Category Archives: Environmental review

Benicia City Council, Carbon emissions, Crude By Rail, Environmental Impacts, Environmental review, Local Regulation, Public Health, Refinery emissions, Valero Crude By Rail

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.

SIGNIFICANT EXCERPT:

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.

Benicians for a Safe and Healthy Community, Crude By Rail, Environmental review, Public Health, Public permitting, Public Safety, Valero Benicia Refinery, Valero Crude By Rail

2014-2016 Comments on Valero Crude by Rail by Benicians for a Safe and Healthy Community

By Roger Straw, March 10, 2016

Formal comments on Valero Crude by Rail by Benicians for a Safe and Healthy Community

I have been asked to make it easier for people to access the several important contributions made by Benicians for a Safe and Healthy Community (BSHC).

BSHC is an informal group of Benicia residents who first gathered in January of 2014 to oppose Valero’s dirty and dangerous Crude By Rail proposal.  At each step along the way, BSHC has contributed significant public comments on the City of Benicia’s environmental review. See below:

 

Benicia Planning Commission, California Environmental Quality Act (CEQA), Crude By Rail, Environmental Impacts, Environmental review, Final Draft Environmental Impact Report (FEIR), Local Regulation, Public Safety, Valero Benicia Refinery, Valero Crude By Rail

Sacramento Area Council of Governments (SACOG) highly critical of Valero oil train EIR

By Roger Straw, February 5, 2016

BREAKING: Sacramento Area Council of Governments (SACOG) highly critical of Valero oil train EIR

SACOGThe Benicia Independent is in receipt of a Sacramento Area Council of Government letter sent on February 4, 2016 to the City of Benicia, but not as yet posted on the City’s website. The letter is severely critical of the City’s Final EIR, and calls for the Benicia Planning Commission to “provide full and adequate responses to our comment letters,” and “to fully evaluate all measures to mitigate the significant environmental impacts that this Project will inevitably have on our communities and our residents.”

The letter is signed by SACOG Immediate Past Chair Don Saylor.  SACOG represents 22 cities and 6 counties in the Sacramento area.

The letter begins by summarizing  two previous letters sent to Benicia, one in 2014 commenting on the original Draft EIR, and another in 2015 commenting on the Revised DEIR.  The 2015 letter claimed that the City did not adequately respond to their first letter.  “…we submitted a second comment letter citing the mandate in the California Environmental Quality Act (CEQA) to describe all mitigation measures that could, if implemented, minimize significant environmental effects. (CEQA Guidelines, §§ 15 I26(c), 15126.1 (a).) We urged the City to adopt all feasible mitigation measures that will protect our communities before the catastrophic events forecast by the RDEIR occur. We noted that nearly one quarter of our region’s population lives within one-half mile of the crude oil shipments.”

This new 2016 letter continues with criticism of the Final Draft EIR, “…we appreciate that the City finally acknowledges the substantial risk to our region resulting from the crude oil shipments. However, the FEIR still fails to adopt a single mitigation measure to address the impacts of the Project and the FEIR fails to adequately respond to our letters.”

The letter concludes with five detailed examples of “the inadequacies and misstatements in the Responses to our comment letters.”

Taken together, these inadequacies point out what may be understood as “fatal flaws,” indicating that the EIR should be revised and recirculated yet again, or thrown out for a fresh start.

Or … as in my opinion, the project should simply be dropped.

California State Water Project, Crude By Rail, Derailment, Environmental review, Feather River, Feather River Canyon, Valero Benicia Refinery, Valero Crude By Rail

Letter from the Mayor of Oroville opposes Valero-Benicia oil trains

By Roger Straw, The Benicia Independent, December 18, 2015

City of Oroville, California – and others – oppose Valero Crude By Rail

Late this afternoon, the City of Benicia posted yet another batch of letters opposing Valero Crude By Rail.

The first letter in this document is significant: it comes from the mayor of the City of Oroville, CA, which is located near the Feather River Canyon and at the head of the California State Water Project.  The letter concludes with

The Oroville City Council and the citizens of the City of Oroville ask Valero to reconsider their proposal to deliver North American crude oil by railcar “uprail” from the Nevada border and down through Roseville to the Benicia refinery due to the potential devastation of California wildlife, water resources, and air quality.

The remaining 12 letters are CREDO Action letters from individuals all over California, also opposing Valero CBR. (These 12 can be added to the previous 2,062 similar letters sent by CREDO supporters.)  I don’t have an exact count, but there were also a LOT of letters generated by the Center for Biological Diversity and by ForestEthics.  We aren’t alone here in Benicia!

For these letters and many others, see our Project Review page.