[Editor’s Note: With the deadline for public comment on expanded drilling in the Baldwin Hills oil field looming one week from today, land-use attorney Kenneth L. Kutcher has led a Culver Crest-based citizens campaign demanding, he says, accountability for strict regulation by Los Angeles County. Yesterday, he directed the following letter — his fourth — to two County agencies he said have not responded to nearly three dozen questions of importance to residents within the orbit of the oil field. Meanwhile, the next community meeting on the oil drilling dispute will be 6 o’clock Thursday evening at the Consolidated Board of Realtors, 3725 Don Felipe Dr. On Wednesday at 6:30, the City Council will vote on a resolution it will file with County officials.]
August 11, 2008
Russell J. Fricano, Ph.D., AICP
Section Head, Community Studies I
County of Los Angeles
Department of Regional Planning
320 West Temple Street
Los Angeles, CA 90012
Re: Project No. R2007-00570-(2) (Dr. Fricano)
Baldwin Hills Community Standards District (CSD) and EIR
SCH No. 2007061133
Environmental Case No. RENVT2007-00048
Public Workshop Date: July 17, 2008
Dear Mr. Fricano:
I attended and participated in the July 17, 2008, public workshop conducted by the County concerning the Baldwin Hills Community Standards District Draft Environmental Impact Report ("DEIR") and Community Standards District ("CSD").
During my opportunity to address County Staff, I asked questions of both the Department of Regional Planning ("DPR") and Marine Research Specialists ("MRS"). MRS responded to most of my questions that night. DPR indicated that written responses would be forthcoming.
I have not yet seen DPR's written responses, and I wanted to take this opportunity to revisit my questions so that they don't get lost in the on-going proceedings. I would also like to ensure that the questions regarding the EIR are reflected in the Final EIR pursuant to State CEQA Guidelines Section 15132(b) & (d). For those reasons, I am writing this letter.
A. Questions For DPR:
1. So far, how many CSDs have been established in the County?
2. How many of those CSDs were the result of individual applications?
3. With the exception of this Baldwin Hills CSD, what was the largest acreage covered by a CSD?
4. What date did DPR staff originally project for releasing the DEIR for this CSD?
5. What were the reasons for the delays beyond that date?
6. How should members of the public obtain a copy of DPR's draft CSD when it is available?
7. How should members of the public provide their comments on DPR's draft of the CSD?
8. When will the Final EIR be available?
9. What application process does the County recommend for processing future well proposals by PXP? And why?
10. What approach is the County recommending to foster eventual conversion of the Oil Field to parkland?
11. If there were another odor emission as occurred in January 2006, what would occur under PXP's CSD if it were adopted as written by PXP?
12. Since PXP's legal representative indicated (during April 2008 meetings with the community) that PXP would be revising their draft CSD based on the mitigation measures contained in the DEIR, has the County received any revised CSD from PXP since the release of the DEIR?
B. Questions For MRS:
13. How many air quality monitors did MRS install after receiving the public comments on the Notice of Preparation ("NOP") in July 2007, urging that air quality monitors be used to collect data for the EIR?
14. How many air samples were collected by MRS from the Oil Field?
15. Were any air samples collected by MRS during events occurring after the NOP that caused public complaints concerning odors from PXP?
16. Has MRS observed the flaring that has disrupted neighbors of the Oil Field?
17. Did MRS ask to observe the flaring?
18. Consistent with public comments on the NOP, did MRS conduct a door-to-door survey of the area residents surrounding the Oil Field to gauge the incident rates of various cancers? For asthma?
19. Is the South Coast Air Quality Management District ("SCAQMD" or "AQMD") a responsible agency for purposes of portable or fixed flaring in the Inglewood Oil Field?
20. Did MRS describe the events of January 10-11, 2006, in the DEIR?
21. If not, why not?
22. Was that event significant to the environmental setting of the DEIR?
23. Did MRS evaluate a “reduced drilling" alternative in the DEIR?
24. If not, why not?
25. Did MRS recommend "well consolidation" as a mitigation measure in the DEIR?
26. If so, how would that be accomplished?
27. If not, why not?
28. What application process does MRS recommend for processing future well proposals by PXP? And why?
29. What policy limit of casualty insurance coverage would ensure that there is sufficient money to fund a cleanup in the event of a major spill/leak at this Oil Field?
30. What policy limit of casualty insurance coverage would ensure that there is sufficient money to provide full compensation in the event of a catastrophic event at this Oil Field?
31. What bond amount would ensure that there is sufficient money to fund proper closure and cleanup of all wells upon abandonment of this Oil Field?
32. What bond amount would ensure that there is sufficient money to fund proper closure and cleanup of 1,065 new wells at this Oil Field?
33. What means would MRS recommend to best ensure that the third party audits recommended by the mitigation measures will actually occur?
34. How would RECLAIM credits help immediate neighbors from the significant adverse air quality emissions projected in the DEIR to occur at the Oil Field?
I look forward to your responses to these questions.
Very truly yours,
Kenneth L. Kutcher
cc: Los Angeles Regional Planning Commission
Supervisor Yvonne B. Burke
Supervisor Gloria Molina
Supervisor Zev Yaroslavsky
Supervisor Don Knabe
Supervisor Michael D. Antonovich
Mike Bohlke
Steve Rusch
Charles Moore
Mayor Scott Malsin
Elaine Lemke
Rose Hamilton
Councilman Bernard Parks
Senator Mark Ridley-Thomas
Speaker Karen Bass
Susana Franco-Rogan
Paul McCarthy
