Ralph Dennis comments on ISO, Benicia City Council, 17 July 2018

Public Comment – Council deliberation on whether to reconsider ISO vote of 19 June 2018

By Ralph Dennis, Benicia, June 17, 2018
Ralph Dennis, Chair, Progressive Democrats of Benicia, Member of Benicia ISO Working Group

Good evening. My name is Ralph Dennis, I’m a resident of Benicia with my wife Vicki. I am also one of the members of the ISO Working Group, and also chair of the Progressive Democrats of Benicia. The Progressive Democrats have been supporters of a Benicia ISO from the beginning of the working group. At its June meeting, PDB members voted unanimously in support of the draft Benicia ISO ordinance presented to Council on June 19.

Thank you for the opportunity to speak tonight.

I ask that you vote tonight to reconsider your June 19 vote concerning an Industrial Safety Ordinance for Benicia.

If the desire is, in fact, to finally do something about determining what is in Benicia’s air, and to provide the City better communication with those businesses affecting Benicia’s air and safety – and that IS what I ultimately heard from the Council’s 3 votes that prevailed on June 19 …

Then, there is nothing to be gained by waiting until November.

  • Fence line monitoring, once installed, will tell us virtually nothing about what’s in the air. According to Eric Stephenson, who runs the Air District’s monitoring programs, fence line monitors are “designed for ground level monitoring” and “not for emissions that are lofted”. Meaning air borne emissions, i.e., what’s in the air.
    • So, Valero’s fence line monitoring program is limited at what it will do. Benicia needs a comprehensive, community wide monitoring program, which an ISO would provide and do it much sooner. And, the sooner we get an ISO up and running the quicker the City and community can tap into Air District resources for community monitoring efforts, something else Mr. Stephenson said is possible.
    • The Air District’s AB617 community monitoring program may include Benicia but not until 2024 at the earliest, based on its recently announced schedule.
    • And, related Air District efforts toward community monitoring are yet to be clarified and probably depend upon individual community initiative to kick start.
  • As to Better communications/Is CUPA sufficient?
    • Last week I saw two Public notices published in the Benicia Herald by the Solano Co Environmental Health Division – CUPA – for Risk Management Plans submitted by two Benicia businesses – Praxair and the City of Benicia Water Treatment Plan.
    • These plans reviewed by CUPA are required by state regulations for businesses which handle and use hazardous materials, and are now available for review by the public – for 45 days, and counting.
    • CUPA told me it plans no public meetings. And, when asked, seemed surprised at the question. Also, no copies of Plans for review on-line, or in public libraries like Contra Costa Co officials have done – we need to go to Fairfield to see the Plans.

I don’t know if anyone in the City was notified by these businesses when their Plans were being prepared or when the Plans were filed. Presumably, you saw the Water Treatment Plant’s plan. But, neither existing state regulations, nor CUPA, provided any means for review or comment – until after the fact, plans already filed and reviewed.

Is publication in a local, soon to be 3 days a week paper with limited circulation to be the extent of communication with the Benicia community? With the City?

On plans that affect the community’s air and safety?

A Benicia ISO would make the City and community partners with businesses in the development of these Plans – not a bystander, at best. And, not depend upon CUPA for communication.

I also asked CUPA whether a Risk Management Plan had been submitted by Valero:

  • Filed in December 2017, but is still under review by CUPA staff.
  • And, I don’t know if anyone at Valero gave the City a heads up last December that the Risk Management Plan was ready to be filed. Or, asked whether the City wanted to take a look at the Plan before it was filed.
  • You know, as a courtesy, or even in an effort to improve communication.
  • But, in any event, CUPA said its Public Notice will be published once review is done. Then, we the public get to see it – including the City of Benicia and its community…for a 45-day period…to provide comments…on a Plan already reviewed and, seemingly, ready for approval. Don’t expect any public meetings from CUPA, and better make sure your subscription is up to date with the newspaper.

For the sake of the community, please vote tonight to reconsider your June 19 3-2 vote, so we can get on with the business of considering an ISO for Benicia.

Thank you.

Respectfully submitted,

Ralph E. Dennis

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