September 7, 2018
Re: Notice of Intent for Potential Amendment to the Resource Management Plan for the Bakersfield Field Office, California, and To Prepare an Associated Supplemental Environmental Impact Statement – Docket No.[(LLCAC06000.L13100000.DS0000.LXSIAREV0000.18XL1109AF) MO#450012099
Dear Staff: Citizens Planning Association has followed land use issues in Santa Barbara County for more than 55 years. We appreciate the opportunity to provide comment for the Supplemental EIS. The Notice of Intent invites input on issues and planning criteria related to the BLM’s intention to prepare a supplemental environmental impact statement (“SEIS”) and Resource Management Plan (“RMP”) amendment for the Bakersfield Field Office RMP Planning Area (“Planning Area”).
The intent of the SEIS is to analyze the impacts of hydraulic fracturing (“fracking”) of oil and gas wells on new leases in the Planning Area. CPA understands that the SEIS is being prepared pursuant to a settlement reached following a successful lawsuit by the Center and Los Padres Forest Watch, after BLM violated its obligations under the National Environmental Policy Act (“NEPA”), 42 U.S.C. § 4321 et seq., and its implementing regulation, when the agency finalized the Bakersfield Field Office RMP without analyzing the impacts of fracking.
CPA is concerned about the identified 122,000 acres of federal land and mineral estate in Santa Barbara County that could be opened to fracking and drilling, including sites near Nojoqui Falls County Park, Lake Cachuma, Highway 154, Tepusquet Canyon, Purisima Hills, Vandenberg Air Force Base, Sisquoc River, the Cuyama Valley foothills, and Carpinteria.
Santa Barbara County is already experiencing the negative impacts of opening old/new wells using fracturing drilling in areas in and around Santa Maria and Cat Canyon. We hope the study will look at possible contamination of the aquifer and ground water table. We also suggest the study looks at the effects of additional roads being built on two lane roads into the canyons and the transfer of materials by truck on our county highways.
In Santa Barbara, the largest land mass that could be leased falls within Vandenberg Air Force Base, at 102,000 acres. In recent years, there has been constant pressure from oil companies to add oil development on the base. CPA suggests the study look closely at the impacts of opening the Vandenberg Air Force Base to drilling. Traffic from the oil business could be a threat to our public safety and the secure space program which protects our national security and advances our position in space, not to mention that VAFB has one of the strictest environmental programs for conservation and species protection in the nation. Their existing programs must be incorporated into any study of possible fracking. The policies to protect the adjacent Burton Mesa Ecological Reserve should also get attention.
The study must include consideration of impacts to air, water, and land including the stress on our infrastructure of highways, bridges, including the hazardous addition of trucks traveling long distances over our highways to Bakersfield.
In regards to water issues, it has been proven that with this kind of drilling that the amount of water that is consumed is not consistent with water conservation during our drought. The drought has opened our County to unprecedented wild land forest fires that have caused loss of soil, vegetation, lives, property, wildlife, and created the perfect environmental stage for disastrous mud flows. These impacts are everyday concerns and realities of our County citizens who are living with these continued potential disasters.
More studies have recently concluded that intense drilling methods endanger our water sources from the loss of water quality and air quality (documented increase in asthma and other respiratory diseases). The risks of increasing land movement/earthquakes in Santa Barbara County near these locations needs close study also.