Roger Straw letter (drawing attention to potential financial impacts of Valera’s proposal including a formula for expectable costs in a worst case scenario.)
DR. PHYLLIS FOX: Expert blasts letters submitted by Benicia consultants
The Benicia Independent is in receipt of a late-breaking letter from well-known environmental expert Dr. Phyllis Fox, in which Fox rebuts letters submitted by the City of Benicia’s consultants last week. Consultants MRS and ESA submitted letters on April 11 and April 12 attacking Dr. Fox’s previous comments.
The Fox letter was submitted less than an hour ago today and is not yet posted on the City’s website.
Fox writes, “I have reviewed the letters by MRS and ESA that respond to my 4/4/16 Comments on Valero’s Appeal of Planning Commission’s Denial of the Valero Crude-by-Rail Project. The MRS and ESA responses are notable for their lack of support for numerous assertions. With few exceptions, they present no supporting calculations nor citations to specific pages in the EIR, reports, or web links. Thus, they present no new evidence and fail to respond to my comments.”
ESA Response Memo to Fox Comments (5-page letter by the City’s consultant, ESA, defending its against criticism by Dr. Phyllis Fox on air quality and flooding.)
MRS Response Letter to Fox Comments (8-page letter by the City’s consultant, Marine Research Specialists, defending its “Quantitative Risk Analysis” against criticism by Dr. Phyllis Fox.)
Benicia Oil-by-Rail Battle Hinges on Legal Controversy
Opponents of oil-by-rail shipments want the city to block a proposed Valero facility, but Valero says the city lacks this power.
By Jean Tepperman
Andres Soto said Benicia shouldn’t wait on federal regulators to reject Valero’s oil-by-rail project. BROOKE ANDERSON
An oil-by-rail facility that Valero wants to build at its Benicia refinery has been stalled by opponents concerned about environmental impacts and safety issues for over three years now. But Valero and an attorney working on contract for the City of Benicia claim that the city cannot stop the project because federal railroad law preempts the city’s powers. Project opponents say this is a flawed interpretation of federal law, however, and that Valero’s new oil facility should be cancelled.
Valero’s original proposal was presented in 2013 as a simple plan to build a couple of rail spurs from the main railroad line to the company’s refinery, and the city announced its intention to approve the plan without doing an environmental impact review. A torrent of opposition greeted this announcement, however. As a result, the city was forced to conduct three environmental impact reviews and hold public hearings. Then, last February, Benicia’s planning commission unanimously reversed approval for the project. Now the oil facility is pending a final decision by the city council.
Supporters say the crude-by-rail project is necessary to preserve Valero’s — and Benicia’s — economic viability and the nation’s energy independence. Opponents say it will cause increased air pollution and environmental destruction, and that expanding oil-by-rail transportation increases the risk of catastrophic accidents like explosions and fires due to derailment.
But according to Bradley Hogin, a contract attorney advising the city, the federal government’s authority over railroads means that local governments are not allowed to make regulations that affect rail traffic — even indirectly. And when they’re deciding on a local project, cities are not allowed to consider the impact of anything that happens on a rail line, claims Hogin. The legal doctrine Hogin is referring to is called federal preemption.
But other attorneys call Hogin’s interpretation of federal laws “extreme” and say that the city has every right to block the project if it so chooses. Environmentalists have also pointed out that Hogin has represented oil companies against environmental and community groups in the past. Project opponents say Hogin is biased in favor of Valero, and is not giving the city accurate legal advice. When asked if Hogin’s previous work suggests that he could be biased, Benicia City Attorney Heather McLaughlin said no. “I think he has had great experience in the refinery industry and I think that’s been helpful for us,” she said.
Hogin’s legal argument that cities are preempted from influencing oil-by-rail projects has major national implications. As the shipment of crude oil via railroad has grown in recent years, so have the number of derailments, oil spills, fires, and explosions, including the 2013 explosion that killed forty-seven people in Lac Megantic, Quebec. As a result, communities across North America have demanded that local authorities stop rail shipments of crude oil through their towns. In addition to Benicia, San Luis Obispo County is currently in the midst of a battle over crude by rail.
“Hogin is making a case that would affect cities across the nation dealing with crude by rail,” said Marilyn Bardet, a founder of Benicians for a Safe and Healthy Community. “They [are trying] to create a legal precedent here.”
Many lawyers, including California Attorney General Kamala Harris, say the exact extent of federal preemption of local authority is still being worked out in the courts. In her legal opinion on the Valero project’s environmental review, Harris cited several cases in which local governments were allowed to implement health and safety regulations involving railroads.
Several lawyers submitted opinions and testified in Benicia City Council hearings held on April 4 and 5 challenging Hogin’s interpretation. And in one of the hearings, Berkeley City Council member Linda Maio told her Benicia counterparts that the city council has the right to make its own land-use decisions. “This is in your town and you’ve been elected to see to the health and safety of your citizens,” said Maio.
Valero and its critics have been arguing about the extent to which Benicia’s authority is preempted by federal law since last summer. After the planning commission rejected Valero’s project in February, the company showed up at the March city council meeting with a surprise request: that the council delay voting on the project until Valero has a chance to make an appeal to the federal Surface Transportation Board (STB), which regulates railroads.
That didn’t sound right to Benicia resident Andres Soto, who works for Communities for a Better Environment, an environmental group opposed to the project, so Soto called the STB and talked to staff attorney Gabriel Mayer. In a report Soto submitted to the city council, he wrote that Mayer told him that the STB is not the final authority on federal preemption, and that the state and federal courts serve that purpose.
Soto also said that the STB deals with disputes among railroads, and since Valero is not a railroad, it’s unlikely the agency would take its case. Many speakers at last week’s hearings urged the city council to deny Valero’s bid for a delay and reject the project immediately.
But project supporters emphasized the economic benefits of bringing crude oil by rail to Benicia. Berman Olbadia of the Western States Petroleum Association, an oil industry lobbying group, said that Valero creates jobs and generates tax revenue. Michael Wolf, of Ageion Energy Services, said that oil by rail reduces California’s dependence on foreign oil.
Later, however, Greg Karras, senior scientist at Communities for a Better Environment, said North American crude would create serious new problems that the environmental reviews for the Valero project did not address. Canadian tar sands produce very heavy oil with an extra load of toxic chemicals, said Karras. In addition, refining tar sands oil would dramatically increase the refinery’s emissions of carbon dioxide, the main pollutant causing global warming. The other major type of North American crude from North Dakota’s Bakken fields produces highly explosive oil. Trains carrying Bakken crude have been involved in a number of fires and explosions.
People from “uprail” communities have also turned out at Benicia hearings to oppose the Valero project. “The oil trains will pass through our downtown and pass my house,” said Frances Burke, a resident of Davis. “We will have the fumes and particulate matter from increased daily trains. I’m also a potential victim of a deadly accident, explosion, or derailment.”
Benicia resident Bardet said the project site is especially dangerous because the crude-oil-offloading tracks would be “adjacent to crude oil storage tanks and Sulphur Springs Creek, in a flood-plain zone and active fault zone, and also directly across from the industrial park along East Channel Road.” According to Bardet, derailment or fire involving flammable crude oil could have catastrophic results.
College student Jaime Gonzalez said the project would further proliferate fossil fuels, which accelerate climate change, and that future generations will bear more of the burden. “The consequences would fall on the shoulders of my generation,” he said.
Hearings will continue April 18 and 19 in Benicia, and the city council will then decide whether to wait for Valero’s federal appeal, or vote to approve or deny the project.
Council Hearings this week: 77 informed, articulate and often passionate speakers critical of of Valero Crude By Rail
This past week, the Benicia City Council heard public testimony for and against Valero’s Crude By Rail proposal – mostly against. Video of these comments can be found on the City’s website.
On the two dates combined, Council heard 77 highly critical comments calling for outright rejection of Valero’s proposal or at the very least a much revised and recirculated environmental report. Only 16 speakers favored Valero’s proposal.
On Monday, April 4, Council heard from 52 speakers. 41 were highly critical or completely opposed to Valero’s proposal, and only 11 spoke in favor. Of the 11 in favor, most either work for or provide services for Valero.
Here is a listing of the 41 who spoke in opposition on April 4, followed by a listing of 36 such speakers on April 6:
MONDAY, APRIL 4 (41 who spoke in opposition)
8 elected and appointed officials from beyond Benicia
1 State of California elected official: Alex Pater, representing Benicia’s State Senator Lois Wolk
4 from uprail communities
Don Saylor, Yolo County Supervisor and Sacramento Area Council of Governments past Board chair
Matt Jones, Yolo Solano Air District, representing 7 air districts: Butte, Feather, Placer, Sacramento, Shasta, and Yolo-Solano
Eric Lee, City of Davis planner
Laurie Lipman, representing Ellen Cochrane, Sacramento Unified School District Board
3 from the East Bay
Linda Maio, Berkeley Vice Mayor
Jesse Arreguín, Berkeley City Councilmember
Alejandro Soto-Vigil, representing Berkeley City Councilmember Kriss Worthington
18 residents from uprail communities of Sacramento, Davis and Dixon:
Chris Brown, Chris Brown Consulting, Sacramento, representing 30 who rode the bus from uprail communities tonight
Maura Metz, Davis
Jean Jackman, Davis
Maria Cornejo-Gutierrez, Dixon
Laurie Lipman, 350 Sacramento
JoEllen Arnold, Sacramento
Jan Rein, Sacramento
Rob Lain, Sacramento
Estevan Hernandez, South Sacramento
Kathleen Williams-Fossdahl, Davis
Jaime Gonzales, Sacramento, Board of Directors, California Student Sustainability Coalition
Carol Warren, Dixon, slides of her neighborhood along the tracks
Don Mooney, Davis, Environmental attorney
Samantha McCarthy, Davis, lives very near the tracks
Frances Burke, Davis, lives very near the tracks
Elizabeth Lasensky, Davis, powerpoint: From Davis to Benicia: Our Lives Are on the Line”
Marilyn Bardet, Benicians for a Safe & Healthy Community
Demonstration roll of local petitions collected by Benicians for a Safe and Healthy Community
Andrés Soto, Benicians for a Safe & Healthy Community (While Mr. Soto spoke, members of BSHC unfurled a demonstration “scroll” of original hand-signed petitions that stretched 4 times the length of the aisle in Council Chambers (see FACEBOOK video). As he concluded speaking, Mr. Soto submitted for the public record BSHC’s list of 4,081 signatures of opponents of the project.)
Madeline Koster
Teresa Ritz
Carol Thompson
Bart Sullivan
Rick Stierwalts
David Jenkins, Benicia Industrial Park business owner
Kathy Kerridge, Benicia Community Sustainability Commission member
June Mejias
Pat Toth-Smith
Kat Black, Chairperson, Benicians for a Safe and Healthy Community
WEDNESDAY, APRIL 6 (36 who spoke in opposition)
On Wednesday, April 6, Council heard from 41 speakers. 36 were highly critical or completely opposed to Valero’s proposal, and only 5 spoke in favor. Of the 5 in favor, most either work for or supply services for Valero.
Here is a listing of the 36 who spoke in opposition on April 6:
7 experts, attorneys and organizers
Valerie Love, Clean Energy Campaigner, Center for Biological Diversity
Elly Benson, Attorney, Sierra Club
Ethan Buckner, Extreme Oil Campaigner, STAND (formerly ForestEthics)
Greg Karras, Senior Scientist, Communities for a Better Environment
Roger Lin, Attorney, Communities for a Better Environment
6 Benicia business owners, including 3 from Benicia’s Industrial Park, 2 from the Arsenal District and 1 from downtown
Giovanna Sensi-Isolani, owner of Fiber-Frolics, downtown Benicia
Jack Ruszel, owner, Ruszel Woodworks, Benicia Industrial Park (adjacent to the tracks, no access if blocked in emergency)
Hadieh Elias, owner, principal and professional engineer, ESE Consulting Engineers, Inc., in Benicia’s Arsenal District
Amir Firouz, principal and structural enginner, ESE Consulting Engineers, Inc., in Benicia’s Arsenal District
Ed Ruszel, Ruszel Woodworks, Benicia Industrial Park (adjacent to the tracks, no access if blocked in emergency)
Jennifer Kalika Stanger, M.D., family physician in Vallejo, lifetime Benicia resident
22 residents, including 20 from Benicia and 2 from other communities. (Note that 7 of the above listed April 6 speakers are also from Benicia, making a total of 29 Benicians.)
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