Exxon Mobil Corp. v. County of Santa Barbara

In this tax refund case, Exxon Mobil Corporation (Exxon) challenges the method by which the county assessor and county assessment appeals board valued its oil processing facility for the 1993-1996 tax years. (Rev. & Tax. Code, § 5140 et seq.) The trial court found that the Santa Barbara County Assessment Appeals Board (Board) used the wrong valuation methodology and remanded the matter for further proceedings. County of Santa Barbara (County) appeals. We affirm.

Facts and Procedural History

Exxon owns and operates the Santa Ynez Unit (SYU). It consists of 76,200 acres of offshore oil and gas leaseholds in federal waters off the coast of Santa Barbara County. The SYU includes production platforms, pipelines, and oil transmission and processing facilities. Crude oil and natural gas are transmitted to Exxon’s Las Flores Canyon facility (LFC), an onshore oil processing facility. There, crude oil is separated from the oil-water emulsion and sold to refineries. Natural gas is also extracted from the oil-water emulsion to power a 45-megawatt cogeneration facility which provides electricity to the SYU onshore and offshore facilities. Some of the natural gas is sold to Pacific…