City of Culver City, California
City Council Agenda Item Report
1
RECOMMENDATION:
Staff recommends the City Council:
1. Approve a professional services agreement with Aspen Environmental (Aspen)
in an amount not to exceed $148,770 to assist the City with review and response
to the Draft Environmental Impact Report (Draft EIR) prepared by the County of
Los Angeles for the establishment of the Baldwin Hills Community Standards
District (CSD) for the Inglewood Oil Field, and Assist the City with Review and
Revisions to the City’s current oil well regulations and oil drilling permit
application submittal requirements; and
2. Approve a budget amendment in the amount of $148,770 from General Fund
unappropriated reserves to fund this agreement.
A Budget Amendment requires a 4/5 vote.
BACKGROUND:
The County of Los Angeles is proposing to implement a CSD in the Baldwin Hills
area that will update the zoning regulations as they relate to oil and gas production
activities in the Inglewood Oil Field. The CSD will establish permanent development
standards, operating requirements, and procedures for oil and gas operations. The
CSD application was submitted by Plains Exploration and Production Company
(PXP).
Meeting Date: 06/23/08 Item Number: A-3
AGENDA ITEM: (1) Approval of a Professional Services Agreement with Aspen
Environmental Group or AMEC to Assist the City in Review and Response to the
Draft Environmental Impact Report Prepared by the County of Los Angeles for the
Establishment of the Baldwin Hills Community Standards District Relating to the
Inglewood Oil Field, and Assist the City with Review and Revisions to the City’s
Current Oil Well Regulations and Oil Drilling Permit Application Submittal
Requirements; and (2) Approval of a Related Budget Amendment.
Contact Person/Dept.: Sherry Jordan /
CDD
Phone Number: (310) 253-5746
Fiscal Impact: Yes [X] No [] General Fund: Yes [X] No []
Public Hearing: [] Action Item: [X] Attachments: [X]
Public Notification: Aspen and AMEC (6/12/08); Master Notification List (6/18/08).
Department Approval:
Sol Blumenfeld (06/19/08)
City Attorney Approval:
Carol Schwab (by H. Baker) (06/19/08)
Fiscal Impact Review Approval:
Jeff Muir (by M. Noller) (06/19/08)
City Manager Approval:
Jerry Fulwood (06/19/08) City of Culver City, California
City Council Agenda Item Report
2
In June of 2007, the County of Los Angeles issued a Notice of Preparation for a
Draft EIR that would assess the potential environmental impacts associated with the
establishment of the Baldwin Hills CSD. The Draft EIR would evaluate the
environmental impacts associated with the future oil and gas production activities
over the next 10 to 20 years. On July 31, 2007, following City Council input, staff
submitted comments on the content and scope of the proposed scope of the Draft
EIR.
The Draft EIR was released on June 19, 2008 and the 60 day review and comment
period will end on August 19th.
DISCUSSION:
Because of the technical nature and the expected large volume of information that
will be need to be reviewed within a relatively short time frame, staff requests the
assistance of a consultant with expertise in analyzing the complex environmental
issues that arise with oil and gas production. The consultant will assist the City in
commenting on the proposed CSD and the Draft EIR. In addition, staff has
requested the consultant assist the City with review and revisions to the City’s
current oil well regulations and oil drilling permit application submittal requirements.
Staff received the following two proposals from qualified firms for this project
(Attachments 1 and 2):
Consulting Firms Proposed
Budget
1. Aspen Environmental
Group,
$148,770
2. AMEC, Earth and
Environmental, Inc. (AMEC)
$103,573
The proposals were reviewed by Public Works, City Attorney, and Community
Development staff and both firms were interviewed. Staff followed up with checking
on references where we inquired about the nature of the assignment, performance
of the consultant, whether the consultant successfully completed the job, and
whether they would hire the consultant again.
Both consultants demonstrated through their submittals and interviews they were
qualified to conduct the third-party review of the County’s Draft EIR on behalf of the
City. The selection criteria staff examined included:
• Scope of Work, Price
• Direct Experience, Staffing City of Culver City, California
City Council Agenda Item Report
3
• Written Proposal Submitted
• Evaluation of Potential Conflicts of Interest
• In Person Interview
• Reference Check.
With regard to most categories the two were determined very similar with the
exception of price and potential conflicts of interest.
The Council Subcommittee expressed specific concerns related to potential conflict
of interest issues with the applicant for the CSD, PXP, and requested staff evaluate
any potential conflicts and check each consultant’s references. Based upon the
Subcommittee’s direction, staff contacted all of the references submitted by the
consultants. In addition, staff requested disclosure statement from each of the
consultants for any current or prior direct client relationship with PXP (Attachment 3).
With regard to the references, both firms received very favorable comments.
However, with regard to the conflict issue, Aspen has stated unequivocally that it has
no current or prior direct relationship with PXP; whereas, AMEC has indicated that
PXP was a direct client as recently as January 2007. It should be noted Aspen has
been hired by the County of Santa Barbara to prepare the environmental review on a
PXP project. Aspen currently remains under contract to the County to provide
support on the environmental review of that project through the remainder of the
decision making process.
Although AMEC has provided the City with assurances that it can construct
whatever “firewalls” are necessary to ensure objectivity and avoidance of real or
perceived conflicts, staff feels that it is essential there not be any potential for
concern by the community in this regard. Therefore staff is recommending the
Council award the contract to Aspen.
Meeting Schedule
July 7 City Council meeting for discussion and early community input
July 17 County EIR workshop
July 22 County EIR workshop
Aug. 2 County Regional Planning Commission public hearing
Aug. 11 City Council reviews proposed comments
Aug. 19 Comment period ends and final comments are submitted to County
Aug. 27 County Regional Planning Commission public hearing
*City staff’s review scheduled is included as Attachment 4 for Council’s reference.
City of Culver City, California
City Council Agenda Item Report
4
FISCAL ANALYSIS:
Aspen has offered its services at $148,770 (including a 15% contingency). This fee
includes review of the Draft EIR and CSD standards and preparation of comments,
review and revisions to the City’s current oil well regulations and oil drilling permit
application submittal requirements, and additional services for technical experts. A
budget amendment for $148,770 from General Fund unappropriated reserves is
needed to fund this contract (10152100.619800). There are sufficient available
funds within the General Fund reserve to cover this request. A 4/5ths vote is
required for a budget amendment.
ATTACHMENTS:
1. Aspen proposal
2. AMEC proposal
3. Disclosure statements
4. City staff review schedule
MOTION:
That the City Council:
1. Approve a budget amendment to increase the Planning Division’s Other
Contractual Services account (10152100.619800) by $148,770 from General
Fund unappropriated reserves;
A Budget Amendment requires a 4/5ths vote.
2. Approve a Professional Services Agreement with Aspen to assist the City with its
review and response to the Draft EIR prepared by the County of Los Angeles for
the establishment of the Baldwin Hills CSD for the Inglewood Oil Field and assist
City staff with review and revisions to the City’s current oil well regulations and oil
drilling permit application submittal requirements, for an amount not to exceed
$148,770; and
3. Authorize the City Attorney to prepare the necessary documents and authorize
the City Manager to execute such documents on behalf of the City.
06/23/2008
(1) Approval of a Professional Services Agreement with Aspen
Environmental Group or AMEC to Assist the City in Review and
Response to the Draft Environmental Impact Report Prepared by
the County of Los Angeles for the Establishment of the Baldwin
Hills Community Standards District Relating to the Inglewood Oil
Field, and Assist the City with Review and Revisions to the City's
Current Oil Well Regulations; and (2) Approval of a Related
Budget Amendment.
MEETING DATE:
AGENDA ITEM:
ATTACHMENTS
Pages
1. Aspen proposal
1-13
2. AMEC proposal
14-21
3. Disclosure statements
22-24
4. City staff review schedule
25Aspen
Arummuntental Group
30423 Canwuud Stroot, Suite 215, Agoura Bills, CA 9130i-4316
Tei. 318-597-3407, Fax. 818-597-8001, ImwAspeuEG,.com
May 21, 2008
Susan Yun
Senior Planner
City of Culver City
9770 Culver Boulevard
Culver City, CA 90232
Subject: Proposal to Provide CEQA Review Services for the Proposed Baldwin Hills Community
Standards District
Dear Ms. Yun,
Aspen Environmental Group (Aspen) is pleased to submit this proposal to assist the City of Culver City in
reviewing and commenting on the Draft Environmental Impact Report (EIR) for the proposed Baldwin
Hills Community Standards District. Our proposal is based on information provided by the City and a
review of information available on line from Los Angeles County. If our proposed scope of services,
schedule, or budget do not meet the City's expectations, we would be happy to review our proposal with
City staff and make necessary revisions in order to ensure that we satisfy the City's needs.
The proposal presented herein is organized into the following sections:
1. Project Understanding
2. Overview of Aspen Environmental Group
3. Qualifications and Experience
4. Project Management and Key Personnel
5. Technical Approach
6. Schedule
7. Proposed Budget
1. Project Understanding
The City of Culver City is seeking the services of an environmental consulting firm that has knowledge of
CEQA and oil/gas projects to review the Draft EIR being prepared by Los Angeles County for the
establishment of a Community Standards District (CSD) for the Baldwin Hills Oil Field. The EIR will
evaluate existing and future oil operations in the Baldwin Hills and will help determine what additional
development standards and regulations should be included in the CSD to mitigate the impacts of drilling
on the surrounding communities. The consultant selected by the City will review the Draft EIR for
Agoura Hills San Francisco Sacramento Phoenix San DiegoMs. Susan Yun
May 21, 2008
Page 2
technical accuracy and CEQA adequacy, and will the results of the EIR review will be provided to City as
comments suitable for submission to Los Angeles County. As part of this review, the consultant will also
evaluate the regulations and standards proposed for the CSD for their feasibility, practicality, and
effectiveness in reducing impacts and addressing community concerns.
Plains Exploration and Production Company (PXP), the operator of the Inglewood Hills Oil Field (also
known as the Baldwin Hills Oil Field), has submitted an application to the County of Los Angeles to
establish a CSD for the portion of the Inglewood Oil Field located in the Baldwin Hills Zoned District in
unincorporated Los Angeles County. The CSD is a supplemental district established to address problems
that are unique to specific geographic areas within unincorporated areas. The Baldwin Hills CSD will
define the boundary of the oil field and establish permanent standards for oil field development. These
development standards are intended to address land use compatibility issues associated with the operation
of an active oil field in close proximity to urban development.
2. Overview of Aspen Environmental Group
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 is headquartered in Agoura Hills and also has offices in Sacramento,
San Francisco, San Diego, and Phoenix. Aspen was founded in 1990 and incorporated in 1991, and
continues to grow as an expert interdisciplinary environmental and engineering services firm, specializing
in the management of environmental assessment efforts under CEQA and NEPA for infrastructure and
public works projects. Aspen also provides a variety of technical services related to environmental
assessment, planning, and regulatory compliance. Aspen's staff is comprised of a broad cross-section of
experienced professionals in engineering and the physical, earth, life, and social sciences.
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, California Department of Water Resources, Los Angeles Unified School District, 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 in the CEQA evaluation of petroleum projects.
Aspen has extensive experience in conducting environmental review of projects in accordance with both
CEQA and NEPA on behalf of government agencies. We regularly serve in the role of prime contractor
to state and federal agencies for CEQA/NEPA projects and routinely manage a team of specialists for
purpose of conducting detailed and comprehensive environmental impact analyses for a wide range of
projects. As needed, Aspen's project management and CEQA/NEPA experience is complemented by the
expertise and experience of specialized subcontractors with appropriate capabilities in data collection and
analyses for environmental impact assessment documents and supporting environmental documentation,
including permit documentation for compliance with the entire range of state and federal environmental
regulations.
Aspen has consistently demonstrated the capability to produce the full range of environmental studies,
reports, and supporting permit documentation that may be required as part of the CEQA and NEPA
review processes. Aspen has been involved in many highly visible and controversial projects, involving
extensive public participation programs and the involvement of numerous local, state, and federal
agencies. This work has been performed almost exclusively under contract to government agencies,
allowing Aspen to provide services to our government clients with almost no possibility of a real or
perceived conflict of interest.
2Ms. Susan Yun
May 21, 2008
Page 3
3. Qualifications and Experience
3.1 Experience Preparing CEQA Documents
Aspen's CEQA expertise and experience has been gained over many years and includes the ail range of
CEQA-compliance functions. Aspen has conducted CEQA review for many types of infrastructure, public
works, and industrial projects for local, state, and federal clients, including all of the following types of
CEQA activities:
• Preparation of Initial Studies, Negative Declarations, Mitigated Negative Declarations, and Draft and Final
EIRs;
• Preparation and distribution of required notices, including Notices of Preparation, Notices of Completion,
and Notices of Determination;
• Preparation of project descriptions and formulation of feasible alternatives;
• Field studies and research;
• Engineering evaluation of projects to determine specific impact parameters;
• Feasibility studies of alternatives and mitigation measures;
• Mitigation measure development, evaluation, implementation, and mitigation monitoring; and
• Public participation, including website creation and maintenance, notices for mail and media, public
workshops and hearings, fact sheets and brochures, graphic displays, and non-English language materials_
Aspen's CEQA projects have been located across the entire State of California, from urban areas with
concerns related to traffic, noise, and enviromnental justice, to rural and wilderness areas where
biological resources, recreation, and scenic vistas were the primary concerns. In each of our completed
projects, we demonstrated our ability to perform the following critical functions:
• Evaluation and analysis of project alternatives, cumulative impacts, and growth-inducing effects;
• Comprehensive analyses of all relevant environmental issues;
Production of high-quality environmental documents synthesizing and editing information developed by
technical specialists;
• Support to the Lead Agency in CEQA compliance and public participation; and
• Management of technical specialists from within Aspen and from subcontractor teams_
Exhibit 1 presents examples of infrastructure projects throughout the State for which Aspen has prepared
CEQA documents. The successful completion of these projects demonstrates the wide range of Aspen's
management and technical skills. All of the projects involved complex technical and controversial issues,
management of specialty subcontractors, public participation programs, and completion of high-quality
documents on schedule and within budget.
Exhibit 1. Aspen's Selected CEQA Experience
Transmission Lines
• Tehachapi Renewable Transmission Project EIR/EIS
• Devers-Palo Verde No. 2 Transmission Project EIR/EIS
• Antelope-Pardee 500-kV Transmission Project EIRIEIS
• Antelope Segments 2 and 3 Transmission Project EIR
• Sunrise Powerlink FIR/EIS
• Talega-EscondidoNalley-Serrano Interconnect Project EIR
• Miguel-Mission 230 kV #2 Project EIR
• Jefferson-Martin 230 kV Transmission Project EIR
• Tr-Valley Capacity Increase Project DR
• Los Banos-Gates 500 kV Transmission Project SEIR
• El Casco System Project DR
• Delta Substation Mitigated Negative Declaration
• Banning Substation and Subtransmission Line Project MND
• Viejo System Project
• Rocklin Upgrade (Atlantic-Del Mar) Project MND
• Paradise Area Reinforcement Project Negative Declaration
• Valley-Auld Transmission Line MND
• Six Flags Power Line and Substation MND
• Alturas Transmission Line EIR/EIS
• NE San Jose Transmission Reinforcement Project FIR
3• Aspen has prepared CEQA analyses for power plants and their
associated natural gas pipelines and transmission lines
throughout the State for approximately:
- 50 power plants (gas-fired, solar, and geothermal)
- 3 peaker power plants
• Lompoc Wind Energy Facility EIR
• Diablo Canyon Power Plant Steam Generator Replacement
Project EIR
• San Onofre Nuclear Generating Station Steam Generator
Replacement Project EIR
• PG&E Divestiture of Hydroelectric Assets EIR
• Liberty XXIII Renewable Energy Power Plant Project EIR
• Alta Windpower Development EIR
• LADWP River Supply Conduit (Lower Reach) EIR
• LADWP River Supply Conduit (Upper Reach) EIR
• LADWP Harbor Refineries Project
• Littlerock Reservoir Sediment Removal Project EIR/EIS
• DWR Tehachapi East Afterbay Project EIR
• Lake Canyon Detention Basin EIR
• Simulation of Natural Flows on Middle Piru Creek EIR
• DWR Piru Creek Erosion Repairs IS/MND
• Bolsa Chica Water Transmission Line Project SEIR
• Whitewater River Basin (Thousand Palms) Flood Control
Project EIS/EIR
• Prado Basin, Reach 9, and Norco Bluffs SEIS/EIR
• Supplemental EAs (5) for Los Angeles County Drainage Area
Improvement Project
• San Luis Rey River Flood Control Project Operation and
Maintenance SEIS/EIR
• Las Virgenes Municipal Water District, Calabasas Water
Transmission Line MND
• PXP TranquilIon Ridge Oil & Gas Development Project EIR
• Kirby Hills Natural Gas Storage Facility Mitigated Negative
Declaration
• Port of Los Angeles Channel Deepening Project EIR/EIS
• Combined Array for Research in Millimeter-wave Astronomy
(CARMA) Relocation Project EIS/EIR
• PG&E Hydroelectric Divestiture EIR
• FDA Laboratory EIS/R
• DOGGR CEQA Compliance and Permitting Procedure
Assessment
• GTC Gaviota Marine Terminal Supplemental EIR/EIS
• Monterey Accelerated Research System (MARS) Cabled
Observatory EIR/EIS
• LAUSD New School Construction Program EIR
• Hermosa Beach Urban Oil/Gas Development (CEQA Process
Consultant)
Exhibit 1. Aspen's Selected CEQA Experience
Power Plants
Water Supply and Flood Control
Pipelines
• Kinder Morgan Concord-to-Sacramento Pipeline EIR
• Kinder Morgan Carson-to-Norwalk Pipeline EIR
• Pacific Pipeline ElS/SEIR (San Joaquin Valley to Los
Angeles/Carson)
• Pacific Pipeline EIR (original route: Santa Barbara to Los
Angeles)
• Alpine Natural Gas Mitigation Monitoring
• Boise Chica Water Transmission Line Project SEIR
Other Infrastructure and Institutional Projects
Telecommunications
• Level 3 Communications Infrastructure Project Mitigated
Negative Declaration (Statewide)
• Preparation of CDFG (Region 3) Stream bed Alteration
Agreements for the following telecommunications projects:
- Williams Communications, Inc.
- XO Communications
- AT&T
- MCI WorldCom
- Metromedia Fiber Network Services, Inc.
Ms. Susan Yun
May 21, 2008
Page 4
Under Aspen's ongoing contracts with the federal and state infrastructure agencies, we have prepared
numerous CEQA documents for high-profile projects. For example, under the contract with the Energy
Commission, Aspen provides engineering and environmental technical assistance to review power plant
certification applications. Since March 2000, Aspen has been issued over 1,155 Work Authorizations for
more than 50 proposed power plants, including impact analysis under the Energy Commission's CEQA-
equivalent process. Factors that have added to the complexity of our projects are the level of coordination
with local, state, and federal agencies and the amount of public participation involved.
3.2 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 Energy Commission's CEQA-equivalent process for
reviewing proposed thermal power plant projects. In its role as prime contractor, Aspen continually
4Ms. Susan Yun
May 21, 2008
Pace 5
reviews environmental and technical documents produced by others, including the work products of
subcontractor teams. For example, Aspen is currently managing multiple contracts for the CPUC and
Energy Commission that involve the management of dozens of technical subcontractors, each responsible
for producing environmental and technical documents that Aspen must direct, review, revise, and edit for
adequacy, accuracy, completeness, conformance with stipulated guidance and style guides, and overall
quality. 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 submitted to the
California Public Utilities Commission and Applications for Certification submitted to the 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 FIR/EIS 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 CFQA 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 Strearnbed
Alteration Agreement and Section 2081 Incidental Take Permits for the project, as well as a master Section
404 permit from the Corps of Engineers. The applicant is preparing the EIR/EIS under guidance from CDFG
and the Corps. 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 FIR/EIS for the Cabrillo Port LNG
1Deepwater Port ELR/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 EIR/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.
• Similar to Cabrillo Port above, 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.
3.3 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 Elk, County of Santa Barbara
• Kinder Morgan Concord-to-Sacramento Pipeline EIR, California State Lands Commission
5Ms. Susan Yun
May 21, 2008
Page 6
• 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 (see Section 3.2 above)
• 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 (see Section 3.2 above)
• Kinder Morgan Carson-to-Norwalk Pipeline EIR
• Yellowstone Pipeline Reroute EIS, USDA Forest Service, Lob o National Forest
• Pacific Pipeline Project Elk and Supplemental EIS/SEIR
• Gaviota Interim Marine Terminal/Chevron Tankering Supplemental EIR/EIS, County of Santa Barbara
• Exxon Tankering Application from Gaviota (proposal withdrawn) Subsequent EIR, County of Santa Barbara
• Hermosa Beach Urban Oil/Gas Development (CEQA Process Consultant), City of Hermosa Beach
• Kern County OH and Gas Well Permitting Environmental Compliance and Permitting Process (CEQA
Process Consultant), Division of Oil, Gas, and Geothermal Resources
• Molino Gas Project Elk (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
4. Project Management and Key Personnel
Sandra Alarcon-Lopez will serve as Aspen's Project Manager for the review of the Draft EIR and CSD.
Ms. AlarcOn-Lopez has extensive experience managing complex and high profile projects and has worked
on many oil and gas development projects as a planner with the County Energy Division. Ms. Alarcon-
Lopez will be the primary point of contact for the City, and will direct Aspen's work. She will coordinate
the team members, assuring that interdisciplinary coordination occurs, and ensuring dissemination of key
data and assumptions to the Team so there are no obstacles to meeting the review schedule. Ms. Sandra
Alarcon-Lopez will also represent the Aspen Team at meetings.
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. Under contract to the California Energy Commission, Mr. Walters has been
responsible for preparing the air quality assessments for power plant projects located throughout
California.
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. In addition, he has extensive experience conducting biological
assessments in the varied habitats found in southern California. Mr. Huntley has also completed
6Ms. Susan Yun
May 21, 2008
Page 7
comprehensive vegetation mapping, sensitive species surveys, and revegetation plans for projects
throughout southern California. 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 was the Project Manager for the MMS 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 (COOGER) study and prepared the Santa Barbara
North County Siting Study for the County's Energy Division. As a result, she is very familiar with oil and
gas development scenarios and the potential effects of those actions.
Jason Ricks has over 10 years of professional environmental science and health and safety experience.
He has spent the past four years working as a Project Manager and analyst for environmental reviews
under CEQA and NEPA, working on the analysis of over 20 infrastructure, flood control, and
development projects. Mr. Ricks 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 energy projects, including: SCE's Antelope Transmission Project and
Tehachapi Renewable Transmission Project. Mr. Ricks recently completed screening-level CEQA
analyses for a 200-MW Solar PV project and a 290-MW Solar Thermal Collection field project in San
Diego County as part of the alternatives analysis for SDG&E's Sunrise Powerlink Project, and is
currently analyzing a solar thermal power plant project in San Luis Obispo County.
Vida Strong has extensive experience in environmental engineering and project management, with an
emphasis in the application of CEQA and NEPA in analysis and mitigation monitoring of controversial
development projects. She has managed and prepared 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. In addition,
she has managed the mitigation monitoring, compliance, and reporting programs for numerous industrial
projects on behalf of the permitting agencies including pipeline, transmission line, and fiber optic
networks. She recently managed the preparation of an EIR evaluating PXP's proposed TranquilIon 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
James Thurber, RG, CEG, CHG, 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 EIR
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. Mr. Thurber is a highly qualified geologist and
hydrogeologist, experienced in the assessment of site conditions related to past and current use of
7Ms. Susan Yun
May 21, 2008
Page 8
hazardous materials and environmental contamination. Mr. Thurber is experienced in the impact analysis
of hazardous materials for large planning projects and preparing appropriate and applicable mitigation
measures. Mr. Thurber has performed hazardous material assessments, for redevelopment projects. long
pipeline projects, and highways.
5. Technical Approach
According the Notice of Preparation published by the Los Angeles County Department of Regional
Planning, the EIR for Baldwin Hills CSD will analyze the following 14 issue areas:
• Safety, Risk of Upset, and Hazardous Materials • Noise and Vibration
• Air Quality • Recreation
• Biological Resources • Fire Protection / Emergency Services
• Water Resources • Cultural Resources / Archaeology
Geological Resources • Aesthetics / Visual Resources
Transportation/Circulation • Energy Resources
Land Use / Policy Consistency Analysis • Public Services and Utilities
Tasks 1 through 4 below describe Aspen's approach to reviewing the information and analysis in the Draft
EIR, including information on the proposed Community Standards District and associated development
standards and regulations.
Task 1: Review Draft EIR
Members of Aspen's professional staff will review the Draft EIR published by Los Angeles County for
the proposed Baldwin Hills Community Standards District (CSD). The various sections of the Draft EIR
will be reviewed by staff members with knowledge and experience relevant to each section. The review
will focus on: (1) compliance with CEQA requirements; (2) adequacy and technical accuracy of the
information and analysis: (3) appropriateness and effectiveness of proposed mitigation measures; (4)
adequacy of the analysis of alternatives; and (5) overall clarity and completeness of the information
presented. Aspen will conduct a critical review of the Draft EIR with intent of identifying inadequacies,
such as the use of outdated information, erroneous assumptions, inappropriate methodologies, or
unsupported conclusions. Review of appendices and supporting technical studies will be conducted to the
degree necessary to understand the analysis in the EIR and to confirm assumptions and conclusions.
Aspen may conduct limited fact checking to confirm information presented in the Draft EIR; however,
Aspen will not attempt to replicate any of the analysis or conduct any type of separate analysis of impacts
in order to verify results.
Task 2: Prepare Comments on the Draft EIR
Based on the review conducted in Task 1, Aspen prepare comments on the Draft EIR for submission to
City staff. The comments will focus on inadequacies and errors found in the document and will include
criticisms, as warranted, of the information and analysis presented in the Draft EIR. To facilitate review
by City staff, the comments will be numbered and organized to correspond to the sections of the Draft
EIR. If warranted, Aspen will also prepare comments on general concerns and overarching issues that are
not specific to individual EIR sections.
The draft comments will be submitted to City staff for review. As described in Task 4 below, Aspen will
meet with City staff members to describe the results of Aspen's review. After City staff has reviewed the
comments, Aspen will revise the comments based on direction provided by the City. The revised
comments will be presented to the City in a format suitable for submission to Los Angeles County as
comments on the Draft EIR.
8Ms. Susan Yun
May 21, 2008
Page 9
Task 3: Review Proposed CSD Standards and Regulations
In addition to the review of and comments on the Draft EIR described in Tasks 1 and 2, Aspen will also
review the provisions of the proposed CSD for the Baldwin Hills oil field area. It is expected that this
information will be contained primarily in the EIR, presumably in the Project Description and in
mitigation presented to address identified impacts. Aspen will review the proposed regulations,
procedures, and standards for the CSD for appropriateness and effectiveness in addressing impacts and
community concerns. As needed, Aspen will recommend revisions or refinements to the CSD and
associated development standards and regulations, including recommendations for additional standards
and requirements, if needed. The evaluation of the proposed CSD will be conducted with an
understanding that the oil field is located in a highly urbanized area, thereby making the compatibility
with surrounding land uses, particularly residential uses, of paramount importance.
Task 4: Meet with City Staff to Review Comments and Recommendations
At the initiation of the services described herein, Aspen's project manager will meet with members of
City staff to discuss the work assignment, share information, and refine expectations related to schedule
and work products. That same day, Aspen's project manager will also conduct a reconnaissance of the
Baldwin Hills oil field area to gain a first-hand understanding of current conditions in the area. After the
initial review of the Draft MR and CSD described in the tasks above, Aspen's project manager and a
senior analyst will meet with City staff members to review Aspen's draft comments. At the City's request,
Aspen's project manager will be available to attend up to three additional meetings during the course of
this assignment, which represents an assumed maximum of five meetings. These additional meetings
could include City committee meetings and County public meetings related to the EIR or CSD.
6. Schedule
Aspen will provide draft comments on the Draft EIR and CSD two weeks after receiving the complete
Draft EIR and receiving authorization to proceed from the City. Aspen will revise the comments one
week after receiving feedback from the City on the draft comments, assuming the City does not request
additional research or other investigations to be conducted in order to finalize the comments.
7. Proposed Budget
Aspen's proposed budget for the requested services is summarized in Exhibit 2 below. This budget is
based on our current understanding of the City's needs and our experience conducting EIR review for
other agencies. If our proposed budget exceeds or fall short of your expectations, we would appreciate the
opportunity to review the scope of work with you, make adjustments as needed, and revise the budget
accordingly.
Exhibit 2. Proposed Budget
Taskl
Draft EIR Review
Task 2
Draft EIR
Comments
Task 3
CSD Review
Task 4
Meetings
TOTAL
Labor Hours 238 65 125 36 464
Cost $31,429 $8,861 $18,220 $6,033 $64,543
Contingency (15%) $4,714 $1,329 $2,733 $905 $9,681
Total $36,143 $10,190 $20,953 $6,938 $74,224
9Ms. Susan Yun
May 21, 2008
Page 10
If you have any questions about our proposal or require additional information, please contact me at (818)
597-3407 ext. 343. Feel free to contact me my e-mail if that is more convenient for you
(jdavidson@aspeneg.com). If you are unable to reach me, please contact our proposed project manager,
Sandra Alarcon-Lopez at (562) 947-5259. Thank you for your consideration.
Sincerely,
ASPEN ENVIRONMENTAL GROUP
Jon Davidson, AICP
Vice President
10Amended Scope of Work and Budget
Baldwin Hills Community Standards District ElR Review
and
City Ordinance Amendment for Oilfield Development
1. EIR and CSD Review Tasks
According to the Notice of Preparation published by the Los Angeles County Department of Regional
Planning, the E1R for Baldwin Hills Community Standards District (CSD) will analyze the following 14
issue areas:
• Safety, Risk of Upset, and Hazardous Materials • Noise and Vibration
• Air Quality • Recreation
• Biological Resources • Fire Protection / Emergency Services
• Water Resources • Cultural Resources / Archaeology
• Geological Resources • Aesthetics / Visual Resources
• Transportation/Circulation • Energy Resources
•
Land Use / Policy Consistency Analysis • Public Services and Utilities
The tasks below describe Aspen's approach to reviewing the information and analysis in the Draft EIR,
including information on the proposed Community Standards District and associated development
standards and regulations.
Task 1.1: Review Draft EIR
Members of Aspen's professional staff will review the Draft EIR published by Los Angeles County for
the proposed Baldwin Hills CSD. The various sections of the Draft E1R will be reviewed by staff
members with knowledge and experience relevant to each section. The review will focus on: (1)
compliance with CEQA requirements; (2) adequacy and technical accuracy of the information and
analysis: (3) appropriateness and effectiveness of proposed mitigation measures; (4) adequacy of the
analysis of alternatives; and (5) overall clarity and completeness of the information presented. Aspen will
conduct a critical review of the Draft EIR with the intent of identifying inadequacies, such as the use of
outdated information, erroneous assumptions, inappropriate methodologies, or unsupported conclusions.
Review of appendices and supporting technical studies will be conducted to the degree necessary to
understand the analysis in the EIR and to confirm assumptions and conclusions. Aspen may conduct
limited fact checking to confirm information presented in the Draft E1R; however, Aspen will not attempt
to replicate any of the analysis or conduct any type of separate analysis of impacts in order to verify
results.
Task 1.2: Prepare Comments on the Draft EIR
Based on the review conducted in Task 1.1, Aspen will prepare comments on the Draft EIR for
submission to City staff. The comments will focus on inadequacies and errors found in the document and
will include criticisms, as warranted, of the information and analysis presented in the Draft EIR. To
facilitate review by City staff, the comments will be numbered and organi7ed to correspond to the sections
of the Draft EIR. If warranted, Aspen will also prepare comments on general concerns and overarching
issues that are not specific to individual EIR sections.
The draft comments will be submitted to City staff for review. As described in Task 1.4 below, Aspen
will meet with City staff members to describe the results of Aspen's review. After City staff has reviewed|1010|11the comments, Aspen will revise the comments based on direction provided by the City. The revised
comments will be presented to the City in a format suitable for submission to Los Angeles County as
comments on the Draft HR.
Task 1.3: Review Proposed CSD Standards and Regulations
In addition to the review of and comments on the Draft EIR described in Tasks 1.1 and 1.2, Aspen will
also review the provisions of the proposed CSD for the Baldwin Hills oil field area. It is expected that this
information will be contained primarily in the E1R, presumably in the Project Description and in
mitigation presented to address identified impacts. Aspen will review the proposed regulations,
procedures, and standards for the CSD for appropriateness and effectiveness in addressing impacts and
community concerns. As needed, Aspen will recommend revisions or refinements to the CSD and
associated development standards and regulations, including recommendations for additional standards
and requirements, if needed. The evaluation of the proposed CSD will be conducted with an
understanding that the oil field is located in a highly urbanized area, thereby making the compatibility
with surrounding land uses, particularly residential uses, of paramount importance.
Task 1.4: Meet with City Staff to Review Comments and Recommendations
At the initiation of the services described herein, Aspen's project manager will meet with members of
City staff to discuss the work assignment, share information, and refine expectations related to schedule
and work products. That same day, Aspen's project manager will also conduct a reconnaissance of the
Baldwin Hills oil field area to gain a first-hand understanding of current conditions in the area. After the
initial review of the Draft FIR and CSD described in the tasks above, Aspen's project manager and a
senior analyst will meet with City staff members to review Aspen's draft comments. At the City's request,
Aspen's project manager will be available to attend up to three additional meetings during the course of
this assignment, which represents an assumed maximum of five meetings. These additional meetings
could include City committee meetings and County public meetings related to the EIR or CSD.
2. Ordinance Amendment and Revised Submittal Requirements
Task 2.1: Review of Existing Ordinance and Adopted County of Los Angeles
Documents
Aspen Project Manager and staff will review the City's existing ordinance to determine where
amendments could be made to address oil and gas well drilling within the City boundaries. Based on
preliminary review of the City's ordinance, Article 2 (Zoning Districts, Allowable Land Uses, and Zone-
Specific Standards) and Article 5 (Land Use and Development Permit Procedures) would be areas that
could accommodate requirements for well drilling. However, other areas could also be suggested for
amendment based on this review.
Aspen will also review other state and local documents as part of this task. The Division of Oil, Gas, and
Geothermal Resources current regulations and requirements and the County of Los Angeles CSD would
be reviewed to determine what changes would be needed to make the CSD applicable to the City of
Culver City. The County's CSD EIR would also be reviewed to identify mitigation measures or other
requirements that could apply to the City. Based on this review, Aspen will present preliminary options
for actions that the City could take to incorporate well drilling requirements in the zoning ordinance.
Task 2.2: Preparation of Draft Amended Ordinance
This task includes the following activities:
. Aspen will prepare an outline of the proposed ordinance amendment for review and approval by the
City prior to beginning work on the document.
2•
Aspen will submit a draft proposed ordinance amendment to the City for review and comment.
•
Aspen will revise the document based on comments received by the City. Aspen has assumed four
review cycles for consideration of the amended ordinance with City Staff and two additional
reviews based on Planning Commission and City Council review.
Task 2.3: Preparation of Application Submittal Requirements
Aspen will review the City's existing permit requirements and other applicable materials such as
requirements identified in the County of Los Angeles CSD process and other city documents to prepare a
list of application requirements. The application requirements will be provided to the City for review and
comment. Aspen assumes two review cycles for consideration of this document.
Task 2.4: Meetings and Coordination with City Staff
Aspen will participate in and prepare for three face-to-face meetings to discuss the changes to the City's
ordinance and the application requirements. Aspen will also be available to present proposed changes to
the City Planning Commission and City Council, if necessary. For purposes of the cost estimate,
participation in two hearings has been assumed.
Proposed Budget
Aspen's proposed budget for the requested services is summarized below. This budget is based on our
current understanding of the City's needs and our experience conducting EIR review for other agencies. If
our proposed budget exceeds or fall short of your expectations, we would appreciate the opportunity to
review the scope of work with you, make adjustments as needed, and revise the budget accordingly.
Exhibit 1 below presents the proposed budget for review of the Baldwin Hills CSD EIR, including a
review of the proposed CSD regulations.
Exhibit 1. Proposed Budget — Baldwin Hills CSD EIR Review Tasks
Task 1.1
Draft EIR Review
Task 1.2
Draft EIR
Comments
Task 1.3
CSD Review
Task 1.4
Meetings
TOTAL
Labor Hours 229
65 142 48 484
Cost $34,435 $8,855 $20,489 $8,058 $71,732
Contingency (15%)
$5,165 $1,328 $3,073 $1,209 $10,760
Total $39,600 $10,183 $23,562 $9,267 $82,492
Exhibit 2 below presents the proposed budget for drafting a proposed City ordinance amendment
addressing oilfield development regulations, including updated submittal requirements for oil field
development applications.
Exhibit 2. Proposed Budget — Ordinance Amendment and Revised Submittal Requirements Tasks
T ask 21
Ordinance Review
Task 2.2
Draft Amended
Ordinance
Task 2.3
Submittal
Requirements
Task 2.4
Meetings and
Coordination
TOTAL
Labor Hours
73 179 67 89 408
Cost $9,535 $25,547 $9,037 $13,569 $57,633
Contingency (15%) $1,430 $3,832 $1,356 $2,035 $8,645
Total $10,965 $29,379 $10,393 $15,604 $66,278|1010|13ATTAciftite
m c
21 May 2008
Ms. Susan Yun
Senior Planner
City of Culver City
9770 Culver Boulevard
Culver City, CA 90232
Subject: Third-party Review of Draft Environmental Impact Report (DER) for the
Baldwin Hills Community Standards District (CSD), prepared by the County of
Los Angeles
Ms. Yun,
Thank you for contacting AMEC Earth & Environmental, Inc. (AMEC) about the City of Culver
City's (City's) need for contactor support in conducting a third-party review of the forthcoming
DE1R under preparation by the County of Los Angeles (County). This brief letter proposal is
intended to demonstrate to you: 1) our capability, capacity, and commitment to serve in the
City's best interests; 2) our understanding of the primary issues associated with the DE1R and
which are the highest priorities for the City; and 3) our understanding of the role you envision for
AMEC in this endeavor.
About the AMEC Team
As a brief introduction, AMEC is a global environmental and engineering firm with significant
presence and experience in Southern California, including involvement in high-profile, complex
environmental planning endeavors involving issues similar to those involved in the DEIR and
CSD under preparation by the County. AMEC's proposed Project Manager for this effort, Mr.
Dan Gira, has more than 20 years of experience in the management and execution of large-
scale community planning programs and complex analyses prepared in compliance with the
California Environmental Quality Act (CEQA), including several addressing impacts associated
with oil and gas licensing and development. AMEC has seven offices in California and our
efforts on this program would be supplemented regionally by TIAX LLC (T1AX), a firm which
brings specialized yet significant expertise to the project team with regard to the assessment of
analyses related to air quality impacts contained within the County's EIR. TIAX provides air
quality expertise for a wide variety of clients, including the South Coast Air Quality Management
District (SCAQMD), California Air Resources Board (GARB), the California Energy Commission
(CEC), and the Department of Energy's Office of Transportation Technologies.
AMEC Earth & Environmental. Inc.
104 West Anapamu Street, Suite 204A
Santa Barbara CA 93101
USA
Tel +1(805) 962-0992
Fax +1(805) 966-1706
www.amec.comProgram Understanding
AMEC would ensure that the DEIR sufficiently addresses the impacts of and mitigation
measures associated with the whole of the project including impacts associated with operation
of existing wells and facilities, and installation and operation of proposed wells to be drilled
within Culver City limits, both inside and outside the CSD (Figure 1). AMEC would ensure that
potential impacts to key surrounding land use and public infrastructure are thoroughly
addressed, including impacts to residential areas within the City and surrounding
unincorporated County areas (e.g., Ladera Heights) and to parks and other community facilities
(e.g., Kenneth Hahn State Recreation Area, Baldwin Hills Overlook, and West Los Angeles
College).
AMEC is aware that the Baldwin Hills Oil Field consists of a mix of facilities, including some
wells and support facilities that have been recently upgraded and others that consist of aging
facilities that have been under production for decades. AMEC is aware that aging oil facilities
and those not meeting modern standards for production have the potential for failure or
production problems when compared to more recently upgraded facilities. As such, AMEC
would consider the DEIR's adequacy in light of efforts taken to disclose, discuss, and identify
the status of all existing facilities as well as those targeted for new production.
AMEC would pay particular attention to the adequacy of mitigation measures proposed in the
document, including the availability of adequate agency staff and funding for monitoring and
enforcement. AMEC would assess and verify potential funding sources as needed to ensure
that proposed mitigation measures are feasible and enforceable. AMEC anticipates reviewing
the DEIR for three types of mitigation measures:
•
New or Revitalized Agency Programs: These measures should generally consist of
agency programs for monitoring, remediation, or enforcement, such as those that would
be incorporated into the CSD, which would commit the County, the State Department of
Oil and Gas, the SCAQMD, or other relevant Federal, State, or local agencies to regular
monitoring, enforcement, and reporting of agency-implemented measures. AMEC would
ensure that regular reporting components were included in such programs, including
appropriate public hearings or briefings so that City decision-makers and interested
members of the public would be easily informed about the progress of such efforts.
AMEC anticipates the need to include possible "reopened" conditions where key project
components would be scrutinized for compliance based on accepted performance
criteria and subject to public review as needed to assess compliance. It may also be
appropriate to consider the availability of any nexus for enhanced funding sources (e.g.,
those derived from new oil exploration profits in order to offset potential environmental
impacts caused by new oil extraction activities). Such programs have been highly
successful in funding public improvements and environmental enhancement measures
to partially offset the impacts of oil development in the Santa Barbara Channel (i.e.,
Santa Barbara County's Coastal Resource Enhancement Fund has generated more
than $15 million for land acquisition, public improvements, and environmental mitigation
since 1987).
Proposal to Provide Third-party Review 2 City of Culver City
EIR for the Baldwin Hills CSD 21 May 2008•
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Proposal to Provide Third:party Review 3 City of Culver City
EIR for the Baldwin Hills CSD 21 May 2008• New Production Development Standards: AMEC would consider the adequacy of
proposed mitigation measures to be applied to new production and would ensure that
such measures are clearly drafted to be feasible and enforceable and to be included as
development standards in the CSD or as permit conditions. Such measures may include
hours of construction operation, night lighting, truck routing, soil stockpiling, fencing, and
other safety measures.
• Oil Producer Actions: These would generally include actions to be undertaken by PXP
or successor producers to ensure follow up on mitigation measures directly linked to new
development and/or remediation and rehabilitation measures to address existing
problems (e.g., existing soil contamination, equipment upgrades to aging existing
infrastructure to improve safety or reduce air quality emissions) that are undertaken to
offset direct and indirect project impacts.
Understanding of Primary Tasks
Review of DEIR. Initial efforts would focus on a detailed review of the DEIR, expected to be
released in June 2008. AMEC and T1AX would pay particular attention to treatment of safety
issues, air quality analyses, and the adequacy of mitigation measures proposed to address
identified significant impacts. In order to conduct a thorough and meaningful review, it is
assumed that AMEC and TIAX will be granted access to associated ancillary studies, including
calculations and emissions factors. (Based on a review of provided materials, it has also been
assumed that TIAX's review of air quality analyses will not include greenhouse gases [GHGs].)
Preparation of Response Letter. Upon completion of this review, AMEC would prepare a
letter on behalf of the City, addressing primary issues of concern, and identifying elements of
the DEIR within which changes are warranted to better represent potential environmental
impacts and mitigation measures,
Meeting Support. As discussed, AMEC has assumed attendance at and participation in up to
five (5) meetings with City and/or County representatives to discuss the EIR, the results of the
third-party review process, and the eventual incorporation of changes to the document, as
necessary. In addition, TIAX attendance at one (1) meeting has been assumed to facilitate a
discussion of air quality issues.
Review of County Documentation. AMEC will be available to review correspondence
between the County and the City (e.g., the County's response-to-comments document
addressing the City's comments on the DEIR).
Cost Proposal
Based on our understanding of the project — as outlined above — AMEC proposes a time-and-
materials (T&M) cost estimate of $77,013 for these services. This estimate is intended to cover
all labor, across all labor categories, as well as indirect costs anticipated to be necessary to
complete the assigned tasks; it also includes a contingency fund, per your request. A detailed
spreadsheet outlining the team structure and breakdown of labor therein is available upon
request.
Proposal to Provide Third-party Review 4 City of Culver City
ElR for the Baldwin Hills CSD 21 May 2008Thank you again for the opportunity to submit this proposal to support the City on this important
project. If you have any questions or require additional information, please do not hesitate to
contact either Dan Gira or me at (805) 962-0992.
Sincerely,
Doug McFarling
Senior Project Manager
CC: Mr. Dan Gira, AMEC (Santa Barbara)
Ms. Julie Kercher, TIAX (Irvine)
Proposal to Provide Third-party Review 5 City of Culver City
EIR for the Baldwin Hills CSD 21 May 2008AMEC EARTH 3/ ENVIRONMENTAL, INC.
CLIENT:
City at Caeer Cloy
PROJECT:
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11, 110,246
$77,013Additions to Proposed Scope of Work (dated May 21, 2008)
1. Approximately 10 hours (each) of specialist support for general peer review of
noise, geo-technical issues (e.g. subsidence), petroleum engineering and safety
(total up to 44 additional hours). The petroleum engineer would also be
available to provide feedback on task 2 below.
2. Review of Culver City's existing Oil and Gas Regulations (Business Regulations;
Chapter 11.12: Oil, Gas and Hydrocarbons) and their interrelationship with
associated zoning ordinance permit requirements and the City's General Plan
and preparation of an updated ordinance, including revised submittal standards,
including the following tasks:
a. Review Chapter 11.12 for consistency with modern oil field development
regulations. AMEC's initial review of this chapter indicates that this
ordinance may not fully reflect modern development standards,
particularly those appropriate for an oil field in a highly urban setting in a
non-attainment air basin. Examples of potentially antiquated provisions
include in-ground sumps for storing petroleum products and drilling mud,
or regulation, boiler regulations more appropriate to historic production
techniques, lack of pipeline safety measures such as liners, double walled
pipes and the use of smart "pigging" devices for maintenance and safety
(16 hours).
b. Review of City's zoning ordinance permit provisions and General Plan to
identify relevant provisions and policies and consider consistency
relationship to new potential oil regulations (8 hours)
c. Review of new Community Standards District for use in development of
the City's code (12 hours).
d. Review of 2-3 California companion jurisdiction's (e.g. Santa Barbara,
Bakersfield, Long Beach) oil field development codes to permit
consideration of inclusion of modern standards for site design,
landscaping, remediation, habitat restoration etc (16 hours).
e. Prepare new draft Oil Development Code to replace or supplement
Chapter 11.12, including new submittal requirements, which incorporates
the best available standards from the proposed CSD and other oil
producing jurisdictions (32 hours).
f. Prepare recommendations for potential amendments to the City's zoning
ordinance and General Plan to improve integration and consistency with
the new oil development code (12 hours).
g. Prepare revisions to draft ordinance based on City comments (20 hours).
Assumptions:
1. Technical specialist would provide general peer review only; no detailed
modeling for geo-tech, safety, noise or petroleum engineering is
included. Such services could be provided upon request.
2. Ordinance preparation includes drafting of amendments to City Code
only; detailed revisions to the City's zoning ordinance and General Plan
are not included.
3. No preparation of CEQA analysis (if required) for proposed ordinance
amendments is included.A-FrAcHAEO- 3
DISCLOSURE STATEMENT
Aspen Environmental Group (Aspen) is not under contract to Plains Exploration and Production
Company (PXP).-.111(.1 is not providing any services to PX.P. Further, a review °lour compan y records
indicates that Aspen has never been under contract to PXP in the past.
Aspen primarily provides consulting services under contract to public agencies. In July 2006 ; Aspen
was awarded a contract by the County of Santa Barbara to prepare an environmentai impact report
(E1R) for PXI"s proposed 'FranciniHon Rid ge Oil and Gas Development Project. The Final E1R for that
project was published in April 2008. However, Aspen re -mains under contract to the County to provide
support on the project through the remainder of the decision-making process. Aspen has conducted no
work. related to any other PXP project.
This is information is true and accurate to the best of my knowledge.
June 18, 2008Page 1 of 2
Baker, Heather
From: Gira, Daniel [danielgira@amec.com ]
Sent: Tuesday, June 17, 2008 4:15 PM
To: Blumenfeld, Sol; sherry.jordon@cuivercity.org ; Herbertson, Charles; Baker, Heather
Cc: McFarling, Doug; Malloch, Rosann M
Subject: Baldwin Hills CSD DEIR; Interview Follow-Up
Attachments: Culver City Proposal.pdf; Additions to Proposed Scope of Work _2_.pdf
Good afternoon,
Thank you for interviewing our team yesterday. It was a pleasure to discuss this interesting project with
the City's panel.
Attached please find response to questions raised at yesterday's interview and a revised cost proposal
for independent review of the proposed CSD EIR for Baldwin Hills. Based on our understanding of City
questions and concerns, AMEC has submitted the information detailed below and proposes the
following additions to the original scope of work (see attachment and revised cost spreadsheet). I also
adjusted team member hours based on the expedited timeline outlined yesterday and everyone's
relative availability. These may need to be adjusted again if the schedule is further revised. These
adjustments resulted in only slight changes in cost.
We have tried to be as comprehensive as possible given the short time frame available for response. In
particular, please consider the scope of work related to revisions to the City's Municipal Code to
address oil production in order to determine if this is consistent with the general direction provided at
our meeting. This task has added considerable cost to our proposal. Please do not hesitate to let me
know if the City requires further information or additional adjustments to the scope of work.
In regards to potential conflicts of interest, to the best of my knowledge, AMEC Earth and
was titled OSRO Feasibility Study. This project was completed and closed July 5, 2007. The project
within AMEC PLC has contracts with PXP. However, we have been unable to confirm this within the
to ensure objectivity and avoidance of real or perceived conflicts. T1AX has also responded that that
have no current dealings with PXP.
short time frame permitted. If this is the case, we can certainly construct whatever firewalls are needed
staff in our California Offices, including our U.S. Oil & Gas Sector Leader, and we are unaware of any
manager was Suzanne Foley who is no longer with AMEC. AMEC also prepared an Environmental
Operating Company, a predecessor to PXP. It is possible that AMEC Paragon, another company
ongoing contracts. AMEC had work with Plains Exploration & Production Co. in January 2007 which
members of the project team have no direct or indirect work with PXP. I have queried senior AMEC
Baseline Survey (EBS) many years ago to renew some oil leases on Vandenberg AFB for Torch
Environmental does not currently have any ongoing contracts involving PXP. I and the primary
In regards, to AMEC's experience with subsidence, AMEC geologists in our Anaheim Office have direct
hands on experience with subsidence, including projects such as AMEC's Santiago landslide in the City
of Anaheim (contact, Natalie Meeks, City Engineer). Subsidence here is associated with dewatering.
Subsidence in the Baldwin Hills associated with oil extractions is a well known phenomenon among
geologist and is thought to have potentially contributed to the historic collapse of the Baldwin Hills dam.
One of AMEC's geologists also had exposure to subsidence in the Baldwin Hills as part of previous
employment with Douglas E. Moran Associates. Additional subsidence references are available on
request. I believe that AMEC's Anaheim Office is already under contact with Culver City to provide
geotechnical services. PXP is not be able to provide specific additional references on urban
air modeling beyond those provided at the interview (e.g. California ARB) until tomorrow. I will follow
06/19/2008Page 2 of 2
up with them.
I hope that the responses above and the additional attached scope of work meet the City's
expectations. Should you have any additional questions, please do not hesitate to contact me.
I will be leaving early today to take my team to the batting cages. Questions can be directed to my cell
phone (805 284-5080) or home e-mail; dangira@msn.com - I will endeavor to respond tonight.
Sincerely,
Dan
Dan Gira
Program Manager
AMEC Earth and Environmental
104 West Anapamu Street, Suite 204A
Santa Barbara, CA 93101
(805) 962-0992
The information contained in this e-mail is intended only for the individual or entity to whom it is
addressed.
Its contents (including any attachments) may contain confidential and/or privileged information.
If you are not an intended recipient you must not use, disclose, disseminate, copy or print its contents.
If you receive this e-mail in error, please notify the sender by reply e-mail and delete and destroy the
message.
t F 1.1 06/19/2008A 1-TAc4-fmeAri
Los Angeles County Community Standards District (PXP) Draft EIR Review
Received Notice of Preparation: 06/28/07
Council discussion of Notice of Preparation 07/23/07
Draft EIR public scoping meetings 07/24 &26/2007
Comments on the Notice of Preparation submitted to LA Co. 07/31/07
Contacted qualified consultants requesting proposals: 05/15/08
Received consultant's proposals: 05/21/08
Staff evaluated and ranked proposals: 06/12/08
Staff interviewed AMEC 06/16/08
Staff begins reference checks: 06/17/08
Staff interviewed Aspen: 06/17/08
Release of Draft EIR: 06/19/08
Council award of contract: 06/23/08
Community input at City Council meeting: 07/07/08
County sponsored public workshops on CSD 0717 & 07/22/08
County Regional Planning Commission public hearing 08/02/08
Council review of prepared comments at public meeting: 08/11/08
Transmittal of comments to LA County: 08/19/08
County Regional Planning Commission public hearing 08/27/08