City of Culver City, California
City Council Agenda Item Report
1
RECOMMENDATION:
Staff recommends the City Council adopt a Resolution transmitting to the County of
Los Angeles Department of Regional Planning the official City response to the June
2008 Draft Environmental Impact Report for the Proposed Baldwin Hills Community
Standards District. (Attachment 1)
BACKGROUND:
The County of Los Angeles (County) has prepared and circulated a Draft
Environmental Impact Report (DEIR), dated June 2008, to assess potential
environmental impacts associated with potential future oil and gas production
activities at the Inglewood Oil Field over the next 20 years. The County is the “Lead
Agency” and the project applicant is Plains Exploration & Production Company
(PXP).
The City received the DEIR on June 19
th
and immediately distributed it to City
Departments and the City Council for review. The County established a 60-day
review and comment period that ends on August 19
th
.
Meeting Date: 08/13/08 Item Number: A-1
AGENDA ITEM: Adoption of a Resolution Transmitting to the County of Los
Angeles Department of Regional Planning the Official City Response to the June
2008 Draft Environmental Impact Report for the Proposed Baldwin Hills
Community Standards District.
Contact Person/Dept.: Sherry Jordan/
CDD and Charles Herbertson/PWD
Phone Number: (310) 253-5746
(310) 253-5630
Fiscal Impact: Yes [X] No [] General Fund: Yes [X] No []
Public Hearing: [] Action Item: [X] Attachments: [X]
Public Notification: Posted on Culver City web page on 7/2/08; mailed notices (20,950)
on 7/3/08 to various public agencies, Culver City property owners and residents, and
interested parties; emailed to the Master Notification List on 8/6/08; published in the
Culver City News on 7/10/08, placed on the cable crawler, flyers made available at 7/17,
7/24, 7/31, & 8/7 Summer Music Festival, county workshops, council chambers, etc;
press release to newspapers on 7/28; Connect CTY (phone notification system) to all
Culver City residents, businesses, and city employees on 7/29; mailed notices to all
listed homeowner associations on 7/29, Master E-Mail Notification List (08/08/08);
Department Approval:
Charles Herbertson, PWD (08/06/08)
Sol Blumenfeld, CDD (08/06/08)
City Attorney Approval:
Carol Schwab (by H. Baker) (08/07/08)
Chief Financial Officer Approval:
Jeff Muir (08/08/08)
City Manager Approval:
Jerry Fulwood (08/08/08) City of Culver City, California
City Council Agenda Item Report
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On June 23, 2008, the City Council authorized a contract with Aspen Environmental
Group to assist the City in commenting on the proposed Community Standards
District (CSD) and DEIR, and with the review and revisions to the City’s current oil
well regulations and oil drilling permit application submittal requirements.
On July 14, 2008, a City Council meeting was held to discuss and seek early Council
and community input while staff was analyzing the DEIR and formulating detailed
comments for Council consideration. At the July 14, 2008 meeting, the City Council
received over two hours of community comments related to this item. The purpose
of tonight’s meeting is to consider staff’s recommended comments, receive any
additional public comment, and then accept or modify these comments for
transmittal to the County.
DISCUSSION:
Project Description
PXP, the operator of the Inglewood Oil Field has submitted an application to the
County to establish a CSD (attachment to the Executive Summary in the EIR). The
CSD is a supplemental district used to address special issues that are unique to
certain geographic areas within the unincorporated areas of the County. The CSD
would establish permanent development standards, operating requirements and
procedures for the portions of the Inglewood Oil Field that are within the County.
The CSD would provide a means for implementing enhanced regulations to address
the unique compatibility concerns associated with operating an oil field in the midst
of urban development.
The proposed CSD is divided into eight major sections that include the following:
A. Intent and Purpose
B. Description of Boundary
C. Definitions
D. Community Wide Development Standards
E. Community Relations
F. Permits Required, and
G. Procedures for obtaining Approval from Department of Regional Planning
Section D provides the development standards, operating requirements and
procedures proposed for the Inglewood Oil Field. This section addresses issues
covering drilling operations, production operations, maintenance operations,
landscaping, grading, operation of oil field recovery heaters (steam generators), non-
producing and idle wells, as well as some general conditions. City of Culver City, California
City Council Agenda Item Report
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DEIR Content
One of the goals of the DEIR is to determine if the CSD as proposed by PXP has the
necessary development standards, operating requirements and procedures to
mitigate the potential environmental impacts of future oil field development activities.
To accomplish this goal an environmental impact analysis was conducted on a
Potential Future Oil Field Development Scenario. This scenario looked at the
maximum development that could occur over the next twenty years. There are no
current applications for oil drilling.
Based upon the environmental impact analysis of the Potential Future Oil Field
Development Scenario, the DEIR identified a number of measures to mitigate the
identified impacts of future oil drilling (Table ES-1, Page ES-25). The development
standards, operating requirements and procedures in the PXP proposed CSD were
then compared with the identified measures to determine areas where the proposed
CSD could be enhanced. The recommended modifications to the proposed CSD
are discussed in Table ES-2 (Page ES-15) in the DEIR.
The only impact identified in the DEIR that could not be mitigated to a less than
significant level in the Potential Future Oil Field Development Scenario was
earthquake-related hazards, such as ground rupture, ground acceleration, and
ground shaking common to the Los Angeles region (Impact No. GR.3, Page 4.4-23).
Because the southeast portion of the oil field is underlain by the active Newport-
Inglewood Fault Zone, there is a greater than average risk of seismic impacts.
Therefore, seismic related impacts are significant. Although mitigation is proposed
to reduce the impacts of earthquake-related hazards, which would require measures
such as not allowing certain types of new facilities within 50 feet of a known active
fault, such measures cannot mitigate these impacts to a less than significant level.
The California Environmental Quality Act (CEQA) requires an EIR to describe a
reasonable range of alternatives to a project. Since the proposed project is a CSD
(zoning legislation), the alternative analysis looked at three alternative regulatory
schemes that the County could implement in establishing development standards,
operating requirements, and procedures to regulate future development at the
Inglewood Oil Field. The following alternatives are discussed in Section 5.0 of the
Draft EIR.
1. No Project Alternative – (future oil field development would be permitted using
the process that was in place prior to the Emergency Interim Ordinance)
2. Site Plan Review with Director Approval - (Considered a ministerial process not
subject to CEQA) City of Culver City, California
City Council Agenda Item Report
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3. Conditional Use Permit Alternative - (considered discretionary process subject to
CEQA)
The DEIR identifies the Conditional Use Permit Alternative as the superior regulatory
scheme since it would provide the best mechanism for conditioning future oil field
development. The County will use the mitigation measures identified in the DEIR as
well as an analysis of the CSD in developing recommendations for modification to
the proposed CSD.
In reviewing the DEIR, staff and Aspen believe the document is inadequate.
Specifically, it does not provide sufficient analysis in several areas including, but not
limited to, public health, noise, air quality, monitoring and enforcement. Additionally,
there is limited information on how the County will apply the mitigation measures to
its proposed CSD. Additional key issues and comments associated with the DEIR
are detailed in Exhibit A to the proposed Resolution (Attachment 1). Exhibit A
consists of a summary of the major issues along with detailed technical comments.
The issue of prohibiting oil drilling (existing or additional drilling) has been raised by
the community at several public meetings. This would require legislative action by
the County and was not analyzed in this DEIR. The purpose of this DEIR is to
analyze and provide information on the environmental impacts of the proposed
project—the CSD proposed by PXP.
Important Future Dates
Aug. 14 County Regional Planning Commission public hearing
Aug. 19 Comment period ends and final comments are submitted to County
Aug. 27 County Regional Planning Commission public hearing
Oct. tbd County Board of Supervisor’s hearing
(At the County Planning Commission meeting on August 14
th
they will determine if
an additional public hearing will be held on September 10th)
FISCAL IMPACT
For the Council’s information, the City-wide public notification for the July 14 and
today’s City Council items was produced at a direct cost of $14,637.08 and the
contract amount approved by City Council for Aspen Environmental Group to assist
staff in the review of the Drat EIR and revisions to the City’s current oil well
regulations was $148,770. Additionally, the City Attorney’s Office has an allocation
of $50,000 for services of a law firm with expertise in environmental law, Greenberg
Glusker, to assist with analyzing the DEIR. City of Culver City, California
City Council Agenda Item Report
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ATTACHMENTS:
1. Proposed Resolution No. 2008-R___, including Exhibit “A” containing detailed
comments on the DEIR.
2. Public Draft Environmental Impact Report Baldwin Hills Community Standards
District, June 2008 – delivered to the City Council on June 23, 2008.
MOTION:
That the City Council:
Adopt a Resolution transmitting to the County of Los Angeles Department of
Regional Planning the official City response to the June 2008 Draft
Environmental Impact Report for the Baldwin Hills Community Standards District.
08/13/2008
Adoption of a Resolution Transmitting to the County of Los
Angeles Department of Regional Planning the Official City
Response to the June 2008 Draft Environmental Impact
Report for the Proposed Baldwin Hills Community Standards
District.
MEETING DATE:
AGENDA ITEM:
ATTACHMENTS
Proposed Resolution No. 2008 R0_,
including Exhibit "A" containing detailed
comments on the Draft EIR
2. Public Draft Environment Impact Report
Baldwin Hills Community Standards District,
June 2008 — delivered to the City Council
on June 23, 2008
Pages
1-160
n/aiiarrrisc
HM &JOT-
RESOLUTION NO. 2008-R
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CULVER CITY,
CALIFORNIA, TRANSMITTING TO THE COUNTY OF LOS ANGELES
DEPARTMENT OF REGIONAL PLANNING THE OFFICIAL CITY RESPONSE
TO THE JUNE 2008 DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE
BALDWIN HILLS COMMUNITY STANDARDS DISTRICT.
WHEREAS, the County of Los Angeles is proposing to adopt a Community
Standards District (CSD) to establish oil drilling regulations for a portion of the Inglewood Oil
Field located in the unincorporated Baldwin Hills area; and
WHEREAS, there is the potential that over the next 20 years an average of
approximately 53 wells per year could be drilled in the Inglewood Oil Field, a portion of
which is within the City of Culver City; and
WHEREAS, the proposed CSD will abut the border of Culver City, and Culver
City residents and business will be directly affected by oil and gas drilling operations within
the CSD; and
WHEREAS, in July of 2007, Culver City provided written comments to the
Notice of Preparation of a Draft Environmental Impact Report (Draft EIR) which, in addition
to other comments, requested that issues relating to possible future drilling and operational
activities, impacts on the areas surrounding the CSD, and impacts to air quality, water,
geological resources, and emergency services be analyzed in the Draft EIR; and
WHEREAS, the County of Los Angeles has prepared a Draft EIR dated June
2008 to analyze the potential environmental impacts of the Plains Exploration & Production
Company's proposed CSD, which was released for public review and comment on June 19,
2008; and|101010101010101010 10
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Page 1 2008-R WHEREAS, a City staff team consisting of various City Departments and
consultants, and a City Council subcommittee, was established to evaluate and comment on
the adequacy of the Draft ElR in addressing potential impacts to Culver City; and
WHEREAS, the City Council of the City of Culver City, accepted public
comments and considered the Draft FIR at public meetings on July 14, 2008, and August
13, 2008.
NOW THEREFORE, the City Council of the City of Culver City, California,
DOES HEREBY RESOLVE as follows:
1.
Determines that the Draft FIR is substantially inadequate for certification
by the Lead Agency and that a complete and proper level of environmental data and
analysis must be incorporated into the Draft FIR to address the identified deficiencies.
2. Establishes that this Resolution, including attached Exhibit A, constitutes
the City of Culver City's official comments on the June 2008 Draft E1R that was prepared for
the proposed Baldwin Hills Community Standards District.
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29City Clerk
3. Directs and authorizes staff to transmit comments of the City of Culver
City on the Draft IER to the County of Los Angeles Department of Regional Planning.
APPROVED and ADOPTED this 13th day of August, 2008.
SCOTT MALSIN, Mayor
City of Culver City, California
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Page 3 2008-R EXHIBIT "A" TO RESOLUTION NO. 2008-R
SUMMARY DOCUMENT TO COMMENTS ON
THE DRAFT ENVIRONMENTAL IMPACT REPORT FOR
THE BALDWIN HILLS COMMUNITY STANDARDS DISTRICT
DATED JUNE 19, 2008
I. INTRODUCTION.
This summary document, including the attached detailed comments on the Draft Environmental
Impact Report for the Baldwin Hills Community Standards District Dated June 19, 2008
("DEIR"), is submitted on behalf of the City of Culver City ("Culver City"). Culver City is a
charter city with a current population of approximately 40,000 residents, many of whom are
located within close proximity to the proposed Community Standards District (the "CSD")
project boundaries. Three Culver City neighborhoods immediately abut the CSD project area:
Culver Crest, Blair Hills and the Raintree complex. Culver City Park is also located adjacent to
the project area. Moreover, much of the project area falls within the Culver City viewshed.
Culver City appreciates the steps Los Angeles County has taken to ensure that the environmental
impacts from Plains Exploration and Production's ("PXP") oil and gas operations within the
Baldwin Hills area are appropriately addressed. Culver City shares the County's concern. We
are uniquely familiar with PXP's oil and gas operations in the area and have been actively
involved in seeking stricter regulation and environmental review of its existing and future
operations in the project area.
II. BACKGROUND.
Culver City and its residents have experienced the consequences of three significant incidents
arising from PXP's operations resulting in substantial releases. Some of the events resulted in
the release of significant petroleum and rotten egg odors (indicative of hydrogen sulfide),
causing various physiological harm. These events, occurring within the space of about two
years, are indicative of the types of releases that we believe will continue to occur.
The first of these incidents occurred on January 10, 2006 and resulted in the significant release of
gases and odors to surrounding neighborhoods with some reporting noxious odors as far as two
miles away. PXP reported that it had unexpectedly hit a pressurized pocket of methane gas that
expelled drilling muds and gases to the surface. Nearby residents reported petroleum and rotten
egg odors, indicative of hydrogen sulfide. Residents reported suffering from headaches, nausea,
ear, eye, nose and throat irritation. Another gas release occurred thereafter on February 6, 2006.
The third of these incidents occurred on March 22, 2008, during which a pipeline leak resulted in
a release of crude oil that reached the Culver City storm drain system, threatening to enter the
Ballona Creek. As was the case With the previous two incidents, this event resulted in an
emergency response by the Culver City Fire Department. In addition, due to the threat to the
storm drain system, this event also required an emergency response from both Culver City and
LII
1Los Angeles County Public Works crews. In sharp contrast to Culver City's actual experiences
with PXP's operations, the DEIR does not sufficiently address these events and suggests that
they will rarely if ever occur in the future. Indeed, according to the DEIR, an oil spill that would
affect the area/creek beds outside of the oil field would only occur once every 5,200 years.
(DEIR 4.1.1.5). However, the three incidents in Culver City, including the March 2008 oil spill,
occurred within a period of only two years, requiring an emergency response from the Culver
City Fire Department, costing Culver City significant resources and causing its residents
considerable discomfort and concern. More importantly, they are indicative of the failure of the
DER to address the very risks with which Culver City is concerned.
These are the types of events that Culver City's residents are concerned they may face in the
future as a result of continued oil operations in Baldwin Hills. Culver City's residents are
frequently subjected to the odors from PXP's daily operations_ It is clear that additional odors
will be generated through current and future oil operations. With those odors, our residents are
concerned about whether the air they breathe is contaminated with diesel particulates, benzene,
hydrogen sulfide and other toxic contaminants, which may cause cancer or other long-term
health impacts for themselves and their children. Our residents also question whether future oil
spills and releases will force them to leave their homes and whether acute exposure will cause
injury or worse. In addition to their health concerns, Culver City residents are concerned that
continued drilling and water injection practices will cause subsidence, seismic instability or
additional gas seeps. They are further concerned the hillsides surrounding their homes and
Culver City will be increasingly marked by the oil drilling operations. Instead of seeing open
space, our residents will view oil pads, pumpers, tanks, roads, etc.
As a result of these incidents, Culver City made inquiry to the Department of Oil Gas and
Geothermal Resources ("DOGGR") and discovered it was issuing permits to PXP without any
CEQA review. This practice was of great concern to Culver City and Los Angeles County and
resulted in discussion of revising the County's existing zoning ordinance to enable it, and not
DOGGR, to be the lead agency with respect to all future oil operation approvals and CEQA
compliance. The County passed urgency legislation and ultimately a moratorium of all drilling
operations pending the County's development of a CSD) for oil drilling operations and
corresponding environmental review. It should be noted, however, that the DER evaluates a
CSD that has been developed and prepared by the CSD applicant, PXP. As proposed, the CSD
does not provide the County with discretionary review for future projects, which does not
provide for continued environmental review. CAL. PUB. RES. CODE § 21080(a); CAL. CODE
REGS. TIT. 14 § 15060(c) (action is not subject to CEQA if it does not involve discretionary
review by the public agency). Thus, if the CSD was adopted as proposed, DOGGR would
continue to be the lead agency for purposes of CEQA review and not Los Angeles County. The
residents of Los Angeles County deserve better.
While the City appreciates the County's efforts to develop stricter regulations to protect public
health and the environment from the impacts of oil operations, the DEW fails to:
Adequately address and/or identify a number of significant environmental
impacts;2. Propose feasible mitigation measures that would mitigate significant
environmental impacts; and
3. Provide sufficient information for the public and the County to understand the
grounds upon which the DEER concludes that environmental impacts are not
significant and or would be adequately mitigated.
The DE1R must include sufficient technical information, and not just conclusions, to enable the
public to review and provide comment. This is a basic requirement of CEQA. Laurel Heights
Improvement Ass 'n v. Regents of Univ. of Cal., 47 Ca1.3d 376, 404 (1988) ("[c]onclusory
comments in support of environmental conclusions are generally inappropriate"). The DEIR
fails to meet these requirements.
The DER must not only fairly consider, evaluate and answer each of these issues, it must show
how these adverse impacts can be mitigated. CAL. PUB. RES. CODE §§ 21002.1(a) and 21061.
The "purpose of an environmental impact report is to identify the significant effects on the
environment of a project, identify alternatives to the project, and to indicate the manner in which
those significant effects can be mitigated." CAL. PUB. RES. CODE §§ 21002.1(a). Thus,
CEQA mandates that the County fully consider the environmental impacts from potentially one
of the largest oil and gas productions to take place in a confined urban setting. Despite this
mandate, the DEIR fails to adequately consider even the most basic questions regarding the
project's impact on public health, the environment, aesthetics and surrounding uses.
Given Culver City's concerns, it has retained Aspen Environmental Group ("Aspen") to provide
third party expert review of the DEIR. Aspen's comments, questions and concerns are attached
to this Exhibit "A" to Resolution No. 2008-R as Attachment 1 and incorporated fully herein.
The qualifications and expertise of those who prepared the comments are also included as
Attachment 2 to this Exhibit "A."
III. ANAYLSIS.
This summary document sets forth and elaborates on some of the more significant comments on
behalf of Culver City.
A. Project Description
An accurate project description is an essential component to assessing whether a
proposed project may have a significant effect on the environment. CAL. CODE REGS.
TIT. 14 § 15124. "An accurate project description is necessary for an intelligent
evaluation of the potential environmental effects of a proposed activity." San Joaquin
Raptor/ Wildlife Rescue Ctr. v. County of Stanislaus, 27 Cal.App.4th 713, 730
(1994)(citations omitted).
The Project Description fails to adequately define plans for the future development of the
oil field, the operation and abandonment of existing wells, the biofarms and the other
ancillary projects. The Project Description also fails to adequately identify the types of
equipment that will be used by PXP for drilling, pumping or workovers. Without
3understanding the nature of the equipment that will be used, it is impossible for the DEIR
to address the impacts except in an overly general and inadequate basis.
The DEW also fails to address the locations and depths of oil formations that will be
accessed through future drilling. Without this infonuation, the DEIR cannot adequately
address the impacts from operations occurring in close proximity to residences and other
sensitive receptors. Drilling a single well near a neighborhood necessarily has a much
different impact than drilling multiple wells over a prolonged period of time near the
same neighborhood. Impacts such as noise, vibration, aesthetics and exposure to toxics
cannot be adequately considered without knowing where the wells and equipment will be
located. As discussed below, the health risk assessment is useless unless it is based on
accurate assumptions regarding the quantity and location of sources near sensitive
receptors. Impacts relating to geological resources, including the potential for subsidence
and seismic events, also cannot be adequately assessed without considering which
geological formations the drilling will impact.
The DE1R did not analyze the impacts of any activity within the Active Surface Field
Boundary that lies outside of the Proposed CSD Boundary. The Active Surface Field
Boundary includes areas within Culver City's jurisdiction. The DEIR should address any
future drilling and operations contemplated within Culver City's boundaries. See San
Joaquin Raptor/Wildlife Rescue Ctr., 27 Cal.App.4th at 739 (EIR that fails to list "past,
present and reasonably anticipated future projects" is inadequate). Even though such
operations will be outside the jurisdiction of the Proposed CSD Boundary, they are within
the Active Surface Field Boundary and part of PXP's overall plans. As required by
CEQA, a careful assessment of the impacts from operations occurring within Culver
City's boundaries is necessary to fully understand the cumulative impacts of the project
in its entirety. It is clear from the DEW that impacts arising from Culver City wells have
not been considered.
The DEW implies that the sole environmental review for this project will be conducted
through this EIR process. However, the DEER acknowledges that the full scope of future
activities is unknown and speculative. Under these circumstances, the DEW is defective
because it cannot adequately assess the impacts from future operations if the scope,
nature and magnitude of future activities are not fully characterized. Although the DEW
suggests that it accounts for this deficiency by considering the information that PXP
provided, it does not adequately limit the extent or amount of future operations that will
occur within the Proposed CSD Boundary. At a minimum, the CSD must limit future
operations to the maximum contemplated in the DEW.
B. Baseline
Establishing an accurate baseline is critical to assessing the environmental impacts from a
proposed project. Save our Peninsula Comm. v. Monterey County Bd. of Supervisors, 87
Cal.App.4th 99, 119 (2001).
The DEW seems to view all current conditions at the site as the baseline from which
future changes to the environment must be measured. Conditions which are not in
4current compliance with applicable laws, however, cannot be considered as part of the
baseline. Current County zoning regulations, for example, prohibit operations and
drilling that result in the creation of a "public nuisance." Los Angeles County Code
22.24.120.D.12. The California Civil Code defines nuisances to include anything which
is "injurious to health" or "offensive to the senses, or an obstruction of the free use of
property, so as to interfere with comfortable enjoyment of life or property." CAL. CIV.
CODE § 3479. A public nuisance is one which affects an "entire community,
neighborhood or any considerable number of persons, although the extent of the
annoyance... inflicted upon individuals may be unequal." CAL. CIV. CODE § 3480.
Noise, vibrations, odors and emissions of toxic contaminants from existing operations
have created such a nuisance. There is no "right" to maintain operations which result in
nuisance, irrespective of how long those operations have been in existence. The DEW
must mitigate both existing and future operations to eliminate any nuisances resulting
from those operations. Moreover, the County is required to enact any regulations that are
reasonably necessary to protect the public health and the environment, even if those
regulations impact existing operations.
C. Air Quality - Public Health
The present and future activities at the oilfield will generate a number of toxic air
contaminants, including diesel particulates, benzene and hydrogen sulfide. The DEW has
failed to adequately address the risks from such contaminants. The risk assessment as
presented in the DEW is entirely inadequate. CEQA prohibits the DEIR from simply
presenting conclusions, without providing the County and public with any means to
deteimine whether the risk assessment was adequately performed. "An EIR must include
detail sufficient to enable those who did not participate in its preparation to understand
and to consider meaningfully the issues raised by the proposed project." Laurel Heights
Improvement Ass'n, 47 Ca1.3d at 405.
One of Culver City's greatest concerns is the health impacts to its residents from oil
drilling operations. For instance, to what extent do the oil operations currently expose
Culver City's residents to toxic chemicals that can cause cancer, disease, injury or death?
These are all questions that should be addressed by an adequate DEW. Unfortunately,
the DEW fails to present any information to support a conclusion that these risks are not
significant.
The DEIR also fails to provide the public with any means to evaluate the real risks
associated with future oil operations. For example, in assessing the baseline risk from
existing operations, Marine Research Specialists ("MRS"), the consultant the was
retained by the County to prepare the DEW, relied solely on data provided by PXP to the
South Coast Air Quality Management District ("SCAQMD"). If PXP inaccurately
reported the information, used erroneous emission factors, undercounted the number of
sources, or made other mistakes, the results, including the cumulative impacts of existing
equipment and future equipment, would be inaccurate. MRS should conduct an
independent review or audit of PXP's emissions inventory, rather than asking the County
and the public to place blind trust in PXP's emission reporting and use of emission
5factors. The complete results of the audit should be included in an appendix to enable the
public to assess the basis for the estimates. See CAL. CODE REGS. TIT. 14 § 15147
(technical data required to be included).
More importantly, it is impossible to determine how MRS estimated future emissions.
The DEIR simply states that "Emissions factors from the SCAQMD were used to
calculate the emissions" for construction related activities. CEQA "requires the EIR to
include underlying technical detail so that the conclusions of the report can be evaluated
by its reading audience." San Franciscans for Reasonable Growth v. City & County of
San Francisco, 193 Cal.App.3d 1544, 1549 (1987); see also CAL. CODE REGS. TIT. 14
§ 15147. However, MRS fails to disclose how it estimated PXP's emissions from its
operations and construction activities except to state that it relied on PXP's reporting for
tank working losses and PXP's reporting to the SCAQMD. (DEW 4.2.4.2). It is
impossible to determine if the number of sources is accurate. The risk assessment fails to
set forth the assumptions that were made regarding the duration considered. For
example, did the risk assessment assume emissions twenty years from now, with over
1000 operating wells, or sooner, with numerous drilling rigs operating? By relying on
PXP's reporting, and blind assumptions regarding the number of sources and/or timing,
errors that PXP may have made, in conjunction with incorrect assumptions, may be
compounded with respect to estimating future emissions. These errors may vastly
underestimate the real risk to Culver City residents and others.
Appendix D only provides a spreadsheet with various sources, emission factors and
contaminants. However, there is no information regarding where these sources are
located. The Health Risk Assessment ("HRA") is dependent on the location of the oil
operations to residences and other sensitive receptors. Without this information, it is
impossible to evaluate the HRA, including its accuracy and the accuracy of its
conclusions. Similarly, the cumulative impact of different construction activities in any
given location may result in a downward spike of toxics. Even the HRA's conclusion
that fugitive emissions from existing equipment will remain the same is unsubstantiated
because there is no way to determine whether existing equipment is operating at
maximum capacity. If the equipment is not operating at maximum capacity, any
additional output would cause additional emissions. Also, it appears that no estimates
have been made for fugitive emissions from well casings, purged drilling muds, gas seeps
or any type of upset events.
The DEIR fails to provide a complete technical analysis as to how it arrived at the HRA
risk values to enable the County and public to assess whether the risk assessment was
done properly. For example, the DE1R fails to include any underlying modeling data and
does not describe how the emissions were allocated to the various area sources. If the
emissions were allocated equally, it may not correctly identify toxic "hot-spots" along the
project area. Moreover, the cumulative risk from the project may not be accurately
portrayed. The DEIR utilizes the MATES study information to detetinine the cumulative
risk. However, the MATES study information may not accurately portray the local
characteristics. Estimating cumulative risk in this way increases the probability of error.
6It is insufficient to merely rely on emission factors. Emission factors are merely
estimates based on industry wide characteristics and averages. PXP's operations could
result in higher emissions. The DEIR must establish that the emission factors used for the
MATES study are accurate for each potential emission source considered. Even a simple
error in calculating an emission rate when multiplied by 1000 new wells could result in
substantial impacts to nearby residents. These impacts may not be known for years until
after our residents have already begun developing health issues.
The HRA also fails to adequately deal with the past emissions and resulting health risks
from the oil operations before there were any regulations. For example, someone who
has lived within the area for the past 50-years may have been exposed to greater impacts
that could cause chronic health impacts. The DER only considers current and future
impacts, which necessarily assumes a level of control technology that did not previously
exist.
The information is not developed to an extent to enable the public to determine which
specific chemicals are causing the risk. Without knowing this information, it is
impossible to develop mitigation measures to address the actual risk. The risks presented
by toxic air contaminants may be severe, resulting in cancer, disease or injury, and must
be thoroughly analyzed and understood by the County and the public.
Finally, the County should adopt a much higher threshold of significance for cancer than
what is stated in the DEIR. The BRA establishes a significance threshold for cancer of
10 in one million, which translates to a cancer threshold of one in one hundred thousand.
We do not believe that this is an adequate risk threshold. The DE1R also underestimates,
without any apparent support, the actual cancer risk. The BRA concludes that the
potential cancer impacts to residents if the mitigation measures are implemented will be
approximately 5 in one million. DE1R 4.3-22. Based on the threshold of significance for
cancer of 10 in one million, the BRA concludes that the cancer risk is "less than
significant." It is not "insignificant" that one, two or more people who are exposed to
these emissions will contract cancer in their lifetime.
Some of the toxic air contaminants of concern include the following:
1. Diesel Particulates
The DE1R fails to adequately address cancer and other risks from diesel
particulates and other PM 10 emissions that will affect local neighborhoods. For
example, it is unclear whether the emissions are properly apportioned. Moreover,
the emissions are not accurately estimated, because they underestimate the size of
the engines for drilling. The DEIR uses emissions for samples that are much
smaller than the rigs set forth in Appendix A.
According to U.S. EPA:
"Acute exposure to diesel exhaust may cause irritation to the eyes, nose, throat
and lungs, some neurological effects such as lightheadedness. Acute exposure
7may also elicit a cough or nausea as well as exacerbate asthma. Chronic exposure
in experimental animal inhalation studies has shown a range of dose dependent
lung inflammation and cellular changes in the lung and there are also diesel
exhaust immunological effects. Based upon human and laboratory studies, there
is considerable evidence that diesel exhaust is a likely carcinogen. Human
epidemiological studies demonstrate an association between diesel exhaust
exposure and increased lung cancer rates in occupational settings."
In order to avoid chronic exposure to diesel particulates, the DEIR should require
the electrification of all pumps, drilling rigs and other heavy equipment. To the
extent electrification is not feasible for heavy equipment, such as graders,
alternative fuels or fuel cell technology must be employed. The use of such
mitigation will not only mitigate diesel particulate emissions (and PM 10
emissions as a criteria pollutant), but also VOCs and greenhouse gases.
2. Hydrogen Sulfide
The DEIR identifies hydrogen sulfide as a toxic air contaminant associated
with the current and future oil operations, but fails to adequately consider the
potential impact of hydrogen sulfide emissions on public health. Acute exposure
can lead to death and chronic exposure is continuing to be studied. According to
the Department of Health and Human Services, Agency for Toxic Substances and
Disease Registry's (the "ATSDR") public health statement for hydrogen sulfide,
exposure to hydrogen sulfide can have varying health affects from irritation to the
eyes, nose and throat to permanent and long-term effects depending upon the
exposure amount and duration of exposure:
"Exposure to low concentrations of hydrogen sulfide may cause irritation to the
eyes, nose, or throat. It may also cause difficulty in breathing for some
asthmatics. Brief exposure to high concentrations of hydrogen sulfide (greater
than 500 ppm) can cause a loss of consciousness. In most cases, the person
appears to regain consciousness without any other health effects. However, in
some individuals, there may be permanent or long-term effects such as headaches,
poor attention span, poor memory and poor motor function... Deaths due to
breathing in large amounts of hydrogen sulfide have been reported in a variety of
different work settings, including ... oil and gas well drilling sites."
Available at http://www.atsdr.cdc. gov/toxprofiles/phs114.html.
California's Office of Environmental Health Hazard Assessment ("OEHHA") has
determined that the chronic risk exposure level for hydrogen sulfide is only 8
parts per billion (ppb). See
http ://www. oehha.c a. gov/air/chroni
c_rel s/AllChrels.html. Only concentrations
below that level pose no significant chronic health risk to the public. The
County is obligated to find that such concentrations would create a significant risk
to the public. There is no evidence that the BRA described in the DEIR
89
considered the chronic effects of hydrogen sulfide and if it did consider those
effects, whether it considered 8 ppb as a threshold of significance.
The DEIR acknowledges that produced gas contains hydrogen sulfide
concentrations as high as 10 parts per million(ppm) to 20 ppm -- or thousands of
times higher than the significance threshold established by OEHHA. With
hundreds of wells producing gas at a rate of thousands of cubic feet of natural gas
per day, the risk that residents located downwind would be exposed to levels over
8 ppb per day appears clear, The DEIR, however, fails to address the risk or even
acknowledge that chronic low level concentrations present any risk. Therefore,
the DEIR entirely fails to address a potentially significant environmental impact,
which could threaten the lives and health of children, elderly and others living
near the oil fields.
The DE1R also fails to properly consider the risk of acute exposure to hydrogen
sulfide. In January and February 2006, the residents of Culver Crest were
exposed to the release of gases from PXP's nearby drilling operations. According
to PXP it had hit a pocket of pressurized gas; a risk that the DEIR says does not
exist in the project area. Those residents reported the smell of rotten eggs and
many reported nausea, headaches and nose, eye and throat irritation. See
Attachment 3 to this Exhibit "A" to Resolution No. 2008-R . The rotten egg
smell is indicative of a hydrogen sulfide release. SCAQ1VID also reported that
hydrogen sulfide had been released. See Attachment 3. The DEER only
considered these incidents for purposes of their odor impacts and not from the
standpoint of acute exposure to hydrogen sulfide. See DEIR 4.2-13 and 4.1-9.
OEHHA has established an acute Reference Exposure Level (REL) for hydrogen
sulfide at 42 ug/m3 or about 30 ppb. This means even short term exposure of
such small concentrations may cause acute physiological effects, including
headache and nausea. As the odor threshold for many people is within the same
range, if the hydrogen sulfide can be smelled it can cause physiological halm.
The DEIR, on the other hand, suggests that acute exposure is only at or above 2
ppm (DEIR 4.2-11) and that concentrations below that amount would be merely
"annoying" and generate "odor complaints." The DEIR then dismisses hydrogen
sulfide as a risk because it is not present in "appreciable quantities."
As the DEIR fails to adequately consider the significant health effects on the
public from acute exposure to hydrogen sulfide, it has failed to consider a
potentially significant environmental impact. This is not merely a hypothetical
impact, it is one that has already occurred as a result of deep drilling, causing
significant public health impacts. Moreover, it is likely that this event could
occur again. Indeed, in failing to consider, discuss or recognize the impacts from
the 2006 incidents, events which are known, how can the County or the public
trust that the DEIR has fairly considered the risks of future unknown or
hypothetical events? A careful analysis of the circumstances that led to the 2006incidents is necessary in order to understand how it can be prevented in the future.
The DEW did not do this.
The mitigation measures proposed to address gases released from drilling
operations are limited to using a portable flare which would only "reduce the
frequency of odor events associated with mud vapors and drilling gases." DEIR
4.2-28. Given the dramatically increased drilling activity at significant depths
(such as where hydrogen sulfide was released in 2006), it is likely that odor
events will increase. The DEIR fails to provide any evidence that a "flare" will
reduce these types of events. As such releases can lead to acute physiological
impacts on nearby residents, reducing the frequency of such events is insufficient.
The HER must establish that these events cannot occur through feasible mitigation
measures. Even the possibility of one event must be considered significant.
In addition to failing to properly consider hydrogen sulfide emissions from
incidents such as the 2006 incidents, the DEIR also fails to consider emissions
from gas seeps, abandoned wells or upsets. The DEIR also appears to only
consider the fugitive emissions large enough to be reportable. The DEER does not
consider the thousands of emissions that are too small to be reportable, but in the
aggregate may contribute to significant environmental and health impacts. DEIR
4.2-12.
In order to properly assess the risk, ambient air sampling should be conducted to
determine the levels of hydrogen sulfide that currently exist and the current
exposure concentration to understand the cumulative effects of additional
hydrogen sulfide emissions from PXP's future operations. Periodic ambient air
monitoring should also be conducted in the future to understand and address
increased concentrations from operations. Most importantly, air monitoring at all
drilling operations should be conducted to determine if potentially harmful
hydrogen sulfide or other gases are being emitted to ensure that immediate
measures to curtail such emissions be implemented.
3. Benzene
The DEW also does not adequately address benzene. OEHHA has established a
chronic reference exposure level for benzene at 20 ppb. The Minimum Risk
Level established by the ATSDR is 3 ppb.
The ATSDR has also issued a public health statement for benzene. Available at
hap ://www. atsdr. cdc gov/toxpro files/phs3. html). According to the health
statement, both the "International Agency for Cancer Research and the EPA have
determined that benzene is carcinogenic to humans." "Brief exposure (5-10
minutes) to very high levels of benzene in the air (10,000-20,000 pprn) can result
in death." "Lower levels (700-3,000 ppm) can cause drowsiness, dizziness, rapid
heart rate, headaches, tremors, confusion, and unconsciousness." Long-term
10
13exposure to benzene can cause leukemia, especially a particular type of leukemia
called "acute myeloid leukemia."
For the reasons discussed above relating to the HRA, the DElR fails to adequately
assess the risk of exposure to benzene.
D. Odors
The DEIR fails to adequately consider the impact of odors on Culver City residents. The
DEIR only considered occurrences of odors that were reported to the SCAQMD. A
quick survey of residents in the neighborhood would have disclosed that nuisance odors
are a common occurrence. Comments from the Culver Crest Neighborhood Association
to the Notice of Preparation advised of "weekly" odor occurrences and requested that
neighbors be contacted directly so that the EIR could fully assess the frequency and
impact of the odors. See Appendix K to DEIR (Letter from CCNA dated July 24, 2007).
This was not done. Merely walking though the project area would have disclosed more
odors than the DEW acknowledges ever occurring. Although the DEW acknowledges
that many of Culver City's residents will be impacted if odors do occur, it fails to
acknowledge all of the potential sources of odors. For example, the DEW fails to
acknowledge that any odors would be generated by hydrogen sulfide emissions, as
clearly occurred in early 2006.
Culver City's residents have had to live with these odors for many years. The proposed
oil operations threaten to further add to these odors without resolving the nuisance that
already exists. The DEIR must be amended to fully consider the odors that are occurring
now so that it can adequately assess the odors that will occur in the future. The proposed
mitigation measures to address the release of gases during drilling operations would only
"reduce the frequency of odor events." DEIR 4.2-28. However, reducing the frequency
of the events would not mitigate the impacts to less than significant, because any one
odor event that creates a nuisance would be significant.
Mitigation measures must be implemented that will reduce all odor events_ The DEIR
states that PXP has ceased downhole testing for pressurized gases because they are
unlikely to be present. As pressurized gases caused the most significant odor event in the
recent past (and likely released hydrogen sulfide gases), all necessary steps must be taken
to avoid such pressurized gases. Air sampling for sulfides must be conducted at the
wellhead at detection limits well below 1 ppm and cease operations until it can be
determined that no sulfides will be released_ Site specific emission factors should be
established for all emitted toxic compounds, such as benzene.
E. Seismic Risk, Subsidence and Gas Seeps
The Baldwin Hills project is located on top of the active Newport-Inglewood Fault Zone.
A portion of this fault zone, including portions within the project area, have been
included within the Alquist-Priolo Fault Zone, which requires special geologic studies
before any stuctures used for human occupancy can be built. The potential for small or
/5/
11large earthquakes caused by water injection is not adequately addressed in the DER.
The DEIR acknowledges that water injection in oil fields has caused earthquakes, but
concludes, without providing a reference, that this has not occurred at the Inglewood Oil
Field. Moreover, there is not an acknowledgment by the DEW that past experience with
water injection may not be indicative of what will occur in the future as much deeper
formations are used for water injection.
There is no evaluation of the risks of earthquake created by deeper water injection. The
DEIR needs to establish that future water injection will not cause a risk of earthquakes.
Nor is there any evaluation of the scope of damage, injury and environmental harm that
would be caused by an earthquake. These evaluations are necessary. The potential for
man-caused earthquakes is clearly a significant impact which must be mitigated to zero
probability. There cannot be any overriding consideration for an event that could cause
significant property damage, bodily injury and environmental harm.
Subsidence has also been identified as potentially significant impact. Subsidence is
typically triggered from the depletion of oil reserves beneath the ground surface. The
project area has experienced significant subsidence historically and such subsidence is
believed to have created vertical and horizontal faults and earthcracking. The subsidence
has also been linked to the failure of the Baldwin Hills dam in 1963, resulting in multiple
deaths. Therefore, although water injection is believed to have helped stem the
subsidence, there is no clear evidence that water injection will continue to mitigate
subsidence over the decades to come. The DEIR needs to include far more analysis than
is provided before it can be definitively determined that subsidence is not a significant
impact in the near term or future. The DEIR must also determine whether the possible
"solution" for subsidence may result in even more significant harm itself.
The DEIR also acknowledges that gas seeps have plagued oil fields in the Los Angeles
Basin, including presumably the project area:
"Oil field gases have a propensity to migrate to the surface along faults and poorly
completed and/or abandoned wellbores. Furthermore, the upward migrating gases will
accumulate in the near-surface collector zones, often trapped and concealed within the
permeable gravel and sand lenses." (DEIR 4.4.1.7).
The DEW identified a number of pathways by which these gas seeps, which can include
methane, ethane, and toxic gases such as hydrogen sulfide, can find their way to the
surface. While water injection may help stem subsidence, the DER notes that studies
indicate that water injection may increase the occurrence of gas seeps, presumably by
creating sufficient pressure to force the gas upward. When combined with the faults and
cracks created by historical subsidence, and the pathways created by hundreds, if not
thousands, of abandoned, idle, or dry wells, the risk of gas seeps to the surface can be no
less than significant. Any new well and continued or expanded water injection could
trigger a significant release of such gases creating a risk of explosion and toxic exposure
to employees and nearby residents.
12In addition to natural pathways, such as cracks or porous sediments, the DEIR also
identified abandoned oil and gas wells or dry holes, undocumented wells and dry holes,
deteriorated armular cement seals, and water extraction and injection wells as potential
conduits for gas migration. The HRA failed to consider the risks from toxic emissions
from all of the other sources of gas seeps that are identified in the DEIR, including
cracks, porous sediments, dry holes, deteriorated cement seals and water extraction and
injection wells and active wells. There is no data or assessment regarding the number of
gas seeps in the project area, how many additional seeps may be created as a consequence
of future operations and construction or the estimated emissions (toxic and otherwise)
that may be generated from those seeps. The DEIR only makes note of a limited soil
vapor study conducted in the area of some abandoned wells. However, even the DEIR
does not suggest that the limited soil vapor study provides any basis to conclude that
seeps are now, or in the future, not a matter of significant environmental concern.
Indeed, as the DEIR acknowledges, produced gas may have levels of hydrogen sulfide as
high as 10 or 20 ppm, it must evaluate the risk of gases escaping as fugitive emissions
through gas seeps.
The referenced soil vapor survey is deficient because it failed to report concentrations of
even the most toxic gases unless those gases exceeded 0.2 ppm. Widespread release of
toxic gases, such as benzene and hydrogen sulfide, at low levels can cumulate with other
fugitive emissions resulting in an exceedance of chronic and acute reference exposure
levels. These are significant impacts which must be avoided.
F. Visual and Aesthetic Resources
Culver City is significantly concerned with the impact of existing and additional oil
facilities, well drilling rigs and construction equipment to the visual and aesthetic
resources of its residents. The DEIR should recognize the impacts of the visual
degradation from further development in the area designated as the Culver City
viewshed, as well as the views from Culver Crest, Blair Hills and Raintree
neighborhoods.
The Baldwin Hills is one of the most prominent geographic features in the region. PXP
plans to place 233 wells in the Culver City viewshed alone. The landscape will be
dramatically changed from not only the pumping equipment, but the proliferation of drill
rigs over 100 feet high for at least 2,330 days or 6.4 years in the aggregate (at 10 days per
well). The defacement of the hills will be visible from miles around. The impact of
future development will impact almost the entire City as the hillsides become saturated
with wells and the ridge lines marked with protruding equipment. Culver City supports
the mitigation measures recommended by the DEER because they go much further than
the CSD. However, more can and needs to be done.
As discussed above, all wells should be relocated and consolidated out of the public view
to the extent technically feasible through the use of slant drilling. If not technically
feasible, low-profile or underground pumping units must be used to the extent feasible.
These measures are commonly used and are practicable. Landscaping plans must either
/61
13include mature, native species capable of shielding the equipment immediately or planted
far enough in advance of any construction activities to shield such work at the time it
occurs. As discussed above, forestation of the hillsides with native species consistent
with the natural environment will yield other benefits as well, such as offsetting
greenhouse gas emissions by acting as carbon sinks.
G. Noise and Vibration
The DER fails to acknowledge that current noise levels are already significant. The
DEW chart at Table 4.9.5 demonstrates that current levels exceed those prescribed by
Los Angeles County Code. The DEW suggests mitigating future noise impacts by
limiting such noise to an increase of 5 db from the baseline. However, allowing 5 db to
be added to the current baseline will cause a significant impact. As the decibel scale is
logarithmic a 5 db increase is one which is significantly louder than the baseline. For
example, a 6 db increase is considered to be twice as loud as the baseline. See
http://www2.sfu.ca/sonic-studio/handbook/Decibel.html.
While not quite twice as loud, an increase of 5 db magnitude must be considered
significant. The addition of drilling rigs, thousands of new pumping units, the attendant
maintenance and workovers will significantly degrade the quality of life by causing
noises to intrude into nearby neighborhoods 24 hours a day. Even a 1 db increase will be
a perceptible and a significant increase in the baseline. Thus, additional average noise
should not be permitted at all. Likewise, any vibration that can be felt by nearby
residents must not be permitted.
Electrification of all existing and future pumping units, drilling rigs and other equipment
is at least one method to feasibly mitigate noise. Soundproofing, as is already required
on drill rigs within 500 feet of residences, should be required on rigs within 1500 feet of
residences. Radio headsets should be used to mitigate the noise from yelling of
directions. Additionally, the use of temporary sound blankets can mitigate noise impacts.
Other mitigation measures must be implemented. The DEIR has also failed to consider
the noise and vibration that will occur from the flare.
H. Compatibility with Surrounding Uses and Recreation
The DEIR fails to adequately consider the Baldwin Hills Conservancy Master Plan which
contemplates the future recreational use of the project area. The Baldwin Hills is a
unique resource that provides much needed recreational uses in the region. The Master
Plan was drawn up to address this resource.
Enforcement
It has been Culver City's experience that PXP has not always complied with minimal
requirements that currently apply to them. For example, in 2006 PXP performed
substantial grading operations, including leveling a ridgeline above West L.A. College,
without obtaining a pen lit. Existing regulations require PXP to implement proven
14
17technology to reduce annoyance and nuisance to the surrounding community. PXP has
failed to do so. The 2006 releases are a result of PXP's failure to implement proven
technology, such as flares, down-hole testing and on-site air monitoring. Although
Culver City's experiences with PXP's compliance may be anecdotal, they raise serious
concerns regarding PXP's willingness to voluntarily comply with applicable laws and
regulations. These experiences underscore that even with requiring the appropriate
mitigation measures, the CSD must provide for a rigorous enforcement mechanism,
which includes frequent inspections and audits.
CEQA requires all adopted mitigation measures to be enforceable through "permit
conditions, agreements, or other measures." CAL. PUB. RES. CODE § 21081.6(b); see
also CAL. CODE REGS. TIT. 14 § 15126.4(a)(2)("Imlitigation measures must be fully
enforceable through peimit conditions, agreements, or other legally-binding
instruments."). Even if all of the mitigation measures are required, the CSD must assure
compliance with those measures and adequate penalties if PXP fails to comply.
J. Mitigation Measures
First, we note the following significant issues that must be addressed through specific
mitigation measures to feasibly mitigate the significant impacts arising from current and
future oil operations:
1. Consolidation of Existing and Future Oil Wells: The location of existing
and future oil wells must be consolidated to the extent feasible to ensure that the
wells are not within the view of the surrounding neighborhoods and the public.
This measure could be accomplished by slant drilling, which PXP and others have
previously used. Employing this mitigation measure would have several
beneficial impacts, including minimizing visual and aesthetic impacts, mitigating
odor and toxic emissions by placing operations further away from sensitive
receptors and minimizing the impact on future recreation uses. This would also
help mitigate any inconsistencies between the drilling operations and the Baldwin
Hills Master Plan by creating open space for future use. Tanks or other ancillary
equipment should also be located outside of public view to the extent feasible.
2. Low Profile Pumping Units Should be Used: The wells that cannot be
feasibly relocated, should be replaced with low profile, residential or underground
pumping units. The use of such pumping units is feasible and frequently
employed in practice. Low profile drilling rigs should be used if and when such
technology becomes feasible.
3.
Develop a Comprehensive Landscaping Plan for the Project Area: A
comprehensive landscaping plan should be developed for the entire project area in
consultation with the Baldwin Hills Parks Conservancy. The plan should include
provisions for shielding all equipment from current and future public users
through the prompt planting of mature or semi-mature trees, shrubs and other
plants. This measure will help mitigate visual, aesthetic and noise impacts,
icr
15impacts to future recreational uses and inconsistency with the Baldwin Hills
Master Plan. Finally, the forestation of the project area will help mitigate the
direct and indirect greenhouse gas ("GHG") emissions from the project because
the trees will act as carbon sinks, thus offsetting some of the carbon emissions.
See California Air Resource's Board Discussion
http://www.arb.ca.c, ,ovice/forestryiforestry.htm. The DEIR should also consider
whether such measures will help to mitigate odors and toxic exposure by filtering
and dispersing the odorous and toxic airborne contaminants.
4. Electrification of all Drilling Rigs and Heavy Equipment: All heavy
equipment and drilling rigs should be powered with electricity. This is
technically feasible and has been achieved in practice for drilling rigs. Indeed,
electrification is required on various public lands, such as the Los Padres National
Forest, where even less concern exists about impacts on nearby residents. See
e.g., Standard Lease Agreement for Los Padres National Forest available at
htto://www.fs.fed.us/r5/lospadres/proj ects/oil- gas/do c-p dfs/ap-files/22-feis-
apndx-b-stips-slts.pdf ("if onsite electricity is available, electric drill rigs will be
used."). If this is not technically feasible for heavy equipment such as
earthmovers, alternative fuels, such as natural gas, should be used. This measure
will mitigate impacts to the public health and the environment from diesel
particulate emissions. It will also mitigate impacts caused by noise and
greenhouse gas emissions.
5. Baseline Comprehensive Health Assessment: A comprehensive health
assessment of the communities immediately surrounding the oil fields must be
conducted to establish a baseline from which to measure the effects of current and
future oil drilling operations. Periodic reassessments, approximately every five
years, must be conducted to determine if the mitigation measures in place have in
fact reduced health risks to a less than significant level. This is a crucial part of
the mitigation monitoring program.
6. The Los Angeles County Department of Planning Must have
Discretionary Review of Oil Drilling Operations: The CSD must be revised to
clarify that the Los Angeles County Department of Regional Planning (the
"DRP") has "discretionary" and not "ministerial" review over development plans
submitted under the CSD. An oil operation of this magnitude should not be
considered solely in a conceptual faun without providing for future CEQA review
as more detailed plans are submitted for DRP approval. Indeed, the DEW makes
only certain assumptions regarding future activities, the number of wells, general
location of wells, equipment to be used and the like. The CSD places very few
limitations on such future activities. Thus, future projects could entail activities
with impacts that exceed even those contemplated in any "worse case scenario"
that the DEIR considered. Future CEQA review would allow DRP to consider the
specific activities relating to any given project, the impacts of such activities and
the residual impacts that occur despite the implementation of the mitigation
measures. As these projects are implemented, DRP will be in a far better position
16
I?than it currently is to determine the effectiveness of such measures. Future
discretionary review would also allow DRP to require state of the art technology
as it becomes available to better mitigate the significant impacts and any
unforeseen circumstances that occur over twenty (20) years of this project. Even
the County's current zoning regulations require the operator to use the best
available proven technology, something that the CSD does not. See Los Angeles
County Code 22.24.120.D. At a minimum, the current EIR should be considered
a program Ea from off of which future EIRs could tier. See CAL. CODE REGS.
TIT. 14 § 15168(a). This will enable the County to focus subsequent
environmental review on the new environmental effects that were not considered
in the current EIR. CAL. CODE REGS. TIT. 14 § 15168(d)(3).
7. CSD Must Require Continuous Air Monitoring: The CSD must provide
for continuous air monitoring throughout the project area and specifically at
wellheads where any drilling is occurring. Whenever toxic air contaminants
exceed established significance criteria levels, the CSD should provide for
notification to appropriate agencies, including the Culver City Fire Depal lanent,
and require immediate steps be taken to curtail the emissions until DRP, Culver
City and others can be assured that appropriate steps have been taken to ensure
future emissions will not occur.
8. Enforcement Procedures Must Be Included: The CSD must provide for an
effective monitoring, enforcement and audit process to demonstrate continued
compliance with the CSD and all required mitigation measures.
9. The CSD's Jurisdiction Should be Definitively Delineated: The CSD
must make clear that it covers only drilling within the CSD. Any slant drilling
from the CSD into other jurisdictions, such as Culver City, will be subject to the
ordinances, regulations and permitting requirements of such jurisdictions. The
DEIR has not considered risks, such as seismic risks, associated with any
subsurface drilling, wells or water injection that extends beyond the CSD
boundaries.
IV. CONCLUSION.
We trust that the County will carefully consider and adequately address Culver City's comments
in the Final EIR and, if necessary, recirculate the DEIR. Further, the City looks forward to
reviewing the revised CSD prepared by the County and expects to see the City's and
community's concerns and issues addressed in the final CSD that is adopted by the Los Angeles
County Board of Supervisors.
Attachments: I. Technical Comments prepared by Aspen
2. Aspen's Statement of Qualifications and resumes
3. SCAQMD Air Quality Complaint Reports
17AsRen
Environmental Group of Resolution No. 2008R August 6, 2008
Ms. Sherry Jordan
City of Culver City
9770 Culver Boulevard
Culver City, CA 90232-0507
Re: Comments on the Public Draft Environmental Impact Report (FIR) for
the Baldwin Hills Community Standards District, June 2008
Attachment I to Exhibit "A"
Dear Ms. Jordan:
Enclosed are Aspen's comments on the Public Draft EIR for the Baldwin Hills Community Standards
District (CSD). Based on our review of the Draft EIR, the document does not provide sufficient
explanation for the identified impact findings especially for those issues that are important to the City of
Culver City (i.e. risk of upset, public health, noise, and air quality). Also, the Draft EIR does not provide
sufficient technical detail/analysis to serve as the environmental basis for issuing ministerial permits if the
County of Los Angeles adopts the CSD. At this time, there are too many unanswered questions to deem
the Draft EIR adequate. Some of the key issues are summarized below. However, Aspen's detailed
comments are provided in the attachment.
• CSD. There is limited information on how the mitigation measures will be applied to the CSD and the
process for implementing the CSD. The CSD should include the construction and operating limitations
identified in Section 3 and in the impact analyzes.
• Risk of Upset. Given past incidents in 2006 and 2008, additional mitigation measures are needed to
address the potential release of H 2S and to require odor risk analysis and periodic facility audits.
• Air Quality. The significance criteria used in the Draft EIR is not based on current SCAQMD accepted
criteria. The baseline emissions and significance criteria need to be revised to accepted SCAQMD
methodology. Well drilling emission estimates are significantly underestimated and need to reflect a
maximum number of drilling rigs used per day and use of equipment horsepower as identified in Appendix
A.
• The significance determination for odor impacts is based on reducing the number of odor events, which is
not a correct approach because the proposed increase in well drilling and operating wells would increase
the potential for odor events.
• Public Health. The Draft EIR has not established that all sources at the site use Best Available Control
Technology for Toxics (TBACT). If TBACT cannot be established then the finding of no significant
impact could change. The Draft EIR needs to include past and future risk to long-term area residents based
on the historic air toxic emissions when there would have been significantly lower emission control
requirements and significantly higher emitting equipment. The Health Risk Assessment documentation is
deficient and therefore cannot be evaluated to determine whether the assessment was performed correctly.
• Noise. The Draft EIR does not evaluate the project with regard to construction noise thresholds. A
quantitative analysis is needed to support the conclusion of less than significant impact with mitigation.
• Land Use and Recreation. The Draft EIR should evaluate the proposed project for consistency with the
Baldwin Hills Park Master Plan due to its regional and local importance.
30423 Canwood Street, Suite 215, Agoura Hills, CA 91301 • Phone (818) 597-3407 • Fax (818) 597-8001
Aspen@Aspen Eacom • http://www.AspenEG.com
2.1City of Culver City Comments on Baldwin Hills Oil Field EIR
Page 2 of 2
If you have any questions or need any clarification with regard to these comments, please do not hesitate
to contact me at (562) 947-5259 or at salopez@aspeneg.com
or you may contact Jon Davidson at (818)
597-3407, ext 343 or at jdavidson@aspeneg.com .
Sincerely,
ASPEN ENVIRONMENTAL GROUP
AAA di et --L/2 0._A C.6,7 7 jifri
Sandra Alarcon-Lopez
Senior Associate
Attachment: Comments on Draft EIR
Statement of Qualifications
30423 Canwood Street, Suite 215, Agoura Hills, CA 91301 • Phone (818) 597-3407 • Fax (818) 597-8001
E-mail: Aspen@AspenEG.com • http://www.AspenEacomComments on the Public Draft EIR
Baldwin Hills Community Standards District
General Comments
• The Draft EIR does not explain how the mitigation measures will be applied to the Community
Standards District (CSD). Because a revised CSD has not been included in the review of the Draft
EIR, there are no assurances that the mitigation measures identified in the document will be adopted
as part of the CSD. Additionally, the CSD should include construction and operating maximums such
as the major construction projects allowed to occur concurrently, maximum number of wells drilled
per year, maximum number of drill rigs in operation during any one day, and production maximums.
• The CSD boundary only encompasses lands within the jurisdictional boundaries of the County of Los
Angeles (Figure 4.8-1), and lands falling within the jurisdictional boundaries of the City of Culver
City are excluded. If any future drilling within the "Culver City Area" drilling area (Figure 3-2) is
possible, even conceptually, in the City of Culver City it should be stated in the Draft FIR and the
City of Culver City should be noted as having jurisdiction within this area. Otherwise, the Draft EIR
should explicitly state that future activities undertaken in the "Culver City Area" drilling area require
approval from the City of Culver City and compliance with City requirements.
• No explanation for the extended CSD boundary south and southwest of the "Active Field Boundary"
and south of the Southern California Edison (Edison) facility (Figure 4.8-2) is provided, although no
future drilling or related production facilities appear to be proposed within this area (Figures 3-2 and
3-4).
• As related to the CSD boundary extension south and southwest of the Edison facility, the Draft EIR
must state if any future activities are proposed in this area. Without explanation, the extension raises
the question as to whether Plains Exploration & Production Company (PXP) plans to request an
extension of DOGGR's productive field limit and surface field boundaries. As noted in the last
paragraph of Draft EIR Section 2.1, DOGGR's boundaries are not fixed and can be modified (e.g.,
expanded) via ministerial actions which are not subject to review and approval under the California
Environmental Quality Act (CEQA). If such future plans are foreseeable, which they appear to be, they
must be included as part of the proposed project to reflect the "whole of the action." CEQA expressly
prohibits project segmenting (or "piecemealing') (CEQA Section 15378 [a], [c] and [d]).
• For the purposes of confirming the proposed project's full objectives, intent and need for the pro-
posed project area, a description of what criteria (or factors) were used to establish the boundary of
the CSD must be provided.
• The Draft EIR analysis needs to be clear on how it defines construction and operation activities and
provide supporting information to justify why certain construction activities have been identified as
operational activities. The Draft EIR identifies well drilling as an operational activity and assesses
impacts based on this classification. However, well drilling should be considered construction or
defined/regulated based on distance from sensitive receptors. As currently defined, the impacts are
not adequately assessed and therefore impact findings are not appropriate because of this definition.
Also see comments in air quality and noise regarding construction versus operational activities.
• The City of Culver City residents are very concerned with past odor releases, noise, and other
nuisance activities from the oil field. The CSD and the Draft EIR do not address how existing
operations will be dealt with in light of past odor releases and spills. Please address how existing
z_3Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
nuisance factors will be controlled and addressed through the CSD and identify mitigation measures
specific to existing operations.
Executive Summary
Page ES-14 Oil Spill Risk. 3rd Paragraph
The 110% containment identified in the Draft EIR may not be adequate according to current regulations.
Secondary containment as required by NFPA 30 and 40 CFR Part 112 should be the entire contents of the
largest single tank plus sufficient free board to accommodate precipitation or firefighting water. For
example, Santa Barbara County requires 100% of the largest tank volume plus 24-hour, 25-year rainfall.
Please address how the project meets these requirements.
Page ES-16, R.2-1 Secondary Containment
As discussed above, the CSD must ensure that the containment volume is adequate as required by
NFPA-30 and 40 CFR Part 112.
Section 2.0 Project Description
General Comment— Bioremediation Farm Description
The County of Los Angeles should include a more detailed description of the Bioremediation Farm because
this onsite activity will create air quality and risk-related emissions including odor. This additional
information should include the types of contaminated soils that would be treated, whether soils would be
from onsite sources or imported from other sites/facilities, quantities treated, odor control effectiveness, and
other applicable environmental and health-related issues.
Page 2-4, Figure 2-3 and Page 2-5, Table 2.1
Figure 2-3 and Table 2.1 list the Inglewood Oil Field Parcel Ownership. Is PXP the current owner and
operator of all of these leases? Is PXP the sole operator of the Inglewood Oil Field? Please clarify.
With regard to the lease owners listed on Table 2.1, is the 53 wells per year estimate for all potential
development on the oil field or just the potential wells to be drilled by PXP?
Section 2.2 Inglewood Oil Field Current Operations
Page 2-8, 1st Paragraph and page 2-9 Figure 2-5
Discuss the processing details and capacities of the Ga.s Plant, Crude Oil Treating Plant and the Water Treatment
Plant. Discuss the details of the Compression Unit, Amine Unit (including details of the design inlet
concentrations of H2S and CO 2 concentrations, Acid Gas disposal, and other details) Glycol Unit, and the
Gas Liquids Removal Unit.
Section 2.2.5 Current Operations Gas Gathering/Gas Processing
Page 2-13, 2nd Paragraph
Discuss the "worst case" H2S contents in the gas and the crude oil. Since the gas plant has the amine H2S
removal system, the gas could have been sour in the past. Please provide and discuss historical H 2S content
in the gas.
Section 2.2.6 Current Operations Well Drilling, Maintenance, and Workover
Page 2-15, 1st Paragraph
Please define the well types identified in this paragraph. Discuss the difference between the "shut-in wells" and
-abandoned wells."
2Baldwin Hills Community Standards District
COMMENTS ON THE PUBUC DRAFT ENVIRONMENTAL IMPACT REPORT
Section 22.7.4 Current Operations Ancillary Systems
Page 2-21, 2nd Bullet
Figure 2-6 (on page 2-10) shows Basin 2a and Basin 2b, in addition to Basin 2. Basin 2a and Basin 2h are
not discussed in this section.
Pages 2-21 and 2-22, Table 2.2 Retention Basins and Table 2.3 Secondary Basin Containment
The capacities provided in this table for Retention Basins do not match with capacities provided in Table
2.2. For example, Table 2.3 shows 33,860 bbls capacity for LAI Tank Farm and Table 2.2 shows 1,281,000
gals (30,500 bbls) for LAT.
Section 2.2.9 Current Operations Employees and Scheduling
Page 2-23, 4th Paragraph
It states, "There are also estimated five visitors to the site each day." As per Table 2-5, there are total of
11 visitors. Please reconcile.
Page 2-25, Table 2.5 Peak Day Employees and Truck Visits
Are the "weekend day shift" and "night shift" personnel in addition to the 200 for the "day shift" and 15
for the "night shift"? They should be included in the "day shift" and "night shift" count.
Section 2.210 Current Operations Chemical Usage and Wastes
Page 2-28, 1st Paragraph
Correct reference in the text from "Table 2.5" to "Table 2.6."
Page 2-28, Table 2.6 Current Chemicals at Inglewood Oil Field
The Table does not show Amine and Anhydrous Ammonia Storage inventory. Please include Amine and
Ammonia storage quantities. Also, explain use of anhydrous Ammonia in the text.
The table lists fl,S Scavenger for H,S removal from gas. Please provide details about the use of the
scavenger. Is Formaldehyde removed? What is the concentration of the H 2S in the gas that is treated by
the scavenger? Is the H2S removal process in addition to or in conjunction with the Amine H2S removal
system in the gas plant? If the gas is sweet (i.e., no H,S) then why are these H 2S removal processes in
use?
Various Sections
Please add definitions for terms such as AWT and PH in this section and in the acronym list in the front
of the report.
Section 2.4 Applicant Proposed Baldwin Hills Community Standards District CSD
General Comment— CSD and Mitigation Measures
• The CSD should include all of the recommended mitigation measures identified in Section 4
(Analysis of Environmental issues). If these mitigation measures are not included in the CSD then
issues such as safety, noise, air quality, traffic, visual, and potentially other significance findings must
be revised from less than significant impacts with mitigation to significant unavoidable impacts.
• As currently prepared and when the CSD is adopted, any future development of the field will be a
ministerial action. However, the Draft EIR does not provide sufficient detail as explained in this
comment letter or sufficient justification for the less than significant impact determinations.
Therefore, all permits should be discretionary and subject to CEQA analysis. Issues such as noise, air
quality, public health and safety, and traffic have the potential to cause significant environmental
impacts even with mitigation. Please incorporate further language in the CSD and in the Draft EIR to
require discretionary permits and project-specific environmental review.
3Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
• CSD is a dynamic document, which the County of Los Angeles should update on a consistent basis.
Please incorporate in the CSD a requirement that the County of Los Angeles update the CSD (or revali-
date) every two years (or sooner if warranted by significant facility modifications) to reflect modifica-
tions made at the facility or changes in the regulations.
• The County of Los Angeles must establish a framework for how all of the various studies and
requirements will be evaluated and reviewed as part of the permitting process. In some cases, the
County will require a third-party reviewer to assess the adequacy of the plan studies. This issue is
important because as currently planned, permits will require no further environmental review. To
reduce potential impacts as discussed in the Draft EIR, the County will need to have third party
review of operator submitted plans to ensure that public safety, health and environmental resources
are protected as proposed in the Draft EIR.
• The CSD is not clear on whether the identified studies and plans will be applied field-wide (program-
wide) or on a project-by-project basis. The CSD should distinguish between those measures that are
field-wide (or program-wide) and must be applied prior to any construction in the field, and those
measures that are project specific and only apply to certain project facilities or operation.
• Roles of permitting agencies should be clearly defined.
• CSD includes the need for a performance bond. However, there should be additional measures such
as insurance requirements in the event of an oil spill or gas leak.
• Page 2-46, Item d Maintenance. Specify that all measures required to reduce noise, odor, and other
environmental impacts shall be employed during maintenance Also, in case of emergencies please
add: " All reasonable measures shall be taken to protect public safety, health and the environment
during an emergency."
Section 3.0 Potential Future Inglewood Oil Field Development
General Comment — Development Options Discussion
This section discusses only one potential development scenario with specific maximum production values.
Other development scenarios and technologies (such as CO 2 sequestration and injection) should be dis-
cussed or should be eliminated through CSD limiting conditions. Additionally, the production maximums
should be part of a CSD limiting condition, as the findings in this Draft EIR are based on those
production assumptions.
Section 3.1 Potential Future Drilling of New Wells
Page 3-2, Paragraph 1 and sentence 4, Number of Rigs
The peak annual activity of 1190 well days will mean that a minimum of four, not three rigs will be
required to complete the drilling activities (1190/365 ---- 3.26), three drill rigs can only have a maximum of
1095 rig days. This issue also relates to the air quality calculations, which used three drill rigs as a basis,
as noted in a later comment.
What is the maximum depth required for the deeper wells drilled by the larger rig? Please provide details.
Page 3-2, Paragraph 4 and sentence 2, preparation time for drilling pad
The number of days required to prepare a drilling pad (i.e., surface grading) is specified as "seven to 14"
days. This conflicts with the 4-day value used in the air quality calculations (Appendix C, page C-9 assump-
tion 3).|1010|2GBaldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Pages 3-2 and 3-3, Kenai Drill Rigs
The discussion of the use of the much larger Kenai Drill Rigs is not clear. It is unclear if these rigs will in
fact be necessary for the Sentous wells. The air quality calculations have not assumed the use of these
large drill rigs for worst-case daily or annual emissions estimation.
Section 3.6 Potential Future Employees and Scheduling
Page 3-11, 3rd Paragraph
Specify how many contractors per workover-day would be required for the workover rigs. Also, include and
discuss the number of contractors required for the operations.
Page 3-12, 2nd Paragraph
It states, "There also would be an estimated five visitors to the site each day." Table 3.4 shows a total of
11 visitors. Please reconcile.
Page 3-13, Table 3.4 Future Operations Peak Day Employees and Truck Visits
Are the "weekend day shift" and "night shift" personnel in addition to the 200 for the "day shift" and 15 for
the "night shift"? These personnel should be included in the "day shift" and "night shift" count.
Page 3-14, Table 3.5 Future Construction Peak Day Employees and Truck Visits
Table 3-5 lists the construction requirements for a new water treatment plant and steam drive plant. It is
unclear if the foinier is the water treatment plant identified as part of the steam drive facility on page 3-
14, or the water processing facility listed in Table 3.3. Description of what construction actions are being
described in Table 3.5 is necessary. If Table 3.5 is describing the requirements for two of the four
elements listed on page 3-14 for the steam drive facility, then the construction requirements for the other
two elements (gas treatment and water softening plants) should be added to Table 3.5.
Section 3.9.2 Steam Drive — Gas Treatment Plant
Page 3-16, 1st Paragraph
Since the gas would be sent to the existing gas plant for further treatment, provide and discuss details of
processing in the existing gas plant units including the acid gas (H 2S and CO2) removal.
Page 3-16, 4th Paragraph
What is the H2S content in the Vapor Recovery Gas? Provide and discuss the H 2S content. How is the
H2S treated in the scrubber vessel? Discuss the H 2S removal system in detail.
Page 3-16, 5th Paragraph
Based upon the discussion provided, it appears that this gas would not be sold to the Gas Company since it
would either be re-injected into the produced field or used. How is this gas kept separate from the other
gas streams coming into the gas plant that are treated and sent to the Gas Company?
Section 3.9.4 Steam Drive — Water Softening
Page 3-17, 1st Paragraph
Does the produced water quality meet the boiler feedwater specifications?
What does production of 8,000 bbls of steam per day mean? The steam rate is measured in lbs/hr at a
specified pressure.
Section 3.9.5 Steam Drive — Steam Plant
Page 3-17, 2nd Paragraph
Discuss the steam production rate and specify the pressure for the steam.
5Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DFtAFT ENVIRONMENTAL IMPACT REPORT
Section 3.9,7 Steam Drive— Construction Requirements
Page 3-19, Section 3.9.7
This section provides identical information to the discussion in Section 3.8 (Potential Future Construction
Requirements, Page 3-12). Please correct or provide further explanation.
Section 4.0 Analysis of Environmental Issues
While the text provides a discussion of the approach for determining the project baseline, additional detail
and explanation is needed. The text refers to some issue areas where new wells or well deepening was not
included. However, the discussion does not provide sufficient justification for this approach and does not
fully explain why this approach would capture "the full impacts of new well drilling and well redrills." In
addition, while the City understands CEQA guidelines regarding establishing the baseline as the time the
Notice of Preparation is released, there is not sufficient explanation for why the average levels from
2006/2007 were used as baseline and no supporting information was provided to demonstrate that this
time frame provides the most representative data for the oil field. Because the baseline is important for
determining the impacts associated with the adoption of the CSD and future well exploration and
production, the rationale for the baseline must be justified and explained in detail.
Section 4.1 Safety and Risk of Upset
Page 4.1-3, 1st Paragraph
Please clarify the last sentence that states: Nitrogen, sulfur-and oxygen-containing compounds are mostly
nitrogen, sulfur, and oxygen because these compounds are not mostly nitrogen, sulfur, and oxygen.
Page 4.1-3, 3rd Paragraph
Include discussion for Olefins that are one of the major components of the hydrocarbon constituents.
Discuss the "worst case" and historical H 2S contents in the Inglewood Oil Field for the gas as well as the
crude oil.
Discuss public health and toxic hazards of H 2S, including ITIDLH (Immediate Danger to Life and Health),
Emergency Response Planning Guidelines (ERPG) including ERPG-1 (0.1 ppm H2S - odor), ERPG-2 (30
ppn-i H,S - without any serious health effects), ERPG-3 (100 ppm H 2S — life threatening health effects),
and other potential critical effects of H 2S based upon H2S exposure standards and physiological
responses.
Page 4.1-10, Table 4.1.2 Scenarios
There are two different Scenario 9s in Table 4.1.2.
Discuss the second Scenario 9: Release of Crude Oil with spill outside containment. Please note that
Appendix B shows this as Scenario 13. Update the table and description as appropriate.
Page 4.1-15, 1st Paragraph
Provide details of the PXP's maintenance program. Does it qualify as "highest standards of maintenance"?
Page 4.1-18, Table 4.1.4 Second Scenario 9
Appendix B shows this second Scenario 9: Release of Crude Oil with spill outside containment, field
wide as Scenario 13. Update the table and text as appropriate.
Page 4.1-29, Table 4.1.7
On Table 4.1.7, explain the toxic event listed in the table. Was the toxic event for H 2S? If so, please
specify what toxic event occurred.
Page 4.1-30, 2nd Paragraph (Section 4.1.1.4.5)
Figure 4.1-2 (on page 4.1-31) shows the injuries footprint of about 3,200 ft and not 2,900 ft as stated in
the text.|1010|AT.Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Page 4.1-37, last Paragraph (Section 4.1.1.4.6) and Page 4.1-38, Figure 4.1-3
Discuss the risk profile curves provided in Figure 4.1-3. Define the Green, Amber and Red Regions includ-
ing criteria for establishing these regions used by Santa Barbara County and explain why this criteria is used
and how it applies to the project/CSD.
Section 4.1.2 Regulatory Settings
Page 4.1-40
The regulations and standards discussed in this section appear to be "boilerplate" off-the-shelf description of
the standards not specific to the project. Please update this section to include (or identify) the codes,
regulations and standards applicable to this proposed project. For example, the CSD does not include the
pipelines.
Section 4.1.2,4 Other Applicable Guidelines, National Codes and Standards
Page 4.1-53
Update all codes and standards to the current latest edition. For example, the current latest edition for ASME
B31.4 is 2006 and not 1989. Delete reference to the revision date for all codes and standards.
Mitigation Measures
Page 4.1-58
The FIR does not discuss two incidents that occurred during January and February 2006 (releases of a
magnitude to cause verified odor complaints). The odors and emissions from these incidents resulted in
complaints from residents. According to the SCAQMD complaint report, the Los Angeles County Fire
Department, Culver City Fire Department and Los Angeles County Health and Hazardous Materials
Department were onsite to confirm there were no hazards to the community. A third incident occurred on
March 2008 when a crude oil release made its way into the storm drain system. The release was stopped
before it reached Ballona Creek. Los Angeles County Health and Hazardous Materials Department
personnel and the State Department of oil and gas were at the oil field in response to the release. Given
these three known events, the Draft FIR should identify measures that directly address the potential for
odor and emissions from the site.
To effectively reduce impacts due to potential releases or incidents, the County of Los Angeles should
add the following mitigation measures to the CSD and incorporate in the Draft FIR. In addition, there is
no guarantee that the produced gas would remain sweet because the field contains sufficient quantities of
sulfur (the current crude oil is sour with <1% sulfur content) and this produced gas could turn sour in the
future. Therefore, mitigation measures have been identified to require the preparation and approval for a
H 2S contingency plan, I-1 2S detectors, and an odor risk analysis. For recommended Mitigation Measure
R.1-10 see the table of 117S Exposure and Physiological Responses at the end of this letter.
R.1-5 Prior to site plan approval', the County of Los Angeles shall review and approve the operator's plan
for meeting the requirements of the safety elements in the Process Safety Management (PSM)
Criteria of OSHA 1910.119 and CCR Title 8 Section 5189. The gas plant, as identified in the FIR, has
flammable liquids (propane) storage exceeding 10,000 lb triggering these requirements. Since the
oil or gas well drilling and servicing operations are exempted from the PSM requirement, the
safety elements of these regulations should be addressed. They include:
As noted in an earlier comment, the City of Culver City recommends discretionary permits for oil and gas
drilling and exploration projects. This mitigation measure references the site plan approval to coincide with the
current approach in the CSD. However, this reference should be changed to CUP or other discretionary permit,
if a discretionary process is ultimately approved by the County of Los Angeles. As applicable, this comment
applies to all mitigation measures.
7Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
• Process Safety Information
• Process Hazard Analysis
• Operating Procedures
• Training
• Contractors
• Pre-Startup Safety Review
• Mechanical Integrity
• Hot Work Permit
• Management of Change
• Incident Investigation
• Emergency Planning and Response
• Injury and Illnesses Prevention Program
• Employer Participation
R.1-6 The operator shall develop a Safety Inspection Maintenance and Quality Assurance Plan (SIMQAP)
delineating the inspection frequencies, procedures and plans meeting the requirements of governing
codes, standards and regulations. The SIMQAP shall be reviewed and approved by the County of Los
Angeles or its representative prior to issuance of any permits. This SIMQAP document being a dynamic
document should be updated (or revalidated) every two years (or sooner if warranted by significant
facility modifications).
R.1-7 Prior to issuing permits, the County of Los Angeles shall review and approve the operator's plan
for meeting the following requirements:
A. The pressure vessels shall be inspected as per CCR, Title 8, Section 6551 implementing
requirements of API 510, Pressure Vessel Inspection Code.
B. The piping systems shall be inspected as per CCR, Title 8, Section 6533 implementing
requirements of API 570, Piping Inspection Code.
C. The storage tanks shall be inspected as per API 653, Tank inspection, Repair, Alteration and
Recommendation Standard.
D. The Pressure Relieving Devices shall be inspected and maintained as per CCR, Title 8, Section
6552. Based upon the service, the relief valves need to be inspected and calibrated at least
annually.
R.1-8 The County of Los Angeles shall appoint an Oversight Committee consisting of representatives
from affected local and permitting agencies to conduct an annual audit of the Baldwin Hills Oil
Field. The audit will ensure implementation of the inspections delineated in the SIMQAP (Mitigation
Measure R.1-6) and the Safety Element requirements discussed in Mitigation Measure R.1-5. All
the action items generated from the audit shall be documented in a brief report and compliance
dates established to address action items in a timely manner. Follow-up shall also be identified in
the brief report.
R.1-9 Prior to site plan approval, the County of Los Angeles shall require the preparation of a Trans-
portation Risk Management and Prevention Program (TRMPP) to address public safety as it
relates to the transportation of the propane, butane and NGLs. The elements of this TRIMPP shall
include:
• Provisions for conducting biennial comprehensive audits of the carriers to assure satisfactory
records, driver hiring practices, driver training programs, programs to control drug and alcohol
abuse, safety incentive program, satisfactory vehicle inspections and maintenance procedures
and emergency notifications.|1010|3 0Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
• Provisions for allowing only carriers, which receive a satisfactory rating under the above
audit.
• Truck loading procedures and checklist for ensuring that the loading rack operator and the
truck driver both conduct and document in writing, a visual inspection of the truck before
loading and after completing the loading.
• Provisions for requiring shippers to use carriers with vehicle monitoring system for governing
or monitoring vehicle speed.
• Provisions for requiring shippers to use carriers with cellular phones for shipments.
The results of the audit shall be made available to all adjacent and affected agencies including the
City of Culver City and City of Los Angeles.
R.1-10 Prior to site plan approval, the oil field operator shall prepare and receive approval of an H2S
Contingency Plan. The Contingency Plan shall address odor and the potential for increased odor
with future well operations as well as the potential toxic effects if the gas turns sour. The plan
shall identify the existing and potential levels of H,S exposure and the physiological responses
and identify additional measures that can be implemented to further reduce impacts. The plan
shall incorporate monitoring and complaint resolution as required by other mitigation measures.
R.1-11 In order to minimize the hazard (flammable and toxic) release footprints, the H2S detectors and
flammable gas detectors shall be placed throughout the facility in all critical areas prior to
operation. The }LS detectors shall be set to alaim at 10 pprn to warn the operator and
alarm/shutdown at 50 ppm. The shutdown should be cross zoned so that the shutdown occurs
only if two detectors go off to provide protection for the false alarms and shutdowns. Similarly,
the flammable gas detectors shall be set to alarm at 25% LEL and alarm/shutdown at 50% LEL,
again, cross zoned.
R.1-12 Prior to project approval, a detailed odor risk analysis shall be conducted. Hydrogen sulfide is not
the only constituent that could cause odors. The odor causing chemicals in the oil fields are
hydrogen sulfide, other sulfides such as carbon disulfide, mercaptans, benzene, xylene, toluene,
volatile organic compounds, etc. Release scenarios need to be developed that could cause odor
incidents. Probability of the odor incidents occurring based upon the equipment failure rates for
the existing facility and the proposed project needs to be estimated and the incremental increase
needs to be mitigated to the maximum extent feasible.
Page 4.1-61 and Mitigation Measure R.2-1
The 110% containment as identified in the Draft EIR may not be adequate as required by current
regulations. The current NEPA 30 and 40 CFR Part 112 require secondary containment to contain at least
100% of the largest tank volume plus sufficient free board to accommodate precipitation or .fire fighting
water. For example, Santa Barbara County requires 100% volume of the largest tank plus 24-hour, 25-year
rainfall. Table 4.1.10 may also need to be modified to address the adequacy of the secondary containment.
Please delete the phrase "where physically possible" in the mitigation measure. Using this phrase weakens the
measure and does not reduce the impact to the extent possible.
Page 4.1-61, Table 4.1.1.0
Butane+ includes butane and heavier gas liquids; therefore the recommended modification noted in the
table is not required. Please clarify in the table.|10 10|31Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Section 4.2 Air Quality
General Comment Air Quality Calculation and Modeling Files
The information presented in this section is incomplete and no verification of the results can be made. The
following incomplete items need to be fully documented:
• The air quality emission calculation files (URBEMIS) noted in this section should be provided for
review.
• The emission estimation methods regarding the total number of emission sources included and/or
excluded and their assumed emission control assumptions and bases are not discussed. For example,
this discussion should include emissions from drilling gas releases and other events, which based on
available information occur either as a normal part of the well drilling process or otherwise fairly
frequently as evidenced by the three incidents that occurred during January and February 2006
(releases of a magnitude to cause verified odor complaints) and March 2008 (crude oil release that
made it to the storm drain system). It does not appear that these non-permitted fugitive emission
sources have been properly accounted for in the HRA.
• The derivation of the emission factors for the existing and future equipment are not documented (only
the emissions are given); it is not clear if the emission factors used from the SCAQMD Annual
Emission Reporting (AER) forms are facility specific or industry averages that while they may be
sufficient for SCAQMD annual report may not reflect actual emissions at the facility. Additionally, it
is unclear if the emission factors used for the future emission sources will accurately portray the
future emissions from the facility.
• The air quality dispersion input and output files, performed for air quality and public health risk
sections, should be provided for review. The one air dispersion file hardcopy that is attached to
Appendix C is not representative of the modeling methods as described in this section or Section 4.3.
Without a critical review of the emission calculation and dispersion modeling methods and assumptions
the findings of this section cannot be verified.
General Comment SCAQMD Permits
The appendices should include the RECLAIM permit for the facility. Many of the assumptions and findings
are based on the fact that the facility is in the RECLAIM program, but a critical review of all of those
assumptions cannot be made without a copy of the RECLAIM permit.
General Comment — Pollutant Acronyms
Pollutant acronyms need to be made consistent throughout the section and general conventions for the
pollutant acronyms are as follows: NO 2, NOx or NO (but use just one consistently), SO 2, SOx or SO,,
(but use just one consistently), PM 10, and PM2.5. Subscripts should be used for chemical names but not
for PM10 and PM2.5.
Section 4.2.1 Environmental Setting
Page 4.2-1
Propose the following corrections/clarifications:
... (referred to hereafter as SCAOMD or the district)... South Coast Air Basin (referred to hereafter as the
Basin)..
Section 4.2.1.1 Meteorological Conditions
Page 4.2-1, paragraph 1, 1st sentence
The term "sparse", a synonym of meager, is not the best term to describe the winter precipitation in
Southern California. Please provide a better description of the winter precipitation in Southern California.
10Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Section 4.2.1.4 Existing Air Quality
Page 4.2-2, next-to-last line
There are only 32 monitoring stations in the Basin, not 34, two of the 34 SCAQMD monitoring stations
are outside of the Basin.2
Page 4.2-2, last line
A critical review indicates the West Los Angeles Monitoring Station is located closer to 3 to 3.2 miles
north of the Inglewood Field as opposed to 2.5 miles north.
Page 4.2-4, Table 4.2.2
Several AAQS are incorrect in the table. 3 The following corrections need to be made:
1. State 1-hour NO2 standard is 0.18 ppm
2. State has annual NO 2 standard of 0.03 ppm
3. Federal PM 10 annual standard was revoked and should be removed from the table.
Pages 4.2-2 and 4.2-3 and Table 4.23, Page 4.2-5 (ambient monitoring station)
On pages 4.2-2 and 4.2-3 it notes that Table 4.2.3 is based on SCAQMD monitoring station located north
of the site (Northwest Coastal LA County station); however, Table 4.2.3 notes that the data is from the
Southwest Coastal LA County station. The source of the data needs to be clarified and the incorrect
notation fixed.
Additionally, a case for the representativeness of the station used versus using the Source Receptor Area 1
station in Los Angeles needs to be made. It is noted later in the section that the site is partially within
Source Receptor Areas 1 and 3, so some analysis of which monitoring station is most appropriate for the
site should be included in the text, particularly if a monitoring station from an SRA (as SRA 2 is claimed
to be used in Table 4.2.3) away from the site location is used.
Section 4.2.1.5 Inglewood Oil Field Criteria Pollutant Emissions
Page 4.2-9, paragraph 1, sentence 1
It is noted that Table 4.2.4 shows two years of AER data (2004/5 and 2005/6); however the table only
shows one year (2005/6).
Page 4.2-10, Tables 4.2.4 — Well Drilling as Operating Emission Source
Table 4.2.4 categorizes well drilling as an operating emission source. While well workovers would appear
to be an operating activity as a maintenance operation for existing wells, new well drilling would
certainly seem to be better classified as a construction activity. Also, the AERs for the site do not include
well drilling operations, which further support the case that these emissions are not considered onsite
operating emissions. Therefore, the well drilling emissions, unless they can be clearly established by
appropriate references (such as SCAQMD letter) to be an operating activity should be moved into the
construction emissions baseline and the construction emissions impact discussion.
Page 4.2-10, Tables 4.2.4 — Drill Rig and Workover Rig Emissions Estimate
The drill rig emission estimate, as shown in Appendix C, does not seem to conform to the drill rig spe-
cifications given in Appendix A. These emissions should be corrected to use the proper horsepower and
equipment types listed in Appendix A for the Caza 516 and Kenai drill rigs. Other comments on this topic
will be made for Table 4.2.10 and Appendix C.
The workover rig horsepower estimate (200 hp) seems low compared with online data for workover rigs
that shows horsepower ranging from 250 to 500.|1010|SCAQMD monitoring stations are provided here http://www.aqmd.govismog/AQSCR2007/aq07card.pdf.|1010|Current ambient air quality standards can be found here: http://www.arb.ca.goviresearch/aaqs/aaqs2.pdf.
11
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COMMENTS ON THE PUBLIC DRAM" ENVIRONMENTAL IMPACT REPORT
Page 4.2-10, Tables 4.2.4 and 4.2.5 — Representativeness of Baseline Emissions
Additional discussion of the representativeness of the baseline emissions presented in these two tables
needs to be made. Additional years of emissions data need to be presented to ensure that the baseline
emissions are not being overstated. A review of AER data indicates that there was considerable emission
variability from AER year 2002 to AER year 2006. Additionally, a review of Figure 2-8 shows that the
well drilling in 2006 was the highest of any of the past 40 years. Therefore, it would appear that the
baseline emissions presented are not representative of average conditions at the site.
Additionally, correspondence with SCAQMD staff counsel indicates that their current policy for estab-
lishing baseline for RECLAIM facilities is to use the highest two emission years of the past five years for
RECLAIM pollutants, in this case NOx, and to use permitted emissions for non-RECLAIM pollutants if it
can be established that the facility has emitted at the permitted levels, and if not, then use the highest two
years of the past five years for the non-RECLAIM pollutants.
Correcting to appropriate baseline emissions would almost certainly show that the future increase in
pollutant emissions from the site are significant per SCAQMD regional emission thresholds.
Page 4.2-10, Table 4.2.5
The table notes that the well pad grading is assumed to take 4 days, while Section 3.1 page 3-2 indicates a
duration of 7 to 14 days for well pad preparation. This discrepancy needs to be corrected.
Section 4.2.1.6 Inglewood Oil Field Odor Emissions
Page 4.2-12, Paragraph 3 and 4, Leak Detection Inspection and Maintenance Plan
The facilities' Leak Detection Inspection and Maintenance Plan should be discussed, including the fre-
quency of inspection for different components.
Page 4.2-13, Paragraph 6, Meteorological Data Discussion
The specific meteorological data source should be provided, and the representativeness of that versus
other nearby meteorological data sources should be discussed.
Section 4.2.2 Regulatory Setting
Page 4.2-16, Paragraph 2, Ozone and CO Attainment Classification
It should be noted in this paragraph that the SCAQMD has requested that it be reclassified as an extreme
ozone nonattainment area. Additionally, this paragraph should be corrected to note that CO was redesi-
gnated as attainment in 2007.
Page 4.2-16, Paragraph 3, Management Plan Discussion
The SCAQMD AQMP includes PM10 as well as ozone and PM2.5 that are discussed in this paragraph.
This paragraph should make some mention of the PM 10 control strategy.
Pages 4.2-16 and 4.2 -17, Portable Equipment Registry — Drill Rig Discussion
Some discussion of the drill rigs used onsite in regards to their having local permits or being part of the
CARE Portable Equipment registration should be mentioned. It is unclear if the drill rigs used on site are
contract rigs or are site-owned rigs with SCAQMD permits or registered with CARE.
Page 4.2-17, Local Authority, SCAQMD Rule and Regulations
A discussion of the applicable SCAQIVID rules and regulations, and the project's compliance with these
rules and regulations, should be provided in this section. The Draft EIR does not provide this critical
information.
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COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Section 4.2.3 Significance Criteria
Page 4.2-17, Table 4.2.8, Localized Significance Thresholds
The localized significance thresholds were recently updated by SCAQMD. 4 These updates include sig-
nificant reductions for the NOx LSTs in SRA 1 and 3. These revised LST values should now be used.
Page 4.2-19, paragraph 2, RECLAIM Baseline
This discussion indicated that the RECLAIM allocation should be used for baseline. However, this is not
the current SCAQMD policy. A recent lawsuit, that is still not completely resolved and is now at the
California Supreme Court, has changed SCAQMD's policy on establishing RECLAIM facility baseline
for CEQA purposes. According to SCAQMD's Principal Deputy District Counsel, Ms. Barbara Baird, the
District's current policy is to use the highest two of the past five years for RECLAIM pollutants, in this
case NOx, and to use permitted emissions for non-RECLAIM pollutants if it can be established that the
facility has emitted at the permitted levels, and if not, then to use the highest two years of the past five
years for the non-RECLAIM pollutants.
Also, an apparent error is the inclusion of the well drilling emissions in the RECLAIM allocation, without
any substantiation that well drilling emissions are subject to RECLAIM, or considered operating emissions
by SCAQMD. In fact, based on the AER emission data, and the RECLAIM allocation noted on page
4.2-20, well drilling emissions would not appear to be included in RECLAIM and are not part of the site's
RECLAIM allocation. Therefore, the baseline and future emissions needs to be revised to the current
SCAQMD policy, and doing so would almost certainly show that the future increase in pollutant emis-
sions from the site are significant per SCAQMD regional emission thresholds.
Section 4.2.4.1 Potential Construction
Page 4.2-21, Table 4.2.9, LST Emissions
Table 4.2.9 needs to clearly separate the onsite and offsite emissions for LST comparison. LST analysis
only includes onsite emissions.
Page 4.2-21, Table 4.2.9, SCAQMD Localized Significance Thresholds
The localized significance thresholds used in Table 4.2.9 are based on a construction site size of 1 acre
and a distance to receptor of 200 meters. There is no discussion of how this distance to receptor was
developed. The site is essentially adjacent to a number of residential communities, so a description of how
construction will be limited to no closer than 200 meters to any residence, such as by mitigation measure,
needs to be addressed. If construction were to occur as close as 50 to 100 meters to a residence then the
LSTs for PM10 and PM2.5 would be exceeded and there would be significant localized emission impacts.
It should be noted that the distance to receptor assumed in Section 4.3, particularly in terms of Mitigation
Measure PH.2-1, only requires a drill rig to be 400 feet from a receptor.
Page 4.2-22, Significance Determination
The significance determination made is based on implementation of Mitigation Measures AQ.1-1 and
AQ.1-2. However, Mitigation Measure AQ.1-1 is not implemented in the proposed CSD. Additionally,
considering other issues regarding construction emission estimates as identified in this comment letter,
the construction emissions would be above SCAQMD thresholds. Therefore, the finding of less than
significant impacts cannot be made even with the identified mitigation measures. Construction emission
impacts would be significant.
Page 4.2-22, Mitigation Measure AQ.1-2
Compliance with SCAQMD Rule 403 is not a mitigation measure, and this opinion is shared by
SCAQMD. However, if Mitigation Measure AQ.1-2 is maintained as a mitigation measure then the
specific activities noted should be at least as stringent as the measures noted in Rule 403. For example, it|1010|SCAQMD approved LST values can be found here: http://www.aqmd.goviceqa/handbook/LST/appCpdf.
13Baldwin Hills Community Standards District
COMMENTS ON THE PUBIIC DRAFT ENVIRONMENTAL IMPACT REPORT
is noted that the maximum speed on unpaved roads should be 25 miles per hour, while the Rule 403
measure is a maximum of 15 miles per hour. Therefore, if this mitigation measure is retained all of the
bullet items should be checked against Rule 403 measures and corrected as necessary.
Additionally, control measures as applicable from the SCAQMD CEQA website tables XI-A through
XI-E (http://www.aqmd.goviceqa/handbook/mitigation/fugitive/MM Jugitive.html) should be added to
the mitigation measure or noted to be required as applicable in the fugitive dust control plan.
Page 4.2-22, Mitigation Measures — Off-road Equipment Standards
For compliance with the SIP a mitigation measure should be added requiring diesel-fueled construction
equipment to meet or exceed CARB/USEPA Tier 2 emission standards. This would be similar to the Miti-
gation Measure AQ.2-4 proposed for the drill rigs.
Section 4.2.4.2 Potential Operations Criteria Emissions
Page 4.2-24, Paragraph 6, Workover Rigs
For clarity it should be stated that the maximum number of concurrent workover rigs increases from one
for the baseline to two for potential development.
Pages 4.2-24 and 4.2-25, Maximum Drill Rig Assumption
As noted in a comment for Section 3.0, the maximum number of drill rig days of 1190 ensures that at
least four drill rigs would have to be used at a time for periods of the year. Considering the maximum
number of annual wells proposed (85) is approximately 300 percent greater than the recent average number
of wells (2000 to 2007) and 75 percent greater than the recent peak well drilling activity that was used to
establish the baseline maximum daily number rigs at three, it is likely that the future peak would be as
high as or higher than 5 or 6 rigs per day. This means that the assumption of no increase from the baseline
maximum of 3 drill rigs is incorrect. Therefore, there would be incremental drill rig emissions, unless a
drill rig limiting mitigation measure were proposed and implemented in the CSD, which needs to be
identified in the emission calculation in Appendix C and presented in Table 4.2-10. However, as noted in
earlier comments it appears that the drill rig emissions belong with construction rather than operation.
Page 4.2-25, Table 4.2-10, LST Emissions
Table 4.2-10 needs to clearly separate the onsite and offsite emissions for LST comparison. LST analysis
only includes onsite emissions.
Page 4.2-25, Table 4.2-10, Offset Requirements
Table 4.2-10 should clearly show the SCAQMD operating baseline, which would not be the same as the
baseline shown in Table 4.2.4, and the amount of emissions that would require offsets, including RECLAIM
credits, under SCAQMD rules. This is important as the significance findings identify offsets as the means to
lowering the regional emissions below the significance thresholds. However, it has not been established
how much of the daily regional emission increase will actually require offsets. For example, well
workover and well drilling (if not moved to construction) would not require offsets under SCAQMD
rules.
Page 4.2-26, Paragraph 2, PM10/PM2.5 Modeling Results
The significance assumption is based on modeling results that were not provided for review. Therefore,
the findings for localized PM10 and PM2.5 impacts cannot be confirmed.
Page 4.2-26, Mitigation Measure AQ.2-1
The offset and RECLAIM requirement is a regulatory requirement and as such is not a mitigation
measure.
1.4
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COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Page 4.2-26, Mitigation Measure AQ.2-4
Electrification of drill rig engines, both workover rigs and new well rigs, should be considered as a
mitigation measure to eliminate the very high NOx emissions that are forecast to occur from well drilling,
and the toxic diesel particulate emissions from the drill rig engines.
Page 4.2-26, Mitigation Measures — Operating Limits
Operating limits, including well drilling limits, should be established in the mitigation measures to ensure
that the actual future emissions do not exceed those evaluated in the Draft EIR.
Page 4.2-27, Residual Impacts — NOx Significance Finding Unconfirmed
The significance assumption for NOx has not clearly been demonstrated through an emission accounting
that the mitigated NOx emission will in fact be below the regional or localized significance thresholds.
Page 4.2-27, Residual Impacts — VOC Significance Finding Missing
While the first paragraph on Page 4.2-26 notes that the emission increase for VOC would be significant,
there is no later discussion of VOC, such as there is for NOx, under residual impacts. Therefore, the Class
II impact as shown on the top of Page 4.2-26 has not been established for VOC.
Section 4.2.4.3 Potential Operations Odor Emissions
Page 4.2-28, Residual Impacts — Significance Finding
The significance finding of less than significant after mitigation has not been established. In fact, the mod-
eling has clearly shown odor impacts and the description in this section only notes that the mitigation
"would reduce the frequency of odor events." A reduced frequency of odor impacts is not sufficient for the
finding of less than significant; therefore odor impacts would remain significant.
This finding is particularly troublesome given the number of odor complaints that have occurred from this
facility, including major odor release incidents in January and February 2006, and the significant crude oil
release that occurred on March 22, 2008.
Page 4.2-28, Drilling H 2S Mitigation Measure
In order to mitigate significant odor impacts from well drilling, H 2S emissions should be monitored in the
air space immediately downwind of the drilling location, with a warning sounding at 0.1 ppm and
shutdown of drilling operations at 1.0 ppm. This shutdown value should help protect the public from
significant odor impacts.
Page 4.2-28, Odor Complaint Resolution Mitigation Measure
A protocol for handling odor complaints should be added to the mitigation measures. The protocol should
include: conducting odor surveys in the affected communities after a compliant, keeping a log of the char-
acteristic of the odors in each compliant and during the survey, and an identification of the odor source if
one can be made. Additionally, odor complaint contact information should be provided on fence line
signs.
Page 4.2-28, Odor Impact Minimization Plan
An Odor Impact Minimization Plan is required by California Integrated Waste Management for any
facility or operation that handles or processes compostable material. The bioremediation farm may or may
not be subject to this regulation. More information on this new regulation can be found at littp://www.
ciwmb.ca.gov/regulationsrfitle14/ch31.htm#article3 or refer to 14CCR Section 17863.4. The applicability and
compliance demonstration with this regulation should be discussed and then implemented as necessary
for the site.
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COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Section 4.2.5 Analysis of Proposed CSD
General Comment - Significance Findings
As noted in previous comments we agree with the contention of this section that the air quality mitigation
measures recommended in this section, with exceptions and additions noted in other comments, should be
included in the CSD. We also note that the significance findings in this section must be revised accordingly
if the air quality mitigation measures are not included in the CSD, as then there would be no way to
guarantee that they would be implemented.
Section 4.2.6 Cumulative Analysis of Proposed CSD
General Comment — Depth of Analysis for Construction Impacts
The cumulative analysis does not appear complete as there is no identification that there would likely be
concurrent construction and operating emission increases. The fact that the known cumulative project list
does not extend far enough in the future to show projects that would be concurrent with onsite con-
struction is not a valid argument. Additionally, it seems likely that well drilling (which as noted earlier
should be considered a construction activity) will resume earlier than the new onsite facilities construction
with its additional requirements for well pad construction. Therefore, there is the potential for con-
struction cumulative impacts.
Page 4.2-31., line 7— Attainment Date
The attainment date of 2010 should be revised to at least 2020 based on realistic projections for PM and
ozone attainment.
Section 4.2.7.1 Background
Page 4.2-34 Table 4.2-12
Please explain the significance of 20-year, 100-year and 500-year Global Warming Potential (GWP). For
example, if the life of methane in the atmosphere is 12 years then what is the implication of 20-, 100-, and
500-year GWP?
Page 4.2-35, 2nd paragraph, Calculation of Greenhouses Gases —Indirect Emissions
For this project indirect emissions should include CO 2 emission from the produced petroleum products.
Page 4.2-35, end of page, Calculation of Greenhouse Gases — Greenhouse Gases from Electricity
It should be noted that California regulations such as SB 1368 and utility renewable energy requirements
will further reduce the CO 2-eq emissions from electricity.
Page 4.2-36 Table 4.2-13
Define Non-renewables, Renewables and Non-hydro Renewables.
Section 4.2.7.2 Affected Environment
Page 4.2-40, Section 4.2.7.2 Last Paragraph
Table 4.2.14 shows 82,951 tons/yr that is different than 80,429 tons/yr stated in the paragraph. Please
reconcile.
Page 4.2-41, Table 4.2-14, Indirect Emissions
For this project indirect emissions shown in the table should include CO, emission from the produced
petroleum products.
Page 4.2-41, Table 4.2-14, Construction Emissions
Construction GI-IG emissions should be included in this table.
Page 4.2-44, Section 4.2.7.4, 3rd Paragraph
Delete reference to CPF (Carpinteria Facility). Ensure that the discussion is relevant to the proposed site.
16Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Section 4.2.7.3 Regulatory Setting
Page 4.2-43, California Senate Bill 1368
The description here is dated and should be updated as regulations per 1368 have been approved.
Section 4.2.7.4 Potential Future Development Contribution to Greenhouse Gas Emissions
Page 4.2-44, 2nd paragraph, Construction Emissions
The description of construction emissions being short-term is not correct for this site. Construction
emissions will occur throughout most of the life of the site, including well pad grading, and as previously
commented new well drilling should be considered a construction activity.
Page 4.2-45, Table 4.2-15, Indirect Emissions
For this project indirect emissions shown in the table, and not just described below the table, should
include CO, emission from the produced petroleum products.
Page 4.2-45, Table 4.2-15, Construction Emissions
Construction GHG emissions should be included in this table.
Page 4.2-47, Potential Greenhouse Gas Emissions Mitigation Measures
Mitigation measures such as CO 2 injection, in supplement to or in place of steam injection should be
included as a potential mitigation measure. Combined CO 2 sequestration/steam generation/power tech-
nologies such as the proposed Kirnberlina project should be included in the discussion (see http://www.
cleanenergysysterns.com/kimberlina.html).
Use of onsite renewable energy such as photovoltaics should also be discussed.
Page 4.2-48, bottom of page — SB 1368 Discussion
This discussion is not quite correct. First, the 1,100 lb CO 2/MWh value is a requirement for new base load
long-term contracts to utilities, and second describing this value as comparable to a combined cycle unit is
not correct as a combined cycle unit should have GHG emission below 1,000 lbs/CO2/MW1i.
Page 4.2-49, Section 4.2.7.4 Green House Gases (GHG)
The impact should be changed as the project would produce higher greenhouse gas emissions and con-
tribute to climate change (Significant, Class I). Other similar oil and gas development projects have been
classified as Class I for GHG. The County of Los Angeles should require PXP to implement a program to
reduce GHG emissions for project components and/or community sources to achieve a net zero increase
in emissions from the project.
Additional Comments on Mitigation Measures
Please make the following revisions to the air quality mitigation measures:
AQ.2-2: Specify timing of installation of cogeneration-type system.
AQ.3-1: Specify alternative flare options if portable flares at subject wells contribute to exceeding the 5
dBA noise threshold.
AQ-3.2: Specify timing of installation of detection system.
AQ.3-3: Specify frequency of visual inspections. Also, include any vapor measurement tools that could be
used in addition to visual inspections.
AQ.3-4: Specify threshold for odor suppressant (i.e., what extent odor is to be reduced).
AQ3-6: Specify timing of installation of meteorological station.
Section 4.3 Public Health Risks
General Comment — Original AB2588 Health Risk Assessment
It is unclear if an original AB2588 health risk assessment was performed for this site sometime in the
1990's. If such a risk assessment were performed the results of that risk assessment should be presented, or
17Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
an indication that the facility was not required to complete an AB2588 risk assessment should be included
with reasons given, as the facility certainly would have had emissions high enough to trigger an AB2588
emission estimate to start the process towards requiring a risk assessment.
General Comment — Health Risk Analysis
The information presented for the health risk analysis (HRA) is incomplete and no verification of the
results can be made. To confirm that the BRA was completed properly and that it truly reflects a con-
servative estimate of the current and future risks to the community from the facility the following incom-
plete items need to be documented fully:
• The emission estimation methods regarding the total number of emission sources included and/or
excluded in the FIRA and their assumed emission control bases are not discussed. For example, the
discussion should include emissions from drilling gas releases and other such events, which based on
available information occur either as a normal part of the well drilling process or otherwise fairly
frequently as evidenced by the three incidents that occurred during January and February 2006
(releases of a magnitude to cause verified odor complaints) and March 2008 (crude oil release that
made it to the storm drain system). It does not appear that these non-permitted fugitive emission
sources have been properly accounted for in the HRA.
• The derivation of the emission factors for the existing and future equipment are not documented (only
the emissions are given); it is not clear if the toxic air contaminate (TAC) emission factors used from
the SCAQMD Annual Emission Reporting (AER) forms are facility specific or industry averages that
while they may be sufficient for SCAQMD annual reports may not reflect actual emissions at the
facility. Additionally, it is unclear if the emission factors used for the future emission sources will
accurately portray the emissions from the facility.
• While some soil gas measurements were performed to determine emissions from gas seeps and well
leaks, the regulatory acceptance of the methods and concurrence with the results and findings were
not provided. Additionally, there was not a clear demonstration of why these current sampling results, if
valid, should be used for all future activities, including the substantial increase in idled/abandoned
wells that will occur with the increased potential of leakage.
• The modeling methodology description is incomplete and the findings and results of the modeling
cannot be independently verified with the information presented in the Draft EIR.
• There is no third party (SCAQMD, ARB, OEHIJA) acceptance noted for the BRA modeling methods
and findings. Without proper third party review the results of the HRA cannot be verified and should
not be used for any regulatory purpose, such as CEQA significance determination.
• There is no description of the specific source modeling assumptions, other than a note that the
"sources... were addressed primarily as area sources."
• The modeling input/output files are necessary to review the adequacy of the modeling methods.
Section 4.3.1 Environmental Setting
Page 4.3-1
Propose the following corrections/clarifications:
...(referred to hereafter as SCAQMD or the district)...South Coast Air Basin (referred to hereafter as the
Basin)..
Section 4.3.1.3 Inglewood Oil Field Toxic Emissions
General Comment — Toxic Emission Factors — Baseline Emissions
The air toxic emission factors are not detailed and cannot be confirmed to be valid. The source of the
emission factors, the representativeness of the emission factors for the site, and the general acceptance of
the emission factors by responsible air quality agencies must be provided.
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General Comment - Baseline Operational Emissions
The emission estimate comments provided for Section 4.2 would also apply for the Toxic Air Contami-
nant emission estimation. These include comments related to proper establishment of baseline emissions
and issues related to construction and well drilling emissions estimates.
Page 4.3-7, Table 4.3.2, Baseline Operational Emissions
It is unclear if the operational emissions presented in Table 4.3.2 reflect a long term average for the oil
field that has been operating for over 70 years. Considering the implementation of air quality require-
ments over the past two decades the local historic risk may be much higher than that indicated using
current emissions. A discussion of past emissions from the site, and the locations of potential long-term
populations (i.e., older neighborhoods and houses) should be evaluated to determine worst-case health
risks from the past, current, and future use of the site.
Section 4.3.1.4 Inglewood Oil Field Baseline Health Risk Assessment
Page 4.3-8, paragraph 3, Health Risk Modeling Description
The modeling methodology description is incomplete and the findings and results of the modeling cannot
be independently verified with the information presented in the Draft EIR. The specific source
assumptions, more than a simple note that the "sources... were addressed primarily as area sources" is
needed. The specific source inputs or copies of the input/output files are needed to review the adequacy of
the modeling methods.
Page 4.3-10, paragraph 5, Risk Percentages
It would seem a better comparison if the site risk were compared to the 600 to 800 excess cancer risk cases
noted for the site area on page 4.3-3. This comment also applies to Section 4.3.6, page 4.3-26, paragraph 3.
Section 4.3.2.1 Federal
Page 4.3-13
A description of the federal hazardous air pollutant (HAPs) regulations, such as MACT and NESHAPS,
should be included.
Section 4.3.2.2 State
Page 4.3-14, 1st paragraph, AB2588 Implementation
This paragraph describes the AB2588 regulation and notes that SCAQMD will ensure implementation.
However, this is a mature regulation and implementation should have already occurred. A description of
how this regulation was implemented for this facility should be provided here. Also, this paragraph
should note that ITSC 44300 is also known as the AB2588 Air Toxics Hot Spots and Assessment Act.
This will allow readers to bridge the earlier discussion of AB2588 in Section 4.3.1.2.
Section 4.3.2.3 Regional
Page 4.3-14, 1st paragraph, SCAQMD AB2588 Implementation
This paragraph does not correctly portray how SCAQMD implemented AB2588 and should be revised.
For example, SCAQMD Rule 1402 implements AB2588 as is noted on page 4.3-15.
Section 4.3.3 Significance Criteria/Section 4.3A.3 Toxic Air Contaminant Emissions from Future
Construction/Operations
General Comments — Minimal Risk Levels (MRLs)
The use of MRLs determined by the Agency for Toxic Substances and Disease Registry should be con-
sidered for determination of minimal acute and chronic risk for various substances, such as FLS (with a
chronic risk level of 0.001 ppm) and Benzene (with a chronic risk level of 0.003 ppm) to determine whether
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the project will have adverse impacts to the local community. The MRLs can be found at http://
vvww.atsdr.cdc. gov/rmis/.
Page 4.3-16, 1st bullet, Cancer Risk Threshold/ Table 4.3.6, page 4.3-21
The significance criteria established on page 4.3-16 is based on whether a facility has Best Available
Control Technology for Toxics (17BACT) or not, with a ten-fold increase in the risk allowed if TBACT is
in place. Table 4.3.6 uses this higher risk value as the significance criteria, but nowhere in this section is it
established that all of the emission sources at this facility in fact have TBACT. It can be assumed that new
sources would likely be required to have TBACT but the facility is over 80 years old, so there is no
guarantee that all of the older equipment has TBACT. A discussion of the applicability of the higher
significance criteria and status of TBACT for all equipment needs to be included. Otherwise the lower
risk threshold would need to be applied which would cause the health risk impacts to be reclassified as
significant using the given significance thresholds.
Section 4.3.4.3 Toxic Air Contaminant Emissions from Future Construction/Operations
General Comment — Toxic Emission Factors — Baseline Emissions
The air toxic emission factors are not detailed and cannot be confirmed to be valid. The source of the
emission factors, the representativeness of the emission factors for the site, the representativeness of the
emission factors for the future operation in particular, and the general acceptance of the emission factors
by responsible air quality agencies must be provided.
Page 4.3-19 Table 4.3.5, Stipulate to Urea as Future Source of SCR Ammonia
A mitigation measure should be added to specify the noted use of urea (page 4.2-24) as the source of
ammonia in the SCR controls for the future heaters/steam generators. This eliminates the potential risk
from ammonia spills that are not analyzed in this document.
Page 4.3-22, Mitigation Measure P11.1-1
The applicability of Mitigation Measure PH.1-1 is unclear and the emission reductions desired could be
achieved through other means, such as the use of Tier 4 engines when they are available or the use of
alternatively fueled engines or electric motors hooked to the grid. This mitigation measure should clearly
specify whether it applies to workover drill rigs as well as new well drill rigs. This mitigation measure
should also note that alternative means to obtaining the desired emission reduction, other than heavy duty
diesel catalysts (i.e., equivalent technologies or emitting engines) are acceptable. A performance standard
for the emissions might be a better approach for this mitigation measure.
Also, the emission reductions of this measure should be reflected in the air quality section, assuming that
the measure is incorporated in the CSD.
Page 4.3-22, Residual Impact and Impact Determination
The significance determination made is based on implementation of Mitigation Measure PH.1-1. How-
ever, this mitigation measure is not implemented in the proposed CSD. Additionally, issues identified
with the toxic emission analysis have not been resolved. Therefore, the finding of less than significant
impacts cannot be made even with the identified mitigation measures. Public health impacts would be
significant.
Page 4.3-24, paragraph 2
The air quality section uses 200 meters as the distance to a receptor for the LST threshold comparison, so
it is inconsistent to note here that the emissions only need to be more than 400 feet (122 meters) from a
receptor.
Page 4.3-25, Residual Impact and Impact Determination
The significance determination made is based on implementation of Mitigation Measure PH.2-1. How-
ever, this mitigation measure is not fully implemented in the proposed CSD. Additionally, issues identi-
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fled with the toxic emission analysis have not been resolved. Therefore, the finding of less than signifi-
cant impacts cannot be made even with the identified mitigation measures. Public health impacts would
be significant.
Section 4.3.5 Analysis of Proposed CSD
General Comment - Significance Findings
As noted in previous comments we agree with the contention of this section that the air quality mitigation
measures recommended in this section, with exceptions and additions noted in other comments, should be
included in the CSD. We also note that the significance findings in this section must be revised
accordingly if the air quality mitigation measures are not included in the CSD and if the specific issues
identified in other comments are not addressed, as then there would be no way to guarantee that the
measures adequately mitigate impacts.
Section 4.3.6 Cumulative Analysis of Proposed CSD
General Comment — Depth of Analysis for Construction Impacts
The cumulative analysis does not appear complete as there is no identification that there would likely be
concurrent construction and operating emission increases. The fact that the known cumulative project list
does not extend far enough in the future to show projects that would be concurrent with onsite con-
struction is not a valid argument. Additionally, it seems likely that well drilling (which has been com-
mented should be considered a construction activity) will resume earlier than the new onsite facilities
construction with its additional requirements for well pad construction. Therefore, there is the potential
for construction cumulative impacts.
Appendix C Air Emission Calculations
General Comment Baseline Year Basis
The baseline year basis is confusing as presented. The basis of 2006 or 2007 is not clear, is not consistent,
and the tables often note both years but only present one year. Additionally, as noted in previous comments
on Section 4.2, the baseline emissions should be properly established based on currently approved
SCAQMD guidelines (highest two years of the past five years).
Page C-1, Table A — Missing Information
This table provides rows for SCAQMD operational thresholds and for impact determination, but they are
blank. They should be completed or deleted.
Page C-1, Table A — Drilling Emissions (construction activity not operation)
As commented on in Section 4.2, drilling emissions would logically seem to be a construction emission
source rather than an operation emission source. Certainly the drilling emissions are not included as
operating emissions in the SCAQMD AER and do not appear to be part of the site's RECLAIM permit.
Page C-6 — Well Workover Rig HP and Number Consistency
The horsepower assumed for the well workover rig (200) seems low in comparison to available on-line
infoiiiiation on well workover rigs that seem to vary from 250 to 500 for onshore work. Additionally, the
number of rigs in this table is 4, while the number of rigs noted in the AQ section (page 4.2-9, bottom of
page) was 6. It appears that the emission estimates need to be revised based on the number of rigs and
potentially the horsepower of the rigs.
Page C-6 — Off-Highway Truck HP Inconsistency
The horsepower for the off-highway truck is noted as 200 in the table and 250 in the footnotes below the
table. This inconsistency should be resolved.
21.
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Page C-9 - Wellpad Grading Duration Conflict
The assumption of 4 days to grade a well pad, as noted in table footnote 3, appear to be in conflict with
Section 3.0 that indicates 7 to 14 days to prepare a well pad. This inconsistency should be resolved.
Page C-10 - Emission Factor Calculations - SCAQMD Reference
It is unclear if the SCAQMD CEQA document reference is the 1993 CEQA Handbook or the currently
available calculation on the SCAQMD website. The 1993 CEQA Handbook is now generally dated and
should be replaced with their website resources or updated USEPA fugitive dust emission calculation
procedures where available and appropriate.
Page C-10 - Assumed Silt Content Conflict
The surface silt loading in percent is noted to be 24 percent and later the silt content of the soil is noted to
be 1.5 (no units given). These two assumptions appear to be inconsistent, and this needs to be resolved.
Page C-11 and C-26 - Well Drilling Horsepower Assumptions
The well drilling horsepower assumptions are significantly different, much less, than the drill rig infor-
mation given in Appendix A. The rig engines horsepower assumed is 1,365, while the Caza 516 rig is
shown to have approximately 3,300 hp of engines and the Kenai rig is shown to have 4,485 hp. Therefore,
it appears that the well drilling emissions (baseline and future) may be significantly underestimated. Also,
the emissions are stated to be based on actual engine certifications that have not been provided. The
discrepancy between Section 3.0/Appendix A and Appendix C must be resolved.
Page C-21- Well Workover Rig HP and Number Consistency
As noted in comments for the table on page C-6, the horsepower assumed for the well workover rig (200)
seems low in comparison to available information on well workover rigs that seem to vary from 250 to
500 for onshore work. Additionally, the number of rigs in this table is 8, which is an assumption of two
times the baseline rigs. However, the number of baseline rigs noted in the AQ section (page 4.2-9, bottom
of page) was 6, not 4, so the number of future rigs should be 12, not 8. It appears that the emission
estimates need to be revised based on the number of rigs and potentially the horsepower of the rigs.
Appendix D — Toxic Air Contaminant Emission and Health Risk
Assessment Results
Please note that the bulk of the comments on the Toxic Air Contaminant emission estimate and Health
Risk Assessment are provided in the Section 4.3 comments.
General Comment — Maximum Risk Location Presentation
All of the maximum risk locations are noted to be boundary receptors. It is not clear if these boundary
receptors are also locations with adjacent residential areas. This table should clearly present the location
of the maximum residential impacts.
Section 4.4 Geological Resources
Section 4.4.1.6 Subsidence and Fault Activation
Page 4.4-11, Paragraph 5, Sentence 1/ Page 4.4-21, Paragraph 4, Sentence 1
Seismicity associated with injection (water or steam)
Provide reference for statement that "no evidence that waterflooding operations have activated earth-
quakes in the Baldwin Hills." Is there evidence of microseismicity (in contrast to major earthquakes)
related to water or steam injection in Inglewood oil field or other nearby Newport-Inglewood fields?
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Section 4.4.1.7 Gas Seeps
Page 4.4-14, Paragraph 4, Pathway for leakage of gas includes ongoing corrosion of steel well casing
and deterioration of cement seals
There is no discussion of the potential for increased gas migration along man-made and natural conduits
due to increased injection (pressure, volume, and rate) of water and steam for secondary recovery.
Section 4.4.4 Analysis of Potential Future Oil Field Development (Impacts)
Page 4.4-18, Paragraph 2, last sentence
There is no reference or analysis to support the statement that "0.5g earthquake could reasonably result in
6 inches of downslope movement" Provide reference, analysis, or other evidence to support this
statement.
Page 4.4-19, Mitigation Measure GR.1-1
The mitigation measure should include a reference to the professional qualifications, California Certified
Engineering Geologist and Geotechnical Engineer, required to conduct the investigation and prepare the
reports.
Page 4.4-19, Impact GR.2
The impact statement should include "uplift or mounding" as another result of secondary oil recovery
activities (see page 4.4-20).
Page 4.4-22, Mitigation Measure GR.2-1
The measure should clearly state that the study of Ground Movement using Differential Interferometric
Synthetic Aperture Radar (SAR) technology should develop an analysis of baseline conditions (oldest
SAR data to recent) of ground movement (uplift and subsidence) in relation to oil field activities (pro-
duction, steam injection, waterflooding). This analysis should identify activity within individual oil pro-
duction zones, and injection schedules, rates, volume and pressure. The measure should identify the
professional qualifications of the individuals conducting the analysis and that the Baseline Ground Move-
ment Report will be submitted to DOGGR, LA County Public Works Depai talent, City of Culver City
Public Works Department, and City of Los Angeles Bureau of Engineering 90 days prior to the start of new
secondary recovery efforts. The Baseline Ground Movement report should coincide with the submittal of
the periodic update and DOGGR review of "fieldwide repressuring plan" (Page 4.4-20, Paragraph 2).
These reports shall be reviewed by an independent expert retained by the County of Los Angeles and
other adjacent and affected jurisdictions.
The Baseline Ground Movement report should identify the amount of ground movement (horizontal and
vertical, uplift and subsidence) that would trigger a prompt review or be considered as "on-going ground
movement" (see Mitigation Measure GR.2-4).
Page 4.4-22, Mitigation Measure GR.2-2
The measure should clearly state that the surveying (horizontal and vertical) shall be obtained with high
precision GPS techniques (1 to 2 mm) and completed by a California Licensed Surveyor. A second
ground movement survey shall utilize Differential Inteiferometric SAR data that is available on a monthly
basis for the Los Angeles metropolitan area. In addition, the results of the high precision GPS and SAR
surveys of ground movement will be analyzed by comparing oil field activities during the previous year
(annual data collection, analysis, and report). The annual report shall be submitted to DOGGR, Los
Angeles County Public Works Depai twent, City of Culver City Public Works Department, and City of Los
Angeles Bureau of Engineering. These reports shall be reviewed by an independent expert retained by the
County of Los Angeles and other adjacent and affected jurisdiction(s).
Page 4.4-23, Mitigation Measure GR.2-4
The measure should include Differential Interferornetric SAR monitoring in addition to the GPS moni-
toring. The measure should clearly state that on-going ground movement includes horizontal and vertical
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(subsidence and uplift). The measure does not identify a trigger level; see comment on Mitigation
Measure GR.2-1. Additionally, the measure should include a provision to continue the ground movement
monitoring (Differential 1nterferometric SAR, high resolution GPS, and seismic activity (Measure GR.3-
3)) for a specified period of time (e.g., 10 to 20 years) following the cessation of oil field operations.
Page 4.4-24, Mitigation Measure GR.3-2
The measure should state that a licensed Geotechnical Engineer, in addition to the Certified Engineering
Geologist, complete the site-specific geotechnical investigation for all proposed permanent structures.
Page 4.4-24, Mitigation Measure GR.3-3
The measure should be modified, or an additional measure developed, to include an annual review of the
seismic activity along faults that traverse across or near (Newport Inglewood fault zone, Chamock fault)
the Inglewood Oil Field as measured from the new Caltech Seismological Laboratory accelerometer
(seismometer) to be installed at the oil field. Microseismic activity of M 2.0 and larger should be
evaluated and compared to historic regional data as well as correlation to new injection and oil production
operations.
Page 4.4-25, Impact GR.4
The impact statement should include injection well casing and annular seals in the analysis of deterio-
ration due to corrosion, fatigue, or erosion.
Page 4.4-25, Paragraph 4, Sentence 2 and 3
The scope of the PXP Pipeline Management Plan should be modified to include testing of injection well
easing and seals for evidence of corrosion or erosion that could allow leakage of gas.
Additional Comments on Mitigation Measures
Please make the following additional comments on the mitigation measures:
GR.3-3: Specify timing of installation of accelerometer.
GR,3-4: Specify timing of seismic assessment and subsequent installation of assessment recommendations.
GR.5-1: Specify timing of SWPPP update.
GR,5-2: Specify timing of Erosion Control Plan preparation and approval.
Section 4.5 Biological Resources
Page 4.5-1, Paragraph 1 and bullets 1 and 2. Baseline Data and Previous Reports used in the
preparation of the setting
Much of the information used in the preparation of the baseline data for the Draft EIR appears to be over
six years old and does not provide an accurate description of existing conditions at the site today. The
information used for this report was obtained by a two day site visit in April 2007, one of the driest years
on record when many annual plants and grasses failed to germinate or lacked adequate expression for
identification, and data collected in 2001 and 2002 during the primary report prepared by the Natural
History Museum. A review of the Baldwin Hills Master Plan indicated the majority of the information
collected for the 2002 Master Plan was obtained from a review of the 2001 Biota of Baldwin Hills
prepared by the Natural History Museum of Los Angeles (CDPR and BHC 2002). While the reviewer
believes the existing reports provide good information, they should not be used as the primary source of
data as they do not accurately reflect nor support the assumptions presented in the Draft EIR.
While the reviewer recognizes that much of the site is disturbed and that historic land use practices in the
Los Angeles area have greatly reduced the potential for sensitive plants and wildlife to occur, the report
must present data, supported by surveys capable of identifying sensitive resources should they occur. The
two-day reconnaissance survey of the 853.9-acre parcel would provide a very limited opportunity to
identify and evaluate the potential for sensitive plants or wildlife to be present within existing areas not
previously disturbed by oil field operations.
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Section 4.51.1 Upland Plant Communities
Page 4.5-2, Paragraph 1 (Plant Community Descriptions)
The Draft FIR provides a list of the vegetation communities present in the project area and briefly charac-
terizes the dominant plant species common to those community types. The teiluinology and classification
terms used in the Draft EIR for plant communities are inconsistent and uneven. The plant community
description should conform to a defined vegetation classification system, or where that classification
system does not provide a clear description of the vegetation present, a description of how the unit was
classified should be provided. Plant communities should be defined as native, non-native, and ornamental
to clearly illustrate the varying levels of existing habitat.
Page 4.5-7, Paragraph 1 and sentence 6 (Coyote bush scrub)
While the reviewer agrees that coyote bush scrub has a different functional capacity than typical coastal
sage scrub communities, it should not be characterized as lower quality habitat. Coyote brush scrub is con-
sidered a coastal scrub vegetation community in the California Terrestrial Natural Communities (CDFG
2003) and can support a broad array of wildlife. This species is often characterized as a native colonizer
of disturbed areas that ultimately transitions to coastal scrub communities over time. Therefore it is an
important successional plant community in the project area and should be considered so in the Draft EIR.
Page 4.5-9, Paragraph 1 (Native trees)
Descriptions of random or isolated native trees should be placed in an overview of the project area or
described as a component of an existing classified vegetation community. As described for general plant
communities, native trees including oaks should be classified as such rather than combined under a gen-
eral category of "tree-dominated." This may undervalue the importance of remnant trees of native plant
communities within the existing area.
Section 4.5.1.2 Wetlands and Riparian Plant Communities
General Comment
The general theme and tone of the Draft EIR regarding riparian resources understates the importance of
even degraded riparian communities. While the reviewer concurs with the assessment that some of the
project area supports highly degraded nparian habitat; even small isolated riparian communities play
important functions for migratory birds. This may be even more important where urbanization has
reduced natural stands of riparian habitat for many miles. These pockets of existing riparian habitat still
act as resting and foraging areas for transient species. In addition, where good quality habitat has been
removed, species are often left with degraded habitats for foraging and nesting.
Section 4.5.1.3 Wildlife
Page 4.5-11, Paragraph 1
Information used to establish the Draft EIR baseline conditions is over six years old and inadequate to
evaluate potential impacts from future oil field development. While the two-day reconnaissance survey
noted a variety of species, the site is over 800 acres in size and further studies would provide for a better
understanding of the current biology at the site. In addition, there is no discussion of the timing or
conditions of the surveys (i.e., time of day, weather conditions), and ongoing activity within the oilfield that
may have limited the detection of wildlife.
Most of the species discussed in the Draft EIR rely on this data and it is both scientifically and profes-
sionally prudent to evaluate baseline conditions utilizing recent data collected during a time of year when
the presence of sensitive wildlife could be detected. To rely on information that is several years old may
either over- or underestimate the potential for sensitive species to occur. For example, the 2001
NHMLACF report indicates that white-tailed kite, a State fully protected species, has been reported in the
area. While this information is extremely old, the potential presence of this species should warrant further
investigation of potential nest sites in or adjacent to the project site. Currently, the presence of nesting for
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this species is dismissed as low because of degraded nesting habitat; however, this species is commonly
observed near open fields and agricultural areas in urbanized areas. While the reviewer is not suggesting
this species is still present in the area, further field investigations would alleviate the concerns raised by
only conducting limited surveys based on historic information.
Section 4.5.1.5 Special Status Species and Other Sensitive Biological Resources
Page 4.5-15, Paragraph 2 (Sensitive plant and wildlife species)
The Draft EIR does not present any scientific or survey based information supporting the claim that
sensitive plants do not occur on the project site. The information presenting sensitive species is
dismissive, inaccurate, and misleading. Use of the Natural Diversity Database alone and reports over six
years old fail to support the conclusions provided in the Draft EIR. While the reviewer recognizes the
sites are heavily disturbed and have been subject to ongoing disturbance for decades, rare plant species
are routinely located in these types of areas. In addition, the databases are tools to assist in the evaluation
of known or recorded species and cannot be relied upon to evaluate the presence of sensitive species.
The Draft EIR indicates that focused surveys for wildlife were conducted in the surrounding area over
eight years ago. This information does not provide the reader or the decision maker with the information
required to make an informed conclusion regarding sensitive wildlife.
Section 4.5.4 Analysis of Potential Future Oil Field Development
Pages 4.5-27 and 4.5-28, (Non-Sensitive plant and wildlife species)
The conclusion of the Draft EIR for non-sensitive plant communities, plants, and wildlife must be
expanded and discussed in greater detail. Typically the removal of these habitat types does not result in
adverse effects to biological resources as they are not rare or sensitive. However, these communities can
be important foraging areas for raptors and other sensitive wildlife. Currently the Draft Ea does not
provide a reasonable argument based on lack of existing biological data to conclude the effects would be
minimal. The Draft EIR must address the use of disturbed habitats such as non-native grasslands, ruderal
plant communities, and exotic trees as foraging and nesting habitat for a wide variety of both common
and sensitive birds. White tailed kite, red-tailed hawks, various owls, and other birds rely on these areas
as they support large numbers of small rodents and reptiles.
Impact BR.1
Page 4.5-28, Paragraph 4
The conclusion presented in the Draft ER that less than eight acres of undisturbed habitat would be
subject to oil exploration is speculative. In addition, the mitigation measures presented to reduce impacts
to native or riparian habitats are vague, have no clear reporting procedures, do not specify timing, do not
require regulatory oversight, and do not require specific remedial actions to be taken in the event of
failure. Therefore, the following mitigation measures are recommended to replace the existing measures
identified in the Draft EIR:
BR.1-1a. Provide restoration/compensation for impacts to native vegetation communities.
Prior to clearing and grading, the oil field operator shall have a qualified restoration biologist
approved by the County document the community type and acreage of vegetation that would be
subject to project disturbance. Impacts to trees greater than 3 inches diameter at breast height
(DBH) and all sensitive trees (California walnut, oaks, or suitable non-native nest trees) will be
documented by identifying the species, number subject to disturbance, and DBH.
The oil field operator shall prepare a Habitat Restoration and Revegetation Plan for the Project.
Plans for restoration, enhancement/re-vegetation and/or acquisition of lands shall be prepared by
a County approved biologist with expertise in southern California ecosystems and native plant re-
vegetation techniques. The plan shall include at minimum: (a) the location of the mitigation site;
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(b) the plant species to be used; (c) a schematic depicting the mitigation area; (d) time of year that
the planting will occur and the methodology of the planting; (e) a description of the irrigation
methodology if utilized; (f) measures to control exotic vegetation on site; (g) success criteria; (h)
a detailed monitoring program; (i) and contingency measures should the success criteria not be
met.
The oil field operator shall utilize a County approved seed mix to revegetate areas disturbed by
construction activities. This mix shall consist of native, locally occurring species collected from
local seed sources. Suitable container plants shall also be used to increase the age strata and
function of the site. Revegetation shall include ground cover, grass, shrub, and tree species in
order to match disturbed areas to surrounding conditions and to restore Of improve wildlife hab-
itat quality to pre-project or higher levels. The plan shall also include a monitoring element
spanning a minimum of five years post-planting.
Permanent impacts to native vegetation shall be mitigated at a 3:1 ratio, disturbed habitat at 1:1,
and barren areas seeded to reduce the potential for the spread of noxious weeds to Ballona Creek
and adjacent Parkland. Permanent impacts to mulefat scrub, willow scrub, and willow riparian
woodland will be replaced at a ratio of 5:1. Where onsite restoration is planned for mitigation of
temporary impacts to sensitive vegetation communities, the operator shall identify a Habitat
Restoration Specialist to be approved by the County to determine the most appropriate method of
restoration.
The creation or restoration of habitat shall be monitored for five years to assess progress and
identify potential problems with the restoration site. Remedial activities (e.g., additional planting,
removal of non-native invasive species, or erosion control) shall be taken during the five-year
period if necessary to ensure the success of the restoration effort. If the mitigation fails to meet
the established performance criteria after the five-year maintenance and monitoring period,
monitoring shall extend beyond the five-year period until the criteria are met or unless otherwise
noted by the County. If a catastrophic event occurs, such as a fire, there will be a one time
replacement. If a second catastrophic event occurs, no replanting is required.
BR.1-1b. Implement a Worker Environmental Awareness Program.
A Worker Environmental Awareness Program (WEAP) shall be implemented for construction
crews by a qualified County approved biologist(s) prior to the commencement of any drilling or
construction activities. Training materials and briefings shall include but not be limited to, dis-
cussion of the Federal and State Endangered Species Acts, the consequences of noncompliance
with these acts, identification and values of sensitive plant and wildlife species and significant
natural plant community habitats, fire protection measures, sensitivities of working near riparian
areas and identification of sensitive species, hazardous substance spill prevention and con-
tainment measures, a contact person in the event of the discovery of dead or injured wildlife, and
review of mitigation requirements. Training materials and a course outline shall be provided to
the County for review and approval at least 30 days prior to the start of construction. Maps
showing the location of sensitive wildlife or populations of rare plants, exclusion areas, or other
construction limitations (i.e., limited operating periods for nesting birds) will be provided to the
environmental monitors and construction crews prior to ground disturbance. The oil field operator
shall provide the County a list of construction personnel who have completed training, and this
list shall be updated by oil field operator as required when new personnel start work. No
construction worker may work in the field for more than 10 days without receiving the WEAP.
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Impact BR.2-1
Page 4.5-28, Paragraph 4
The conclusion presented in the Draft DR that federal or State listed plant or animal species are not
present is speculative and not supported by recent biological surveys of the project site. As such, the Draft
EIR cannot claim that effects to listed species would not occur.
The proposed mitigation measures do not provide adequate language to detect and or protect sensitive
plants and wildlife in the project areas. While some measures do provide guidance on protecting the
resource in general, the measures do not clearly articulate the proposed survey methodology that would be
used to conduct the survey, what actions would be taken to ensure the species is protected or mitigated,
and lacks the reporting standards required by the public resource code. Specific comments on each
mitigation measures are provided below.
Mitigation Measure BR.2-1 a (1) defers adequate botanical studies to a later date, does not indicate the
timing of the surveys, and does not provide or indicate what specific actions would be taken to protect or
mitigate for the sensitive plant.
Mitigation Measure BR.2-1 a (2) lacks specificity on the buffer for the survey area and infers that pro-
tection is only for migratory birds. With the exception of several exotic species such as European starling,
all nesting birds are protected by both CDFG and the MBTA regulation. Currently the mitigation lacks
sufficient protection to ensure compliance with these regulations.
Mitigation Measure BR.2-la (5). Language such as "if feasible" will not provide resource protection for
sensitive birds or wildlife. If nesting birds are present the removal of vegetation that results in the loss or
abandonment of the nest would constitute a violation of the MBTA and can only be authorized by the
USFWS Division of Law Enforcement.
Mitigation Measure BR.2-lb (1). Please see comment for Mitigation Measure BR.2-la (5). This language
does not provide clear guidance regarding the measures that will be taken to avoid a violation of the
MBTA.
Mitigation Measure BR.2-lb (2). Typically the CDFG and USFWS require a 300- to 500-foot buffer
between nesting birds and construction activities. However, this buffer may be adjusted based on specific
conditions such as existing noise and disturbance, topography, or the birds' tolerance to disturbance. This
buffer should be monitored by a biologist and the buffer distance modified after consultation with the
CDFG.
Mitigation Measure BR.2-lb (3). Without specific language regarding when and how the surveys would
be performed the measure does not provide adequate measures to protect the species. For example, this
species may be very difficult to detect if soil temperatures are outside the not inal activity range of this
species. The measure does not identify what actions (i.e., raking, visual, etc.) would be taken to locate the
species. In addition, the measure does not indicate the location of the translocation efforts or provide a
mechanism for reporting the movement as required by CDFG Scientific Collecting permit guidelines.
Based on the concerns presented above, the following mitigation measures are recommended to replace
the measures identified in the Draft EIR:
BR.24a. Conduct surveys for sensitive plants and avoid populations of listed and sensitive
plants.
The oil field operator shall conduct protocol surveys for rare plants in all areas subject to ground-
disturbing activity. The surveys shall be conducted during the appropriate blooming period(s) by a
qualified County approved plant ecologist according to protocols established by the USFWS,
CDFG, and CNPS. All listed plant species shall be marked and avoided if present. Impacts to
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listed plant species would only be authorized through the context of a Biological Opinion or
CDFG 2081 take authorization.
In consultation with the County approved plant ecologist, the project shall be redesigned, con-
structed, and operated in such a way as to avoid direct and indirect impacts to listed plant
populations. All project activities and features shall be situated to avoid impacts to any popula-
tions of listed species found during surveys. Populations of listed plant species located within
temporary construction areas shall be fenced or flagged for avoidance prior to construction, and a
biological monitor shall be present to ensure compliance with off-limit areas.
Prior to site grading, any populations of listed plant species identified during the surveys shall be
protected by a buffer zone. The buffer zone shall be established around these areas and shall be of
sufficient size to eliminate potential disturbance to the plants from human activity and any other
potential sources of disturbance including human trampling, erosion, and dust. The size of the
buffer depends upon the proposed use of the immediately adjacent lands, and includes
consideration of the plant's ecological requirements (e.g., sunlight, moisture, shade tolerance,
edaphic physical and chemical characteristics) that are identified by the County approved quali-
fied plant ecologist. At minimum, the buffer for tree and shrub species shall be equal to twice the
drip line (i.e., two times the distance from the trunk to the canopy edge) in order to protect and
preserve the root systems of the plant. The buffer for herbaceous species shall be, at minimum, 50
feet from the perimeter of the population or the individual. A smaller buffer may be established,
provided there are adequate measures in place to avoid the take of the species, and with the
approval of the USFWS, CDFG, and County.
BR.2-lb. Conduct pre-construction surveys and monitoring for breeding/nesting birds.
The oil field operator shall conduct pre-construction surveys for nesting birds if construction and
removal activities are scheduled to occur during the breeding season. Surveys shall be conducted
in areas within 500 feet of any construction activities (i.e., staging areas, drilling sites, and access
road locations). Surveys for raptors shall be conducted for all areas from February 1 to August 31.
Surveys for common/sensitive bird species shall be completed from March 15 to September 15.
Operator shall designate a qualified County approved biologist to conduct pre-construction
surveys and monitoring for breeding birds. If breeding birds with active nests are found, a
biological monitor shall establish a 300-foot buffer around the nest and no activities will be
allowed within the buffer until the young have fledged from the nest or the nest fails. The 300-
foot buffer may be adjusted to reflect existing conditions including ambient noise and disturbance
with the approval of the County and CDFG. The biological monitor shall conduct regular
monitoring of the nest to determine success/failure and to ensure that project activities are not
conducted within the buffer(s) until the nesting cycle is complete or the nest fails. The biological
monitor shall be responsible for documenting the results of the surveys and the ongoing
monitoring and will provide a copy of the monitoring reports for impact areas to the County. If
for any reason a bird nest must be removed during the nesting season operator shall provide
written documentation providing concurrence from the USFWS and CDFG authorizing the nest
relocation. Operator shall provide a written report documenting the relocation efforts. The report
shall include what actions were taken to avoid moving the nest, the location of the nest, what
species is being relocated, the number and condition of the eggs taken from the nest, the location
of where the eggs are incubated, the survival rate, the location of the nests where the chicks are
relocated, and whether the birds were accepted by the adopted parent.
BR.2-1c. Conduct focused surveys for sensitive wildlife and implement monitoring, avoidance,
and minimization measures.
A qualified County approved biologist shall conduct focused surveys for sensitive wildlife includ-
ing coast horned lizards in all areas that support habitat for sensitive species. If sensitive wildlife
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or coast horned lizards are detected in or adjacent to the proposed work area, no work shall be
authorized until the biologist has inspected and cleared these areas.
The oil field operator shall retain a qualified County approved biologist with demonstrated exper-
tise with species expected to occur in the planning area to monitor construction activities and
assist operator in the implementation of the monitoring program if sensitive wildlife are encoun-
tered. The authorized biologist will be present during ground-disturbing activities immediately
adjacent to or within habitat that supports populations of sensitive wildlife including coast horned
lizards. If the installation of fencing is deemed necessary by the authorized biologist, a clearance
survey for the coast homed lizards shall be conducted at the time of the fence installation.
Clearance surveys for coast homed lizards shall be conducted by the authorized biologist prior to
the initiation of construction each day. Individuals, if located, will be relocated to suitable habitat
outside the project area.
Impact BR.2-2
Pages 4.5-34 and 4.5-35 General Comment
The Draft EM does not disclose or discuss the types of sensitive wildlife that occur downstream of the oil
fields, their locations, or evaluate what types of effects a release of oil into the creek would have on bio-
logical resources from either the spill or the associated clean-up activities. There is also no discussion of
indirect effects to wildlife or vegetation from daily spills or what would occur from a major release. The
Draft EIR. indicates a catastrophic spill could occur every 4,900 years; and while the likelihood of a spill
may be low under CEQA the Draft EIR has a responsibility to present information on the potential effects
to biological resources that could be affected from such an event. The Draft OR must provide a
discussion of the effects of oil spills to biological resources, both direct and indirect, the effects of clean-
up activities, and what actions have been taken to reduce or avoid impacts from both the spill and associated
clean-up.
The conclusion that residual impacts from a large spill are less than significant is not supported by any
analysis and fails to provide the decision maker with adequate information to draw an informed conclusion.
Mitigation Measure BR.2-2 (1). Currently, the measure lacks any specific actions that would be taken to
reduce or mitigate the effects of a spill. The measure is vague and defers the mitigation to the devel-
opment of a plan.
Mitigation Measure BR.2-2 (2 and 3). This section defers the actual analysis of a spill to a later document.
Impacts of a spill and any clean-up activities must be addressed in the context of the Draft EIR and not
deferred to a later date.
Impact BR.3 Wetlands
Page 4.5-36. General Comment
The Draft Elk is dismissive of potential jurisdictional features that occur within the borders of the
existing oilfield. In California more than 95 percent of riparian habitats that were present prior to
European settlement have been severely degraded or destroyed (Smith, 1977; Katibah, 1984). While these
habitats constitute only a small fraction of the proposed project area and a low percentage of the total
landscape (often less than one percent), they typically accommodate a disproportionately high number of
species and provide a larger degree of ecological function than surrounding upland areas (Fischer and
Fischenich, 2000). While degraded in some areas, the Draft EIR indicates several drainages occur in the
project areas that have the potential to qualify as State or federal jurisdictional waters. The Draft DR does
not provide any clear information as to the regulatory steps that are required by law that must be taken
when working in riparian or wetland areas. As the exact location of future drilling activities is not known
the Draft EIR must either adequately delineate the features that occur in the project area or provide
mitigation that requires a delineation of these areas and subsequent regulatory approval prior to clearing
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COMMENTS ON THE PUBUC DRAFT ENVIRONMENTAL IMPACT REPORT
or modifying these features. The following mitigation measure is recommended to replace the existing
Draft EIR measure:
BR.3-1. Provide Documentation of Regulatory Permit Compliance.
Prior to construction in any riparian or potential wetland drainage feature, the operator shall pro-
vide copies of all approved permits (1602, 404, 401, 402) or letters from the CDFG, RWQCB,
and USACE indicating the riparian and wetland areas do not fall under State of federal jurisdic-
tion. Prior to ground disturbance in any potential riparian or wetland area, the operator shall have
a qualified County approved biologist prepare a wetland delineation of the proposed work area.
This report shall be submitted to the County and provided to the regulatory agencies during the
application for water quality pellnits.
Impact BR.4 Wildlife Movement
Page 4.5-37. General Comment
The reviewer recognizes that much of the project site consists of degraded habitats within an urban
matrix. In addition, the area is fenced which limits the movement of larger mammals. However, the
existing habitat in the project area, including riparian areas and adjacent parkland, is a likely stopover for
migratory birds. Currently the Draft ER provides mitigation measures that indicate priority areas "should"
be given to specific areas. The measure then references an existing mitigation measure (BR.1-1). To avoid
ambiguity the language regarding the areas that will be restored must be clarified and included in the
discussion of impacts for the section. Mitigation Measure BR.I-1 or the proposed new measures should
then be referenced as the appropriate mitigation for this impact.
Subsection 4.5.5 Analysis of Proposed CSD
Page 4.5-39, Table 4.5.5
•Mitigation Measures BR.1-1 through BR.1-3: see comments regarding Impact BR.1. A Habitat Resto-
ration and Revegetation Plan should be prepared for each project. See recommended mitigation.
Section 4.6 Water Resources
Section 4.6.1.3 Groundwater
Page 4.6-4, Paragraphs 1, 2 and 3, Groundwater in Baldwin Hills
The statement that the Baldwin Hills are generally considered non-water bearing is accurate. However,
the formations within the hills are in direct contact with the foimations that comprise the aquifers within
the adjacent groundwater basins (West Coast, Central and Santa Monica). This lateral continuity is
important to understanding potential water quality impacts related to waterflood injection.
Page 4.6-16, Impact WR.2, A rupture or leak could substantially degrade groundwater quality
The impact statement should include consideration of a rupture or leak from injection wells, which could
substantially degrade groundwater.
Page 4.6-15, Mitigation Measure, Potential impacts to local groundwater resources from a leaking
or ruptured injection well casing or seal
An additional mitigation measure should be developed to address potential impacts to local groundwater
if watertlood brackish water leaks from injection wells, seals or natural pathways into potable aquifers in
the adjacent groundwater basins. The mitigation measure could also acknowledge the revised PXP
Pipeline Management Plan to conduct routine testing of injection well casing and seals. The mitigation
measure should include water quality testing of existing municipal supply wells and deep monitoring
wells proximate to the Inglewood Oil Field. In addition, deep (500 to 1500 feet) aquifer-specific moni-
toring wells will likely need to be constructed to monitor water quality at locations between injection
wells and nearby groundwater supply wells.
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Section 4.6.4 Analysis of Potential Future Oil Field Development
Page 4.6-19 Impact WR.3
New grading and construction would alter the existing drainage pattern of the site and potentially increase
the rate or amount of surface runoff in a manner that would result in flooding on or off site.
The Draft EIR concludes that natural drainage would be altered by the project such that the rate and
amount of storm surface runoff into detention basins would be altered thus potentially resulting in basin
overtopping. Although this impact is warranted, it may be overstated; the likelihood of this happening is
small. The impact finding should be supported by giving design capacities of the six detention basins in
comparison to the expected runoff to be received by them.
Mitigation Measure WR.3-1 requires a hydrologic analysis in compliance with Los Angeles County reg-
ulations. The mitigation measure should also state that drainage patterns shall not be altered in a manner that
increases the drainage area contributing to any of the detention basins, or otherwise increases the amount
or frequency of runoff (such as through creation of new impervious areas), without reworking the basins
to accommodate the increased runoff.
Cumulative Analysis. The cumulative analysis should provide an indication of the project area's relative
contribution to the pollution and flood flows of Ballona Creek.
Section 4.7 Transportation and Circulation
General Comments
• Information regarding site access, parking, and local transit routes is presented in the environmental
setting but is never referenced again in the analysis. However, these issues are usually analyzed in
CEQA documents; even if no impacts are anticipated, some analysis should be presented in order to
support an impact conclusion.
• This analysis does not address all the significance criteria listed in 1997 LA County Traffic Impact
Analysis Report Guidelines (including interrupted traffic flow due to design features and unsafe access) in
the analysis section, although some of these issues are addressed in the environmental setting.
• It is unclear if the trips associated with future development would be atti ibutable to construction
activities only or if they would be permanent (operational).
• The Draft EIR concludes that the addition of trips associated with future development would not
result in significant impacts. However, it would be more effective to determine what would constitute
a significant impact and then provide traffic parameters in the CSD that projects would not be
allowed to exceed without implementation of mitigation measures or the need for further CEQA
review.
Section 4.7.1.3 Site Access and Parking
Page 4.7-3, 7th Paragraph, Parking
It is stated that employee and truck parking is provided on site and that parking will not change with
future development, however there is no discussion regarding capacity. Additionally, the statement "parking
will not change" is vague — does this mean capacity will not change, designated parking areas will not
change, or parking demand will not change? Please clarify.
Section 4.7.3 Analysis of Potential Future Oil Field Development
Page 4.7-10, 2nd Paragraph under Section 4.7.3
This paragraph states that current oil field operations require 150 employees for the day shift and that the
number of employees during the first shift is anticipated to grow to 200 employees. However it is unclear
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COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
whether this increase of 50 personnel is attributable to the future baseline or future oil field development
without looking at the tables and figures.
Section 4.8 Land Use'
Section 4.8.1.2 Existing Land Use
Page 4.8-2, Paragraph 2, Project Site Land Use
In addition to the land uses associated with oil production within the Inglewood Oil Field, the proposed
project site (within the CSD boundary) includes an open space area, a portion of the Holy Cross Cemetery
and a Southern California Edison (Edison) facility (substation) and a gas plant; these are not adjacent land
uses. They should be noted in the text of this paragraph, which describes existing land uses within the site
proper. The Draft EIR should discuss why these areas are included in the CSD.
Page 4.8-2, Table 4.8.1, Summary of Land Uses that Abut the Perimeter of the CSD
Religious (cemetery) uses, open space, and Quasi-Public- Utilities (the Edison substation and a gas plant)
are not, in full, adjacent to the CSD boundary but also fall within it. The acreages of these existing land
uses within the CSD boundary should be provided.
Section 4.8.1.3 Land Use Plans and Policies
Page 4.8-6, Paragraph 3, Los Angeles County General Plan
The paragraph does not define short and medium range "actions" or identify whether the proposed project
is considered a short or medium range action. Additionally, the text does not explain how the County of
Los Angeles' "allocation of resources" applies to the proposed project. The purpose of this paragraph is
unclear.
Pages 4.8-6 and 4.8-7, Project Site Land Use Designations
According to Figure 4.8-3a (Land Use Policy Map — Los Angeles County), the proposed project site
additionally contains two relatively small areas designated Commercial. The text of this section, however,
does not identify allowable or compatible land uses associated with the Commercial designation. Allow-
able and compatible land uses associated with the Commercial designation should be noted, and any
conflicts with oil development and production should be identified.
Section 4.8.3, Significance Criteria
Page 4.8-17, Paragraph 1
Per the State CEQA Initial Study Form (Appendix G of the CEQA Guidelines), the third impact criteria
addressed within the land use analysis is:
"Conflict with any applicable habitat conservation plan or natural community conservation plan."
The vast majority of the time, this impact criteria is also addressed in the land use analysis prepared for
EIRs. This impact criteria should be addressed within the Draft EIR's land use analysis due to the
significant community effort and support associated with the Baldwin Hills Park Master Plan, which is, in
part, a habitat restoration and conservation plan.
Additionally, the first impact criteria should be modified to demonstrate the proposed project's potential
effects on both existing and planned land uses both within the proposed project site and its surroundings,
as follows:|1010|2002. Community Conservancy International (CCI). Baldwin Hills Park Master Plan. Prepared by the Commu-
nity Conservancy International. Prepared for the California Department of Parks and Recreation and the Baldwin
Hills Conservancy. May 2002. http://www.bhc.ca.govidocturients/Baldwin_Hills Master_Plan_Firial.pdf Accessed
July 20, 2008
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-Incompatible with, or preclude or diminish existing and planned land uses within and surrounding the
area of effect, or result in substantial quality of life effects on occupants within and surrounding the area
of effect."
Section 4.8.4 Analysis of Potential Oil Field Development
The analysis is limited to addressing potential effects associated with noise (Impact LU.1), visual and
aesthetic resources (Impact LU.2 and LU3), and air quality and public health (Impact LU.4). Although
these types of impacts are germane and appropriate to address land uses surrounding the proposed project
site, none of these impacts relate directly to existing or future land uses (and compatibility) or land use
planning (e.g., not land use planning policy, as addressed in Section 4.8.5, but future and planned land use
development per known pending and approved projects and land use designations). The impact analysis
should include the following:
Impact LU.5. Implementation of the proposed project would cause temporary disruptions or preclusions
of existing and planned residential and non-residential land uses within and surrounding the site.
Impact LU.6. Implementation of the proposed project would cause the long-term disruption or preclusion
of existing and planned residential and non-residential land uses within and surrounding the site.
By addressing these two impacts, the proposed project's land use effects on those areas within the CSD boun-
dary that are not within the active field boundary will be disclosed and mitigated, as needed and feasible.
Additionally, the proposed site's planned future use as a park will be addressed, analyzed, and mitigated,
as needed and feasible.
Section 4.8.5 Planning and Zoning Consistency
Page 4.8-21, Table 4.8.2, Consistency with Los Angeles County General Plan Policy
1) General Goals and Policies - Environmental Protection
• Add a consistency analysis for Policy 15 ("Protect areas that have significant natural resources and
scenic values, including significant ecological areas, the coastal zone and prime agricultural lands.")
• Add a consistency analysis for Policy 21 ("Stress the development of community parks particularly in
areas of the greatest deficiency, and take advantage of opportunities to preserve large natural and
scenic areas.")
2) Land Use Element - Quality, Compatible Design
• Add a consistency analysis for Policy 17 ("Establish and implement regulatory controls that ensure
compatibility of development adjacent to or within major public open space and recreation areas
including National Forests, the National Recreation Area, and State and regional parks.")
Comment for Section 4.8.5: The Baldwin Hills Park Master Plan (Plan) was prepared for two govern-
mental agencies, the California Department of Parks and Recreation and the Baldwin Hills Conservancy.
During its preparation, consultations with over 30 different public agencies were conducted, over 200
individual meetings with a broad range of organizations, community leaders, elected officials and other
stakeholders were undertaken, and two public workshops with, collectively, over 700 attendees were held to
ensure that the Plan "balanced community needs and concerns with natural resource protection needs and
physical site constraints" (Con-imunity Conservancy International [CCI], 2002). Additionally, an 85-
member Baldwin Hills Park Advisory Committee was formed for development of the Plan to provide
community guidance on the planning process (CCI, 2002).
The Plan is consistent with the goals contained in Senate Bill 1084 (SB 1084), and contains a suite of 14
Specific Management Goals and a series of General Management Goals (CCI, 2002). The Plan also states
the overall goals of the park's various conceptual design plans (e.g., identified design alternatives) (CCL
2002). Although it is acknowledged that the Plan is not a formally adopted land management and
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planning document, it is a document of both local and regional importance. Additionally, as noted in the
Recreation Section (Subsection 4.10.1, Environmental Setting), the area surrounding Baldwin Hills is one
of the most park-poor urban areas in the State, thereby making realization of the intent and goals of the
Plan a significant local and regional objective at both community and agency levels. The proposed project's
nexus to the Plan should be addressed in Draft EIR Section 4.8.5, and an analysis of whether the proposed
project would impede or foster the Plan's intent and goals should be included.
Additional comment for Section 4.83: See comment under Section 4.10.2 Regulatory Setting (Recreation).
Page 4.8-26 Table 4.8.3 Culver City Sphere of Influence Policy 1.B
The City of Culver City does not agree with the policy analysis presented in the table with regard to consistency
with the Culver City Sphere of Influence. The consistency analysis should also consider air quality and toxics,
and the determination should be revised to address the issues presented in this comment letter. Also, the measures
for landscaping and aesthetics have not been proven to effectively mitigate impacts. Therefore, the City does not
believe that the project is consistent with Policy 1.B.
Section 4.9 Noise and Vibration
General Comment
The Draft ElR noise section does not provide any consistency analysis of the proposed project to applic-
able County of Los Angeles and Culver City noise ordinances and policies.
Section 4.9.1 Environmental Setting
Page 4.9-10, Baseline Vibration Monitoring
There is no discussion as to how vehicle movements on local roadways contribute to existing vibration
levels.
Section 4.9.2 Regulatory Setting
Page 4.9-11, Section 4.9.2.1 (Los Angeles County Code)
Explain why proposed project activities, including drilling, would not be subject to the Los Angeles
County Code exterior noise standards for designated land use zones and time intervals (Section 12.08.390)
during construction. Furthermore, explain why proposed project activities would not be subject to Los
Angeles County Code (Section 12.08.440, Part A) prohibiting construction activity hours if it may cause a
disturbance at a nearby residential or commercial property.
Page 4.9-13, Section 4.9.2.1 (Los Angeles County Code), Exemptions
Explain why these exemptions are identified. Because drilling is required for the proposed project, these
exemptions would not apply.
Section 4.9.3 Significance Criteria
Page 4.9-14, Significance Criteria
Explain why there is no discussion regarding construction noise in the significant criteria. Section 4.9.3 of
the Draft EIR only identifies operation significance criteria. The County of Los Angeles Noise Ordinance
specifies construction noise thresholds, and both the County of Los Angeles and Culver City Noise
Regulations specify prohibited hours to conduct construction activities. The omission of these
construction related thresholds has resulted in inadequate significance criteria to determine noise impacts.
Page 4.9-14, Significance Criteria, 3rd paragraph
Please explain the rationale or cite the reference used to determine "pure tone" and the included loga-
rithmic quantification contained within this paragraph. Several terms and the logic used in this paragraph
are not explained adequately in Draft E1R Section 4.9.1.1 (The Characteristics of Noise).
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Page 4.9-15, Significance Criteria Rationale
Please explain how the significance criteria adequately address Chapter 9.07 of the Culver City Municipal
Code and not just the County of Los Angeles requirements.
Section 4.9.4 Analysis of Potential Future Oil Field Development
Pages 4.9-18 and 4.9-19
Second paragraph states: "the height of the noise sources associated with the drilling process varies."
Explain why the drilling activities of a new injector well at Vapor Recovery Unit 294 are used as a com-
parison analysis for projected noise levels expected for proposed project drilling. No data is provided as
to similarities between the two projects and drilling techniques and parameters that make drilling noise
vary to such a degree.
Pages 4.9-17 through 4.9-20, Impact N-1
There is no quantitative justification that drilling activities would result in a less than significant impact
with mitigation incorporated (Class II). As stated on Draft E1R pages 4.9-3 and 4.9-4, noise barriers are
expected to "reduce noise levels by approximately 5 dBA." As stated on page 4.9-17, "During drilling of new
wells, potential impacts are exacerbated because drilling continues day and night." The expected noise
levels presented for drilling activities, as identified in Table 4.9-6, when reduced by 5 dBA through the use
of noise barriers (proposed as Draft EIR Mitigation Measure N.1-1) would be substantially higher than
ambient Leg noise conditions identified at sensitive receptors in Table 4.9-3. No minimum distances are
identified between the nearest possible drilling activity and sensitive receptors, and no quantitative analysis
is presented as to how drilling will not result in a 5 dBA increase over existing ambient 24-hour L eg noise
conditions at receptor sites, as identified as the threshold of significance for noise impacts in the Draft
EIR. As stated on page 4.9-18, "the results of the analysis indicate that drilling nose would be considered
significant depending upon the location of the drill rig within the oil field." No discussion of distance is
included in the analysis and noise impacts are concluded to be less than significant with mitigation
incorporated. Furthermore, based on this information provided in the Draft EIR, drilling noise would
likely exceed the County of Los Angeles Noise Standards 1 through 5 as identified on pages 4.9-12 and
4.9-13. Based on the information presented, a quantitative comparison analysis is required to show drilling
noise would not result in a 5 dBA increase. Without this analysis, drilling activities should be stated to
result in a significant unavoidable (Class I) noise impact.
Pages 4.9-17 through 4.9-20, Impact N-1
The analysis is void of discussion of noise impacts of new truck trips associated with the proposed project. No
discussion of estimated noise levels from these vehicles is identified. However, Mitigation Measures N.1-3
through N.1-5, are proposed to mitigate vehicle related impacts associated with drilling. No mention as to
potential noise impacts on local roadway routes are discussed either.
Pages 4.9-20 through 4.9-21, Impact N-2
The analysis is void of quantitative analysis to detetinine that workover of future oil wells would not
result in an increase of 5 dBA over existing ambient noise conditions at nearby receptors. Without this
analysis, drilling activities should be stated to result in a significant unavoidable (Class I) noise impact.
Pages 4.9-21 through 4.9-22, Impact N-3
The analysis is void of quantitative analysis to determine that well pumps would not result in an increase of
5 dBA over existing ambient noise conditions at nearby receptors. The noise levels shown in Table 4.9-7
are greater than 5 dBA than those shown in Table 4.9-3 representing ambient conditions at nearby
receptors. While the noise measurements shown in Table 4.9-7 were taken only 10 feet from the well
pump, without stating what the nearest potential receptor distance could be and perfoiming a quantitative
analysis, these activities should be stated to result in a significant unavoidable (Class 1) noise impact.
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COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Pages 4.9-24 through 4.9-25, Impact N-5
Explain why the drilling activities of a new injector well at Vapor Recovery Unit 294 are used as a
comparison analysis for projected vibration levels expected for proposed project drilling. No data is
provided as to similarities between the two projects and drilling techniques and parameters that could
make drilling vibration vary. Furthermore, this analysis is completely void of any analysis of vibration
impacts from truck trips associated with the proposed project on nearby receptors and receptors along
roadways.
Pages 4.9-25 through 4.9-29, Table 4.9-11
The Recommended Modifications to the Proposed CSD based on the analysis do not include any
quantitative basis or details as to how the measures would reduce any impact to a Class II level and not
exceed established thresholds of significance.
Section 4.9.7 Mitigation Monitoring Plan
Pages 4.9-28 through 4.9-29,
Mitigation Measure N.1-1 and Impact N.2 plan requirements rely on a field monitor to record noise levels
during drilling and well workover activities at receptor locations within 1,000 feet of the oilfield
perimeter to ensure that "required noise limits" are not exceeded. This measure should include the logic
of a 5 dBA increase over existing ambient conditions, should state how and what the assumed ambient
condition levels are, state when the noise monitoring will occur (times of day), and state what will happen
when/if they are exceeded. Without a quantitative noise analysis in the Draft EIR., it should be assumed a
5 dBA increase will occur, resulting in significant and unavoidable (Class 1) noise impacts.
Section 4.10 Recreation6
Page 4.10-1, Paragraph 1, Sentence 4
As addressed in comments related to the Draft FIR's Land Use Section (Section 4.8), the land use analysis
does not contain an assessment of impacts to planned recreational facilities (e.g., the planned Baldwin
Hills Park) in terms of direct physical impacts or potential incompatibilities, as referenced in this
sentence. Recommendations have been made for the Land Use Section to correct these omissions.
Section 4.10.1 Environmental Setting
Page 4.10-2, Figure 4.10-1, Existing Park and Recreation Facilities (and associated text)
It is noted that West Los Angeles College contains outdoor recreational facilities (tennis courts and a foot-
ball field) immediately adjacent to Freshman and Sophomore Drives; the football field is immediately
adjacent to the proposed project site (Google Earth, 2008). These should be noted in the description of
existing recreational facilities, and information on their availability for public use should be added.
Section 4.10.2 Regulatory Setting (Recreation), Section 4.8.2 Regulatory Setting (Land Use), and
Section 4.8.5 Planning and Zoning Consistency Analysis (Land Use)
Page 4.10.3, Section 4.10.2 Regulatory Setting
The discussion references a requirement from the 2008 Los Angeles County Draft General Plan, which is
not an adopted plan and is inconsistent with the reference to the general plan in the Land Use Section
(Subsections 4.8.2 and 4.8.5), which addresses the adopted 1980 Los Angeles County General Plan.
Although not adopted, the 2008 Draft General Plan is far enough along in its development and review
processes to be germane to the proposed project (County of Los Angeles, 2008). To make the Draft EIR
2008. County of Los Angeles (Department of Regional Planning). County General Plan Update Program. July
2008. [Online] http://planning.co.lasca.us/spGPMain.htm . Accessed July 20, 2008.
2008. Google Earth. Aerial Photography of the proposed project area. (Aspen Environmental Group license
agreement). July 20, 2008.
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internally consistent, and to provide the reader with an understanding of the proposed project's
consistency with both the existing and planned applicable goals and policies, it is recommended that
Sections 4.8 (Land Use) and 4.10 (Recreation) address and analyze both the 1980 Final and 2008 Draft
General Plans.
Section 4.10.4 Analysis of Potential Future Oil Development
Page 4.10-4, Section 4.10.3 Significance Criteria
The discussion states that one of the significance criteria addressed in the impact analysis is "Conflicts
with planning efforts to protect recreational resources of the project area." However, the impact analysis
(Subsection 4.10.4, Analysis of Potential Future Oil Field Development) only addresses impacts related to
noise (Impact Rec. 1), visual and aesthetic resources (Impact Rec. 2), and air quality (odors) (Impact Rec.
3). The recreation impact analysis fails to address planning efforts associated with the Baldwin Hills Park
Master Plan (Plan), which is a recreation planning document of both local and regional importance (see
comment on Subsection 4.8.5, Land Use, Planning and Zoning Consistency Analysis). An analysis of the
Plan should be included in Section 4.10.4 to conform to the significance criteria referenced above (e.g.,
"Conflicts with planning efforts to protect recreational resources of the project area").
Section 4.11 Fire Protection and Emergency Response
Section 4.11.1 Environmental Setting
Page 4.11-3, Paragraph 3 and sentence 3, Response Capabilities
CCFD also permits and inspects aboveground tanks as a Participating Agency through LA County CUPA
(Certified Unified Agency Program).
Page 4.11-4, 2nd Paragraph, last sentence
The last sentence states that each of the previously referenced response times of environmental service
providers is estimated to be within one hour, however it is not clear on what this statement is based. Is
this the author's estimate or that of the referenced service providers?
Page 4.11-4, Table 4.11.1 Fire Stations Available to Respond to an Emergency
Table does not include Culver City Fire Department (CCFD) Station One or Station Three.
Section 4.11.2 Regulatory Setting.
Page 4.11-5, Paragraph #2, sentence #2
Delete specific 'LA County FD' reference and replace with generic 'Fire Department' Criteria and Guidelines.
Replace 'Uniform Fire Code' with 'California Fire Code'.
Page 4.11-6, Table 4.11.2 Applicable Standards and Codes
Correct 'UFC Articles' to current code as follows:
UFC Article 04 — CFC Section 105 Permits
UFC Article 09 — CFC Chapter 2 Definitions
UFC Article 10— CFC Chapter 9— Fire Protection Systems
UFC Article 11 — CFC Chapter 3 — General Precautions Against Fire
UFC Article 12 — CFC Chapter 10— Means of Egress
UFC Article 13 — included in Chapter 3
UFC Article 14— included in Chapter 9
UFC Article 49— CFC Chapter 26— Welding and Other Hot Work
UFC Article 79— CFC Chapter 34 Flammable and Combustible Liquids
UFC Article 80 — CFC Chapter 27 Hazardous Materials
UFC Article 85 — CFC Chapter 6 Building Services and Systems
38
CoBaldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Add:
CCFD Fire Prevention Regulations, Guidelines, & Procedures
Section 4.11.3 Significance Criteria
Page 4.11-7, lst Paragraph under Section 4.11.3
This paragraph states that a set of criteria has been developed but does not provide any background Or
rationale as to how these criteria were developed or why they are appropriate.
Page 4.11-9, 1st Bullet under Table 4.11.3
Significance criterion states that a significant impact would occur if: the project site is located more than 10
miles (15 min) from an emergency response location with both HazMat (spill response) or fire fighting
capabilities (i.e., a fire station or facility with fire fighting and emergency response capabilities) or
accessibility to the site is difficult or limited causing issues in terms of evacuations and response.
This criterion should say "...both Hazmat (spill response) and fire fighting capabilities..."
Section 4.11.4 Analysis of Potential Future Oil Field Development
Page 4.11-9, 2nd Paragraph under Section 4.11.4, Impact conclusions not supported by analysis
Analysis for this threshold provides one sentence that simply states spacing requirements "appear to be
adequate" as per listed requirements, however the analysis does not present any background information
or hypothetical situation to analyze.
The Draft EIR and CSD should require that future development adhere to API, NEPA, and IRI
recommendations including a mitigation measure requiring all future development be designed in
accordance with these recommendations for equipment spacing. The oil field operator should be required
to identify any potential scenarios in which recommendations may be infeasible.
Page 4.11-10, lst Paragraph, Incomplete analysis of Significance Criterion 4
The fourth significance criterion presented in Section 4.11.3 states that a significant impact would occur
if: Project site is located more than 10 miles (15 min) from an emergency response location with both
HazMat (spill response) or fire fighting capabilities (i.e., a fire station or facility with fire fighting and
emergency response capabilities) or accessibility to the site is difficult or limited causing issues in terms
of evacuations and response.
The analysis on page 4.11-10 identifies the closest fire dep.' inent (located one block from Inglewood Oil
Field) but does not identify response capabilities of that fire depaitmerit or provide any information about
site accessibility. This analysis also does not address the second part of this criterion regarding
accessibility.
Please include discussion of the response capabilities of LA County Fire Station #58 as well as the
accessibility of the site to response vehicles and personnel (onsite roadways, gates, onsite emergency proto-
cols, etc). The CSD shall state that all future development must be designed to ensure adequate access for
emergency vehicles and/or that the facility design would be subject to review and approval by the fire
department.
Page 4.11-10, 2nd Paragraph, Incomplete analysis of Significance Criterion 5
Analysis states that applicant has a SPCC (Spill Prevention Control and Countermeasure) Plan that was
reviewed in 2003 but that the current status of that plan's compliance is unknown. Discussion proposes a
mitigation measure to review compliance status, but it is unclear if the SPCC would be included in such a
review. Please discuss whether the existing SPCC would apply to and/or would be appropriate for future
development. If not appropriate, or if such analysis is inconclusive, provide mitigation measures that
would ensure an adequate SPCC is developed for all future development.
39Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Page 4.11-10, 3rd Paragraph, Incomplete analysis of Significance Criterion 1
Discussion states Inglewood Oil Field is "not required to comply with most recent fire code requirements"
and that site does not "appear" to have fire water storage capacity. Analysis concludes that new devel-
opment would increase potential for fires to occur and that lack of "appropriate fire fighting capabilities"
would be a significant impact. There is no discussion indicating whether new development is also
grandfathered or must comply with requirements. The impact analysis should provide some sort of basis
for a conclusion and the CSD should require all future development to be designed to comply with all fire
codes and that designs of all future development should be approved by the fire departn sent prior to
implementation.
Page 4.11-10, 4th Paragraph, Incomplete analysis of Significance Criterion 3
Analysis provides no discussion regarding early fire detection. Analysis states evacuation plans are in
place to ensure employee safety--however, it is unclear whether these are existing plans for the Inglewood
Oil Field or if plans would apply to or be developed specifically for future development.
Please discuss fire detection capabilities of future development and how they would compare to NFPA
requirements. At a minimum discuss whether NFPA requirements would be considered during the design of
future facilities and the CSD should require that all future development to include fire detection capability.
Page 4.11-10, Mitigation Measures
Mitigation Measure FP.1-1 should identify when such an audit should be completed — e.g., prior to
construction of future development. Additionally, the last two sentences of this measure should form the
basis of a second measure. The intent of Mitigation Measure FP.1-1 is to identify existing and potential
deficiencies and inadequacies of fire fighting capabilities. Another measure to implement any recommen-
dations of the audit that would expand and improve fire-fighting capabilities should also be included.
Specify timing of third-party review and audit.
Mitigation Measure FP.1-2 requires implementation of a community alert system, but does not provide
any information on how such a system would be developed or what specific measures should be included.
Specify timing of development of community alert notification system, including necessary equipment
installation.
Mitigation Measure FP.1-3 should be revised to clearly identify who is responsible for developing the
response training and equipment plan (such as a qualified engineer, industrial hygienist, etc.) and should
specify when the training will occur.
Mitigation Measure FP.2-1. Measure does not specify that SPCCP is the mechanism to address spill
containment response training and equipment (see Table 6.1).
Section 4.11.6 Cumulative Analysis
Page 4.11-12, 1st Paragraph
The first sentence states that "Cumulative projects that could impact the fire protection analysis.." is
incorrect. Cumulative projects would impact area fire fighting capabilities, not fire protection analysis.
Page 4.11-12, 2nd Paragraph
The first sentence states that future oil development at the Inglewood Oil field would not be expected to
increase the demand for fire protection services, however, the third paragraph on page 4.11-10 states that
"With new development at the site, fire fighting requirements and the potential for fires would increase."
While there is a difference between the demand for fire protection services and fire fighting requirements,
the cumulative analysis does not clearly explain why increased fire fighting requirements and potential for
fires would not result in a commensurate increase in fire protection services. Additionally, it is unclear
what "baseline fire protection services" specifically refers to.
40Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Section 4.12 Cultural Resources
Section 4.12.1.2 Presence of Cultural Resources within the Project Area
Page 4.12-3, Paragraphs 2 to 5 [following first full paragraph], Historic Archaeological Sites and
Architectural Resource
This section lists two historic archaeological sites (PXP-1H, PXP-2H) and one historic architectural
resource (the Cone Trust House) that were identified in the northern portion of the project area. It is not
clear where these sites are located relative to the proposed CSD boundary or the Culver City drilling area.
A better description of the location of the archaeological sites in relation to the CSD and affected jur-
isdictions should be provided and, if appropriate, a map should be included that illustrates the location of
the known historic structure (Cone Trust House).
Section 4.12.4 Analysis of Potential Future Oil Field Development
Page 4.12-6, Mitigation Measure CR.1-1
In order to ensure that drilling activities do not impact the Cone Trust House, Mitigation Measure CR.1-1
should specify the maximum distance from the Cone Trust House at which drilling activities may be
safely located.
Pages 4.12-6 to 4.12-7, Mitigation Measure CR.1-3
In order to ensure that any disturbances to the Cone Trust House are repaired or restored following its
potential relocation, Mitigation Measure CR. 1-3 should specify a timeframe within which PXP must
complete these repairs (e.g., within three months following the relocation of the Cone Trust House).
Section 4.12.6 Cumulative Analysis
Page 4.12-9, Cumulative Analysis
Section 15130(b)(1) of the CEQA Guidelines (CCR, Title 14, Division 6, Chapter 3) describes the elements
that are necessary for an adequate discussion of significant cumulative impacts, which include either:
(A) A list of past, present, and probable future projects producing related or cumulative impacts,
including, if necessary, those projects outside the control of the agency, or
(B) A summary of projections contained in an adopted general plan or related planning document, or in a
prior environmental document which has been adopted or certified, which described or evaluated
regional or areawide conditions contributing to the cumulative impact. Any such planning document
shall be referenced and made available to the public at a location specified by the lead agency.
The cumulative analysis addressed in Section 2.5 of the Draft ElR uses a list approach. According to
Section 2.5, the cumulative projects list includes all approved or pending projects located in the study
area. Past projects, such as past drilling operations in the project area, are not included in the cumulative
projects list.
In Section 4.12.6, there is no discussion of the combined effect of past and current drilling operations with
potential future operations. Consequently, this section does not adequately discuss cumulative impacts to
cultural resources.
Comments on Mitigation Measures
CR.1-2 & CR.1-3: Who determines if the Cone Trust House has to move or not? CR.1-1 specifies that
future oil development shall be located to avoid disturbances to the Cone Trust House.
CR.2-1: As written, this measure is impractical since facility construction and well development will
occur over many years. As a result a series of workshops will be required as additional or new crew
members are brought on board
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Co3Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DFtAFT ENVIRONMENTAL IMPACT REPORT
Section 4.13 Visual Resources and Aesthetics
Section 413.1 Environmental Setting
Page 4.13-4 Section 4.13.1.4 Public Views of the Proposed CSD Area
The assessment of public views does not include areas that are outside of the active field boundary but are
within the CSD boundary (i.e., south of SCE facilities). Views from these areas (i.e., Culver Crest) should be
evaluated in the visual assessment because they are potential view sites. In addition, the Draft E1R should
evaluate residential areas such as Raintree town homes and the Blair Hills neighborhood in Culver City
because of their proximity to the active field boundary.
Section 4.13.4 Analysis of Potential Future Oil Field Development
Page 4.13-27, Paragraph 2 [following Impact V.51, Sentence 2, Nighttime Lighting
This discussion concludes that Impact V.5 (Future oil field development could increase nighttime lighting
and glare) would be temporary, since drilling operations for new wells are of short duration. However, the
analysis should include a discussion of the long-term nighttime lighting effects from drilling new oil wells
over a 20-year period, which was identified in Section D of the Executive Summary and Section 3 of the
Project Description, as the timeframe for the analysis of future oil field development.
Page 4.13-23 Public Views
Mitigation Measures V.1-1 and V.1-3 require the preparation of a Landscaping Plan and re-vegetation and
screening plans. However, Mitigation Measures V.1-1 and V.1-3 should be modified to:
• Require the use of mature plants in revegetation and screening
• Require a timeframe during which revegetation must be completed
Please make the following modifications to the mitigation measures; text additions are shown in bold
italic, while suggested deletions are reflected in str-iketlifetigh.
Modified Mitigation Measure V.1-1. Landscaping shall be planted and maintained at the
periphery of the property for the specific purpose to beautify and screen the operations from
adjoining residential, recreational, institutional areas or adjacent public streets or highways. A
Landscaping Plan shall be prepared addressing screening, irrigation and planting protocols. Drip
irrigation and drought tolerant plants that are mature in size shall be used for landscaping. The
Landscaping Plan shall be prepared prior to the approval of a Site Plan Review, and its imple-
mentation and compliance monitored by a certified landscape architect. The plan shall be reviewed
and approved by the County of Los Angeles and adjacent and affected agencies.
Modified Mitigation Measure V.1-3. A revegetation and screening plan for new or deepened
well sites shall be submitted to and approved by the Director. The revegetation and visual screening
plans shall ensure that, within three months of upon completion of the drilling of a new or
deepened well, disturbed/graded terrain surfaces at the drill site shall be placed in a clean con-
dition and shall be landscaped with appropriate vegetation that is mature in size so as to screen
the sites from public view, the tanks and any other permanent equipment that may be installed.
Further, such landscaping shall be routinely inspected and be maintained in good condition.
In addition, the Draft E1R should have considered the use of low-profile drilling rigs and pumpers as a
way to reduce visual impacts to the surrounding communities. A comparison should be provided of
existing facilities and potential low-profile equipment/pumpers. The Draft EIR should include visual
simulations to clearly demonstrate and support the significance determination. An electronic data search
identified one corporation that specializes in low profile residential wells. Hydraulic Rod Pumps,
International (HRPI) utilizes subsurface hydraulic cylinders in place of conventional and mechanical rod
pumping units at locations that have surface and/or visual restrictions (Source: http://www.hrpi.net/) .
HRPI has installed low profile wells at the following locations:
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tiBaldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
• Kau man and Broad Homebuilders development that surround wells operated by Signal Hill Petroleum.
• Yorba Linda (Coyote Hills) oil field fee land (operated by Unocal Company of California) that was
sold to residential and real estate developers.
• City of Fullerton oil well that is operated by Unocal Company of California.
• Beverly Hills oil wells that are operated by Hillcrest Beverly Oil Corporation. These wells are across
the street from 20 th Century Fox Studios, and are surrounded by a private country club and golf course.
In the EIR, please evaluate the potential for using low-profile rigs and pumpers to reduce visual impacts
in the surrounding community. The following mitigation measure shall be applied field-wide to minimize
visual resource impacts resulting from the presence of aboveground equipment at new production sites:
V.1-6 Prior to construction, the oil field operator shall identify and document how it will use low-profile
equipment and pumpers to reduce visual impacts to the surrounding community. The operator
shall submit a proposed equipment list that identifies construction techniques and equipment,
which will minimize: (1) the height of new wells and drilling equipment, and (2) the aboveground
footprint of new well production sites. The equipment list shall be reviewed and approved by the
Director and incorporated in the plan. The plan shall include visual simulations that demonstrate
how use of low-profile equipment and pumpers, and/or vegetation and screening (as required by
Mitigation Measure V.1-1) reduce visual impacts to the surrounding communities and public
facilities. If vegetation is primarily used to reduce visual impacts then the plan must include long-
term provisions for maintaining the vegetation to effectively screen equipment and pumpers.
Section 4.13.6 Cumulative Analysis
Page 4.13-29, Cumulative Analysis
In Section 4.13.6, there is no discussion of the combined effect of past and current drilling operations with
potential future operations. Consequently, this section does not adequately discuss cumulative impacts to
visual resources. (See description of CEQA Guidelines for cumulative impacts in Section 4.12 Cultural
Resources.)
Comments on Mitigation Measures
V.5-1: Does not specify preparation of a Plan (see Table 6.1). Specify timing of plan preparation and
implementation. Remove "to the extent feasible" and add specific descriptive information such as "shall not
spill onto adjacent properties."
V.5-2: Recommend combining Mitigation Measures V.5-1 and V.5-2.
Section 4.14 Public Services and Utilities
Sections 4.14.1 through 4.14.6
Analysis of Public Services
Neither the environmental setting nor the impact analysis for Section 4.14 includes any discussion of
public services (e.g., police, schools, parks). The expansion of drilling activities within the project area
may require additional police protection from local jurisdictions, and impacts should be addressed
accordingly. The CSD would also be located adjacent to educational facilities (West Los Angeles College)
and parks (Kenneth Hahn State Recreation Area, Culver City Park), which should be included in the
analysis for public services. At the very minimum, this section should include a discussion of impacts that
pertains to the significance criteria for public services from the CEQA Guidelines (Appendix G,
Environmental Checklist Form, Section XIII).
43Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Section 4.14.4 Analysis of Potential Future Oil Field Development
Page 4.14-7, Impact PS.1
The discussion of solid waste impacts to utilities focuses solely on the effects of drilling operations. There
is no analysis of the solid waste impacts associated with the construction and operation of new facilities,
which may include: well slot manifolds and automatic well test units; oil cleaning plant; water treating
facility; water injection wells; and a vapor recovery skid. Future development of the project area may also
include a steam drive facility, which would necessitate the following equipment installations: new wells
and oil treatment plant; new gas treatment plant; new water treatment plant and water softening plant; and
new steam generation plan.
The solid waste impacts of new facilities that may be associated with the development of the project area
should be included in this analysis.
Page 4.14-8, Impact PS.2
The discussion of wastewater impacts to utilities focuses solely on the effects of drilling operations. There
is no analysis of the wastewater impacts associated with the construction and operation of new water-
related facilities, which may include: water treating facility; water injection wells; and a vapor recovery
skid. Future development of the project area may also include a steam drive facility, which would
necessitate the following equipment installations: new water treatment plant and water softening plant; and
new steam generation plan.
The wastewater impacts of new facilities that may be associated with the development of the project area
should be included in this analysis.
Page 4.14-9, Impact PS.3
The impact analysis for potable water focuses solely on the effects of drilling operations. There is no
analysis of water supply impacts associated with the construction and operation of new water-related facil-
ities, which may include: water treating facility; water injection wells; and a vapor recovery skid. Future
development of the project area may also include a steam drive facility, which would necessitate the
following equipment installations: new water treatment plant and water softening plant; and new steam
generation plan.
Impacts to the water supply from the construction and operation of new facilities that may be associated
with the development of the project area should be included in this analysis.
Section 4.14.6 Cumulative Analysis
Page 4.14-10, Cumulative Analysis
In Section 4.14.6, there is no discussion of the combined effect of past and current drilling operations with
potential future operations. Consequently, this section does not adequately discuss cumulative impacts to public
services and utilities. (See description of CEQA Guidelines for cumulative impacts in Section 4.12 Cul-
tural Resources.)
Comment on Mitigation Measure
PS. 1-1: Specify timing of Recycle Plan preparation and implementation.
Section 4.15 Energy and Mineral Resources
Subsection 4.15.1 Environmental Setting
Page 4.15-2, 4th full paragraph, last sentence
The last sentence states that the area currently has adequate supply of electricity and natural gas and is
anticipated to have adequate supplies for future development but provides no basis for these conclusions.
44
&CoBaldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Subsection 4.15.1.1 Energy and Mineral Resources Consumption by the Inglewood Oil Field
Facilities
Page 4.15-3, 1st and 3rd Paragraphs
This section of the Draft EIR does not site reference sources for the consumption data presented.
Section 4.15.4 Analysis of Potential Future Development
General Comments
Significance Criterion #2 (conflict with the adopted California energy conservation plans) has not been
addressed. Please include discussion of how the project would comply with requirements of California
energy conservation plans.
Page 4.15-6, 1st and 2nd Paragraphs
Impact ER.1 states that future development would double the current electrical consumption and that new
transformers would not be required, however no basis is provided for this conclusion. The analysis states
that this increase in electricity consumption is small compared to overall consumption in Los Angeles
County and the State of California and would therefore not require modifications to the current electrical
facilities, however it is not clear to what facilities this statement refers (e.g., onsite, local, county, or
state). Additionally, the fact that electrical demand of future development would represent a small pro-
portion of county or state consumption does not provide enough basis to determine whether onsite elec-
trical facilities would require modification.
Additionally, natural gas is not addressed under Impact ER.1 (although it is addressed under Impact
ER.2). It appears that the 4th significance criterion presented in Section 4.15.3 has been divided into two
separate impacts. It also appears that Impact ER.1 is intended to address both the 4th and 5th significance
criteria presented in Section 4.15.3. This makes it difficult for the reader to clearly determine whether
each significance criterion has been addressed.
Page 4.15-6, last Paragraph, Significance Criterion 1
Discussion under Impact ER.2 indicates that the project would result in a net increase of petroleum and
natural gas. Minerals are not addressed in the analysis, however, they are addressed in the environmental
setting. Please include discussion in the analysis section addressing minerals and associated impacts from
the project.
Pages 4.15-6 and 4.15-7, Significance Criterion 3
Although discussion under Impact ER.2 indicates that future development would result in net increases of
non-renewable energy resources, Significance Criterion 3 (Use of non-renewable energy resources in a
wasteful and inefficient manner) is not addressed. Please include discussion of how these resources would
be used, if at all.
Section 4.15.5 Analysis of Proposed CSD
Page 4.15-7, Last Paragraph
At minimum, the CSD should include measures to ensure future projects would not conflict with con-
servation plans as well as measures to promote efficient energy use during construction and operation of
future projects.
Section 4.16 Environmental Justice
Section 4.16.1 Environmental Setting
Page 4.16-2, Paragraph 5, Sentence 1 (and throughout text)
All references to the minority population "Black" (or "black') should be replaced with "Black or African
American," consistent with the minority classification system used by the U.S. Census Bureau.
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6 7Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Page 4.16-4, Table 4.16-1, Study Area Race Characteristics
To better help the reader understand the distribution of minority populations within the Study Area, please
provide the percentages of each minority category as well as their total number.
Page 4.16-5, Figure 4.16-2, Distribution of Poverty in the Study Area
Several block groups contain a below poverty level population of greater than 15 percent; however, no
indication is provided as to whether these areas contain a below poverty level of greater than 50 percent,
which is the threshold for analysis of Environmental Justice. Consistent with Figure 4.16-1, this figure (4.16-2)
should reflect population percentages between 0 and 100.
Section 4.16.3 Significance Criteria
The first impact significance criterion used for this analysis follows the same significance criterion
applied by the California State Lands Commission (CLSC) (e.g., "Have the potential to
disproportionately impact minority and/or low income populations at levels exceeding the corresponding
medians for the county in which the Project is located'). However, as defined by the "Final Guidance for
Incorporating Environmental Justice Concerns in EPA's NEPA Compliance Analysis," minority and low-
income populations may also be defined as being any minority or low income population that is greater
than 50 percent of a project area's general population. The threshold of 50 percent or greater of the
affected area is the impact criteria applied by several State agencies, including the California Energy
Commission (CEC); typically, a radius ranging between one to six miles of a proposed project is used by
the CEC. Based on the data provided in Figure 4.16-1, Table 4.16.1and Figure 4.16-2, it appears that if
the impact criterion of 50 percent or greater for minority and low income populations was applied to the
study area, potentially significant Environmental Justice impacts could occur.
Section 4.16.4 Analysis of Potential Future Oil Field Development
As noted under the comment for Section 4.16.3 (Significance Criteria), above, if the following impact
criterion was used in the Environmental Justice impact analysis, a potentially significant impact could
occur:
"The minority or low-income population of the affected area is greater than 50 percent of the
affected area's general population."
For the EIR to fully disclose any potentially significant Environmental Justice impacts, the above
criterion should be applied to the impact analysis.
Section 5.0 Alternatives
Section 5 evaluates action alternatives that relate to other permit process scenarios such a Conditional Use
Permit process and Site Plan Review with Director Approval. While these are valid permit alternatives,
the discussion did not present a reasonable range of alternatives as required by CEQA. In order "to reduce
the environmental effects of future oil development" (as stated on page 5-2 paragraph 5), the analysis
must consider a reasonable range of alternatives. Alternatives that should be addressed in the analysis are
listed below, however, other alternatives should also be identified and considered to meet the intent of
CEQA.
? The analysis should have considered changes to the regulations of the CSD to consolidate surface
facilities and activities within designated areas of the field to reduce public health and environmental
impacts to the neighboring communities and public facilities (school and park). As a separate
alternative or part of this alternative, phasing out of existing facilities or the limited operation of
existing facilities to reduce impacts should be evaluated.
O The No Project Alternative should have also included consideration of ongoing energy conservation
measures to replace the oil and gas production with projects such as solar energy, energy conservation
46
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COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
and alternative energy sources, making automobiles more fuel efficient, replacing equivalent fuel with
ethanol, and making existing power generation facilities more efficient.
Section 6M Mitigation Monitoring Program
In addition to the changes suggested in the individual issue area sections, please also add the following to
Table 6.1 of the Mitigation Monitoring Program:
• Add a method of verification (MOV) to all mitigation measures (i.e., review and approval of devel-
opment plans and inspection of site).
• Add timing for completion of mitigation measures to all measures (i.e., prior to construction or prior
to agency approval).
• PH.2-1: Add "Review and approval of HRA and any proposed buffer zone decreases by the County
of Los Angeles and adjacent and affected agencies."
• BR. 1-1: Monitoring/Reporting Action and MOV address site surveys, not preparation and imple-
mentation of Plan (see mitigation measure). Under Responsible Agency add USFWS and CDFG as
plan review and approval agencies.
• BR.1-2: Monitoring/Reporting Action addresses mitigation ratios only and not plan preparation and
implementation (see mitigation measure).
• BR.1-3: Monitoring/Reporting Action: "BR.1 -1" should be corrected to "BR.1-2."
• BR.2-1 a, b: Amend to state "Review surveys and Restoration Plan implementation." Responsible
Agency: Add USFWS and CDFG coordination for special status species.
• N.1-2 and N.5-1: Monitoring/Reporting Action: Define "periodic."
• N.2: Monitoring/Reporting Action: Add reference to Mitigation Measures N.1-1 and N.1-2.
• N.5-2: add "Test vibration or low-frequency noise levels at the oil field perimeter as specified by the
County."
• V.1-1: Monitoring/Reporting Action: "Landscape, Revegetation and Screening Plan" specified, not
"Landscaping Plan" as specified by Mitigation Measure V.1-1.
• V.1-4: Monitoring/Reporting Action: Specify "within 30 days of installation: as noted by the miti-
gation measure.
• V.1-5: Monitoring/Reporting Action: Specify "within 120 days of CSD approval" as noted by the miti-
gation measure. Under MOV specify "Review and approval of plan..."
Section 7.0 Other CEQA Considerations
Section 7 needs substantially more detail to address direct and indirect growth-inducing impacts and
irreversible commitment of resources. For irreversible commitment of resources, CEQA Section 15126.2
states that resources should be evaluated to "assure that such current consumption is justified." CEQA also
states that analysis should consider both primary and secondary impacts from the commitment of resources.
Additional detail is necessary to adequately address the commitment of resources and growth-inducing
impacts. The discussion does not discuss indirect impacts and does not address impacts to open space
areas such as the park and the Baldwin Hills Master Plan. In addition, the discussion includes
consideration of the development of open space but does not address encroachment as identified in the
criteria identified in the section. Further, the discussion of Precedent Setting Action does not provide
47Baldwin Hills Community Standards District
COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
sufficient detail on why the adoption of the CSD, which will facilitate the approval of well permits, would
not be precedent setting. This section needs substantially more detail to meet the intent of CEQA.
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COMMENTS ON THE PUBLIC DRAFT ENVIRONMENTAL IMPACT REPORT
Table of H 2S Exposure Standards and Physiological Responses
Level, PPM Effect Source
0.003-0.11 24-hour exposure criteria World Health Organization, Environmental
Health Criteria, 1982
0.003 Odor Threshold Environment Canada, 1984
0.005 30 minute averaging time, level to avoid complaints due to odor
annoyance
World Health Organization, 1984
0.007 30 minute averaging time, Level to not produce odor nuisance Task Form on International program on
Chemical Safety, 1981
0.007 Proposed inhalation reference exposure level (REL), Chronic toxicity OEHHA Proposed REL, 1999, 0.66 ppm
with 100 factor of safety
0.008 Geometric mean odor threshold based on odor detections ranging
from 0.0007 to 1.8 ppm
Amoore, 1985
0.012-0.069 Range of odor thresholds for study group, geometric mean of 0.029 California State Department of Health,
1969
0.03 1-hour averaging time California Ambient Air Quality Standard
0.03 Chronic and Acute toxicity value CAPCOA Health Risk Assessment,
AB2588 chronic and acute REL
0.03 Estimated 40% of population would find objectionable. Some
reported headaches and other symptoms
Amoore, 1985, Reynolds and Kemper,
1985
0.09 Minimal Risk Level, Intermediate Exposure (15-364 days) ATSDR, 1997
0.1 60 minute exposure, no objectionable odor ERPG-1, AIHA, 1990
0.1 Mild adverse effects OEHHA, Jappinen et al. (1990)
0.3 Distinct odor Environment Canada, 1984
0.3 Complaints of nausea, headaches, eye and throat irritation. Terra Haute, Indiana, US Health Service,
1964
0.6 2-month average, 20-month-old child symptoms included deviation
of the eyes, motor skills failures. Complete resolution when exposure
ceased
Department of Surgical Neurology,
Edinburgh, 1986
0.66 Extrathoractic respiratory effects, based on mouse studies, human
equivalent
OEHHA Proposed REL study, 1999
1 24 hr/day for 90 days continuous exposure guideline level NAS/NRC, 1985
10 8 hr exposure (time weighted average, TWA) ACGIH
10 8 hr TWA permissible exposure limit (P EL) OSHA
10 10 minute allowable maximum value (ceiling) NIOSH
10 24 hr emergency exposure guideline level (EEGL) NAS/NRC, 1985
10-14 4 — 7 hr exposure, Conjunctivitis Nesswetha, 1969
15 15 minute TWA short term exposure limit (STEL) ACGIH
15 15 minute TWA STEL OSHA
30 60 minutes, no irreversible or serious health effects ERPG-2, AIHA, 1990
50 10 minute EEGL NASINRC, 1985
50 Level at which evacuation is required NIOSH
50-100 Olfactory paralysis after 3 to 15 minutes ACGIH, 1986, Beauchamp, 1984
100 60 minutes, no life threatening health effects ERPG-3, AIHA, 1990
100 30 minutes, no life threatening health effects IDLH
200 Almost immediate olfactory paralysis, stings eyes and throat Beauchamp, 1984
300-500 Pulmonary edema, imminent threat to life Beauchamp, 1984
500 30 minute to 1 hour exposure, headache, dizziness, staggering
followed by unconsciousness and respiratory failure
Beauchamp, 1984
700 Unconscious quickly, death if not rescued promptly Beauchamp, 1984
1000 Rapidly produces unconsciousness, respiratory failure and death Beauchamp, 1984
5000 Imminent death Beauchamp, 1984
*0,001 ppm is equivalent to 1 ppb (part per billion)
Source: Arthur D. Little (now Marine Research Specialists), 2000. VENOCO Quantitative Risk Assessment. Prepared for Santa Barbara County
Fire Department.
49
7/August 2008
Attachment 2 to Exhibit "A"
of Resolution No. 2008R
Statement of Qualifications
1. Qualifications and Experience
Aspen Environmental Group is a leader in the provision of professional environmental and engineering
services to local, state, and federal agencies responsible for building or reviewing large energy, water, and
infrastructure projects. Aspen currently serves as prime contractor to the California Energy Commission,
California Public Utilities Commission, Western Area Power Administration, Los Angeles Department of
Water and Power (LADWP), California Department of Water Resources, Ventura County Watershed
Protection District, and US Army Corps of Engineers. In addition, Aspen has worked for the California
State Lands Commission and the Department of Conservation's Division of Oil, Gas, and Geothermal
Resources (DOGGR) in the CEQA evaluation of petroleum projects.
1.1 Oil and Gas Experience
Aspen focuses on the analysis of infrastructure projects for public agencies, with a particular emphasis on
energy projects, including pipelines, power plants, marine terminals, transmission lines, and renewable
energy projects. Aspen also has a long history of conducting analysis of oil and gas projects, including
exploration, transportation, refining, and storage. Listed below is a summary of Aspen's experience related
to oil and gas.
• PXP Tranquillon Ridge Oil & Gas Development Project EIR, County of Santa Barbara
• Kinder Morgan Concord-to-Sacramento Pipeline ER, California State Lands Commission
• Environmental Information Document and Coastal Consistency Determinations for Federal Oil and Gas Leases
Offshore Santa Barbara, Ventura, and San Luis Obispo Counties, Minerals Management Service, U.S.
Department of the Interior
• Cabrillo Port LNG Deepwater Port EIS/EIR review, City of Oxnard
• Kirby Hills Natural Gas Storage Facility MND, California Public Utilities Commission
• City of Long Beach LNG Import Project EIS/EIR review, City of Long Beach
• Kinder Morgan Carson-to-Norwalk Pipeline EIR
• Yellowstone Pipeline Reroute EIS, USDA Forest Service, Lob o National Forest
• Pacific Pipeline Project FIR and Supplemental EIS/SEIR
• Gaviota Interim Marine Terminal/Chevron Tankering Supplemental E IR/EIS, County of Santa Barbara
• Exxon Tankering Application from Gaviota (proposal withdrawn) Subsequent FIR, County of Santa Barbara
• Hermosa Beach Urban Oil/Gas Development (CEQA Process Consultant), City of Hermosa Beach
• Kern County Oil and Gas Well Permitting Environmental Compliance and Permitting Process (CEQA Process
Consultant), Division of Oil, Gas, and Geothermal Resources
• Molino Gas Project EIR (air quality, land use, public policy, and recreation analyses), Arthur D. Little
• Alpine Gas Transmission Line, Mitigation Monitoring Services, California Public Utilities Commission
• San Joaquin Refinery Health Risk Assessment, San Joaquin Refining Company
1.2 Experience Reviewing EIRs Prepared by Others
Since its inception, Aspen has served as prime contractor for some of California's largest environmental
review efforts and continues to serve in this role on major CEQA and NEPA projects, as well as similar
large environmental assessment efforts, such as the California Energy Commission's CEQA-equivalent
process for reviewing proposed thermal power plant projects. In its role as prime contractor, Aspen
continually reviews environmental and technical documents produced by others, including the work
products of subcontractor teams. Aspen must also regularly review environmental and technical documents
submitted by applicants to regulatory agencies and, on behalf of those agencies, provide comments on the
adequacy and completeness of those submittals. This includes Proponent's Environmental Assessments
9_,Statement of Qualifications
submitted to the California Public Utilities Commission and Applications for Certification submitted to the
California Energy Commission, as well as other supporting documentation.
Aspen is trusted by resource and regulatory agencies to provide objective independent reviews of
environmental documents and has been contracted by multiple agencies specifically to review EIR and EIS
documents and technical reports prepared by others. Aspen is recognized not only for objective judgment,
but also for our technical knowledge of environmental issues and in-depth working knowledge of
environmental regulations and procedures. Summarized below are three examples of Aspen's role reviewing
environmental documents produced by others:
• Aspen was hired by the California Department of Fish and Game (CDFG) to participate in a multi-year process
to develop and review a large EIR/E1S being prepared for the Newhall Ranch Resource Management and
Development Plan and Spineflower Conservation Plan. Aspen is providing CEQA compliance guidance to
CDFG, which is serving as the CEQA lead agency. Newhall Ranch is a major land development project in the
Santa Clara Valley, encompassing 11,999 acres and approved for the development of 21,308 dwelling units and
982 acres of non-residential uses. The developer is seeking a master Streambed Alteration Agreement and
Section 2081 Incidental Take Permits for the project, as well as a master Section 404 permit from the Army
Corps of Engineers. The applicant is preparing the EIR/EIS under guidance from CDFG and the Army Corps of
Engineers. Aspen has been involved in all aspects of the EIR/EIS development, including selection of
alternatives, and is reviewing and editing the administrative draft EIR/EIS document on behalf of CDFG.
• Aspen was retained by the City of Oxnard to review the Draft EIR/EIS for the Cabrillo Port LNG Deepwater
Port EIR/EIS. Cabrillo Port is a highly controversial proposal to construct a liquefied natural gas (LNG) port
off the coast of Oxnard and Malibu. Because the City of Oxnard and its citizens were concerned about the
project, the City asked Aspen to review the Draft E1R/EIS and present comments to the City Council. The City
used Aspen's input to provide comments on the Draft EIR/EIS to the lead agencies. The City also hired Aspen
to review the re-circulated Draft EIR/EIS and participate in public workshops on the project.
• Aspen was hired by the City of Long Beach to review the Draft EIR/EIS for a proposed Sound Energy
Solutions Long Beach LNG Import Project at the Port of Long Beach. Aspen was approached by the City
because of its reputation conducting environmental analysis of major energy projects. Aspen conducted a
review of the document for CEQA and NEPA adequacy and technical accuracy. Aspen provided comments to
the City, which then utilized Aspen's input to provide comments on the Draft EIR/EIS to the lead agencies.
2. Project Management and Key Personnel
Aspen's team members are comprised of a broad cross-section of experienced professionals in engineering
and the physical, earth, life, and social sciences, which is complemented by the expertise of specialized
subcontractors with appropriate capabilities in data collection and analyses for environmental impact
assessment documents and supporting environmental documentation. The following is a brief biography of
the Aspen Team members and subcontactors who contributed to the review and evaluation of the Baldwin
Hills CSD and Draft EIR. Please refer to the attached resumes for further detail on individual project
management and CEQA/NEPA experience.
Aspen Team Members
Sandra Alarcon-Lopez
is serving as Aspen's Project Manager for the review of the Draft EIR and CSD.
Ms. Sandra Alarcon-Lopez has been with Aspen since 1999 and has over 24 years of experience managing
environmental projects and programs including experience conducting environmental impact analysis
pursuant to CEQA and NEPA. Ms. Alarcon-Lopez has significant experience as a project manager for local
and regional government projects. She has managed the preparation of and effectively completed technical
evaluations for major transmission line projects proposed in California and Arizona and has managed the
preparation of energy-related reports for the California Energy Commission. Ms. AlarcOn-Lopez has
significant oil and gas experience through her work as a land use planner for the Energy Division of the
County of Santa Barbara. She has recently completed technical evaluations for several major transmission
line projects, and has managed the following energy and/or utility projects: LNG EIR/EIS Document
August 2008 2'Aspen:
lvJ-
August 2008 3
Statement of Qualifications
Review for the City of Oxnard; Assessment of Well Permitting Compliance for DOGGR; and the Lower
Reach and Upper Reach Water Pipeline Project EIRs for LADWP.
William Walters, PE, is a chemical engineer with 19 years of experience conducting air quality
assessment for infrastructure projects under CEQA and NEPA. He is an expert in developing emissions
inventories (criteria and air toxic pollutants), dispersion modeling, regulatory compliance review, and
development and implementation of technically feasible mitigation measures. Mr. Walters prepared the Air
Quality section of the Environmental Information Document in support of the Coastal Consistency
Determinations for the suspension of operation requests for undeveloped units and leases off the central
California coast. Mr. Walters characterized and quantified air emissions for offshore oil and gas
development activities associated with federal oil and gas Lease Sale 95 for the US Minerals Management
Service. In addition, he prepared comments on the Air Quality, Alternatives, Marine Traffic, Public Safety,
and Noise section of the Cabrillo Port Liquefied Natural Gas Deepwater Port Draft EIS/EIR for the City of
Oxnard.
Chris Huntley has 15 years of experience conducting and managing biological assessments, large-scale
construction and restoration projects, comprehensive vegetation mapping, sensitive species surveys, and
revegetation plans for projects throughout southern California. Mr. Huntley understands the regulatory
environment and is familiar with the mechanisms involved in compliance with both the federal and
California Endangered Species Acts. With extensive experience in managing large construction projects,
Mr. Huntley has unique experience in resolving conflicts and ensuring compliance with environmental
regulations. Supported by a solid background in biological resources, experience in completing CEQA
analysis, and over a decade of construction management experience, he works closely with resource agency
personnel, contractors and affected jurisdictions to ensure that projects are conducted in compliance with
applicable laws, regulations, and standards.
Sue Walker is a land use planner with over 18 years of experience in preparing environmental impact
assessments for compliance with CEQA and NEPA, which has included analysis of several oil and gas
development projects. She served as the Project Manager for the MIVIS Environmental Information
Document for Post-Suspension Activities of the Nine Federal Undeveloped Units and Lease OCS-PO409
Offshore Santa Barbara, Ventura, and San Luis Obispo Counties. In addition she was the Assistant Project
Manager for the California Off-shore Oil and Gas Energy Resources study and prepared the Santa Barbara
North County Siting Study for the County's Energy Division.
Jason Ricks has over 10 years of professional environmental science and health and safety experience. He
specializes in NEPA and CEQA project management and documentation with particular expertise in traffic
and transportation, environmental contamination, and hydrology analysis. Mr. Ricks currently serves as
Project Manager for the Port of Los Angeles Channel Deepening Project EIS/EIR and the LADWP
Distribution Station No. 144 Project IS/MND. He has performed environmental analyses for several
transmission and solar energy projects.
Vida Strong has 21years of experience managing and preparing environmental documents for numerous
industrial projects, including pipeline, transmission line, and fiber optic networks, which required the critical
application of alternatives development and screening criteria, knowledge of a broad range of issue areas,
and extensive local, state, and federal agency coordination. She recently managed the preparation of an EIR
evaluating PXP's proposed Tranquillon Ridge oil and gas development project in Santa Barbara County.
Prior to joining Aspen, Ms. Strong was an Energy Specialist for Santa Barbara County's Energy Division,
where she oversaw the permitting and environmental review of major oil and gas development projects and
proposals, and oversaw the implementation of mitigation monitoring plans. Additional project experience
includes the Chevron's Pt. Arguello oil and gas processing facility; Mobil Clearview Project; and Mobil
Ellwood Oil and Gas Processing Plant/Marine Terminal.
Scott Debauc he has 10 years of experience as an environmental planner, and specializes in the analysis of
land use, socioeconomics, and public policy for large-scale infrastructure and development projects. His
experience in conducting environmental impact assessments for energy and/or utility projects include theAugust 2008 4
Statement of Qualifications
following: PG&E's Proposed Divestiture of Hydroelectric Assets Draft FIR; Looking Glass Networks Fiber
Optic Cable Project IS/1VIND; SDG&E Miguel Mission Substation Draft EIR; as well as several Staff
Assessments for the California Energy Commission.
Philip Lowe, PE, is a senior engineer and project manager with 28 years experience in the hydrologic
analysis of watersheds; surface water hydraulic analysis; channel erosion and sedimentation analysis; design
of flood control and erosion control structures; plan formulation and feasibility including benefit/cost
analysis; environmental impact analysis; US Army Corps of Engineers 404 Permitting; and habitat
restoration and enhancement. Mr. Lowe prepared the water resources analyses for numerous energy-related
projects, which include: Crude Oil Pipeline Investigations and Hydraulic and Hydrologic Analyses of Oil
Spill Sites for Counties in the States of Missouri, Kansas, and Texas; Kinder Morgan Concord to
Sacramento Pipeline EIR; Pacific Pipeline EIS/SEIR; Yellowstone Pipeline EIS; San Vicente Reservoir
Pipeline EIR; Sunrise Powerlink Transmission Line EIR; Devers/Palo Verde Transmission Line FIR;
SONGS/Diablo Canyon Steam Generator Replacement Project FIR; Viejo System Project Transmission
Line FIR; as well as Final Staff Assessments for the California Energy Commission.
Aspen Team Subcontractors
James Thurber, RG, CEG, CHG, of Geotechnical Consultants, Inc., is a geotechnical engineer with over
25 years of experience and an in-depth knowledge of the development, protection, and management of
municipal groundwater resources. Mr. Thurber is actively involved in the engineering geology,
hydrogeology and hazardous material assessments for numerous local and regional environmental impact
reports. Mr. Thurber's FIR experience includes long linear pipelines, new power plants, highways, and large
redevelopment projects. He is experienced with hazardous waste investigations and site characterization for
leaking underground fuel tanks, industrial facilities and solid waste landfills.
Jay Sheth, PE, of Robert Brown Engineers, is a chemical engineer with over 36 years experience in
process risk assessment and evaluation, project management, process design, facilities revamp, plant
construction, start-up and environmental permit management. He has provided safety review of oil and gas
projects for the County of Santa Barbara since 1984, and his work has included reviewing process and
mechanical design; HAZOPS; risk assessments; corrosion control, monitoring, inspection and maintenance;
EIRs; relief system; startup and commissioning procedures; operating procedures; electrical area
classifications; handling of hazardous and toxic chemicals; safety regulations; emergency shutdown systems
and other safety related systems. Specific county projects include: PXP's (formerly Chevron) Pt. Arguello
Project; Phillips' Tajiguas Gas Plant Modification; Shell Molino Gas Plant Expansion; PXP's (formerly
Unocal) Pt. Pedernales Project; ExxonMobil Santa Ynez Project; All American Pipeline Project; Texaco
Gaviota Marine Terminal; E&B Natural Resources' (Formerly ARCO) South Cuyama Project; POPCO's
Gas Plant Expansion; Venoco's (formerly ARCO/Mobil) Ellwood Oil & Gas Treating Facility, Ellwood
Marine Terminal and Platform Holly; Unocal/Nuevo's (now PXP) Gas Plant; Malin° Energy's Gas Plant
Project; Greka's (formerly Conoco) Santa Maria Asphalt Refinery; and ConocoPhillips' (formerly Unocal)
Pipelines and Pump Stations.Aspen
Enaironmentai Group
SANDRA ALARCON-LOPEZ
Senior Associate
ACADEMIC BACKGROUND
M.A., Architecture & Urban Planning, University of California, Los
Angeles, 1982
B.A., Speech and Hearing Sciences, University of California, Santa
Barbara, 1980
PROFESSIONAL EXPERIENCE
Ms. AlarcOn-Lopez has over 24 years of experience managing environmental projects and programs
including experience conducting environmental impact analysis pursuant to California Environmental
Quality Act (CEQA) and National Environmental Policy Act (NEPA). She has effectively managed small
and large projects ranging from environmental studies to major public involvement programs to
environmental restoration programs. She prepared, adopted, and implemented general plans and elements
for the City of Whittier, County of San Bernardino, and County of Santa Barbara. Ms. Alarcon-Lopez has
significant experience as a project manager for local and regional government projects and in managing
and carrying out public participation activities. Ms. Alarcon-Lopez has managed the preparation of and
effectively completed technical evaluations for major transmission line projects proposed in California
and Arizona and has managed the preparation of energy-related reports for the California Energy
Commission. She also has significant oil and gas experience through her work as a land use planner for
the Energy Division of the County of Santa Barbara.
Aspen Environmental Group 1999 to present
At Aspen Environmental Group, Ms. Alarcon-Lopez is a project manager responsible for working with
in-house and contract personnel to complete environmental analyses on federal, state, and local
government projects. Her projects include:
• Project Manager for LNG EIR/EIS Document Review, City of Oxnard. Managed the technical
and procedural review of the Cabrillo Port Liquefied Natural Gas Deepwater Port Project draft
environmental report. The review included the 2004 Draft EIR/EIS and a second review in April 2006
of the revised draft. The scope of work involved reviewing all issue areas addressed in the draft
documents and preparing comments regarding the adequacy of the document for the City of Oxnard.
Aspen's senior technical staff provided input to this review. All comments for each review (one in
2004 and the second in 2006) were consolidated into a review/comment white paper. The City used
the review/comments as part of their formal comments submitted on the Draft EIR/EIS and Revised
Draft EIR (the EIS was not recirculated).
Project Manager for Assessment of Well Permitting Compliance. Project Manager for the
preparation of an assessment report that analyzed the Department of Conservation, Division of Oil.
Gas, and Geothermal Resources' (Division) compliance with the CEQA. The assessment considered
lead and responsible agency roles, applicable regulatory processes, environmental compliance, and oil
and gas well permitting processes in Kern County. The report provided program options to the
Division regarding measures that could be taken to bring their existing well permitting practices into
compliance with CEQA. This assessment included consideration of over 37 plans, regulatorySANDRA ALARCON-LOPEZ, page 2
documents, and reports; contact with industry groups, environmental organizations, and other
interested parties; and five workshop-type meetings with interested parties to obtain input into the
report and its conclusions. This was a highly controversial project with significant concern from
interest groups and the oil and gas industry. Phase II included an evaluation of regulatory changes
needed to bring the Division's program into compliance with CEQA and preliminary environmental
assessment to determine how changes were evaluated with regard to CEQA.
Project Manager for the Lower Reach and the Upper Reach Water Pipeline Projects EIRs for
the Los Angeles Department of Water and Power (LADWP). Project Manager for preparation of
two EIRs for the LADWP's Lower Reach River Supply Conduit Pipeline project and the River
Supply Conduit Improvement — Upper Reach project. The original linear project covered a 13.3-mile
alignment that crossed the City of Los Angeles and City of Burbank jurisdictions. After completion of
the Administrative Draft FIR, the project was changed to address the Lower and Upper Reaches
separately, therefore the first EIR dealt with only 7 miles of the original route. The revised project
only covered property within the City of Los Angeles. The project involved the replacement of an
existing pipeline with a new pipeline in a new alignment. The project involves the construction of 48-
, 60-, 66-, 72-, 84-, and 96-inch diameter welded steel underground pipeline. The Lower Reach Initial
Study and the Notice of Preparation were completed and released in August 2004. The Draft FIR was
released in May 2005 and the Final EIR was released in December 2005. Also, as part of the Lower
Reach project, Ms. Alarcon-Lopez managed the preparation of a specialized noise study to determine
the impact of the regulator station noise on an adjacent cemetery property and prepared a tree survey
that identified more than 1,500 trees in Griffith Park (a major regional park in the City of Los
Angeles) that had the potential to be impacted by the project. Ms. Alarcon-Lopez has completed the
focused E1R for the Upper Reach, which involves the placement of a 78-inch diameter water pipeline in
the cities of Los Angeles and Burbank. The NOP/IS was released for public review on January 25, 2007
and the Draft EIR in March 2008.
Public Involvement Manager for Sunrise Powerlink Project (EIR/EIS) for the California Public
Utilities Commission (CPUC). Ms. Alarcon-Lopez is responsible for managing the work of in-house
and subcontractor staff to complete the extensive public involvement effort for the Sunrise Powerlink
Environmental Impact Report/Environmental Impact Statement (EIR/E1S). This project, proposed by
San Diego Gas Sz Electric Company, includes the construction and operation of a highly controversial
150-mile 500-kV and 230-kV transmission line from Imperial County near El Centro to the City of
San Diego. For public scoping, over 200 comment letters were received, reviewed, and summarized;
seven public scoping meetings were carried out; and eight newspaper advertisements were placed for
this project. She managed the preparation of an 800-page scoping report that outlined all verbal and
written comments submitted on the project during the public scoping process, and documented all
notices and advertisements. Ms. Alarcon-Lopez also completed a second scoping report to document
the written and oral comments presented during the second phase of public meetings to gather input
on the project alternatives. For this second phase, eight public meetings were noticed in eleven
newspapers. For the Draft EIRJEIS, nine public meetings were held over a one-week period to take
public comments on the conclusions of the Draft EIR/EIS.
• Public Involvement Manager for Tehachapi Renewable Transmission Project (TRTP)
(EIRJEIS) for the CPUC. Ms. Alarcon-Lopez is responsible for managing the work of in-house and
subcontractor staff to complete the extensive public involvement effort for the TRIP EIR/EIS. This
project, proposed by Southern California Edison, includes the construction and operation of a major
transmission line that would cross the counties of Kern, Los Angeles, and San Bernardino as well as
17 cities and the Angeles National Forest. For public scoping, Ms. Alarcon-Lopez managed
subcontract staff to identify and schedule the public scoping meetings. She also worked with in-house
and contract staff in preparing a scoping report for this project. As part of the scoping report, Ms
Alarcon-Lopez prepared a comment analysis using the Forest Service approach in consolidating,
rtnSANDRA ALARCON-LOPEZ, page 3
categorizing, and assessing all of the comments received on the project. The comment analysis
considered 249 written comment letters and oral comments from 53 individuals received at the nine
public scoping meetings. In addition, she prepared newspaper notices that were placed in 15
newspapers including Spanish, Korean, and Chinese language newspapers. She prepared a Notice of
Preparation that was mailed to about 15,000 property owners, agencies, and other interested parties.
She prepared a post card notice that was sent to contacts on the mailing list and a poster notice that
was placed in over 100 locations along the proposed project route.
Public Involvement for El Casco System Project (EIR) for the CPUC. Ms. Alarcon-Lopez worked
on the public involvement effort for this electric subtransmission line and associated
telecommunications systems project proposed by Southern California Edison in San Bernardino and
Riverside Counties. She coordinated the scheduling, set up, and noticing of the public scoping meetings.
In addition, she prepared the scoping report that documented the public and agency comments received
on the project, and she coordinated the public meetings for the Draft EIR as well as all noticing.
? Land Use Analyst and Public Involvement Manager for Antelope Pardee 500-kV Transmission
Project (EIR/EIS) for the CPUC. Ms. Alarcon-Lopez prepared the land use impact analysis for the
evaluation of the 25-mile transmission project proposed by Southern California Edison in Los Angeles
County. The land use analysis was prepared as part of the EIRJEIS for the project and covered local
jurisdictions and federal land under the jurisdiction of the U.S Forest Service. Ms. Alarcon-Lopez
prepared the public participation plan for the project and managed the preparation of an extensive
mailing list for the project, coordinated the logistics of public meetings for scoping and the Draft
EIR/EIS, coordinated all noticing efforts, and managed the preparation of the scoping report that
outlined all verbal and written comments submitted on the project during the public seeping process.
• Public Involvement Manager for the Antelope Transmission Project (EIR), Segments 2 and 3
for the CPUC. Ms. Alarcon-Lopez was responsible for coordinating the public involvement associated
with the Antelope Transmission Project DR. The project included construction and operation of a new
56.7 mile 220-kV and 500-kV transmission line in Kern and Los Angeles County. She managed the
preparation of an extensive mailing list for the project, coordinated the logistics of public meetings for
scoping and the Draft EIR, coordinated all noticing efforts, and managed the preparation of the seeping
report to document the scoping process, and managed the text write ups of public involvement efforts in
the Draft and Final EIR.
• Land Use Analyst and Public Involvement Manager for Devers Palo Verde 500-kV
Transmission Project (EIR/EIS) for the CPUC. Ms. Alarcon-Lopez prepared the land use impact
analysis for the evaluation of the 230-mile transmission project proposed by Southern California Edison
in Southern California and Arizona. The land use analysis was prepared as part of the EIR/EIS for the
project and covered local jurisdictions and federal land under the jurisdiction of the U.S Bureau of Land
Management. She also reviewed and managed the preparation of the wilderness and recreation and
agricultural sections of the report. Ms. Alarcon-Lopez prepared the Policy Screening Report that
evaluated the project's consistency with over 33 land use or resource management plans. The Policy
Screening Report was a major appendix report in the EIR/EIS. She was also responsible for planning
and carrying out the public notification and involvement effort on the project. As part of this role, she
prepared the Public Involvement Plan, two Seeping Reports, and coordinated the conduct and noticing
of eight public seeping meetings for the NOP as well as four informational workshops and three public
participation hearings for the Draft EIRJE1S.
• Principal Author of Imported Electricity Report for the California Energy Commission (CEC).
Ms. Alarcon-Lopez was the principal author of A Preliminary Environmental Profile of California's
Imported Electricity, June 2005. This report was prepared in support of the 2005 Environmental
Performance and 2005 Integrated Energy Policy Report (Docket 04-IEP-I). Ms. Alarcon-Lopez
conducted extensive website and agency research regarding coal generated electricity and worked withSANDRA ALARCON-LOPEZ, page 4
CEC staff to develop the out-of-state Designated Coal power plant profiles. She also worked closely
with other contributing authors to obtain information on out-of-state hydropower, gas, nuclear and
renewable energy resources. The report addressed air quality, biological resources, and hydrological
resource impacts from out-of-state energy. The report included information on electricity capacity and
generation for the ten US western states considered in the report and provided electricity trends for the
US western states, western Canada, and northern Mexico. She worked with CEC staff to finalize the
report and participated in hearings to present the report to the Commission.
• Project Manager for Environmental Assessment/Biological Assessment/Mitigation Plan for
Proposed Border Patrol Facilities in San Diego. Project manager for this U.S. Army Corps of
Engineers and U.S. Immigration and Naturalization Service (INS) project. For the Environmental
Assessment/Biological Assessment, Aspen conducted a field biological survey to confirm plant and
animal species on the project and alternative sites. Soil samples were collected and analyzed to assess
the potential for contamination prior to development of vehicle maintenance facilities for the INS. A
Mitigation Plan was also prepared to outline the mitigation measures associated with the project, the
options with regard to mitigation fee potential, and to identify responsible agencies and the overall
implementation strategy.
• Project Manager for Comparative Evaluation Report and Environmental Assessment for the
Tucson Drainage Area Detention Basin Complex in Tucson, Arizona.
Project Manager for the
preparation of both the Comparative Evaluation Report and the Environmental Assessment. The
Comparative Evaluation addressed two proposed designs for the basin complex. The report included
an assessment of environmental outputs (mitigation and restoration), grading plan differences, and the
incremental costs associated with the proposed changes to an approved plan. The evaluation of the
habitat value of each plan was a key component in this evaluation. This assessment was considered
in a Habitat Evaluation Procedure Plan, which was part of the comparative report and then revised as
part of the Environmental Assessment. An Environmental Assessment was also prepared to
document the environmental impacts associated with the two detention basin plans. The report
included analysis of groundwater and soil contamination that resulted from an adjacent dry cleaning
facility.
• Project Manager for Ecosystem Restoration Report/Environmental Assessment of Old San Jose
Creek, Santa Barbara County. Project Manager for the preparation of the Ecosystem Restoration
Report and Environmental Assessment. This project included vegetation mapping and soil sampling
to assess the suitability of soil for restoration of the creek, and an historical evaluation of how the
creek has changed over time through the use of aerial photography. A creek restoration plan was
developed for this project that included three alternative scenarios. A Habitat Evaluation Procedure
Plan was prepared to compare the habitat value of each restoration alternative and was evaluated by
the U.S. Fish and Wildlife Service. This project also required a real estate evaluation for all properties
along the creek and the development of landscape costs for the implementation of each restoration
alternative. Hydrological, geotechnical, and economic evaluations of the project area prepared by the
U.S. Army Corps of Engineers were used in the preparation of the Ecosystem Restoration Report and
the Environmental Assessment (EA). The Draft EA of the Recommended Plan addressed the
environmental impacts associated with the restoration project. The EA, part of the Detailed Project
Report, was prepared to describe the costs and benefits associated with the restoration project.
• Project Manager for the Visalia Landfill Facility E1R.
Project Manager for the preparation of an
Environmental Impact Report for the proposed expansion of the Visalia Landfill Facility in Tulare
County. The EIR covered the replacement of an existing unlined waste management unit (WMU) with
the construction and operation of a new lined WMU that would meet all State and federal regulations.
The EIR considered the environmental impacts associated with the project and included a monitoring
program to address the implementation of mitigation measures. Some of the key issues considered in
the ElR included the evaluation of traffic impacts associated with the transporting of waste to the site,
r7,9SANDRA ALARCON-LOPEZ, page 5
the potential for impacting the San Joaquin kit fox in the development of the WMU, the potential to
impact cultural resources, and the impact of the WMU on the adjacent agricultural facilities.
• Project Manager for Los Angeles Unified School District New School Sites Environmental
Reports (EIRS and MNDs). Project Manager for school projects in the City of Los Angeles. Ms.
Alarcon-Lopez participated in the consultant panel established by the LAUSD to develop a template
for environmental reports on new schools. In addition, the Program EIR that was managed by Ms.
Alarcon-Lopez received the 2006Environmental award from the Los Angeles Section of the
American Planning Association. Projects are summarized below:
? LAUSD Phase II Projects. Project Manager for new schools construction under Phase II of the LAUSD's
New School Construction Program. She managed the South Region Elementary School No.I and Central
Region Middle School No.7 projects. For both of these projects, Ms Alarcon-Lopez completed Mitigated
Negative Declarations (MNDs). Both projects required traffic impact studies, air quality modeling, and
assessment of other environmental issue areas. The Central Region Middle School No. 7 Project also
included the preparation of a Rail Safety Study to address abandoned railroad tracks south of the proposed
project site. Ms. Alarcon-Lopez also prepared a draft and final MND for the Valley Region Montague
Charter Academy Addition Project. The MND was prepared for a 16-classroom addition proposed on an
existing elementary school campus. She completed the Final MND in May 2007, but the document was not
released to the public in May. (In December 2007, the Final MND was sent to LAUSD for their distribution
as our contract terminated in December 31, 2007.)
• LAUSD Central Region Middle School #I4 EIR. Project Manager for this controversial new school
project; the original .MND prepared for this project was challenged. Working under a court order, the
LAUSD prepared and distributed the NOP for this school. Ms Alarcon-Lopez prepared an EIR work plan to
layout the strategy for addressing the court order and prepared an updated mailing list. She managed the
preparation of an EIR that addressed transportation/traffic, pedestrian safety, historical resources, land use
and planning, population and housing, and fire protection. The Draft EIR was released for public review in
March 2007. She participated in a public meeting held to take comments on the draft document. She
prepared a Final Elk that addressed over 56 written comment letters and oral comments made during the
public meeting. This was a highly controversial project with significant and complex issues that were
addressed in the Final EIR. She worked extensively with LAUSD attorneys in preparing the Final EIR for
this project. The Final EIR was released in June 2007 and the document was certified at a public meeting
held before the LAUSD Board of Education on June 26, 2007.
• LAUSD New School Construction Program EIR. Project Manager for the preparation of a Program EIR
that assessed the program-wide impacts of implementing the district's new school construction program.
The Program EIR managed by Ms Alarcon-Lopez addressed 125,000 of the total 200,000 new seats to be
provided by the district through the construction of new schools and the expansion of existing schools. Ms.
Alarcon-Lopez managed the preparation of the Notice of Preparation (NOP) and Initial Study (IS), which
was published in May 2003. Aspen conducted the community outreach during the public scoping. The
public scoping included eight public meetings throughout the district to solicit public comment on the
NOP/IS, advertisement in 22 local newspapers, distribution of public notices to approximately 2,100
interested parties, distribution of over 100 documents, placement of reports in 29 public repository sites,
and the preparation of a scoping report. Ms Alarcon-Lopez managed the preparation of the Draft Program
E1R report, which was published in March 2004. The Program EIR addressed all environmental issues
areas and documented site selection, design, construction, and operation measures that the LAUSD agreed
to implement, as applicable, on all projects. The report evaluated environmental impacts associated with
projects before specific sites were identified. It provides information on applicable regulations that will be
implemented by the LAUSD in carrying out its program and documents how traffic, cultural resources, air
quality, noise, and other environmental resource area assessments will be carried out and evaluated when
specific sites are selected and new schools or school additions are designed and constructed. Six public
meetings were held to take comments on the Draft Program EIR. Over 100 copies of the document were
distributed; two separate mailings were conducted to notify the public about the release of the draft
document and the six public meetings (approximately 2,100 notices for each noticing event); documents
were distributed to the 29 public repositories; and two separate advertisements were placed in 22
newspapers regarding the release of the document and the public meetings. Comments made at the publicSANDRA ALARCON-LOPEZ, page 6
meetings and provided in written letters during the 45-day public review period, were addressed in the
Final EIR. The Final FIR was published on May 11, 2004. The Board of Education certified the Program
EIR on June 8, 2004. The public notification for the certification meetings were at the same level as those
conducted for the Draft Program EIR. In addition, all public information materials were made available in
four languages (English, Spanish, Armenian, and Korean). For public scoping, public information
materials were also translated into Japanese, Chinese, and Russian.
• Kennedy High School Portable Classroom Additions (Revised) Initial Study/Mitigated Negative
Declaration (IS/MND). Ms. AlarcOn-Lopez revised the IS/MND for portable classroom additions
proposed at Kennedy High School. This project was redesigned by the LAUSD to include the development
of on-campus parking.
• Pio Pico School Playground Expansion EIR. Ms. Alarcon-Lopez completed a Notice of Preparation,
Initial Study, and Administrative Draft FIR for the expansion of a playground at the existing Pio Pico
School in the LAUSD. The playground was proposed on five residential properties. One of the residences
is a potentially significant historical resource because of its association with an African American woman
journalist, Fay M. Jackson. This project was cancelled by the LAUSD after completion of the
administrative draft report.
• Narbonne, Cleveland, Wilson, and Kennedy High Schools Portable Classroom Additions IS/MND.
Ms. Alarcon-Lopez completed four ISs/MNDs for portable classroom additions at Narbonne, Cleveland,
Wilson, and Kennedy High Schools in the LAUSD. These reports were all fast-track and the Notice of
Preparations and Administrative Draft reports were completed concurrently. Ms. AlarcOn-Lopez
completed a Final IS/MND and response to agency and public comments for Narbonne, Cleveland, and
Wilson High Schools. The Kennedy High School report was put on hold by the LAUSD to address parking
concerns.
Valley New High School No. l (CS UN) EIR. This new high school was proposed on the campus of the
California State University Northridge (CSUN) as an academy high school which would share athletic
facilities with CSUN. This project was highly controversial with the neighboring community and required
extensive interaction with the Los Angeles Department of Transportation to address concerns with traffic.
Ms Alarcon-Lopez participated in the public scoping meeting and public hearing on the Draft FIR. A
revised traffic study was needed to address the public comments on traffic and to explore additional traffic
mitigation; traffic was a significant unavoidable impact after mitigation. The report was certified by the
Board of Education and was not challenged by the public despite significant controversy regarding traffic
impacts.
• East Valley High School No. 2 (Gemco) EIR. This new high school was proposed on a commercial lot,
which was the previous location of a Gemco retail store. Ms. Alarcon-Lopez worked with a traffic consult-
ant to address concerns with traffic and parking and with the LAUSD and the City of Los Angeles
Department of Transportation in addressing potential mitigation measures. This project was a fast-track
project that required quick turnaround in order to secure needed funding. She worked closely with the
LAUSD and was able to meet the funding deadline. The report was certified on time and the project was
executed on schedule. In addition, portions of the FIR were used to update the FIR template for future
LAUSD projects.
Project Manager for Meeting Facilitation and Report for the California Energy Commission
(CEC). Ms. Alarcon-Lopez facilitated the meetings of the Elkhorn Slough Advisory Team. The
advisory team was responsible for selecting projects that could be funded through the mitigation fees
imposed on an adjacent energy facility project. The team was composed of State agency
representatives and local technical experts. The meetings resulted in a plan that identified project
priorities, project stewardship, a process for selection and ranking of projects, and timelines. At the
request of the Foundation, Ms. AlarcOn-Lopez assisted the Elkhorn Slough Foundation in preparing
the report that documented the results of the Team meetings and established the project selection and
ranking process. This plan was adopted by the Regional Water Quality Control Board and the CEC
without any revisions.SANDRA ALARCON-LOPEZ, page 7
Jacobs Engineering Group Inc. 1990 to 1999
In close to ten years at Jacobs Engineering, Ms. MarcOn-Lopez worked on a variety of large complex
projects and managed a wide range of environmental restoration projects. Ms. Alarcon-Lopez's major
project activities included the following:
• ARCO CES Nationwide Contract ($8.7 million). Program Manager for the ARCO CES contract.
Managed seven project managers in six Jacobs offices. Served as primary point of contact to ARCO
for all contractual and personnel related issues. Selected project activities included:
• Managed investigation of three properties in Kansas City, Kansas. Prepared focused site investigation for
determining baseline contaminant levels, four cost estimates for remediation alternatives, and managed a
risk-based analysis to quantify the environmental risks associated with a vacant property, which was part of
the old refinery. Completed a due diligence review of one of the properties that was purchased by ARCO.
• Managed the site characterization of a former foundry property in Kewanee, Illinois. Managed the site
investigation that included soil and groundwater sampling and the human health risk assessment. Prepared
a comprehensive sampling work plan that received approval within a 45-day time frame by the state and
prepared a site characterization report that documented the sampling results and presented a
recommendation for no further action_ These documents provided the basis for an expedited site closure.
• RAILCYCLE solid waste management project for Waste Management of North America Inc ($3
million). Managed the work of in-house and contract staff in preparation of technical documents,
monitored the project budget, and served as primary interface with the client. Activities included:
• Managed technical and administrative activities. Oversaw a major geologic investigation of the landfill site
that included the drilling of 21 wells, soil and groundwater testing, and geophysical surveys. Also managed
air quality, biological, cultural resource, paleontological, and land use studies of the landfill site in the
Mojave Desert
• Provided support to the environmental impact report/statement document and prepared a seoping document
for this project
• Managed the preparation of a surface and groundwater compliance plan.
• U.S. Navy Comprehensive Long-Term Environmental Action Navy (CLEAN) Program.
Activities included:
• Managed the preparation of the proposed plan for one of the operable units at the Marine Corps Logistics
Base (MCLB) at Barstow
• Managed the preparation of fact sheets, brochures, and other informational materials for Naval Air Station
North Island, Naval Amphibious Base Coronado, and San Pedro Defense Field Support Point
• Managed the preparation of a major public involvement effort for MCLB Barstow. This involved the
development of an historical aerial display, two three-panel displays on base activities, four single panels
on topics regarding base cleanup and public participation, a fact sheet, and other public involvement
materials as well as meeting logistics_
• Vandenberg Air Force Base (AFB), California, part of Jacobs Air Force Installation Restoration
Program (IRP) contract. Activities included:
• Oversaw community relations activities for restoration projects at Vandenberg AFB
• Managed the preparation of preliminary endangerment assessments (PEA), and brought to closure EPA
sites that could not be closed (or considered "no action" sites by the regulators) by previous attempts.
Completed 11 PEA reports as part of this effort
• Managed the preparation of a public involvement effort. This involved preparation of a community
relations plan that included approximately 90 interviews, and the layout and production of two fact sheets
for the base.SANDRA ALARCON-LOPEZ, page 8
City of Whittier 1990 to 1998
Ms. Alai-On-Lopez served two four-year terms as a Planning Commissioner with the City of Whittier
(appointed by the City Council). She made decisions on controversial projects, assessed the long-term
impacts of project developments, and ensured that mitigation reduced or eliminated any project impacts.
In addition, she was involved in the development and approval of the revised general plan for the City of
Whittier. She served as the Chair of the Commission from 1993 through 1995.
Planning Consultants Research 1989 to 1990
As the Manager of Waste Management Services for Planning Consultants Research, Ms. Alarcon-
Lopez worked on several planning and environmental projects including the following projects:
• Managed a permitting and environmental review effort for the Lopez Canyon landfill in the city of
Los Angeles
• Prepared a hazardous material management plan for the Lockheed Company in Burbank
• Completed a site feasibility study that evaluated three candidate sites for an autoclave facility for
Waste Management of North America.
Independent Consultant 1988 to 1989
As an independent consultant, Ms. Alarcon-Lopez was the primary author of the draft county Hazardous
Waste Management Plan (HWMP) for the County of San Bernardino. As primary author of the San Ber-
nardino County HWMP, work involved analyzing and writing about issues regarding hazardous waste
management such as siting hazardous waste facilities, transportation, summary of legislation, policy
development, and preparation of other documents related to the plan, as well as taking the plan before
public bodies for their review and consideration
• Oversaw for the County of San Bernardino the public involvement component for HWMP
development including the coordination of informational materials and workshops
• Prepared a consistency evaluation, which compared a county
HWMP to the county's general plan for
the County of San Bernardino.
County of Santa Barbara 1983 to 1988
As a Land Use Planner for the County of Santa Barbara Resource Management Department, Ms. Alarcon-
Lopez prepared the county's Draft Hazardous Waste Management Plan. Her work involved analyzing
and writing about issues regarding hazardous waste management such as siting hazardous waste facilities,
transportation, summary of legislation, policy development, and preparation of other documents related to
the plan, as well as taking the plan before public bodies for their review and consideration.
She prepared, managed, and/or contributed to several major NEPA and CEQA documents including off-
shore oil and gas projects, hazardous waste management plans/facilities, and other industrial, commercial,
and recreational projects. She participated in:
•
Application review and environmental documentation (EIRJEIS) for complex offshore oil and gas
development and related facilities, and the review and permitting of projects in the coastal areas of
Santa Barbara County
•
Represented the local jurisdiction on panels with State and federal agencies for the joint preparation
of environmental documents as an employee of Santa Barbara County Resource Management
Department
•
Presented project information and recommendations to decision-making bodies and the public.pen
Environmental Group
As
SCOTT DEBAUCHE
Environmental Planner
ACADEMIC BACKGROUND
M.S. Candidate, Urban & Regional Planning, University of Minnesota
B.S., Urban & Regional Planning, University of Minnesota, 1994
PROFESSIONAL EXPERIENCE
Mr. Debauche is an environmental planner with six years of experience preparing a variety of federal and
State of California environmental, planning, and analytical documents for large-scale infrastructure and
development projects. Mr. Debauche brings the experience of being both a public and private sector
planner, specializing in the integration and completion of NEPA and CEQA documentation, joint
documentation, land use, socioeconomic, and public policy analysis, environmental justice analysis, and
public and community involvement programs.
Aspen Environmental Group 2001 to present
California Public Utilities Commission (CPUC).
Under Aspen's environmental services contract with
the CPUC, Mr. Debauche has prepared environmental analysis sections of environmental reports
analyzing large-scale infrastructure projects. His project experience with the CPUC includes the
following:
• PG&E's Proposed Divestiture of Hydroelectric Assets Draft UR.
Mr. Debauche prepared several
key sections of the Draft EIR, including Socioeconomics and Hazardous Materials analysis.
•
Looking Glass Networks Fiber Optic Cable Project IS/MND, northern and southern California.
As part of Aspen's ongoing contract with the CPUC for review of Telecommunications projects, this
document encompasses and evaluation of project impacts and network upgrades in the San Francisco
Bay Area and the Los Angeles Basin Area. Prepared the socioeconomic analysis for this
comprehensive CEQA document reviewing the potential impacts of hundreds of miles of newly
proposed fiber optic lines throughout northern and southern California, including Los Angeles and
Orange Counties.
• SDG&E Miguel Mission Substation Draft FIR. The major part of the Proposed Project would
include the installation of a new, bundled 230 kV circuit between Miguel and Mission Substations,
which would be located entirely within SDG&E's existing 35-mile ROW. Mr. Debauche prepared
social science analysis for the Initial Study, as well as the Draft EIR Project Description and several
key environmental sections.
California Energy Commission (CEC), Technical Assistance in Application for Certification Review.
In response to California's power shortage, Aspen is assisting the California Energy Commission in
evaluating the environmental and engineering aspects of new power plant applications throughout the
State. As part of this effort, Mr. Debauche works as a technical specialist for socioeconomics and
environmental justice, and alternatives analyses for the following power plant projects:
• Valero Cogeneration Project, Benicia,
CA. Assisted in the preparation of the Socioeconomics Staff
Assessment for a proposed cogeneration facility at the Valero Refinery in Benicia. Issues addressedSCOTT DEBAUCHE, page 2
included impacts on public services and other project-related population impacts such as school
impact fees.
• Rio Linda/Elverta Power Project, Sacramento, CA. Assisted in the preparation of the
Socioeconomics Staff Assessment for a 560-megawatt natural gas power plant in the northern
Sacramento County. Issues of importance included environmental justice and impacts on property
values.
• Magnolia Power Project, Burbank, CA. Assisted in the preparation of the Socioeconomics Staff
Assessment for this nominal 250-megawatt natural gas combined-cycle fired electrical generating
facility to be located at the site of the existing City of Burbank power plant. Environmental justice
issues and potential impacts on local economy and employment were evaluated.
• Avenal Energy Project, Kings County, CA. Assisted in the preparation of the Socioeconomics
Staff Assessment for this 600-megawatt combined cycle electrical generating facility, and associated
linear facilities.
• Inland Empire Energy Center, Riverside County, CA. Assisted in the preparation of the
Socioeconomic Staff Assessment for a 670-megawatt natural gas-fired, combined-cycle electric
generating facility and associated linear facilities including, a new 18-inch, 4.7-mile pipeline for the
disposal of non-reclaimable wastewater, and a new 20-inch natural gas pipeline. The project would
be located on approximately 46-acres near Romoland, within Riverside County.
• Coastal Plant Study. Socioeconomic specialist for this special study being conducted as part of
Aspen's contract with the California Energy Commission (CEC). The study includes identification and
evaluation of potential issues associated with the possible modernization, re-tooling, or expansion of
California's 25 coastal power plants including the Encina Power Plant and the San Onofre Nuclear
Power Plant.
U.S. Army Corps of Engineers, Los Angeles District. Responsible for conducting the analyses of the
social science issue areas for a variety of EISs and EAs as part of two environmental services contracts.
Delivery orders have included:
• Northeast Phoenix Drainage Area Alternatives Analysis Report, Phoenix and Scottsdale, AZ.
Worked with preparation of an alternatives analysis report that evaluated the potential environmental
impacts associated with channel and detention basin alternatives to control flooding problems
resulting from fast rate of development in the northeast Phoenix area.
• Murrieta Creek Flood Control and Environmental Restoration Project. Mr. Debauche served as
a technical writer of an Environmental Assessment and Mitigation Monitoring plan for Phase 1 of a
flood control and restoration project in Riverside County.
California Department of Water Resources. Responsible for conducting the environmental analyses
for CEQA compliance as part of two environmental services contracts. Delivery orders have included:
• Piru Creek Stabilization and Restoration Project. The California Department of Water Resources
(CDWR) proposes to repair erosion damage at a series of three locations downstream of Pyramid
Dam and seismically retrofit the Pyramid Darn access bridge that crosses Piru Creek. Mr Debauche
served as technical writer of the Initial Study for this project.
Los Angeles Unified School District (LAUSD), Los Angeles County, CA. Deputy Program manager
and Technical writer for several CEQA documents (EIRs and ISNINDs) being prepared as part of
Aspen's ongoing services contract with the LAUSD to help approve school projects that would meet
existing overcrowded conditions in the greater Los Angeles area. Projects have included:SCOTT DEBAUCHE, page 3
? East Valley Middle School No. 2 EIR. Served as a key technical writer for this middle school
project proposed to be located at the previous Van Nuys Drive-In site. The EIR focused on impacts
associated with air quality, hazards and hazardous materials, noise, land use and planning, and traffic
and transportation. Major issues of concern included traffic and noise generated by school operation
activities. The EiR included LAUSD design standards and measures employed to minimize
environmental impacts.
? Mt. Washington Elementary School Multi-Purpose Room Addition Project IS/MND. Served as
Deputy Program Manager for this project proposed the development of a multi-purpose room facility,
including a library, auditorium, and theater, to the existing Mt. Washington Elementary School
campus located in Los Angeles. The surrounding residential community had concerns regarding the
proposed project's impacts on aesthetics, traffic, air quality, and noise. Of particular concern, was
impacts generated due to the after-hours use of the multi-purpose room facility by civic and
community groups.
• Canoga Park New Elementary School IS/MND. Served as technical writer for this elementary
school project proposed to be developed on a parcel of land owned by the non-profit organization,
New Economics For Women (NEW). This "Turn-Key" project consisted of a Charter Elementary
School to be developed by NEW and sold to the LAUSD for operation. It was later decided that
NEW would lease the school back and run it as a charter school. Issues of concern included,
pedestrian safety, traffic, air quality, noise, and land use.
• New School Construction Program EIR. Serves as a technical writer for social science issues,
including socioeconomics, and population and housing for this Program EIR being prepared for the
LAUSD. The LAUSD 2020 Program would provide student seats throughout the LAUSD via a
combination of the addition of portable classrooms to existing campuses, modernization and
reconfiguration of existing campuses, and the construction of new schools. Mr. Debauche prepared
the socioeconomic, population, and housing sections of this EIR.
• Hughes Magnet Span School IS/MND. Served as a technical writer for socioeconomics, hydrology,
public services and utilities, and recreational impacts for the proposed re-opening of the existing
Hughes Middle School as a Magnet Span School serving up to 1,620 District 6th though 12th grade
students. The re-opening of the Hughes Middle School would require the relocation of the existing
uses of the campus. The existing Enadia Way Elementary School and Platt Ranch Elementary School
would be re-opened for the relocation of these uses.
• Wonderland Elementary School Portable Classroom Additions IS/MND. Served as the technical
writer of an IS/MND for a proposed addition to the Wonderland Avenue Elementary School, located
in the City of Los Angeles. Ms. Walker is responsible for overall coordination and scheduling of the
project's environmental review, communications with the LAUSD, senior technical review of all
documents produced, presentation during the project's public scoping meetings and hearings, and
assurance of public noticing. Served as technical writer of the 1S/MND.
• Pio Pico Elementary School Playground Expansion IS/MND. Completed a Notice of Preparation,
Initial Study, and Administrative Draft EIR for the expansion of a playground at the existing Pio Pico
School in the LAUSD. The playground was proposed on five residential properties. One of the
residences is a potentially significant historical resource because of its association with an African
American woman journalist, Fay M. Jackson. This project was cancelled by the LAUSD after
completion of the administrative draft report. Served as technical writer of the IS/MND.
• Fairfax Senior High School Portable Classroom Addition IS/MND. Served as technical writer of
the IS/MND for the addition of portable classrooms at the school. Major issue areas covered were
noise, hydrology, and geotechnical analysis.SCOTT DEBAUCHE, page 4
• Polytechnic Senior High School Portable Classroom Addition IS/MND. Served as technical
writer of the IS/MND for the addition of portable classrooms at the school. Major issue areas covered
were noise, hydrology, and geotechnical analysis.
• Washington Senior High School Portable Classroom Addition IS/MND. Served as technical
writer of the IS/MND for the addition of portable classrooms at the school. Major issue areas covered
were noise, hydrology, and geotechnical analysis.
EIP Associates
1998 to 2001
MTA Mid Cities/Westside Transit Corridor Study EIS/EIR. Was a key writer of the EIS/EIR for this
3-phase (including prepared the Major Investment Study (MIS), the Environmental Impact Statement
(EIS), and an evaluation of the urban design implications of transit interventions on selected routes) study
intended to address current and long range traffic congestion in the central and westside areas of the Los
Angeles, Basin. Three east/west corridors and a range of transit alternatives ranging including Rapid Bus,
light rail, and heavy rail are being evaluated. In addition to preparing several issue area chapters of this
comprehensive joint E1S/EIR, Mr. Debauche assisted with the Environmental Justice Analysis (per
Executive Order 12898), the Section 4(f) Parklands discussion, and the land use and socioeconomics
sections of the EIS/EIR.
Wes Thompson Ranch Development Project EIR. Served as project writer for this hillside residential
development in the City of Santa Clarita. Issues of concern included seismic and air quality impacts
associated with the excavation of 2 million cubic yards of soil, the project's non-compliance with the
City's hillside ordinance for innovative design, and traffic generated by project-related population growth
in the area. Four different site configuration alternatives were developed as part of the DR analysis.
Other issues of concern included sensitive biological resources, the potential for hydrological impacts due
to disturbance of the hillside, and cultural resources. As the technical writer for socioeconomics, noise,
hazardous materials, air quality, and public services, Mr. Debauche conducted analysis and prepared these
environmental sections as well as the project description, alternatives screening and development, traffic
assistance, and cumulative scenario for:
City of Santa Monica Environmental Assessments. Was key writer of several environmental
assessment documents for housing, commercial, institutional, and mixed-use developments in compliance
with CEQA. As the technical writer for socioeconomics, noise, hazardous materials, air quality, and
public services, Mr. Debauche conducted analysis and prepared these environmental sections as well as
the project description, alternatives screening and development, traffic assistance, and cumulative
scenario for:
• Seaview Court Condominiums 1S/MND. This comprehensive Initial Study/Mitigated Negative
Declaration included six technical reports including traffic, cultural resources, parking survey, shade
and shadow analysis, and a geotechnical assessment to evaluate the level of severity of this
development in the waterfront area of Santa Monica. Major issues of concern were; parking and
project-generated traffic on adjacent narrow residential streets; visual obstruction and shading impacts
of the proposed structure; liquefaction and seismic impacts to adjacent properties as result of the
project's excavation for a subterranean parking garage; and the potential impacts of the project to
impact the integrity of a historic district and the historic Seaview Walkway to the beachfront.
• Four-Story Hotel IS/MND. A comprehensive Initial Study/Mitigated Negative Declaration was
prepared for this four-story hotel adjacent to St. John's Hospital in Santa Monica. Major issues of
concern included project-generated traffic on surrounding multi-family residential uses and
emergency access to the hospital.SCOTT DEBAUCHE, page 5
• Santa Monica College Parking Structure B Replacement EIR. This focused EIR addressed issues
related to traffic and neighborhood land use impacts associated with the addition of a 3-story parking
structure in the center of the SMC campus. Major issues of concern included the potential for
project-generated traffic to cause congestion at the school's main entrance on Pico Boulevard, and the
potential for overflow traffic to impact the Sunset Community of single-family homes adjacent to the
school.
• North Main St. Mixed-Use Development Project MR. This EIR included evaluation of impacts
resulting from the development of a mixed-use development in Santa Monica's "Commercial
Corridor" on Main Street, with ground-floor residences and boutique commercial uses. Major issues
of concern included traffic and parking impacts to Main Street and surrounding residential land uses,
shade and shadow impacts, and neighborhood impacts.
Specific Plans and Redevelopment Projects. As the technical writer for socioeconomics, noise,
hazardous materials, air quality, and public services, Mr. Debauche conducted analysis and prepared these
environmental sections as well as the project description, alternatives screening and development, traffic
assistance, and cumulative scenario for:
• Cabrillo Plaza Specific Plan MR in Santa Barbara. This project consisted a mixed-use
commercial development on Santa Barbara's waterfront on Cabrillo Boulevard. On-site uses
included an aquarium, specialty retail, restaurants, and office space.
• Culver City Redevelopment Plan and Merger EIR. This programmatic EIR evaluated the impacts
of the City's redevelopment of its redevelopment zones. A major land use survey and calculation of
acreage of redevelopment lands was conducted as part of the EIR.
• Dana Point Headlands Specific Plan EIR. This EIR evaluated the development of coastal bluff in
the City with hotel, single- and multi-family residential, and commercial uses. Major issues of
concern included ground disturbance as a result of excavation, impacts to terrestrial and wildlife
biology, recreation impacts to beachgoers, and project-generate population inducement.
• Triangle Gateway Redevelopment Project MR in Beverly Hills, CA. This Elk evaluated the
development of a supermarket, retail shops, and office space in the triangle gateway portion of
downtown Beverly Hills. Issues of concern evaluated by Mr. Debauche included traffic, land use,
and impacts to on-site historic structures.
UCLA Campus Housing Expansion. This EIR evaluated the development and expansion of
campus housing within the UCLA campus. Issues of concern evaluated by Mr. Debauche included
hazardous materials and population/housing.
CH2M Hill - Minneapolis, MN 1995 to 1998
APRIL 1998 TO MARCH 2001
Minneapolis/St. Paul International Airport Expansion EIS: Was a key writer of the EIS for this $4
million technical and environmental study, including the preparation of an Environmental Impact
Statement (EIS), and an evaluation of the urban design implications of a proposed $800 million expansion
of the existing MSP International airport, including transit and terminal modifications and the inclusion of
a new perpendicular runaway. The studies included alternatives to the project and the long-term effects
on the cities of Minneapolis and St. Paul. In addition to preparing several issue area chapters of this
comprehensive EIS, Mr. Debauch assisted with the Environmental Justice Analysis (per Executive Order
12898), the Section 4(f) Parklands discussion, and the socioeconomics sections of the EIS. In addition,
Mr. Debauche assisted with preparation of a technical report on airport noise effects on nearby housing
and mitigation programs for the impacts of the proposed runway.
<6s1SCOTT DEBAUCHE, page 6
Minneapolis/St. Paul Wastewater Treatment Facility Expansion EIS: Was a key writer of the EIS for
expansion of the existing wastewater treatment facility serving the twin cities area. The studies included
alternatives to the project and the long-term effects on the cities of Minneapolis and St. Paul. Mr.
Debauche prepared several issue area chapters of this comprehensive EIS, including the Environmental
Justice Analysis (per Executive Order 12898), and the socioeconomics sections of the EIS.
PROFESSIONAL ASSOCIATIONS
• American Planning Association (APA), Chapter MemberAspen
E onmenta( Group
CHRISTIAN S. HUNTLEY
Senior Associate/Senior Biologist
ACADEMIC BACKGROUND
Graduate Studies, Biology, California State University Northridge
B.A., Biology, University of California at Santa Cruz, 1992
PROFESSIONAL EXPERIENCE
Mr. Huntley has over nine years of experience with Aspen supporting and managing Task Order
Contracts in support of CEQA/NEPA projects including EIR/EIS, IS/MND, EA, BE/BA, and BA. In
addition, Mr. Huntley has extensive experience conducting biological assessments, managing large-scale
construction and restoration projects, and supporting agency clients through the Section 7 process. With
over 14 years experience as a biologist, Mr. Huntley also has proven experience working with the sensitive
biological resources that occur in southern California including rare plants, arroyo toads, two-striped garter
snakes, and southwestern pond turtles. Mr. Huntley has also completed comprehensive vegetation mapping,
sensitive species surveys, and revegetation plans for projects throughout southern California. With
extensive experience in managing large scale construction projects, Mr. Huntley has unique experience in
resolving conflicts and ensuring compliance with environmental regulations. Supported by a solid
background in biological resources, experience in completing CEQA, NEPA, USDA Forest Service
Biological Assessments, sensitive species consultation, and over a decade of construction management
experience, he works closely with resource agency personnel, contractors and affected jurisdictions to
ensure that projects are constructed on time and in compliance with applicable laws, ordinances,
regulations and standards.
Aspen Environmental Group 1998 to present
• Tehachapi Renewable Transmission Line Project California Public Utilities Commission/US
Forest Service (2007-2008), Issue Area Coordinator/Biologist. Mr. Huntley is acting as the issue
area coordinator for biological resources on this 500 kV transmission line proposed by Southern
California Edison in support of wind energy projects. This transmission line is over 100 miles in
length and two separate lines cross the Angeles National Forest Key. Some of the key issues on this
project include potential impacts to Mojave ground squirrel, arroyo toads, California Condors, spotted
owl, and a host of forest sensitive plant species. Other key issues involve the coordination with State
Park, Forest, and resource agency staff.
• Antelope/Pardee Transmission Line Project Segments 2-3 EIR, California Public Utilities
Commission/US Forest Service (2006-2008), Issue Area Coordinator/Biologist. Mr. Huntley acted
as the issue area coordinator for biological resources on this 500 kV transmission line proposed by
Southern California Edison in support of wind energy projects. Key issues on this project include
potential impacts to Mojave ground squirrel, California red-legged frogs, burrowing owl, and rare
plants. As part of this project Mr. Huntley conducted focused surveys for arroyo toads and
coordinated ESA compliance with the USFS and IJSEWS. As part of the project Mr. Huntley
completed the BE/BA to comply with the provisions of the ESA and the Management Indicator
Species Report for ANF compliance.
• El Casco Sub-Transmission Line Project EIR, California Public Utilities Commission (2006-
2007), Issue Area Coordinator/Biologist Mr. Huntley acted as the issue area coordinator for
c\DCHRISTIAN S. HUNTLEY, page 2
biological resources and completed the impact analysis section of the EIR for this 17 mile sub-
transmission line upgrade to be completed by Southern California Edison. This line is located in the
Western Riverside Multiple Species Conservation Area and crosses areas supporting several federally
protected species including the least Bell's vireo, southwestern willow flycatcher, and Stephens's
kangaroo rat.
m Vista Del Lago Visitor Center Slope and Waterline Repair Biological Evaluation/Biological
Assessment, California Department of Water Resources (2006-2008), Project
Manager/Biologist. Mr. Huntley is managing the preparation of the Biological Evaluation/
Biological Assessment in compliance with the USES to conduct repairs to a failed slope at the Vista
Del Lago Visitor Center at Pyramid Lake. Mr. Huntley is also acting as the USFS and CDFG liaison
for this project and is managing the preparation of regulatory permits for compliance with CDFG,
USACE, and Regional Board requirements.
• Antelope/Pardee Transmission Line Project EIR/EIS-BE/BA, California Public Utilities
Commission/US Forest Service (2005-2007) Issue Area Coordinator/Biologist. Mr. Huntley acted
as the issue area coordinator for biological resources on this 500 kV transmission line upgrade to be
completed by Southern California Edison. Key issues on this project included compliance with the
USFS Forest Plan and sensitive species including California condor, burrowing owl, and rare plants.
Mr. Huntley reviewed and prepared the Biological Resource Section for the EIR/EIS, developed
project alternatives, coordinated with USFS staff, and conducted sensitive species surveys for arroyo
toad in support of this project.
• Devers/Harquauhala Transmission Line Project 2 EIRJEIS, California Public Utilities
Commission/Bureau of Land Management (2005/2006), Issue Area Coordinator/Biologist Mr.
Huntley acted as the issue area coordinator for biological resources on this 230 mile 500 kV
transmission line upgrade to be completed by Southern California Edison. This project crosses key
wildlife areas including the KOFA Wildlife Sanctuary, the San Bernardino National Forest, the
Mojave and Sonoran Desert habitat, and sections of the Riverside Multiple Species Conservation
Area. Mr. Huntley reviewed and re-structured the Biological Resource Section for the EIR/EIS.
• March Air Reserve Base Cactus and Heacock Channels Environmental Assessment and
Biological Technical Report US Army Corps of Engineers (2005-2007), Project
Manager/Biologist. Mr. Huntley conducted and managed the preparation of a Biological Technical
Report for two channels located along the perimeter of the March Air Reserve Base in Riverside
California. Mr. Huntley and a team of biologists conducted burrowing owl surveys, vegetation and
vernal pool mapping, and documented existing biological conditions at the two channels. As part of
this project detailed GIS maps were created to assist the Corps in preparing environmental documents
for the area. Currently, Mr. Huntley is managing the completion of an Environmental Assessment to
evaluate impacts of construction of approximately three miles of flood control channel located at
Cactus and Heacock Drainages.
• Patriot Integrated Air Defense Exercise Project Environmental Assessment and Environmental
Baseline Survey, Nellis Air Force Base Nevada (2006-2008), Project Manager/Biologist. Mr.
Huntley is currently managing the preparation of a new EA for ongoing military activities to be
conducted on Bureau of Land Management (BLM) lands surrounding Nellis Air Force Base in
Lincoln and Nye County, Nevada. Mr. Huntley is coordinating with the USAF regarding field surveys
of the proposed anti-aircraft sites, the assessment of biological and cultural resources, and will prepare
the DR/FONSI and Right-Of-Way document for the USAF. Mr. Huntley will also prepare sections and
manage the completion of an Environmental Baseline Report for each of the proposed artillery sites.
• Pyramid Dam Emergency Access Road IS/MND and Biological Evaluation/Biological
Assessment, California Department of Water Resources (2005-2007), Project Manager/CHRISTIANS. HUNTLEY, page 3
Biologist. Mr. Huntley is preparing the biology section of the IS/MND and the Biological Evaluation/
Biological Assessment in compliance with the USFS to construct an emergency access road from
Interstate 5 to the Pyramid Lake Darn. Mr. Huntley is also acting as the USFS and CDFG liaison for
this project and is managing the sensitive species surveys for the proposed project.
Horsethief Creek Road Repairs Project, IS/MND and Biological Assessment, California
Department of Water Resources (2005-2007), Biologist/Project Manager. Mr. Huntley prepared
the biological resource section and managed the completion of the IS/MND and the BA for
construction of an all weather road at Horsethief Creek located near Lake Silverwoocl in San
Bernardino County. Mr. Huntley is also assisting DWR through formal consultation with the
USFWS. The proposed project is intended to provide an all-weather access to DWR facilities while
avoiding impacts to federally endangered arroyo toads. Mr. Huntley also managed and conducted the
sensitive species surveys required for this project including arroyo toad, two-striped garter snake, and
southwestern pond turtles. Currently, Mr. Huntley is directing the monitoring efforts at the site to
avoid impacts to arroyo toads a federally listed species.
• Sunset Substation IS/WIND and Biological Site Assessment, City of Banning (2006-2007),
Biologist. Mr. Huntley is prepared the biology section of the IS/MND as a sub-contractor to R.W.
Beck. In addition, Mr. Huntley conducted burrowing owl surveys and managed surveys for Los
Angeles Pocket Mouse at select locations along the proposed right-of-way.
• Littlerock Dam and Reservoir Restoration Project EIRJEIS-BE/BA, Palmdale Water
District/US Forest Service (2004-2008), Deputy Project Manager/Biologist. Mr. Huntley is
currently acting as deputy project manager and project biologist for the sediment removal activities
associated with the Littlerock Dam and Reservoir in the Angeles National Forest. Mr. Huntley is
working to develop project alternatives for sediment disposal while avoiding impacts to federally
endangered arroyo toads. Mr. Huntley will also be managing the sensitive species surveys for this
project and completing the biological resources section of the EIR/EIS and BE/BA.
• Salton Sea Debris Removal Project, Los Angeles Department of Water and Power (2007-2008),
Project Manager/Biologist. Mr. Huntley conducted Phase I, IL and III burrowing owl surveys at
several sites scheduled for clean up in the Imperial Valley. Mr. Huntley managed the monitoring of
clean up activities and developed mitigation strategies to comply with State and local permit
requirements regarding the protection of this species.
• Castaic
Lake Biotic Assessment, Los Angeles Department of Water and Power (2007), Project
Manager/Biologist. Mr. Huntley conducted focused surveys for arroyo toad and other sensitive plant
and wildlife species to update the existing conditions present at the Castaic Power plant located at
Castaic Creek. This area is known to support a variety of sensitive plant and wildlife species.
• Lake Canyon IS/EIR, Ventura, Ventura County Flood Control District, Biologist (2006-2007). Mr.
Huntley conducted biological surveys of this proposed detention basin and prepared the biological
resource section of the Initial Study. Based on the assessment of potential impacts from this project
the County intends to prepare an Environmental Impact Report.
•
California Energy Commission Emergency Siting Team, Power Plant Development,
Compliance Project Manager.
For two years, Mr. Huntley's duties included management of
technical staff for the completion of CEQA equivalent environmental permitting for over nine new
emergency power plants, review of applicant submittals, drafting of Memoranda of Understanding with
Chief Building Officials, conducting audits of building officials, and coordinating with affected
agencies to resolve concerns with potential resource impacts. Other duties included maintaining
contractor construction milestones, detailed compliance monitoring and reporting, development of
mitigation measures and conflict resolution for power plants.
°\1--CHRISTIAN S. HUNTLEY, page 4
• Monterey Bay Accelerated Research System Cabled Observatory (MARS) EIR/EIS, California
State Lands Commission/Monterey Bay National Marine Sanctuary (2004-2006), Deputy
Project Manager. The MARS project is an advanced cabled observatory in Monterey Bay that would
provide a continuous monitoring presence in the MBNMS as well as serve as the test bed for a state-
of-the-art regional ocean observatory, currently one component of the National Science Foundation
(NSF) Ocean Observatories Initiative (001). Mr. Huntley acted as the deputy project manager for this
project. In addition his duties involved review of technical data, development of the project
description and alternatives, and coordination with state and federal agencies.
• Lower Colorado Flood Control Project EIR/EIS, US Army Corps of Engineers (2003-2004),
Deputy Project Manager/Biologist. Mr. Huntley conducted reconnaissance surveys and vegetation
mapping along a 23 mile section of the Lower Colorado River in Yuma Arizona. In addition, Mr.
Fluntley updated the biological resource section of the current baseline conditions and is working with
a team of State and federal agencies in an effort to determine the future alignment of the Lower
Colorado River in this location. As part of this process Mr. Huntley developed project alternatives
that met the criteria identified by the United States Boundary Water Commission and State and
federal resources agencies.
• Piru Creek Restoration of Natural Flows Project EIR, California Department of Water
Resources (2004-2005), Biologist. Mr. Huntley managed resource specialists for completion of
sensitive bird surveys along Piru Creek. In addition, he conducted sensitive species surveys for
aquatic resources including two-striped garter snake and southwestern pond turtle, and coordinated
with technical experts during reconnaissance surveys for arroyo toad. Mr. Huntley completed
engineering cross sections of Piru Creek and prepared a comprehensive State jurisdictional riparian
delineation for an 18-mile section of middle Piru Creek between Pyramid dam and Lake Piru.
Currently, Mr. Huntley is preparing the biological resources section and developing environmentally
sound alternatives to address impacts associated with restoring natural flows to Piru Creek.
Discussions of biological resources focus on the potential beneficial impacts that may occur to
southwestern arroyo toad, southwestern pond turtle, red-legged frog and two-striped garter snake.
• Murrieta Creek Flood Control Project Phase II-IV Revegetation Plan and Sensitive Species
Surveys, US Army Corps of Engineers (2006-2007), Project Manager/Biologist. Mr. Huntley is
preparing the comprehensive vegetation maps and detailed restoration plan for over six miles of
riparian habitat located at Murrieta Creek in Riverside California. As part of this task Mr. Conducted
and managed a team of resource experts in completing sensitive plant and animal species within the
Murrieta Creek. Prepared detailed vegetation maps, site assessment and impact analysis for the
Environmental Assessment, comprehensive revegetation and restoration plan to address project
impacts, and developed mitigation for sensitive plant and wildlife species. In addition, Mr. Huntley
worked closely with local resource agencies and managed sensitive wildlife surveys and the trapping
and relocation of southwestern pond turtles from the project area. Currently Mr. Huntley is providing
technical assistance to the Corps regarding this project.
• Murrieta Creek Flood Control Project Supplemental EA, US Army Corps of Engineers (2003-
2006), Deputy Project Manager/Biologist. Mr. Huntley conducted site surveys for sensitive plant
and animal species within the Murrieta Creek. Prepared detailed vegetation maps, site assessment and
impact analysis for the Environmental Assessment, comprehensive revegetation and restoration plan
to address project impacts, and developed mitigation for sensitive plant and wildlife species. In
addition, Mr. Huntley worked closely with local resource agencies and managed sensitive wildlife
surveys and the trapping and relocation of southwestern pond turtles from the project area. Currently
Mr. Huntley is providing technical assistance to the Corps regarding this project.
• East Branch Extension Project Phase II, California Department of Water Resources (2006),
Project Manager/Biologist. Mr. Huntley managed and conducted sensitive species surveys for DWR
£13CHRISTIAN S. HUNTLEY, page 5
in support of the EIR for this aqueduct extension project. In addition, Mr. Huntley provided expert
testimony to the San Bernardino Superior Court to allow access to key areas in support of the surveys.
Focused surveys included the slender horned spineflower, Santa Ana River wooly star, California
gnatcatcher, -least Bell's vireo, and southwestern willow flycatcher.
Emergency Storm Repairs Biological Assessment, California Department of Water Resources
(2005), Project Manager/Biologist. Mr. Huntley prepared the Biological Assessment to evaluate
potential impacts to sensitive species from emergency storm repairs at two locations at Piru Creek.
The BA documented site conditions, identified potential sensitive species habitat and presence in the
project area, and addressed specific USEWS requirements associated with arroyo toads.
• Fort Irwin Environmental Baseline Survey Reports US Army Corps of Engineers (2005), Project
Manager/Biologist. Mr. Huntley managed the preparation of two Environmental Baseline Survey
reports near Fort Irwin, San Bernardino County, California to support the land acquisition of over 95
parcels by the US Army for the Fort Irwin National Training Center. Mr. Huntley conducted site
investigations, documented existing biological conditions and managed the preparation of the report.
• Joint Red Flag '05 Exercise Environmental Assessment, US Army Corps of Engineers/Bureau of
Land Management, Nellis Air Force Base Nevada (2004-2005), Project Manager/Biologist. Mr.
Huntley managed and coordinated the EA process for the ground component of the Joint Red Flag '05
Exercise which was conducted Bureau of Land Management (BLM) lands surrounding Nellis Air
Force Base in Lincoln County, Nevada. Mr. Huntley conducted extensive field surveys of the proposed
anti-aircraft sites, completed the assessment for biological and visual resources, prepared the
DR/FONSI, managed sensitive species surveys, identified and flagged populations of noxious weeds,
and prepared of military training guides for the soldiers in the field.
•
South Adit Access Road Repair Project Biological Evaluation/Biological Assessment, California
Department of Water Resources (2005/2006), Project Manager/Biologist. Mr. Huntley prepared
the Biological Evaluation/Biological Assessment in compliance with the USFS to repair storm
damage to the existing asphalt road surface and to stabilize the adjacent hillside to maintain access to
the South Adit; a Department of Water Resources facility located along the West Branch of the
California Aqueduct. Mr. Huntley managed sensitive resource surveys for rare plants and wildlife,
conducted pre-construction surveys, and coordinated with the USFS personnel. As part of ongoing
construction activities at the site Mr. Huntley provided environmental training and materials,
monitored construction at the site, relocated wildlife from the construction area, developed a stream
diversion plan and tree removal plan for CDFG review, reviewed the SWPPP, and conducted
restoration activities at the site.
•
Creel Census Surveys, California Department of Water Resources (2004-2005), Project
Manager/Biologist. In an effort to obtain information on species composition and angler usage on
DWR waterways, Mr. Huntley managed creel census surveys at three locations in southern
California. These included Castaic Lake, Pyramid, Lake and Piru Creek. Piru Creek is located in the
Angeles National Forest and contains habitat for the endangered arroyo toad. Creel surveys are
supporting analysis currently underway to restore natural flows on Middle Piru Creek to benefit
populations of arroyo toad in the National Forest.
•
Rare Plant Surveys and Tree Report for the Lower Reach River Supply Conduit, Los Angeles
Department of Water and Power (2006), Biologist. Mr. Huntley managed and conducted rare plant
surveys and a comprehensive tree inventory along a 14 mile water pipeline corridor.
Owens Gorge Re-watering Project IS/MND, Los Angeles Department of Water and Power
(2006), Biologist.
Mr. Huntley prepared the biology section of the IS/MND to address potential
0\L\CHRISTIAN S. HUNTLEY, page 6
impacts to sensitive plants and wildlife along the Owens Gorge near Bishop, California. This project
involves the restoration of flows to a previously de-watered section of the Owens Gorge.
• Sunset Substation IS/MND and Biological Site Assessment, City of Banning (2006), Biologist.
Mr. Huntley is providing technical assistance and preparing the biology section of the IS/MND as a
sub-contractor to R.W. Beck. in addition, Mr. Huntley conducted burrowing owl surveys and
managed surveys for Los Angeles Pocket Mouse at select locations along the proposed right-of-way.
Perris Lake Permit Support, California Department of Water Resources (200512006), Biologist.
Mr. Huntley prepared a biological technical report to support permitting activities at Perris Lake in
Riverside California. Mr. Huntley also reviewed and prepared the Storm Water Pollution Prevention
Plan in compliance with Regional Board requirements.
• Angeles National Forest Fuels Reduction Project, Biological Evaluation/Biological Assessment,
United States Department of Agriculture Forest Service (2005/2006), Biologist. Mr. Huntley
reviewed existing documents and assisted staff in responding to comments from USES staff. Mr.
Huntley met with USES staff and conducted site inspections at several plantation and natural stands.
• Focused Surveys for least Bell's vireo and southwestern willow flycatchers at the Hansen Dam,
Los Angeles River, and San Gabriel River, US Army Corps of Engineers (2005), Project
Manager. Mr. Huntley managed the focused surveys and report preparation for this task.
Tortoise Monitoring at Las Vegas Wash Las Vegas, NV, US Army Corps of Engineers (2005-
2006), Project Manager. Mr. Huntley managed the survey and report preparation for monitoring
activities associated with this task. Monitoring crews conducted work within the Tropicana, Flamingo,
and Blue Diamond tributaries as part of the ongoing flood control activities.
• Newhall Ranch Project, California Department of Fish and Game (2005-2008), Biological
Coordinator. Mr. Huntley is assisting CDFG staff in reviewing environmental documents,
scheduling and coordinating meetings with resource professionals and agency staff, and providing
technical review of the Newhall Development Plan EIR/EIS in Santa Clarita, California. Mr.
• Line 401 PG&E Redwood Expansion Project, CPUC, Lead Environmental Monitor. Under
contract to the California Public Utilities Commission (CPUC), Mr. Huntley served as Lead Envi-
ronmental Monitor and supervised two environmental monitors in the field on the implementation of
the CPUC's conditions of approval for construction of this 14-mile natural gas pipeline. Respon-
sibilities included: supervision, guidance and development of environmental monitors, onsite field
monitoring, compliance review and mitigation development of pre-construction plans, and mitigation
compliance documentation. Other duties included review of variance and temporary extra work space
(TEWS) requests; recommendations for CPUC issuance of Notices to Proceed with construction and
variance approvals; approval of TEWS requests; preparation of weekly reports for all monitoring
activity; and coordination with PG&E, construction managers and subcontractors, local munic-
ipalities, affected and interested agencies and the public.
• Level 3 Fiber Optics Network Construction Monitoring and Supplemental Environmental
Review Program, CPUC, Environmental Monitor. Mr. Huntley's duties included inspection of
several southern California segments including Santa Barbara to Burbank, San Bernardino, Corona to
Atwood and San Diego to the California/Arizona State line. Environmental compliance during con-
struction addressed biological and cultural resource, air and water quality, traffic control, and public
utilities. Other tasks included maintaining daily documentation, review of pre-construction mitigation
measures, weekly reporting of compliance activities, and coordination with Level 3 personnel and
subcontractors, and affected agencies.CIIRISTIAN S. HUNTLEY, page 7
California Energy Commission (CEC) Coastal Power Plant Study, Deputy Project
Manager/Biologist. Conducted biological surveys at 21 coastal power plants as part of the CEC's
coastal power plant study. Site visits characterized habitat within the footprint of the power plant,
landscaping, and identified potential environmental and permitting issues associated with potential
expansion of the power plants.
• CEC Hydroelectric Power Plant Inventory Study, Deputy Project Manager/Natural Resources
Analyst. Mr. Huntley coordinated a team that collected power and environmental data on over 200
hydroelectric power plants located in California. Physical power data included electrical output,
system upgrades, water storage capacity and peaking availability. Environmental information included
developing a data base addressing sensitive species issues, fish screens and ladders, monitoring
parameters and a map of known hydroelectric facilities and barriers to anadromous fish passage. Mr.
Huntley also obtained water use information on thermal power plants in support of the CEC's bi-annual
environmental performance report.
se Arundel Barranca Habitat Restoration Plan, Ventura County Flood Control District (2005),
Biologist. Mr. Huntley developed a planting schematic for a 3000-foot section of existing flood control
channel as part of the proposed Arundel Barranca flood control channel plan.
•
Pacific Pipeline Project EIR/EIS for the US Forest Service, Angeles National Forest, and the Cali-
fornia Public Utilities Commission, Environmental Monitor. Served as an Environmental Monitor
and supervised mitigation monitoring for all sensitive resources for a construction segment along a
132-mile crude oil pipeline within southern California.
? SCE Valley-Auld Power Line Project, CPUC, Environmental Monitor. Conducted inspections of
construction of this 11-mile long power line upgrade for compliance with the project's Mitigated
Negative Declaration mitigation measures and compliance plans. Other tasks included review of pre-
construction compliance materials, maintaining inspection documentation, and coordination with SCE
and its subcontractors.
• Matilija Dam Ecosystem Restoration Project EIR/EIS, US Army Corps of Engineers, Biologist.
Mr. Huntley conducted biological surveys and assisted in the completion of the EIS/EIR to assess
impacts to sensitive biological resources located on Matilija Creek and the Ventura River downstream
of the of the Matilija Dam. The analysis focused on potential impacts associated with dam removal on
sensitive species known to occur on the Ventura River and the beneficial impacts of the restoration of
spawning territory for the endangered Evolutionary Significant Unit of Southern Steelhead.
• Piru Creek Repairs Project IS/MND, California Department of Water Resources, Biologist.
Mr.
Huntley completed sections of the US Forest Service Biological Assessment/Biological Evaluation,
and biological technical report for the Piru Creek Repairs Project. In addition, Mr. Huntley has
conducted sensitive species surveys and coordinated with CDFG, USES and RWQCB regarding
permits and sensitive species issues.
•
Viejo System Project IS/MND, California Public Utilities Commission, Biologist. Conducted
biological surveys and completed the biological section of the Initial Study and Mitigated Negative
Declaration for the SCE's transmission line upgrade project.
111
Compliance and Mitigation Development, California Public Utilities Commission, State Lands
Commission, California Department of Water Resources, Biologist. Working with technical
experts Mr. Huntley developed mitigation measures for a number of State and federal projects
including the Kinder Morgan pipeline, Santa Ana pipeline and Viejo transmission line project.
• Hollywood
Reservoir Pump Station Upgrade IS/MND, Los Angeles Department of Water and
Power Biologist. Conducted biological surveys of the lower Hollywood Hills pump station as part of
ckQCHRISTIAN S. HUNTLEY, page 8
a planned upgrade of the Los Angeles water system and completed the biological resource section of
the Initial Study and Mitigated Negative Declaration.
• Lake Skinner Filtration Plant, Metropolitan Water District, Biologist. Mr. Huntley conducted
biological surveys and completed a biological assessment at the Lake Skinner Filtration Plant to assist
Metropolitan in obtaining streambed alteration, regional water, and US Army Corps of Engineers
permits.
• Compliance and Mitigation Development, California Public Utilities Commission, State Lands
Commission, California Department of Water Resources, Biologist. Working with technical
experts Mr. Huntley developed mitigation measures for a number of State and federal projects
including the Kinder Morgan pipeline, Santa Ana pipeline and Viejo transmission line project.
San Antonio Creek Erosion Repairs Project BA/EA, US Army Corps of Engineers, Biologist.
Mr. Huntley conducted botanical surveys and prepared detailed vegetation maps within San Antonio
Creek. Mr. Huntley also prepared the Biological and Environmental Assessments for the project and
developed mitigation for sensitive plant and wildlife species.
• Santa Fe Pacific Pipeline, CPUC, Environmental Monitor. Inspected construction of three petro-
leum distribution station sites for compliance with approved project mitigation measures and
compliance plans.
• LACDA, US Army Corps of Engineers, Environmental Monitor & Biological Assessment.
Conducted inspections of Los Angeles County Drainage Area levee wall expansions for improved
flood control. Also conducted Biological Assessments for proposed project changes.
• Las Virgenes Municipal Water District IS/MND, Biologist. Conducted site surveys for sensitive
plants and animal species for potential water pipeline expansion. Prepared detailed vegetation maps
and site assessment documenting site botany and reviewed Biological Assessment for the site.
• Dent Drain Permit Support, Ventura River, Ventura County Flood Control District, Biologist.
Conducted site surveys for sensitive plants and animals and prepared Biological Assessment for
proposed construction along the Ventura River.
• Honda Barranca Permit Support, Ventura County Flood Control District, Biologist. Conducted site
surveys for sensitive plants and animals and prepared Biological Assessment for two locations
proposed for repairs along the Honda Barranca.
• Arundel Barranca Permit Support, Ventura County Flood Control District, Biologist. Conducted
site surveys for sensitive species and prepared Biological Assessment for proposed modification to
3000-feet of existing flood control channel.
• Looking Glass Networks, CPUC, Mitigation Review and Development. Mr. Huntley's duties
included review and development of mitigation measures for installation of a proposed fiber optic
interconnects located across California. Technical areas addressed included biology, soil and water, air
quality, and cultural resources.
• Spine Flower Survey, US Army Corps of Engineers, Biologist. Mr. Huntley conducted sensitive
species surveys for the slender-horned spine flower covering approximately 5,300 acres in the Santa
Ana River Wash, below the Seven Oaks Darn in San Bernardino County, to assess species impact
from changes in hydrology once the Seven Oaks Dam is operational. The survey and mapping
required extensive use of GPS equipment for the mapping of transects surveyed and the location of
spine flower Populations.CHRISTIAN S. HUNTLEY, page 9
• INS Air Station, Otay Mesa Biological Assessment, US Army Corps of Engineers, Biologist.
Conducted sensitive plant and animal surveys and prepared biological assessment for proposed and
alternative station sites, including preparation of detailed vegetation maps.
• Visalia Land Fill Biological Assessment, Biologist. Surveyed potential expansion sites for sensitive
biological species including San Joaquin kit fox, burrowing owls, and several endangered plant species.
Prepared Biological Assessment for sensitive and plant and wildlife species.
• Rancho Cucamonga, Biologist. Conducted site surveys for sensitive plants species for site suitable
for future wetland revegetation. Prepared detailed vegetation maps and site assessment documenting
site botany.
SELECTED TECHNICAL EXPERIENCE/TRAINING AND CERTIFICATIONS
SWPPP trained 2006
California Energy Commission Outstanding Performance Award, 2001
CDFG Scientific Collecting Permit for pond turtle and garter snake.
Certified Caltrans Horizontal Directional Drilling Inspector 2001
Desert Tortoise Handling Workshop, Ridgecrest California 2001
CEC Expert Witness Training 2001
Railroad Right-of-Way Safety Training 2002
Small boat handling, licensed and certified since 1993
Research Scuba-diving certification and training since 1989
0\cio
Aspen
entaiaroupl. Group
PHILIP 0. LOWE, P.E.
Senior Associate, Water and Earth Resources
ACADEMIC BACKGROUND
M.S. Watershed Management, University of Arizona, 1975
B.S. Wildlife Management, University of Arizona, 1973
REGISTRKFIONS/CERTIFICATIONS
1988 Professional Engineer (Civil)/Arizona/21699
1996 Professional Engineer (Civil)/California/55258
PROFESSIONAL EXPERIENCE
Mr. Lowe is a senior engineer and project manager with 28 years experience in the hydrologic analysis of
watersheds, water resources analysis, floodplain analysis, analysis and design of hydraulic structures, and
channel erosion and sedimentation analysis. In addition to his engineering experience, Mr. Lowe is educated
in wildlife ecology and watershed management. His responsibilities and experience include environmental
permitting and environmental impact analysis under CEQA and NEPA. Typical projects managed by Mr.
Lowe are in the following areas:
• Hydrologic analysis of watersheds
• Surface water hydraulic analysis
• Channel erosion and sedimentation analysis
• Design of flood control and erosion control structures
• Plan formulation and feasibility including benefit/cost analysis
• Environmental impact analysis
• US Army Corps of Engineers 404 Permitting
• Habitat restoration and enhancement.
Relevant project experience includes:
• Hydrology Specialist, Sunrise Powerlink Transmission Line EIR. Mr. Lowe prepared the water
resources section of an EIR/EIS for the Sunrise Powerlink transmission line. This power transmission
project would extend from the Imperial Valley to San Diego in California. Portions of the project and
project alternatives would pass through the Cleveland National Forest and the Anza-Borrego State Park.
• Hydrology Specialist, Devers/Palo Verde Transmission Line EIR. Mr. Lowe prepared the water
resources section of an EIRJEIS for the Devers/Palo Verde transmission line project extending from the
Palo Verde Nucelar Power Plant in Arizona to San Bernardino, California. One route alternative
evaluated passed through the San Bernardino National Forest near Palm Springs, California.
• Littlerock Reservoir Sediment Transport Analysis. Angeles National Forest, California. Mr. Lowe
performed a sediment transport analysis for the Littlerock Reservoir in the Angeles National Forest near
Palmdale, California for the purpose of evaluating environmental impacts associated with reservoir
dredging. The analysis consisted of an assessment of hydrologic conditions, field survey of river and
reservoir topography and sediment conditions, hydraulic analysis using HEC-RAS, and sediment
transport analysis using the FIEC-RAS sediment transport package. Mr. Lowe developed sediment
dredging alternatives and evaluated potential upstream impacts from the alternatives using sediment
transport analysis. The alternatives were evaluated and compared, and mitigation measures developed to
avoid upstream impacts.
99PHILIP 0. LOWE, page 2
• Littlerock Reservoir Slurry Analysis. Palmdale, California. Mr. Lowe is project manager for a
feasibility analysis of using a slurry dredging operation to excavate sediment from the Littlerock
Reservoir. Accumulated sediments are compromising the water storage capacity. The study will
determine the feasibility of using a dredge and slurry operation as an alternative to conventional trucking
to excavate and transport up to 2,000,000 cubic yards of sediment a distance of approximately six miles.
• Littlerock Reservoir Grade Control Design. Palmdale, California. Mr. Lowe is project manager for
final design of a grade-control structure to control adverse upstream effects of excavation of up to
2,000,000 cubic yards of sediment from the Littlerock Reservoir near Palmdale, California.
• Staff Assessment for Cosumnes Power Plant, California Energy Commission. Mr. Lowe prepared
the surface water and soils analysis in the Soil and Water Resources sections of the Final Staff
Assessment for the proposed Cosumnes Power Plant in Sacramento County.
Staff Assessment for Tracy Peaker Power Plant, California Energy Commission. Mr. Lowe
prepared the Soil and Water Resources section of the Final Staff Assessment for the proposed Tracy
Peaker Power Plant near Tracy, California.
• SONGS/Diablo Canyon Steam Generator Replacement Project Environmental Impact Report
(FIR). Mr. Lowe prepared the water resources analysis in preparation of an EIR for replacement of the
steam generators at Southern California Edison's San Onofre Nuclear Generating Station near San
Clemente in San Diego County, as well as for a similar EIR for the Diablo Canyon nuclear power plant
near San Luis Obispo.
• Viejo System Project Transmission Line EIR. Mr. Lowe was responsible for preparation of an Initial
Study under the California Environmental Quality Act (CEQA) for a 3.1-mile electrical transmission line
to be located in southern Orange County, California.
• Loop 303 Camelback Basins Candidate Assessment Report. Flood Control District of Maricopa
County. Mr. Lowe is project manager for a Candidate Assessment Report to update the hydrologic
analysis and develop flood control alternatives to revise the Loop 303 Corridor/White Tanks Area
Drainage Master plan in western Marieopa County, Arizona. The project involves hydrologic analysis
using HEC-1 for the 65-square-mile watershed, and hydraulic analysis, development and evaluation of
alternatives, stakeholder involvement, and development of a recommended plan for a flood-control
project to be built in conjunction with the proposed Loop 303 freeway.
• Durango Regional Conveyance Channel Master Plan. Flood Control District of Maricopa County.
Mr. Lowe was project manager for hydrologic and hydraulic analysis, including alternatives analysis and
conceptual master plan of drainage for the Durango Regional Conveyance Channel in Phoenix and
Avondale, Maricopa County, Arizona. The analysis included development of discharges along the
drainage channel for a range of existing and improved scenarios, preparing a conceptual plan for
development drainage in the event the channel is not constructed, developing a range of drainage master
plan alternatives with cost estimates, and drainage master plan recommendation including 10% plans.
• Sunland Channel Master Plan. Flood Control District of Maricopa County. Mr. Lowe was project
manager for a master plan of drainage for the Sunland Channel in Avondale, Maricopa County, Arizona.
The analysis included hydrologic evaluation using HEC-1, development of master plan alternatives with
cost estimates, coordination with stakeholders, preparing a conceptual plan for development drainage in
the event the channel is not constructed, and preparing a recommended plan with cost estimate and 10%
plans.
• Los Angeles Unified School District (LAUSD) Program Environmental Impact Report for New
School Construction. Mr. Lowe prepared the water resources section for a program EIR for a new
school construction program for the Los Angeles Unified School District. The purpose of the ProgramPHILIP 0. LOWE, page 3
DR was to establish a consistent process for CEQA review of future LAUSD projects proposed in the
New School Construction program. The purpose of the program was to provide 200,000 new classroom
seats in order to accommodate anticipated enrollment growth.
• Ranchos Soldados Drainage Report, Tucson, Arizona. Mr. Lowe was responsible for the preparation
of a drainage report for a 160-acre residential development in eastern Tucson, Arizona. The analysis
included hydrologic analysis using the Pima County hydrology method, floodplain delineation for five
watercourses, building setback analysis, 404 jurisdictional delineation, hydraulic design of proposed
roadway culvert, scour analysis for utilities and roadway crossings, and preparation of a drainage report
describing existing and post-development conditions.
• City of Phoenix Drainage Improvements. Mr. Lowe was project manager for alternatives analysis,
plan recommendation, and 30% plans for drainage improvements at a site within the City of Phoenix for
the purpose of eliminating ponding as a means of mosquito control. The project, in an established
drainageway, involved hydrologic and hydraulic analysis, development of innovative solutions for
developing positive drainage in difficult situations, cost estimating, evaluation of alternatives, and
development of preliminary plans.
• Miguel Mission Transmission Line UR. Mr. Lowe prepared the hydrology and water resources section
of this EIR being prepared on behalf of the California Public Utilities Commission evaluating a proposed
35-mile transmission line in San Mateo County. Work included preparation of an initial study prior to
preparation of the EIR document.
• Jefferson-Martin Transmission Line EIR.
Mr. Lowe prepared the hydrology and water resources
section of this ER being prepared on behalf of the California Public Utilities Commission evaluating a
proposed 27-mile transmission line in San Mateo County.
Kinder Morgan Concord to Sacramento Pipeline EIR. Mr. Lowe prepared the hydrology and water
resources section of an EIR evaluating a proposed 70-mile petroleum products pipeline for the California
State Lands Commission. Analysis includes consideration of potential for pipeline accidents to
contaminate surface and groundwater in Contra Costa, Solano, and Yolo Counties.
•
Sulphur Creek Ecosystem Restoration, US Army Corps of Engineers (Corps), Los Angeles District.
Mr.
Lowe was project manager responsible for preparing a Detailed Project Report for ecological
restoration of approximately one half mile of Sulphur Creek in the City of Laguna Niguel, CA. The
project involved hydrologic and hydraulic analysis of the creek, hydrogeomorphic analysis of stream
functional capacity, and development of a plan to restore stream functional capacity lost through urban
development and encroachment.
• Wood Canyon Ecosystem Restoration, Corps, Los Angeles District. Mr. Lowe was responsible for a
Detailed Project Report for riparian restoration of Wood Canyon Creek in Orange County, CA. The
project involved hydrogeomorphic evaluation of stream functional capacity, and design of restoration
features to increase functional capacity.
• Agua Fria Ecosystem Restoration, Corps, Los Angeles District.
Mr. Lowe prepared the preliminary
hydrologic and hydraulic analysis for the Agua Fria ecosystem restoration project in Maricopa County,
Arizona.
• Cache Creek Environmental Impact Report, Yolo County, CA. Mr. Lowe prepared the hydrologic
impact analysis for the Cache Creek Resource Management Plan environmental impact report.
• Hydrologic Analysis for the Pacific Pipeline EIS/SEIR, Kern and Los Angeles Counties.
As a
subconsultant to Aspen and on behalf of the CPUC, Mr. Lowe was responsible for preparation of the
hydrologic analysis section in support of an EIR/E1S under CEQA and NEPA for a 58-mile oil pipeline
10 iPHILIP 0. LOWE, page 4
route originating in Kern County and terminating in Santa Clarita. The pipeline crosses 62 watercourses,
including 24 that drain directly into water supply reservoirs. Mr. Lowe evaluated baseline conditions and
potential groundwater, water quality, stream hydrology, hydraulic, and sediment transport impacts for
each crossing of the proposed and alternate routes.
Flood Control Studies for Arizona Communities, US Army Corps of Engineers. Mr. Lowe was
responsible for preparation of 43 US Army Corps of Engineers Continuing Authorities Program flood
control studies for communities in ten Arizona counties. The purpose of the studies was to make
determinations regarding potential Federal interest in flood and erosion control projects at the earliest
possible stage of Federal investigation. The project involved (1) data collection; (2) a field investigation;
(3) description of the flood or erosion problem and problem history; (4) hydrologic and hydraulic
evaluation; (5) assessment of flood-related damages, (6) development of preliminary flood control and
erosion-control alternatives; (7) estimate of benefits and costs; and (8) preliminary environmental
evaluation.
• Los Angeles River Alternatives Study (LARAS). Mr. Lowe was project manager for the LARAS study
initiated by Los Angeles County to investigate alternatives to the US Army Corps of Engineers Los
Angeles County Drainage Area feasibility plan for flood protection along the lower Los Angeles River in
Los Angeles, CA. The LARAS Study conducted by Mr. Lowe involved engineering and environmental
feasibility investigations of channel widening, use of existing sand and gravel mines as detention basins,
re-operation of Whittier Narrows, Santa Fe and other reservoirs, raising Whittier Narrows Dam,
watershed management solutions, detention in groundwater spreading basins, habitat restoration, water
supply, and recreation.
• Gila River Indian Community Planning Assistance, US Army Corps of Engineers. Mr. Lowe
developed and directed a study to develop flood control and erosion control strategies for the Gila River
Indian Community near Blackwater, Arizona. The study made an evaluation of Gila River hydrology,
hydraulics, floodplain limits and erosion potential. The flooding potential was evaluated using a two-
dimensional flow model adapted to evaluating flood conditions for a range of discharges on the wide,
braided floodplain.
• Pacific Heights Environmental Impact Report for, Los Angeles County, CA. Mr. Lowe was
responsible for the preparation of an environmental impact report under CEQA for a 50-unit residential
development on a 110-acre, designated significant ecological area in the community of Hacienda Heights,
CA. FIR issue areas included biology, drainage, geology and soils, visual resources, traffic and access,
land use and public services.
• San Antonio Creek Hydraulic and Sediment Analysis, Vandenberg Air Force Base. Severe
accumulation of fine sediments in San Antonio Creek on Vandenberg Air Force Base resulted in loss of
roadway access across the creek near the point where the creek enters the Pacific Ocean. Mr. Lowe was
project manager responsible for a hydrologic, hydraulic and sediment transport analysis to determine
sources and rate of sediment accumulation, and development of long-term crossing solutions.
• Mission Zanja Flood Control Feasibility Study. Mr. Lowe was project manager for a Corps of
Engineers feasibility-level hydraulic analysis and design for drainage improvements to reduce flooding
along the Mission Zanja drainageway through the City ofRedlands in San Bernardino County, CA. The
project involved: (I) detailed hydraulic analysis of the existing Mission Zanja culvert through the
downtown area; (2) development and hydraulic analysis of alternatives for an improved inlet to the
culvert; (3) sediment-transport analysis of all alternatives; (4) assessment of economic benefits; (5)
preliminary design and quantity estimates; and (6) preparation of concept design plans.
• San Antonio Creek Reconnaissance Study, Upland,
CA. Mr. Lowe was Project Manager of a
reconnaissance study of San Antonio Creek for the US Army Corps of Engineers. The study included aPHILIP 0. LOVE, page 5
detailed hydraulic capacity analysis, fioodplain analysis, general inventory of and valuation of floodplain
structures, determination of potential without-project flood control and water supply benefits and
development of potential flood control and water supply solutions along an 11-mile, urbanized reach to
the San Antonio Creek flood control channel in western San Bernardino County, CA,
• San Juan Creek River Management Plan, City of San Juan Capistrano. Mr. Lowe was project
manager for reconnaissance-level development of a comprehensive plan for erosion control, flood
reduction, riparian vegetation, and wetland restoration and comprehensive management of San Juan
Creek in Orange County. Long-term aggregate mining, agricultural use, urban runoff, channelization and
piece-meal bank protection have caused significant degradation of the channel system, impacting water
quality, beach sand supplies, and the functions and values of the ecosystem. The river management plan
includes the removal of large drop structures and levee impoundments to facilitate movement of fish, re-
establishment of a riffle-pool sequence with frequent, gentle low drops protected by riprap, re-
establishment of riparian and wetland vegetation between riffles, and construction of gabion, riprap or
articulated revetment bank protection to protect existing infrastructure.
• Lytle Creek Levee Design, San Bernardino County, CA. Mr. Lowe was responsible for hydrologic,
hydraulic and sediment transport analysis, concept design and 404 Permit application for a two-mile soil-
cement levee to protect an 800-acre sand and gravel mine on the Lytle Creek alluvial fan in San
Bernardino County, CA. Analysis included a HEC-2 evaluation of pre- and post-project conditions, an
evaluation of alternative bank protection materials, a sediment transport analysis using a quasi-dynamic
sediment routing model, scour analyses, and evaluation of expected long-term changes in channel bed
profile. The levee was constructed of soil cement at a substantial cost saving in comparison to traditional
bank protection materials. As part of this project Mr. Lowe prepared a 404-Permit application, with
supporting report, documenting impacts to waters of the US and to threatened and endangered species,
with mitigation.
• San Antonio Parkway Bridge Scour Analysis. Mr. Lowe conducted river geomorphology, hydraulic
and sediment modeling studies to determine scour depths, long-term degradation and lateral erosion
potential for design of a major bridge over San Juan Creek in Orange County, CA.
• Hydrologic Analysis for the Pacific Pipeline Environmental Impact Report, Santa Barbara County,
Ventura County and Los Angeles County, CA. Mr. Lowe was responsible for the preparation of the
hydrology section in support of an environmental impact report under CEQA for a 170-mile pipeline
route originating from Gaviota, Santa Barbara County and terminating at Long Beach, Los Angeles
County. The project included hydrologic, hydraulic, groundwater, water quality, erosion, and
sedimentation evaluation for approximately 150 stream crossings. Mr. Lowe prepared the hydrology
section of the EIR consisting of impacts analysis, cumulative impacts, mitigation measures, and the
alternatives analysis.
• Desert Greenbelt 404 Permit Application, Scottsdale, Arizona. Mr. Lowe was project manager on
obtaining the 404 Permit with the Corps of Engineers for the City of Scottsdale's Desert Greenbelt
project. Desert Greenbelt is a five-mile flood-control channel on an alluvial fan in Scottsdale, Arizona.
• Project Manager, Gila River Riparian Restoration. Mr. Lowe was project manager for preparation of
a reconnaissance report for habitat restoration along the Gila River between Painted Rock Dam and the
Colorado River in Maricopa and Yuma Counties, Arizona. The Gila River riparian area, formerly a lush
habitat of cottonwood, willow, mesquite and marsh habitats prior to the modern era, has been severely
degraded by farming, the construction of dams upstream, and the intrusion of the invasive salt cedar
which is favored by the hydrologic regime formed by the dams.
• Yellowstone Pipeline Environmental Impact Statement Hydrologic Analysis. Mr. Lowe was
responsible for preparation of the hydrologic and hydraulic analysis in support of the Yellowstone
L03PHILIP 0. LOWE, page 6
Pipeline Environmental Impact Statement under NEPA for the Lobo National Forest in Montana. The 10-
inch pipeline carries gasoline, diesel, and jet fuel between Missoula, Montana, and Cataldo, Idaho. Six
alternative routes totaling approximately 300 miles in length are being investigated in detail. Mr. Lowe
was responsible for evaluating potential hydrologic, hydraulic, sediment, groundwater, and water quality
impacts along each alternative and at each stream crossing. Secondary impacts such as oil spills, rupture,
or exposure of pipe through erosion or other impacts related to the stream are also evaluated. He assessed
the severity of potential impacts, developing mitigation measures and prepared a report consistent with
the format and guidelines required by NEPA.
•
Crude Oil Pipeline Investigations and Hydraulic and Hydrologic Analyses of Oil Spill Sites for
Counties in the States of Missouri, Kansas, and Texas. Mr. Lowe was project manager for an evaluation
of oil spills from a network of hundreds of four- to eighteen-inch crude oil pipelines across the midwestem
United States. •Due to deterioration of the network, oil spills occurred over a three-state area, potentially
impacting thousands of square miles of surface waters. Mr. Lowe performed a hydrologic analysis by
regional equation method, determined probable limits of the waters of the US, and evaluated the extent or
potential environmental impacts associated with the oil spills. Approximately 130 oil spill sites spread over
several counties in the states of Missouri, Kansas, and Texas were investigated.
• San Vicente Reservoir Pipeline EIR Hydrologic Analysis.
Mr. Lowe was a task leader responsible for
the hydrologic and hydraulic analysis in support of an environmental impact report for a 28-mile pipeline to
carry tertiary treated wastewater from the North City Wastewater Treatment Plant to San Vicente Reservoir
in San Diego County, CA. Two alternative routes were investigated. Mr. Lowe evaluated potential
hydrologic, hydraulic, sediment, groundwater, and water quality impacts along each alternative and at
each stream crossing. Secondary impacts related to rupture or exposure of pipe through erosion or other
impacts stream were also evaluated. Mr. Lowe also assessed the severity of potential impacts, developed
mitigation measures and prepared a report consistent with the format and guidelines required by the
California Environmental Quality Act (CEQA).
• Rio Salado Reconnaissance Study.
Mr. Lowe was Delivery Order Manager for the Rio Salado
Reconnaissance Report for the United States Corps of Engineers. The report presented the results of an
investigation into the feasibility of habitat restoration and riparian enhancement along 28 miles of the Salt
River in Tempe and Phoenix, Arizona. Alternatives investigated included construction of an inflatable
dam for water impoundment and riparian enhancement in the Salt River at Tempe, mesquite forest and
wetland enhancement in the Indian Bend Wash at Tempe, construction of a fisheries lake, habitat
restoration and recreation enhancements along the Salt River in Phoenix, and use of treated wastewater
for riparian enhancement at the confluence with the Gila River. Benefits and costs were estimated and
presented in a comprehensive report.
• Unnamed Wash Drainage Improvement, Laughlin, Nevada.
Mr. Lowe was responsible for revising
the Unnamed Wash flood-control master plan for Clark County, Nevada. The Unnamed Wash, located at
Laughlin, is an alluvial watershed with an undersized flood-control channel and a history of severe
flooding damage. The project included hydrologic, hydraulic and sediment-transport evaluation of
existing and proposed conditions, evaluation of alternatives, concept design, preparation of information
for an assessment district, final design, and application for permits, including a US Army Corps of
Engineers 404 Permit. Features of the revised Master Plan included a soil-cement entrance transition,
soil-cement channels with grade-control structures, a baffle-chute drop structure, and a sediment basin to
collect transported sediments prior to entry into the Colorado River.
• North Scottsdale Flood Control Reconnaissance Study.
Mr. Lowe was project manager on preparation
of a US Army Corps of Engineers reconnaissance report for flood protection in the North Scottsdale area
of Maricopa County, Arizona.
0)\PHILIP 0. LOWE, page 7
• Plunge Creek Levee Design, San Bernardino County, CA. Mr. Lowe was responsible for hydrologic,
hydraulic and sediment transport analysis, concept design and 404 Permit application for a 1.3-mile, soil-
cement levee to protect an existing 860-acre sand and gravel mine on the Plunge Creek alluvial fan in San
Bernardino County, CA. Analysis included a HEC-2 evaluation of pre- and post-project conditions, an
evaluation of alternative bank protection materials, a sediment transport analysis, scour analyses, and
evaluation of expected long-term changes in channel bed profile. Mr. Lowe developed a levee concept
design, with supporting report, for use in preparation of an environmental impact report for the project.
As part of this project Mr. Lowe prepared a 404-Permit application, with supporting report.
• City of Tucson Drainage Standards Manual, Tucson, Arizona. Mr. Lowe assisted in the preparation
of a comprehensive drainage standards manual for the City of Tucson, Arizona. The manual included
hydrologic procedures, methods of hydraulic and floodplain analysis and design procedures. Mr. Lowe
had full responsibility for developing and writing the sections on storm drain design, open channel
design, and erosion and sedimentation.
• Project Manager, Arroyo Chico and Alamo Wash Basin Management Plans, Tucson, AZ. Mr.
Lowe was responsible for development of the Arroyo Chico and Alamo Wash Basin Management Plans
in Tucson. The Arroyo Chico and Alamo Wash originate in and drain through urban areas of the City of
Tucson. They are both short-duration, high-flood-peak watersheds. The basin management plan projects
included hydrologic and hydraulic analysis of existing conditions, floodplain mapping, evaluation of
potential flood damage, development of flood-control alternatives, detention routing, cost estimates, eco-
nomic analysis, and development of a preliminary capital improvement program for the City of Tucson.
These projects included using the Corps HEC-1 and HEC-2 programs, floodplain mapping, identification
of flood hazard areas and evaluation of potential economic risk of flooding.
• Emergency Response to 1993 Mississippi River Floods, US Army Corps of Engineers. Assisted in
mobilization of project team to St. Louis, Missouri, area within 36 hours from the notice to proceed with
the project. Located, posted and documented high water marks for the summer 1993 flooding along the
Mississippi River, Meremac Creek and River Des Peres, near St. Louis, Missouri. The 1993 flood
elevations were determined in order to guide reconstruction of the floodplain areas in a manner that
would optimize opportunities for hazard mitigation. A computerized data base retrieval system was
developed for management of the high water mark information. Reviewed the accuracy of existing
floodplain maps of the disaster area and its vicinity and compared them to the 1993 event.
• Environmental Impact Report for a Sand and Gravel Mine, Riverside County, CA. Mr. Lowe was
responsible for preparation of an environmental impact report under CEQA for a 190-acre sand and
gravel mine in the Temescal Wash of western Riverside County. Environmental issues included erosion
and sedimentation, floodplain impacts, transportation and circulation, geotechnical impacts, visual
impacts, vegetation, wildlife, noise, endangered species, air quality, water quality, cultural resources and
public safety.
• Reclamation Plan for Dawson Canyon Mine. Mr. Lowe prepared a reclamation plan for a sand and
gravel mine in the Temescal Wash at Dawson Canyon in Riverside County, CA. Reclamation included
planting of native vegetation, screening and installation of soil cement drop structures to control
head cutting in the Temescal Wash.
• Laughlin Bay Boat Lagoon and Wetland Enhancement, Laughlin, NV. Mr. Lowe was responsible
for the design and US Army Corps of Engineers 404 Permit application for a boat lagoon and wetland
enhancement project in Laughlin Bay at Laughlin, Nevada. The project included analysis of Colorado
River and tributary hydrology, hydraulic analysis of the existing bay, design of a boat lagoon that would
also serve as flood protection for the bay, and preparation of a wetland mitigation program acceptable to
the Army Corps of Engineers, the United States Environmental Protection Agency, the United States Fish
SPHILIP 0. LOWE, page 8
and Wildlife Service, the Nevada Department of Wildlife and the Nevada Department of Environmental
Protection.
Environmental Constraints Analysis for a Residential Development in Apple Valley, CA. Mr. Lowe
was responsible for preparation of an environmental constraints analysis for a proposed 1,100-acre
development project in the Apple Valley area of San Bernardino County, CA. The constraints analysis
was prepared as an Environmental Impact Report for developing acceptable land use criteria and
mitigation measures for preliminary planning of the project. The analysis included an overall analysis of
a surrounding 35,000-acre area for regional planning purposes. Environmental issues included
endangered species (desert tortoise), flooding, earthquake faulting, traffic, land use, wildlife, vegetation,
aesthetics, water supply, wastewater treatment, air quality, cultural resources, and paleontological
resources.
\to'PAspen
Environmental Group
JASON W. RICKS
Associate Environmental Scientist
ACADEMIC BACKGROUND
M.S. Environmental Public Health, TuIane University, New Orleans, LA, 1998
B.S. Biology, Alma College, Alma, MI, 1994
PROFESSIONAL EXPERIENCE
Mr. Ricks has over 10 years of professional environmental science and health and safety experience. He
has spent the past five years working as a Project Manager and analyst for environmental reviews under
CEQA and NEPA, working on over 30 infrastructure, public facility, and development projects. Mr.
Ricks specializes in NEPA and CEQA project management and documentation with a particular focus in
traffic and transportation, environmental contamination, and hydrology analysis. He also has four years of
environmental site assessment experience.
Aspen Environmental Group 2006 to present
• Tehachapi Renewable Transmission Project EIR/EIS. Mr. Ricks is serving as the Issue Area
Coordinator for physical science technical sections for a joint EIR/EIS for the California Public
Utilities Commission (CPUC) and USDA Forest Service for an extensive series of transmission
system upgrades spanning Kern, Los Angeles, and San Bernardino Counties. Mr. Ricks is managing
the Physical Sciences team in analyzing potential impacts to air quality; noise; geology, soils, and
paleontology; environmental contamination; hydrology; fire prevention and suppression; and traffic
and transportation.
• El Casco System Project EAR. Mr. Ricks completed the Geology and Soils, Hazards and Hazardous
Materials, Hydrology, and Terrorism analyses for the EIR being prepared for the CPUC. The
Proposed Project would be located in a rapidly growing area of northern Riverside County, which
includes the Cities of Beaumont, Banning, and Calimesa. A 115-kV subtransmission line begins at
Banning Substation and extends westward toward the proposed El Casco Substation site within the
existing Banning to Maraschino 115-kV subtransmission line and Maraschino-El Casco 115-kV
subtransmission line ROWs.
• Ventura River Bank Restoration Project IS/MND. Mr. Ricks is the Project Manager preparing a
MND for the Ventura County Watershed Protection District to address impacts associated with
restoring the flood protection function of the Ventura River Bank. Mr. Ricks is responsible for all
aspects of the project including content editing, client interaction, schedule maintenance, staff
coordination, alternatives analysis, and budget tracking.
• LADWP Distribution Station #144 IS/MND. Mr. Ricks is the Project Manager preparing a MND
for the Los Angeles Department of Water and Power for a new electrical distribution station in
downtown Los Angeles. Mr. Ricks is responsible for all aspects of the project including content
editing, client interaction, schedule maintenance, staff coordination, alternatives analysis, and budget
tracking.
so Port of Los Angeles Channel Deepening Project, Supplemental EIS/E1R. Mr. Ricks is the
Deputy Project Manager preparing a joint Supplemental EIS/EIR for the US Army Corps of
[o1JASON. W. RICKS, page 2
Engineers and the Port of Los Angeles to address impacts associated with providing additional
disposal capacity to complete the Port's Channel Deepening Project. Mr. Ricks developed the
methodology and approach to impact analysis for the SEIS/SEIR and is responsible for all aspects of
the project including content editing, client interaction, schedule maintenance, staff coordination,
alternatives analysis, and budget tracking.
• Littlerock Reservoir Sediment Removal EIRJEIS. Mr. Ricks conducted analysis and prepared the
Geology, Hydrology, and Hazards sections of the joint EIR/EIS for the Littferock Reservoir Sediment
Removal EIR/EIS prepared for the Palmdale Water District and Angeles National Forest. This
document was prepared to document the potential effects of constructing a grade control structure and
excavating up to 540,000 cubic yards of sediment from Littlerock Reservoir in order to restore the
water storage capabilities for beneficial use and prevent sediment loss of the upstream channel.
? Cabrillo Port Liquefied Natural Gas (LNG) Deepwater Port, Ventura County, CA. Under
contract to the City of Oxnard, Aspen was tasked to review the Draft EIS/EIR for this the proposed
construction and operation of an offshore floating storage and regasification unit (FSRU) that would
be moored in Federal waters offshore of Ventura County. As proposed, liquefied natural gas (LNG)
from the Pacific basin would be delivered by an LNG Carrier to and offloaded onto, the FSRU; re-
gasified; and delivered onshore via two new 21.1-mile (33.8-kilometer), 24-inch (0.6-meter) diameter
natural gas pipelines laid on the ocean floor. These pipelines would come onshore at Ormond Beach
near Oxnard, California to connect through proposed new onshore pipelines to the existing Southern
California Gas Company intrastate pipeline system to distribute natural gas throughout the Southern
California region. Mr. Ricks reviewed the document for technical adequacy and assisted the City in
preparing written comments for the following sections of the EIS/EIR: Ground Transportation and
Marine Traffic.
• Antelope Segments 2 and 3, 500-kV Transmission Project. Mr. Ricks conducted analysis and
prepared the Traffic section of the EIR for the California Public Utilities Commission (CPUC). This
EIR was prepared for a 56.7-mile 500-kV transmission line proposed by Southern California Edison
(SCE) to serve wind power projects in the Antelope Valley in Los Angeles County and the Tehachapi
area in Kern County.
• Antelope-Pardee 500-kV Transmission Project. Mr. Ricks conducted analysis and prepared the
Traffic section of the joint EIR/EIS for the California Public Utilities Commission (CPUC) and
USDA Forest Service. This EIR/EIS was prepared for a 25.6-mile 500-kV transmission line proposed
by Southern California Edison (SCE) to serve wind power projects in the Antelope Valley in Los
Angeles County and the Tehachapi area in Kern County.
• Sunrise Powerlink Project EIR/EIS. Mr. Ricks devised the methodology for analysis of cumulative
impacts of the 21 different alternatives to the Proposed Project. This methodology provided
comprehensive analysis of potential cumulative impacts while realizing efficiencies to avoid
redundancy in analyzing impacts that consisted of short reroutes of portions of the overall 150-mile
linear corridor project. He also prepared programmatic impact analysis for a solar thermal power
plant and solar photovoltaic project as part of the non-wires alternative to the Proposed Project.
• Newhall Ranch Specific Plan CEQA Consultation Services. Under contract to the California
Department of Fish and Game (CDFG), Mr. Ricks is assisting the CDFG and Corps of Engineers in
the preparation of an EIR/EIS for a master Streambed Alteration Agreement, Section 404 Permit, and
Section 2081 Take Permit (for the San Fernando Valley Spineflower) for the Newhall Ranch Specific
Plan. Mr. Ricks is providing expert technical review services for the following issue areas: hazards
and hazardous materials, visual resources, public utilities, socioeconomics, and environmental justice.
D'61JASON. W. RicKs, page 3
? Sunset Substation and Transmission and Distribution Project CEQA Documentation, Banning,
CA. Mr. Ricks conducted analysis and prepared the mineral resources, geology and soils, hazards
and hazardous materials, and hydrological sections for an Initial Study for the City of Banning. The
City proposes to construct the Sunset Substation and supporting 33-kilovolt (kV) transmission line
that would interconnect with the City's existing distribution system. The purpose of this new
substation and transmission is to relieve the existing overloads that are occurring within the City's
electric system and to accommodate projected growth in the City.
• California Energy Commission (CEC), Technical Assistance in Application for Certification
Review. In response to California's power shortage, Aspen is assisting the CEC in evaluating the
environmental and engineering aspects of new power plant applications throughout the State. As part of
this effort, Mr. Ricks is serving as a technical specialist for traffic and transportation for several
power plant projects:
• Chevron Power Plant Replacement Project. Mr. Ricks conducted analysis and prepared the traffic
portion of the Initial Study for the Chevron Power Plant Replacement Project at the existing Chevron
Refinery in Richmond, CA.
• Carrizo Energy Solar Farm. Mr. Ricks is preparing the traffic and transportation portion of the Staff
Assessment for a new solar thermal power plant in Luis Obispo County.
• Chula Vista Energy Upgrade Project Mr. Ricks is preparing the traffic and transportation portion of the
Staff Assessment for upgrading and expanding an existing peaker plant.
• Humboldt Bay Repowering Project. As technical senior, Mr. Ricks managed the analysis of the traffic
portion of the Staff Assessment for replacement of a natural gas fired generator at the existing Humboldt
Bay Power Plant.
• lvanpah Solar Electric Generating System. Mr. Ricks is preparing the traffic and transportation portion
of the Staff Assessment for a new solar thermal power plant in west San Bernardino County.
PREVIOUS EXPERIENCE
Los Angeles Unified School District 2004 to 2006
As a CEQA Project Manager for the Los Angeles Unified School District (LAUSD), Mr. Ricks directed and
oversaw the work of several teams of CEQA professionals to produce CEQA documentation for more
than 12 new elementary and high school construction projects. He was responsible for evaluating
proposals, directing and reviewing analysis of all CEQA documents, developing schedules, tracking and
reporting project progress, and managing the budget for each project. He also organized and conducted all
Scoping and Draft EIR community public meetings for each project.
Meredith and Associates 2002 to 2004
As an assistant Project Manager, Mr. Ricks: performed technical reviews of soil and groundwater
investigations to support environmental litigation; developed Health and Safety Policy and Procedures for a
local school district; and prepared Phase I environmental assessments.
Tetra Tech Inc. 2001 to 2002
As a Staff Scientist, Mr. Ricks: researched and wrote Phase I and Phase II environmental assessments, soil
and ground water monitoring reports, and health and safety plans for environmental remediation projects;
collected and analyzed quantitative soil and groundwater data; and coordinated, conducted, and supervised
remediation fieldwork activities.
tDc‘JASON. W. RICKS, page 4
City of Wladyslawowo 1998 to 2000
As a U.S. Peace Corps Volunteer in Wladyslawowo, Poland, Mr. Ricks: managed a grant project to develop
a community environmental education park; researched and wrote grant applications for municipal
infrastructure projects; and taught environmental-content English language lessons to middle school and
high school students.
IR. Simplot
1995 to 1997
As a Microbiologist Mr. Ricks established and managed a quality assurance microbiology testing program
for a food processing company and worked with sanitation staff to improve strategies to meet FDA and
HACCP health and safety standards.
ADDITIONAL TRAINING AND COURSES
Advanced CEQA Training, UCLA Extension, June 2007
• California Environmental Quality Act (CEQA) Compliance Workshop, January 2005
• 8-Hour Health and Safety Refresher Course, March 2002
• 24-Hour Hazardous Waste Operations Training, March 2001
• Project Management Training, Stare Pole, Poland, 1999Aspen
nvironniental Group
VIDA STRONG
Senior Environmental Engineer and Project Manager
ACADEMIC BACKGROUND
Master of Urban Planning, San Jose State University, 1991
B.S., Engineering, California Polytechnic State University, San Luis Obispo, 1987
PROFESSIONAL EXPERIENCE
Ms. Strong has extensive experience in environmental engineering and project management, with an
emphasis in the application of CEQA and NEPA in analysis and resultant mitigation monitoring of
controversial development projects. She has managed the mitigation monitoring, compliance, and report-
ing programs for numerous industrial projects on behalf of the permitting agencies. In addition, she has
been involved in the management and preparation of environmental documents for numerous industrial
projects, requiring the critical application of alternatives development and screening criteria, knowledge
of a broad range of issue areas, and extensive local, State, and federal agency coordination. Prior to
joining Aspen Environmental Group, Ms. Strong was an Energy Specialist for the Santa Barbara County
Planning and Development Department's Energy Division, where she managed the permitting and
environmental review of major oil and gas development projects and proposals, and oversaw the
implementation of mitigation monitoring plans.
Aspen Environmental Group 1994 to present
Ms. Strong's project experience at Aspen includes the following:
• Project Manager, Lompoc Wind Energy Project Final EIIL Under contract to Santa Barbara
County, Energy Division, Ms. Strong is currently managing the preparation of the Final EIR for the
proposed Lompoc Wind Energy Project. This project involves the installation of 60 to 80 wind
turbines and associated facilities including an approximately 8 mile 115kV power line, electrical
collection and distribution lines, substation, meteorological towers, onsite access roads and road
improvements, communication system, and operation and maintenance facility. The EIR focuses on
the potential impacts associated with project construction and operation. Operational issues of
concern include avian mortality and long-term visual impacts associated with project facilities within
a rural environment.
• Project Manager, PXP Tranquillon Ridge Development Project EIR. Under contract to Santa
Barbara County, Energy Division, Ms. Strong is currently managing the preparation of an EIR for the
proposed PXP Tranquillon Ridge Development Project. This project involves extended reach drilling
from Platform Irene in federal waters into the Tranquillon Ridge Field located in State waters. Oil
emulsion and gas production would be transported from Platform Irene in existing pipelines to the
Lompoc Oil and Gas Plant (LOOP). The EIR focuses on the potential impacts associated with the
extended reach drilling activities and extension of life of Platform Irene, the existing pipelines, and
LOGP. The development of an onshore drilling facility and associated pipelines is also being
assessed as an alternative. Issue areas of concern include system safety/risk of upset, marine biology
and water quality, fisheries, terrestrial biology, hydrological resources, cultural resources, air quality,
land use, noise, and traffic.VmA STRONG, page 2
• Project Manager, PG&E Delta DPA Capacity Increase Substation Project. Under contract to the
California Public Utilities Commission (CPUC), Ms. Strong is currently managing the mitigation
montoring, compliance, and reporting program for the PG&E Delta DPA Capacity Increase
Substation Project. This project includes a proposed electric substation site, a new loop segment of
an existing 230 kV transmission line, a temporary asphalt road, and a temporary bridge over Sand
Creek in eastern Contra Costa County, within the limits of the City of Antioch, California. As Project
Manager, Ms. Strong is responsible for the field monitoring effort, Notice to Proceed and Variance
Request recommendations sent to CPUC, agency coordination, and Weekly Reporting. Construction
of this project began in September 2007.
• Project Manager, SCE Riverway Substation Project. Under contract to the California Public
Utilities Commission (CPUC), Ms. Strong is currently managing the mitigation montoring,
compliance, and reporting program for the SCE Riverway Substation Project. This project involves
the construction of a new 1.7-acre 66/12 kV low-profile substation with two 28 MVA transformers
and six 12 kV distribution lines in the City of Visalia. The project also includes approximately 1,200
feet of underground 66 kV subtransmission lines, as well as new fiber optic cable and communication
equipment to connect the substation to SCE's existing telecommunication system. . As Project
Manager, Ms. Strong is responsible for the field monitoring effort, Notice to Proceed and Variance
Request recommendations sent to CPUC, agency coordination, and Weekly Reporting. Preliminary
site preparation for this project began in October 2007.
• Project Manager, Lodi Gas Kirby Rills Natural Gas Storage Facility Project.
Under contract to
the California Public Utilities Commission (CPUC), Ms. Strong is currently managing the mitigation
montoring, compliance, and reporting program for Lodi Gas' natural gas storage project, Phases I and
2, in Solano County. Phase 1 construction has been completed and involved the installation of
necessary piping and compression and metering facilities to utilize a depleted underground gas
reservoir for natural gas storage. Phase 2 construction, which allows for additional well development
and associated facility enhancements, is scheduled for Spring 2008. As Project Manager, Ms. Strong
is responsible for the field monitoring effort, Notice to Proceed and Variance Request
recommendations sent to CPUC, agency coordination, and Weekly Reporting.
• Deputy Program Manager, PG&E Tr-Valley 2002 Capacity Increase Project.
Under Aspen's
environmental services contract with CPUC, Ms. Strong managed the mitigation monitoring,
compliance, and reporting program for PG&E's 230kV Capacity Increase Project in the Cities of
Pleasanton, Livermore, and Dublin, and Alameda County. Construction involved underground
installation of the double-circuit 230 kV transmission line conduit and construction of a substation
and several transition stations as three separate phases. The project rights-of-way for each of the
project's three phases traverse diverse environments ranging from residential areas to rural grazing
lands. As Project Manager, Ms. Strong was responsible for the field monitoring effort, Notice to
Proceed and Variance Request recommendations sent to CPUC, agency coordination, and Weekly
Reporting.
• Delivery Order Manager (Project Manager), US Army Corps of Engineers Miscellaneous Envi-
ronmental Services
Contract. Under Aspen's current two-year environmental services contract
with the Corps, Ms. Strong has monitored mitigation implementation for construction of the
following flood control improvement projects:
• Prado Basin and Santa Ana River Mainstem (Reach 9) Project, Riverside, San Bernardino, and Orange
County.
Aspen is currently monitoring the construction of this extensive flood control effort. In addition,
Aspen also monitors and maps the clearing of vegetation at Prado Basin and Reach 9, Phases I and IT, of
the river. Endangered species residing in the riparian forest, riparian scrub and coastal sage scrub habitat
include the Santa Ana sucker, least Bell's vireo, willow flycatcher, and coastal California gnatcateher.
Aspen also prepared the Revegetation Plan for the Reach 9, Phase I, portion of the project and conductedVIDA STRONG, page 3
fisheries monitoring. Weekly and Quarterly Reports are prepared by Aspen to document monitoring,
construction, and vegetation clearing activities.
• Murrieta Creek Flood Control, Environmental Restoration and Recreation Project, Riverside County.
Aspen monitored the clearing, construction, and revegetation effort associated with this flood control effort.
Reporting, mapping of cleared vegetation, and photo-documentation of pre- and post-construction
conditions were tasks also conducted under this Delivery Order.
• Program Manager, CDFG Region 3 Construction Monitoring and Permitting Program. For
construction projects permitted by the California Department of Fish & Game (CDFG), Region 3,
Ms. Strong serves as Program Manager where she oversees the team of Environmental Monitors and
Resource Specialists. Under this Program, on behalf of CDFG, the Aspen Team prepares Streambed
Alteration Agreements (SBAA) and monitors SBAA condition implementation during construction.
In addition, Ms. Strong prepares contractual materials and cost estimates. In addition to AT&T,
Williams, MCl/Worldeom, and XO Communications fiber installations; and SoCal Gas, Clearlake
Oaks Water District, and Pajaro Valley Water Management Agency pipeline replacement projects;
recently completed projects include:
• California Department of Parks and Recreation Hollister Hills Project, San Benito County
• San Mateo County Public Works (3 Projects — Colrna Creek Channel Improvements, Cupid ROW Canal
Vegetation removal, and Colma Creek Flood Control Project work extension)
• Arup/Brierley for SFPUC Test Bore Project, San Mateo County
• San Mateo County Parks (2 Projects — Edgewood County Park pedestrian bridge & riparian restoration,
and Wunderlich Bridge Replacement Project)
• Republic Services Vasco Road Landfill Project
• Midpeninsula Regional Open Space District Ridgetop Trail Construction Project
• BKF Engineers for City of Burlingame Easton Creek Sanitary Sewer Rehabilitation Project
• Santa Clara Valley Transit Authority Llagas Creek Flood Control Channel Project and State Route
152/156 Project
• UTC Shingle Creek Sheet Pile Wall Repair Project, Santa Clara County
• LFG A lambique Creek On-Site Bridge Replacement Project, Woodside
• BF Consulting for City of Milpitas Abel Street Infrastructure Improvements Project/Channel Repair
• City of Belmont East Laurel Creek Slope Stabilization Project.
• Nektar Therapeutics Belmont Creek Vegetation Removal and Management Project.
•
The Santa Clara Valley Transportation Authority SR152-SR156 Project, SR152-SR-156 Box Culvert
Project, and Freight Track Relocation and Berryessa Creek Improvement Project.
? Project Manager, Monitoring, PG&E Jefferson-Martin 230 kV Transmission Line Project.
Under contract to CPUC, Ms. Strong managed the mitigation monitoring, compliance, and reporting
program for the PG&E Jefferson-Martin Project. This project involved the installation of a 27-mile
230 kV transmission line through scenic San Mateo County in the Highway 280 corridor, urban
Colma and Daly City, and across San Bruno Mountain. As Project Manager, Ms. Strong was
responsible for the field monitoring effort, Notice to Proceed and Variance Request recommendations
sent to CPUC, agency coordination, and Weekly and Monthly Reporting.
• Project Manager, Monitoring, SDG&E Miguel-Mission 230 kV #2 Project. Under contract to the
California Public Utilities Commission (CPUC), Ms. Strong managed the mitigation monitoring,
compliance, and reporting program for a new SDG&E 230 kV circuit within an existing transmission
line right-of-way between Miguel and Mission substations in San Diego County. The project included
installing a new 230 kV circuit on existing towers along the 35-mile right-of-way, as well as
relocating 69 kV and 138 kV circuits on approximately 80 steel pole structures. In addition, a
temporary 230 kV transmission line was installed and the Miguel Substation and Mission Substation
were modified to accommodate the new 230 kV transmission circuit. As Project Manager, Ms.VIDA STRONG, page 4
Strong is responsible for the field monitoring effort, Notice to Proceed and Variance Request
recommendations sent to CPUC, agency coordination, and Weekly Reporting.
• Project Manager, Monitoring, SCE Viejo System Project. Under contract to the CPUC, Ms.
Stone managed the mitigation monitoring, compliance, and reporting program for the SCE Viejo
System Project on behalf of CPUC. This SCE project involved the installation of a 220/66/12 kV
substation and 3.1-mile 66 kV subtransmission line in southern Orange County, California. The
subtransmission line traverses residential and recreational areas in the City of Mission Viejo and the
substation is located in a business park adjacent to a wilderness area in the City of Lake Forest. As
Project Manager, Ms. Strong was responsible for the field monitoring effort, Notice to Proceed and
Variance Request recommendations sent to CPUC, agency coordination, and Weekly Reporting.
Deputy Program Manager, PG&E Atlantic Del Mar Project. Under Aspen's environmental
services contract with CPUC, Ms. Strong managed the mitigation monitoring, compliance, and
reporting program for PG&E's Atlantic Del Mar Project in the Cities of Rocklin and Roseville. This
approximate four-mile transmission line involved both underground and overhead construction. The
project right-of-way traverses potential habitats for listed vernal species and areas containing historic
resources. As Project Manager, Ms. Strong was responsible for the field monitoring effort, Notice to
Proceed and Variance Request recommendations sent to CPUC, agency coordination, and Weekly
Reporting.
• Project Manager, Looking Glass (LGN) Metropolitan Area Network. Under Aspen's fiber optic
services contract with CPUC, Ms. Strong managed the Mitigation Implementation and Monitoring
Plan for LGN's proposed service connections within the San Francisco Bay Area and Los Angeles
Basin. As Project Manager, for each LGN service connection, Ms. Strong was responsible for Notice
of Construction and Work Plan review, Notice to Proceed recommendations, the construction
monitoring effort, and post-construction reporting.
• Project Manager, AboveNet (formerly Metromedia) Fiber Network. Under Aspen's fiber optic
services contract with CPUC, Ms. Strong managed the mitigation monitoring of AboveNet's
construction of service connections within the San Francisco Bay Area.
• Deputy Program Manager, PG&E Northeast San Jose Transmission Reinforcement Project.
Under Aspen's environmental services contract with CPUC, Ms. Strong managed the mitigation
monitoring, compliance, and reporting program for PG&E's 230kV Reinforcement Project in the
Cities of San Jose, Milpitas, and Fremont. Construction of the dual 230kV circuit involved
underground construction, single-pole tower installation, and construction of the Los Esteros
Substation. Given the proximity of the project to the Bay, sensitive biological resources were present,
including the burrowing owl and wetland mitigation sites. As Project Manager, Ms. Strong was
responsible for the field monitoring effort, Notice to Proceed and Variance Request recommendations
sent to CPUC, agency coordination, and Weekly Reporting.
• Project Manager, Williams Communications Sentry Marysville Project. Under Aspen's fiber
optic services contract with CPUC, Ms. Strong managed the mitigation monitoring, compliance, and
reporting program for Williams fiber optic installation project in Yuba and Butte Counties. As Project
Manager, Ms. Strong was responsible for the field monitoring effort, Notice to Proceed and Variance
Request recommendations sent to CPUC, agency coordination, and Weekly Reporting.
a Deputy Program Manager, PG&E Line 401 Capacity Loops Project. Under Aspen's
environmental services contract with CPUC, Ms. Strong managed the mitigation monitoring,
compliance, and reporting program for PG&E's Capacity Loops Project in Modoc and Shasta County.
This project was permitted under the PG&E/PGT Project constructed in the early 1990's and involved
the installation of a natural gas pipeline within Modoc National Forest and rugged, private landsVIDA STRONG, page 5
within Shasta County containing sensitive cultural and biological resources, respectively. Extensive
timber harvesting was also conducted as part of the clearing effort for this project. Given the federal
lands and sensitive resources present, numerous federal and State agencies were involved in the
permitting of the project. Ms. Strong analyzed and prepared the recommendations for Notices to
Proceed and Variance Requests, and maintained communications with CPUC and other interested
agencies, including Weekly Report submittals.
• Program Manager, Level 3 Fiber Optics Network Program: Ms. Strong oversaw Aspen's work on
this statewide CEQA compliance project under the direction of the California Public Utilities
Commission (CPUC). Level 3 Communications installed a 2,000-mile fiber optic network
throughout California. As Program Manager, she managed a team of up to six Environmental
Monitors, conducted the analysis and prepared recommendations for CPUC regarding Notices to
Proceed with construction and variance requests, and maintained communications with CPUC,
affected agencies, other interested parties regarding the status of project construction and compliance.
• SCE Valley-Auld Power Line Project Mitigation Monitoring Program, CPUC: Ms. Strong
served as Project Manager for the monitoring of this 11-mile long power line upgrade for compliance
with the project's Mitigated Negative Declaration mitigation measures and compliance plans. Other
tasks included review of pre-construction compliance materials, preparation of variance
recommendations and monthly reports, and coordination with SCE and its subcontractors.
• Alpine Natural Gas Project Mitigation Monitoring Program, CPUC. Ms. Strong was the Project
Manager for this monitoring and compliance project for construction of Phase I of a 27-mile natural
gas pipeline and distribution system in a rural residential area of Calaveras County, under contract to
the California Public Utilities Commission. Ms. Strong's responsibilities include management of
environmental monitor(s) and coordination with lead agencies and pipeline owner/contractors.
• Kinder Morgan Carson to Norwalk Pipeline Mitigation Monitoring, Compliance, and
Reporting Program:
Ms. Strong served as Deputy Project Manager for this monitoring and
compliance project for construction of a 14-mile products pipeline in southern California, under
contract to the California Public Utilities Commission. She managed construction compliance issues,
coordinated with the environmental manager for Kinder Morgan Energy Partners, and prepared
monthly reports for the project's Internet web site.
• Pacific Pipeline Mitigation Monitoring, Compliance, and Reporting Program.
Ms. Strong
served as Deputy Program Manager for this monitoring and compliance project for construction of a
132-mile crude oil pipeline in southern California, which included the installation of a parallel fiber
optic network, under contract to the California Public Utilities Commission and the Angeles National
Forest. This pipeline was constructed by separate crews at seven pipeline sub-segments and eight
stations. Her primary responsibilities on this program included estimation of budgetary and monitor
requirements; coordination of technical reviews and decisions on applicant variance requests;
securement and deployment of environmental monitors; and coordination with lead agencies and
pipeline owner/contractors.
• Alturas Transmission Line Project EIRJS.
Deputy Project Manager for the EIR/S on Sierra Pacific
Power Company's Alturas Transmission Line Project. This EIR/S, completed for the California
Public Utilities Commission and the US Bureau of Land Management in November 1995, addressed
the impacts of a proposed 165-mile, 345 kV intertie between Alturas, California, and Reno, Nevada.
It included consideration of numerous route alternatives in northeastern California and northwestern
Nevada as well as other electric power transmission, generation and conservation alternatives. Ms.
Strong's responsibilities included description of the proposed project and alternatives,
characterization of project parameters for impact analysis, definition of controversial energy supply
\ 1 sVIDA STRONG, page 6
and demand issues, coordination with electrical power transmission experts, assistance in
management of team subcontractors, and document preparation and production coordination.
MacPherson Oil Project Integrated Risk Assessment, City of Hermosa Beach. Ms. Strong served
as Project Manager for the preparation of an Integrated Risk Assessment for the MacPherson Oil
Project, under contract to the City of Hermosa Beach. Under this contract, she managed the critique
of system safety studies completed for the project. As a result of the critique, an Integrated Risk
Assessment was prepared to fully analyze the potential public safety impacts resulting from the
project.
Delivery Order Manager (Project Manager), US Army Corps of Engineers Miscellaneous
Environmental Services Contract. For Aspen's two-year environmental services contract (1995-
1997), Ms. Strong managed the following projects:
• Deep Draft Navigation Improvements Project Consistency Determination, Los Angeles Harbor.
Served as Delivery Order Manager for document to address design refinements to Stage 2 of the Port of
Los Angeles Pier 400 Deep Draft Navigation Improvement (DDNI) project.
• Vandenberg AFB San Antonio Creek Bridges Project Alternative Analysis Report. Ms. Strong served
as Delivery Order Manager for the preparation of an Alternative Analysis Report on various alternatives
(developed in conjunction with hydraulic engineering contractor) for the crossing of San Antonio Creek.
Baseline conditions and the life expectancy of the existing crossing, El Rancho Road Bridge, due to erosion
resulting from seasonal inundation by runoff, was also considered in the analysis. Crossing of San Antonio
Creek by the Air Force is considered mission-critical for the transport of missiles to base launch sites.
Upper Newport Bay Environmental Restoration Baseline Conditions Study. Ms. Strong managed the
preparation of a Baseline Conditions Report in support of a feasibility study on Environmental Restoration
opportunities in Upper Newport Bay, City of Newport Beach, California. The Baseline Conditions Report
was prepared to an EIS/R level of detail and format. The Report also presented the goals and objectives of
restoration and available strategies for assessing overall ecosystem conditions (e.g., modified Habitat
Evaluation Procedures). Interagency coordination in the form of interagency meeting attendance, and
preparation and distribution of meeting materials was also conducted.
US Food and Drug Administration Laboratory EIS/EIR. Ms. Strong managed preparation of an EIS/R
prepared for a proposed US Food and Drug Administration Mega-laboratory in Irvine, California. This
E1S/R is was prepared under Aspen's US Army Corps of Engineers General Environmental Services
Contract, and included the University of California, Irvine as the CEQA Responsible Agency. The
document addressed a broad range of impacts, including biological and water resource impacts on the
adjacent San Joaquin Freshwater Marsh Reserve, public health and safety impacts resulting from accidental
release from the facility, loss of open space, and transportation impacts.
• Border Lighting, Fencing, and, Roadways Final EAs. Delivery Order Manager for a variety of Environ-
mental Assessments (EAs), including the installation of floodlights, two-tiered fencing, and roadways
parallel to the US/Mexico border over a total distance of approximately eight miles.
Sepulveda Armory EA. Managed preparation of an Environmental Assessment for a proposed new
National Guard Armory, Sepulveda Basin in Van Nuys, CA.
• INS San Clemente Checkpoint Lane Expansion Project EA. Delivery Order Manager for the EA
addressing the environmental concerns of noise, traffic, HTRW, and aesthetics resulting from the addition
of a commuter lane.
Previous Employment 1987 to 1994
Ms. Strong was an Energy Specialist for the Santa Barbara County Planning and Development Department,
Energy Division, Santa Barbara, CA (1991 to 1994). in this position, she managed various permitting and
CEQA/NEPA related reviews, and Operation and Condition Compliance Monitoring. Her projects included:VIDA STRONG, page 7
• Mobil Clearview. Worked directly with Mobil Oil Co. on development of a project description to
meet County application processing needs (environmental review, policy consistency determination,
etc.) during the initial pre-application review. Representing the County as the Lead Agency for this
complicated and controversial project, she:
• Coordinated the environmental review needs of the various permitting agencies, including the County,
State Lands Commission, California Coastal Commission, and US Army Corps of Engineers
• Served as the primary media contact
• Monitored State legislation on conversion of State leases to sanctuary status and UCSB purchase of project
site.
111 Mobil Ellwood Oil and Gas Processing Plant/Marine Terminal. Ms. Strong managed permitting
and environmental review of proposed facility modifications and sites designated as legal
nonconforming uses within recreational and residential zoning districts; she coordinated multi-agency
review as required. She also monitored compliance with County permit conditions and worked with
Mobil and various County agencies on plan updates (Emergency Response Plan, Fire Protection
Plan).
• Marine Tanker Transport Review. Managed permitting and environmental review of offshore oil
producers' request to tanker Point Arguello crude oil from Gaviota to Los Angeles, including:
• Worked directly with SEIR/S consultant (Aspen) on completion of environmental document (certified Final
SEIRJS) that required a major change to the project description after release of the Draft EIRJS.
• Worked directly with the various permitting agencies (State Lands Commission, California Coastal Commis-
sion) on completion of environmental review, permitting needs, and appeal review.
• Developed staff report, including staff recommendations, conditions, findings and background. Reviewed
and analyzed crude oil transportation options (mode, route, destination) and economics.
• Project work included interface with County Counsel, Board of Supervisors, and Chevron U.S.A.
• Emergency Tankering Application Review. Managed review and analysis of crude on transpor-
tation options (mode, route, destinations) versus Local Coastal Program/Coastal Zoning Ordinance
definitions of emergency, and regional and statewide needs. This project also required extensive
interface with the County Counsel and news media.
• Gas Re-Injection Feasibility Analysis. In support of the Tr-Party Agreement between Chevron, US
Minerals Management Service (MMS), and Santa Barbara County on the limitation of pipeline
transport of sour gas, Ms. Strong provided consultation to Chevron on behalf of the County on study
preparation. Issues addressed included reservoir modeling, system safety, economics, and environmental
impacts and benefits. Ms. Strong also worked with MMS regarding Re-Injection Study development and
compliance with the Tr-Party Agreement. Further, she monitored offshore producers' compliance with
this agreement, including stipulations regarding hydrogen sulfide concentration, pressure operating
limits for sour gas pipeline operation and maintenance, and agency reporting requirements.
Oil and Gas Processing Facility Permitting. Ms. Strong monitored compliance with County permit
conditions for Chevron's Pt. Arguello oil and gas processing facility. She coordinated the System
Safety and Reliability Review Committee (including County Departments of Building and Safety,
Environmental Health Services, Air Pollution Control District, and Office of Emergency Services) in
their review of facility and operational modifications. She also worked with the California Regional
Water Quality Control Board on produced water discharge, and managed the Environmental Quality
Assurance Program field monitor.VIDA STRONG, page 8
From 1988 to 1991, Ms. Strong served as a Project Manager at Coats Consulting in Aptos, California,
where she managed the environmental review division. She was responsible for EIR and Negative
Declaration preparation for residential, commercial, and light industrial projects.
Ms. Strong also worked as a Marketing Engineer for Zilog Corporation, designer and manufacturer of
microprocessors and peripherals, in Campbell, California, from 1987 to 1988. She monitored product
line sales, costs, and profits, and presented product line financial status to management on a weekly basis.
She was also involved in new product development and introduction.
HONORS AND AWARDS
? Cum Laude - B.S., Engineering
• Marketing Person of the Year - Zilog
SELECTED TECHNICAL REPORTS
M.U.P. Thesis - Fiscal Impact Analysis for Rancho San Benito: A Proposed New Town
AREAS OF EXPERTISE
• Mitigation Monitoring, Compliance, and Reporting
• CEQA/NEPA AnalysisAsper.
Environmergai Group
SUSAN S. WALKER
Senior Associate, Environmental Planning
ACADEMIC BACKGROUND
M.A., Applied Geography, The City University of New York, 1988
B.A., Physical Geography, University of Colorado at Boulder, 1983
PROFESSIONAL EXPERIENCE
Ms. Walker joined Aspen Environmental Group in 1999, and has over 18 years of experience in environ-
mental consulting. Ms. Walker primarily functions as a Project Manager for both large- and small-scale
multidisciplinary environmental review documents under the National Environmental Policy Act (NEPA)
and California Environmental Quality Act (CEQA). Ms. Walker additionally functions as a Principal
Investigator and Issue Area Coordinator for land use and public policy analyses and related social science
analyses. Ms. Walker also has expertise in regulatory permit acquisition, the development of permit
compliance strategies, permit compliance implementation and tracking, agency coordination and relations,
and, assistance with GIS planning and implementation. Ms. Walker's project-specific efforts are provided
below.
Aspen Environmental Group 1999 to present
• Port of Los Angeles Channel Deepening Project. Ms, Walker is currently serving as the Issue Area
Coordinator for social sciences, and as a senior technical analyst for a Supplemental Environmental
Impact Statement/Environmental Impact Report (Supplemental EIS/EIR) addressing proposed
channel deepening within the Port of Los Angeles. Ms. Walker is completing senior technical
reviews of all resource/issue-specific analyses related to the social sciences, and is also functioning as
either the principal analyst or as a co-analyst for the Supplemental EIS/EIR's land use, visual
resources, recreation, socioeconomic and environmental justice analyses.
• Sylmar to Pacific Ocean DC Electrode Replacement Project. Ms. Walker is currently acting as
the Project Manager for preparation of an Initial Study for replacement of the onshore, underground
segment of a direct current (DC) electrode located in the vicinity of West Los Angeles, Santa Monica,
and Pacific Palisades, California. Ms. Walker is responsible for overall coordination and
management of Aspen's project team and its subcontractors, senior technical review of all
resource/issue-specific analyses, oversight of document reproduction and distribution and
development of a CEQA-related public property owner and agency distribution list, and, preparation
of the Initial Study's Project Description, mandatory findings of significance, and land use and
recreation analyses. Following completion of the Initial Study, Ms. Walker will manage completion
of either a Mitigated Negative Declaration (WIND) or Environmental Impact Report (EIR) for the
project.
Lake Canyon Dam and Detention Basin. Ms. Walker is currently serving as the Project Manager
for a proposed flood control detention basin and dam. The project sponsor is the Ventura County
Watershed Protection District (VCWPD), and its purpose is to protect areas of the City of Ventura
from flood waters associated with a 100-year storm event. Ms. Walker is responsible for the
management of all aspects of Aspen's efforts, including: completion, noticing, and distribution of the
project's Initial Study, Draft EIR, Final EIR; coordination and facilitation of the project's public
meetings, including the development and presentation of meeting materials, agendas and projectSUSAN S. WALKER, page 2
summaries; participation in the project's various environmental review hearings with decision
makers; and, oversight of the project's regulatory permit acquisition efforts for impacts associated
with jurisdictional surface waters.
? Ormond Beach Habitat Restoration Feasibility Study. Ms. Walker is currently acting as the
Project Manager for preparation of a Wetlands Restoration Feasibility Study for more than 750 acres
of land within the Oxnard Plain in Ventura County, California. The project includes: identifying
restoration goals with the assistance of regional experts and the local stakeholders; assessing various
opportunities and constraints in the area (biological, engineering, cultural, infrastructure, regulatory,
land use, land availability, funding, soils and surface water contamination and rernediation, water
quality, geotechnical, socioeconomic, and recreation); developing and subsequently evaluating and
ranking the final restoration alternatives identified by the project team; and, providing short-term and
long-term recommendations to the State Coastal Conservancy (SCC) for implementation. The SCC
will use the results and recommendations of this study to make decisions on the nature and timing of
future restoration activities.
? Tehachapi Renewable Transmission Project. Ms. Walker is currently acting as the land use
analyst and Issue Area Coordinator for the social sciences for the Tehachapi Renewable Transmission
Project's EIR/EIS, and its associated resource/issue-specific Specialist Reports. The project involves
a suite of new, replacement and modified transmission lines extending from a planned substation
located southeast of the City of Tehachapi, Kern County, to a substation located in the City of
Ontario, San Bernardino County; the project also involves one new and several expanded substations.
Ms. Walker is responsible for the management, coordination and senior technical oversight of seven
technical teams, including the analysts for cultural resources, visual resources, socioeconomics,
agricultural resources, recreation and wilderness, environmental justice, and public utilities. She is
additionally responsible for preparation of the EIR/EIS's land use analysis and Land Use Specialist
Report. Her efforts have also included review of the Proponent's Environmental Assessment (PEA)
for technical adequacy, the preparation of data adequacy comments and data requests, and assistance
with development of the technical approach for the analysis of cumulative impacts.
• Redmont Pump Station Replacement Project. Ms. Walker is currently serving as the Project
Manager for an Initial Study and Mitigated Negative Declaration (IS/MND) for a proposed water
supply pump station replacement project in the community of Sunland, which is located in the City of
Los Angeles, California, Ms. Walker is responsible for preparation of the IS/MND's Project
Description and Mitigation Monitoring Plan, completion of the IS/MND's land use and planning,
recreation, aesthetics, and mandatory findings of significance, management of Aspen's project team,
including its subcontractors, senior technical review of all resource/issue-specific analyses addressed
in the IS/MND, and oversight of document reproduction. Ms. Walker is additionally responsible for
completion of the project's environmental review notices.
• Tranquillon Ridge Oil and Gas Development Project. Ms. Walker served as a senior technical
analyst for an EIR addressing proposed oil and gas development of the Tranquillon Ridge oil and gas
field, located in State waters offshore northern Santa Barbara County, California. Ms. Walker
completed the EIR's analyses for visual resources/aesthetics, land use and public policy, and
recreation. Ms. Walker additionally assisted with development of the EIR's off- and on-shore
cumulative project listings and descriptions, as well as completion of multiple resource/issue-specific
technical analyses for the EIR's cumulative impacts assessment.
• Owens River Gorge Restoration Project. Ms. Walker served as both the Project Manager and a
senior technical analyst for a preliminary environmental review of proposed modifications to the
water flows released into an approximate 10-mile reach of the Owens River Gorge, located in Mono
and Inyo Counties, California. The analysis was completed for the Los Angeles Department of Water
and Power for habitat restoration and maintenance. Ms. Walker was responsible for all aspects of theSUSAN S. WALKER, page 3
project's management, coordination and senior technical review for an Initial Study level of analysis,
and prepared the document's Project Description, as well as numerous resource/issue-specific
technical sections, including land use and planning, recreation, and mandatory findings of
significance.
le Preliminary Environmental Profile of California's Imported Electricity. Ms. Walker served as a
contributing author of a technical report addressing the primary sources of California's imported
electricity, and the key biological and water-related impacts associated with that electricity's
generation. The report was prepared for the California Energy Commission (CEC) in support of its
"Environmental Performance in 2005 Integrated Energy Policy Report." Ms. Walker's efforts were
focused on issues associated with power generated from natural gas and hydroelectricity. In addition,
Ms. Walker provided overall assistance to the report's Project Manager, including overall staff
coordination and guidance, as well as senior technical reviews.
• Antelope-Pardee 500-kV Transmission Project. Ms. Walker served as a technical analyst for an
Alternatives Siting Report for the proposed Antelope-Pardee 500-kV Transmission Project. Her
efforts included the identification of alternative above- and below-ground Right-Of-Way alignments,
coordination with transmission engineers to evaluate the technical feasibility of the alternatives, and
preliminary assessments of the potential impacts and key advantages and disadvantages of the
alternatives. Ms. Walker additionally prepared several technical sections of the project's
environmental review document, including its assessment of both growth inducing impacts and
irreversible and irretrievable commitment of resources. She also prepared numerous responses to
comments on the Draft EIRJEIS for the purposes of its finalization, and completed several of the
resource/issue-specific technical analyses included in the Final EIR/EIS's "Findings of Fact."
• Environmental Information Document and Coastal Consistency Determinations for Federal Oil
and Gas Leases Offshore Santa Barbara, Ventura and San Luis Obispo Counties. Ms. Walker
served as the Project Manager for preparation of a multidisciplinary Environmental Information
Document (EID) and ten Federal Coastal Consistency Determinations that evaluated the potential
effects of future development of the undeveloped federal oil and gas leases offshore Santa Barbara,
Ventura and San Luis Obispo Counties, California. The documents address both lease-specific and
cumulative impacts for the period 2006 through 2030. In addition to overall project management and
coordination, Ms. Walker was responsible for senior technical review and the preparation of text
regarding near- and long-term activities that may occur on the Pacific Outer Continental Shelf, and was
a principal author of the California Coastal Act policy consistency analyses prepared for each of the
project's Lease/Unit-specific Coastal Consistency Determinations.
• Simulation of Natural Flows in Middle Piru Creek. Ms. Walker served as the Project Manager for
an EIR addressing a proposed dam flow re -lease modification schedule into middle Piru Creek, located
in Ventura and Los Angeles Counties, California. The purpose of the project was to mimic natural
surface water flows. Ms. Walker was responsible for overall management and coordination of the
project team, senior technical review of all resource-issue specific analyses, and preparation of
several sections of the EIR, such as the description of the proposed project and its alternatives and the
analyses for the environmentally preferred alternative, growth-inducing impacts, and cumulative
impacts. Ms. Walker was also responsible for the writing and publication/distribution of all public
and agency notices, and coordinated the content of, and led the project's public workshops and meetings.
1
Ventura River Arundo Removal Demonstration Project. Ms. Walker served as the Project Man-
ager for the preparation of an ER for the proposed removal of Arundo donax, a highly invasive non-
native plant species, using four different removal and revegetation techniques within the Ventura River,
Ventura County, California. Ms. Walker additionally served as the overall Project Manager for the
effort's regulatory permit acquisition program. Ms. Walker prepared multiple chapters of the EIR,
including its Project Description, completed numerous technical analyses of the document, such asSUSAN S. WALKER, page 4
pubic health, visual resources, land use and planning, recreation, and General Plan environmental
policy consistency, provided senior technical review for all other sections of the EIR, prepared for and
participated in the project's public hearings, and assisted with the project's public noticing
requirements under CEQA.
• Morro Bay Power Plant Project. Ms. Walker served as the Power Plant Coordinator and land use
analyst for preparation of the Preliminary and Final Staff Assessments (PSA and FSA, respectively)
for the Morro Bay Power Plant Project. Ms. Walker managed Aspen Environmental Group's staff
and subcontractors' work efforts and schedules, coordinated with the CEC Project Manager regarding
overall project logistics and schedule, and, conducted the land use analysis for the PSA and FSA,
including participation in public workshops and evidentiary hearings.
• Mountain View Power Plant Project. Ms. Walker assisted with preparation of the socioeconomics
analysis during preparation of the PSA and FSA for the proposed Mountain View Power Plant Project.
Efforts included data searches and reviews, agency contacts, and preparation of the analysis and text
for the PSA and FSA.
• Inland Empire Power Plant Project. Ms. Walker acted as the Power Plant Coordinator and socio-
economics and alternatives analyst for the CEC's environmental review of the Inland Empire Power
Plant Project. Efforts included overall staff coordination, communications and scheduling during prep-
aration of the project's data adequacy analyses, PSA, and FSA, as well as the coordination of, prep-
aration for, and participation in the project's various public workshops and hearings.
? Coastal Power Plant Evaluation. Ms. Walker functioned as a senior analyst during preparation of an
evaluation focused on the key environmental and regulatory issues associated with the licensing and
operation of coastally located power plants within California. Ms. Walker conducted agency
interviews, researched power plant-specific licensing cases and other project-specific analyses and
reports, and prepared written summaries of the findings of these efforts for inclusion in a draft and
final report for review by the CEC.
• Level 3 Communications Infrastructure Project. Ms. Walker served as the Deputy Project Man-
ager for the preparation of 21 Initial Studies and a master Subsequent MND for the Level (3)
Communications Infrastructure Project. The project consisted of the installation of nearly 2,000 miles
of fiber optic telecommunications cable throughout California, as well as the cable's related above-
ground support facilities. Ms. Walker managed in-house technical and support staff during
preparation of the Draft and Final Initial Studies and Subsequent MND, coordinated the completion
and publication/distribution of all necessary public and agency noticing, and, oversaw final document
editing, compilation and production. Additionally Ms. Walker prepared the 21 Project Descriptions
for each Initial Study, prepared the master overview section of the Subsequent MND, and completed
each Initial Study's Population and Housing analysis.
• Visalia Landfill Master Development Plan. Ms. Walker provided management assistance during
preparation of Draft and Final EIRs for a proposed expansion of the Visalia Landfill, located in
Tulare County, California. Ms. Walker completed the Draft and Final "Project Description" and
-Introduction" sections of the EIR, conducted the land use and planning analysis of the ER, and
assisted with completion of the document's "Impact Overview" section. In addition, Ms. Walker
assisted Aspen's Project Manager with overall project coordination and management of technical
staff.
• Bull Creek Channel Ecosystem Restoration Project. Ms. Walker functioned as Project Manager for
preparation of an Environmental Assessment (EA) and Ecosystem Restoration Report (ERR) for the
Bull Creek Channel Ecosystem Restoration Project. The project was sponsored by the U.S. Army
Corps of Engineers (Corps) with cooperation by the City of Los Angeles (City). The project involvedSUSAN S. WALKER, page 5
restoration of a degraded reach of Bull Creek, located within the Sepulveda Dam and Flood Control
Basin, Los Angeles, as well as the development of a new park and wetlands habitat area. Ms. Walker
provided overall management of, and direction to the project's technical team, completed senior
technical reviews of a draft and final documents, and also prepared several technical sections of the ERR
and EA.
• San Jose/Old San Jose Creek Restoration Project. Ms. Walker provided technical analysis for
preparation of an EA and ERR for proposed restoration of the final reaches of San Jose and Old San
Jose Creeks, located in Santa Barbara County, California. Her efforts included completion of
-baseline" and impact analyses for several resource-specific issues, including land use and planning,
recreation, aesthetics, and cumulative impacts, as well a preparation of several sections of the two
documents' overall content, such as their respective Project Descriptions and Project Purpose and
Need.
• Imperial Beach Shore Protection Project. Ms. Walker served as the Project Manager for the Impe-
rial Beach Shore Protection Project, a beach restoration effort sponsored by the Corps with
participation by the City of Imperial Beach. The effort included preparation of a Draft and Final
EIS/EIR for the project. Ms. Walker's efforts included: coordination with Corps staff and managers
regarding overall project logistics and schedule; management of the project's in-house technical team
and the project's various subcontractors; preparation of many of the EIS/EIR's non issue/resource-
specific technical sections, such as the document's Project Description; oversight of all document
editing, compilation and production; and, participation in local and California Coastal Commission
public hearings.
• Prado Basin and Vicinity Project. Ms. Walker functioned as an analyst during finalization of the
Prado Basin and Vicinity Project E1S/EIR. The project consisted of a proposal to raise the Prado
Dam, located in San Bernardino County, California, and install a series of flood control structures
within the Prado Dam Basin to provide greater flood control of the downstream area of the Santa Ana
River. Ms. Walker prepared numerous responses to comments submitted on the Draft E1S/EIR, and
is also assisted with over project management and coordination.
• Bellevue Primary Center Interim Facility. Ms. Walker served as the Project Manager for a revised
IS/MND for the Los Angeles Unified School District's (LAUSD) Bellevue Primary Center Interim
Facility. The project consisted of the temporary relocation of a primary center located in the City of
Los Angeles. Ms. Walker coordinated with LAUSD staff during preparation of the IS/MND,
managed Aspen Environmental Group's staff, oversaw final document editing, compilation and
production, and, prepared the revised Project Description.
• Hamilton High School Master Addition. Ms. Walker acted as the Project Manager for an IS/MND
for a proposed expansion of the Hamilton High School, located in the City of Los Angeles. Ms.
Walker was responsible for: overall coordination and communications with LAUSD staff and its con-
sultants; management and coordination of Aspen Environmental Group's staff and its subcontractors;
preparation of the documents' general sections, such as the Project Description; and, senior technical
review of all sections and analyses contained within the draft and final documents. Ms. Walker also
prepared materials for, and participated during, the project's public hearings and community outreach
meetings.
• Aldama Elementary School Master Addition. Ms. Walker served as the Project Manager for an
IS/MND addressing a proposed addition to the Aldama Elementary School, located in the City of Los
Angeles. Ms. Walker was responsible for: overall coordination and scheduling of the project's envi-
ronmental review; senior technical review of all technical analyses prepared for the documents;
preparation of several of the documents' sections such as their Project Descriptions and the MN D's
Mitigation Monitoring Plan; and, participation during the project's public hearings.
23SUSAN S. WALKER, page 6
Wonderland Avenue Elementary School Master Addition. Ms. Walker served as the Project Man-
ager for an IS/MND addressing a proposed addition to the Wonderland Avenue Elementary School,
located in the City of Los Angeles. Ms. Walker was responsible for overall coordination and
scheduling of the project's environmental review, review of all environmental review documents
produced for the project, completion of several of the Initial Study's technical analyses, preparation
of all of the responses to comments received on the Draft IS/MND, and, completion and distribution
of the project's public and agency notices.
• Reseda High School Master Portable Addition. Ms. Walker served as the Project Manager for an
IS/MND addressing proposed portable classroom additions to Reseda High School, located in the
City of Los Angeles. Ms. Walker was responsible for overall management of Aspen's internal staff and
subcontractors, senior technical review of all draft and final technical analyses, and preparation of
several sections of the two documents, including the Initial Study's and MND's respective Project
Descriptions, the MND's Mitigation Monitoring Plan, and the Initial Study's aesthetics, agricultural
resources_ hazards and hazardous materials, land use and planning, recreation and mandatory findings
of significance analyses.
• Hughes Middle School Re-Opening. Ms. Walker served as the Project Manager for the preparation
of an Initial Study for a proposed re-opening of a middle school as a "span" (6th through 12th grade
students) in Woodland Hills, California. The analysis involved two separate school campuses,
including a relocation of an existing Adult School. Ms. Walker was responsible for: overall
management and coordination of the project team; preparation of numerous technical sections of the
Initial Study; senior technical review of all other technical analyses; and, preparation for, and
facilitation of the project's public scoping meeting. Ms. Walker was also responsible for the
preparation, publication and distribution of all of the project's public and agency noticing.
• LAUSD New Construction Program EIR. Ms. Walker is served as the Principal Investigator for an
extensive public outreach and demographic analysis of the LAUSD's District-wide Program EIR for
new school construction over a 15 to 20 year period. Ms. Walker was responsible for an in-depth
assessment of numerous demographic and economic attributes of the District's population, both
regionally and locally, and additionally assisted with sections of the document's "Program
Description."
? Morro Ray Sampling and Chemical Analysis Project. Ms. Walker acted as the Project Manager
for a water sampling and chemical analyses project within Morro Bay. The purpose of the project
was to sample selected locations of the Bay for the necessary approvals needed for proposed dredging
activities. Principal agency approvals include the U.S. Environmental Protection Agency and
California Coastal Commission. Ms. Walker's involvement included the coordination and scheduling
of activities between the Corps and Aspen's subcontractors, and senior technical review of all
documents submitted to the Corps.
• Kern County Oil and Gas Development Permitting Evaluation. Ms. Walker served as a senior
analyst for an evaluation of the local and State permitting processes for new oil and gas development
projects within Kern County, California. Ms. Walker provided technical analyses of various
regulatory, policy, and resource-specific issues, and also assisted with overall facilitation of the
project during agency, industry, and special interest group meetings and workshops.
• Division of Oil, Gas and Geothermal Resources Regulatory Compliance Initial Study. Ms.
Walker served as a senior analyst for an Initial Study evaluating the California Division of Oil, Gas and
Geothermal Resources' (DOGGR) proposed program for compliance with CEQA for oil and gas
drilling in Kern County, California. Ms. Walker revised DOGGR's regulations for CEQA compli-
ance for review by DOGGR counsel and the Deputy Attorney General, and prepared the agricultural
resources and land use and planning analyses of the project's Initial Study. Ms. Walker also assistedSUSAN S. WALKER, page 7
with overall project management, and provided senior technical review for several of the Initial
Study's resource/issue-specific analyses.
? Combined Array for Research in Millimeter-wave Astronomy Project Special Use Permit Appli-
cation. Ms. Walker prepared several sections of a Special Use Permit (SUP) application package for
submittal to the U.S. Forest Service for a proposed astronomy facility in the Inyo National Forest,
California. Ms. Walker's efforts included an analysis of the federal, State and local regulatory
permits and approvals required for the proposed facility, an evaluation of the facility's consistency
with the U.S. Forest Service's SUP Screening Criteria, and technical editing and review of the
project's final SUP application package.
Previous Experience
1989 to 1999
Prior to joining Aspen Environmental Group Ms. Walker served as a Project Manager at Dames & Moore,
and as a contract planner with the Energy Division of the Santa Barbara County (California) Planning and
Development Department. A selection of projects she worked on is provided below.
Environmental Impact Reports, Statements, and Analyses
Point Pedernales Project Modification. Ms, Walker was responsible for completion of an Initial
Study and EIR Addendum, and coordination of a Quantitative Risk Analysis for a proposed hydrogen
sulfide concentration increase in the 23-mile off- to onshore natural gas pipeline of the Point Peder-
nales Project located in northern Santa Barbara County.
• Santa Barbara County Groundwater Element. Ms. Walker served as the project manager for a
Public Draft revision and Final Programmatic EIR addressing the proposed adoption and implementa-
tion of a Groundwater Element into the Santa Barbara County Comprehensive General Plan.
• Vista Del Mar School Relocation and Water Supply Pipeline. Ms. Walker served as the Project
Manager for preparation of a series of Supplemental and Addenda EIRs for construction of a pro-
posed elementary school and water supply pipeline located in central Santa Barbara County.
• Arroyo Las Posas Channel Improvements Project. Ms. Walker served as the Project Manager for
preparation of a Draft and Final EIR addressing a phased series of stream channel improvements to
the Arroyo Las Posas, Ventura County. She additionally served as a technical analyst for land use
and visual resources and participated in the project's public hearings.
Los Angeles Department of Water and Power Land Exchange. Ms. Walker served as the Project
Manager for Finalization of an EA and Senate Briefing Report for a proposed exchange of properties
in Clarke County, Nevada, and Los Angeles County, California, by the Los Angeles Department of
Water and Power and Bureau of Land Management.
• Port of Oakland Feasibility Study. Ms. Walker prepared an environmental feasibility analysis for
proposed rail access to the Port of Oakland by the Atchison, Topeka & Santa Fe Railroad Company.
The analysis included assessments of traffic and transportation, air quality, land use, and risk.
• Mobil M-70 Pipeline Replacement. Ms. Walker assisted with the overall coordination and prepa-
ration of an EIS/EIR addressing the replacement of a 92-mile crude oil pipeline located between
Lebec and Torrance, California.
? California Offshore Oil and Gas Resources Study. Ms. Walker served as the Assistant Project
Manager for the preparation of an extensive inter-disciplinary study evaluating the potential environ-
mental, engineering, and socio-economic constraints associated with various levels of offshore oil and
gas development in Ventura, Santa Barbara, and San Luis Obispo Counties.
2-5SUSAN S. WALKER, page 8
• Las Vegas Valley Flood Control Master Plan. Ms. Walker assisted with the preparation of a Pro-
grammatic EIS for a long-range Master Plan of the Las Vegas Valley Flood Control District's phased
Flood Control Improvements Project. Her efforts included overall project coordination and analysis
of land use and facilities infrastructure.
• Molycorp Pipeline Replacement Project. Ms. Walker prepared a detailed Project Description for
regulatory permitting and inclusion in a joint EA/MND for replacement of a wastewater pipeline system
operated for a rare earths mine located in the Mojave Desert.
• Elsmere Solid Waste Facility. Ms. Walker prepared of an extensive, multidisciplinary "standalone"
Executive Summary for public review detailing the findings of an ElS/EIR for development of a
regional landfill for Los Angeles County.
• Atchison-Topeka Remediation Project. Ms. Walker prepared an Initial Study and MND for a pro-
posed remediation project in support of truck/train internaodal operations within the City of Vernon,
California.
• Bureau of Land Management Land Exchange. Ms. Walker prepared socioeconomic and prime
farmlands analyses for an EA addressing a series of proposed land exchanges within southern and
central Nevada. Analysis included completion of a Farmland Protection Policy Act assessment and
U.S. Natural Resource Conservation Service 1006 "Farmland Conversion Impact Rating Forms."
Environmental Regulatory Permitting and Compliance Planning
? Mead-Adelanto Transmission Project. Ms. Walker served as Project Manager for the multidisci-
plinary federal, State, and local regulatory permitting and construction-phase permit compliance plan-
ning and implementation of a 210-mile 500 kV transmission line extending from Boulder City,
Nevada, to Adelanto, California.
11 Vista Del Mar Water Supply Pipeline.
Ms. Walker served as the Project Manager for the multidis-
ciplinary regulatory permit acquisition and construction-phase compliance planning and implemen-
tation of an elementary school and water supply pipeline located in Santa Barbara County.
• Point Pedernales Project Condition Effectiveness Review.
Ms. Walker completed a comprehensive
Preliminary Screening Analysis assessing the effectiveness of the 192 conditions associated with the
Santa Barbara County Final Development Plan for the Pt. Pedernales Project, an on- and offshore oil
and gas development project.
• Point Pedernales Project Permit Modifications.
Ms. Walker completed the analysis and regulatory
processing of Final Development Plan Substantial Conformity Determinations and a Final Development
Plan Director's Amendment for proposed modifications to the Pt. Pedernales Project's oil and gas
processing facility located in northern Santa Barbara County, California.
111 Point Pedernales Project Regulatory Compliance.
Ms. Walker was responsible for the compliance
tracking and enforcement of the 192 Final Development Plan conditions associated with the Pt.
Pedernales Project, an on- and offshore oil and gas development project located in northern Santa
Barbara County.
• Torch Lompoc Gas Processing Facility. Ms. Walker was responsible for the oversight and coor-
dination of the final regulatory technical reviews and approvals required for commissioning and oper-
ation of a natural gas processing plant located in northern Santa Barbara County.
• Los Medanos Energy Facility.
Ms. Walker served as the Assistant Project Manager during prepa-
ration of multiple amendments to an approved CEC Application For Certification for a series of pro-
posed modifications to a power plant located in Contra Costa County.SUSAN S. WALKER, page 9
Pastoria Energy Facility. Ms. Walker served as a Principal Investigator and technical editor during
preparation of a CEC Application For Certification for a proposed power plant located in southern
Kern County. Resource-specific investigations included assistance with completion of the applica-
tion's socioeconomic, cumulative impacts, water supply, and "Applicable Laws, Ordinances,
Regulations and Standards" analyses.
• Kern River Natural Gas Pipeline. Ms. Walker served as a Principal Investigator during the pre-
construction preparation of compliance implementation plans, as well as construction-phase develop-
ment and implementation of multiple databases tracking the environmental monitoring and regulatory
permit compliance of a 904-mile natural gas pipeline traversing the •states of Wyoming, Utah,
Nevada, and California.
? Hercules Remediation Project. Ms. Walker assessed the federal, State, and local regulatory permit
acquisition requirements for the remedial clean-up of an extensive petrochemical spill associated with
the Hercules Oil and Gas Development Project located in Santa Barbara County.
Land Use and Public Policy Analyses & GIS Applications
• Santa Barbara North County Siting Study. Ms. Walker completed the land use analysis and oil
and gas facility infrastructure "baseline" section for a siting and constraints study focused on the
potential alternatives available for the construction and operation of a new consolidated oil and gas
processing facility in northern Santa Barbara County, California.
• Miramar Railroad Realignment. Ms. Walker served as the Principal Investigator for the land use
and public policy baseline, impacts, and constraints analyses for a rail line straightening and expan-
sion project located in the northern portion of the City of San Diego. Analyses were completed for
inclusion in both a "stand alone" environmental constraints study and EIR.
• Mobil M-70 Pipeline Replacement Project. Ms. Walker served as the Principal Investigator for the
land use analysis, mapping, and impact assessment of a proposed 92-mile crude oil pipeline and alter-
natives between Lebec and Torrance, California. The effort included local and County public policy
analysis of pipeline placement and operation requirements.
• Las Vegas Valley Water District Cooperative Use Project. Ms. Walker Principal conducted an
image processing and spatial analysis of a series of LANDSAT satellite images to classify natural
habitats and land use for the preliminary siting of an extensive network of water supply wells and
pipelines throughout southern Nevada.
• Kern County Valley Floor Habitat Conservation Plan. Ms. Walker conducted an extensive habitat
and land use air photo interpretation, mapping, and analysis of the western half of Kern County for
inclusion in the Kern County Valley Floor Habitat Conservation Plan. The effort included mapping
and analysis of the County's General Plan Land Use Element Goals and Policies, and County Zoning
Ordinances.
• Borax Mine Expansion. Ms. Walker served as the Principal Investigator for the Project Description,
Project Alternatives, and socioeconomic and land use analyses portions of an EA addressing a pro-
posed expansion of the U.S. Borax Boron Mine facility, Kern County, California.
• Clark County (Nevada) Flood Control District Master Plan EIS. Ms. Walker prepared the Project
Description, cumulative impacts, and land use analyses of the Clark County Flood Control District
Master Plan EIS.
• QAD Facility Expansion. Ms. Walker Prepared the noise and land use analyses for a preliminary
environmental assessment/screening for a proposed facility expansion of a light-industrial enterprise
J27SUSAN S. WALKER, page 10
in Carpinteria, California. The task included local and Santa Barbara County analysis of General Plan
and Zoning regulations related to land use development.
• Santa Clara River Flood Control Improvements. Ms. Walker served as the Principal Investigator
for a detailed air photo interpretation, mapping, and quantification of predominant habitat types, land
uses, and stream network patterns associated with the Santa Clarita Valley, California. Analysis
included impact assessment of a proposed series of regional flood control improvements of the Santa
Clara River.
• Dominigoni Valley Development Project. Ms. Walker conducted an air photo interpretation, map-
ping, and analysis tracking the historic land uses, natural habitats, and stream network patterns associ-
ated with the Dorninigoni Valley, California. The analysis was conducted to evaluate potential land
development and its affects on local stream networks.
• Geographic Information System Applications. Ms. Walker has managed and/or implemented the
design, development, and analysis of numerous multidisciplinary Geographic Information System
(GIS) efforts, including: California Offshore Oil and Gas Energy Resources Study; Kern County
Habitat Conservation Plan; Chevron Hawaii Refinery Pipeline Data Management System; Union
Pacific—Southern Pacific Merger Application Environmental Analysis; Caltrans Route 41 Environmental
Assessment Project; and, NelIis Air Force Base Integrated Natural Resources Management Plan.
PROFESSIONAL AFFILIATIONS
• Association of Environmental Professionals
CERTIFICATES/AWARDS
• Darlcenwald Award for outstanding academic achievement by a first year graduate student (City
University of New York, Department of Geography and Geology, 1987).Aspen
environmental Group
WILLIAM WALTERS, P.E.
Air Quality Specialist
ACADEMIC BACKGROUND
B.S., Chemical Engineering, 1985, Cornell University
PROFESSIONAL EXPERIENCE
Mr. Walters has over 20 years of technical and project management experience in environmental compli-
ance work, including environmental impact reports, RCRA/CERCLA site assessment and closure, site
inspection, source monitoring, emissions inventories, source permitting, and energy and pollution control
research.
Aspen Environmental Group 2000 to present
Responsible as lead technical and/or project manager of environmental projects. Specific responsibilities
and projects include the following:
• Preparation of the Air Quality Section and General Conformity Analysis for the Matilija Dam
Ecosystem Restoration Project EIS/R for the United States Army Corps of Engineers (Corps).
• Preparation of the Air Quality Section for the Heacock and Cactus Channels Flood Damage
Reduction Project's Draft Environmental Assessment and Mitigated Negative Declaration for the
Corps.
• Preparation of the Air Quality Section for the Santa Ana River Interceptor Line (SARI)
Protection/Relocation Project's Draft Supplemental Environmental Impact Statement/Environmental
Impact Report.
• Preparation of emission inventory and General Conformity Analysis of the Murrieta Creek Flood
Control Project and the Joint Red Flag exercise to be conducted in the Nevada Test and Training
Range for the Corps.
111 Preparation of emission inventory and General Conformity Analysis of the Patriot Integrated Air
•Defense Exercise to be conducted in the Nevada Test and Training Range for the United States Air
Force.
• Preparation of emission inventory for the construction activities forecast for the San Jose/Old San
Jose Creeks Ecosystem Restoration project for the Corps.
• Preparation of the Air Quality Section of the Environmental Information Document in support of the
Coastal Consistency Determinations for the suspension of operation requests for undeveloped units
and leases off the Central California Coast.
? Preparation of the Air Quality sections for two separate Department of Water Resources (DWR)
Santa Ana Valley Pipeline Repairs Project CEQA Categorical Exemption Memorandums.
• Preparation of the Air Quality Section for the DWR Horsethief Creek Bridge Mojave Siphon
Maintenance Road project IS/MND.WILLIAM WALTERS, page 2
• Preparation of the Air Quality Section for the DWR Pyramid Dam Emergency Access Road project
IS/MND.
• Assistance in the preparation of the Air Quality Sections for the DWR Tehachapi Second Afterbay
Project Initial Study and EIR.
• Preparation of the Air Quality Inventory for the Los Angeles Department of Water and Power
(LADWP) Upper Reach River Supply Pipeline Project EIR and Lower Reach River Supply Pipeline
Project E IR.
• Project management and preparation of the Air Quality Section for the Los Angeles Department of
Water and Power (LADWP) Valley Generating Station Stack Removal IS/MND support project.
• Preparation of the Air Quality Section for the LADWP Sylmar to Pacific Ocean DC Electrode Cables
Replacement Project IS/MND.
• Preparation of an Air Quality Inventory for the Los Angeles Department of Water and Power's
revised Pine Tree Wind Development Project.
• Preparation of the Air Quality section of the SCE Devers-Palo Verde 500 kV No. 2 Transmission
Line Project EIS/EIR for the California Public Utilities Commission (CPUC).
• Preparation of the Air Quality section of the SCE Antelope-Pardee 500 kV Transmission Project
EIR/EIS for the CPUC.
• Preparation of the Air Quality section of the SCE Antelope Transmission Project Segments 2 and 3
EIR for the CPUC.
• Preparation of the Air Quality section for the SCE El Casco System Project Draft EIR for the CPUC.
• Preparation of the Air Quality section of the PG&E Hydrodivestiture Draft EIR/EIS for the CPUC.
• Preparation of the air quality sections for the Kirby Hills Natural Gas Storage Project Phase I and
Phase II Initial Studies/Mitigated Negative Declarations for the CPUC.
• Preparation of the air quality section and General Conformity Analysis for the Littlerock Reservoir
Sediment Removal Project for the Palmdale Water District.
• Preparation and project management of the air quality section of the Staff Assessment and/or Initial
Study and the visual plume assessment for the following California Energy Commission (CEC)
licensing projects: Hanford Energy Park; United Golden Gate, Phase I; Huntington Beach Moderniza-
tion Project (including Expert Witness Testimony); Woodland Generating Station 2; Ocotillo Energy
Project, Phase I; Magnolia Power Project; Colusa Power Project; Inland Empire Energy Center; Rio
Linda/Elverta Power Plant Project; Roseville Energy Center; Henrietta Peaker Project; Tracy Peaking
Power Plant Project (including Expert Witness Testimony); Avenal Energy Project; San Joaquin
Valley Energy Center (including expert witness testimony); Salton Sea Unit 6 Project (including
expert witness testimony); Modesto Irrigation District Electric Generation Station (including expert
witness testimony); Walnut Energy Center (including expert witness testimony); Riverside Energy
Resource Center (including expert witness testimony); Pastoria Energy Facility Expansion; Colusa
Generating Station; Panoche Energy Center; and Starwood Power Plant.
• Preparation and project management of the visual plume assessment for the following California
Energy Commission (CEC) licensing projects: Metcalf Energy Center Power Project (including
Expert Witness Testimony); Contra Costa Power Plant Project (including Expert Witness Testimony);
Mountainview Power Project; Potrero Power Plant Project; El Segundo Modernization Project; Morro
Bay Power Plant Project; Valero Cogeneration Project; East Altamont Energy Center (including expert
/ 3 0WILLIAM WALTERS, page 3
witness testimony); Russell City Energy Center; SMUD Cosumnes Power Plant Project (including
expert witness testimony); Pico Power Project; Blythe Energy Project Phase H; City of Vernon
Ma!burg Generating Station; San Francisco Electric Reliability Project; Los Esteros Critical Energy
Facility Phase II; Roseville Energy Park; AES Highgrove Power Plant; Sun Valley Energy Project;
Walnut Creek Energy Park; South Bay Replacement Project; Panoche Energy Center; Colusa
Generating Station; Bullard Energy Center; Carlsbad Energy Center; San Gabriel Generating Station;
Sentinel Energy Project; City of Vernon Power Plant; Chevron Richmond Power Plant Replacement
Project; and Victorville 2 Hybrid Power Project.
• Preparation and project management of the public health section of the Initial Study for the Woodland
Generating Station 2 CEC licensing project.
• Preparation of project amendment or project compliance assessments, for air quality or visual plume
impacts, for several licensed power plants, including: Metcalf Energy Center; Pastoria Power Plant;
Elk Hills Power Plant; Henrietta Peaker Project; Tracy Peaker Project; Magnolia Power Project; Delta
Energy Center; SMUD Cosumnes Power Plant; Walnut Energy Center; San Joaquin Valley Energy
Center; City of Vernon Malburg Generating Station; Otay Mesa Power Plant; Los Esteros Critical
Energy Facility; Pico Power Project; Riverside Energy Resource Center; Blythe Energy Project Phase
II; Inland Empire Energy Center; Salton Sea Unit 6 Project; and Russell City Energy Center.
• Preparation and instruction of a visual water vapor plume modeling methodology class for the
California Energy Commission.
111 Assistance in the preparation of the noise assessment section of the Staff Assessment for the Contra
Costa Power Plant CEC licensing project.
• Assistance in the aircraft safety review of thermal plume turbulence for the Riverside Energy
Resources Center; and the Blythe Energy Power Plant and Blythe Energy Project Phase II (including
expert witness testimony) siting cases. Assistance in the aircraft safety review of thermal and visual
plumes of the operating Blythe Energy Power Plant.
• Preparation of vertical plume velocity reports to support aircraft safety reviews for multiple projects,
including: the Russell City Energy Center Amendment (including expert witness testimony),
Eastshore Power Project (including expert witness testimony); and the Victorville 2 Hybrid Power
Project.
Preparation of the air quality section of the staff paper; "A Preliminary Environmental Profile of
California's Imported Electricity," for the CEC and presentation of the findings before the
Commission.
• Preparation of the staff paper "Natural Gas Quality: Power Turbine Performance During Heat Content
Surge" for the CEC, and presentation of the preliminary findings at the California Air Resources
Board Compressed Natural Gas Workshop and a SoCalGas Technical Advisory Committee meeting.
• Preparation of the staff paper "Emission Offsets Availability Issues" and preparation and presentation
of the Emission Offsets Constraints Workshop Summary paper for the CEC.
• Preparation of information request and data analysis to update the Energy Commission's Cost of
Generation Model capital and operating cost factors for combined and simple cycle gas turbine
projects. Additionally, performed a review of the presentation for the revised model as part of the
CEC's 2007 Integrated Energy Policy Report workshops, and attended the workshop and answering
Commissioner questions on the data collection and data analysis.WILLIAN1 WALTERS, page 4
Preparation of permit applications, emission calculation spreadsheets, the 2006/2007 Annual
Emission Report for submittal to the SCAQMD, and an air quality compliance manual for Desa
International's Southern California manufacturing facility.
• Preparation of the Air Quality Section of the Los Angeles Unified School District New School
Construction Program EIR and provided traffic trip and VMT calculation support for the Traffic and
Transportation Section. As part of this project attended two public scoping meetings.
• Management and preparation of the Draft Air Quality Sections for the Reseda Senior High School
Portable Addition IS/MND and Wonderland Elementary Addition IS/MND projects for LAUSD.
• Technical review and updating of the Air Quality Section for the Valley High School No. 1 FIR
(CSUN), Jefferson No. 6 Primary Center MND, Southern Regional Elementary School #1 MND, and
Central Regional Elementary School #16 MND projects for LAUSD.
• Preparation of the Air Quality Sections and/or impacts modeling assessments for the Central Regional
Middle School #7 MND, Southern Regional Middle School 46 EIR, Narbonne HS Stadium Lighting
and Improvements, and Maclay Elementary School Addition projects.
• Revision of the Risk Management Plan (RIVIP) for the SSI Foods Wilder Idaho Facility Ammonia
Refrigeration Systems.
• Preparation of a control technology evaluation for the control of nuisance odors from wood-fired
pizza ovens for the A16 restaurant in San Francisco, California.
• Preparation of comments on the Air Quality, Alternatives, Marine Traffic, Public Safety, and Noise
section of the Cabrillo Port Liquefied Natural Gas Deepwater Port Draft FIS/EIR for the City of
Oxnard.
Preparation of comments on the Air Quality section of the Long Beach LNG Import Project Draft
Environmental Impact Statement/Environmental Impact Report for the City of Long Beach.
Preparation of an odor and health impact study in support of the Ventura County Piru Area Plan
Update EIR.
Camp Dresser & McKee, Inc. 1998 to 2000
Mr. Walters was responsible as lead technical and/or project manager of environmental projects. Specific
responsibilities and projects include the following:
• Preparation of emission inventories and dispersion modeling for criteria and air toxic pollutants for
the Los Angeles International Airport Master Plan (LAXMP) EIS/EIR.
• Project Manager/Technical lead for the completion of air permit applications and air compliance
audits for two Desa International fireplace accessory manufacturing facilities located in Santa Ana,
California.
• Air quality audit for a confidential can manufacturing company at two manufacturing sites.
• Project manager/technical lead for the completion of Risk Management Plans (RMPs) for four J.R.
Simplot food processing facilities in Oregon, Idaho, and Washington and the Consolidated Repro-
graphics facility located in Irvine, California. Project manager for the concurrent Process Safety Man-
agement plan support for the J.R. Simplot Hermiston (Oregon) and Heyburn (Idaho) facilities and the
project manager/technical lead for the RMP support for the SS1 food processing facility in Wilder,
Idaho, and the Atlantic Custom Processors food processing facility in Fort Fairfield, Maine.
3 2-WILLIAM WALTERS, page 5
Completion of an environmental tax credit application for the J.R. Simplot Hermiston Oregon food
products facility.
Planning Consultants Research
1997 to 1998
Mr. Walters was responsible as lead technical and/or project manager of environmental projects. Specific
responsibilities and projects include the following:
IS Project Manager for a stationary source emission audit of the entire Los Angeles International Airport
complex for Los Angeles World Airports (LAWA) in support of the LAXMP.
• Review of the Emission Dispersion Modeling System (EDMS) and preparation of a report with
findings to the Federal Aviation Administration for LAWA in support of the LAXMP.
• Project manager for the ambient air monitoring and deposition monitoring studies performed for
LAWA in support of the LAXMP, including the selection of the monitoring sites and specialty sub-
contractor, and review of all monitoring data.
• Completion of intersection "CO Hotspots" modeling, ambient monitoring, and deposition monitoring
reports for LAWA in support of the LAXMP.
Aspen Environmental Group/Clean Air Solutions 1995 to 1996
Mr. Walters was responsible as lead technical and/or project manager of environmental projects. Specific
responsibilities and projects include the following:
• Manager of the Portland, Oregon, office of Clean Air Solutions from March 1995 to December 1995,
with responsibilities including Project Management, Business Development, and Administration.
• Control technology assessment, engineering support and Notice of Intent to construct preparation for
J.R. Simplot's Hermiston, Oregon, food processing facility. Review and revision of an Air
Contaminant Discharge Permit application, Title V permit application, and PSD modeling analysis for
J.R. Simplot's Hermiston facility.
• Air quality compliance report including an air emission inventory, regulation and permit compliance
determination, and recommendations for compliance for Lumber Tech, Inc.'s Lebanon, Oregon, wood
products facility.
• Source test methodology and equipment selection for testing inlet and outlet concentrations of total
petroleum hydrocarbon and benzene from soil gas extraction/oxidation units for Cascade Earth
Sciences, Ltd.
• Preparation of a Tier II (synthetic minor) permit application for the American Fine Foods' Payette,
Idaho, food processing facility.
• Emission inventory and compliance evaluation for Simplot's Aberdeen, Idaho, food processing
facility.
• Preparation of an Air Contaminant Discharge permit application for Marlette Homes, Inc. Hermiston,
Oregon, manufactured housing facility.
• Preparation of a Title V permit application for Simplot's Helm, California, fertilizer manufacturing
facility.
Source test contractor selection and test oversight for J.R. Simplot's food processing plant in Herm-
iston, Oregon, and Boise Cascade's wood-fired boiler in WilIamina, Oregon.
133WILLIAM WALTERS, page 6
Fluor Daniel, Inc.
1990 to 1995 and 1996 to 1997
Mr. Walters was responsible as lead technical or project manager for major environmental projects for
both government and private clients. His projects included:
• Prepared several air permit applications for the ARCO Los Angeles Refinery Polypropylene Plant
Project.
Phase I environmental assessments for seven properties located in Southern California.
• Prepared Environmental Baseline Reports for 33 sites in Guam for the US Navy.
• Prepared site investigation and RCRA closure plan report for Olin Hunt Specialty Chemical's Vernon,
California, hazardous waste storage site.
• Project manager of the Anaconda Smelter site for the US Environmental Protection Agency's (EPA)
Alternative Remedial Contract System (ARCS) project during the conclusion of technical activities
and project closeout. Prepared a cost recovery report for the project.
• Task manager for nine site investigations under the EPA Region VI ARCS contract. Project activities
included data collection, work plan preparation, field sampling, final report preparation, and Hazard
Ranking System (HRS) PREscore preparation.
• For the Hanford (Washington) Waste Vitrification Project, prepared an air emission inventory for
criteria pollutants, prepared an emission inventory and compliance evaluation of toxic air pollutants,
performed compliance review of design drawings and equipment specifications, analyzed failure
probability and consequence analysis of design-basis accidents.
• Prepared fugitive and point source VOC emission estimates and performed a "Top-Down" BACT
analysis for a 217 MMBtu/hr steam boiler for a proposed ethanol production facility in Great Falls,
Montana.
• Performed environmental analysis for the Bonneville Power Authority, including air pollution BACT
analysis, wastewater analysis, and evaluation of secondary environmental effects of electric power
producing technologies.
Jacobs Engineering Group 1988 to 1990
Mr. Walters was responsible for a wide range of air pollution regulatory and testing projects, including
the following:
• Project manager of air toxic emission inventory reports (under California's AB2588), prepared for US
Borax's boron mining and refining facility and the Naval Aviation Depot (North Island Naval Base,
San Diego, California).
• Prepared air permit applications and regulatory correspondence for several facilities:
• US Department of Energy's Feed Material Production Center uranium processing facility in Fernald, Ohio
• Emission sources at a confidential high technology electronics manufacturing facility
? Evaluation of a sludge dewatering process at Unocal's Wilmington, California, Refinery
a United Airlines blade repair facility at the San Francisco Airport
a Relocation of Kerr-McGee's rocket fuel storage and blending facility to Apex, Nevada.
• Prepared source testing plans, Quality Assurance/Quality Control (QA/QC), and testing oversight for
several facilities, including: QA/QC for RCRA air emissions sampling plan for the Department of
Defense's Chem-Demil facility on Johnston Atoll; prepared plan and provided QA/QC and field
I"WILLIAM WALTERS, page 7
oversight for emissions testing at Baxter Healthcare in Irvine, California; and prepared plan and
provided testing oversight for Kerr-McGee's existing ammonium perchlorate manufacturing facility
in Henderson, Nevada.
• Completed identification of air permitting regulations and control technology requirements for a
proposed 30,000 barrel per day catalytic cracking unit for Coastal Corporation's Pacific Refinery,
located in Hercules, California.
• Characterized and quantified air emissions for offshore oil and gas development activities associated
with Federal oil and gas Lease Sale 95, offshore southern California, for the US Minerals Manage-
ment Service.
• Assisted in selection and design of air pollution control equipment for various clients.
• Prepared environmental reports, including waste stream quantification and characterization for
several proposed facilities, including:
• Lake Minerals proposed soda ash plant at Owens Lake, California
• Minses proposed potash facility located on the Salar de Atacama in Chile.
San Joaquin County Air Pollution Control District During 1987 and 1988
Mr. Walters served as an air pollution engineer and was responsible for the following: start-up site inspections
of air pollution sources; monitoring source tests and evaluating source test reports; permitting minor and
major sources of air pollutants; processing emission banking applications; and aiding in the preparation of
the District's Best Available Control Technology (BACT) quarterly reports, Reasonable Further Progress
reports, and emission inventories.
Adelphi Center for Energy Studies 1985 to 1986
Mr. Walters served as a combustion facility manager/research engineer and was responsible for the
following: management and implementation of all conventional and novel fuel combustion projects,
including the preparation of interim and final reports, conducting source tests using EPA methods 1-4 and
17, and the data analysis of all combustion tests; maintenance and repair of all combustion facility
equipment; preparation of all combustion project proposals; and implementation and data analysis of fuel
atomization studies, fuel rheology research, and bench scale coal ash removal research.
CERTIFICATIONS
11 Chemical Engineer, California License 5973
• CARB, Fundamentals of Enforcement Seminar
• EPA Methods 1-8, 17; Training Seminar
AWARDS
• California Energy Commission Outstanding Performance Award 2001
135JAY SHETH
CHEMICAL ENGINEER
Mr. Sheth is a graduate of the University of Southern California and a registered professional chemical
engineer in both California and Arizona.
EDUCATION
M.S., Chemical Engineering, University of Southern California, 1975
B.S., Chemical Engineering, University of Southern California, 1973
REGISTRATION
California Chemical
No. 3535
Arizona Chemical
No. 23163
SPECIAL FIELDS OF KNOWLEDGE
Hydrocarbon Processing - Design and Operations
Risk Assessment, Risk Analysis and Hazard and Operability Studies
Operations Management
Project Management
Petroleum Processing, Economics and Feasibility
System Safety and Reliability
AICHE Process Risk Management Training
PROFESSIONAL ACTIVITIES
Tau Beta Pi
American Institute of Chemical Engineers
American Society of Mechanical Engineers
PROFESSIONAL EXPERIENCE
Mr. Sheth has had over thirty-six years experience in process risk assessment and evaluation, project
management, process design, facilities revamp, plant construction, start-up and environmental permit
management.
Mr. Sheth has been associated with Robert Brown Engineers for more than thirty years serving as
lead process and project engineer in the hydrocarbon facility risk assessment and evaluations, facility
audits, process design of gas treating facilities, refinery expansions, grass root refineries, SNG
modifications for refinery fuel gas feed, offsite facilities, in-line fuel oil and gasoline blending
facilities, utilities, and sulfur removal and recovery. He has conducted configuration and economic
feasibility studies for shale oil, tar sands bitumen, grass-roots refineries and related facilities. He has
also been involved with simulation of the California refineries for California Energy Commission
(CEC) projects.
/ 36.Mr. Sheth has an extensive experience in the risk assessment and Hazard and Operability Studies
(HAZOPS). Mr. Sheth has been associated with risk assessment, risk analysis and HAZOPS for more
than twenty two years.
Mr. Sheth, as part of five-member panel, conducted evaluation of design and operational safety of
Alyeska's Valdez Marine Terminal's Tanker Vapor Control System in Alaska.
Currently, Mr, Sheth has been involved with the County of Santa Barbara providing safety review of
the oil and gas projects. The responsibilities include reviewing process and mechanical design;
HAZOPS; risk assessments; corrosion control, monitoring, inspection and maintenance; EIRs; relief
system; startup and commissioning procedures; operating procedures; electrical area classifications;
handling of hazardous and toxic chemicals; safety regulations; emergency shutdown systems and
other safety related systems. The safety reviews are being conducted since 1984. The oil and gas
projects in the county include: PXP's (formerly Chevron) Pt. Arguello Project; Phil lips' Tajiguas Gas
Plant Modification; Shell Motino Gas Plant Expansion; PXP's (formerly Unocal) Pt. Pedernales
Project; ExxonMobil Santa Ynez Project; All American Pipeline Project; Texaco Gaviota Marine
Terminal; E&B Natural Resources' (Formerly ARCO) South Cuyama Project; POPCO's Gas Plant
Expansion; Venoco's (formerly ARCO/Mobil) Ellwood OH & Gas Treating Facility, Ellwood
Marine Terminal and Platform Holly; Unocal/Nuevo' s (now PXP) Gas Plant; Molino Energy's Gas
Plant Project; Greka's (formerly Conoco) Santa Maria Asphalt Refinery; ConocoPhillips' (formerly
Unocal) Pipelines and Pump Stations; and other oil and gas processing facilities.
Mr. Sheth is one of the principal participants of the annual Safety, Inspection, Maintenance and
Quality Assurance Program (S1MQAP) audits of all Oil & Gas processing facilities in the County of
Santa Barbara. These audits ensure that the facilities are operated in a safe and environmentally
sound manner.
Mr. Sheth was involved in preparation of Initial Study and EIRs for petroleum pipelines in the L.A.
Basin. Mr. Sheth assisted in preparation of the Supplemental EIRs for the Pacific Pipeline and Santa
Fe Product Pipeline. He was responsible for the implementation of the mitigation measures (as part of
the Pacific Pipeline Mitigation Monitoring Program) during the design and construction of the Pacific
Pipeline.
Mr. Sheth was involved in evaluating and auditing Alyeska's Valdez Marine Terminal Tank Vapor
Recovery and Tanker Vapor Control Systems for safety, corrosion and leaks. Mr. Sheth was also
involved with All American Pipeline Company's System Safety Section of the EIR for the crude oil
pipeline from California to Texas.
A grass root refinery was constructed in record time under the leadership of Mr. Sheth. The project
was completed (from conception to startup) Within a year. The project included economic feasibility,
permitting, design, construction management, and startup of the facility.
Mr. Sheth has performed economic feasibility studies for various hydrocarbon processing facilities.
Over the years, projects included four west coast refineries for possible purchase and bank evaluation
for collateral coverage, heavy crude oil gasification to produce synthetic natural gas for the Gas
Company, Shale oil feasibility for the Edison and petroleum products loading operation. Feasibility
study of a grass root refinery in Arizona resulted in realization of the refinery project.
132Mr. Sheth has provided litigation assistance for a number of projects. Among the projects for which
the assistance provided were: Feedstock contract dispute and Rate case for NI Gas, Fuel contract
dispute for Southern California Edison (SCE) and oil price fixing dispute against the Oil Companies.
Mr. Sheth was also involved in preparing testimony for FERC (Federal Energy Regulatory
Commission) and CPUC (California Public Utilities Commission) hearings for a rate reasonableness
review. Mr. Sheth was expert witness for number of litigations including the litigation of Nuevo's
crude oil pipeline rupture due to corrosion in the offshore environment, Venoco's Pig Receiver
accident as well as Venoco's insurance claims for the sour gas releases from the Ellwood facilities.
Mr. Sheth has been involved in the project management for the start-up of a gas treating facility. The
facility included an offshore pipeline, gas sweetening, dehydration, NGL recovery, sulfur removal
and recovery and offsites.
As an adjunct to his process engineering activities at RBE, Mr. Sheth has conducted freight
forwarding inspection and certification of process equipment and materials being sent to Indonesia.
As a senior chemical engineer at C. F. Braun, Mr. Sheth was responsible for utility flow diagrams,
hydraulic calculations and steam balances for amine, sour water and offsite units.
As a process and plant engineer for Basin Petroleum Company, Mr. Sheth was responsible for
converting a petrochemical plant into a refinery. This work included process design for a crude
topping unit, vapor recovery system and offsites. He also supervised plant construction and start-up.
Mr. Sheth conducted environmental studies, assisted in filing and obtaining permits for the plant
hydrocarbon emissions, air pollution and water pollution control systems. Mr. Sheth also conducted
pilot plant studies for various sulfonation processes and prepared sulfonation reports, cost analysis,
laboratory tests for quality control.
At the University of Southern California Mr. Sheth served as a research assistant and tutor. He
assisted the department of chemistry professor in his kinetics research, and assisted department of
chemical engineering chairman in preliminary studies on various coal gasification processes. He
served as a teaching assistant for the unit operations laboratory in the department of chemical
engineering. He also tutored chemistry, mathematics and physics.
Mr. Sheth is President of Robert Brown Engineers, overseeing the operations since 1986.
/3TGEOTECHNICAL CONSULTANTS, INC.
Geotechnical Engineering - Geology • Hydrogeology
JAMES E. THURBER, R.G., C.E.G., C.H.G.
STATEMENT OF QUALIFTCATIONS
James Thurber leads Geotechnical Consultants, Inc.'s (GTC's) geologic and
hydrogeologic efforts. Mr. Thurber is actively involved in engineering geology, hydrogeology,
and hazardous material assessments for numerous local and regional environmental impact
reports. His EIR experience includes long linear pipelines and transmission lines, new power
plants, highways, new schools, and large redevelopment projects. He is experienced in the
impact analysis of hazardous materials for large planning projects and preparing appropriate and
applicable mitigation measures. Mr. Thurber has also conducted hazardous waste investigations
and site characterization for leaking underground fuel tanks, industrial facilities and solid waste
landfills, and is experienced in the assessment of site conditions related to past and current use of
hazardous materials and environmental contamination.
He brings with him 25 years of experience and an in-depth knowledge of the
development, protection, and management of municipal groundwater resources. His expertise
encompasses hydrogeologic assessment of groundwater basins; aquifer characteristics
determination; water well site selection; water well design; management of well construction;
and the assessment and development of well rehabilitation programs. Mr. Thurber has conducted
groundwater resource studies to evaluate storage capacity, estimate recharge, and develop flow
models to assess long-term yield, seawater intrusion, and drought impacts. His particularly
sought after skills include the design of large-diameter, high-capacity municipal supply wells;
injection and monitoring wells in nested and cluster configurations; and interpretation of
stratigraphie and geophysical logs for final selection of screened intervals and gravel pack during
well construction to optimize sand-free groundwater production and aquifer-specific monitoring.
EDUCATION
Colorado State University, M.S., Geology, 1982
California State University, Northridge, B.S., Geology, 1978
California State University, Northridge, B.A., Geography, 1976
CERTIFICATION AND REGISTRATION
Registered Geologist No.4197, State of California
Certified Engineering Geologist No.1458, State of California
Certified Hydrogeologist No. 162, State of California
MEMBERSHIP
National Ground Water Association
American Water Works Association
/3?GIC
JAMES E. THURBER, R.G., C.E.G., C.H.G.
STATEMENT OF QUALIFICATIONS
EXPERIENCE
GEOTECHNICAL CONSULTANTS, INC. Mr. Thurber joined the firm in 1985 and
manages GTC's Orange County office. Select project experience includes:
SCE Tehachapi Renewable Transmission Project, Kern, Los Angeles, and San
Bernardino Counties, California. We are analyzing environmental contamination, geology,
soils, and seismic issues for a 159 mile long 500kV transmission line and four alternative
alignments extending from Tehachapi across Antelope Valley, across the San Gabriel Mountains
and San Gabriel Valley to Mesa Substation in Montebello, and then east across the Montebello,
Puente, and Chino Hills to Mira Loma Substation in the City of Ontario. These alignments
traverse the San Andreas, San Gabriel, Sierra Madre, Whittier, and Chino fault zones as well as
landslide prone areas in the San Gabriel Mountains and Chino Hills.
Lower Crystal Springs Dam Improvement Project EIR, San Mateo County,
California. A new spillway and stilling basin are planned to prevent erosion and scour of the
dam abutments during the Probable Maximum Flood. The new concrete stilling basin measures
90 feet by 100 feet with 18 foot high sidewalls and will rest on sandstone after removal of 15 feet
of alluvium. Geologic impacts related to excavation and shoring of artificial fill, alluvium and
colluvium along San Mateo Creek, erosion during construction, and potential corrosive soil and
bedrock were evaluated.
Irvington Tunnel Project EIR, Alameda County, California. Geotechnical
Consultants analyzed the environmental impacts of geology, soils and seismicity for the critical
4-mile long water conveyance tunnel, portals and disposal areas. GTC also assisted with the
identification and analysis of groundwater resources. The new water transmission tunnel will
parallel the existing tunnel and will pass through an uplifted block of Tertiary sedimentary rock
bounded by the active Calaveras and Hayward faults. Geologic impacts of tunneling include
intercepting groundwater and decreasing spring flows, tunneling through weak rock and fault
gouge zones, slope stability concerns at the portals, and placement of large volumes of tunnel
rock and muck at disposal sites.
Calaveras Dam Replacement Project LW, Alameda and Santa Clara Counties,
California. The new dam will replace the existing seismically unsafe dam. The dam site requires
deep excavation to remove loose deposits, weathered bedrock and a large landslide on the right
abutment. Three borrow sites and two large disposal sites are required to obtain the range of
earth materials needed for dam construction and disposal of excess and unusable material.
Geologic issues include active faulting and strong groundshaking sourced from the nearby
Calaveras fault, placement of large disposal fills, and erosion along access roads, borrow sites
and permanent disposal areas.
Sunrise Powerlink Project EIR/EIS, Imperial and San Diego Counties, California.
We conducted the analysis of the environmental impacts of geology, soils, seismicity and
environmental contamination for the 150-mile long transmission line that extends from the
Page 2
/'10JAMES E. THURBER, R.G., C.E.G., C.H.G.
STATEMENT OF QUALIFICATIONS
Salton trough, over the Peninsula Ranges and into the Coastal terraces. The diverse geologic
setting presents several impacts related to crossing of active faults, strong seismic shaking,
erosion, slope stability, and access to mineral resources. The environmental analysis is
evaluating five alternatives and potential new in-area power generation. Hazardous materials
and unexploded military ordinance sites are also being identified and evaluated for project
impacts.
SCE Antelope-Pardee Transmission Segment 1, Los Angeles County, California.
We are analyzing geology, soils, and seismic issues for five alternative alignments, each
measuring about 25 miles long. In addition, we are evaluating environmental contamination
along these alignments, particularly the underground portions. These alignments traverse high
desert, and mountainous areas, and the San Andreas rift zone.
SCE Antelope Transmission Project Segments 2 and 3, Los Angeles and Kern
Counties, California. We are analyzing geology, soils, and seismic issues for three alternative
alignments extending from Tehachapi across Antelope Valley to Palmdale and the Vincent
Substation. In addition, we are evaluating environmental contamination along these alignments,
particularly the underground portions. These alignments traverse the Garlock and San Andreas
fault zones.
Master Plan Elk - Los Angeles Pierce College Facilities; Hazardous Material and
Geologic Hazards EIR Sections. Prepared the Geology and Soils, and Hazardous Materials
Draft EIR sections. The geologic/seismic hazard assessment identified geologic setting,
including soil characteristics, faults, and seismicity at the proposed project site, and the
preliminary hazardous material site assessment investigated the potential for environmental
contamination to adversely impact proposed Pierce College Master Plan improvements.
Provided analysis of significant impacts from geologic hazards and developed mitigation
measures.
Jefferson-Martin 230 kV Transmission Line EIR. Mr. Thurber was responsible for
overseeing the preparation of the geology and environmental contamination sections of the EIR.
California Energy Commission, Staff Assessments Technical Assistance in
Application for Certification Review. Geotechnical Consultants Inc. is assisting Aspen
Environmental Group and CEC in evaluation of new power plant applications throughout the
State. Mr. Thurber is serving as a Project Hydrogeologist for the issue area of groundwater for
cooling and potable supply.
Groundwater Staff Assessment. Conducted the analyses of groundwater issues for
domestic supply and cooling at the Morro Bay Power Plant (MBPP) and the San Joaquin Valley
Energy Center (SJVEC). Provided written testimony for the staff assessments of MBPP and
SIVEC, and provided oral testimony at the MBPP hearings.
Page 3(IC
JAMES E. THURBER, R.G., C.E.G., C.H.G.
STATEMENT OF QUALIFICATIONS
Compliance Review. Provided support for CEC staff evaluating preliminary well design
and estimates of groundwater production and aquifer storage and recovery for the High Desert
Power Plant. As Project Hydrogeologist, assisted with review of aquifer test planning, analysis
of aquifer test results, and well interference calculations for the Blythe Energy Power Plant.
Miguel-Mission 230 kV #2 EIR. Mr. Thurber is the Associate Geologist overseeing
preparation of the geology and environmental contamination sections of the EIR. The project is
being prepared for the California Public Utilities Commission (CPUC) to evaluate a proposed 35
mile lone 230 kV circuit within an existing transmission fine ROW between Miguel and Mission
substations in San Diego County. In addition, the Miguel Substation and Mission Substation
would be modified to accommodate the new 230 kV transmission circuit.
Kinder Morgan Concord to Sacramento Pipeline EIR. Project manager for the
geology and environmental contamination sections of an EIR evaluating a proposed 70-mile long
refined petroleum products pipeline for the California State Lands Commission. Analysis
included consideration of potential impacts from active fault crossings, landslides, liquefaction,
existing soil and groundwater contamination, and from potential pipeline accidents in Contra
Costa, Solano, and Yolo Counties.
Bolsa Chica Water Line EIR. Prepared geology, seismicity, groundwater resources and
hazardous materials sections of the Bolsa Chica Water Line Environmental Impact Report. This
project was prepared for the CPUC to evaluate a proposed water transmission line through the
City of Huntington Beach for use by Southern California Water Company. Provided analysis of
significant impacts from geologic hazards, hazardous materials, use of groundwater resources,
and developed mitigation measures.
New Mental Health Treatment Facility, Coalinga and Imperial County. Performed
preliminary geologic and hazardous material site assessments to evaluate the potential for
geologic/seismic hazards and environmental contamination to impact the proposed New Mental
Health Treatment Facilities. Prepared environmental contamination and geologic hazards sections
of the EIR.
A listing of other projects is given below:
Environmental Impact Technical Studies
Preliminary Environmental Assessment, Proposed Military Vehicle Storage Facility,
Bakersfield, California
New Mental Health Treatment Facility, Coalinga and Imperial County, California
Initial Study to Evaluate the Division of Oil, Gas, and Geothermal Resources, CEQA
Compliance Program, Kern County, California
Caltrans District 7 Headquarters EIR; Los Angeles, California
Sunrise Powerlink Transmission Project, Imperial and San Diego Counties, California
Tranquillon Ridge Oil Pipeline EIR Update, Santa Barbara County, California
Page 4
PO-JAMES E. THURBER, R.G., C.E.G., C.H.G.
STATEMENT OF QUALIFICATIONS
SFPUC WSIP-Program HR, San Francisco Bay Area, California
SFPUC Lower Crystal Spring OR, San Mateo, California
SFPUC Calaveras Dam EIR, Sunol, California
SFPUC Alameda Siphons, Sunol, California
SFPUC Irvington Tunnel EIR, Sunol to Newark, California
Devers-Palo Verde 500kV Transmission Line, Arizona to California
Antelope Transmission Project, Kern and Los Angeles Counties, California
Antelope-Pardee Transmission Line, Antelope Valley to Santa Clarita, California
Santa Fe Pacific Pipeline, Carson to Norwalk, California
Ade!ante Eastside Redevelopment Project, Los Angeles, California
California Public Utilities Commission, Level 3 Communications Network. California
North County Landfill Siting Study, San Diego County, California
Imperial Redevelopment Project, San Diego, California
Cajon Pipeline, San Bernardino and Los Angeles Counties, California
Pacific Pipeline, Santa Barbara, Ventura and Los Angeles Counties, California
North Park Redevelopment Project, San Diego, California
San Ysidro Redevelopment Project, San Diego, California
Municipal Water Wells
Colorado Well, Arcadia, California
Brewer Desalter Well, Torrance, California
Well 14 and 15, 99th Street Well Field, City of Los Angeles, California
Well Nos.19, 20, 21, 22, 23, 24 and 25, Orange, California
Well Nos.IB, 8, 9 and 11, Mesa Consolidated Water District, Costa Mesa, California
Water Well Rehabilitation, Mesa Consolidated Water District, Well Nos.4, 5, 7
and 8, Costa Mesa, California
Vandenberg Well, City of Tustin, California
Well IDP-1 through IDP-4, Irvine Desalter Project, Orange County Water District,
Irvine, California
Sebastopol Road and Occidental Road Wells, Santa Rosa, California
Ball and Boisseranc Wells, Buena Park, California
Well 2363 and 2201, USMC Camp Pendleton Air Base, Oceanside, California
Valley Well No.2, San Diego Wild Animal Park, San Pasqual Valley, Escondido
Injection/Recharge Wells
Injection Wells 124 and 125, Well Development and Aquifer Testing, Talbert Seawater
Barrier, Orange County Water District, Fountain Valley, California
Injection Well Cluster 126, Talbert Seawater Barrier, Orange County Water District,
Fountain Valley, California
Page 5
/11.3JAMES E. THURBER, R.G., C.E.G., C.H.G.
STATEMENT OF QUALIFICATIONS
Groundwater Monitoring, Site Characterization Studies
West Coast Barrier Triple Nested Monitoring Well, Redondo Beach, California
Nested Monitoring Wells, Sonoma County Water Agency, Windsor, California
Nested Monitoring Wells, Orange County Water District, Newport Mesa,
Orange County, California
West Waterman Canyon Portal, Inland Feeder Tunnel, San Bernardino, California
San Pasqua! Valley, San Diego, California
Mesa Consolidated Water District/Orange County Water District, Deep Multi-Port
Monitoring Well, Costa Mesa, California
Calabasas Landfill, Calabasas, California
Puente Hills Landfill, Whittier, California
Los Alamitos AFRC Landfill, Los Alamitos, California
Domtar Gypsum, Inc., Vernon, California
Culver City Motor Clinic, Culver City, California
Norwalk Dump, Norwalk, California
Stinnes-Western Chemical Corporation, Vernon, California
Cooper Drum Company, South El Monte, California
George Air Force Base, Adelanto, California
Palomar Airport Landfill, Carlsbad, California
Water and Wastewater Treatment Facilities
SFPUC Harry Tracy Water Treatment Plant Geologic Hazard Assessment, San Mateo,
California
SFPUC Moccasin Penstock Replacement Tunnel Feasibility, Moccasin, California
Metro Biosolids Center/Northern Sludge Processing Facility, San Diego, California
Point Loma Wastewater Treatment Plant, Sludge Pumping Facilities,
San Diego, California
San Diego-Tijuana Land and Ocean Outfalls, San Diego, California
Sunnydale Transport/Storage Facilities, San Francisco, California
San Diego Sludge Management Facilities, San Diego, California
Tehachapi Wastewater Treatment Plant, Tehachapi Correctional Institution,
Tehachapi, California
Silverwood Lake Water Treatment Plant, Crestline, California
Groundwater Desalter Facility, San Juan Capistrano, California
Leaking Underground Fuel Tanks
Orange Fire Station, Orange, California
California Industrial Products, Santa Fe Springs. California
Rexnord-Trid airIndustries, Torrance, California
W.A. Woods Industries, South Gate, California
Burch Ford, La Habra, California
Page 6JAMES E. THURBER, R.G., C.E.G., C.H.G.
STATEMENT OF QUALIFICATIONS
Tunnels
Moccasin Penstock Replacement Tunnel Feasibility, Moccasin, California
North Outfall Replacement Sewer, Los Angeles, California
North City Tunnel Connector, San Diego, California
Inland Feeder - Mountain Segment Tunnel, San Bernardino, California
Freeway, Light Rail, Airport Projects
BART Earthquake Safety Program, Aerial Guideway Structures Project, San Francisco
Bay Area, California
Yuma Drive Interchange, Riverside, California
Route 91 Sound Walls, Riverside, California
I-15/Glen Helen Parkway Interchange, San Bernardino, California
I-10 HOV Project, Los Angeles, California
Route 222 — Bass Lake Road Improvements, Madera County, California
Routes 18, 40, 62, 83, and 79 Roadway Rehabilitation Projects, San Bernardino County,
California
Santa Monica Airport, Santa Monica, California
Ontario Airport, Ontario, California
Los Angeles Airport, Los Angeles, California
Rice Avenue - U.S. 101 Interchange (IS/EA; ND/FONSI) Oxnard, California
Isabel Avenue Extension, Livermore, California
Other Projects
Los Angeles Regional Transit System Blue Line, Los Angeles, California
AT&T Light Guide Cable, Northern California
Celeron/All American Pipeline, Santa Barbara County, California
Hayward Fault Evaluation, Fremont, California
Aguanga-Earthquake Valley Fault, Warner Springs, California
MBC/NSPF Gallery Fault Investigation, San Diego, California
Smith Headquarters Facility, Los Angeles, California
Indicator Pile Pre-drilling and Observation, Box Culvert, San Diego, California
LAMTA Red Line East Side Vibration Propagation Study, Los Angeles, California
MBC/NSPF South Access Road, San Diego, California
California Science Center/California African American Museum Parking Structure EIR;
Los Angeles, California
Page 7Attachment 3 to Exhibit "A"
of Resolution No. 2008R South Coast Air Quality Management District
Air Quality Complaint Report
Complaint 181387
Recebee Sy: GRACEN on 1t1012006 22:25:00 Assignment No: Mug
Assign By: Paw on 1/1112006 07:42:37 Inspector: JOSEPH LIAW (JLM)
Dispatch On: 1/1 0/2005 Instruction:
Team: C
Type: ODORS
Description: SMELLED SOMETHING FUNNY OUTSIDE.
Instance Start Data:
Instance End Date:
Complainant
Finit Name:
Address:
Phone:
Laid Name:
Alleged Source Nama: OIL WELL
Manses: LA CIENEGIVSLAUSON, CULVER CRY, CA 90230 (Sector LF)
Actual Source Name:
Address:
Dispresitiori
SUNK on 1/11/2006 07:4627
Complaints nos. 181387 and 181389
On I/10/06 at 2330 hours, I arrived at the complainant's home located at to investigate the
odor complaint. I met with both the complainant, , and her husband, . According to
he stated that earlier that evening at 2230 hours, he stepped outside his home
and imielled a strong diesel exhaust odor. He
characterized the odor as
similar to the exhaust from airplanes or from diesel trucks. Also, he stated that the smell was strong
for only a brief period and has since gone away. During the time I was there, both
and stated that they were
unable to smell any odors. Deft their residence at 2345 hours and heeded towards PXP LA for surveillance. The facility
is
located along S. La Cienega Blvd, and La Brea Ave. While driving along S. La Cknega Blvd., I did notice a petroleum amen
that was mixed with exhaust fumes. Since there really weren't any traffic, I did not believe that it was from a car or truck. Also,
along La Cienega, there were no places to stop and get out of the vehicle to determine the odor. Therefore, I drove along
Stocker St. and Fairfax Ave. to verify the odor. Plains Exploration & Production Company (F1D# 133987) in Los Angeles
office is located on 5640 S. Fairfax Avenue. I was able to park along the road at several spots and walk up to the fence line
closer to the on wells. At these spots, I was only able to detect a faint crude oil odor, which
WaS different than the smell along
La Cienega Blvd. At the time, I thought it was possible that I was detecting a smell that had a mix of crude oil and vehicle
exhaust.
As for the complaint investigation, both the complainants and I were unable to identify the odor at the complainant's residence.
Also, the described odor according to the complainants was a diesel odor. During
ray surveillance, I was able to identify a faint
petroleum odor. However, it was weak at the lime, arid! was unable to match this odor to the one the complainant identified
when be
called the districts complaint number. Therefor; the source of the odor was unknown and no further actions were
taken. heft the area at 0010 hours.
On 1/11/06,1 was notified by Supervisor Sam Vegeta that the our emergency response team went out to PXP LA after 2130
hours on 1110/06 in
response to a substance release from a oil well. I contacted Pat Gorski (323-298-2441), EH&S Advisor for
PXP LA. to gather more information. According to Mr. Gorski, during the late evening of 1/10/06, a rig drilling for PXP in the
Inglewood Oil Field exper a=1:rihrIE nf
natural gas during drilling operations. An unknown am= of methane gas and
hydrogen sulfide was released into the atmosphere. Also, the prevail:44 r. -airied the odor from the location towards the
ocean_ According to Mr. Ciorski, the concentrations of gas on and leaving location were confirmed to =ilea' ta f.t.=.^ -^,41hlit nor
hazardous, Also, representatives from Los Angeles County Fire Department, Calves City Fire Department
and Los Angeles
County Health and Bazanl.,
-ms Mate.tialA Dcvarmient have been cersite to confirm there were no hazards posed to the
conernmity.
INSPECTOR:
sigma=
SUPERVISORaieeeterc
DATE:
r/ATV.
1/6South Coast Air Quality Management District
Air Quality Complaint Report
Complaint 181392 .
Receive By: AKIM on ¶111/200607:41:37 Assignment No: 918895
Ass Et samv on 1/11/2008 07:52:50 inspector: JOSEPH UAW (JL05)
Dispatch an: 1/11/2006 Instruct1on:
Team: c
Type: ODORS
Dew:4410n: Strong fumes front oli Mang. Fumes began last night and Is. stilt present
Instance Start Date: Instance End Date:
Complainant
First Name:.
Address:
Phone:
Last Name:
Alleged Source
Name: PXP (OIL DRILLING)
Address: LA CIENEGA/STOCKER, CULVEFL cry, CA 90230 (Sector LF)
Actual Source
Name:
Address:
SUNK on 1/11/2006 17:39:47
1.11/WITIOLCABIDICat On 1/11106, complaints *181392,
181393, 181394, 181395 and 181402 were called in regards to an odor associated with a
incident at Plains Exploration & Production Company (FE13# 133987) located on 5640 S. Fairfax Ave. in Los Angeles.
Earlier on 1/11/06,1 was notified by Supervisor Sam Vegeta that the our emergency response team went out to PXF LA after
2130 hours on 1/10/06 in response to a substance release from a cal well. I contacted Pat Gorski (323-298-2441), Ell&S
Advisor for PXP LA, to gather more information. According to Mr. Gorski, dining the late evening of 1/10/06, a rig drilling
for PXP in the Inglewood Oil Field experienced an influx of natural gas during drilling operations. An unknown amout of
methane gas and hydrogen sulfide was released into the atmosphere. Also, the prevailing winds carried the odor from the
location towards the ocean. According to Mr. Gorski, the concentrations of gas on and leaving location were confirmed to
neither be flammable nor hazardous. Also, representatives from Los Angeles County Fire Deparhnent, Culver
City Fire
Department and Los Angeles County Health and Hazardous Materials Department have been =site to confirm there were no
hazards posed to the community.
After gathering the information, I contacted each of the complainants to inform them of my findings. Also, I asked each of than
as continue to call AQ/vID's complaint number whenever they notice any odors.
INSPECTOR:
DATE:
SUPERVISOR: DATE:
signature
DispnininnCULVER CITY FIRE DEPARTMENT
INCIDENT REPORT
Universe:None Population:None Repeat Set:None
1CIDENT 10#
20060118
4CIDENT DATE
01111/2006
DATE REPORT ENTERED
01/11/2006
RECORD COMPLETE
DISPATCH TIME
02;16:42
ROLLOUT TIME
02:16:53
ARRIVAL TIME
02:17:14
RESPONSE (IN MIN)
0
CODES RESPONSE
JURISDICTIONAL STATION
33
SH1FT
A
REPORTED BY
SYVERSON
SYVERSON
UNITS ON SCENE
B1
SITUATION FOUND
200 Overpressure rupture. explosion. overheat, other
410 Flammable gas or liquid condition, other
MUTUAL AID
N None or no mutual ald involved
MET)-10D OF ALARM
01 Telephone
ADDRESS/LOCATION
10640 YOUNGSWORTH RD
ZIP CODE
90230
NUMBER OF PERSONNEL
ENGINES USED
0
OTHER VEHICLES USED
SPECIFIC PROPERTY USE
ACTION TAKEN
AREA OF FIRE ORIGIN
• EVEL OF FIRE ORIGIN
ORM OF HEAT
jGNITION FACTOR
MATERIAL TYPE
MATERIAL FORM
1GNMON FACTOR
EXTINGUISHMENT METHOD
TOTAL DOLLAR LOSS
NUMBER OF STORIES
FLAME DAMAGE
SMOKE DAMAGE
TYPE CAUSING MOST SMOKE
TYPE CAUSING MOST SMOKE
AVENUE OF SMOKE TRAVEL
DETECTOR PERFORMANCE
SPRINKLER PERFORMANCE
OCCUPANT LAST
FIRST
ADDRESS
10640 YOUNGSWORTH
PHONE
RESPONS1NBLE PARTY
ADDRESS
10640 YOUNGSWORTH RD
PHONE
EQUIPMENT INVOLVED
NNN No equipment Involved in Ignition
RIC NARRATIVE
THERE WAS NO RIC NEEDED FOR THIS CALL
INCIDENT NARRATIVE 81 responded to an odor investigation in the area of Culver Crest. Units had been In the area earlier for a
Possible natural gas leak. At that time there was a slight mei of a petroleum-type odor corning from the
area of the oil production fields. E3 and R3 had also been dispatched to a resident who complained or a
headache and burning eyes - possibly as a result of the small 81 arrived to the area to discover that the
amen from earlier had increased In Intensity and area. 81 conlacted LA County Health Haz Mat. Yoshiaki
Ishlmaru and Karen emitting arrived. 81 also contacted LA County Fire and asked for an engine company
to meet at the Command Post. Culver City notified 81 that they were receiving a high volume of calls forthis Odor. Engine 58 arrived on scene ( Captain Dean Rivera). LA County and el proceeded on to the oil
field, Plains Exploration Production (PXP). Upon arrival we were met by the production operator, Al
Deacon. We informed him that we had received multiple calls fore strong odor in the Culver Crest area
and Inquired if them were any operations that were ongoing that might be the cause of be smell. He
escorted us to rig # 1 .195 (Vickers). We were met there by the job consultant, Craig Cody and ProdUction
Foreman Jim Galvin. They indicated that there had been a problem on the rig. They had apparently hit a
pocket of methane which in turn caused a large volume of 'mud" (400 barrels) to come to the surface.
Cody stated that they had been monitoring for LEL' and H2S and no alarms had sounded throughout the
Incident that occurred at approximately 2131 We were then met at the site by the Operations Manager, IA
Basin, Gerry Cates. Ha confirmed that there had been a release and that they were in the process of
pumping out the mud, The well was shut down and in control and had been since shortly after the incident
occurred. LA County Health Haz Mat monitored the area and had no readings for LEI. or I-12S using three
different monitors. AOMD (Mohan), State OES (Control 006-0270), and National Response Canter
(0784-841, Miss Johnson) were notified. B1 contacted Culver City to have them Inform residents who
called that the smell was not harmful and according to Health Haz Mat could be characterized as a
"nuisance only at the lima. Gales Informed 81 that they would be performing additional procedures to
'circulate" the gasses that were building In the welt This operation would start around 0700 and commence
around 1100 houre on 1-11-06. They would be conducting routine analysis of the gas LEL levels throughout
that process. He added that there were an additional 50-100 barrels of mud that was still in the well that
would have to be pumped out and disposed of. All mud that was collected would be moved to sealed
containers to reduce odors. It was the opinion of the PXP and Hoz Mat officials that the cause for the smell
was not the gas release but rather the mud on the ground in and around the well area. LA County Fire, Has
Met and Culver City Battalion One cleared. Culver City and LA County Engine 58 will return to the site at
approximately 0900 to monitor prowess.
Culver City Inc if 20080118
ACIMD 951-830-8938
LACci Fire Inc 8221
Yoshiaki ishimaru 323-690-4093 Cell it 213-200-4057
Karen Codding 323-890-4112
Gerry Calea 323-298-2226
Jim Galvin 323-298-22138
Plains Exploration and Production 323-298-2200
Plains Exploration and Production Emergency #323-855-3203
Captain Dean Rivera, Engine 58, 323-291-8392, 323-881-2455
/LiEMERGENCY RESPONSE SUMMARY
DATE: January 11, 2006
INCIDENT: • Emergency Response Notification 4121860
Methane and H2S release at an Oil Well Drilling Site in Culver
City.
LOCATION: Plains Exploration and Production Co. (I D # 133987)
5640 Fairfax Ave.,
Culver City, CA 90056
Thomas Guide 673 A4
REQUESTOR: State OES notified and LA Co. Fir Dept. Health Haz. Mat.
AQ1vID STAFF: Mohan Nagavedu, ER Coordinator (x3739)
Sam Vergara, Field Supervisor (x.2318)
Larry Israel, ER Inspector
ACT/ON: Supervising AQ Inspector SamVergers and AQ Inspector Larry
Israel were dispatched to respond to the incident and handle any
complaints, render aid to L.A. Co. Health Haanat, and take
enforcement action as necessary.
One sample collected — SUMA canister on La Cienega north of
Stocker.
ADDMONAL: While drilling at about 8800 ft they hit a large pocket of methane.
Appox. Several hundred barrels of contaminated drilling mud and
water was collected in a sump. Facility has shut down the drilling
end started to pump the contaminated water and mud. Four
compinintx received by District: C-181387and 181389 was
received on 1/10/05 around 2250 hrs.and C 181392 and 181393
were received this morning. Refinery Inspector Joseph Liaw to
follow up on the complaints.
/5-0PONCE 1f2CCEI 08:0111D0
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Air Quality Notification Report
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SUDS FAIRFAX AVE. Unit 4011411, LOS ANGELES, CA 40D.66
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13987 PLAINS EXPLORATION & mocucrica co, LP
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btspectar Quantrit
INSPECOA:
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BUPER.VESCIR:
DATE:
DAT&
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Service* Branch
(909)396-2391 -
"SOU.I.kt COAST AIR QUALITY MANAGEMENT DISTRICT.
21865 Copley Dr., Diamond Bar, CA 91165-4182
MONITORING AND ANALYSIS
REPORT OF LABORATORY ANALYSIS
Page 1 of 3
TO: Jay CUD. Sr. Menager
-
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Toxic
RrirERENCE NO: PAMSGC2
SAMTIX DESCRTPTION: FACELTTY kith Ono each canister
OTHER
JUTE SAMPLiD: 01/11/06
SAMPLE SOURCE:
DATE RECEIVXD: - 01/11106
Emergeocy Response
Phthm Exploraiion Production
DATE ANA.LYZEZP: 1/11-13/06 .
SUBMITTED BY:
Lanmsncilsrael
ANALYTICAL WORK PERFORMED, METHOD 07 ANALYSIS AND RESULTS
.1 . nil. : • f-
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•
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Date Approvcd: "AC ApprOvcd By:
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Lit 06011-01
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kl Atribtant %IOC* a Micypeoapy. O PitmcidAkii12008 Tadarkral keportalEramperney Rawasas:Ptaisis eeplarattaa Productlati.120001141.4fiLAURANCE ISRAEL . Date: VI 1106
Office: - Compliance Budget #: . 50-.J75
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Approver/ by:
REASON • • UESTED:
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X DISTRICT 126rFORMATION
SCFUTS COAST AIR QUALITY MANAGEKENT DISTRICT
INVOICE sot.TACM
SAMPLE ANALYSIS REQUEST
LABORATORY NO. TO: SCAQMD LAB: X OTHER: El SOURCE NAME: FLAMM EXPLORATION PRODUCTION No. Sources Address: 5640 FAIRFAX AVE Y1Y: INGLEWOOD
Mailing Addresm: SANE AS ABOVE City , Zip: •
Contact Pars6rt::
JbEN BARKER Ti:de: SAFETY SPECIAL/ST. Tel: .1110.5 8968443`
Stollpla CO/locoed by r_ SAM VER:GARA Date: 1/11/06 • Time: 06:01 bra
. or, Cteee_s*- 2plo a
SAMPLE #1: 6 `11=it canister # .54149 aralliatert air sample at interaection of Stocker Ave anti/C=6th
Halm Park.
•
Analysis Rt!quegted: - Percenta,gn of Hydrocarbon/ and Non•hydt °carbons. MdrIlltoc aud.--920Peunda,-
m .' in= •”.• 1 ••• • • .4: •+ • . 1 1 211111 4
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.Reanazkez Please expedite estitag,ency response sample ind notify Jay Chen, ST. Maxiagex, Toxic.South Coast Air Quality Management District
Air Quality Complaint Report
Complaint 181853
Receive By: AKIM on 2/512006 00:30:19 Assigninent Na: 922762
Assign By: madams on 22006 10:58:06 Inspector. JOHN LEVY (JL01)
Dispatch On: W/2006 Instruction: Imrestlgate odor complaint
Team: C
Type: ODORS
Description: Chemical odor. (Pis contact).
Instance Start Date: instance End Date:
Complainant
First Name:
Address:
Phone:
Last Name:
Alfeud Source
Name: OIL DRILLING
Address: UNK, BALDWIN HILLS, CA 90056 (Sector LF)
Art-oal Source
Name:
Address:
DISPDS4tt011
SUNK on 2/10/2006 13:33:07
Inapector Comment On February 7, 2006, I received this complaint assignment for an incident that was reported to the District hotline on February
6. I spoke by phone to the complainant on February 8, at 16:35 hours. ,told that she has lived in her home for
seven years, and has never experienced odors as strong as those she has recently noticed at her home during the past month.
The odors, which she described as "strong gaseous type", have been present about three times during the past month She told
roe that she could not smell anything at the time of our conversation, but the odors were extremely strong on Feb. 6. I informed
her that the fire department and the District have received numerous complaints over the past few weeks from residents in and
around her neighborhood, and that it appears that the source may have been drilling activities being conducted at the oil
production facility operated by PXP in Culver City. Inspector Joseph Liaw is currently in the process of gathering data for a
possible public nuisance violation against PXP.
DATE: INSPECTOR: .
signet=
SUPERVISOR
DATE:
signature
[5-6South Coast Air Quality Management District
Air Quality Complaint Report
Complaint 181920
Receive By GRACEN on 2)7/2096 21:26:00 Assignment No: 923048
Assign By mohann on 202008 07:47:47 inspector: JOSEPH L1AW (JL05)
Dispatch On: 21712008 Instruction:
Teem: C
Type: ODORS
Description: METHANE GAS ODOR
Instance Start Date:
ktstance End Date:
Complainant
Fest Name:
Address:
Phone:
Last Norm:
Name. UNKN
Addreea: UNKN, CULVER CITY, CA 90230 (Sector LF)
Name: PLAINS EXPLORATION & PRODUCTION CO, LP ID: / 33987
Address: 5640 S FAIRFAX AVE. LOS ANGELES, CA 90056 (Sector LF)
Diaposifinrt
NV on 2121/200614:05:48
-
Inspertor_Cornnonnt
Complaint nos. 181919 - 181924, 181927, 181944, 181958
On 217/06, at 2250 hours, I arrived at the , which is the home of the complainant,
• While waiting outside the home, I detected a noticeable crude oil odor. I met with to disco's the nature of
the complaint She informed me that she has noticed a crude oil odor since Monday, 2/6/06. Also, the odor has been especially
bad during the evening I met With her. After briefly discussing the nature of the odor, asked if she could have a
neighbor come by and join the conversation. The neighbor, had also called in a complaint (#181922)
regarding the same odor nuisance stated that it was a crude oil odor. I informed them that I was also detecting the
odor that they described. Alter this, I explained AQMD Rule 402 regarding public nuisance to them: I informed them that I
would need to verify that the source of the odor before any enforcement actions could be taken. A.fter our discussion, 1
informed them that I would contact them with my tiodings and left at 2333 horns.
After leaving the complainant's home, I started driving along Flaxton St. to the northeast corner of the neighborhood. I was able
to detect a stronger crude oil odor the closer I drove to Plains Exploration and Production Company ("PXP"). PXP (F/D#
133987) is located on 56408. Fairfax Ave. in Los Angeles. The facility is located northeast from the complainants home. •
Since it was close to midnight during my surveillance, it was difficult to and the fence line for the PXP oil field. Therefore, I
was only able to drive to the corner of Flaxton St-, and Youngwordi Rd., which is the northeast corner of the neighborhood.
After this, I left the area and headed to PXP.
At 2350 hours, I entered PXP and met with Al Deacon (323-8553203), Production Operator, to discuss the odor complaints.
When asked if there were any active drilling, Mr. Deacon pointed out that there were three drilling rigs in operation. We drove
around to each of the three, and I was able to detect odors at each location. When we drove to the third location, I was able to
detect a very strong crude oil odor. The well site is identified by PXP as Vickers VIC2-1234. From this well locating, I was
able to scc West Los Angeles College. Based on my observation, the College is located only a few hundred yards southwest of
the well. In regards to , West IA College is just north of her. Mr. Deacon and dapped at the site and met
with Jason Crawford (661-201-9014), Drilling Foreman, to discuss the odor. Mr. Crawford informed me that the strong crude
oil odor is coming from the two shakers. Basically, when drilling fluid is pumped down the bore, the fluid pushed product back
up to the surface. However, the liquid that comes back up contains gas from the formation. For this particular well, the
• formation starts at 6512 feet and bottoms out at 9357 feet. After they completed drilling, the next process is called the logging
operation, which lasted for 36 hours in this case. This is the proms necessary to gather information about the well and the
formation_ During this process, drilling fluid re-circulates continuously down the hole. According to Mr. Crawford, once the
drilling fluid gets down to the depth of the formation, gas gets elarenclaed in the fluid. Once the fluid gets back to the surface, it
is directed to either of the two shakers, which is an open pit that shakes the liquid to separate the drilling mud from the gas. As
INSPECTORl
DATE:
signaler
SUPERVISOR: DATE:
signature
/57South Coast Air Quality Management District
Air Quality Complaint Report
a result; the gas is released to the atmosphere. Mr. Crawford stated that the odor Can be very strong during this process. Also,
he does not know of any device or operation in which the emissions from the shakers are not open to the atmosphere.
From 2/8 to 2/15/06,1 met with several complainants who also experienced the odor nuisance in the evening of 2/7/06. In
addition, several complainants relaxed additional neighbors who experienced the odor. In total, I was able to get 12 witnesses
to fill out a public neicance corozdaint form.
On 2/17/06, at 1015 hours, I returned to PXP and met with Carartnev Salway (323-298-2266), Environmental & Regulatory
Compliance Supervisor, and Patrick Gorski (323-298-2291), EH&S Adviser, to discuss the incident. Ms. Salway and Mr.
Gorski explained the process of logging operation and the necessity to perform the process. Among the information gathered
during this operation is the potential production of the particular well as well as information about the formation. In addition,
they reiterated that they do not know of any practice that can eliminate the emissions from the process. However, they have
already begun to research on ways to eliminate this odor problem in the /inure. Also, during our meeting, / got a better timeline
of the incident. The logging operation started armed 0600 hours on 217/06. During the logging operation, information is
gathered from the surface and continues down until the bottom of the formation. According to the operation logs, the logging
operation reached 7,000 feet below the surface wound 2000- 2100 hours the same day. During this lime, the drilling liquid is
in the zone of the formation_ Therefore, this is the time in the operation that is referred to as "bottoms up" byPXP operators.
During this time, gas and other products are pumped bad up to the surface along with the drilling fluid. Therefore, this is the
time when the odors would be the strongest. The logging operation then concluded at around 0230 hours on 2/8106. After
removing the logging equipments, the well is completed by installing the casing pipes and cementing the hole. This process
lasts for roughly 12 hours. According to Ms. Salway and Mr. Gorski, there normally is not a strong odor during this process. I
explained to Ms. Solway and Mr. Gorski that there were many complaints in the neighborhood of a strong crude oil smell during
the time when the facility was performing "bottoms up". In addition, I was able to verify the odors coming from the drilling
operations during the "bottoms up" time period. Therefore, I informed Ms. Saway and Mr. Gorski that PXP is in violation of
Ride 402 for causing a public nuisance. I issued NOV P37137 to Plains Exploration & Production Company and personally
issued the notice to Candace Salway, Environmental & Regulatory Compliance Supervisor.
INSPECTOR:
sipianee
SUPERVISOR:
sigma=
DATE:
DATE:
/5TCULVER CITY FIRE DEPARTMENT
INCIDENT REPORT
Universe: NONE Population: NONE Repeat Si: a NONE
INCIDENT ID#
INCIDENT DATE
DATE REPORT ENTERED
RECORD COMPLETE
DISPATCH TIME
ROLLOUT TIME
ARRIVAL TIME
RESPONSE (IN MIN)
CODE 3 RESPONSE
JURISDICTIONAL STATION
SHIFT
REPORTED BY
UNITS ON SCENE
SITUATION FOUND
MUTUAL AID
METHOD OF ALARM
ADDRESSLOCATION
ZIP CODE
NUMBER OF PERSONNEL
ENGINES USED
OTHER VEHICLES USED
SPECIFIC PROPERTY USE
ACTION TAKEN
AREA OF FIRE ORIGIN
LEVEL OF FIRE ORIGIN
FORM OF HEAT
IGNMON FACTOR
MATERIAL TYPE
MATERIAL FORM
IGNITION FACTOR
EXTINGUISHMENT METHOD
TOTAL DOLLAR LOSS
NUMBER OF STORIES
FLAME DAMAGE
SMOKE DAMAGE
TYPE CAUSING MOST SMOKE
TYPE CAUSING MOST SMOKE
AVENUE OF SMOKE TRAVEL
DETECTOR PERFORMANCE
SPRINKLER PERFORMANCE
OCCUPANT LAST
FIRST
ADDRESS
PHONE
RESPONSINBLE PARTY
ADDRESS
PHONE
EQUIPMENT INVOLVED
RIC NARRATIVE
INCIDENT NARRATIVE
20081016
0312212008
03/25/2008
08:08:55
08:10:4-4
08:14:12|1010|11
OELAPUENTE
WHITE
El
131
R1
413 Oil or other combustible li q uid spill
N None or no mutual aid involved
9800 JEFFERSON BL
90232|101010|43 Hazardous materials spill control and confinement
41 Identify. analyze hazardous materials
9800 JEFFERSON BL
310558E1838
9800 JEFFERSON BL
Ric NOT NEEDED
El notes:
El WAS DISPATCHED TO A HAZ MAT INVESTIGATION ABOVE THE DOG PARK AT CULVER CITY
PARK. ON OUR ARRIVAL WE FOUND CRUDE OIL RUNNING OUT OF THE PXP OIL FIELD, El
REQUESTED B1 ADVISING AN UNKNOWN QUANTITY OF THE PRODUCT HAD MADE ITS WAY INTO
/THE STORM DRAIN SYSTEM. El CONSTRUCTED AN EARTHEN DAM TO STOP THE FLOW INTO
THE STORM DRAIN. WE ALSO GAINED ACCESS TO THE OIL FIELD IDENTIFIED THE PIPE LEAKING
AND A RATE OF RELEASE. THE LEAK WAS FLOWING AT A RATE OF APPROXIMATELY .5
GALLONS /MIN. B1 ARRIVED AND ASSUMED COMMAND AT 0830. R1 WAS DISPATCHED TO LA
SALLONA CREEK TO ASSESS THE EXTENT OF THE RELEASE. NO PRODUCT HAD REACHED THB
CREEK, PXP PERSONNEL ARRIVED ON SCENE AND SHUT DOWN THE WELL SUPPLYING THE
LEAKING PIPE. El CREW REMAINED ON SCENE AND ASSISTED PXP WITH DYKING THE
PRODUCT. PXP CREWS BEGAN CLEAN UP, El CLEARED.
61 notes:
B1 dispa-.ched to Culver City Park bra confirmed (E11 release of crude oil from a well owned by Plains
Exploration & Production Company (PXP). Upon arrival established command, appointed a safety officer.
developed a Wrill19 n incident action elan, site safety plan, and made the proper notifications. The release of
product was stopped at a pproximately the time B1 arrived onscene. R determined that no product had
reached La Ballena Creek and this was confirmed later by LA County Flood Contioli personnel.
Clean up was alerted by PXP persorthel and upon the arrival of a private contractor, Ancom Marine, a full
scale clean up was conducted, the stem' drain system was cleaned by Ancom under the supervision of LA
County Fined Centre and Culuer City Public Works personnel.
Notifications: La County Health Haz Mat, DES Wamig Center (inc# 08-2244 and the National Response
Center (Inc# 865747), City Coucil was notified via the Fire Chief. Other comunications included the Coast
Gaurd, State Dept of Fish & Game.
LA County Health Haz Mat personnel were onscene along wket State Depaerneril of Oil & Gas.
Timeline
0808 initial displach
0828 B1 onscene & assumed comma mid
ma Release stopped
0915 Notifications canple:e
0948 Full scale clean up begthe by contractor - Ancom Marine
1143 Command turned over to Culver City Public Works|10 13|