CPA Points Out Some Deficiencies for AERA DEIR
January 19, 2019
RE: AERA DEIR deficiencies
Citizens Planning Association appreciates the opportunity to comment on the DEIR for the AERA proposal.
CPA believes 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.
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. All chemicals used in the steaming process should be listed.
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. Recent studies show that Santa Barbara County did not reach its goal of reducing GHG emissions. Staff should include an analysis of why this goal was not attained and list the sources of the emissions. Greka is currently under investigation and any new information on its non-compliance should be included in this EIR. We also urge a more inclusive study for all the proposed Cat Canyon projects so this is not approached in a piecemeal fashion.
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. Monitoring should also not be counted as a mitigation. It is strictly a measurement tool.
Lastly, the ‘import’ of oil to mix with the AERA product needs more study, both in terms of the safety of the tinkering and added transportation negative impacts.
Mary Ellen Brooks
Citizens Planning Association. 916 Anacapa St., Santa Barbara CA 93101