April 14, Re: Comments on Draft Background Report for Ventura County General Plan Update

Transcription

1 Ms. Susan Curtis Project Manager, General Plan Update Ventura County Resource Management Agency 800 S. Victoria Avenue Ventura, CA Re: Comments on Draft Background Report for Dear Ms. Curtis, This report constitutes our current comments on the Draft Background Report (the report) prepared for the current. We understand our comments will be both responded to and included in the draft report submitted for adoption to the Planning Commission at a hearing date to be determined. First, CFROG asks that the Background Report be not only reviewed for adoption by the Planning Commission, but also go before the Board of Supervisors for final adoption. As elected officials, who can only be removed from office by the will of the people, the Supervisors are the appropriate body to make the final determination on a document that is creating the baseline for analysis of the General Plan under the California Environmental Quality Act. Regional Market Trends This section comments on labor trends in the region and Ventura County and thus, should contain information about the current existence or lack of jobs in the alternative green energy field and the potential for growth in this sector. The report provides information on the current state of oil and gas jobs and should also state the expected decline in production and anticipated resulting job losses based on dwindling reserves and efforts to shift away from fossil fuel based energy. PO Box 114 Ojai, CA ed@cfrog.org CFROG is a 501(c)(3) tax-exempt organization

2 Page 2 of 6 Solid and Hazardous Waste Disposal and Recycling Oil field waste disposal is a major component of the oil and gas industry, and as long as Ventura County has oil and gas production it must also have methods for disposal. Currently there is one commercial Class II Oil Field Waste Disposal company (Anterra) in operation and one company has applied for a land use permit under new ownership. These facilities should be included in any baseline report of the County, along with mention of the many waste injection wells operated by individual oil companies, and any other facilities, such as sump pits that are currently permitted by the Ventura County Air Pollution Control District. Air Quality While there are no defined boundaries to the Ventura County air shed for modeling purposes, some areas such as valleys like the Ojai Valley and Simi Valley are prone to trapping pollutants resulting in poorer air quality. In the second paragraph of this section the use of the term resistance is unnecessary and inappropriately technical, and it is more common to refer to particle size as aerodynamic diameter. While it is correct that today mobile sources are the largest contributor of ozone precursors, the CA ARB is projecting that by 2020 off-road emissions, mostly of small lawn and garden equipment, will overtake emissions from the combined emissions of passenger vehicles. This is due to the sharp reduction in vehicle emissions. This will impact air quality and sources in Ventura County over the next 20 years. Please see the attached document, written and also submitted separately by CFROG Advisory Board Member Steven D. Colome, Sc.D. Mineral Resources- The number of currently active oil and gas wells oil and gas wells in Ventura County should be listed. According to the Division of Oil, Gas and Geothermal Resources (DOGGR) as of April 14, 2017 there are 3,715 active onshore and 92 active offshore oil and gas wells permitted in Ventura County. That is an increase from Spring The fact that production has declined and continues to do so should be listed. The actual or average number (over a certain period of time) of reported spills, leaks and discharges, explosions and so on should also be included as part of a baseline statement. Energy Resources The report currently states that it is unlikely for more offshore oil and gas development to occur in our area. We do not agree. With the political shifts occurring at the federal level, we are currently seeing efforts to remove protections in our National Marine Sanctuaries, National Parks, National Forests and other protected areas, which have prevented

3 Page 3 of 6 oil and gas activity from expanding in those areas. Moratoriums on drilling are being lifted. The potential for more drilling and fracking in federal and protected areas is there, and should be included in the report. And while we hear about dwindling oil and gas reserves, we continue to see oil and gas expansion in our land use process, and more leases being signed. This trend should be included. Water Resources The vulnerability of our water sources to impacts from discharges, spills and leaks from aging oil and gas infrastructure, human error, natural disasters, seismic events, inevitable system failures and so on, should be included in the report. Hazards and Safety Section 11.1 Geologic and Seismic Hazards Seismic vulnerability should be considered in relation to the extensive network of unmapped gathering pipelines and idle wells and other aging and unknown oil and gas infrastructure throughout the County. In the actual chapter regarding Seismic Hazards a map of the faults and known pipelines should be included. A statement recognizing that many miles of gathering and flow pipelines are not mapped and that this increases the County s vulnerability to emergency situations in the event of a seismic event should also be part of this section. The fact that the County does not have any information related to seismic vulnerability of the oil and gas infrasture should be included. Chapter 12: Climate Change Section 12.1 Greenhouse Gas Emissions: The California Air Resources Board (CARB) has released a new report on Short-Lived Climate Pollutants (SLCP) and their impact on air quality and Climate Change. SLCP is not mentioned at all in the Background report. This is surely an oversight. It should be included in the Executive Summary that SLCP account for 40% of climate forcing and that the CARP report states, Ultimately, to eliminate fugitive methane emissions, the State needs to transition away from its use of oil and natural gas." The executive summary should also make clear that Ventura County will continue to be in nonattainment status past the year 2020 if the current Air Quality Management Plans are relied upon. Please see the attached document submitted by Dr. Colome for additional comments regarding the Climate Change portion of the report.

4 Page 4 of 6 Comments regarding references to oil and gas production throughout the Background Report. We understand the role of the Background Report is to be an objective statement of the current situation in Ventura County. If that is the case, then it would be misleading to make any indication that hydraulic fracturing fracking is currently taking place in Ventura County. CFROG understands that only one fracking permit has been approved in Ventura County since And that permit was not used by the operator. Therefore, no fracking has occurred in Ventura County since And while it is reported that most - if not all - wells in Ventura County have been fracked in past decades, new technology has been developed and applied to the process, as well as other extraction enhancement methods. So fracking that would take place in the future is not the same as fracking that has occurred over the past 100+ years in Ventura County. If fracking is going to be mentioned in the report the language should be accurate and non-biased. In addition, in order to be truly objective, if the Background Report is going to mention the use of fracking nationwide, it must also state that fracking is being banned in some areas, and that new studies are linking both fracking and/or the injection of fracking waste to water contamination and other health risks/impacts, including induced earthquakes. Also, there is no information that fracking in the future would lead to economic benefit for Ventura County as the industry has stated fracking has NOT tapped the reserves in the Monterey Shale formation. The report states that some enhanced methods are being used less in recent years. But in fact, we are still seeing considerable amounts of cyclic steam, water flooding etc. Records from the Los Angeles Regional Water Quality Control Board include AERA Energy s plans for water flooding etc. The report must also mention the growing public sentiment opposed to fossil fuel extraction and facilities that utilize fracked gas and how that may impact economic drivers in this industry and also the development and availability of new cleaner technology battery storage, solar, geothermal etc. may have an impact in this industry over the next 20 years. Los Padres National Forest- There is oil and gas activity in and around National forest land. Including roadways, pipelines and other infrastructure. Disadvantaged Unincorporated Communities- All communities that have high ratings in the CalEnviroScreen tool should be included in the baselines assessment for the General Plan. California has laws regarding Environmental Justice and that must be taken into account in the General Plan Update process. Piru There is expanding oil and gas activity in the canyons behind the community of Piru any further expansion of oil and gas activity in the area has the potential to impact air quality and water. More wells mean more air emissions, more risk of leaks, more oil and more waste leads

5 Page 5 of 6 to more oil tanker trucks traveling through Piru. Anywhere oil and gas activity expands there is an increased potential for spills, leaks and discharges into the air and onto the ground creating an increase in the potential for impacts to public health and the environment. Description of Ojai Valley Area Plan The report should include a description of the unique bowl or bath tub topography of the Ojai Valley, creating a situation where the area is uniquely subject to poor air quality when pollutants are present and become trapped. This also applies, although to a somewhat lesser degree in Simi Valley. Ventura River Map: The map showing the oil and gas development along Ventura Avenue seems to not include the intensity of wells on the north side of highway 33. Accurate maps must be used. Here is a map from 2016, new data is available showing more wells today.

6 Page 6 of 6 Comments regarding Multi-Hazard Management Plan - The hazardous materials component, which includes oil and gas activities should be part of this Background Report and part of the General Plan update process for the following reasons. 1. Ventura County is the third largest oil and gas producing county in the state. As such it has large volumes of hazardous crude oil, acid, produced brine water, and other chemicals in storage tanks, pipelines, tanker trucks, and miscellaneous oil infrastructure facilities scattered throughout the County. 2. The age, status and location of these tanks and pipelines are unknown as there is no Ventura County database information on all of these components and facilities. 3. Many of these facilities are located in areas of high flood, wildfire, and landslide danger. 4. Most of these facilities are vulnerable to earthquake damage as they are located on or near major active faults throughout the County. The benefits of including Hazardous Materials to the Multi-Hazard Management Plan are that it would require the following actions: 1. Hazard Analysis: This would include the nature, history, location, extent and probability of future events for each hazard. 2. Vulnerability Analysis: This analysis would allow Ventura County to attain a realistic estimate of the hazards to population, housing, critical infrastructure such as hospitals, emergency response, government and education facilities. 3. Capability Assessment: This would evaluate the technical, human, financial, legal and regulatory resources available for hazard mitigation. 4. Mitigation Strategy: This would provide a blueprint for reducing the potential losses identified in the vulnerability analysis. This would also force the development of a mitigation action plan that would coordinate the efforts of DOGGR, Cal Fire, Regional Water Board and Fish and Wildlife and give the Environmental Health Department more responsibility and oversight of hazardous materials incidents and disasters. Sincerely, Kimberly Rivers Executive Director Cc: Shelley Sussman Kimberly Prillhart Chris Stephens