LETTER OF OPPOSITION: Greg Karras, Senior Scientist for Communities for a Better Environment

By Roger Straw, March 31, 2016

This morning, Greg Karras, Senior Scientist for Communities for a Better Environment (CBE) sent the Benicia City Council a 15-page Expert Report, Regarding the Appeal of Planning Commission Actions on the Valero Benicia Crude by Rail Project and Environmental Impact Report (EIR).

For Mr. Karras’ lengthy attachments, see the City of Benicia’s posting of letters received March 25-31.


Valero’s appeal asserts … that: “All of the public discussion about the Project has focused on the impacts of rail operations.” …The assertion that “[a]ll public discussion about the Project has focused on the impacts of rail operations”2 is inaccurate and misleading. Goodman and Rowan (2013) showed that the project could change the refinery’s crude slate.3 Fox (2013) showed this could cause significant impacts from refining operations.4 By 1 July 2013 at least eleven groups, including CBE and the refinery workers union United Steelworkers (Local 675), sought full disclosure and analysis of the changes in refinery oil feedstock and emissions that could result from the project.5 The EIR identified this potential for project-driven changes in its crude slate to cause impacts in the refinery as an “area of controversy.”6 Fox (2014),7 Pless (2014),8 Karras (2014),9 Fox (2016),10 Pless (2016)11 and others12 commented in detail on the EIR’s failure to evaluate these and other refining impacts of the proposed project. Valero is on record acknowledging this focus of independent public comment on refining impacts of the project, as shown by the company’s attempt, at the Planning Commission’s Public Hearing, to rebut comments regarding these refinery impacts of the project,13 in direct contradiction to its position on appeal.