Tax Administrator. The Board of Assessment Appeals upheld the retroactive assessment finding that Kinder Morgan had underreported the selling price of its production by over-deducting its costs.

Oil and gas leaseholds and lands are valued under Colorado statutes, Article 7 of Title 39, pursuant to which a lessee must submit an annual statement (reporting the volume and price of product sold at the wellhead), following which the county assessor determines property value and tax liability. See § 39-7-101 -103(2). Because the sale of unprocessed oil or gas rarely occurs at the wellhead, an operator usually estimates the wellhead selling price, deducting costs for, e.g. gathering, processing, and transporting the extracted material – called the “netback” method of calculating the wellhead price. See § 39-7-101(1)(d) (“The net taxable revenues shall be equal to the gross lease revenues, minus deductions for gathering, transportation, manufacturing, and processing costs borne by the taxpayer pursuant to guidelines established by the [Property Tax Administrator].”). The resulting price for purposes of § 39-7-101(1)(d) is an estimate. An “operator’s netback calculation depends on whether the operator contracts with a related or an unrelated party to perform these gathering, processing, and transportation services. If the operator enters into a bona fide, arm’s-length transaction with an unrelated party to perform these services, then the operator may deduct the full amount paid for these services from its final, downstream sales price in its netback calculation (the ‘unrelated-parties netback method’). See 3 Div. of Prop. Taxation, Colo. Dep’t of Local Affairs, Assessor’s Reference Library: Real Property Valuation Manual (ARL) 6.35–6.36 (Rev. Jan. 2017).” Accordingly, if, as here, “the operator instead enters into a transaction with a related party . . . then it may deduct only a portion of the amount paid for these services (the ‘related-parties netback method’). 3 ARL 6.39–6.41.” (Emphasis added.)

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Colorado Supreme Court Rules in Favor of Condominium Developers in Construction Defects Cases

On June 5, 2017, the Colorado Supreme Court issued a decision in Vallagio at Inverness Residential Condo. Ass’n v. Metro Homes, Inc., 2017 CO 69, June 5, 2017 (“Vallagio”) that will likely benefit condominium developers in Colorado by helping to alleviate litigation costs related to construction defects claims, thereby incentivizing new construction of condominiums along the Front Range.

For the past several years, the Colorado General Assembly has ardently debated construction defects reform. Senate Bill 156, introduced earlier this year, was intended to make arbitration mandatory for construction defects claims, but failed to pass. House Bill 1279 requiring the consent of the majority of condominium unit owners to bring a claim, as opposed to just the HOA board, passed this session. Developers supported both of these bills as a means to decrease the amount of construction defects claims that would be brought, thereby spurring more condominium projects in Colorado.

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Paris Agreement Exit: Who Holds the Real Power?

President Trump announced on June 1 that the United States is withdrawing from the Paris Agreement. The announcement follows months of uncertainty about whether President Trump would fulfill his campaign pledge to withdraw U.S. participation in the deal (which was signed by 195 countries with only two countries in opposition--Nicaragua (because it wasn’t stringent enough) and Syria).

According to the President, the decision is necessary to protect the U.S. economy from burdensome emissions restrictions and foreign interference in U.S. energy policy:

In order to fulfill my solemn duty to protect America and its citizens, the United States will withdraw from the Paris climate accord . . .[s]o we're getting out, but we will start to negotiate, and we will see whether we can make a deal that’s fair.

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Monument Making, the Antiquities Act of 1906 and the Extent of Presidential Power

On April 26, 2017, President Trump issued an Executive Order (“EO”), “Review of Designations under the Antiquities Act,” to address what he called a “massive federal land grab.” The EO directs Interior Secretary Zinke to review all monument designations made under the Antiquities Act since 1996 that either exceed 100,000 acres or were “made without adequate public outreach and coordination” and make recommendations on legislative or administrative changes. The following week, on May 2, 2017, the House Natural Resources Subcommittee on Federal Lands held an oversight hearing, “Examining the Consequences of Executive Branch Overreach of the Antiquities Act,” to hear from witnesses in states with “widely opposed designations.” Why all the high-level interest in a 111 year-old law?

We last blogged on this topic in October 2015 to highlight how President Obama was using the Act’s authority for his conservation legacy and to note that Congress was reacting by considering legislation to limit the Act. President Obama used his last year in office to create or expand 15 monuments from the expansion of the enormous Hawaiian Papahānaumokuākea Marine National Monument (283.4 million acres) to the designation of the tiny Stonewall National Monument (0.12 acre) in New York and, in late December, the Utah Bears Ears National Monument (1.35 million acres). In total, as was described in the Subcommittee Hearing memo, President Obama used the Act 34 times “to lock up 553,599,880 acres of land and water as national monuments” which represents “66% of all monuments ever designated.” See list in CRS, “National Monuments of the Antiquities Act” App. C (Jan. 30, 2017).

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Wyoming Supreme Court Justices Disagree: Were Tax Assessments of Minerals Constitutional?

As noted in a prior blog post, Wyoming’s Supreme Court Justices agree most of the time. In fact, in 2016 more than 95% of the Court’s orders and opinions were unanimous. This post highlights a recent disagreement between the members of the Wyoming Supreme Court in the case of Anadarko Land Corp. f/k/a Union Pacific Land Resources Corp., and Three Sisters, LLC v. Family Tree Corporation, 2017 WY 24, 389 P.3d 1218 (Wyo. 2017) concerning a 1911 tax assessment that changed--or did it--the ownership of minerals in 2017.

This case features the appeal of a district court decision upholding the validity of a 1911 Laramie County tax assessment against minerals owned by Anadarko Land Corporation’s (“Anadarko”) predecessor-in-interest1. Anadarko’s predecessor, the Union Pacific Railroad, acquired the mineral interests at issue in a Patent issued by the United States in 1901. In 1911, Laramie County assessed taxes on these unproduced minerals. Anadarko’s predecessor did not pay the assessed taxes, and Laramie County put the mineral interests up for bid at a tax sale. When no bids were made for the mineral interests, Laramie County acquired the minerals and then, by a tax deed in 1919, sold the mineral interests to Iowa Land & Livestock Company. At this point, two divergent chains of title emerged. One chain derived from Anadarko’s predecessor and the other from the Laramie County tax sale

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Colorado Legislature Considers Limitations On “Force Pooling”

Rep. Mike Foote (D-Lafayette) and Rep. Dave Young (D-Greeley) introduced House Bill HB17-1336, legislation which would prevent a lessee representing less than a majority of the mineral royalty owners from obtaining a force pooling order. The authors of the legislation argue the intent of the bill is to prevent a mineral rights owner or lessee from forcing adjacent mineral interest owners to lease their minerals and to provide better information to affected parties. In addition, the legislation would provide mineral owners with additional time to decide whether to lease, participate in proposed well(s), or decide not to participate in the drilling of proposed well(s). Proponents of the legislation also argue that under current law, an oil and gas operator has too much of an advantage when it can tell an unleased mineral owner that if he or she does not sign a lease, then they will be force pooled.

The bill was introduced late in the session where rules allow expedited consideration, with the probable strategy being to prevent extended deliberation. The bill appears to conflict with Colorado property and constitutional law. Given significant departures from existing law, a longer time is necessary to fully appreciate how current law would be changed. Here are some of the problems:

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COGCC: A Balancing Act or “Subject To” Protection of Health, Safety, and Environment – A Surprising Decision from the Colorado Court of Appeals

A recent decision from the Colorado Court of Appeals (“Court”) could mean a new focus for the Colorado Oil and Gas Conservation Commission (COGCC). On March 23, a three-judge panel issued a split decision in Martinez v. Colo. Oil & Gas Conservation Comm'n, 2017 COA 37, with two of the three Judges rejecting the COGCC’s assertion that its role under the Oil and Gas Conservation Act (Colo. Rev. Stat. §§ 34-60-101 to -130) (the “Act”), is to balance oil and gas development with other public interests such as public health, safety, and welfare.

At issue was a petition for rulemaking filed with the COGCC in 2013 by members of the Boulder-based Earth Guardians asking that the COGCC “not issue any permits for the drilling of a well for oil and gas unless the best available science demonstrates, and an independent, third party organization confirms, that drilling can occur in a manner that does not cumulatively, with other actions, impair Colorado’s atmosphere, water, wildlife, and land resources, does not adversely impact human health and does not contribute to climate change.” The COGCC solicited and reviewed a substantial amount of public input on the matter, and later denied the petition, finding, inter alia, that the proposed rule would require it to “readjust the balance crafted by the General Assembly under the Act,” thus making the proposed rule “beyond the Commission’s limited grant of statutory authority.” The petitioners appealed that decision to the Denver District Court, which affirmed the COGCC’s denial of the petition.

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Earthquakes: State Regulation of O&G Injection Wells Is OK Oklahoma Judge Dismisses Federal Lawsuit on Jurisdictional Grounds

On Tuesday, April 4, 2017, Judge Stephen P. Friot, United States District Court for the Western District of Oklahoma, dismissed a nationally significant lawsuit brought over earthquakes linked to oil and gas wastewater injection wells on jurisdictional grounds.  See Sierra Club v. Chesapeake Operating, LLC, et al., No. CIV-16-134-F (W.D. Okla., Order dated 4/4/2017) (unpublished), The court deferred to the expertise of the Oklahoma Corporation Commission (“OCC”), the state body governing wastewater injection wells in Oklahoma. Citing the actions and capability of the OCC, Friot concluded:

Every night, more than a million Oklahomans go to bed with reason to wonder whether they will be awakened by the muffled boom which precedes, by an instant, the shaking of the ground under their homes. Responding to earthquake activity is serious business, requiring serious regulatory action. The record in this case plainly demonstrates that the Oklahoma Corporation Commission has responded energetically to that challenge. Of equal importance, it is plain that the Oklahoma Corporate Commission has brought to bear a level of technical expertise that this court could not hope to match.  The challenge of determining what it will take to meaningfully reduce seismic activity in and near the producing areas of Oklahoma is not an exact science, but it is no longer one of the black arts.  This court is ill-equipped to outperform the Oklahoma Corporation Commission in advancing that science and putting the growing body of technical knowledge to work in the service of rational regulation.

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What's Up With Chevron and Does It Matter?

If you have paid any attention to the U.S. Senate confirmation process for Colorado’s Judge Neil Gorsuch to the U.S. Supreme Court, you’ve heard Chevron come up.  According to Senator Al Franken (D-Minnesota), “For anyone who cares about clean air or clean water or about the safety of our food and medicines, it’s incredibly important . . . [it] simply ensures that judges don’t discard an agency’s expertise without good reason.”  In a 2016 opinion, Judge Gorsuch called Chevron a behemoth and argued that it “permit[s] executive bureaucracies to swallow huge amounts of core judicial and legislative power and concentrate federal power in a way that seems more than a little difficult to square with the constitution of the framers’ design.”

Chevron refers to a U.S. Supreme Court decision decided 33 years ago, Chevron U.S.A., Inc. v. Natural Resources Defenses Council, Inc., 467 U.S. 837 (1984) that embodies the judicial doctrine of court “deference” to an agency’s interpretation of ambiguous federal statutes.1   In Chevron, the Supreme Court reasoned that an agency is the subject matter expert and should have the authority to make policy choices – within reason.

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Wyoming Wolves De-Listed Under the Endangered Species Act

On March 3, 2017, the D.C. Circuit reinstated the rule promulgated by the United States Fish and Wildlife Service (“FWS”) in 2012 to remove the Northern Rocky Mountain gray wolf in Wyoming from the endangered species list under the Endangered Species Act (“ESA”). Defenders of Wildlife v. Zinke, --F.3d.--, 2017 WL 836089 (D.C. Cir. Mar. 3, 2017).  The FWS has been trying to turn over the management of the wolves in Wyoming to the state since 2008, but has faced several reversals at the hands of the courts.  This decision reverses a 2014 ruling of the U.S. District Court, District of Columbia that vacated the FWS 2012 rule delisting the gray wolf.

Although the D.C. District Court agreed with the FWS finding that the species had recovered and did not overturn FWS’ determination that the gray wolf is not endangered or threatened within a significant portion of its range, it found fault with the state plan to guarantee the required baseline wolf population.  The District Court denied the delisting of the gray wolf because FWS did not require Wyoming to meet a specific numeric buffer above the baseline population but instead relied upon representations in a “non-binding” Addendum to its wolf management plan.  On appeal the D.C. Circuit disagreed, and held that nothing in the ESA demands that level of certainty.  The Court stated that:

[FWS’] decision to delist in the absence of legal certainty is compatible with the ESA’s requirement for monitoring of the species after delisting ‘for at least five years' and its emergency provisions authorizing the [FWS] to take immediate action to ensure the delisted species does not become threatened or endangered again.

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Employer Alert: Colorado Supreme Court Narrows Employer Liability in Negligence Cases

The Colorado Supreme Court recently issued a decision that significantly reduces an employer’s liability in cases where both the employer and the employee are sued for injuries caused by the employee while performing job duties.  

In Ferrer v. Okbamicael, 2017 CO 14, decided on February 27, 2017, a pedestrian sued a taxi cab company and the taxi cab driver who struck her while on the job, causing significant injuries.  The pedestrian asserted two types of claims against the taxi cab employer: one based upon the doctrine of respondeat superior, where an employer is indirectly liable for the acts of its employees, and additional direct claims for negligent hiring, entrustment, supervision and training.  The taxi cab employer admitted that the taxi cab driving was acting within the scope of his employment duties at the time of the accident, thereby conceding the respondeat superior claim, but argued that this concession meant that it could not also be held liable on the direct negligence claims.  The Colorado Supreme Court agreed, establishing new law that an employer can avoid direct claims of negligence in this context by conceding that the employee was acting within the scope of employment at the time of the injury.  

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Update to February 11, 2016 Blog Post/Weed and Water - Can Water Be Used for Marijuana Cultivation in Colorado

Last Year, WSMT blogged about whether water could be lawfully appropriated for Marijuana cultivation.  2/11/16 blog post.  We provided three arguments why that would be allowed.

Almost exactly a year later, the Division  water referee agreed In Re High Valley Farms, LLC, 14CW3095 with two of the reasons we set forth in our blog from last year - namely that appropriation of water is controlled by state law, and that the word "lawfully" in the state law definition of beneficial use of water means that the appropriation, not the use of the water, must be lawful.  A copy of the February 17, 2017 order is available here.

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Wyoming Legislature Rejects Attempts to Penalize Wind Energy Industry

In a state that has been described as having “world class wind,” a boast hard to ignore during a winter that featured days upon days of wind gusts reaching 80 mph at times, wind energy has struggled to find a secure toehold due to the vice-like grip traditional extractive mineral industries have on the energy sector in Wyoming.  That may be changing, however.

This year, bills were proposed in both the Wyoming House and Senate that sought to limit the ability of wind producers to market their product within the State.  Luckily (or not, depending on your point of view), each bill failed in committee before being introduced on the floor of either house.  House Bill 127 sought to increase the tax on wind energy from $1.00/megawatt hour to $5.00/megawatt hour.  This bill was defeated by a 7-2 vote by the House Revenue Committee on January 23, 2017.  In the Senate, Senate File 71 proposed that utility companies that use wind or solar power would incur a penalty of $10.00/kilowatt hour starting in 2019.  After widespread public opposition to this bill reached the desks of the Senate, it died in committee.  So, while Wyoming is the only state in the U.S. to tax wind1, and while wind producers still face a more difficult permitting process before the Industrial Siting Council than their traditional extractive mineral counterparts, the State legislature prevented two significant roadblocks to future development from being erected.

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After Years of Planning, the Forest Service Approves Arapahoe Basin’s Ski Area Expansion (WAHOOOO!)

On March 3rd, the attorneys of Welborn Sullivan Meck & Tooley will embark on our annual ski trip to Arapahoe Basin in the White River National Forest.  We look forward to the trip as a highlight of each winter season and, if we’re being honest with ourselves, a highlight of the year when all the hustle of firm life is exchanged for the exhilaration of a ski day in the Colorado mountains.  It is not too often that we lawyers get outside for an entire day to rip runs and bask in the sun.  

This year we will miss our fearless leader on the slopes and winter’s biggest fan, Chelsey Russell.

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