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CONSIDERATION OF ORAL AND WRITTEN COMMENTS ON THE FINAL EIR FOR ARCO COAL OIL POINT PROJECT

SANTA BARBARA COUNTY

The Following people testified before the Commission:

William Wallace, Ch~irman Sarata earbara County Board of Supervisors

John Cohan, Senior Deputy County Counsel

Honorable Sheila Lodge Mayor, City of Santa Barbara

Paul Aiello Jordana, Inc.

Leo Jacobson Isla Vista Resident

Daniel G. Aldrich, Jr. Chancellor, UC, Santa Barbara

James Case Professor, UC, Santa Barbara

Alice Alldredge Pr~fessor. UC, ?anta ~arbara

Al Ebeling Prciessor, UC, Santa Barbara

A. E. Nash ucse Ac~demrc Senate

Giles Gunn Professor, UC, Santa Barbara

Mark Srednicki Associate Professor, UC, Santa Barbara

Sally Holbrook Professor, UC, s~~t~ Barbar-a

Q,~Ytd Gsbhard ?rofessor, UC, Santa Barbara

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Marty Blu~. President Leagu~ of W~men Vot&rs

Richard Ranger ARCO Oil and Gas Company

Mike Webb Anthros~here, Inc.

Maz-c Euans ucsa Student

P&ul Steinberg. ucsa. Student

P'aul Herzog ucsa Student

Michael Herald iJCSB Student

Francine Allen UCSB Student

liahna Gordon UCSB Student

Ken Brucker UCSB Student

Emilio Pazzi UCSB Student

Judy Dunhill ucsa Student

Curtis Anderson President, Isla Uista ~ssociation J'ani"'e Keller Ge·'- '•il Out, Inc.

Roger lagerqufst Isla Vista Re~ident

Robert Sollen Sierra Cll.!b

Nigel Buxton Isla Vista Rental Committee

Alan Hur Commercial ·Fisherman

Michael Stoker Chamber of Commerce

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Michael McDermott Santa Barbara Resident

Martin Kellogg Isla Uista Resident

Robert Klausner Citizens Planning Association

Gary Faus"ne UCSB Student

Kimberly Coy Isla Vista Resident

Greg Thayer Camp Bartlett Resident

Evan Oliver Santa Barbara Resident

joan Michelsen uese student

Sonja Hatch UCSB Student

Debor~h Brown UCSB Student

Marc McGinnis General Counsel, justice Department

Don Barthelmess Operations Supervisor Interna'tional Underwater Contractors

Lee Dyer UCSB Student

. Larry Davidson UCSB Student

George Obern President, Hope Ranch Park Homes Association

Michael Boyd Isla Vista Recreation and Park District

Deu Urat Energy Division, County of Santa Barbara

Mark Walker UCSB Student

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janet Franklin UCSB Student

M. V. Scherb Safety Consultant

Robert Uatter Santa Barbara County Fi~ Department

Yasmin R~driguez UCSB Student

Hal Kopeikin Resident

Viuian Obern Executiue Se~retary Santa Barbara County Trails Association

Michael Phinney Isla Uista Resident

Sean Dur~in Isla Uista Resident

Sue Higman Isla Vista Resident

Upon motion made by Chairman Dauis, ahd unanimously approved, the Commission uoted to consider certification of the Environmental Impact Report within the first ten days in March in Santa Barbara.

1/19/87

. Attachment: Staff Report

Ja~uary 19, 1987

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CUI• T. CIUNllCIC I I d sCMllw

TO: MEMBE&S OF THE CALIHORNIA STATE LANDS COMMISS~ON SUBJECT: Coal Oil Point Project SUllS3ary an~ Issue Re~eonses

'The attached materials have been prepared by the co-iasion staff as a means of assis~ing· the Cpaissioners i-n better understanding the c~itical ias~es which have been raised by local governm~t: officials, the Unive:sity of California, Santa Barbara, and the public rel•t:inq to ARCO's oil developaent at Coal Oil Point in the Santa Barbara Channel.

A ••jority of the •aterial deals specifically with issues and questions rais•d du~tng the COllllisoion•s public hearing in Santa ~arbara on January 13, 1987.

The secti.ons. contained which was

information in this package is divided into three Section l contains a SWlllary ·of various elements

in the finalizing addendum to the project Ent/EIS released on ~anuary 13, L987.

The second section contains a project su11111ary as proposed by the ap_plicant, inc:lu~ing ARCO's various alternatives, as well as alternatives propQsed by t:he County of Santa Barbara and the consultant's enviroilJlentally preferred altern~t~ve.

The third section of the •aterial c:overs ten specific: issues which were identified during the Co••ission's public hearing on January 13, 19~7. Each issue is fully defined or explained in terms of its relationsQip to the Coal Oi'l Po~nt project. Th;;.s explanation l.s ~~llowed by a su.aary of the concerns voiced during the hearing,. followed b7 a ·sta.te?Aent of the reco~~ded aitigation aeasu:es taken ~ro• the final

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'ti!R/EIS and any additional State Lands Commission staf·f comments which were felt to be useful to the Commissioners in further understanding how a particular c-oncern might u=ltimately be resolved.

According to the Commission's direction~ this material does not contain· Stat€ Lands Commission ::staff recommendations on the coal Oil Point project. These ~ecommendations t·1ill ,be included in a memorandum to Commissioners which is due on February 9, 1987 and will also i:ne1ude responses ~o new issues raised. iiu.ring the commission's public hearing ·in Santa Barbara on January 28, 1987.

MZfjM b..AIRE T. DEDRICK Executive Officer

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I. PINALIZING ADDENDUM CONTENT SUMMARY

The finalizing which was released on EIR/EIS, constitutes proposed project.

addendum to the coal Oil .Point EIR/EIS January 13, 1987, together with th• Draft the Final EIR/EIS (EIR/EIS) for the

The addendum to the Draft EIR/EIS serves four primary purposes. First, it provides a formal r:ecord of the writte.n comments and public hearing testimony concerning the Draft which was received during the public review phase of the environmental process. Second, the addendum offers responses to the comments which were received during this review process. Next the addendum includes any changes to the Draft EIR/EIS which were necessary as a result of the review pr_ocess and further analysis of the project by the consultant. Fi:nally, the addendum includes an updated analysis- of the various project components wherever nec.assary, due to changes in the regulatory environment. The addendum also ~ontains the consultant's environment~lly preferred- alternative {.or th~ proj~ct. -

Vqlume I contains three sections. Secl:ion l provides a reader's guide to the finalizing addendum as well as documentation of the review process of the Draft ·EIR/EIS. It includes a fully r~vised executive summary and :!::::?d'ct summary tables reflecting the various comments on the Draft EIR/EIS as well as the changes necessitated by the response to com~~nts.

Section 2 contains supplemental information o~ the potential impacts if Exxon's Santa Ynez Unit processes· oil off.shore in the OS&T rather than in Las Flores canyon. Tl'f1!re is· -.!lso a section summarizing the identified impacts of \-tie Coal Oil Poin~ Project on the community of Isla Vista.

Section 3 is a supplemental study of air quality impac~s if Exxon processes oil offshote. Thi~ material was pr~pare~ ~6 docu~ent conclusions concerning ~*xon's changed project discussed in Section 2.

Volume II (Section 4) of the document is a recot:d of comments to the Draft EIR/EIS and the responses to these comments. These comments and responses have been divided into nine sections by agency type, organization, individuals,. and public hearing comments for the purpose of providing an organized response to all comments. Each section first provides a record of comments tc the Draft ElR/EIS that ari:! code numbered by agency type~ Responses to each comment are provi~ed in tha back of each subsection.

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Volume III contains the final three seqtions of the repor.t. Section 5 provides corrected pages to the Draft EIR/EIS. Section 6 contains corrected pages for the Technical Appendices. Cpanges in the te>'"t were noted through the crossing out of verbiage to be deleted and the underlining of all added text.. 3ection 7 con1;ains two .supplement.al r~'liews prepared in response to comments submittad on the Draft EIR/EIS.

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ARCO l J!' OIL POINT PROJECT STATE LANDS COMM!SSION

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II. COAL OIL POINT DEVELOPMENT DESCRIPTION OP APPLIC~..NT'S PROJEct'

A~U O~HER ALTERNA~IVES

The Draft EIR/EIS analyzes the "No Project" alt~rnacive, the prGject as proposeg by ARCO, seven alternatives to various aspects of the project as proposed ~Y ARCO and. over 250 possible permutations of the prcject~ The pr.oject as proposed by ARCO and the seven r~lated alternatives are described below.

PROJECT PROPOSED BY APPLICANT

ARCO propo~es to develop a new off shora oil and gas ¢1iscovery site adjacent to the Sapta Barrara ~o~st and the University of California, Santa Barbara ana the unincorporated community of Isla Vista. The development invol'ves st·ate 0·11 and gas leases PRC 208, 308, 309, 3120 and 3242 which wet-e' issued by the commisston in 1946, 1947, 1964 and 1965.

The applicant proposes either to commingle or segregate ·the produced oil for processing at El'lwood. Although·• ARCO favors c9r.uningling of its own 1.-eases, they have stated they would oppose commingling of its oil with oil from other lessees. Each of these options provides for free water knockout of the oil offshore on each of the platforn.~ and d~hydration of th

0e wet oil emulsion to pipeline quality onshore

at the existing Ellwood facility. Under the segregated opti·on for each of the five (5) leases,, oil production would be­segreq~ted on the plat£ orms and processed onshore in separate proceseing trains. This option a~ proposed by the applicant would use 5 new pipelines in addition to the existing pi.?e'J.i:ne for transport of the oil emulsion onshore. The use of fewer new pipeli~es is feasible. The commingled option as proposed by the applicant would us~ 2 new pipelines.

The app_\icant proposas to use three double platf_9rm complexes. The double p:lat".focm complexes are composed of a drilling platform and a, production platform connected by a bridge. Each platf~rm component woul~ m~asure lQO feet by 120 feet and have two (2) decks. The lowest deck would be 50 feet above t.he wat~r and the top aeck would be 25 feet above the lower deck.. The drilling derrick mast height would be· 250 feet above the water level. The applicant ''s proposal provides for i: ree water knockout of the oil on the proouction component of each complex.

The applicant proposes to remove its existing· gas pi:ocessing operation f.rom Ellwood ~nd to process all the sweet and sour gas at a new gas proc1essing facility to be ctmstructed at La$ Flores canyon.

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A; peak production the three platform complexes proposed by the applicant would produce up co 80,000 barrels of oil per day, up to 60 million cubic feet of as~ociated sour gas per day "nd up to 90 million Gubic feet of sweet ga~ per day.

ALTERNATIVES PROPOSED BY AP_PLICA~T _AND EXAMINED BY THE EIR/EI§.

At the request of the Commission's~· staff a~1 Santa Barbara county the applicant submitted enqineering deS. .gns .for seven alternatives to thei~ proposed project. Under all the alternatives describ~d below, the estimated peak production and value of products is the same as for the applicant's pi:opcsed pr.oject. Under any alternatives which would result in p,rocessing at a facility other than Ellwood, the applicant would maintain their existing g~s p:ocessing facility at Ellwood.

1. Single Platforms

Under this alternative ARCO would construct thrA!e single platforms each measuring 180 feet by 180 feet. Each platform would have three de~ks with the fi1:st deck located 50 feet above the water line and the top deck located 60 feet abo~e the lower deck. The drilling derrick m~st height would be 295 feet ~bove the water level. ·

This alternative provides for free water knockout of the oil on each of the platforms and dehydration of the- wet oil emulsiQn to pipeline sales quality onshare at the existing Ellwooc facility. The applicant prpposes to use 2 nf,w pipelines to bring tha oil emulsion onshore.

2. Total Offshore Oil De_QY~a~ion

Under this alt-arnat1. ve ARCO would construct three double platform co~plexes. Each production component of the platf otm complex would measure 130 feet by 205 feet and ~ould have three decks with the first aeck located about 50 feet above the water line and the top deck located about 60 feet above the lower deck. The drilling component of the platform complex would measure 120 feet by 180 feet and would h~ve two decks with the first deck .located SO feet above the wat·er lina and the second deck 25 feet above the lower deck. Th~ drilling derrick mast height would be 2SO feet above the water level.

The applicant's proposal provides for dehydration of the oil to pipeline sales quality on each platform and transport af the dry oil onshore for temporary storage at Dos Pµeb-los and transport out of Santa Barbara in the Celeron-All American pipeline. The at;>plicant proposes to use 2 new pipeli'nes to bring the oil onshore.

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3. Commingled Oil Processing at Las Flores canyon

Under this alterr.ati ve the applicant proposes to construct a commingled oil processing facility in La~ Flo-ces canyon. The wet oil emula~on would be comminq1ed offshore and transported· onshore in 2 new pipelines to landfall at Ell'l:~od and transported from Eli~ood in a single pipeline to Las Flor~ Canyon for final dehydration.

Under this option ARCO proposes to use either double pla~form complexes or single platforms as discussed above.

4. Gas Processing in Venadito canyon

For this alternative the gas processing fac~lity required l;>Y the p!:oject is located in Venadito canyon instead of La·s Flores Canyon. Fgr analysis purposes, the design and operation C?f the facility are assumed to be the same as that in La~ Flores C~µ:;-on.

5. Placement of Oil Pipelines to Las Flores Canyon in Of £shore Gas Pipeline corridor

This alternative uould, place one to three pipelines (depending upon whether a commingled -or seqreg~ted system is used) within the same corridor a~ the proposed g~s pipelines to Las Flores canyon. The offshore pipeline corridor would require expansion in width QY 100 to 300 feet for one to three pipeli·nes re~pecti vely. Tfi';;:; alternative would also assume that the crude oil pipeline between Ellwood and Las Flores Canyon and the Dos Pueblos South storage facility would nq~ be constructed.

6. Placement of Gas Pipelines to Shore at Ell~ood and then within the tjnsh~~e ~ipeli~e Corridor to Las Flores Carifo~

This alternative would place the proposed sweet .and sour gas ~1pelines within the offshore pipeline corr~dor to Ellwood and , then overland within the oil pipeline corridor to Corral ~r-?.ton. .~n expansion of 100 to 200 feet (30 to 61 m} in offshore corridor fro~ Holly ·to landfall at Ellwood would be required. It is expected that the onshore portion of the p;peli1·1e wou~d be accommodated within the 100-foot wide corridor. This alternative would eliminate the gas pipe1ine corridor from Haven ~o landfall ~t corral canyon.

1. Oil Storage at ~a~ Flor.es Canyon

This alternative. would el~inate oi~ storage at Dos Pueblos South but wauld provide compai:able wet and/or

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e processed crude oil storage at Las Flores Ca:nyon. This storage facility would be located at the proposed Exxon ma~ine terminal tankage area east of Corral canyon.

SANTA BARBARA COUNTY'S PREFERRED ALTERNATIVES

In testi~ony given to the Commission on January 13, 1987 Dr. William Wallace, Chairman of the Bo.rtrd~ ~1:ated that tne-·, Board supported the following as alternative~ to the project-:-

1. single platforms; 2. removal o~ Platform Heron; 3. onshore rather than offshore process!.i.'191· 4. commingled transportation and processing as opposed.

to th~ ~egregated option; 5. developme~t of alternatives to flaring; and 6. prohibition of onsite dischc.:rge of muds and ¢uttin9s.

EIR CONSULTAN'rS IDENTIFIED ENVIRONMENTALLY PREFERRED ALT~~TIVE" (CEQA Guidelines section 15126)

The consultant recommends that two single platforms (Heron and Haven) be constructed along with one double platform complex (Holly A-B).. The single platforms would' bave the same size and config~ration as those proposed by the applicant in alternati-ve A and the double platform complex WO\lld be the same si~e as proposed by the applicant in alternative B. This propo. al woulq provide for all oil to be dehydrated off shore at tbe Holly A· , complex. 'rhe oil · could be processed in a c~.~in9led or segregated conf!guration. The dry pipeline q~ality oil would then be transported onshore to a consolidated storage facility at either Las Flores Canyon or Gaviota. The consultant has recommended the ruinjection of all sour gaa:. 1he processing of the sweet ~as wo~ld occur offshore.

The consultant recommends~ (l) against the off.shore di-sposal of muds and cuttings; and (2) the phas~ out and eventual shutdown of the Ellwood facility.

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III. ISSUES AND RESPONSES

The following material responds to ten of the most critical issues raised by a significant number of the inditJ-idua·ls who appeared before· the Commission at the public hearing in ~anta Barbara on January 13, 1987.

1. PRODUCED WATER

General Definition of the Issue

Produ~ed water is the water produced with crude oil from the subsurface reser.voir. The water is separated from the crude oil by emulsion breaking chem~cals and heat applied during dehydration. This produced water is normally a brine prima~ily containing sadium chloride, ·with traces- of other materials such as ammonia. Neither the applicant's proposed project nor the consultant• s preferred alternative as detailed in the final EIR/EIS would result in any produced water being discharged into the ocean. These proposals call for the reinjection of produced water into geologic formations which. do not contain fresh ·water. The Las Flores canyon oil processing alternative favored by the County, is the only prop\l)sal ~hicb wo\llc:1 result in produced water, after treatment, _being discharged into the ocean through an ocean ou~fall. Such a

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discharge would have to comply with conditions specified by the ~ permitting agency, and the Regional Water Quality Control Board. ~

General Impacts Identified in· EIR/E~S

Although the EIR/EIS analysis for the Las Plores Canyon alternat·ive identified no immediate lethal impacts to marin~ organisms from the treated produced water, it is possible -that marine organisms could be affe-Cted over a prolonged period of time by regular discharges of thd.s treated by-product. The data base on these subJ;et;hal ef £ects is limited and therefore the exact extent of the pot~ntial damage is unknown. Sine~ there is a potential for si9nif icant impacts and since the location of the autf all is hear Naples Reef, a prime reseatch area for UCSB marine biologists, impacts associat•d with produced water discharge ar•! considered significant under C!QA ~uj.delines.

Impacts to rsla Vista

If the County's Las Flores canyon alternat.tve is selected, the proposed produced water outfall would be located at the muuth of corral Canyon which· is several miles west of the community of I-sla Vista. The~i-·.fore, no impacts would occur at Isla Vista. ·

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~ Mitiqations

Impacts associated with the disposal o'f produced water from the Las Flores facility can be mitigate~ by r·equiring t!lat ·· the appl~cant d"ispose of produced water via ~.njec:tion wells at Dos Pueblos South or Ellwood as proposed in the other alternatives considered in the EIR/EIS.

2. NO~

General Definition of the Issue

Off shore and onshore facilities will generate noise during construction, operation and abandonment activities. The EI.R/EIS included field .measurements of existing noise levels near all facilities as well as modeling of noise impacts from new facilities. ·

Two types of noise impacts were identified:

l. General noise impacts engines, compressors general, these levels and,

from sources such as diese..l or other equipment. In

remained relatively CC.ll~tan~:

2. Impact noises; thos~ instantaneous noises produced by such activities as flaring, pile driving and other operations where metal clangs agai:1st metal ..

It is entirely possible that under some atmo~phe~ic conditions, noise from the project, i~~i~~ing human voices, could be heard by onshore residents and still not reach significant l&vels as defined in the EI.R/EIS. ~be methodology used in ~he EIR/EIS is consistent with the Santa Barbara county Noise Ordinance and with qther environmental reports prepared for the region.

General Impacts Identified in the EIR/~IS

The EIR/EIS addresses in detail the issue of noise resulting f:om construction and operations on the platforms.

Noise levels are commonly measured in decibels (db). In order to better upderstand the impacts discussed in this material, the following list of common noise levels is given to place the discussion of sound measurements in perspectiv~:

Activi,tY

Whispers Quiet Gf fice Average conversation

at 3 f~et Noisy Stenographic Room Train passing at 50 feet

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30 dB (A) 40 JB {-A)

65 dB (A) 73 dB {A) 90 dB {A)

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Noise associated with platform installation wil'l cause _a adverse impacts at the shoreline. The piledriver used to drive ·~ the piles to anchor Platform Heron will, for example, produce a metal to metal clanking sound of approximately 50 dB (A) at the shoreline. This will increase noise levels by ~pproxirnately 7 dB (A} above background level which is 43 db (A} during the quietest condi~ions. Ot~er anticipated· noises during platform construction are expec~ed to raise the lowest background noise level at the·shoreline by no more than 3 dB (A).

Onsho1:e constru~tion of the oil progessing facility at Ellwood and the onshore pipelines will also cause disturbances. Noise generijlted during const·ruction of the Ellwood facility will raise levels to 73 dB {A) at the Sandpiper golf course.. Onshore pipeline construction will raise noise levels to 87 dB (A) at the same location and off shore pipeline constructton will raise noise levels to 70 dB (A).

Operation of the platforms will also cause noise to be beard at the shoreline. This will occur particularly during drilling operations. The noise impact will result from the metal to metal clanking of equipment.. Noise levels from this activity will be about 50 db (A), 1 above the lowest background level. Flaring will not result in noise impacts at the shoreline. The EIR/EtS analysis indicates that the noise from flarinq (approximately 63dS(A) > at the platform will diminish to ,a level beJ.ow the background noise leYel. at the shoreline of 43dB(A).

Impacts to Isia Vista

The general discussion of noise impacts above ~re applicable to Isla Vista.

Mitigations

No mitigation measures are available to reduce direct metal-to-metal impact noise~ to insignificant levels. aowever, it is Sta~e Lands Commission staff~s opinion that general operational noise levels may be reduced througp additional mitigation measures such as structural enclosures and the use of equipment buffering materials.

Moving the platforms further offshore would reduce the magnitude of impact noise, but would not reduce this impact ~o ~~significant levels.

3. AIR QUALITY (Odors, Flaring·)

General Definition of the Issue

Air pollution is a con<;.ern in the Santa Barpara-ventu·ra area because the area cur~ently exceeds Federal and State standards for total suspended particulates (TSP.-> and oxidants.

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Under the regulations of the Santa Barbara County Air Pollution control District (SBCAPCD) ,. the permittin9 agency - for air qu~ity, a net air quality benefit to the area mu$t occur as a result of project approval.

The project will be a major contributer of emissions of ni.trous oxides (NOx)., reactive organic ga·ses (ROG}, sulfur oxides ( S01d , TSP, and carbon monoxiae <co.) • NOx and ROG a-re imt>ortant pollutants because th~y ar.e necessary components in the.formation of oxidant-

Odors result from the emissions of hydrogen sulfide .(-H2S), methyl me.i;captans, and sulfur dioxide. Acid rain and acid fog are also of concern.

General Impacts Identified in the EIR

Oxidant, N02, TSP, and odor impacts were 4efined in th~ EIR/EIS. Generally, the impacts of all alternatives were comparable. The impacts v~ried depending on the locatiotts of the various oil and gas processing facilities.

Air quality impacts duxing -construction are short-term and localized and while they may affect average yearly emissions, the impacts will not continue to occur once const~uction is CFmpleted.

Under regular operating conditions, when ~11 equipment is operating properly, the EIR/EIS -predicts minimal emissions. Under emergency conditions caused by sho~t-term equipment f~ilut~ or malfunctions, the ~elease of more significant ~missions is anticipated which would continue unt~l the emergency condition is repaired and routine operations a~e ~esumed or the plant is shut down completely.

Although the project as originally proposed by the ~ applicant could result in long term significant air quality impactsr the applicant cannot obtain a permit from the SBAJ?CD unless a ~ fil guality benefit is demonstrated. The EIR " identified extensive mitigation measures which cqul? be used by the applicant to me~t the standards set by the SBAPCD.

Flaring

Flaring resulting from the 'lllalfunction of platfOfii:t equipment occurs infrequently. The flare is used to cornbust released gases ~nd is 99.0\ to 99 .. 5\ efficient in converting H2S to S02. 502 is not a problem in t~e air basin. Flaring would have a visual impact which can QnJ.y be mitigated by reducing the time required to J:epair equipment.

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Odors

Even under irregular operating conditions and worst case meteorology, odors from the offshore platforms would dissipate to levels not detectable by humans before they reached the ~horeline. Significant odor impacts were, ~owever, identified for all onshore a-il and gas processing facilities when upset conditions occurred.

Other Air Quality concerns

Toxic pollutants f OL which there are no standa·.tds an.~ pQtenti-al acid rain or acid fog were also considered in. the E!R/EIS. No impacts were predicted from known toxic materials. The situation for acid rain and acid fog is., however, more difficult to predict.

While some of the chemical and physical mechanism~ leading to the formation of acid in atmospheric water droplets are known, the phenomenon is not well understood. cause and effect relat;ionships are difficult to establish. Components necessary to the formation of acid in the atmosphere will be emitted by the project, namely sulfur dioxide (which may react to form sulfuric acid) and oxides of nitrogen (which may react to form nitric acid'). Thus, there is ·the potenttal for formation of acid rain or acid fog in the region from pollutants emitted by the project or other projects. ~

However, no acid precipitation problem has been identified in the san~a B&rbara and Ventur.a County areas. Components necessary for the formation of acid rain (N03 and S03) do not occur in high enough concentrations in the area .• Therefore, there is minimal potential for significant impq~ts Qf acid rain.

Impacts to Isla Vista

Generally, Isla Vista will expa~ience air quality impacts s;milar to those experienced by otl'Jer communities alonq the south coast of Santa Barbara county.

Residents of I·sla Vista currently detect odors that have been' attributed to the seeps, Platform - Hol'ly, the 1.Rco marine terminal lca~ing operations 9r some combination of these sources. Modeling conducted for the EIR/EIS inch.c.,,ted that odors from the new offshore facilities wou-ld not be "'Oetectable in Isia Vista. ~ is possible that odors from upset conditions at ~n Ellwood oil and/or gas proces~ing facility could be detected in Isla V·ista unde~ certain wind conditions.

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Residents have also indicated concern about acid rain an , acid fog. Given the available information on existing acid> precipitation conditions (there appear tc be none) and the amounts of precursors expected to be emitted by the project vl: other proj~cts7 it does noc appear that significant adid eain or acid fog attributable to oil development will occur in Isla Vista.

Mitigations

Mitigation measures differ s6m~what for construction and operation activities, although some mitigation measures- are applicable to both. Generally, these measures fall into two broad categories: 1) technical controls on emissions source~-?­and 2) operational controls on the scheduling and use of equipment. ARCO has agreed to mi-tigation measures which will meat the standards established by the local ai~ quality control distr.ict.

4. HODS AND CUTTINGS

~&neral Definition of the Issue -Dril-lin9 muds are the fluids used in the well bore to

·control the well flow, lubricate the drill string and bit during drilling, -and remove the material cut by the drill bit £rom the .bottom of the werl to the surface. D~ill cuttings are t'he reek fragments cut by the driil bit.

General Imeacts Identified in the EIR/EIS

The EIR identified many impacts associated with the db::c:harge of muda and cuttings. Among t:be most significant i'mpac:ta are bur~lin9 of hard bottom marin~ comlnunitiea, imp,act to the uni versi.ty sea water ifi!:.ak:e, contamination of Naples Reef, and adverse effects on commercial and othe~ marine species, among others.

Mitigations

The effects are most effectively mit;:i9ated by preventing the discharge of muds and cuttings at the pl~tform locations. Hauling the drilling muds and cuttings ~o shore or to a federa"l.ly approved offshore Clisposal site will eliminate the impacts. ·

5. COMMERCIAL PISB.ING "

General Definition of the Issue ' ,_

commercial fishing is an important activity within the Santa Earbara Channel. Fish species regularly sought in the

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area are lobster, halibut, sea bass, and the ridge-neck pra~, among others. Impacts to commercial fishing fall into four major categories. First, the exclusion of fishermen from an area on a temporary basis due to construction of facilities. second, the exr~usion of fi~hermen f rqm an area on a perm~nent basi.s due to the installation of platforms and pipe) . .Lnes. Third, the ongoing operational conflicts beJ;ween fishing vessels and vessels servicing the platforms: and fourth, damage to fishing equipment.

As an exampJ.e, the current installation of platform and pipelines in the Foint Arguello Field will affect loeal fishermen over a period of six to twelve months. At the peak period of construction, ten to twelve vessels were involved and conflicts with fishing vessels did occur. However, damages have been compensated according to the terms of their perm±ts.

General ImJ?acts Identified in the EIR/EIS

The EIR identified significant impacts upon ~be activitl:es of cqmmercial fishermen. Exclusion of c;-i.lln~tt.:ers and trappers during the pt.~k f-ishing season &nd loss of fishing gear were addre~sed. 'l'he •:oal Oil Point a.rea is heavily ~is!l'a by gillnetters from Januat!r to March when halibut migrate :i.n,to the area. 'l'rap fishermen\ would be affected if construction activity Qccured after mid-October when lobster season begins~

D~<lile and loss of gear during construction were also considered during the devel.opment of the EIR/EIS-.

Loss or damage to the commercial fishing habitat wa$ also addressed. Disturbance of benthic habitats (or keip bed) during construction or operation could have significant effects on the productivity of commercial species and sub3equently affect commercial fishermen. Vessels- traveling through kelp beds could have considerable effect.

The EIR also addressed potential impacts on marictslture. A maricu~ture lease just off Goleta Point could be affected by discharges or oil spills from the pr~jec~.

Exclusion of fishermen from areas as a result of th~ placement of plat~forms is 'considered an adverse impact. The EIR also i;ecognizeq potential loss of_ fishing gear O'r traps 4qe to p~oj~ct vessel~- 'traveling outside of designated. corridot~:·_4,s v

a significant irnp4ct~

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...

ti} Mitigations

The EIR identified mitigations which would reduce the impact to commercial fishing to in~ignif icance. Scheduling construction act~vities of pipelines outside of principal ~ fisr,ing seasons in the az:ea, minimizing the construct.ion schedule, using cor£idors for pipelines and publishing and noticing construction for pipelines in advance will elimj,nate "" most of the adverse impacts assoc~ated with-construction-

Di1:ect compensation t.o fishermen for loss or damage of fishins gear or equipment is an effective miti9ation.

Other miti9at1on includes:

0.) Enforcement of vessel t.r.affic corridors.

( 2) Enforcement of an identified1 vessel corridor between Ellwood pier and the platfo~ms in ordersto ~liminate or lessen impacts to_the kelp beds.

(3) Restoration of damaged benthic habitats and kelp beds.

(4) Frevention of the discharge of muds and cuttings.

(5) Relocation of platform Heron off the hard bott~m. ( 6) Adoption of an Oil Spil'l Co_ntingency Plan apprpved

by St'ate Lands Commission. ·

( 7) Enfo~cement of the CownissiQn' s requirement for a Critical Operat:i.ons and Curtai.1,n:ent Pl,an.

·6. MARINE TERMINAL/PIPELINES

Gene?al Definition of the-Issue

Under ARCO's proposed project, the Ellwood marine terminal would be phased out following the completion of onshore connections to transport their oil out of Santa Barba~a via the a:,lJnost completed CelE1!ron pipeline. If any alternative i·s selected fer processing a,-.: "new" Ci:> al Oil .Point oil at a site other than Ellwood, such as at Las Flo~es-, . ex:.t.Sting production from Holly would remain at Ellwood_ and the marine termit1.al would not be phased out. There·· are no proposal..s t·o transport new production f.rom the Coal Oil Point Project via marine transporta~iono ~

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C\lENDAR PACE

MfNlJTE PACE

i!neral Is~acts Identif~ed in the EIBLEIS _

T~ use of the Celeron pApeline wc~ld eliminate environmental impacts generally identified with;- marine transpor·ta-tion such as air qualit.~y, oil spills offsho:ce., etc,. The Sllwood marine terminal is an existing facility.

Iapact4 to Isla Vista

see discussion of odors within Air Q1~a:lity. The imp~ct desc;ibed would continue if the op_erations of the existing

- .Ellwood marine terminal are maintained.

Mi:t.ir.iat:ions

,,

Mone specified for marine transportation as it is not o

part of the proposed-project.

7. RELOCATION or PLA'?!'ORM HERON

Gene~al Definition of the Issue --- -Pl~tform Heron is the ~Ost easterly of the three

placfo,tiJls in the proje~t.1 propr,sed by the applicant. It is. planned to be locatea on Lease !08 close to the common b9undary with Lease 309 and about 10., 00\.. feet offshore~ roughly on line with a southerly extension of Camino Corto, a major street in Isla Vista. Heron is ~xpected to be the most productive of the, three proposed drillinq siteg, producing sli9titly more than so percent of the total resource production.

Local r~sidents have voiced· their con~ern about the vi:sual impact of Heron as seen from Camino Corto a~ well as potential ~oise and light reaching shore fro~ the platform.

'.rhe proposed Si'te for Heron a0lso pose ft- r>ot~nti~l pt.-Oblems becaL1.se it i's located on rock~· bottom habitat,-- cr~ati,ng concerns for fisherm~n, ~iologist~ and scientists.

General Impacts Identified in the EIRt&-IS

If Heron is placed as proposed, there are likely-- to be .ma.voidable. adverse impacts created by the project. These ine2-,ude visual/aesthetic impacts,. loss of hardbottom area:J, aa well as increased noise and light created by both conotruction and operation of the platform. An expanded discusaion of noi!!e, air quality, -CU .. sposal of muds and cuttings, and produced watec discharqe appear sep~rately in this mater~al.

,,

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Q

Cit Impar.ts on Isi~ Vista

Camir~ corto is a major north-south street in Isla Vista, offering ~ccess to the beach from El Collegio Roaa. El­Colle9io in turn is the westerly outlet from the Universit}• 1·s fili~in cainpµs. Platform Heron, as proposed, wo11ld be located a.long tbe. southerly projection of Camino Corto, ~ithin full \Tiew 9f m'Otorists driving south along the st;reet. ·Wbi.lla moving the platform location either east or west would reduce the visual impact from Camino Corto, it i$ not likely to eliminate the is8ue as a concern.

Mitis.,ations

Alternatives to the proposed locati<;n of PlatfQrm Heron include: no platform; moving the platform 1000 to 1500 meters to the west; moving it to- the east; or moving i!eron futther offshore. Each of the~e option~ is discussed briefly below.

No platform:

- .,

ll

Platform a~ron is expected to produce more than 50\ '~ of the total produce ion of the project. Without Heron a portion of the resource would not ~ · recovered and leases PRC 30'B and 309 would · n<>.,t be fully developed.

" Moving the platform 1000 to 1500 meters west:

- .

!tocatin9 Heron further to the ~est, while reducing· the hard. ·oottom an~ visual impacts, would move the platfor~ off of the optimal location for access to the oil field. It is estimated that recoverable reserves will decrease by 25 percent under this altecnative. As a result significant ~mounts of the resource could nat physically be d~veloped. Tha illustrati9n which follows this discussion demonstrates this problem.

!!ov.ing the platform to the east:

Locat1ng Platform Heron con~iderably east of its proposed location would have similar impacts , J;Q those occurring from a We$terly move. Agal0n, movement east would remove ·it from the Camino- Corto line of sight but al&o would· result in a significant amount of unrecoverable reserves as · showrt on - the illustratio.n of a westwa0rd move.

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CALENDAR PAGE

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- 18 -

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Moving_ the platform fttrther_ offshore:

k move to the south would reduce the visual impact of the platform and to some extent also lessen the noi~ impact. It is also likely a reduction of rec9verable reserves may occur but to a lesse-r _ ex~ent than a move either east or west, depending on the distance involved.

8.. REVENUE SBAR!NG WITH LOCAL GOVERNMENT

General Definition of the Issue

Revenue to the State from offshore oil arid gas produ~tion in state waters go into the State Treasury. While the funds are µsed for a variety of purposes, the law provides for only a smail portion o~ the re.venue to be tr~nsferred back to local governments in the area of lease production.

Revenues to the State from oil and gas production on tide and submer9ea lands is deposited into several diffex:ent funds pursuant to Publ:'ic: :Resource Section 6217. Fo~ 198'5-86 the funds and amounts we~e:

General Fund California Water Fund Fisheries Restoration ~und central Valley Project

Constrµction Fund capital Outlay Fund for

Public Higher Education State School Building Lease­

Purcbase Fund Energy and Resources Fund Special Account fo~ Capital

Outlay

~ Million

15.0 25.0

5 .. 0

s.o 126 •. 0

150.0 S.7

94 •. 3

426.0

Of the General Fund portion of this money, $4651 000 was allocat.:a to local government under the provisions of Publ;c Resources -ICode Section 6817. Section 681-7 allots funds to local cities and counties with ccean frontage on state oil an~ gas leases which is owneCJ1 and operated as a park and .available free of charge for recreational USf:!, Allocation is made by a specific formula which provides for 1% of the' State revenues from these lease~, up to $100,oqo per milP. of q~alifyin~ frontage, t~ be ~eturned to qualifying local gove~nments. Revenues which exce~~d those received by the State in the ~983-84 fiscal year are not subject to th~ $100~000 lim~ta~i~n.

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' MINUTE l'ACE 234.

•

' ,

Gener,c:il Im2,a,cts Identified in the EIR/E~S

General revenues to 17 local governm~nt enti~ies are exp@~~~d to increase with population and persunal income ~rt.Cr~ases due ttl the project,! These include both the\ city and co11nty of Santa ~rbara. Additionall)1 1 San~ Barbara' ccunty is grro~ected tc receive an increase of $"5. 9 million Pf!!:'' year frora pt~erty ta~es. 'NO other counties or municipalities are expect:.ed to recei\re siqnifieant additional ,9rope-rty ta:c rever~es.

Impacts tq Isla Vista

aecau~e Isla Vista is an unincorporated at-oa of ~o;.anta Barbara cciunty,, it does not. directly receive any funding under Section 6817.. However I s~,nta Barbara county may \!Se i t:s alloted funds wit:min the Isl~ Vista community ',so long as the work is consistent with the st~tutory limitations. For 1985-86 Santa Barbara county rec~i ved $100, 000,.

Mitigations

Re~enue Maring for local governmen~ including speci&l districts and' ·anincorpot$.~d conanunit~es could be authorized by .statute. FundtJ provided' uft4'!r the ex\i,sting subvention program to Santa Ba,;P,~~2'- county could' be use~ in the Isla Vista or other qualifying areas of the county.

9. PRESStm:IZ!~ION AND ~ATURAL SEEPS

General Definition of the .. Issue

'rhe coal Oil Point l?roject involves th~ development of three reservoirs. such development is oft~n -accomplished through the injection o~ materials (usually gas or water) to fac.tlita~e extraction of hydrocarbons. Speakers at the January 13 public hearing expressed conc~rn that injection of gas would cause additional seep3ge of oil and gas into the ocean.

Concern was expressed· that a prev~ously dtilled and abandoned well (3120-2) was leaking.

General I,_,mg~cts Identified in the EIR/E~S

Seepage of oil, gas and tar has occurred natural!~~ and was present in the earliest records for the area. These s~eps within the Santa Barbara Channel can produce s~-70 bac~el~\Of -oil per day. Rates of seepage vary ovet time, risfng a~d fal~ing at irregular intervals. ARCO baa constru~ted two met~ tents Which are being used to contain some existing g~s seeps.

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;.,z,. inspection of well 3120-2 is planned within the very near fut:ur.e.

Impacts on Isla Vista

tsla Vista, together with other shoreside communi·ties, experiences tar and oil on the beach as a re.~1.at of natural seep acti•1~·t:v.. Reduction in offshore rese~~ir pressu·res throu9h de' ·~ment and production should have the beneficial effe~t of : ening seep flows.

The Coai Oil Point Project does not propose artificial pressurization Qf the target reservoirs. Production reservoirs wil~ be pressure depleted~ Th±s means that reservoirs will be produced by allowing the expansion of gas -hs::ld under pressu;,:e to force the oil to the well bore. Introduction of gas 'or water is not planned to maintain reservoir pressu~- Thus, t~~a will be· no chance for pressurization to hav~ an imp~~t Qn the seep ratee. ·

Periodic aerial inspection has not shown leakage at the location of well 3120-2. Subsea television inspection in th' past hQs showed no leak.

J$-l~.i9ations·

~ince no reservoir pressurization is planned, ~itigat~~n is necessary.

no

ReLnjection of sour gaa is contrary to longstanding State Lands ecAUnission policy.

lf the inspection of well 3120-2 indicates it is leaking, ARCO will be asked to take whatever steps are necMsary-to stop the leak).

10.. COMMINGLING VS .. SEGREGATION ____ ....,. __ ...__.......,_._ ......................... _.... ..................... _ Gen~ral Definition of the Issue

The State Lands Commission generally requires the segregation o~ wet oil from different lea3es with variable royalty rates until the oil is dehydrated and sold at the LACT (Lease Automatic ~ustody Transfer) unit. The actual crude .oil produced i~ then accurately measured and its quality determined froni each lease or group of leases having the same royalty terT!ls. On the other hand, commingling of wet """~<lde oil from leases with different royalty rate structures prior to dehyd?at.ion is viewed by the G~unty of Santa Barbara as a desirable means of processing the most oil in the fewest . and smallest facilities.

- 22 - CAlENDA!l PAGt:

MINUTE PAGE, 236

0

In a segrega:ted oil processing facility, the oil froan a s:i. ·~qle lease is kept separate .from oii .from any ether lease un~il ~he net d~hydrated oil can b~ measured at the ~ACT unit. ~ha to.A.CT unit is used to measure the dE:ihydrated oil for sale. ~his simpl.tf ies roy~l.ty dete.t:mina·tion because 'lO allocation is necessary.

In a commingled facility, oil from multiple leases produced at different coyalty rates is processed in common processing facilities. This re~uire~ an accurate we~ oil ~ll~cation and measuring system in order to determine how much of the net dehydrated oil belongs to each lease or well in order t;o calcu~te each lease ''s royalty.

A study (Dr. James R. ~ence-UCSB Professor) commissioned by Santa Be:trba·::a county, concludes that measurement e.rrors ir' a commingled system are unbiased and fandom and therefore all erro,+s will cancel .out over the life of the project. However / an· evaluatign of the eence study by Dr. John, Lohrenz (USC) comrnissiol?'~d by the State !.arids Commission concludes that the Bence st~~y is statistically correct if such errors are unbia~~d and rand"m. However, f',~e Lohrenz st;udy states that the measu.;ement; errors associat1ft~ with a commingled system a-re biased and ncn~random· and would ~esult in the loss of millions of dollars ·Of revenue to the State.

The sta;f of the Commission is continuing its ~xamination of the technical capabi_l.ities of existing neasu.-rement techng):.ogy. On the basis of a statement by the University a-.;:. the January 13, 1987 heari.ng that accurate measuring- devices for wet oil commingled systems pre-sently exi.st in1 wo;-ldwide application, the Commission has retained additional technical expe,::,tise and arr'ilnged a meeting for Thursday, January 22, 1987 with University perso.~nel.

General Impacts Identified ~n the EIR/EIS

~he EIR/EIS examined the environmental impacts associated with boeh systems. From that analysis it can not be ~oncluded that either :,7:l'S!.eitl is envi~onmentally preferable or superior to the other.

Impacts to Isla Vista

N/A

Mitigations

U/A

•·

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