CPA Joins EDC and Others to Comment on ERG EIR

March 13, 2019

March 13,2019

To:  Santa Barbara County Planning Commission

Re:  ERG West Cat Canyon Revitalization Plan

Citizens Planning Association has reviewed the staff report for today’s hearing and we recommend that the Planning Commission deny this project.  We have read through the comment section and agree with hundreds of Santa Barbara County residents that this project does not support the County’s existing policies to combat climate change and reduce greenhouse gas emissions. 

Because of the three Class 1 impacts, the Planning Commission must make a Statement of Overriding Consideration to approve this project. CPA believes your commission cannot do that, based on the weakness of several of the stated Findings. We would like to focus our comments on the Findings.

Under the Finding “Economic Benefits”, staff claims that this project will provide an “oil/gas product to meet the State demands for fossil fuels as the State develops and refines strategies to reduce carbon footprint through clean energy alternatives and energy conservation”.   CPA would argue that SB County has an existing policy to lower its own GHG emissions by 2020, the Energy and Climate Action Plan.  Unfortunately, the County did not even meet its goal in the most recent year reported.  The ERG project will now increase our County’s emissions even more. This Finding sets up SB County as a source for more fossil fuel, as the rest of the State weans itself off dirty energy. This Finding should not be used to justify supporting this project.

The Finding regarding jobs created is very weak.  Fourteen full time jobs in a county job pool of tens of thousands jobs is miniscule.  Other jobs mentioned in the project description are temporary, and indirect jobs are not new jobs.   More jobs could be created in the growing alternative energy industry. Thus, this Finding is not a robust argument to support a Statement of Overriding Consideration.

The Finding regarding increased taxes for the County is also weak. The County tax total listed for over the life of the project, which could be 40 years, is a small fraction of even one year of the county budget.  Also, taxes should not be used as a finding as ERG has already been given special tax breaks under the Williamson Act (per the minutes from the APAC.)  In addition, ERG’s bankruptcy status is also troubling. They should be required to post a performance security to ensure compliance with all conditions over the life of the project.

CPA would disagree with the Finding that this project is not detrimental to the health and safety of residents in the area.  A monitoring program is used here as mitigation.  CPA has previously argued that the entire North County needs better air quality monitoring, especially near oil facilities.  We read with interest the letter from the private group that went on the Cat Canyon property and found emissions far exceeding acceptable numbers.

Besides the Class I impacts that cannot be mitigated, many of the Class II impacts are supposedly mitigated by an Emergency Response Plan.  CPA feels this is inadequate because an ERP is activated after a catastrophic event.  Mitigation measures should prevent an incident. Proponents of the project will argue that SB County has the strictest regulations in the country. At this time, the EPA is barely functioning.  Our County has experienced catastrophes to include the Plains Oil spill at Refugio and the numerous violations at the Greka Oil, incidents caused by human error.

CPA urges the Planning Commission not accept the staff report Findings in support of a Statement of Overriding Consideration. Without robust Findings and a Statement of Overriding Consideration, this project cannot be approved.


Mary Ellen Brooks

Board Member, Citizens Planning Association








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