Latest Benicia DEIR comments: Center For Biological Diversity, Communities for a Better Environment, Natural Resources Defense Council

On December 16, the City of Benicia released yet another document highly critical of the Valero Crude-by-Rail Draft EIR.  The massive report was submitted for the record on December 5 by the Center for Biological Diversity, Communities for a Better Environment, and Natural Resources Defense Council.  The document focuses on biological resources and climate change.  Many thanks to our friends in these excellent organizations!

The summary page follows:

CBD-CBE-NRDC_lttrhdDecember 5, 2014

Amy Million, Principal Planner
Community Development Department
250 East L Street
Benicia, CA 94510
amillion@ci.benicia.ca.us

Re: The City of Benicia’s Draft Environmental Impact Report for the Valero Benicia Crude by Rail Project

Dear Ms. Million,

On behalf of the Center for Biological Diversity, Communities for a Better Environment, and Natural Resources Defense Council, we submit the following comments on the City of Benicia’s Draft Environmental Impact Report (DEIR) for the Valero Benicia Crude by Rail Project (Project). The Project, if approved, would allow the Valero refinery to receive up to 70,000 barrels per day of crude oil by train, which equates to a potential for 1.07 billion gallons of crude oil imported by train each year.

These comments supplement prior comment letters by detailing the significant deficiencies in the DEIR’s assessment of impacts to Biological Resources in Section 4.2. Specifically the DEIR (1) fails to adequately analyze and mitigate impacts to biological resources at the Project area; (2) fails to adequately analyze and mitigate impacts along the rail lines serving the Project; (3) fails to properly analyze the cumulative impacts of increased crude oil shipments on biological resources; and (4) fails to adequately evaluate impacts related to climate change.

Because this Project would result in significant impacts to biological resources, the City cannot certify the DEIR before adopting all feasible mitigation measures. At present, the DEIR fails to identify and analyze mitigation measures that would reduce the Project’s impacts.

However, there are numerous mitigation measures and alternatives that would reduce the impacts of the Project. These measures must be analyzed in the DEIR, so that the full range of options are publicly disclosed and considered by decision‐makers.

[Editor: The document continues … Note that the “Public Comment” link below goes to a huge 584-page document on the City’s website, a 24mb download.  WordPress will not allow an upload of this magnitude here on The Benicia Independent.  The bulk of the document (570 pages) is supplemental studies, all important, but for the heart of the document, see the 14-page Comment Letter minus the supplements.  – RS)

Public Comments October 17-December 15, 2014  (A single comment letter, from the Center for Biological Diversity, Communities for a Better Environment, and Natural Resources Defense Council.)

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