CPA Strongly Opposes the County Allowing 100,000 Oil Tanker Trips on Harris Grade Road

To: Jacquelynn Ybarra, Project Planner

Re: Draft Negative Declaration for proposed Sentinel Peak Resource Truck Rack (and Trucking Project) 22LUP-00000-00199

100,000 Oil Tanker Trips over a 50 Year period Proposed

Citizens Planning Association has followed this oil development since 1980, when the Lompoc Separation Plant was first proposed. We are very concerned that this current project is not receiving the proper environmental review and public hearing process that prior proposals received. We urge the director to deny this Land Use Permit.

CPA would like to point out serious inadequacies in the MND now being used to approve this trucking project over the counter. We suggest this oil trucking project be given full environmental review and public hearings. Below are some inadequacies we have found in the MND.

Project Setting description: The plant is within one mile of two densely populated residential communities that heavily travel Harris Grade Road. Population is approx. 10,000 and growing, with several new developments very close to both Harris Grade Road and Hwy 1. The use of ‘rural’ setting is not accurate.

Fire Protection: (p. 44) Tankers will be traveling on HG Road which has the environmentally sensitive BMER on both sides. There is no mention of the BMER in terms of high fire risk. It is mentioned that a spill or ‘upset’ would immediately impact up to 500 ft. with possible explosions and pool fires. Several housing communities, such as Summit View (at the Wye) and the soon to be built Burton Ranch project (485 home) abut the roadway and are probably within 50 ft. This proximity needs to be addressed.

Lack of Traffic Analysis: What policies will be in place to assure that the tankers will not be impeded by construction vehicles, etc. and vice versa. Has the developer been contacted about this tankering along the perimeter of the project? This project will have three new intersections on Harris Grade Road, with only stop signs planned. This should be included in any traffic analysis.

The ‘Wye’ intersection is at a LOS D according to Caltrans. With the addition of hundreds of new units, both in Mission Hills and V. Village, the traffic will only worsen. This is not considered in the MND. A full EIR, with a detailed traffic analysis, not 3 paragraphs written in 2022 saying ‘all is well’, would highlight the issues with this intersection. The intersection is especially problematic during the school ‘rush’ hours. Mixing school busses, other school traffic, and oil tankers is not a good idea. A full EIR would probably suggest time restrictions IF this trucking is allowed, such as no trucking before 9 a.m. and no trucking after 2 p.m. This latter proposal is because right now, when the high school is released, cars wait through 2 lights to cross the intersection.

Sec. 4.9

In this discussion of the Phillips pipeline 300, staff explains that Sentinel Peak cannot move its product because Phillips made the business decision to shut down the existing pipeline. Staff suggests the pipeline could be purchased and re-started. However, this pipeline has sections between 30 -82 years old. Project description suggests the oil could someday go back to pipeline transport. A complete EIR would include a study of the pipeline to determine its viability. Otherwise, as mentioned in this MND, staff is only speculating.

Project description says this tankering would involve an average of 6 round trips of 230 miles to Coalinga. Oil tankers would be capped at 2000 trips per year for 50 YEARS. That is projecting over 100,000 new oil tanker trips up and down this residential road. Not to mention Hwy 1 between the Wye and the VSFB. There have been 5 fatalities in this stretch just this year. In a complete EIR process, staff would add an accident/fatality study to this part of the route and the entire route to determine exactly what the risk is. (See attached study done for the Exxon project).

Life of the Project: As mentioned above, project description states this will be 50 years. When the plant was first built, residents were told the plant would shut down in 2000. It had a 15 year life expectancy. That did not happen. The County allowed a change in operation to do processing, not just separating. They did add tankering of sludge by- product but that was only for 3 trips per week.

P.55: reference to ‘Low population Densities”. In a full EIR, this decription would be changed, based on what is included above. 10,000 and in near future, additional 5000 residents is not a low population density when the tankers will be using a major artery through our residential areas.

Hazardous Conditions: p. 89

One condition for the oil tankering is no oil tankered on rainy days. It should be added to this no variation in the trucking route due to fallen branches, accidents, etc. on Harris Grade Road. In the past, residents have seen tankers head west on Burton Mesa Blvd. going through the residential/commercial areas of Vandenberg Village heading to Hwy 1. Again, a real environmental review process would show this should be prohibited and clearly stated in conditions of approval.

Harris Grade Road Closure: Because of a major landslide up in the hills, Harris Grade Road is now closed to all through traffic. Also, there is a weight limitation for Harris Grade Road. With a full load, will the oil tankers be given a waiver? This possibility should be discussed in a full EIR.

Noise: MND says the further away from the plant, the less noise. That is not the case due to the surrounding topography. Many residents have made complaints of noise coming from the plant or old pumpjacks. Several neighbors have had monitors put on their properties until the problem was solved. Nowhere in the MND is this noise issue mentioned.

Lights: Residents have asked for the lights at the plant to be capped since 1985. The night lights in the fog makes the plant visible for miles. In the few months that the plant has been shut down, everyone is noticing how we have regained our ‘night skies’. The environmental documents should require as a condition the capping of all on site lights. Again, this could be part of a complete EIR.

Towards the end of the MND, it is mentioned that this area does not have a Community Plan which would probably have more policies and goals that would prohibit oil tankering. A more rigorous environmental document should include some discussion by County planners who might explain why this area was never given the opportunity to do a full community plan and if that has anything to do with existing oil infrastructure.

p.95#5 Staff states this review is adequate. CPA believes this LUP should be denied. We suggest the County require a full EIR and public hearings on the Planning Commission level so the residents can find out exactly what this project entails and can participate in a transparent process. The title of the project is misleading as the trucking component of the project is hidden in the details. An over-the-counter LUP and this deficient MND are not adequate review.

Marell Brooks, President, Citizens Planning Association