See a searchable version of the letter here: 2014-10-02 AGO Valero CBR Project DEIR Comment Letter OCR.   (Here is the original pdf.)

Summary, from p. 2:

Unfortunately, the DEIR for this Project fails to properly account for many of the Project’s potentially significant impacts pursuant to the California Environmental Quality Act(CEQA). Specifically, the DEIR:

1. Underestimates the probability of an accidental release from the Project by considering only a fraction of the rail miles travelled when calculating the risk of derailment, by relying on a currently unenforceable assumption that newer, safer tank cars will be used, by failing to adequately describe the potential consequences of an accident resulting in a release of crude oil, and by improperly minimizing the risk to public safety from increased rail-use;

2. Improperly asserts that the proper baseline for the Project’s impact on air emissions is determined by the Refinery’s maximum permitted emissions;

3. Fails to analyze the impacts on air quality from the foreseeable change in the mix of crude oils processed at the Refinery;

4. Ignores reasonably foreseeable Project impacts by impermissibly limiting the scope of the affected environment analyzed to only the 69-milestretch from Benicia to Roseville;

5. Fails to consider the cumulative impacts on public safety and the environment from the proliferation of crude-by-railprojects proposed in California; and

6. Employs an overly broad determination of trade secrets, which results in the nondisclosure of the types of crude oil to be shipped by rail and refined onsite. As a result, the DEIR fails to provide sufficient information for an adequate analysis of the safety risks from transportation or the air quality impacts from refining the new crude.

These issues must be addressed and corrected before the City Council of Benicia takes action  pursuant to CEQA on the DEIR or the Project.