The State of Missouri has untapped potential for the development of oil and natural gas resources. While the Missouri courts were quiet this past year on interpreting oil and gas rules and regulations, the legislature was active in amending laws governing storage tanks. The state has experienced a tremendous upsurge in oil and gas production in the past two fiscal years. Missouri is poised to ramp up its conventional oil and gas production in the coming years, so increased legisla- tive actions and court activity will likely occur in the near future. Missouri\u27s energy resources include coal bed methane, oil sand, and oil shale. Despite the limited supplies of traditional hydrocarbons, considerably large deposits of heavy oil exist, which are of interest to energy producers. According to the Missouri Department of Natural Resources, improving technologies along with efficient, environmentally responsible oil production, will result in increased economic benefit to the state in the form of jobs and revenue