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Powder River Basin Resource Council v. Wyoming Oil & Gas Conservation Commission

ELR Citation: 43 ELR 20072
Nos. 94650-C, (D. Wyo., 03/21/2013) (WIlking, J.)

A district court held that individual ingredients of hydraulic fracturing formulas are trade secrets and do not need to be publicly disclosed. The Wyoming Public Records Act does not define trade secrets, but the Wyoming oil and gas commission's policy for evaluating trade secrets is reasonable and complies with the Act. In addition, the environmental group seeking disclosure failed to establish that the commission's decision to grant trade secret protection requests were arbitrary, capricious, or not in accordance with the law. The court also noted that while both positions have merit, their competing concerns would be best addressed through legislative action or further rule promulgation.