CPA Comments on ERG DEIR

June 26, 2018


June 26, 2018

To:  Ms. Nancy Minick, Chief Planner

Re:  ERG DEIR:  Proposed West Cat Canyon Revitalization Plan

Citizens Planning Association appreciates the opportunity to comment on the DEIR for the ERG proposal.

CPA agrees with the observation made in the Executive Summary that there is no public benefit to this project that would outweigh the negative impacts to our environment and to the health of County residents. Any existing studies by County Public Health as related to environmental degradation need to be included in the EIR.

CPA requests that the Air Quality section be made more robust. APCD must re-evaluate and require adequate numbers and appropriate placement of air monitors, both on site and off site.  There should be sensitive receptors even in nearby urban areas to address changes in prevailing winds and other atmospheric conditions.  Without proper Air Quality monitoring, potential Class I Impact problems will not be detected.

According to the DEIR, the current Air Quality Management Plan anticipated ‘no growth in oil/gas production”.  As clean energy was the goal, it made sense to anticipate there would be no additional wells.  The use of undisclosed chemicals in the steaming process is especially disconcerting. APCD should update its AQMP prior to the FEIR to assure air pollution is not a Class I Impact.

CPA is likewise concerned with the amount of GHG emissions released in the different phases of this project. GHG emissions should be reclassified as a Class 1 impact. Santa Barbara County has experienced horrific fires and resultant debris flows this past winter. Local areas like Montecito are now susceptible to fire and slides/debris flows as a result of the Thomas Fire and climate change.   This discussion should be included in the GHG emissions section.

Several mitigations in this DEIR rely on an Emergency Response Plan to a catastrophic event.  Mitigations should prevent emergencies/catastrophic events, not respond to them.  More robust mitigations need to be in place so that the need for an Emergency Response Plan will be rare.

Respectfully submitted,

Marell Brooks, co-President, Citizens Planning Association

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