5.0 ALTERNATIVES 5.0 ALTERNATIVES

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1 5.0 ALTERNATIVES The California Environmental Quality Act (CEQA), Section , requires an Environmental Impact Report (EIR) to describe a reasonable range of alternatives to a project or to the location of a project which could feasibly attain its basic objectives, but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. This section discusses a range of alternatives to the proposed Project, including alternative arrangements and a No Project Alternative. Criteria used to evaluate the range of alternatives and remove certain alternatives from further consideration are addressed. The CEQA Guidelines, Section , provide direction for the discussion of alternatives to the proposed Project. This section requires: A description of...a range of reasonable alternatives to the project, or to the location of a project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives ( (a)). A setting forth of alternatives that...shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project ( (f)). A discussion of the No Project alternative, and...if the environmentally superior alternative is the No Project alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives ( (e)(2)). A discussion and analysis of alternative locations that would substantially lessen any of the significant effects of the project ( (f)(2)(B)). This EIR has used an alternatives screening analysis to define a reasonable range of alternatives to be evaluated in the EIR. In accordance with CEQA Guidelines Section (c), this alternative screening analysis identifies the alternatives proposed during the scoping process and considered by staff and explains why some of the proposed alternatives were rejected for further analysis. A detailed analysis and a comparison of the impacts of each of the alternatives that are selected for further evaluation and identification of the environmentally superior alternative are provided in this section. This screening methodology also uses the rule of reason approach to alternatives as discussed in State CEQA Guidelines (Section (f)). The rule of reason approach has been defined to require that EIRs address a range of feasible alternatives that have the potential to diminish or avoid adverse environmental impacts. The State CEQA Guidelines state: "The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the Lead Agency determines could feasibly attain most of the basic objectives of the project (Section (f))." In defining feasibility of alternatives, the State CEQA Guidelines state: "Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries (projects with a regionally significant impact should consider the regional context), and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site (Section (f)(1))." 14EIR February 2015

2 If an alternative was found to be technically infeasible, then it was dropped from further consideration. This was the primary feasibility factor that was used to eliminate an alternative without further screening analysis. Feasible means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors (CEQA Guidelines 15362). In addition, CEQA states that alternatives should attain most of the basic objectives of the project... (Section (a)). If an alternative was found to not attain the basic objectives, then it was also eliminated. The use of a screening analysis for the alternatives ensures that the full spectrum of environmental concerns is adequately considered, and that a reasonable choice of alternatives is selected for evaluation in the EIR. Given the CEQA mandates listed above, the remainder of this section covers: (1) a brief description of a range of reasonable alternatives to the proposed Project; (2) a screening analysis that summarizes and compares the significant environmental effects of each alternative; and (3) an environmental analysis of the alternatives that were selected for further consideration in the EIR, which are discussed in detail in this section. A summary of the results of the screening analysis is presented in Table Description of Alternatives and Screening Analysis A variety of alternatives for the Project was considered in a screening analysis to determine potential alternatives which might produce fewer significant impacts, or reduce the severity of those significant impacts, than the proposed Project. The approach taken was to list a wide number of possible alternatives and then screen those to only the alternatives that would satisfy the following: The alternative is technically feasible; The alternative would avoid or substantially lessen any of the significant impacts of the proposed Project; and The alternative would attain most of the basic proposed Project objectives (see section 2.0, Project Description). Alternatives considered included the No Project Alternative, those associated with different drilling and processing locations or arrangements. As shown in Table 5-1, the following alternatives were selected for further analysis in this EIR, and are analyzed in the following sections: No Project Alternative; CTS Alternative; Careaga Alternative; and Careaga and CTS Alternative. In addition, four alternatives were examined and screened out. These were the 1) Reduction of the total number of wells drilled; 2) Use of less intensive methods for oil extraction; 3) Solar Steam Generation; and 4) Consolidated Pods. These alternatives are discussed below. 14EIR February 2015

3 Table 5-1 Summary Results of the Alternatives Screening Analysis Alternative No Project Alternative: no new diatomite wells Reduction of the total number of wells drilled Use of less intensive methods for oil extraction Solar Steam Generation Consolidated Pods Alternative CTS Alternative Careaga Alternative Careaga and CTS Alternative Screening Result Retained for full analysis (as required by CEQA) Eliminated Eliminated Eliminated Eliminated Retained for full analysis Retained for full analysis Retained for full analysis No Project Alternative The CEQA requires that the alternative of the No Project be evaluated along with its impacts as part of the EIR (CEQA Guidelines Section (e) (1)). For projects that are other than a land use or regulatory plan, the No Project Alternative is the circumstances under which a project does not proceed. If disapproval of the project under consideration would result in predictable actions by others, such as the proposal for another project, this No Project consequence should be discussed (CEQA Guidelines Section (e)(3)(B)). The CEQA Guidelines go on to say that the Lead Agency should analyze the impacts of the No Project Alternative by projecting what would reasonably be expected to occur in the foreseeable future if a proposed Project was not approved (Guidelines Section (e)(3)(C)). The Applicant s proposed Project is the drilling of up to 144 oil wells and production from up to 96 wells and the associated pipelines and production infrastructure for exploration and production of oil and gas resources. With the No Project Alternative, no new wells would be drilled and the field would continue to be developed with the existing 96 diatomite wells. Under the No Project Alternative, no new activity would occur at the Project Site. Because CEQA requires the EIR to analyze the No Project Alternative, it has been retained for further analysis Reduced Wells Alternative This section describes the alternative of reducing the number of wells of the proposed Project to a number that would reduce impacts. Impacts associated with the proposed Project would be associated with air emissions and GHG, impacts to biological resources and hydrology. The only impacts that are anticipated to produce potentially significant and unavoidable impacts would be those to biological resources and hydrology related to oil spills or oil seeps. Air emissions of criteria pollutants would be less than the SBCAPCD thresholds. GHG emissions would exceed the screening thresholds, but those cumulative impacts would be mitigated to a level considered to be less than significant through the purchasing of offset credits approved by the SBCAPCD. Impacts to other issue areas, including impacts to biological resources due to pod expansion; traffic; and cultural resources, would be less than significant. A reduction in the number of wells would reduce the amount of crude oil being transported through pipelines and would reduce the potential sizes of spills from pipelines. A reduction of 50 percent, to 74 wells, would correspondingly reduce the crude oil production and transportation by approximately 50 percent. Spill from a pipeline rupture would be reduced due to the reduced throughput, but would still remain substantial due to the draindown volume, which is not a function of throughput. However, 14EIR February 2015

4 reducing the number of wells would not achieve the Project s objectives (see Section 2.0, Project Description), and spill risks to hydrology and biological resources would remain significant and unavoidable. This alternative has, therefore, been eliminated from further consideration Less Intensive Oil Extraction Methods This section describes the alternative of utilizing different methods of extracting the oil from the formations. The Applicant has proposed the use of steam to extract the crude oil. The production of steam requires a substantial amount of energy as water must be purified and then heated to produce the steam. Less energy intensive methods can be used, including hot water flooding or cold water flooding. The use of hot water flooding requires that water be heated to lower temperatures than required to produce steam, thereby using less energy, and then injected into the formation to mobilize the crude oil. Cold water can also be used, which does not require any heating, and therefore uses minimal energy. Generally, the use of hot water instead of steam produces less crude oil recovery due to the lack of steam pressure and gas drive in addition to the viscosity reduction and swelling as a recovery mechanisms due to the higher temperatures. Depending on the crude oil characteristics and soil properties and the amounts of material injected, steam can recover over 80 percent of the crude oil while hot water injection can recover approximately 20 percent. Cold water flooding could extract approximately 5 percent of the crude oil (Allawzi 2008). As hot water injection would recover substantially less of the crude oil than the proposed Project, the use of a hot or cold water flooding alternative does not meet the Project objectives (see Section 2.0, Project Description) and has been eliminated from further consideration Solar Steam Generation Alternative Emission reductions could be achieved through the installation of solar facilities on or near the Project Site. Installation of thermal-solar systems to produce steam could reduce GHG emissions. Utilizing mirror systems, the sun can be concentrated to produce high enough temperature to produce steam. This steam could then be used to supply steam to the Project. Chevron is currently implementing a program similar to this in Coalinga to produce some steam for their thermal wells. The amount of steam that could be produced would equal the amount of steam that would be produced from the purchased natural gas. The produced gas or natural gas would continue to be utilized for steam production and emissions would still be associated with the combustion of produced/ natural gas at the Project Site. A thermal-solar project could generate significant impacts related to biological resources or to agricultural resources. Also, steam could only be produced during sunny days and during the daytime, reducing the efficiency of the steam injection process. It would also take a large area for installation of solar facilities to produce the equivalent amount of steam. For example, a 100 acre site could generate about 1,000 mmbtu/day, or about 25 percent of the total steam generator capacity. Although this approach would reduce onsite GHG emissions, it does not necessarily introduce greater efficiencies than the mitigated Project, where GHG reductions would be required as part of the mitigation measures. Due to the potential permitting and biological impacts due to the large area that would be needed for installation of solar facilities, and the continued need for the combustion of the produced/landfill gas onsite, thereby not eliminating onsite GHG emissions, this alternative has been eliminated from further consideration Consolidated Pods Alternative Grouping well locations on to fewer pods would allow for a potential reduction in the additional disturbed areas around existing pods, thereby potentially reducing the impacts to biological resources. The new proposed Project well locations are essentially grouped into two areas: Pods 8, 9, 10, 11 and 12; and Pods 14EIR February 2015

5 13, 14 and 15. By combining the wells in these areas into two pods, the areas of disturbance would be reduced. The first group (Pods 8-12) could be consolidated onto Pod 9, and the second group (Pods 13-15) could be consolidated onto Pod 14. In addition, consolidation of the proposed Project wells into two pods would reduce pipeline disturbance areas by approximately 0.46 acres by eliminating the need for pipeline segments 2, 3, 4, and 5, reducing impacts to oak woodland, chaparral and scrub by 0.26 acres. It would also eliminate about 3,100 feet of pipeline within the Project Site. Pods 9 and 14 would need to be increased in size in order to fit the additional wells associated with this alternative. Pod 9 would need to be increased in size from 0.30 acres to about 1.0 acre, most likely to the north and east. Pod 14 would need to be increased in size from 0.43 acres to about 0.75 acres, most likely to the east. Pods 9 and 14 each have minimal areas of sensitive biological species, but could incur additional biological impacts, as they would have to be expanded in order to fit the additional wells. The potential for oil seeps and surface expressions would remain unchanged as the same number of wells would be drilled. The consolidation of wells into two pods would achieve only some of the objectives of the proposed Project, since well drilling could still take place, but would most likely not be able to reach all of the proposed areas of production. Current diatomite wells have a depth of approximately 600 feet and a horizontal displacement of approximately 400 feet. The distances between the proposed Project pods and the consolidated Pods 9 and 14 range up to 1,000 feet. Consolidation of the wells onto fewer pods would most likely reduce crude oil production by percent as some areas could not be reached, depending on the exact geology of the target areas. This estimate of crude oil production is based on a reach from each Pod of between 500-1,000 feet (about the maximum that the Applicant proposed under the proposed Project). However, as this alternative does not lessen any significant and unavoidable impacts (by only addressing impacted areas which are considered to be a Class II impact) more than the other alternatives discussed below, this alternative has been eliminated from further consideration CTS Alternative Grouping well locations on to fewer pods would allow for a potential reduction in the additional disturbed areas around pods and would also eliminate any pods that are located within 2,200 feet of CTS ponds (either known or undetermined). See Figure 5-1. The new proposed Project well locations are essentially grouped into two areas: Pods 8, 9, 10, 11 and 12; and Pods 13, 14 and 15. By combining the wells located within 2,200 feet of CTS ponds (Pods 10, 11 and 12) into Pod 9, no Pods would be located within 2,200 feet of CTS ponds. Pods 8, 13, 14 and 15 would remain as under the proposed Project. In addition, consolidation of the proposed Project Pods 10, 11 and 12 into Pod 9 would reduce pipeline disturbance areas by approximately 0.15 acres by eliminating the need for pipeline segments 2 and 3, reducing impacts to oak woodland, chaparral and scrub by 0.10 acres. It would also eliminate about 1,310 feet of pipeline within the Project Site. Pod 9 would need to be increased in size in order to fit the additional wells associated with this alternative. Pod 9 would need to be increased in size from 0.30 acres to about 0.75 acres, most likely to the north and east. Pod 9 has minimal areas of sensitive biological species, but could incur additional biological impacts, as they would have to be expanded in order to fit the additional wells. The potential for oil seeps and surface expressions would remain. The consolidation of some wells into Pod 9 would achieve only some of the objectives of the proposed Project, since well drilling could still take place, but would most likely not be able to reach all of the proposed areas of production. Current diatomite wells have a depth of approximately 600 feet and a 14EIR February 2015

6 horizontal displacement of approximately 400 feet. The distances between the proposed Project pods and the consolidated Pod 9 range up to 1,000 feet. Consolidation of some of the wells onto fewer pods would most likely reduce crude oil production by percent as some areas could not be reached, depending on the exact geology of the target areas. This estimate of crude oil production is based on a reach from each Pod of between 500-1,000 feet (about the maximum that the Applicant proposed under the proposed Project). Even with some reduction in production capabilities, this alternative has still been retained for further analysis Careaga Alternative The Careaga Alternative would only allow drilling of new wells from surface areas that are not above the Careaga tar zone areas and production from the Diatomite Formation in areas where the Diatomite Formation does not underlie the Careaga Formation (see Figure 5-1). Historically, oil seeps have been produced in areas that are primarily associated with activities conducted on top of the Careaga Formation. Chemical fingerprinting indicates that the oil seeps originate from the basal, tar-soaked section of the Careaga Sand, which is a geologic formation that is younger and overlying the Sisquoc (Diatomite) Formation. As a result, the majority of the oil seeps are located in areas underlain by the Careaga Sand. This alternative would potentially minimize oil seep production, a potentially significant and unavoidable impact, through limiting the areas where drilling and production could occur. The potential for surface expressions, however, would remain unchanged as they originate from the Diatomite Formation, not the Careaga. The Seep Paper (Fong 2013) indicates that 80 percent of the proposed Project wells would occur outside of the Careaga tar zone outcrop. The 20 percent of wells associated with the proposed Project that would overlie portions of the Careaga tar zone are similar in depth to those of the Module 2 and Pilot expansion in the years (see section 4.8, Hydrology and Water Quality). During this period a total of 16 oil seeps were produced in this southern area (seeps 26-28, 81-88, 90-94, see Figure 2-6), with most of these installed since 2013 (seeps installed in 2011). The Applicant estimates that oil seeps would be generated into the future. Oil seep activity has generally been greater in areas where the Careaga tar zone is shallow: 38 oil seeps have occurred in zones where the Careaga tar zone is less than 60 feet deep. Some oil seep activity has occurred in areas where the Careaga tar zone is deeper, such as would be the case for the proposed Project. Historically, between 7 and 16 oil seeps (the Seep Paper does not include oil seeps that have occurred since 2012) have occurred within zones where the Careaga tar zone is greater than 100 feet in depth. In addition, 25 oil seeps have historically been generated that lie on or outside of the Careaga tar zone outcrop. As of January 2015, a total of 94 oil seeps have been generated since 2005 (with about 50 currently active). This indicates that, even by entirely drilling and producing outside of the Careaga tar zone, as under this alternative, there exists the potential for additional oil seeps to be generated. Seep 88, for example, occurred outside of the estimated Careaga tar zone to the south in the direction of the proposed Project wells. Even with some oil seeps historically occurring outside of the Careaga tar zone, the potential for oil seeps would be reduced, but not eliminated, under this alternative as the Careaga Formation would not be penetrated with well casings, and any uplifting would not be centered under the Careaga tar zone. This alternative would eliminate the Pod 8 and prevent penetration of the Careaga tar zone by wells drilled from other pods. The limitation of wells to non-careaga tar zone areas would achieve most of the objectives of the proposed Project, since well drilling could still take place, but would most likely produce 20 percent less crude oil. Even with some reduction in production capabilities, this alternative has still been retained for further analysis. 14EIR February 2015

7 Figure 5-1 Careaga and CTS Zones Source: Seep paper Fong 2013, Sage Bio Assessment Careaga and CTS Alternative The Careaga Alternative would only allow drilling of new wells from and to non-careaga tar zone areas while the CTS Alternative would prevent surface activities in areas within 2,200 feet of CTS ponds. Based on Figure 5-1, an alternative consisting of a combination of these two alternatives would exclude wells from surface or sub-surface activity within the Careaga tar zone (the same as the Careaga Alternative) and would exclude any surface activities from the 2,200 foot CTS dispersal zones. This would consolidate Pods 8, 10, 11 and 12 into Pod 9 while leaving Pods 13, 14 14EIR February 2015

8 and 15 the same as the proposed Project. The limitation of wells to non-careaga tar zone areas and non- CTS dispersal zone areas would achieve some of the objectives of the proposed Project, since well drilling could still take place, but would most likely produce percent less crude oil. This estimate of crude oil production is based on a reach from each Pod of between 500-1,000 feet (about the maximum that the Applicant proposed under the proposed Project) into the CTS zone subsurface from Pod 9 and a loss of 20 percent of the wells due to the exclusion from the Careaga tar zone areas, as per the Applicant. It is also assumed that the wells would be placed at a roughly even grid throughout the proposed OHREP area (as per the Applicant Seep Paper, Fong 2013). Even with the reduction in production capabilities, this alternative has been retained for further analysis. The potential for oil seeps would be reduced under this alternative as no drilling would take place through or into the Careaga tar zone areas. The potential for surface expressions would remain as they originate from the Diatomite Formation, not the Careaga. 5.2 Impacts and Comparison of Alternatives Based on the screening analysis presented above, three alternatives were selected for further evaluation in the EIR. State CEQA Guidelines Section (d) states: The EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed Project. A matrix displaying the major characteristics and significant environmental effects of each alternative may be used to summarize the comparison. If an alternative would cause one or more significant effects in addition to those that would be caused by the Project, the significant effects of the alternative shall be discussed, but in less detail than the significant effects of the proposed Project. In accordance with State CEQA Guidelines Section (d) as presented above, this EIR provides sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the Project and the other alternatives. It should be noted that assumptions made regarding the alternatives descriptions could differ from actual proposals and the analyses are not presented to a project-level of detail. Different alternative Project configurations and a project-level environmental analysis could result in different conclusions from those presented herein. The remainder of this section further analyzes the environmental impacts of the selected alternatives. Table 5-2 provides a matrix summarizing the advantages and disadvantages of each selected alternative No Project Alternative The proposed Project would involve the construction and operation of additional wells at the Orcutt Oil Field. With the No Project Alternative, the additional wells would not be constructed or operated. The Orcutt Oil Field would continue to extract crude oil from the existing wells, both diatomite and nondiatomite. Crude oil processing levels would stay the same or similar to levels that are currently ongoing. Impacts related to aesthetics, fire protection, land use and public services would stay the same as those under the proposed Project as these issue areas are not impacted by the proposed Project. While there would be additional potential for releases of toxic materials associated with the proposed Project, none of these releases have the potential to impact areas offsite. Therefore, the No Project Alternative would have the same safety impacts as the proposed Project operations. New oil spill-related impacts to biological resources, hydrology and cultural resources would be eliminated under the No Project Alternative, as additional crude oil would not be transported through the existing infrastructure and no increase in spill risk would occur. 14EIR February 2015

9 Construction-related impacts to air quality, biological resources, cultural resources, energy, geological resources, hydrology, and transportation would be eliminated under the No Project Alternative, as no construction would occur. New onsite operations-related impacts to air quality, energy and transportation would be eliminated under the No Project Alternative, as no additional operations would occur CTS Alternative The proposed Project would involve the construction and operation of additional wells at the Orcutt Oil Field. Under the CTS Alternative, the additional wells would be constructed and operated on fewer pods instead of the proposed eight pods. There would be a net reduction in the acreage required to be cleared as well as only development in areas not within the 2,200 foot CTS dispersal zone. There would also be a reduction in the amount of crude oil that could be obtained as fewer wells would be drilled. Impacts related to aesthetics, fire protection, land use and public services would be the same as those under the proposed Project, as these issue areas are not impacted by the proposed Project. While there would be additional potential for releases of toxic materials associated with the proposed Project, none of these releases have the potential to impact areas offsite. Therefore, this alternative would have the same safety impacts as the proposed Project operations. Additional issue areas are addressed individually below. Air Quality: Criteria and Toxic Pollutants and Greenhouse Gasses Air emissions would be generated from construction activities, including the use of construction equipment used for drilling, pipeline installation and for pod clearing. Under the CTS Alternative, drilling emissions would be reduced as fewer wells would be drilled. Grading and clearing emissions, and emissions associated with the installation of the in-field pipelines, would be reduced over the proposed Project, as less area would be required to be graded and cleared and fewer in-field pipelines would be installed. Operational emissions would be reduced compared to the proposed Project as fewer wells would be installed and less crude oil would be produced. GHG emissions related to construction would be reduced, as less construction activities would be required. GHG emissions related to operations would be reduced compared to the proposed Project Biological Resources Impacts to biological resources would be generated from construction activities, including pipeline installation and for pod clearing. Under the CTS Alternative, grading and clearing impacts, and impacts associated with the installation of the in-field pipelines, would be reduced over the proposed Project as less area would be required to be graded and cleared and fewer in-field pipelines would be installed. Operational impacts to biological resources from the increased offsite transportation of crude oil would be reduced as those under the proposed Project as less crude oil would be transported. Operational impacts to biological resources from the increased onsite transportation of crude oil would be reduced over the proposed Project, as fewer pipelines would be utilized. Impacts to the California Tiger Salamander (CTS) would be reduced in severity under this alternative as no pods or wells would be installed in surface areas located within 2,200 feet of known or undetermined CTS breeding ponds. In addition, pipeline segments 2 and 3, which would be located within 2,200 feet of known or undetermined CTS breeding areas, would not be constructed. Because project construction and 14EIR February 2015

10 operation would not occur within 2,200 feet of known or potential CTS breeding ponds, impacts to CTS, while not completely eliminated, would be reduced. See Figure 5-1. However, as pods and pipelines would still be installed within the 1.24 mile USFWS dispersal buffer, impacts to CTS would remain Class I, although with lessened severity. Oil seep generation due to penetrating the Careaga Formation and steaming the Diatomite Formation would continue as crude oil would be produced from through and beneath the Careaga tar zone. Energy Impacts to energy would be only marginally less than the proposed Project due to less construction activities. Operational energy use would be similar to the proposed Project. However, as less crude oil would be produced from the CTS Alternative, this would negatively impact the amount of energy produced by the Project. Geological Resources Impacts to geological resources could be generated from construction activities, including pipeline installation and pod clearing. Under the CTS Alternative, grading and clearing impacts, and impacts associated with the installation of the in-field pipelines, would be reduced over the proposed Project as less area would be required to be graded and cleared, and fewer in-field pipelines would be installed. Operational impacts to geological resources would be the same as those under the proposed Project. Hydrology and Water Quality Impacts to hydrology and water quality could be generated from construction activities, including pipeline installation and for pod clearing. Under the CTS Alternative, grading and clearing impacts, and impacts associated with the installation of the in-field pipelines, would be reduced over the proposed Project as less area would be required to be graded and cleared and fewer in-field pipelines would be installed. Operational impacts to hydrology and water quality from the increased off-site transportation of crude oil would be reduced compared to the proposed Project as less crude oil would be transported. Operational impacts to hydrology and water quality from the increased onsite transportation of crude oil would be reduced over the proposed Project, as fewer pipelines would be utilized. Oil seep generation due to penetrating the Careaga formation and steaming the Diatomite Formation would continue as crude oil would be produced from, through and beneath the Careaga tar zone. Transportation Impacts to transportation would be generated from construction activities, including pipeline installation and pod clearing, as equipment would need to be brought in to the Project Site. The impacts to transportation for the CTS Alternative would be similar to those under the proposed Project, as similar equipment would need to be brought to the Project Site. Operational impacts to transportation would be similar to those under the proposed Project, as similar maintenance would be required, thereby generating the same number of offsite vehicles trips Careaga Alternative The proposed Project would involve the construction and operation of additional wells at the Orcutt Oil Field. Under the Careaga Alternative, the additional wells would be constructed and operated entirely outside of the Careaga tar zone. Under this alternative, there would be a 20 percent reduction in 14EIR February 2015

11 the amount of crude oil that could be obtained as 20 percent of the wells under the proposed Project would be drilled to areas that lie beneath the Careaga tar zone, and these wells would not be installed. As this alternative would involve the elimination of one of the pods (Pod 8), there might be a small net reduction in the acreage required to be cleared (0.04 acres of undisturbed area for Pod 8). The same amount of in-field pipelines would be installed as under the proposed Project, as it would still be necessary for Pod 9 to connect to the existing pipelines at Pod 6. Impacts related to aesthetics, fire protection, land use and public services would be the same as those under the proposed Project, as these issue areas are not impacted by the proposed Project. Though there would be additional potential for releases of toxic materials associated with the proposed Project, none of these releases have the potential to impact areas offsite. Therefore, this alternative would have the same safety impacts as the proposed Project operations. Additional issue areas are addressed individually below. Air Quality: Criteria and Toxic Pollutants and Greenhouse Gasses Air emissions would be generated from construction activities, including the use of construction equipment used for drilling, pipeline installation and for pod clearing. Under the Careaga Alternative, drilling emissions would be reduced as fewer wells would be drilled. Grading and clearing emissions would be reduced over the proposed Project, as less area (elimination of Pod 8) would be required to be graded and cleared. Emissions associated with the installation of the in-field pipelines would stay the same as the proposed Project. Operational emissions would be reduced under the proposed Project as less crude oil would be produced. GHG emissions related to construction would be similar to the proposed Project, with a nominal decrease in total GHG construction emissions due to the elimination of Pod 8. GHG emissions related to operations would be reduced under the proposed Project as less crude oil would be produced. Biological Resources Impacts to biological resources would be generated from construction activities, including pipeline installation and for pod clearing. Under the Careaga Alternative, grading and clearing impacts, and impacts associated with the installation of the in-field pipelines would be similar to the proposed Project, with a nominal decrease over the proposed Project due to the elimination of Pod 8. Operational impacts to biological resources from the increased offsite transportation of crude oil would be reduced relative to the proposed Project, as 20 percent less crude oil would be transported thereby reducing the potential spill sizes from pipelines. These impacts would remain Class I but reduced in severity. Operational impacts to biological resources from the increased onsite transportation of crude oil would be reduced over the proposed Project, as 20 percent less crude oil would be transported. Impacts to CTS within the 2,200 foot dispersal area would remain under this alternative as Pods 10, 11 and 12 and associated pipelines would still be constructed. While they are outside of the Careaga tar zone, they would still be within the 2,200 foot CTS zones (see Figure 5-1). Operational impacts due to oil seeps would be reduced in severity with this alternative as drilling would not penetrate the Careaga formation. However, as the potential for oil seeps would remain, operational impacts due to oil seep activity would remain Class I. Energy Impacts to energy would be only marginally less than the proposed Project due to the marginally less construction activities. Operational energy use would be similar to the proposed Project. However, as less crude oil might be produced from the Careaga Alternative, this would negatively impact the amount of energy produced by the Project. 14EIR February 2015

12 Geological Resources Impacts to geological resources could be generated from construction activities, including pipeline installation and pod clearing. Under the Careaga Alternative, grading and clearing impacts would be nominally reduced over the proposed Project as less area would be required to be graded and cleared. Operational impacts to geological resources would be the same as those under the proposed Project. Hydrology and Water Quality Impacts to hydrology and water quality could be generated from construction activities, including pipeline installation and for pod clearing. Under the Careaga Alternative, grading and clearing impacts would be reduced over the proposed Project as less area would be required to be graded and cleared. Operational impacts to hydrology and water quality from the increased off-site transportation of crude oil would be reduced compared to the proposed Project as 20 percent less crude oil would be transported thereby reducing the potential spill sizes from pipelines. These impacts would remain Class I, but reduced in severity. Operational impacts to hydrology and water quality from the increased onsite transportation of crude oil would be reduced over the proposed Project. Operational impacts due to oil seeps would be reduced in severity with this alternative as drilling would not penetrate the Careaga formation. However, as the potential for the occurrence of some oil seeps would not be completely eliminated, operational impacts due to oil seep activity would remain Class I. The potential for surface expressions would remain as they originate from the Diatomite Formation, not the Careaga. Transportation Impacts to transportation would be generated from construction activities, including pipeline installation and pod clearing, as equipment would need to be brought in to the Project Site. The impacts to transportation for the Careaga Alternative would similar to those under the proposed Project, as similar equipment would need to be brought to the Project Site. Operational impacts to transportation would be similar to those under the proposed Project, as similar maintenance would be required, thereby generating the same number of offsite vehicles trips Careaga and CTS Alternative Under the Careaga and CTS Alternative, project wells would be constructed and operated entirely outside of the Careaga tar zone and surface activities would be limited to areas outside of the CTS 2,200 foot dispersal buffer. Under this alternative, there would be an estimated percent reduction in the amount of crude oil that could be obtained as 20 percent of the wells under the proposed Project would be drilled to areas that lie beneath the Careaga tar zone, and would not be installed. Additionally, areas to the east and south would not be able to be reached from the newly consolidated Pod 9. As this alternative would involve the elimination of Pods 8, 10, 11 and 12, there would be a net reduction in the acreage required to be cleared for development of the Pods. Fewer in-field pipelines would be installed than under the proposed Project as pipeline segments 2 and 3 would not be built, yet it would still be necessary for Pod 9 to connect to the existing pipelines at Pod 6. Impacts related to aesthetics, fire protection, land use and public services would be the same as those under the proposed Project, as these issue areas are not impacted by the proposed Project. Though there would be additional potential for releases of toxic materials associated with the proposed Project, none of these releases have the potential to impact areas offsite. Therefore, this alternative would have the same safety impacts as the proposed Project operations. 14EIR February 2015

13 Additional issue areas are addressed individually below. Air Quality: Criteria and Toxic Pollutants and Greenhouse Gases Air emissions would be generated from construction activities, including the use of construction equipment used for drilling, pipeline installation and for pod clearing. Under the Careaga and CTS Alternative, drilling emissions would be reduced as fewer wells would be drilled. Grading and clearing emissions would be reduced over the proposed Project, as less area (elimination of Pod 8, 10, 11 and 12) would be required to be graded and cleared. Emissions associated with the installation of the infield pipelines would be reduced over the proposed Project. Operational emissions would be reduced under the proposed Project as less crude oil would be produced. GHG emissions related to construction would be similar to the proposed Project, but with a decrease in total GHG construction emissions due to the elimination of some pods. GHG emissions related to operations would be reduced under the proposed Project as less crude oil would be produced. Biological Resources Impacts to biological resources would be generated from construction activities, including pipeline installation and pod clearing. Under the Careaga and CTS Alternative, grading and clearing impacts, and impacts associated with the installation of the in-field pipelines, would be reduced over the proposed Project as less area would be required to be graded and cleared and fewer in-field pipelines would be installed. Operational impacts to hydrology and water quality from the increased off-site transportation of crude oil would be reduced compared to the proposed Project as percent less crude oil would be transported thereby reducing the potential spill sizes from pipelines. Operational impacts to biological resources from the increased onsite transportation of crude oil would also be reduced over the proposed Project, as fewer pipelines would be utilized. Impacts to the California Tiger Salamander (CTS) would be reduced in severity under this alternative as no pods or wells would be installed in surfaces areas that are within 2,200 feet of known or undetermined CTS breeding ponds. In addition, pipeline segments 2 and 3, which would be located within 2,200 feet of known or undetermined CTS breeding ponds, would not be constructed. Because project construction and operation would not occur within 2,200 feet of known or potential CTS breeding ponds, impacts to CTS, while not completely eliminated, would be reduced. See Figure 5-1. However, as pods and pipelines would still be installed within the 1.24 mile USFWS dispersal buffer, impacts to CTS would remain Class I, although with lessened severity. Operational impacts due to oil seeps would be reduced in severity with this alternative as drilling would not penetrate the Careaga formation. However, as the potential for oil seeps would remain, operational impacts due to oil seep activity would remain Class I, but with less severity. The potential for surface expressions would remain as they originate from the Diatomite Formation, not the Careaga. Energy Impacts to energy would be less than the proposed Project due to the reduction in construction activities. Operational energy use would be similar to the proposed Project. However, as less crude oil might be produced, this would negatively impact the amount of energy produced by the Project. Geological Resources Impacts to geological resources could be generated from construction activities, including pipeline installation and pod clearing. Under the Alternative, grading and clearing impacts would be reduced over the proposed Project as less area would be required to be graded and cleared. 14EIR February 2015

14 Operational impacts to geological resources would be the same as those under the proposed Project. Hydrology and Water Quality Impacts to hydrology and water quality could be generated from construction activities, including pipeline installation and for pod clearing. Under the Careaga and CTS Alternative, grading and clearing impacts would be reduced over the proposed Project as less area would be required to be graded and cleared. Operational impacts to hydrology and water quality from the increased off-site transportation of crude oil would be reduced compared to the proposed Project as percent less crude oil would be transported thereby reducing the potential spill sizes from pipelines. These impacts would remain Class I, but with less severity. Operational impacts to hydrology and water quality from the increased onsite transportation of crude oil would be reduced over the proposed Project. Operational impacts due to oil seeps would be reduced in severity with this alternative as drilling would not penetrate the Careaga formation. However, as the potential for the occurrence of some oil seeps would not be completely eliminated, operational impacts due to oil seep activity would remain Class I but with less severity. The potential for surface expressions would remain as they originate from the Diatomite Formation, not the Careaga. Transportation Impacts to transportation would be generated from construction activities, including pipeline installation and pod clearing, as equipment would need to be brought in to the Project Site. The impacts to transportation for the Careaga and CTS Alternative would be similar to those under the proposed Project, as similar equipment would need to be brought to the Project Site. Operational impacts to transportation would be similar to those under the proposed Project, as similar maintenance would be required, thereby generating the same number of offsite vehicles trips. 5.3 Environmentally Superior Alternative This section summarizes the environmental advantages and disadvantages associated with the proposed Project and the alternatives evaluated above. Based upon this discussion, the environmentally superior alternative is selected as required by CEQA. The State CEQA Guidelines, Section (d) (2), state that if the environmentally superior alternative is the No Project Alternative, then the next most environmentally preferred alternative must also be identified. CEQA does not provide specific direction regarding the methodology of comparing alternatives and the proposed Project. Each Project must be evaluated for the issues and impacts that are most important; this will vary depending on the project type and the environmental setting. Issue areas with significant longterm impacts are generally given more weight in comparing alternatives. Impacts that are short-term (e.g., construction-related impacts) or those that are mitigable to less than significant levels are generally considered to be less important. Table 5.2 provides a summary of the alternatives impacts by issue area. Although this EIR identifies one environmentally superior alternative, it is possible that the ultimate decision-makers could balance the importance of each issue area differently and reach a different conclusion. The No Project alternative would be environmentally preferable to the proposed Project, as it does not increase the risks of oil spills to the environment (which produces Class I impacts to biological and hydrological resources), but the Project objectives (see Section 2.0, Project Description) would not be realized. 14EIR February 2015

15 Impacts associated with the CTS Alternative, would be less severe than those associated with the proposed Project (related to CTS and oil spill impacts), but would most likely not be able to reach all of the crude oil and would experience a percent reduction in crude oil production, thereby only partially meeting the Project objectives. Potentially significant and unavoidable (Class I) impacts to biological resources and hydrology related to oil spills would be less severe than those under the proposed Project if less crude oil is produced. These impacts would not be eliminated and would remain significant and unavoidable (Class I), but with less severity. Impacts to CTS would be less severe than the proposed Project as all construction and operational activity would occur outside of the 2,200 foot CTS dispersal buffer. This alternative would therefore substantially lessen the Class I impacts. However, as project activities would remain within the 1.24 mile potential range for CTS, impacts would remain Class I. Oil seep activity would be similar to the proposed Project under the CTS Alternative as oil would be produced from within the Careaga tar zones. Impacts would remain Class I as the potential for seeps would still exist. There would be some reduction of impacts to biological resources and hydrology due to the reduced pod area footprints, but these are not considered to be significant and unavoidable impacts. Under the Careaga Alternative, crude oil production would most likely decrease by 20 percent. This would lead to reductions in the severity of crude oil pipeline spill impacts to biological and hydrological resources, due to the reduced spill sizes associated with lower volumes of crude oil being transported. However, impacts would remain Class I. Limiting the areas that can be drilled from and into would most likely reduce the future oil seep activity as the Careaga formation would not be penetrated with well casings and heating of the Diatomite Formation would not occur directly beneath any Careaga tar zones. There is some uncertainty associated with this conclusion as some oil seeps have historically been produced outside of the Careaga tar zones and the exact mechanisms and extent of the Careaga tar zone are not entirely understood. Most likely some oil seep activity would continue, but at a reduced level. Class I impacts associated with oil seep activity and impacts on Biological and Hydrological resources would remain Class I, but this alternative would substantially lessen the Class I impacts. Impacts related to the Careaga and CTS Alternative would be reduced over the proposed Project as well as the other alternatives, as this alternative would both reduce the potential for future oil seeps, which substantially lessens the severity of a Class I impacts associated with oil seeps, as well as reducing the potential for CTS impacts by keeping all surface activities out of the CTS dispersal zone, and thereby also substantially lessening the severity of the CTS related Class I impact. However, as this alternative would reduce crude oil production by up to 45 percent, it has the potential to only partially achieve the objectives of the Project. Although the CTS Alternative, the Careaga Alternative and the Careaga and CTS Alternative would reduce the impacts from pipeline spills due to a reduction in crude volume produced, only the Careaga Alternative and the Careaga and CTS Alternative would reduce the potential for oil seeps to occur in the future. As the potential for CTS impacts is limited, the reduction in severity to CTS habitat impacts from the CTS Alternative is considered to be less advantageous than the reduction in oil seep potential associated with the Careaga and the Careaga and CTS Alternatives. This is due to the high historical frequency of oil seeps, the substantial impact on plants and habitat associated with oil seep can installation, which has a very high probability of occurring versus the unlikely potential of impacting CTS resources. As the Careaga and CTS Alternative would lessen both the impacts to CTS as well as from oil seeps, it is the next most Environmentally Superior Alternative over the No Project Alternative. However, the Careaga and CTS Alternative has the potential to not achieve the project objectives due to a potential 45 percent reduction in crude oil production. Therefore, the Careaga Alternative is the Environmentally Superior Alternative and this alternative would be environmentally superior to the proposed Project. It would also achieve most of the Project objectives. 14EIR February 2015