Maples

This appeal concerns the valuation of petroleum and natural gas rights as taxable real property interests. Appellant James W. Maples (Assessor) appeals from a judgment denying a petition for writ of administrative mandate. He petitioned for the writ in his capacity as Assessor/Recorder of the County of Kern. Assessor sought to overturn a decision of respondent Kern County Assessment Appeals Board (AAB) reducing Assessor’s valuation of certain property owned by real party in interest Occidental of Elk Hills, Inc. (Occidental), from an assessed value of $3.65 billion to an adjusted value of $1,921 billion. Occidental cross-appeals from the trial court’s denial of its motion for statutory attorney fees. We will reverse the judgment and direct the trial court to grant the writ, in part. Because Occidental has not prevailed in the underlying action, its cross-appeal is moot.

Facts and Procedural History

In 1912, the United States established the “Naval Petroleum Reserve Numbered 1” in Kern County (the Reserve). The Reserve comprises 36,922.49 acres and is approximately 78 percent of the Elk Hills oil field, one of the top 10 petroleum fields in the continental United…