HomeMy WebLinkAbout09/08/14
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RESOLUTION NO. 14-XXXX
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF HERMOSA BEACH,
CALIFORNIA, CALLING AND GIVING NOTICE OF THE HOLDING OF A SPECIAL
MUNICIPAL ELECTION ON TUESDAY, MARCH 3, 2015, FOR SUBMISSION OF A
PROPOSED ORDINANCE TO THE ELECTORATE RELATING TO A PROPOSED
OIL AND GAS DRILLING AND PRODUCTION PROJECT PROPOSED BY E&B
NATURAL RESOURCES MANAGEMENT CORPORATION FOR THE CITY
MAINTENANCE YARD AT 555 6TH STREET
WHEREAS, the Settlement Agreement between the City and E&B Natural Resources
Management Corporation (“E&B”) calls for the City Council to submit to the voters at a special
election the question whether to amend the Hermosa Beach Municipal Code to allow E&B’s oil
drilling and production project to proceed at the City maintenance yard located 555 6th Street
and to approve a development agreement that would afford E&B a vested right to proceed with
its project.
WHEREAS, the Agreement to Implement the Settlement Agreement entered into
between the City and E&B on July 23, 2014 calls for the special election to take place on March
3, 2015.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF HERMOSA
BEACH, CALIFORNIA, DOES HEREBY RESOLVE, DECLARE, DETERMINE AND
ORDER AS FOLLOWS:
SECTION 1. That pursuant to the requirements of the laws of the State of California
relating to general law cities, including but not limited to Elections Code Section 9222, there is
called and ordered to be held in the City of Hermosa Beach, California, on Tuesday, March 3,
2015, a Special Municipal Election for the purpose of submitting to the voters the following
proposed ordinance:
Shall E&B Corporation’s oil drilling/production project
proposed at the City’s 555 6th Street maintenance yard be
approved with 1) amendments to the General Plan and
Municipal Code to exempt the project from the City’s ban on
oil drilling and remove the existing restriction on the City’s
use of project royalties, 2) a pipeline franchise to transport
YES
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oil/gas underground, 3) a development agreement, and 4) a
determination that project benefits outweigh its unavoidable
environmental impacts?
NO
SECTION 2. That the proposed complete text of the ordinance submitted to the voters
is attached as Exhibit “A.”
SECTION 3. That the ballots to be used at the election shall be in form and content as
required by law.
SECTION 4. That the City Clerk is authorized, instructed and directed to coordinate
with the County of Los Angeles Registrar-Recorder/County Clerk to procure and furnish any
and all official ballots, notices, printed matter and all supplies, equipment and paraphernalia that
may be necessary in order to properly and lawfully conduct the election.
SECTION 5. That the polls shall be open at seven o'clock a.m. (7 a.m.) of the day of
the election and shall remain open continuously from that time until eight o'clock p.m. (8 a.m.)
of the same day when the polls shall be closed pursuant to Election Code § 10242, except as
provided in § 14401 of the Elections Code of the State of California.
SECTION 6. That in all particulars not recited in this resolution, the election shall be
held and conducted as provided by law for holding municipal elections.
SECTION 7. That notice of the time and place of holding the election is given and the
City Clerk is authorized, instructed and directed to give further or additional notice of the
election, in time, form and manner as required by law.
SECTION 8. That the City Clerk shall certify to the passage and adoption of this
Resolution and enter it into the book of original Resolutions.
SECTION 9. The City Council authorizes the City Clerk to administer said election and
all reasonable and actual election expenses shall be paid by the City upon presentation of a
properly submitted bill, of which up to $50,000 shall be reimbursed by E&B to the City pursuant
to the Settlement Agreement.
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PASSED, APPROVED AND ADOPTED THIS ____ DAY OF SEPTEMBER, 2014.
________________________________________________________________________
PRESIDENT of the City Council, and MAYOR of the City of Hermosa Beach, California
ATTEST: APPROVED AS TO FORM:
__________________________________ __________________________________
City Clerk City Attorney
1 Development Agreement between City of Hermosa Beach and E&B Natural Resources
DEVELOPMENT AGREEMENT
BY AND BETWEEN
CITY OF HERMOSA BEACH
AND E&B NATURAL RESOURCES MANAGEMENT CORPORATION
THIS DEVELOPMENT AGREEMENT (“Development Agreement” or “Agreement”) is entered into as of the ____ day of ______________, _____, by and between the CITY OF
HERMOSA BEACH, a California municipal corporation ("City"), and E&B NATURAL
RESOURCES MANAGEMENT CORPORATION, a California corporation (“E&B”).
RECITALS
A. The City is the owner of that certain real property in the City of Hermosa Beach, County of Los Angeles, and State of California described in Section 2.4 of this Agreement
(Exhibit A to this Agreement), and also known informally as the City Maintenance Yard
(“Property” or “City Maintenance Yard”).
B. On or about January 14, 1992, the City entered into Oil and Gas Lease No. 2 (“Lease”) with Macpherson Oil Company, a California corporation, for itself and for Windward
Associates, a California limited partnership, of which it is the general partner (collectively
“Macpherson”). The Lease was approved by the California State Lands Commission (“CSLC”).
The Lease authorized Macpherson to perform oil and gas extraction activities in the tidelands granted to the City by the State of California, and also authorized Macpherson to utilize the Property for oil and gas drilling activities (“Macpherson Project”).
C. During the 1990s, Macpherson sought and obtained approvals for the Macpherson
Project from the City, the CSLC, the California Coastal Commission and the South Coast Air Quality Management District. In 1995, the voters of the City passed Proposition E, an initiative to ban oil drilling in the City. During this time, and subsequently, Macpherson, the City, the
CSLC, and opponents to the Macpherson Project were parties to several lawsuits regarding the
Macpherson Project, including an action by Macpherson against the City regarding whether
Proposition E constituted a breach of the Lease (“Macpherson Lawsuit”). The trial court in the Macpherson Lawsuit determined that the adoption of Proposition E constituted a breach of the Lease, subject to certain City defenses, and scheduled a trial in April 2012 to determine
Macpherson’s damages.
D. E&B, who had no prior relationship with Macpherson, investigated the Macpherson Project and approached the City and Macpherson with a proposal to settle the Macpherson Lawsuit and to provide E&B with a potential opportunity to proceed with “a state-
of-the-art directional well oil drilling project conducted from an urban drill site.” (Settlement
Agreement, p. 2.) On March 2, 2012, the City, Macpherson and E&B entered into a Settlement
Agreement and Release (“Settlement Agreement”).
2 Development Agreement between City of Hermosa Beach and E&B Natural Resources
E. The Settlement Agreement, among other consideration, provided for the dismissal
of the Macpherson Lawsuit, certain payments to Macpherson, and the assignment to E&B of
Macpherson’s rights under the Lease and all other permits for the Macpherson Project which would allow E&B to proceed with a redesigned oil development project (“Project”) under certain conditions. Under the terms of the Settlement Agreement, the City is to place on the ballot, in a
manner that comports with all applicable law, a measure that asks the voters whether to approve,
among other things, “a development agreement that would afford E&B a vested right to proceed
with the Project . . . .” (Settlement Agreement, p. 7.) F. The California Elections Code sets forth the procedures for a local legislative body to
submit a proposition to the voters of the City. As contemplated in the Settlement Agreement, the
City elected to undertake environmental review of the Project referenced in paragraph E above in
accordance with the requirements of the California Environmental Quality Act (“CEQA”). On July 8, 2014, the City Council of City certified an Environmental Impact Report in compliance with CEQA by its adoption of Resolution No. 14-6908.
G. The California Legislature enacted Section 65864 et seq. of the Government
Code, which provides that cities and counties may enter into development agreements with persons having legal or equitable development interests in real property. Section 65867.5 of the Government Code states that a development agreement is a “legislative act” to be approved by
ordinance, and the California Constitution establishes the right of voters to approve legislative acts.
Elections Code section 9222 authorizes the City Council to submit any ordinance to the voters for
their approval. Section 65869 of the Government Code mandates Coastal Commission approval for any development agreement in an area where a local coastal program has not been certified.
H. The City has adopted rules and regulations for consideration of development
agreements, pursuant to Government Code Section 65865, in Chapter 17.64 of the City’s
Municipal Code. I. In compliance with the Settlement Agreement and all other applicable law, the
City submitted the [insert title of proposition] (“Proposition”) to the voters of the City on
[insert date] in compliance with California Elections Code Section 9222. The Proposition
includes the following legislative approvals: 1) an amendment to the Land Use Plan of the Local Coastal Program (a component of the City’s General Plan) to modify the land use designation for the Property to allow for the implementation the Project and to provide energy policies in
compliance with the California Coastal Act; 2) various amendments to the Municipal Code to
allow the Project to proceed on the Property and to remove the restriction on the City’s use of
project royalties; 3) a franchise for oil and gas pipelines; 4) amendments to the Oil Code; and 5) this Development Agreement, and in connection with these legislative approvals, makes CEQA findings including a statement that the project benefits outweigh its unavoidable environmental
impacts (i.e. a statement of overriding considerations). These legislative approvals are referred
to in this Agreement as “Proposition Approvals.”
J. By approving the Proposition and this Agreement, the voters of the City have determined that the public interest is served by entering into this Agreement because the Project,
described in Exhibit B to this Agreement, will provide for the remediation of the City Maintenance
3 Development Agreement between City of Hermosa Beach and E&B Natural Resources
Yard, will provide for safe oil drilling and production activities, and will provide substantial
economic benefits to the City and to the Community in the form of royalties as described in the
Lease and as further set forth in Exhibit C to this Agreement. K. This Agreement will bind future City Councils to the terms and obligations
specified in this Agreement and limit, to the degree specified in this Agreement, the future
exercise of the City's ability to regulate development on the Property.
L. This Agreement and the Project is consistent with, and will serve to implement the policies, objectives, and standards of, the elements of the City of Hermosa Beach General
Plan, as amended by the Proposition Approvals.
M. This Agreement and the Project is consistent with, and will serve to implement, the provisions of Article 3 of the California Coastal Act.
N. This Agreement will eliminate uncertainty in planning and provide for the orderly
development of the Property and generally serve the public interest.
AGREEMENT
NOW THEREFORE, in consideration of the above recitals, the mutual covenants and
conditions herein contained, and other good and valuable consideration, the receipt and adequacy
of which are hereby acknowledged, the parties agrees as follows:
1 DEFINITIONS
For purposes of this Agreement, except as otherwise expressly provided or unless the
context otherwise requires:
"Agreement" means this Development Agreement by and between the City and E&B.
"Approval Date" means the date on which the ordinance approving this Development Agreement becomes effective under Elections Code Section 9217, specifically ten days after the date the vote is declared by the City Council [INSERT DATE].
"CEQA" means the California Environmental Quality Act, Section 21000, et seq., of the
California Public Resources Code.
"City" means the City of Hermosa Beach, California.
"City Council" means the City Council of the City of Hermosa Beach.
"Code" or “HBMC” means the Municipal Code of the City of Hermosa Beach.
4 Development Agreement between City of Hermosa Beach and E&B Natural Resources
"Commencement Date" means that date when the Commission approves the
Development Agreement under Government Code Section 65869; provided, however, if
litigation challenging the validity of this Agreement including any Project Approvals and/or environmental review pursuant to CEQA should be brought against the City or the Coastal Commission, the Commencement Date shall be the date such litigation is concluded in a manner
that permits the commencement or continuation of the parties' rights and obligations under this
Agreement.
“Commission” means the California Coastal Commission.
“Conditional Use Permit” means the Conditional Use Permit for Oil Development at the City Maintenance Yard, approved by the City in Resolution No. 93-5632, and the validity of
which was confirmed by the Settlement Agreement, which is to be abandoned and superseded
pursuant to the terms of this Agreement.
"Current Land Use Regulations" means the ordinances, resolutions, rules, regulations, requirements and official policies of the City in force as of the Effective Date and shall also include the Proposition Approvals.
"Development Agreement Act" means Section 65864 et seq., of the California
Government Code.
“E&B” means E & B NATURAL RESOURCES MANAGEMENT CORPORATION, a California corporation in the business of exploring for and producing oil and gas and each of its respective successors and assigns to all or any portion of its interests in the Property during such
time as such portion is subject to this Agreement.
“Election Date” means the date that the Proposition was submitted for a vote to the
voters.
"Event of Default" is defined in Section 5.1.1.
"Exactions" means any requirement imposed by the City in connection with or pursuant to
any land use regulation or land use approval process for the dedication of land, construction or
improvement of public improvements or amenities, payment of development fees, or other
mitigation measures required to mitigate the impacts of the development including, without limitation, all development impact fees or linkage fees, utility capacity fees, service or connection fees, major facilities fees, park fees, flood control fees, environmental impact mitigation fees,
affordable housing fees, arts fees, transportation fees, child care fees and any similar
governmental fees, charges and exactions required for the development of projects or property.
"Force Majeure Delay" is defined in Section 6.23.
"Future Ministerial Permits" is defined in Section 3.2.1.
"General Plan" means the General Plan of the City as of the Effective Date.
5 Development Agreement between City of Hermosa Beach and E&B Natural Resources
“Off-site Project Components” or “Off-site Components” means the Project components
in the City of Hermosa Beach outside of the Property as described in Exhibit B to this
Agreement, including (1) oil and gas pipelines along Valley Drive, Hermosa Beach, California, (2) supply staging/storage at 601 Cypress Avenue, Hermosa Beach, California, (3) a parking lot at 636 Cypress Avenue, Hermosa Beach, California, and (4) various locations outside the
jurisdiction of Hermosa Beach. The location of (2) and (3) are more particularly described in
Exhibit A.
“Oil Code” means the Hermosa Beach Oil Code, Chapter 21A (Oil Production), approved by the City with Ordinance No. 85-803.
"Processing Fees" means all routine and generally applicable City-wide fees required by
the City for processing applications and permits including, but not limited to, fees for land use
applications, project permits, building applications, building permits, grading permits, maps and
certificates of occupancy in effect at the time paid. Expressly exempted from Processing Fees are all Exactions.
"Project" means the proposed development of the Property described in the Project
Description contained in Exhibit B.
"Project Approvals" means the Proposition Approvals approved by the voters of the
City on the Election Date, and to be implemented by the City as set forth in the Proposition, the LUP approved by the City and certified by the Commission, the Coastal Development Permit approved by the Commission, the Conditional Use Permit (to be superseded pursuant to the terms
of this agreement), the Development Agreement approved by the City and the Commission, and
those other discretionary actions and approvals of the City and other public agencies as set forth
in Section 2.6 of this Agreement.
“Proposition __” means the proposition that was approved by the voters on the Election Date.
“Proposition Approvals” means the: 1) an amendment to the Land Use Plan of the Local
Coastal Program (a component of the City’s General Plan) to modify the land use designation for
the Property to allow for the implementation the Project and to provide energy policies in compliance with the California Coastal Act; 2) various amendments to the Municipal Code to allow the Project to proceed on the Property and to remove the restriction on the City’s use of
project royalties; 3) a franchise for oil and gas pipelines; 4) amendments to the Oil Code; and 5)
this Development Agreement, and in connection with these legislative approvals, CEQA findings
including a statement that the project benefits outweigh its unavoidable environmental impacts (i.e. a statement of overriding considerations).
"Public Benefits" means those improvements to be constructed, services to be provided
and/or amounts to be paid by E&B to the City as consideration for this Agreement pursuant to
Section 2.1 and Exhibit C.
"Term" means the term of this Agreement, as provided in Section 6.1 of this Agreement.
6 Development Agreement between City of Hermosa Beach and E&B Natural Resources
"Zoning Ordinance" means the comprehensive Zoning Ordinance of the City, found in
Chapter 17 of the Code of the City of Hermosa Beach as it exists on the Effective Date.
2 THE DEVELOPMENT AGREEMENT PROCESS
2.1 Statement of Benefits and Consideration. The voters of the City have determined that the
Project is a development for which a development agreement is appropriate. Development
of the Project in accordance with a development agreement will provide for the orderly
development of the Property in accordance with the objectives set forth in the General Plan, including the Land Use Plan of the Local Coastal Program, as amended. Moreover, a development agreement for the Project will eliminate uncertainty in planning for and
securing orderly development of the Property, ensure attainment of the maximum efficient
utilization of resources within the City at the least economic cost to its citizens, and
achieve the provision of public services, public uses, urban infrastructure and other goals and purposes for which the Development Agreement Act was enacted, all in the promotion of the health, safety and general welfare of the City of Hermosa Beach and its residents. In
exchange for these and other benefits to the City, E&B will receive the assurance that E&B
may develop the Project during the Term of this Agreement, subject to the terms and
conditions herein contained. By approving Proposition ___, the voters of the City have found and determined that this Agreement is consistent with the General Plan, including the Land Use Plan of the Local Coastal Program, as amended, and have approved this
Agreement.
This Agreement does not (1) grant density or intensity in excess of that otherwise
established in the Project Approvals, (2) supersede, nullify or amend any condition imposed in the Project Approvals, (3) guarantee to E&B any profits from the Project, or (4) prohibit or, if legally required, indicate E&B’s consent to, the Property's inclusion in any public
financing district or assessment district.
The City will receive substantial benefits as a result of the development of the Property in
accordance with this Agreement, as set forth in Exhibit C, in recognition of and in exchange for this Agreement and the benefits provided to E&B pursuant to this Agreement. The voters of the City acknowledge the adequacy of the consideration provided by E&B to the
City pursuant to this Agreement.
In consideration of the benefits, commitments and consideration to be provided by E&B
pursuant to this Agreement and in order to strengthen the public planning process and reduce the economic costs of development, the voters of the City hereby provide E&B assurance that it can proceed with the development of the Property for the Term of this
Agreement pursuant to the land use, density and intensity specified in the Current Land Use
Regulations, the Project Approvals and this Agreement. E&B would not enter into this
Agreement or agree to provide the public benefits, commitments and consideration described in this Agreement if it were not for the certainty provided by this Agreement that the Property can be developed during the Term of this Agreement in accordance with the
7 Development Agreement between City of Hermosa Beach and E&B Natural Resources
Current Land Use Regulations and the Project Approvals including the land use, density
and intensity set forth in the Project Approvals.
2.2 Public Hearings. On June 23, 2014, the Planning Commission of the City, after providing notice as required by law, held public hearings on the legislative elements of the Project, including this Agreement and the amendments to the Hermosa Beach Municipal Code and
Coastal Land Use Plan. The City Council, after providing public notice as required by law,
similarly held public hearings on the Project, including this Agreement [insert dates and
specific code provisions].
2.3 City Council and Voter Findings. The City Council adopted findings that review of the environmental impacts of this Agreement and the Project Approvals has been conducted in
accordance with the provisions of CEQA and the State and local guidelines adopted
thereunder, and the City Council has given consideration to such environmental review
prior to placing the Proposition on the ballot and has undertaken all actions necessary to comply with CEQA. In approving the Proposition and this Agreement, the voters of the City have determined and found that this Agreement is consistent with the General Plan,
including the Land Use Plan of the Local Coastal Program, as amended, and all other
applicable City plans, policies and regulations.
2.4 Property. The Property includes all real property that is subject to this Agreement. The Property as of the Election Date is commonly known as City Maintenance Yard, as more fully described in Exhibit A incorporated herein by reference.
2.5 The Project. The Project consists of the development, construction and operations on the
Property permitted under this Agreement and the Project Approvals. The description of
the Project and its uses are more fully described in the Project Description set forth in Exhibit B which is incorporated herein by reference. The Project includes Off-site Components within the City of Hermosa Beach.
2.6 Current Project Approvals. The Project includes, without limitation, all items described in
the Project Description contained in Exhibit B and incorporated herein by reference and
the following Project Approvals:
(a) Conditional Use Permit for Oil Development at the City
Maintenance Yard, approved by the City in Resolution No. 93-
5632 (as set forth in Section 2.7 below, to be abandoned per
HBMC Section 17.70.030 and superseded pursuant to the terms of
this Agreement);
(b) Environmental Impact Report, dated June 2014, prepared pursuant
to CEQA and certified by the City Council on July 8, 2014 (with
revisions identified in City Council Resolution No. 14-6908);
(c) Amendments to the Land Use Plan and Land Use Plan Map of the Local Coastal Program (a component of the City’s General Plan),
8 Development Agreement between City of Hermosa Beach and E&B Natural Resources
approved by Proposition __ on ________________, and by
Commission [insert Commission action] on
______________________;
(d) Amendment to the Municipal Code, approved by Proposition __ on _________________;
(e) Franchise for Oil and Pipelines, approved by Proposition __ on
_______________;
(f) Amendment to the Oil Code, approved by Proposition __ on _______________; and
(e) Development Agreement, approved by Proposition __ on
_________________, and by Commission [insert Commission
action] on _________________.
2.7. Abandonment of Conditional Use Permit. With adoption of the Proposition, oil drilling and production is permitted on the Property subject to a development agreement. The relevant conditions of approval from the 1993 Conditional Use Permit (CUP) for oil development at the
Property (Resolution No. 93-5632) are incorporated into this Development Agreement as Exhibit
D-1 herein, and E&B shall comply with said conditions as required herein. Thus, upon the
Commencement Date, this agreement will supersede the 1993 CUP, which shall no longer serve a regulatory purpose. Hermosa Beach Municipal Code Section 17.70.030 allows for voluntary abandonment of a Conditional Use Permit. This Agreement at the Commencement Date shall
serve as both a written request to abandon the CUP and the City’s declaration that the 1993 CUP
is abandoned.
3 VESTED DEVELOPMENT RIGHTS
3.1 Vested Rights to Develop. Subject to the terms, conditions, and covenants of this
Agreement, including the Reservations of Power in Section 3.4, and the conditions of
approval and mitigation measures attached hereto and incorporated herein as Exhibit D, as
of the Approval Date E&B shall have a vested right to develop the Property and Project, including Off-site Components, in accordance with, and to the extent of, the Project Approvals, and the Current Land Use Regulations. The approved use of the Property, the
density and intensity of use, the maximum height, footprint, and square footage of
proposed buildings and structures, and provisions for reservation and dedication of land or
public purposes shall be those set forth in the Project Approvals and the attached Exhibits. Nothing in this Agreement shall be deemed to obligate E&B to initiate development of the Project or any portion thereof within any period of time or at all.
3.1.1 Certain Changes Prohibited Without Consent of E&B. Except as otherwise
provided in this Agreement, during the Term, the City shall not, as to the Property and the
Project, including Off-site Components, without the prior written consent of E&B, which may be
9 Development Agreement between City of Hermosa Beach and E&B Natural Resources
withheld in E&B’s sole and unfettered discretion: (a) change the Current Land Use Regulations,
or Project Approvals as they apply to the Property or Project so as to prevent or adversely affect
development or construction of the Project in accordance with this Agreement, the Current Land Use Regulations or Project Approvals; or (b) apply to the Property or the Project any new or amended ordinance, resolution, rule, regulation, requirement or official policy that is inconsistent
with the Current Land Use Regulations or Project Approvals, so as to prevent or adversely affect
development or construction of the Project in accordance with this Agreement, the Current Land
Use Regulations or Project Approvals, or prevent or adversely affect the operation of the Project as contemplated hereby in accordance with the Current Land Use Regulations or Project Approvals; or (c) apply to this Agreement, the Property or the Project any new or amended
ordinance, resolution, rule, regulation, requirement or official policy that requires additional
discretionary review or approval not otherwise required for the Project by the Current Land Use
Regulations or Project Approvals; or (d) apply to this Agreement, the Property or the Project any new or amended ordinance, resolution, rule, regulation, requirement or official policy that materially, adversely affects the timing or phasing of construction or development, or which
limits the availability of utilities or other infrastructure for the Project. For the purposes of this
Section 3.1, “prevent or adversely affect development or construction of the Project” shall
include, without limitation, any changes which fundamentally affect the ability of any of the permitted uses to operate within the Project (e.g. prohibit any of the uses in the Project Approvals, change parking standards for any of the uses, etc.).
3.1.2 Rights are Vested. Unless amended or terminated in the manner specified
in this Agreement (and subject to the provisions of this Agreement), E&B shall have the rights
and benefits afforded by this Agreement and this Agreement shall be enforceable by E&B and the City notwithstanding any growth control measure, initiative, proposition or any development moratorium adopted after the Effective Date, or any change in the General Plan,
zoning, or subdivision regulations adopted by the City which alter or amend the Current Land
Use Regulations or Project Approvals or the adoption of any new or amended ordinance,
resolution, rule, regulation, requirement or official policy that is inconsistent with the Current Land Use Regulations or Project Approvals and so as to prevent or adversely affect development or construction of the Project in accordance with the Current Land Use Regulations
or Project Approvals. This Section shall be construed to prohibit the City from applying to the
Property or the Project, including any Off-site Components, any development moratorium or
growth control measure that is adopted specifically to prohibit the construction or operation of the Project, or as an interim measure pending contemplated General Plan, Specific Plan or zoning changes, or as a general growth control management measure except as provided for
pursuant to Section 3.4. Termination of this Agreement pursuant to Section 5.2.1 or 5.2.2
shall cause the rights and benefits afforded by this Agreement to no longer be vested (subject
to planning and zoning law) and as a result, the City shall no longer be limited from taking any action which may adversely affect the Property or the Project. If termination is challenged, the rights afforded herein are not terminated until a court, in a final adjudication, affirms the
termination.
3.1.3 Future Changes to Current Land Use Regulations. Following the
Approval Date, if the City modifies the Current Land Use Regulations in a manner that E&B, in its sole discretion, determines is more beneficial than the Current Land Use Regulations, then
10 Development Agreement between City of Hermosa Beach and E&B Natural Resources
E&B may choose in its sole discretion to be governed by the modified land use regulations rather
than the Current Land Use Regulations, without E&B being deemed to have waived or limited
any rights, remedies or privileges under this Agreement.
3.2 Other Rights.
3.2.1 Future Ministerial Permits. E&B will seek additional ministerial permits
as required by the City, including, without limitation, excavation only permits, grading permits,
demolition permits, building permits, well permits, drilling permits and public works permits, as needed to implement the Project Approvals and to construct and operate the Project. Collectively, these ministerial permit applications are called the "Future Ministerial Permits".
The City agrees that it will not unreasonably withhold or unreasonably condition any of the
Future Ministerial Permits which must be issued by the City in order for the Project to proceed,
provided that E&B reasonably and satisfactorily complies with all preliminary procedures, actions, payment of Processing Fees and criteria generally required for processing such Future Ministerial Permits, and provided further that such Future Ministerial Permits comply with this
Agreement, the Current Land Use Regulations and the Project Approvals and approvals of other
governmental agencies with jurisdiction over the Project. The City further agrees that no
discretionary permits, other than the Project Approvals, are required from the City to construct and operate the Project.
3.3 Reservations of Power.
3.3.1 Limitations, Reservations and Exceptions. Notwithstanding any other
provision of this Agreement, the following subsequent land use regulations shall apply to the
development of the Property:
(a) Processing Fees (but not Exactions) imposed by the City to cover the estimated actual costs to the City of processing applications for Project Approvals, fees for
monitoring compliance with any Project Approvals, inspection fees, or fees for monitoring
compliance with environmental mitigation measures.
(b) Procedural regulations applied on a City-wide, nondiscriminatory basis relating to City entities required to review petitions or applications, forms of petitions and applications, notice requirements, information requested with petitions or applications, conduct
of hearings, form of staff reports, nature and type of recommendations by City entities, appeal
procedures and any other similar matters of procedure.
(c) Regulations governing building codes and similar construction standards and specifications including, but not limited to, the California and International Codes, as they may be changed from time to time.
(d) Regulations that are necessary to protect the public health and
safety, including without limitation, development moratorium or limitation on the delivery of
City-provided utility services, which meet each of the following requirements: (a) are based on
11 Development Agreement between City of Hermosa Beach and E&B Natural Resources
genuine health, safety and general welfare concerns (other than general growth management
issues); (b) which arise out of a documented emergency situation, as declared by the President of
the United States, Governor of California, or the Mayor or City Council of the City of Hermosa Beach; and (c) are based upon its terms or its effect as applied, does not apply exclusively or primarily to the Property or the Project. To the extent possible, any such regulations shall be
applied and construed so as to provide E&B with the rights and assurances provided under this
Agreement. This subsection governs generally applicable emergencies in the area not specifically
related to or caused by the Project.
(e) Regulations that are not in conflict with the Project Approvals, Current Land Use Regulations or this Agreement. Any regulation, whether adopted by initiative
or otherwise, limiting the rate, timing, phasing or sequencing of development of the Property
shall be deemed to conflict with the Project and shall therefore not be applicable to the
development of the Property. Any regulation limiting the permitted uses of the Property, limiting the density or intensity of use of the Property, or limiting the size, height or location of improvements on the Property shall be deemed to conflict with the Project Approvals and shall
therefore not be applicable to the development of the Property.
(f) Regulations that are in conflict with the Project, but as to which the
E&B has given its prior written consent for such regulations to be applied to the Property or to the development of the Property.
(g) Regulations applied on a City-wide, non-discriminatory basis that
do not prevent or adversely affect development or construction of the Project.
3.3.2 Modification or Suspension by State or Federal Law. In the event that
state or federal laws or regulations, or those of any regional authority having jurisdiction over the Project or Property, enacted after the Approval Date of this Agreement, prevent or preclude compliance with one or more of the provisions of this Agreement or the Project conditions, such
provisions of this Agreement shall be modified or suspended as may be necessary to comply
with such state, federal, or regional authority laws or regulations and to effectuate to the extent
possible the terms of this Agreement.
3.3.3 Police Power. The parties acknowledge and agree that City is restricted in its authority to limit its police power by development agreement and that the foregoing
limitations, reservations and exceptions are intended to reserve to City all of its police power
which cannot be so limited. This Agreement shall be construed to reserve to City all such power
and authority which cannot be restricted by development agreement.
3.3.4 Taxes, Assessments and Fees. Anything herein to the contrary notwithstanding, City may impose on the Project any new non-discriminatory, City-wide taxes,
assessments and fees, including but not limited to business license taxes or franchise fees, but not
including any Exaction or other fee designated to mitigate the impact of development of the
Project.
3.4 Regulation by Other Public Agencies. It is acknowledged by the parties that other public agencies not within the control of the City may possess authority to regulate aspects of the
12 Development Agreement between City of Hermosa Beach and E&B Natural Resources
development of the Property separately from or jointly with City, and this Agreement does
not limit the authority of such other public agencies. Changes to the project mandated by
such regulatory agencies shall be automatically included into this Development Agreement and shall supersede any inconsistent provisions herein.
3.5 Agreement and Assurances on the Part of E&B. Without in any way limiting E&B’s
rights under Section 5.2.2 not to proceed with development of the Project and, in such an
event, to terminate this Agreement in its sole and subjective business judgment, if E&B
proceeds with the Project, E&B agrees that it will use commercially reasonable efforts, in accordance with its own business judgment and taking into account market conditions and economic considerations, to develop the Project, in accordance with the terms and
conditions of this Agreement, the Current Land Use Regulations, the Lease and the Project
Approvals.
3.6 Public Benefits.
3.6.1 The parties acknowledge and agree that development of the Project will result in public benefits as set forth in Exhibit C. The City acknowledges the adequacy of the
consideration, including the Public Benefits, provided by E&B to the City pursuant to this
Agreement.
3.6.2 Exactions and Processing Fees.
3.6.2.1 Exactions. No Exaction may be imposed on this Project except as specifically articulated in this Agreement, and except as required by the conditions of approval
and the Mitigation Monitoring and Reporting Program contained in Exhibit D.
3.6.2.2 Processing Fees. E&B shall pay to City all applicable Processing
Fees regularly charged by the City and the amount of such Processing Fees may be increased from time to time on a non-discriminatory City-wide basis.
3.7 Public Improvements and Utilities
3.7.1 Installation Obligations. The parties hereby agree that the obligations to
install public improvements and utilities necessary for the development of the Property shall be
as provided for in the Project Approvals.
3.7.2 City-Provided Utilities: Reservation of Sufficient Capacity. To the extent that it is within the control of the City, the City shall use its best efforts to ensure that there shall
be sufficient capacity, facilities and services with respect to City-provided utilities to complete
construction of the Project and open the uses thereon to the public. The City agrees that if
limitations in the provision of utilities become necessary due to the existence of an emergency situation, they shall be applied only to the extent necessary to respond to such emergency, and shall not be applied against the Property or the Project in a discriminatory manner.
3.7.3 City-Provided Utilities: Nondiscriminatory Rates and Provision of
Service. The City agrees that rates and charges for City-provided utilities for the Property and
13 Development Agreement between City of Hermosa Beach and E&B Natural Resources
Project shall not be set or imposed in a discriminatory manner, but shall be those rates and
charges that are or would be generally applicable to any user of a comparable quantity and
quality of the utility use in the City (i.e., any other entity whose use or consumption of the utility is comparable to that of E&B), and that the City shall not discriminate against the Property or the Project in the provision of any City-provided utilities (such as potable and reclaimed water,
sewer and drainage).
3.7.4 Dedications, Reservations and Conditions of Development. The portions
of Property to be reserved or dedicated for public purposes pursuant to this Agreement, if any, shall be that property described in the Project Approvals. Unless otherwise indicated herein, the property described in the Project Approvals to be reserved or dedicated for public use shall be
dedicated by E&B as provided in the Project Approvals. The City shall take such actions as may
be necessary to vacate any prior dedications, offers to dedicate and grants of easements that are
no longer necessary for the development of the Project in accordance with this Agreement.
3.8 Mitigation Measures and Conditions of Approval. E&B shall at its own expense timely
perform all mitigation measures identified in the environmental documentation for the
Project and conditions of approval identified in the Project Approvals as set forth in
Exhibit D. E&B shall have no duty to complete the mitigation measures or conditions of approval, except as otherwise set forth in this Agreement, if the contemplated development fails to occur.
4 ASSIGNMENT, AMENDMENT AND REVIEW
4.1 Assignment
4.1.1 Right to Assign. E&B shall have the right to sell, transfer or assign its rights or interests in the Property in whole or in part (provided that no such partial transfer shall
be permitted to cause a violation of the Subdivision Map Act, Government Code Section 66410
et seq.) to any person, partnership, joint venture, firm or corporation at any time during the
Term, subject to the City’s consent, as provided in Subsection 4.1.2. The conditions and covenants set forth in this Agreement and incorporated herein shall run with the land and the benefits and burdens shall bind and inure to the benefit of the parties. Any such sale, transfer or
assignment shall include the assignment and assumption of the rights, duties and obligations
arising under or from this Agreement with respect to the property transferred and shall be made
in strict compliance with the following requirements:
(a) Except as provided in Section 6.17 of this Agreement, no sale, transfer or assignment of any right or interest under this Agreement shall be made unless made
together with the sale, transfer or assignment of all or a part of the Property and then, only in
accordance herewith.
14 Development Agreement between City of Hermosa Beach and E&B Natural Resources
(b) Concurrently with the closing of such sale, transfer or assignment,
E&B shall provide the City with an executed agreement by the purchaser, transferee or assignee
and providing therein that the purchaser, transferee or assignee expressly and unconditionally assumes the duties and obligations of E&B under this Agreement to the extent of such transfer or assignment, in a form satisfactory to the City Attorney.
(c) The purchaser, transferee or assignee shall provide the City with
security equivalent to any security previously provided by E&B to secure performance of its
obligations hereunder, if any, or under any of the Project Approvals.
Any sale, transfer or assignment under Section 4.1 of this Agreement not made in strict compliance with the foregoing conditions shall constitute a default by E&B under this
Agreement and any such assignment shall be void and of no effect. Notwithstanding the
failure of any purchaser, transferee or assignee to execute the agreement required by
subparagraph (b) of this Subsection 4.1.1, the burdens of this Agreement shall be binding upon such purchaser, transferee or assignee, but the benefits of this Agreement shall not inure to such purchaser, transferee or assignee until and unless such agreement is executed.
4.1.2 City’s Reasonable Consent Required. E&B may sell, transfer or assign its
rights or interests in the Property in whole or in part and this Agreement to any other person,
partnership, joint venture, firm, corporation, trust or other lawful entity with the City’s consent, which consent shall not be unreasonably withheld or conditioned (“Transfer”). In the event E&B desires to make such Transfer, E&B shall submit to the City a request for approval at least forty-
five (45) days prior to such Transfer, which approval shall not be unreasonably withheld,
conditioned or delayed by the City. The City may withhold, condition or delay its approval upon
finding of any of the following:
(a) The proposed purchaser, transferee or assignee lacks the financial ability to perform the obligations of this Agreement;
(b) The proposed purchaser, transferee or assignee lacks the necessary
qualifications, competence, experience or capability to implement the development plan
contemplated by the Project Approvals with the skill, expertise and quality equivalent to that of E&B; provided, however, if the proposed purchaser, transferee or assignee is a nationally or regionally recognized, or regionally known in Southern California, as an owner or developer of
oil and gas facilities, such proposed purchaser, transferee or assignee shall be deemed to have
met this requirement; or
(c) An Event of Default by E&B as defined in Section 5.1.1 has occurred and is continuing under this Agreement. E&B shall provide to the City such information that the City reasonably requests in order for the City to make any determinations
provided for by this Subsection above. E&B agrees to provide such information on a timely
basis sufficient to permit the City to make its determinations within the forty-five (45) day time
period.
4.1.3 Applicability. The provisions of Sections 4.1.1 and 4.1.2 shall not be applicable to a Transfer as a result of which E&B retains at least a fifty (50) percent interest in
15 Development Agreement between City of Hermosa Beach and E&B Natural Resources
the Property or as a result of which E&B retains at least twenty-five (25) percent interest in the
Property and maintains effective management control of the Project.
4.2 Changes and Amendments to Project
4.2.1 In the event E&B reasonably finds that a change or amendment in the Project Approvals is reasonably necessary or appropriate, E&B shall apply for any required
changes to the Project Approvals. Any such application that does not require an amendment to
the Zoning Ordinance, or General Plan shall be processed in the normal manner for processing
such matters in accordance with the Current Land Use Regulations, except as otherwise provided by this Agreement, including the Reservations of Power. Any application that requires an amendment to the Zoning Ordinance, or General Plan shall be processed in the normal manner
for processing such matters in accordance with the land use regulations in effect at the time the
application is filed.
4.2.2 Minor Changes to Project - No Amendment of Agreement
The parties acknowledge that refinements or modifications of the Project may be required during the Term. The parties agree that refinements and modifications which
constitute a "Minor Change” in the Project or Project Approvals shall not require an amendment
to this Agreement or public notice and a hearing. For any such Minor Change, the City shall not
impose as a condition to approval any Exaction, except as authorized in this Agreement. The City Manager shall be authorized to make the determination on behalf of the City whether a requested refinement or modification may be effectuated pursuant to this Section 4.2.2 or
whether the requested refinement or modification is of such a character to require an amendment
hereof pursuant to Section 4.2.3. The City Manager shall be authorized to approve any Minor
Changes hereunder on behalf of the City. If and when the parties find that Minor Changes are necessary or appropriate, they shall, unless otherwise required by law, effectuate such changes or adjustments through a letter prepared by the City Manager, which, after execution, shall be
attached hereto as addenda and become a part hereof. The City Manager shall not unreasonably
withhold or delay its determination that a requested refinement or modification is a “Minor
Change” as that term is used herein. A change to the Project Approvals shall not be deemed “Minor Change” if such change:
(a) Alters the permitted uses of the Property as a whole;
(b) Requires an amendment to the Zoning Ordinance, or General Plan,
or other legislative acts not contemplated in this Agreement;
(c) Increases the density or intensity of use of the Property as a whole;
(d) Constitutes a project requiring a subsequent or supplemental environmental impact report pursuant to Public Resources Code
Section 21166;
(e) Creates a situation adverse to public health or safety.
16 Development Agreement between City of Hermosa Beach and E&B Natural Resources
4.2.3 Other Changes. Any change in the Project which does not qualify as a
"Minor Change" as defined herein shall require an amendment to this Agreement as provided in
Section 6.9.
4.3 Annual/Special Review.
4.3.1 Annual Review. The City shall, at least every twelve (12) months during
the Term of this Agreement, review the extent of good faith substantial compliance by E&B with
the terms of this Agreement. Subject to the notice and cure procedure set forth in Section 5.1.2,
such a periodic review may result in amendment or termination of this Agreement, provided a default has been established under the terms of this Agreement. Pursuant to Government Code Section 65865.1, as amended, E&B shall have the duty to file an annual review request with
the City, pay any applicable Processing Fees for such annual review and demonstrate its good
faith compliance with the terms of this Agreement at such periodic review. Upon request by the
City, E&B shall provide such information as may be necessary or appropriate in order to ascertain compliance with this Agreement, provided however, that the parties recognize that this Agreement and the documents incorporated herein could be deemed to contain many
requirements (i.e., construction standards, landscape standards, etc.) and that evidence of each
and every requirement would be a wasteful exercise of the parties' resources. Accordingly, E&B
shall be deemed to have satisfied its duty of demonstration if it presents evidence satisfactory to the City of its good faith and substantial compliance with the major provisions of this Agreement.
4.3.1.1 Any party may address any requirement of this Agreement during
the review. However, ten (10) days’ written notice of any requirement to be addressed shall be
made by the requesting party. If at the time of review an issue not previously identified in writing is required to be addressed, the review at the request of either party shall be continued to afford sufficient time for analysis and preparation.
4.3.2 Special Review. The City Council may order a special review of
compliance with this Agreement at any time. The Director of Community Development or City
Council, as determined from time to time by the City Council, shall conduct such special reviews. Any special review shall comply with the procedural provisions of an annual review as provided by Section 4.3.1.
4.3.3 Opportunity to be Heard. Upon written request to the City by E&B, E&B
shall be permitted an opportunity to be heard orally and/or in writing at a hearing before the City
Council regarding its performance under this Agreement. E&B shall also be heard before the City Council at any required public hearing concerning a review of action on the Agreement.
4.3.4 Information to be Provided E&B. The City shall, to such an extent as is
practical, deposit in the mail to E&B a copy of staff reports and related exhibits concerning
contract performance a minimum of seven (7) business days prior to any such review or action
upon this Agreement by the Planning Commission or the City Council.
17 Development Agreement between City of Hermosa Beach and E&B Natural Resources
5 DEFAULT, REMEDIES AND TERMINATION
5.1 Enforceability.
5.1.1 Default. Subject to Sections 5.1.2 and 5.1.3, failure by any party to perform any term or provision of this Agreement required to be performed by such party shall constitute an event of default ("Event of Default”). In the event that E&B files for reorganization
or other relief under any Federal or State bankruptcy or insolvency law, whether voluntarily or
by involuntary bankruptcy or insolvency action, all provisions of this Agreement shall remain in
full force and effect unless E&B engages in an Event of Default. For purposes of this Agreement, a party claiming another party is in default shall be referred to as the "Complaining Party", and the party alleged to be in default shall be referred to as the "Party in Default".
5.1.2 Procedure Regarding Defaults.
5.1.2.1 Notice of Default. The Complaining Party shall give written notice
of default to the Party in Default, specifying the default complained of by the Complaining Party. Delay in giving such notice shall not constitute a waiver of any default nor shall it change the time of default. The Party in Default shall diligently endeavor to cure, correct or remedy the
matter complained of, provided the such cure, correction or remedy shall be completed within
the applicable time period set forth herein after receipt of written notice (or such additional, time
as may be deemed by the Complaining Party to be reasonably necessary to correct the matter). Any failures or delays by a Complaining Party in asserting any of its rights and remedies as to any default shall not operate as a waiver of any default or of any such rights or remedies. Delays
by a Complaining Party in asserting any of its rights and remedies shall not deprive the
Complaining Party of its right to institute and maintain any actions or proceedings which it may
deem necessary to protect, assert, or enforce any such rights or remedies. If an Event of Default occurs, prior to exercising any remedies, the Complaining Party shall give the Party in Default written notice of such default. Without limitation, evidence of default may arise in the course of
the regularly scheduled annual review or a special review described in Section 4.3.
5.1.2.2 Cure Periods. If the default is reasonably capable of being cured
within thirty (30) days, the Party in Default shall have such period to effect a cure prior to exercise of remedies by the Complaining Party. If the nature of the alleged default is such that it cannot practicably be cured within such thirty (30) day period, the cure shall be deemed to have
occurred within such thirty (30) day period if (i) the cure is commenced at the earliest practicable
date following receipt of the notice; (ii) the cure is diligently prosecuted to completion at all
times thereafter; (iii) at the earliest practicable date (in no event later than thirty (30) days after the curing party's receipt of the notice), the curing party provides written notice to the other party that the cure cannot practicably be completed within such thirty (30) day period; and (iv) the cure
is completed at the earliest practicable date. In no event shall the Complaining Party be
precluded from exercising remedies, subject to the preceding sentence if a default is not cured
within sixty (60) days after the first notice of default is given. Subject to the foregoing, if a party fails to cure a default in accordance with the foregoing, the Complaining Party, at its option, may terminate this Agreement pursuant to this Agreement and California Government Code Section
65868, and/or institute legal proceedings pursuant to this Agreement.
18 Development Agreement between City of Hermosa Beach and E&B Natural Resources
5.1.2.3 Procedures Regarding City Termination. Notice of intent to
terminate shall be by certified mail, return receipt requested. Upon delivery by the City of notice
of intent to terminate, the matter shall be scheduled for consideration and review by the City Council within thirty (30) days in accordance with Government Code Sections 65867 and 65868. Upon consideration of the evidence presented in said review and a determination by the City
Council based thereon, the City may give written notice of termination of this Agreement to
E&B. Any determination of default (or any determination of failure to demonstrate good faith
compliance as a part of annual review) made by the City against E&B, or any person who succeeds to E&B with respect to any portion of the Property, shall be based upon written findings supported by substantial evidence in the record. Any purported termination of this
Agreement for alleged default shall be subject to review in the Superior Court of the County of
Los Angeles pursuant to Code of Civil Procedure § 1094.5(c).
5.1.3 Institution of Legal Action. Subject to notice of default and opportunity to cure under Section 5.1.2, and subject further to the limitation on remedies set forth in Section 5.1.4, in addition to any other rights or remedies, any party to this Agreement may institute legal
action to cure, correct or remedy any default, to enforce any covenants or agreements herein, to
enjoin any threatened or attempted violation hereof, or to obtain any other remedies consistent
with this Agreement. If a legal action or proceeding is brought by any party to this Agreement because of an Event of Default under this Agreement, or to enforce a provision hereof, the prevailing party shall be entitled to reimbursement of all costs and expenses, including
reasonable attorneys’ fees, incurred in prosecuting such legal action or proceeding. This
provision is separate and several and shall survive the merger of this Agreement into any
judgment on this Agreement.
5.1.4 Remedies.
5.1.4.1 E&B’s Remedies. It is acknowledged by the parties that the City
would not have entered into this Agreement if it were liable in damages under or with respect to
this Agreement or the application thereof. In addition, the parties agree that monetary damages
are not an adequate remedy for E&B if the City should be determined to be in default under this Agreement. The parties further agree that specific performance shall be E&B’s only remedy under this Agreement and E&B may not seek monetary damages in the event of a default by City
under this Agreement. E&B covenants not to sue for or obtain monetary damages for the breach
by City of any provision of this Agreement.
5.1.4.2 City's Remedies. The parties agree that the City shall have limited remedies for monetary damages and specific performance as specifically provided for in this Section 5.1.4.2. The City shall not have any right to compel specific performance with respect to
the construction of the Project, or any obligation to construct the Project, including without
limitation Section 3.7. Further, the City shall have no right to monetary damages as a result of
E&B's failure to construct the Project or its failure to comply with Section 3.7. The City shall have the right to sue for monetary damages for failure by the E&B to pay any amounts owing under this Agreement including without limitation any amounts owing pursuant to Section 6.5.1.
In no event shall the City be entitled to consequential damages or punitive damages for any
breach of this Agreement. City also shall have the right to seek monetary damages for
19 Development Agreement between City of Hermosa Beach and E&B Natural Resources
reimbursement of the actual cost to the City incurred by the City to construct, complete,
demolish, remove or restore any physical infrastructure improvement in the public right of way
which E&B commences construction of but fails to complete. If a condition of the Project or E&B’s failure to perform any provision of this Agreement causes an immediate and serious threat to life, health, property or natural resources, the City may pursue all remedies available
under the Hermosa Beach Oil Code Chapter 21-A and Section 21 of the Lease. Additionally, in
the event of a court finding (1) a violation of this development agreement or the conditions of
approval in Exhibit D to this agreement, or (2) a violation of an order issued under Hermosa Beach Oil Code Section 21-A-10.1, a Court may impose civil penalties up to $10,000/per day for each day in which E&B is determined to be non-compliant.
5.1.4.3 Other Actions. Nothing in this Agreement shall be deemed to
waive or limit any rights and remedies that the parties would otherwise have against the other
relating to matters not covered by this Agreement.
5.2 Termination of Agreement.
5.2.1 As to the Property and all of the rights of E&B hereunder, and except as
otherwise provided in this Agreement, this Agreement shall be deemed terminated and of no
further effect upon the expiration of the Term of this Agreement unless earlier terminated
pursuant to this Agreement. Subject to the notice and cure provisions set forth in Section 5.1.2, the City shall have the right to terminate this Agreement as to the Property and the rights of E&B hereunder, in the event E&B defaults and fails to cure such default within the respective cure
period. Subject to the notice and cure provisions set forth in Section 5.1.2, E&B shall have the
right to terminate this Agreement and the rights of the City hereunder in the event the City
defaults and fails to cure such default within the respective cure period. Upon the termination of this Agreement, neither party shall have any further right or obligation with respect to the Property hereunder except with respect to any obligation to have been performed prior to such
termination or with respect to any default in the performance of the provisions of this Agreement
which has occurred prior to such termination (other than commencement of construction of either
phase) or with respect to any obligations which are specifically set forth as surviving this Agreement.
5.2.2 Termination by E&B Prior to Development. E&B is free, in its sole and
subjective business judgment, not to proceed with development of the Project and, in such an
event, to terminate this Agreement. The City acknowledges that such a right is consistent with
the intent, purpose and understanding of the parties to this Agreement. In the event E&B decides not to proceed with development of the Project and to terminate this Agreement, E&B shall provide written notice to the City of that decision and of the final, irrevocable termination of this
Agreement. Immediately upon the giving of such written notice to the City, the parties’ rights
and obligations under this Agreement shall cease, except with respect to any obligations which
are specifically set forth as surviving this Agreement. In the event of such written notice to the City terminating this Agreement, all Project Approvals other than the Lease and those included in the City’s General Plan and/or the Municipal Code, shall terminate and be extinguished.
Termination by E&B shall not affect any of E&B’s obligations to pay assessments, liens or taxes
incurred prior to the effective date of termination.
20 Development Agreement between City of Hermosa Beach and E&B Natural Resources
6 GENERAL PROVISIONS
6.1 Term.
6.1.1 Term. The Term of this Agreement shall commence upon the Commencement Date and shall be coterminous with the term of the Lease, unless terminated, modified or extended pursuant to the provisions of this Agreement or by the voters of the City.
The Term of this Agreement shall be tolled during any period of time in which a Force Majeure
Delay exists.
6.1.2 Additional Rights. Expiration or termination of this Agreement shall not affect any right vested under law independent of this Agreement.
6.2 Approval Procedure: Recordation. The following procedure shall govern approval of this
Agreement (which shall precede the execution hereof by the City):
(a) The voters shall have approved Proposition __ approving this
Agreement;
(b) The Coastal Commission shall have approved this Agreement (including any revisions to this Agreement authorized by the Proposition); and
(c) As provided in Section 65868.5 of the Development Agreement
Act, following execution by the City, the City shall cause a copy of this Agreement to be
recorded with the County Recorder within ten (10) days following the execution of the agreement by both parties. Any recording costs shall be paid by E&B.
6.3 Cooperation and Implementation. City represents that it will cooperate with E&B to the
fullest extent reasonable and feasible to implement this Agreement. Upon satisfactory
completion by E&B of all of its preliminary actions and payments of appropriate fees, City
shall promptly commence and diligently proceed to complete all steps necessary for the implementation of this Agreement and the development of the Property in accordance with the terms of this Agreement, including, but not limited to, the processing and
checking of any and all Project Approvals, agreements, covenants and related matters
required under the conditions of this Agreement, building plans and specifications, and any
other plans necessary for the development of the Property, requests for inspections and certificates of occupancy, filed by or on behalf of E&B. E&B shall, in a timely manner, provide City with all documents, plans and other information necessary for the City to
carry out its obligations hereunder.
6.4 Legal Challenges.
6.4.1 Defense. If any legal action or other proceeding is instituted by a third party or parties, other governmental entity or official challenging the validity of any provision of the Project Approvals, of the EIR or of this Development Agreement, E&B and the City shall
cooperate in defending any such action. The City shall notify E&B of any such legal action
against City within ten (10) days after the City receives service of process, except for any
21 Development Agreement between City of Hermosa Beach and E&B Natural Resources
petition for a Temporary Restraining Order, in which case the City shall notify E&B
immediately upon receipt of notice thereof.
6.4.2 Continued Processing. The filing of any lawsuit(s) by a third party (not a party to this Agreement) after the Approval Date against the City and/or E&B relating to this Agreement or to other development issues affecting the Project shall not delay or stop the
processing or issuance of any permit or authorization necessary for development of the Project,
unless the City in good faith determines that such delay is legally required.
6.5 Indemnity.
6.5.1 E&B Indemnity. To the fullest extent permitted by law, and notwithstanding the indemnification provisions set forth in the Lease, E&B hereby agrees, at its
sole cost and expense, to defend, protect, indemnify, and hold harmless the City and its elected
officials, officers, attorneys, agents, employees, consultants, volunteers, successors, and assigns
(collectively "Indemnitees") from and against any and all third party damages, costs, expenses, liabilities, claims, demands, causes of action, proceedings, expenses, judgments, penalties, liens, and losses of any nature whatsoever, including reasonable fees of accountants, attorneys,
engineers, consultants or other professionals and all costs associated therewith, arising or
claimed to arise, directly or indirectly, out of, in connection with, resulting from, or related to
any act, failure to act, error, or omission of E&B or any of its officers, agents, servants, lessees, employees, contractors, subcontractors, materialmen, suppliers or their officers, agents, servants, lessees, or employees, or arising or claimed to arise, directly or indirectly, out of, in connection
with, resulting from, or related to this Agreement or Project Approvals, or any approval
subsequently granted by the City for the development of the Property, any construction permitted
pursuant to this Agreement or Project Approvals, or any subsequent use of the Property, or any portion thereof, permitted by this Agreement or Project Approvals except for any actions resulting from the gross negligence or intentional acts of an Indemnitee. The City may elect to
participate in the litigation, in which case E&B agrees to reimburse the City for its litigation
costs and fees, including the retention of outside counsel. Neither party shall settle any such
lawsuit without the consent of the other party.
6.5.2 Survival of Indemnity. The indemnity provisions contained in Sections 6.4 and 6.5 shall survive the termination of the Agreement and are in addition to any other rights or
remedies which Indemnitees may have under the law. Payment is not required as a condition
precedent to an Indemnitee's right to recover under these indemnity provisions, and an entry of
judgment against an Indemnitee shall be conclusive in favor of the Indemnitee's right to recover under these indemnity provisions. E&B shall pay Indemnitees for any reasonable attorneys’ fees and costs incurred in enforcing these indemnification provisions.
6.6 Notices. All notices or other communications required hereunder shall be in writing and
shall be personally delivered (including by means of professional messenger service), or
sent by registered or certified mail, postage prepaid, return receipt required, or by electronic mail (provided the email transmission is followed by delivery of a "hard" copy), and shall be deemed received on the date of receipt personally, by registered or certified
mail or by facsimile.
22 Development Agreement between City of Hermosa Beach and E&B Natural Resources
Unless otherwise indicated in writing, such notice shall be sent addressed as
follows:
If to the City:
City Manager City of Hermosa Beach
1315 Valley Drive
Hermosa Beach, CA 90254
With a copy to:
Michael Jenkins, Esq.
Jenkins & Hogin
1230 Rosecrans Avenue, Suite 110 Manhattan Beach, CA 90266 Telephone: (310) 643-8448
Fax: (310) 643-8441
If to E&B:
E & B Natural Resources Management Corporation 1600 Norris Road
Bakersfield, CA 93308
Telephone: (661) 679-1797 Fax:
With a copy to:
[name]
Telephone:
Fax:
6.7 No Third Party Beneficiaries. This Agreement is made and entered into for the sole
protection and benefit of the parties to this Agreement and their successors and assigns. No
other person shall have any right of action based upon any provision of this Agreement.
6.8 Time of Essence. Time is of the essence for each provision of this Agreement of which time is an element.
23 Development Agreement between City of Hermosa Beach and E&B Natural Resources
6.9 Modification, Amendment or Extension. Subject to any notice and hearing requirements
imposed by law, this Agreement may be modified, amended and/or extended from time to
time by mutual written consent of the City Council and E&B as set forth in Government Code Sections 65867, 65867.5 and 65868 and the Approval Ordinance and Chapter 19.66 of the Municipal Code.
6.10 Conflicts of Law. In the event that state, regional or federal laws or regulations enacted
after the Approval Date or the action or inaction of any other affected governmental
jurisdiction prevent or preclude compliance with one or more provisions of this Agreement or require changes in plans, maps or permits approved by the City, the parties shall (a) provide the other party with written notice of such state, regional or federal restriction,
provide a copy of such regulation or policy and a statement of conflict with the provisions
of this Agreement, and (b) E&B and the City staff shall, within thirty (30) days, meet and
confer in good faith in a reasonable attempt to modify this Agreement, but only to the minimum extent necessary to comply with such federal, regional or state law or regulation. Thereafter, regardless of whether the parties reach an agreement on the effect of such
federal, regional or state law or regulation upon this Agreement, the matter shall be
scheduled for hearings before the Council. Ten (10) days’ written notice of such hearing
shall be given, pursuant to Government Code Sections 65090 and 65867. The Council, at such hearing, shall determine the exact modification or suspension which shall be necessitated by such federal, regional or state law or regulation. E&B, at the hearing, shall
have the right to offer oral and written testimony. Any modification or suspension shall be
taken by the affirmative vote of not less than a majority of the authorized voting members
of the Council. Any suspension or modification may be subject to judicial review. The City shall cooperate with E&B in the securing of any permits which may be required as a result of such modifications or suspensions, so long as the cooperation by City will not
require City to incur any cost, liability or expense without adequate indemnity against or
right of reimbursement therefore from E&B. . If E&B and the City do not agree on the
modification or suspension, either party may elect to terminate this Agreement, upon 30 days’ written notice to the other Party.
6.11 Waiver. No waiver of any provision of this Agreement shall be effective unless in writing
and signed by a duly authorized representative of the party against whom enforcement of a
waiver is sought and referring expressly to this Section. No waiver of any right or remedy
in respect of any occurrence or event shall be deemed a waiver of any right or remedy in respect of any other occurrence or event
6.12 Successors and Assigns. Except as expressly provided to the contrary in this Agreement,
the burdens and obligations of this Agreement shall be binding upon, and the benefits of
this Agreement shall inure to, all successors in interest to the parties to this Agreement and
all successors in interest to the Property or any portion thereof or any interest therein, and shall be covenants running with the land.
6.13 Governing State Law. This Agreement shall be construed in accordance with the laws of
the State of California.
24 Development Agreement between City of Hermosa Beach and E&B Natural Resources
6.14 Constructive Notice and Acceptance. Every person who now or hereafter owns or acquires
any right, title or interest in or to any portion of the Property is and shall be conclusively
deemed to have consented and agreed to every provision contained herein, whether or not any reference to this Agreement is contained in the instrument by which such person acquired an interest in the Property.
6.15 Statement of Compliance. Within thirty (30) days following any written request, in
accordance with the notice provisions of this Agreement, which either party may make
from time to time, and upon payment of a fee to the City to reimburse the City for its reasonable expenses associated herewith, the other party shall execute and deliver to the requesting party a statement certifying that: (a) this Agreement is unmodified and in full
force and effect or, if there have been modifications hereto, that this Agreement is in full
force and effect, as modified, and stating the date and nature of such modifications; (b)
that this Agreement is in full force and there are no current uncured defaults under this Agreement or specifying the dates and nature of any such defaults, and manner of cure; (c) any other information reasonably requested. The failure to deliver such statement within
such time shall be conclusive upon the party which fails to deliver such statement that this
Agreement is in full force and effect without modification except as may be represented by
the requesting party and that there are no uncured defaults in the performance of the requesting party. Said statement(s) shall be in the form reasonably satisfactory to the City, E&B and to any purchaser, lender, title company, governmental agency, or other person
reasonably requesting such statement(s) in connection with sale, use, development,
construction, financing or marketing of the Property. The City and E&B, for their own
respective uses, shall also be entitled to obtain a statement of compliance at any reasonable time.
6.16 Insurance. E&B shall be subject to the insurance requirements of section 18(b) of and
Exhibit C to the Lease, and the additional insurance requirements set forth herein. To the
extent that the provisions set forth inconsistent terms, the provisions set forth herein shall
prevail. E&B shall demonstrate to the City that it carries on the E&B Project General Liability Insurance, in an aggregate amount of not less than $15,000,000, combined limits, $15,000,000 in Well Control Drilling Insurance, and a policy of Pollution Legal Liability
Insurance in an aggregate amount of not less than $30,000,000 combined limits. This
insurance shall provide coverage for claims for bodily injury, environmental or property
damage that result from pollution conditions at, on or emanating from the E&B facilities. The General Liability Insurance policy shall include the following endorsements or similar endorsement providing equivalent coverage: CG 04 20 (Pollution—Limited Exception for
a Short-Term Pollution Event); and CG 22 62 (Underground Resources and Equipment
Coverage).
There shall be no modification of the General Liability Insurance policy limiting the scope of coverage for liability arising from oil and gas producing operations, using any of the following endorsements or their equivalents: CG 22 73 (Exclusion—Oil or Gas Producing
Operations); CG 22 57 (Exclusion—Underground Resources and Equipment); CG 22 47
(Exclusion—Saline Substances Contamination); and CG 21 42 (Exclusion—Explosion,
Collapse, and Underground Property Damage Hazard (Specified Operations)) or CH 21 43
25 Development Agreement between City of Hermosa Beach and E&B Natural Resources
(Exclusion—Explosion, Collapse, and Underground Property Damage Hazard (Specified
Operations Excepted)). The Pollution Legal Liability Insurance policy may not contain an
exclusion of onsite remediation costs if such an exclusion would exclude, remove or impair coverage for onsite remediation performed in response to a governmental order, demand, warning or other legally enforceable requirement. Should an exclusion exist in
the policy, E&B shall post a bond to cover costs associated with remediation.
The insurance policies must be secured through an insurance company having a Best’s
rating of “A – VII” or better. E&B shall submit one or more certificates of insurance to the Community Development Department to be approved by the City Risk Manager. The General Liability and Pollution Legal Liability Insurance policies shall be in place prior to
issuance of the Permit and shall remain in full force and effect until revocation of the
permit. E&B shall submit certificates of insurance 30 days in advance of the renewal
anniversary of each policy. Such certificate(s) shall evidence the coverages described above, shall name the City of Hermosa Beach as an additional insured as to each policy provided, and shall afford the City 60 days advance notice of cancellation or non-renewal.
The City Risk Manager may adjust the aggregate coverage amount specified above over
time depending on factors such as inflation, modifications to State and Federal oil spill
financial responsibility guidelines, and project modifications. In making such adjustments, the City Risk Manager shall give due regard to the cost and availability of such coverage, and shall allow E&B a reasonable period of time in which to place such coverage.
The Well Control Drilling Insurance policy shall only be required to be in effect while
drilling operations are being conducted. E&B may satisfy the Well Control Drilling
Insurance requirement by having its drilling contractor or subcontractors supply the required insurance, so long as the aggregate insurance maintains the total required.
6.17 Mortgagee Protection. The parties hereto agree that this Agreement shall not prevent or
limit the right of E&B at its sole discretion, to encumber its leasehold interest in the
Property or any portion thereof or any improvement thereon by any mortgage or other security device (collectively "Mortgage") securing financing of the purchase, development or operation of the Property or any portion thereof (including, without limitation, any
combination of purchase financing, construction financing, bridge loans, take-out and
permanent financing), as provided in this Agreement; provided, however, that any such
Mortgage shall be subordinate to the rights and obligations under this Agreement.
The City acknowledges that prospective lenders providing such financing may request certain acknowledgements, estoppels, interpretations and/or modifications of this
Agreement, and agrees upon request, from time to time, and upon payment of a fee to the
City to reimburse the City for its reasonable expenses associated herewith, to meet with
E&B and representatives of such lenders to discuss in good faith any such request for acknowledgements, estoppels, interpretations and/or modifications. The City shall not unreasonably withhold its consent to and/or execution of any such requested
acknowledgements, estoppels, interpretations and/or modifications which the City
26 Development Agreement between City of Hermosa Beach and E&B Natural Resources
determines is consistent with the intent and purposes of this Agreement and reasonably
protects the interests of the City under this Agreement.
If the City timely receives a request from a Mortgagee requesting a copy of any notice of default given to E&B under the terms of this Agreement, the City shall provide a copy of that notice to the Mortgagee within ten (10) days of sending the notice of default to E&B,
as the case may be. The Mortgagee shall have the right, but not the obligation, to cure the
default during the remaining cure period allowed such party under this Agreement.
Any Mortgagee who comes into possession of E&B’s interests in the Property, or any part thereof, pursuant to foreclosure of the mortgage, shall take the Property, or part thereof, subject to the terms of this Agreement; in no event shall any such Mortgagee or its
successors or assigns be entitled to a building permit or occupancy certificate until all fees
and other obligations due by E&B under this Agreement have been performed and/or paid to
the City, all defaults have been cured, and all otherwise applicable conditions to such permit or certificate have been satisfied.
6.18 Covenant of Good Faith and Fair Dealing. No party shall do anything which shall have the
effect of harming or injuring the right of the other parties to receive the benefits of this
Agreement.
6.19 Covenant of Cooperation. E&B and the City shall cooperate with and assist each other in the performance of the provisions of this Agreement, including assistance in obtaining permits for the development of the Property or the Project which may be required from
public agencies other than the City, so long as the cooperation by City will not require City
to incur any cost, liability or expense without adequate indemnity against or right of
reimbursement therefore from E&B . E&B reserves the right to challenge any ordinance, measure, moratorium or other limitation in a court of law if it becomes necessary to protect the development rights vested in the Property pursuant to this Agreement.
6.20 Justifiable Reliance. The City acknowledges that, in investing money and planning effort
in and to the Project and all public improvements and dedication offers required hereunder,
and in undertaking commencement of the Project, E&B will be doing so in reliance upon the City's covenants contained in this Agreement and upon the enforceability of this Agreement, and the City agrees that it will be reasonable and justifiable for E&B to so
rely.
6.21 Project Is Private Undertaking. It is specifically understood and agreed to by and between
the parties hereto that: (1) the subject development is a private development; (2) except for the obligations of the City described herein, if any, the City has no responsibilities for or duty to third parties concerning any public improvement until such time and only until
such time that the City accepts the same pursuant to the provisions of this Agreement; (3)
E&B shall have full power over and exclusive control of the development of the Project
herein described subject only to the limitations and obligations of E&B under this Agreement and the Project Approvals; and (4) the contractual relationship between the City and E&B is such that E&B is not an agent of the City nor is City an agent of E&B.
27 Development Agreement between City of Hermosa Beach and E&B Natural Resources
Notwithstanding the foregoing, nothing contained in this Agreement shall be deemed to
waive or modify any otherwise applicable obligations the City, acting in its governmental
capacity and not as a party to this Agreement, may have to E&B or any other party, under and in accordance with all applicable laws.
6.22 Further Actions and Instruments. The parties to this Agreement shall cooperate with and
provide reasonable assistance to the other parties to the extent contemplated in the
performance of all obligations under this Agreement and the satisfaction of the conditions
of this Agreement. Upon the request of any party, the other parties shall promptly execute, with acknowledgment or affidavit if reasonably required, and file or record such required instruments and writings and take any actions as may be reasonably necessary under the
terms of this Agreement to carry out the intent and to fulfill the provisions of this
Agreement or to evidence or consummate the transactions contemplated by this
Agreement.
6.23 Section Headings. All Article and Section headings and subheadings are inserted for convenience only and shall not affect any construction or interpretation of this Agreement.
6.24 Enforced Delay (Force Majeure).
(a) In addition to specific provisions of this Agreement, performance by any
party hereunder, including making payments, shall not be deemed to be in default where delays or defaults are due to war, insurrection, strikes, walkouts, riots, floods, earthquakes, fires, casualties, acts of God, litigation not commenced by a Party to this Agreement
claiming the enforced delay (including without limitation, third party legal challenges to
the Project, the Project Approvals or the environmental clearance for the Project Approvals
and the Project), unavailability of materials, unforeseeable events beyond the control of E&B, governmental restrictions including moratoria imposed or mandated by governmental entities other than the city (but only as to delays or defaults on the part of
E&B), enactment of conflicting state or federal laws or regulations (but only if the party
claiming delay complies at all times with the provisions of this Agreement pertaining to
such conflicting laws), delays caused by the delay or failure by any entity other than the party claiming such delay to provide financing for or construction of needed public facilities or infrastructure as contemplated or required by this Agreement, delays due to the
enforcement of environmental regulations, litigation brought by third parties, or similar
bases for excused performance. Any period of enforced delay provided for in this Section
shall run concurrently with any period of enforced delay under the Lease. E&B shall only be required to provide one notice claiming such extension for enforced delay under both this Agreement and the Lease.
(b) An extension of time for any such cause including an extension of the
Term (a "Force Majeure Delay") shall be for the period of the enforced delay and shall
commence to run from the time of the commencement of the cause, if notice by the party claiming such extension is sent to the other parties within thirty (30) days of knowledge of the commencement of the cause. Notwithstanding the foregoing, none of the foregoing
events shall constitute a Force Majeure Delay unless and until the party claiming such
28 Development Agreement between City of Hermosa Beach and E&B Natural Resources
delay and interference delivers to the other party written notice describing the event, its
cause, when and how such party obtained knowledge, the date the event commenced, and
the estimated delay resulting therefrom. Any party claiming a Force Majeure Delay shall deliver such written notice within thirty (30) days after it obtains actual knowledge of the event. The time for performance due to a Force Majeure Delay will be extended for such
period of time as the cause of such delay exists (whether or not it extends beyond the Term
or the Extended Term) but in no event for longer than for such period of time.
(c) Notwithstanding the first sentence of paragraph (b), above, the following shall apply: (i) E&B shall be entitled to a Force Majeure Delay for a period longer than the period of enforced delay if the City Council determines that such longer period is
reasonably required; and (ii) E&B shall be entitled to a Force Majeure Delay
notwithstanding the fact that E&B may not have given timely notice to the City, if the City
Council determines that such Force Majeure Delay is reasonably required.
(d) A Force Majeure Delay shall not include the existence of any adverse or difficult market or economic conditions.
6.25 Emergency Circumstances.
(a) If, as the result of specific facts, events or circumstances, the City believes
that a severe and immediate emergency threat to the health or safety of the City or its residents, meeting the requirements of subparagraph (b), below, requires the modification, suspension or termination of this Agreement, the City will, after reasonable notice to E&B
(in light of all the circumstances), hold a hearing on such facts, events or circumstances, at
which E&B shall have the right to address the City Council. The City shall have the right
to modify, suspend or terminate this Agreement, in whole or in part, if, following such hearing, the City Council determines that such modification, suspension or termination is required in order to protect the health and safety of the City and its residents.
(b) This Section 6.25 governs generally applicable emergencies in the area not
specifically related to or caused by the Project. For purposes of this Section 6.25, an
emergency must meet each of the following criteria: (i) it must be based on genuine health, safety and general welfare concerns (other than general growth management issues); (ii) it must arise out of a documented emergency situation, as declared by the
President of the United States, Governor of California, or the Mayor or City Council of the
City of Hermosa Beach; and (iii) based upon its terms or its effect as applied, it does not
apply exclusively or primarily to the Property or the Project. To the extent possible, any such action by the City shall be taken in a manner so as to provide E&B with the rights and assurances provided under this Agreement.
6.26 Severability. Invalidation of any of the provisions contained in this Agreement, or of the
application thereof to any person, by judgment or court order, shall in no way affect any of
the other provisions hereof or the application thereof to any other person or circumstance, and the same shall remain in full force and effect, unless enforcement of this Agreement, as so invalidated, would be unreasonable or inequitable under all the circumstances or would
29 Development Agreement between City of Hermosa Beach and E&B Natural Resources
frustrate the purposes of this Agreement and/or the rights and obligations of the parties
hereto.
6.27 Interpretation. The language in all parts of this Agreement shall in all cases be construed simply, as a whole and in accordance with its fair meaning and not strictly for or against any party. The parties hereto acknowledge and agree that this Agreement has been
prepared jointly by the parties and has been the subject of arm's length and careful
negotiation over a considerable period of time, that each party has independently reviewed
this Agreement with legal counsel, and that each party has the requisite experience and sophistication to understand, interpret and agree to the particular language of the provisions hereof. Accordingly, in the event of an ambiguity in or dispute regarding the
interpretation of this Agreement, this Agreement shall not be interpreted or construed
against the party preparing it, and instead other rules of interpretation and construction
shall be utilized.
6.28 Counterparts. This Agreement may be executed in duplicate counterpart originals, each of which is deemed to be an original and all of which when taken together shall constitute one
and the same instrument.
6.29 Entire Agreement. This Agreement consists of __ pages and ______________ exhibits
(designated __ through __), which constitute the entire understanding and agreement of the parties, and, with the exception of (1) the Lease,; (2) the Settlement Agreement; (3) the Agreement to Implement the Settlement Agreement dated July 23, 2014; and (4) the
Reimbursement Agreement dated May 17, 2012; shall supersede any prior agreements,
discussions, commitments, representations or agreements, written or oral, between the
parties hereto.
IN WITNESS WHEREOF, the parties have each executed this Agreement on the date first written above.
CITY OF HERMOSA BEACH
E&B NATURAL RESOURCES
MANAGEMENT CORPORATION
By:____________________________ By:___________________________________
Mayor
President
ATTEST:
By: _____________________________
30 Development Agreement between City of Hermosa Beach and E&B Natural Resources
City Clerk
APPROVED AS TO FORM:
By: ____________________________ By: _________________________________
City Attorney Attorneys for E&B Natural Resources
Management Corporation
Exhibit A Development Agreement between City of Hermosa Beach and E&B Natural Resources
EXHIBIT “A”
LEGAL DESCRIPTIONS
555 6TH STREET, HERMOSA BEACH, CALIFORNIA 90254
That portion of APN 4187-031-900 described as:
That portion of Lot A lying south of a line commencing at the northeasterly corner of Lot 11,
Block U, Tract 2002, as per Map recorded in Map Book 22, Pages 154 and 155, in the Office of
the Recorder of the County of Los Angeles, and continuing along the easterly prolongation of the
northerly line of said Lot 11, to the easterly line of Lot A; Lots 11 through 18, Block R, Tract
2002; Lots 11 through 18, Block U, Tract 2002; and the vacated portion of Bard Street adjoining
said lots.
601 CYPRESS AVENUE , HERMOSA BEACH, CALIFORNIA 90254
APN 4187-030-037
Lots 11 Through 14, Block H, Tract 1686, M.B. 20- 188, City Of Hermosa Beach
636 CYPRESS AVENUE, HERMOSA BEACH, CALIFORNIA 90254
APN 4187-031-022
Lots 5 And Lot 6, Block I, Tract # 1686, M.B. 20- 188, City Of Hermosa Beach .
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Directional Drilling
Drilling wells at
multiple angles to
better reach and
produce oil and gas
reserves.
Directional drilling
allows for multiple
wells from the same
drilling location.
EXHIBIT “B”
PROJECT DESCRIPTION
(From Section 2.0 of FEIR) Revised with removal of City maintenance yard discussion The Proposed City Maintenance Yard Project described herein is a separate
project that the City will undertake if the voters approve the Proposed Oil
Project. This Development Agreement only applies to the Proposed Oil Project described below, and except for any obligations explicitly assigned
to E&B herein and payments from E&B for the City Maintenance Yard
Project, the Proposed City Maintenance Yard Project is not governed by
this Agreement. To the extent feasible, references to the Proposed City
Maintenance Yard have been removed from the Project Description.
Project Description
E&B Natural Resources Management Corporation (E&B), the Applicant, is proposing the E&B
Oil Drilling & Development Project (Proposed Oil Project) on a 1.3-acre site located in the City
of Hermosa Beach (City). The site for the Proposed Oil Project (Project Site), as shown in Figure 2.1, would be located at 555 6th Street, bounded on the east by Valley Drive and on the
south by 6th Street, approximately seven blocks east of the beach and the Pacific Ocean. Oil and
gas pipelines constructed and used by the Project would extend from the Project Site to one of
four potential valve box locations for the oil line and to a Southern California Gas (SGE)
metering station for the gas line. The Project Site is owned by the City and is currently used as the City (Public Works) Maintenance Yard. The Applicant has leased the Project Site from the
City for the implementation of the Proposed Oil Project.
The Proposed Project is composed of two parts: 1) the relocation of the City Maintenance Yard
(called the Proposed City Maintenance Yard Project); and 2) the development of an oil and gas
facility on the current City Maintenance Yard site (called the Proposed Oil Project). In order to clear the current City Maintenance Yard site (called the Project Site) for the construction of the
proposed oil and gas facility, the City Maintenance Yard would be temporarily relocated during
Phase 1 of the Proposed Project. If it is determined that the production of oil and gas on the
Project Site would be economically viable (Phase 2 of the Proposed Project), construction of the
permanent City Maintenance Yard would be completed once Phase 3 of the Proposed Project begins. The permanent Proposed City Maintenance Yard Project
has two options: a Parking Option, which would add a net 97
parking spaces with a below grade parking garage, and a No
Added Parking Option, which would have the same amount of
parking as is currently available.
This Project Description reflects information contained in the
Project Application submitted to the City of Hermosa Beach by
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
the Applicant, along with supporting information provided in conjunction with the Project
Application (E&B Natural Resources, Planning Application and Appendices, Volumes 1 – 3,
November 14, 2012; Response to Planning Application Completeness Review, April 11, 2013;
Response to Requested Clarifications, June 24, 2013; Quantitative Risk Analysis, July 3, 2013; Errata, July 22, 2013).1Information related to the relocation of the City Maintenance Yard and
construction and operation of the Proposed City Maintenance Yard is derived from information
provided by the City of Hermosa Beach Public Works Department. The description of the
Proposed Project incorporates the essential elements of the Project as it is proposed, including all
phases and major components as well as the locations of all proposed offsite activities (in addition to those occurring on the Project Site). More detailed information related to some
aspects of the Proposed Project (including proposed operational parameters and design features)
may be found within individual sections of the Final Environmental Impact Report (EIR), where
considered relevant to the discussion of specific environmental issues and/or effects. In addition,
a description of the environmental setting and current conditions related to the environmental issues is presented in the Environmental Setting subsection of the individual sections of the
Final EIR.
This section discusses the Project objectives, historical operations on the Proposed Project Sites,
the four phases of the Proposed Oil Project, scheduling, vehicle trip and employee requirements,
and necessary permitting associated with the Proposed Project. A number of technical drawings related to the Proposed Project design and layout are included in Appendix A to the Final EIR.
2.1 Project Overview
The Applicant proposes the development of an onshore drilling and production facility site that
would utilize directional drilling of 34 wells (30 oil wells, four wells for water disposal/injection)
to access the oil and gas reserves in the tidelands (pursuant to a grant by the State of California to the City) and in an onshore area known as the uplands. Both of these areas are located within the
Torrance Oil Field within the jurisdiction of the City. In addition, the Proposed Project would
result in the installation of offsite underground pipelines for the transportation of the processed
crude oil and gas from the Project Site to purchasers, extending through the Cities of Redondo
Beach and Torrance. The Applicant proposes a laydown site for supply staging/storage within the basement level of the industrial building at 601 Cypress Avenue during the construction
phases. The Applicant also proposes to construct a parking lot at 636 Cypress Avenue for use by
some of its construction employees/contractors on weekdays and by the public at other times.
The City Maintenance Yard is proposed to be relocated to a temporary facility to be established
on the rear (westerly) portion of the City Hall site (1315 Valley Drive) prior to and during the initial phase of the Proposed Oil Project so that the maintenance operations could be moved
when the existing City Maintenance Yard is demolished as part of Proposed Oil Project
activities. The construction of the permanent City Maintenance Yard would be undertaken on the
site now occupied by the Hermosa Self-Storage (552 11th Place) after the Applicant completes
1 Information submitted by the Project Applicant is available for public review at the City of Hermosa Beach
Community Development Department.
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
the testing phase of the Proposed Oil Project in Phase 2. As indicated below, the permanent City
Maintenance Yard and the oil and gas facility on the Project Site would be constructed at the
same time during Phase 3 of the Proposed Project.
The timeframe from commencement of the Proposed Project until the permanent oil and gas facility would be operational is estimated to be approximately 3.25 years. The existing lease (Oil
and Gas Lease No. 2) allowing drilling into the tidelands provides for a 35-year period.
Table 2.1 summarizes events in the Proposed Project timeline. Specifics of each of the Proposed
Project components are described in the following sections.
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Figure 2.1 Proposed Project Location
Source: Project Application, Amendments and Appendices
Hermosa Beach
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Table 2.1 Proposed Project Schedule Summary
Phase Year 1 Year 2 Year 3 Year 4 Year 5 Year 6
1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4
Temporary City Yard
Oil Project Phase 1
Oil Project Phase 2
Drill
Test
Permanent City Yard
Oil Project Phase 3*
Oil Project Phase 4*
Drill
Operate Continuously for 30+ years
Re-drills Average 30 days/year, max 150 days/yr**
Note: * If the test phase is determined to be successful, Phase 3 and 4 would occur. For construction
only. Does not include permitting timeframe. ** These are the maximum proposed by the Applicant. The 150 days per year would occur once every 5 years. Most likely re-drill activity would be lower.
2.2 Proposed Project Objectives
Pursuant to Section 15124(b) of the California Environmental Quality Act (CEQA) Guidelines, the description of the Proposed Project is to contain “a clearly written statement of objectives”
that would aid the lead agency in developing a reasonable range of alternatives to evaluate in the
EIR and would aid decision makers in preparing findings and, if necessary, a statement of
overriding considerations. The City is the lead CEQA agency which prepared the EIR, considered the EIR for certification and is placing the Proposed Project on the ballot. Project approvals will be made by the electorate of the City of Hermosa Beach.
As part of the Project Application, the Applicant provided its stated objectives for the Proposed
Oil Project, which consist of the following:
1. Develop the Proposed Oil Project consistent with the 1993 Conditional Use Permit and the March 2, 2012 Settlement Agreement, with the utilization of directional drilling techniques from the Project Site, which is the current City Maintenance Yard;
2. Maximize oil and gas production from the Torrance Oil Field within the City’s
jurisdiction, thereby maximizing the economic benefits to the City;
3. Provide an oil and gas development project on the Project Site that utilizes the latest technology and operational advancements related to safety and production efficiency in order to provide a project that would be safe and would meet the applicable
environmental requirements;
4. Conduct construction and drilling activities on the Project Site incorporating
technological advancements, operational practices, and design features related to air quality, odors, noise, hazards, and water quality to minimize the potential impacts on the adjacent community and the environment;
5. Provide landscaping, hardscape, signage, lighting, and other design features to minimize
the visual effects of the Proposed Oil Project on the adjacent community; and
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
6. Implement operational practices and incorporate design features to provide safe vehicular
ingress and egress during temporary construction activities and the ongoing operation of
the Proposed Oil Project.
Pursuant to the March 2, 2012 Settlement Agreement between the City of Hermosa Beach, E&B, and Macpherson Oil Co., the City’s primary objective is to comply with the California
Environmental Quality Act and place on the ballot a measure allowing the City of Hermosa
Beach electorate to decide whether or not to approve the Applicant’s Proposed Oil Project and a
Development Agreement to vest the Project so that, if approved, the Project cannot later be
invalidated by a vote of the people.
In the event that voters approve the Proposed Oil Project, the City would need to relocate the
City Maintenance Yard. Under those conditions, the City's objectives for relocation of the City
Maintenance Yard would be to:
1. Provide City Yard Maintenance facilities that support provision of high-quality City
services in an integrated and cost-efficient manner; 2. Consolidate City facilities and functions for maximum efficiency and flexibility;
3. Minimize disruption of City functions during relocation of the City Maintenance Yard;
4. Ensure the relocated City Maintenance Yard is compatible with surrounding uses; and
5. Ensure there is no net loss of public and employee parking spaces as a result of both the
Proposed Oil Project and the relocation of the City Maintenance Yard consistent with the Preferential Parking Program approved by the Coastal Commission.
2.3 Historical and Current Operations
Oil drilling and production in the Los Angeles Basin has a long history. According to the
California Division of Oil, Gas, and Geothermal Resources (DOGGR) database, almost 30,000
oil wells have been drilled in the Los Angeles Basin in the last 100 to 150 years. Figure 2.2 shows the location of these wells.
The Proposed Oil Project would drill into the western edge of the Torrance Oil Field (see Figure
2.2). Most of the production from the Torrance Oil Field has been generated from wells drilled
in the City of Torrance, with some drilling in the Cities of Redondo Beach and Hermosa Beach.
There have been approximately 1,500 wells drilled in the Torrance Oil Field historically.
Although the Project Site is relatively flat, it is underlain by windblown sand dunes that
previously covered the region, resulting in uneven ground due to natural conditions. In the
1920s and 1930s, the northeastern portion of the Project Site had a large depression that was
mined for sand. Around 1927, the City’s dump and refuse burner were located on the Project
Site, and, by 1947, the depression was filled. The resulting former landfill is approximately 45 feet deep and is filled with glass, porcelain, and ceramic towards the bottom and soils containing
miscellaneous metals, wires, glass, and other materials toward the top (i.e., closer to the ground
surface). Between the depths of 3 feet and 25 feet below ground surface (bgs), the former
landfill contains some soil with lead at concentrations above the Environmental Protection
Agency (EPA) Region 9 Industrial Regional Screening levels. In addition, soils impacted with
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
total petroleum hydrocarbons (TPH) were found at depths of 25 to 44 feet bgs within the central
portion of the landfill. For a detailed discussion of the soil conditions on the Project Site, refer to
Section 4.7, Geological Resources/Soils, of the Final EIR.
Figure 2.2 Historical Wells Drilled in the Los Angeles Basin
Source: DOGGR
In 1930, an oil well (Stinnett Oil Well No. 1) was drilled in the western portion of the Project Site. The oil well was abandoned in 2005, consistent with the then-current standards of the
DOGGR. During the mid-1940s, the first building was constructed on the Project Site for City
maintenance uses, with the last building constructed in the 1980s. Since the 1990s, with the
exception of the addition of trailers, storage containers, and sheds, the Project Site has generally
remained unchanged.
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
The Project Site is currently developed as the City Maintenance Yard, and the Proposed Oil
Project would require the relocation of the City Maintenance Yard. As indicated in Figure 2.3,
existing development on the Project Site consists of three buildings, two trailers, storage
containers, sheds, trash bins, a propane tank, concrete paving and asphalt, fencing, and masonry walls. In addition, within the boundaries of the Project Site, there is an asphalt parking area in
the southern portion of the City Maintenance Yard that provides 15 parking spaces for
employees (Monday through Thursday between the hours of 6:00 a.m. and 6:00 p.m.) and for the
public after hours (6:00 p.m. to 6:00 a.m.) and on weekends and holidays.
Existing site contamination from historical site uses is also shown in Figure 2.3. According to an Environmental Site Assessment prepared in 2012 (Brycon 2012), 10 of the 73 soil samples taken
exceeded Regional Water Quality Control Board guidelines for total petroleum hydrocarbons, all
within the mid range hydrocarbons (C13-C22). Volatile organic carbons were not present in any
of the samples at concentrations above the EPA Region 9 Industrial Regional Screening Levels.
Six of the samples exceeded the EPA Region 9 Industrial Regional Screening Levels for lead. In addition, a series of groundwater borings conducted in 2013 (Brycon 2013) found the presence
of total petroleum hydrocarbons, lead, barium, and arsenic in the groundwater below the City
Maintenance Yard that exceeded the Maximum Contaminant Levels (MCLs) established for
drinking water by the Regional Water Quality Control Board.
The immediately adjoining properties were sparsely developed into the 1940s, with a few residential units located to the northwest of the Project Site. Post 1940s, significant development
occurred with industrial buildings being constructed to the south and west of the Project Site by
1953 and to the north of the Project Site by the 1960s. By 1960, the buildings to the west of the
Project Site were identified as containing a building material warehouse, a boat repair shop, and
a contractor’s storage yard.
By 1960, the building to the south was being utilized as a planter mix manufacturing site. Since
the 1960s, the various adjoining buildings have been utilized for multiple small businesses as
industrial/commercial uses. To the east, from the late 1800s, there was a railroad right-of-way
(ROW) that was utilized by the Santa Fe Railway. During the 1960s, the railroad ROW was
converted to a greenbelt/park (Veterans Parkway - Hermosa Valley Greenbelt (Greenbelt)), followed by a Council initiative in 1987 directing the City of Hermosa Beach to acquire the
Railroad ROW for public use as parkland and open space in perpetuity; the property is zoned
O-S-1 Restricted Open Space.
Currently, other land uses adjacent to the Project Site (on the same block between 8th and
6thStreet and Cypress Avenue and Valley Drive) are commercial/industrial (Cypress Auto Body, A&B Heating, JB Plumbing, McGivern Surfboard Manufacturing, Buddhist Meditation Center,
NUWORK, a recording studio and other various small commercial/industrial businesses), with
some residential uses along 8th Street to the north. Adjacent blocks include residential uses
located 150 feet to the north of the Project Site, 250 feet to the west and 180 feet to the east (east
of the Greenbelt), with small commercial/industrial uses and the Beach Cities Self Storage facility located to the immediate south across 6th Street with its required parking lot abutting the
southwest corner of the Project Site. Figure 2.4 shows the southern area of the City of Hermosa
Beach along with land uses.
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Figure 2.3 Existing Site Conditions
Source: Applicant Project Application, DOGGR well database, Phase 2 Environmental Site Assessments
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Figure 2.4 Project Site and Area Land Uses (Zoning Map)
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Source: City of Hermosa Beach Zoning Map, November 2013
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
PHASE 1
Site Preparation
6-7 Months
2.4 Proposed Oil Project Phases
The Proposed Oil Project would occur in the following four phases:
• Phase 1: Site Preparation;
• Phase 2: Drilling and Testing;
• Phase 3: Final Design and Construction; and
• Phase 4: Development and Operations.
Each phase is discussed in the following sections.
The Applicant proposes a facility designed for a maximum capacity of 8,000 barrels per day
(bpd) of crude oil and 2.5 million standard cubic feet per day (scfd) of produced gas at
completion of the drilling stage of the Proposed Oil Project in Phase 4. The operational
parameters of the Proposed Oil Project are summarized in Table 2.2. Prior to the initiation of the Proposed Oil Project, it would be required that plans be submitted by the Applicant to the City and other permitting authorities for review and approval. These would include coastal
development permits, oil and gas well permits, demolition plans, grading plans, utility and
electrical plans, cement/foundation plans, landscaping plans, street and ROW
improvement/modification plans, and construction plans, amongst others. Figure 2.5 shows the Project Site along with the electrical and pipeline connections and the Cypress Avenue parking lot.
2.4.1 Phase 1 Site Preparation
The purpose of Phase 1 would be to prepare the Project Site
for drilling and testing as well as for the subsequent phases of the Proposed Oil Project. It is anticipated that Phase 1 would occur for approximately six months. Prior to Phase 1
activities, the temporary City Maintenance Yard would be
installed.
2.4.1.1 Phase 1 Construction Activities
Phase 1 would consist of the following construction activities:
• Underground existing overhead utilities;
• Construction of modifications to intersection of 6th Street and Valley Drive;
• Relocation of City Maintenance Yard to the temporary site;
• Clearance of Project Site;
• Construction of retaining walls and rough grading;
• Installation of perimeter fencing;
• Construction of well cellar;
• Installation of offsite electrical conduit and onsite electrical equipment;
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
• Completion of onsite surface and entrance/exit;
• Installation of temporary landscaping; and
• Installation of 35-foot sound attenuation wall.(per Mitigation Measure NV-3a)
Table 2.2 Proposed Oil Project Design Parameters
Parameter Value
Crude oil production Phase 2: Up to 800 bpd
Phase 4: Up to 8,000 bpd
Crude oil properties 18 API
Natural gas production Phase 2: Up to 250,000 scfd
Phase 4: Up to 2.5 million scfd
Produced water disposal/injection Phase 2: Up to 1,600 bpd
Phase 4: Up to 16,000 bpd
Maximum number of wells
Phase 2: 4 wells (3 production, 1 water disposal/injection)
Phase 4: 34 total (30 production, 4 water
disposal/injection)
NGL production Up to 1 bpd mixed with crude oil
Pipeline length and tie-in, gas Approx. 0.43 miles + 1.4 miles
Pipeline length and tie-in, crude Approx. 3.55 miles
Water use, during construction
Approx. 2,000 gallons per day during grading and earthwork (potable)
Approx. 10,000 gallons per day during pipeline installation (potable)
Approx. 20,000 gallons per month during facility construction (potable)
Water use, during drilling 130,000 gallons per well (reclaimed water)
(Approx. 4,500 gallons per day)
Water use, during operations and
maintenance
(Landscaping- Reclaimed Water)
(Domestic-Potable Water)
1,300 gallons per day
(1,000 gallons per day for landscaping)
(300 gallons per day for domestic use)
Electrical use, Phase 2 4.5 megawatts (including drill rig)
Electrical use, Phase 3 0.3 megawatts
Electrical use, Phase 4
7.0 megawatts (including drill rig)
3.0 megawatts during normal ongoing operations
Onsite electrical generation of 1 MW
Well workovers, annually 90 days/year
Well re-drills (full sized drilling rig, peak
annually
Up to 5 per year, up to 30 re-drills for the life of the
Project
Notes:bpd = barrels per day; kW = kilowatts; scfd = standard cubic feet per day; NGL = natural gas
liquids; API = American Petroleum Institute; estimated peak values and maximums shown
Source: Project Application, Amendments and Appendices.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Figure 2.5 Project Site and Pipeline/Electrical Connections
Source: E&B Supplemental Application materials, January 2014
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Each of these activities is discussed in the following subsections. Figure 2.6 shows the proposed
arrangement of the Project Site under Phase 1. Appendix A of the Final EIR provides the
conceptual grading plan, site plan, elevations, and landscape concept plan for the Proposed Oil
Project at the completion of Phase 1.
The laydown area (equipment and supply storage/staging) for the Proposed Oil Project would be
in the basement of the building located at 601 Cypress Street on the northwest corner of Cypress
Street/6th Street (See Figure 2.3).
Underground Existing Overhead Utilities
There are currently overhead power lines and communication lines on poles that run overhead
through the existing trees along Valley Drive. These existing lines would be removed along the
Project frontage and relocated underground adjacent to the Project Site in a location determined
by the utility companies and the City. Appendix A of the Final EIR provides drawings showing
the general location where the utility lines would be placed underground.
Construction of Modifications to Intersection of 6th Street and Valley Drive
The Proposed Oil Project would include the construction of modifications to the intersection of
6th Street/Valley Drive to provide the necessary turning radius for Project-related trucks.
Appendix A of the Final EIR provides drawings showing the conceptual design of the proposed
intersection modifications. These modifications would result in:
• Removal of a portion of the landscaped area and entry driveway to the Beach Cities Self
Storage facility;
• Redesign of the sidewalk on the southwest corner of the intersection;
• Relocation of the stop sign and striping for the northbound lanes on Valley Drive to
address the redesign of the southwest corner;
• Removal of a utility pole and underground utilities on the southwest corner of the intersection;
• Removal of a utility pole and underground the utilities on 6th Street; and
• The removal of two on-street parking spaces on 6th Street.
As a part of the intersection modifications, the stop sign and striping for the southbound lanes on Valley Drive would be relocated to improve the line of sight to and from the intersection with 6th Street. This modification would be made concurrently with the addition of the perimeter fencing
on the Project Site (See Figure 2.6). In addition, the curb on the northwest corner along 6th
Street adjacent to the Project Site would be temporarily provided as a rolled asphalt curb for
Phases 1 and 2.
The two on-street parking spaces removed from 6th Street would be provided as part of the Project’s overall parking replacement program discussed further below.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Water Injection
Pumping produced
water back down the
well hole into the oil
reservoir from which it
was originally extracted.
Relocation of the City Maintenance Yard
Prior to Phase 1, a temporary City Maintenance Yard would be built at the New City
Maintenance Yard location to the rear of City Hall at 1315 Valley Drive. At this point, the maintenance operations would be moved into the temporary City Maintenance Yard.
Clearance of the Project Site
Prior to the initiation of the site clearance activities, temporary 24-foot sound attenuation walls
(per Mitigation Measure NV-1a) would be erected at the Project Site to reduce noise impacts
related to construction. These sound walls would be designed to be movable and would be relocated within the Project Site as needed to attenuate noise associated with Phase 1 demolition
and construction activities. The temporary sound walls would be removed from the Project Site
after the onsite construction activities in Phase 1 are completed.
Following the relocation of the City Maintenance Yard , the Project Site would be cleared. The
site clearance activities would include the removal of three existing buildings (one of which would be moved to the temporary site), two trailers, storage containers, sheds, trash bins, a
propane tank, concrete paving and asphalt, fencing and masonry walls. In addition, the asphalt
parking area to the west of the City Maintenance Yard would be removed, resulting in the
removal of 15 parking spaces. The building located at 636 Cypress Avenue would also be
demolished at this time to clear the parcel for the off-site temporary parking area. Prior to the demolition of both buildings, building materials would be assessed for asbestos content and
presence of lead based paint, consistent with the requirements of the South Coast Air Quality
Management District (SCAQMD). If asbestos containing materials or lead based paint are
detected, the appropriate abatement process would be implemented. The building materials
removed from the Project Site would be transported by truck to the recycling facility at Southern California Disposal in Santa Monica, the recycling facilities at Hanson Aggregates in Long
Beach, or another certified facility for recycling or disposal.
The Proposed Oil Project would include an overall parking replacement program that meets the
intent of the City’s Preferential Parking Program and Coastal Development Permit requirements.
Section 2.4.5 discusses the parking plan for the Proposed Oil Project.
Three of the four existing mature trees along the frontage of the
Project Site on Valley Drive would be retained to help screen
construction activities. The Applicant has concluded that the
fourth tree should be removed because it is in poor health, and it would limit access to the Project Site (See Figure 2.6). The
three remaining trees would be trimmed to keep branches from
hanging over onsite equipment and to help prevent trespassing.
Construction of Retaining Walls and Rough Grading
Once the Project Site is cleared, retaining walls would be constructed along the western
boundary of the Project Site and set back 10 feet along the western portion of the southern
property boundary (See Figure 2.6).
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Figure 2.6 Proposed Oil Project Phase 1 Conceptual Site Plan
[need to fix this image]
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Source: Applicant application
Section 2: Project Description
Exhibit B
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Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Rough grading would occur to allow for:
• The construction of a well cellar for three test oil wells and a water disposal/injection
well;
• Surface drainage towards a temporary retention basin, which would contain a 100-year
flood event;
• A level area for the set up and movement of the drill rig; and
• The installation of temporary production equipment.
It is anticipated that the rough grading would not require the import or export of fill material.
Appendix A of the Final EIR provides the conceptual grading plan that indicates the retaining
wall locations and rough grading at the completion of Phase 1.
Installation of Perimeter Fencing
Following the rough grading, the Project Site would be enclosed by a six-foot temporary
perimeter chain link fence covered with green fabric. The fence would include secured gates for
the entrance off Valley Drive and the exit to 6th Street. The Applicant proposes to include the
appropriate signage consistent with the requirements of the City. Figure 2.6 shows the location of the fencing and gates at the completion of Phase 1, and Appendix A of the Final EIR shows an
elevation of the fencing.
Construction of Well Cellar
A cement well cellar approximately 8 feet wide by 40 feet long by 12 feet deep would be constructed for three test wells and one water disposal/injection well to allow for the drilling of the wells in Phase 2. The well cellar would provide containment of any potential oil spillage
during Phase 2. Figure 2.6 shows the location of the well cellar.
Installation of Offsite Electrical Conduit and Onsite Electrical Equipment
Electrical service for the Proposed Oil Project would be provided by Southern California Edison (SCE). The electrical conduit and onsite electrical equipment for all phases of the Proposed Oil
Project would be installed in Phase 1. The electrical load during Phase 2 and Phase 3 would be
4.5 Megawatts (MW) and 0.3 MW, respectively. During Phase 4, the electrical load during
drilling would be 7.0 MW and during ongoing operations would be 3.0 MW. According to the Applicant, SCE has determined that the existing 16 kilovolt (kV) circuit running along 8th Street
to the north of the Project Site has the necessary capacity to serve the Proposed Oil Project. To
receive electrical service from SCE, the Proposed Oil Project would provide for the installation
of an underground conduit for a linear distance of 280 feet under Valley Drive from 8th Street to
the northeast corner of the Project Site (see Figure 2.6)
Electrical equipment consisting of step down transformer(s), switchgear, and variable frequency
drive units would be installed in the northeast corner of the Project Site designated as the New
SCE Yard in Figure 2.6. The electricity would be used to provide power for well pumps, the
temporary production equipment, the temporary construction trailer, safety system controls,
onsite lighting, and the drill rig used in Phase 2 and Phase 4 (both drilling and re-drills). An uninterruptable power supply would be installed for critical systems such as the temporary
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
production equipment safety systems and security lights. An emergency generator would be
installed to provide power for the safe shutdown of the drilling operation in the event of a loss of
power from SCE.
Appendix A of the Final EIR provides the general location of the offsite underground conduit.
Completion of Onsite Surface and Entrance/Exit
The surface of the Project Site would be covered with crushed aggregate base material to serve
as a dust inhibitor and driving surface. Temporary berms would be constructed around the areas
where the drill rig and associated equipment would be set up and the temporary production equipment installed to provide secondary containment. In addition, a temporary berm would be
provided around the well cellar to avoid surface flows from entering the well cellar. The existing
driveway access from Valley Drive and 6th Street would be used. On both sides of the driveway
on 6th Street, a rolled asphalt curb would be provided.
Installation of Temporary Landscaping
Landscaping would be provided along the eastern and southern perimeter of the Project Site to
provide a visual buffer. The plant materials and irrigation would be consistent with the
requirements of the City. The trees and other plant materials would be planted in a manner that
allows for their replanting as a part of the permanent landscaping provided in Phase 3. Reclaimed water supplied by West Basin Municipal Water District would be used for irrigation.
The reclaimed water line serving the Greenbelt east of Valley Drive would be tapped and
extended to the Project Site. Appendix A of the Final EIR includes a conceptual landscape plan
and plant materials for the temporary landscaping provided at the completion of Phase 1.
Installation of 32-Foot Sound Attenuation Wall
Upon completion of the Phase I improvements, a 35-foot sound attenuation wall (per Mitigation
Measure NV-3a) would be erected inside the chain link construction fence in order to attenuate
noise generated during Phase 2 drilling and testing. The 35-foot sound wall would stay installed
through the duration of Phase 2.
2.4.1.2 Phase 1 Site Preparation Detailed Schedule
It is anticipated that Phase 1 would occur for a period of approximately six months as indicated
in the schedule provided in Table 2.3.
As required by the previous Conditional Use Permit and as proposed by the Applicant, the
construction activities on the Project Site, including the operation of earthmoving equipment, would be conducted between the hours of 8:00 a.m. and 6:00 p.m. Monday through Friday (except holidays) and 9:00 a.m. and 5:00 p.m. on Saturdays. Offsite construction activities
within the public ROW would occur between the hours of 8:00 a.m. and 3:00 p.m. Monday
through Friday in the City of Hermosa Beach.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Truck deliveries to the Project Site would be limited to the hours between 9:00 a.m. and 3:00
p.m. Monday through Friday, except in the case of an emergency and with the prior approval of
the Director of Public Works. The Project-related truck trips would be limited to 18 round trips
per day and limited to the designated truck routes.
2.4.1.3 Phase 1 Site Preparation Personnel and Equipment Requirements
The vehicles, equipment, and employees estimated for Phase 1 are provided in the detailed
listing in Appendix A of the Final EIR. Vehicle trips are summarized in Table 2.4. The Project-
related personnel would utilize parking spaces in an offsite parking area provided consistent with
the proposed parking plan described in detail in Appendix A.
Table 2.3 Phase 1 Project Schedule
Activity Schedule (Weeks)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
Construction of Temporary City Yard
Underground overhead utilities
6thStreet & Valley intersection
Relocation of Yard
Remove buildings
Remove other site structures
Construct retaining walls
Grade, well cellar, aggregate
Construct chain link fence
Construct well cellar
Install electrical service
Install landscaping
Install 32-foot sound wall
Note: relocation of Yard would only include moving of shop materials and equipment. The Temporary City Maintenance Yard would be construction prior to the start of Phase 1 and would take approximately 9 months. See section 2.5.
2.4.1.4 Phase 1 Truck Routes
Truck trips would be required in order to deliver and remove construction-related materials and
equipment to and from, respectively, the Project Site. Trucks would utilize roads designated as
truck routes by the cities of Hermosa Beach, Redondo Beach, Manhattan Beach and Torrance.
Truck routes are shown in Figures 2.13 and 2.14.
The routes identified by the Applicant as those utilized for all phases of the Project are as follows:
Inbound Trucks
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
PHASE 2
Drilling and Testing:
Drilling for 3-4 Months
Testing for 7-9 Months
More
1. Inbound trucks from westbound Artesia Boulevard
2. Left on to southbound Pacific Coast Highway
3. Right on to westbound Pier Avenue
4. Left on southbound Valley Drive 5. Right into the Project driveway on Valley Drive
Or
6. Inbound trucks from westbound 190th Street (which becomes Anita Street)
7. Right on northbound Pacific Coast Highway
8. Left on to westbound Pier Avenue 9. Left on to southbound Valley Drive
10. Right into the Project driveway on Valley Drive
Outbound Trucks
11. Outbound trucks on to eastbound 6th Street
12. Right on to southbound Valley Drive 13. Left on to eastbound Herondo Street
14. Continue onto Anita Street, then 190th Street to the Interstate 405 (I-405)/ Crenshaw
interchange
Or
15. Outbound trucks on to eastbound 6th Street 16. Right on to southbound Valley Drive
17. Left on to eastbound Herondo Street
18. Left on to northbound Pacific Coast Highway
19. Right on to Artesia Boulevard.
2.4.2 Phase 2 Drilling and Testing
The purpose of Phase 2 would be to conduct the drilling
and testing of wells in order to determine the potential
productivity and economic viability of the Proposed Oil
Project. During this phase, up to three test wells and one
water disposal/injection well (a total of four wells) would be drilled. These wells would be drilled utilizing
directional drilling technology, which enables the wells to
be drilled laterally for long distances, so that the bottom-
hole locations may be located several thousand feet from the surface location of each wellhead on the Project Site (see Figure 2.7 and 2.8).
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
2.4.2.1 Phase 2 Site Geology and Drilling Objectives
The Proposed Oil Project would utilize directional drilling techniques to access the crude oil and
gas reserves in the tidelands (offshore) and uplands (onshore) in the portions of the Torrance Oil
Field within the City’s jurisdiction. The Project Application states that "no hydraulic fracturing (or “fracking”) of wells will occur because the geologic zones for the Proposed Project are
permeable and capable of yielding oil and gas without hydraulic fracture stimulation."
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Table 2.4 Phase 1 Vehicle Trip Summary
Activity Trucks, Maximum RT/day* Autos/PU, Maximum RT/day Total, Maximum RT/day
Underground overhead utilities 4 10 14
Construct 6th& Valley intersection 3 8 11
Remove buildings 10 8 18
Remove other existing site structures 15 6 21
Construct retaining walls 5 14 19
Grade, well cellar and aggregate 15 10 25
Construct chain link fence 1 4 5
Construct well cellar 4 8 12
Install electrical service 6 15 22
Install landscaping 1 2 3
Install 32-foot sound attenuation wall 3 12 14
Greatest number of trips in one day 18
(during week 9)
31
(during week 12)
43
(during week 10)
Notes: * According to the 1993 CUP, which is valid pursuant to the Settlement Agreement, the number of truck trips shall be limited to a maximum of 18 rounds trips per day, except in an emergency.
Trucks are 3+ axle or greater or trucks with trailers. Autos are automobiles or pickups/trucks with 2 axles.
Trips are round trips.
Maximum truck activity occurs during week 9 with the installation of electrical service and the removal of existing structures.
Maximum auto activity occurs during week 12 with the installation of electrical service and construction of the retaining wall.
Maximum activity trucks and autos combined occur during week 10.
Truck maximum and auto/PU maximum do not necessarily occur on the same day, so the total maximum
is not necessarily a simply addition of the two. See appendix.
See Appendix A for a detailed breakdown of vehicles, employees, trucks and construction equipment for
each week.
Source: Project Application, Amendments and Appendices
The approximate extent of the City’s jurisdiction within the Torrance Oil Field is provided in
Figure 2.7. Figure 2.8 provides a typical well cross section illustrating how wells can reach the
oil reserves, within the tidelands, from the Project Site. The Project Application states the primary target zones are the Upper Main, Lower Main, and Del Amo Zones with some
production potential within the Schist Conglomerate.
As shown in Figure 2.8, the Upper Main Zone is the uppermost part of the Puente Formation.
The Project Application states that it is expected to be the shallowest oil productive zone in the
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
City. Of the three known producing horizons in the Torrance Oil Field, the Upper Main Zone is
the most prolific. The Upper Main Zone beneath the Hermosa Beach tidelands and uplands is
expected to be 300 feet thick and composed of inter-bedded thin sands and shales. The shales
are currently fractured and provide both fractured porosity and permeability. The fractures are critical to the performance of the reservoir in the area due to the fine-grained and thin-bedded
nature of the sands. The Lower Main Zone lies below the Upper Main Zone in the Puente
Formation. The Project Application states that similar to the Upper Main Zone, the shales of the
Lower Main Zone are currently fractured and important for oil production. However, the Lower
Main Zone has fewer interbedded fine-grained sands and is over 500 feet thick.
Figure 2.7 Proposed Oil Project Lease Areas (below)
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Source: Project Application
Section 2: Project Description
Final Environmental Impact Report 2-59 E&B Oil Drilling & Production Project
Figure 2.8 Applicant Proposed Oil Project Lease Areas Cross Section
Source: Project Application. Representative figure not to scale or reflective of the exact geology of the region.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
The Del Amo Zone lies beneath the Lower Main Zone. It contains the least amount of thin-
bedded sandstone in the Puente Formation. The Project Application states that similar to the
other two zones, the shales of the Del Amo Zone are currently fractured and important for oil
production. The Del Amo Zone varies the most in thickness and could be from 200 feet up to 700 feet thick.
The Schist Conglomerate underlies the Del Amo Zone and is resting on metamorphic basement
rock (Catalina Schist). The Schist Conglomerate could be as much as 400 feet thick and is
composed of reworked fragments derived from erosion of the underlying Catalina Schist. The
Project Application states that although it is unknown if the Schist Conglomerate is productive beneath the City, it is still a viable exploration target.
The production test wells would target areas to the south-west, the north-west and the north areas
of the lease (see Figure 2.7). The wells for the Proposed Oil Project would be at a true vertical
depth of approximately 3,000 feet and a measured depth of approximately 9,000 feet. The actual
well depth would vary depending on the area targeted.
The Applicant indicates that the wellhead pressures anticipated during and immediately after
drilling would be 0.0 pounds per square inch (psi) and that the wells are not anticipated to be
free-flowing.
DOGGR must review and approve an engineering study conforming to CCR Section 1724.6 and
1724.7 for operations. No Class II injection wells will be permitted prior to review and approval of the study. A Notice of Intent will need to be submitted for each proposed well. The Notice of
Intent will be reviewed for accuracy and completeness and, if appropriate, a drilling permit
issued.
2.4.2.2 Phase 2 Construction and Drilling Activities
Phase 2 construction and drilling would consist of the following activities and improvements:
• Installation of Temporary Construction Trailer
• Delivery and Set Up of Drill Rig
• Installation of Temporary Production Equipment
• Drilling of Wells
• Testing and Operational Systems
These activities are discussed in the following subsections.
Phase 2 Installation of Temporary Construction Trailer
A temporary construction trailer would be installed in the northeast portion of the Project Site
(see Figure 2.9). In addition, the associated utilities, including potable water and sewer, would
be extended from the existing lines currently located along 6th Street that serve the City
Maintenance Yard. Water and sewer service would be provided by the California Water Service
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Company and the City, respectively. Electricity would be provided by Southern California
Edison (SCE) as discussed above under Phase 1 construction activities.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Figure 2.9 Proposed Conceptual Site Plan - Project Phase 2
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Source: Applicant application
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
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Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Automated Drilling Rig
Ground Flare
Phase 2 Delivery and Set Up of Drill Rig
An electric drilling rig and its associated equipment would
be brought to the Project Site on large trucks with trailers
to be permitted by the City and the California Highway Patrol (CHP). The drilling rig would be an "automated
drill rig" (ADR), which means that many of the drill rig
procedures (loading pipe, etc,) would be done by
mechanical means automatically. The approximately 87-
foot high drill rig would be powered by electricity. A large crane with a 150-foot boom would be used to erect
the drill rig. Support equipment for the drill rig would
include pipe racks, mud and cutting system, pumps,
hydraulic equipment, and an accumulator. In the event of
a loss of power from SCE, a generator, which would be a non-road portable diesel-fuel generator certified by the
California Air Resources Board (CARB), would provide
power for the safe shutdown of the drilling operation.
Phase 2 Installation of Temporary Production Equipment
Temporary oil, water, and gas production equipment would be installed on the Project Site. This
temporary equipment would include a well test station, an induced gas flotation/filter skid, a gas
combustor (enclosed ground flare), fluid handling
tanks, piping, vapor recovery unit, pumps, and
vessels. The production equipment would be delivered by trucks to the Project Site. The
temporary production equipment would be installed
in the eastern portion of the Project Site within an
area enclosed by a containment berm as shown in
Figure 2.9.
Phase 2 of the Proposed Oil Project would be
designed as a closed-loop system, with pressure
relief valves venting to a flare and tanks venting to
a vapor recovery system. The control system
would be computerized and would monitor the closed-loop system, providing warnings, corrective
actions, and shutdowns, if necessary. Corrective
actions could be closing valves, sounding alarms,
shutting down wells or other process related
functions. In addition, according to the Applicant, redundancy would be built into the system to
provide an extra level of protection, ensuring there would be a backup for each safety device.
All safety devices would be tested on a regular basis as per applicable codes and standards.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Operators would be onsite 24 hours per day, seven days per week, to monitor all aspects of the
Proposed Oil Project’s production process.
Phase 2 Drilling of Wells
Once the drill rig and associated equipment set up is complete, up to three test wells would be drilled utilizing directional drilling technology. This would enable the wells to be drilled
laterally for long distances so that the bottom-hole locations may be located horizontally several
thousand feet from the surface location of the well head on the Project Site. All wells would be
permitted, drilled and cemented in accordance with the State Division of Oil, Gas, and
Geothermal Resources (DOGGR) regulations. Drilling would proceed in the following manner:
• Installation of conductor casing;
• Drilling of wells;
• Placement of casing and cementing of wells (in stages at various depths); and
• Completion of the well, including installation of down-hole pumps and tubing.
Installation of Conductor Casing
The conductor casing is the initial hole drilled into the ground with a large diameter pipe installed to maintain integrity. The subsequent drilling of the well would take place through the conductor casing. Conductor casing would be installed with a small drilling rig, referred to as a
dry-hole digger, which would be used to set the conductor casing for all of the intended wells in
the Project Site. A large diameter hole, about 18 inches in diameter, would be drilled to an
approximately 80-foot depth. This type of drilling is similar to boring a hole with an auger. Usually, no drilling fluid is needed to drill the hole, hence the name dry-hole digger. A large diameter casing, commonly referred to as “conductor pipe”, typically 13-3/8 inches in diameter,
is lowered to the bottom of the hole and is cemented in place with construction concrete. This
forms the first seal of the near-surface formations and also serves as a steel conduit to allow the
drilling fluid used in the next stage of the well drilling to be circulated to the surface without washing away the shallow near-surface dirt. All conductors necessary to develop the Proposed Oil Project test phase would be set at this time and the dry-hole digger moved off before the
drilling rig would be mobilized and brought to the Project Site.
Drilling, Casing and Completion of Wells
The components of the drill rig and all necessary equipment would then be moved onto the
Project Site with large specially equipped trucks. The drill rig height would be 87 feet. The
drilling setup would include three main parts; the drilling structure (i.e., mast, substructure,
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
catwalk, silicon-controlled rectifier (SCR) house, top drive, back-up generator, crown block,
traveling block, iron rough neck, drill pipe, control cabin), the blow out preventer (BOP) system
(i.e., BOP Stack, Shear Ram, BOP Controller, and Accumulator), and the mud system (i.e., mud
tanks, mud shakers, mud pumps, mud return line). The drilling rig would also require other equipment such as a spare parts house, other tanks, and storage areas as needed to support the
drilling operation. The substructure of the drill rig would be located over the first well conductor
casing, the mast would be raised, and the other equipment would be aligned and connected. The
drill pipe would be laid out on racks convenient to the rig floor so they may be used when
needed. Water tanks would be filled, and drilling fluid additives would be stored on site. The drill rig for the Proposed Oil Project would be run on electric utility power, so an electrical
hookup would be made at this time. Drilling operations would then begin. The initial
mobilization and rigging up operation is expected to last about seven to ten working days.
“Spudding in” is the term used to begin drilling operations. A large (12 ¼-inch diameter) drill
bit is attached to the first joint of drill pipe (usually 30 feet long) and lowered into the conductor casing. As the first length of pipe is completely lowered in, another length of pipe is attached to
the end, thereby increasing the length of the drill “string”. When the drill string reaches the
bottom of the conductor casing at a depth of 80 feet, the drilling begins. In order to drill
downwards through soil and rock, the drill bit requires rotation and downward force, which is
provided by the weight of thick-walled pipe on top of the drill bit. A single, 30-foot long drill pipe for a larger diameter drill bit weighs approximately three tons. As the drill bit drills deeper,
more drill pipe is placed on top, thereby increasing the downward force; this is collectively
known as the drill string. The drill bit turns clockwise as the weight of the drill pipe column
forces it downward. Drilling fluid, called mud, is pumped down the inside of the hollow drill
pipe, through a hole in the drill bit, and flushes the drilled rock cuttings away from the bit and up the space between the wall of the borehole and the outside of the drill pipe, which is referred to
as the “annulus.” When the mud reaches the surface, it circulates to a mud tank where the rock
cuttings are separated out of the fluid by using a shaker, and the clean mud is pumped back down
the hole in a continuous circuit, constantly circulating the drilled rock cuttings up and away from
the drill bit as it penetrates deeper into the earth. The cuttings are analyzed, stored in 20 cubic yard bins, and then hauled offsite.
Initially, a large diameter bit is used to drill to a predetermined depth. When the specified depth
is reached, drilling is stopped, the drilling string is removed and a large diameter pipe (a casing
string) is assembled in 40-foot lengths and lowered to the bottom of the well bore. Cement is
then pumped down the inside of the casing, around the bottom of the hole, and up the annulus between the casing and the well bore. When the cement hardens, it ensures that the entire casing
and well bore are encased in cement, protecting the fresh water aquifers and surrounding
subsurface areas from the production fluids inside of the casing. See Figure 2.10 for a schematic
of the well bore and casing.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Figure 2.10 Typical Well Bore and Casing
Source:Project Application
Next, a piece of equipment known as a blowout preventer (BOP) is attached to the well head. The BOP is a safety system used during drilling operations in oil and gas fields to prevent the uncontrolled release of reservoir fluids and to immediately shut off the flow in the event that
abnormal pressure is encountered in the well bore that cannot be controlled by the hydrostatic
head of the drilling fluid when drilling resumes beneath the surface casing. Blow out prevention
equipment shall conform to DOGGR’s publication M07 “Blowout Prevention in California, Equipment Selection and Testing 2006 edition. If the subsurface pressure begins to cause the well to flow, the BOP is activated, closing in the well and trapping the pressure until it can be
bled off safely and drilling can continue. A BOP would be placed on each wellhead during the
drilling and removed after the well is completed. A BOP utilizing Blind Shear Rams would be
utilized. Blind Shear Rams are a type of BOP common in the offshore environment that allow for the shutting off of flow through the well even if drill pipe is in the wellbore. Pursuant to the requirements of the Code of Federal Regulation on Oil and Gas and Sulphur Operations in the
Outer Continental Shelf(30 CFR part 250), the Applicant indicates that the BOP would be
certified that the shear rams can actually shear the drill pipe prior to drilling.
The surface casing serves three primary functions:
• It isolates fresh water formations from contact with any fluids coming from deeper in the earth;
• It serves as a mounting place for the blowout preventer; and
• It serves as the support for the production casing that would be placed in the well if oil is found.
Once the surface casing is cemented in, drilling operations resume with a smaller drill bit. This
smaller hole is drilled to the total depth decided upon by the Applicant’s geologic and
engineering staff. Usually, the only interruptions to drilling operations would be to remove the
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
drill pipe (also known as tripping pipe) from the well to replace a dull drill bit, and then lowering
the pipe back to the bottom of the well.
In order to achieve the directional aspect of the drill hole, the well bore is bent. The act of
“bending” a well out of the vertical axis typically begins after vertical drilling has progressed several hundred feet beneath the surface. Although the specifics of each well proposed for this
Project have not been established, it is not uncommon to begin to deviate from vertical at a depth
of about 600 feet and still reach a target formation located at a depth of 4,000 feet, but also
almost 4,000 to 6,000 feet sideways from the surface spot location. This system would be used
on virtually all of the wells drilled for the Proposed Oil Project.
When the well reaches total depth (TD), drilling operations are halted and the drill pipe is
removed from the well leaving mud in the hole to contain any potential production fluids located
at the reservoir depth. A logging tool is then lowered into the hole to record petrophysical data
of the formations through which the rig has drilled. If the well looks like it would produce oil,
production casing is installed in a similar fashion to the installation of the surface casing. Production casing for the Proposed Oil Project is planned to be 7inches in diameter. Production
casing would be cemented similarly to how the surface casing is cemented, as previously
described. Once the cement has been allowed to fully harden, another electric logging tool,
called a cement bond log, is lowered to the bottom of the well to evaluate the completeness and
effectiveness of the cement on the outside of the production casing. If the cement is found to have defects, the casing can be perforated and cement forced into the well at a specific location
or the casing can be removed and the well re-drilled. Devices are inserted to ensure any
perforations are sealed.
The well is then “completed”, which is a series of activities that allow for the production fluids to
flow into the well bore inside the casing and to the surface.
Table 2.5 shows a list of chemicals that would be used during drilling operations. The amounts
listed are the estimated quantities consumed per well drilled. These materials are packaged by
the manufacturer for shipping and would be delivered to the job site by conventional delivery or
flatbed trucks.
Drilling each well would require approximately 130,000 gallons (or 0.4 acre-feet) of water. The water would be reclaimed water provided by the West Basin Municipal Water District from an
existing reclaimed water line serving the Greenbelt east of Valley Drive. The West Basin
Municipal Water District has provided the Applicant with a “will serve” letter.
The drilling process requires the use of drilling mud to circulate drilled rock cuttings out of the
well hole, retain the integrity of the well hole, and control reservoir pressure. The drilling mud would be collected onsite in Baker tanks (enclosed tanks that are approximately 12 feet tall by 40
feet long and hold up to 500 barrels each). Although most of the mud would be reused on
subsequent wells, some mud would be removed from the Project Site and disposed of each day
by truck at an approved disposal site at Anterra’s Oxnard Licensed Class 2 Disposal Facility or a
similar facility. In addition, all other waste generated by the test drilling would be transported by truck to the appropriate disposal site at Clean Harbors Buttonwillow Landfill, or a similar facility
if closer to the Project Site.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Table 2.5 Phase 2 Drilling Chemicals
Common/Trade Name Use Container Amount per Well
Gel Wyoming Bentonite Used to enhance mud viscosity 100-pound sack 525 sacks
DMA Sodium Polyacrylate Water absorbent mud
additive
50-pound sack 82 sacks
Benex Anionic Acrylamide Mud additive 2-pound sack 75 sacks
GEOZan Xanthan Gum Mud viscosifier 25-pound sack 40 sacks
Omniopol Sodium Polyacrylate Liquid Water absorbent mud additive - 380 gallons
CFR Fatty Acid Liquid Mud additive to
enhance lubricity
- 600 gallons
Bicarb Sodium Bicarbonate Mud additive for pH control 50-pound sack 40 sacks
Citric Acid Mud additive for pH
control
50-pound sack 11 sacks
Walnut Hulls Filter medium, used to reduce torque and drag
of drill pipe and for plugging of fractures
and high porosity formations
50-pound sack 48 sacks
Cement Bulk-Truck Used for well sealing - 3 bulk trucks
Biotreat 8415 Treatment of water
before injection into the oil reservoir
Hydrochloric Acid 15%, used for acid
washing during completion
Bin varies
Hydrofluoric Acid 3%, used for acidizing
muds
Bin varies
Source: Project Application, Amendments and Appendices
The Proposed Oil Project would comply with the 1993 CUP conditions of approval, proposed
operational practices, and proposed design features. The noise reduction methods would include
the following:
• An electric drill rig would be utilized, reducing the need for diesel engines;
• The drill rig would have no draw works or cables resulting in less noise;
• A 35-foot-high acoustical barrier wall (per Mitigation Measure NV-3a) would be erected
around the perimeter of the Project Site during all drilling activities. The wall would have a sound transmission class (STC) rating of at least 32;
• The air inlets and vents of the hydraulic power unit would be fitted with silencers;
• An acoustical shroud would enclose three sides of the rig mast to reduce the top drive noise (if applicable);
• The mud pumps would be enclosed with acoustical barriers having a sound transmission
class (STC) rating of at least 25;
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
• An 8-foot high acoustical barrier with an STC rating of at least 25 would be installed
around the shaker tables;
• Drilling Quiet Mode Plan would be implemented at the drill site between 7:00 p.m. and 8:00 a.m., a plan which would provide for the following: disablement of all audible
mobile equipment and truck backup alarms; minimization of pipe handling; cessation of
cementing operations, maintenance, and tripping pipe; and limits within the delivery
schedule; and
• An automated and remotely managed system to connect/disconnect pipe (Iron Roughneck) would be used, which would reduce pipe handling;
No processing of gas would occur during Phase 2. The gas separated from the oil and water
would be directed to a gas combustor (enclosed ground flare), where disposal of it would occur
through burning.
The Applicant indicates that low levels of potential “native” hydrogen sulfide (H2S), in the order
of 0.0 to 6.0 parts per million (ppm), may be encountered in the gas produced from the
underlying oil reservoir.
Because the produced fluids may contain some H2S, fixed H2S detection systems would be
installed around the drilling site and continuous monitoring would be present during all drilling, workover, and well servicing operations. Sensors would be located in areas that are frequently
used by personnel, selected drilling area locations, areas where H2S may accumulate, and any
other areas determined by hazard analysis to pose a potential risk. Personnel would also carry
personal H2S monitors attached to their clothing for immediate H2S detection during drilling.
Figures 2.12 and 2.13 provide an outline of the City’s designated truck route for construction trucks through the cities of Hermosa Beach, Redondo Beach and Torrance.
Phase 2 Testing and Operational Systems
After the completion of the first test well and the water disposal/injection well, the extracted oil
would go through production and testing. The temporary production equipment on the Project Site would be used to process the production fluid. The oil would be processed to a standard that would be suitable for sale. The produced water would be processed and re-injected back into the
oil-producing reservoir below the oil water contact. Disposal of the gas produced during Phase 2
would occur through burning in the enclosed ground gas flare. Figure 2.11 shows the steps
involved in processing the oil, water, and gas produced from the test wells in Phase 2.
Processing of Production Fluids
During Phase 2, the Proposed Oil Project is designed to handle up to 800 barrels of oil per day
and up to 250,000 standard cubic feet of gas per day. After the oil is processed, it would be
trucked from the Project Site to an offsite oil receiving facility at 2650 Lomita Boulevard in Torrance. The route used for crude haul trucks is detailed in Appendix A of the Final EIR.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Figure 2.11 Phase 2 Process Flow Diagram
Source: Applicant application
The produced fluids would be sent from the wells to a three-phase separator, which would separate the fluid into gas, oil and water streams. The gas exits the top of the separator, the oil exits the middle, and the water exits the bottom of the separator. Each one of these fluids enters
a specific system of treatment as follows.
Oil Treatment System
The produced oil would enter a series of stock tanks after leaving the three-phase separator. The stock tanks would be used if the oil needs to be further processed to remove excess water. The
water removed from the oil and water mixture would be sent back to the three-phase separator
through a drain system. Once the oil is processed to a standard suitable for sale, the oil from the
stock tank would be loaded into a tanker truck and transported to the purchaser.
Gas Treatment System
The produced gas would be sent directly to a compressor and then to the gas flare for combustion
after leaving the three-phase separator. A vapor recovery system attached to the temporary
Baker tanks would be utilized to capture vapors and to direct them to a vapor recovery
compressor and to the gas system and flare. The vapor recovery, tank and flare system would be subject to Southern California Air Quality Management District (SCAQMD) permit requirements.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Figure 2.12 Truck Routes from Highway 405 to Project Site
Source:Project Application, Amendments and Appendices
Figure 2.13 Truck Routes to Highway 405from theProject Site
Source:Project Application, Amendments and Appendices
The Proposed Project provides for the disposal of treated stormwater runoff and produced water
from the drilling and production process back into the oil reservoir using water disposal/injection
wells. The injection of untreated water can result in the creation of H2S concentrations in the oil
reservoir above preexisting levels (referred to as the “native” condition). Prior to the injection of produced water from the oil extraction process, or the injection of surface runoff from
precipitation that collects on the Project Site, the water would be treated by a biocide to eliminate
sulfate-reducing bacteria (SRB). Once wells begin production, the extracted water would be
tested for SRBs to determine if treatment is needed. In addition, the surface runoff water and
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
any other injected water, would be tested. SRBs are an assemblage of specialized bacteria that
thrive in the absence of oxygen and obtain energy for growth by oxidation of organic nutrients,
with sulfate being reduced to hydrogen sulfide (H2S). SRBs are treated by the use of a biocide
and this treatment could be a batch or continuous treatment. There are numerous antibacterial agents available on the market that could be used for this specific treatment if it is determined to be needed.
Facility Storm Drain System
The Proposed Oil Project Site is designed to retain, process, and inject storm water within the perimeter fence or wall for a 100-year storm event. All rainwater falling on the site would be collected and pumped into the water processing system for disposal/injection into the oil
reservoir. In addition, any spills on the site would also be contained, both within process system
walls/berms around equipment and site walls/berms around the site. Process walls/berms would
be designed to contain at least 110 percent of the largest vessel plus the precipitation generated by a 100-year storm event.
Safety Systems
Operators would be onsite 24 hours per day, seven days per week, to monitor the Proposed Oil
Project’s production process during Phase 2.
A fire protection system as required by Federal, State, and local codes, ordinances and regulations would be installed by the Applicant prior to the drilling and testing activities on the
Project Site. The Fire Protection Plan for Phase 2 of the Proposed Oil Project would be provided
to the City of Hermosa Beach Fire Department for review and approval prior to the initiation of
Phase 2.
The design and operation of the Proposed Oil Project would be required to meet provisions within the California Fire Code (CFC) and standards of the National Fire Protection Association
(NFPA), including the requirements for the storage of hazardous materials, the installation and
use of fire protection systems and devices, and the implementation of safety measures for
employees and emergency responders.
Onsite personnel and a site security program, including a closed circuit television system, a gate access system, and an intrusion and motion detection system, would control all access to and
from the Project Site during Phase 2. In addition, temporary lighting would be provided. The
lighting would be shielded/hooded and directed downward, as is consistent with City
requirements.
All tanks would have containment equal or greater in capacity than at least 110 percent of the largest vessel plus the precipitation generated by a 100-year storm event.
Water Treatment System
The produced water would be pumped into a treatment system, including a gas flotation unit and
a filter unit, to remove excess oil after leaving the three-phase separator. The primary objective of both units would be to clean the water of oil and solids such as sand. The water would then
enter a water surge tank after leaving the filter unit and would be sent to the water
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
disposal/injection pumps for disposal/injection into the oil-producing reservoir through the
disposal/injection well. If determined to be needed, before it enters the water surge tank, the
water would be injected with a biocide to eliminate any bacteria that may be in the produced
water.
Electrical Requirements
Approximately 75 kilo-watt hours of electricity would be required to drill each well.
Chemicals
Project operations would require the use of chemicals. These chemicals would be documented in a required Hazardous Materials Business Plan. Typical chemicals utilized in the temporary
production facility are shown in Table 2.6.
Table 2.6 Phase 2 Testing Chemicals
Common/Trade Name Use Maximum Quantity (Gallons)
Emulsion Breaker/Phasetreat 6378 Help separate oil and water 60
Water Clarifier/Floctreat 7991 Water additive 40
Emulsion Breaker/Waxtreat 3610 Help separate oil and wax 50
Corrosion Inhibiter/Cor 7182 Additive to reduce corrosion 400
Surface Cleaner/4U General purpose cleaner 165
Scale Dissolver/Techni Solve 1780 General purpose scale
remover
55
Scale Inhibitor/Techni Hib 7621 Additive to reduce scaling 120
Source: Project Application, Amendments and Appendices
Noise Abatement
The Proposed Project would be implemented in compliance with the 1993 Conditional Use Permit conditions of approval. In addition, the applicant proposes to incorporate several
operational practices and design features intended to abate noise. The conditions of approval,
operational practices and design features that would be incorporated into the production
operations include the following:
• Heavy/large reciprocating equipment would be mounted on vibration isolators;
• Pipe tripping would be restricted to daylight hours only;
• Loudspeaker paging systems would be prohibited;
• Well workover rigs or any other workover-type rig (not the main drilling rig) that is used would be operated only between 8:00 am and 6:00 pm during daytime weekday hours
only, excluding holidays, except in an emergency as defined in the Conditional Use
Permit (CUP) and reported to the City in accordance with the notification requirement.
The exhaust and intake of the diesel engine (if used on the workover rig) would be muffled to reduce noise to an acceptable limit. The operator would use whatever means
necessary, including, but not limited to, enclosing the diesel engine and rig in acoustic
blankets or housing;
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
• All oil maintenance equipment, vehicles and non-electrical motors would be equipped
with manufacturer approved mufflers or housed in a sound-proofing device;
• Noise monitoring would be conducted under the supervision of an independent certified acoustical engineer;
• Each well pump would produce a sound power level no greater than 83 dBA. This may
be achieved by fitting sound attenuating enclosures that provide an insertion loss of at
least 15 dB;
• The produced oil pumps, produced water pumps, water booster pumps and variable
frequency drive electrical (VFD) cabinets would produce a sound power level no greater
than 77 dBA;
• The water injection pumps would produce a sound power level no greater than 83 dBA.
• The vapor recovery compressors would produce a sound power level no greater than 83
dBA; and
• The cooler for the compressors would produce a sound power level no greater than 85 dBA.
Decision not to Proceed -Abandonment
If it is determined that the production of oil and gas on the Project Site would not be
economically viable, the Applicant would remove the sound attenuation walls, the temporary production equipment, and the temporary construction trailer and abandon the three test wells
and the water disposal/injection well in accordance with the requirements of DOGGR. The
Project Site would be left as a graded site with site improvements including the retaining walls,
the perimeter chain link fence, and the perimeter landscaping.
As the temporary City Maintenance Yard would already be constructed under the Proposed Project, the current City Maintenance Yard Site would be empty and would be available for
development within the M-1 Light Manufacturing zoned area of Hermosa Beach. The Project
Site would then be available for City or other development proposals, or for the temporary City
Maintenance Yard to be relocated back to this site. However, any future use would need to be
consistent with the lease agreement with the Applicant. Current site contamination would remain as part of the abandonment process and would be removed in accordance with the
requirements of any future site use.
2.4.2.3 Phase 2 Drilling and Testing Schedule
It is anticipated that Phase 2 would occur for approximately 12 months as indicated in the
schedule provided in Table 2.7. The drill rig would operate continuously for 24 hours per day, seven days per week, until the appropriate depth and bottom-hole location for each well has been
reached. It is estimated it would take 120 days for drilling activities, 24 hours a day, which is
approximately 30 days per well for four wells. After the drilling of the three oil wells and one
water disposal/injection well is complete, the drill rig would be removed from the Project Site.
As each well is drilled, the produced fluids from that well would go thorough production and testing, as described above.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
2.4.2.4 Phase 2 Drilling and Testing Personnel and Equipment Requirements
The vehicles, equipment, and employees estimated for Phase 2 are provided in detail in
Appendix A of the Final EIR. A summary of the vehicle trips is shown in Table 2.8. Parking for
the employees would be provided in an adjacent parking area as previously discussed for Phase 1. Since Phase 1 prepares the Project Site for Phase 2, the conceptual landscape plan and
elevations provided above for Phase 1 would also be applicable to Phase 2.
Table 2.7 Phase 2 Project Schedule
Activity
Schedule (Weeks)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 thru
54
Install trailer and associated utilities
Deliver and set up drill rig/equipment
Install oil, water, and gas equipment
Drill 3 test wells and water well
Testing of wells
Remove drill rig and equipment
Source: Project Application, Amendments and Appendices
Table 2.8 Phase 2 Vehicle Trip Summary
Activity 3-axle Trucks, Maximum
RT/day*
2-axle trucks, Autos, Maximum
RT/day
Total, Maximum RT/day
Install trailer and associated utilities 2 5 7
Deliver and set up drill rig/equipment 7 20 27
Install oil, water, and gas equipment 6 15 21
Drill 3 test wells and water well 9 10 19
Testing of wells 13 5 18
Remove drill rig and equipment 5 20 25
Greatest number of trips in one day 18
(during weeks 15, 17, 19, 21-24)
25
(during weeks 7-12 )
37
(during week 7)
Notes: * According to the 1993 CUP, which is valid pursuant to the Settlement Agreement, the number of
truck trips shall be limited to a maximum of 18 rounds trips per day, except in an emergency.
Trucks are 3+ axle or greater or trucks with trailers. Autos are automobiles or pickups/trucks with 2 axles.
Trips are round trips.
Maximum truck activity occurs during drilling and testing of wells.
Maximum auto activity occurs during weeks 7-12 with the installation of oil, water and gas equipment and the drilling of wells. Maximum activity trucks and autos combined occurs during week 7.
Testing of wells would involve crude transportation by truck, by way of an average of 7 trucks per day/5 days per week or up to 12 trucks in one day (round trip).
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Truck maximum and auto/PU maximum do not necessarily occur on the same day, so the total maximum
is not necessarily a simply addition of the two. See appendix A.
See Appendix A for a detailed breakdown of vehicles, employees, trucks and construction equipment for
each week.
Source: Project Application, Amendments and Appendices
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
PHASE 3
Final Design and
Construction:
16 Months
2.4.3 Phase 3 Final Design and Construction
If it is determined that the production of oil and gas on the
Project Site would be economically viable, the Applicant
would begin Phase 3 of the Proposed Oil Project. The purpose of Phase 3 would be to utilize the production
information from Phase 2 to prepare the final design of the
facility, prepare the onsite area for facility installation,
install the permanent oil and gas production facilities, and
construct offsite Pipelines.
2.4.3.1 Phase 3 Onsite Construction
Phase 3 onsite activities would involve the following construction activities:
• Preparation of final engineering design;
• Removal of temporary production equipment;
• Removal of three remaining trees;
• Removal of 35-foot sound attenuation wall and perimeter fencing (per Mitigation
Measure NV-3a);
• Installation of 24-foot sound attenuation wall (per Mitigation Measure NV-4a);
• Implementation of remedial action plan;
• Construction of remaining retaining walls and final grading;
• Completion of construction of well cellars;
• Construction of 35-foot block wall (per Mitigation Measure NV-6a);
• Removal of 24-foot sound attenuation wall (per Mitigation Measure NV-4a);
• Construction of small office building;
• Installation of permanent production equipment;
• Construction of final site improvements;
• Construction of final street improvements along Project frontage;
• Installation of final landscaping;
• Installation of 32-foot sound attenuation wall;
• Setting of conductor pipe; and
• Installation of lighting systems.
Each of these activities is detailed in the discussion that follows. A site plan for Phase 3 is shown in Figure 2.14. The conceptual grading plan, site plan, elevations (with the 32-foot sound attenuation wall), and conceptual landscape plan for the Proposed Oil Project at the completion
of Phase 3 are shown in Appendix A of the Final EIR.
Prepare Final Engineering Design
The final design of the permanent oil and gas production facilities, to be implemented during the first few months of Phase 3, would be based on the oil and gas analysis and production results
from Phase 2 activities. Final design would include the sizing and development of the exact
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
specifications for the oil, gas, and water separation production equipment and the detailed
engineering to prepare the required final construction drawings.
Remove Temporary Production Equipment
The temporary oil, water, and gas production equipment installed on the Project Site during
Phase 2 would be removed. The wells drilled during Phase 2 would be shut in, and steel plating
would be placed on top of the well cellar.
Remove Remaining Trees
The three remaining mature trees along the frontage of the Project Site along Valley Drive would be removed to allow for the construction of final site improvements including a perimeter wall
and the installation of permanent landscaping.
Remove 32-Foot Sound Attenuation Wall and Perimeter Fencing
The 35-foot sound attenuation wall (per Mitigation Measure NV-6a) and the 6-foot perimeter chain link fencing would be removed from the Project Site.
Install 16-Foot Sound Attenuation Wall
Prior to the initiation of earthmoving activities, a temporary 24-foot sound attenuation wall (per
Mitigation Measure NV-4a) would be brought to the Project Site. The sound walls would be designed to be movable and would be relocated within the Project Site as needed to attenuate noise and dust associated with the earthmoving activities needed for the implementation of the
Remedial Action Plan and the final grading of the Project Site. The temporary sound walls
would be removed from the Project Site after the onsite earthmoving and grading activities are
completed.
Implementation of Remedial Action Plan
The Remedial Action Plan would be implemented to address lead, barium, arsenic and total
petroleum hydrocarbon (TPH) contaminated soil and groundwater within and beneath the former
landfill area in the northeastern portion of the Project Site. It is anticipated that approximately 9,000 cubic yards of lead contaminated soil would be removed from the Project Site in accordance with the Remedial Action Plan and hauled to a Class 1 landfill at the Kettleman Hills
Facility, approximately 190 miles from the Project Site. The TPH contaminated soil
(approximately 4,500 cubic yards located deeper than 25 feet) would be treated onsite via vapor
extraction. For a detailed discussion of the soil remediation that would occur prior to final grading of the Project Site, refer to the Remedial Action Plan provided in Appendix A of the Final EIR. Groundwater contamination attributed to historic use of the site has been documented
(Brycon 2013). The RWQCB have indicated that the Regional Water Quality Control Board
Site Cleanup Program reviewed the Report on Groundwater Assessment and indicated the matter
would go on its large backlog of low priority cases.
Construction of Remaining Retaining Walls and Final Grading
Retaining walls (up to 6 feet high) would be constructed 10 feet back from the Valley Drive and
6th Street property lines, along the eastern boundary of the Project Site and along the eastern
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
portion of the southern boundary of the Project Site (see Figure 2.14). In addition, retaining
walls would be constructed within the Project Site for the containment area associated with the
production equipment. After the completion of the retaining walls, the Project Site would be
graded to allow for the installation of Project equipment and to allow for proper site drainage. The final grading of the Project Site would not require the import or export of fill material.
Appendix A of the Final EIR provides the conceptual grading plan that indicates the location of
the retaining wall locations and the final grading of the Project Site.
Complete Construction of Well Cellars
The cement well cellar constructed in Phase 2 would be extended, and a second well cellar
would be constructed to allow for the drilling of the remaining wells in Phase 4. At completion,
the well cellars would be approximately 8 feet wide by 120 feet long by 12 feet deep, with stairs
at each end and covered with expanded metal grating. The well cellars would be equipped with
storm water collection sumps and pumps to direct the storm water to the drain sump. From the drain sump, water would be directed into the processing system and injected, by the water
disposal/injection wells drilled in Phase 4, into the oil-producing reservoir below the oil water
contact. Figure 2.14 shows the location of the well cellars.
Construction of 16-Foot Split-Face Block Wall
A 16-foot split-face block wall would be constructed around the perimeter of the Project Site. The wall would be set back 10 feet from the Valley Drive and 6th Street property lines to allow
for a landscape area. The wall would have a gated entrance off Valley Drive (set back 70 feet
from the sidewalk) and a gated exit to 6th Street. The gates would be metal and motor operated.
The appropriate signage would be provided, as is consistent with City requirements.
Remove 16-Foot Sound Attenuation Wall
After the completion of the Remedial Action Plan, final site grading, and construction of the well
cellars and perimeter wall, the 16-foot temporary sound attenuation wall would be removed from
the Project Site.
Construction of Small Office Building
A small office building approximately 650 square feet in size would be constructed in the
northeast portion of the Project Site to house employee offices and control and monitoring
equipment. The building would have a restroom and break room. The improvements extended
to the Project Site in Phase 1 would provide for associated utilities, including water, sewer, natural gas, and telephone. The California Water Service Company and the City would provide
water and sewer service, respectively. Southern California Gas Company (SCGC) would
provide natural gas, and electricity would be provided by Southern California Edison (SCE).
Verizon would provide telephone service. Office related solid waste services would be provided
by Athens Services or a future city franchisee.
Section 2: Project Description
Exhibit B
Development Agreement between City of Hermosa Beach and E&B Natural Resources
Figure 2.14 Phase 3 Proposed Conceptual Site Plan
Section 2: Project Description
Exhibit B
Development Agreement between City of Hermosa Beach and E&B Natural Resources
Source: Applicant application
Section 2: Project Description
Exhibit B
This page intentionally left blank.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Installation of Permanent Production Equipment
Permanent oil, water, and gas production equipment would be installed on the Project Site. The
permanent oil production facilities would include tanks, vessels, piping, pumps, filters, and supporting metering equipment. These are listed in Table 2.9. A retaining wall around all of the vessels, tanks and other equipment containing oil would provide secondary containment. The
design capacity of the secondary containment would exceed the fluid capacity of the largest tank
by 110 percent plus the precipitation from a 100-year storm event.
In Phase 4, the oil production facility would be used to separate gas, water, and solids from the oil, after which the oil would be stored in tanks prior to transport via pipeline from the Project Site. The separated water would be accumulated in tanks, filtered, and then injected into the oil-
bearing reservoir by the four water disposal/injection wells. Gas from each well would be
treated on the Project Site and then sold to the SCGC. The permanent gas production facilities
would have compressors, vessels, a H2S and carbon dioxide (CO2) removal system, a moisture removal system, and an odorizing system. The use of this equipment is discussed in Section 2.4.4, Phase 4 Development and Operations.
Table 2.9 Phase 3 and 4 Processing Equipment Listing
Equipment Size and Number
Oil Shipping Tanks 40 foot diameter by 16 feet high, 2900 BBLS, 2 tanks
Water Clarifier 40 foot diameter by 16 feet high, 2900 BBLS, 1 tank
Water Surge 30 foot diameter by 16 feet high, 1120 BBLS, 2 tanks
Gas compressors 30 foot by 40 foot - 3 compressors
DEA Skid (acid gas removal) 12 foot by 40 foot, 1 skid
Low Temperature Separation
(LTS) skid (propane refrigerant)
12 foot by 40 foot, 1 skid
Flare/Gas Combustor 10 foot diameter by 22 feet high
Vapor Recovery Compressor 17 foot by 28 foot
IGF Skid 18 foot by 8 foot, 1 skid
Filter Skid 25 foot by 18 foot, 1 skid
Micro Turbines (five turbines) 200 kw each, 30 foot by 40 foot
3-Phase Separator 7 foot diameter by 35 feet long
Lease Automatic Custody
Transfer (LACT) Skid
5 foot by 12 foot
Source: Project Application, Amendments and Appendices. BBLS=barrels (42 gallons), skid=a pre-fabricated unit.
Construction of Final Site Improvements
In addition to the areas where the concrete well cellar, the containment area, and the oil and gas
production equipment have been constructed, the ground surface of the Project Site would be
paved with concrete or asphaltic concrete and designed so that no fluids, including rain water up
to a 100-year storm event, would leave the Project Site. Liquids, including rainwater, would be
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
captured in the containment areas or in the well cellars, processed through the production
facility, and injected into the oil-bearing reservoir via four water disposal/injection wells.
Construction of Final Street Improvements Along Project Frontage
The Proposed Oil Project would include the construction of street improvements along the
frontage of the Project Site on 6th Street and Valley Drive. The improvements would include the
installation of new curbs, gutters, and sidewalks.
Installation of Final Landscaping
Permanent landscaping would be provided along the perimeter of the Project. To the extent feasible, plant materials used in the temporary landscape plan installed in Phase 1 would be
reused in the permanent landscaping. Reclaimed water supplied by the West Basin Municipal
Water District would be used for irrigation. Appendix A provides the conceptual landscape plan
and plant materials for the permanent landscaping that would be provided at the completion of
Phase 3.
Installation of 32-Foot Sound Attenuation Wall
At the completion of the improvements in Phase 3, a 32-foot sound attenuation wall would be
erected inside the 16-foot block wall to provide for noise attenuation during Phase 4 drilling.
Appendix A of the Final EIR provides the elevations of the Project Site, including the sound attenuation walls with the block walls, from Valley Drive and 6th Street at the completion of
Phase 3.
Set Conductor Pipe
Prior to drilling in Phase 4, a dry-hole digger/auger would be used to set the conductor casing in the well cellars for all of the intended wells on the Project Site in a manner similar to the setting
of the conductor pipe in Phase 2. A hole approximately 18 inches in diameter would be drilled
to a depth of approximately 80 feet. A conductor pipe would be lowered to the bottom of the
hole and cemented in place. This would form the seal of the near-surface formation and serve as
a steel conduit to allow the drilling fluid used in the next stage of the well to be circulated to the surface without washing away the shallow near-surface dirt. All conductors necessary to
develop the Proposed Oil Project would be set, and the dry hole digger/auger would be moved
off the Project Site.
Lighting Systems
The permanent lighting for the Proposed Oil Project would be installed as a part of Phase 3. The lighting,as proposed in the Applicant’s Lighting Plan, would be designed to be directed
downward and shielded in order to avoid obtrusive light spillage beyond the Project Site,
reflective glare, and illumination of the nighttime sky.
2.4.3.2 Phase 3 Offsite Pipeline Construction
During Phase 3, offsite pipelines for oil and gas would be constructed to transport the oil and gas to markets. Each route is discussed in the following subsections.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Gas Pipeline Route
As it leaves the Project Site, the offsite underground pipeline for the transport of gas would be
constructed for a distance of 0.43 miles in the ROW of southbound Valley Drive (which is a one way street south of 2nd Street) in the City of Hermosa Beach to a tie-in to a SCG gas line in the
Southern California Edison(SCE) Utility Corridor east of N. Francisca Avenue in the City of
Redondo Beach. See Figure 2.15 for the proposed pipeline routes. Appendix A contains
detailed drawings of the route and valve box options.
This portion of the gas pipeline would consist of two parallel pipelines, 4 inches in diameter, and located at a depth of approximately 3.5 to 4 feet below ground surface (bgs) within the road
ROW until it ties into the SCG line at a proposed metering station immediately to the east of N.
Francisca Avenue. The pipeline would be a loop system that allows for the gas to be returned to
the Project Site for further treatment in the event that the produced gas does not meet SCG
standards. The metering station site, which would be provided as a part of the Proposed Oil Project and is owned by SCG, would be approximately 40 by 60 feet in size and surrounded by
an 8-foot high block wall.
As shown in Figure 2.15, this first portion of the gas pipeline is bounded to the east by the
Greenbelt and Ardmore Park and, further to the east, by Ardmore Avenue and residential
development in the City of Hermosa Beach; to the west by the Beach Cities Self Storage facility, light manufacturing land uses, South Park, and residential development in the City of Hermosa
Beach; and to the west in the City of Redondo Beach by facilities associated with the AES Power
Plant. The gas line is designed for a maximum operating pressure of 465 pounds per square inch
gauge (psig), but would typically operate at approximately 225 psig of pressure.
Once the proposed gas pipeline from the Project Site ties into the SCG point of receipt at the proposed metering station, SCG would construct a six-inch gas pipeline that extends northeast
for approximately 1.4 miles to connect to an existing SCG pipeline transmission facility (Line
1170) located on the south side of 190th Street near its intersection with Green Lane, between
Flagler Lane and Beryl Street, in the City of Redondo Beach. After the first portion of the new
six-inch gas pipeline leaves the proposed metering station and continues northeast, it would be located in an existing SCG easement within the SCE Utility Corridor between N. Francisca
Avenue and Pacific Coast Highway. The new pipeline would exit the SCE Utility Corridor on
the south side of the intersection of Herondo Street/Anita Street with Pacific Coast Highway,
extend across Pacific Coast Highway, and continue northeast within the ROW of Anita
Street/190th Street to its point of connection with the existing SCG pipeline transmission facility (Line 1170). If for some reason the first portion of the new pipeline could not be located within
the existing SCG easement within the SCE Utility Corridor between N. Francisca Avenue and
Pacific Coast Highway, it would leave the proposed metering station and continue for a short
distance north within the ROW of N. Francisca Avenue and turn northeast at Herondo Street
within the ROW until it reaches the intersection of Herondo Street/Anita Street with Pacific Coast Highway. At that point it would continue to the northeast as described previously.
Although SCG would obtain the necessary permits and construct the new gas pipeline, the
Applicant would pay for the associated costs of construction.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Pigging
Passing a device through a
pipeline that cleans or
inspects the pipeline. A pig
is usually a small rubber
device slightly smaller in
diameter than the pipeline.
The pig is forced through it
by product flow. Usually
cylindrical or spherical, pigs
sweep the line by scraping
the sides of the pipeline
and pushing debris ahead
The proposed gas line from the proposed metering station to the existing SCG pipeline
transmission facility is bounded to the north by commercial land uses and residential
development in the City of Redondo Beach and to the south by commercial land uses, residential
development, and public facilities including Dominguez Park and Redondo Beach Dog Park in the City of Redondo Beach.
Oil Pipeline Route
The offsite underground pipeline for the transport of oil to an area refinery via a connection to a
valve location in the City of Torrance would be constructed for a distance of approximately 3.55 miles in one of three potential pipeline scenarios that would follow a route through the Cities of Hermosa
Beach and Redondo Beach and terminate in Torrance.
The selection of the pipeline route would occur after
Project approval. Appendix A of the Final EIR shows the pipeline route scenarios in detail.
The pipeline would be 8 inches or less in diameter,
located at a depth of approximately 3.5 to 4 feet bgs
depending on the grade. At one of four potential valve
box locations, the pipeline would tie-in to an existing pipeline that transports oil to a refinery. Appendix A of the Final EIR provides the proposed alignments of
the three oil pipeline scenarios, the respective
jurisdictional boundaries, and the adjacent land uses.
Appendix A of the Final EIR provides the four valve box location options that the pipeline could tie into. More details are included in Appendix A.
The oil line would be designed for a maximum operating pressure of approximately 500 psig, but
would typically operate at approximately 100 to 200 psig of pressure. The pipeline would
include pigging stations to send and receive maintenance pigs into and from the pipelines to clean or inspect the pipelines during ongoing operations. This would occur for the lifetime of the Proposed Oil Project. Pigging refers to the practice of using pipeline inspection gauges or 'pigs'
to perform various maintenance operations on a pipeline without stopping the flow of the product
in the pipeline (refer to sidebar for more information).
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Figure 2.15 Proposed Pipeline Routes
Source:Project Application, Amendments and Appendices
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
As shown in Figure 2.15, the oil pipeline would be constructed for a distance of 0.39 miles in the
ROW of southbound Valley Drive (which is one-way starting at 2nd Street) in the City of
Hermosa Beach to the corner of Valley Drive/N. Francisca Avenue and Herondo Street in the
City of Redondo Beach. At this point, the oil pipeline would turn to the east along one of the following three pipeline scenarios (see Appendix A of the Final EIR):
• Scenario 1 consists of the construction of the oil pipeline towards the east within the
ROW of Herondo Street, Anita Street, and 190th Street in the City of Redondo Beach to
the intersection of 190th Street/Hawthorne Boulevard in the City of Torrance. At this point, Scenario 1 would continue to one of the four valve box options presented later in this discussion;
• Scenario 2 consists of the construction of the oil pipeline towards the east within the
ROW of Herondo Street and Anita Street in the City of Redondo Beach and the ROW of 190th Street in the City of Torrance to the intersection of 190th Street/Hawthorne Boulevard. At this point, Scenario 2 would continue to one of the four valve box options
presented later in this discussion; and
• Scenario 3 consists of the construction of the oil pipeline towards the east within the SCE
Utility Corridor in the Cities of Redondo Beach and Torrance. When the oil pipeline meets Hawthorne Boulevard in the City of Torrance, Scenario 3 would continue to one of
the four valve box options presented later in this discussion.
The function of the valve box is to house the valve on the new oil pipeline to isolate it from the
main oil transmission line and allow for inspection, operation, and maintenance of the valve and
line to be performed as required by Federal and State regulations.
The site requirement for a valve box for the Proposed Oil Project would be approximately six
feet wide by eight feet long by six feet high. The valve box would be a precast concrete box
with walls that are typically eight to ten inches thick. The valve box would be located below
grade and designed to State of California Highway “traffic-rated” standards to allow for vehicle
travel over it. A standard 36-inch or 42-inch manhole cover would provide access down into the valve box from grade. The manhole cover, the weight of which takes two people to remove and
replace, would be bolted into place with special tools, providing security for the valve box. The
oil pipeline would end at one of the following valve box locations:
• Valve Option 1 – For Pipeline Scenarios 1 and 2, the pipeline would continue from the Hawthorne Boulevard/190th Street intersection down 190th Street to the Exxon Mobil
Refinery, where it would connect with a valve box location within the refinery site. For
Pipeline Scenario 3, the pipeline would turn north in Hawthorne Boulevard and east in
190th Street to the refinery site;
• Valve Option 2 - For Pipeline Scenarios 1 and 2, the pipeline would turn south in Hawthorne Boulevard to the SCE Utility Corridor where it would turn east to the valve
box location. For Pipeline Scenario 3, the pipeline would continue east in the SCE
Utility Corridor across Hawthorne Boulevard to the valve box location;
• Valve Option 3 – For Pipeline Scenarios 1, 2, and 3, the pipeline would turn north in Hawthorne Boulevard to the valve box location adjacent to the Santa Fe Rail Road line;
and
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
• Valve Option 4 - For Pipeline Scenarios 1, 2, and 3, the pipeline would turn north in
Hawthorne Boulevard to the valve box location northeast of the intersection of 190th
Street/Hawthorne Boulevard.
The oil pipeline would be equipped with a supervisory control and data acquisition system (SCADA), which would monitor pipeline pressure and flow and, if a leak is suspected, would
notify the operators. The percentage that is set in the SCADA system would notify the operator
of potential oil leak. The detection timeframes set by the Applicant would vary depending on the
crude oil flow rate in the pipeline. When the flow rate is at the maximum anticipated production rate of 8,000 barrels per day, flowing on a continuous basis, the flow rate would be 5.5 barrels per minute, and the following would apply:
• 15 minute time interval 5 % or 4.1 barrels
• 1 hour time interval 2 % or 6.7 barrels
• 24 hour time interval 1 % or 80 barrels
If oil production is considerably less than the 8,000 barrels per day, the percentages would be
adjusted upward to maintain essentially the same volume of oil previously noted based on the
reduced flow rate in the pipe.
Pipeline Construction Methods
The gas and oil pipelines would be installed utilizing conventional trenching methods within
either one trench or two separate trenches within the roadway ROW. The construction and
installation process would occur in stages consisting of approximately 237 feet in length each. Two stages would be constructed per day (a segment of 237 feet would be new construction, and another 237 feet would be the completion of the construction from the previous day). With the
addition of approximately 126 feet for lane transitions and safety cones, a total of approximately
600 linear feet of roadway would be affected per day. A construction spread would be used to
accomplish most aspects of the gas and oil pipeline construction along the alignments previously discussed. A construction spread is a clustering of construction equipment that moves along the pipeline route, sequentially removing asphalt roadway, trenching, laying pipe, filling, re-paving,
and cleaning up. A pipeline construction spread consisting of several units would be organized
to proceed in the following order:
• Pre-construction activities
• Asphalt removal and ditching or ROW grubbing and ditching
• Pipe handling/welding
• Pipe coating
• Pipe lowering, backfilling, and street repair
• Pipe testing and inspection
• Metering, pigging, odorant station installation
If the oil pipeline can be laid within the SCE Utility Corridor (Scenario 3 pipeline route), a
construction spread similar in arrangement, but smaller, would be used since the alignment
would not have asphalt. In addition, if it is determined that existing sleeves under streets
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
crossing the SCE Utility Easement exist, trenching across some streets may not need to occur.
The following describes the activities that would occur for the construction of the pipelines and
Figure 2.16 depicts a typical pipeline construction spread.
Pre-Construction Activity
The pipeline alignment ROW would include roadways and/or land in existing paved streets and
other property, potentially including private property. Approval to construct and operate a
pipeline would be obtained from or authorized by franchise agreements or permits from the
agency with jurisdiction over the roadways and, if needed, from affected property owners.
The construction requirements in the municipal codes and ordinances of the Cities of Hermosa
Beach, Redondo Beach, and Torrance allow for the construction on major roadways during the
following weekday hours:
• Hermosa Beach: 8:00 a.m. to 6:00 p.m. on weekdays and 9:00 a.m. to 5:00 p.m. on Saturday. No construction on Sundays and holidays;
• Redondo Beach: 9:00 a.m. to 3:00 p.m. on weekdays. No construction on weekends and
holidays; and
• Torrance: 8:30 a.m. to 3:30 p.m. on weekdays. No construction on weekends and holidays.
Figure 2.16 Typical Pipeline Construction Spread
Note: All activities may not occur simultaneously.
The pipeline construction activities would occur on weekdays between the hours of 9:00 a.m.
and 3:00 p.m. (as per the CUP requirements), a time frame which is after morning peak commute
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
hours (i.e., 7:00 a.m. to 9:00 a.m.) and before evening peak commute hours (i.e.: 4:00 p.m. to
6:00 p.m.) on the affected roadways. The Applicant proposes no construction activities during
weekends and holidays. The Applicant would prepare a Construction Traffic Management Plan
(CTMP) that would include the following:
• Require the pipeline contractor(s) to obtain and follow Street Construction Permits in the
affected Cities of Hermosa Beach, Redondo Beach, and Torrance, and Caltrans facilities
(Pacific Coast Highway and Hawthorne Boulevard);
• Develop detour and traffic management plans consistent with the affected City’s Standard Roadway Plans (e.g., Torrance Street Standard T603), the California Manual of
Uniform Traffic Control Devices (MUTCD), or the Work Area Traffic Control
Handbook (WATCH);
• Revise pipeline construction segments to minimize access conflicts to adjacent residents and businesses;
• Develop truck route plans to reduce traffic on the street network during peak traffic
commute hours;
• Avoid construction-related traffic to occur during peak travel periods; and
• Implementation of staggered construction worker shifts to minimize Project traffic during
the peak hours.
Underground Service Alert would notify service providers of construction to avoid conflicts with
existing utilities and disruptions of service to utility customers. Because construction would occur in either paved streets or an existing utility corridor, extensive grading is not proposed.
Asphalt Removal and Ditching
Once traffic control measures are in place, trenching operations would begin. Typically, a five-
foot deep and 18- to 24-inch wide ditch (single pipe) or 36-inch wide ditch (double pipes) would be excavated (varying depths, depending on the conditions encountered). Backhoes and track
hoes would excavate the ditch. However, hand digging would be necessary to locate buried
utilities, such as other pipelines, cables, water mains, and sewers. Fugitive dust emissions at the
construction site during earthmoving operations would be controlled by water trucks equipped
with fine-spray nozzles. Spoils from cuts, including cuts in the streets, would be saved for backfill or would be removed, and the ditch would be backfilled with slurry material as approved
by the local jurisdictional agency. Effort would be made to minimize the amount of excess
material. Material unsuitable for backfill and not economically useful for other purposes at the
pipeline location would be disposed of at a landfill according to local jurisdictional guidelines.
When used for backfill, the spoils from the trenches would be hauled to previously disturbed sites, as determined by the construction contractor.
Pipe Handling
Special trucks would transport the pipe in 40- to 80-foot lengths from the shipment point or
storage yard to the pipeline installation point. Where sufficient room exists, trucks would carry the pipe along the roadway, and sideboom tractors would unload the joints of pipe from the stringing trucks and lay them end to end beside the ditch-line for future line-up and welding. A
portable bending machine would bend the pipe to fit the ditch contour both vertically and
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
horizontally. Construction ROW conditions could occasionally require pipe bends that are not
able to be accomplished in the field. In these cases, manufactured or shop-made bends would be
used, and pipe would be bent prior to the application of coating. While the line-up crew lays the
pipe, line-up clamps would hold the pipe sections in position until approximately 50 percent of the first welding pass is completed. The welding crew would then apply the remaining weld
passes to comply with API 1104, ASME B31.4, or ASME 31.8.2 All pipeline welds would be
radiographically inspected.
Pipe Coating
Protecting the pipe from moisture and air helps prevent corrosion, thereby preventing cracks,
breaks, and leaks in the pipe. The steel pipeline would be coated externally with fusion-bond
epoxy or a corrosion resistant tape wrap system. Pipeline coating would be applied at the mill
before delivery to the construction site. However, field coating would be necessary on all field
weld joints to provide a continuous coating along the pipeline. After the pipe has been welded and radiographically inspected, one of the following would be applied: two-part epoxy, heat-
shrink polyethylene sleeves or polyethylene tape and tape primer.
Pipe Lowering, Backfilling, and Street Repair
The pipe would be lifted and lowered into the ditch by one or two sideboom tractors spaced so
that the weight of unsupported pipe would not cause mechanical damage. Cradles with rubber rollers or padded slings would allow the tractors to lower the pipe without damage as they travel
along the ditch line. Additional welds could be required in instances where the ditch line is
obstructed by other utilities crossing the pipe ditch. These welds would typically be made in the
ditch at the final elevation. In addition to normal welding and weld inspection, each weld would
require pipe handling for line-up, cutting to exact length, coating, and backfilling.
Backfill material in roadways would most likely be slurry material or could be ditch spoils,
according to local agency requirements. Slurry material would be delivered by concrete trucks
and consist of sand and cement. Concrete trucks would be trucks from local commercial
sources. The area would be repaved if it was previously an existing paved street. In areas where
the pipeline would be in previously unpaved areas, the backfill would include topsoil preserved from the excavation for re-vegetation where needed.
At the time of backfilling, a colored warning tape would be buried approximately 12 to 18 inches
above the pipeline to indicate the presence of a buried pipeline to third-party excavators. The
backfilled earth would be compacted using a roller or hydraulic tamper. The trench would be
filled with slurry where approved or required by local regulations. Steel plates would cover any open trench at the end of each workday.
Pipe Testing and Inspection
All field welding would be performed by qualified welders that meet the Applicant’s
specifications and in accordance with all applicable laws, ordinances, regulations, and standards, including API 1104, the Standard for Welding Pipe Lines and Related Facilities, and the rules
2 ASME - American Society of Mechanical Engineers; API – American Petroleum Institute
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
and regulations of the U.S. Department of Transportation found in the Code of Federal
Regulations.
All welds would be visually and radiographically inspected. All rejected welds would be
repaired or replaced as necessary and radiographically inspected again. The radiographic reports and a record of the location of welds would be maintained for the life of the pipeline. In addition
to standard testing of all pipe and fittings at the mill, hydrostatic testing would be performed
after construction and prior to startup. Federal regulations mandate hydrostatic testing of new,
cathodically protected pipelines prior to placing the line into operation. This test involves filling
a test section of the pipeline with fresh water and increasing pressure to a predetermined level. Such tests are designed to prove that the pipe, fittings, and weld sections would maintain
mechanical integrity under pressure without failure or leakage.
Cathodic protection controls the corrosion of a metal surface by making it work as a cathode of
an electrochemical cell. This is achieved by placing the cell in contact with the metal surface
and another more easily corroded metal to act as the anode of the electrochemical cell. The cathodic protection system consists of power sources called rectifiers, buried anodes (either
sacrificial or impressed current), and test stations along the pipelines.
Metering and Pigging Station Installation
A gas-metering station would be required at the custody transfer location where the Applicant’s proposed gas pipeline interconnects with the existing SCG pipeline. The metering station would measure and record gas volumes, gas quality, and gas characteristics and provide custody
transfer of the gas to SCG. The metering station would be located adjacent to N. Francisca
Avenue, southeast of the intersection of Herondo Street and N. Francisca Avenue. SCG would
then construct a new six-inch pipeline to a tie-in location with the existing SCG pipeline transmission facility (Line 1170) as previously discussed in Section 2.4.3.2, Phase 3 Offsite Pipeline Construction.
In addition to the metering station, a pigging station would be installed at the metering station
and Project Site for the gas pipeline, as required by SCG, and at the tie-in point for the oil
pipeline.
An odorant station would be installed at the Project Site consisting of a 500 gallon odorant tank that would be filled approximately annually. The gas would be odorized before it leaves the site.
2.4.3.3 Phase 3 Hazardous Materials
Hazardous materials used as part of Phase 3 would be associated with construction activities,
including diesel fuels, lubricating oils, pipe coatings, solvents, etc. No storage of hazardous materials beyond standard consumer quantities (a few gallons) is anticipated in this phase.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
2.4.3.4 Phase 3 Schedule
It is anticipated that Phase 3 would occur for a period of approximately 14 months as indicated in
the schedule provided in Table 2.10.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Table 2.10 Phase 3 Project Schedule
Activity
Schedule (Weeks)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28-
38
39-
53
54 55 56 57 58 59 60 61 62 63 64
Remove temporary equipment
Remove trees along Valley
Remove32-foot sound wall
Implement RAP
Construct retaining walls
Final grading
Construct well cellars
Construct 16-foot block wall
Remove 16-foot sound wall
Construct/install facilities
Construct street improvements
Install landscaping
Construct offsitepipelines
Start-up of equipment
Install 32-foot sound wall
Set conductor
Note: Days are weekdaysSource: Project Application, Amendments and Appendices
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Table 2.11 Phase 3 Vehicle Trip Summary
Activity 3-axle Trucks,
Maximum RT/day
2-axle Trucks, Autos,
Maximum RT/day
Total, Maximum
RT/day
Remove production equipment 6 15 21
Remove trees along Valley Drive 2 4 6
Install 16-foot noise wall 6 8 14
Implement Remedial Action Plan 18 8 28
Construct retaining walls 3 20 24
Final grading (balanced) 4 6 10
Construct well cellars 9 15 25
Construct 16-foot perimeter wall 5 20 25
Remove 16-foot noise wall 5 5 10
Construct/install onsite facilities 18 40 47
Construct street improvements 11 9 20
Install landscaping 1 7 7
Construct pipeline 18 22 54
Start-up production equipment 0 7 7
Install 32-foot sound wall 6 9 16
Set conductor 2 5 7
Greatest number of trips in one day 18
(during weeks 6-13,
23, 54)
62
(during weeks 39-53)
78
(during week 39-53)
Notes: * According to the 1993 CUP, which is valid pursuant to the Settlement Agreement, the number of
truck trips shall be limited to a maximum of 18 rounds trips per day, except in an emergency.
Trucks are 3+ axle or greater or trucks with trailers. Autos are automobiles or pickups/trucks with 2 axles.
Trips are round trips (RT).
Maximum truck activity occurs during week 6-13 with RAP activities, week23 with construct well cellars,
perimeter wall and onsite facilities and week 54 with construction of onsite facilities, pipeline construction and conductor setting. However, the majority of the pipeline construction traffic would occur away from the
Project Site except during the installation of the sections of the pipeline located very close to the Project facility.
Maximum auto activity occurs during weeks 39-53 with the facilities construction.
Maximum activity trucks and autos combined occurs during weeks 39-53, however, the majority of the
vehicles for the pipeline construction would be parked at the contractor’s facilities or near the pipeline alignment.
Truck maximum and auto/PU maximum do not necessarily occur on the same day, so the total maximum is not necessarily a simply addition of the two. See appendix.
See Appendix A for a detailed breakdown of vehicles, employees, trucks and construction equipment for each week.
Source: Project Application, Amendments and Appendices
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
PHASE 4
Development and
Operations:
2.5 years drilling
program. Operations -
ongoing
2.4.3.5 Phase 3 Personnel and Equipment Requirements
The vehicles, equipment, and employees estimated for Phase 3 are provided in Table 2.11. The
vehicle trips required to transport employees and equipment for Phase 2 are also provided in
Table 2.11.
2.4.4 Phase 4 Development and Operations
The purpose of Phase 4 would be to maximize oil and
gas recovery from the reservoirs by drilling additional
wells and operating the permanent facility. To
accomplish this, Phase 4 would involve the drilling of wells; the operation of the permanent oil production
equipment; the transport of the oil and gas by pipeline
to their respective destinations; and the ongoing
maintenance of the Proposed Oil Project. The Proposed
Oil Project would be designed for a maximum capacity of 8,000 barrels of oil per day and 2.5 million cubic feet
of gas per day.
Figure 2.17 provides the conceptual site plan for Phase 4. Elevations and the conceptual
landscape plan for the Proposed Oil Project during Phase 4 are included in Appendix A of the
Final EIR.
2.4.4.1 Phase 4 Drilling
Phase 4 drilling would involve delivery and setup of the drilling rig and the drilling of the
remaining wells.
Delivery and Set Up of Drill Rig
The drilling rig and its associated equipment would be brought to the Project Site by trucks with
trailers permitted by the City and the California Highway Patrol. The approximately 87-foot
high drill rig would be powered by electricity. A large crane with a 150-foot boom would be
used to erect the drill rig. The crane would be removed from the Project Site after the drill rig
and supporting equipment have been set in place. Support equipment for the drill rig would include pipe racks, mud and cutting system, pumps, hydraulic equipment, and an accumulator.
In the event of a loss of power from SCE, the generator, which would be a non-road portable
diesel-fuel generators certified by the California Air Resources Board (CARB), would provide
power for the safe shutdown of the drilling operation. The drill rig and its associated equipment
would require the same setup as described under Section 2.4.2, Phase 2 Drilling and Testing.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
2.4.5 Drill Remaining Wells
The drilling of the remaining oil wells and water disposal/injection wells, up to a total of 30 oil
wells and four water disposal/injection wells, would involve the same activities as described for
Phase 2. As previously discussed regarding Phase 2, once the drilling of a well is complete, the cemented casing would be run from the surface to the bottom of the wellbore where the well
penetrates the oil-producing reservoir. The well would be plumbed into the temporary
production equipment and pump system that had been installed. The pump system, installed
below ground, would bring the oil, gas, and water to the surface for processing. In addition, up
to three additional water disposal/injection wells (in addition to the single water disposal/injection well drilled during Phase 2) would be drilled to allow for the injection of
processed produced water back into the oil-producing reservoir and at below formation fracture
pressure. The drill rig would operate continuously for 24 hours per day, seven days per week,
until the appropriate depth and bottom-hole location for each well has been reached. It is
estimated it would take approximately 30 days to drill each well, including the time for placing the drilling rig in position and installing rigging. After the drilling of the wells is complete, the
drill rig would be removed from the Project Site. Including set up for each well and removal
from the Project Site, the total drilling time for Phase 4 would be about 30 months (2 ½ years).
Drilling each well would require approximately 130,000 gallons (or 0.4 acre-feet) of water. The
water would be reclaimed water provided by the West Basin Municipal Water District conveyed via extension of an existing waterline serving the Greenbelt east of Valley Drive. The West
Basin Municipal Water District has provided the Applicant with a “will serve” letter.
The drilling process requires the use of drilling mud to circulate drilled rock cuttings out of the
well hole, retain the integrity of the well hole, and control reservoir pressure. The drilling mud
would be collected onsite in tanks. Although most of the mud would be reused on subsequent wells, some mud would be removed from the Project Site and disposed at Anterra’s Oxnard
Licensed Class 2 Disposal Facility or a similar facility. All other waste generated by the test
drilling would be transported by truck to Clean Harbors Buttonwillow Landfill or a similar
facility closer to the Project Site.
Noise abatement would be incorporated into the drilling process in the same manner as described for Phase 2, including a 32-foot high sound attenuation wall. After the drilling of the wells is
completed, the 32-foot sound attenuation wall would be removed from the Project Site.
Re-Drilling of Wells
Re-drilling of a well occurs if production from a well declines substantially or if problems exist with the well, affecting the well’s efficiency or viability. The same activities would be required
for re-drills as for initial drilling, except that conductor piping would not have to be installed
again, as the same conductor piping would be used for the re-drill.
Although the Applicant does not expect the need for the re-drilling of wells, the activity may be
required under extraordinary circumstances. Depending on the circumstances, a workover rig might be able to be used to complete a re-drill. However, for the purpose of providing a worst-
case analysis, the Applicant estimates that up to 30 re-drills could occur over the life of the
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Proposed Oil Project, with up to five re-drills occurring during any given year. In the event that
a re-drill would occur, noise attenuation design features, including the use of a 32-foot sound
attenuation wall and acoustical covers, would be implemented on the Project Site. Re-drills
would involve the same activities and equipment as the drilling proposed for Phase 2 and 4.
2.4.5.1 Phase 4 Processing and Operations
During the drilling of the remaining oil wells and water disposal/injection wells, the production
of the extracted oil would occur. Figure 2.18 shows the steps involved in processing the oil,
water, and gas produced from the wells during Phase 4. The permanent production equipment
on the Project Site would be used to process the oil and gas to a standard that would be suitable for sale. The produced water would be processed and injected into the oil-producing reservoir.
The gas produced would be processed and sold to the gas company. The oil and gas produced
would be transported offsite via pipelines constructed during Phase 3.
Figure 2.18 Phase 4 Process Flow Diagram
Source: Applicant application
Noise abatement would be incorporated into operational practices and permanent production
equipment. The anticipated personnel on the Project Site would be four personnel for a 12-hour
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
daytime shift, two personnel for an 8-hourgraveyard shift, and two personnel for an 8-hour swing
shift. Therefore, personnel would be present 24 hours per day on the Project Site.
During the ongoing operation of the Proposed Oil Project, active wells would require periodic
routine service. These activities could include the replacement of down-hole pumps, piping, and cleaning. These maintenance activities would typically be accomplished by utilizing a service
rig, or “workover” rig, approximately 110 feet high. The workover rig would be operated on the
Project Site a maximum of 90 days per year. The workover rig would be operated between the
hours of 8:00 a.m. and 6:00 p.m. on weekdays only (excluding holidays). Only a single
workover rig would be onsite at one time.
In addition, there would be an occasional need for other services such as facilities repair and
solid and liquid waste pick-up. Preventative maintenance would be performed on a routine basis
to ensure the integrity of the operating equipment. The pipelines would be periodically inspected
to ensure their continued integrity.
The permanent production facility would be utilized to separate and treat produced oil, gas and water. The separation and treatment of these fluids allows for the oil and gas to be sold and
subsequently transported via pipeline and for the water to be injected into the oil-producing
reservoir below the oil water contact line. Figure 2.18 provides a simplified flow diagram of the
flow of fluids through the permanent production facility. The following describes the steps of
production and operational characteristics in Phase 4.
Fluids Piped from the Wellhead to the Production Facility
After a well has been drilled and completed (final down-hole equipment installed), the extracted
fluids would be piped to the permanent production facility on site. The combination of fluids
(i.e., oil, gas, and water mixture) is referred to as an emulsion. This emulsion would be sent via pipes to a production header, where it is commingled with the emulsion from all the wells in a
gross line before entering a three-phase separator. There is also a test header that allows the
diversion of emulsions from a single well through a well test station before the three-phase
separator. The well test station allows for the testing of each well quality and flow
characteristics. After the emulsion passes through the well test station, it would be directed back to the gross line where it would be commingled back with the emulsion from the production
header and then enter the three-phase separator. The three-phase separator separates the oil, gas,
and water. The gas exits the top, the oil exits the middle, and the water exits the bottom of the
separator. Each of these fluids enters a specific system of treatment, as is discussed in the
following subsections.
Oil Treatment System
After the produced oil leaves the three-phase separator, it would enter a stock tank, where it may
need to be heated depending on the quality of the crude oil. This heating would allow excess
water to drop from the oil. Heating, if necessary, would be provided by the microturbine exhaust waste heat recovery system. From the stock tank, the oil would be measured using a Lease Automated Custody Transfer Unit (LACT) and transported via pipeline to the purchaser. Any
water that drops out of the oil would be routed to the water treatment system. Vapors would be
directed to the gas processing systems through the vapor recovery unit.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Gas Treatment System
During this phase, gas would be treated, sold, and subsequently transported via pipeline to the
SCGC. Treatment of the gas would be required to meet gas pipeline specifications. After the gas leaves the three-phase separator, it would be sent to the first stage compressor. The first stage compressor would increase the pressure of the gas for treatment. The first stage of gas
treatment is removal of H2S from the gas utilizing triazine using the SulfaScrub system.
SulfaScrub is a non-regenerative batch process that requires replacement of the SulfaScrub
materials periodically. The SulfaScrub process is a “scavenging” process, meaning it is used to remove H2S in process gas at low concentrations (up to concentrations of approximately 200
ppm).
After leaving the SulfaScrub system, the gas would be sent through the amine system. This
amine system removes CO2 from the gas. After leaving the amine system, the gas would pass
through the second stage compressor, where pressure is increased prior to the gas’ entry into the low temperature separation system. The low temperature separation system removes any remaining moisture (mostly water) and gas liquids from the gas prior to sale. Propane would be
utilized as a refrigerant in the low temperature separation system. Before the gas leaves the
Project Site, it would be odorized using an odorizing substance (mercaptan or equivalent) as
required by law. The gas would then be sent via pipeline through a metering station to a SCG pipeline constructed in Phase 3 located near the corner of Herondo Avenue and N. Francisca Drive to the south of the Project Site.
Water Treatment System
After the water leaves the three-phase separator, it would be sent to the clarifier tank. This tank
would allow solids in the water to drop out. From the clarifier tank, the water would then enter the induced gas flotation unit for the removal of suspended matter, such as oil or solids. The
induced gas flotation unit removes oil by injecting gas bubbles into the water. The bubbles
adhere to the suspended matter, causing the suspended matter to float to the surface and form a
froth layer, which is then removed by a skimmer.
From the induced gas flotation unit, the water would then pass through a filter unit. The filter unit would be used to clean the water of any remaining oil and solids, such as sand. After the
water has left the filter unit, it would enter the water surge tanks for storage before
disposal/injection.
From the water surge tank, the water would then flow through pumps and be sent to the
disposal/injection wells for injection into the oil producing reservoir.
Section 2: Project Description
Exhibit B Development Agreement between City of Hermosa Beach and E&B Natural Resources
Figure 2.17 Phase 4 Site Plan with Drilling Rig
Source: Project Application
Section 2: Project Description
Exhibit B
This page intentionally left blank.
Section 2: Project Description
Exhibit B
Vapor Recovery System
Gas from all tanks and vessels not part of the gas processing system (the oil and water processing
tanks and vessels), as well as pressure relief valves, would be gathered through pipes into a closed-system and directed to a vapor recovery compressor unit. The vapor recovery compressor would compress the gas and then add it to the gas in the gas processing system (from the three-
phase separator, etc), where it would be processed and sent via pipeline to the metering station
and the SCG system.
Process Drain System
All equipment would be connected to a drain system that would be directed to a drain tank.
Liquids from the drain tank would be sent back to the three-phase separator for reprocessing.
Solids from the drain system may periodically be removed to an offsite approved disposal
facility.
Electrical Generation System
The facility would utilize a Microturbine system, which would consist of five 200 kw Capstone
turbines configured as a single 1,000 kw package. Anticipated NOx emissions would be 4 ppm.
Gas produced on the Project Site would be utilized as fuel for the turbines.
Facility Storm Drainage System
The Proposed Oil Project Site is designed to retain, process, and inject storm water within the
perimeter fence or wall for a 100-year storm event. All rainwater falling on the site would be
collected and pumped into the water processing system for injection into the oil reservoir. In
addition, any spills on the site would also be contained, both within process system walls/berms around equipment and site walls/berms around the Project Site. Process walls/berms would be
designed to contain at least 110 percent of the largest vessel plus the precipitation from a 100-
year storm event.
Waste
Waste would be generated as part of the facility operations and the production process. Regular waste would include typical municipal trash such as paper, trash bags, food, and cups. Process
waste would include generic oil field waste such as sandy oil (from the tank bottoms), spent H2S
scavenger, spent filters, oily cloths (i.e., rags), gloves and Tyvek® suits. Intermittently the
facility could generate hazardous waste. These wastes could include empty drums, rinse water, painting supplies, spilled chemicals, spent media, and hydraulic fluids. The Applicant indicates that the Project Site would have an Environmental Protection Agency (EPA) and Department of
Toxic Substances Control(DTSC) Identification Number.
Phase 4 Safety and Security Systems
The Fire Protection Plan for Phase 4 would be provided by the Applicant for review and approval by the City of Hermosa Beach Fire Department (Fire Department) and incorporated
into the Phase 4 Site Safety Plan. Emergency access would be incorporated into the design of
the Proposed Oil Project. An additional fire hydrant would be provided adjacent to the Project
Site as a component of the Proposed Oil Project. The location of the hydrant would be
Section 2: Project Description
Exhibit B
determined by the Fire Department, and installation would occur as a part of the construction
completed in Phase 3.
A fire suppression system for the ongoing operation of the Proposed Oil Project in Phase 4
would be installed during Phase 3. The fire suppression systems would include a foam injection system and automated detection and annunciation systems. Automated alarm systems would be
installed for the detection of chemicals and fire hazards to notify onsite personnel that an
emergency situation is potentially occurring. If it is determined that a chemical fire or fire
emergency exists, the onsite operator would activate the emergency shutdown system and notify
the Fire Department. The Fire Department and their allied agencies would respond as indicated in their mutual and automatic aid agreement contracts. The onsite personnel for the Proposed Oil
Projectwould be trained for initial spill response and activation of emergency systems at the site
as per HAZWOPER requirements, but would not be trained for fire fighting and would rely on
the Fire Department for response activities.
The fire detection system would consist of thermal fire detection and optical surveillance systems that would monitor potential fire zones and activate warning indicators.
The Applicant proposes Subsidence and Induced Seismicity Monitoring Programs to detect
subsidence as a result of drilling activities. This would ensure that subsidence would not be
tolerated to the degree that it could endanger the facility, offsite structures, and the shoreline.
Also, an Induced Seismicity Monitoring Program would be designed to detect seismic activity that might result from drilling activities.
The security system for the ongoing operation of the Proposed Oil Project in Phase 4 would be
installed and initiated during Phase 3. Security on the Project Site would be provided by onsite
personnel and a site security program that would include a Closed Circuit Television System, a
gate access system, and an intrusion and motion detection system. The security system would control all access to and from the Project Site.
During the final design of the Proposed Project and submission of plans to the appropriate
agencies for permits, the following plans and programs would be developed by the Applicant as
part of the facility drilling and operations phases (Phase 2 and Phase 4 activities):
• Odor Minimization Plan;
• Air Monitoring Plan;
• Fire Protection Plan;
• Safety and Environmental Management Program;
• Mechanical Integrity Program;
• Hazardous Materials Business Plan;
• Subsidence and Induced Seismicity Monitoring Programs;
• Noise Monitoring Plan;
• Quiet Mode Drilling Plan; and
• Various plans related to grading, equipment design, electrical design, landscaping, etc.
Section 2: Project Description
Exhibit B
Safety devices would be installed within the piping, vessels, and tanks in the processing system.
Safety devices would provide early warning, corrective action, or shut down of a specific
segment of the system or the entire facility, if necessary. A number of safety devices are
required or recommended by codes, standards and regulations, including:
• High level warning systems;
• High pressure warning systems;
• Automatic shutdown valves;
• Vessel and pipe design requirements;
• Vapor recovery and component leakage limits; and
• Fuel contaminant limits.
Detailed piping and instrument diagrams would be provided by the Applicant during the detailed
permitting stages, and reviews of the final design would be undertaken at that time. Specific
measures to reduce the risk of hazardous material releases are addressed in Section 4.8, Safety,
Risk of Upset, and Hazards.
Phase 4 Hazardous Materials
The operation would require the use of hazardous chemicals. The chemicals would be stored
onsite with secondary containment. The chemicals would be documented in a required
Hazardous Materials Business Plan and submitted to the Los Angeles County Fire Department as
the Certified Unified Program Agency (CUPA) and the Hermosa beach Fire Department. Typical chemicals utilized in the permanent production facility and the maximum quantities that
would be onsite at any time are listed in Table 2.12.
Hydrogen Sulfide
The Applicant indicates that low levels of potential “native” H2S, in the order of 0.0 to 6.0 parts per million (ppm), may be encountered in the gas produced from the underlying oil reservoir. In order to have the capability to treat higher levels, the Proposed Oil Project has been planned to
treat H2S levels of 15 ppm and has a maximum design capacity to treat H2S levels of up to 100
ppm. After treatment with the SulfaScrub system, the H2S levels of the gas would be reduced to
less than 4.0 ppm. SCG’s specifications limit the H2S concentrations in gas delivered to the meter from a producer to less than 4.0 ppm.
The Proposed Project provides for the disposal/injection of treated produced water from the
drilling and production process back into the oil reservoir using water disposal/injection wells.
Untreated produced water can result in the creation of H2S concentrations in the reservoir above
the existing levels in the oil reservoir (referred to as the “native” condition). Prior to the disposal/injection of produced water from the oil extraction process, surface runoff from precipitation that collects on the Project Site, or any additional injected water, the water would
be treated by a biocide to eliminate sulfate-reducing bacteria (SRB). Once wells begin
production, the extracted water would be tested for SRBs to determine if treatment is needed. In
addition, the surface runoff and additional water would be tested. SRBs are an assemblage of specialized bacteria that thrive in the absence of oxygen and obtain energy for growth by oxidation of organic nutrients, with sulfate being reduced to hydrogen sulfide (H2S). SRBs are
treated by the use of a biocide and this treatment could be a batch or continuous treatment.
Section 2: Project Description
Exhibit B
There are numerous antibacterial agents available on the market that could be used for this
specific treatment if it is determined to be needed.
Table 2.12 Phase 4 Drilling Chemicals
Common/Trade Name Use Maximum Quantity Onsite (Gallons)
Odorant/Mercaptan Odorize the sales gas 500
H2S Scavenger/Pertrosweet
HSE700
Gas treatment for H2S 9,000
Emulsion Breaker/Phasetreat 6378 Help separate oil and water 60
Water Clarifier/Floctreat 7991 Water additive 40
Emulsion Breaker/Waxtreat 3610 Help separate oil and wax 50
Corrosion Inhibiter Cor7182 Additive to reduce corrosion 400
Surface Cleaner/4U General purpose cleaner 165
Scale Dissolver/Techni Solve 1780 General purpose scale remover 55
Scale Inhibitor/Techni Hib 7621 Additive to reduce scaling 120
Glycol/TEG Gas treatment for water
removal
55
Amine/DEA Gas Treatment for H2S removal 110
Methanol For oil treatment 55
Biotreat 8415 Water treatment prior tore-
injection
55
Hydrochloric Acid 15%, used for acid washing during completion Varies
Hydrofluoric Acid 3%, used for acidizing muds Varies
Note: Project Application, Amendments and Appendices
2.4.5.2 Phase 4 Schedule
It is anticipated that Phase 4 would occur for a period of approximately 30 to 35 years, as indicated in the schedule provided in Table 2.13. The drilling of the remaining wells would
occur during the first 30 months of Phase 4, with periodic re-drills thereafter for the life of the
project (averaging 30 days per year with a maximum of 150 days in one single year).
The permanent production equipment would operate 24 hours a day, seven days per week. The
Project Site would be staffed 24 hours a day, seven days per week.
Section 2: Project Description
Exhibit B
Table 2.13 Phase 4 Project Schedule
Activity
Schedule (Weeks)
1 2 3 4 5 through 131 132 133 134 135 Life of Project
Deliver and Set up drill rig
Drill remaining 30 wells
Remove drill rig
Remove 32-foot noise wall
Facility operations and maintenance Continuous
Re-drills Avg. 30 days/yr
Max 150 days/yr*
Well workovers Max 90 days per year
Source: Project Application, Amendments and Appendices. To re-drill a well, a drilling rig similar to the
one initiallyused to drill the wells would be used with the same setup, drilling and removal procedures. Workovers would use an 110-foot tall truck mounted drilling rig and would be conducted a maximum of 90 days per year. * This is the maximum number of days per year proposed by the Applicant. The 150 days
per year is predicted to occur once every 5 years. Most likely re-drill activity would be lower.
2.4.5.3 Phase 4 Vehicle Requirements
The number of vehicles estimated by the Applicant to be necessary for Phase 4 operations are
provided in Table 2.14. During drilling, parking for Project employees would be provided as
previously described under Section 2.4.1.1, Phase 1 Construction Activities, under the subsection
Clearance of the Project Site. Parking for Project employees would be provided on the Project Site after the drilling of all the wells is completed and the drill rig has been removed from the Project Site.
2.4.6 Parking Requirements
The Proposed Project construction and operation activities would result in increased parking
demand. The elimination of existing parking would also make necessary the replacement of spaces lost. Parking requirements addressed in this FEIR include the following:
• Temporary parking for a maximum of 40 Project employee vehicles, varying between
approximately 20 and 40 employee vehicles during construction and/or drilling activities
in Phases 1-4, excluding ongoing production in Phase 4;
• Long-term parking for four Project employees during the ongoing operation of the Proposed Project and four additional spaces for maintenance workers in Phase 4;
Exhibit B
Replacement of 15 parking spaces currently located at the City Maintenance Yard that supply
free remote public parking on weekends under the City’s Preferential Parking Program approved
by the Coastal Commission. These spaces are used by:
• Maintenance Yard employees during working hours (i.e., Monday through Thursday from 7:00 a.m. to 6:00 p.m. excluding holidays) and by the public at other times; and
• Replacement of two on-street public parking spaces that would be eliminated by
improvements to the southwest corner of 6th Street and Valley Drive. These spaces are not part of the City’s Preferential Parking Program.
Table 2.14 Phase 4 Vehicle Trip Summary
Activity 3-axle Trucks, Maximum RT/day
2-axle Trucks,
Autos, Maximum RT/day
Total, Maximum RT/day
Deliver and Set up drill rig 6 20 26
Drill remaining 30 wells 12 11 23
Remove drill rig 5 20 25
Remove 32-foot sound wall 4 8 12
Facility operations and maintenance 5 13 18
Well workovers/Major Maintenance 4 14 18
Greatest number of trips in one day 17
(during drilling )
34
(during drilling)
44
(during drilling)
Notes: * According to the 1993 CUP, which is valid pursuant to the Settlement Agreement, the number of truck trips shall be limited to a maximum of 18 rounds trips per day, except in an emergency.
Trucks are 3+ axle or greater or trucks with trailers. Autos are automobiles or pickups/trucks with 2 axles.
Trips are round trips.
Maximum activity occurs during drilling of wells with facility operations and maintenance.
Truck maximum and auto/PU maximum do not necessarily occur on the same day, so the total maximum
is not necessarily a simple addition of the two. See Appendix A.
Re-drilling would produce the same level of traffic as traffic produced during drilling activities.
See Appendix A for details regarding vehicles, employees, trucks and construction equipment necessary for Project operations each week.
Source: Project Application, Amendments and Appendices
In order to comply with the City’s Preferential Parking Program and Coastal Development
Permit requirements and be consistent with the City’s Coastal Land Use Plan (titled Local
Coastal Plan) policies,, 17 public parking spaces would have to be generated under the Proposed
Oil Project to replace the 15 parking spaces removed at the current City Maintenance Yard and the 2 on-street public parking spaces removed from 6th Street, Table 2.15 provides the Applicant’s assessment of parking demand for each phase of the Proposed Oil Project and the
Applicant’s proposal for the development of the required parking as a component of the
Exhibit B
Proposed Oil Project. As indicated in Table 2.15, Phases 1, 2, and 3 and the drilling portion of
Phase 4 would require temporary offsite parking.
Exhibit B
Table 2.15 Proposed Oil Project Parking Requirements
Phase and Peak Activities
Peak
Number of Employees
Number of
Offsite Parking Spaces Needed Comments
Phase 1: construct fence, wells cellar and
install electrical service
27 20 Some employees would
park onsite and others would use temporary
parking lot.
Phase 2: Install equipment and drill test wells. 22 12 Two 5 person shifts for drilling, some carpooling
assumed.
Phase 3: Construct wall, remove soundwall, construct onsite facilities 30-60 40 Peak employees occurs for constructing onsite
facilities. Assumes some carpooling.
Phase 4: Drilling and Operations 10 4 5 persons per shift with
2 shifts per day. Carpooling is assumed.
Phase 4: Operations Only 2-4 0 No offsite parking
needed.
Source: Applicant submittals January 2014
The following information summarizes E&B’s proposal in the Project Application to meet
parking demands.
Cypress Parking Lot: Parking for 20 employees during temporary construction and drilling
activities during Phases 1, 2, 3, and the drilling portion of Phase 4 would be provided in an offsite temporary parking lot to be developed at 636 Cypress Avenue adjacent to the western
Project boundary (referred to as the temporary parking lot).
The Applicant states it has entered into an agreement with the current owner of the subject
property at 636 Cypress Avenue (Assessor Parcel No. 4187-031-22) for this use. Access to the
parcel is provided from Cypress Avenue. While adjoining the Project Site at 555 6th Street, the temporary parking lot will not be accessible from the Project Site due to an elevation difference
between the properties and the need for secured points of entry onto the Project Site.
The 6,000-square foot parcel at 636 Cypress Avenue is a relatively level property. Itis currently
developed with a single-story building that occupies approximately 75 percent of the parcel and a
parking lot with approximately 6 parking spaces. The development of the parcel would comply with all City requirements. Development would require demolition of the existing building,
removal of the current asphalt parking area, and minimal grading. The Cypress Parking Lot
would be completed before the commencement of construction activities to occur under Phase 1
Site Preparation of the Proposed Project.
Improvements that would be made to the new 60-foot by 100-foot parking lot with 20 parking spaces would include drainage, landscaping with irrigation, lighting, a trash container, and other
elements to comply with the City of Hermosa Beach Municipal Code. Details of the redeveloped
parcel are shown in Figure 2-18.
Exhibit B
The Applicant has requested that the City supply the required 17 replacement spaces as part of
the City Maintenance Yard relocation. If the No Added Parking option is constructed, then the
17 spaces would be provided on a temporary basis at the proposed temporary parking lot at 636
Cypress Avenue and on a permanent basis as indicated below.. The City has not agreed to supply any replacement spaces regardless whether the Parking option or No Added Parking
option were to be constructed
Additional 20 Temporary Parking Spaces (Phase 3):During peak construction activities in Phase
3, parking for a maximum of 20 temporary parking spaces, in addition to the 20 temporary
parking spaces provided at the off-site temporary parking area at 636 Cypress Avenue , would be provided at one or more sites, not yet identified, that would be leased or rented by the Applicant. Employees would walk to or be shuttled to the Project Site.
The Applicant proposes to ensure to the City, through the submittal of any required
documentation, that the parking spaces would be available during the temporary construction and
drilling activities for the Proposed Project. If spaces are “remote,” located farther than 5 to 8 blocks from the Project Site as defined by the Applicant, a van pool shuttle service from the
remote parking spaces would be provided to the Project Site by the Applicant. The Applicant
proposes to obtain all required approvals and entitlements from the City and to make any
required modifications to conform with City codes, identified as mitigation measures in the
certified EIR, and any other requirements that may be imposed as a result of the Development Agreement or ballot measure.
Construction Vehicle Parking (Phases 1-4 excluding permanent operations): The Applicant
indicates that it has an agreement to utilize the below-ground parking area at 601Cypress Street
for non-hazardous equipment storage and construction vehicle parking. Parking for construction
vehicles and staging would be provided both at the Project Site at 555 6th Street and within the building at 601 Cypress Street during Phases 1-4.
Parking for Ongoing Operations in (Phase 4): The long-term parking for a maximum of four
Project employee vehicles during ongoing operations and maintenance will be supplied by four
marked parking spaces on the Project Site at 555 6th Street. Additional parking required for
maintenance activities for ongoing operations would also be accommodated onsite along the perimeter wall as indicated in Figure 2-18. No additional offsite parking would be required for
long-term Project operations.
Replacement of Spaces Eliminated by the Project: Fifteen parking spaces at the Project Site at
555 6th Street are used by City Maintenance Yard employees during working hours of Monday
through Thursday from 7:00 a.m. to 6:00 p.m. excluding holidays. These spaces also supply free remote public parking on weekends under the City’s Preferential Parking Program, approved by
the Coastal Commission, and are otherwise used by the public when available. The Application
proposes to replace 15 spaces for free remote public parking in the offsite temporary parking lot
at 636 Cypress Avenue on a temporary basis and as indicated below on a permanent basis. The
City would be responsible to supply parking for its Maintenance Yard employees as part of its City Maintenance Yard relocation plan.
Exhibit B
Two on-street public parking spaces would also be eliminated by Project improvements to the
southwest corner of 6th and Valley Drive; these spaces are not part of the City’s Preferential
Parking Program. The Application proposes to replace these two spaces in the offsite temporary
parking lot at 636 Cypress Avenue on a temporary basis and as indicated below on a permanent basis.
The Application indicates potential overlap with onsite employee scheduling during the drilling
portion of Phase 4, requiring four parking spaces at 636 Cypress Avenue to be vacant as one shift
arrives and another shift is leaving. This results in the availability of 16, rather than 17, parking
spaces for a period of approximately one hour.
The Application indicates that relocation of the 17 public parking spaces requires a coordinated
approach between the Applicant and the City and proposes that this relocation be governed by
the Lease Agreement (Section 13). The Applicant proposes the relocated City Maintenance Yard
be developed in a manner which could supply the permanent public parking spaces on weekends
and at night, similar to the way in which the existing parking spaces at the current City Maintenance Yard are utilized. If the relocation of the City Maintenance Yard does not become
the location for the permanent public parking spaces, then the Applicant proposes to provide 15
replacement public parking spaces as well as the additional 2 public parking spaces, prior to the
commencement of Project operations, at the offsite temporary parking lot at 636 Cypress Avenue
or to provide other suitable public parking spaces consistent with requirements of the City’s Preferential Parking Program, the California Coastal Act, and a framework proposed by the
Applicant.
2.4.7 Project Life and Decommissioning
Under the Proposed Oil Project, the oil and gas resources would be developed until they are
depleted and developing them is no longer economically viable, for up to 35 years. Currently, the amount of crude oil that could be produced from the field is unknown, and future crude
prices are difficult to assess. According to the Lease Agreement, the Proposed Oil Project could
operate for up to 35 years. Figure 2.19 shows the estimated crude oil, gas and water production
for the life of the Proposed Oil Project.
If during Phase 2 the Applicant does not consider the level of production from the Project Site to be economically feasible, then decommissioning of the installed equipment would commence.
Decommissioning would involve the removal of the drilling and temporary testing equipment
and would include abandonment of wells according to the Division of Oil, Gas and Geothermal
Resources (DOGGR) requirements. The Project Site would be left as a graded site with site
improvements including the retaining walls, the perimeter chain link fence, and the perimeter landscaping.
At the end of the Proposed Oil Project, when the owner applies to DOGGR and to the City to
abandon the facility, a separate permit process and CEQA environmental review would be
required to evaluate decommissioning of the entire Project Site. Since the timing of the
decommissioning is unknown, the Applicant has not submitted a detailed decommissioning plan, and therefore any assessment of decommissioning activities would be speculative at this time.
Exhibit B
Figure 2-18 Cypress Parking Area
Source: E&B Updated Parking Plan 1/8/2014
Exhibit B
Figure 2.19 Estimated Production Levels
Source: Based on Applicant submitted estimates
2.4.8 Project Scheduling Summary
Under the Proposed Oil Project, there are a number of different activities with various
allowances for time of day, day of week and annual limits. These are summarized in Table 2.16.
Table 2.16 Proposed Oil Project Scheduling Summary
Activity Allowed Period Annually Days and Hours per Day
Workover Rig Maximum 90 days
per year
8 am - 6 pm weekdays only
Drilling Rig Phase 2 - 120 days
Phase 4 - 30 months 24 hours per day
Re-drills 30 days per year
average, up to 150 per year max 24 hours per day
Phase 1 and Phase 3 Construction Any 8 am - 6 pm weekdays and
Exhibit B
9 am - 5 pm Saturdays
Offsite ROW Construction Any 8 am - 3 pm weekdays only in
the City of HB
Truck deliveries Any 9am - 3 pm weekdays or emergencies
Quiet mode drilling Phase 2 and Phase
4 Drilling, Re-drills
7 pm - 8 am
Pipeline construction activities Phase 3 9 am - 3 pm weekdays.
Exhibit C
EXHIBIT “C”
PUBLIC BENEFITS OF PROJECT
As consideration for the benefits provided to E&B through this agreement, E&B has agreed to
provide the Public Benefits in addition to the Project’s benefits as noted in the Settlement
Agreement. [TO BE UPDATED ACCORDINGLY]
1) Remedial Action Plan: E & B will pay the entire cost of soils and groundwater remediation of the maintenance yard should the oil ban be lifted and the project move forward to
Phase III – full production.
2) Temporary and Permanent Relocation of City Maintenance Yard: E & B will pay the
following amounts towards temporary and permanent relocation of the maintenance yard in lieu of the amounts called for in Section 13 of the lease:
Temporary relocation:
Permanent relocation:
3) Timing of Revenues:
Exhibit D
EXHIBIT “D”
CONDITIONS OF PROJECT APPROVAL
Exhibit D includes:
1. Exhibit D-1
Conditions of Approval from 1993 Conditional Use Permit for Oil Development at
the City Maintenance Yard, approved by the City in Resolution No. 93-5632 (CUP
to be abandoned and superseded by this agreement)
2. Exhibit D-2
Additional Project Conditions
3. Exhibit D-3
Mitigation Measures/Mitigation Monitoring Plan- from Section 8.0 of Final
Environmental Impact Report (as revised at Hermosa Beach City Council
certification hearing on July 8, 2014 per Resolution 14-6908).
Exhibit D-1
Exhibit D-1 Conditions of Approval from 1993 Conditional Use Permit for Oil Development at the City
Maintenance Yard, approved by the City in Resolution No. 93-5632
(CUP to be abandoned and superseded by this Agreement) (Amendments to conditions necessary for consistency with Project Description, Mitigation Measures and other conditions and terms are reflected herein)
SECTION 1. GENERAL
1. The testing phase for all production shall be a maximum of one year from the date drilling is initiated.
2. A minimum of one annual site audit shall take place to inspect for soil contamination as a result of accidental spills in any area not paved and expose. Auditor shall be hired
by City.
3. The maximum number of days the work over rigs or any other rig (other than a drill
rig) that is to be used on-site shall be 90 days per year, and shall be operated weekdays 8:00 A.M. to 6:00 P.M. excluding holidays.
4. In the event that a residence with solar panels is affected by shading, a site specific study paid for by the oil contractor shall be conducted to determine economic impact.
5. Pursuant to Assembly Bill 3180 the operation shall be monitored for all condition of
the approval of which the City has responsibility which includes (but not limited to)
noise monitoring and inspection of the site for proper maintenance.
6. The proposed plans shall be submitted to the State Division of Oil, Gas & Geothermal
Resources for their review and recommendation;
a. Any recommendation by the State Division of Oil, Gas & Geothermal
Resources shall be taken into consideration prior to approval, and may be
included as condition of approval.
7. Drill cuttings and other wastes, shall be collected in above ground containers and disposed of at an approved disposal site. Receipts for all disposal of waste product
shall be provided within ten (10) days of disposal to the Public Works Director.
8. All requirements, standards, conditions stated within the oil Production Code, Chapter
21-A, of the City’s Municipal Code shall be met, unless more restrictive requirements
are imposed through mitigation measures; where it cannot be clearly determined
whether the City’s Oil Ordinance, Chapter 21-A or mitigation measure are more
stringent, the appropriate City staff shall make a determination; appealable to the City Council.
Exhibit D-1
9. Three (3) copies of final building plans including site, elevation, and floor plans shall
be submitted for review and approval by the Planning Director prior to the issuance of
any Building Permit.
10. The proposed development shall be in substantial conformance with submitted plans.
Any minor modification shall be reviewed and may be approved by the Planning Director.
11. All wells must be drilled and completed within 55 months from the start of drilling of
the first exploratory well in accordance with the following schedule:
PHASE 1 SITE PREPARATION 6 MONTHS
PHASE 2 DRILLING AND TESTING PHASE 12 MONTHS
(Exploratory drilling, production testing)
PHASE 3 FINAL DESIGN AND CONSTRUCTION
PHASE 14 MONTHS (Permanent facility construction)
PHASE 4 DEVELOPMENT AND OPERATIONS (DRILLING) 34 MONTHS
(Development Drilling, 1 month per well)
If the Drilling Contractor is delayed at any time in the progress of work by any act or
neglect of the City of Hermosa Beach or any other governmental body having authority over
this project, or by labor disputes, adverse weather conditions, by law, war, riots, strikes,
unavoidable casualties, unusual delays in receiving material or equipment or by an act of
God, or causes beyond the control of the Drilling Contractor, when justified, the time period may be extended to a reasonable time to correspond with the delay incurred by the Drilling
Contractor.
SECTION 2. LAND USE
1. The maximum size for any storage tank of any type shall be forty feet in diameter and
sixteen feet in height, appurtenances not included.
2. Prior to construction and prior to obtaining building permits for oil production, a
complete soil analysis shall be performed and approved by all applicable governing
agencies having jurisdiction over the project.
3. Not more than five tanks shall be installed, and shall be submerged in a concrete basin which contains 10% above the volume required by the State Division of Oil, Gas &
Geothermal Resources and the Uniform Fire Code which is as follows: the volumetric
Exhibit D-1
capacity of the diked area shall not be less than the greatest amount of liquid that can
be released from the largest tank within the diked area. The capacity of the diked
areas enclosing more than one tank shall be calculated by deducting the volume of the tanks other than the largest tank below the height of the dike.
4. All wells shall be drilled and cemented in accordance with State Division of Oil, Gas and Geothermal Resources regulations to protect underground aquifers.
5. The electrical service systems shall be designed with sufficient capacity to minimize
surging impacts.
6. The well cellars shall be concrete lined and shall be designed to hold contaminated
run-off from on-site sources; or a sump shall be provided.
7. Solid state control console linked to a control system to perform energy conservation
functions such as start/stop time programming of motor equipment, data logging of
energy consumption and maintenance and service scheduling shall be provided.
a. All Electrical machinery where possible shall have a minimum coefficient of efficiency of 0.75.
SECTION 3. PUBLIC SAFETY
1. The site shall be enclosed by a solid masonry or concrete wall with solid gates during
all operations, protecting both against public entry, observation and attraction. A
chain link fence to provide security is acceptable only through Phases 1 and 2.
2. Security personnel shall be employed at all times during the drilling stage (24 hours)
and emergency phone numbers shall be posted during production Phases 2 and 4.
3. Signs warning of unauthorized entry and safety hazards shall be posted on all sides.
4. Access to facilities shall be limited to authorized personnel only.
5. Trees shall be maintained at a distance from all walls to prohibit children and others
from unauthorized entry.
6. All site personnel shall be instructed on required safety procedures if hydrogen sulfide
concentrations are encountered. Documentation of training and instruction shall be
made available to the City Manager.
7. Both solid and liquid wastes shall be sampled and tested to determine if it needs to be treated as a hazardous waste.
Exhibit D-1
8. An Oil Spill Prevention Control Countermeasures (SPCC) Plan and an Oil Drilling
Contingency Plan will be Prepared for the Project and approved by the State Division
of Oil, Gas and Geothermal Resources, and the City of Hermosa Beach Fire and Building and Safety Departments.
9. Drillsite and production facilities shall be constructed in accordance with the State seismic standards, and designed in accordance with U. B.C. seismic requirements for
hazardous facilities.
10. A soils engineering report and engineering geology report prepared by a licensed
geologist and engineer shall be prepared and reviewed in conjunction with the plans for all physical improvements. Said report shall address potential seismic hazards,
such as liquefaction, due to soils or geologic conditions. All recommendations
contained in said reports shall be incorporated in the construction documents.
11. An emergency response plan, including a blowout prevention and control plan, shall
be prepared for review and approval by the State Division of Oil, Gas & Geothermal
Resources and the Hermosa Beach Fire Department.
12. When a leak or spill occurs, it shall be contained, the fluid shall be recovered and the
area restored to its original condition.
SECTION 4. FIRE SAFETY
1. Adequate fire detection and fighting equipment and supplies, approved by the Fire
Department, shall be maintained on the drillsite and tank production facility at all
times.
2. A supplementary analysis by a professional consultant shall be provided detailing any
necessary improvements the Fire Department may need to prevent, and to halt oil related fires and shall also include the following: public notification, warning and
evacuation plan.
3. Oil sumps, drip pans, etc. shall be cleaned at regular intervals to reduce fire hazards
and prevent minor spills.
4. Oily rags, paper and miscellaneous waste shall be disposed of in an appropriate
manner to reduce fire hazards
5. Signs warning of flammable fluids and prohibiting smoking shall be installed where
appropriate.
6. The drillsite and production facility shall be protected by automatic fire detection sensors and suppression systems. The fire suppression systems shall include a tank-
cooling sprinkler system.
Exhibit D-1
7. Drilling operations shall be conducted in accordance with appropriate State Division
of Oil, Gas & Geothermal Resources regulations and shall utilize all required blowout prevention equipment and safety devices.
8. Fire flows to service the operation shall meet Fire Department regulations.
9. All equipment necessary to contain an oil fire or blowout shall be provided and/or
maintained on site and all fire personnel shall be trained on its use.
SECTION 6. VEHICLE TRAFFIC AND CIRCULATION ON AND OFF SITE
1. All truck deliveries shall be limited to daylight hours (9:00 AM – 3:00 PM), Monday
through Friday, except for an emergency situation, as defined by this agreement and reported to the City in accordance with the notification requirement, which have been
reported to the Director of Public Works in advance of the delivery.
2. Operation of earthmoving equipment shall be limited to daytime hours between 8 AM
and 6 PM.
3. Equipment deliveries shall be made only during daytime hours between 9 AM and 3
PM.
4. Project related truck travel shall be restricted to specific truck routes and access points
as approved by the Public Works Department.
5. Signs shall be installed to direct detour traffic as approved by the Public Works
Director.
6. The number of truck trips shall be limited to a maximum of 18 round trips per day, except in an emergency, as defined by this agreement and reported to the City in
accordance with the notification requirement.
7. Maintenance Yard site access shall be designed to enable trucks to turn into the site
without inhibiting traffic movement on Valley Drive or Sixth Street.
8. Minor curb radii reconstruction shall be done by the operator as determined by the
City Public Works depending on the length and necessary turning radii for project related trucks.
9. Area residents shall be notified of pipeline construction prior to commencement.
Signs shall be installed to direct detour traffic.
10. All trucks arriving or departing the drill site shall be washed to prevent spillage of
earth and all routes shall be swept and washed by the driller as required by the City.
Exhibit D-1
11. An evaluation of the structural condition of the existing pavement shall be performed
by a soils engineer on all access streets and the proposed truck routes prior to commencing any site preparation or construction and prior to the issuance of any
necessary permits. The evaluation shall include as a minimum:
a) the number, type, size and weight of trucks for export of materials or product,
b) the number, type, size and weight of truck deliveries of building supplies,
drilling supplies etc.,
c) the number, type, size and weight of equipment transported to the site,
d) other associated transportation items,
e) other anticipated loading.
The evaluation shall contain recommendations as to the actions required to maintain
said streets and routes in their current condition throughout the planned development phase, planned production phase, and in the close out phase.
12. The operator shall perform the actions on the existing pavement as recommended by the soils or highway engineer, the operator will hire a licensed contractor and provide
street profiles, drawings, and engineering to the satisfaction of the Public Works
Department prior to work commencing.
13. The City Council may restrict the use of certain street, alleys, or roadways in
connection with the permittee’s operation. In the event any street, alley or roadway is
damaged by the permittee’s operations, such damages shall be paid for by the
permittee upon demand by the City, and the failure to pay such damages, being the reasonable cost of the repair of any such damaged portions, shall be grounds for the
revocation of the permit and the collection of such damages.
SECTION 7. SANITARY SEWER
1. Use of sanitary sewer is prohibited, except for the minimal use associated with the
office and restroom facilities. Any water from oil production shall be disposed in the
four disposal wells.
SECTION 8. NOISE /VIBRATION
1. Tripping will be restricted to daylight hours only.
2. Loudspeaker paging systems shall be prohibited.
Exhibit D-1
3. Well workover rigs or any other rig that is used shall be operated only between the
hours of 8:00 A.M. and 6:00 P.M. during daytime weekday hours only, excluding
holidays, except in an emergency, as defined herein and reported to the City in accordance with the notification requirement. The exhaust and intake of the diesel
engine (if used on the workover rig) shall be muffled to reduce noise to an acceptable
limit. The operator shall use whatever means necessary, including but not limited to, enclosing the diesel engine and rig in acoustic blankets or housing.
4. All oil maintenance equipment, vehicles and non-electrical motors shall be equipped
with manufacturer approved mufflers or housed in a sound-proofing device.
5. Noise monitoring shall be conducted under the supervision of an independent
certified acoustical engineer paid for by the permittee. Reports shall be submitted to
the Planning Director within three working days after the completion of each phase of the monitoring. The monitoring shall include the following:
a. Pre-drilling phase monitoring. Prior to the start of the drilling phase, noise
measurements shall be obtained during the operation of the specific drilling rig
which has been selected and the measurements shall be related to those experienced at the nearest residential boundaries to the drilling site. In
addition, the noise control measures which have been (or will be) applied to
the rig as needed for compliance with the City of Hermosa Beach noise ordinances shall be identified.
b. Start of Drilling. Noise measurements shall be obtained during the nighttime
hours (10:00 P.M. to 7:00 A.M.) for at least six hours on each of the three
nights within the five day period from the start of the drilling phase.
Monitoring is to occur at the nearest residential boundary to the actual drilling
operation.
c. During the drilling phase. Noise monitoring shall occur during a six-hour
period between the hours from 10:00 P.M. to 7:00 A.M. at least once each
month during the drilling phase of the project. The noise level data obtained
shall be compared to the City of Hermosa Beach Noise Ordinance standards
by the Planning Department. Where an exceedence of the standards is identified, noise control measures shall be required.
Production phase. Noise measurements shall be obtained during a six-hour period between the hours from 10:00 P.M. to 7:00 A.M. at least once each year during the production and
completion phase.SECTION 9. LANDSCAPING
1. A Detailed Landscape Plan for Phases 2 (exploratory drilling and testing) and Phase
4, indicating the type, size and quantity of plant materials shall be submitted to the Planning Commission, and shall comply with Section 21A-2.9 of the Oil Code.
Exhibit D-1
2. During Phase 2, test facility, landscaping consisting of 24” box, or larger size trees
may be installed without permanent planting.
3. Minimum 24” boxed trees for Phases 2 and 4 shall be adequate in size to create a
buffer effect to obscure visibility of oil production activity. Permanent trees planted
around the perimeter of the site for Phase 4 shall be a minimum sixteen (16) feet high at planting.
4. Trees along the lot perimeter shall be provided to create a dense landscape buffer to
the satisfaction and field review of the Planning Director.
5. The aesthetic impact of the exposed masonry walls on the west and northern sides
shall be softened with the planting of climbing vines to the satisfaction and review of
the Planning Director.
6. Landscaping shall be maintained in a neat and clean condition.
7. A complete automatic sprinkler system shall be provided prior to commencement of
Phases 2 and 4.
SECTION 10. AESTHETICS 1. The tanks, acoustical wrap and wall, and production facility shall be painted a neutral
color to blend in with in with the surroundings; color shall be reviewed and approved
the Planning Commission.
2. The use of architectural lighting beyond safety and security requirements shall be
prohibited.
3. The site for drilling equipment and the storage facilities shall be depressed in combination with walls so that the visual impact is minimized.
4. All outdoor lighting shall be shielded and directed inward of the site.
5. Lighting shall be limited solely to the amount and intensities necessary for safety and security purposes.
6. Certain activities which might involve unshielded lighting (i.e., site preparation and restoration) activities shall be limited to daylight hours and thus not require nighttime
lighting.
7. A wall maintained graffiti free of a minimum of 12 feet in height shall be provided;
wall materials shall be reviewed and approved by Planning Director. During test drilling minimum 6’high fencing shall be provided. See Mitigation Measures for
Noise and Vibration in D-3 below for additional requirements for this wall.
Exhibit D-1
8. Tanks shall be submerged 6 to 8 feet or more below grade and will be adjacent to the
35-foot high privacy wall.
9. If the drill derrick remains idle for more than one year, review and approval by the
City Planning Commission or the City Council shall be required, or the derrick shall be dismantled at the expense of the operator.
10. All production equipment and structures shall be painted to blend with the
surrounding environment with review and approval by the Planning Director.
11. On-site signs shall be limited to those needed for public health and safety.
12. All derricks masts hereafter erected for drilling, re-drilling or remedial operations or for use in production operations shall be removed within 45 days after completion of
the work unless otherwise ordered by the Division of Oil, Gas & Geothermal
Resources of the state.
13. The operator shall diligently and continuously pursue drilling operations until the all 30 oil wells and all four (4) water disposal wells are completed or abandoned to the
satisfaction of the Division of Oil, Gas & Geothermal Resources of the state and upon
completion or abandonment shall remove all drilling equipment from the drill site within 45 days following completion or abandonment of the well unless otherwise
ordered by the Division of Oil, Gas & Geothermal Resources.
SECTION 11. ODORS/VAPOR/AIR POLLUTION 1. A vapor recovery system shall be installed to recover 99% of hydrocarbon emission
during storage and transfer of crude oil.
2. Raw gas shall not be allowed into the atmosphere.
3. Gas and vapor detection systems shall be installed at appropriate locations.
4. All project site activities shall be conducted such as to eliminate escape of gas in
accordance with best available control technology and practices which shall be reviewed and approved by the City.
5. All requirements of AQMD shall be met at all times.
6. A state-of-the-art scrubber shall be employed for the exploratory phase to eliminate
odors from waste gases, and any flame shall be enclosed.
7. Tanks shall be designed and located so that no odors or fumes can be detected from the adjacent areas outside the exterior walls of the project.
Exhibit D-1
8. Operators shall not blow lines to the atmosphere, except in an emergency, as defined
below in Section 14. and reported to the City in accordance with the notification
requirement.
9. Construction equipment and vehicles shall be maintained in proper tune.
10. Odorless drilling muds shall be used.
11. Well tubing and rods shall not remain out of the well during workover operation less
than 8-hours. The tubing will be surface washed with a detergent solution to remove
odor bearing residual hydrocarbons if exposed longer than 8-hours.
12. Odor control will be further enforced by the SCAQMD under Rules 402, 466.1 of
their regulations, and the commercial recovery system shall be employed for the permanent facility.
13. There shall be no open flames allowed.
14. The permittee shall monitor drilling mud during drilling on the site for odorous substances and take such measures to eliminate any odor which would be perceptible
outside the drill site.
15. The permittee shall undertake no refining process or any process for the extraction of
products from natural gas, except for such minor processeds as necessary to make
natural gas acceptable to the City gas mains for domestic use. [correction of typo]
16. Well cellars shall be maintained in a clean and efficient manner to prevent waste
accumulation and shall be frequently steam cleaned.
SECTION 12. GRADING/STORM WATER/SITE RUNOFF
1. Grading shall not be performed when wind speeds exceed 20 mph. The contractor
shall maintain a wind speed monitoring device on site during grading operations. The
contractor shall continually keep the soil moist during grading operations. At no time
shall any dust be allowed to leave the work site.
2. Normal wetting procedures shall be employed during grading. Review and approval
of procedure shall be by Public Works Director.
3. Graded surfaces shall be paved or landscaped per approved plan.
4. Project site shall be graded so that all contaminated runoff is collected and treated
on-site and disposed of according to all laws.
Exhibit D-1
5. Site shall be graded in a manner so that all hazards or contaminated fluids and runoff
are directed toward a cellar and approved pit and disposed of properly.
6. No water from the site shall be allowed to enter the storm drainage system or any
public area.
7. No water from the site shall be allowed to surface flow across the public beach.
SECTION 13. PIPELINE CONSTRUCTION
1. The pipeline operators shall adhere to all applicable federal, state, regional, and local statutes governing design, construction, operation, and maintenance of the pipelines
and related equipment.
2. A detailed pipeline survey shall be conducted in order to locate existing pipelines
prior to excavation for pipeline construction.
3. A responsible agent paid for by the applicant shall be present during excavations.
4. Areas of construction and maintenance activities shall be delineated by signs,
flagmen, pavement markings, barricades, and lights, as determined by permit
requirements of all local agencies.
5. Where pedestrian activities are affected during construction, appropriate warning
signs shall be installed and pedestrians will be diverted. Pedestrian access to
businesses and residences will be maintained during construction. Special facilities,
such as handrails, fences, and walkways shall be provided, if necessary, for the safety
of pedestrians.
6. Obstruction of emergency vehicle operations will be partially mitigated by ensuring that providers of emergency services are kept informed of the location, nature, and
duration of construction activities so alternate routes can be chosen. It is essential that
fire department access is maintained to all buildings adjacent to construction
activities. For this reason, a minimum of at least one lane for streets undergoing
construction will be kept open at all times, and fire hydrants in construction areas will remain accessible.
7. If public transit stops along pipeline routes need to be temporarily relocated during construction, the applicant shall provide signs directing riders to the temporary stop
location.
8. When hauling excavated and waste materials from construction sites, substandard
roadways will be avoided and local jurisdiction regulation governing hauling vehicles will be adhered to.
Exhibit D-1
9. Pipeline construction and operation of earth moving equipment shall be limited to
daylight hours between 8:00 AM and 3:00 PM and shall not be permitted during
weekend periods. Additionally, construction-related trucks should not be operated during peak traffic hours of 7 to 9 AM and 3 to 7 PM. Pipeline construction at major
intersections shall be limited to daylight hours between 9:00 AM and 3:00 PM to
avoid peak traffic periods.
10. Equipment deliveries shall be made only during daytime hours between 8 AM and 3
PM.
11. In order to reduce visual impacts and possible safety hazards, storage of pipes and other materials, as well as construction equipment, shall not be permitted on any
street during non-construction hours.
12. Area residents within 300’ shall be notified about the pipeline construction operation
prior to commencement of construction.
13. Detour signs on pipeline construction routes shall be placed at appropriate locations.
14. Steel plates covering pipeline excavation trenches shall be placed to permit traffic
movement during non-construction hours.
15. Pipelines shall be designed with ample safety factors, pressure-tested prior to being
placed in operation, and monitored for corrosion once in operation.
16. Safety shut-down devices that respond to drops in pipeline pressure shall be
incorporated into the project in order to stop the flow of the pipeline contents in case
of a pipeline rupture.
17. Groundwater level and land subsidence shall be monitored to insure that pipeline damage does not occur as a result of geologic and hydrologic phenomena. The annual
subsidence survey shall include a report to the City on monitoring efforts to insure
pipelining damage has not occurred.
18. Pipeline construction along Valley Drive shall be approved by the Director of Public Works prior to issuance of a permit.
19. Pipeline construction shall not occur in the area known as the Hermosa Valley Greenbelt except that the permittee may connect to West Basin Municipal Water
District’s existing reclaimed water line for the purposes and as described in Exhibit B
to this Agreement.
20. Storage of materials shall not be allowed on the Hermosa Valley Greenbelt. The storage or dumping upon the greenbelt of any materials, construction equipment,
debris, oil drilling equipment, drilling rigs, piping, etc., and any and all equipment
Exhibit D-1
and vehicles necessary for the construction and maintenance of the pipeline and oil
development site shall be prohibited. The use of the greenbelt as a staging area for
construction of the oil facility or pipeline shall be prohibited. There shall be no parking or standing of any vehicles on the greenbelt for any time period.
21. Trenches shall be covered during non-working hours to minimize traffic circulation problems.
SECTION 14
Definition and notification requirements for emergency situations:
I. For purposes of these conditions, “Emergency” is defined as follows:
A threat to the health and safety of persons in the surrounding area to the drill site
and the following conditions which require immediate action:
A. Conditions which could lead to potential spill or well blowout:
1. Entry of oil and gas into the wellbore while drilling, tripping or out of
the hole which may be indicated by one or more of the following:
a. Pit volume gain
b. Well flowing with pumps off
c. Flow rate increases with circulation
d. Improper hole fill-up on trips
e. Sudden increase in drilling rate
f. Pump pressure decreases and pump rate increases
g. Decrease in returning mud rate
h. Sloughing shale i. Changes in mud salinity and/or mud flow properties
2. Lost circulation or loss of ability to circulate
3. Casing or wellhead failure while drilling
4. Stuck pipe and/or equipment during any of the following operations:
a. Drilling
b. Tripping drill pipe and tools
c. Wireline logging
d. Drill stem testing
e. Running casing f. Perforating and stimulating completion interval
Exhibit D-1
5. Loss of rig power or equipment failure while drilling or tripping.
B. Injuries to personnel at the Drill Site
C. Conditions which could reduce the stability and safety of the rig and
production equipment:
1. Natural events:
a. Excessive winds, rain and lightning
b. Floods c. Subsidence
d. Earthquakes
2. Other events
a. Riots/Demonstrations
b. Fire
II. Notification Required: In the case of an emergency, as defined above, the
permittee shall give immediate notice to the City of the occurrence of the
emergency event. The City will provide the permittee with a list of phone numbers of City personnel to call for notification purposes. A written notice, including a
detailed description of the emergency condition, and the actions take and/or
proposed to be taken to correct the situation, shall be provided within 24 hours of
the occurrence of the emergency event.
SECTION 15
1. Each of the above conditions is separately enforced, and if any of the conditions of approval is found to be invalid by a court of law, all the other conditions shall remain valid
and enforceable.
2. The subject property shall be developed, maintained and operated in full compliance with
the conditions of this grant and any law, statute, ordinance or other regulation applicable to any development or activity on the subject property. Failure of the permittee to cease any
development or activity not in full compliance shall be a violation of these conditions.
Exhibit D-2
Exhibit D-2
ADDITIONAL PROJECT CONDITIONS
A. GENERAL
E&B (herein “Operator”) is the owner and Operator of this project, responsible for
implementing and complying with all applicable conditions.
A-1 Project Description
This Development Agreement, and associated conditions, is based upon and limited to the
project described in Exhibit B to the Development Agreement.
A-2 Acceptance of Conditions
Execution of this agreement shall be deemed as acceptance of all conditions herein and
waiver of any objections thereto.
A-3 Costs of Implementing and Enforcing Conditions The Operator shall be fully responsible for all reasonable costs and expenses incurred by the City or any City contractors, consultants, or employees, in implementing, monitoring, or
enforcing this approval, including but not limited to, costs for permitting, permit conditions
implementation, mitigation monitoring, compliance monitoring, reviewing and verifying
information contained in reports, undertaking studies, research and inspections,
administrative support, and including the fully burdened cost of time spent by City
employees on such matters.
Draw-Down Account. The Operator shall maintain a draw-down account with the City, from which actual costs will be billed and deducted for the purpose of defraying the expenses
involved in the City’s review and verification of the information contained in any required
reports or plans and any other activities of the City, including but not limited to:
enforcement, permitting, inspection, coordination of compliance monitoring, administrative
support, technical studies, and the hiring of independent consultants. The initial amount to be deposited by the Operator shall be $500,000. In the first year, if withdrawals from the
account have reduced its balance to less than 50 percent of the amount of the initial deposit
($250,000), the Operator shall deposit $50,000 in supplemental funds within 30 business days of notification. After the first year, if the balance in the draw-down account is reduced
at any time to $50,000 or less, the Operator shall deposit $50,000 in supplemental funds on
each occasion that the account is reduced to $50,000 or less within 30 business days of
notification. There is no limit to the number of supplemental deposits that may be required.
At the discretion of the Operator, the amount of an initial or supplemental deposit may exceed the minimum amounts specified in this subsection. The City Manager or Designee
may, from time to time, increase the minimum $50,000 figure to account for inflation or the
Exhibit D-2
City’s experience in obtaining funds from the account. Operator shall be entitled to
reasonably review during normal business hours the expenditures from the deposit to ensure
the expenditures are related to the Project. Should Operator object to an expenditure, Operator shall submit a request in writing to the City Manager for a detailed written
explanation of the expenditure. Following receipt of the written explanation from the City
and should Operator continue to object to payment of the expenditure, it shall file such objection in writing with the City Council explaining why such expenditure is not
appropriate from the draw down account or why the amount of the expenditure is not
appropriate for the work. Following City Council consideration of the matter and decision,
the Council’s determination on the expenditure shall be final and binding on the parties.
A-4 Substantial Conformity
The Project shall be designed, constructed, and operated in substantial conformity with the Project Description in Exhibit B and all conditions of approval set forth in this Exhibit D.
A-5 Conflicts Between Conditions
In the event that any condition or mitigation measure contained in this development agreement is determined to be in conflict with any other condition contained herein, then
where principles of law do not provide to the contrary, the condition most protective of
natural environmental resources and public health and safety shall prevail to the extent feasible.
A-6 Facility Throughput and Source Limits
All facilities constructed under this approval shall be limited to the following maximum
production volumes: Phase 2 shall be limited to 800 barrels of oil and up to 250,000
standard cubic feet per day of gas. Phase 4 shall be limited to 8,000 barrels of oil per day
and 2.5 million standard cubic feet of gas per day.
A-7 Alternative Mitigation if Condition Invalidated
If any condition of this project is invalidated by a court of law in a final adjudication, this
approval shall be suspended pending imposition of a substitute condition or mitigation measure that will achieve equivalent results or reduction of impacts. A substitute condition or
mitigation measure shall be incorporated into the Development Agreement in accordance
with Section 4.2 of the Agreement- Changes and Amendments to Project before the suspension shall be lifted and the project is allowed to proceed.
A-8 Applicability of Conditions to Construction and Operations
These conditions are intended to apply to the E&B Project during both the construction and the operation of the permitted facilities. The term "operations" shall be understood to
Exhibit D-2
encompass both construction and operation phases unless such an interpretation would be
inappropriate.
A-9 Compliance Plans to have Same Force and Effect as Conditions
All elements of the plans and programs required under this Exhibit D shall have the force and effect of a project condition. The remedies available to the City upon Operators failure to
comply with such plans and programs includes but is not limited to those remedies which are
available to the City upon Operator’s failure to comply with a project condition.
A-10 Performance Security
The Operator shall be subject to the following provisions:
a. Performance Bond.
Prior to issuance of the first drilling permit, the Operator shall provide to the City Manager
or Designee, a faithful performance bond or financial instrument in the sum to be determined
by the City Manager, payable to the City and executed by a corporate surety acceptable to
the City and licensed to transact business as a surety in the State of California to cover the exploratory phase of the Project. The exploratory phase performance bond shall be
conditioned upon the faithful performance by Operator of duties related to well
abandonment, site restoration and environmental cleanup, financing spill response connected with exploration. Should the Project proceed to the oil production phases of the Project, the
Operator shall provide to the City Manager or Designee, a faithful performance bond or
financial instrument in the sum to be determined by the City Manager, payable to the City
and executed by a corporate surety acceptable to the City and licensed to transact business as
a surety in the State of California Such bond shall be conditioned upon the faithful
performance by Operator of duties related to well abandonment, site restoration and
environmental cleanup, financing spill response and shall be in a format and include terms
approved by the City Manager connected with the production phases of the project. These bonds shall be in addition to any other bond required by law (including without limitation
Public Resources Code Sections 3202, 3204, 3205, 3205.2 and 3206 and 14 C.C.R. § 1722.8.
These bonds shall satisfy the bond requirement in Section 23 of the Lease, and in the City
Manager’s discretion, may satisfy the bond requirement in Condition E-1 below.
b. Change of Operator. The performance bond(s) required above shall continue in force for
one (1) year following any sale, transfer, assignment, or other change of Operator of the
Project Site, or of the current Operator’s termination of activities at the Project Site. The City may release said bond prior to the end of the one (1) year period upon satisfaction by said
Operator of all its obligations. Notwithstanding the foregoing, the performance bond shall
not be terminated or released upon the sale, transfer, assignment, or other change of Operator
until the new Operator has delivered a replacement bond complying with the provisions of
this section.
Exhibit D-2
c. Funding Options. At its sole option, the City may accept Certificates of Deposit, Cash
Deposits, or U.S. Government Securities in lieu of commercial bonds to meet the above
bonding requirements on terms approved by the City Manager.
B. PROJECT REVIEW
B-1 Construction Review by Community Development Director
Prior to commencement of construction for Phase 1, 2, 3 and 4, and for subsequent
modifications, Operator shall submit to Community Development Department relevant
construction plans, engineering drawings and supporting text demonstrating compliance with the relevant conditions of this approval. Construction may not commence until City has
reviewed and approved the appropriate submittal, consistent with the system safety review.
Within 15 days of submittal, City shall deem the submittal complete, or incomplete and provide a list of deficiencies. Within 15 days of deeming the submittal complete, City shall
give written notice of approval of construction plans, or indicate in writing conditions which
have not been met, or notify the permittee that the system safety review shall be completed
within a period of time specified by the City, based on sound engineering practices. When
such conditions have been met, construction may be commenced. The City may require post-construction inspections or review of as-built drawings, as necessary to confirm
consistency with the approved submittal.
B-2 Condition Scheduling Conflicts
In the event that scheduling requirements among or between conditions in this approval (or
with this approval and conditions imposed by other agencies) conflict with respect to timing,
Community Development Department (in consultation with other departments, agencies, and
Operator as appropriate) shall resolve such conflict.
B-3 Authority to Begin Construction
Operator shall not commence construction without written confirmation from Community
Development Director, or designee, that all conditions which require approval prior to
construction of Phase 1, Phase 2, Phase 3 and Phase 4, as specified by this approval, have
been satisfied.
B-4 Authority to Begin Operations After construction and prior to start-up, Operator shall not commence operations without
written confirmation from Community Development Director, or designee, that all conditions
which require approval prior to start-up, as specified by this approval, have been satisfied.
Start-up, for purposes of this condition, is defined as the introduction of hydrocarbons into
the facility production equipment for both Phase 2/4.
C. MANAGEMENT AND MONITORING
Exhibit D-2
C-1 Environmental Quality Assurance Program (EQAP) Under EM-1 below in Exhibit D-3, Operator is required to provide funding for
implementation and administration of an environmental monitoring program, including an
environmental monitor (“Monitor”), to ensure compliance with the environmental conditions of approval. The Monitor shall assist in condition compliance and mitigation monitoring for
all applicable construction and operational stages of the project. The monitor shall be under
contract with the City and funded by the Operator.
1. In accordance with EM-1, the Monitor will create a monitoring program for the
project that includes a post-construction component to monitor measures that extend
beyond the construction period and the operational phase of the project.
2. The Monitor will prepare a working monitoring plan that reflects the approved
environmental mitigation measures and conditions of approval. The monitor’s plan
will include:
a. Goals, responsibilities, authorities, and procedures for verifying compliance
with environmental mitigations;
b. Lines of communication and reporting methods;
c. Daily and weekly reporting of compliance;
d. Construction crew training regarding environmental sensitivities;
e. Authority to stop work; and
f. Action to be taken in the event of non‐compliance.
3. Under EM-1 and other conditions, Operator is also responsible for funding work
required by permit conditions requiring use of individuals with special expertise (e.g.,
geologist, noise engineer, etc.). The Monitor will coordinate the monitoring efforts of
the specialists, including communication with the City and responsible Agencies,
reporting and availability (at appropriate times: prior to issuance of construction
permits, or during construction, as required by applicable permit conditions).
To assist the Monitor in creating and implementing its working monitoring plan, Operator
shall prepare and obtain Community Development Department approval of an Environmental
Quality Assurance Program (EQAP) prior to commencement of Phase 1 construction activities, and obtain Community Development Department approval of a revised EQAP
prior to commencement of Phase 2, Phase 3, construction activities and Phase 4, Operations.
The approved EQAP and all approved revisions to the EQAP shall be submitted to the
Monitor prior to commencement of each Project phase. This EQAP shall encompass both
construction and operations phases of the E&B Project, and shall describe the steps Operator will take to assure compliance with the conditions contained in the approval for this project.
The EQAP is intended to provide a monitoring and reporting framework for compliance with
all conditions, programs and plans specified by these conditions and the mitigation measures.
Exhibit D-2
As such, it will become a comprehensive reference document for the City, the Monitor, other
agencies, and the public regarding the E&B Project.
The EQAP shall include, without limitation:
a. All plans, as required by these conditions and mitigation measures, relevant to construction and operation of the permitted facilities (including the Risk Management
Program, SIMQAP, Emergency Response Plan, Hazardous Material and Waste Management
Plan, Site Security Plan, and Fire Protection Plan). To the extent there is any overlap or
redundancy between plans required under Exhibits D-2 and D-3, upon E&B request the
Monitor may in its discretion authorize E&B to combine required plans into one submittal;
b. Provisions for regularly communicating with and reporting to the Monitor;
c. Provisions for ensuring knowledge of and compliance with these conditions;
d. Provisions for the submittal to Community Development Department and the Monitor
of monthly compliance reports throughout construction and annual summary reports
during operations unless more frequent reporting is deemed necessary by Community Development or the Monitor. Upon receipt of compliance reports, Community
Development Department or the Monitor shall advise Operator of what additional
compliance items require reporting prior to the next report. These compliance reports shall describe:
1. Project status, including but not necessarily limited to:
i. the extent to which construction has been completed on various
project phases
ii. the background and experience of the construction labor force
iii. the rate of production/throughput during operation, iv. environmental planning and implementation efforts, and
v. any revised time schedules or timetables of construction and/or
operation that will occur in the next one-year period.
2. Condition compliance, including but not necessarily limited to the results of the specific mitigation requirements identified in these conditions and any compliance plans.
3. Results and analyses of all data collection efforts being conducted by Operator pursuant to these permit conditions.
d. Copies of all local, state, and federal permits relative to the E&B Project, and any
amendments thereto.
The EQAP shall be updated regularly to include all up-to-date compliance plans required
under these conditions of approval.
Exhibit D-2
C-2 24-Hour Emergency Contact Prior to issuance of the Permit for Phase 1, Operator shall provide to the Community
Development Department and the City Fire Department the current name and position, title,
address, and 24-hour telephone numbers of the person in charge of the facility, person in charge of construction, and other representatives who shall receive all orders and notices, as
well as all communications regarding matters of condition and permit compliance at the site
and who shall have authority to implement a facility shutdown pursuant to this agreement or
other City ordinances.
There shall always be such a contact person(s) designated by the Operator. One contact
person shall be available 24 hours a day in order to respond to inquiries received from the
City, or from anyone in case of an emergency.
If the address or telephone number of Operator’s agent should change, or the responsibility
be assigned to another person or position, Operator shall provide to Community
Development Department the new information within 24 hours of the effective date of such
change.
C-3 Operator to Provide Copies of Permits to Community Development Department Operator shall furnish to Community Development Department and Monitor copies of all
local, state, and federal permits relative to the E&B Project within 30 days of receipt by
Operator.
C-4 Pipeline Construction Confined to Right-of-Way
All pipeline construction activities, including work areas and staging and storage areas of
pipe, shall be confined to the area defined in the encroachment permit.
C-5 Capacity and Throughput Reports
Operator shall report to Community Development Department and Monitor the volumes and
rates of: (1) inlet volumes; (2) transferred for sales into the Southern California Gas Company transmission line; and (3) Oil volumes transported to Pipeline. Reports shall be
made on at least a monthly and annual basis and supporting documentation will be provided
upon request from Community Development Department or Monitor. Upon approval from the Community Development Director and the Monitor, these reports may be combined with
and submitted at the same time as Royalty Statements under Section 4 of the Lease.
C-6 Risk Mitigation Program
A Risk Management Program to substantially reduce the risks of project-related accidents
which may result in loss of life and/or injury, and damage to property and/or the natural
Exhibit D-2
environment shall be submitted for approval to the Hermosa Beach City Community
Development, Fire and Public Works Departments. Other City departments, as deemed
necessary, may be consulted. All reasonable costs associated with this City review shall be borne by Operator. Operator shall be entitled to participate fully in the review process.
Operator shall submit with the Program all appropriate construction plans, Process Hazards Analyses (PHA), and Hazard and Operability Studies (HAZOPs) for the proposed facility
and ancillary equipment to the City who may employ a third-party technical review in order
to evaluate project design and help identify possible design hazards prior to issuance of
ministerial permits. The HAZOPs shall be reviewed and approved by the City prior to
construction for each Phase of the project. This review shall also evaluate all mitigation identified in the EIR. The City may require as-built inspections and the submittal of as-built
drawings for approval prior to the operation of any plant modifications.
C-7 Safety Inspection, Maintenance And Quality Assurance Program
Operator shall submit a detailed Safety Inspection, Maintenance and Quality Assurance
Program (SIMQAP) for all facilities and pipelines which shall be implemented during
construction and operations. Separate SIMQAP plans may be submitted for Phase 1 and Phase 2/3/4 activities. The SIMQAP shall be reviewed and approved by the City, including
the Hermosa Beach City Community Development Department, Hermosa Beach Fire
Department and the Monitor. Other City departments, as deemed necessary, may be consulted. The SIMQAP for construction shall be approved prior to construction, and the
SIMQAP for operation shall be approved prior to operation for each Phase of the project.
The plan is a dynamic document and, as such, updates including new procedures, safety and
maintenance technologies and processes, shall be reviewed jointly by Operator and the City.
The SIMQAP shall be revised as appropriate. The SIMQAP shall include, but not be limited
to, evaluation of staffing levels for safe operation of the plant in emergency situations,
establishing procedures for review of safety inspection records, regular maintenance and
safety inspections, periodic safety audits, development of safety system testing protocols, training and experience standards for personnel and use of simulation techniques in training
programs, inspections of all trucks carrying hazardous and/or flammable material prior to
loading, monitoring of critical safety devices and systems, and review of the routing of all
trucks carrying hazardous material. Operator shall implement the approved plan and shall
provide for involvement of the Monitor, City staff, or its consultants in all inspections as appropriate. Prior to construction and operations, Operator shall demonstrate that employees
(and subcontractors) are trained in the safety, inspection, maintenance and operations
requirements of the project. All costs associated with this review process shall be borne by Operator.
C-8 Emergency Response Plan
Operator shall submit to the applicable City Departments and the City Fire Department an Emergency Response Plan (ERP) that addresses response procedures to be implemented by
Exhibit D-2
Operator for accidental events that pose significant threats to public health and safety,
property, or the environment.
The ERP shall be reviewed and approved by the City Fire, Community Development and
Public Works Departments prior to commencement of drilling operations. Separate ERPs
may be required for Phase 1 and Phase 2/3/4 activities. The ERP shall include specific measures to avoid impacts on cultural resources, sensitive habitats, and sensitive biological
resources identified in the project EIR whenever possible without affecting emergency
response. Operator shall demonstrate the effectiveness of its ERP by responding effectively
as determined by Fire to one emergency response drill prior to Phase 1 and prior to approval
of the Plan by Fire. The ERP shall be submitted sufficiently prior to Operator’s projected start-up date so as to allow reasonable time for review and the planning of a drill required
prior to ERP approval.
The ERP shall be a dynamic document and, as such, shall be jointly reviewed by the City and
Operator, and revised when warranted to incorporate new planning strategies or procedural
changes, new technologies, and the acquisition of more effective, feasible response
equipment as it becomes available. Any changes shall be submitted to the City Fire,
Community Development and Public Works Departments for their review and approval, prior to implementation. Operator shall demonstrate the ongoing effectiveness of the ERP by
responding to no more than two surprise drills each year which may be called by the City. If
critical operations are underway, Operator need not respond to the drill at that time but shall explain the nature of the critical operations and why response is not possible. The City may
then call for an additional surprise drill in the same year. Operator shall implement all
reasonable changes based on review of drill performance, which will further enhance overall
emergency response planning and capabilities. Upon E&B’s request and written approval
from the Monitor, this plan may be combined with the emergency response plan required
under FP-1d and FP-1e below.
C-9 Hazardous Material and Waste Management Plan
Prior to start-up, Operator shall submit a Hazardous Material and Waste Management Plan
(HMWMP) to the City Fire Department and Community Development Department for all
facilities. The HMWMP shall be reviewed and approved by Fire and Community
Development prior to start-up.
The Plan shall demonstrate compliance with the provisions of the Uniform Fire Code as
adopted in Chapter 15 of the Hermosa Beach Municipal Code and the provisions of the Health and Safety Code §25500 et seq, Chapter 6.95 Business Plan Requirements, with the
exception of emergency response procedures which are complied with above.
The Hazardous Material and Waste Management Plan shall include but not be limited to the
following:
Exhibit D-2
a. Locations and methods for storing hazardous materials and wastes, both within the
facility and along the OIL pipeline right-of-way.
b. Treatment procedures, or justification where none are used, to reduce the hazardous
nature of the materials before they are permitted to leave the site.
c. Specific routes for transportation of hazardous waste materials to Class I disposal
sites consistent with City policy.
d. Letter of commitment that the materials are transferred by a carrier licensed in
hazardous material transport.
e. Letter of commitment ensuring complete accounting of intake, processing, and exit of
hazardous material and wastes.
f. Detailed description of a monitoring system to be installed, capable of detecting
hazardous material and wastes that may escape from primary storage devices.
g. A revised Hazardous Materials Business Plan which accurately reflects the revised chemical inventory of the project site to Environmental Health Services for review and
approval, in accordance with the California Health & Safety Code, Chapter 6.95, Section
25,500 et seq.
The HMWMP shall be a dynamic document and, as such, shall be jointly reviewed by the
City and Operator, and revised when parties mutually agree it is warranted to incorporate
new planning strategies, changes in procedures, new technologies, or changes in materials, or
when required by law. Any changes requested by Operator or City shall be submitted to Fire
and Community Development for their review and approval, prior to implementation.
C-10 Site Security Plan
Prior to issuance of a Permit for Phase 1, Operator shall submit to the Community
Development and the Hermosa Beach City Police Department for review and approval a site
security plan. The plan shall describe the procedures to be implemented by Operator which
will prevent intentional damage to the drilling and production facilities which may result in environmental damage or public safety hazards. The plan shall include placement of security
cameras to the satisfaction of the Community Development and Police Departments, and
employment of security personnel at all times during drilling stages (24 hours) (see condition 3.2 in D-1) and employment of security personnel from dusk until dawn at all other times.
The plan shall be reviewed and revised as warranted to require incorporation of new planning
strategies, new technologies or changes in plant operation, and changes in notification
procedures.
C-11 Fire Protection Plan
Exhibit D-2
All E&B Project facilities shall have fire protection features installed in accordance with the
provisions of an E&B Project Fire Protection Plan (FPP), and as such features may be
required under this Exhibit D. All facilities, construction activities, process equipment, and fire protection equipment shall comply with the standards of the National Fire Protection
Association (NFPA), American Petroleum Institute, Uniform Fire Code as adopted in
Chapter 15, Building and Construction of the Hermosa Beach Municipal Code, and the Hermosa Beach City Fire Department. In the event of a conflict between these standards, the
Fire Marshal, in consultation with the Operator, shall make a cost/benefit decision regarding
which standards apply.
Prior to construction, Operator shall receive Fire Department approval of an FPP which addresses both construction and operation of the E&B Project. Operator shall distribute
copies of the approved contingency plans to applicable City Departments and the City Fire
Department. All plan recipients are to be notified of contingency plan changes via formal contingency plan updates. Separate FPPs may be submitted for Phase 1 and Phase 2/3/4
activities. The FPP shall include, but may not be limited to, discussions of the following:
Onsite firefighting equipment and systems
Fire and detection
Access
Vegetation management
Employee training and safe practices
Process control and monitoring analysis
Drainage and containment
Safety, inspection (including City inspectors) and maintenance practices
Upon E&B’s request and written approval from the Monitor, this plan may be combined with
the emergency response plan required under FP-1d and FP-1e below.
C-12 Prevention of Internal Pipeline Corrosion
Operator shall implement techniques to prevent internal corrosion in accordance with the
requirements of the California State Fire Marshal (Title 5 §51010-5-019 of the California Government Code), 49 CFR 192 Parts 150, 475 and 477, and 49 CFR 195.418 as part of the
Oil and pipeline maintenance procedures. The internal inspection records shall be submitted
to and reviewed by the appropriate governmental agencies. Such activities shall include
routinely scheduled pigging of the pipeline to remove pockets of accumulated fluids that
contribute to internal corrosion (such as hydrogen sulfide, carbon dioxide, and water), the use
of corrosion inhibitors and corrosion coupons, and periodic testing by a state-of-the-art
"smart pig" to identify areas where corrosion, pipewall thinning, dents, cracks and other
defects have occurred. Specific measures are discussed below:
Exhibit D-2
a) Whenever any section of the pipelines are removed for any reason, they shall be
inspected for possible internal corrosion and records retained for inspection by the State Fire
Marshal.
b) The pipeline shall be tested with a state-of-the-art "smart pig" to identify areas where
corrosion, pipewall thinning, dents cracks and other defects have occurred. State-of-the-art pigging will be capable of defining wall-thickness contours around any area of
reduced wall thickness. The smart pigging will be done prior to operation of the Oil
and natural gas pipelines and at a subsequent interval to be determined by the
California State Fire Marshal. A program of maintenance shall be developed to
ensure that permits to perform the work are obtained as soon as possible and that pipeline defects are rectified within one month of securing the necessary permits for
severe defects, and within six months for moderate defects. This procedure shall be
noted in the SIMQAP and receive approval by the SSRRC prior to operations of either the OIL or natural gas pipelines.
C-13 Prevention of External Pipeline Corrosion
Operator shall undertake the following provisions to avoid external pipeline corrosion:
a) The Oil and natural gas pipelines shall be coated to reduce the potential for external
corrosion. Final selection of pipeline coating will be demonstrated, to the satisfaction of the California State Fire Marshal, that the selected coating would provide the maximum level of
protection of available coatings for all expected operating conditions; and
b) A baseline pipe-to-soil cathodic profile and reading shall be obtained after the pipeline has
been installed, but before any cathodic protection facilities are connected. Other utilities
shall disconnect their bonds as well. This measure shall be included on the construction
plans which shall be reviewed by the City.
C-14 Pipeline Hydrotesting
The oil and natural gas pipelines shall be hydrotested prior to operation, and every five years
thereafter or sooner if warranted by major ground movement that has the potential to
undermine the structural integrity of the pipeline. This procedure shall be noted in the SIMQAP which shall be reviewed and approved prior to operations.
C-15 Structural Support for Underground Utilities
Operator shall provide structural support for underground utilities in and near the
construction area during work in the trench and backfilling operations to prevent damage to
such facilities during construction activities.
C-16 Underground Utility Damage
Exhibit D-2
Operator shall halt work in the immediate vicinity in the event of inadvertent damage to an
underground utility, until the owner of the utility has been contacted and repairs have been
effected.
C-17 Underground Pipeline Warning Marker A plastic ribbon or other suitable material shall be buried 12 to 18 inches above the oil and
natural gas pipelines and shall cover the length of the pipeline. The material shall be brightly
colored and be labeled with a warning that this area contains a hazardous liquid pipeline
trench. This measure shall be noted on the design and construction plans to be reviewed and
approved by the City.
C-18 Pipeline Route Warning Signs The entire pipeline route shall be marked with pipeline warning signs a minimum of every
500 feet. Spacing of markers may be greater in agricultural areas provided markers are
clearly within sight of each other. Bright colored markers shall be installed above new
pipelines that extend offsite of the proposed facility. This type of measure helps reduce the
likelihood of external mechanical interference, of which third party damage associated with excavation near the pipelines is the most common cause of pipeline failures.
C-19 Underground Service Alert Notification
Operator shall notify owners through the office of Underground Service Alert of any
underground facilities (including electrical, water, petroleum pipelines, fiber-optics and
agricultural water delivery and drainage pipelines) 48 hours in advance of excavation in the
vicinity of these facilities. Operator shall have an electrical contractor on-call at all times
during construction near the potentially affected facility to repair any circuits if required by
the owner in the event they are damaged during construction. The appropriate response to
hazards associated with damage to natural gas pipelines will be determined in consultation with Southern California Gas Company. The City Fire Department shall be notified of the
schedule for construction activities in the vicinity of natural gas and other oil pipelines.
C-20 Finished Pipeline Route Maps Upon completion of pipeline construction, Operator shall provide all jurisdictional agencies
with at least two copies of maps showing the finished pipeline route and shall include
locations accessible by fire department emergency response vehicles. Said maps shall be 7 1/2 minute quadrate scale, (one inch equals 24,000 inches), and shall represent topographical
features.
C-21 Supervisory Control and Data Acquisition and Emergency Shutdown Systems
The pipeline supervisory control and data acquisition (SCADA) and Emergency Shutdown
(ESD) systems, including inspection, maintenance and quality assurance procedures for the
Exhibit D-2
SCADA and ESD systems, shall be reviewed and approved by the Fire Department and the
Building Department and Public Works Department prior to operations of either the oil or
natural gas pipelines, and as appropriate thereafter. The SCADA and ESD systems shall comply with the provisions of Fire Department Development Standard No. 7 and the
National Electrical Code Article 760.
Operator shall conduct a comprehensive safety and reliability analysis of the SCADA system
as well as the processing facility and oil and natural gas pipelines control room prior to
commencement of pipeline operations, and as appropriate thereafter. The analysis shall meet
or exceed the guidelines developed by the Institute of Electronic and Electrical Engineers.
Any improvements identified in the study shall be included in the suggested hardware and software. Results of the study shall be provided to the Community Development
Department.
Company shall design the project such that the entire project will integrate the supervisory
control and data acquisition (SCADA) or other monitoring system for all the components of
this project in a manner so as to provide timely and efficient detection, shutdown,
notification and response to an emergency involving any of the project components. Any
break, rupture, and/or damage to the facilities shall result in the orderly shutdown of the pumping operations, and will activate the shut off valves in a manner which will minimize
environmental damage.
C-22 Update of Operational Risk Assessment
Upon City request, Operator shall fund the updating of the operational risk assessment
subject to ministerial permitting, as needed, so that any surrounding land use proposals are
aware of existing risk, if any.
D. FACILITY DESIGN
D-1 Submittal of As Built Drawings
Within one year after initial start-up of the E&B Project (Phase 1), and again within one year
of commencement of Phase 2 operations, Operator shall submit as-built drawings of the
entire facility(s) to City. Any facility modifications required for Phase 3 operations shall also be documented on facility as-built drawings within one year of their construction.
Operator shall submit as many sets of drawings (up to ten sets) as requested by the
Community Development Department.
D-2 Solid Waste Disposal
Solid waste generated on the site shall be collected by the City’s franchised commercial trash
hauler. Construction waste shall be transported by E&B’s own efforts to a facility authorized to accept construction waste in accordance with the provisions of the Hermosa Beach
Exhibit D-2
Municipal Code. Hazardous waste shall be transported by E&B’s own efforts to a facility
authorized to accept hazardous waste in accordance with all local, state and federal laws.
D-3 Water Conservation Measures
The design of all new and/or modified onsite facilities shall incorporate the use of cost-effective water-conserving fixtures, including by way of example indoor and outdoor
plumbing fixtures and irrigation.
D-4 Energy Conservation Measures Throughout the project life, as equipment is added or replaced, cost-effective energy
conservation techniques shall be incorporated into project design, including by way of
example indoor and outdoor lighting, HVAC, drill equipment, vehicles, and microturbines.
E. ABANDONMENT
E-1 Abandonment Procedures
In implementing Section 26 of the Lease and Article VII of the Hermosa Beach Municipal Code - Oil Code Chapter 21A, Operator shall secure all necessary permits and proceed in
accordance with a City Council approved abandonment and restoration plan within one year
of permanent shut down. The abandonment plan shall be processed with environmental
review of the plan. Operator shall post a performance bond, or other security device
acceptable to City Council, prior to commencement of Phase 1 construction for estimated
costs of abandoning Phase 1 facilities. Operator shall also post a performance bond, or other
security device acceptable to City Council, prior to commencement of Phase 2 for estimated
costs of abandoning Phase 2 facilities. Notwithstanding, as part of approval of the abandonment plan, the City may in its discretion require that all or portions of pipeline be
abandoned in place or completely removed.
E-2. Abandonment Costs All costs associated with abandonment or removal shall be borne by Operator.
E-3. Wellsites
Prior to permanent shutdown or termination of this agreement or the lease, any well drilled
by Operator shall be plugged and abandoned within three months from the date it is
determined that such well is no longer capable of production, subject to weather and rig
availability, and capped, in accordance with the rules and regulations of the State Division of Oil, Gas & Geothermal Resources. Thereafter, the wellsite shall be restored as near as
practicable to its original condition.
Exhibit D-2
F. Miscellaneous Conditions F-1. Hydraulic Fracturing Prohibited
The use of hydraulic fracturing as a well stimulation technique for enhanced hydrocarbon production shall be prohibited on the project site.
F-2. Pipelines
All pipelines installed for the Project shall not go below the depth authorized by the State Division of Oil, Gas & Geothermal Resources. After completion of the construction of any
such pipelines, Operator shall restore the surface of the area impacted by the construction of
such pipeline as nearly as practicable to its condition immediately prior to such construction.
F-4. Fire Marshal Position
Operator shall fund a full-time dedicated Fire Marshal position for the Hermosa Beach Fire
Department for the full Term of the Development Agreement.
F-5. Training Operator shall pay for annual training for Hermosa Beach Fire Department personnel and fire
personnel from the City’s automatic aide partners on fighting oil fires.
F-6. Odor (from HIA)
In the event of frequent reports of odor emanating from the site, Operator shall pay for
additional studies and/or periodic air monitoring. If the studies or monitoring indicate that
additional control measures should be implemented to reduce the frequency of noticeable odors, Operator shall include those measures as project conditions.
F-7. Notice (from HIA)
During Phase 3 pipeline construction, Operator shall provide written notification of impending construction activities, including the dates and times of activities that may
produce excessive noise, to all residents within 100 feet of the construction activities. Notice
shall be provided no less than 72 hours before construction begins.
F-8. Light impact reduction (from HIA)
Operator shall pay for or provide black-out blinds or curtains for bedrooms with direct line-
of-sight to the exposed side of the electric drill rig that will be lit at night. The amount of payment or the brand of blinds/curtains shall be pre-approved by the City Manager, and may
be provided through a direct mail program.
Exhibit D-2
F-9. Community Relations (from HIA) As recommended in Intrinsik’s Health Impact Assessment for the project, and at the City
Council’s discretion, the Operator may be required to pay for the costs associated with (1)
organizing a Community Liaison Committee; (2) a follow-up Community Health Assessment; and/or (3) a quality of life health survey.
[Continue to following page for Mitigation Measures]
Exhibit D-3
EXHIBIT “D-3”
Mitigation Measures/Mitigation Monitoring Plan from Section 8.0 of FEIR
(as revised at Hermosa Beach City Council certification hearing on July 8, 2014 per
Resolution 14-6908).
8.0 Summary of Mitigation Measures and Mitigation Monitoring Plan
8.1 Mitigation Monitoring Program
As the Lead Agency under the California Environmental Quality Act (CEQA), the City of
Hermosa Beach (City) is required to adopt a program for reporting or monitoring regarding the implementation of mitigation measures for this Project, if it is approved, to ensure that the
adopted mitigation measures are implemented as defined in this Environmental Impact Report
(EIR). This Lead Agency responsibility originates in Public Resources Code Section 21081.6(a)
(Findings) and the CEQA Guidelines Sections 15091(d) (Findings) and 15097 (Mitigation
Monitoring or Reporting).
8.2 Monitoring Authority and Enforcement Responsibility
The purpose of a Mitigation Monitoring, Compliance, and Reporting Program (MMCRP) is to
ensure that measures adopted to mitigate or avoid significant impacts are implemented. A
MMCRP can be a working guide to facilitate not only the implementation of mitigation measures
by the Project proponent, but also the monitoring, compliance, and reporting activities of the City and any monitors it may designate.
The City may delegate duties and responsibilities for monitoring to other environmental monitors
or consultants as deemed necessary, and some monitoring responsibilities may be assumed by
responsible agencies, such as affected jurisdictions and cities. The number of monitors assigned
to the Project will depend on the number of concurrent activities and their locations. The City or its designee(s), however, will ensure that each person delegated any duties or responsibilities is
qualified to monitor compliance.
Any mitigation measure study or plan that requires the approval of the City must allow at least
60 days for adequate review time. When a mitigation measure requires that a mitigation program
be developed during the design phase of the Project, the Applicant must submit the final program to City for review and approval for at least 60 days before any activity begins. Other agencies
and jurisdictions may require additional review time. It is the responsibility of the environmental
monitor assigned to the Project to ensure that appropriate agency reviews and approvals are
obtained.
The City or its designee will also ensure that any deviation from the procedures identified under the monitoring program is approved by the City. Any deviation and its correction shall be
Exhibit D-3
reported immediately to the City or its designee by the environmental monitor assigned to the
Project.
The City is responsible for enforcing the procedures adopted for monitoring through the environ-
mental monitor assigned to the Project. Any assigned environmental monitor shall note problems with monitoring, notify appropriate agencies or individuals about any problems, and
report the problems to the City or its designee.
8.3 Mitigation Compliance Responsibility
The Applicant is responsible for successfully implementing all the mitigation measures in the
MMCRP, and is responsible for assuring that these requirements are met by all of its contractors and field personnel. Standards for successful mitigation also are implicit in many mitigation
measures that include such requirements as obtaining permits or avoiding a specific impact
entirely. Other mitigation measures include detailed success criteria. Additional mitigation
success thresholds will be established by applicable agencies with jurisdiction through the permit
process and through the review and approval of specific plans for the implementation of mitigation measures.
8.4 General Monitoring Procedures
Environmental Monitors. The City and the environmental monitor(s) are responsible for
integrating the mitigation monitoring procedures into the construction or operation process in
coordination with the Applicant. To oversee the monitoring procedures and to ensure success, the environmental monitor assigned to the Project must be on site during that portion of the
construction or operation that has the potential to create a significant environmental impact or
other impact for which mitigation is required. The environmental monitor is responsible for
ensuring that all procedures specified in the monitoring program are followed.
Construction and Operations Personnel. A key feature contributing to the success of mitigation monitoring will be obtaining the full cooperation of construction and operations personnel and
supervisors. Many of the mitigation measures require action on the part of the supervisors or
crews for successful implementation. To ensure success, the following actions, detailed in
specific mitigation measures, will be taken:
• Procedures to be followed by construction or operations companies hired to do the work will be written into contracts between the Applicant and any contractors. Procedures to
be followed by construction and operations crews will be written into a separate
document that all personnel will be asked to sign, denoting agreement.
• One or more meetings will be held to inform all and train personnel about the requirements of the monitoring program.
• A written summary of mitigation monitoring procedures will be provided to supervisors
for all mitigation measures requiring their attention.
General Reporting Procedures. Site visits and specified monitoring procedures performed by other individuals will be reported to the environmental monitor. A monitoring record form will
Exhibit D-3
be submitted to the environmental monitor by the individual conducting the visit or procedure so
that details of the visit can be recorded and progress tracked by the environmental monitor. A
checklist will be developed and maintained by the environmental monitor to track all procedures
required for each mitigation measure and to ensure that the timing specified for the procedures is adhered to. The environmental monitor will note any problems that may occur and take
appropriate action to rectify the problems.
Public Access to Records. The public is allowed access to records and reports used to track the
monitoring program. Monitoring records and reports will be made available for public
inspection by the City or its designee on request.
8.5 Mitigation Monitoring Table
The Tables below present a summary of monitoring and reporting plan requirements for the
mitigation measures identified in Chapter 4 of the EIR as applicable to the Proposed Project.
The Table provides the following information, by column:
• Mitigation Measure (description of the mitigation measure identified in Chapter 4);
• Monitoring/Plan Requirements (monitoring or plan requirements necessary to verify
compliance with the mitigation measure);
• Method of Verification (this is how the responsible agency can determine if the mitigation measure has been implemented);
• Timing (this identifies when action needs to be taken on mitigation measure); and
• Responsible Agency (this is the agency that is responsible for assuring compliance with
the mitigation measure).
Exhibit D-3
Table 8-1 Aesthetics and Visual Resources
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
EM-1 Prior to issuance of the first grading and/or construction permits, the Applicant shall enter into agreements with the City to provide funding for the
implementation and administration of an environmental monitoring program, including an environmental monitor, to ensure compliance with each Agency’s
environmental Conditions of Approval. The monitor shall assist the Agencies in condition compliance and mitigation monitoring for all applicable construction
and operational stages of the Oil Project, as specified in a scope of work, as approved by the Agencies.
The monitoring program shall include a post‐construction program to monitor measures that extend beyond the construction period (e.g., success of landscaping, etc.), as well as monitor certain mitigation measures required
during the operational phase.
The monitor will prepare a working monitoring plan that reflects the Agencies ‐
approved environmental mitigation measures/conditions of approval. This plan will include:
1. Goals, responsibilities, authorities, and procedures for verifying compliance with environmental mitigations;
2. Lines of communication and reporting methods;
3. Daily and weekly reporting of compliance;
4. Construction crew training regarding environmental sensitivities;
5. Authority to stop work; and
6. Action to be taken in the event of non‐compliance.
The environmental monitor shall be under contract to the Agencies. Costs of
the monitor, monitoring program, and any Agency administrative fees, shall be paid by the Applicant.
The Applicant shall also be responsible for funding work required by permit conditions requiring use of individuals with special expertise (e.g., geologist,
noise engineer, etc.). The Agencies’ environmental monitor will coordinate the monitoring efforts of the specialist, including communication with the Agencies,
reporting and availability (at appropriate times: prior to issuance of construction
permits, or during construction, as required by applicable permit conditions).
Conditions included within
the Development
Agreement, including
administrative measures to
ensure bonding,
payment methods and
insurance
Before the start of Phase
1
City of Hermosa
Beach
AE-1a Material choice of electrical drill rig acoustical shroud shall be of neutral sky Approval of Prior to City of
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
color which is selected for its ability to reduce visual impact, in coordination with and approval by the City Community Development Director. Construction Documents and
Specifications and field-
demonstration
issuance of permits Hermosa Beach
AE-1b The sound attenuation wall shall be replaced by a permanent wall with design features installed at the end of Phase 3. The intent is to provide stability of
views and opportunities for positive visual elements that partially mitigate the visual presence of the walls from the Hermosa Greenbelt and other sensitive views in the immediate Project vicinity. The permanent wall shall be allowed to be provided in lieu of the 16-foot block wall. Landscape design shall be
allowed to be adjusted to respond to façade articulations, though quantities and densities shall be maintained. The permanent wall shall be designed with
architectural features in coordination with and approval of the City Community
Development Director.
Approval of Construction
Documents and Specifications and Inspection
Prior to issuance of
permits and during construction
City of Hermosa
Beach
AE-2a Design of the sound attenuation wall exterior façade shall be required to include design articulations that are complementary to the character, scale, and
quality of the surrounding environment. The intent is to mitigate the visual impact of the wall from the Hermosa Greenbelt and other sensitive views in the
immediate project vicinity. The following measures of success shall be met: 1) Articulations of façade decrease scale and proportion of mass into smaller
increments that more closely resemble those of adjacent buildings; and 2) Colors, detailing and material use are varied to a level consistent with existing
visual environment.
Approval of Construction
Documents and Specifications
and Inspection
Prior to issuance of
permits and during
construction
City of Hermosa
Beach
AE-2b Planting area growth medium shall be capable of supporting the long term health and growth of the landscape design. Requirements shall be: 1)
Demonstrated free of debris and construction waste (asphalt, concrete, etc) to a minimum depth of 3 feet within all planted areas. Wall footings shall be
designed to limit encroachment into planted areas; 2) Soils analysis report shall be conducted by a certified soil scientist. Report shall include
recommendations to meet the intent of this mitigation measure; and 3) If soils
are determined to be unsuitable to support plant growth, they shall be amended or removed/replaced to meet requirements of soils analysis for plant pallette
selected.
Approval of Construction
Documents and Specifications
and Inspection
Prior to issuance of
permits and during
construction
City of Hermosa
Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
AE-2c Vine plantings where used shall meet the following conditions: 1) be self-attaching or structure supported; 2) have demonstrated success in the City; 3)
be planted at a density to achieve full coverage at maturity; 4) be planted at a minimum 5 gallon size; and 5) be required on the visible portion of the west
wall at the temporary parking facility.
Approval of Construction
Documents and Specifications
and Inspection
Prior to issuance of
permits and during
construction
City of Hermosa
Beach
AE-2d All trees shall be required to be a minimum of 20’ in height at installation and
meet the American Standard for Nursery Stock (ANSI Z60.1-2004). If a tree species alternate is proposed, it shall be required to be an equal to the species proposed in the Project Application in the following characteristics: 1) Dense
evergreen with similar form and habit; 2) Probability of achieving a minimum of 35-40 feet at maturity; and 3) Comply with Municipal Code Chapter 8.60 and 8.56.
Approval of
Construction Documents and Specifications
and Inspection
Prior to
issuance of permits and during
construction
City of
Hermosa Beach
AE-3a Pipeline alignments and valve box locations shall be designed to avoid the
removal or modification of trees, hedgerows, and/or large shrubs to the extent feasible.
Approval of
Construction Documents and
Specifications and Inspection
Prior to
issuance of permits and
during construction
Cities of
Hermosa Beach,
Redondo Beach, and
Torrance
AE-3b If landscaped areas, streetscapes, plazas and/or parklands are required to be temporarily disturbed, they shall be restored to their previous condition
following completion of construction. Avoidance of disturbance shall be the preferred option, especially where landscape elements act to screen views (hedges, large shrubs, etc) or where they act as community gateways
(Redondo Beach at Hwy-1).
Approval of Construction
Documents and Specifications and Inspection
Prior to issuance of
permits and during construction
Cities of Hermosa
Beach, Redondo Beach and
Torrance
AE-3c Block color/s selection and pattern (if applicable) shall be complementary to adjacent buildings. A buffer of shrubs and vines shall be planted to match the
existing character and quality of the adjacent properties.
Approval of Construction
Documents and Specifications
and Inspection
Prior to issuance of
permits and during
construction
Cities of Hermosa
Beach, Redondo
Beach and Torrance
AE-4a Final acoustical cover material selection shall be required to be fully opaque. Fully opaque shall be defined as completely blocking all light from passing through its surface. The exterior finish shall be low reflectivity and not capable of producing glare.
Approval of Construction Documents and Specifications
Prior to issuance of permits and during
City of Hermosa
Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
and Inspection construction
AE-4b Colors and finishes of equipment and surfaces within the soundwall (including the interior face of the soundwall, the interior face of the drill rig acoustical
cover, and the physical structure of the drill rig within the acoustical shield) shall have a reflectivity rating of 0.3 or lower.
Approval of Construction
Documents and Specifications
and Inspection
Prior to issuance of
permits and during
construction
City of Hermosa
Beach
AE-4c All proposed site lighting fixtures associated with the drilling activities shall
demonstrate compliance with the mandatory B-U-G ratings for area lighting as required by CalGreen mandatory measures in the 7/1/2012 supplement. The
Lighting Zone used to demonstrate compliance shall be LZ-2.
Approval of
Construction Documents and
Specifications and Inspection
Prior to
issuance of permits and
during construction
City of
Hermosa Beach
AE-5a Colors and finishes of surfaces within the facility, including the interior face of
the soundwall, ground materials (darker or asphalt), wall paints and equipment paints to the extent feasible shall have a low reflectivity rating of 0.3 or lower to
reduce the potential for glow.
Approval of
Construction Documents and
Specifications and Inspection
Prior to
issuance of permits and
during construction
City of
Hermosa Beach
AE-5b Final sound wall material/s selection/s (including gates) shall be fully opaque. Fully opaque shall be defined as completely blocking all light from passing
through its surface. The exterior finish shall be low reflectivity and not capable of producing glare.
Approval of Construction
Documents and Specifications
and Inspection
Prior to issuance of
permits and during
construction
City of Hermosa
Beach
AE-5c All proposed site lighting, including fixtures outside the wall, shall be fully shielded. Fully shielded shall be defined as: A luminaire constructed and
installed in such a manner that all light emitted by the luminaire, either directly from the lamp or a diffusing element, or indirectly by reflection or refraction
from any part of the luminaire, is projected below the horizontal plane through the luminaire’s lowest light-emitting part (IES/IDA, 2011)
Approval of Construction
Documents and Specifications
and Inspection
Prior to issuance of
permits and during
construction
City of Hermosa
Beach
AE-5d The LZ-2 parameters of the Model Lighting Ordinance (IES/IDA, 2011) shall be used to demonstrate that maximum vertical illuminance for the site are not
exceeded. For site lighting inside the wall, Table B allowances shall be used. Lighting outside the wall at site entrances shall not exceed that of existing street lighting, which produces a maximum of 1 footcandle. For the purposes of measuring vertical illumination, the plane of the property line shall be
Approval of Construction
Documents and Specifications
and Inspection
Prior to issuance of
permits and during
construction
City of Hermosa
Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
extended to an elevation equal to the height of the electric drilling rig.
AE-5e All proposed site lighting fixtures shall demonstrate compliance with the mandatory B-U-G ratings for area lighting as required by CalGreen mandatory
measures in the 7/1/2012 supplement. The Lighting Zone used to demonstrate compliance shall be LZ-2.
Approval of Construction
Documents and Specifications
and Inspection
Prior to issuance of
permits and during
construction
City of Hermosa
Beach
AE-6a Any proposed metering station site lighting shall be fully shielded and shall
incorporate permanent features (shields, hoods, etc.) shall incorporate permanent features which prevent light spillage beyond the property line.
Approval of
Construction Documents and
Specifications and Inspection
Prior to
issuance of permits and
during construction
City of
Redondo Beach
AE-6b Light levels and quantities of fixtures shall not exceed that which is needed for
security and safety.
Approval of
Construction Documents and
Specifications and Inspection
Prior to
issuance of permits and
during construction
Cities of
Redondo Beach and
Torrance
Table 8-2 Air Quality and GHG’s
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible
Party
AQ-1a The Applicant shall submit and implement a Fugitive Dust Control Plan that
includes SCAQMD mitigations for fugitive dust mitigation, according to Rule 403, and SCAQMD CEQA Guidelines. Fugitive dust mitigation measures in the
plan shall include the following (this mitigation is applicable to both the Proposed Oil Project and the Proposed City Maintenance Yard Project):
- Apply water every 3 hours to disturbed areas and unpaved roads within a construction site (61 percent reduction).
- Require minimum soil moisture of 12 percent for earthmoving, by using
Plan review,
site inspections
Before and
during construction
Both Oil Project and
City Yard
SCAQMD
City of Hermosa
Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
a moveable sprinkler system or water truck. Moisture content can be verified by lab sample or moisture probe (69 percent reduction).
- Limit onsite vehicle speeds on unpaved roads to 15 mph and posting of speed limits.
- All trucks hauling dirt, sand, soil, or other loose materials are to be tarped with a fabric cover and maintain a freeboard height of 12 inches (91
percent reduction).
- Install gravel bed trackout apron (3 inches deep, 25 feet long, 12 feet
wide per lane, and edged by rock berm or row of stakes) to reduce mud and dirt trackout from unpaved truck exit routes (46 to 80 percent reduction).
- Water storage piles by hand or apply cover when wind events are declared, according to SCAQMD Rule 403 when instantaneous wind speeds
exceed 25 miles per hour (90 percent reduction).
- Appoint a construction relations officer to act as a community liaison
concerning onsite construction issues, such as dust generation.
AQ-1b The Applicant shall implement a NOx reduction program including the following, or equivalent, measures to the satisfaction of the SCAQMD (this mitigation is
applicable to both the Proposed Oil Project and the Proposed City Maintenance
Yard Project):
- All off-road construction equipment shall be tuned and maintained
according to manufacturers’ specifications.
- Any temporary electric power shall be obtained from the electrical grid,
rather than portable diesel or gasoline generators.
- All off-road diesel construction equipment with greater than 100-
horsepower engines shall meet Tier 3 NOx requirements.
- Limit onsite truck idling to less than 5 minutes.
- A copy of the certified tier specification, best available control
technology documentation, or the CARB or SCAQMD operating permit for each
piece of equipment shall be kept onsite during all operations.
Plan review,
site inspections
Before and during
construction
SCAQMD
City of
Hermosa
Beach
AQ-3a The Applicant shall limit flaring during Phase 4 to a total of 5 hours per day at the full flaring capacity (or to an equivalent volume of flared gas) during all
emergency or routine flaring events in order to ensure that NOx emissions are reduced below the thresholds. Lower NOx emission combustors or other
equivalent measures can also be used to satisfy the requirement.
Plan review, site inspections Before Phase 4 operations SCAQMD
City of
Hermosa Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
AQ-3b The Applicant shall implement methods to reduce the off-gassing of muds by at least 90 percent through the installation of fully enclosed mud pit areas with
vapor control (either through carbon canisters or vapor recovery) and/or the use of mud degassing units routed to vapor control systems. The Applicant shall
monitor the muds vapor immediately above the muds exit point from the wellbore and at other areas above the mud pits where muds may be exposed to
the atmosphere in order to ensure that hydrocarbon vapors are captured at the minimum rate of 90 percent.
Plan review, site inspections Before Phase 2 and Phase 4
drilling
SCAQMD
City of
Hermosa Beach
AQ-4 The Applicant shall limit the microturbine PM emissions to 0.0035 lbs/mmbtu, or
an equivalent reduction in the number and/or size of the microturbines, in order to reduce emissions to below the localized thresholds. The City shall be
responsible for ensuring that the applicant will be subject to permit conditions
that limit emissions from the set of microturbines, not just individual permit units.
Plan review,
site inspections
Before Phase
4 operations
SCAQMD
City of Hermosa Beach
AQ-5a The Applicant shall at all times have a gas buster and SCAQMD-approved portable flare at the site and connected for immediate use to circulate out and
combust any gas encountered during drilling. The flare shall be capable of recording the volume of gas that is flared. The operator shall report any flared
gas from drilling to the Hermosa Beach Fire Chief and the SCAQMD.
Plan review, site inspections Before Phase 2 drilling SCAQMD
City of
Hermosa Beach
AQ-5b The Applicant shall install a compressor seal vent collection system. In the event of a seal leak, vapors shall be collected and sent to the vapor recovery
system or flare for destruction.
Plan review,
site inspections
Before Phase
4 operations
SCAQMD
City of
Hermosa
Beach
AQ-5c The Applicant shall develop and implement an Odor Minimization Plan, submitted to and approved by the City and the SCAQMD. The Odor
Minimization Plan shall address reducing the frequency from potential sources of odors from all site equipment, including wells and drilling operations,
temporary operations such as truck loading, and measures to reduce or eliminate these odors (e.g., containment, design modifications, carbon
canisters). The Plan shall address issues such as facility information, buffer zones, signs with contact information, logs of odor complaints, the protocol for
handling odor complaints and odor release investigations and methods instituted to prevent a re-occurrence. The Plan shall require that all odor
complaints and issues be immediately communicated to the City and that the City shall have the authority to implement and enforce contingency measures to
Plan review, site inspections Before Phase 2 and Phase 4
Drilling operations
SCAQMD
City of
Hermosa Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
ensure that any nuisance odors from the facility are eliminated.
AQ-5d The Applicant shall develop and implement an Air Monitoring Plan. The Plan
shall provide for the monitoring of total hydrocarbon vapors and hydrogen sulfide and total hydrocarbon vapors at all perimeter locations of the facility as well as at strategic locations near processing equipment. At all times during
operations, drilling, redrilling and workover operations, the Operator shall maintain monitoring equipment that shall monitor and digitally record the levels of hydrogen sulfide and total hydrocarbon vapors. Such monitors shall provide automatic alarms that are audible and visible to the Operator of the drilling
equipment, and gas plant, and shall be triggered by the detection of hydrogen sulfide or total hydrocarbon vapors. Alarm points shall be set at a maximum of
1 5 and 5 10 ppm H2S and 500 and 1,000 ppm hydrocarbons, with the higher level requiring shut-down of drilling or plant operations and the lower level
requiring notification to appropriate agencies, including the Hermosa Beach Fire Department and SCAQMD. A meteorological station to monitor wind speed and
direction under the guidance and specification of the SCAQMD shall be installed at the site. The Air Monitoring Plan shall be reviewed and approved by
the City and the SCAQMD.
Plan review,
site inspections
Before Phase
2 and Phase 4 Drilling
operations
SCAQMD
City of
Hermosa
Beach
AQ-5e The Applicant shall use an odor suppressant spray system on the mud shaker
tables, and shall install carbon capture canisters on all tanks (permanent and portable) that are not equipped with vapor recovery, containing potentially
odiferous materials (for example; the mud baker-type tanks) for all drilling operations so that no odor can be detected at the closest receptor.
Plan review,
site inspections
Before Phase
2 and Phase 4 Drilling
operations
SCAQMD
City of Hermosa
Beach
AQ-5f The fugitive component leak detection program under Rule 1173 shall utilize a
Leak Detection and Reporting (LDAR) level of monthly detections with an action level of 100ppm, the installation of bellows valves where applicable (valves 2
inches or smaller) and the use of IR cameras or equivalent during monthly
detections to ensure that leaking components are minimized at the facility.
Plan review,
site inspections
Before Phase
2 operations
SCAQMD
City of Hermosa Beach
AQ-6 The Applicant shall provide credits for all GHG emissions generated above the threshold of 10,000 MTCO2e per year. A GHG Reporting and Reduction Plan
shall be submitted to the SCAQMD and the City detailing the measures to be implemented to achieve the required reductions, updated annually, and shall
include specifications on the protocol, vintage, and registry for any offsite mitigation. The following mitigation credits shall not require prior City or
Plan review, site inspections Before Phase 4 operations SCAQMD
City of
Hermosa Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
SCAQMD approval:
1. Credits generated within Los Angeles County per an approved SCAQMD
protocol;
2. Credits generated within the State of California per an approved SCAQMD
protocol;
3. Credits that are generated and verified under the CAPCOA GHG Rx
program;
4. Credits that are generated and verified under the voluntary SCAQMD
Regulation XXVII;
5. Verified credits registered with the Climate Action Reserve or the American
Carbon Registry.
In addition, independently verified GHG credits available through other carbon
registries that follow specific protocols may be eligible for offsite mitigation, subject to review and prior approval by the City and the SCAQMD. The general
criteria for acceptable credits include:
• Real: emission reduction must have actually occurred, as the result of a
project yielding quantifiable and verifiable reductions or removals.
• Additional/Surplus: an emission reduction cannot be required by a law,
rule, or other requirement.
• Quantifiable: reductions must be quantifiable through tools or tests that
are reliable, based on applicable methodologies, and recorded with adequate documentation.
• Verifiable: The action taken to produce credits can be audited and there is sufficient evidence to show that the reduction occurred and was quantified
correctly.
• Enforceable: An enforcement mechanism must exist to ensure that the
reduction project is implemented correctly.
• Permanent: Emission reductions or removals must continue to occur for
the expected life of the reduction project.
Operational/drilling GHG emissions from stationary and mobile sources shall be
quantified and reported to the City and to the SCAQMD annually. Emissions reporting will follow the same reporting format and procedures as required by
the Mandatory Reporting Rule.
AQ-7a All diesel equipment used at the site shall meet EPA Tier 3 emission Plan review, Before Phase SCAQMD
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
requirements and be equipped with a CARB Level 3 diesel particulate filter to reduce Diesel PM emissions. Workover rigs operated at the project site shall
have cumulative total DPM emissions below 1.5 lbs/year or shall utilize electric drive/sources .
site inspections 4 operations City of Hermosa
Beach
AQ-7b Vapor recovery on crude oil tanks shall achieve a minimum of 99 percent recovery of fugitive emissions. Plan review, site inspections Before Phase 4 operations SCAQMD
City of Hermosa
Beach
Table 8-3 Biological Resources
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible
Party
BIO-1 To minimize potential impacts to nesting native bird species, and in compliance with the federal Migratory Bird Treaty Act and Sections 3503, 3503.5, or 3513 of
the California Fish and Wildlife Code, initial vegetation removal/trimming shall
be done outside the breeding season (breeding season is defined herein as January 15 through August 31 for raptors and February 15 through August 31 for all non- raptor species). If vegetation removal/trimming must be completed
during this period, then surveys for nesting birds must be conducted by a
qualified, City-approved Biologist, within 3 days prior to vegetation removal or other construction-related disturbances. If nesting birds are observed within the
project area, then a minimum 100-foot buffer from any non-raptor species and 500 foot buffer from any raptor nest would be established and maintained for the duration of vegetation removal/trimming activities or until nestlings fledge
from the nest.
Plan review,
site inspections
Before and during
construction
City of Hermosa
Beach
BIO-2 The Applicant shall submit for City approval and shall implement an Emergency
Response Plan that would, in compliance with the California State Oil Spill Contingency Plan (CDFW, OSPR 2014),address protection of biological
resources and possible revegetation of any areas disturbed during an oil spill or cleanup activities. The Emergency Response Plan shall, at a minimum, include
Plan review Before
construction
City of
Hermosa Beach
OSPR
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
specific measures to avoid impacts to native vegetation and wildlife habitats, plant and animal species, and environmentally sensitive habitat areas during
response and cleanup operations. The Emergency Response Plan shall include provisions for containment and cleanup measures and responsibilities. The
plan shall contain:
• Definition of the authorities, responsibilities, and duties of all entities
involved in oil removal operations, and methods of emergency action agency coordination during and after an oil spill;
• Agreements and statements from all resource agencies involved in an oil response and removal operation;
• Procedures and frequencies for regular monitoring and inspections of pipelines and facilities;
• Procedures for early detection and timely notification of an oil discharge;
• A description of the necessary onsite equipment and details on the placement of the material required to quickly control, contain, and remove any
discharged oil;
• Assurance that full resource capability is known and can be committed
following a discharge;
• A description of sensitive biological resources in the SMB that should
be prioritized for clean-up activities in the case of an oil spill into the marine environment; • Actions for after discovery and notification of a discharge;
• Procedures to facilitate recovery of damages and enforcement measures.
The Emergency Response Plan shall be approved by the California Department of Fish and Wildlife (CDFW) Office of Spill Prevention and
Response (OSPR).
When habitat disturbance cannot be avoided, the Emergency
Response Action Plan shall provide stipulations for development and implementation of site-specific habitat restoration plans and other site-specific
and species-specific measures appropriate for mitigating impacts to local populations of special-status wildlife species and to restore native plant and
animal communities to pre-spill conditions. Access and egress points, staging areas, and material stockpile areas that avoid specific habitat areas shall be
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
identified. The Emergency Response Action Plan shall include species- and site-specific procedures for collection, transportation and treatment of oiled
wildlife.
The Emergency Response Plan shall be approved by the City prior to
commencing any construction activities.
_____________________________________________________________________________________________________________________
Table 8-4 Cultural Resources
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible
Party
CR-1 Prior to beginning demolition of the existing City Maintenance Yard Building,
guidelines shall be developed for the careful exposure of extant elements of the historic brick and mortar furnace. Once exposed, detailed documentation of the
furnace shall be undertaken. Documentation shall be guided by the Historic American Engineering Record (HAER) standards. This documentation shall
include production of high quality 35-mm photographs and plan drawings of building elements exposed, including but not limited to, a floor plan, any
character-defining building features, and elevation drawings.
All work carried out pursuant to the recordation of the furnace building shall be
conducted by, or under the direct supervision of a person or persons meeting, at a minimum, the Secretary of the Interior’s Professional Qualifications
Standards (48 FR 44738-39 as revised in 1994) as an architectural historian. A written report detailing the HAER-like documentation shall be provided to the
City upon completion the work. This report shall be produced on archivally stable materials and filed with the Hermosa Beach Historical Society.
Development
and implementation
of a monitoring and
documentation plan by a
qualified archaeologist.
During
building demolition
within areas of recorded
historical resources.
Project
Proponent and
Construction Contractor
CR-2a The design of the New City Maintenance Yard Building shall be compatible in design, styling, material, and massing of the adjacent City Hall complex. The
building design should not attempt to replicate the New Formalist style, but it shall not conflict or contrast with the existing building style. The buildings
constructed in the New City Maintenance Yard shall be no more than two
Design of the
New City Maintenance
Building and
landscape
Design Phase Project
Proponent and City
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
stories high. They shall not overpower or overshadow the existing building complex.
CR-2b The landscaping associated with the proposed New City Maintenance Yard shall replicate the planting types surrounding the City Civic buildings, to the
extent possible, in order to blend the new construction into the existing Complex. The final design of both the new building and landscape should be developed in consultation with an historic architect or architectural historian who
meets Secretary of the Interior’s Professional Qualifications Standards (48 FR
44738-39 as revised in 1994).
Design of the New City
Maintenance Building and
landscape
Design Phase Project Proponent
and City
CR-3a
Prior to any ground-disturbing activities or building removal within the Proposed Project sites, an Archaeological Monitoring Plan shall be developed by a
qualified archaeologist with provision for review and input by concerned Native Americans and approval by the City. The Plan will also address worker safety
during building demolition and ground disturbing activities and during the implementation of the Remedial Action Plan. The Plan is to include provisions
for archaeological and Native American monitoring, detailed documentation of all early twentieth-century artifact-bearing deposits exposed during ground-
disturbing site work, and development of a clear collection policy for both prehistoric and historic artifacts, subsequent artifact analysis, reporting of
findings, and disposition and/or curation of any significant artifacts recovered. All reports of findings shall be filed with to SCCIC.
Development and
implementation of a monitoring
plan by a qualified
archaeologist in consultation
with concerned Native
American tribes.
The monitoring
plan shall be submitted for
review by the City of
Hermosa Beach and
approval prior to beginning
development. Plan shall be
implemented prior to and
during construction.
Project Proponent
and Construction
Contractor
CR-3b
Any significant archaeological deposits remaining in the area of the previous City of Hermosa Beach Dump following over-excavation at the Proposed Oil
Development Project site must be protected in place. Stabilization and covering of these archaeological deposits shall be monitored by a qualified historical
archaeologist meeting the Secretary of the Interior’s Professional Qualifications
Standards (48 FR 44738-39 as revised in 1994).
Following
construction any remaining
archaeological deposits must
be stabilized and covered for protection.
Following
over-
excavation
Project
Proponent and
Construction
Contractor
CR-4 Should Project-related excavations be designed to exceed 45 feet in depth at A The Project
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
the City Dump, or depths greater than 15 feet along the pipelines, or otherwise be shown to have the potential to impact intact San Pedro Sand deposits as
described above, a Paleontological Resources Monitoring and Mitigation Plan (PRMMP) shall be developed by a qualified paleontologist in consultation with
the City and implemented prior to or during Project-related ground disturbing activities. The Plan will also address worker safety during building demolition
and ground disturbing activities and during the implementation of the Remedial Action Plan.
paleontological resource
monitoring and mitigation
program (PRMMP) for
treatment of the paleontological
resources will be developed
and implemented.
monitoring plan shall be
submitted for review by the
City of Hermosa
Beach and approval prior
to beginning development.
Plan shall be implemented
prior to and/or during
construction.
Proponent and
Construction Contractor
CR-5
Ground-disturbing activities in the area of the discovery shall immediately be
halted or redirected. A temporary construction exclusion zone shall be established surrounding the site to allow for further examination and treatment
of the find. A City representative shall immediately notify the Los Angeles County Coroner’s office by telephone. By law, the Coroner will determine within
two working days of being notified if the remains are subject to his or her
authority. If the Coroner recognizes the remains to be Native American, he or she shall contact the Native American Heritage Commission who will appoint the Most Likely Descendent (MLD). Additionally, if the remains are determined
to be Native American, a plan will be developed regarding the treatment of human remains and associated burial objects and the plan will be implemented
under the direction of the MLD.
The Native American
Heritage Commission
(NAHC) must be contacted by the Los Angeles
County Coroner, and a
Most Likely
Descendant must be designated.
Any further treatment of the remains will
occur in consultation with the MLD,
Upon discovery of
human
remains.
Project Proponent
and Construction
Contractor
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
the NAHC, and a qualified
archaeologist.
__________________________________________________________________________________________________________
Table 8-5 Fire Protection and Emergency Response
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
FP-1a The Applicant shall ensure adequate (3,000-5,000 gpm) water supplies are
available from the existing water lines and hydrant system, by extending the 8 inch water main or some other source for water supplies that provides sufficient
water supply rates, pressure and duration to comply with codes, standards and requirements of the LACFD and the HBFD. Installation of a fire pump, or
installation of a piping connection to area water mains that can supply the flows, may be required to ensure the appropriate water flow and pressure
requirements. The Applicant shall ensure that all area hydrants and water supplies are tested annually as to the NFPA standards for water flows and
pressures, and shall ensure that the results are reported to the City of Hermosa Beach and the Hermosa Beach Fire Department.
Review of
water flow calcs and tests,
annual reviews
Before Phase
2
City of
Hermosa
Beach
HBFD
FP-1b The Applicant shall coordinate with the HBFD to integrate a community alert notification system for the proposed project into the City's existing alert system
to automatically notify area residences and businesses in the event of an emergency at the project site that would require residents to take shelter or take
other protective actions. The Applicant shall implement programs to ensure that all immediate neighbors are provide ample opportunity to participate in the
notification system.
Review and testing of
system
Before Phase 2 City of Hermosa
Beach
HBFD
FP-1c The Applicant shall fund an additional FTE position at the HBFD, or equivalent, for personnel with specific capabilities in inspection and code compliance
associated with oil and gas production facilities. This arrangement shall be to
Training and hiring
completed at
Before Phase 2 City of Hermosa
Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
the satisfaction of the HBFD. HBFD HBFD
FP-1d The Applicant shall develop emergency response plans addressing the facility's fire-fighting capabilities pursuant to the most recent NFPA requirements, Los
Angeles County Fire Code, LACFD, California Code of Regulation, and API
requirements, in coordination with and to the satisfaction of the LACFD and the City of Hermosa Beach Fire Department. These plans shall include, but not be limited to, fire monitor placement, water capabilities, fire detection capabilities,
fire foam requirements, facility condition relating to fire-fighting ease and
prevention, and measures to reduce impacts to sensitive resources. The plan should also address coordination with local emergency responders and area
schools and daycare facilities.
Review and approval of
plans
Before Phase
2
City of Hermosa
Beach
HBFD
FP-1e The Applicant shall ensure that the emergency response planning includes development of evacuation plans of neighbors for an emergency scenario at the
facility,. The plan shall be reviewed by the LACFD, HBFD and the City annually and updated as needed. The relevant portions of the plan shall be distributed
to the public utilizing a method determined by the reviewing Agencies.
Review of plan revision Before Phase 2 and Phase 4 City of Hermosa
Beach
HBFD
FP-1f The Applicant shall ensure and make funding available to 1) upgrade the dispatch system and procedures within Hermosa/Torrance/Redondo to
implement a CAD-to-CAD system to improve dispatch times; and 2) extend the mutual aid agreements to become automatic aid agreements between the Hermosa Beach Fire Department, Redondo Beach Fire Department and the Torrance Fire Department and to include the Torrance HAZMAT unit, or provide
for funding to provide additional equipment and to train a sufficient number of Hermosa Beach, Redondo Beach and/or Manhattan Beach Emergency
Response personnel to provide first response HAZMAT capabilities.
Review of Mutual Aid
agreement
revision
Before Phase
2 and Phase 4
City of Hermosa
Beach
HBFD
FP-1g The Applicant shall ensure, during Phase 2 and Phase 4, that the site shall
have sufficient water containment capabilities, as per guidance and approval of the Fire Department. Area storm drains along 6th Street and Cypress Avenue
shall be equipped with flapper-type valves to enable the closure of the storm drain system in the event of potential overflow.
Review of plan
and onsite inspections
Before Phase
2 and Phase 4
City of
Hermosa Beach
HBFD
FP-2a The Applicant shall ensure that design and construction comply with applicable
codes and standards for equipment spacing, particularly those related to flare location and distances to public areas and distances from well drilling
equipment to buildings. If this cannot be achieved, additional requirements
Third party
audit report
review
Before Phase
2 and Phase 4
City of
Hermosa
Beach
HBFD
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
shall include the construction of thermal radiation barriers or insulation on the crude oil tanks, installation of thermal barriers/walls around the flare stack,
increasing the height of the flare stack during drilling, relocation of the flare stack, providing thermal radiation modeling to estimate the impacts of
equipment on the crude tanks and process piping and public areas and the design and construction of blast walls as per API 752. Fire rated barriers shall
be established, as per LACFD requirements, to ensure that all buildings within 100 feet of well drilling would be protected from thermal radiation. Thermal
assessments shall be completed to ensure that the thermal radiation from the flare is within acceptable levels (as per API RP 521) and does notproduce
damage to other equipment or nearby walls/soundwalls. The design and construction compliance status shall be verified by third-party audits under the
direction of the City.
FP-2b Fire protection measures specific to the crude oil containment system shall be provided, including the installation of manual fire foam systems with automatic
detection and notification (to both the operators and the HBFD) capable of foaming in the perimeter of the crude oil containment system, wellhead area
and the area immediately adjacent to combustion or spark producing equipment within or immediately adjacent to the crude oil containment area. The system
shall be capable of being remotely activated from a safe location in the event of
a crude oil fire. The highest level electrical classification achievable shall be designated for all equipment located within the crude oil containment and
wellhead area.
Review of design
documents
Before Phase
2 and Phase 4
City of Hermosa
Beach
HBFD
____________________________________________________________________________________________________________
_________
Table 8-6 Geological Resources/Soils
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible
Party
GEO-1a In coordination with the Caltech Seismological Laboratory, the Applicant shall install an accelerometer at the Project Site to determine site-specific ground Inspection by a California Following any seismic event City of Hermosa
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
accelerations as a result of any seismic event in the region (Los Angeles/Orange County and offshore waters of the Santa Monica Bay and San
Pedro Channel). The drilling operator shall cease operations and inspect all onsite oil field-related pipelines, storage tanks, and other infrastructure following
any seismic event that exceeds a ground acceleration at the Project Site of 13 percent of gravity (0.13 g). The drilling operator shall not reinstitute operations
at the Project Site and associated pipelines until it can be determined that all oil field infrastructure is structurally sound.
Registered Civil Engineer that results in substantial
ground accelerations
at the Project Site, as pre-
determined by a California-
licensed geotechnical
engineer.
Beach
GEO-1b All seismic related recommendations provided by NMG Geotechnical (2012) shall be incorporated into the Proposed Oil Project design. These measures
shall include, but not be limited to the following:
- Drilled-in-place piles or cast-in-drilled-hole piles shall be constructed for
foundations in the landfill area, i.e., northeast Project Site, to reduce seismically
induced settlement.
- Ground improvement techniques, including high pressure grout injection, i.e., compaction grouting, shall be used in the landfill area to reduce seismically induced settlement and allow construction of conventional shallow foundations.
- Seismic design criteria for horizontal and vertical accelerations, identified in Tables 10 and 11 of the geotechnical report, shall be used during Proposed Project design (including incorporation of updated seismic design criteria from
the 2013 California Building Code).
- During Phase 1, the upper 2 to 4 feet of soil in the vicinity of the proposed well
cellars shall be excavated and replaced with compacted fill. In addition, the basement under the maintenance building shall be removed and filled in with
compacted fill. In addition, the basement under the maintenance building shall
be removed and filled in with compacted fill.
- During Phase 3, the eastern portion of the site shall be excavated
approximately 7 feet deeper than the majority of the proposed building pad, with a minimum of 3 feet of overexcavation below design grades, and recompacted to provide a uniform fill blanket below proposed tanks, compressors, and other
equipment.
- Asphalt pavement and underlying subgrade soils shall be designed to
Review and approval of
geotechnical
report.
Approve geotechnical
report prior to issuance of grading
permit.
City of Hermosa
Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
accommodate the proposed drill rig.
Positive surface drainage shall be provided to direct runoff away from slopes
and structures and toward suitable drainage devices. Ponding of water on structural pads shall not be allowed.
GEO-2a
Injection pressures associated wastewater injection shall not exceed reservoir fracture pressures as specified in California Code of Regulations Title 14,
Division 2, Section 1724.10, and as approved by the California Division of Oil, Gas, and Geothermal Resources..
Comparing pressure
measurements on each injection well to
formation
fracture pressure
During waste water injection
operations
California Division of Oil
and Gas and Geothermal Resources
(DOGGR)
and Hermosa Beach Public Works
Department
GEO-2b
In coordination with the Caltech Seismological Laboratory, the Applicant shall
install an accelerometer at the Project Site to determine site-specific ground accelerations as a result of any seismic event in the region (Los
Angeles/Orange County and offshore waters of the Santa Monica Bay and San Pedro Channel). Readings from the accelerometer shall be recorded at the Oil
Field and transmitted in real-time to the Caltech Seismological Laboratory. The drilling operator shall cease operations and inspect all onsite oil field-related
pipelines, storage tanks, and other infrastructure following any seismic event that exceeds ground acceleration at the Project Site of 13 percent of gravity
(0.13 g). The drilling operator shall not reinstitute operations at the Project Site and associated pipelines until it can be determined that all oil field infrastructure
is structurally sound.
Monthly City of
Hermosa Beach
GEO-2c In the event that monitoring indicates that Proposed Oil Project-induced seismicity is occurring, wastewater injection operations shall be adjusted to
alleviate such seismicity. The drilling operator shall first receive approval from the California Division of Oil, Gas, and Geothermal Resources prior to any
change (increase) in the injection operations.
Seismicity
monitoring
Following monthly
monitoring, as
necessary
City of Hermosa
Beach
GEO-3 All slope stability related recommendations provided by NMG Geotechnical
(2012) shall be incorporated into the Proposed Oil Project design. Temporary excavations shall be stabilized per the latest edition of Cal/OSHA requirements
Submit
temporary shoring plans
Prior to permit
issuance
City of
Hermosa Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
for loose sands, including shoring or laying back of trench walls. Shoring along the northern perimeter of the Project Site shall be designed by an experienced
structural engineer due to the proximity to existing buildings that must be protected from potential settlement and lateral movements.
and calculations.
GEO-4a Prior to approval of the first Phase 4 drilling permit, the Applicant shall have submitted and the City of Hermosa Beach and the California Coastal Commission shall have approved a Subsidence Monitoring and Avoidance
Program, for both onshore and offshore areas. The onshore monitoring plan shall be completed throughout the life of this project, in accordance with Appendix A, Subsidence Monitoring Program, of the Subsidence and Induced Seismicity Technical Report, E&B Oil Development Project (Geosyntec
Consultants 2012), included as Appendix _F of this EIR. The offshore monitoring plan shall be completed throughout the life of this project in
accordance with the Offshore Subsidence Monitoring Program and Possible
Mitigation Measures, Hermosa Beach, California (Coastal Environments 1998), included as Appendix _F of this EIR. The latter shall be updated, as applicable, to reflect advances in science since 1998. In addition, Section 7.6, Mitigation of
Onshore Subsidence, of the latter report, shall not be applied to this mitigation measure, as the onshore monitoring program would be completed in accordance with the Geosyntec Consultants (2012) report.
Monitor subsidence with GPS
technology.
Prior to Phase 4 Annually Hermosa Beach Public Works
Department
GEO-4b The Subsidence Monitoring Program shall include:
Ground elevation survey methodologies with high vertical resolution; including
onshore surface elevations and offshore bathymetric elevations;
Prior to Phase 4 II drilling, establishment of a network of onshore and offshore
survey or subsidence monitoring locations, including continuous GPS stations, GPS benchmarks, and tautly anchored offshore monitoring points, positioned
within the City, outside the City, and in offshore areas, that are sufficiently spaced to draw conclusions about subsidence within the zone of influence of
the Project;
Because subsidence can occur for a variety of reasons, establishment of
control points outside the zone of influence to allow differentiation of possible subsidence effects related to other activities;
Use of InSAR imagery technology to evaluate regional subsidence patterns
Monitor subsidence
with GPS technology.
Prior to Phase 4 Annually Hermosa Beach Public
Works Department
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
both within and beyond the proposed oil field;
Sufficient monitoring frequency to establish trends in subsidence in order to
distinguish background ground movement from any subsidence caused by proposed oil field operations;
Reservoir monitoring, including documentation of produced fluid volume (oil, gas and water) and reservoir pressures at similar frequency to ground elevation
measurements;
Reporting requirements; and
Action levels, as specified in the onshore and offshore subsidence monitoring reports.
Surveying for both vertical and horizontal ground movement shall be completed along the perimeter and throughout the interior of the oil field, including both
onshore and offshore areas, utilizing Global Positioning System technology in combination with a network of ground stations. The onshore continuous
monitoring GPS stations shall include:
Hermosa Beach Pier. The pier will serve as the furthest offshore point in the
onshore monitoring program.
Longfellow Outfall. This Outfall is larger and more structurally stable than some
of the other outfalls along the City’s coast.
King Harbor Jetty. This location was selected to achieve a distribution of
continuous monitoring points along the coast of Hermosa Beach. This will help provide a limited regional picture of the subsidence between survey events.
GEO-4c An onshore and offshore baseline subsidence report shall be completed and made available to the City of Hermosa Beach and the California Coastal Commission at least two months and no more than six months prior to planned commencement of Phase 4 II drilling operations. Subsidence monitoring reports shall be completed annually and the results shall be forwarded to the
California Coastal Commission and the City of Hermosa Beach for review, no more than one month following the end of each annual monitoring cycle. In
addition, results shall be forwarded to the adjoining City of Redondo Beach and
City of Manhattan Beach.
Coordinate with Hermosa Beach Public Works
Department
At least two months prior to Phase 4 2 drilling
operations
Hermosa Beach Public Works Department
GEO-4d In the event that the Global Position System monitoring indicates that significant subsidence, as defined by the onshore and offshore subsidence monitoring
reports described in GEO-4a, is occurring in and/or around the Proposed
Coordinate with California
Division of Oil
Following monitoring
results
California Division of Oil
and Gas and
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
Project area, wastewater or water reinjection operations shall be increased to alleviate such subsidence. The Applicant shall coordinate with the California
Division of Oil, Gas and Geothermal Resources, which will approve increased levels of wastewater or water reinjection operations in accordance with the
approved Subsidence Monitoring Program. The Applicant will also coordinate with the City of Hermosa Beach, Public Works Department, to verify that
subsidence has been mitigated sufficiently. The Applicant will also coordinate with the City of Hermosa Beach, Public Works Department, to verify that
subsidence has been mitigated sufficiently.
and Gas and Geothermal
Resources (DOGGR)
indicating subsidence Geothermal Resources
(DOGGR) and Hermosa
Beach Public Works
Department
GEO-4e In the unlikely event that subsidence related mitigation induces seismicity, corrective actions related to subsidence shall proceed until baseline surface
elevations have been achieved, as subsidence related damage would likely be more pronounced in comparison to damage associated with Project related
micro-seismicity. Upon reestablishment of baseline elevations, drilling operations shall cease until a balance between subsidence avoidance and induced seismicity avoidance can be established, as agreed upon by the California Division of Oil, Gas and Geothermal Resources, the California
Coastal Commission, and the City of Hermosa Beach.
Coordinate with California
Division of Oil and Gas and
Geothermal Resources (DOGGR)
Following monitoring
results indicating
subsidence
California Division of Oil
and Gas and Geothermal
Resources (DOGGR) and Hermosa Beach Public
Works
Department
GEO-6
A Registered Civil Engineer shall analyze surficial and near-surface soils at the Project Site subsequent to grading and prior to on-site construction, to
determine whether expansive soils are present. Similarly, soils at the Proposed City Maintenance Yard Project Site and along the proposed pipeline route shall
be analyzed for soil expansion potential. In the event that clay-rich, expansive soils are present, foundations shall be designed to accommodate expansive
soils and pipelines shall be placed within a blanket of non-expansive soils to prevent structural damage and/or failure. Foundation and pipeline design shall
be reviewed and approved by a Registered Civil Engineer.
Soil auger and analytical
laboratory
Prior to final design City of Hermosa
Beach
GEO-7a Proposed Oil Project design must conform to the recommendations of HDR Schiff (2012), included within Appendix C in NMG Geotechnical (2012), or as
per the City Engineer, and should occur prior to completion of the final Project
design.
Design for protection
against
corrosion
Prior to final
design
City of Hermosa
Beach
GEO-7b All buried metal pipelines shall be coated and placed under impressed cathodic protection. To monitor for internal corrosion, corrosion coupons or equivalent Under impressed Prior to final design City of Hermosa
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
measures can be utilized. cathodic protection Beach
GEO-7c External pipe inspections shall be conducted for the exposed pipeline sections to ensure atmospheric coatings are in good conditions. All external inspections
shall be documented and reviewed by the operations management and repairs documented, when necessary.
Visual inspections Monthly City of Hermosa
Beach
GEO-7d In accordance with California Division of Oil, Gas, and Geothermal Resources
pipeline regulations (Public Resources Code Sections 3013 and 3782), a pipeline management plan shall be implemented for the Project Site. Similarly,
in accordance with United States Department of Transportation, Pipeline and Hazardous Materials Safety Administration regulations, a pipeline management
plan shall be implemented for proposed pipelines located beyond the perimeter of the Project Site. These plans shall include, but not be limited to mechanical
testing, including ultrasonic and hydrostatic testing.
Prepare under
guidance of California
Department of Conservation
Division of Oil, Gas, and
Geothermal Resources and
United States Department of
Transportation, Pipeline and
Hazardous Materials
Safety Administration
Prior to final
design
California
Division of Oil and Gas and
Geothermal Resources
(DOGGR), United States
Department of
Transporta-tion, Pipeline
and Hazardous
Materials Safety
Administra-
tion, and
Cities of Hermosa
Beach, Redondo
Beach, and Torrance
GEO-7e All concrete in contact with the high sulfate or corrosive soils shall be Type V concrete in accordance with the 2010 California Building Code. Pour proper concrete adjacent to
corrosive soils
During construction City of Hermosa
Beach
Exhibit D-3
___________________________________________________________________________________________________________
Table 8-7 Safety, Risk of Upset and Hazards
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible
Party
SR-1a The Applicant shall cause to be prepared an independent third-party audit,
under the direction and supervision of the City, of the gas and crude oil plants and pipelines, once constructed, including the well pads, to ensure compliance
with Fire Code, applicable API and NFPA codes, EPA RMP, OSHA PSM, DOGGR and SPCC and emergency response plans requirements. All audit
items shall be implemented in a timely fashion, and the audit shall be updated annually, as directed by the City and the Los Angeles County Fire Departments.
The final installation of the facilities shall include a seismic assessment, including walkthroughs, of equipment to withstand earthquakes prepared by a
registered Structural Engineer in compliance with Local Emergency Planning Committee Region 1 CalARP guidance and the seismic assessment shall be
updated, with walkthrough inspections, annually to ensure compliance with the codes and standards at the time of installation.
Review of audit
reports
Before Phase
4 operations and annually
thereafter
LACFD
HBFD
Cities of
Redondo Beach and
Torrance
SR-1b The Applicant shall ensure that the crude oil spill containment areas shall be
designed as Class I Division I areas according to NFPA and NEC, or that spark producing equipment (such as the flare) would be isolated from the containment
area, in order to reduce the potential for crude oil fires. The refrigeration
system shall utilize non-flammable refrigerant.
Review of
design
documents
Before Phase
3 construction
City of
Hermosa
Beach
HBFD
Cities of
Redondo Beach and
Torrance
SR-1c The Applicant shall ensure that all crude-oil truck haulers and a sufficient number of onsite personnel (at least two per shift) are trained in HAZMAT (to
the HAZWOPER technician level at least) spill response and that each truck carries a spill response kit.
Site inspections,
review of contracts
Before Phase 2 drilling City of Hermosa
Beach
HBFD
Cities of Redondo
Beach and Torrance
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
SR-1d The Applicant shall install automatic valves on the gas pipeline that will automatically shut down under a low pressure scenario at the Processing
Facility Area for all pipelines leaving the processing plant, and shall install a backflow prevention device at the main gas pipeline tie-in location, to prevent
the release of gas from the main transmission pipeline in the event of a rupture in the gas pipeline. The second, return pipeline shall remain isolated from the
main gas pipeline during normal operations.
Review of design
documents
Before Phase 3 construction City of Hermosa
Beach
HBFD
Cities of Redondo
Beach and Torrance
SR-1e The Applicant shall ensure that warning tape is installed above the pipelines within the pipeline trench to warn third parties that pipelines are located below
the warning tape and that the pipelines are capable of utilizing a smartpig.
Review of design
documents
Before Phase
3 construction
City of Hermosa
Beach
HBFD
Cities of Redondo Beach and
Torrance
SR-1f The odorant system shall have its own, smaller containment area around it
limiting the spilled pool size to the minimum size attainable, in order to prevent any offsite impacts. Transfer of odorant shall utilize carbon canisters and a
canister change-out/maintenance program to ensure that filling of odorant tanks do not cause offsite impacts.
Review of
design documents
Before Phase
3 construction
City of
Hermosa Beach
HBFD
SR-1g The comingled produced gas shall be continuously monitored for hydrogen sulfide. If H2S levels in the produced gas from any individual well exceeds 100 ppm, then that well shall be shut in and abandoned as per DOGGR requirements. Wells shall be tested when fluids first flow, when the well is placed into production and periodically thereafter in order to ensure that all
wells operate below 100 ppm H2S.
Review of design
documents and in-field
inspections
Before Phase 2 drilling City of Hermosa
Beach
HBFD
Cities of
Redondo Beach and
Torrance
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
SR-2 The Applicant shall sample soil during Phase 1 grading to ensure that soil lead contamination levels are below 9,500 mg/kg and that soil contaminated with
TPH are below the regulatory guidelines. If soils are encountered above these levels, then those soils shall be removed from the site and transported to a
disposal site. This may necessitate implementing the RAP during Phase 1 if substantial amounts of contamination are encountered.
Review of design
documents and in-field
inspections
Phase 1 City of Hermosa
Beach
____________________________________________________________________________________________________________
_________ Table 8-8 Hydrology and Water Quality
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
HWQ-2a The Applicant shall properly maintain the associated crude oil pipelines, storage tanks, and processing facilities within and outside the Project Site, including
smart-pigging according to State of California Office of the State Fire Marshal requirements and the standards outlined by the Department of Oil, Gas and
Geothermal Resources, and the Los Angeles Regional Water Quality Control Board. The Applicant shall visually inspect onsite storage tank and processing
equipment at least daily and provide a visual inspection of the crude oil pipeline right-of-way inspections on a weekly basis.
Review of maintenance
reports
Before Phase 4 operations
Annually
Cities of Hermosa
Beach, Redondo
Beach, and Torrance
HWQ-2b The Applicant shall install a leak detection system for crude pipelines to the Exxon Mobil Refinery transfer of custody location. The system shall include
pressure and flow meters, flow balancing, supervisor control and data acquisition system, and a computer alarm system in the event of a suspected
leak. Temperature, pressure, and flow shall be monitored at each pipeline entry and exit. If any variable deviates by more than 10 percent of the normal
operating range, the system shall trigger both audible and visual alarms. Flow balancing shall be conducted every 5 minutes, 1 hour, 24 hours, and 48 hours
with the accuracy defined once the system is established and tested.
Review of system design
and testing
results
Before Phase 4 operations Cities of Hermosa
Beach, Redondo
Beach, and
Torrance
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
HWQ-2c Personnel at the site shall be trained in equipment use and containment and
cleanup of an oil spill. Dry cleanup methods, such as absorbents, shall be used on paved and impermeable surfaces and shall be included in a spill trailer
maintained onsite. Spills in dirt areas shall be immediately contained with an earthen dike and the contaminated soil shall be dug up and discarded in
accordance with local and state regulations.
Review of training and
equipment
Before Phase 2 and Phase 4
operations
and
intermittently thereafter
Cities of Hermosa
Beach, Redondo
Beach, and Torrance
HWQ-2d Oil spills shall be contained and cleaned according to measures outlined in the then-current California Stormwater Quality Association Best Management
Practice Handbook.
Review of training and
incident reports
Before Phase 2 and Phase 4 operations,
and intermittently
thereafter
Cities of Hermosa Beach,
Redondo Beach, and
Torrance
HWQ-2e A United States Environmental Protection Agency, Spill Prevention, Control,
and Countermeasure Plan, approved by the City of Hermosa Beach Fire Department, shall be implemented in the event of a spill. The Plan, which shall
include a spill response trailer, equipment, and personnel training shall be completed prior to Phase 2 and Phase 4, and in compliance with the California
State Oil Spill Contingency Plan (California Department of Fish and Game, Office of Spill Prevention and Response 2010) and the Los Angeles/Long
Beach Oil Spill Contingency Plan (California Department of Fish and Wildlife 2011). Spill cleanup shall be completed under the oversight of the lead
regulatory agency, with respect to oil spills, as identified in the Spill Prevention, Control, and Countermeasure Plan.
Review of
reports
Before Phase
2 and Phase 4 operations
Cities of
Hermosa Beach,
Redondo Beach, and
Torrance
HWQ-2f The well cellar shall be lined with an impermeable membrane to prevent oil-based substances from seeping into groundwater supplies. All drilling muds
storage shall be contained within Baker-type enclosed tanks, which shall be sized to accommodate high intensity rainfall events without overtopping.
Review of
design documents,
field inspection
Before Phase
2 and Phase 4
operations
Cities of
Hermosa Beach,
Redondo Beach, and
Torrance
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
HWQ-2g
The Applicant shall install a check valve in the crude oil pipeline at the Herondo and Valley drive where the crude oil pipeline turns eastward and starts uphill.
Review of design
documents, field inspection
Before Phase 4 operations Cities of Hermosa
Beach, Redondo
Beach, and Torrance
HWQ-2h The Applicant shall fund and install, under the direction of the Hermosa Beach Public Works Department, an oil/grit separators or oil/water separator located along Herondo Street downstream of Valley Drive, in order to capture small to
medium sized spills before they reach the ocean. Installation and maintenance costs shall be provided by the Applicant and the devices shall be inspected by the Applicant to ensure that the "trap" is operational before any storm events.
Review of design documents,
field inspection
Before Phase 4 operations, and
intermittently
thereafter
Cities of Hermosa Beach,
Redondo
Beach, and Torrance
HWQ-2i The Applicant shall utilize a smaller 6" ERW pipe and a heat and impact resistant coating at a minimum comparable to a 3-layer fusion bonded epoxy
(such as BrederoShaw 3LPP) and weld coverings equivalent to sleeves with epoxy primer. Specification of the pipe and coating shall approved by the City.
Review of design
documents, field inspection
Before Phase 4 operations City of Hermosa
Beach, CSFM
HWQ-2j The Applicant shall install a 3 sack slurry starting 6 inches above the pipe to the
base of the pavement or ground surface and lay strips of warning tape over the top to prevent third-party damage.
Review of
design documents,
field inspection
Before Phase
4 operations
City of
Hermosa
Beach
Exhibit D-3
Table 8-9 Noise and Vibration
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
NV-1a Increase the height of the noise barrier on all sides of the site to 24-feet (24-feet is the maximum feasible height for a noise barrier during Phase 1). Minimum
sound insulation performance of the barrier shall remain at STC-25.
Review of design
documents and in-field
inspections
Before Phase 1 City of Hermosa
Beach
NV-1b The gates on the east and south sides of the site shall be 24-feet high, consistent with the height of the acoustical barrier around the perimeter of the
site. The gates shall have no holes or gaps in them and shall be designed to
deliver a minimum sound insulation performance of STC-25.
Review of design
documents and in-field
inspections
Before Phase
1
City of Hermosa
Beach
NV-1c All acoustical barriers around the site shall offer the following minimum sound
absorption performance: Center Frequency (Hz), 125, 250, 500, 1k, 2k, 4k - Sound Absorption Coefficient, 0.49, 0.72, 0.74, 0.29, 0.21, 0.14.
Review of
design documents and
in-field inspections
Before Phase
1
City of
Hermosa Beach
NV-2a Increase the height of the noise barriers on all sides of the site from 32-feet to 35-feet (35-feet is the maximum height allowed). Minimum sound insulation
performance of the barrier material should be STC-32.
Review of design documents and in-field
inspections
Before Phase 2 City of Hermosa
Beach
NV-2b The gates on the east and south sides of the site shall have no holes or gaps in them and shall be designed to deliver a minimum STC of 32. Any gaps above
the gates must be closed off, by extending the acoustical barrier material from the sides. The intent is to maintain the acoustical integrity of the STC-32 noise
barrier in all locations.
Review of design
documents and in-field
inspections
Before Phase 2 City of Hermosa
Beach
NV-2c All acoustical barriers around the site shall offer the following minimum sound absorption performance: Center Frequency (Hz), 125, 250, 500, 1k, 2k, 4k -
Sound Absorption Coefficient, 0.49, 0.72, 0.74, 0.29, 0.21, 0.14.
Review of design
documents and in-field inspections
Before Phase
2
City of Hermosa
Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
NV-2d Install pads on the V-door and other appropriate areas, timbers and pads on the drill deck, pads between drill and casing pipe while in storage and pad and
timbers at the boards on the mast to reduce metal-on-metal noise.
Review of design
documents and in-field
inspections
Before Phase 2 City of Hermosa
Beach
NV-2e Provide full acoustical enclosures around the mud pumps. The enclosures shall
be factory-assembled by a manufacturer with a proven track-record of building noise-reducing enclosures for industrial applications. The total sound power level radiated by the enclosure shall not exceed 77 dBA, including noise
contributions from: the access door(s), observation windows, ventilation
openings and ventilation fans (if required).
Review of
design documents and in-field
inspections
Before Phase
2
City of
Hermosa Beach
NV-2f Provide enhanced inlet and outlet silencers for the Hydraulic Power Unit enclosure and upgrade the walls, roof and floor of the enclosure as necessary
to limit the total sound power level radiated by the enclosure to 77 dBA.
Review of design
documents and in-field
inspections
Before Phase 2 City of Hermosa
Beach
NV-2g The acoustical shroud around the drilling mast shall be comprised of acoustical blankets material with a minimum STC rating of 25. The acoustical blankets
material shall provide continuous coverage of three sides of the mast and shall
cover the uppermost 26-feet of the fourth side.
Review of design
documents and in-field
inspections
Before Phase
2
City of Hermosa
Beach
NV-2h Provide acoustical treatment within the combustor fan housing and/or at the
ventilation openings, as necessary to limit the total sound power level radiated by the housing (including contributions from the door and ventilation openings)
to 86 dBA.
Review of
design documents and
in-field inspections
Before Phase
2
City of
Hermosa Beach
NV-2i Eliminate use of the combustor during drilling in Phase 2 or prior to the initiation of
production occurring concurrent with drilling in Phase 2, acoustical treatment shall be provided: within the combustor fan housing and/or ventilation openings, as necessary to
limit the total sound power level radiated by the housing (including contributions from the door and ventilation openings) to 86 dBA; and to the combustor stack to limit the power level radiated by the stack to 80 dBA..
Review of
design documents and
in-field
inspections
Before Phase
2
City of
Hermosa
Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
NV-2j During the drilling portion of Phase 2, implement a “Super-Quiet Mode” of operation between the hours of 2AM and 5AM, during which time drilling would
essentially be suspended to minimize noise. Super-Quiet Mode would impose the following additional measures and limitations: no pipe-handling of any kind
anywhere on the project site, shakers switched off, top drive and rig floor completely enclosed on four sides by acoustical blankets material with a
minimum STC rating of 25, operation of the top drive limited to “exercising” the pipe string only, top drive travel limited to the bottom half of the drilling rig mast.
Super-Quiet Mode shall be implemented from the outset of drilling work during Phase 2; however, if monitoring shows consistently that noise emissions for
normal drilling operations (with mitigation measures NV2a through NV2i in place) would result in less-than-significant impact during all or part of the period
between 2AM and 5AM, the Applicant may, at the discretion of the City, be permitted to reduce the hours Super-Quiet Mode operations, or eliminate
Super-Quiet Mode altogether.
Review of design
documents and in-field
inspections
Before Phase 2 City of Hermosa
Beach
NV-3a Increase the height of the noise barriers on all sides of the site from 32-feet to 35-feet (35-feet is the maximum height allowed). Minimum sound insulation
performance of the barrier material should be STC-32.
Review of design
documents and in-field
inspections
Before Phase
2
City of Hermosa
Beach
NV-3b The gates on the east and south sides of the site shall have no holes or gaps in
them and shall be designed to deliver a minimum STC of 32. Any gaps above the gates must be closed off, by extending the acoustical barrier material from
the sides. The intent is to maintain the acoustical integrity of the STC-32 noise barrier in all locations.
Review of
design documents and
in-field inspections
Before Phase
2
City of
Hermosa Beach
NV-3c All acoustical barriers around the site shall offer the following minimum sound absorption performance: Center Frequency (Hz), 125, 250, 500, 1k, 2k, 4k -
Sound Absorption Coefficient, 0.49, 0.72, 0.74, 0.29, 0.21, 0.14.
Review of design documents and in-field
inspections
Before Phase 2 City of Hermosa
Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
NV-3d Provide acoustical treatment within the combuster fan housing and/or at the ventilation openings, as necessary to limit the total sound power level radiated
by the housing (including contributions from the door and ventilation openings) to 86 dBA.
Review of design
documents and in-field
inspections
Before Phase 2 City of Hermosa
Beach
NV-4a Increase the height of the noise barrier on all sides of the site to 24-feet (24-feet
is the maximum feasible height for a noise barrier during Phase 3). Minimum sound insulation performance of the barrier shall remain at STC-25.
Review of
design documents and in-field
inspections
Before Phase
3
City of
Hermosa Beach
NV-4b The gates on the east and south sides of the site shall be 25-feet high,
consistent with the height of the acoustical barrier around the perimeter of the site. The gates shall have no holes or gaps in them and shall be designed to
deliver a minimum sound insulation performance of STC-25.
Review of
design documents and
in-field inspections
Before Phase
3
City of
Hermosa Beach
NV-4c All acoustical barriers around the site shall offer the following minimum sound
absorption performance: Center Frequency (Hz), 125, 250, 500, 1k, 2k, 4k -
Sound Absorption Coefficient, 0.49, 0.72, 0.74, 0.29, 0.21, 0.14.
Review of
design documents and
in-field
inspections
Before Phase
3
City of
Hermosa
Beach
NV-6a Increase the height of the noise barriers on all sides of the site from 32-feet to35-feet (35-feet is the maximum height allowed by zoning code). Minimum
sound insulation performance of the barrier material shall be STC-32.
Review of design
documents and in-field
inspections
Before Phase 4 City of Hermosa
Beach
NV-6b The gates on the east and south sides of the site shall have no holes or gaps in them and shall be designed to deliver a minimum STC of 32. Any gaps above
the gates must be closed off, by extending the acoustical barrier material from the sides. The intent is to maintain the acoustical integrity of the STC-32 noise
barrier in all locations.
Review of design
documents and in-field
inspections
Before Phase
4
City of Hermosa
Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
NV-6c All acoustical barriers around the site shall offer the following minimum sound absorption performance: Center Frequency (Hz), 125, 250, 500, 1k, 2k, 4k -
Sound Absorption Coefficient, 0.49, 0.72, 0.74, 0.29, 0.21, 0.14. In the event that a permanent 35-foot wall is built, the interior surfaces of the wall (i.e. those
facing inwards towards the drilling and production operations) shall be treated with exterior grade acoustical panels offering equivalent sound absorption
performance to that specified in this Measure above a height of 10-feet from the ground.
Review of design
documents and in-field
inspections
Before Phase 4 City of Hermosa
Beach
NV-6d Install pads on the V-door and other appropriate areas, timbers and pads on the drill deck, pads between drill and casing pipe while in storage and pad and
timbers at the boards on the mast to reduce metal-on-metal noise.
Review of design documents and in-field
inspections
Before Phase 4 City of Hermosa
Beach
NV-6e Provide full acoustical enclosures around the mud pumps. The enclosures shall be factory-assembled by a manufacturer with a proven track-record of building
noise-reducing enclosures for industrial applications. The total sound power level radiated by the enclosure shall not exceed 77 dBA, including noise
contributions from: the access door(s), observation windows, ventilation openings and ventilation fans (if required).
Review of design
documents and in-field
inspections
Before Phase 4 City of Hermosa
Beach
NV-6f Provide enhanced inlet and outlet silencers for the Hydraulic Power Unit enclosure and upgrade the walls, roof and floor of the enclosure as necessary
to limit the total sound power level radiated by the enclosure to 77 dBA.
Review of design documents and in-field
inspections
Before Phase 4 City of Hermosa
Beach
NV-6g The acoustical shroud around the drilling rig mast shall be comprised of acoustical blankets material with a minimum STC rating of 25. The acoustical
blankets material shall provide continuous coverage of three sides of the mast and shall cover the uppermost 26-feet of the fourth side.
Review of design
documents and in-field
inspections
Before Phase 4 City of Hermosa
Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
NV-6h During the drilling portion of Phase 4, implement a “Super-Quiet Mode” of operation between the hours of 2AM and 5AM, during which time drilling would
essentially be suspended to minimize noise. Super-Quiet Mode would impose the following additional measures and limitations: no pipe-handling of any kind
anywhere on the project site, shakers switched off, top drive and rig floor completely enclosed on four sides by acoustical blankets material with a
minimum STC rating of 25, operation of the top drive limited to “exercising” the pipe string only, top drive travel limited to the bottom half of the drilling rig mast.
Super-Quiet Mode shall be implemented from the outset of drilling work during Phase 4; however, if monitoring shows consistently that noise emissions for
normal drilling operations (with mitigation measures NV6a through NV6g in place) would result in less-than-significant impact during all or part of the period
between 2AM and 5AM, the Applicant may, at the discretion of the City, be permitted to reduce the hours of Super-Quiet Mode operations, or eliminate
Super-Quiet Mode altogether.
Review of design
documents and in-field
inspections
Before Phase 4 City of Hermosa
Beach
NV-7a Increase the height of the masonry walls on the north and west sides of the site
to a minimum of 27-feet.
Review of design
documents and in-field
inspections
Before Phase
4
City of Hermosa
Beach
NV-7b Apply outdoor acoustical panels to all available surfaces of the north and west
walls that face the production operations above a height of 10-feet above the ground. The purpose of the acoustical panels is to control reflection of
production noise in the direction of the sensitive uses to the east and south. The acoustical panels shall offer the following minimum sound absorption
performance: Center Frequency (Hz), 125, 250, 500, 1k, 2k, 4k - Sound Absorption Coefficient, 0.28, 0.68, 0.95, 0.86, 0.89, 0.72.
Review of
design documents and
in-field inspections
Before Phase
4
City of
Hermosa Beach
NV-7c Well workover rigs shall be powered by electric drive/sources or “ultra-quiet”
generators or engines - either diesel or natural gas-powered - that are capable
of operating below the noise significance thresholds for daytime operation.
Review of
design documents and
in-field
inspections
Before Phase
4
City of
Hermosa
Beach
Exhibit D-3
Table 8-10 Transportation and Circulation
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
TR-1a For Phases 1-3, the Applicant shall fund, through and in consultation with the School District and Safe Routes to School, an afternoon crossing guard to be
stationed at the Project Site area to ensure pedestrians passing nearby the Project Site have assistance in crossing the streets and the entrances/exit of
the Project Site. Alternately, the Applicant shall ensure that trucks do not travel to and from the Project Site unless school is in session (i.e. truck travel
prohibited on Valley Drive after 2:48 p.m., on Wednesdays after 1:45 p.m. or on school minimum days after 12:45 p.m.). The Applicant shall consult with the
School District to ensure timing is current.
Review of contracts and
site inspections
Prior to construction
activities
City of Hermosa
Beach
TR-1b For Phases 1-3, the Applicant shall install, subject to the approval of the City Public Works Department, warning signs and blinking yellow lights one block
north and south (if applicable with possible one-way on Valley Drive) of the Project Site warning vehicle traffic that trucks may be entering and exiting the roadway. Blinking lights shall only operate when trucks are utilizing the
roadway (not 24 hours per day).
Review of design
documents and
site inspections
Prior to construction
activities
City of Hermosa
Beach
TR-1c The Applicant shall ensure that all trucks accessing the Project Site and utilizing the Pier Avenue/Valley Drive intersection are less than 65 feet long to prevent
safety hazards at the double intersection on Pier Avenue between Valley Drive and Ardmore Avenue. If trucks longer than 65 feet are required, then flagger
shall be used at the Pier Avenue and Valley/Ardmore intersection.
Review of contracts and
site inspections
Phase 1-4
Prior to
construction activities
City of Hermosa
Beach
TR-1d For Phases 1-3, the Applicant shall, with the approval and coordination of the City Public Works Department, either 1) restripe Valley Drive south of Pier
Avenue to be a southerly directed one-way street. No on-street parking shall be allowed on Valley Drive between 6th Street and 8th Street to allow for sufficient line of sight for trucks entering and exiting the Project Site; or 2) restripe the section of Valley Drive between 2nd Street and Herondo Street to make it two-
way and direct all truck traffic along Herondo Street to approach the project site
from the south.
Review of design
documents and
site inspections
Prior to pipeline
construction
activities
City of Hermosa
Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
TR-2a Pipeline construction activities within the Pipeline right-of-way shall be limited to weekday between the hours of 9:00 a.m. and 3:00 p.m., unless the applicable
municipality approves a specific exception to the time limit for periods of limited duration, subject to measures required by the municipality to protect the public
health and safety. The Applicant shall coordinate with adjacent jurisdictions throughout the design and construction phase.
Review of design
documents and site inspections
Prior to pipeline
construction activities
Cities of Hermosa
Beach, Redondo
Beach, and Torrance
TR-2b The applicant shall implement a Construction Traffic Management Plan (CTMP) during Pipeline construction that includes the following pursuant to the procedures and subject to approval of the applicable municipality: 1) Require
the Pipeline contractor(s) to obtain and follow street construction permits in the affected areas (Cities of Hermosa Beach, Redondo Beach, and Torrance, and Caltrans facilities - PCH and Hawthorne Boulevard); 2) Develop detour and traffic management plans consistent with the affected City’s standard roadway
plans (e.g., Torrance Street Standard T603), the California Manual of Uniform Traffic Control Devices (MUTCD), or the Work Area Traffic Control Handbook
(WATCH); 3) Revise Pipeline construction schedules to minimize access
impacts to adjacent residents and businesses; and 4) Ensure that all affected residences and business have adequate emergency access during all times and phases of construction. The Applicant shall coordinate with adjacent
jurisdictions throughout the design and construction phase.
Approval of CTMP Prior to pipeline construction
activities
Cities of Hermosa Beach,
Redondo
Beach, and Torrance
TR-3a The applicant shall be prohibited from routing Proposed Oil Project-related
heavy truck exceeding 20,000 pounds on 190th Street between Anza Avenue and PCH, except during Pipeline construction. The Applicant shall comply with
all requirements of the applicable city.
Use of
alternative route
Phases 1-4 Cities of
Hermosa Beach,
Redondo Beach, and
Torrance
TR-3b The applicant shall route inbound and outbound heavy (>20,000 pounds) truck
traffic along PCH and Artesia Boulevard, which are designated truck routes.
Use of alternative
route
Phases 1-4 Cities of Hermosa
Beach, Redondo
Beach, and
Torrance
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
TR-3c Applicant shall supply private parking sufficient to meet all parking demands and shall direct all employees and contractors to park within Applicant’s private
parking areas, or to utilize an alternative parking program approved by the City.
Review of Plans and
onsite inspections
Phase 1-4 City of Hermosa
Beach
TR-4a The City shall design the permanent Proposed City Maintenance Yard so that it does not enter/exit directly onto Valley Drive. Review of Plans Phase 3 City of Hermosa
Beach
TR-4b If the permanent Proposed City Maintenance Yard Project affects the sidewalk, then the design shall incorporate a sidewalk design along Valley Drive which
utilizes a landscape buffer to separate the pedestrians from the street.
Review of Plans Phase 3 City of Hermosa
Beach
Table 8-11 Water Resources
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
WR-1 Prior to approval of demolition and new construction, a Registered Civil Engineer in the State of California shall evaluate the capacity of the existing
sewer line system, beginning at the proposed tie-ins on Valley Drive for the Proposed City Maintenance Yard Project and 6th Street for the Proposed Oil
Project, and continuing downstream to the Sanitation Districts of Los Angeles County sewer system, prior to any connections. A 7-day capacity performance
test shall be performed, based on Sanitation Districts of Los Angeles County average wastewater generation factors, to determine baseline and peak flows,
and to ensure the sewer has adequate capacity in the downstream areas. The capacity analysis shall be submitted to the City Public Works Department and
the Districts for review and approval.
In the event that existing sanitary sewer facilities are insufficient to
accommodate increased flows from the Project Site, the Applicant shall provide mobile sanitary facilities (i.e., toilet, sink, and urinal) for onsite personnel, as
necessary.
Area study of the proposed
sewer line and a 7-day
performance capacity test
should be performed at
select downstream
locations to verify the
adequacy of the existing
sewer.
Prior to issuance of
permit
City of Hermosa
Beach
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
WR-2 Implement MM HWQ-2a through HWQ-2d. See HWQ-2a through HWQ-
2d
See HWQ-2a through HWQ-
2d
See HWQ-2a through
HWQ-2d
WR-3a The Applicant shall complete a site-specific Area of Review/Zone of Endangering Influence analysis, per Division of Oil, Gas, and Geothermal
Resources requirements, to determine if oil and gas wells are present that
might serve as conduits for injected liquids to migrate upward to underground sources of drinking water. In the event that such wells are present, those wells shall be plugged and abandoned such that underground sources of drinking
water (i.e., less than 10,000 mg/L total dissolved solids) are protected.
Plugging and abandonment of those wells shall include zonal isolation plugs outside all casings and shall be completed per current Division of Oil, Gas, and
Geothermal Resources standards.
Coordination with Division of
Oil, Gas, and
Geothermal Resources
Prior to initiation of
injection
operations
City of Hermosa
Beach and
Division of Oil, Gas, and Geothermal
Resources
WR-3b The Applicant shall confine injected fluids into the intended zone of injection in order to adequately protect underground sources of drinking water. Injection
well cement shall be placed at the base of all underground sources of drinking water, and not just at the base of fresh water, to protect water with total
dissolved solids content ranging from 3,000 mg/L to 10,000 mg/L.
Coordination with Division of
Oil, Gas, and Geothermal
Resources
During injection well
drilling and injection
operations
City of Hermosa
Beach and Division of
Oil, Gas, and Geothermal
Resources
WR-3c The Applicant shall complete step-rate tests, using bottom-hole and surface pressure gauges, such that maximum allowable surface injection pressures are
set at a maximum of 95 percent of the fracture pressure of the formation being
injected.
Coordination with Division of
Oil, Gas, and Geothermal
Resources
Prior to injection
operations
City of Hermosa
Beach and Division of
Oil, Gas, and Geothermal
Resources
WR-3d The Applicant shall ensure that the hydrostatic pressure in overlying West
Coast Basin aquifers is not exceeded during injection over the active life of the disposal wells. To ensure that this does not occur, the static reservoir pressure
shall be monitored on a periodic basis, per Division of Oil, Gas, and Geothermal Resources requirements, and injection into the receiving zone shall cease if and
when the hydrostatic pressure is exceeded.
Coordination
with Division of Oil, Gas, and
Geothermal Resources
Prior to
injection operations
City of
Hermosa Beach and
Division of Oil, Gas, and
Geothermal Resources
Exhibit D-3
Proposed Oil Project and Pipeline Mitigation Measures
Mitigation
Measure Requirements
Compliance Verification
Method Timing Responsible Party
WR-3e The Applicant shall meet with Division of Oil, Gas, and Geothermal Resources staff annually to review the status of the waste water injection wells. Any
deficiencies identified by Division of Oil, Gas, and Geothermal Resources staff shall be immediately rectified by the Applicant.
Coordination with Division of
Oil, Gas, and Geothermal
Resources
Annually following
initiation of Phase 2
City of Hermosa
Beach and Division of
Oil, Gas, and Geothermal
Resources
1
AN ORDINANCE OF THE CITY OF HERMOSA
BEACH AMENDING THE HERMOSA BEACH
COASTAL LAND USE PLAN (PART OF THE
CITY’S GENERAL PLAN) AND MUNICIPAL
CODE TO ALLOW AN OIL DEVELOPMENT
PROJECT AT 555 6TH STREET (CITY
MAINTENANCE YARD) AND REPEALNG A
RESTRICTION ON THE USE OF PROJECT
ROYALTIES, AMENDING THE OIL
PRODUCTION CODE, AWARDING A PIPELINE
FRANCHISE FOR OIL AND GAS, AND
APPROVING A DEVELOPMENT AGREEMENT
WITH E&B NATURAL RESOURCES
MANAGEMENT CORPORATION AND MAKING
CEQA FINDINGS
The People of the City of Hermosa Beach hereby ordain as follows:
Section 1. The People of the City of Hermosa Beach do hereby find as follows:
A. The purpose of this Ordinance is to modify City law in order to allow an oil
drilling and production project (“Project”) to be developed by E&B Natural
Resources Management Corporation (“E&B”) on City-owned land located at
555 6th Street (the City maintenance yard) in accordance with Oil and Gas
Lease No. 2 (the “lease”) entered into in January, 1992 between the City and
Macpherson Oil Company (“Macpherson”), E&B’s predecessor-in-interest.
B. This Ordinance proposes to: 1) amend the Hermosa Beach Coastal Land Use
Plan (part of the City’s General Plan) to change the land use designation for
the City Maintenance Yard and to adopt energy policies consistent with
E&B’s Project; 2) amend various provisions of the City’s Municipal Code to
allow E&B’s Project to proceed, but continue to prohibit oil drilling elsewhere
in the City, and to remove the restriction on the City’s use of Project royalties;
3) approve a Development Agreement between the City and E&B in order to
provide E&B with a statutory vested right to proceed with its Project and to
set forth all conditions of approval and mitigation measures that will govern
the Project; 4) approve an oil pipeline franchise allowing E&B to construct
and operate subterranean pipes for the transmission of oil and gas from the
drill site to a location outside the City; and 5) adopt a legally-required
statement that the Project is the most desirable, feasible alternative and that its
benefits outweigh its significant unavoidable impacts.
2
Section 2. The matrix set forth in Section 17.28.020 of Title 17, Chapter 17.28 of the
Hermosa Beach Municipal Code is amended by adding the following new category in
alphabetical order:
Oil and gas production and processing P 17.42.140
Section 3. Section 17.28.030(D) of Title 17, Chapter 17.28 of the Hermosa Beach
Municipal Code is amended to read as follows:
D. Building Height. Any building may have a maximum of thirty-five (35) feet in
height and have a maximum of two stories. Oil and gas operations may exceed this
height for a temporary period of time to a height as set forth in an approved Development
Agreement.
Section 4. A new section 17.42.140 is added to Title 17, Chapter 17.42 of the
Hermosa Beach Municipal Code to read as follows:
17.42.140 Oil and Gas Production and Processing.
Oil production and processing is permitted on City-owned property located at 555
6th Street in the M-1 Zone subject to approval of a Development Agreement. No precise
development plan is required.
Section 5. Section 5.56.010 of Title 5, Chapter 5.56 of the Hermosa Beach Municipal
Code is amended to read as follows:
5.56.010 Oil Drilling.
Except as provided in Sections 17.28.020 and 17.42.140, the drilling, boring or otherwise
sinking of an oil or gas well, or oil or gas wells, or the maintenance, pumping or
operation of any oil well or oil wells or gas well or gas wells in the City is declared to be
a nuisance and is declared to be unlawful. Except as provided in Sections 17.28.020 and
17.42.140, it is unlawful for any person to drill, bore or otherwise sink or maintain, pump
or operate or cause to be drilled, bored or otherwise sunk, or maintained, pumped or
operated, or to aid in the drilling, boring or otherwise sinking, or maintaining, pumping or
operating of any gas or oil well or wells for the purpose of procuring oil, gas or other
hydrocarbon substances within any portion of the City. Except as provided in Sections
17.28.020 and 17.42.140, it is unlawful for any person to commence the construction or
to construct or maintain any derrick, or any oil well apparatus in the City for the purpose
of drilling for or maintaining any oil or gas well in the City.
Section 6. Section 5.56.020 of Title 5, Chapter 5.56 of the Hermosa Beach Municipal
Code is hereby repealed.
3
Section 7. The Hermosa Beach Coastal Land Use Plan, part of the City’s General
Plan, is amended to add a new chapter entitled Coastal Industrial (Oil and Gas)
Development as set forth in Attachment A to this ordinance and incorporated herein by
reference. In the event that the Coastal Commission proposes modifications to the
amendment, such modifications will be incorporated into the Hermosa Beach Coastal
Land Use Plan without a further vote of the electorate provided they are consistent with
the Lease and the Settlement Agreement entered into by and between the City,
Macpherson, and E&B dated March 2, 2012.
Section 8. Title 21 Oil Production Code of the Hermosa Beach Municipal Code is
amended as follows:
A. Sec. 21A-1.20 Definition of “Grade” is amended to read as follows:
“Grade” (adjacent ground elevation) means the lowest point of elevation of
the finished surface level of the ground, paving or sidewalk, excluding
excavations for well cellars and storage tanks within the enclosed area of the
privacy wall and for the privacy wall described in Section 21A-2.9(C). For the
purpose of determining the height of privacy walls and other structures for oil
projects, this definition supersedes the definition of grade in Chapter 17.04
and Section 17.46.130 of Title 17 of the Municipal Code.
B. Sec. 21A-2.10(E) Process Operations is amended to read as follows:
E. Process Operations. No process operations shall be permitted at any well
site excluding oil and gas processing and treatment activities involving the
chemical separation of oil and gas constituents and the removal of impurities.
Processing activities would include oil stripping; hydrogen sulfide and carbon
dioxide removal systems; depropanizers, debutinizers, or other types of
fractionation; sulfur recovery; wastewater treatment; and separation and
dehydration of oil/gas/water.
Section 9. The Hermosa Beach Coastal Land Use Plan - Land Use Map (Appendix J),
part of the City’s General Plan, is amended to modify the designation for the project site
at 555 6th Street in Hermosa Beach from Open Space to Industrial (IND), as set forth in
Attachment B to this ordinance. In the event that the Coastal Commission proposes
modifications to the amendment, such modifications will be incorporated into the Coastal
Land Use Plan without further vote of the electorate provided they are consistent with the
Lease and Settlement Agreement entered into by and between the City, Macpherson, and
E&B dated March 2, 2012.
4
Section 10. An application for a Development Agreement was filed in accordance with
Hermosa Beach Municipal Code Chapter 17.64 and California Government Code section
65864 et seq. on November 14, 2012 by E&B Natural Resources Management
Corporation to develop an oil production and processing project on a City-owned parcel
located at 555 6th Street pursuant to the lease, City Council Resolution No. 93-5632
(Conditional Use Permit) and the Settlement Agreement entered into by and between the
City, Macpherson and E & B dated March 2, 2012. The application was deemed
complete on April 18, 2013.
A. A public hearing was duly noticed for consideration by the Planning
Commission meeting on June 23, 2014. At that meeting the Commission
reviewed the staff report, considered all the pertinent testimony, and adopted a
resolution (No. 14-9) making its recommendations to the City Council.
B. A duly noticed public hearing was conducted by the City Council on______,
2014 at which the Council considered all pertinent testimony and adopted
Resolution No. _____ incorporating the Development Agreement into this
ordinance to be considered by the electorate.
C. The People of the City of Hermosa Beach hereby find and declare:
1. With approval of the Coastal Land Use Plan amendments and zoning
ordinance and other Municipal Code text amendments proposed in this
ordinance, the Development Agreement is consistent with all
applicable provisions of the General Plan and the Municipal Code.
2. The Development Agreement contains all the mandatory provisions
required and permissive content allowed by Government Code Section
§65865.2.
D. Based on the above findings, the People of the City of Hermosa Beach hereby
approve the Development Agreement, which is attached hereto as Attachment
C to this ordinance and incorporated herein by reference.
E. The City Manager is authorized to execute the Development Agreement and
fill in the blanks in the introductory sections and in the signature blocks.
F. In the event that the Coastal Commission proposes any modifications to the
Development Agreement pursuant to Government Code section 65869, such
modifications will be automatically incorporated into the Development
Agreement without a further vote of the electorate provided they are
5
consistent with the Lease and the Settlement Agreement entered into by and
between the City, Macpherson and E&B dated March 2, 2012.
G. The Development Agreement may be amended by mutual agreement of City
and E&B as provided for in the terms of the Development Agreement and
without further vote of the electorate provided the amendment is not
inconsistent with or as may be necessary to implement the Project.
Section 11. An oil and gas pipeline franchise is hereby granted to E&B Natural
Resources Management Corporation for placement of pipelines to serve its oil
production facility at 555 6th Street as set forth and described in the Project Description
contained in Exhibit B to the Development Agreement. The location of the pipelines
approved by this franchise shall be as described in the map attached hereto as
Attachment D to this ordinance and incorporated herein by reference (limited to the
portion of the pipeline shown within the territorial boundaries of the City of Hermosa
Beach), specifically for the placement of oil and gas pipelines constructed underground
in the right of way of Southbound Valley Drive to the City of Hermosa Beach border
with Redondo Beach at Herondo Street. Construction of the pipeline authorized by this
franchise shall be preceded by approval by the City, which approval shall not be
unreasonably denied, of a ministerial encroachment permit setting forth appropriate
conditions as required by the Municipal Code and implementing the mitigation
measures set forth in the Final Environmental Impact Report (“EIR”) and incorporated
in the Development Agreement. The term of this franchise shall be co-terminus with
the term of the lease. The franchise fee shall be subsumed by the royalties to be paid to
the City as provided in the lease.
Section 12. Pursuant to the requirements of the California Environmental Quality Act
(“CEQA”), Public Resources Code section 21000 et seq. and the Guidelines
promulgated thereto in 14 Cal. Code Regs section 15000 et seq., the People find as
follows:
A. As contemplated in the Settlement Agreement entered into by and between the
City, Macpherson, and E&B dated March 2, 2012, the City caused to be
prepared an EIR evaluating the environmental impacts of the discretionary
approvals approved by this ordinance. The City Council reviewed and
considered the Final EIR and certified on July 8, 2014 that the Final EIR was
prepared in accordance with the requirements of CEQA, reflects the
independent judgment of the City Council, and constitutes an accurate and
complete statement of the environmental impacts of the proposed project.
B. The record for the Project demonstrates that the Applicant incorporated design
features and operational practices into the Project that implement the modern
technology and operational advancements related to air quality, odors, noise,
6
hazards, and water quality to reduce the potential impacts on the adjacent
community and the environment.
C. The record for the Project demonstrates that changes or alterations have been
required in the Project that, to the extent feasible, substantially lessen some of
the significant environmental effects identified in the Final EIR. The Final
EIR recommends imposition of various mitigation measures to mitigate the
significant adverse environmental impacts expected to be caused by the
Project. Those mitigation measures have been incorporated into the Project
entitlements in the Development Agreement and are implemented by way of a
Mitigation Monitoring and Reporting Program set forth in Exhibit D-3 to the
Development Agreement.
D. The EIR identifies significant adverse environmental impacts that cannot be
mitigated to a level of insignificance, significant impacts that can be mitigated
to a level of insignificance, and impacts that would be less than significant.
Those impacts are summarized below:
Aesthetics and Visual Resources
An 87-foot electric drill rig with three-sided acoustical shield would be
installed at the Project Site at the beginning of Phase 2 for about 4 months,
then during Phase 4 for 30 months, then periodically thereafter for re-drills for
up to an maximum average of 30 days per year or a maximum of 150 days
once every 5 years. The rig would introduce, primarily into the foreground
and middleground environments, a visually dominant vertical feature which is
distinct in form, mass, height, material and character from structures in the
viewshed of locations which are considered to have high sensitivity. The
effects of light, shade and shadow would produce contrasting geometric
vertical planes and would project into a typically uniform (or otherwise
naturally varied) sky backdrop.
Night views of the open (illuminated) side of the drill rig, with the pattern and
scale of this illuminated feature, would be out of character with existing
nighttime views. Similar to day time impacts, this vertical feature would
project above the horizontal plane of the existing illuminated environment and
would become a focal element. The duration of exposure, number of sensitive
viewers, and nature of the visual change would result in impacts that would be
significant. During periods of Phase 4, a 110-foot workover rig could be
present on site for up to 90 days per year. The open truss structure of the
workover drill rig introduces a focal element of industrial character into
viewsheds of primarily residential and light industrial character. The
workover rig would not operate at night (after 6 pm).
7
The mitigation measures provided in the Final EIR reduce these impacts to the
extent feasible. However, these impacts (with the drill rig or workover rig on
the Project Site) have the potential to remain significant adverse impacts after
mitigation. The Mitigation measures include: the selection of colors and
materials for the drill rig acoustical cover that are of a neutral sky color and
fully opaque; the installation of a permanent 35-foot wall at the end of Phase 3
to provide for the stability of views and opportunities for positive visual
elements (i.e., articulations of the façade) for the duration of Phase 4;
landscape plantings installed at the end of Phase 3 that respond to the design
of the walls; and the selection of colors and finishes and lighting to minimize
glare and reflectivity.
The impacts when the drill rig or workover rig are not present on the project
site would be less than significant with mitigation.
Air Quality and Odors
Due to the close proximity of the Project site to neighbors, businesses and the
public (within 100 feet of businesses, 160 feet of residences, 55 feet of the
Greenbelt and 20 feet of the public sidewalks), certain scenarios could cause
odors offsite. These could include various maintenance activities such as line,
tank or vessel openings; workovers removing well hole equipment (pumps or
tubing), thereby exposing the well equipment to the atmosphere; minor
accident scenarios; and drilling activities including muds handling that could
cause short-duration, intermittent odors, or pump leaks. Because odor
thresholds for certain compounds found in the oil and gas industry are very
low, in the parts per billion range, release of these compounds can cause odor
impacts off-site. Therefore, due to the close proximity of neighbors, odor
impacts could impact surrounding areas and would be a significant impact.
The Mitigation measures provided in the Final EIR reduce the potential
impacts related to odors to the extent feasible. However, the impacts related
to odors have the potential to remain significant adverse impacts after
mitigation. The mitigation measures proposed that would reduce the
frequency of odor events include: the implementation of systems that direct
odor-causing releases to flare-type systems; the implementation of a
compressor seal vent collection system; implementation of an Odor
Minimization Plan and an Air Monitoring Plan that include buffer areas,
signage, monitoring, and alarms when certain levels of H2S and hydrocarbons
are reached as well as notification protocol and remedies if releases occur; the
use of an odor suppressant system; and increased vigilance associated with
South Coast Air Quality Management District (SCAQMD) Rule 1173 (related
to controlling "leaker" components) to further reduce emissions from fugitive
components that could cause odors.
The air quality impacts related to construction and long-term operational
8
emissions, health risk, and greenhouse gas (GHG) emissions would be less
than significant with mitigation.
Biological Resources
Oil spills and ruptures from the installed off-site oil pipelines could result due
to geologic hazards, mechanical failure, structural failure, corrosion, or human
error during operations. During a storm event, a spill of crude oil from the
pipeline near the corner of Herondo Street and Valley Drive could be directed
into the storm drain system, which from that point drains about 1,500 feet
through storm drain piping onto the beach, near the high tide line. The
amount of oil that would enter the ocean would depend on how much sand
was on the beach at that particular time. This would have the potential to
result in impacts to the numerous sensitive habitats and species present in the
Pacific Ocean. Oil spills and cleanup activities could potentially result in
impacts to biological resources. Direct impacts on wildlife from oil spills
include physical contact with the oil, ingestion of oil, and loss of food and
critical nesting and foraging habitats.
The mitigation measures provided in the Final EIR reduce the potential
impacts to biological resources to the extent feasible. However, these impacts
have the potential to remain significant adverse impacts after mitigation. The
mitigation measures include development of an Emergency Response Plan in
compliance with the California State Oil Spill Contingency Pan. The plan
shall include provisions for containment and cleanup measures and
responsibilities. In addition, the Final EIR provides for mitigation measures
for potential impacts to Hydrology and Water Quality discussed below,
including implementing infrastructure preventative maintenance, conducting
structural integrity tests, and routine inspections, would reduce the likelihood
and severity of potential oil spills and exposure impacts to sensitive biological
resources; but, impacts would remain significant and unavoidable. The fully
enclosed drain systems proposed by E&B for the Project site would retain any
spills on-site. Therefore, potential spills at the Project Site would not result in
a significant impact to biological resources.
Hydrology and Water Quality
As described for Biological Resources above and in the Final EIR, during a
storm event, a release from the off-site pipeline near the corner of Herondo
Street and Valley Drive could produce a worst-case oil spill of 16,000 gallons
that could drain directly into subsurface soils and/or to the ocean through
storm drains. The probability for this impact to occur during a 0.50 inch rain
event would be reduced from 0.40% to 0.087% over the Project life time after
applying the mitigation measures described below.
The mitigation measures provided in the Final EIR related to Biological
Resources and Hydrology and Water Quality would reduce the potential
9
impact to water quality to the extent feasible. However, this impact to water
quality has the potential to remain a significant adverse impact after
mitigation. The mitigation measures, in addition to the measures listed above
for Biological Resources, include implementing infrastructure preventative
maintenance (i.e., smart-pigging) and routine visual inspections, the
installation of a leak detection system and check valve into the crude oil
pipeline at Herondo Street, the installation of an oil separator in storm drain
systems of Herondo Street, and the use of pipeline design measures , which
include the use of impact resistant coating, the installation of a slurry above
the pipe to the base of the pavement or ground surface, and the laying of strips
of warning tape over the top of the pipeline to prevent third-party damage.
These mitigation measures would reduce the frequency or severity of an oil
spill reaching the ocean; but, impacts would remain significant and
unavoidable.
Land Use
The drilling, construction, and potential future operations would be in close
proximity to land uses zoned as open space (parks, baseball fields and the
Greenbelt) and residential. Project activities during all phases may generate
significant noise, odor, and visual impacts that have the potential to be
incompatible with these adjacent land uses.
The mitigation measures provided for Noise and Vibration below would
reduce the potential noise impacts during the concurrent drilling and
production, as well as production only, in Phases 2 and 4 to a less than
significant level. The mitigation measures in the Final EIR provided above
for odors and aesthetics and below for noise during demolition and
construction would reduce the land use compatibility impacts to the extent
feasible. However, the land use impacts have the potential to remain
significant adverse impacts after mitigation.
Noise and Vibration
The predicted noise impact during demolition and construction activities in
Phase 1 and 3 of the Project has the potential to be significant at the homes to
the northwest and west of the Project Site where Project-related noise could
result in an increase in daytime noise levels over existing noise levels.
The mitigation measures provided in the Final EIR reduce the potential noise
impacts to the extent feasible. However, these impacts during demolition and
construction have the potential to remain significant adverse impacts after
mitigation. The mitigation measures include the provision of 24-foot high
noise barriers along the project perimeter and gates at the access points to the
project site with all acoustical barriers required to meet the specified
performance standards.
10
Predicted noise impacts during the concurrent drilling and production in Phase
2 and Phase 4 drilling stages and during Phase 4 re-drills would be reduced to
less than significant with mitigation. Noise levels when drilling is not
occurring during Phase 4 would be less than significant. During re-drills,
noise levels would be the same as those during drilling and, therefore, less
than significant after mitigation. Predicted noise levels due to increases in
traffic would be less than significant. Predicted vibration impacts would be
less than significant after mitigation.
Recreation
As discussed for Biological Resources and Hydrology and Water Quality
above, during a rain event, a potential oil spill from the oil pipeline near the
corner of Valley Drive and Herondo Street could drain directly into the storm
drains and flow to the ocean. An oil spill along the coastline could affect
beach areas, leading to beach closures and boating restrictions in
contaminated areas during and potentially after cleanup. Public perception of
the recreational quality of the areas beaches (Hermosa, Manhattan, Redondo,
etc.) could also be affected, causing a reduction in beach recreational activities
for a substantial period of time.
The mitigation measures provided for Biological Resources and Hydrology
and Water Quality would reduce the frequency and severity of an oil spill
reaching the ocean to the extent feasible. However, the impacts have the
potential to remain significant adverse impacts after mitigation.
Safety, Risk of Upset, and Hazards
The potential for a blowout to result from drilling activities could produce off-
site risks if they encounter pressurized areas of the reservoir. Although it is
not known at this time which reservoir areas, if any, are pressurized to the
extent that pressures could produce a blowout, historical data from drilling in
Redondo Beach indicates that such potential does exist. Pressurization once
the wells are placed into production (after drilling) would last for only a short
period of time (estimated at 30 days based on the Redondo Beach wells), but
could still result in a blowout during drilling. E&B indicated in the Planning
Application that wells would be pressurized for a short period after drilling.
The mitigation measures provided in the Final EIR reduce the potential
impacts related to a well blowout during drilling to the extent feasible.
However, these impacts during drilling have the potential to remain
significant adverse impacts after mitigation. E&B proposed design features,
including the use of an off-shore equivalent-style blow out preventer
equipment (BOPE), venting to a flare, and non-cascading shutdown systems
that would be incorporated into the design of the Project to address this
potential impact. In addition, the mitigation measures provided in the Final
11
EIR would include: preparation of an independent third-party audit with all
audit items implemented immediately and the audit updated annually; and the
design of crude oil spill containment areas as Class Division I areas according
to NFPA and NEC or the isolation of spark producing equipment from the
containment area.
The potential for risks from a pipeline rupture would be less than significant
with mitigation. The potential for impacts from risks associated with spark-
producing equipment resulting in the chances of igniting a crude oil spill
would be reduced to less than significant with mitigation. In addition,
the potential for risks during operations without drilling would be a less than
significant impact.
E. As to the significant adverse environmental impacts that cannot be mitigated
to a level of insignificance, the People hereby adopt the following findings
and statement of overriding considerations:
The EIR examined alternatives to the proposed Project. Although the No
Project/No Development Alternative is considered environmentally superior,
the alternative does not achieve any of the project objectives. Of the other
alternatives considered, the next best alternative is the AES Site, which
reduces the greatest number of the Project’s significant and unavoidable
impacts to less than significant with mitigation. Nevertheless, use of the AES
site also does not meet most of the project objectives to the extent the
objectives are tailored for the City Yard site and the 1993 Conditional Use
Permit for that site and the March 2012 Settlement Agreement. The use of the
AES site also has a number of potential legal and land use issues, related to
Redondo Beach Charter Article 27 and would most likely require a vote of the
people of Redondo Beach and a re-zoning. These issues are similar to those
presented by the Proposed Project. The EIR recognizes that while both the
Proposed Project and the AES Site Alternative have similar challenges, E&B
has no control over the AES site. Due to these considerations, it cannot be
considered a feasible alternative. After examining the alternatives, adoption
and implementation of the Proposed Project is the most desirable, feasible,
and appropriate action.
The development agreement includes all feasible mitigation measures as part
of the Mitigation Monitoring and Reporting Program and significant
conditions of approval for the Project in Exhibit D to the Development
Agreement. Even with implementation of those mitigation measures, the
Final EIR and the record of proceedings for the Project identify potentially
significant and unavoidable environmental impacts from the Project in the
areas of Aesthetics and Visual Resources (with drill rig and workover rig on-
site), Air Quality (odors), Biological Resources (from potential off-site oil
12
pipeline rupture), Hydrology and Water Quality (water quality from potential
off-site oil pipeline rupture), Land Use, Noise (construction and demolition),
Recreation (from potential off-site pipeline rupture), and Safety, Risk of Upset
and Hazards (from potential well blowout during drilling).
The proposed project would provide public benefits described below.
[PUBLIC BENEFITS LISTED IN FINAL DEVELOPMENT AGREEMENT
TO BE INSERTED IN FINAL ORDINANCE]
1) Remedial Action Plan: E&B will pay the entire cost of soils and
groundwater remediation of the maintenance yard should the oil ban be lifted
and the project move forward to Phase III – Final Design and Construction.
2) Temporary and Permanent Relocation of City Maintenance Yard: E & B
will pay the following amounts towards temporary and permanent relocation
of the maintenance yard in lieu of the amounts called for in Section 13 of the
lease:
Temporary relocation:
Permanent relocation:
3) Timing of Revenues:
After balancing these specific economic, legal, social, technological, and other
benefits of the proposed project, the voters of the City of Hermosa Beach have
hereby determined that the significant and unavoidable adverse environmental
impacts identified may be considered acceptable in light of the benefits listed
above which offset these unavoidable, adverse environmental impacts that
will be caused by the Project. Having adopted all feasible mitigation
measures and recognized all unavoidable significant impacts, each of the
separate benefits of the proposed project, as stated herein, is hereby
determined to be unto itself an overriding consideration, independent of other
benefits, that warrants approval of the proposed Project and outweighs and
overrides its unavoidable significant effects, and thereby justifies the approval
of the E&B Oil Project.
Based on the foregoing findings and the information contained in the record, it
is hereby determined that:
a. All significant Cultural Resources, Energy, Environmental Justice, Fire
Protection and Emergency Response, Geology and Soils, Noise impacts
during drilling and production, Public Services, Transportation/Traffic, and
13
Water Resources effects on the environment due to approval of the Project
have been eliminated or substantially lessened where feasible;
and
b. Any remaining significant Aesthetic and Visual Resources (with drill rig
and workover rig on-site), Air Quality (odors), Biological Resources (from
potential off-site oil pipeline rupture), Hydrology and Water Quality (water
quality from potential off-site oil pipeline rupture), Land Use, Noise
(construction and demolition), Recreation, and Safety, Risk of Upset, and
Hazards (from potential well blowout during drilling) effects on the
environment found to be unavoidable are acceptable due to the factors
described above. Thus on balance, the economic and other benefits accruing
to the City and the community from the Project outweigh the risk of potential
impacts to the community.
Section 13. If any provision of this ordinance, or the application of any such provision
to any person or circumstances, shall be held invalid, the remainder of this ordinance to
the extent it can be given effect, or the application of those provisions to persons or
circumstances other than those as to which it is held invalid, shall not be affected
thereby, and to this end the provisions of this ordinance are severable. The people
hereby declare that they would have adopted each section, subsection, sentence, clause,
phrase, or portion of this Ordinance, irrespective of the fact that any one or more
sections, subsections, sentences, clauses, phrases, or portions of this Ordinance be
declared invalid or unenforceable.
Section 14. This Ordinance shall be considered adopted immediately upon the date
that this Ordinance is confirmed and approved by the voters of Hermosa Beach at the
Special Municipal Election of March 3, 2014 and shall become effective on March 13,
2014.
Section 15. The City Manager is hereby directed to submit to the California Coastal
Commission the amendment to the Hermosa Beach Coastal Land Use Plan, part of the
City’s General Plan, and the Development Agreement adopted herein.
PASSED, APPROVED AND ADOPTED by the People of the City of Hermosa Beach
at a special municipal election on March __, 2015.
14
BALLOT ORDINANCE
ATTACHMENT A
Amendment to the City of Hermosa Beach Coastal Land Use Plan
Amend the Coastal Land Use Plan by adding a new section titled “Coastal
Industrial (Oil and Gas) Development” as follows:
COASTAL INDUSTRIAL (OIL AND GAS) DEVELOPMENT
A. Statement of Philosophy
The City of Hermosa Beach recognizes that while emphasizing protection,
enhancement, and restoration of coastal resources is critical to the achievement
of community goals, certain types of industrial and energy developments, such
as oil and gas, may be appropriate in the coastal zone when consistent with the
Coastal Act and policies established by this plan, as well as relevant initiatives
passed by the voters of the City of Hermosa Beach.
In November 1995, the Hermosa Beach electorate passed Proposition E, an
initiative that re-established a citywide ban on any oil or gas well or wells for the
purpose of procuring oil, gas or other hydrocarbon substances. On __________,
Measure ___ adopting Ordinance ________ was passed by the electorate
allowing an Oil and Gas Development Project proposed by E&B Natural
Resources Management Corporation on a 1.3 acre City-owned property at 555
6th Street in Hermosa Beach. The ban on oil and gas development otherwise
remains in effect within the City.
Until the City has a certified Local Coastal Program, the legal standard of review
for consideration of a coastal development permit by the Coastal Commission is
whether a proposed project is consistent with the Chapter 3 policies of the
Coastal Act, will not prejudice the City’s ability to prepare a Local Coastal
Program, and is consistent with the requirements of the California Environmental
Quality Act.
B. Coastal Act Policies
Coastal-Dependent and Coastal-Related Development Criteria
The Coastal Act policies which guide industrial development distinguish between
coastal-dependent development, coastal-related development, and other types of
15
industrial developments. According to Section 30101 and 30101.3 of the Act:
30101. “Coastal-dependent development or use” means any development or
use which requires a site on, or adjacent to, the sea to be able to function at
all.
30101.3 “Coastal-related development” means any use that is dependent on
a coastal-dependent development or use.
The exploration, development and production of oil and gas reserves located
offshore may qualify as a coastal-dependent development. However, not all
activities or facilities associated with such developments are necessarily coastal-
dependent uses. Processing and storage facilities that support development of
offshore oil and gas reserves may not require a site on or adjacent to the sea or
within the coastal zone within the meaning of Section 30101. Such facilities may
therefore be considered coastal-related developments. Whether or not
exploration, development and production of offshore or onshore oil and gas and
its associated facilities is appropriate in the coastal zone is a determination to be
made on a case-by-case basis.
Under Section 30255 of the Act, coastal-dependent developments or uses,
whether industrial or not, are given priority over other development on or near the
shoreline:
Coastal-dependent developments shall have priority over other developments
on or near the shoreline. Except as provided elsewhere in this division,
coastal-dependent developments shall not be sited in a wetland. When
appropriate, coastal-related developments should be accommodated within
reasonable proximity to the coastal-dependent uses they support.
In addition, Section 30260 of the Act establishes special criteria for allowing
coastal-dependent industrial facilities:
Coastal-dependent industrial facilities shall be encouraged to locate or
expand within existing sites and shall be permitted reasonable long-term
growth where consistent with this division. However, where new or expanded
coastal-dependent industrial facilities cannot feasibly be accommodated
consistent with other policies of this division, they may nonetheless be
permitted in accordance with this section and Sections 30261 and 30262 if (1)
alternative locations are infeasible or more environmentally damaging; (2) to
do otherwise would adversely affect the public welfare; and (3) adverse
environmental effects are mitigated to the maximum extent feasible.
This section anticipates that coastal-dependent industrial and energy
development may not be consistent with the Chapter 3 policies of the Coastal
16
Act, yet it may be necessary for the public welfare. Accordingly, Section 30260
allows the permitting of coastal-dependent oil and gas development that is not
consistent with the Chapter 3 policies, provided that the proposed development
complies with provisions of the Coastal Act in Sections 30261 and 30262.
Specific sections of the Coastal Act that address energy (oil and gas)
development are:
Coastal Act, Section 30250(a) and (b) state in part:
(a) New residential, commercial, or industrial development, except as
otherwise provided in this division, shall be located within, contiguous with, or
in close proximity to, existing developed areas able to accommodate it or,
where such areas are not able to accommodate it, in other areas with
adequate public services and where it will not have significant adverse
effects, either individually or cumulatively, on coastal resources. In addition,
land divisions, other than leases for agricultural uses, outside existing
developed areas shall be permitted only where 50 percent of the usable
parcels in the area have been developed and the created parcels would be no
smaller than the average size of surrounding parcels.
(b) Where feasible, new hazardous industrial development shall be
located away from existing developed areas.
Section 30108 (definitions) defines feasible:
"Feasible" means capable of being accomplished in a successful manner
within a reasonable period of time, taking into account economic,
environmental, social, and technological factors.
Section 30262 excluding parts (a)(3) and (a)(4) provides guidance for oil and gas
development:
(a) Oil and gas development shall be permitted in accordance with Section
30260, if the following conditions are met:
(1) The development is performed safely and consistent with the geologic
conditions of the well site.
(2) New or expanded facilities related to that development are
consolidated, to the maximum extent feasible and legally permissible, unless
consolidation will have adverse environmental consequences and will not
significantly reduce the number of producing wells, support facilities, or sites
required to produce the reservoir economically and with minimal
environmental impacts.
(5) The development will not cause or contribute to subsidence hazards
unless it is determined that adequate measures will be undertaken to prevent
damage from such subsidence.
17
(6) With respect to new facilities, all oilfield brines are reinjected into oil-
producing zones unless the Division of Oil and Gas, Geothermal Resources
of the Department of Conservation determines to do so would adversely
affect production of the reservoirs and unless injection into other subsurface
zones will reduce environmental risks. Exceptions to reinjections will be
granted consistent with the Ocean Waters Discharge Plan of the State Water
Resources Control Board and where adequate provision is made for the
elimination of petroleum odors and water quality problems.
(7)(A) All oil produced offshore California shall be transported onshore by
pipeline only. The pipelines used to transport this oil shall utilize the best
achievable technology to ensure maximum protection of public health and
safety and of the integrity and productivity of terrestrial and marine
ecosystems.
(B) Once oil produced offshore California is onshore, it shall be
transported to processing and refining facilities by pipeline.
(C) The following guidelines shall be used when applying subparagraphs
(A) and (B):
(i) "Best achievable technology," means the technology that
provides the greatest degree of protection taking into consideration both of
the following:
(I) Processes that are being developed, or could feasibly be
developed, anywhere in the world, given overall reasonable expenditures on
research and development.
(II) Processes that are currently in use anywhere in the
world. This clause is not intended to create any conflicting or duplicative
regulation of pipelines, including those governing the transportation of oil
produced from onshore reserves.
(ii) "Oil" refers to crude oil before it is refined into products,
including gasoline, bunker fuel, lubricants, and asphalt. Crude oil that is
upgraded in quality through residue reduction or other means shall be
transported as provided in subparagraphs (A) and (B).
(iii) Subparagraphs (A) and (B) shall apply only to new or expanded
oil extraction operations. "New extraction operations" means production of
offshore oil from leases that did not exist or had never produced oil, as of
January 1, 2003, or from platforms, drilling island, subsea completions, or
onshore drilling sites, that did not exist as of January 1, 2003. "Expanded oil
extraction" means an increase in the geographic extent of existing leases or
units, including lease boundary adjustments, or an increase in the number of
well heads, on or after January 1, 2003.
(iv) For new or expanded oil extraction operations subject to clause
(iii), if the crude oil is so highly viscous that pipelining is determined to be an
infeasible mode of transportation, or where there is no feasible access to a
pipeline, shipment of crude oil may be permitted over land by other modes of
transportation, including trains or trucks, which meet all applicable rules and
regulations, excluding any waterborne mode of transport.
18
(8) If a state of emergency is declared by the Governor for an emergency
that disrupts the transportation of oil by pipeline, oil may be transported by a
waterborne vessel, if authorized by permit, in the same manner as required
by emergency permits that are issued pursuant to Section 30624.
(9) In addition to all other measures that will maximize the protection of
marine habitat and environmental quality, when an offshore well is
abandoned, the best achievable technology shall be used.
b) Where appropriate, monitoring programs to record land surface and
near-shore ocean floor movements shall be initiated in locations of new large-
scale fluid extraction on land or near shore before operations begin and shall
continue until surface conditions have stabilized. Costs of monitoring and
mitigation programs shall be borne by liquid and gas extraction operators
c) Nothing in this section shall affect the activities of any state agency that
is responsible for regulating the extraction, production, or transport of oil and
gas.
Section 30232 requires protection against oil and hazardous substance spills:
Protection against the spillage of crude oil, gas, petroleum products, or
hazardous substances shall be provided in relation to any development or
transportation of such materials. Effective containment and cleanup facilities
and procedures shall be provided for accidental spills that do occur.
In Section 30265(a) the California legislature finds with regard to offshore oil
transportation:
(a) Transportation studies have concluded that pipeline transport of oil is
generally both economically feasible and environmentally preferable to other
forms of crude oil transport.
Oil and gas exploration, development and production must also be consistent
with the public access, recreation, environmentally sensitive habitat, visual,
cultural, air quality, water quality, and marine resource protection policies, among
others, of the Coastal Act stated in other sections of this Plan.
C. Goals and Objectives
1. To ensure that oil and gas exploration, development and production is
conducted in a manner that is consistent with the City’s beach culture,
high quality of life, and environmental values.
2. To ensure that oil and gas exploration, development and production is
consistent with Measure ___ passed by the electorate on
_______________ allowing an Oil and Gas Development Project at 555
6th Street.
19
D. Policies and Programs
Policy 1. Oil and gas development is permitted in the coastal zone if found to be
consistent with the policies in Chapter 3 of the Coastal Act and this Plan, and as
authorized by Measure ___ passed by the electorate on _______________ .
Policy 2. Offshore oil and gas wells, platforms, processing and storage facilities
are prohibited.
Policy 3. Oil and gas drilling sites, including wells, processing, storage and
accessory facilities are permitted only within the Industrial designation on the
Land Use Map.
Program 3.1. Pursuant to Measure ____ , oil, gas and reinjection wells and
related processing, storage and accessory facilities, excluding pipelines, shall
be confined to the 1.3 acre site at 555 6th Street, and shall not be relocated or
expanded unless and until an amendment to this Plan is approved by the
voters of the City of Hermosa Beach and certified by the Coastal
Commission.
Policy 4. Pipelines are permitted within the Industrial designation on the Land
Use Map and public rights-of-way regardless of land use designation.
Program 4.1. Pipelines to convey produced oil and gas within the City of
Hermosa Beach shall be confined to the corridor defined by Measure ____
located within the Valley Drive right-of-way from 555 6th Street to Herondo
Street to the City of Redondo Beach. Upon completion of pipeline
construction, the corridor shall be recontoured, reseeded, landscaped or
surfaced, to conform with the surrounding topography and vegetation or
surfacing. Any new or replacement pipelines shall be located within the
designated pipeline corridor.
Program 4.2 All oil and gas products shall be transported by pipeline to
processing and refining facilities. Produced resources may be transported by
vehicles designed for this purpose only during exploration and construction
phases of minimum duration necessary to confirm the petroleum resource,
construct facilities on the project site, and construct pipelines. Oil and gas
produced from production wells shall be conveyed by pipeline.
Policy 5. Processing of oil and gas resources is limited to facilities and activities
required for compliant and safe well stream separation of crude oil, gas and
formation water, conveyance of unrefined products offsite to a purchaser or
refinery, and disposal of waste byproducts.
20
Policy 6. Monitoring and oversight of oil and gas exploration, development and
production projects in compliance with this Plan and Coastal Commission
requirements may be undertaken by the California State Lands Commission, a
trustee agency, or other qualified agency pursuant to agreement of the Coastal
Commission, City of Hermosa Beach and the subject agency.
Policy 7. Oil and gas exploration, development and production shall use the
best achievable control technology to ensure maximum protection of public
health and safety and of the integrity and productivity of terrestrial and marine
ecosystems.
Policy 8. Oil and gas exploration, development and production shall be
designed and operated in a manner that reduces the potential for subsidence
hazards and impacts to groundwater aquifers.
Policy 9. Oil and gas exploration, development and production shall protect
water quality and coastal resources and prevent runoff or discharges.
Policy 10. Oil and gas exploration, development and production shall minimize
air emissions and their impacts on the enjoyment of coastal resources, human
health and land uses in the surrounding community.
Policy 11. Greenhouse gas emissions generated by oil and gas exploration,
development and production should be reduced or offset to achieve net zero
carbon emissions.
Policy 12. Oil and gas exploration, development and production shall be
designed, constructed, operated and the site restored in a manner that does not
adversely affect coastal access and the enjoyment of recreational resources and
activities.
Policy 13. Oil and gas exploration, development and production shall be
designed, constructed, operated and the site restored in a manner that protects
the enjoyment of coastal resources, views and scenic areas and corridors, and
maximizes compatibility with the character of surrounding areas.
Policy 14. No well stimulation or well stimulation treatment of any type, including
but not limited to acid well stimulation, hydraulic fracturing, pursuant to the Public
Resources Code commencing with Section 3150, shall be permitted unless and
until an amendment to this Plan is approved by the City of Hermosa Beach
voters and certified by the Coastal Commission, after consideration of short- and
long-term environmental impacts, and a coastal development permit or
amendment as applicable is approved.
Policy 15. If onsite and in-kind mitigation are infeasible, offsite mitigation and/or
21
in-lieu fees or programs approved by the City and applicable agencies may be
used to mitigate for adverse impacts.
Policy 16. Upon completion of exploration, development and production, oil and
gas facilities shall be dismantled and removed, and the site cleaned of
contamination and reclaimed to natural conditions, or conditions to accommodate
reasonably foreseeable development, in an orderly and timely manner that
avoids impacts to the health, safety, and welfare of the public and environment.
Program 16.1. Upon the completion of exploration, development and
production or intentional abandonment of operations, permittee shall
obtain all applicable permits to remove, alter or retain facilities, structures,
and other improvements, and reclaim the site to natural conditions, or
other conditions as may be approved by the City in compliance with
applicable laws and permits. In the event the permitee desires to
temporarily idle or defer abandonment of operations, the permittee shall
obtain City approval pursuant to a review process including consideration
of short- and long-term environmental impacts and comply with all laws
and regulations. In the event that conditions exist evidencing that the use
has been abandoned, the City may pursue remedies allowed by law and
compel proper site closure.
Program 16.2. The City shall conduct a review process to permit the
removal, retention, or abandonment in-place of facilities, structures, and
improvements associated with oil and gas facilities determined to be
abandoned, and to reclaim the sites to natural conditions, or other
conditions as may be approved by the City in compliance with applicable
laws and permits. This process shall be independent of any development
permits associated with future use of the land, but may be processed
concurrently with development permits.
22
BALLOT ORDINANCE
ATTACHMENT B
Amend the Hermosa Beach Coastal Land Use Plan – Land Use Map (Appendix J) from
Open Space to Industrial (IND) on that portion of the property located at 555 6th Street
as follows:
Project site:
Amend from Open Space to
Industrial (IND)
23
BALLOT ORDINANCE
ATTACHMENT C-
[INSERT DEVELOPMENT AGREEMENT]
24
BALLOT ORDINANCE
ATTACHMENT D
DIAGRAM OF OIL AND GAS PIPELINES
FOR PIPELINE FRANCHISE
Final Health Impact Assessment
E&B Oil Drilling and Production Project
Intrinsik Inc.
September 8, 2014
Comments on Re-issued
Draft HIA
Final Health Impact Assessment, E&B Oil Drilling and Production Project – September 8, 2014
•Re-issued draft HIA was available July 14, 2014
•30 day comment period
•19 commenters (17 community members, 1 organization, the Applicant)
•104 comments
•Response to individual comments in Appendix C of Final
HIA
Type of Comments
•General opposition to the Project
•Concerns about authors’ objectivity
•Did the Intrinsik purchase of McDaniel Lambert influence the findings?
•Views that access to recreation/green space will be negatively rather than positively impacted
•Concerns about removing greenhouse gas emissions as a
health determinant
•Concern that stress was not adequately addressed
•Request to define distance of local impacts
•Opposition to blackout curtains
Final Health Impact Assessment, E&B Oil Drilling and Production Project – September 8, 2014
Type of Comments, cont’d
•Request for Executive Summary
•Concern that HIA relies on effectiveness of EIR mitigation measures
•Concern that regulatory thresholds for criteria air pollutants may not be adequately health protective
•Comment that additional positive health benefits were
omitted from report
•Concerns that negative impacts were minimized
•And others….
Final Health Impact Assessment, E&B Oil Drilling and Production Project – September 8, 2014
Changes to Final HIA
•Added 2 page Executive Summary
•Acknowledged there will be disturbance to recreation and green space nearby the Project Site due to construction activities
•Clarified that the recommendation for blackout curtains is an option for those who wish to take advantage of it, not
meant to be an imposition on community
•Commenter’s specific suggestions for wording additions or changes to HIA text were made when feasible
•In the summary table, defined the extent of the ‘local’ impact for a well blowout (based on EIR figure of 750 feet), the exact extent for other impacts not possible to quantify
•No significant changes to the HIA findings
Final Health Impact Assessment, E&B Oil Drilling and Production Project – September 8, 2014
HIA Recommendations
Odor: if frequent reports of odors occur, additional
study and/or periodic monitoring may be warranted
Noise Emissions: provide local residents and schools
with written notification (time and duration) of Phase
3 pipeline construction activities
Light Emissions: provide black-out blinds/curtains as
an option for residents with a direct sight line of the
exposed side of 87-foot electric drill rig
Final Health Impact Assessment, E&B Oil Drilling and Production Project – September 8, 2014
HIA Recommendations
Property Values: conduct a property value analysis to
identify potential project-related changes and ensure
fluctuations remain within expected local, regional
and national levels
Recreation & Green Space: develop a community
advisory group to assist the City on how to direct
revenue for recreational activities and green space
Final Health Impact Assessment, E&B Oil Drilling and Production Project – September 8, 2014
Monitoring
Community Liaison Committee: CLC would serve as
the vehicle through which citizens could voice active
concerns about Project activities; committee would
work collectively to find ways of addressing concerns.
Follow-up Community Health Assessment: Analysis
of health statistics by susceptible subpopulation
status could identify whether so me groups are
disproportionately impacted by Project operations.
Quality of Life Health Survey: Establish baseline
conditions and monitor whether quality of life
measures (e.g., sleep) change during the Project
Final Health Impact Assessment, E&B Oil Drilling and Production Project – September 8, 2014
Draft Development Agreement,
Exhibit E-2:
F-6. Odor
In the event of frequent reports of odor emanating from the
site, Operator shall pay for additional studies and/or periodic
air monitoring. If the studies or monitoring indicate that
additional control measures should be implemented to
reduce the frequency of noticeable odors, Operator shall
include those measures as project conditions.
Final Health Impact Assessment, E&B Oil Drilling and Production Project – September 8, 2014
Draft Development Agreement,
Exhibit E-2:
F-7. Notice
During Phase 3 pipeline construction, Operator shall provide
written notification of impending construction activities,
including the dates and times of activities that may produce
excessive noise, to all residents within 100 feet of the
construction activities. Notice shall be provided no less than
72 hours before construction begins.
Final Health Impact Assessment, E&B Oil Drilling and Production Project – September 8, 2014
Draft Development Agreement,
Exhibit E-2:
F-8. Light impact reduction
Operator shall pay for or provide black-out blinds or curtains
for bedrooms with direct line-of-sight to the exposed side of
the electric drill rig that will be lit at night. The amount of
payment or the brand of blinds/curtains shall be pre-
approved by the City Manager, and may be provided through
a direct mail program.
Final Health Impact Assessment, E&B Oil Drilling and Production Project – September 8, 2014
Draft Development Agreement,
Exhibit E-2:
F-9. Community Relations
As recommended in Intrinsik’s Health Impact Assessment for
the project, and at the City Council’s discretion, the Operator
may be required to pay for the costs associated with (1)
organizing a Community Liaison Committee; (2) a follow-up
Community Health Assessment; and/or (3) a quality of life
health survey.
Final Health Impact Assessment, E&B Oil Drilling and Production Project – September 8, 2014
Final Health Impact Assessment, E&B Oil Drilling and Production Project – September 8, 2014
Follow-up Community Health Assessment
and Quality of Life Health Survey
•The design of these studies, including indicators to
be included, analysis methodology, and timing of
monitoring, should be developed with input from
stakeholders
•If the proposed Project moves forward, the City
should work with the Applicant to develop the scope
and hire the appropriate party
Thank you.
Dr. Mary McDaniel
Venice, California
Christopher Ollson, PhD
Toronto, Canada
Kathleen Souweine
Venice, California
Final Health Impact Assessment, E&B Oil Drilling and Production Project – September 8, 2014
1608 Pacific Avenue, Suite 201 ▪ Venice, CA 90291
Tel: 310-392-6462 ▪ www.intrinsik.com
FINAL
HEALTH IMPACT ASSESSMENT
E&B OIL DRILLING AND PRODUCTION PROJECT
September 3, 2014
Prepared at the request of:
Department of Community Development
City of Hermosa Beach
1315 Valley Drive
Hermosa Beach, CA 90254
Each Phase of E&B’s Project was considered in the HIA:
Phase 1: Site Preparation and Construction (6‐7 months)
Phase 2: Drilling and Testing (10 to 13 months)
Phase 3: Final Design and Construction (16 months)
Phase 4: Development and Operations (30 to 35 years)
EXECUTIVE SUMMARY
Health Impact Assessment
E&B Oil Drilling and Production Project
September 2014
This summary presents the findings of the Health Impact Assessment (HIA) completed to inform voters about the potential
health impacts of E&B’s proposed oil drilling and production project (the Project) in the City of Hermosa Beach, CA. The City
commissioned this HIA in addition to a Cost‐Benefit Analysis (CBA) and an Environmental Impact Report (EIR). The HIA
complements the EIR and CBA, providing additional consideration of potential impacts (negative and positive) on
community health from the proposed Project. This Final HIA is the result of a comprehensive process that included public
meetings and input on draft documents from community members, a peer reviewer, the City and its other consultants,
E&B, and community organizations. We would like to thank the community for taking the time to provide comments
throughout the process. This input was essential to the completion of the HIA.
The HIA was based on best practices and included the following steps: screening, scoping, assessment, recommendation,
reporting, evaluation, and monitoring. The scoping step identified six major categories (including 18 individual health
determinants) based on stakeholder input and other factors: air quality; water and soil; upset scenarios; noise and light;
traffic; and community livability. During the assessment step, we completed a baseline health profile as a reference point
and then predicted what Project‐related (with EIR mitigation) health effects could occur based on a combination of
information from the EIR, scientific literature, regulatory or other health‐based thresholds, and expert opinion. Each health
determinant was carefully assessed using a combination of quantitative, semi‐quantitative and qualitative approaches.
An evaluation matrix was developed to characterize the predicted health impacts so they could be compared and
contrasted. The evaluation matrix includes consideration of various
characteristics of health impacts including magnitude, likelihood,
adaptability, and others. Ultimately, the aim of the assessment was
to determine whether the Project could potentially have a negative,
positive or no substantial effect on health. Potential health impacts
were considered both on a local (close to the proposed Project Site)
and community‐wide scale.
Key Findings
Air Quality
The air pollutants we evaluated in the HIA included: nitrogen dioxide (NO2), particulate matter (PM), toxic air contaminants
(TAC), and odor. Predicted NO2, PM, TAC concentrations with EIR mitigation were compared to health‐based thresholds.
The HIA concludes that there is no substantial effect on human health with respect to air emissions of NO2, PM, and TAC
through Phases 1 to 4. The odor‐related health effect is considered negative near the Project Site due to periodic odor
releases during production operations (Phases 2 and 4) that cannot be completely mitigated. Odor can have various health
consequences including stress, and could result in periodic discomfort and annoyance. If frequent reports of odor occur,
additional study and/or periodic monitoring of odor may be warranted.
Water & Soil Quality
The water and soil assessment considered surface water impacts from Project‐related runoff to the Pacific Ocean and soil
particulate emissions during construction activities. Due to the EIR mitigation measures and other factors, we concluded
that there is no substantial effect on human health with respect to surface water quality and soil particulates during any
Phase of the Project.
Upset Scenarios
Upset scenarios included the possibility for a crude oil spill to the ocean or a well blowout. The oil spill assessment
concludes no substantial effect through Phases 1 to 4. The blowout assessment within the HIA concludes that there is a low
probability of occurrence, but in the event of a blowout, there could be significant negative health implications including
fatalities. The HIA also found a negative health effect of stress due to fear of a blowout accident. The HIA recommends that
the City incorporate the possibility of an oil spill or well blowout into its current emergency preparedness plan.
Noise & Light
This assessment considered Project noise emissions and light emissions, including lighting safety. With respect to noise, the
HIA concludes that there is no substantial effect on human health from Phase 1, 2, 3a (site construction) and 4, and a
potential negative impact from pipeline construction activities in Phase 3b. Therefore, it is recommended that written
notification be provided to residents and schools in the vicinity of these activities that identifies the potential for excess
noise and outlines the location and duration of the impacts.
The light assessment within the HIA concludes no substantial effect on human health due to nighttime light emissions;
however, there is potential for some nearby individuals to experience disruption of typical sleep patterns during periods
when the drill rig is present (Phase 2 and intermittently in Phase 4). Therefore, it is recommended that black‐out
blinds/curtains be provided as an option for residents whose bedroom windows are in the direct line‐of‐sight of the
exposed portion of the drill rig to eliminate any infiltration of outdoor lighting.
Traffic
The traffic assessment examined the potential for increased truck and other traffic to impact pedestrian, bicyclist, and
motor vehicle safety and the potential for perceived traffic hazards to impact people’s walking and bicycling choices.
Primarily due to the required EIR mitigation measures, we concluded that there is no substantial effect on human health
with respect to traffic safety and perceived traffic safety hazards during any Phase of the Project.
Community Livability
The community livability assessment evaluated a number of community aspects that are valued by the citizens of Hermosa,
including: property values, access to green space (parks and recreation), aesthetics (view), education funding, social
cohesion, and political involvement. The community livability assessment within the HIA concludes that there is: no
substantial effect on human health with respect to social cohesion; a potential negative effect from stress over property
values and aesthetic/visual resources (while drill rigs are erected in Phases 2 and 4); and a potential positive effect on
health from enhanced funding for recreation and green space, educational funding and political involvement activities.
Monitoring
If the proposed Project is approved, the HIA
provides monitoring recommendations for the City
to consider. Those recommendations include:
(1) a community liaison committee to address
resident’s active concerns about Project activities;
(2) a follow‐up community health assessment to
identify if some groups are disproportionately
impacted by Project activities; and,
(3) a quality of life survey to establish baseline
conditions in Hermosa Beach, and to monitor health
status changes during the Project.
There is no simple answer to the impact that the Project will have on
the health of Hermosa Beach residents since different aspects of the
proposed Project will impact the community in different ways.
We caution that the assessment and conclusions are based on
population health and not on single individuals. There are some
aspects of the Project that may negatively influence health (e.g.,
odor, well blowout, noise from pipeline construction, property values
and aesthetics), and at the same time there were potential positive
health outcomes identified (e.g., increased education funding, ability
to enhance green space).
With the exception of a well blowout accident, the negative health
outcomes were largely nuisance related (e.g., odor, noise, aesthetics)
and without irreversible health impacts. As mitigated in the Final EIR,
the majority of the health determinants examined revealed that the
Project would have no substantial effect on the health of the
community. Based on the Final EIR mitigation measures and
additional recommendations provided in the HIA, on balance we do
not believe that the Project will have a substantial effect on
community health in Hermosa Beach. Ultimately it is the voters of
Hermosa Beach who will decide whether the impacts described in
this HIA are acceptable or not.
Conclusion
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA
RATIONALE FOR REISSUED HIA
The first draft Health Impact Assessment (HIA) for this project was released in February, 2014.
It was prepared concurrently with the draft Environmental Impact Report (EIR) and Cost Benefit
Analysis. The February draft HIA was largely based on the consideration of worst case
scenarios rather than refined geographic data and the fully mitigated proposed Project in the
Final EIR.
McDaniel Lambert (now Intrinsik Environmental Sciences (US), Inc. [Intrinsik]) received many
stakeholder comments on the February draft HIA. Written comments were submitted by the EIR
consultant, community members and by the Applicant, E&B Natural Resources Management.
Oral comments were also received at the presentations on the 24th and 26th of February, as well
as at the Saturday Open House on March 8th. A number of the comments affected multiple parts
of the document, calling for an extensive revision.
When HIAs are conducted in conjunction with EIRs it is more appropriate to assess the potential
for the Project to affect health on the post-mitigation scenarios, since by law certification of the
EIR requires the implementation of these measures. The reissued draft HIA and this final HIA
report had the benefit of the full public process and complete analysis reflected in the Final EIR
and assessed the Project on the basis of post-mitigation scenarios.
In addition, McDaniel Lambert was able to draw upon the experience of a number of experts
from the parent company, Intrinsik, along with an external peer review. Therefore, the final HIA
was prepared by an expanded multi-disciplinary team. This final HIA supersedes all previously
released material related to the HIA including the February draft report and all corresponding
presentations and/or related written material.
Intrinsik Health Impact Assessment Team
Dr. Mary McDaniel, DO, JD, MPH, Mary McDaniel is a board-certified occupational and
environmental physician, licensed attorney, and risk and crisis communication expert. She
brings more than 20 years of experience in health assessment, risk communication, crisis
response, and occupational and environmental medicine.
Dr. Christopher Ollson, PhD, is a Senior Environmental Health Scientist. He has over 17 years
of experience in leading human health risk assessments and evaluating health impacts in
support of environmental assessments for a range of energy projects.
Bart Koppe, BSc, PBiol, is a Senior Risk Assessment Specialist. His expertise is in conducting
health risk assessments for regulatory submissions for oil and gas-related projects. In addition,
he is considered an expert in petroleum related air quality issues.
Kathleen Souweine, MPH, is an epidemiologist and has experience in both the environmental
sciences and a range of epidemiological projects. She is a former analyst in the USEPA Office
of Ground Water and Drinking Water.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA
Lindsay McCallum, MEnvSci, PhD (Candidate), is an Environmental Health Scientist. In
addition to being an experienced health risk assessor she is pursuing doctoral research in
health impact assessment at the University of Toronto.
Christine McFarland, BSc, is an Environmental Risk Assessor. She specializes in human
health risk and air quality assessments conducted in support of environmental assessments of
oil and gas projects.
Katherine Butler, MPH, is an epidemiologist who was formerly with McDaniel Lambert and a
co-author of the initial Hermosa Beach draft HIA report. She has since joined the Los Angeles
County Department of Public Health, where she is leading efforts to promote HIA capacity
building.
External Peer Reviewer
Dr. Elizabeth Hodges Snyder, MPH, PhD is a soil and water scientist and environmental
health practitioner originally trained in human and ecological risk assessment. Her
interdisciplinary background includes experience in both natural science laboratory and social
science research. In the years following attainment of her graduate degrees, her research
program and teaching agenda have evolved to address the fields of health impact assessment
(HIA) and food security. Recent works include an assessment of participant perspectives on the
ability of HIA stakeholder engagement to capture and reflect factors that impact Alaska Native
health, and an adapted community food assessment (CFA) in Anchorage, Alaska. Dr. Hodges
Snyder is a founder of the Society of Practitioners of Health Impact Assessment (SOPHIA).
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page i
PROJECT SUMMARY
INTRODUCTION
Founded in 1907, Hermosa Beach is a small 1.43 square mile city on Los Angeles (LA) County’s South
Bay coastline, bordered by Manhattan Beach to the north and Redondo Beach to the south. Known as
“The Best Little Beach City”, it has a population of approximately 20,000 people, with a high proportion of
residents between the age of 25 and 50 (US Census, 2013). Under the settlement agreement that ended
litigation, an election will be held to allow City of Hermosa Beach (the City) voters to decide whether to
repeal the existing ban on oil drilling within the City limits. Repealing the ban on oil drilling would allow
E&B Natural Resources Management Corporation’s (E&B’s) proposed oil drilling and production project to
move forward. In order to inform voters about the potential economic, social, environmental, and health
impacts (positive and negative) of the E&B proposed oil drilling and production project, the City
commissioned a Health Impact Assessment (HIA), in addition to a Cost-Benefit Analysis (CBA) and
Environmental Impact Report (EIR). The EIR complies with the California Environmental Quality Act
(CEQA), while the CBA and HIA are complementary documents that the City commissioned to provide
community members with additional information on the proposed Project.
The proposed E&B Oil Development Project (proposed Project) consists of drilling 30 oil wells on a 1.3-
acre site located on the current City Maintenance Yard property (the Site) located at 555 6th Street, at the
intersection of Valley Drive and 6th Street in the City. The Site is bounded by industrial/commercial use
properties to the north, south, and west. The Site is bounded by the Greenbelt, a park and recreational
use space, to the east. Adjacent blocks also include residential uses located 150 feet to the north of the
Project Site, 250 feet to the west and 180 feet to the east (east of the Greenbelt). The Pacific Ocean is
approximately a half mile west of the Site.
If approved, the proposed Project will be completed in four Phases. Phase 1 will last six to seven months
and involves construction activities associated with Site preparation for drilling and testing. Phase 2 will
last 10 to 13 months and involves drilling and testing of wells in order to estimate the potential productivity
and economic viability of the proposed Project. If Phase 2 determines that the proposed Project is
economically feasible, Phase 3 would be carried out to prepare the Site for permanent oil and gas
production facilities and to construct offsite pipelines. Phase 3 would take approximately 13 months and
involve construction of additional retaining walls and final grading, extending and completing the
construction of the cement well cellar, placing a small office building onsite, installation of permanent
production equipment, final Site and landscaping improvements, and erecting the 32-foot sound barrier
wall for noise attenuation during Phase 4 drilling. The permanent oil production facility will include tanks,
vessels, piping, pumps, filters and corresponding metering equipment. Phase 4 is the final phase of the
proposed Project and will maximize oil and gas recovery through the construction of an 87-foot high drill
rig, the drilling of the remaining oil wells and water disposal/injection wells, and through the continuous
operation of the proposed Project. It is estimated that it will take two weeks to set up the drill rig, and two
and a half years to drill the remaining wells, up to a total of 30 oil wells and four disposal/injection wells.
Facility operations and maintenance would be continuous for approximately 30 to 35 years, with periodic
re-drills during the life of the Project.
An initial draft HIA was released in February 2014. Following receipt of a number of public comments and
finalization of the EIR, the HIA underwent extensive revision and was reissued in July 2014. The reissued
HIA was conducted using a multi-disciplinary approach and was subject to external peer-review by Dr.
Elizabeth Hodges Snyder of the University of Alaska Anchorage. Dr. Hodges Snyder provided the HIA
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page ii
team with constructive feedback and a number of comments (Appendix C), all of which have been
addressed in the final HIA.
HEALTH IMPACT ASSESSMENT METHODOLOGY
The World Health Organization (WHO) defines health as “a state of complete physical, mental and social
well-being and not merely the absence of disease or infirmity” (WHO, 1948). This definition is considered
an ideal to strive for, and it forms the basic principle upon which HIA is based.
In California, an HIA is not legally required for this type of project, but an EIR is mandatory. In order to
expand on existing health considerations in the EIR, the City of Hermosa Beach commissioned this HIA
to help inform voters and evaluate different aspects of the proposed Project through a public health lens.
The rationale for the HIA lies in its unique approach to assessing a multitude of potential impacts (both
positive and negative) that could affect community health. The HIA is intended to provide additional
information, as well as relying on existing information provided in the EIR, to holistically evaluate health.
Although the reports are complementary, in several instances the HIA provides further details on how
specific aspects of the Project could positively or negatively affect the health of the community, and
proposes additional recommendations where necessary. An HIA typically consists of a series of steps
that are intended to provide a structural framework around which the assessment will be conducted.
Although guidance documents from around the world have slight
variations on these steps, they typically include: screening, scoping,
assessment, recommendation, reporting, evaluation and monitoring
(Ross et al., 2014).
An HIA evaluation matrix is a tool to characterize and summarize the
predicted health impacts (positive, negative, and neutral) of the
proposed Project so they can be compared and contrasted. As there
is no globally accepted standard for health impact characterization in
HIA, the evaluation matrix used in this HIA was developed based on
best practices published in a number of guidance documents and
used in other assessments (Ross et al., 2014; USEPA, 2013; CDPH,
2010; IAIA, 2006; NRC, 2011).
The evaluation matrix developed for this HIA includes consideration
of the different characteristics of potential impacts including
geographic extent (local, widespread), magnitude, likelihood of
occurrence, and others. Each of these characteristics is
independently evaluated based on data from the EIR, evidence from
the scientific literature, and professional judgment. A brief discussion
of the Project without mitigation measures is included where
applicable. However, the Project characteristics were ultimately
evaluated based on a scenario where the proposed EIR mitigation
measures have been implemented. The assessment focuses on the
Project including mitigation measures to ensure they are adequately
protective and, if not, to propose additional recommendations based
on the HIA findings. The evaluation criteria are discussed in further
detail below (Table PS-1).
Recommendation
Screening
Scoping
Assessment
Reporting
Evaluation
Monitoring
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City of Hermosa Beach, CA Page iii
For each health determinant evaluated in the HIA, a technical scientific assessment of the potential health
impact includes a detailed discussion of all aspects of the evaluation matrix. A specific definition has been
provided for each element (i.e., magnitude, adaptability, likelihood, etc.) to ensure a consistent and
meaningful assessment across all determinants.
Table PS-1 HIA Evaluation Matrix
Health Determinant List the determinant being assessed
Potential Health Outcome List potential health outcomes associated with each determinant
Pre-Mitigation Discussion The discussion is limited to identification of the direction of the
pre-mitigation impact (positive, negative, neutral or unknown) and
identification of any potential issues that could arise if no
mitigation measures were implemented.
EIR Mitigation List mitigation measures from the Environmental Impact Report
(EIR), where applicable
Geographic Extent Localized or Community
Vulnerable Populations List subgroups that could be disproportionately affected by Project
activities
Magnitude Low, Medium, High, or Unknown
Adaptability High, Medium, Low, or Unknown
Likelihood Unlikely, Possible, or Probable
Post-Mitigation Health Effect Negative, Positive, No substantial Effect, or Unknown
Comments or Additional
Recommended Measures
None, or Additional Recommendations (specific and actionable)
Health Determinant: A determinant is defined as “an element that identifies or determines the nature of something.”
In this case, the determinant is an element of the proposed Project that has the potential to impact health in a
positive or negative manner; however, the determinant itself is non-directional. The scoping section of the HIA
identifies health determinants that are evaluated in detail.
Potential Health Outcome: List and discuss potential health outcomes associated with the determinant (e.g., the
toxicology and physical health changes associated with exposure).
Pre-Mitigation Discussion: A brief discussion of the potential impact of the Project without mitigation is provided for
completeness; however, the HIA is based only on a scenario where the mitigation measures required in the EIR
have been implemented as part of the Project. The discussion is limited to identification of the direction of the pre-
mitigation impact (positive, negative, neutral or unknown) and identification of any potential issues that could arise
if no mitigation measures were implemented.
EIR Mitigation: What are the mitigation measures that have been identified in the EIR for this determinant that are
related to health and could change the outcome of the HIA? Measures are listed based on information provided in
the Final EIR.
Geographic Extent: How far are the impacts likely to reach?
Localized: limited to the areas in close proximity to the Project Site Community: potential for wider scale impacts across the community
Vulnerable Populations: Are there populations that could be disproportionately affected (positively or negatively) by
Project activities?
Magnitude: What is the extent of the health impact post-mitigation?
Low: the impact is minor, it is temporary or reversible, and does not pose a hazard/benefit to health
Medium: the impact is detectable, it is reversible, and poses a minor to moderate hazard/benefit to health
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page iv
High: the impact is substantial, it is permanent, and poses a major hazard/benefit to health Unknown: the impact is unclear and poses an unknown hazard/benefit to health
Adaptability: How resilient is the community to this type of change; are they able to adapt?
High: people will be able to adapt to the change with ease and maintain pre-project level of health
Medium: people will be able to adapt to the change with some difficulty and will maintain pre-project level
of health, although some support may be necessary
Low: people will not be able to adapt or maintain pre-project level of health
Likelihood: What is the probability of the impact occurring based on the expected frequency of the exposure?
Unlikely: the impact is anticipated to occur rarely, if ever
Possible: there is potential for the impact to occur on a regular basis
Probable: the impact will almost certainly occur and persist over time
Post-Mitigation Health Effect: What is the ‘direction’ of the post-mitigation effect?
Positive: the effect is expected to positively influence health following implementation of EIR mitigation
measures
Negative: the effect is expected to negatively influence health following implementation of EIR mitigation
measures
No Substantial Effect: there is no substantial effect expected following implementation of EIR mitigation
measures Unknown: the direction of the effect following implementation of EIR mitigation measures is unknown
Comments or Additional Recommended Measures: Provide comment about the effect, and/or determine if there
any additional measures recommended based on the Post-Mitigation Health Effect.
None: there are no additional measures recommended based on the findings of the HIA
Additional Recommended Measures: there are additional measures recommended based on the findings
of the HIA (provide brief summary of recommendations)
The decision-making framework (the framework) used to weigh and evaluate each of the elements of the
evaluation matrix in order to come to a final conclusion on “Post-Mitigation Health Effect” for each health
determinant is provided in Figure PS-1. The elements (i.e., magnitude, adaptability and likelihood) are
arranged in descending order (top to bottom) of weight and potential influence on the final determination
of effect. Each pathway through the framework leads to a specific conclusion that is either directional (i.e.,
positive or negative) or non-directional/neutral (i.e., no substantial effect). In some cases where
professional judgment dictates, it is possible to deviate from the decision making framework; however, a
detailed evidence-based rationale is required to be provided in the accompanying text.
There are three different outcomes that can be used to classify a potential health effect. The classification
is based solely on the definitions provided above and is intended to describe the extent of the post-
mitigation health impact. The most heavily weighted aspect of the evaluation matrix is magnitude, which
comprises the first level of the framework. Adaptability is the next level of the evaluation matrix as it
relates to resiliency and ability to maintain health status if an impact were to occur.
This element is less heavily weighted than magnitude but does influence the final determination of effect.
The final level of the matrix is likelihood, which is the probability of the impact occurring based on the
expected frequency of exposure. Likelihood is less heavily weighted than magnitude but similar to
adaptability, it influences the final conclusion, especially in situations where the impact is expected to
occur rarely, if ever. Where an element of the evaluation matrix is classified as ‘unknown’ a discussion of
the uncertainty and potential influence of this limitation on the conclusions must be provided. In these
scenarios, the determination of effect is largely based on professional judgment and sound rationale.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014 City of Hermosa Beach, CA Page v Figure PS-1 Decision-Making Framework for the HIA Evaluation Matrix (H = high; M = medium; L = low; U = unlikely; P = possible; R = Probable) MagnitudeAdaptabilityLikelihoodMEDIUMHealth DeterminantHIGHLOWHMLUPRUPRUPRUPRUPRUPRUPRUPRUPRHMLHMLNo Substantial Effect (Neutral)Positive/Negative Neutral/PositivePositive/NegativeDirectional outcomeNon‐directional outcome
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City of Hermosa Beach, CA Page vi
ASSESSMENT AND RECOMMENDATIONS
The assessment process in HIA involves: (1) developing a health baseline profile, (2) assessing the likely
impacts, and (3) characterizing the health impacts. The baseline health assessment establishes the
current health status of the City of Hermosa Beach residents in order to evaluate whether the current
profile of the community reveals vulnerabilities to any of a number of health outcomes, and also to
provide a benchmark so that the HIA can predict the extent of change from current health conditions. The
baseline assessment found that Hermosa Beach is a relatively young community that is highly educated,
has above average income levels, and a higher sense of well-being than other California residents.
Overall, demographic indicators show that Hermosa Beach is not highly vulnerable to negative health
outcomes traditionally associated with poverty, unemployment, and low educational attainment.
The HIA considered 18 determinants of health that fall under six major categories (i.e., air quality, water
and soil quality, upset conditions, noise and light emissions, traffic, and community livability).
Consideration was given to those determinants that were identified as community priorities and are most
likely to be impacted by the proposed Project. Each of these outcomes was carefully assessed using a
combination of quantitative, semi-quantitative and qualitative approaches where appropriate. Ultimately,
the aim of the assessment was to determine whether the Project (post-mitigation) could potentially have a
negative, positive or no substantial effect on health. Potential health impacts were considered both on a
local (adjacent to the proposed Project Site) and community-wide scale.
Air Quality
The potential for air emissions from
construction and operation of the proposed
Project to affect air quality in Hermosa
Beach was evaluated using the emissions
inventory produced as part of the EIR. The
air pollutants carried forward for assessment
in the HIA included nitrogen dioxide (NO2),
particulate matter (PM), toxic air
contaminants (TAC), and hydrogen sulfide
(H2S) and other odorous compounds.
Nitrogen dioxide (NO2) has the potential to produce a range of respiratory effects depending on the
concentration in air (e.g., eye, nose and throat irritation, inflammation of lung tissue). For the assessment,
the maximum 1-hour and maximum annual average NO2 air concentrations were calculated (background
plus Project) and found to be below the WHO air quality health guidelines, indicating that adverse health
effects are not expected to result from either short-term or long-term exposure. Additionally, there were no
exceedances of California’s Ambient Air Quality Standards (AAQS), or the US EPA National Ambient Air
Quality Standards (NAAQS) for NO2. Therefore, it was concluded that exposure to NO2 from the proposed
Project (post-mitigation) is expected to have ‘no substantial effect’ through the duration of the proposed
Project and no additional recommendations were required.
Particulate matter (PM) is a widespread air pollutant composed of a mixture of solid and liquid particles,
and its effects on health are well documented. Particles with a diameter of 10 micrometers or smaller are
referred to as PM10, and particles with a diameter of 2.5 micrometers or smaller are known as PM2.5.
Exposure, particularly to the smaller PM2.5 particles, is associated with increased respiratory and
cardiovascular disease and mortality. The maximum 1-hour and maximum annual average PM2.5 air
The air quality assessment within the HIA concludes that
with implementation of the proposed EIR mitigation
measures there is no substantial effect on human health
with respect to air emissions (NO2, PM and TAC).
However, periodic odor releases, identified in the EIR as
significant and unavoidable, were characterized as
negative near the Project Site. Odor can have various
health consequences, and could result in periodic
discomfort and annoyance near the Project Site.
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concentrations were added to baseline concentration in LA County and resulted in exceedances of the
WHO air quality guidelines. However, when background levels from South Coastal Los Angeles County
(assumed to better represent Hermosa Beach air quality) were used, the Project was below the California
annual AAQS or US EPA NAAQS. The assessment concluded that any exceedances of the WHO air
quality guidelines are based on existing background levels in the area and the Project is not expected to
have a material impact on existing PM2.5 related health risks. While there is no substantial effect from
post-mitigation exposure to PM2.5 through the duration of the proposed Project, existing ambient levels of
PM2.5 air concentrations in the area are already in the range at which increased mortality has been
observed in large urban centers.
Toxic Air Contaminants (TAC) can be used to describe a wide array of chemicals, including volatile
organic compounds (VOCs), polycyclic aromatic hydrocarbons (PAHs), hydrogen sulfide (H2S), inorganic
elements (e.g., metals) and particulate emissions from diesel exhaust. Without mitigation measures,
Project emissions of certain TAC would pose a potential risk to human health; however, with
implementation of the measures proposed in the EIR, the proposed Project is expected to have no
substantial effect through the duration of the proposed Project and no additional recommendations were
required.
Odor can result from the release of compounds such as H2S. Sensitivity to environmental odors varies
greatly from person to person. The most commonly reported symptoms from odor exposure are
headaches, nasal congestion, eye, nose, and throat irritation, hoarseness, sore throat, cough, chest
tightness, and shortness of breath, among others. According to the WHO, odor annoyance can also affect
overall quality of life. Adverse health outcomes associated with odor are related to the frequency,
duration, concentration, and the individuals’ level of sensitivity. Hydrogen sulfide is the primary odor
associated with oil and gas production and it has a relatively low odor threshold. The H2S odor threshold
(i.e., the lowest concentration perceivable by human smell) is highly variable within the human population
and can be detected at concentrations as low as a half of a part per billion (0.5 ppb). Although mitigation
measures proposed in the EIR would reduce the frequency of odor releases, they were still identified as
‘significant and unavoidable’ during production operations (Phases 2 and 4) because of the close
proximity of residences and businesses to the Project. For these reasons, the odor-related health effect is
considered ‘negative’ near the Project Site and additional recommendations have been provided (i.e., an
odor study and/or periodic monitoring in the event of excessive reports of odor).
Water and Soil Quality
If uncontrolled, Site-related chemicals in polluted
stormwater runoff water could be detrimental to the
environment and human health. For people
swimming or recreating in the Pacific Ocean,
contact with polluted stormwater runoff could result
in acute health symptoms such as eye and skin
irritation. Runoff from the proposed Project site
generally flows to the west towards an inlet that discharges to the Ocean at an outfall at the end of
Herondo Street. During a rain event, contaminants and debris that enter the storm drain system could
flow into the nearby Santa Monica Bay, which is currently listed as an “impaired water body” for ‘contact’
recreation. During Phase 2 and 4 drilling operations, surface runoff at the Project site would be contained
with walls and berms and pumped into the water processing system for injection into the oil reservoir;
therefore, preventing negative impacts to surface water quality and potential health outcomes during
The water and soil quality assessment within the
HIA concludes that with implementation of the
proposed EIR mitigation measures, there is no
substantial effect on human health with respect to
surface water quality and soil particulates.
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City of Hermosa Beach, CA Page viii
operations. Without mitigation, construction-related contaminants and debris flowing into storm drains
connected to the Pacific Ocean could result in impacts to water quality and increases in acute health
outcomes during Phases 1 and 3 of the proposed Project. However, EIR mitigation measures will reduce
the possibility of construction-related impacts to the Pacific Ocean through the requirement of a Storm
Water Pollution Prevention Plan. Overall, the potential health impact associated with surface water is
classified as no substantial effect because Site runoff will be controlled during all Project phases.
Soils under the current maintenance yard and potential Project Site have contamination related to its
former use as a landfill. While the Site is currently paved over and thus not posing any present hazard,
Project-related construction activities will release particulate emissions when equipment moves on soil or
unpaved surfaces and during trenching, grading, and other earth-moving activities. The primary
contaminant of concern in onsite soil is lead; however, on-site surface soil data is limited and the top 3
feet of soil is not currently well characterized with respect to potential contamination. Therefore, additional
surface soil data is important to address in order to determine the potential health hazard posed by
chemicals in soil prior to Phase 3 RAP activities. The EIR required mitigation measure SR-2 addresses
this data gap by requiring the Applicant to sample soil during Phase I grading and remove soil
contamination exceeding regulatory thresholds from the Site as early as Phase 1 if substantial
contamination is present. Implementation of the RAP to remove contaminated soil and mitigation
measures to reduce fugitive dust emissions will reduce the possibility of hazardous soil particulate
emissions during Project- related activities and thus soil particulates do not pose a substantial effect to
human health through the duration of the proposed Project.
Upset Scenarios
This HIA evaluated the health impacts of two
upset scenarios, an offsite oil spill and a well
blowout. Potential human health impacts of
exposure to an offsite oil spill include headaches,
eye/skin irritation, respiratory conditions, anxiety,
and depression. In the unlikely event of a spill
(0.07% chance of an oil spill to the ocean), E&B
would be required to contain and clean-up any
crude oil in the environment, thus irreversible or
chronic health outcomes would not be expected
to occur and the HIA concludes ‘no substantial
effect’ related to the oil spill health determinant
through the duration of the proposed Project.
A well blowout could result in serious injuries and/or fatalities among community members in the vicinity
of the proposed Project Site. A well blowout is a very low probability event, predicted to occur once in 323
years during drilling and once in 604,127 years during non-drilling periods if the wells are pressurized.
The fear of a blowout accident could result in moderate impacts to human health due to elevated levels of
distress over the possibility that a blowout could occur. Because a well blowout could have severe health
consequences and the possibility of an upset scenario occurring cannot be completely avoided through
mitigation, the blowout assessment concludes a ‘negative’ health effect. In addition to emergency
response plans prepared by E&B, the City should consider incorporating the possibility of an oil spill or
well blowout into their current public preparedness awareness program.
In the oil spill assessment concludes there is no
substantial effect with implementation of the
proposed EIR mitigation measures. The blowout
assessment within the HIA concludes that there is
a low probability of occurrence, but in the event
such upset scenarios were to occur, they could
have significant negative health implications. The
HIA also found a negative health effect of stress
due to fear of a blowout accident. The HIA
recommends that the City incorporate the
possibility of an oil spill or well blowout into its
current emergency preparedness plan.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page ix
Noise and Light Emissions
Noise is ubiquitous in suburban/urban and commercial areas. Health implications associated with
exposure to excess noise are typically focused on nighttime sleep disturbance. Since the Project-related
activities predicted to produce the highest noise
levels were only permitted during daytime hours,
nighttime impacts of noise are not a primary concern
in the current HIA. The impact of Project-related
noise emissions on the local community, particularly
residents located around the Project Site and along
the pipeline and truck routes is negative without the
use of mitigation measures; however, the EIR has
identified a variety of mitigation techniques to reduce
the potential impact of noise on the surrounding
community including a 35-foot acoustical barrier
around the Project site. Based on the current HIA,
there is expected to be no substantial effect on
human health resulting from project activities in
Phases 1, 2, 3a (site construction) and 4. There is some potential for negative health effects from high
levels of noise associated with pipeline construction (Phase 3b); however, this is expected to be short-
term in duration (approx. one week per location) and is limited to daytime hours. Therefore, for Phase 3b
(pipeline construction), it is recommended that local residents and local schools be provided with written
notification of the impending work that identifies the potential for excess noise and outlines the location
and duration (expected to be short-term: 1 week) of the impacts.
The invention and widespread use of artificial light, especially at night, has become a necessity in many
areas of the world to enhance commerce, promote social activity, and increase public safety. Despite the
fact that the use of artificial light is a widespread
consequence of industrial and economic
development, it can have unintended negative
consequences, especially when it becomes
inefficient, annoying and unnecessary. The major
health concern related to excessive light-at-night is
disruption of sleep and biological circadian rhythms
which influence melatonin production and promote
overall health. To ensure visibility, site security and
worker safety artificial lighting will be installed as part
of the proposed Project. The majority of the on-site
lighting will be shielded and downcast to reduce
glare. Additionally, the site will have a 32-foot
acoustical barrier that will eliminate light spill beyond
the Site boundary in most cases. The one exception to this is the presence of lighting on the electric drill
rig, which extends up to 87 feet. Residents who have a line-of-sight view of the exposed side of the
electric drill rig from their bedroom window(s) may be disproportionately impacted. For these individuals, it
is recommended that black-out blinds or curtains be provided as an option for those who would like
blinds/curtains but do not wish to pay for them themselves to help eliminate the potential for infiltration of
light emissions from the nighttime lighting on the drill rig.
The noise assessment within the HIA
concludes that, with implementation of the
proposed EIR mitigation measures, there is no
substantial effect on human health from Phase
1, 2, 3a (site construction) and 4, and a
potential negative impact from pipeline
construction activities in Phase 3b. Therefore,
it is recommended that written notification be
provided to residents and schools in the
vicinity of these activities that identifies the
potential for excess noise and outlines the
location and duration of the impacts.
The light assessment within the HIA concludes
that, with implementation of the proposed EIR
mitigation measures, there is no substantial
effect on human health with respect to light
emissions; however, there is potential for
nearby individuals to experience disruption of
typical sleep patterns. Therefore, it is
recommended that black‐out blinds/curtains
be provided as an option for residents whose
bedroom window(s) are in the direct line‐of‐
sight of the exposed portion of the electric
drill rig to eliminate any infiltration of
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page x
Traffic
Increases in traffic volume are associated with increased risk of injury and death due to vehicle-vehicle,
vehicle-pedestrian, and vehicle-bicycle collisions. Currently, fatalities resulting from motor vehicle
collisions are very rare in the pedestrian and bike-friendly
City of Hermosa Beach. A Traffic Impact Analysis (TIA)
prepared by Arch Beach Consulting (2013) concluded
that project-related traffic would not significantly impact
the level of service on any of the studied roadway
segments and therefore the EIR indicated that project-
related traffic will not have a significant impact on traffic
congestion. However, the introduction of truck traffic on
roads not accustomed to large trucks could represent a safety hazard to bicyclists and pedestrians.
Consequently, the EIR recommends additional mitigation including increased crossing guard presence at
the Site, installation of warning signs and lights, ensuring that trucks are not too long, and reconfiguring
Valley Dr. Overall, with safety measures in place, and because of the limited extent of increased traffic,
traffic safety is not predicted to have a substantial health impact in the community through the duration of
the proposed Project.
Findings from the literature suggest that perception of safety is an important mediator of the relationship
between traffic safety and active transportation, or walking/bicycle trips. Perceived risk of injury may
discourage walking and bicycling, which can directly impact health by decreasing physical activity levels.
Parental perception of safety is especially important for rates of walking and biking among children. Since
the Project Site lies on a safe walk to school route, there is a possibility that perceived traffic hazards
could result in decreased active transportation. However, the impact is limited to a portion of Valley Drive.
and most community members should be able to adapt to the increased perception of traffic hazards by
seeking alternative routes for walking and biking. Therefore, no additional measures are recommended.
Community Livability
Community livability defines elements that make it desirable
to live in a particular place. These can include
environmental, social and economic elements. For the
proposed Project, local residents voiced certain concerns
they have regarding different aspects of community
livability. The following health determinants associated with
community livability were identified and assessed as part of
the HIA: property values; access to recreational resources
and green space; aesthetics and visual resources;
education funding; social cohesion; and, political
involvement.
Commercial and industrial developments have the potential
to impact local property values. The complexities around
property value fluctuations make it difficult to accurately
evaluate the potential impact from one project. The CBA concluded that property values within Hermosa
Beach could be impacted by 0-10%; and it was suggested that any decrease in property values is likely to
be localized. Any perceived or actual decrease has the potential to moderately increase stress and
anxiety among Hermosa Beach residents, which is suggestive of a negative effect on human health. To
The traffic assessment within the HIA
concludes that, with implementation of
the proposed EIR mitigation measures,
there is no substantial effect on human
health with respect to traffic safety and
perceived traffic safety hazards.
The community livability assessment
within the HIA concludes that with
implementation of the proposed EIR
mitigation measures there is: no
substantial effect on human health
with respect to social cohesion; a
potential negative effect from stress
over property values, aesthetic/visual
resources; and a potential positive
effect on health from enhanced
recreation and green space,
educational funding and political
involvement activities.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page xi
reduce any potential stress or anxiety that local property owners may experience as a result of the
proposed Project, E&B could consider having a property value analysis conducted.
Access to recreational areas and green space is an important community resource and a key component
of overall health and well-being. Hermosa Beach residents are considered to be very active due to their
proximity to the beach, access to parks and availability of recreation and fitness facilities. While the
proposed Project would not be removing any existing green space in the community, it will be located
adjacent to a park, near other parks, and near walking and biking travel routes. Disturbances during
pipeline and Site construction (Phases 1 and 3) could temporarily affect ready access of recreational
resources or the quality of the recreational experience. On the other hand, Project revenue could be
used to enhance recreational resources, and it is predicted that there will be an overall positive impact on
community health in regards to recreation and green space. It is recommended that a community
advisory group be formed to aid the City in deciding priority for recreational / green space funding.
Aesthetic value is a complex concept that is highly subjective. There is a high degree of individual
variability when it comes to the visual impact and/or aesthetic value of an object or a place. The presence
of the electric and workover drill rigs during Phase 2 and 4 have the potential to negatively impact health
by diminishing the aesthetic appeal of the landscape. This has the potential to influence levels of
annoyance and stress; however, this is not anticipated to have a substantial effect on health. Therefore,
the post-mitigation health effect is considered negative. No additional recommendations have been made.
Educational funding can provide improvements in some of the key indicators of socioeconomic status
(i.e., occupation and income) and has been described as a cost-effective method of increasing health and
well-being. Hermosa Beach has one of the top school districts in the country and the modest increase in
annual funding that will be provided to the schools as a result of revenue from oil production is expected
to have a positive effect on health now and in the future. This positive effect is expected for all Phases of
the Project.
Social cohesion is a complex concept that is difficult to measure and is related to the interactions between
community members. Some local residents have voiced concerns about the situation causing a division in
the community – those in favor of oil development versus those opposed. As an indicator of health, social
cohesion is linked to the idea of ‘quality of life’ which is associated with certain aspects of health and well-
being. Hermosa Beach residents experience higher levels of well-being than most California cities.
Although it is not expected that all residents will experience a reduction in social cohesion due to
differences of opinion, some individuals may. For those residents, this could result in increased stress;
however, social cohesion is not considered to have a substantial effect on community health.
Active involvement in local politics is associated with increased self-efficacy and can have positive
impacts on health and well-being. Hermosa Beach residents have the unique opportunity to decide
whether the proposed Project can go ahead by voting on whether to allow oil drilling within the City. This
opportunity extends to all adult members of the community, although only a subset of the population is
actively involved in the politics and may benefit from the positive impact on health.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page xii
MONITORING AND EVALUATION
The following monitoring recommendations have been made for the City to consider including in
discussions around the Development Agreement:
Community Liaison Committee: Consideration should be given to forming a Community Liaison
Committee (CLC) if the Project is approved, and prior to commencement of construction
activities. The CLC would serve as the vehicle through which citizens could voice active
concerns about Project activities. The intention of the committee would then be to work
collectively to find ways of addressing resident’s concerns.
Follow-up Community Health Assessment: Analysis of health statistics by susceptible
subpopulation status could identify whether some groups are disproportionately impacted by
Project operations. An update to the baseline health study could be completed five years after
the Project becomes operational, but would depend on the level of concern within the
community at that time.
Quality of Life Health Survey: A quality of life (QOL) health survey could be used as a tool to
establish current baseline conditions, and to monitor whether health status changes during the
Project. There are well established survey tools available (SF-36 and Pittsburgh Sleep Quality
Index [PSQI]) that could be employed. The most cost-effective means of delivering these
surveys would be on-line; however, data quality collection can be compromised. Mail drops
could also be considered. This survey would then be followed up after operations began.
Although not a component of all HIAs, the evaluation step can demonstrate the effectiveness of HIA in the
planning process by showing what the assessment actually achieved. An internal evaluation of the overall
approach and effectiveness of the HIA will be conducted internally by Intrinsik’s HIA team. The City of
Hermosa Beach may also wish to evaluate the utility of the HIA to identify aspects of the process that
were beneficial and those that could be enhanced in the future.
CONCLUSION
There is no simple answer to the potential impact that the Project will have on the health of Hermosa
Beach residents since different aspects of the proposed Project will impact the community in different
ways. We caution that the assessment and conclusions are based on population health and not on single
individuals. There are a number of aspects of the Project that may positively influence health (e.g.,
increased education funding, ability to enhance green space), and at the same time there were potential
negative health outcomes identified (e.g., odor, well blowout, noise from pipeline construction, property
values, and aesthetics). With the exception of a well blowout accident, the negative health outcomes were
largely nuisance related (e.g., odor, noise, aesthetics) without irreversible health impacts. The majority of
the health determinants examined revealed that the Project (post-mitigation) would have no substantial
effect on the health of the community.
Based on the Final EIR mitigation measures and additional recommendations provided in the HIA, on
balance we do not believe that the Project will have a substantial effect on community health in Hermosa
Beach. Ultimately it is the voters of Hermosa Beach who will decide whether the impacts described in this
HIA are acceptable or not.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014 City of Hermosa Beach, CA Page xiii Table PS-2 Health Impact Assessment Summary Based on Post-Mitigation Measures Health Determinant Potential Health Outcome EIR Mitigation Measures Geographic Extent Vulnerable Populations Magnitude Adaptability Likelihood Post-Mitigation Health Effect Comments or Additional Recommended Measures Air Quality Nitrogen Dioxide (NO2) Emissions Respiratory irritation and airway constriction NOx reduction program (AQ-1b), limited flaring (AQ-3a), and air monitoring plan (AQ-5d) Localized Children; elderly; pre-existing cond Low High Unlikely No substantial effect None Particulate Matter (PM) Emissions Morbidity (e.g., cardio-pulmonary effects) and mortality. Limited flaring (AQ-3a), limited microturbine PM emissions (AQ-4), air monitoring plan (AQ-5d), and diesel emission requirements (AQ-7a) Localized Children; elderly; pre-existing cond Low High Unlikely No substantial effect. None Toxic Air Contaminants (TAC) Emissions Varies for the TACs. Includes acute effects, chronic non-carcinogenic and carcinogenic effects. Air quality mitigation measures (AQ-1a, AQ-1b, AQ-3a, AQ-3b, AQ-4, AQ-5a through AQ-5f, AQ-6, AQ-7a, AQ-7b) Localized Children; elderly; pre-existing cond Low High Unlikely No substantial effect. Cancer risks, chronic non-cancer risks and acute risks will be below threshold values post-mitigation. Odor Emissions Acute health symptoms from odiferous compounds in crude oil Air quality mitigation measures to reduce off-gassing of vapors from drilling muds (AQ-3b ) and for operational odor controls including an Odor Minimization Plan (AQ-5a through AQ-5f) Localized Odor sensitive individuals Medium Low Possible Negative Periodic discomfort and annoyance from odor releases is likely. If frequent reports of odor occur, additional study and/or periodic monitoring of odor may be warranted. Water and Soil Surface Water Acute health symptoms Storm Water Pollution Prevention Plan (HWQ 1-1a to 1-1g) Localized Beach users Medium Medium Unlikely No substantial effect None Soil Particles Varying degrees of human health risk Fugitive Dust Control Plan (AQ-1a) and soil sampling (SR-2) Localized Children Unknown Unknown Unlikely No substantial effect None Upset Scenarios Crude Oil Spill Acute health symptoms and psychological effects including stress An independent third party audit of equipment and additional upset scenario risk reduction measures (SR-1a through SR-1g) Localized People in immediate vicinity Medium Medium Unlikely No substantial effect Incorporate well blowout scenario into the City of Hermosa preparedness plan Well Blowout Injuries and/or fatalities and psychological effects including stress An independent third party audit of equipment and additional upset scenario risk reduction measures (SR-1a through SR-1g) Localized People in immediate vicinity (est. max 750 ft)1 High Low Unlikely Negative Incorporate well blowout scenario into the City of Hermosa preparedness plan Noise and Lighting Noise Emissions Annoyance, stress, sleep disturbance and hypertension and cognitive impairment at very high sound pressure levels Noise mitigation measures Phase 1: NV-1a to NV-1c Phase 2: NV-2a to NV-2j; NV-3a to NV-3d Phase 3a (site construction): NV-4a to NV-4c Phase 3b (pipeline construction): none Phase 4: NV-6a to NV-6h; NV-7a to NV-7c Phase 1-4: Localized (Project Site and truck /pipeline routes) Residents and schoolchildren in proximity to pipeline route Phase 1: Low Phase 2: Low Phase 3a: Low Phase 3b: Medium Phase 4: Low Phase 1: High Phase 2: High Phase 3a: High Phase 3b: Medium Phase 4: High Phase 1: Possible Phase 2: Possible Phase 3a: Possible Phase 3b: Probable Phase 4: Possible Phase 1: No substantial effect Phase 2: No substantial effect Phase 3a: No substantial effect Phase 3b: Negative Phase 4: No substantial effect In anticipation of potential elevated noise levels from pipeline construction activities (Phase 3b) it is recommended that local residents be provided with written notification of impending work including the dates and times of activities that may produce excessive noise. Light Emissions Annoyance, stress and possible disturbance of typical sleep cycles Light mitigation measures Phases 2-4: AE-4a to AE-4c; AE-5a to AE-5e; AE-6a to AE-6b Localized People with a direct line-of-site of the lit side of electric drill rig at night Low High Unlikely No substantial effect Although the magnitude is ‘low’ for the majority of residents, it could be higher for those individuals with a bedroom window in the direct line-of-sight of the exposed side of the electric drill rig that will be lit at night. It is recommended that these individuals be provided with the option of black-out blinds or curtains to eliminate any potential impact to typical sleep patterns.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014 City of Hermosa Beach, CA Page xiv Table PS-2 Health Impact Assessment Summary Based on Post-Mitigation Measures (con’t) Health Determinant Potential Health Outcome EIR Mitigation Measures Geographic Extent Vulnerable Populations Magnitude Adaptability Likelihood Post-Mitigation Health Effect Comments or Additional Recommended Measures Traffic Traffic Safety Potential increase in number of pedestrian, bicycle or other injuries Traffic mitigation measures (TR-1a through TR-1d) Localized Pedestrians and cyclists (Children and the elderly) High Medium Unlikely No substantial effect None Perceived traffic hazards Decrease in active transportation Traffic mitigation measures (TR-1a through TR-1d) Localized Pedestrians and cyclists (Children) Medium Medium Unlikely No substantial effect None Community Livability Property Values Potential increase in stress and anxiety Not Applicable Localized Property owners Medium Medium Possible Negative E&B could consider evaluating housing prices for those in the immediate vicinity of the Project Site. Access to Recreational Resources and Green Space Change in physical activity levels, which can lead to other health issues Not Applicable Community None Medium High Possible Positive To maximize potential health benefits from access to green space and recreational activities the City should form a community advisory group on how to spend revenue. Aesthetics and Visual Resources Annoyance and stress from negative perceptions and anxiety over project aesthetics Aesthetic and visual mitigation measures AE-1a to AE-1b; AE-2a to AE-2d; AE3a to AE-3c Community None Medium Medium Possible Negative The overall impact is negative based on the aesthetic environmental change leading to increased levels of annoyance and stress in some individuals. Education Funding Increased resources and funding for education can indirectly lead to a more positive health status Not Applicable Community Schoolchildren Medium High Probable Positive None Social Cohesion Potential increase in stress Not Applicable Community None Low Medium Possible No substantial effect None Political Involvement Increase in self-efficacy and positive impacts on health and well-being over communities ability to vote Not Applicable Community Voters Medium High Possible Positive None 1Figures 4.8-5 and 4.8-6 of Final EIR provide estimated range and map, respectively (MRS, 2014)
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page xv
TABLE OF CONTENTS
PROJECT SUMMARY .................................................................................................................. i
1.0 PROJECT INTRODUCTION .............................................................................................. 1
1.1 City of Hermosa Beach ................................................................................................... 1
1.2 Oil Development and Production Activities ..................................................................... 2
1.3 Project Description ......................................................................................................... 3
1.3.1 Phase 1 – Site Preparation and Construction (6 to 7 months) ................................ 5
1.3.2 Phase 2 – Drilling and Testing (10 to 13 months) ................................................... 5
1.3.3 Phase 3 – Final Design and Construction (16 months) ........................................... 5
1.3.4 Phase 4 – Development and Operations (approximately 30 to 35 years) ............... 6
2.0 HEALTH IMPACT ASSESSMENT INTRODUCTION AND METHODOLOGY ................. 7
2.1 HIA Definition .................................................................................................................. 8
2.2 Purpose and Rationale for Conducting an HIA ............................................................... 9
2.3 Steps of an HIA ............................................................................................................ 10
2.4 HIA Evaluation Matrix ................................................................................................... 13
3.0 SCREENING .................................................................................................................... 19
4.0 SCOPING ......................................................................................................................... 20
4.1 Stakeholder Engagement ............................................................................................. 20
4.2 Pathways ...................................................................................................................... 23
4.2.1 Air Quality .............................................................................................................. 25
4.2.2 Water and Soil Quality ........................................................................................... 28
4.2.3 Upset Conditions ................................................................................................... 30
4.2.4 Noise and Light ..................................................................................................... 32
4.2.5 Traffic .................................................................................................................... 34
4.2.6 Community Livability ............................................................................................. 36
5.0 ASSESSMENT ................................................................................................................ 38
5.1 Baseline Health Assessment ........................................................................................ 38
5.1.1 Demographic Characteristics ................................................................................ 38
5.1.2 Current Health Conditions ..................................................................................... 39
5.1.3 Environmental Quality ........................................................................................... 41
5.1.4 Health Supporting Resources and Health Promotion ............................................ 41
5.1.5 Discussion of Vulnerable and Sensitive Populations ............................................ 42
5.2 Air Quality Assessment ................................................................................................ 42
5.2.1 Nitrogen Dioxide (NO2) .......................................................................................... 43
5.2.2 Particulate Matter (PM) ......................................................................................... 48
5.2.3 Toxic Air Contaminants ......................................................................................... 54
5.2.4 Odor ...................................................................................................................... 61
5.2.5 Summary and Conclusions of Air Quality .............................................................. 65
5.3 Water and Soil Quality .................................................................................................. 67
5.3.1 Surface Water ....................................................................................................... 67
5.3.2 Soil Particulates ..................................................................................................... 70
5.3.3 Summary and Conclusions for Water and Soil Quality.......................................... 72
5.4 Upset Conditions .......................................................................................................... 73
5.4.1 Oil Spill .................................................................................................................. 73
5.4.2 Well Blowout .......................................................................................................... 76
5.4.3 Summary and Conclusions for Spill or Blowout Upsets ........................................ 78
5.5 Noise and Light ............................................................................................................. 79
5.5.1 Noise Emissions .................................................................................................... 79
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page xvi
5.5.2 Light Emissions ..................................................................................................... 96
5.5.3 Summary and Conclusions of Noise and Light Emissions .................................. 106
5.6 Traffic .......................................................................................................................... 107
5.6.1 Traffic Injury ......................................................................................................... 107
5.6.2 Active Transportation .......................................................................................... 115
5.6.3 Summary and Conclusions ................................................................................. 119
5.7 Community Livability ................................................................................................... 120
5.7.1 Property Values ................................................................................................... 120
5.7.2 Community Resources: Access to Recreational Resources and Green Space .. 125
5.7.3 Community Resources: Aesthetics and Visual Resources.................................. 129
5.7.4 Community Resources: Education Funding ........................................................ 139
5.7.5 Social Cohesion .................................................................................................. 142
5.7.6 Political Involvement ............................................................................................ 145
5.7.7 Summary and Conclusions for Community Livability .......................................... 147
6.0 ADDITIONAL RECOMMENDATIONS, MONITORING AND EVALUATION ................ 149
6.1 Recommendations ...................................................................................................... 149
6.2 Monitoring ................................................................................................................... 150
6.3 Evaluation ................................................................................................................... 152
7.0 LIMITATIONS AND UNCERTAINTIES ......................................................................... 153
8.0 CONCLUSIONS ............................................................................................................. 155
9.0 REFERENCES ............................................................................................................... 159
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page xvii
FIGURES
Figure 1-1 Proposed Project Location (Source: Project Application) ........................................... 4
Figure 2-1 Social Determinants of Health (Whitehead and Dahlgren, 1991) ............................... 7
Figure 2-2 Steps of an HIA (Modified from Ross et al., 2014) ................................................... 10
Figure 2-3 Decision-Making Framework for the HIA Evaluation Matrix ..................................... 18
Figure 4-1 Distribution of Survey Participants Place of Residence ............................................ 22
Figure 4-2 Social Ecological Health Framework (USHHS, 2008) .............................................. 24
Figure 4-3 Air Quality Pathway Diagram .................................................................................... 27
Figure 4-4 Water and Soil Quality Pathway Diagram ................................................................ 29
Figure 4-5 Upset Scenarios Event Pathway Diagram ................................................................ 31
Figure 4-6 Noise and Light Pathway Diagram ........................................................................... 33
Figure 4-7 Traffic Pathway Diagram .......................................................................................... 35
Figure 4-8 Community Livability Diagram .................................................................................. 37
Figure 5-1 Possible health implication of exposure to noise (WHO, 2009) ................................ 81
Figure 5-2 Noise Monitoring Locations around the Proposed Project Site (MRS, 2014) ........... 83
Figure 5-3 Common Environmental Noise Levels (MRS, 2014) ................................................ 85
Figure 5-4 Noise Levels Measured at 20 Construction Sites (Mean ± SD) (Golmohammadi et
al., 2013) ..................................................................................................................................... 91
Figure 5-5 Increase in Artificial Night Sky Brightness in North America (Chepesiuk, 2009) ...... 98
Figure 5-6 View Simulation of Drilling Rig at Night (MRS, 2014) ............................................. 103
Figure 5-7 Project Site Location and Traffic Impact Assessment Study Area (MRS, 2014) .... 112
Figure 5-8 Safe Routes to School (MRS, 2014) ...................................................................... 117
Figure 5-9 Pedestrian Sidewalk, Valley Dr./ 6th St. (google maps) ......................................... 118
Figure 5-10 Common Indicators of Socio-Economic Status (SES) .......................................... 120
Figure 5-11 Parks currently located throughout the City of Hermosa Beach ........................... 127
Figure 5-12 Typical descriptors of aesthetic value as an indication of visual appeal ............... 130
Figure 5-13 Key Observation Point (KOP) 7: Existing and During Phase 2 and 4 with Drill Rig
(MRS, 2014) .............................................................................................................................. 137
Figure 5-14 Key Observation Point (KOP) 18: Existing and During Phase 2 and 4 with Drill Rig
(MRS, 2014) .............................................................................................................................. 138
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page xviii
TABLES
Table 2-1 HIA Evaluation Matrix ................................................................................................................ 14
Table 4-1 Ranking of Environmental and Health Areas of Concern .......................................................... 23
Table 5-1 Demographic Summary (US Census, 2013) ............................................................................. 39
Table 5-2 Potential Acute Health Effects Associated with NO2 ................................................................. 45
Table 5-3 Comparison of Maximum Predicted NO2 Air Concentrations for the Mitigated Scenario against
Health-Based Air Quality Guidelines ........................................................................................................... 46
Table 5-4 HIA Evaluation Metric – Nitrogen Dioxide (NO2) ....................................................................... 47
Table 5-5 PM10 Air Concentrations Measured in Los Angeles County in 2012 ......................................... 49
Table 5-6 PM2.5 Air Concentrations Measured in Los Angeles County in 2012 ........................................ 50
Table 5-7 Comparison of Maximum Predicted Air Concentrations for PM2.5 for the Mitigated Scenario
against the World Health Organization’s Air Quality Guidelines ................................................................. 52
Table 5-8 HIA Evaluation Metric – Particulate Matter (PM2.5) .................................................................... 53
Table 5-9 Predicted Cancer Risks (per one million) associated with the Project under the Mitigated
Scenario ...................................................................................................................................................... 56
Table 5-10 Predicted Acute Hazard Indices under the Mitigated Scenario ............................................... 56
Table 5-11 Predicted Chronic Hazard Indices under the Mitigated Scenario ............................................ 57
Table 5-12 Potential Additive Interactions between the Toxic Air Contaminants ...................................... 58
Table 5-13 Cancer Risks and Non-Cancer Risks for the Mixtures ............................................................ 59
Table 5-14 HIA Evaluation Metric – Toxic Air Contaminants (TAC) .......................................................... 60
Table 5-15 Air Quality Assessment: Odors ................................................................................................ 64
Table 5-16 Water and Soil Quality Assessment: Surface Water ............................................................... 69
Table 5-17 Water and Soil Quality Assessment: Soil Particulates ............................................................ 71
Table 5-18 Upset Scenario: Crude Oil Spill ............................................................................................... 75
Table 5-19 Upset Scenario – Well Blowout ............................................................................................... 78
Table 5-20 Summary of Existing Ambient Leq Noise around the Proposed Project Site (MRS, 2014) .... 83
Table 5-21 Truck and Pipeline Route Ambient Noise Measurement Summary (MRS, 2014) ................... 84
Table 5-22 Daytime and Nighttime Noise Level Standards (MRS, 2014) ................................................. 87
Table 5-23 Predicted Daytime Noise (dBA) around Local Schools from Project Site and Maintenance
Yard Relocation Activities (SRA, 2014) ...................................................................................................... 93
Table 5-24 Predicted Daytime Noise around Local Schools from Pipeline Construction Activities (SRA,
2014) ........................................................................................................................................................... 94
Table 5-25 Noise and Light Assessment: Noise Emissions ...................................................................... 95
Table 5-26 Noise and Light Assessment: Light Emissions ...................................................................... 105
Table 5-27 Project Trip Generation Estimates (Arch Beach Consulting, 2012). ..................................... 111
Table 5-28 Roadway Segment Analysis, 6th St from Valley Dr to Hermosa Ave (Arch Beach Consulting,
2012). ........................................................................................................................................................ 113
Table 5-29 Traffic Assessment: Traffic safety .......................................................................................... 114
Table 5-30 Traffic Assessment: Perceived traffic hazards ...................................................................... 118
Table 5-31 Community Livability Assessment: Property Values ............................................................. 124
Table 5-32 Community Livability Assessment: Access to Recreational Resources and Green Space .. 129
Table 5-33 Community Livability Assessment: Aesthetics and Visual Resources .................................. 139
Table 5-34 Community Livability Assessment: Education Funding ......................................................... 141
Table 5-35 Community Livability Assessment: Social Cohesion ............................................................. 144
Table 5-36 Community Livability Assessment: Political Involvement ...................................................... 146
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APPENDICES
Appendix A Summary of Los Angeles Urban Oil Drilling Sites
Appendix B Scoping Checklist
Appendix C Response to Public and Peer Review Comments
Appendix D Health Impact Assessment Community Survey
Appendix E Baseline Health Assessment
Appendix F Quality of Life Committee Presentation
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Glossary of Terms, Acronyms, and Abbreviations
AAQS
ACS
Ambient Air Quality Standards
American Cancer Society
BCHD Beach Cities Health District, serving Manhattan, Hermosa, and Redondo
Beaches
BTEX Acronym for benzene, toluene, ethylbenzene and xylenes, compounds
commonly found in petroleum derivatives
Cal/EPA
CARB
California Environmental Protection Agency
California Air Resources Board
CBA Cost-benefit analysis, a method of considering the advantages and
disadvantages of a project by converting all outcomes into monetary values
CEQA California Environmental Quality Act, legally requires EIR
City
CNEL
CNS
CO
City of Hermosa Beach
Community Noise Equivalent Level
Central Nervous System
Carbon monoxide
Community
Dialogue
COPD
A group of 15-30 community members engaged in activities to help define
the quality of life and vision for the future of Hermosa
Chronic Obstructive Pulmonary Disease
CUP Conditional Use Permit approved on August 12, 1993, which the proposed
project must comply with
dB Decibel - A unit of a logarithmic scale of power or intensity called the power
level or intensity level
dBA A-weighted decibel, to approximate human sensitivity to sound
DDT Pesticide banned by the USEPA in 1972 due to environmental effects
Determinants of
health
EPA
Factors that contribute to the health of individuals or communities
Environmental Protection Agency
E&B E&B Natural Resources Management Corporation
EIR Environmental Impact Report, the analysis of the environmental effects of a
project and reasonable alternatives to it, mandated by CEQA
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Footcandle The illuminance at a point on a surface which is one foot from, and
perpendicular to, a uniform point source
H2S Hydrogen sulfide
HBEF Hermosa Beach Education Foundation
HHRA
HI
Human Health Risk Assessment
Hazard Index
HIA Health Impact Assessment, a combination of procedures, methods, and
tools by which a project can be judged as to its potential effects on the
health of a population
IARC International Agency for Research on Cancer
Incidence rate
KOP
LACDPH
LAN
A measure of the new cases of illness during a specified time period
Key Observation Point
Los Angeles County Department of Public Health
Light-at-Night
Ldn Sound level measured over the 24 hour period, with a 10 dB penalty added
to the levels between 23.00 and 07.00 hours
Leq Equivalent sound level, or the average noise level over a period of time
LOS
lux
MATES
Level of service, related to the degree of traffic congestion at intersections
The illuminance at the same point at a distance of 1 meter from the source
Multiple Air Toxics Exposure Study
MATES III Multiple Air Toxics Exposure Study III
Morbidity Refers to the presence of disease in an individual or population
Mortality rate A measure of the frequency of death in a defined population during a
specified time interval
NAAQS National Ambient Air Quality Standards
NOx
NNG
Oxides of Nitrogen
Night Noise Guidelines
OEHHA California Office of Environmental Health Hazard Assessment
PAHs Polycyclic aromatic hydrocarbons
PCE Passenger car equivalence
PCB Polychlorinated biphenyl, PCBs are no longer commercially produced in the
US due to toxicity
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PCH Pacific Coast Highway, the most trafficked roadway in Hermosa Beach
PM
PMI
Particulate matter, particles with a diameter smaller than 10 µm are referred
to as PM10, and particles with a diameter smaller than 2.5 µm are known as
PM2.5
Point of Maximum Impact
ppb Parts per billion
ppm Parts per million
proposed Project
REL
Proposed E&B oil drilling and production project
Relative Exposure Level
SCAQMD
SES
Southern California Air Quality Monitoring District
Socio-economic Status
SIR Standardized incidence ratio, quotient of observed and expected number of
cases (e.g., cancer cases)
Site
SO2
SWPP
TAC
Proposed project site, at the current City Maintenance Yard
Sulfur dioxide
Storm Water Pollution Prevention Plan
Toxic Air Contaminant
TMDL Total maximum daily load, a regulatory water quality requirement
TPH Total petroleum hydrocarbons
TIA Traffic impact analysis
USEPA United States Environmental Protection Agency
µg/m3 Microgram per meter cubed
VOCs Volatile organic compounds
WSB Walking school bus
WHO World Health Organization
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1.0 PROJECT INTRODUCTION
Under the settlement agreement that ended litigation with Macpherson Oil Company, an
election will be held to allow the City of Hermosa Beach (the City) voters to decide whether to
repeal the existing ban on oil drilling within City limits. Repealing the ban on oil drilling would
allow the E&B Natural Resources Management Corporation’s (E&B’s) proposed oil drilling and
production project to move forward (Macpherson Oil sold its interests to E&B at the time of the
settlement agreement). The terms of the settlement agreement provide that, if voters agree to
lift the ban, the City will enter into a development agreement with E&B to develop an oil drilling
and production facility (the Project) at the City Maintenance Yard (the Site) and the City will owe
E&B $3.5 million. If the voters do not lift the ban on oil drilling the City of Hermosa Beach would
owe E&B a total of $17.5 million.
In order to inform voters about the potential economic, social, environmental, and health
impacts and/or benefits of E&B’s proposed oil drilling and production project, the City
commissioned a Health Impact Assessment (HIA), in addition to a Cost-Benefit Analysis (CBA)
and Environmental Impact Report (EIR). The EIR complies with the California Environmental
Quality Act (CEQA), while the CBA and HIA are complementary documents that the City
commissioned to provide community members with additional information on the proposed
Project.
If the proposed Project is approved by Hermosa Beach voters, the agencies that will oversee
and participate in environmental and safety reviews include the California Coastal Commission,
the State Lands Commission, the South Coast Air Quality Management District, the State
Division of Oil, Gas and Geothermal Resources, and the City of Hermosa Beach, among others.
1.1 City of Hermosa Beach
Founded in 1907, Hermosa Beach is a small 1.43 square mile City on Los Angeles (LA)
County’s South Bay coastline, bordered by Manhattan Beach to the north and Redondo Beach
to the south. Known as “The Best Little Beach City”, it has a population of approximately 20,000
people, with a high proportion of residents between the age of 25 and 50 (US Census, 2013).
The City is a desirable place to live for many reasons especially the year-long mild
temperatures, ranging from highs of 67 degrees in the winter to 77 degrees in the summer and
nighttime temperatures that rarely dip below 50 degrees. Residents often keep windows open
year-round, and use of heating and air-conditioning units are rare. The City is also known as
being a popular place for outdoor activities such as surfboarding, volleyball, skateboarding,
jogging and bicycling, among others. There is a popular wood chip jogging/walking trail (the
“Greenbelt”) running north-south between Valley Drive and Ardmore Avenue, one of the main
transportation routes that traverses the length of Hermosa Beach, and connecting the City to its
northern and southern beach city neighbors. It is regularly used by residents and visitors for
exercise, outdoor recreation, and active transport through the City. A diverse restaurant and bar
scene also creates a vibrant nightlife in Hermosa.
Together with Manhattan Beach and Redondo Beach, Hermosa is part of what is known as the
“Beach Cities”. Hermosa Beach has its own elementary schools and middle school but high
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school students are served by either Manhattan Beach or Redondo Beach. Hermosa also
shares public transportation and health services with the two other Beach Cities. The City of
Hermosa has its own police and fire departments, a community theater, and senior center.
1.2 Oil Development and Production Activities
The current boom in domestic crude oil production is approaching the historical high achieved in
1970 of 9.6 million barrels per day (EIA, 2013). Projections and analysis summarized in the
Energy Information Administration’s Annual Energy Outlook 2014 Release Overview attribute
the growth in domestic production to improvements in advanced technologies for crude oil and
natural gas production. Specifically for U.S. production of crude oil, projections for higher
production volumes result mainly from increased onshore oil production, primarily from
formations with low permeability. California remains one to the top producers of crude oil in the
nation, accounting for almost one-tenth of the total U.S. production (EIA, 2013). Petroleum
reservoirs are concentrated in geologic basins along the Pacific Coast and in the Central Valley.
Los Angeles is considered the most urban oil field in the country, with a long history of the
petroleum industry operating in non-industrial areas (CLUI, 2010). Due to the high cost of land
in the Los Angeles basin, there has been economic incentive to develop modern drilling
technology that allows oil wells to be concentrated into smaller areas. Directional drilling
techniques decrease the industry’s surface footprint while increasing the subsurface drillable
area. Since industrial processes are generally not desired in densely populated areas due to
environmental and health concerns, many oil drilling sites in Los Angeles have incorporated
mitigation measures (e.g. noise muffling, visual barriers, closed-loop systems) to help reduce
the potential impacts on surrounding communities.
There are 34 known active oil fields in the Los Angeles Basin spread out across the regions of
Inglewood, Westside and Downtown, Eastern Los Angeles and Inland, the Coast and South
Bay, Harbor and Long Beach, and the South Coast (Appendix A). The active oil fields vary
greatly in size and in oil production volumes. Small fields like Chino-Soquet produce just over
1,000 barrels of oil per year while Wilmington, the most productive oil field in the Los Angeles
Basin, produces about 3.5 million barrels per year from 1,300 active wells. Many of the wells
operate in densely populated urban areas. For example, the Beverly Hills Oil Field is accessed
from three urban well sites, including one within Beverly Hills High School and another on Pico
Boulevard hidden from view by a windowless four-walled structure that appears to be an office
building to the passerby. Given the long history of oil drilling in Los Angeles, the wells and
pumpjacks were often present before suburban housing developments encroached upon drilling
leases.
Appendix A summarizes some of the known issues associated with urban drilling sites. Various
health and environmental concerns surround production at the Inglewood oil field, which covers
950 acres in urbanized Los Angeles. In 2006, noxious gases entrained in drilling muds were
released and detected by neighbors more than 1,000 feet from drilling activities. As a result of
several investigations, a 2011 CEQA lawsuit settlement required the operator to: reduce drilling
of new wells, increase air quality monitoring, and adhere to more stringent noise limits.
Additionally, LA County was required to perform mandatory health assessments with
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City of Hermosa Beach, CA Page 3
environmental justice components. Other health concerns from urban oil drilling relate to surface
methane seeps, noise and odor, and land subsidence. Oil seeps from the Salt Lake oil field
located beneath the Fairfax district caused a 1985 methane explosion at a clothing store,
injuring over 20 people. Concern about the potential for future fire and explosions led the City of
Los Angeles to impose requirements for methane venting and monitoring. That said these are
relatively rare accidents and upset conditions.
This HIA evaluates potential health effects that could result from oil drilling and production
activities in the City of Hermosa Beach according to the site-specific Project description
(summarized in Section 1.3) and information provided in the Final EIR.
1.3 Project Description
The proposed Project consists of drilling 30 oil wells on a 1.3-acre site located on the current
City Maintenance Yard property (the Site) located at 555 6th Street, at the intersection of Valley
Drive and 6th Street in the City. The Site is bounded by industrial/commercial use properties to
the north, south, and west. Commercial/industrial properties include Beach Cities Self Storage,
Cypress Auto Body, A&B Heating, JB Plumbing, McGivern Surfboard Manufacturing, Buddhist
Meditation Center, NUWORK (a recording studio), and other various small businesses. The Site
is bounded by the Greenbelt, a park and recreational use space, to the east. Adjacent blocks
also include residential uses located 150 feet to the north of the Project Site, 250 feet to the
west and 180 feet to the east (east of the Greenbelt). The Pacific Ocean is approximately a half
mile west of the Site. While the Site itself is relatively flat, the surrounding topography is rolling
and varies due to underlying windblown sand dunes. The Site is currently the location of the City
Maintenance Yard and the proposed Project would require relocation of the City Maintenance
Yard to another property. The fenced and gated Maintenance Yard Facility includes two
buildings, an office trailer, several equipment storage containers, a vehicle washout area, and a
construction materials storage area. The Maintenance Yard location was used as a landfill from
about 1927 to 1947, and an abandoned oil well is also on the Site. Figure 1-1 shows the Site
location in relation to the public property, private property, and Pacific Ocean.
The proposed Project would involve the installation of underground pipelines to transport the
processed oil and gas. The complete description of the proposed Project is provided in the
Project Application and supporting documents (E&B, 2012; 2013a,b). Briefly, E&B (the
Applicant) has stated the following objectives:
Develop the proposed Project consistent with the 1993 Conditional Use Permit and
the March 2, 2012 Settlement Agreement, with the use of directional drilling
techniques from the Project site, which is the current City Maintenance Yard;
Maximize oil and gas production from the Torrance Oil Field within the City’s
jurisdiction, thereby maximizing the economic benefits to the City;
Provide an oil and gas development Project on the Site that utilizes the latest
technology and operational advancements related to safety and production efficiency
in order to provide a Project that would be safe and meet the applicable
environmental requirements;
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Conduct construction and drilling activities on the Project Site incorporating
technological advancements, operational practices, and design features related to air
quality, odors, noise, hazards, and water quality to minimize the potential impacts on
the adjacent community and the environment;
Provide landscaping, hardscaping, signage, lighting, and other design features to
minimize the visual effects of the proposed Project on the adjacent community; and,
Implement operational practices and incorporate design features to provide safe
vehicular ingress and egress during temporary construction activities and the
ongoing operation of the proposed Project.
Figure 1-1 Proposed Project Location (Source: Project Application)
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City of Hermosa Beach, CA Page 5
To accomplish E&B’s objectives, the proposed Project would occur in four phases, as described
below.
1.3.1 Phase 1 – Site Preparation and Construction (6 to 7 months)
The primary purpose of Phase 1 is to prepare the Site for drilling and testing, as well as the
subsequent phases of the proposed Project. Construction activities include clearing and grading
the Site, constructing retaining walls and the well cellar, installing fencing and electrical
equipment, and placing existing overhead utilities underground. At this time, the City
Maintenance Yard would be relocated to a temporary location. The most disruptive construction
activities during this phase are expected to be demolition of existing infrastructure on the Site
and construction of the well cellar. The erection of temporary 16-foot sound attenuation walls
would reduce noise impacts related to construction. Construction activities will require trucks
delivering and removing construction equipment to use designated truck routes in the cities of
Hermosa Beach, Manhattan Beach, Redondo Beach and Torrance. Truck deliveries during all
phases of the proposed Project would be limited to the hours between 9:00 am and 3:00 pm
Monday through Friday, and limited to 18 round trips per day.
1.3.2 Phase 2 – Drilling and Testing (10 to 13 months)
This phase will involve drilling and testing of wells in order to estimate the potential productivity
and economic viability of the proposed Project. Up to three wells and one water
disposal/injection well (a total of four wells) would be drilled. The primary construction and
drilling activities include installing a temporary trailer on the northeast corner of the site, setting
up the drill rig and other production equipment, drilling the test wells, and operation activities. An
electric drill rig will be used, reducing the need for diesel engines. The 87-foot high drill rig would
operate for 24 hours per day, seven days per week for an estimated 120 days during this phase.
Temporary lighting would be provided that would be shielded / hooded and directed downward.
A 32-foot-high sound barrier wall would be constructed around the perimeter of the Site for the
duration of all drilling activities. Processed oil from Phase 2 would be trucked to an offsite oil
receiving facility in Torrance. If it is determined that the proposed Project is not economically
viable, the Applicant would decommission installed equipment leaving the Site empty and
available for future development or for the temporary City Maintenance Yard to move back to
the Site. Conversely, if the project is found to be economically viable the City Maintenance Yard
will be permanently relocated.
1.3.3 Phase 3 – Final Design and Construction (16 months)
If Phase 2 determines that the proposed Project is economically feasible, Phase 3 would be
carried out to prepare the Site for permanent oil and gas production facilities and to construct
offsite pipelines. After removing the temporary production equipment and the 32-foot wall from
Phase 2 and preparing the Site for earthmoving activities, the Remedial Action Plan would be
implemented to address residual metal and petroleum-contaminated soil and groundwater
beneath the former landfill area in the northeastern portion of the Site. This phase would then
involve construction of additional retaining walls and final grading, extending and completing the
construction of the cement well cellar (to be approximately 8 feet wide by 120 feet long by 12
feet deep), placing a small office building onsite, installation of permanent production
equipment, final Site and landscaping improvements, and erecting the 32-foot sound barrier wall
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page 6
for noise attenuation during Phase 4 drilling. The permanent oil production facility will include
tanks, vessels, piping, pumps, filters and corresponding metering equipment. The Site will be
paved and the facility will be designed in a manner to capture all liquids, including rainwater, in
designated containment areas. Street improvements (e.g. new curbs, gutters, sidewalks) will be
completed along 6th Street and Valley Drive.
The offsite underground pipeline for gas transport would be constructed to a tie-in point of
receipt at a proposed metering station in the City of Redondo Beach (0.43 miles from the Site),
and from there the gas company would construct a pipeline that extends for approximately 1.4
miles to an existing pipeline transmission facility in the City of Redondo Beach. Also during
Phase 3, approximately 3.55 miles of underground pipeline for oil transport would be
constructed to a tie-in at a valve box in Torrance along one of three proposed pipeline routes.
Pipeline construction activities would occur on weekdays between 9:00 am and 3:00 pm, over a
period of approximately 4 months during Phase 3. A depiction of the proposed pipeline routes
can be found in the Final EIR Section 2, Figure 2.15. At the time of HIA preparation a preferred
pipeline route had yet to be selected.
1.3.4 Phase 4 – Development and Operations (approximately 30 to 35 years)
Phase 4 will maximize oil and gas recovery through the construction of an 87-foot high drill rig,
the drilling of the remaining oil wells and water disposal/injection wells through the continuous
operation of the proposed Project. It is estimated that it will take two weeks to set up the drill rig,
and two and a half years to drill the remaining wells, up to a total of 30 oil wells and four
disposal/injection wells. Facility operations and maintenance would be continuous for
approximately 30 to 35 years, with periodic re-drills during the life of the Project (averaging 30
days per years with a maximum of 150 days in one single year). Re-drilling of a well would
occur if production from a well declines or if problems exist with the well. Re-drills would involve
the same activities and equipment as all other drilling activities, including the use of a 32-foot
sound attenuation wall. Over the life of the proposed Project, active wells would also require
periodic maintenance, which will be accomplished by utilizing a 110-foot high “workover” rig
(during weekdays 8:00 am to 6:00 pm only for a maximum of 90 days per year). The permanent
production equipment would operate 24 hours a day, seven days per week.
The Site would be staffed 24 hours a day, seven days per week. At the end of the proposed
Project, a separate permit process and CEQA environmental review would be required to
decommission the Site.
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2.0 HEALTH IMPACT ASSESSMENT INTRODUCTION AND METHODOLOGY
The World Health Organization (WHO) defines health as “a state of complete physical, mental
and social well-being and not merely the absence of disease or infirmity” (WHO, 1948). This
definition is considered an ideal to strive for, and it forms the basic principle upon which HIA is
based. Historically, community health has been a secondary consideration (if it is formally
considered at all) in many policy/project decision making processes. When it has been included,
it tends to be limited to an evaluation of health impacts associated with environmental
contaminants. For this reason, HIA is intended to incorporate a wider range of potential health
determinants. Often referred to as the ‘social determinants of health’ this collection of factors
related to health status ranges from biological characteristics (i.e., age, gender, genetics, etc.)
to socioeconomic factors (i.e., education, income, lifestyle factors, etc.) (Figure 2-1).
Figure 2-1 Social Determinants of Health (Whitehead and Dahlgren, 1991)
There are a number of ways that health (and its determinants) can be implicated from the
execution of policy, program or project decisions. The complexities that surround each of these
determinants and the interactions among them make it particularly difficult to predict the social
impacts and associated health consequences of policy or project decisions. Despite this
difficulty, social determinants are an important predictor of overall health and well-being, which
is why the development and use of HIA has become increasingly prevalent in North America.
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2.1 HIA Definition
There are many different definitions of HIA and no universally agreed upon methodology;
although the basic purpose and approach are generally similar across international jurisdictions.
The WHO (1999) defines HIA as:
“A combination of procedures, methods and tools by which a policy, programme or
project may be judged as to its potential effects on the health of a population, and the
distribution of those effects within the population.”
However, they note that there is no ‘correct’ definition of HIA since the definitions provided by
various government and health agencies place emphasis on different aspects of the process.
The National Research Council (NRC, 2011) provides a more prescriptive definition of HIA as:
“A systematic process that uses an array of data sources and analytic methods and
considers input from stakeholders to determine the potential effects of a proposed policy,
plan, program or project on the health of a population and the distribution of those
effects within a population. HIAs provide recommendations on monitoring and managing
those effects.”
Another useful definition that highlights the interdisciplinary nature of HIA and points out the
quantitative and qualitative aspect of the process was published by Lock (2000):
“A structured method for assessing and improving the health consequences of projects
and policies in the non-health sector. It is a multidisciplinary process combining a range
of qualitative and quantitative evidence in a decision making framework.”
It is apparent from these and other definitions, that HIA is a process that has yet to be well
defined in terms of specifics, although the general approach is consistent among jurisdictions.
The recently released book “Health Impact Assessment in the United States” notes that
although there is considerable variability, several key features appear across almost all
definitions and tools (Ross et al., 2014):
1. Main purpose is to inform decision making;
2. Follows a structured but flexible process; and,
3. Examines the full range of relevant impacts to health (i.e., physical, social, etc.).
In addition, the North American HIA Practice Standards Working Group (2010), identified a
minimum number of elements that must be included in an HIA in order to distinguish it from
other processes. Accordingly, an HIA must:
Inform the decision-making process around a proposed policy, program or project
and be conducted prior to the decision being made;
Employ a systematic analytical process that:
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o Includes a scoping phase that fully considers potential impacts on health
(including social, environmental and economic determinants) and identifies
key issues for analysis;
o Encourages and uses stakeholder feedback;
o Establishes baseline health conditions;
o Relies on the best available evidence to evaluate different aspects of the
health impact (e.g., likelihood, magnitude, distribution, etc.); and,
o Makes conclusions and recommendations based on a transparent and
context-specific evaluation of the evidence while acknowledging the data
sources, strengths and limitations of evidence, uncertainties and
methodological assumptions.
Identify appropriate recommendations (i.e., mitigation measures, design alternatives,
etc.) to protect and promote health;
Propose a plan to monitor/track the implementation with respect to the health
determinants of concern; and,
Include a transparent and comprehensive reporting process.
2.2 Purpose and Rationale for Conducting an HIA
Specifically, this HIA is intended to provide additional consideration of potential impacts (positive
and negative) on health resulting from the proposed E&B Oil Drilling and Production Project in
Hermosa Beach. A report produced jointly by Health Impact Project and Arizona State
University (Sandra Day O’Connor College of Law) explored the purpose and legal basis for
conducing HIAs in the United States. The report is entitled ‘Legal Review Concerning the Use of
Health Impact Assessments on Non-Health Sectors’ and it provides an overview of HIA legal
provisions and requirements for HIAs in different jurisdictions. The authors of this report state
that:
“HIAs incorporate a broad definition of health and employ a unique interdisciplinary
methodology and input from people with a stake in the outcome of the decision to
evaluate prospective effects on the social, economic, and environmental conditions that
influence health due to governmental or private-sector policies, programs, and projects.”
Through a systematic review of the existing laws surrounding health considerations in decision-
making, the authors concluded that there is a substantial legal basis in the U.S. to promote the
use of HIA in conjunction with existing regulations. They point out that while HIAs are becoming
more common in the U.S., they are still underutilized. They go on to state that “the foundation
provided by existing laws and policies creates important opportunities to factor health
considerations into decisions made in non-health sectors using HIAs” (Hodge et al., 2012).
In California, an HIA is not legally required for this type of project, but an Environmental Impact
Report (EIR) is mandatory. In order to expand on existing health considerations in the EIR, the
City of Hermosa Beach commissioned this HIA to help inform voters and evaluate different
aspects of the proposed Project through a public health lens. The rationale for the HIA lies in its
unique approach to assessing a multitude of potential impacts (both positive and negative) that
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City of Hermosa Beach, CA Page 10
could affect community health. The HIA is intended to provide additional information, as well as
relying on existing information provided in the EIR, to holistically evaluate health. Although the
reports are complementary, in several instances the HIA provides further details on how specific
aspects of the Project could positively or negatively affect the health of the community, and
proposes additional recommendations where necessary.
This HIA is not intended to be an advocacy tool for any particular group (whether opposed or in
favor of the Project). Rather it is intended to provide further consideration of potential health
outcomes using quantitative and qualitative tools to scientifically assess the potential for the
Project to influence overall community health status.
2.3 Steps of an HIA
An HIA typically consists of a series of steps that are intended to provide a structural framework
around which the assessment will be conducted. Although guidance documents from around the
world have slight variations on these steps, the process is fundamentally the same.
Based on the recently published guidance document “Health Impact Assessment in the United
States” (Ross et al., 2014), there are seven steps to conducting an HIA (Figure 2-2).
Figure 2-2 Steps of an HIA (Modified from Ross et al., 2014)
Recommendation
Screening
Scoping
Assessment
Reporting
Evaluation
Monitoring
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SCREENING: The first step of any HIA process is screening to determine whether this type of
assessment is warranted based on a rapid review of available evidence (Ross et al., 2014). Key
questions that are answered in this step include:
Is an HIA needed?
Is an HIA feasible and how much effort will be required?
Are there other types of assessments that would be more appropriate?
According to Ross et al. (2014), screening involves:
“…judgments about how an organization’s resources should be used and whether the
results of the HIA will contribute to stakeholder knowledge or the decision making
process. In addition, screening can establish whether there are likely to be vulnerable
populations or areas that need consideration and whether there are important
community concerns that should be addressed.”
This step generally involves a rapid review of available evidence to determine whether the
policy, program or project is likely to affect health determinants or health outcomes. In many
cases; however, the decision to conduct an HIA is made before the HIA practitioners are
involved; such as with the current Project.
SCOPING: The purpose of the scoping step is to plan the overall approach to the HIA including
methods, contents and logistics (Ross et al., 2014). There is no single scoping protocol that fits
all types of projects; however, there is general consensus around what aspect of the HIA should
be planned. The main issues to be addressed typically fall in to three categories:
1. Management of the HIA: initiating the process to ensure that the results are included in
the decision making process and that the HIA will move forward with sufficient time and
resources.
2. Scope of the HIA: scoping the HIA such that the issues of highest priority (based on
established evidence and community input) are included along with identification of the
assessment population/area.
3. Methodological Approach of the HIA: identifying the major sources of information
required for the HIA and determining how the evaluation and analysis will be conducted,
including a communication plan for stakeholder engagement.
ASSESSMENT: The assessment step is where all of the planning in the scoping phase is
carried out to “identify whether impacts are likely to occur and then to quantify or characterize
the predicted impacts” (Ross et al., 2014). Assessments typically consist of both quantitative
methods of analysis, where applicable, and qualitative evaluations and discussions. The
assessment process varies widely depending on the project specifics; however, there tends to
be specific steps involved in carrying out the assessment part of an HIA (Ross et al., 2014):
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Step 1: Develop a health baseline or community profile
This step typically involves finding and compiling data on existing health conditions
within the population or area of interest. This baseline assessment allows for
identification of health challenges and opportunities, possible vulnerabilities, and
establishment of current health status as a reference point from which to conduct the
assessment.
Step 2: Assess the likely impacts
The purpose of the assessment (also described as appraisal or analysis) is to predict
what health effects could occur as a result of the proposed project or policy, identify the
extent of the effects, and determining how different groups could potentially be impacted
(e.g., children vs adults, specific neighborhoods or groups, etc.). This should be done
using the best available evidence and can include: systematic reviews and meta-
analyses; peer reviewed literature; government agency reports and other reputable gray
literature; previously published HIAs, quantitative models, expert opinion and
stakeholder input.
Step 3: Characterize/summarize the health impacts
Finally, it is important to provide a summary of the evaluation of predicted impacts
(positive and negative) so that they can be compared and contrasted. This is especially
important when the HIA is to be used as a component of the decision-making process,
because it enables decision makers to quickly see which potential health impacts are of
more or less concern. It allows for the HIA to be meaningfully integrated into evaluating
the proposed project/policy since decisions can be made based on these findings (e.g.,
mitigation measures, monitoring, etc.).
RECOMMENDATIONS: Based on the findings of the assessment, specific recommendations
may be made with respect to any identified health impacts and should include input from key
stakeholders to ensure they are politically, socially and technically feasible. According to Ross
et al. (2014):
“Recommendations are specific action items that describe how conditions should be
amended in order to minimize the predicted adverse impacts of the proposed project or
policy and to maximize potential benefits. The development of recommendations is a
critical step of health impact assessment (HIA) because it provides an opportunity to
translate the results of the assessment into actions that may improve the health of the
affected population.”
REPORTING: The process of completing an HIA (including screening and scoping steps) are
typically written up in a report-style format to be distributed to interested and involved parties
(i.e., decision-makers, special interest groups and other stakeholders, health authorities or other
government bodies, the media, etc.). Reporting can be difficult because different interest groups
will prefer that the information be presented in different ways. For example, key policy or
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decision makers may want a detailed formal report, whereas the media and the public may
prefer a concise and plain language summary of key findings.
EVALUATION: Evaluation is considered an important aspect of HIA since it involves reflection
and critical assessment of the process in order to foster improvement. Although not included in
all HIAs, it can be a valuable step in the process because it allows for reflection on the HIA
process, its role in the decision-making and any outcomes that were influenced as a result of
the findings. The evaluation step can demonstrate the effectiveness of HIA in the planning
process by showing what the HIA actually achieved. It is essentially a method to allow
practitioners to reflect on the process and make changes to their approach, which will foster
continuous improvement of HIA in the future.
MONITORING: Monitoring is often combined with evaluation since they are similar concepts but
with different objectives. In their book, Ross et al. (2014) separate out monitoring from
evaluation and state:
“The purpose of monitoring is to track the health impact assessment (HIA) and its effect
over time. The monitoring process can be envisioned as a system of checks and
balances to ensure accountability in the implementation of the HIAs recommendations
and to gauge compliance with regulations.”
Monitoring is one of the least well-defined steps of HIA. When an HIA recommends monitoring it
is generally in the form of requesting testing or data collection over time to ensure that mitigation
and control measures (that were either relied upon in the HIA or recommended as a result of the
HIA) are operating effectively and to observe health implications over time.
2.4 HIA Evaluation Matrix
An HIA evaluation matrix is a tool to characterize and summarize the predicted health impacts
(positive, negative, and neutral) of the proposed Project so they can be compared and
contrasted. As there is no globally accepted standard for health impact characterization in HIA,
the evaluation matrix used in this HIA was developed based on best practices published in a
number of guidance documents and used in other assessments (Ross et al., 2014; USEPA,
2013; CDPH, 2010; IAIA, 2006; NRC, 2011).
The HIA is founded on the idea that commercial and industrial developments undoubtedly
impact people living or working in their vicinity. In HIA it is important to distinguish between the
directionality of these impacts (i.e., positive, negative, and neutral) and consider the nature and
extent of various types of effects on health.
The evaluation matrix developed for this HIA includes consideration of the different
characteristics of potential impacts including geographic extent (local, widespread), vulnerable
populations, magnitude, likelihood of occurrence, and others. Each of these characteristics is
independently evaluated based on data from the EIR, evidence from the scientific literature, and
professional judgment. A brief discussion of the Project without mitigation measures will be
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included where applicable. However, the Project characteristics are ultimately evaluated based
on a scenario where the proposed EIR mitigation measures have been implemented. This is
because once the EIR is certified the mitigation measures must be adhered to. Further, the HIA
is intended to quantitatively and qualitatively assess those conditions in which the community
will be living and working following Project approval and initiation. Evaluating a scenario that
does not exist would produce results that are prone to misinterpretation and not helpful to
decision makers and the public. Rather, the assessment focuses on the Project including
mitigation measures to ensure they are adequately protective and, if not, to propose additional
recommendations based on the HIA findings.
The evaluation criteria are discussed in further detail below (Table 2-1).
Table 2-1 HIA Evaluation Matrix
Health Determinant List the determinant being assessed
Potential Health Outcome List potential health outcomes associated with each
determinant
Pre-Mitigation Discussion The discussion is limited to identification of the direction of the
pre-mitigation impact (positive, negative, neutral or unknown)
and identification of any potential issues that could arise if no
mitigation measures were implemented.
EIR Mitigation List mitigation measures from the Environmental Impact Report
(EIR), where applicable
Geographic Extent Localized or Community
Vulnerable Populations List subgroups that could be disproportionately affected
(positively or negatively) by Project activities
Magnitude Low, Medium, High, or Unknown
Adaptability High, Medium, Low, or Unknown
Likelihood Unlikely, Possible, or Probable
Post-Mitigation Health Effect Negative, Positive, No substantial Effect, or Unknown
Comments or Additional
Recommended Measures
None, or Additional Recommendations (specific and
actionable)
For each health determinant evaluated in the HIA, a technical scientific assessment of the
potential health impact will include a detailed discussion of all aspects of the evaluation matrix.
A specific definition has been provided for each element (i.e., magnitude, adaptability,
likelihood, etc.) to ensure a consistent and meaningful assessment across all determinants.
Health Determinant: A determinant is defined as “an element that identifies or determines the
nature of something”. In this case, the determinant is an element of the proposed Project that
has the potential to impact health in a positive or negative manner; however, the determinant
itself is non-directional. The scoping section of the HIA identifies health determinants that are
evaluated in detail.
Potential Health Outcome: List and discuss potential health outcomes associated with the
determinant (e.g., the toxicology and physical health changes associated with exposure).
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Pre-Mitigation Discussion: A brief discussion of the potential impact of the Project without
mitigation is provided for completeness; however, the HIA is based only on a scenario where
the mitigation measures required in the EIR have been implemented as part of the Project. The
discussion is limited to identification of the direction of the pre-mitigation impact (positive,
negative, neutral or unknown) and identification of any potential issues that could arise if no
mitigation measures were implemented.
EIR Mitigation: What are the mitigation measures that have been identified in the EIR for this
determinant that are related to health and could change the outcome of the HIA? Measures are
listed based on information provided in the Final EIR.
Geographic Extent: How far are the impacts likely to reach?
Localized: limited to the areas in close proximity to the Project Site
Community: potential for wider scale impacts across the community
Vulnerable Populations: Are there populations that could be disproportionately affected
(positively or negatively) by Project activities?
Magnitude: What is the extent of the health impact post-mitigation?
Low: the impact is minor, it is temporary or reversible, and does not pose a
hazard/benefit to health
Medium: the impact is detectable, it is reversible, and poses a minor to moderate
hazard/benefit to health
High: the impact is substantial, it is permanent, and poses a major hazard/benefit to
health
Unknown: the impact is unclear and poses an unknown hazard/benefit to health
Adaptability: How resilient is the community to this type of change; are they able to adapt?
High: people will be able to adapt to the change with ease and maintain pre-project
level of health
Medium: people will be able to adapt to the change with some difficulty and will
maintain pre-project level of health, although some support may be necessary
Low: people will not be able to adapt or maintain pre-project level of health
Likelihood: What is the probability of the impact occurring based on the expected frequency of
the exposure?
Unlikely: the impact is anticipated to occur rarely, if ever
Possible: there is potential for the impact to occur on a regular basis
Probable: the impact will almost certainly occur and persist over time
Post-Mitigation Health Effect: What is the ‘direction’ of the post-mitigation effect?
Positive: the effect is expected to positively influence health following implementation
of EIR mitigation measures
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Negative: the effect is expected to negatively influence health following
implementation of EIR mitigation measures
No Substantial Effect: there is no substantial health effect expected following
implementation of EIR mitigation measures
Unknown: the direction of the effect following implementation of EIR mitigation
measures is unknown
Comments or Additional Recommended Measures: Provide comment about the effect,
and/or determine if there any additional measures recommended based on the Post-Mitigation
Health Effect.
None: there are no additional measures recommended based on the findings of the
HIA
Additional Recommended Measures: there are additional measures recommended
based on the findings of the HIA (provide brief summary of recommendations)
The decision-making framework (the framework) used to weigh and evaluate each of the
elements of the evaluation matrix in order to come to a final conclusion on “Post-Mitigation
Health Effect” for each health determinant is provided in Figure 2-3. The elements (i.e.,
magnitude, adaptability and likelihood) are arranged in descending order (top to bottom) of
weight and potential influence on the final determination of effect. Each pathway through the
framework leads to a specific conclusion that is either directional (i.e., positive or negative) or
non-directional/neutral (i.e., no substantial effect). In some cases where professional judgment
dictates, it is possible to deviate from the decision making framework; however, a detailed
evidence-based rationale is required to be provided in the accompanying text.
The evaluation matrix is the tool that was used to classify and weigh different aspects of
potential impact resulting from Project activities. The impacts that have been evaluated as part
of this HIA were classified by their geographic extent, magnitude, adaptability and likelihood.
The geographic extent, although important in identifying the physical reach of possible impacts,
is not weighted in the evaluation matrix in a way that would influence the final conclusion (i.e.,
positive, negative or no substantial effect). Rather, geographic extent is used to identify
potentially impacted populations, as well as informing and targeting any necessary mitigation
measures. Vulnerable populations were also included as part of the assessment and the
potential for disproportionate impacts on these individuals was carefully considered in the
classification of magnitude and adaptability. They were also taken into account when making
additional recommendations.
There are three potential outcomes used to classify a health effect. The classification is based
solely on the definitions provided above and is intended to describe the extent of the post-
mitigation health impact. The most heavily weighted aspect of the evaluation matrix is
magnitude, which comprises the first level of the framework. Adaptability is the next level of the
evaluation matrix as it relates to resiliency and ability to maintain health status if an impact were
to occur. This element is less heavily weighted than magnitude but does influence the final
determination of effect. The final level of the matrix is likelihood, which is the probability of the
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impact occurring based on the expected frequency of exposure. Likelihood is less heavily
weighted than magnitude but similar to adaptability, it influences the final conclusion, especially
in situations where the impact is expected to occur rarely, if ever. Where an element of the
evaluation matrix is classified as ‘unknown’ a discussion of the uncertainty and potential
influence of this limitation on the conclusions must be provided. In these scenarios, the
determination of effect is largely based on professional judgment and sound rationale.
In order to come to a final conclusion regarding the potential for a Post-Mitigation Health Effect,
the health determinant being assessed must be classified as to its magnitude (high, medium,
low), adaptability (low, medium, high), and likelihood (unlikely, possible, probable). For example,
if for a specific health determinant the impact is detectible, reversible and poses a minor to
moderate hazard to health, the magnitude would be classified as ‘medium’ moving down the
center pathway in the framework (Figure 2-3). Then, if people are able to adapt to the change
with ease and maintain a pre-project level of health, adaptability would be classified as ‘high’.
Finally, if the impact is anticipated to occur rarely, if ever, then the likelihood would be identified
as ‘unlikely’ and the corresponding pathway in the framework would lead to a no substantial
effect (i.e., neutral) conclusion for the posit-mitigation health effect.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014 City of Hermosa Beach, CA Page 18 Figure 2-3 Decision-Making Framework for the HIA Evaluation Matrix (H = high; M = medium; L = low; U = unlikely; P = possible; R = probable) MagnitudeAdaptabilityLikelihoodMEDIUMHealth DeterminantHIGHLOWHMLUPRUPRUPRUPRUPRUPRUPRUPRUPRHMLHMLNo Substantial Effect (Neutral)Positive/Negative Neutral/PositivePositive/NegativeDirectional outcomeNon‐directional outcome
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3.0 SCREENING
The primary objective of the screening step is to determine whether an HIA should be
conducted and to begin defining specific objectives by considering potential Project-related
health impacts. The overall goal of this HIA is to identify and evaluate potential health impacts
(both positive and negative) associated with the proposed E&B oil drilling and production
Project. The HIA is also intended to provide a better and more holistic understanding of the
likelihood, magnitude and extent of potential health impacts.
The City of Hermosa Beach is committed to communicating the findings of the HIA prior to the
vote on the proposed Project in order to facilitate the decision-making process. The availability
of existing regulatory frameworks to evaluate health impacts is also taken into consideration
when determining the need for an HIA. The proposed E&B oil drilling and production Project is
subject to regulation under the California Environmental Quality Act (CEQA), which requires an
EIR. Consequently, the HIA is not intended to be a stand-alone document; rather it is
complementary to the existing information provided in the EIR. The difference lies in the scope
of the health impacts considered, with HIA focusing on a wider range of health determinants
including social and economic aspects which may not have been addressed in the EIR, or may
not have focused on human health implications of Project activities. The purpose of this HIA is
to provide a focused and context-specific evaluation of aspects of the Project that could have a
positive, negative or neutral impact on community health.
The proposed oil and gas Project in the City of Hermosa Beach has generated considerable
controversy. At an Open House in September 2013 and a public meeting in October 2013,
residents expressed a variety of concerns about the potential health impacts of the proposed
Project. Health concerns raised by members of the community included:
Physical – hazards resulting from accidents, malfunctions and emergencies
Environmental – adverse impacts to the quality of air, water, soil, or food
Socioeconomic – impacts to community resources
Psychological – mental health impacts
Other – cumulative effects, political stress of the decision-making process
The questions and comments received from members of the public regarding these health
topics reinforced the City’s decision to include an HIA in the assessment process. Therefore, it
was determined that conducting an HIA on the proposed Project would add value and serve to
highlight health considerations within the decision-making process. The residents of Hermosa
Beach will be voting on whether to lift the ban on oil drilling and will have information from the
HIA, EIR and CBA available to inform their decision.
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4.0 SCOPING
The scoping step for this HIA was conducted based on the Guide for Health Impact Assessment
(CDPH 2010), which outlines the process for identifying priority issues, research questions and
methods. Additional guidance documents used in the development of this HIA include the
‘Technical Guidance for Health Impact Assessment in Alaska’ (2011), which specifically
addresses the evaluation of potential impacts from proposed oil and gas development projects,
and the recently published ‘Health Impact Assessment in the United States’ (Ross et al. 2014),
which is an up to date publication featuring example case studies. Lastly, tools and resources
provided by Human Impact Partners, a nationwide organization dedicated to building the
capacity of HIAs, supplemented the scoping process through its searchable database of
scientific articles on social, economic and environmental determinants of health.
Since the proposed Project has the potential to influence a range of health outcomes in the
community, a comprehensive scoping checklist that considers the likelihood and magnitude of
impacts was used to initiate this step (Appendix B). Through stakeholder participation, and a
review of the scientific evidence surrounding potential health impacts, this list was further
refined.
4.1 Stakeholder Engagement
Stakeholder engagement is a key component of an HIA and is particularly useful in the scoping
step. Community participation and expert consultation ensure that the most important issues
and local knowledge are included in the analysis. The relevant stakeholders identified in this
HIA include:
The decisions-makers (voting public of Hermosa Beach);
Local government (City of Hermosa Beach);
Non-residents who work, recreate, or otherwise spend time in Hermosa Beach;
Pro-oil and anti-oil activist groups (e.g., Keep Hermosa Hermosa, Protect Hermosa’s
Future);
The Project Applicant E&B Oil Company; and,
Local health agency (Beach Cities Health District).
The HIA team attempted to reach out to all stakeholders throughout the HIA process. The
exception was E&B representatives, whom the HIA team did not interview while undertaking this
project. Specific opportunities for stakeholder involvement included:
A Community Dialogue process, sponsored by the City, to identify the values and long-
term goals for Hermosa Beach. A series of workshops were conducted in small groups
to engage local residents and business owners in describing priorities and building a
framework for decision-making. The HIA team participated in, and coordinated with, the
Community Dialogue process to incorporate key quality of life aspects identified by
Hermosa Beach community members into the evaluation of overall community health
and well-being.
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A public Open House was held on July 13, 2013 to introduce the concept of HIA and
kick-off stakeholder involvement. The Open House was held on a weekend from 9 am to
2 pm in the Community Center located in the center of town.
An HIA scoping meeting was held on September 23, 2013 to elicit community feedback
regarding potential health concerns of interest. The HIA public scoping meeting was held
on a weeknight from 7 pm to 10 pm at the Community Theater also located in the center
of town. To accommodate those who were unable to attend in person, the scoping
meeting was broadcast on a local television station and the videotape posted on the City
website. Following the scoping meeting, public comments (both written and oral) were
received and are available on the City’s website (http://www.hermosabch.org/). The
scoping meeting was facilitated by City Staff and was well-attended (approximately 400
people).
One-on-one interviews with community members
Two presentations of the initial draft HIA findings, February 24th 26th from 6:30 pm to 10
pm in the Community Theater.
The public and peer review comments received on the initial draft HIA, and responses,
are included in Appendix C. The public comments on the reissued draft HIA in July 2014
are also included in Appendix C.
All public opportunities for engagement were advertised to the community via multiple outlets
including postcard mailers, announcements in the local newspaper, banners in public spaces,
and e-mail blasts to the City mailing list.
In addition to feedback from the public meetings, an online survey was conducted to help
identify the key issues of concern among community members. The survey was announced at
the scoping meeting, and the link was posted on the City’s website. The survey consists of four
multiple choice questions asking where respondents live, whether there is concern about health
impacts of the proposed Project, what potential health impacts are of most concern, and if the
level of concern depends on the various Project phases. A copy of the survey is provided in
Appendix D. A total of 292 community members responded. The majority of the survey
participants live in Hermosa Beach near the Site of the proposed Project (South of Pier Avenue
and West of Pacific Coast Highway, Figure 4-1).
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Figure 4-1 Distribution of Survey Participants Place of Residence
Of the 292 survey participants, 93% were either very or somewhat concerned about the
potential health impacts of the proposed Project. The remaining 7% of participants were either
not concerned about potential health impacts or are not sure. Survey participants ranked their
level of concern for 18 topics as “very concerned”, “somewhat concerned”, “not concerned” or
“no opinion”; participants were also given the option to specify “other” concerns. Overall, survey
respondents appeared to be concerned about potential health and environmental impacts
(responses of “I am very concerned” ranged from 62% to 89% for individual topics). Table 4-1
ranks the concerns of respondents in order of greatest concern (based on the rating average).
Issues of most concern included explosions/spills, impacts to the ocean or beach, soil
contamination, air quality, odor and surface water contamination. Although some members of
the community were very concerned about all of the topics - vibration, parking and light
problems ranked lowest in terms of overall level of concern. A total of 73 survey participants
also specified other areas of concern that are not listed in Table 4-1 (e.g., hydrogen sulfide,
cancer, traffic accidents, and sensitivity of children to environmental exposures). The complete
list of survey responses is included in Appendix D.
The last question of the survey asked if the level of concern differs based on the phase of the
proposed Project. The responses reflected a higher level of concern associated with both drilling
phases – Phase 2 and Phase 4. Comparatively, the survey respondents were less concerned
with the construction phases, Phase 1 and 3. Where applicable, the assessment (Section 5)
discusses the potential for impacts in the different Project phases.
0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
50%
Hermosa Beach ‐
North of Pier
Ave and West of
the PCH
Hermosa Beach ‐
South of Pier
Ave and West of
the PCH
Hermosa Beach ‐
North of Pier
Ave and East of
the PCH
Hermosa Beach ‐
South of Pier
Ave and East of
the PCH
Manhattan
Beach
Redondo Beach
Survey Question 1: Where do you live?
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Table 4-1 Ranking of Environmental and Health Areas of Concern
Answer Options Very
concerned
Somewhat
concerned
Not
concerned
No
opinion
Rating
Average
Explosions/Spills/Accidents 254 23 6 1 1.13
Potential impacts to the
ocean 259 16 10 1 1.14
Soil contamination 249 27 8 1 1.16
Air quality issues 247 26 9 1 1.17
Odor 248 25 8 2 1.17
Surface water
contamination 244 22 11 3 1.19
Truck traffic 230 45 6 2 1.22
Drinking water
contamination 234 30 15 4 1.25
Property values 223 33 19 4 1.3
Noise 220 39 21 3 1.32
Land subsidence (sinking) 212 43 16 6 1.34
Less access to community
spaces 210 51 16 5 1.35
Earthquakes 207 55 20 2 1.36
Image of the City 210 41 24 4 1.36
Vibration 204 47 25 6 1.41
Parking problems 195 58 23 6 1.43
Lights 177 63 32 6 1.52
The online survey was a convenient way to facilitate public input into the scoping process while
minimizing time and expense associated with traditional survey techniques. However, we
recognize that the informal online survey precluded the recruitment of a representative sample
of the population. Because the survey was one method, among others, to gather input from the
community and no scientific conclusions are made with the results, the fact that the respondents
do not constitute a representative subsample of the population is not considered to be a
significant limitation of the HIA.
It is believed that all interested members of the public and stakeholders were reached during the
HIA, given the extensive outreach and consultation efforts undertaken.
4.2 Pathways
A complex interplay of genetic, environmental and lifestyle factors determines the health of
individuals and communities. Environmental exposures can influence community health but so
can individual behaviors, social networks, living conditions and cultural practices. Therefore,
determinants of health include social and economic elements, in addition to the physical
environment and individual characteristics and behaviors. There are many models that have
recognized the social-economic influences on health, including that provided by the federal
government’s national health objective, Healthy People 2020 (Figure 4-2).
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Figure 4-2 Social Ecological Health Framework (USHHS, 2008)
In order to facilitate the scoping process, pathway diagrams were created to understand the
potential health impacts (positive and negative) of approving the proposed Project.
Considerations included potential changes in social, economic, physical, psychological and
other health-related quality of life outcomes. Public input and a review of other oil and gas
development projects in the Los Angeles area were used to further refine the areas of health
focus for this evaluation. Due to the large variety in designs for oil and gas development
projects, a professional engineer with over 15 years of experience in the oil and gas industry
was consulted to provide expertise on the engineering features of the proposed project as
described in the E&B Project application (2012; 2013a,b). Additionally, key case studies and
scientific review articles of health assessments related to oil and/or gas development were
taken into consideration during the development of pathways for this HIA, including:
1. Northeast National Petroleum Reserve – Alaska Final Supplement Integrated Activity
Plan/Environmental Impact Statement (BLM, 2008)
2. Health Impact Assessment for Battlement Mesa, Garfield County Colorado (U of C,
2010)
3. Inglewood Oil Field Communities Health Assessment (LACDPH, 2011a)
4. Health Impact Assessment of Shale Gas Extraction (NAP, 2013)
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Health determinants were prioritized based on a combination of key issues identified by
community members, health research published in scientific peer-reviewed journals and
professional experience. Based on a combination of public input, expert consultation, and a
review of available scientific evidence, the following pathways were selected for further
evaluation in the HIA:
Air Quality;
Water and Soil Quality;
Accidents and Upset Conditions;
Noise and Light;
Traffic; and,
Community Livability.
The relocation of the City Maintenance Yard was not evaluated in the HIA. This is because its
proposed relocation will be to a site with existing commercial land use (i.e., storage facilities).
The construction and relocation of the City Maintenance Yard is not anticipated to be
substantially different than other common local construction projects and is identified in the EIR
as a separate Project. Therefore, the relocation activities were considered to be outside the
scope of the HIA.
In addition, the HIA did not evaluate the “No Project Alternative”, as presented in the EIR. This
scenario was an evaluation of a condition under which no development of the oil and gas
resources would occur. “There would be no drilling and no construction at the Project Site or
along Pipeline routes. The City maintenance Yard would not be relocated and rebuilt. None of
the impacts associated with the Proposed Project would occur. No new impacts would occur
under the No Project Alternative” (MRS, 2014). This is clearly illustrated in the Executive
Summary of the EIR in Table ES.3 (MRS, 2014). This scenario was not evaluated in the HIA as
there would be no deviation from baseline health.
4.2.1 Air Quality
In the project description, E&B stated that its proposed oil and gas development facility will
utilize the latest technology and operational advancements in order to reduce potential impacts
on air quality. The specific measures are outlined in the EIR and include an automatic drill rig
powered by electricity (as opposed to diesel), limiting the number of truck trips to and from the
Site, and air monitoring activities. This HIA relied on pollutant inventory data from the EIR and
evaluated a number of different air pollutants that could be emitted from three primary sources:
construction, truck traffic, and operations (Figure 4-3).
As with any new development, emissions from project construction have the potential to impact
the surrounding community. Construction equipment and the vehicles that transport equipment
release fine particulate and diesel particulate matter into ambient air. In some circumstances,
increasing the number of on-road vehicles can cause traffic congestion, and increase the risk of
traffic injury to motorists, pedestrians and bicyclists (Section 5.6). In addition to emissions from
the internal combustion engines of construction equipment, soil excavation and movement
during construction activities generate dust (Section 5.3.2.).
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page 26
Emissions during oil production operations (including testing, drilling and production phases)
could potentially impact local air quality, particularly without any air pollution controls or
mitigation measures. The emission sources associated with operational activities include onsite
microturbines used to generate onsite electricity, routine and emergency flaring events, and
volatile fugitive emissions from valves, compressors, pumps and connections. Muds that contain
hydrocarbons can surface and release hydrocarbon vapors (referred to as “mud off-gassing”).
Drilling muds may contain hydrogen sulfide, benzene and other volatile compounds, which
could potentially impact health if they are released in sufficient quantities. Additionally, hydrogen
sulfide and hydrocarbon vapors could leak into ambient air producing detectable odors. Due to
the close proximity of the site to neighbors, businesses and the public (within 100 feet of
businesses, 160 feet of residences and 20 feet of the public sidewalks), there is potential for
odor issues off-site including various maintenance activities, small spills, and leaks from
equipment components.
A significant body of scientific and public health literature exists that describes the association
between excess levels of ambient air pollutants and certain health outcomes, specifically
respiratory and cardiovascular disease. It is important to note that these effects are dose-
dependent, in other words, the mere presence of a chemical does not mean that exposure will
result in adverse health effects. The literature also identifies the potential impacts that odors can
have on quality of life and, at high enough levels, acute health risks.
The air quality pathway diagram in Figure 4-3 summarizes the potential health effect pathways
between the proposed Project and health outcomes in the event that exposures were
uncontrolled. It should be noted that this diagram, developed during the scoping step, is a
preliminary effect pathway diagram. The next step in the HIA is the assessment step, which
validates or invalidates each potential pathway.
In the first Draft of the HIA the potential health outcomes of greenhouse gas generation from the
Project were briefly evaluated. However, the authors of the reissued draft HIA Report do not
believe that localized or community health effects related to potential greenhouse gas emissions
can be adequately evaluated in a project-level HIA. Rather, the global issue of greenhouse gas
generation requires a much broader assessment of state and national sources and policies to
adequately evaluate cumulative impacts of the energy sector.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014 City of Hermosa Beach, CA Page 27 Figure 4-3 Air Quality Pathway Diagram Δ in air pollutants•Nitrogen Dioxide•Particulate Matter•Toxic Air ContaminantsΔ in odors ConstructionOperationsConstruction equipment/ activitiesΔ in on‐road vehicle trafficΔ in H2SΔ in air quality‐related diseases•Cancer•Cardiovasculardisease•Asthma/other respiratory diseases•Reproductive HealthFugitive emissionsRoutine and emergency flaring eventsΔ in neighborhood livability Δ in acute symptoms (e.g., headaches, nausea)Δin respiratory illness and Δ in neurological diseaseTruck trafficNotes: ∆ indicates ‘a potential change in’, = project impacts, = health determinants, = health outcomes
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page 28
4.2.2 Water and Soil Quality
Two potential sources of water and soil quality impacts were identified in the scoping phase: (1)
discharge of wastewater and surface water runoff during construction and operations, and (2)
deposition of windblown soil particulates to offsite surface soil. The primary water resource
located near the Site and pipeline route is the Pacific Ocean. The ocean provides a potential
exposure pathway for recreational users to come into contact with contaminants from the Site.
There are no other surface water bodies in the vicinity of the proposed Project.
Soil particulate emissions refer to the dust generated during construction and operations when
equipment moves over soil or unpaved surfaces during trenching, grading, and other earth-
moving activities. The public may be exposed to contaminated materials if contamination is
present in soil and is mobilized during dust-generating activities. Adjacent land uses that could
potentially be impacted by soil particulates include commercial, residential and recreational
areas.
Groundwater was not included in the scope of the HIA because it was ruled out as a pathway
for human health concern. Most of the groundwater in the West Coast Basin remains at an
elevation below sea level due to historic over-pumping; therefore, seawater intrusion barriers
have been established. The groundwater located beneath the Site lies to the west of the barrier
that prevents seawater intrusion into fresh groundwater supplies. As groundwater is within the
seawater intrusion barrier, it is not used as a drinking water source. While groundwater is not a
drinking water source, and not evaluated in the HIA, it is still a protected resource. Potential
impacts to groundwater quality due to Project wastewater generation are addressed in Section 4
of the EIR.
The water and soil pathway diagram in Figure 4-4 summarizes the potential health effect
pathways between the proposed Project and health outcomes in the event that exposures were
uncontrolled. It should be noted that this diagram, developed during the scoping step, is a
preliminary effect pathway diagram. The subsequent step in the HIA, the assessment step,
generates evidence to validate or invalidate each potential pathway.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014 City of Hermosa Beach, CA Page 29 Figure 4-4 Water and Soil Quality Pathway Diagram Δ in surface water qualityΔ in acute symptoms, gastrointestinal disease, among beachgoersConstructionΔ storm water runoff Δ in acute symptoms, neurological symptoms, chronic diseasesTruck trafficΔ in soil qualityOperationsNotes: ∆ indicates ‘a potential change in’, = project impacts, = health determinants, = health outcomesΔ soil deposition, dust emissions
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
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4.2.3 Upset Scenarios
Two potential types of upset scenarios were identified as major health concerns in the scoping
phase: (1) an oil spill to surface waters, and (2) a well blowout event. While there are other
potential upset scenarios related to the proposed Project, this HIA focused on these two upset
scenarios based on community concerns voiced during the scoping meeting and the accidents
that could present the highest risk to the public.
An oil spill that is sufficient in volume could impact the adjacent beach and/or the Pacific Ocean.
The beach and ocean provide potential exposure pathways for recreational users to come into
contact with crude oil from a spill. The ingestion of contaminated fish or seafood caught from the
ocean also provides a potential exposure pathway in the event of an oil spill. Additionally, a well
blowout occurring on the Site could immediately affect the public if the explosion or explosion
debris materials were to extend beyond the Project Site.
The accident and upset event diagram in Figure 4-5 summarizes the potential health effect
pathways between the proposed Project and health outcomes in the event that an accident
were to occur. It should be noted that this diagram, developed during the scoping step, is a
preliminary effect pathway diagram. The next step in the HIA is the assessment step, which
validate or invalidate each potential pathway.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014 City of Hermosa Beach, CA Page 31 Figure 4-5 Upset Scenarios Event Pathway Diagram Oil release to beach, oceanΔ in acute symptoms, gastrointestinal disease, among beachgoersAccident/Upset eventWell blowoutΔ in injuries and/or fatalitiesExplosion (fire and vapor clouds) from blowoutNotes: ∆ indicates ‘a potential change in’, = project impacts, = health determinants, = health outcomesCrude oil spillΔ psychological effects, recreational activities
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
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4.2.4 Noise and Light
The Project has the potential to increase local noise levels. Construction, operations and related
activities such as truck traffic are possible sources of noise associated with the proposed
Project. Some studies have suggested that exposure to noise can lead to annoyance and sleep
disturbance, or at very high levels can be associated with increased blood pressure
(hypertension), cardiovascular disease, and cognitive impairment. Construction and operation
activities also have the potential to cause vibrations. Ground vibration produced by the drilling
and production activities would be below the 0.01 inches/second threshold when it reaches the
closest sensitive business (i.e., a recording studio), which was determined to be less than
significant in the EIR (MRS, 2014). Therefore, vibration was excluded from this assessment due
to the negligible magnitude of potential impact and the low ranking vibration received in the
community survey of health concerns (Table 4-1).
Road vehicle traffic is one of the sources of noise in urban areas, and has been well studied in
the public health literature. Noise generated by vehicle traffic depends on presence of increased
truck traffic, the traffic volume, traffic speed, and vehicle type. It is possible that the presence on
increased truck traffic resulting from Project activities in the area could influence noise levels in
the community.
In addition to potential noise impacts, disturbances associated with nighttime lighting have been
identified as a subject of concern for some community members. The proposed Project will
require lighting to maintain a safe working environment for employees at night. Key lighting
features of the proposed Project include light fixtures on the Site entrance, the construction
trailers and/or office buildings, and the drill rig equipment. As discussed in the EIR, the majority
of lighting would be shielded and downcast, and would be located behind the 35-foot sound
attenuation wall to minimize light spill or glare beyond the Site perimeter.
The noise and light pathway diagram in Figure 4-6 summarizes the potential health effect
pathways between the proposed Project and health outcomes in the event that exposures were
uncontrolled. It should be noted that this diagram, developed during the scoping step, is a
preliminary effect pathway diagram. The next step in the HIA is the assessment step, which
validate or invalidate each potential pathway.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014 City of Hermosa Beach, CA Page 33 Figure 4-6 Noise and Light Pathway Diagram
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page 34
4.2.5 Traffic
The construction and operations phases of the proposed Project will cause an increase in traffic,
especially large truck traffic. Additional vehicles related to the proposed operations could
change traffic congestion. The influx of new truck traffic and the potential impact on safety was
one of the primary concerns of community members. Substantial increases in transportation and
traffic can impact the health and safety of a community by heightening the potential risk of
vehicle-vehicle, vehicle-pedestrian, and vehicle-bicyclist accidents. Perceptions about traffic
safety hazards can influence health by altering actives such as walking and biking.
Increased traffic-related air pollution and traffic-related noise could also result in health changes
in the community. The potential traffic-related impacts to air and noise are identified in Sections
4.2.1 and 4.2.4, respectively.
The traffic pathway diagram in Figure 4-7 summarizes the potential health effect pathways
between the proposed Project and health outcomes in the event that exposures were
uncontrolled. It should be noted that this diagram, developed during the scoping step, is a
preliminary effect pathway diagram. The next step in the HIA is the assessment step, which
validate or invalidate each potential pathway.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014 City of Hermosa Beach, CA Page 35 Figure 4-7 Traffic Pathway Diagram
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City of Hermosa Beach, CA Page 36
4.2.6 Community Livability
Community livability is the focus area used to describe a series of community characteristics
that enhance or degrade the experience of living in a specific area. The different aspects of
community livability that are evaluated in this HIA were identified through public stakeholder
engagement activities. During the scoping phase, many community members commented they
were concerned that the presence of oil and gas industry could change the identity of Hermosa
as “The Best Little Beach City.” As part of the Community Dialogue process, a community-led
committee was assembled to define important quality of life factors. This committee found
common themes that they feel describe the identity of Hermosa Beach, including (Appendix F):
City streets are clean and the beach environment is regularly maintained;
Reputation for being a small scenic town and friendly beach community;
Bars that attract party crowds at night;
Health conscious community that enjoys exercising and spending time outdoors;
Accessible city government with active citizens involvement;
Safe environment with low crime rate;
Known for green/sustainable activities and carbon neutral goal; and,
Schools have a high reputation and benefit from community involvement.
This area of health focus incorporates the quality of life values into an evaluation of three key
aspects of the Project that could influence community livability: potential change in city identity,
increased city revenue from oil and gas production, and access to neighborhood resources.
Under these key areas of concern, six potential health determinants were included for
evaluation in the HIA: property values; access to recreational resources and green space;
aesthetics and visual resources; education funding; social cohesion; and, political involvement.
In addition to the potential impacts from Project construction and operation, there could be
possible benefits and drawbacks from the opportunity to vote on the proposed Project.
Community members have expressed concern that letting voters decide whether the proposed
Project is approved has created political divisions and stress, with residents who are in favor
divided from those who are opposed. While the debate over the proposed Project has the
potential to disrupt social cohesion, involving the community in the political process can be
beneficial to health and well-being.
The community livability pathway diagram in Figure 4-8 summarizes the potential health effect
pathways between the proposed Project and health outcomes in the event that exposures were
uncontrolled. It should be noted that this diagram, developed during the scoping step, is a
preliminary effect pathway diagram. The next step in the HIA is the assessment step, which
validate or invalidate each potential pathway.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014 City of Hermosa Beach, CA Page 37 Figure 4-8 Community Livability Diagram Δ in community resourcesΔ in aspects of community livability (e.g., property values, aesthetics, green space, funding)Δ in city identity (real or perceived)Δ in chronic disease•Cardiovasculardisease•Diabetes•HypertensionΔ in access to neighborhood resources (e.g., recreational resources and green space)Δ in neighborhood crime/safetyΔ in property valuesΔ in physical activityΔ in mental healthΔ in social cohesionVote on proposed ProjectΔ in annoyance and stressΔ in city revenue (e.g. for education, infrastructure improvements)Δ in political involvementNotes: ∆ indicates ‘a potential change in’, = project impacts, = health determinants, = health outcomesΔ in aesthetics
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5.0 ASSESSMENT
As described previously, the assessment process in HIA involves: (1) developing a health
baseline profile, (2) assessing the likely impacts, and (3) characterizing the health impacts. This
Section first summarizes the baseline profile, and then provides the individual assessments and
impact characterizations for each the six categories identified in the scoping phase (air quality,
water and soil quality, noise and light, accidental releases, traffic, and community livability).
The HIA Team worked very closely with the EIR Team as it was being finalized. This HIA
focused on conditions reported in the EIR after Project mitigation measures were considered. In
some instances the HIA Team requested additional information from the EIR Team to complete
this report (e.g., air quality and noise).
5.1 Baseline Health Assessment
The first step of the HIA assessment process is to create a baseline health profile that describes
the current health conditions in the community. The baseline health assessment establishes the
current health status of the City of Hermosa Beach residents in order to evaluate whether the
current profile of the community reveals vulnerabilities to any of a number of health outcomes,
and also to provide a benchmark so that the HIA can predict the extent of change from current
health conditions (Ross et al., 2014).
Existing health and environmental data from regulatory agency monitoring and published
reports were documented in the baseline health assessment, and some of the baseline data
collected specifically for the EIR was also incorporated into the baseline health assessment.
The following sections summarize key information from the Hermosa baseline health
assessment that is provided as a separate report in Appendix E. The baseline health
assessment remains unchanged from the February 2014 draft HIA.
5.1.1 Demographic Characteristics
Table 5-1 provides both city and county level demographic indicators from the US Census. The
City of Hermosa Beach, as defined by the 2010 Census, has 19,506 residents with 52.7% male
and 47.3% female. Age is an important factor in determining vulnerability. According to the
census data for Hermosa, approximately 25% of the population may be considered to be more
vulnerable to certain environmental exposures, based on age (9% over the age of 65 and 16%
under 18 years). This is fewer than the percentage of Los Angeles County residents considered
vulnerable to environmental exposures based on age (35%).
In the 2010 US Census, 95.8% of residents in Hermosa reported one race: 86.8% identified as
White, 5.7% as Asian, 1.2% as Black or African American, 0.3% as American Indian and Alaska
Native, 0.2% as Native Hawaiian and Other Pacific Islander, and 1.7% as some other race.
Compared to the County of Los Angeles, Hermosa is much less racially and ethnically diverse.
On the county level, 48.2% of the population identifies as Hispanic or Latino while only 8.4% of
the Hermosa population identifies as Hispanic or Latino.
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Education level, income, and housing are all components of social determinants of health.
Social determinants of health refer to the role that our social environment and economic
situation play in shaping our health, as social and economic factors are the single largest
predictor of health outcomes, compared to clinical health care, health behaviors, and the
physical environment (LACDPH, 2013). Nearly 70% of Hermosa residents have obtained a
bachelor’s degree or higher, compared to less than 30% in greater Los Angeles County. Median
household income in Hermosa Beach is almost double that of LA County ($102K vs. $56K).
Fewer than 4% of Hermosa residents live in poverty, compared to 16.3% of LA County
residents. In contrast to the income profile, the homeownership rate in Hermosa is less than that
of LA County (44.9% versus 47.8%). The homeownership profile is likely explained by Hermosa
as a beach tourist destination and an area highly attractive to both renters and leasers. Further,
with a median housing unit value over one million dollars, homeownership in Hermosa is over
twice as expensive in Hermosa compared to Los Angeles County.
Overall, demographic indicators show that Hermosa Beach is not highly vulnerable to negative
health outcomes traditionally associated with poverty, unemployment, and low educational
attainment.
Table 5-1 Demographic Summary (US Census, 2013)
2010 Census Measures Hermosa Beach LA County
Population 19,506 9,818,605
Persons under 18 years, percent 15.9% 23.7%
Persons 65 years and over, percent, 2010 9.0% 11.5%
Female persons, percent 47.3% 50.7%
Race
White alone, percent 86.8% 71.6%
Black or African American alone, percent 1.2% 9.3%
American Indian and Alaska Native alone, percent 0.3% 1.5%
Asian alone, percent 5.7% 14.5%
Native Hawaiian and Other Pacific Islander alone, percent 0.2% 0.4%
Ethnicity
Hispanic or Latino, percent 8.4% 48.2%
High school graduate or higher, percent of persons age 25+, 2007-2011 98.5% 76.1%
Bachelor's degree or higher, percent of persons age 25+, 2007-2011 69.9% 29.2%
Homeownership rate, 2007-2011 44.9% 47.8%
Housing units in multi-unit structures, percent, 2007-2011 48.4% 41.9%
Median value of owner-occupied housing units, 2007-2011 $1,000,001 $478,300
Median household income, 2007-2011 $102,289 $56,266
Persons below poverty level, percent, 2007-2011 3.60% 16.30%
5.1.2 Current Health Conditions
Available data from various sources were gathered in order to characterize the current health
status of the community compared to the expected health status based on data from LA County
or California. Health conditions examined include cancers, mortality, hospitalizations, birth
outcomes, and traffic-related injuries.
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Based on the Los Angeles County Cancer Registry, the observed number of cancer cases in
the City of Hermosa from 2000 to 2010 was within or below the expected number, based on
age-, race- and sex-adjusted incidence rates for Los Angeles County, for most cancers.
Exceptions include melanoma (122 cases versus 24-49 expected) and breast cancer (148
cases versus 90-120 expected). The observed number of colorectal cancers was significantly
lower in Hermosa (41 cases versus 51-84 expected).
The statistically significant increase in melanoma and breast cancer diagnoses among residents
of Hermosa Beach compared to Los Angeles County can largely be explained by known lifestyle
risk factors. Higher socioeconomic status is an accepted risk factor for both of these cancers
and the demographic profile shows that Hermosa Beach residents have higher income and
education than Los Angeles County residents as a whole. In addition, sun exposure is the
strongest risk factor for melanoma and thus an elevated incidence rate would be expected in the
Southern California beach communities, assuming these residents spend more time in the sun
during daylight hours compared to residents elsewhere in the county. Otherwise there is no
evidence that residents of Hermosa Beach experience unusually high or low risk of common
types of cancer (Cozen, 2014).
Hermosa Beach appears to have a favorable mortality profile, according to all-cause mortality,
diseases of the heart, and cancer, compared to LA County (CDPH, 2013). The unadjusted all-
cause mortality rate in Hermosa (40.5 deaths per 10,000 people) is lower than the all-cause
mortality rate in Los Angeles County (56.9 deaths per 10,000 people). Hermosa mortality rates
are also lower for diseases of the heart (9.2 versus 15.8) and cancer (9.0 versus 13.9).
However, differences in population age distribution may explain an apparent decreased risk of
mortality in Hermosa Beach. For example, age is significantly associated with both heart
diseases and cancers, and the County of Los Angeles has a greater proportion of people age
65 years and older (11.5 %) compared to Hermosa (9%).
Hospitalization rates for asthma, diabetes, acute myocardial infarction, and mental illness are
overall much lower in Hermosa Beach compared to California (OSHPD, 2013). The rate of
patients hospitalized for alcohol-drug dependence/alcohol-drug induced mental disease is
elevated in Hermosa compared to California (169 versus 109 hospitalizations per 100,000
people). While hospitalization data may indicate higher than expected alcohol and drug use in
Hermosa, these unadjusted results do not allow conclusions to be made about statistical
significance.
A birth profile for the Hermosa ZIP code was accessed from the California Department of Public
Health data for 2011 (CDPH, 2013b). Access to prenatal care appears slightly better in
Hermosa compared to state-wide; 88% of women in Hermosa received prenatal care in the first
trimester versus 82% of women in California. The rate of low birth weight infants born weighing
less than 2,500 grams (about 5.5 pounds) is the same among Hermosa and California births
(7% in both populations). In 2011, nearly half of births in Hermosa Beach (47%) were to
mothers age 35 and older versus 19% of births in California; indicating a potential vulnerability
to certain developmental conditions, such as autism or Down’s syndrome.
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Information regarding injury and fatality from traffic conditions was gathered from the California
Highway Patrol Integrated Traffic Records System (CHP 2014). From 2009 to 2011, the annual
number of reported vehicle-pedestrian collisions resulting in injury in Hermosa ranged from 3 to
10, the annual number of reported vehicle-bicycle collisions resulting in injury ranged from 6 to
13, and the annual number of reported vehicle-vehicle collisions resulting in injury ranged from
36 to 44. While vehicle-vehicle accidents are far more common than vehicle-pedestrian and
vehicle-bicycle accidents, pedestrians and bicyclists are more likely to suffer from injuries and
severe injuries as a result of the collision compared to motorists or vehicle passengers.
Fatalities due to traffic accidents are extremely rare in Hermosa.
5.1.3 Environmental Quality
Existing environmental quality measures from regulatory agency monitoring and reporting were
gathered in order to characterize the environmental conditions in Hermosa.
South Coast Air Quality Management District (SCAQMD) air monitoring stations provide data for
criteria air pollutants throughout Orange County, Los Angeles, Riverside, and San Bernardino
counties. Hermosa does not have an air monitoring station within its boundaries, and is
contained in the Southwest Coastal Los Angeles County area with an air monitoring station in
nearby Hawthorne. SCAQMD data for 2011 to 2012 show exceedances of the particulate matter
PM10 annual average standard of 20 µg/m3 in 2011 (21.7 µg/m3), as well as the ozone 1-hour
maximum standard of 0.09 ppm and ozone 8-hour maximum standard of 0.07 ppm in 2012
(0.11 and 0.08 ppm, respectively, in the vicinity of Hermosa Beach). Local air monitoring data is
not available for smaller particulate matter PM2.5 but estimated PM2.5 in Hermosa exceeds the
California standard of 12 µg/m3 (13.74 µg/m3) (Cal/EPA and OEHHA 2013). Traffic density in
the region is likely a significant contributor to particulate air pollution.
The California Environmental Protection Agency (Cal/EPA) and the California Office of
Environmental Health Hazard Assessment (OEHHA) developed CalEnviroScreen, an online
mapping application, that can be used to identify California communities that are
disproportionately burdened by multiple sources of pollution (Cal/EPA and OEHHA 2013).
CalEnviroScreen assigns a score to each community based on cumulative environmental
sources such as ambient air, pesticide use, chemical releases, traffic, hazardous substances
cleanup sites, risk to groundwater, permitted hazardous waste facilities, surface water
pollutants, and solid waste sites. Overall, Hermosa ranks in the lowest 10% for CalEnviroScreen
scores, indicating an overall low pollution burden in Hermosa Beach relative to California.
5.1.4 Health Supporting Resources and Health Promotion
Health supporting resources such as the availability of nutritious foods and health care services
are important indicators for various health conditions in communities. There are two large chain
groceries, ten other groceries, and one farmer’s market within Hermosa, providing access to
fresh foods throughout the City. There are no licensed healthcare facilities within the City of
Hermosa. There are various healthcare facilities located in the nearby City of Torrance;
however, for those community members who do not own a vehicle, it may be challenging to
access health care.
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The City of Hermosa Beach and its community members are exceptionally committed to health
promotion and community livability. In 2012, the City of Hermosa Beach launched the Healthy
Air Hermosa public education campaign to ensure residents and visitors can enjoy a smoke-free
environment in public outdoor gathering spots such as the Pier, the Strand, the Greenbelt, Pier
Plaza, City owned parking lots, and all parks. Smoking was previously banned on the beach, in
city buildings and inside restaurants (City of Hermosa Beach, 2012). In February 2013, the City
of Hermosa Beach became the first community in the country to achieve Blue Zones
Community Policy designation – for adopting policies to improve its residents’ well-being. Those
policies include a “Living Streets Policy” focused on making the community more livable,
walkable, and bikeable (e.g., Pier Ave); and a pledge to create a community garden.
A Gallup-Healthways Well Being survey of 1,332 Hermosa, Manhattan and Redondo residents
conducted in 2010 found that the overall well-being rating local residents was higher than the
California average and above the top tier of other cities. More than 90 percent of local residents
said they had access to health care, health insurance and enough money for food, shelter and
other basic needs. Two-thirds were found to be “thriving.” However, the survey also found that
46 percent of the Beach Cities residents felt stressed for most of the day, a number that ranked
them 176th out of 188 communities surveyed. When asked if they had significant worries, 37
percent said they did, which ranked the Beach Cities 177th out of those 188 communities
surveyed (Blue Zones, 2010).
5.1.5 Discussion of Vulnerable and Sensitive Populations
In general, HIAs seek to discuss the potential impact on vulnerable populations of society that
may be disproportionately affected by the project. Invariably, children and the elderly are
considered to be vulnerable populations with respect to numerous different types of
environmental exposure. This is also true for many of the determinants that were evaluated in
this HIA. Vulnerable populations were also included as part of the assessment and the potential
for disproportionate impacts on these individuals was carefully considered in the classification of
magnitude and adaptability. They were also taken into account when making additional
recommendations. Each assessment provides details of the vulnerable population(s) considered
in the evaluation.
Of particular interest in this HIA, the baseline health assessment revealed that there is only a
small portion of the population of Hermosa Beach that lives below the poverty line (4%). Social
environmental equity issues are not a concern as there is no concentration of low-income
housing in proximity to the Project.
In addition, over the course of the 35 year life of the Project there is no indication that population
demographics will change. Seventy-five percent of the population is between 18 and 65, with
over 40% between the ages of 25 and 44.
5.2 Air Quality Assessment
Air emissions from the construction and operation of the Project could affect air quality in the
City of Hermosa Beach. The identification of the air pollutants to be assessed in the HIA began
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page 43
with the emissions inventory associated with the construction and operations of the Project.
Emissions associated with the Project and modeled in the EIR include criteria pollutants (e.g.,
carbon monoxide, nitrogen dioxide, sulfur dioxide and particulate matter), volatile organic
compounds (VOCs) and other toxic air contaminants (e.g., polycyclic aromatic hydrocarbons
(PAHs) and metals), and odorous / toxic compounds (e.g., hydrogen sulfide or H2S). Carbon
monoxide (CO) and sulfur dioxide (SO2) were not carried forward in the HIA as the calculated
emission estimates for these criteria pollutants were determined to be below the South Coast
Air Quality Management District (SCAQMD) regional and local thresholds (see Tables 4.2-7 to
4.2-9 of the EIR) under both the mitigated and unmitigated scenarios, suggesting that the CO
and SO2 emissions associated with the Project will have negligible to low impact on current air
quality on both a local and regional scale. All other pollutants identified in the EIR exceeded
some threshold of significance in the EIR, and therefore were carried forward for further
evaluation in this HIA. These pollutants include:
Nitrogen dioxide (NO2)
Particulate matter (PM10 and PM2.5)
Toxic air contaminants (TACs)
Hydrogen sulfide (H2S) and other odorous compounds
This section presents the potential health effects that might be experienced by people from
short-term and long-term exposure to each of these air pollutants, the ambient air
concentrations for each of the air pollutants, and the potential health effects associated with the
maximum predicted air concentrations of the air pollutants associated with the proposed Project
when added to current (or existing) air concentrations.
5.2.1 Nitrogen Dioxide (NO2)
5.2.1.1 NO2 and Health
Depending on the concentrations in air, NO2 is associated with a range of respiratory effects
(USEPA, 2008). According to the Agency for Toxic Substances and Disease Registry (ATSDR,
2002), low levels of NO2 in air can irritate the eyes, nose, throat and lungs. Breathing air with
high concentrations of NO2 can result in changes in pulmonary function due to inflammation of
lung tissue. Exposure to NO2 can have a more pronounced effect on the health of individuals
with pre-existing respiratory conditions, such as asthma, chronic obstructive pulmonary disease
or bronchitis. Short term NO2 exposure is strongly associated with asthma exacerbation (i.e.,
wheezing, cough, use of medication) among children (USEPA, 2008).
To protect the general public against the described health effects, regulatory bodies across the
globe have set ambient air quality guidelines for NO2. In California, ambient air quality standards
are defined as the “maximum allowable level of [an] air pollutant that can be present in outdoor
air for a given averaging time without causing harmful health effects to most people” (CalEPA,
2007). The California 1-hour AAQS for NO2 is 0.18 ppm (340 µg/m3). In setting the 1-hour
AAQS, the California Environmental Protection Agency (CalEPA) states that the short-term
effect of interest includes a potential to aggravate chronic respiratory disease and respiratory
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symptoms in sensitive groups (CalEPA, 2007). California’s annual AAQS for NO2 is 0.030 ppm
(57 µg/m3).
A summary of the relationships between short-term exposure to NO2 and health effects reported
in the published scientific literature is provided in Table 5-2. Although some studies have
reported mild respiratory effects in asthmatics at NO2 concentrations less than 375 µg/m³
(CalEPA, 2007), because of the absence of a clear dose–response relationship and statistical
uncertainty, the findings of these studies are not considered to reflect the acute effects of NO2
exposure (Forastiere et al., 1996; Cal EPA, 2007). A recent meta-analysis of NO2 exposure and
airway hyper-responsiveness in asthmatic adults suggests that there is no evidence that NO2
causes clinically relevant effects in asthmatics at concentrations up to 1,100 µg/m³ (585 ppb)
(Goodman et al., 2009).
The WHO set its 1-hour air quality guideline for NO2 at 200 µg/m³ (106 ppb; WHO, 2006). This
value is based on the increased incidence of adverse respiratory effects in animal and
epidemiological studies. Similarly, the USEPA established a 1-hour National Ambient Air Quality
Standard of 188 µg/m3 (100 ppb) for NO2 (USEPA, 2008). Both the WHO guideline and USEPA
NAAQS are intended to be protective of sensitive individuals in the population, including
asthmatics, children, the elderly and individuals with pre-existing respiratory conditions. It is
noted that the 2008 USEPA NAAQS review of NO2 states there was little evidence of an effect
threshold, or a value below which no health effects would be expected, based on their review of
the data. The USEPA NAAQS and World Health Organization air quality guideline are more
stringent than California’s 1-hour AAQS for NO2. Although the NAAQS is slightly lower than the
WHO guideline, the NAAQS is based on a 3-year average 98th percentile of the annual
distribution of daily maximum 1-hour concentrations. In contrast, the WHO air quality guideline
is compared against the maximum predicted hourly air concentrations, making it a slightly more
conservative metric for assessing the potential short-term health risks for NO2. As such, the
WHO 1-hour air quality guideline was used to characterize the short-term health risks
associated with NO2 in the HIA.
The USEPA (2010) chronic NAAQS for NO2 is 100 µg/m³ (53 ppb). The NAAQS was developed
in 1971 (USEPA, 2010) and has been subsequently upheld through a number of scientific and
regulatory reviews between 1971 and 2010. A scientific review of the annual NAAQS conducted
in 1993 upheld the standard of 100 µg/m³, based on the results of a meta-analysis of
epidemiological studies. In 1996, the annual standard was maintained by the USEPA on the
basis that, in combination with the short-term standard, the annual standard was protective of
both the potential short-term and long-term human health effects of NO2 exposure (USEPA,
1996). The most recent edition of the Final Rule (USEPA, 2010) indicates that the annual
standard was upheld due to the uncertainty associated with the potential long-term effects of
NO2. The uncertainty associated with potential long-term effects of NO2, in the case of
respiratory morbidity, is due to the high correlation among traffic pollutants which makes it
difficult to accurately estimate the independent effects of NO2 in long-term exposure studies.
The WHO (2006) chronic air quality guideline for NO2 is 40 µg/m³ (0.023 ppm). The WHO
(2006) indicates that the 40 µg/m³ is based on consideration of background concentrations and
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the observation that adverse health impacts may occur when concentrations in addition to
background exceed that level. Although this value is not well substantiated in the available
supporting documentation, it is the more conservative or stringent value when compared to the
USEPA NAAQS and California AAQS. As such, the WHO annual air quality guideline was used
to characterize the long-term health risks associated with NO2 in the HIA.
Table 5-2 Potential Acute Health Effects Associated with NO2
Air Concentration
µg/m³ and (ppb)
Description of the Potential Health Effects1
<190 (101) No documented reproducible evidence (consistent and significant) of adverse
health effects among healthy individuals or susceptible individuals following
short-term exposure. Study results are variable and are indiscernible from
background or control groups.
190 (101) to
560 (298)
Increased airways responsiveness, detectable via meta-analysis, among
asthmatics. Large variability in protocols and responses.
490 (261) Allergen-induced decrements in lung function and increased allergen-induced
airways inflammatory response among asthmatics. Most studies used
non-specific airways challenges. No NO2-induced change in lung function. No
documented effects among healthy individuals.
560 (298) to
750 (399)
Potential effects on lung function indices, including inconsistent changes forced
expiratory volume in 1 second (FEV1) and forced vital capacity among patients
with chronic obstructive pulmonary disease (COPD) during mild exercise.
1,900 (1,011) to
3,700 (1968)
Increased likelihood of inflammatory response and airway responsiveness among
healthy individuals during intermittent exercise. Symptoms have not been
detected by most investigators among healthy individuals. Asthmatics might
experience small decrements in FEV1.
≥3,700 (≥1968) Changes in lung function, such as increased airway resistance, in healthy
individuals.
Notes: 1 These descriptions identify the health effects that might be experienced among normal, healthy individuals following acute
exposure to NO2. Also listed are the types of symptoms that might occur among individuals with pre-existing breathing disorders,
such as asthma, bronchitis or COPD. The exact nature and severity of responses that might occur among individuals with
pre-existing conditions will depend on several factors, including:
the severity of the person’s condition
the age of the individual
the level of management of the disorder, including the availability and use of medications
the person’s level of physical activity
external environmental factors such as temperature and humidity
The symptoms that could be experienced by these individuals could be more or less severe that those described because of these
factors.
Sources: Azadniv et al. (1998); Beil and Ulmer (1976); Blomberg et al. (1997, 1999); Cal EPA (2007); Devlin et al. (1999); Gong et
al. (2005); Goodman et al. (2009); Jorres et al. (1995); Morrow et al. (1992); von Nieding et al. (1979, 1980); von Nieding and
Wagner (1977); Vagaggini et al. (1996); USEPA (2008).
5.2.1.2 Current Conditions
In 2012, background or ambient air concentrations of NO2 were measured at 26 stations within
the SCAQMD; however, a monitoring station was not identified within the local vicinity of the
Project, nor was a station identified within the City of Hermosa Beach. The closest air
monitoring station to the Project that measures ambient NO2 concentrations in air is in the City
of Hawthorne within Southwest Coastal Los Angeles County (Area 3, Station 820). For the
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purposes of the Project EIR and HIA, it was assumed that the air quality in Hermosa Beach
would be similar to that of Hawthorne. In 2012, the maximum measured 1-hour NO2
concentration at Station 820 was 116 µg/m³, and the annual average NO2 concentration was
19.6 µg/m³. These concentrations remain below the WHO air quality guidelines for NO2 (i.e., 1-
hour AQG of 200 µg/m³ and annual AQG of 40 µg/m³) (WHO, 2006).
As described in Section 5.2.1.1, short-term and long-term exposure to air pollutants can affect
human health. The current health status of Hermosa Beach residents is described in Appendix
E using the health statistics for the incidence and mortality rates of diseases that are often
associated with air pollution in the scientific literature, such as chronic lower respiratory disease,
heart disease and asthma.
5.2.1.3 Project Impact
In order to predict the maximum 1-hour NO2 air concentrations (i.e., background plus Project)
that people might experience in the vicinity of the Project, the maximum 1-hour NO2 air
concentrations predicted for the Project at the Point of Maximum Impact (PMI) and within the
residential community surrounding the Project under the mitigated scenario were added to the
maximum 1-hour background or ambient air concentration of NO2 described in Section 5.2.1.2.
Similarly, the maximum annual average NO2 air concentrations (i.e., background plus Project)
were calculated by adding the maximum predicted annual average NO2 air concentration for the
Project under the mitigated scenario to the annual average background or ambient air
concentration of NO2 described in Section 5.1.1.2. Table 5-3 provides the maximum predicted 1-
hour and annual air concentrations and the corresponding air quality guidelines established by
the WHO for the protection of public health.
Table 5-3 Comparison of Maximum Predicted NO2 Air Concentrations for the Mitigated
Scenario against Health-Based Air Quality Guidelines
Averaging
Time
Location Background
Air
Concentration1
(µg/m³)
Maximum Predicted Air
Concentration (µg/m³)
Air Quality
Guideline2
(µg/m³) Project Cumulative
(Background +
Project)
1-hour PMI 116 38.2 154 200
Residential 116 33.3 149
Annual PMI 19.6 3.6 23.2 40
Residential 19.6 2.3 21.9
Notes:
1 Based on the maximum of the measured ambient hourly NO2 air concentrations within Southwest Coastal Los Angeles County
(Area 3, Station 820) during 2012. 2 WHO (2006)
PMI = Point of Maximum Impact
Residential = Highest concentration at homes adjacent to the Site
The maximum predicted 1-hour and annual NO2 concentrations for the PMI and the residential
locations are below the WHO air quality guidelines, indicating that adverse health effects are not
expected to result from either short-term or long-term exposure to NO2. Moreover, there are no
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predicted “exceedances” of California’s Ambient Air Quality Standards, or the USEPA National
Ambient Air Quality Standards.
The impact of Project-related NO2 emissions on the health of the community is provided in Table
5-4.
Table 5-4 HIA Evaluation Matrix – Nitrogen Dioxide (NO2)
Health Determinant Nitrogen Dioxide (NO2)
Potential Health Outcome Respiratory irritation and airway constriction
Pre-Mitigation Discussion The direction of the pre-mitigated impact is negative.
Construction activities and operations could generate NOx
emissions that exceed South Coast Air Quality Management
District Thresholds.
EIR Mitigation NOx reduction program (AQ-1b), limited flaring (AQ-3a), and air
monitoring plan (AQ-5d)
Geographic Extent Localized
Vulnerable Populations Children, elderly, individuals with pre-existing conditions
Magnitude Low
Adaptability High
Likelihood Unlikely
Post-Mitigation Health Effect No Substantial Effect
Comments or Additional
Recommended Measures
None.
As described in Table 5-4, without mitigation, construction activities and operations could
generate NOx (e.g., NO2) emissions that exceed SCAQMD thresholds. However, the Project will
comply with a range of air quality mitigation measures and permits, including combustion
emission limits. These mitigation measures were described in detail in Section 4.2.4.1 of the
EIR.
The influence of the proposed Project on NO2 ground-level air concentrations is expected to be
‘localized’ because air pollutant concentrations dissipate from the source. The vulnerable
population identified for air quality impacts are ‘children, the elderly and individuals with pre-
existing health conditions’. The magnitude of the health effect related to NO2 is ‘low’,
meaning that they are not expected to be high enough to pose a health hazard to the
community of Hermosa Beach. The adaptability is considered ‘high’, in that people are
expected to be unaffected or easily able to adapt to the change in NO2 emissions (i.e., people
will be able to maintain their pre-project level of health). The likelihood of an adverse health
effect occurring as a result of the Project’s NO2 emissions was defined as ‘unlikely’. Based on
the findings of the Air Quality assessment and the planned mitigation measures for the Project
(see Section 4.2 of the EIR), the potential NO2-related health impact associated with the Project
is classified as ‘no substantial effect’. Therefore, no additional measures are recommended.
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5.2.2 Particulate Matter (PM)
5.2.2.1 PM and Health
Particulate matter is a widespread air pollutant composed of a mixture of solid and liquid
particles, and its effects on health are well documented. Particles with a diameter of 10
micrometers or smaller are referred to as PM10, and particles with a diameter of 2.5 micrometers
or smaller are known as PM2.5. Both PM10 and PM2.5 include inhalable particles that are small
enough to enter the lungs, and both short-term (hours, days) and long-term (months, years)
exposure can result in increased respiratory and cardiovascular disease. Specifically, PM
exposure is associated with exacerbation of asthma and an increase in hospital admissions. In
addition, increased mortality rates from cardiovascular and respiratory diseases are well
documented in large urban centers. The most susceptible groups include people with pre-
existing lung or heart disease, older adults and children.
Long-term exposure to smaller particles (PM2.5) tends to be a stronger risk factor for morbidity
and mortality than exposure to larger particles (PM10) (Zanobetti and Schwartz, 2009).
According to the California Environmental Protection Agency, “exposure to outdoor PM10 and
PM2.5 levels exceeding current air quality standards is associated with increased risk of
hospitalization for lung and heart-related respiratory illness, including emergency room visits for
asthma” (CalEPA, 2005).
California set its 24-hour and annual standards for PM10 at 50 µg/m3 and 20 µg/m3, respectively.
Like California, WHO’s 24-hour and annual air quality guidelines for PM10 are 50 µg/m3 and
20 µg/m3, respectively (WHO, 2006). The USEPA does not have an annual NAAQS for PM10
but does offer a 24-hour standard of 150 µg/m3.
While California does not have a 24-hour AAQS for PM2.5, it has set its annual AAQS for PM2.5
at 12 µg/m3. This value was recommended by the California Air Resources Board and is based
on a growing body of epidemiological and toxicological studies showing significant toxicity
(resulting in mortality and morbidity) related to exposure to fine particles (CARB, 2009). The
USEPA (2006) offers a 24-hour NAAQS of 35 µg/m³ for PM2.5 for primary and secondary
particulate, which is intended to be protective of human health effects as well as several
environmental and socioeconomic endpoints. The USEPA’s annual primary NAAQS for PM2.5 is
12 µg/m3.
The WHO 24-hour and annual average air quality guidelines for PM2.5 are 25 µg/m3 and
10 µg/m3, respectively. The WHO suggests that the annual average should take precedence
over the daily guideline because at low levels there is less concern for episodic excursions. The
annual average guideline is based on long-term exposure studies using the American Cancer
Society (ACS) data (Pope et al., 2002) and Harvard Six-Cities data (Dockery et al., 1993). The
studies reported a robust association between PM exposure and mortality. Historical mean
PM2.5 concentrations across cities in these two studies were 18 and 20 µg/m³, respectively, but
average concentrations in individual cities were as low as 11 µg/m³ over the period of study. An
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annual mean guideline concentration of 10 µg/m³ was therefore noted to be below the mean for
most likely effects (WHO, 2006).
WHO acknowledges that “research has not identified thresholds below which adverse effects do
not occur” (WHO, 2006). As such, WHO (2006) states that ambient air quality guidelines for
PM2.5 may never be fully protective of human health:
“As thresholds have not been identified, and given that there is substantial inter-
individual variability in exposure and in the response in a given exposure, it is unlikely
that any standard or guideline value will lead to complete protection for every individual
against all possible adverse health effects of particulate matter. Rather, the standard-
setting process needs to aim at achieving the lowest concentrations possible in the
context of local constraints, capabilities and public health priorities.”
In light of the concept that a clear threshold of effect has not been identified for PM2.5, the more
stringent WHO guidelines were used to characterize the PM-related health risks in the HIA.
5.2.2.2 Current Conditions
In 2012, background or ambient air concentrations of PM10 were measured at 22 stations within
the SCAQMD; however, the closest ambient air monitoring station to the Project was identified
within the Southwest Coastal Los Angeles County (Area 3, Station 820). For the purposes of the
EIR and HIA, it was assumed that air quality in Hermosa Beach would be similar to that of
Hawthorne. In 2012, the maximum measured 24-hour PM10 concentration was 31 µg/m³ and the
annual average was 19.8 µg/m³. These concentrations remain below the California and WHO
24-hour and annual air quality guidelines for the protection of public health (i.e., 50 µg/m³ and
20 µg/m³, respectively).
Table 5-5 presents the 24-hour and annual air concentrations of PM10 measured at ambient air
monitoring stations across Los Angeles County in 2012. Note that 98th percentiles were not
reported for the 24-hour averaging time.
Table 5-5 PM10 Air Concentrations Measured in Los Angeles County in 2012
Monitoring Station Measured Air Concentration (µg/m³)
24-hour Maximum Annual Average
1 Central LA 80 30.2
2 Northwest Coastal LA County -- --
3 Southwest Coastal LA County (Station 820) 31 19.8
4 South Coastal LA County 1
South Coastal LA County 2
South Coastal LA County 3
45
54
--
23.3
25.5
--
6 West San Fernando Valley -- --
7 East San Fernando Valley 55 26.4
8 West San Gabriel Valley -- --
9 East San Gabriel Valley 1
East San Gabriel Valley 2
78
--
30.3
--
10 Pomona/Walnut Valley -- --
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Monitoring Station Measured Air Concentration (µg/m³)
24-hour Maximum Annual Average
11 South San Gabriel Valley -- --
12 South Central LA County -- --
13 Santa Clarita Valley 37 19.6
Source: 2012 Air Quality: South Coast Air Quality Management District
--Not Available
Background or ambient air concentrations of PM2.5 were measured at 20 stations within the
SCAQMD during 2012, and nine in Los Angeles County. However, the Southwest Coastal Los
Angeles County air monitoring station (Area 3, Station 820) did not measure for PM2.5. The
closest stations that measured for PM2.5 are within South Coastal Los Angeles County (Area 4,
Station 072 and 077) and South Central Los Angeles County (Area 12, Station 112). In 2012,
maximum 24-hour ambient PM2.5 air concentrations measured at these stations ranged between
46.7 µg/m³ and 51.2 µg/m³, while annual PM2.5 air concentrations ranged between 10.4 µg/m³
and 11.7 µg/m³.
Table 5-6 presents the maximum and 98th percentile 24-hour and annual air concentrations of
PM2.5 measured within Los Angeles County during 2012. These concentrations exceed the
WHO 24-hour and annual air quality guidelines for PM2.5 of 25 µg/m³ and 10 µg/m³, respectively
(WHO, 2006). California has not established an AAQS for 24-hour PM2.5, but the 98th percentiles
of measured 24-hour PM2.5 concentrations within Los Angeles County are below the 24-hour
NAAQS for PM2.5 of 35 µg/m³. In 2012, the measured annual average air concentrations of
PM2.5 were below California’s annual AAQS and the USEPA NAAQS for PM2.5 (12 µg/m³) at the
majority of the monitoring stations in LA County. The exceptions were at Central Los Angeles
and East San Fernando Valley, where the measured annual average PM2.5 air concentrations
were 12.55 µg/m³ and 12.17 µg/m³, respectively.
Table 5-6 PM2.5 Air Concentrations Measured in Los Angeles County in 2012
Monitoring Station 24-Hour Air
Concentration (µg/m³)
Annual Air
Concentration
(µg/m³)
Maximum 98th
Percentile
Average
1 Central LA 58.7 31.8 12.55
2 Northwest Coastal LA County -- -- --
3 Southwest Coastal LA County (Station 820) -- -- --
4 South Coastal LA County 1 (Station 72)
South Coastal LA County 2 (Station 77)
South Coastal LA County 3
49.8
46.7
--
26.4
25.1
--
10.37
10.57
--
6 West San Fernando Valley 41.6 31.2 10.48
7 East San Fernando Valley 54.2 28.2 12.17
8 West San Gabriel Valley 30.5 24.2 10.12
9 East San Gabriel Valley 1
East San Gabriel Valley 2
39.6
--
25.6
--
11.02
--
10 Pomona/Walnut Valley -- -- --
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11 South San Gabriel Valley 45.3 28.5 11.85
12 South Central LA County (Station 112) 51.2 30.3 11.69
13 Santa Clarita Valley -- -- --
Source: 2012 Air Quality: South Coast Air Quality Management District
--Not Available
5.2.2.3 Project Impact
Health impacts of particulate matter are greater from fine particles with aerodynamic diameters
less than 2.5 µm, since they can be carried deep into the alveolar spaces of the lung and may
reach the circulatory system where they could affect cardiac function (Pope and Dockery, 2006;
USEPA, 2009; CCME, 2012). Therefore, fine particulate matter (PM2.5) tends to exhibit a greater
potential impact on human health than coarser particulate matter (Zanobetti and Schwartz,
2009). The air quality modelling conducted for the EIR conservatively assumed that all fine
particulate matter would be in the smaller form (i.e., assumed all PM10 is PM2.5). As a result, the
discussion of the potential Project impacts focused on PM2.5.
In order to predict the maximum 24-hour PM2.5 air concentrations (i.e., background plus Project)
that people might experience in the vicinity of the Project, the maximum 24-hour PM2.5 air
concentrations predicted for the Project at the PMI and within the surrounding residential
community under the mitigated scenario were added to the 98th percentiles of 24-hour
background or ambient air concentrations of PM2.5 described in Section 5.2.2.2. Similarly, the
maximum annual average PM2.5 air concentrations (i.e., background plus Project) were
calculated by adding the maximum predicted annual average PM2.5 air concentration for the
Project under the mitigated scenario to the annual average background or ambient air
concentrations of PM2.5 described in Section 5.2.2.2.
Table 5-7 compares the maximum predicted 24-hour and annual air concentrations to the
corresponding WHO air quality guidelines for PM2.5. In addition to the maximum predicted air
concentrations at the PMI and residence, Table 5-7 also presents the Project’s PM2.5
concentrations averaged over the 1.5 x 1.5 mile air quality main receptor grid (see EIR, Section
4.2, Impact #AQ.7, page 4.2-62).
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Table 5-7 Comparison of Maximum Predicted Air Concentrations for PM2.5 for the
Mitigated Scenario against the World Health Organization’s Air Quality Guidelines
Averaging
Time
Location Background Air
Concentration1
(µg/m³)
Predicted Air Concentration
(µg/m³)
Air Quality
Guideline2
(µg/m³) Project Cumulative
(Background +
Project)
24-hour PMI 24.2 to 31.81 4.2 28.4 to 36.0
25 Residential 24.2 to 31.81 2.3 26.5 to 34.1
Receptor grid
average3
24.2 to 31.81 0.5 24.7 to 32.3
Annual PMI 10.12 to 12.55 1.6 11.72 to 14.15
10 Residential 10.12 to 12.55 0.6 10.72 to 13.15
Receptor grid
average3
10.12 to 12.55 0.09 10.21 to 12.64
1 Based on the 98th percentile of measured daily PM2.5 concentrations in LA County in 2012
2 WHO 2006
3 PM2.5 concentrations averaged over the 1.5x1.5 mile air quality receptor grid
PMI = Point of Maximum Impact
Residential = Highest concentration at homes adjacent to the Site
As shown in Table 5-7, the maximum predicted 24-hour and annual concentrations for PM2.5 at
the PMI and in the surrounding residential community exceed the WHO air quality guidelines as
a result of the assumed daily and annual background air concentrations. The upper end of the
range of maximum predicted 24-hour concentrations for PM2.5 also could exceed the USEPA
24-hour NAAQS of 35 µg/m³; however, this assumes that the background 24-hour PM2.5 air
concentrations within Hermosa Beach are comparable to Central Los Angeles or West San
Fernando Valley. It is more likely that the current air quality within Hermosa Beach more closely
resembles that of South Coastal Los Angeles County, where the maximum predicted 24-hour air
concentration of PM2.5 would remain below the 24-hour NAAQS of 35 µg/m³ (i.e., 29.3 to
30.6 µg/m³ at the PMI). Similarly, on an annual basis, the upper end of the range of maximum
predicted PM2.5 concentrations could exceed the annual AAQS in California and the NAAQS for
PM2.5 of 12 µg/m³. Assuming the background or ambient annual air concentrations for PM2.5 in
South Coastal Los Angeles County would result in predicted annual PM2.5 concentration of
11.97 to 12.17 µg/m³ at the PMI, 10.97 to 11.17 µg/m³ at the highest residential location, and
10.46 to 10.66 µg/m3 averaged across the main air quality receptor grid. When adding the
predicted values to the existing PM2.5 air concentrations at the South Coastal Los Angeles
County monitoring stations, the Project is not expected to result in exceedances of the California
annual AAQS or USEPA NAAQS at the local residences.
The WHO chose an annual average concentration of 10 µg/m³ as its long-term air quality
guideline as this represents the lower end of the range over which significant effects on survival
were observed in the American Cancer Society’s (ACS) study (Pope et al., 2002). In the ACS
and Harvard Six-Cities studies (Dockery et al., 1993; Pope et al., 1995; HEI, 2000; Pope et al.,
2002; Jerrett, 2005), robust associations were reported between long-term exposure to PM2.5
and mortality. The historical annual mean PM2.5 concentration was 18 µg/m³ (range, 11.0 to
29.6 µg/m³) in the Six-Cities study and 20 µg/m³ (range, 9.0 to 33.5 µg/m³) in the ACS study. In
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the ACS study, statistical uncertainty in the risk estimates becomes apparent at concentrations
near 13 µg/m³. Below this level the confidence bounds significantly widen (i.e., the uncertainty
grows).
Exceedances of the WHO air quality guidelines, California AAQS and USEPA NAAQS for PM2.5
are due to existing conditions in the area. Existing PM2.5 air concentrations in the area are in the
range at which health effects have been identified in large urban centers. Based on the
predicted values presented in Section 4.2 of the EIR and described herein, the Project is not
expected to have a material impact on existing PM2.5-related health risks to the community of
Hermosa Beach. The impact of Project-related PM2.5 emissions on the health of the community
is provided in Table 5-8.As described in Table 5-8, without mitigation, construction activities and
operations could result in emissions of fine particulate matter that exceed SCAQMD localized
significance thresholds. However, the Project will comply with a range of air quality mitigation
measures and permits, including combustion emission limits. Particulate matter emissions will
be controlled, in part, through dust suppression program, and mitigation measures related to
flaring and microturbine emissions. These mitigation measures were described in detail in
Section 4.2.4.1 of the EIR.
Table 5-8 HIA Evaluation Matrix – Particulate Matter (PM2.5)
Health Determinant Particulate Matter (PM2.5)
Potential Health Outcome Morbidity (e.g., cardio-pulmonary effects) and mortality.
Pre-Mitigation Discussion The direction of the pre-mitigated impact is negative.
Construction activities and operations could generate PM10 and
PM2.5 emissions that exceed localized significance (SCAQMD)
thresholds.
EIR Mitigation Limited flaring (AQ-3a), limited microturbine PM emissions (AQ-4), air
monitoring plan (AQ-5d), and diesel emission requirements (AQ-7a)
Geographic Extent Localized
Vulnerable Populations Children, elderly, individuals with pre-existing conditions
Magnitude Low
Adaptability High
Likelihood Unlikely
Post-Mitigation Health Effect No Substantial Effect
Comments or Additional
Recommended Measures
None.
The influence of the Project on PM2.5 ground-level air concentrations is expected to be
‘localized’ because air pollutant concentrations dissipate from the source. The vulnerable
population identified for air quality impacts are ‘children, the elderly and individuals with pre-
existing conditions’. Although existing concentrations of PM2.5 may exceed air quality
guidelines, the magnitude of the health effect related to PM2.5 is ‘low’, meaning that PM2.5
emissions are not expected to be high enough to exacerbate health risks to the community of
Hermosa Beach. The adaptability is considered ‘high’, in that people are expected to be able to
easily adapt to the change in PM2.5 emissions (i.e., people will be able to maintain their pre-
project level of health). The likelihood of an adverse health effect occurring as a result of the
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
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Project’s PM2.5 emissions was defined as ‘unlikely’. Based on the findings of the Air Quality
assessment and the planned mitigation measures for the Project (see Section 4.2 of the EIR),
the potential PM2.5-related health impact associated with the Project is classified as ‘no
substantial effect’. Therefore, no additional measures are recommended.
5.2.3 Toxic Air Contaminants
5.2.3.1 Toxic Air Contaminants and Health
The term “toxic air contaminants” can describe a wide array of chemicals, including volatile
organic compounds (VOCs), polycyclic aromatic hydrocarbons (PAHs), inorganic elements
(e.g., metals) and particulate emissions from diesel exhaust. Considering that there are many
different types of groups of toxic air contaminants, the potential health effects associated with
these compounds are accordingly diverse and can range from short-term sensory irritation to
long-term, irreversible effects such as cancer. The nature and extent of the various toxic
responses depend largely on the magnitude and duration of the exposures.
5.2.3.2 Current Conditions
The Multiple Air Toxics Exposure Study (MATES) is an urban toxic air pollution study that was
initiated by the SCAQMD. As described in Section 4.2 of the EIR, the MATES program includes
a monitoring program that uses both fixed and mobile monitoring stations, an up-to-date
emissions inventory of toxic air contaminants, and exposure modeling to evaluate health risks in
the South Coast Air Basin. The focus of the program is on the cancer risks associated with the
toxic air contaminants.
According to the third iteration of the MATES program (i.e., MATES III), the existing
carcinogenic risk from air toxics in the South Coast Air Basin is approximately 1,200 excess
cancer cases per one million people, based on the average air concentrations at the MATES
fixed monitoring sites. According to the MATES III study and as described in Section 4.2 of the
EIR, the existing air toxics cancer risk in the general vicinity of the Project is approximately 687
excess cancer cases per one million persons. Based on the MATES II Study, in the South Coast
Air Basin, approximately 94% of the cancer risk is due to emissions associated with mobile
sources, with the remainder of the risk (6%) attributed to toxics emitted from stationary sources.
Accounting for approximately 84% of the total risk, diesel exhaust was identified as the primary
contributor to the air toxics risks.
The California Air Resources Board (CARB) reports annual summaries for select monitoring
stations across the state. The closest monitoring station with data on VOCs is North Long
Beach. Ambient benzene concentrations have been steadily decreasing over the last two
decades. In 2012, the mean benzene concentration at North Long Beach was 0.402 ppb (or
1.28 µg/m³). Ambient PAH air concentrations have also been on the decline. MATES III data
from 2008 are used to estimate current conditions for the Hermosa Beach area. This evaluation
focuses on the most carcinogenic chemical in the group of PAHs - benzo(a)pyrene. Three
monitoring stations, Central LA, Rubidoux and Wilmington, monitor benzo(a)pyrene and have
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reported average concentrations of 0.00012, 0.00014 and 0.00018 µg/m3, respectively (Table
IV-3, SCAQMD 2008).
5.2.3.3 Project Impact
Section 4.2 of the EIR presents the findings of the human health risk assessment (HHRA) of the
toxic air contaminants associated with the Project. The HHRA was conducted using the CARB
Hotspots Analysis and Reporting Program (HARP) model 1.4f. HARP is a scientifically
defensible method for characterizing health risks for toxic air contaminants. Its use for assessing
health risks has been endorsed by the State of California and it is the recommended model for
calculating and presenting HHRA results for the Hot Spots Program (CalEPA, 2003). Applicants,
proponents or operators who conduct and submit an HHRA to the SCAQMD must do so
according to the OEHHA Air Toxics Hot Spots Program Risk Assessment Guidelines (SCAQMD
2011). The HHRA of the Project presented in Section 4.2 and Appendix B of the EIR appeared
to follow the OEHHA guidelines for assessing health risks of trace air contaminants.
In the toxic air contaminant HHRA, carcinogenic risks and non-carcinogenic risks (acute and
chronic) were calculated for offsite populations, including commercial workers and residents.
The toxic air contaminants considered in the HHRA include:
VOCs, such as acetaldehyde, acrolein, benzene, 1,3-butadiene, ethylbenzene,
formaldehyde, hexane, methanol, methyl ethyl ketone (MEK), propylene, styrene,
toluene and xylenes;
PAHs, such as naphthalene and benzo(a)pyrene;
Metals, such as arsenic, cadmium, copper, lead, manganese, mercury, nickel, selenium
and zinc;
Halides, such as chlorine;
Sulfur-containing compounds, such as H2S; and,
Diesel exhaust particulates.
In this type of HHRA, the carcinogenic risk is described as the incremental increase in cancer
cases among people exposed over a lifetime as a result of the Project. In accordance with
SCAQMD guidance, cancer risks are compared to a cancer risk threshold of 10 in one million
(10x10-6, or 10 excess cases of cancer per 1,000,000 people exposed). Cancer risks are
calculated as shown and provided in Table 5-9.
Cancer Risk = Incremental Exposure Estimate
Cancer Potency Factor
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Table 5-9 Predicted Cancer Risks (per one million) associated with the Project under the
Mitigated Scenario
Toxic Air Contaminant Point of Maximum Impact Peak Residence
Acetaldehyde 0.0029 0.0020
Benzene 6.0 2.1
Diesel Exhaust Particulate 0.091 0.039
Ethylbenzene 0.0048 0.0034
Formaldehyde 0.022 0.015
Naphthalene 0.0021 0.0015
PAHs 0.090 0.064
Sum (per 1,000,000) 6.2 2.2
Non-cancer risks are expressed in terms of a hazard index (or HI), which is a ratio of the
estimated exposure compared to levels at which health effects would not be expected to occur,
specifically the OEHHA reference exposure levels (RELs). An HI is calculated as:
Hazard Index = Exposure Estimate
REL
A hazard index that exceeds the benchmark of 1.0 signifies that the exposure estimate exceeds
the REL for a given chemical. The potential acute and chronic non-cancer risks, expressed as
hazard indices, for the toxic air contaminants are provided in Table 5-10 and Table 5-11,
respectively.
As shown, the acute and chronic hazard indices for the toxic air contaminants are less than 1.0,
indicating that the maximum predicted exposure estimates are all less than their OEHHA RELs.
A hazard index less than 1.0 is associated with a low health risk. Therefore, the Project is not
expected to result in non-cancer health effects in the City of Hermosa Beach.
Table 5-10 Predicted Acute Hazard Indices under the Mitigated Scenario
Toxic Air Contaminant Peak Boundary Receptor Peak Residence
1,3-Butadiene 0.000039 0.000015
Acetaldehyde 0.0022 0.00086
Acrolein 0.0078 0.0094
Arsenic 0.00062 0.00023
Benzene 0.0057 0.0028
Chlorine 0.00000026 0.000000096
Copper 0.0000011 0.00000042
Formaldehyde 0.038 0.016
Hydrogen Sulfide (H2S) 0.0069 0.0034
Mercury 0.000020 0.0000076
Methanol 0.00000014 0.000000054
Methyl ethyl ketone 0.000015 0.0000057
Nickel 0.000079 0.000029
Styrene 0.00000039 0.00000014
Toluene 0.00012 0.000065
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Toxic Air Contaminant Peak Boundary Receptor Peak Residence
Xylenes 0.000013 0.000012
Sum 0.048 0.027
Given that chemical exposures rarely occur in isolation, the potential cancer and non-cancer
health risks associated with the mixture of toxic air contaminants were assessed in the HHRA.
Chemicals within a mixture may interact in different ways such that toxicity may be altered,
possibly becoming enhanced (i.e., additivity, synergism or potentiation), reduced (i.e.,
antagonism) or remaining unchanged. The assessment of the health risks of chemical mixtures
is challenging by virtue of the infinite number of chemical combinations that are possible.
Recent efforts have been taken by several leading scientific and regulatory authorities to better
understand the types of interactions involved and to develop methods for assessing mixtures
(Boobis et al., 2011; European Commission, 2012; Meek et al., 2011).
Table 5-11 Predicted Chronic Hazard Indices under the Mitigated Scenario
Toxic Air Contaminant Peak Boundary Receptor Peak Residence
Acetaldehyde 0.000010 0.0000013
Acrolein 0.0023 0.00022
Benzene 0.0026 0.00027
Diesel Exhaust Particulate 0.000053 0.000020
Ethylbenzene 0.0000014 0.00000014
Formaldehyde 0.00059 0.000066
Hexane 0.000090 0.0000094
Hydrogen Sulfide (H2S) 0.00063 0.000066
Naphthalene 0.0000098 0.00000095
Propylene 0.000000018 0.0000000066
Toluene 0.00033 0.000065
Xylenes 0.000012 0.000012
Sum 0.0039 0.00041
These efforts have led to the following observations:
Under certain conditions, chemicals can act in combination as a mixture in a manner that
affects the overall level of toxicity.
Chemicals with common modes of action can act jointly to produce combined effects
that may be greater than the effects of each of the constituents alone. These effects are
additive in nature.
For chemicals having different modes of action, there is no robust evidence available to
indicate that mixtures of such substances are of health or environmental concern
provided the individual chemicals are present in amounts at or below their threshold
dose levels.
Interactions (including antagonism, potentiation and synergism) usually occur only at
moderate to high dose levels (relative to the lowest effect levels), and are either unlikely
to occur or to be of any toxicological significance at low or “environmentally relevant”
exposure levels.
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If information is lacking on the mode(s) of action of chemicals in a mixture, it should be
assumed by default that they will act in an additive fashion, with the manner and extent
to which they may interact act determined on a case-by-case basis using professional
judgment.
Based on these observations, the cancer and non-cancer risks for those toxic air contaminants
that act through a common or similar toxicological mechanism and/or affect the same target
tissues and/or organs in the body (i.e., share commonality in effect) were summed. In other
words, the toxic air contaminants are assumed to interact in an additive fashion. As shown in
Table 5-12, consideration was given to the potential additive interaction between the toxic air
contaminants as carcinogens, neurotoxicants, developmental toxicants, eye irritants,
immunotoxicants, reproductive toxicants, and respiratory toxicants. The predicted incremental
cancer risks and non-cancer hazard indices are provided in Table 5-13 for these mixtures.
Table 5-12 Potential Additive Interactions between the Toxic Air Contaminants
Cancer
Risks /
Hazard
Indices
Critical Effects Chemical Mixture Constituents
Cancer Cancer Acetaldehyde, benzene, diesel exhaust particulate, ethylbenzene,
formaldehyde, naphthalene, PAHs
Acute CNS effects Arsenic, H2S, mercury, methanol, toluene, xylenes
Developmental effects 1,3-Butadiene, arsenic, benzene, mercury, styrene, toluene
Eye irritants Acetaldehyde, acrolein, chlorine, formaldehyde, MEK, styrene,
toluene, xylenes
Immunological effects Benzene, nickel
Reproductive effects 1,3-Butadiene, arsenic, benzene, mercury, styrene, toluene
Respiratory effects Acetaldehyde, acrolein, chlorine, copper, MEK, styrene, toluene,
xylenes
Chronic CNS effects Benzene, hexane, toluene, xylenes
Developmental effects Benzene, ethylbenzene, toluene
Reproductive effects Benzene, ethylbenzene, toluene
Respiratory irritation Acetaldehyde, acrolein, diesel exhaust particulate, formaldehyde,
H2S, naphthalene, propylene, toluene, xylenes
Maps of the acute and chronic health indices were presented as Figure 4.2-5 and 4.2-6 in
Section 4.2 of the EIR. As shown in the figures and in Table 5-13, the acute and chronic hazard
indices for the toxic air contaminant mixtures are less than the threshold value of 1.0, indicating
that short-term and/or long-term exposure to the mixtures of toxic air contaminants is not
expected to result in adverse health effects in the City of Hermosa Beach.
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Table 5-13 Cancer Risks and Non-Cancer Risks for the Mixtures
Chemical Mixture Peak Boundary Receptor Peak Residence
Cancer risk, per million 6.2 2.2
Acute risk, hazard index
CNS effects 0.0077 0.0037
Developmental effects 0.0065 0.0031
Eye irritants 0.048 0.027
Immunological effects 0.0057 0.0028
Reproductive effects 0.0065 0.0032
Respiratory irritation 0.010 0.010
Chronic risk, hazard index
CNS effects 0.0030 0.00032
Developmental effects 0.0029 0.00031
Reproductive effects 0.0029 0.00031
Respiratory irritation 0.0039 0.00041
A map of the predicted post-mitigation carcinogenic risks was presented as Figure 4.2-8 in
Section 4.2 of the EIR. The predicted post-mitigation carcinogenic risks are less than 10 in one
million, which is the SCAQMD significance threshold for assessing incremental lifetime cancer
risks. This suggests that the Project’s emissions are not expected to pose a significant cancer
risk to the residents of Hermosa Beach.
Although the acute and chronic non-cancer risks did not account for the potential additive
effects of NO2 on respiratory irritation, inclusion of the maximum acute hazard index of 0.77 at
the Point of Maximum Impact (i.e., 154.2 µg/m³/200 µg/m³) and 0.74 for the peak residential
location (i.e., 149.3 µg/m³/200 µg/m³) for NO2 would not result in an exceedance of the
threshold value of 1.0. The maximum acute hazard index for the respiratory irritants, including
NO2, would be 0.78 and 0.75 at the PMI and peak residential location, respectively. On a
chronic basis, inclusion of NO2 in the respiratory irritants mixture would result in a maximum
hazard index of 0.58 at the PMI and 0.55 at the peak residential location, both of which are
below the threshold value of 1.0.
For the reasons stated, the health risks associated with the Project’s emissions of toxic air
contaminants are expected to be low. The impact of Project-related TAC emissions on the
health of the community is provided in Table 5-14. As described in Table 5-14, without
mitigation, the Project’s emissions of certain toxic air contaminants would exceed the SCAQMD
regional thresholds. Pre-mitigation cancer risks would also exceed the threshold value of 10 in
one million.
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Table 5-14 HIA Evaluation Matrix – Toxic Air Contaminants (TAC)
Health Determinant Toxic Air Contaminants (TAC)
Potential Health Outcome Varies for the TACs. Includes acute effects, chronic non-
carcinogenic and carcinogenic effects.
Pre-Mitigation Discussion The direction of the potential pre-mitigated impact is negative.
Toxic Air Contaminant (TAC) emissions from operations would
be associated with combustion sources (e.g., flares and
microturbines) and fugitive emissions. Emissions of volatile
organic compounds (VOCs) would exceed the SCAQMD
regional thresholds, due primarily to fugitive emissions from
tanks, valves and components of muds off-gassing during
drilling. Predicted unmitigated cancer risks exceed threshold
value of 10 in 1,000,000. Acute and chronic health indices (i.e.,
non-carcinogenic risk estimates) are below the threshold
values of 1.
EIR Mitigation Air quality mitigation measures (AQ-1a, AQ-1b, AQ-3a, AQ-3b, AQ-4,
AQ-5a through AQ-5f, AQ-6, AQ-7a, AQ-7b)
Geographic Extent Localized
Vulnerable Populations Children, elderly, individuals with pre-existing conditions
Magnitude Low
Adaptability High
Likelihood Unlikely
Post-Mitigation Health Effect No Substantial Effect
Comments or Additional
Recommended Measures
Cancer risks, chronic non-cancer risks and acute risks will be
below threshold values post-mitigation.
The Project will comply with a range of air quality mitigation measures and permits, including
component monitoring for leaks, combustion equipment emission limits, restrictions on venting,
etc. All diesel equipment used at the site will meet EPA Tier 3 emission guidelines, and be fitted
with a CARB Level 3 diesel particulate filter to reduce diesel PM emissions. These mitigation
measures were described in detail in Section 4.2.4.1 of the EIR.
The influence of the Project on TAC ground-level air concentrations is expected to be
‘localized’ because air pollutant concentrations dissipate from the source. The vulnerable
population identified for air quality impacts are ‘children, the elderly and pre-existing
conditions’. The magnitude of the health effect from the Project’s contribution to the TAC air
concentrations is ‘low’, meaning that they are not expected to be high enough to pose a health
risk to the residents of Hermosa Beach. The adaptability is considered ‘high’, in that people are
expected to readily be able to adapt to the change in TAC emissions (i.e., people will be able to
maintain their pre-project level of health). The likelihood of an adverse health effect occurring as
a result of the Project’s TAC emissions was defined as ‘unlikely’. Based on the findings of the
Air Quality assessment and the planned mitigation measures for the Project (see Section 4.2 of
the EIR), the potential TAC-related health impact associated with the Project is classified as ‘no
substantial effect’. Therefore, no additional measures are recommended.
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5.2.4 Odor
5.2.4.1 Odor and Health
Sensitivity to environmental odors varies greatly from person to person. Young children, the
elderly, and pregnant women may be more sensitive to odors. In general, the most commonly
reported symptoms from odor exposure are headaches, nasal congestion, eye, nose, and throat
irritation, hoarseness, sore throat, cough, chest tightness, shortness of breath, wheezing, heart
tremors (palpitations), nausea, drowsiness, and depression (ATSDR, 2014). According to the
WHO, odor annoyance can also affect overall quality of life. Adverse health outcomes
associated with odor are related to the frequency, duration, concentration, and the individuals’
level of sensitivity (ATSDR, 2014).
Several compounds associated with oil and gas development can produce odors. In particular,
the sulfur compounds tend to have very low odor threshold levels (e.g., the rotten eggs smell
from hydrogen sulfide). Naphthalene is another compound found in crude oil that has a low odor
threshold usually described as a “mothball” odor. Volatile organic compounds (VOCs) also
known as “aromatics” can have a “sweet” or “chemical” smell or a “gas station” odor.
Hydrogen sulfide is the primary odor associated with oil and gas production and is the one with
the lowest odor threshold. The hydrogen sulfide (H2S) odor threshold (i.e., the lowest
concentration perceivable by human smell) is highly variable within the human population. It can
be detected by humans at concentrations as low as a half of a part per billion (0.5 ppb) by two
percent of the population. It is estimated that 50% of humans could detect the odor of H2S at 8
ppb, while over 90% could detect the odor at 50 ppb and virtually everyone could detect H2S at
200 ppb (Collins and Lewis, 2000).
The toxicological effects of H2S inhalation are well studied, and can vary dramatically from minor
effects (i.e., runny nose, eye and throat irritation) at lower concentrations to severe effects (i.e.,
respiratory paralysis, unconsciousness, and death) at much higher concentrations (see Section
5.2.3.3 for toxicological-based hazard indices from exposure to the proposed Project H2S
emissions). The toxicological effects of H2S begin at 2,000 ppb which may include nausea,
tearing of the eyes, headaches and bronchial constriction in some asthmatics. To account for
uncertainty in human variability, the minimal risk level for acute-duration inhalation health
concerns is listed as 700 ppb (ATSDR, 2006). This means most people can begin to smell H2S
well below the concentrations known to cause direct toxicological effects (MOE, 2007; WHO,
2003). To avoid odor annoyance, the WHO advises ambient concentration levels should not
exceed 5 ppb, with a 30 minute averaging time (WHO, 2000).
Distinguishing between nuisance odor and health symptoms related to odor exposure continues
to be a gray area.
Chemicals that have been implicated for eliciting adverse outcomes associated with odors
include hydrogen sulphide, ammonia, mercaptans, methyl sulphide, methyl disulphide, and
other reduced sulphur compounds as well as malodorous VOCs that can be emitted from
facilities such as waste treatment lagoons, solid waste landfills, land spreading operations, pulp
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and paper mills, petroleum refineries, smelters, confined animal feeding operations, tanneries
and rendering facilities.
Recent epidemiological studies have shown that people living in communities neighboring
facilities that emit unpleasant or annoying odors on a regular or continuous basis often
experience higher than normal incidences of physical symptoms, including sensations of
irritation, respiratory problems, gastrointestinal problems, sleep disturbances, headaches, and
hypertension, as well as psychological/behavioral symptoms such as irritability, tension,
nervousness, anger, frustration, embarrassment, depression, fatigue, confusion and negative
moods. The presence of such odors also has been reported to interfere with people’s daily
activities, use of property, social interactions, and quality of life as well as contributing to fears
and anxiety over chronic diseases and property values (Heaney et al., 2011; Horton et al., 2009;
Schinasi et al., 2011; Wing et al., 2008, 2013). Adverse outcomes are most prevalent when the
odors occur in an episodic and unpredictable manner, contributing to a sense of helplessness
and lack of control that fosters feelings of frustration, anger and/or anxiety.
The nature and extent of the adverse outcomes reported in these studies should be interpreted
with some caution since oftentimes the people recruited for the investigations were involved in
citizen action groups or were participants in class-action lawsuits, introducing the possibility of
selection bias. In addition, the communities surveyed were often of low or very low socio-
economic status, introducing determinants apart from odors (e.g., living conditions, education
level, diet, access to medical care) that are associated with health and well-being and;
therefore, may have confounded the results.
Given the fact that the odor threshold for sulfur compounds is so much lower than the level that
could cause direct toxicological effects, it is likely that the explanation for health symptoms
involves odor-related mechanisms. An investigation into the apparent health impacts of odors
on communities concluded that there may be a number of explanations, including: the
exacerbation of an underlying medical condition, innate odor aversion, aversive conditioning,
pre-existing psychological conditions (e.g., hypochondriasis or somatization disorder), among
others (Schusterman, 1992).
5.2.4.2 Current Conditions
The neighborhood around the proposed Project Site (the present City Yard) is mixed use
residential, commercial, and light industrial with minimal existing odor sources. There are no
known industrial or natural (i.e., geothermal) sources of H2S currently in the City.
As described in Section 5.2.4.1, the most commonly reported symptoms from odor exposure
are headaches, nasal congestion, eye, nose, and throat irritation, hoarseness, sore throat,
cough, chest tightness, shortness of breath, wheezing, heart tremors (palpitations), nausea,
drowsiness, and depression (ATSDR, 2014). The current frequency at which Hermosa Beach
residents experience the listed symptoms is unknown.
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5.2.4.3 Project Impact
According to the EIR, emissions during oil production operations (including testing, drilling and
production phases) have the potential to create odors in the neighborhood adjacent to the
Project Site. Odor emission sources associated with operational activities include onsite
microturbines used to generate onsite electricity, routine and emergency flaring events, and
volatile fugitive emissions from valves, compressors, pumps and connections. Drilling muds that
contain hydrocarbons can surface and release hydrocarbon vapors (referred to as “mud off-
gassing”). Drilling muds may contain H2S, benzene and other volatile contaminants, which are
odiferous compounds. Upset conditions and leaking equipment components could also release
odors. Additionally, the compounds used to odorize natural gas (often mercaptans) also contain
sulfur compounds and, similar to H2S, have very low odor thresholds.
The occurrence of six or more odor complaints associated with the proposed Project facility was
the threshold for determining a significant odor impact in the EIR. As reported in the EIR, odors
from both normal operations as well as odors associated with accidental releases are
considered potentially significant impacts without mitigation. Mitigation measures, as detailed in
Section 4.2.4.4 of the EIR and summarized below, require the Applicant to:
Flare gases encountered during drilling;
Collect or flare vapors from seal leaks;
Develop and implement an Odor Minimization Plan which gives the City the authority to
enforce contingency measures to eliminate nuisance odors;
Monitor hydrogen sulfide and hydrocarbon vapors with automatic alarms that will be
triggered at 5 and 10 ppm H2S;
Use odor suppressant or carbon capture canisters when odors cannot be controlled by
others means; and,
Utilize leak detection and reporting to minimize leaking components.
Mitigation would likely reduce the frequency of odor releases. However, odor impacts reported
in the EIR remain significant and unavoidable because the close proximity of residences,
businesses, and public areas to the Project Site means small releases could generate odor
complaints. Odors would be limited to the immediate vicinity of the Site and would not be
expected to occur beyond 500-1,000 feet except for during an accident scenario (MRS, 2014).
The release of offensive smelling odors introduces the possibility that certain individuals might
experience health effects unrelated to the toxicity of the chemicals contained in emissions, but
associated with the unpleasant odors themselves. As described in Section 5.2.4.1, studies have
indicated the presence of unpleasant odors can contribute to a number of physical and
psychological/behavioral symptoms, possibly related to the nuisance caused by the odors,
especially if the annoyance escalates to feelings of frustration and aggravation. Adverse health
outcomes from odors are commonly associated with facilities known for having higher and more
continuous/frequent emissions of odorous compounds, such as pulp and paper-mills, confined
animal feeding operations and solid waste landfills.
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The impact of project-related odors on the health of the community is provided in Table 5-15.
Table 5-15 Air Quality Assessment: Odors
Health Determinant Odors
Potential Health Outcome Acute health symptoms from odorous compounds in crude oil
Pre-Mitigation Discussion Negative health outcomes may occur during all phases
EIR Mitigation AQ-3b to reduce off-gassing of vapors from drilling muds and
AQ-5a through AQ-5f for operational odor controls including an
Odor Minimization Plan
Geographic Extent Localized
Vulnerable Populations Odor sensitive individuals
Magnitude Medium
Adaptability Low
Likelihood Possible
Post-Mitigation Health Effect Negative
Comments or Additional
Recommended Measures
Periodic discomfort and annoyance from odor releases is
likely. If frequent reports of odor occur, additional study and/or
periodic monitoring of odor may be warranted.
As described in Table 5-15, without mitigation, the health outcome from project related odors
would be negative because odor releases could occur with sufficient frequency to result in
adverse health outcomes among community members. The extensive mitigation measures
proposed in the EIR will likely reduce number of odor releases, although, detectable offsite odor
concentrations could still occur during small upset releases. Odors would be limited to the
immediate vicinity of the Site (500 to 1,000 feet) so the geographic extent is expected to be
‘localized’ (except in the event of an accident). The vulnerable population identified for odor
impacts are ‘odor sensitive individuals’. The post-mitigation magnitude of an adverse health
impact from odor is ‘medium’ because odors will be detectable, and pose a minor to moderate
hazard to health. Adaptability is considered to be ‘low’ since people may not be able to adapt to
the odor releases while maintaining pre-project level of health. Health symptoms related to odor
could occur in sensitive individuals; therefore, likelihood of health impact is considered
‘possible’. Periodic discomfort and annoyance from odor releases is likely. Based on the fact
that odor releases cannot be completely mitigated and adverse health outcomes could occur,
the potential odor-related health impact associated with the Project is classified as ‘negative’
among community members in the immediate vicinity of the Site. Although not anticipated, in
the case that reports of odor become frequent, additional studies and/or air monitoring of odor
may be warranted.
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5.2.5 Summary and Conclusions of Air Quality
The potential for air emissions from construction and operation of the proposed Project to affect
air quality in Hermosa Beach was evaluated using the emissions inventory produced as part of
the EIR. Emissions associated with the Project and modeled in the EIR include criteria
pollutants (e.g., carbon monoxide, nitrogen dioxide, sulfur dioxide and particulate matter),
volatile organic compounds (VOCs) and other toxic air contaminants (e.g., polycyclic aromatic
hydrocarbons (PAHs) and metals), and odorous / toxic compounds (e.g., hydrogen sulfide or
H2S). Carbon monoxide (CO) and sulfur dioxide (SO2) were not carried forward in the HIA as
the calculated emission estimates for these criteria pollutants were determined to be below the
South Coast Air Quality Management District (SCAQMD) regional and local thresholds.
Nitrogen dioxide (NO2) has the potential to
produce a range of respiratory effects depending
on the concentration in air (e.g., eye, nose and
throat irritation, inflammation of lung tissue). For
the assessment, the maximum 1-hour and
maximum annual average NO2 air
concentrations were calculated (background plus
Project) and found to be below the WHO air
quality health guidelines, indicating that adverse
health effects are not expected to result from
either short-term or long-term exposure.
Additionally, there were no exceedances of
California’s Ambient Air Quality Standards
(AAQS), or the US EPA National Ambient Air
Quality Standards (NAAQS) for NO2. Therefore,
it was concluded that exposure to NO2 from the
proposed Project (with mitigation) is expected to
have ‘no substantial effect’ and no additional recommendations were required.
Particulate matter (PM) is a widespread air pollutant composed of a mixture of solid and liquid
particles, and its effects on health are well documented. Particles with a diameter of 10
micrometers or smaller are referred to as PM10, and particles with a diameter of 2.5 micrometers
or smaller are known as PM2.5. PM exposure, particularly to the smaller PM2.5 particles, is
associated with increased respiratory and cardiovascular disease and mortality. The maximum
1-hour and maximum annual average PM2.5 air concentrations were added to the baseline
concentration for LA County and resulted in exceedances of the WHO air quality guidelines.
However, when background levels from South Coastal Los Angeles County (assumed to better
represent Hermosa Beach air quality) were used, the Project was below the California annual
AAQS or US EPA NAAQS. The assessment concluded that any exceedances of the WHO air
quality guidelines are based on existing background levels in the area and the Project is not
expected to have a material impact on existing PM2.5 related health risks. While there is no
substantial effect from post-mitigation exposure to PM2.5 from the proposed Project, existing
The air quality assessment within
the HIA concludes that with
implementation of the proposed EIR
mitigation measures there is no
substantial effect on human health
with respect to air emissions (NO2,
PM and TAC). However, periodic
odor releases, identified in the EIR as
significant and unavoidable, were
characterized as negative near the
Project Site. Odor can have various
health consequences, and could
result in periodic discomfort and
annoyance near the Project Site.
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ambient levels of PM2.5 air concentrations in the area are in the range at which increased
mortality has been observed in large urban centers.
Toxic Air Contaminants (TAC) can be used to describe a wide array of chemicals, including
volatile organic compounds (VOCs), polycyclic aromatic hydrocarbons (PAHs), inorganic
elements (e.g., metals) and particulate emissions from diesel exhaust. Without mitigation
measures, Project emissions of certain TAC would pose a potential risk to human health;
however, with implementation of the measures proposed in the EIR, the proposed Project is
expected to have no substantial effect and no additional recommendations were required.
Odor can result from the release of compounds such as hydrogen sulfide (H2S). Sensitivity to
environmental odors varies greatly from person to person. The most commonly reported
symptoms from odor exposure are headaches, nasal congestion, eye, nose, and throat irritation,
hoarseness, sore throat, cough, chest tightness, and shortness of breath, among others.
According to the WHO, odor annoyance can also affect overall quality of life. Adverse health
outcomes associated with odor are related to the frequency, duration, concentration, and the
individuals’ level of sensitivity. Hydrogen sulfide is the primary odor associated with oil and gas
production and is the one with the lowest odor threshold. The H2S odor threshold (i.e., the
lowest concentration perceivable by human smell) is highly variable within the human
population. Although mitigation measures proposed in the EIR would reduce the frequency of
odor releases, they were still identified as ‘significant and unavoidable’ because of the close
proximity of residences and businesses to the Project. For these reasons, the post-mitigation
health effect is considered ‘negative’ near the Project Site and additional recommendations
have been provided (i.e., an odor study and/or periodic monitoring in the event of excessive
reports of odor).
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5.3 Water and Soil Quality
This section assesses the potential health impacts of two exposure pathways that could pose a
risk to residential, commercial and recreational community members:
1. Discharge of wastewater and surface water runoff during construction and operations;
and,
2. Deposition of windblown soil particulates to offsite surface soil.
5.3.1 Surface Water
5.3.1.1 Surface Water and Health
As rain water runs over impervious surfaces (paved areas where water cannot soak into soil), it
can pick up oil and grease residues, concrete washout water, heavy metals, and debris. During
heavy rain events the stormwater and runoff enters storm drains which outfall to the Pacific
Ocean. Untreated storm runoff can be a significant source of beach water pollution and people
who swim in water near storm drains may experience health effects.
An epidemiological study conducted in Santa Monica Bay examined the health effects of
swimming in ocean water contaminated by storm drain runoff (Haile et al., 1999). The study
included over 11,000 swimmers, categorized according to swimming location distance to a
storm drain (0, 1-50, 51-100, or 400 yards), who subsequently participated in a follow-up
interview 9 to 14 days after swimming to ascertain the occurrence of a number of symptoms
including fever, chills, eye discharge, earache, ear discharge, skin rash, infected cut, nausea,
vomiting, diarrhea, stomach pain, cough, runny nose, and sore throat. The findings revealed
that individuals who swim in areas adjacent to storm drains were approximately 50 percent
more likely to develop symptoms compared to those who swim 400+ yards away (Haile et al.,
1999). Increases in risks were greatest for fever, chills, ear discharge, coughing, gastrointestinal
illness, and significant respiratory disease. The authors concluded that there may be an
increased risk for a broad range of adverse health effects associated with swimming in ocean
water subject to urban runoff. However, increases in symptoms were also associated with high
levels of bacterial indicators and waters where human viruses were present. This suggests that
sources of exposure in urban runoff associated with adverse health outcomes are likely related
to pathogens (from human and animal waste) rather than chemical pollutants from industrial
processes.
If uncontrolled, Project-related chemicals (petroleum products) in polluted stormwater runoff
water could be harmful to the environment and human health. For people swimming or
recreating in the Pacific Ocean, contact with polluted stormwater runoff could result in acute
health symptoms such as eye and skin irritation. The effects of contact or ingestion of
contaminated water are much greater in vulnerable populations such as children, the elderly,
and those with compromised immune systems.
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5.3.1.2 Current Conditions
The City of Hermosa has two miles of beach within the larger Santa Monica Bay that stretches
north to Malibu and south to Palos Verdes Peninsula, and the proposed Project Site is located
less than half a mile from the beach. The entire Santa Monica Bay and its beaches are listed as
impaired under Section 303(d) of the Clean Water Act because the surface waters do not meet
federal water quality standards. The impairments are due to the human health risks associated
with consumption of DDT and PCB impacted aquatic life, and the recreational health risks due
to the presence of coliform bacteria (USEPA Region 9, 2012).
As described in the baseline health assessment (Appendix E), the presence of coliform bacteria
in the Santa Monica Bay is an indicator that water quality may not be sufficient to use waters for
recreation. To address the problem of bacteria in the water, the Los Angeles Regional Water
Quality Control Board established the Santa Monica Bay bacteria Total Maximum Daily Load
(TMDL) in 2003. The TMDL requires cities to improve water quality through compliance with
targets for bacteria in surface water. The City of Hermosa Beach’s stormwater pollution
prevention program is a multifaceted program designed to reduce runoff and ensure compliance
with the TMDL. Efforts of the Hermosa stormwater pollution prevention program include
infiltration projects, low flow diversion to sanitary sewer, and a grease control ordinance (SBSP,
2013).
Runoff from the proposed Project site generally flows to the west towards an inlet that
discharges to the Ocean at an outfall at the end of Herondo Street (MRS, 2014). The Herondo
storm drain collects runoff from more than 2,000 acres, of which less than 300 acres are within
the City of Hermosa Beach. To reduce impacts to water quality at the beach from non-
stormwater runoff (e.g., overwatering of lawns, irrigation overspray onto the sidewalk, etc.), low
flows are diverted from the storm drain to the sanitary sewer during dry weather to provide
treatment and prevent discharge of urban runoff from this large drainage system onto Hermosa
Beach (South Bay Stormwater Program, 2013).
5.3.1.3 Project Impact
If uncontrolled, construction activities to build the proposed oil and gas development facility and
the pipeline corridors could result in discharge of contaminants and debris into surface runoff.
During a rain event, contaminants and debris that enter the storm drain system could flow into
the nearby Santa Monica Bay, which is currently listed as an “impaired water body” for ‘contact’
recreation. Potential construction-related contaminants that could impact offsite surface water
include sanitary wastes, phosphorous, nitrogen, oil and grease residues, concrete washout
water, heavy metals, debris, and incidental releases of oil, oil-based mud, generator fuel, or
maintenance related hazardous materials (MRS, 2014). Swimming in close proximity to storm
drains is associated with a number of acute health symptoms including fever, chills, ear
discharge, coughing, gastrointestinal illness, and respiratory disease (Haile, 1999). Because the
Project Site falls within a drainage area that is over six times larger than the area of Hermosa
Beach, health effects to those swimming in ocean water after a rain event could be attributed to
various sources, and it would be difficult to determine a specific source of contamination. When
there is a significant rainfall (> 0.1 inch), the California Department of Public Health issues an
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advisory for beachgoers to avoid water contact for a period of 72 hours after the rainfall
(LACDPH, 2012). It is advisable that community members follow the recommendations when
public health advisories for beachgoers are issued.
During Phase 2 and 4 drilling operations, surface runoff at the Project site would be contained
with walls and berms and pumped into the water processing system for injection into the oil
reservoir; therefore, preventing negative impacts to surface water quality and potential health
outcomes during operations. However, during Phase 1 and 3 construction on the proposed
Project Site, pipeline construction, and implementation of the Remedial Action Plan to address
known contaminated soil beneath the current site, impacts are considered potentially significant
by the EIR (MRS, 2014). As a result, the EIR recommends the mitigation measures (HWQ 1-1a
to 1-1g) for the development of a Storm Water Pollution Prevention Plan (SWPP) to reduce
construction-related water quality impacts. The Applicant shall develop the SWPPP in
accordance with the State General Construction Permit and the Los Angeles Regional Water
Quality Control Board.
The impact of Project-related runoff to surface water on the health of the community is provided
in Table 5-16.
Table 5-16 Water and Soil Quality Assessment: Surface Water
Health Determinant Surface water
Potential Health Outcome Acute health symptoms
Pre-Mitigation Discussion Negative health outcomes may occur during Phases 1 and 3
EIR Mitigation Storm Water Pollution Prevention Plan (HWQ 1-1a to 1-1g)
Geographic Extent Localized
Vulnerable Populations Beach users
Magnitude Medium
Adaptability Medium
Likelihood Unlikely
Post-Mitigation Health Effect No substantial effect
Comments or Additional
Recommended Measures
None
Without mitigation, construction-related contaminants and debris flowing into storm drains
connected to the Pacific Ocean could result in impacts to water quality and increases in acute
health outcomes during Phases 1 and 3 of the proposed Project (Table 5-16). However, EIR
mitigation measures will reduce the possibility of construction-related impacts to the Pacific
Ocean through the requirement of a Storm Water Pollution Prevention Plan.
Based on findings in the literature, potential impacts on surface water (and associated acute
health symptoms) are limited to a ‘localized’ group of individuals who may be swimming in
closest proximity to the Herondo storm drain after a rain event. The vulnerable population
identified for surface water impacts are ‘beach users’. The magnitude is classified as ‘medium’
since the potential acute health outcomes would be detectable, reversible and pose a minor to
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moderate hazard to health. The adaptability is classified as ‘medium’ given that most people
can adapt to the change in their environment by avoiding swimming near the storm drain,
although others may be unaware of its location. The likelihood was defined as ‘unlikely’ since
Site runoff will be controlled throughout all phases of the proposed Project to prevent surface
water releases to the Ocean. Overall, the potential health impact associated with surface water
is classified as ‘no substantial effect’ due to the preventative measures which will be
implemented. Therefore, based on findings from the surface water assessment, no additional
measures are recommended.
5.3.2 Soil Particulates
5.3.2.1 Soil Particulates and Health
Windblown soil particulates may contain various chemicals of human health concern. Particulate
emissions during construction are produced when equipment moves on soil or unpaved
surfaces and during trenching, grading, and other earth-moving activities. People can then be
exposed to these particulates when they inhale, through incidental ingestion of dust, or in rare
cases, children may intentionally consume soil (a behavior called pica). Depending on the
naturally occurring and anthropogenic components of soil, particulates can present varying
degrees of human health risk.
5.3.2.2 Current Conditions
Soil data to characterize current conditions are not available for areas surrounding the Site,
such as the Ardmore/Valley Greenbelt area, residential yards, or other parks such as Clark
Field. The only information available on soil conditions exists for the current City Maintenance
Yard. Brycon completed a site investigation in 2012 that focused on characterizing the extent of
the contamination related to the former landfill, as well as possible impacts from current
maintenance yard activities. Soil sampling was conducted to characterize the extent of onsite
petroleum-related contaminants; including benzene, VOCs, and lead. The extent of shallow soil
sampling in the upper 2 feet was very limited during this investigation, however one soil sample
collected at 3-feet below ground was identified to have diesel-range hydrocarbons present at a
concentration of 3720 mg/kg, which is above the commercial human health screening levels of
2400 mg/kg (RWQCB, 2013). Concentrations of TPH motor oil, BTEX, and other VOCs were
not found above health-based screening levels. PAHs in soil (with the exception of naphthalene)
were not analyzed.
Metals were analyzed in 26 soil samples, and lead was identified as an onsite contaminant of
concern. The maximum lead concentration of 9,680 mg/kg was identified from a soil sample
collected from 15-feet below ground; this concentration is above both the residential and
commercial scenario soil screening levels of 80 mg/kg and 320 mg/kg, respectively, established
by the Office of Environmental Health Hazard Assessment (CalEPA, 2009). The ground surface
at the City Maintenance Yard is currently paved, which means there is presently no human
exposure pathway to any soil contamination related to the former landfill. However, lead and
other site-related contaminants have the potential to travel offsite during site preparation in
Phase 1 for the proposed Project if proper dust suppression is not employed.
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5.3.2.3 Project Impact
As described above, the onsite soil is currently impacted by former landfill activities and the
primary contaminant of concern in onsite soil is lead. The proposed Project describes that,
during Phase 3, the Remedial Action Plan (RAP) would be implemented to remove
contaminated soil up to a depth of 15 feet below ground within the former landfill area. However,
construction activities prior to Phase 3 could result soil emissions and exposure to people
offsite. For example, the Site will be graded to depths of 1 to 3 feet during Phase 1 of the
proposed Project. During this time, people could come into contact with windblown particles
from the exposed top 3 feet of soil.
On-site surface soil data is limited and the top 3 feet of soil is not currently well characterized
with respect to potential contamination. Therefore, additional surface soil data is important to
address in order to determine the potential health hazard posed by chemicals in soil prior to
Phase 3 RAP activities. The EIR required mitigation measure SR-2 addresses this data gap by
requiring the Applicant to sample soil during Phase I grading to ensure that Site soil lead
concentrations are below 9,500 mg/kg and that total petroleum hydrocarbons (TPH) are also
below regulatory thresholds. Soil contamination exceeding regulatory thresholds should be
removed from the Site. Removal of contaminated soil and implementation of the RAP will likely
occur during Phase 3 of the proposed Project but the mitigation measure (SR-2) states that
remediation could occur during Phase 1 if substantial contamination is encountered (MRS,
2014). The RAP will be implemented under the appropriate regulatory oversight agency.
Regardless of the extent of current soil contamination, the EIR mitigation measure AQ-1a
requires the Applicant to submit and implement a Fugitive Dust Control Plan that includes
SCAQMD mitigations for fugitive dust mitigation, including applying water on unpaved areas
during construction, tarping of trucks hauling dirt, limit on-site vehicle speeds, etc. Surface water
controls (berming the Site and measures discussed in Section 5.3.1.3) will also prevent the
runoff of soil particles offsite. The impact of Project-related soil particulates on the health of the
community is provided in Table 5-17.
Table 5-17 Water and Soil Quality Assessment: Soil Particulates
Health Determinant Soil Particulates
Potential Health Outcome Varying degrees of human health risk
Pre-Mitigation Discussion Depending on chemicals of concern in the soil, soil particulates
may pose a hazard off-site without mitigation
EIR Mitigation Fugitive Dust Control Plan (AQ-1a) and Soil Sampling (SR-2)
Geographic Extent Localized
Vulnerable Populations Children
Magnitude Unknown
Adaptability Unknown
Likelihood Unlikely
Post-Mitigation Health Effect No substantial effect
Comments or Additional
Recommended Measures
None
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As described above, without removal of contaminated soil and/or mitigation measures to reduce
fugitive dust emissions, soil particulate emissions during Project related activities could result in
human health hazards. These measures will reduce the possibility of impacts to community
health.
Potential inhalation or incidental ingestion of contaminated soil (and the associated health
hazards) is limited to a ‘localized’ group of individuals who may be within the immediate vicinity
of the proposed Project Site where dust emissions would potentially be present. The vulnerable
population identified for soil impacts are ‘children’. The magnitude and adaptability are
classified as ‘unknown’ because the severity of the health outcome depends on the
components and level of the contamination of the soil. The likelihood of soil-related health
impacts to the community was defined as ‘unlikely’ because preparation of the Site includes
implementation of a RAP to address current Site contamination which will happen under the
oversight of the appropriate regulatory agency. Overall, the potential health impact associated
with soil particulates is classified as ‘no substantial effect’ due to the preventative measures
which will be implemented. Therefore, based on findings from the soil assessment, no additional
measures are recommended.
5.3.3 Summary and Conclusions for Water and Soil Quality
If uncontrolled, Site-related chemicals in polluted stormwater runoff water could be detrimental
to the environment and human health. For people swimming or recreating in the Pacific Ocean,
contact will polluted stormwater runoff could
result in acute health symptoms such as eye
and skin irritation. Runoff from the proposed
Project site generally flows to the west towards
an inlet that discharges to the Ocean at an
outfall at the end of Herondo Street. During a
rain event, contaminants and debris that enter
the storm drain system could flow into the
nearby Santa Monica Bay, which is currently
listed as an “impaired water body” for ‘contact’
recreation. During Phase 2 and 4 drilling operations, surface runoff at the Project site would be
contained with walls and berms and pumped into the water processing system for injection into
the oil reservoir; therefore, preventing negative impacts to surface water quality and potential
health outcomes during operations. Without mitigation, construction-related contaminants and
debris flowing into storm drains connected to the Pacific Ocean could result in impacts to water
quality and increases in acute health outcomes during Phases 1 and 3 of the proposed Project.
However, EIR mitigation measures will reduce the possibility of construction-related impacts to
the Pacific Ocean through the requirement of a Storm Water Pollution Prevention Plan. Overall,
the potential health impact associated with surface water is classified as no substantial effect
because Site runoff will be controlled during all Project phases.
Soils under the current maintenance yard and potential Project Site have contamination related
to its former use as a landfill. While the Site is currently paved over and thus not posing any
The water and soil quality assessment
within the HIA concludes that with
implementation of the proposed EIR
mitigation measures, there is no
substantial effect on human health
with respect to surface water quality
and soil particulates.
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present hazard, Project-related construction activities will release particulate emissions when
equipment moves on soil or unpaved surfaces and during trenching, grading, and other earth-
moving activities. The primary contaminant of concern in onsite soil is lead; however, on-site
surface soil data is limited and the top 3 feet of soil is not currently well characterized with
respect to potential contamination. Therefore, additional surface soil data is important to
address in order to determine the potential health hazard posed by chemicals in soil prior to
Phase 3 RAP activities. The EIR required mitigation measure SR-2 addresses this data gap by
requiring the Applicant to sample soil during Phase I grading and remove soil contamination
exceeding regulatory thresholds from the Site as early as Phase 1 if substantial contamination is
present. Implementation of the RAP to remove contaminated soil and mitigation measures to
reduce fugitive dust emissions will reduce the possibility of hazardous soil particulate emissions
during Project- related activities and thus soil particulates do not pose a substantial effect to
human health.
5.4 Upset Scenarios
This section assesses the potential health impacts of two upset scenarios: an oil spill and a well
blowout. Due to the unique nature and rarity of such events occurring they were placed in a
separate health assessment category.
5.4.1 Oil Spill
5.4.1.1 Oil Spill and Health
An oil spill related to the proposed Project could have various health consequences. A major
pipeline accident in 2010 spilled 840,000 gallons of crude oil into the Kalamazoo River in
Michigan (MDCH, 2013). Community members surveyed immediately following two oil spill
events reported headaches, eye/skin irritation, respiratory conditions, anxiety, and depression
(UDOH, 2011; MDCH, 2013). Emergency response and cleanup efforts following pipeline oil
spills are effective in limiting the public’s exposure to crude oil contaminants. Human health risk
assessments of soil and surface water following cleanup of pipeline ruptures indicate that
residual chemical levels found in the environment are not expected to cause long-term harm to
public health. However, oil spill cleanup workers are known to experience a range of symptoms
due to direct contact with crude oil during emergency response activities.
Potential indirect health impacts of oil spills may include elevated levels of anxiety and
depression, resulting from either the perceived risk of a potential upset or from an actual spill
event. Psychological impacts of the Deepwater Horizon oil spill on Florida and Alabama
communities have been described, particularly among business owners who experienced
economic loss associated with community oil exposure (Grattan et al., 2011). As discussed in
Section 3.1, the fear of an accidental explosion or oil spill was the concern ranked highest
among the community. This indicates potential stress related to the fear of an environmentally
devastating oil spill.
People who might be in the area at the time of a spill would be unlikely to experience health
effects other than minor, transient sensory and/or non-sensory effects, including: discomfort,
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irritability, mild irritation of the eyes, nose and throat, cough, headache, lightheadedness,
vertigo, dizziness, and/or nausea. Odors could be apparent to some individuals, especially
sensitive individuals. The odors would be dominated by a hydrocarbon-like smell, with some
potential for other distinct odors due to the presence of sulfur-containing chemicals in the vapor
mix. The odors could contribute to added discomfort and irritability among those exposed.
Additionally, large oil spills can impact fish consumption advisories and local economies that
depend on fish and seafood commerce. Long-term effects of oil spills have not been well
studied; this gap in public health knowledge has been acknowledged by the scientific
community since the 2010 Deepwater Horizon oil spill occurred (Woodward, 2010) and is
currently being addressed by the Gulf Long-term Health Follow-up Study.
5.4.1.2 Current Conditions
Currently there are no oil and gas operations in the City of Hermosa or in the immediate vicinity.
Potential risks posed by the current city maintenance yard include small spills of oil, accidents
related to releases from vehicle gasoline tanks, or releases from the onsite propane tank (MRS,
2014). However, as no large quantities of materials are stored at the current city maintenance
yard, spill potential is minimal and unlikely to affect areas offsite.
5.4.1.3 Project Impact
Information from the EIR (Section 4.8) was reviewed to identify the probability and extent of a
crude oil spill related to Proposed Project activities. That information, as summarized below,
was considered in order to evaluate the potential human health impacts of an offsite spill that
reaches the beach and/or ocean.
A crude oil spill could occur either on the Project Site, from the crude oil pipeline, or from trucks
transporting oil during Phase 2 (through parts of Hermosa Beach, Manhattan Beach, Redondo
Beach, and Torrance) (MRS, 2014) A spill from equipment on the Project Site is unlikely to
impact the community because the Site will be completely contained. While pipelines are
generally regarded as a safe way to transport oil, pipeline accidents can occur. The pipeline for
transporting crude oil offsite could leak or rupture and depending on the location along the
pipeline length, the volume of oil in the pipeline, and the draining potential (the elevation of the
rupture in relation to elevation of Project Site), the oil spill could enter storm drains that flow to
the ocean outfall on the beach (MRS, 2014). The EIR estimated a worst case spill volume of
about 16,000 gallons from a pipeline rupture at Herondo and Valley Drive, which could enter the
storm drain and impact the ocean.
A spill from a truck, which has a capacity of about 6,700 gallons of oil, could also be directed
into the storm drain system. However, a spill entering a storm drain would require storm flows
during a rain event in order to actually reach the ocean. The EIR calculated that the probability
of any oil spill occurring during a 0.50 inch storm event in the Horondo Street area would be
0.07% over the life of the Project. In the case of a spill, the Oil Pipeline Environmental
Responsibility Act requires any pipeline corporation to immediately clean up all crude oil that
leaks or is discharged from a pipeline (Assembly Bill 1868). Therefore, in the event of a crude oil
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spill, cleanup efforts are required to ensure that oil is contained and does not remain in the
environment.
In the unlikely event that a spill does occur and migrate to the beach before containment, the
most likely health impact would be symptoms such as headaches and/or nausea from the
odiferous compounds of crude oil. Acute eye/skin irritation, respiratory conditions, anxiety, and
depression could also occur in people exposed to a crude oil spill; however, chronic health
consequences are not expected to result from a short-term exposure to oil. Additionally, an oil
spill may result in a fish and seafood advisory because the Santa Monica Bay is an important
site for recreational diving and fishing. Community members who fish are advised to always pay
attention and follow local fish advisories. Even if a spill never occurs, psychological stress
related to the fear of a catastrophic spill is also a potential health impact from the proposed
Project. The EIR provides mitigation measures that would minimize the risk and extent of an
offsite crude oil spill. The mitigation measures that relate to offsite spill mitigation include:
An Independent third-party audit should be completed and updated annually to ensure
compliance of the gas and crude oil pipelines with Fire Code, and other applicable codes
and emergency response plans requirements;
All crude-oil truck haulers and a sufficient number of onsite personnel (at least two per
shift) should be trained in HAZMAT spill response and each truck should carry a spill
response kit;
The installation of back-flow prevent devices would ensure that a rupture of the pipeline
along Valley Drive would produce a release with a short duration; and,
Warning tape should be installed above the pipelines within the pipeline trench to warn
third parties that pipelines are located below the tape.
The impact of a Project-related oil spill on the health of the community is provided in Table 5-18.
Table 5-18 Upset Scenario: Crude Oil Spill
Health Determinant Crude oil spill
Potential Health Outcome Acute health symptoms and psychological effects including
stress
Pre-Mitigation Discussion Without mitigation, extent of a potential spill could be greater
and more likely to result in a negative health impact. Although
highly unlikely, the possibility of a spill occurring is not possible
to mitigate completely.
EIR Mitigation An independent third party audit of equipment and additional
upset scenario risk reduction measures (SR-1a through SR-1g)
Geographic Extent Localized
Vulnerable Populations People in immediate vicinity
Magnitude Medium
Adaptability Medium
Likelihood Unlikely
Post-Mitigation Health Effect No substantial effect
Comments or Additional
Recommended Measures
Incorporate oil spill scenario into the City of Hermosa public
preparedness awareness program
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While mitigation measures reduce the risk and extent of an oil spill, it is not possible to
completely eliminate the possibility of an offsite oil spill occurring. In the event an offsite oil spill,
health impacts would be limited to a ‘localized’ group of individuals in contact with the spill
area. The vulnerable population is identified as ‘people in the immediate vicinity’ of spilled oil.
The magnitude is classified as ‘medium’ because an oil spill that reaches the beach/ocean
could result in acute health outcomes that are detectable, reversible, and pose a minor hazard
to health. The adaptability is classified as ‘medium’ because people suffering psychological
stress because of concern that a spill could occur or psychological impacts after a crude oil spill
may require support. The likelihood was defined as ‘unlikely’ since an oil spill into the ocean is
a very low probability event (0.07%). Overall, the HIA predicts ‘no substantial effect’ but in the
unlikely event that a spill was to occur it could negatively affect local or community health. To
that end, it is recommended that the City of Hermosa incorporate the possibility of an oil spill
into their current public preparedness awareness program. While the facility is required by
regulation to have emergency response plans in place, the preparation of an up-to-date
emergency preparedness plan for the community is the duty of the City of Hermosa Beach
Emergency Preparedness Advisory Board.
5.4.2 Well Blowout
5.4.2.1 Well Blowout and Health
As described in the EIR, well blowouts occur when drilling encounters an area of pressure that
exceeds the capacity of the drilling muds, and oil and gas flow back up the well to the surface
(MRS, 2014). The release of flammable material could, if it encounters an ignition source, either
explode or burn. People located nearby during such an event could suffer serious health
consequences. For example, direct health impacts can include fatalities and injuries that would
require hospitalization, as well as neurological conditions linked to acute exposure. Injury from a
well blowout could range in severity and type, including burns from contact with fire or physical
injury due to getting struck by equipment parts that come loose and hit someone because of
high pressures. In most documented instances of well blowouts, such as the Deepwater Horizon
blowout explosion, workers face the greatest risk of death or injury as they are the closest in
proximity to the situation.
Additionally, as in the case of an oil spill, potential indirect health impacts of a well blowout may
include elevated levels of anxiety and depression, resulting from either the perceived risk or
from an actual upset event. As discussed in Section 3.1, the fear of an accidental explosion was
the concern ranked highest among the community. This indicates psychological stress related to
the fear of a fatal explosion is also a potential health impact from the proposed Project.
5.4.2.2 Current Conditions
Currently, there are no oil and gas operations in the City of Hermosa or in the immediate
vicinity. The storage and use of propane at the maintenance yard introduces some small risk of
fire to the onsite area under current conditions.
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5.4.2.3 Project Impact
Information from the EIR (Section 4.8) was reviewed to identify the probability and extent of a
well blowout related to Proposed Project activities. That information, as summarized below, was
considered in order to evaluate the potential human health impacts of an upset event.
A well blowout accident, and the associated consequences such as fire and vapor clouds, could
potentially result in severe impacts to human health due to fatalities and/or injuries. The fear of a
blowout accident could result in moderate impacts to human health due to elevated levels of
distress over the possibility that a blowout could occur. As described in Section 4.8.4.4 of the
EIR, there is considerable uncertainty regarding whether pressure will be encountered in the
wells during drilling. It is possible that the oil reservoir is not pressurized, in which case a
blowout could not occur. If substantial pressures are encountered, then a pressurized release,
or blowout, could occur during drilling and soon after the well has been drilled. The risk of
fatality and/or injuries from a well blowout accident depends on a number of factors including
the volume of flammable materials, duration of release, meteorological conditions, and how
many people are exposed.
A frequency analysis conducted for the EIR estimated the rate of upset events during the
proposed Project. Assuming the reservoir is pressurized and blowouts could occur, the failure
rate for a wellhead rupture during drilling is one failure per 323 years. The failure rate for a
wellhead rupture during production is only one failure per 604,127 years (Table 4.8-12; MRS,
2014). In the unlikely event of a blowout, the EIR consequence analysis estimated that offsite
fatalities and injuries could occur as far away as 300 and 750 feet, respectively, from the Project
Site (Figure 4.8-5; MRS, 2014). Because the proposed Project Site is located within 100 feet of
businesses and 160 feet of residences, a well-blow out incident could result in fatalities and/or
injuries among the public. Considering together the frequency and consequence analyses, the
resulting risks exceed the EIR threshold for significance. Because the blowout scenario cannot
be mitigated to a level of insignificance, the EIR concludes that blowout risks during drilling
remain ‘significant and unavoidable’ (MRS, 2014).
The impact of a Project-related well blowout scenario on the health of the community is provided
in Table 5-19.
The EIR identifies mitigation measures which would reduce the risk of generating serious
injuries or fatalities to members of the public in the event of a well blowout. The Applicant’s
proposed project features and measures required by the Conditional Use Permit would also
reduce these risks. While mitigation measures reduce the risk of a well blowout resulting in
injuries or fatalities, it is not possible to completely eliminate the possibility that a catastrophic
event could occur or eliminate distress over the fear of a blowout occurring.
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Table 5-19 Upset Scenario – Well Blowout
Health Determinant Well blowout
Potential Health Outcome Injuries and/or fatalities and psychological effects including
stress
Pre-Mitigation Discussion Risk of well blowout during drilling is not possible to mitigate
completely, evaluation is the same with and without mitigation
EIR Mitigation An independent third party audit of equipment and additional
upset scenario risk reduction measures (SR-1a through SR-1g)
Geographic Extent Localized
Vulnerable Populations People in immediate vicinity (est. maximum of 750 feet from
the Site)1
Magnitude High
Adaptability Low
Likelihood Unlikely
Post-Mitigation Health Effect Negative
Comments or Additional
Recommended Measures
Incorporate well blowout scenario into the City of Hermosa
public preparedness awareness program
1Figures 4.8-5 and 4.8-6 of Final EIR provide estimated range and map, respectively (MRS, 2014)
In the event of a well blowout, health impacts would be limited to a ‘localized’ group of
individuals. For example, an explosion from a well blowout and the associated fragment, vapor
cloud, or fire impacts could extend to a maximum of about 750 feet from the Project Site. The
vulnerable population is identified as ‘people in the immediate vicinity’ of a well blowout. The
magnitude is classified as ‘high’ because a well blowout could result in serious injuries and/or
fatalities. The adaptability is classified as ‘low’ because people suffering from injuries or
psychological impacts after a catastrophic scenario may not be able to adapt or maintain pre-
project level of health. The likelihood was defined as ‘unlikely’ since a well blowout is a very low
probability event (once in 323 years during drilling and once in 604,127 years during non-drilling
periods– if at all). Overall, the HIA predicts ‘negative” effect, because there is no question that
in the unlikely event that an upset or accident was to occur it could negatively and severely
affect local or community health. To that end, it is recommended that the City of Hermosa
incorporate the possibility of a well blowout into their current public preparedness awareness
program. While the facility is required by regulation to have emergency response plans in place,
the preparation of an up-to-date emergency preparedness plan for the community is the duty of
the City of Hermosa Beach Emergency Preparedness Advisory Board.
5.4.3 Summary and Conclusions for Spill or Blowout Upsets
This HIA evaluated the health impacts of two upset scenarios, an offsite oil spill and a well
blowout. Potential human health impacts of exposure to an offsite oil spill include headaches,
eye/skin irritation, respiratory conditions, anxiety, and depression. In the unlikely event of a spill
(0.07% chance of an oil spill to the ocean), the Applicant would be required to contain and
clean-up any crude oil in the environment, thus irreversible or chronic health outcomes would
not be expected to occur and the HIA concludes ‘no substantial effect’ related to the oil spill
health determinant.
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A well blowout could result in serious injuries and/or fatalities among community members in the
vicinity of the proposed Project Site. A well blowout is a very low probability event, predicted to
occur once in 323 years during drilling
and once in 604,127 years during non-
drilling periods if the wells are
pressurized. The fear of a blowout
accident could result in moderate
impacts to human health due to
elevated levels of distress over the
possibility that a blowout could occur.
Because a well blowout could have
severe health consequences and the
possibility of an upset scenario
occurring cannot be completely
avoided through mitigation, the
blowout assessment concludes a
‘negative’ health effect. In addition to
emergency response plans prepared
by the Applicant, the City should consider incorporating the possibility of an oil spill or well
blowout into their current public preparedness awareness program.
5.5 Noise and Light
This section assesses the potential for noise and light emissions to have an impact on human
health from various Phases of the proposed Project. Although both noise and light are useful
components of everyday life, they are highly subjective emissions that can be perceived
differently by different individuals. For example, sounds that are considered pleasant or
tolerable to one person may be perceived as annoying or unwanted to another. Additionally,
keeping the lights on at night may prove useful or necessary to one person and be considered
ineffective or unacceptable to another. This poses a unique challenge when assessing these
variables. For this reason, objective health-based evidence has been used to evaluate potential
impacts of noise and light emissions on the surrounding community.
5.5.1 Noise Emissions
5.5.1.1 Noise and Health
Noise is typically used to describe any sound that is unwanted. The definition of an unwanted
sound is subjective since there is a high degree of variability among individual sound
preferences with different individuals having different perceptions and attitudes towards different
types of noise (WHO, 2009). This is often based on a combination of factors including personal
preferences, sensitivities, and attitudes, which can vary depending on the individual, group or
community (Pierrette et al., 2012). In Hermosa, the Community Dialogue quality of life
committee identified two types of sounds that are heard frequently in the neighborhood and do
not cause annoyance: wind chimes and foghorns. Not coincidentally, these two sounds are
representative of the beach lifestyle and local residents have become accustomed to these
In the oil spill assessment concludes there is
no substantial effect with implementation of
the proposed EIR mitigation measures. The
blowout assessment within the HIA concludes
that there is a low probability of occurrence,
but in the event such upset scenarios were to
occur, they could have significant negative
health implications. The HIA also found a
negative health effect of stress due to fear of a
blowout accident. The HIA recommends that
the City incorporate the possibility of an oil
spill or well blowout into its current
emergency preparedness plan.
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specific noises. This is an example of how attitudes and adaptability can influence noise
tolerance more than the underlying auditory physiology.
One of the major effects of exposure to environmental noise is annoyance. Noise-related
annoyance, typically described as a feeling of displeasure evoked by a noise, has been
extensively linked to a variety of common noise sources such as rail, road, and air traffic
(Berglund and Lindvall, 1995; Laszlo et al., 2012; WHO Europe, 2011). Although annoyance is
considered to be the least severe potential impact of community noise exposure (Babisch, 2002;
WHO Europe, 2011), it has been hypothesized that sufficiently high levels of noise-related
annoyance could lead to negative emotional responses (e.g., anger, disappointment,
depression, or anxiety) and psychosocial symptoms (e.g., tiredness, stomach discomfort and
stress) (Fields et al., 2001; 1997; Job, 1993; WHO Europe, 2011; Öhrström, 2004; Öhrström et
al., 2006). Therefore, regulations exist in many jurisdictions around the world to limit community
noise exposure from stationary sources (e.g., factories) as well as road, rail, and air traffic in
order to curtail community levels of annoyance and more severe impacts of community noise
exposure. It is important to emphasize that the existence of these guidelines has not eliminated
community noise annoyance and noise related annoyance remains prevalent in many areas.
Noise has become a ubiquitous part of modern society, with many people living in urban areas
that are infiltrated with some type of noise 24 hours per day (Lekaviciute and Sobotova, 2013).
To address the widespread issue of noise, especially at night, governments and health agencies
have put noise limits in place to protect public health. The World Health Organization (WHO,
2009) has published a document entitled “Night Noise Guidelines for Europe” that identifies the
potential health impacts of exposure to different levels of nighttime noise (Figure 5-1).
Children are especially vulnerable to the harmful effects of noise. This is particularly true in
learning environments as children’s ability to recognize speech under unfavorable noise
conditions is still developing through the teenage years. Short-term exposure to loud noise can
affect children’s short-term memory, reading, and writing ability. Long-term exposure to lower
levels of noise can affect cognitive performance of children including attention span,
concentration and memory, and discrimination between sounds (Klatte, 2013).
The document evaluates the scientific and epidemiologic data around potential effects of
nighttime noise. A small number of factors were found to have sufficient evidence of biological
effects and changes in sleep quality with specific sound levels. For example, at a sound
pressure level of 35 decibels (dB) changes in duration of various stages of sleep, in sleep
structure and fragmentation of sleep begin to occur. At sound levels of 42 dB, increased
movement while asleep and self-reported sleep disturbance begin to occur. There is also some
evidence of increased risk of hypertension when nighttime noise levels reach 50 dB (WHO,
2009). Based on the weight of evidence, WHO identifies an interim night noise guideline of 55
dB, acknowledging that in many areas (especially urban/commercial/industrial) lower limits are
not feasible. As an ideal target nighttime noise guideline the WHO recommends 40 dB. Stating
that: “the LOAEL [lowest observed adverse effect level] of night noise, 40 dB Lnight, outside,
can be considered a health-based limit value of the night noise guidelines necessary to protect
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the public, including most of the vulnerable groups such as children, the chronically ill and the
elderly, from the adverse health effects of night noise” (WHO, 2009).
Figure 5-1 Possible health implication of exposure to noise (WHO, 2009)
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The Centers for Disease Control and Prevention (CDC, 2013) has also set recommended
exposure levels for noise based on sensitive receptors (i.e., youth). The exposure levels are
classified as safe, potentially hazardous and hazardous. The typical exposures identified as
‘safe’ included typical library setting (40 dB for any duration), and normal conversational speech
(60 dB for any duration) and the sound of an electric pencil sharpener (71 dB for any duration).
Exposures identified as ‘potentially hazardous’ included a school cafeteria (85 dB for 8 hours)
and use of power tools (100 dB for 15 minutes). Finally, hazardous noise exposures included a
loud rock concert (110 dB for 1.5 minutes) and firecrackers or firearms (140-165 dB –
immediate hearing damage possible).
Overall, exposure to noise is partly based on objective components such as high sound
pressure levels (150 dB) having the ability to cause hearing loss, and subjective aspects related
to noise perception, annoyance and stress. Another important consideration when evaluating
potential impacts of noise is the timing and duration of exposure. Nighttime noise has been
found to be more annoying than the same sound pressure levels during the day (WHO, 2009).
Furthermore, the duration of exposure is an important consideration since higher levels of noise
can be tolerated for shorter time periods than lower noise levels (CDC, 2013). In order to
effectively evaluate potential impacts of noise emissions on health, the specific noise source
and exposure scenario must be critically evaluated.
5.5.1.2 Current Conditions
The existing noise conditions in the area around the proposed Project Site and along the
pipeline and truck routes were determined as part of the EIR. Noise monitoring was conducted
using unmanned data acquisition systems to continuously measure and log noise levels. The
specific locations selected for monitoring included areas in proximity to future potential noise
impacts from the proposed Project and areas with sensitive land uses (MRS, 2014).
According to the EIR, in order to capture the most relevant data and get an accurate noise
baseline for evaluation, monitoring was carried out on both weekdays (Monday-Friday) and
weekends (Saturday-Sunday) at six locations in the vicinity of the Project Site (6th St. and
Cypress, 634 Loma St., 730 Cypress St., 526 8th St., 600 6th St., Veterans Parkway). The
noise monitoring occurred on a continuous basis during August and September 2013, with a
break in measurements over the Labor Day holiday weekend to avoid gathering non-
representative data. The locations selected for long-term noise monitoring around the Project
Site are shown in Figure 5-2. The results of the noise monitoring include both daytime (8 am to
7 pm) and nighttime (7 pm to 8 am). The equivalent sound level (Leq) is the average noise level
over the period of time, reported in dBA that approximates human sensitivity to sound. Both the
lowest hourly Leq and the overall average Leq are provided for each of the selected locations
(Table 5-20).
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Figure 5-2 Noise Monitoring Locations around the Proposed Project Site (MRS, 2014)
Table 5-20 Summary of Existing Ambient Leq Noise around the Proposed Project Site
(MRS, 2014)
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Extensive noise monitoring was also conducted along the truck and pipeline routes during
August 2012. The data from the 2012 study has been used as the baseline for the noise impact
analysis for the truck and pipeline routes in the EIR (Table 5-21).
Table 5-21 Truck and Pipeline Route Ambient Noise Measurement Summary (MRS, 2014)
Since Hermosa Beach is a City that includes residential, commercial and light-industrial land
uses, and has a considerable amount of traffic, it is not surprising that their baseline noise levels
fluctuate between around 40 dBA (L50) and approximately 70 dBA (Leq) depending on the time
of day and day of the week (MRS, 2014). This suggests that Hermosa residents living in these
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areas are already accustomed to experiencing noise levels that are consistent with
suburban/urban and commercial areas. Typical noise levels in an urban outdoor environment
are approximately 65 dBA during the day and approximately 45 dBA during the night (MRS,
2014). Daytime Leq levels are within typical noise levels for outdoor urban environments;
however, nighttime Leq levels are slightly higher. Near the Project Site, the monitoring location
on 526 8th Street has the highest noise measurements for daytime or nighttime.
Baseline ambient monitoring data was also available for locations in proximity to several local
schools that are located in the vicinity of the proposed Project Site, proposed Maintenance Yard
or pipeline route. The ambient daytime noise levels (Leq) were monitored near the following
schools:
Our Lady of Guadalupe (Valley Drive – Hermosa Beach): 64.4 dBA;
Our Lady of Guadalupe (Anita Street – Hermosa Beach): 64.4 dBA;
Hermosa Valley School (Valley Drive – Hermosa Beach): 63.4 dBA;
Hermosa View Elementary (Valley Drive – Hermosa Beach): 63.3 dBA;
Towers Elementary (190th Street – Torrance): 61.5 dBA; and,
Magruder Middle School (190th Street – Torrance): 69.6 dBA.
Additionally, the locations monitored in the vicinity of the pipeline and truck routes and had
daytime noise levels ranging from approximately 57 to 77 dBA. Although the typical noise level
for daytime urban areas is around 65 dBA, it is possible that the presence of traffic may elevate
the average noise levels above this. For example, the noise associated with a large truck
passing by (50 feet away) can produce noise levels of 85 dBA (Figure 5-3).
Figure 5-3 Common Environmental Noise Levels (MRS, 2014)
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5.5.1.3 Project Impact
According to the EIR, there are potential noise impacts from the proposed Project, including the
development and ongoing operation of the oil drilling and production facility, the truck routes and
construction of oil and gas pipelines that would extend out from Hermosa Beach into the cities
of Redondo Beach and Torrance and the relocation of the City Yard (MRS, 2014).
Noise Guidelines:
The EIR stated that there are no quantitative noise standards in the City of Hermosa Beach
Municipal Code; however, the Code does include certain qualitative noise regulations and
restrictions on the allowable timing of noisy activity that are generally applicable to the Project
(MRS, 2014):
No person shall make, permit to be made or cause to suffer any noises, sounds or vibrations
that are so loud, prolonged and harsh as to be physically annoying to reasonable persons of
ordinary sensitivity and to cause or contribute to the unreasonable discomfort of any persons
within the vicinity. When considering whether a noise, sound or vibration is unreasonable,
the following factors shall be taken into consideration:
The volume and intensity of the noise;
Whether the noise is prolonged and continuous;
How the noise contrasts with the ambient noise level;
The proximity of the noise source to residential and commercial uses;
The time of day; and
The anticipated duration of the noise.
There are restrictions around the hours that construction activities are allowed to take place. All
construction activities must be conducted between the hours of 8:00 am and 6:00 pm, Monday
through Friday (except national holidays), and between 9:00 am and 5:00 pm on Saturday, and
are prohibited at all other hours and on Sunday and national holidays. Construction activities
include site preparation, demolition, grading, excavation, and the erection, improvement,
remodeling or repair of structures, including operation of equipment or machinery and the
delivery of materials associated with those activities (MRS, 2014).
Regarding noise from drilling or re-drilling activities associated with the proposed Project, there
are specific exterior noise level standards as per the Hermosa Beach Municipal Code (Oil Code)
(Table 5-22). Additionally, per the Oil Code, the only activity permitted between the hours of
7:00 pm and 8:00 am is ‘on-bottom’ drilling, with single joint connections.
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Table 5-22 Daytime and Nighttime Noise Level Standards (MRS, 2014)
For the purpose of the EIR, Project noise levels contributing a 3 to 5 dBA increase over the
baseline noise level were selected as significance criteria. These levels are derived from typical
human response to changes in noise level. As per the EIR, a change of 3 dBA is generally
acknowledged as the point at which most people would begin to perceive an increase or
decrease in noise level; a change of 5 dBA is considered to be the point at which most people
would perceive a significant increase or decrease in noise level. The lower value was selected
for residential locations with nighttime occupancy (nighttime usually produces the lowest hourly,
A-weighted equivalent noise level), whereas the higher value was used for areas that generally
do not have nighttime occupancy (MRS, 2014).
Since industry-related noise can often impact sensitive receptors, many mitigation methods are
available to reduce noise, including: walls, temporary and permanent acoustical barriers, engine
exhaust silencers, acoustical equipment enclosures, sound-absorbing blankets and panels, and
sound-dampening flooring and siding materials (MRS, 2014). Without mitigation, the project
would pose unacceptable health risk to residents due to high levels of noise occurring over a
prolonged period of time. The EIR mitigation measures proposed for each Phase of the Project
and their impact on noise emissions is discussed below.
Phase 1:
According to the EIR, the noisiest portion of the demolition stage is expected to be the removal
of concrete paving, fencing and walls, estimated to last up to 7 weeks. By a similar assessment,
the noisiest part of the construction work in Phase 1 has been determined to be the pumping of
concrete for the new well cellar; the noisiest stage of this construction work would occur when a
concrete truck and concrete pump are in use simultaneously, estimated to last up to 2 weeks.
Based on modelling of these two worst-case scenarios, additional measures (beyond the typical
noise-reduction design features) to mitigate noise emissions were necessary (MRS, 2014). The
mitigation measures generally include (NV-1a to NV-1c):
Increasing the height of the noise barrier on all sides of the Site to 24-feet (24-feet is the
maximum feasible height for a noise barrier during Phase 1);
Increasing the height of the gates on the east and south sides of the site (24-feet); and,
All acoustical barriers around the site will be subject to specific sound absorption
performance standards.
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According to the EIR, the noise modelling results show that even with implementation of these
additional mitigation measures, there is a ‘significant’ increase in local noise. The change in
local daytime noise from the demolition activities is expected to result in an increase of 2.5 dBA
to 10.3 dBA, and an increase of 1.3 dBA to 9.2 dBA from construction activities. The highest
overall noise levels that would occur as a result of demolition (66 dBA) and construction (65
dBA) are both well within normal daytime noise level for urban and commercial areas (MRS,
2014; Figure 5-3). It is important to note that noise levels decrease with distance and based on
the noise contour drawings provided in the EIR report (MRS, 2014), the noise decreases rapidly
as you move away from the Project Site. It is not anticipated that the construction activities from
the proposed Project will differ in any way from other construction Projects that regularly occur
in urban and suburban areas (Golmohammadi et al., 2013). Although it is likely that a subset of
the local population will be highly annoyed by the noise, it is relatively short-term in nature and
will only occur during the day.
Phase 2:
Phase 2 of the proposed Project is estimated to take 12 months. According to the EIR, the test
drilling and test production activities would occur simultaneously for approximately two months.
During this time, drilling and test production equipment would operate 24-hours per day. After
the overlap period, the test production activity only would continue for approximately seven
months, with equipment operating continuously 24-hours per day. The drilling would occur for
four months. Based on modelling of the worst-case noise scenarios, additional measures
(beyond the typical noise-reduction design features) to mitigate noise emissions were necessary
(MRS, 2014). The mitigation measures generally include (NV-2a to NV-2j; NV-3a to NV-3d):
Increasing the height of the noise barrier to 35 feet (maximum height allowed by zoning);
All acoustical barriers around the site will be subject to specific sound absorption
performance standards.
Installation of ‘pads’ in various locations to reduce metal-on-metal noise;
Provision of additional acoustical enclosures, acoustical shrouds, silencers;
Implement a “Super-Quiet Mode” of operation between the hours of 2AM and 5AM,
during which time drilling would essentially be suspended to minimize noise; and,
Provide acoustical treatment within the combustor fan housing and/or at the ventilation
openings, as necessary to limit the total sound power level to 86 dBA.
According to the EIR, implementation of the additional mitigation measures results in an
increase in noise that is not significant (<3 dBA). Additionally, the predicted drilling and test
production noise levels are below the limit of 45 dBA as per the Hermosa Beach Oil Code
(MRS, 2014). Given that the World Health Organization Nighttime Noise Interim Target is 55
dBA, the standard set by Hermosa Beach (45 dBA) is considered a sufficient nighttime noise
target (WHO, 2009). At these levels, there is the potential for sensitive individuals to experience
sleep disturbance and a subset of the population may become annoyed. However, any impact
on sleep quality is expected to be minimal since the background nighttime levels of noise (46.5
to 58.6 dBA, Leq) measured in the vicinity of the proposed Project Site are already above 45
dBA and to our knowledge, this is not currently an issue for Hermosa residents.
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Phase 3:
Site Construction
Construction activities at the Project Site during Phase 3 are scheduled to last for 14 months.
According to the EIR, the noisiest portion of the work is expected to occur during an eight-week
period when the construction of five steel tanks and installation of mechanical and electrical
equipment occurs simultaneously. This part of the site construction was modeled as
representing the worst-case noise scenario.
For the site construction in Phase 3, the same noise reduction measures as Phase 1 are
proposed. In addition, a 16-foot high permanent masonry wall is proposed around the perimeter
of the Site, with a temporary 16-foot high barrier wall in-place to ensure that no site construction
work is carried out in Phase 3 without a perimeter noise barrier being in place. Further,
temporary portable noise barriers (minimum of 8-feet high) will be positioned around the
concrete truck engine, welders and crane engine when these items are in use (MRS, 2014).
Based on modelling of the worst-case noise scenarios, additional measures (beyond the typical
noise-reduction design features) to mitigate noise emissions were necessary (MRS, 2014). The
mitigation measures generally include (NV-4a to NV-4c):
Increasing the height of the noise barrier on all sides of the site to 24-feet;
Increasing the height of the gates on the east and south sides of the site (25-feet); and,
All acoustical barriers around the site will be subject to specific sound absorption
performance standards.
According to the EIR, the noise modelling results show that even with implementation of these
additional mitigation measures, there is a ‘significant’ increase in local noise. The change in
local daytime noise from site construction activities is expected to result in an increase of 2.2
dBA to 11.9 dBA. The highest overall noise level that would occur as a result of construction
(66.5 dBA) is within normal daytime noise level for urban and commercial areas and would
decrease with increasing distance from the Site (MRS, 2014). As with Phase 1, it is not
anticipated that the construction activities from the proposed Project will differ in any way from
other construction Projects that regularly occur in urban and suburban areas (Golmohammadi et
al., 2013). Although it is likely that a subset of the local population will be highly annoyed by the
noise, it is relatively short-term in nature and will only occur during the day.
Pipeline Construction:
During this stage of Phase 3, new Pipelines would be constructed to move produced oil and gas
offsite. The pipelines would pass through the cities of Hermosa Beach, Redondo Beach and
Torrance. According to the EIR, construction of the Pipelines is scheduled to take 17 weeks,
with the time in front of any one location limited to approximately 1 week (MRS, 2014). The
Hermosa Beach portion of the pipeline construction would extend south from the Project Site
along Valley Drive to Herondo Street. The section of the Valley Drive work expected to cause
the most noise impact would occur between South Park and 2nd Street, which has been
selected as the worst-case scenario for noise modelling in the EIR. In order to reduce the
potential noise emissions from pipeline construction, the following design features were
proposed (MRS, 2014):
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Temporary noise reduction barriers, minimum 12-feet high, located on either side of the
pavers and trenchers in such a way as the block the line-of-sight between the equipment
and the nearest sensitive receiver. The barriers will be moved alongside the equipment
as the work progresses; and
Pipeline construction will be limited to daylight hours between 8:00am and 3:00pm,
Monday through Friday in the City of Hermosa Beach and 9:00am to 3:00pm Monday
through Friday in the cities of Redondo Beach and Torrance. There will be no pipeline
construction work on Saturdays, Sundays or holidays.
Although these design features will reduce the amount of noise emitted from pipeline
construction activities, they cannot reduce the noise below a level that will constitute a
‘significant’ increase that will be noticed by residents. Based on the results of the noise
modelling, the EIR stated:
“Due to the nature of the work, further options for mitigation of pipeline construction
noise (beyond the measures already proposed by the Applicant and included in the
noise model) are expected to be very limited - and it would therefore not be possible in
practice to reduce noise impact on nearby sensitive receivers to less than significant
levels at any portion of the Pipeline route” (MRS, 2014).
The noise emissions associated with pipeline construction are anticipated to produce a
noticeable increase in local outdoor noise. The noise in the immediate vicinity of the pipeline
construction will be from 18.8 dBA to 31.2 dBA above existing background levels. The average
daytime noise (Leq) can be expected to reach 80.5 dBA to 89.6 dBA depending on the location.
These levels are consistent with a noisy restaurant or a large truck (passing by at 50 ft), and
have the potential to lead to negative health effects if experienced for prolonged periods of time.
Since pipeline construction is transient and the construction activities will only remain in any one
area for approximately 1 week, the exposure is short-term in duration. Additionally, since the
pipeline construction is limited to daytime hours and will only occur during the weekdays, when
the majority of people are not in their homes, the potential for health impacts is drastically
diminished.
The majority of scientific literature has focused on the potential for noise to disrupt sleep, which
can lead to other health issues, rather than high level, short duration exposures to noise. Since
all construction activities are restricted from 3:00 pm to 8:00 am, potential health issues
associated with nighttime noise are not relevant. A study conducted by Golmohammadi et al.
(2013) looked at community noise annoyance due to construction worksites. They examined
noise levels around 20 construction sites and evaluated self-reported annoyance levels of
nearby residents. The noise measurements collected at all 20 construction sites show that the
sound pressure levels ranged from 60.2 dBA to 92 dBA (mean = 74.57 ± 7.12 dBA), which is
within the range of noise levels (max = 89.6 dBA) anticipated for Phase 3 pipeline construction
(Figure 5-4).
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Figure 5-4 Noise Levels Measured at 20 Construction Sites (Mean ± SD) (Golmohammadi
et al., 2013)
The study found that the majority of residents interviewed (note the study was not blinded)
reported being annoyed by noise from nearby construction activities. The main complaints were
sleep disturbance, disrupting concentration and relaxation, interfering with leisure activities (e.g.,
reading, watching television), and making communication more difficult. Sleep disturbance is not
an issue for pipeline construction associated with the proposed Project since these activities are
only permitted to occur during the day (8:00 am to 3:00 pm in Hermosa Beach and 9:00 am to
3:00 pm Redondo Beach and Torrance). Therefore, due to the short-term nature of the
construction activities (1 week), time of day (8:00 am to 3:00 pm), and the fact that high levels of
annoyance (and possibly stress) are the main issues, additional recommendations are not
necessary. Therefore, to address the unavoidable increases in annoyance related to impacts on
everyday tasks and leisure activities, it is recommended that written notification of the
impending work be distributed to local residents. The notification should give all residents living
in the vicinity of the pipeline construction activities fair warning that the activities are to occur at
specific dates and times, and that higher than normal levels of noise may be experienced
despite precautions to minimize noise emissions.
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Phase 4:
Phase 4 includes drilling and production activities on the Site, which would overlap. In the EIR,
the noise analysis assessed noise levels during drilling and production and during production
only (no drilling). A total of 27 oil and gas wells and three water disposal/injection wells are
proposed over a 30-month period, with drilling equipment operating 24-hours a day during this
time. The drilling equipment that will be used is the same as that in Phase 2 and all of the Phase
2 noise reduction measures would also be applied in this phase, including the 32-foot high
sound attenuation barrier. Once the drilling stage is complete, the 32-foot high noise barrier
would be removed (leaving only the 16-foot high masonry wall constructed in Phase 3) and
production activity would continue 24-hours a day for the remainder of the life of the Project.
During re-drills, the 32-foot wall would be installed during the re-drill period (MRS, 2014).
According to the EIR, based on modelling of the worst-case noise scenarios associated with
development, operations and long-term production in Phase 4, additional measures (beyond the
typical noise-reduction design features) to mitigate noise emissions were necessary (MRS,
2014). The mitigation measures generally include (NV-6a to NV-6h; NV-7a to NV-7c):
Increasing the height of the noise barrier to 35 feet (maximum height allowed by zoning);
All acoustical barriers around the site will be subject to specific sound absorption
performance standards.
Installation of ‘pads’ in various locations to reduce metal-on-metal noise;
Provision of additional acoustical enclosures, acoustical shrouds, silencers;
Implement a “Super-Quiet Mode” of operation between the hours of 2AM and 5AM,
during which time drilling would essentially be suspended to minimize noise;
Provide enhanced inlet and outlet silencers for the Hydraulic Power Unit enclosure and
upgrade the walls, roof and floor of the enclosure as necessary to limit the total sound
power level radiated by the enclosure to 77 dBA;
Increasing the height of the masonry walls on the north and west sides of the site to a
minimum of 27-feet;
Apply outdoor acoustical panels to all available surfaces of the north and west walls
that face the production operations above a height of 10-feet above the ground; and
Well workover rigs shall be powered by electric drive/sources or the use of “ultraquiet”
generators or engines that are capable of operating below the noise significance
thresholds for daytime operation.
According to the EIR, implementation of the additional mitigation measures results in acceptable
noise levels (<3 dBA). The noise from production activities at the site are expected to result in
increase of 0.2 to 2.8 dBA above existing background levels. With mitigation measures in place,
the highest noise level is associated with long-term production activities but remains well below
applicable noise thresholds (38.7 dBA), including for periodic re-drilling. Additionally, the
predicted drilling and production noise levels are below the limit of 45 dBA as per the Hermosa
Beach Oil Code (MRS, 2014).
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Truck Traffic Noise:
Due to Project operations, it is expected that there will be an increase in truck traffic, which
could lead to elevated traffic noise levels in the community. As discussed in the EIR, it is
conventional to assess the noise impact of changes in traffic flow noise in terms of a 24-hour
noise average such as Community Noise Equivalent Level (CNEL) or day-night equivalent noise
level (Ldn). CNEL is marginally more stringent than Ldn, because it includes a 5 dB penalty for
the evening hours (which Ldn does not) and was selected as the default metric for assessing
traffic noise impact associated with the Project. A 3 dB increase in the CNEL was selected as
the threshold of significance because it is generally acknowledged as the point at which most
people would begin to perceive an increase or decrease in noise level (MRS, 2014).
The noise impact of additional traffic generated by the Project will be most pronounced on
Valley Drive between Pier Avenue and 6th Street and between 6th and Herondo Streets. Traffic
noise CNEL values for Valley Drive were calculated as part of the EIR at the closest residential
properties to Valley Drive using a traffic noise model, and including present day and future traffic
volumes with as well as the estimated additional trips associated with each of the four phases of
the Project. The predicted increase in CNEL as a result if vehicle traffic on Valley Drive is
modeled to range from 0 to 0.1 dBA, which is below the significance level of 3 dBA and would
not produce a perceptible change to the human ear. Therefore, a potential increase in noise
from truck traffic is not considered a health concern by the HIA Team.
Noise at Local Schools:
The proposed Project activities including Site development and operations, relocation of the
maintenance yard and pipeline construction have the potential to produce noise emissions that
could impact local schools. Therefore, noise modeling was conducted at several school sites in
Hermosa Beach, Redondo Beach and Torrance (SRA, 2014) to evaluate the potential project-
related noise contribution from the Site and maintenance yard relocation (Table 5-23) as well as
the pipeline (Table 5-24).
Table 5-23 Predicted Daytime Noise (dBA) around Local Schools from Project Site and
Maintenance Yard Relocation Activities (SRA, 2014)
Phase Hermosa Valley
School
Hermosa View
Elementary
Our Lady of
Guadalupe
PROJECT SITE
Phase 1 Demolition 25.7 25.5 23.4
Phase 1 Construction 21.8 23.2 19.6
Phase 2 Drilling + Production 8.9 6.0 5.2
Phase 2 Test Production Only 7.1 2.2 1.4
Phase 3 Construction 27.2 24.9 24.8
Phase 4 Drilling + Production 7.1 5.8 5.9
Phase 4 Production Only 4.0 3.7 2.7
MAINTENANCE YARD RELOCATION
Permanent Facility Demolition 29.1 24.2 17.6
Permanent Facility Construction 33.5 29.0 26.1
Permanent Facility Operation 12.5 9.0 0.0
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Table 5-24 Predicted Daytime Noise around Local Schools from Pipeline Construction
Activities (SRA, 2014)
Pipeline
Segment
Closest Schools City Predicted Daytime
Noise Levels (dBA)
Valley Drive Our Lady of Guadalupe Hermosa Beach 27.5
Hermosa Valley School Hermosa Beach 31.7
Hermosa View Elementary Hermosa Beach 32.8
Jefferson Elementary Redondo Beach 23.4
Anita Street Our Lady of Guadalupe Hermosa Beach 53.4
Jefferson Elementary Redondo Beach 53.4
Beryl Heights Elementary Redondo Beach 50.2
190th Street Jefferson Elementary Hermosa Beach 53.4
Towers Elementary Torrance 54.5
Valor Christian Academy Redondo Beach 53.4
Washington Elementary Redondo Beach 45.8
Adams Middle School Redondo Beach 42.3
Bert Lynn Middle School Torrance 42.3
Beach Cities Child
Development Centre
Redondo Beach 50.9
Magruder Middle School Torrance 52.8
Edison Elementary Torrance 47.8
North High School Torrance 47.8
Edison Corridor Bert Lynn Middle School Torrance 44.2
West High School Torrance 40.4
Overall, the predicted daytime noise levels from mitigated project activities are within or below
levels expected in urban areas during the day. The predicted daytime noise levels for schools
located in the general vicinity of the proposed Project Site ranges from 2.2 dBA to 25.7 dBA.
The highest predicted noise level is from Phase 1 demolition (Hermosa Valley School), which is
still well-below a level that would pose a potential health concern. Pipeline construction would
result is noise levels ranging from 23.4 dBA (Jefferson Elementary) to 54.5 dBA (Towers
Elementary). Although pipeline construction is expected to be short-term in duration
(approximately 1 week at any one location), it will occur during daytime hours when school is in
session. Therefore, the recommendation to provide written notification of pipeline construction
activities is also extended to local schools.
The impact of a change in noise emissions due to the proposed Project on the health of the
community are provided in Table 5-25. The impact of noise emissions on the local community,
particularly residents located around the Project Site and along the pipeline and truck routes is
negative without the use of mitigation measures. The EIR has identified a variety of mitigation
techniques to reduce the potential impact of noise from the proposed Project on the surrounding
community.
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Table 5-25 Noise and Light Assessment: Noise Emissions
Health Determinant Noise Emissions
Potential Health Outcome Annoyance, stress, sleep disturbance and hypertension, and
cognitive impairment at very high sound pressure levels
Pre-Mitigation Discussion Negative health outcomes associated with elevated levels of
noise may result from all Phases of the proposed Project with
no mitigation measures in place
EIR Mitigation Noise mitigation measures:
Phase 1: NV-1a to NV-1c
Phase 2: NV-2a to NV-2j; NV-3a to NV-3d
Phase 3a (site construction): NV-4a to NV-4c
Phase 3b (pipeline construction): None
Phase 4: NV-6a to NV-6h; NV-7a to NV-7c
Geographic Extent Phase 1-4: Localized (Project Site and truck/pipeline routes)
Vulnerable Populations Residents and schoolchildren in proximity to pipeline route
Magnitude Phase 1: Low
Phase 2: Low
Phase 3a (site construction): Low
Phase 3b (pipeline construction): Medium
Phase 4: Low
Adaptability Phase 1: High
Phase 2: High
Phase 3a (site construction): High
Phase 3b (pipeline construction): Medium
Phase 4: High
Likelihood Phase 1: Possible
Phase 2: Possible
Phase 3a (site construction): Possible
Phase 3b (pipeline construction): Probable
Phase 4: Possible
Post-Mitigation Health Effect Phase 1: No substantial effect
Phase 2: No substantial effect
Phase 3a (site construction): No substantial effect
Phase 3b (pipeline construction): Negative
Phase 4: No substantial effect
Comments or Additional
Recommended Measures
In anticipation of potential elevated noise levels from pipeline
construction activities (Phase 3b) it is recommended that local
residents and local schools be provided with written notification
of impending work including the dates and times of activities
that may produce excessive noise.
The geographic extent of noise emissions from all Phases of the proposed Project is ‘localized’
since any potential noise impacts will occur within the vicinity of the Project Site or along
pipeline or truck routes. The vulnerable populations identified for noise emissions are ‘residents
and schoolchildren in proximity to pipeline route’. Additionally, since it is well established
that noise decreases with increasing distance from the source, noise emissions will likely be
limited to the areas adjacent to Project-related activities. The post-mitigation magnitude of
noise-related health effects s for Phase 1,2, 3a (site construction) and 4 are ‘low’ since noise
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levels are below the limit of 45 dBA established by the Hermosa Beach Oil Code or they are
within typical noise levels experienced in urban/commercial areas. The post-mitigation
magnitude of noise-related health effects for Phase 3b (pipeline construction) is considered
‘medium’ since the impact is detectable, it is reversible, and poses a minor to moderate hazard
to health. Although noise levels will be moderately high, construction is limited to daytime hours
(Monday-Friday 8:00 am to 6:00 pm) and is short-term (approx. one week). This would limit the
potential for serious health implications.
Adaptability to post-mitigation activities in Phase 1, 2, 3a (site construction) and 4 is considered
to be ‘high’ since noise levels are within typical levels for urban/commercial land use and
people will be able to adapt to the change and maintain pre-project level of health. Adaptability
for Phase 3b (pipeline construction) is considered to be ‘medium’ since the noise emissions will
be higher than in the other Phases (albeit short in duration) and people will be able to adapt to
the change with some difficulty and will maintain pre-project level of health, although some
support may be necessary. The likelihood of noise emissions from Phase 1, 2, 3a (site
construction) and 4 is ‘possible’ since noise emissions from these Phases have the potential to
occur on a regular basis; however, the change may not be perceptible and is not expected to
influence health status. The likelihood of noise emissions from Phase 3b (pipeline construction)
is ‘probable’ since it has been demonstrated that high level of noise will occur during pipeline
construction and residents in the immediate vicinity will likely experience annoyance and
increased stress during this time. Overall, there is considered to be ‘no substantial effect’ for
Phase 1, 2, 3a (site construction) and 4 on the health of the community as a result of noise
emissions from the proposed Project. However, there is a potential for ‘negative’ impacts
(annoyance and stress) from the short-term high-level noise emissions associated with pipeline
construction activities in Phase 3b. Therefore, for Phase 3b (pipeline construction), it is
recommended that local residents and local schools be provided with written notification of the
impending work that identifies the potential for excess noise and outlines the location and
duration (expected to be short-term: 1 week) of the impacts.
5.5.2 Light Emissions
5.5.2.1 Light and Health
Light can be emitted from both natural and human sources and increase productivity, visibility
and safety. Conversely, unwanted sources of light have collectively been identified as light
pollution and artificially illuminate the night sky. With respect to light pollution, Chepesiuk (2009)
states that:
“Light pollution comes in many forms, including sky glow, light trespass, glare, and
overillumination. Sky glow is the bright halo that appears over urban areas at night, a
product of light being scattered by water droplets or particles in the air. Light trespass
occurs when unwanted artificial light from, for instance, a floodlight or streetlight spills
onto an adjacent property, lighting an area that would otherwise be dark. Glare is
created by light that shines horizontally. Over illumination refers to the use of artificial
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light well beyond what is required for a specific activity, such as keeping the lights on all
night in an empty office building.”
Many commercial and industrial developments require the use of artificial lighting for safety and
operation. Since these types of developments are often placed in proximity to residences, the
potential impacts of additional light sources (positive and negative) are an important
consideration.
The invention and widespread use of artificial light, especially at night, has become a necessity
in many areas of the world to enhance commerce, promote social activity, and increase public
safety (Blask et al., 2012). The amount of artificial light used for residential, commercial and
industrial purposes across the United States has dramatically increased within the past several
decades (Figure 5-5). In Europe, over half the population has lost the ability to see the Milky
Way with the naked eye. Moreover, 99% of the population of Europe and the United States
(excluding Hawaii and Alaska) live in areas where the night sky is brighter than the threshold for
light-polluted status set by the International Astronomical Union (i.e., artificial sky brightness is
>10% of natural sky brightness above 45 degrees of elevation). This can be contrasted against
only 63% of the world’s population living in areas exceeding the light-pollution threshold,
indicating that higher levels of artificial light-at-night are associated with more developed nations
(Chepesiuk, 2009).
Despite the fact that the use of artificial light is a widespread consequence of industrial and
economic development, it can have unintended negative consequences, especially when it
becomes inefficient, annoying and unnecessary (Chepesiuk, 2009; Falchi et al., 2011).
According the National Park Service, approximately 50% of the light from a typical unshielded
light fixture is wasted, shining upward where it is not necessary, 40% shines downward to
illuminate the intended target and 10% is emitted horizontally, which can cause glare.
Therefore, the International Dark-Sky Association recommends “that all lighting be installed
such that no light is emitted above a horizontal plane running through the lowest part of the
fixture” and that good lighting is shielded in a manner that directs all of the light to where it is
wanted and needed (Chepesiuk, 2009).
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Figure 5-5 Increase in Artificial Night Sky Brightness in North America (Chepesiuk, 2009)
In the environment, artificial light can affect wildlife species and other ecosystem components
through the alteration of diurnal light and dark patterns which are involved in regulating
migration, reproduction, and predator-prey relations (Gotthard 2000; Lorne & Salmon 2007;
Moore et al. 2000). Furthermore, light pollution can impact plants due to the artificial polarization
of light which regulates natural polarization of sunlight involved in photosynthesis (Horváth et al.
2009). These findings have contributed to a growing interest in exploring potential effects of
artificial light on human health. However, uncertainty remains as to whether artificial light poses
human health risks, and if so, to what extent and magnitude (Kantermann & Roenneberg,
2009).
Studies on light pollution have found that artificial light has the potential to influence biological
processes in humans. Blask et al. (2012) stated that “light is the most powerful stimulus for
regulating human circadian rhythms and is the major environmental time cue for synchronizing
the circadian clock.” The presence or absence of light influences the production of melatonin,
which is involved in the regulation of many physiological systems in mammals, such as the
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sleep/wake cycle, reproduction, cardiovascular system and blood pressure, including energy
metabolism and energy balance (Amaral, 2014). “Melatonin is one of the most studied
biomarkers of the human physiological response to light. This substance is the biochemical
correlate of darkness and is only produced at night, regardless of whether an organism is day-
active (diurnal) or night-active (nocturnal). Conceptually, melatonin provides an internal
representation of the environmental photoperiod, specifically night-length” (Blask et al., 2009).
However, it is important to note that light is not required to generate circadian rhythms or
produce melatonin. For example, individuals who are completely blind do not experience light-
dark cycles, yet they generate circadian rhythms close to a 24-hour cycle (Blask et al., 2009).
It was initially thought that very bright light (>2,500-20,000 lux) was required to suppress the
production of melatonin and disrupt the rhythm (e.g., as in jet lag) in humans. However, it has
since been suggested that suppression of melatonin production can occur in normal human
volunteers from light levels as low as:
5 lux of monochromatic blue light;
5-17 lux of monochromatic green light;
<100 lux of white fluorescent light; and,
100 lux of broadband white light.
In a study conducted by Cho et al. (2013) it was found that sleeping with lights on (40 lux
fluorescent) was associated with longer periods of shallow sleep and more frequent arousals.
Typical lighting in residences (i.e., night lights, hallway/bathroom lighting, and television or
computer illumination) can also suppress melatonin during the night; however, studies
investigating light at night have suggested that human circadian rhythms are wavelength
dependent. These findings indicate that human melatonin levels are most sensitive to exposure
to short wavelengths, or blue light, and that this should be considered in the context of
controlling illumination (Lockley et al., 2003).
There is a theory regarding the use of “light-at-night” (LAN) and the potential link to cancer. This
theory was largely developed based on studies conducted on shift workers and the International
Agency for Research on Cancer (IARC) classification of “shift work that involves circadian
disruption” as potentially carcinogenic (Kantermann and Roenneberg, 2009). The LAN
hypothesis is “based on the following chain of arguments: melatonin is a hormone produced
under the control of the circadian clock at night, and its synthesis can be suppressed by light; as
an indolamine, it potentially acts as a scavenger of oxygen radicals, which in turn can damage
DNA, which in turn can cause cancer” (Kantermann and Roenneberg, 2009). Despite the fact
that this theory has attracted a lot of attention, there is no experimental evidence that LAN is the
basis of increased cancer incidence in shift workers (Kantermann and Roenneberg, 2009).
Furthermore, Stevens (2009) has stated “The LAN theory is easy to state but difficult to assess
scientifically. Virtually no sighted person in the modern world does not use electric light to
reduce the length of the natural daily dark period. This is also increasingly true in the developing
world. Finding appropriate comparison groups is difficult.” Additionally, Blask et al. (2012) has
found that limited epidemiological studies support the hypothesis of nighttime lighting and/or
disruption of circadian rhythms increasing cancer risk. They identify the importance of
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epidemiological studies as a critical component of assessing whether or not there is a link
between light exposure and disease risk in humans; however, they point out that these studies
are observational and thus “can rarely provide mechanistic understanding of the association”
(Blask et al., 2009).
Finally, it is important to consider the extent of the use of artificial light at night and the fact that
we have been prolonging ‘daytime’ for many decades, especially in developed countries. It is
also important to consider the tradeoff between positive uses of light (i.e., traffic and street
lights, safety, increased production and time for recreational activities), and excess, inefficient or
unnecessary lighting (i.e., light pollution). “Almost everyone in modern society uses electric light
to reduce the natural daily dark period by extending light into the evening or before sunrise in
the morning...on that basis, we are all exposed to electric light at night” (Chepesiuk, 2009).
5.5.2.2 Current Conditions
Hermosa Beach is a city of approximately 20,000 residents located just over 20 miles from
downtown Los Angeles. Within the city limits there are residential, commercial and industrial
land uses. The proposed Project Site is a maintenance yard that is located within an area
containing residential, commercial and light industrial uses. The buildings surrounding the Site
are comprised primarily of one to three-story structures. During nighttime hours, the surrounding
area is characterized by moderate levels of interior and exterior lighting for nighttime activities,
security, parking, and signage. The majority of these light sources are shielded and directed
towards the ground to maximize efficiency and minimize ambient glare. Light from interior
lighting from windows and porches of the residential uses contribute to the ambient nighttime
levels. Other exterior lighting sources include pole-mounted street and traffic signal lighting
along city streets.
The EIR included a baseline evaluation of the local light emissions on the proposed Project Site
and surrounding areas. The following are the findings from the EIR report (MRS, 2014):
Clark Stadium: The most significant night time lighting observed in the Project area was
from Clark Stadium where light levels exceeded 35 footcandles (as measured at the
tennis courts adjacent to Valley Drive). Using a typical conversion (1 footcandle = 10.8
lux), Clark Stadium emits approximately 377 lux at night. This is roughly equivalent to the
lighting that would be experienced in a typical residential or office setting (WOT, 2014).
Lighting near or exceeding this level is evenly distributed across the active use areas of
the park site.
South Park: South Park light levels were considerably lower than around Clark Stadium
with only occasional low-level light fixtures along the main path and parking area.
Greenbelt: The Hermosa Greenbelt adjacent the Project Site is not lit at night.
Residential: Interior lighting spill-over from windows and porches of the residential uses
contribute to the ambient nighttime levels.
Green spaces: Lower light levels are located on undeveloped parcels, non-active-use
parks and open spaces.
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Proposed Project Site: Light levels generated within the Project Site are low to
moderate. Light sources include exterior security lighting on building facades and light
poles located in the surface of parking areas. The buildings and tanks on the Project Site
have painted metal finishes and do not contain large glare-producing windows. Existing
fixtures are not full cut-off and some light spill into the night sky was observed.
Proposed Maintenance Yard: Light levels generated at the Proposed City Maintenance
Yard Site are low to moderate. Light sources include exterior security lighting on building
facades and light poles located in the surface of parking areas on the east third of the
site. Existing fixtures are not full cut-off and some light spill into the night sky was
observed.
With the exception of Clark Stadium (which increases light levels in the area when it is used at
night) the character, intactness and unity of the lit environment is fairly uniform and consistent
with a Lighting Zone 2 (LZ-2) (MRS, 2014).
5.5.2.3 Project Impact
A potential increase in the presence of artificial light sources varies depending on the Phase of
the proposed Project. The EIR points to several plans and policy documents that identify
regulations and guidelines for aesthetics, visual resources, vistas, light and glare that relate to
the development of the Proposed Project. These include the California Coastal Act, City of
Hermosa Beach General Plan, City of Redondo Beach General Plan, City of Torrance General
Plan, and local planning and zoning ordinances. Light emissions from the proposed Project are
evaluated regarding their potential to impact human health with the assumption that all
mitigation measures in the EIR pertaining to light and glare are implemented.
Phase 1:
The first phase of the proposed Project would occur for a period of approximately six months.
During this time, demolition or construction activities would occur on the Project Site during
daytime hours (Monday-Friday 8 am to 6 pm; Saturday 9 am to 5 pm), which is consistent with
the City Municipal Code. Since the Phase 1 activities will be occurring only during the day, no
nighttime lighting is necessary. Outside of the Project Site, existing street lighting located on
Valley Drive and 6th Street will be sufficient. Therefore, an assessment of light emissions from
Phase 1 of the proposed Project is not necessary for the current HIA.
Phase 2:
The second Phase of the proposed Project would occur on a continuous basis (day and night)
for approximately twelve months. During this Phase, four wells would be drilled utilizing an
electric drill rig and temporary production equipment would be installed and used to process the
extracted oil, gas, and water. Phase 2 will require the use of temporary nighttime lighting for Site
security and worker safety consistent with the requirements of the City. To address Site
security, temporary pole mounted low-energy light fixtures at a height of 10 ft will be provided at
the Site entrance and exit. These lights would be shielded/hooded and downcast so that it
would not create light spill or glare beyond the property line (MRS, 2014). Additionally,
temporary lighting (two 150-watt light fixtures) would be provided for the temporary construction
trailer. Each fixture would be shielded/hooded and downcast so that it would not create light spill
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or glare, and the construction trailer would be located behind a 32-foot sound attenuation wall
that would block any light spill or glare from leaving the Project Site (MRS, 2014).
For the safety of on-site workers, lighting would be provided for the electric drill rig. Lighting for
the drill rig will require pole-mounted lights approximately 15 feet above the rig platform and on
the drill rig mast, which would start approximately 19 feet above ground surface and extend
upward to approximately 87 feet. The drill right will be enclosed with an acoustical cover on
three sides. The lights will face inward to provide workers with an ambient glow for visibility and
safety purposes. All light fixtures would be shielded, hooded and downcast, and would be
located behind the 32 foot sound attenuation wall, which will significantly reduce operational
light spill or glare beyond the Site perimeter, with the exception of the drill rig mast which
extends up to 87 feet. Additionally, the EIR stipulates that “lighting shall be limited solely to the
amount and intensities necessary for safety and security purposes” and that “the use of
architectural lighting beyond safety and security requirements shall be prohibited” (MRS, 2014).
Due to the presence of the electric drill rig, which extends above the height of the sound
attenuation wall, there is potential for additional light emissions in the surrounding area.
Therefore, an assessment of potential health impacts from the presence of additional nighttime
lighting from the electric drill rig (Phase 2) is necessary for the HIA.
Phase 3:
The third phase would occur for a period of approximately fourteen months. Grading and
construction activities would occur on the Project Site between 8 am and 6 pm Monday to
Friday and 9 am to 5 pm on Saturdays, as per the Municipal Code. No nighttime lighting will be
required for the Project Site and the perimeter of the Project Site would be illuminated by the
existing street lights on Valley Drive and 6th Street. Therefore, an assessment of light emissions
from Phase 3 of the proposed Project is not necessary for the current HIA.
Phase 4:
The fourth, final phase would occur for a period of approximately thirty to thirty-five years.
During Phase 4 of the Proposed Project, remaining wells would be drilled utilizing an electric
drill rig and production equipment would be installed and used to process the extracted oil, gas,
and water (MRS, 2014). Lighting will be required for Site security and worker safety, including
light fixtures (150-watt) at the entrance and exit mounted on the perimeter wall at a height of
approximately 15 ft. The light fixtures would be shielded/hooded and downcast so that they
would not create light spill or glare beyond the property line (MRS, 2014). Lighting would also be
provided for the small office building and would consist of a 150-watt light fixture wall-mounted
at the building entrance at a height of 10 ft. The light on the office building would be located
behind the 16-foot split-faced block wall, which would block any light spill or glare from leaving
the Project Site. To address worker safety, lighting would be provided for the drill rig and drill rig
platform as discussed above for Phase 2. Further, any maintenance activities on the Project
Site that would require the use of a workover rig would occur during daylight hours (8 am to 6
pm); therefore, no nighttime lighting would be required (MRS, 2014).
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Due to the presence of the electric drill rig, which extends above the height of the sound
attenuation wall, there is potential for additional light emissions in the surrounding area.
Therefore, an assessment of potential health impacts from the presence of additional nighttime
lighting from the electric drill rig (Phase 4) is necessary for the current HIA.
Presence of Electric Drill Rig (Phase 2 and 4):
The EIR provides an illustration to demonstrate the lighting on the drill rig mast that will be
present during portions of Phase 2 and Phase 4 (Figure 5-6). During Phase 2 the drill rig would
operate 24-hours per day, 7-days per week until the desired depth for each hole has been
reached. It is estimated that this would take approximately 30 days per well (including
installation, rigging and demobilization) for four wells, resulting in a total of 120 days for drilling
activities. During Phase 4, which would occur for approximately 30-35 years, drilling would
occur for the first 30 months to drill the remaining wells and re-drilling would occur over the life
of the project when necessary (MRS, 2014). Although much of the light associated with drilling
operations will be obstructed by the EIR mitigation measures (i.e., downcast, directional lighting
and the 32-foot sound attenuation wall), the electric drill rig extends beyond the height of the
wall that will be visible to the surrounding community.
Figure 5-6 View Simulation of Drilling Rig at Night (MRS, 2014)
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Due to the design and construction of the electric drill rig (3-sided enclosure), it is anticipated
that the majority of residents in the area will not be impacted from the light associated with
drilling activities. However, since one side of the drill rig will be open and lighting is required for
worker safety and visibility, there is the potential for some light spill or glare beyond the Site
boundary. The EIR states the following with respect light emissions from the electric drill rig:
“The Applicant has stated that measures have been taken in this design to minimize
potential for light spill and glare from the open side, however the interior faces of the
acoustical shroud and the elements of the mast structure would catch light and would
have the effect of producing a vertical lighted column visible from areas in the
foreground, middleground and background areas. Views of the open (illuminated) side of
the drill rig would be limited to the direction the open side faces. The pattern and scale of
this illuminated feature would be out of character with existing nighttime views. Similar to
day time impacts, this vertical feature would project above the horizontal plane of the
existing illuminated environment and would become a focal element. The duration of
exposure, number of sensitive viewers, and nature of the visual change would result in
impacts that would be significant” (MRS, 2014).
Therefore, people living within the direct sight line of the exposed portion of the drill rig may be
disproportionately affected by nighttime lighting. In some instances, especially in sensitive
individuals, the increase in light emissions has the potential to interfere with typical sleep cycles.
It is recommended that black-out blinds or curtains be provided to residents with one or more
bedroom windows with a direct line-of-sight of the exposed side of the electric drill rig, which will
be lit at night for worker safety and visibility. Providing certain residents with blackout
blinds/curtains will not only eliminate any potential for sleep disruption but it will also provide
additional protection from existing outdoor light sources (i.e., street lights, other residences,
commercial buildings, etc.) that are not related to the proposed Project.
Residents and visitors of Hermosa Beach can also potentially benefit from additional nighttime
lighting including increased leisure-time, physical activity and commuting by foot or bicycle, as
well as increased perception of safety (Velasquez et al., 2009). It is anticipated that these
changes would be most evident in areas with high pedestrian traffic, along Valley Drive and
portions of the Greenbelt in close proximity to the Site.
The impact of change in light emissions due to the proposed Project on the health of the
community is provided in Table 5-26.
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Table 5-26 Noise and Light Assessment: Light Emissions
Health Determinant Light Emissions
Potential Health Outcome Annoyance, stress and possible disturbance of typical sleep
cycles
Pre-Mitigation Discussion Negative health outcomes may occur from excess light and
glare from the proposed Project during Phase 2 and 4 with no
mitigation measures in place
EIR Mitigation Light mitigation measures: Phases 2-4: AE-4a to AE-4c; AE-5a
to AE-5e; AE-6a to AE-6b
Geographic Extent Localized
Vulnerable Populations People with a direct line-of-site of lit side of electric drill rig at
night
Magnitude Low
Adaptability High
Likelihood Unlikely
Post-Mitigation Health Effect No substantial effect
Comments or Additional
Recommended Measures
Although the magnitude is ‘low’ for the majority of residents, it
could be higher for those individuals with a bedroom window in
the direct line-of-sight of the exposed side of the electric drill rig
that will be lit at night. It is recommended that these individuals
be provided with black-out blinds or curtains to eliminate any
potential impact to typical sleep patterns.
The geographic extent of light emissions is ‘localized’ since the majority of light sources
associated with the proposed Project have been mitigated in such a way that light spill or glare
will be limited to the Site boundaries. The magnitude of the health effect in the area is expected
to be ‘low’ since the extent of the impact is minor and does not pose a significant hazard to
health given the effectiveness of the proposed EIR mitigation measures to limit exposure to light
emissions. The vulnerable populations identified for light emissions are ‘people with a direct
line-of-site of lit side of electric drill rig at night’. Adaptability is determined to be ‘high’
since the use of artificial light at night is ubiquitous in the United States, including in urban and
suburban areas, and people will be able to adapt to the change with ease and maintain pre-
project level of health. The likelihood of any resulting health effect from light exposure is
‘unlikely’ since over the course of the proposed Project the presence of additional light will not
be of concern (with potential exception of those with direct view of drill rig). Overall, there is
considered to be ‘no substantial effect’ on the health of the community as a result of light
emissions from the proposed Project.
The most likely effect of light emissions from the proposed Project is annoyance and stress
induced by an unwanted change in the local environment. Based on the EIR mitigation
measures, including directed and downcast lighting and a 32-foot attenuation wall, it is not
anticipated that there will be health impacts from light emissions from the proposed Project. For
some people who have a direct line-of-sight from their bedroom window to the lit side of the
electric drill rig, there is some potential for interference with typical sleeping patterns. For these
individuals, it is recommended that black-out blinds or curtains be provided as an option to
eliminate the potential for infiltration of light emissions from the nighttime lighting on the drill rig.
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Moreover, this measure will provide an additional benefit by eliminating infiltration of existing
outdoor lighting as well (e.g., traffic signals, street lights, nearby residences, etc.) that is not
associated with the proposed Project.
5.5.3 Summary and Conclusions of Noise and Light Emissions
Noise is ubiquitous in suburban/urban and commercial areas. Health implications associated
with exposure to excess noise are typically focused on nighttime sleep disturbance. Since the
Project-related activities predicted to produce the highest noise levels were only permitted
during daytime hours, nighttime impacts
of noise are not a primary concern in
the current HIA. The impact of Project-
related noise emissions on the local
community, particularly residents
located around the Project Site and
along the pipeline and truck routes is
negative without the use of mitigation
measures; however, the EIR has
identified a variety of mitigation
techniques to reduce the potential
impact of noise on the surrounding
community including a 35-foot
acoustical barrier around the Project
site. Based on the current HIA, there is
expected to be no substantial effect on human health resulting from project activities in Phases
1, 2, 3a (site construction) and 4. There is some potential for negative health effects from high
levels of noise associated with pipeline construction (Phase 3b); however, this is expected to be
short-term in duration (approx. one week per location) and is limited to daytime hours.
Therefore, for Phase 3b (pipeline
construction), it is recommended that
local residents and local schools be
provided with written notification of the
impending work that identifies the
potential for excess noise and outlines
the location and duration of the impacts.
The invention and widespread use of
artificial light, especially at night, has
become a necessity in many areas of
the world to enhance commerce,
promote social activity, and increase
public safety. Despite the fact that the
use of artificial light is a widespread
consequence of industrial and economic
development, it can have unintended
The noise assessment within the HIA
concludes that, with implementation of the
proposed EIR mitigation measures, there is
no substantial effect on human health from
Phase 1, 2, 3a (site construction) and 4, and a
potential negative impact from pipeline
construction activities in Phase 3b.
Therefore, it is recommended that written
notification be provided to residents and
schools in the vicinity of these activities that
identifies the potential for excess noise and
outlines the location and duration of the
The light assessment within the HIA
concludes that, with implementation of the
proposed EIR mitigation measures, there is
no substantial effect on human health with
respect to light emissions; however, there is
potential for nearby individuals to
experience disruption of typical sleep
patterns. Therefore, it is recommended that
black‐out blinds/curtains be provided as an
option for residents whose bedroom
window(s) are in the direct line‐of‐sight of
the exposed portion of the electric drill rig
to eliminate any infiltration of outdoor
lighting.
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negative consequences, especially when it becomes inefficient, annoying and unnecessary. The
major health concern related to excessive light-at-night is disruption of sleep and biological
circadian rhythms which influence melatonin production and promote overall health. To ensure
visibility, site security and worker safety artificial lighting will be installed as part of the proposed
Project. The majority of the on-site lighting will be shielded and downcast to reduce glare.
Additionally, the site will have a 32-foot acoustical barrier that will eliminate light spill beyond the
Site boundary in most cases. The one exception to this is the presence of lighting on the electric
drill rig, which extends up to 87 feet. Residents who have a line-of-sight view of the exposed
side of the electric drill rig from their bedroom window(s) may be disproportionately impacted.
For these individuals, it is recommended that black-out blinds or curtains be provided to
eliminate the potential for infiltration of light emissions from the nighttime lighting on the drill rig.
5.6 Traffic
The traffic assessment focuses on the potential impacts the proposed project may have on
traffic safety and the impact that the perceived decrease in pedestrian safety could have on
active transportation.
5.6.1 Traffic Injury
5.6.1.1 Traffic and Health
Vehicular traffic is a well-known potential safety hazard. Traffic safety hazards are associated
with a number of factors, including vehicle volume, vehicle type, road infrastructure, driving
behavior, and population density. Increases in traffic volume are associated with increased risk
of injury and death due to vehicle-vehicle, vehicle-pedestrian, and vehicle-bicycle collisions.
Pedestrian injury collisions often occur in areas with large numbers of pedestrians and high
traffic flow. According to a model of vehicle-pedestrian accidents developed using census tract
level data from San Francisco, a 15% increase in census-tract traffic volume is associated with
an approximate 11% increase in vehicle-pedestrian injury collisions (Wier et al., 2009). In a
study of nine intersections in Boston’s Chinatown, researchers calculated an increase in three to
five injuries per year for each increase in 1,000 vehicles (Brugge et al., 2002). An analysis of
pedestrian injury at roadway intersections in Oakland, California found that the risk of collision
for pedestrians increases with higher traffic vehicle flow, as well as with commercial and mixed-
use areas when compared to only residential areas (Geyer et al., 2005). Vehicle-pedestrian
accidents disproportionately impact the elderly and the very young, due to slower walking
speeds and slower reaction times (US DOT, 2012).
Large truck crashes are associated with an increased severity of injury to the occupants of other
vehicles involved in the crashes. According to the National Highway Traffic Safety Association,
in 2011 large trucks were associated with 3,757 fatalities in the United States. Of these
fatalities, 72 percent were occupants of other vehicles, 11 percent were pedestrians or
bicyclists, and 17 percent were occupants of the large trucks (NHTSA, 2013).
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5.6.1.2 Current Conditions
Traffic on streets in Hermosa Beach consists of motorists who live, work, recreate, and shop in
the City, as well as motorists who are passing through but do not stop for any reason.
Commuter traffic is primarily concentrated on Pacific Coast Highway (PCH). Streets parallel to
PCH (Ardmore Ave., Highland Ave., Valley Dr., and Prospect Dr.) also absorb some of the
spillover commuter traffic. Traffic counts were collected on roadway segments of Pier Ave,
Valley Drive, and Herondo Street in mid-July 2013 to specifically establish baseline truck traffic
in the vicinity of the Site. Based on the three-day traffic count data, daily averages of 55 two-
and three-axle trucks (medium trucks) were counted along Valley Drive, between Pier Avenue
and Herondo Street. No four-(or more) axle trucks were counted during the three-day traffic
count (Arch Beach Consulting 2013). While current pedestrian or bicyclist counts are not
available, Hermosa is considered a pedestrian and bike-friendly city. A detailed description of
the existing transportation conditions near the project Site can be found in the EIR (Section
4.13.3).
The baseline health assessment found that fatalities resulting from motor vehicle collisions in
Hermosa are currently very rare (see Appendix E). There were zero reported fatalities from any
type of collision in Hermosa from 2009 to 2011; data from recent years is not yet available (CHP
2014). While vehicle-vehicle accidents are far more common than vehicle-pedestrian and
vehicle-bicycle accidents, pedestrians and bicyclists are more likely to suffer from injuries and
severe injuries as a result of the collision compared to motorists or vehicle passengers. On
average, from 2009 to 2011 in Hermosa, 100% of reported vehicle collisions involving
pedestrians resulted in an injury, 91% of vehicle collisions involving bicycles resulted in an
injury, and 35% of vehicle collision with another vehicle or stationary object resulted in an injury.
There are certain streets where pedestrians are more vulnerable to collision with a vehicle,
including PCH, Pier Ave., Hermosa Ave., and Beach Drive (see Appendix E).
5.6.1.3 Project Impact
During Phase 1 of the proposed Project, there would be demolition and construction activities
resulting in various vehicles traveling to and from the Site. Construction improvements to the
intersection of 6th St./Valley Dr. will provide the necessary turning radius for project-related
trucks turning southbound on Valley Dr. from 6th St. (construction would include the relocation
of a stop sign and striping, removal of utility pole and utilities, and the removal of parking
spaces).
During Phase 2, processed oil would be removed from the Site by truck and delivered to an off-
site location. During Phase 2 and Phase 4 drilling, the electric drill rig, with an approximately 87-
foot high rig mast and its associated equipment would be brought to the Site on large trucks with
trailers permitted by the City and the California Highway Patrol. Other temporary and permanent
production equipment would also be brought to and from the Site by large trucks with trailers. A
trucking safety program would be implemented to address potential trucking risks associated
with the transport of the processed oil to an off-site location.
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During Phase 3, there would be construction activities resulting in various vehicles traveling to
and from the Site, including trucks used in the export of soil during the implementation of the
Remedial Action Plan at the Site. In addition, there would be construction activities associated
with the installation of off-site pipelines resulting in short-term road closures in the Cities of
Hermosa Beach, Redondo Beach, and Torrance. Other design features of Phase 3 would
include the installation of new curbs, gutters, and sidewalks along the frontage of the Site on
Valley Dr. and 6th St.
As described in the EIR (MRS, 2014), the proposed project will be implemented consistent with
Resolution No. 93-5632, approved on August 12, 1993, for a Conditional Use Permit (CUP),
including the following traffic requirements:
All truck deliveries shall be limited to daylight hours (9:00 am – 3:00 pm), Monday
through Friday;
The number of truck trips shall be limited to a maximum of 18 round trips per day, except
for an emergency situation;
Project related truck travel shall be restricted to specific truck routes and access points
as approved by the Public Works Department. Signs shall be installed to direct detour
traffic as approved by the Public Works Director;
Site access shall be designed to enable trucks to turn into the site without inhibiting
traffic movement on Valley Drive or 6th Street;
Areas of construction and maintenance activities [for the pipeline construction] shall be
delineated by signs, flagmen, pavement markings, barricades, and lights, as determined
by permit requirements of all local agencies; and,
Where pedestrian activities are affected during [pipeline] construction, appropriate
warning signs shall be installed and pedestrians will be diverted. Pedestrian access to
business and residences will be maintained during construction. Special facilities, such
as handrails, fences, and walkways shall be provided, if necessary, for the safety of
pedestrians.
The proposed project would also include implementation of a City-approved Pedestrian
Protection Plan during Phases 1 and 3 to provide specific pedestrian protection measures
during periodic sidewalk closures along Valley Drive throughout Phase 1 (during week 5,
between weeks 6 and 13, between weeks 58 and 59, and between weeks 60 and 61) and
Phase 3 (first five weeks, between weeks 5 and 8, between weeks 9 and 11, and between
weeks 26 and 27).
A Traffic Impact Analysis (TIA) prepared by Arch Beach Consulting in November, 2012 (with an
August 2013 Technical Memorandum Addendum) identifies intersections and roadway
segments that could be impacted by the proposed project, establishes baseline traffic
conditions, and estimates the level of traffic that would be generated during construction and
operation, and compares traffic conditions with and without the proposed project (Arch Beach,
2012; 2013).
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The TIA applies a Passenger Car Equivalence to all trucks generated by the proposed project to
assess the truck traffic generated by the proposed project against road capacity during the
morning and evening peak commute hours, which contain primarily passenger cars. Table 5-27
provides trip generation rates, in terms of Passenger Car Equivalence, for each phase of the
proposed project. Based on the adjusted trip generation methodology, Phase 1 would generate
110 daily trips, Phase 2 would generate 170 daily trips, Phase 3 would generate 218 daily trips,
Phase 4 would generate 152 daily trips, and the ongoing operations would generate 44 daily
trips. The heaviest traffic would occur during Phase 3 final design and construction, lasting
approximately 16 months.
Additionally, the TIA performed average daily traffic counts from 33 roadway segments and 44
intersections potentially impacted by the proposed project (Figure 5-7). To evaluate the
proposed project’s potential impact on roadway segments and intersections, the total PCE trips
associated with each phase of the proposed project was added to each intersection to
determine if there was a potential to exceed significance criteria. The significance criteria in the
EIR traffic assessment was based on level of service ratings, or degree of traffic congestion at
intersections.
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Table 5-27 Project Trip Generation Estimates (Arch Beach Consulting, 2012).
Construction Activity Vehicle Type
Daily (PCE)
In Out Total
PHASE 1 – SITE PREPARATION
PEAK ACTIVITY
3+ axle truck (3.0) 45 45 90
2 axle trucks (2.0) 0 0 0
Cars-pickups (1.0) 10 10 20
Total with PCE 55 55 110
PHASE 2 – EXPLORATORY
DRILLING AND TESTING PEAK
ACTIVITY
3+ axle truck (3.0) 54 54 108
2 axle trucks (2.0) 3 3 6
Cars-pickups (1.0) 25 25 50
Total with PCE 85 85 170
PHASE 3 – FINAL DESIGN AND
CONSTRUCTION PEAK ACTIVITY
3+ axle truck (3.0) 54 54 108
2 axle trucks (2.0) 0 0 0
Cars-pickups (1.0) 55 55 110
Total with PCE 109 109 218
PHASE 4 – DEVELOPMENT AND
OPERATION PEAK ACTIVITY
3+ axle truck (3.0) 36 36 72
2 axle trucks (2.0) 8 8 16
Cars-pickups (1.0) 32 32 64
Total with PCE 76 76 152
OPERATIONAL PHASE – LIFE OF
PROJECT PEAK ACTIVITY
3+ axle truck (3.0) 12 12 24
2 axle trucks (2.0) 2 2 4
Cars-pickups (1.0) 8 8 16
Total with PCE 22 22 44
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Figure 5-7 Project Site Location and Traffic Impact Assessment Study Area (MRS, 2014)
The TIA-calculated percent increases over baseline traffic counts are overall very small for
individual road segments (usually less than 1%). The greatest percent increase in traffic is
projected for the roadway segment on 6th St. from Valley Dr. to Hermosa Ave (Arch Beach
Consulting, 2013). Results of the roadway segment analysis for the roadway segment on 6th St.
from Valley Dr. to Hermosa Ave. during each project phase are summarized in Table 5-28.
During Phase 3, lasting approximately 16 months, traffic is projected to increase by over a third
during morning and evening peak hours (33.5%). Still, the existing use of the roadway is much
less than capacity (i.e., 806 daily trips out of capacity for 2,500), and therefore does not have a
significant impact on traffic congestion. Overall, the TIA concluded that project-related traffic
would not significantly impact the level of service on any of the studied roadway segments. The
finding of no significant impact is primarily because (1) current traffic at some impacted
intersections is below capacity, or (2) the number of additional vehicles per day at other heavily-
traffic intersections is small relative to current traffic volumes.
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Table 5-28 Roadway Segment Analysis, 6th St from Valley Dr to Hermosa Ave (Arch
Beach Consulting, 2012).
Construction Activity Time Capacity Existing
Existing
+
Ambient
(2015)
Existing
+
Ambient
+
Project
%
Impact
PHASE 1 – SITE
PREPARATION PEAK
ACTIVITY
am 200 72 73 89 8%
pm 200 73 74 90 8%
daily 2,500 806 812 922 4.4%
PHASE 2 –
EXPLORATORY DRILLING
AND TESTING PEAK
ACTIVITY
am 200 72 73 109 18%
pm 200 73 74 110 18%
daily 2,500 806 812 982 6.8%
PHASE 3 – FINAL DESIGN
AND CONSTRUCTION
PEAK ACTIVITY
am 200 72 73 140 33.5%
pm 200 73 74 141 33.5%
daily 2,500 806 814 1,032 8.7%
PHASE 4 –
DEVELOPMENT AND
OPERATION PEAK
ACTIVITY
am 200 72 73 107 17%
pm 200 73 74 108 17%
daily 2,500 806 819 971 6.1%
OPERATIONAL PHASE –
LIFE OF PROJECT PEAK
ACTIVITY
am 200 72 76 87 5.5%
pm 200 73 77 88 5.5%
daily 2,500 806 845 889 1.8%
Based on the TIA, the EIR indicates that project-related traffic will not have a significant impact
on traffic congestion according to level of service criteria. However, level of service criteria were
derived for determining impacts to roadway capacity rather than impacts to traffic-related injury.
Further, traffic volume is only one component of traffic-related safety. Type of vehicle, vehicle
speed, and driving behavior also affect risk of traffic accidents. As discussed in the description
of current conditions, there were no heavy truck trips on Valley Dr. during the three day count
period in July 2013. The increased truck traffic, particularly given the baseline of zero heavy
trucks, could represent a safety hazard to bicyclists and pedestrians.
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The restriction of truck trips to between the hours of 9:00 am and 3:00 pm minimizes the
possibility that trucks will be on the roadways while children are walking to and from school.
Students walking to Hermosa Valley School are expected to be in school in the morning (as
early as 8:15 am) prior to trucks being on Valley Drive. As the regular school day ends as early
as 2:48 pm for some students, trucks would still utilize Valley Drive while students are walking
on adjacent sidewalks. In addition, Hermosa Valley School has days when students are
dismissed as early at 12:15 pm. Also, on Wednesdays, school is dismissed earlier at 1:45 pm
for some students (HBCSD, 2014).
The EIR recommends mitigation measures TR-1a through TR-1d to reduce the impact
associated with the introduction of truck trips in close proximity to sensitive receptors to less
than significant. In summary, those mitigation measures include (MRS, 2014):
Increased crossing guard presence near the Site;
Installation of warning signs/yellow lights that warn drivers of the approaching area
where trucks may be entering the roadway;
Ensuring that trucks are not too long (<65 feet) to hang over onto Ardmore Avenue when
utilizing the Pier Avenue and Valley Drive intersection. If trucks are longer than 65 feet,
then a flagger should be used at that intersection; and,
For Phases 1-3, the Applicant shall either (1) convert Valley Drive to one-way to increase
lane width and enhance pedestrian and bicyclist access (consistent with the
recommendation in the Beach Cities Livability Plan [WLCI 2011]); or (2) restripe the
section of Valley Drive between 2nd Street and Horondo Street to make it two-way and
direct all truck traffic to approach the Project Site from the South.
The impact of a change in truck traffic due to the proposed project on the health of the
community is provided in Table 5-29.
Table 5-29 Traffic Assessment: Traffic safety
Health Determinant Traffic safety
Potential Health Outcome Potential increase in number of pedestrian, bicycle or other
injuries
Pre-Mitigation Discussion Without mitigation, there is potential negative impact
associated with the introduction of truck trips in close proximity
to sensitive receptors
EIR Mitigation Traffic mitigation measures: (TR-1a through TR-1d)
Geographic Extent Localized
Vulnerable Populations Pedestrians and cyclists (children and the elderly)
Magnitude High
Adaptability Medium
Likelihood Unlikely
Post-Mitigation Health Effect No Substantial Effect
Comments or Additional
Recommended Measures
None
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Injury due to truck-traffic collision can occur because trucks are large, have reduced visibility
due to their size and elevation, and there is no barrier between the sidewalk and the street on
some roadways. Traffic injury can result in fatality or serious injury, especially when accidents
involve pedestrians or bicyclists. Without EIR mitigation measures summarized above, it is
possible that the introduction of truck trips uncommon with existing conditions in close proximity
to sensitive receptors would present a risk to pedestrians and bicyclists. However, the project
will only go forward with mitigation measures in place.
The extent of a potential health impact from the proposed Project with mitigation is ‘localized’.
While truck routes extend throughout Hermosa Beach and adjacent communities during pipeline
construction, the impact would be concentrated along Valley Dr., particularly at the intersection
of Valley Dr. and 6th St. since nearly all project-related vehicles will be using this intersection
and crossing over the sidewalk. Vulnerable populations were identified as ‘pedestrians and
cyclists, particularly those who are either young or elderly’. The magnitude is ‘high’ since
just a single traffic accident can pose a major hazard to an individual’s health. The adaptability
is considered ‘medium’ since those individuals that experience a disruption in safety may seek
alternative routes to avoid increased truck traffic. The likelihood of increased accidents
occurring from the proposed project is ‘unlikely’ since the mitigation measures such as the
addition of crossing guards and the reconfiguration of Valley Dr., in addition to the safety
measures required by the CUP, will reduce the likelihood of injuries. Converting Valley Drive to
a one-way thoroughfare would increase the separation distance between pedestrians and trucks
traveling on Valley Drive, therefore alleviating some of the risk of injury to pedestrians and
bicyclists along Valley Drive. Alternatively, converting Valley Drive between 2nd Street and
Horondo Street to two-way means that all truck traffic would approach the Project Site from the
South, therefore eliminating increased truck traffic on roadways North of the Project Site (i.e.,
Pier Avenue) that are more heavily trafficked by pedestrians. Overall, with safety measures in
place, there is considered to be ‘no substantial effect’ on traffic safety as a result of the
proposed project. Therefore, no additional measures are recommended.
5.6.2 Active Transportation
5.6.2.1 Traffic and Active Transportation
Perceptions about traffic safety can also impact health by altering active physical transportation
activities, including walking and biking. People who live in areas more conducive to walking and
bicycling are more likely to use these forms of active transportation. Research has
demonstrated that adults living in neighborhoods characterized by higher levels of traffic safety
had increased odds of being active (Jongeneel-Grimen et al., 2013). An individual’s perception
of their environment may be just as important as the condition of the physical environment itself.
A cross-sectional study in higher- and lower- income areas of St. Louis, Missouri and Savanah,
Georgia found that active transportation was positively associated with perceived access to bike
lanes (Hoehner, 2005). A comprehensive review of the literature found that the perceived risk of
injury by motorized traffic due to traffic speed and volume impacts people’s decisions to drive,
walk, bicycle, or use public transportation (Jacobsen, 2009). Parental perceptions of safety are
especially important for rates of walking and bicycling among children (Olvera, 2012). A survey
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conducted on a representative sample of the U.S. population inquired whether children walked
or biked to school and sought to identify any barriers to walking or biking. Of the respondents,
40% reported that traffic danger was a barrier against walking or biking to school (CDC, 2002).
Findings from the literature suggest that perception of safety is an important mediator of the
relationship between traffic safety and walking/bicycle trips. Perceived risk of injury may
discourage walking and bicycling, which can directly impact health by decreasing physical
activity levels. Physical inactivity is a major contributor to the steady rise in rates of obesity,
diabetes, heart disease, stroke, and other chronic health conditions in the United States (CDC,
2011).
5.6.2.2 Current Conditions
Data on pedestrian/bicyclist counts and data on perceived safety of the streets in Hermosa are
not available. However, Hermosa Beach is considered a pedestrian and bike-friendly city.
Pedestrians, joggers, bicyclists, skateboarders are a typical sight at all times of day especially
along Pier Avenue and near the beach. According to the South Bay Bicycle Master Plan, the
City of Hermosa Beach has 1.8 miles of Class I bike path (bicycle-only paths along the beach),
0.5 miles of Class II bike paths (bicycle lanes) and 2.8 miles of Class III bike paths (shared road
for motorist and bicyclists) for a total of 5.1 miles within the City (Alta, 2011). The South Bay
Bicycle Master Plan seeks to further encourage bicyclists specifically by converting Valley and
Ardmore to one-way streets with bike lanes (WLCI, 2011).
Children attending either of the two public elementary schools in Hermosa (Hermosa View
Elementary and Hermosa Valley) arrive and leave via passenger car, walking, or bicycle.
Hermosa View Elementary is located on the corner of 19th St. and Prospect Ave. (east of PCH)
and Hermosa Valley School is located on Valley Dr. between 18th St. and Pier Ave. (west of
PCH). Since 2011, Hermosa View Elementary has had a Walking School Bus (WSB) program
led by the Beach Cities Health District (BCHD), as a means of encouraging healthy behavior
and curbing childhood obesity. The WSB program allows children within a mile radius of school
to meet up with classmates and BCHD-trained parent volunteers at designated “bus stops,” and
safely walk to campus. WSB is between 7:50 and 8:15 am and “stops” at the following locations:
Hollowell/Prospect, 6th St./Prospect, 9th St./Prospect, and 15th St./Prospect.
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Figure 5-8 Safe Routes to School (MRS, 2014)
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Figure 5-9 Pedestrian Sidewalk, Valley Dr./ 6th St.
(google maps)
Additionally, Hermosa Beach City School District publishes a map showing all the safe routes to
school, which includes Valley Drive
in front of the Site and the Proposed
City Maintenance Yard (Figure 5-8).
It is important to note that there is no
landscape buffer along most parts of
Valley Drive, with pedestrian
sidewalks located immediately
adjacent to the road (Figure 5-9).
5.6.2.3 Project Impact
As discussed above, research has
shown that perceived traffic safety
and hazards can influence active
transportation in a population.
Accurately or not, community members may judge injury risk and change their behavior
accordingly. Increased truck traffic, especially along Valley Dr., may make the adjacent sidewalk
(including the school route) less walkable if parents, children, and other community members
feel that their safety is compromised. Portions of Valley Dr. with no landscape buffer between
the sidewalk and roadway may be particularly susceptible to decreased use by pedestrians and
bicyclists.
The impact of a change in truck traffic due to the proposed project on the health of the
community is provided in Table 5-30.
Table 5-30 Traffic Assessment: Perceived traffic hazards
Health Determinant Perceived traffic hazards
Potential Health Outcome Decrease in active transportation
Pre-Mitigation Discussion Same as post-mitigation
EIR Mitigation Traffic mitigation measures: (TR-1a through TR-1d)
Geographic Extent Localized
Vulnerable Populations Pedestrians and cyclists (children)
Magnitude Medium
Adaptability Medium
Likelihood Unlikely
Post-Mitigation Health Effect No substantial effect
Comments or Additional
Recommended Measures
None
As discussed in Section 5.6.1.3, the EIR proposes a number of mitigation measures to alleviate
potential traffic safety hazards. Those measures could also improve the perceived danger
posed by increased truck traffic. For example, seeing increased crossing guard presence may
influence the level of perceived risk to children walking to school. However, mitigation measures
may or may not change people’s perceived risk of injury from Project related traffic. Without a
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better understanding of current safety perceptions and their relation to active transport, it is not
possible to distinguish between the pre-mitigated and post-mitigated health impact. The extent
of a potential impact is ‘localized’. The impact would be concentrated where people perceive
changes in traffic patterns, particularly at the intersection of Valley Dr. and 6th St. since nearly
all project-related vehicles will be using this intersection and crossing over the sidewalk.
Vulnerable populations were identified as ‘pedestrians and cyclists, particularly children’.
The magnitude is ‘medium’ since perceived risk of injury may discourage walking and bicycling
and impact health by decreasing physical activity levels, but the impact is reversible and poses
a minor hazard to health. The adaptability is considered ‘medium’ since those individuals that
experience a disruption in perception of safety may maintain physical activity levels by seeking
alternative routes to avoid increased truck traffic. For example, children and adults can choose
to use the Greenbelt path that runs parallel to the Valley Dr., which is separated from the street
by a sizeable buffer, instead of the Valley Dr. sidewalk near the Project Site. The likelihood of
perceived traffic safety hazards causing a decrease in active transportation due to the proposed
Project is ‘possible’ since negative traffic perceptions do not necessarily reflect actual traffic
hazards, and therefore are impossible to completely mitigate. Overall, because the impact is
localized and most community members should be able to adapt to the increased perception of
traffic hazards by seeking alternative routes, there is considered to be ‘no substantial effect’
on perceived traffic hazards resulting in decreased levels of active transportation due to the
proposed Project. Therefore, no additional measures are recommended.
5.6.3 Summary and Conclusions
Increases in traffic volume are associated with increased risk of injury and death due to vehicle-
vehicle, vehicle-pedestrian, and vehicle-bicycle collisions. Currently, fatalities resulting from
motor vehicle collisions are very
rare in the pedestrian and bike-
friendly City of Hermosa Beach. A
Traffic Impact Analysis (TIA)
prepared by Arch Beach
Consulting (2013) concluded that
project-related traffic would not
significantly impact the level of
service on any of the studied roadway segments and therefore the EIR indicated that project-
related traffic will not have a significant impact on traffic congestion. However, the introduction
of truck traffic on roads not accustomed to large trucks could represent a safety hazard to
bicyclists and pedestrians. Consequently, the EIR recommends additional mitigation including
increased crossing guard presence at the Site, installation of warning signs and lights, ensuring
that trucks are not too long, and reconfiguring Valley Dr. Overall, with safety measures in place,
and because of the limited extent of increased traffic, traffic safety is not predicted to have a
substantial health impact in the community.
Findings from the literature suggest that perception of safety is an important mediator of the
relationship between traffic safety and active transportation, or walking/bicycle trips. Perceived
risk of injury may discourage walking and bicycling, which can directly impact health by
The traffic assessment within the HIA concludes
that, with implementation of the proposed EIR
mitigation measures, there is no substantial effect
on human health with respect to traffic safety and
perceived traffic safety hazards.
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decreasing physical activity levels. Parental perception of safety is especially important for rates
of walking and biking among children. Since the Project Site lies on a safe walk to school route,
there is a possibility that perceived traffic hazards could result in decreased active
transportation. However, the impact is limited to a portion of Valley Drive. and most community
members should be able to adapt to the increased perception of traffic hazards by seeking
alternative routes for walking and biking.
5.7 Community Livability
Community livability defines elements that make it desirable to live in a particular place. These
can include environmental, social and economic elements. Hermosa Beach is a desirable
community for many reasons including proximity to the beach, local bars and restaurants, ample
community services, local climate, walkable neighborhoods, and quality housing. For the
proposed Project, local residents voiced certain concerns they have regarding different aspects
of community livability. A quality of life committee was formed as part of the Community
Dialogue process, with the objective of facilitating communication with the City on a number of
large decisions (including the proposed Project). The quality of life committee created a
presentation (Appendix F) that was reviewed and discussed with the HIA Team in order to
identify the following health determinants associated with community livability:
Property Values;
Community Resources:
o Access to Recreational Resources and Green Space
o Aesthetics and Visual Resources
o Education Funding
Social Cohesion; and,
Political Involvement.
5.7.1 Property Values
5.7.1.1 Property Values and Health
Socio-economic status (SES) has long been
established as an important population health risk
factor (NCHS 2011). According to Coffee et al. (2013)
“SES is a complex, multidimensional concept that is
typically represented using one or all of the ‘triad’ of
indicators, education, income and occupation.”
(Figure 5-10). In addition, housing characteristics
(e.g., housing tenure, housing type, number of
bedrooms, etc.) have also been used as a proxy.
Figure 5-10 Common Indicators of Socio-Economic Status (SES)
Education
OccupationIncome
SES
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Residential property is often the most valuable asset that an individual will own and therefore, it
provides a useful estimate of socio-economic status. Property values are driven by a number of
different factors including economic market changes, trends, and proximity to amenities such as
reputable schools, green spaces and amenities. To illustrate the association between property
characteristics and health measures, a recent study correlated higher residential property
values with lower cardiovascular risk, lower obesity risk, reduced cholesterol scores and lower
diabetes risk (Coffee et al., 2013). This association seems to hold true for Hermosa Beach since
it is a city of economic prosperity and high levels of health and well-being overall. Although this
correlation doesn’t necessarily imply causation, it reflects the close ties between property value
and socioeconomic status, which is an established indicator of health status (Adler and Ostrove,
1999).
Due to the inherent complexity around estimating SES, it stands to reason that any potential
links between property values, SES and health must be carefully considered and evaluated.
Since property values are peripherally linked to socioeconomic status, and socioeconomic
status is indirectly associated with health status, drastic changes in property values that
fundamentally change an individual’s SES could potentially influence health. Although minor to
moderate changes in property values will not likely result in direct physiological harm, they may
lead to increased stress and anxiety.
5.7.1.2 Current Conditions
Since education, income and occupation are considered to be fundamental elements of
socioeconomic status, they were evaluated as part of the baseline health assessment
(Appendix E). With respect to education, Hermosa Beach residents are considered highly
educated, with nearly 70% of residents having obtained a bachelor’s degree or higher. This can
be compared to LA County where less than 30% of residents have post-secondary education.
Hermosa Beach residents are also considered to be more financially secure when compared to
county and national averages. The median household income in 2012 was approximately
$51,000 in the US (US Census 2012), $56,000 in LA County and $102,000 in Hermosa Beach.
Therefore, residents of Hermosa Beach have an annual household income that is approximately
double the rest of the country, including that of LA County.
Baseline conditions related to property values in Hermosa Beach are also considerably higher
than average. The median value of owner-occupied homes in Hermosa Beach is $1,000,001.
The median price of a new home in the US at the end of 2013 was $275,500 (US Census,
2014); therefore, the average house price in Hermosa Beach is >350% or 3.6 times higher than
the national average. The homeownership rate in Hermosa Beach is slightly less than that of LA
County (44.9% versus 47.8%), which is likely due to Hermosa’s popularity as a beach tourist
destination and an area highly attractive to both renters and leasers.
The Los Angeles County Department of Public Health (LACDPH) ranked 117 cities in LA
County by economic hardship, using the following indicators: (1) crowded housing, (2) percent
of persons living below the Federal poverty level, (3) unemployment, (4) percent of persons over
age 25 without a high school education, (5) dependency (percentage of the population under 18
or over 64 years), and (6) per capita income. Based on 2005‐2009 data for the indicators listed,
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LACDPH ranked Hermosa Beach number 1 out of 117 cities, that is, Hermosa Beach was
determined to have the least level of economic hardship county‐wide (LACDPH, 2103).
Since fluctuations in housing and land value can impact people’s stress levels, the current
reported stress levels of Hermosa Beach residents are also discussed in this section. The
Beach Cities Health District (BCHD) conducted a survey of 1,332 residents in Hermosa Beach
and surrounding communities, and found the overall well-being rating for residents of Hermosa
Beach, Manhattan Beach, and Redondo Beach was higher than the California average and
above the top tier of other cities. The survey found that 46% of the Beach Cities residents felt
stressed for most of the day, a number that ranked their stress higher than most communities
(176th out of 188 communities surveyed). Additionally, they were ranked 160th for anger and
when asked if they had significant worries, 37% said they did, which ranked the Beach Cities
177th out of those 188 communities surveyed (Blue Zones, 2010). More than 90% of local
residents said they had access to health care, health insurance and enough money for food,
shelter and other basic needs. Two-thirds were found to be “thriving.”
Overall, the baseline health assessment concluded that demographic indicators show that
Hermosa Beach is not highly vulnerable to poor health outcomes traditionally associated with
poverty, unemployment, and low educational attainment.
5.7.1.3 Project Impact
Like the HIA, the Cost Benefit Analysis (CBA) was conducted to provide additional information
and analysis that is not required as part of the EIR under the CEQA. An evaluation of private
property values was conducted as part of the CBA, including an analysis of properties in LA
County in proximity to other existing and proposed oil wells (Kosmont, 2014). The CBA noted
that “given the multitude of factors that influence buyer’s decisions, and wide variation in
individual calculus, the value or impairment in value of a particular attribute is extremely difficult
to predict.” Although many of the analyses were inconclusive, they identified case studies that
had conducted similar evaluations. One case study called the ‘Oil Well Lot Proximity Study’
evaluated impacts of adjacency to oil wells on single-family homes and small income properties
between 1980 and 2007 (Neustein and Matthews, 2011). This study found that “the
discrimination against oil lot adjacent lots was found to be roughly 5% ($20 per square foot
[PSF] at $500 PSF).” Overall, the CBA concluded that “the Authors consider a 0-10% reduction
in property values possible for properties proximate to the Project site.”
The complexities around property value fluctuations make it difficult to accurately evaluate the
potential impact from one project; however, assuming that the CBA conclusion is correct in
determining a 0-10% decrease, there is potential for this to increase stress levels among some
residents. It is important to note that the Project Site is approximately 1.3 acres and is to be
located on the current City Maintenance Yard property (already commercial/industrial land use).
This is considered a relatively small area compared to other types of industrial developments. A
study conducted in the Netherlands (de Vor and de Groot, 2009) evaluated the impact of
industrial sites on residential property values. Their study included a wide range of industrial
facilities and activities that are commonly located in proximity to people including landfills, waste
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sites, contaminated properties and manufacturing facilities. The authors conducted a review of
the literature on this issue and found that impacts on property value tend to be relatively
localized (decreasing with distance) and contain a high degree of variability (value impacts
ranging from 0.24 % to as high as 20%). The review also illustrated the fact that all different
types of development are considered ‘unwanted’ and that this issue is far from being unique to
oil and gas developments. For example, studies have shown that air traffic, railway traffic and
road traffic all have the potential to impact property values. The authors also noted that
individual selectivity plays a role in property value impacts, as does the potential employment
opportunity presented by industrial development. They concluded that:
“The results reveal that the distance to an industrial site has a statistically significant
negative effect on the value of residential properties. However, the effect is largely
localized within a relatively short distance from the nearest industrial site. Furthermore
we obtained statistical evidence for substantial localized price differentials, which vary
according to the size of an industrial site.”
This highlights the fact that many different types of development are met with some level of
concern over potential impacts on local property values. For most homeowners, future
developments (whether industrial in nature or not) are beyond their immediate control, but so
are many of the factors that influence property value fluctuations including interest rate changes,
economic activities, government decisions, etc. However, in the case of Hermosa Beach the
community has the ability to vote on whether or not to lift the ban on oil drilling, which is unique
since most industrial developments are not approved at a community-level. For further
discussion on political involvement, see Section 5.7.6.
Whether the potential decrease in property values is real or perceived, it may cause increased
stress and anxiety among some residential and commercial property owners. It is important to
identify that many property owners are in fact landlords who rent out their space. These
individuals may or may not reside in the city itself and may or may not be dependent on rental
income as their primary source of income. There is little to no publically available data to
evaluate this aspect; however it is important to note that Hermosa Beach is among the
wealthiest cities in LA County with a median annual household income over $100,000. Given
the construction and operation of the proposed Project is not anticipated to significantly impact
the average household income, education (in fact improvements via additional funding are
likely), or occupation of most of Hermosa Beach residents, the Project will not drastically affect
the socioeconomic status of the community. Since socioeconomic status has been linked to
health status, this is a promising finding. However, given that 46% of the community self-
identified as experiencing stress on a regular basis it is advisable for residents to engage in
activities known to reduce stress in general.
The impact of a change in property values due to the proposed Project on the health of the
community are provided in Table 5-31.
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Table 5-31 Community Livability Assessment: Property Values
Health Determinant Property Values
Potential Health Outcome Potential increase in stress and anxiety
Pre-Mitigation Discussion Not Applicable
EIR Mitigation Not Applicable
Geographic Extent Localized
Vulnerable Populations Property owners
Magnitude Medium
Adaptability Medium
Likelihood Possible
Post-Mitigation Health Effect Negative
Comments or Additional
Recommended Measures
E&B could consider evaluating housing prices for those in the
immediate vicinity of the Project Site.
Since this aspect of community livability is related to the potential impact on property values
rather than Project operations, the pre-mitigation discussion and EIR measures are considered
‘not applicable’. Based on findings in the literature, potential impacts on property values (and
associated stress) are limited to a ‘localized’ group of individuals who are located in closest
proximity to the proposed Project site. The vulnerable populations identified for the property
value impacts are ‘property owners’. The magnitude is classified as ‘medium’ since the
potential stress and anxiety is considered to be detectable, reversible and posing a minor to
moderate hazard to health. Since it is anticipated that the stress experienced as a result of
concern over property values is not physiologically different than other sources of stress, it is
advisable that community members seek out and engage in activities intended to reduce stress.
In identifying the adaptability as ‘medium’, consideration was given to the fact that people are
often able to adapt to changes in their environment and are able to cope with stressful
situations, although they may require some support. The likelihood was defined as ‘possible’
since there is potential for stress from property value fluctuations to occur on a regular basis.
Overall, the potential health impact associated with an actual or perceived decrease in property
values is classified as negative, due to potential increases in stress and anxiety.
To reduce any potential stress or anxiety that local property owners may experience as a result
of the proposed Project the Applicant could consider having a property value analysis
conducted prior to construction, during construction and one year into operations. This analysis
would need to take into consideration local, regional and national fluctuations in property values
and compare and contrast the data against potential changes in the value of properties located
near the proposed Project. This would help to document any observed fluctuations in property
values and show whether they remain within expected levels consistent with other similar
communities. Additionally, the Applicant could consider stabilizing “proven” impacts to property
values, perhaps through an arbitrator process.
During preparation of this report, a draft development agreement (City of Hermosa Beach,
2014) was released that contains some consideration of stabilizing property values. The draft
agreement states that “similar to Huntington beach, E&B proposed setting up and funding an
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account that would stabilize proven impacts to property values for 5 years (during drilling) for
properties in close proximity to the project. E&B clarified that the timeframe was undecided at
this time. It further clarified that the residents would need to voluntarily apply for this program.”
(City of Hermosa Beach, 2014). This proposal is similar to the additional mitigation
recommended in the HIA to further reduce potential impacts from stress and anxiety over
property value fluctuations.
5.7.2 Community Resources: Access to Recreational Resources and Green Space
5.7.2.1 Access to Recreational Resources and Green Space and Health
Community resources that encourage good nutrition and physical activity are instrumental in
improving quality of life. For example, community garden programs funded by California Healthy
Cities and Communities have provided opportunities for good nutrition and physical activity
education. In Oceanside, two community gardens were established and 228 residents receive
nutrition education; of these residents, 86% reported a desire to improve eating habits (Twiss et
al., 2003). Furthermore, regular physical activity has been shown to have a multitude of positive
health implications including (CDC, 2014):
Weight control;
Reducing the risk of cardiovascular disease;
Reducing the risk of type 2 diabetes and metabolic syndrome;
Reducing the risk of some cancers;
Strengthening bones and muscles;
Improving mental health and mood; and,
Increasing the chance of living longer.
A large number of studies show that access to outdoor green space benefits the overall physical
and mental well-being of communities; however, the mechanism for this beneficial relationship
is unclear. Green spaces can allow people to reduce stress by connecting with natural
environment, provide an opportunity for social interaction, and encourage physical activity.
However, a recent study found that the availability of green space is not directly associated with
levels of physical activity (Ord et al., 2013). Therefore, both physical and psychological
mechanisms are likely factors contributing to the association between green space and health.
In a large study (Asrell-Burt et al., 2013) of more than 260,000 middle to older-age adults, it was
found that residents in the neighborhoods with the most green space were at lower risk of
psychological distress (Kessler scores of 22+) and were less sedentary (OR=0.8, 95% CI: 0.77,
0.87) than residents in neighborhoods with the least green space (OR=0.83, 95% CI: 0.76,
0.92). Additionally, access to green space benefited mental health among more physically
active people, but did not appear to benefit the least physically active people (Astell-Burt, 2013).
In a longitudinal study of British households, moving to urban areas with more green space was
associated with sustained mental health improvements for three consecutive years (Alcock et al.
2014); however, this study did not explore the interaction with level of physical activity.
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Another study measuring the relationship between coastal proximity and health and well-being
found that living near the coast was associated with better general health and mental health
(White et al., 2013). There are a number of factors that determine the accessibility of green
space including distance between green space to where people live, walkability, safety, physical
appearance, and hours of operation and/or cost (Garcia, 2011).
5.7.2.2 Current Conditions
Hermosa Beach residents have access to community “green space”, such as parks, and
recreational resources readily available to the community. For example, there are three large
fields, located at Valley Park, Clark Stadium and South Park, which are home to several youth
and adult sport leagues. Hermosa also has tennis courts, a skateboard park, and over 70 beach
volleyball courts available to the public according to the City website. Based on feedback from
the community, one of the most valued green spaces in Hermosa (other than the beach) is the
Greenbelt, a popular greenery-lined 3.5 mile trail with a wood chip path used for running and
walking. At 6th and Valley, the Greenbelt passes within 55 feet of the proposed Project Site.
In total, Hermosa Beach has over 20 parks or green spaces that amount to approximately 138
acres (Figure 5-11), including the Hermosa City Beach (Green Info Network, 2014). Based on a
total population of 19,605, there are approximately 7 acres of green space per 1,000 residents.
This is much higher than most inner city assembly districts that have less than 1 acre of green
space per 1,000 residents. Communities with the least access to green space tend to be those
with lower income levels and more people of non-white race/ethnic backgrounds. Demographic
indicators show that Hermosa Beach is not highly vulnerable to poor health outcomes
traditionally associated with poverty, unemployment, and low educational attainment. The Los
Angeles County Department of Public Health ranked Hermosa Beach number 1 out of 117 cities
to have the least level of economic hardship county-wide, which has far-reaching effects on
access to community resources including green space.
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Figure 5-11 Parks currently located throughout the City of Hermosa Beach
(http://www.hermosabch.org/modules/showdocument.aspx?documentid=437)
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The City of Hermosa Beach and its community members are exceptionally committed to an
outdoor lifestyle and making their environment a healthy place to live. In 2010, the Beach Cities
Health District joined the Blue Zones ProjectTM initiative to create a beach cities community that
is healthier and more walkable, bikeable, and socially engaged. Blue Zones uses the Gallup-
Healthways Well Being Index™ to benchmark well-being and measure progress (Blue Zones
2010). In addition, the Beach Cities Health District (BCHD) seeks to promote health and prevent
diseases in the communities of Hermosa Beach, Manhattan Beach and Redondo Beach.
According to the 2013 BCHD report, three out of five beach cities adults (60%) meet the federal
guideline for physical activity, which is 150 minutes of moderate-intensity exercise per week.
This is commendable considering that nationally less than half (48%) of adults meet the
standards for physical fitness (US DHHS, 2008).
5.7.2.3 Project Impact
Hermosa is well-known for supporting an active lifestyle including a wealth of beach/park
activities (i.e., surfing, volleyball, skating and skateboarding, jogging, and bicycling). Therefore,
Hermosa Beach residents may be interested in using City revenues from the Project to further
develop additional green spaces to further improve physical and psychological health. The
Community Dialogue quality of life working committee identified the desire to increase children’s
beach play areas by adding swings and slides. It is possible that the proposed Project could
generate revenue to support improvements of existing parks and development of additional
recreational areas.
The Cost Benefit Analysis found that the majority of oil and gas revenue would come from the
Tidelands fund, which could be used to fund beach preservation. The amount of Tidelands
revenue and the proportion of the revenue available to improve green spaces outside of the
beach and coastal areas are uncertain. However, the CBA estimates that over the 35 year life of
the Project the City would realize net revenues of approximately $118 million to $270 million (in
2014 dollars), of which an estimated 37% to 42% would accrue to the General Fund (i.e., not
restricted to the Tideland fund) that the City could use to fund various community improvements
(Kosmont, 2014).
While revenue from the proposed Project is predicted to have an overall community-wide
positive impact on recreation and green space, Project activities occurring in close proximity to
existing parks should also be considered. The Project Site is currently the City Maintenance
Yard and there will be no impact to the amount of existing green space in Hermosa. However,
the Project Site is next to the Greenbelt, near other parks, and near walking and biking travel
routes. Disturbances, particularly related to construction activities in Phases 1 and 2 could
temporarily decrease ready access to recreational resources or the quality of the recreational
experience.
The impact on community livability recreational resources and green space due to the proposed
Project is provided in Table 5-32.
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Table 5-32 Community Livability Assessment: Access to Recreational Resources and
Green Space
Health Determinant Access to Recreational Resources and Green Space
Potential Health Outcome Change in physical activity levels, which can lead to other
health issues
Pre-Mitigation Discussion Not Applicable
EIR Mitigation Not Applicable
Geographic Extent Community
Vulnerable Populations None
Magnitude Medium
Adaptability High
Likelihood Possible
Post-Mitigation Health Effect Positive
Comments or Additional
Recommended Measures
To maximize potential health benefits from access to green
space and recreational activities the City should form a
community advisory group on how to spend revenue.
Since there will be no impact to the amount of existing green space in Hermosa Beach, there
are no EIR mitigation measures, and a pre-mitigation discussion is not applicable. The
geographic extent is ‘community’ since existing green spaces (i.e., Cypress/Clark Park and
Clark Stadium, South Park and the Greenbelt) will remain intact, and revenues may be used
across the City to improve recreation and green space. There were no vulnerable populations
identified for access to recreational resources and green space; therefore, it was classified as
‘none’. The magnitude is classified as ‘medium’ since overall the impact (if any) could improve
access to recreational and green space and pose a minor to moderate benefit to health.
Additionally, adaptability is considered to be ‘high’ since the people will be able to adapt to the
change with ease and maintain a pre-Project level of health. Finally, the likelihood of health
impacts from access to green space is ‘possible’ since it is anticipated that at least some
portion of the City revenue from the Project would be used to improve or expand existing
tideland recreational or green space conditions. Though there is a temporary local adverse
impact to recreational resources due to disturbances to parks and recreation near the Project
Site, overall, the post-mitigation effect is ‘positive’ with respect to health and access to green
space for the proposed Project. It is recommended that a community advisory group be formed
to aid the City in deciding priority for recreational / green space funding.
5.7.3 Community Resources: Aesthetics and Visual Resources
5.7.3.1 Aesthetics and Health
Aesthetic value is a complex concept that is highly subjective. There is a high degree of
individual variability when it comes to the visual impact and/or aesthetic value of an object or a
place. There are several factors involved in whether an individual finds an object or place
visually appealing, including attitude and preconceived notions. Places that are identified as
having a high aesthetic quality have been associated with increased contemplation, personal
reflection, enjoyment, relaxation. An increasing number of studies have considered the impact
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of aesthetics, with a growing consensus general well-being can be improved as a result of
contact with environments considered to have high aesthetic value (Galindo and Rodriguez,
2000; Brady, 2006; Philipp, 2001).
The way that aesthetic value is assessed is an important component of evaluating potential links
to human health and well-being. There are a number of terms (MRS, 2014) that can be used to
objectively describe aesthetics in terms of its elements, character and quality (Figure 5-13).
Figure 5-12 Typical descriptors of aesthetic value as an indication of visual appeal
In a study conducted by Galindo and Rodriguez (2000) a series of photographs (mixed type
landscapes and cityscapes) were provided to test subjects who were asked to rate the
photographs based on their assessment of its aesthetic value. Although there was considerable
difference among individual selections, photographs that were ranked the highest in terms of
aesthetic appeal were identified as having several common factors including:
Presence of vegetation;
Openness;
Feelings of tranquility;
Cleanliness;
Familiarity of surroundings; and,
Absence of traffic/noise/pollution.
Conversely, photographs that were given poor rankings on the basis of aesthetic value lacked
the above components in addition to ‘deterioration and neglect’ as well as ‘feelings of distress’.
Aesthetics
and Visual
Appeal
Land Cover
Dominance
Texture
Scale
Diversity Intactness
Continuity
Vividness
Land Use
Unity
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It is interesting to note that although the presence of buildings and roads were on the list of
reasons to provide a lower aesthetic score, they were not considered as important as the
presence of vegetation (Galindo and Rodriguez, 2000). This provides insight into potential
mitigation options for future development in urban areas.
Another article, published by Brady (2006), explored the potential association between aesthetic
environments and well-being. Although the author tends to focus on the natural environment, it
is acknowledged that there are also benefits from landscapes that provide vital services or
leisure activities. The author points to a number of studies that “support the long-standing nature
tranquility hypothesis, which recognizes the benefits of nature for humans and has had an
important role in urban planning and landscape design, including the work of Frederick Law
Olmstead, who designed Central Park and Prospect Park in New York, among other green
urban spaces” (Brady, 2006). The author concludes that the benefits of both ‘wild’ and
‘cultivated’ nature are clear and that engaging in leisure activities such as gardening or
spending time outdoors can positively impact feelings of tranquility and overall well-being.
Changes in the aesthetics of a local environment have the potential to cause annoyance and
stress, particularly if the change is viewed as intrusive or unwanted. Additionally, something that
is considered necessary and aesthetically pleasing to one person may be unappealing to
another. An example of this is the public’s reaction to wind turbines – some individuals see them
as beneficial and/or beautiful, while others consider them ugly intrusions on the natural
landscape (Pedersen and Larsman, 2008). It has been demonstrated that people who have a
negative attitude toward an environmental change are much more likely to experience
annoyance and stress than those who see the change as positive. Therefore, any potential
impacts resulting from a change in the local landscape aesthetics are expected to be related to
visual cue and attitude rather than to any physiological change.
5.7.3.2 Current Conditions
As part of the EIR, a visual impact analysis was conducted to determine the potential aesthetic
impacts associated with the proposed Project, including an evaluation of the existing (baseline)
visual character and quality of the area. Part of the process of evaluating existing conditions,
included identification of several Key Observation Points (KOP), which were public locations
selected where viewer exposure and sensitivity are both high. The following KOPs were
identified for evaluating aesthetics and visual resources in the areas surrounding the proposed
Project:
Views from/near public roads which serve as a primary or secondary access to residential
subdivision areas or recreation areas:
Pacific Coast Hwy 1 (Primary); KOP 12;
Hermosa Ave (Primary); KOP 9;
Pier Ave (Primary); KOP 3 and 4;
Valley Drive (Primary); KOP 5, 15, 16;
6th Street (Secondary); KOP 10, 13, 14 and 19;
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8th Street (Secondary); KOP 16, 17, and 18;
Views from Recreation Areas:
Hermosa Valley Greenbelt (Veterans Parkway); KOP 2, 15 and 20
Ardmore Park; KOP 20
Civic Center; KOP 5
Community Center (Tennis Court Access); KOP 1
South Park; KOP 11
The Strand; KOP 8
Hermosa Beach; KOP 7
Hermosa Beach Pier; KOP 6
The visual resources in the vicinity of each major project component were evaluated in the EIR
based on different landscape types or units. A landscape type/unit was defined as “an area of
landform plus land cover forming a distinct, homogenous component of a landscape,
differentiated from other areas by its degree of slope and pattern of land cover” (MRS, 2014).
The two landscape units for the proposed Project are 1.) developed/roaded and 2.) open
space/park.
The EIR evaluated baseline aesthetics and visual resources at two distinct areas associated
with Project activities: Project Site and Pipeline.
Project Site:
The proposed Project Site is located in a densely developed area. According to the EIR, the Site
is immediately surrounded by light manufacturing and open space land uses. One- and Two-
family residences and open space borders the light manufacturing district. The built environment
is comprised of primarily one to three-story structures with a relatively high degree of
architectural variety and character. Development of individual parcels has typically been
maximized making buildings the dominant physical/visual feature on most parcels. Planted
landscape features have been integrated where feasible to complement and enhance the built
environment. City streets, parks, the Veterans Parkway (Hermosa Valley Greenbelt), and public
beach provide the public network that links and provides physical and visual access to the built
environment (MRS, 2014)
The Pipeline:
The proposed pipeline would run through the cities of Hermosa Beach, Redondo Beach, and
Torrance, within existing street and utility rights of way. The views along the pipeline route are
consistent with those of a large roadway and include expansive areas of pavement, areas of
streetscape enhancement, landscaping, street lighting and traffic signals. The utility right of way
includes large transmission towers, areas of undeveloped grassland (Metering Station site), an
entry monument for the City of Redondo Beach, a container plant nursery and a dog park
(Dominguez Park) (MRS, 2014).
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5.7.3.3 Project Impact
The potential for aesthetic impacts examined in the HIA include two major components of the
Project:
1. The proposed Project (Phase 1-4); and,
2. The Pipelines.
Both could significantly alter the existing character and quality of the visual environment.
Aesthetic Regulations:
Various regulations and guidelines are in place for aesthetics, visual resources, vistas, light and
glare that relate to the development of the Proposed Project. These include the California
Coastal Act, City of Hermosa Beach General Plan, City of Redondo Beach General Plan, City of
Torrance General Plan, and local planning and zoning ordinances. The following excerpts have
been taken from the EIR and focus on those aspects of the regulations/guidelines that are
intended to address visual impact and the aesthetic environment (MRS, 2014).
California Coastal Act (Scenic and Visual Qualities)
The scenic and visual qualities of coastal areas shall be considered and protected as a resource
of public importance. Permitted development shall be sited and designed to protect views to and
along the ocean and scenic coastal areas, to minimize the alteration of natural land forms, to be
visually compatible with the character of surrounding areas, and, where feasible, to restore and
enhance visual quality in visually degraded areas.
City of Hermosa Beach General Plan
The City of Hermosa Beach General Plan stipulates that introduction of massive land uses such
as large buildings or new transportation corridors should be carefully evaluated. The Plan is
concerned with abrupt changes in scale and form resulting in a land use overwhelming another.
But it suggests that this visual shock can be lessened by generous landscaping and limiting the
apparent size of buildings and parking lots near the boundary.
City of Hermosa Beach Municipal Code
The Municipal Code identifies certain requirements for building height and landscaping, which
could affect visual quality of the Project Site and surrounding area. Manufacturing and
commercial facilities are required to ensure that the appearance and effects are harmonious
with the character of the area which they are located. Additionally, building height is restricted to
35 feet with a maximum of two-stories. Oil and gas operations are an exception and may
exceed this height for a temporary period of time, which requires approval of a conditional use
permit (MRS, 2014). Finally, all yard or open areas must be attractively landscaped and
permanently irrigated.
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Local Coastal Plan
It requires local coastal communities to develop plans for the preservation, enhancement and
access to their coastal zone areas. The City of Hermosa Beach developed their Local Coastal
Plan in 1981. The plan states "that the City should restrict building height to protect overview
and viewshed qualities and to preserve the City's' existing low-rise profile".
All Project Phases:
Evaluation of aesthetic and visual resource impacts can be subjective in nature, and therefore
requires that an objective methodology be established (MRS, 2014). The process used in the
EIR was adapted from the guidelines used by the Federal Highway Administration for
assessment of visual impacts. Impact intensity was established based on evaluating the
baseline environmental setting and visual conditions against those depicted in the photo
simulations.
Based on the results of the EIR visual assessment, the majority of Project-related activities
(including pipeline construction) that have the potential to impact the aesthetics of the local
community would be sufficiently diminished by existing operational design features and, where
applicable, with additional mitigation measures (MRS, 2014). The exception to this is the
presence of the electric and workover drill rigs that would be on the Project Site for a portion of
Phase 2 and Phase 4. For this reason, it is not anticipated that visual impact from project-
related activities, other than the presence of the drill rigs, will result in substantial negative
impacts on health. A closer assessment of potential impacts resulting from aesthetics
associated with drilling activities during Phase 2 and Phase 4 is provided below.
Presence of the Electric Drill Rig (Phase 2 and 4):
The 87-foot electric drill rig with three-sided acoustical shield would be installed at the Project
Site at the beginning of Phase 2 (MRS, 2014). The presence of the rig on-site during this phase
is expected to last approximately five months (four months drilling with two-week setup and two
week take down). The rig would introduce a visually dominant vertical feature that is distinct in
form, mass, height, material and character from structures in the viewshed of locations which
are considered to have high sensitivity. For the fivemonths that it is up during this phase, the rig
would break the skyline and become a dominant focal point (MRS, 2014).
The 32-foot sound wall constructed at the end of Phase 3 is proposed to remain on site during
the first 2.5 years of Phase 4. The presence of the block wall would help to divide the mass of
the sound attenuation wall, however the overall form, scale and lack of visual articulation would
be uncharacteristic of the surrounding environment. Over time the surrounding landscape would
mature and its capacity to soften the impact of the block retaining wall would increase. At the
conclusion of drilling, the 32-foot sound wall and electric drilling rig are proposed to be removed
from the site. Impacts associated with the electrical drill rig are similar for Phase 4, with an
increase in duration to 2.5 years. The period with the drill rig onsite would produce substantial
degradation of the existing visual character and would be a significant impact (MRS, 2014).
During periods of Phase 4, the workover rig (110 feet) could be present on site for up to 90 days
per year. The structure of the workover drill rig introduces a focal element of industrial character
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into viewsheds of primarily residential and light industrial land use. Similar to the electric drill rig,
this visual element would extend higher than other structures in the surrounding area and would
provide a focal point against the skyline. It is possible that the workover rig could be set up at
the Project Site up to 15 times per year. Since these operations have the potential to occur
periodically throughout the year, this introduces the possibility for collective recurring visual
impacts over the 30-35 year length of Phase 4 (MRS, 2014).
Based on the aesthetics assessment conducted as part of the EIR, the following mitigation
measures are proposed to reduce and/or eliminate potential impacts to the local cityscape (AE-
1a to AE-1b; AE-2a to AE-2d; AE3a to AE-3c) (MRS, 2014):
Material choice of electrical drill rig acoustical shroud shall be of neutral sky color which
is selected for its ability to reduce visual impact.
The sound attenuation wall shall be replaced by a permanent wall with design features
installed at the end of Phase 3. The intent is to provide stability of views and
opportunities for positive visual elements that partially mitigate the visual presence of the
walls from the Hermosa Greenbelt and other sensitive views in the immediate Project
vicinity. Landscape design shall be allowed to be adjusted to respond to façade
articulations, though quantities and densities shall be maintained.
Design of the sound attenuation wall exterior façade shall be required to include design
articulations that are complementary to the character, scale, and quality of the
surrounding environment.
Planting area growth medium shall be capable of supporting the long term health and
growth of the landscape design.
Vine plantings where used shall meet the following conditions: 1) be self-attaching or
structure supported; 2) have demonstrated success in the City; 3) be planted at a
density to achieve full coverage at maturity; 4) be planted at a minimum 5 gallon size;
and 5) be required on the visible portion of the west wall at the temporary parking facility.
All trees shall be required to be a minimum of 20’ in height at installation and meet the
American Standard for Nursery Stock.
Pipeline alignments and valve box locations shall be designed to avoid the removal or
modification of trees, hedgerows, and/or large shrubs to the extent feasible.
If landscaped areas, streetscapes, plazas and/or parklands are required to be
temporarily disturbed, they shall be restored to their previous condition following
completion of construction. Avoidance of disturbance shall be the preferred option,
especially where landscape elements act to screen views (hedges, large shrubs, etc) or
where they act as community gateways (Redondo Beach at Hwy-1).
Block color/s selection and pattern (if applicable) shall be complementary to adjacent
buildings. A buffer of shrubs and vines shall be planted to match the existing character
and quality of the adjacent properties.
Following the implementation of mitigation measures, visual impact and aesthetics would be
significantly improved for activities associated with Phase 1-4. However, the impacts of the
proposed Project while the drill rigs are on site are still considered to ‘substantially degrade the
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visual environment’ (MRS, 2014). Due to the height of the electric and workover drill rigs, there
would be a noticeable change in the overall skyline that would be more prominent at locations
closer to the Project Site but would be visible from many different parts of the community.
Although the proposed mitigation to select a ‘neutral sky color’ for the electric drill rig drastically
improves the visual impact of the structure by decreasing its prominence against the skyline
(Figure 5-14 and 5-15), it is still considered outside of the typical character of the area.
Consequently, the presence of the drill rig may influence individual levels of annoyance and
stress associated with the local environmental change. Visual cue and attitude have been found
to be highly associated with levels of annoyance from different types of environmental change.
For example, studies conducted on wind turbine developments have found that visual cue and
attitude were found to be more highly correlated with annoyance levels from wind turbine
installations than from noise or other potential emissions (Bakker et al., 2012; Janssen et al.,
2011; Pedersen and Larsman, 2008). Although the presence of the drill rigs will have a negative
impact on the local scenery, and may contribute to increased annoyance and stress in some
individuals, it is not anticipated to pose a serious health effects.
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Figure 5-13 Key Observation Point (KOP) 7: Existing and During Phase 2 and 4 with Drill
Rig (MRS, 2014)
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Figure 5-14 Key Observation Point (KOP) 18: Existing and During Phase 2 and 4 with
Drill Rig (MRS, 2014)
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The impact of change in aesthetics and visual resources due to the proposed Project on the
health of the community is provided in Table 5-33.
Table 5-33 Community Livability Assessment: Aesthetics and Visual Resources
Health Determinant Aesthetics and visual resources
Potential Health Outcome Annoyance and stress from negative perceptions and anxiety
over project aesthetics
Pre-Mitigation Discussion Potential for increased annoyance and stress as a result of
Project implementation (all phases) without mitigation
EIR Mitigation Aesthetic and visual mitigation measures: AE-1a to AE-1b; AE-
2a to AE-2d; AE3a to AE-3c
Geographic Extent Community
Vulnerable Populations None
Magnitude Medium
Adaptability Medium
Likelihood Possible
Post-Mitigation Health Effect Negative
Comments or Additional
Recommended Measures
The overall impact is negative based on the aesthetic
environmental change leading to increased levels of
annoyance and stress in some individuals.
The pre-mitigation impacts of the proposed Project on the aesthetics around the project area
are considered negative for all Phases. The EIR has identified design features and additional
mitigation measures (building requirements, stylizing, and landscaping) that will significantly
improve the visual impact of the project overall. The geographic extent of changes in aesthetics
and visual resources is classified as ‘community’ since the presence of the drill rigs on the
Project Site will be visible outside of the immediate area. There were no vulnerable populations
identified for aesthetics and visual resources; therefore, it was classified as ‘none’. The
magnitude of the aesthetic changes is classified as ‘medium’ since the extent of the impact is
detectable, it is reversible, and poses a minor hazard to health. Adaptability to this type of
environmental change is ‘medium’ given that not all individuals will adapt to the change (i.e.,
modified landscape) with ease; this is true regardless of the proposed EIR mitigation measures
and their ability to substantially reduce negative visual impacts. The likelihood is ‘possible’
since there is potential for the impact to occur on a regular basis due to the presence of the drill
rigs during Phase 2 and 4; however, they are not permanent fixtures. Overall, there is a
‘negative’ impact resulting from the aesthetics associated with presence of the drill rigs and
their alteration of the existing landscape. The result of this impact is an increase in annoyance
and stress for some individuals. No additional recommendations have been made.
5.7.4 Community Resources: Education Funding
5.7.4.1 Education and Health
Education was identified as a community resource that residents consider important to overall
quality of life. Not only does education contribute to economic measures of success (e.g.
income, employment, occupation), but it has also been shown to promote social well-being
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indicators including increased civic engagement, reduced crime and increased social and
emotional skills (OECD, 2010). Some of the major concluding statements made in the OECD
report relate specifically to the relationship between education and overall health and well-being:
“A large body of literature suggests that education is strongly associated with a
variety of social outcomes, such as better health, stronger civic and social
engagement, and reduced crime. A smaller number of studies further suggest that
education has a positive effect on most of these social outcomes. More importantly,
from a policy perspective, education has been shown to be a relatively cost-effective
means of improving health and reducing crime”
“Education helps individuals make informed and competent decisions by providing
information, improving their cognitive skills and strengthening their socio-emotional
capabilities, such as resilience, self-efficacy and social skills. As such, education can
help individuals follow healthier lifestyles, manage illness, increase their interest in
political issues…and offer an ideal environment for children to develop healthy habits
and participatory attitudes.”
5.7.4.2 Current Conditions
The Hermosa Beach City Elementary School district is of a much higher quality than the state
average and is ranked in the top 4% nationwide (US News, 2013). Only 2% of Hermosa Beach
residents have less than a high school degree, whereas >19% of California residents do not
graduate high school (US Census, 2009). According to the Community Dialogue committee on
quality of life, parents and teachers work in a collaborative environment that is supportive of
students, and the community is actively involved in major fundraisers to assist and promote the
success of its schools (see Appendix F).
The Hermosa Beach Education Foundation (HBEF) is a 100% volunteer organization that raises
money to support student programs. In 2012, HBEF contributed a total of $1,290,038 to benefit
all grade levels in Hermosa Beach City School District. These private donations go towards
funding programs like science labs, libraries and elective classes like journalism, drama,
technology and art. Looking forward, residents have indicated that they would like to continue to
work with the local school district in order to maintain and further improve the quality of
education.
Additionally, in order to support after-school recreational programs, the City of Hermosa Beach
expanded its Positive Active Recreation for Kids (PARK) program that focuses on crafts and
sports.
5.7.4.3 Project Impact
The proposed Project is anticipated to influence educational funding by providing the local
school district with an annual monetary contribution (for the 35 year life of the Project), as
contractually required under the lease. Additional school district funding would further enhance
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education programs in Hermosa Beach, and therefore improve the social and economic health
outcomes among schoolchildren throughout the community.
With respect to potential revenues for the Hermosa Beach School District, based on production
estimates completed as part of the CBA, it was estimated that the school district would receive
net revenues of approximately $1.2-3.2 million, over the 35 year life of the Project (Kosmont
2014). Since the annual amount of School District funding from the proposed Project depends
on the amount of oil produced, the Cost Benefit Analysis estimates a range that Hermosa Beach
schools may receive per year. Based on the CBA Expected case the School District would
receive a minimum of $10,000 per year and a maximum of $130,000 the year of peak
production (average of approximately $52,000 per year). Whereas, based on the Applicant’s
production estimates, the School District would receive a minimum of $10,000 per year and a
maximum of $360,000 the year of peak production (an average of approximately $112,000 per
year) (Kosmont 2014). This average annual contribution to the Hermosa Beach City School
District would increase private funding between 4% (based on average CBA Expected) and 9%
(based on average Applicant estimates). Although this contribution is modest compared to the
amount of money raised by the HBEF, it is available to be used at the discretion of the district
and will facilitate continued provision of top quality education in Hermosa Beach for decades.
The impact of additional education funding due to the proposed Project on the health of the
community are provided in Table 5-34.
Table 5-34 Community Livability Assessment: Education Funding
Health Determinant Education Funding
Potential Health Outcome Increased resources and funding for education can indirectly
lead to a more positive health status
Pre-Mitigation Discussion Not Applicable
EIR Mitigation Not Applicable
Geographic Extent Community
Vulnerable Populations Schoolchildren
Magnitude Medium
Adaptability High
Likelihood Probable
Post-Mitigation Health Effect Positive
Comments or Additional
Recommended Measures
None
Educational funding that is to be provided to the local school district is related to Project
production; however, there are no construction or operational issues that would require
mitigation in relation to this determinant. Therefore, a discussion of pre-mitigation impacts and
EIR measures is ‘not applicable’. The geographic extent of impacts are classified as
‘community’ since the funding is being provided to the district and is not assigned to a
particular school, subject or grade-level. The vulnerable populations identified for education
funding are ‘schoolchildren’. The magnitude is classified as ‘medium’ since the impact is
detectable and poses a minor to moderate benefit to health. This is based on findings in the
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literature that support education as a cost-effective method of improving health (OECD, 2010).
Adaptability is considered to be ‘high’ since the funding will become a part of the regular annual
budget for the duration of the Project and the community will be able to maintain (if not improve)
their pre-Project level of health. Further, the likelihood of prolonged beneficial health impacts
brought on by increased educational funding are anticipated to the ‘probable’ since the impacts
are expected to persist over time and there is an established link between education, and
present/future health and well-being indicators. Overall, the post-mitigation health effect of
increased funding for education in Hermosa Beach is expected to be ‘positive’. Therefore,
based on the assessment, no additional measures are recommended.
During preparation of this report, a draft development agreement (City of Hermosa Beach,
2014) was released that contains some consideration of supplemental education funding. The
draft agreement states that “E&B proposed additional funds for the schools to be provided by
way of a separate agreement with the Education Foundation or other non-profit organization…”
(City of Hermosa Beach, 2014). The HIA has identified a positive effect resulting from increased
education funding and any additional increase (i.e., through a supplemental funding agreement)
would further enhance this potential benefit.
5.7.5 Social Cohesion
5.7.5.1 Social Cohesion and Health
Social cohesion is a complex concept. The earliest known definition of social cohesion identifies
it as an ordering feature of a society, and defines it as “the interdependence between the
members of a society, shared loyalties and solidarity” (Jenson 1998). Due to its inherent
complexity, there are many different aspects of social cohesion including (Berger-Schmitt,
2000):
The strength of social relations;
Shared values and communities of interpretation;
Feelings of common identity and a sense of belonging to the same community;
Trust among societal members; and,
The extent of inequalities and disparities.
As an indicator of health, social cohesion is linked to the idea of ‘quality of life’ which is
associated with certain aspects of health and well-being. However, it is important to distinguish
between a lack of social cohesion occurring because of differences of opinion among different
community groups, or because of a lack of individual social support in the form of personal ties
to family, friends, etc. (Berger-Schmitt, 2000). Studies have shown that strong social cohesion
and support contributes to self-esteem and strengthens a person’s ability to handle stress
(Cohen et al. 2000; Poortinga, 2006).
5.7.5.2 Current Conditions
Hermosa Beach is a community that has a high level of well-being and other elements that
contribute to positive social cohesion (Blue Zones, 2012). Furthermore, well-being has
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increased in these communities over the last few years, whereas levels in California and the US
have remained static. According to the baseline health assessment (Appendix E) that examined
the results of the Blue Zones Project:
“The baseline survey of 1,332 Beach Cities residents was conducted in 2010. Among its
major findings was that the overall well‐being rating for residents of Hermosa, Manhattan
and Redondo was higher than the California average and above the top tier of other
cities. More than 90 percent of local residents said they had access to health care,
health insurance and enough money for food, shelter and other basic needs.”
As discussed in the EU Report ‘Social Cohesion as an Aspect of the Quality of Societies’
(Berger-Schmitt, 2000), fundamental elements such as housing, transportation, community
resources and social programs all contribute to the fabric of a community and influence the
potential for cohesion. However, even when all of the key components are present, social
cohesion can be disrupted by controversial issues and divided opinions. In these situations,
severe disruptions in social cohesion can potentially contribute to increased stress.
According to a recent poll, 46% of Beach Cities residents (from Hermosa, Manhattan, and
Redondo Beaches) felt stressed for most of the day. The poll suggests that there is room for
improvement in some areas including; daily stress and worry, treating one another with respect,
and being more well-rested (Blue Zones, 2012). Baseline indicators suggest that Hermosa
Beach residents are healthy and active, with an exceptionally high level of well-being; however,
they may benefit from taking measures to reduce stress in general.
5.7.5.3 Project Impact
Social cohesion is an intricate concept that does not readily lend itself to empirical
measurement. However, based on input from community members during the Open House and
scoping meeting, community politics surrounding the impending vote is distressing to some.
Some local residents have voiced concerns about the situation causing a division in the
community – those in favor of oil development versus those opposed. Additionally, there is
some worry that the proposed Project could highlight this disagreement and cause friction
among individuals. Out of a city of almost 20,000 people, approximately 400 people showed up
to the HIA public scoping meeting to voice their opinion on the Project. It is reasonable to
assume that those people in attendance were likely interested (whether supportive or critical of
the Project) in the issue and that most of the people who did not show up were either unable or
uninterested. However, it should be noted that the community Open House was held on a
weekend (9 am-2 pm) during summer and the HIA public scoping meeting was on a weeknight
(7 pm-10 pm) in the fall in order to accommodate as many people as possible. Therefore, it is
unlikely that a large proportion of the community was unable to attend either of the public
forums due to scheduling conflicts. Since there are many residents who did not attend public
meetings, the impact to social cohesion due to political friction is likely a limited impact. It is not
anticipated that the community as a whole is experiencing a distressing lack of social cohesion,
to the point of adverse health implications, over this issue.
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If some disruption in social cohesion does occur for some members of the community, as a
result of differing opinions on the proposed Project, it is important to remember that social
cohesion is based on more than a single disputed issue. Instead, it is based on a large number
of factors related to the accessibility and functionality of a community as a whole including:
housing conditions, access to quality transportation, access to and investment in education,
employment opportunities, income and standard of living, and many more (Berger-Schmitt
2000).
It is also important to discuss the fact that people often have differences of opinion or have
disagreements regarding certain issues; this is not an uncommon phenomenon. There are
many issues that can arise (at home, at work or in other social settings) and lead to different
points of view. The health implications of this are largely dependent on an individual’s conflict
management skills and ability to deal with stressful situations. Although it is not ideal to be in a
stressful situation, there are many ways to alleviate stress and these activities should be
incorporated into normal routine.
The impact of the proposed Project on the social cohesion of the community is provided in
Table 5-35.
Table 5-35 Community Livability Assessment: Social Cohesion
Health Determinant Social Cohesion
Potential Health Outcome Potential increase in stress
Pre-Mitigation Discussion Not Applicable
EIR Mitigation Not Applicable
Geographic Extent Community
Vulnerable Populations None
Magnitude Low
Adaptability Medium
Likelihood Possible
Post-Mitigation Health Effect No substantial effect
Comments or Additional
Recommended Measures
None
With respect to pre-mitigation impacts and EIR mitigation measures, these were considered ‘not
applicable’ since there is no Project construction or operational issue that can be changed with
respect to social cohesion. As discussed previously, the extent of the potential impact is
‘community’ since it affects all of Hermosa Beach; however, only a subset of the population is
expected to experience any disruption in social cohesion (leading to a potential increase in
stress) as a result of the proposed Project. There were no vulnerable populations identified for
impacts to social cohesion; therefore, it was classified as ‘none’. The magnitude is ‘low’ since
the impact is minor, temporary or reversible, and does not pose a significant hazard to health.
This classification is based on the concept that social disagreements can happen for a variety of
reasons, but they are generally repairable and are largely based on individual factors. The
adaptability is considered ‘medium’ since individuals will be able to adapt and maintain a pre-
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Project level of health, although some support may be needed. Although it is believed that the
majority of the community will not experience any disruption in social cohesion, those individuals
that do may seek support to overcome feelings of stress over personal disagreements. The
likelihood some level of discord occurring from the proposed Project is ‘possible’ since it the
Project is considered controversial; however, this potential impact is anticipated to subside over
time following the vote. Therefore, it stands to reason that timely resolution of this issue would
be beneficial. Overall, there is considered to be ‘no substantial effect’ from changes in social
cohesion as a result of the proposed Project. Although we understand that tensions brought on
by this Project may have interrupted social cohesion amongst a subgroup of residents, it is not
anticipated to overall impact community health. Therefore, no additional measures are
recommended.
5.7.6 Political Involvement
5.7.6.1 Political Involvement and Health
One indicator of a healthy community is a high degree of public participation in and control over
the decisions affecting one’s life, health, and well-being. Involvement in community
organizations and the political process are ways that individuals exercise control over decisions
that affect their lives (Kawachi et al., 1997).
In the peer-reviewed literature on this subject, group membership and political participation are
significantly associated with human health outcomes:
An analysis of data from 40 diverse U.S. communities showed that people who were
involved in electoral participation were 22% less likely to report poor/fair health (Kim
et al., 2006).
A study examining neighborhood environment in England and Scotland, found that if
political engagement was low, people had 52% higher odds of reporting poor health
(Cummins et al., 2005).
A higher level of civic engagement through ties to community groups was associated
with increased recall of cardiovascular disease health-promoting messages in a
longitudinal cohort from the Minnesota Heart Health Program (Viswanath, 2006).
Community and political engagement also increase people’s self-efficacy, which is the
perceived ability to affect change in one’s life. In a report entitled ‘Social Cohesion as an Aspect
of the Quality of Societies’ (Berger-Schmitt, 2000) identified “political activities and engagement”
as an aspect of strengthening self-efficacy and the social capital of a society. A strong and
integrated social capital was identified as a positive indicator of ‘social cohesion’, which was
also assessed in this HIA (Section 5.5.4).
5.7.6.2 Current Conditions
To our knowledge, there are no publically available data to document the current status of
political involvement among Hermosa Beach residents. However, as part of the Community
Dialogue process, the committee defined “accessible city government and citizens who are
actively involved” as an important quality of life factor that describes the identity of Hermosa
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Beach. Since this committee is made up of local residents, this suggests that at least a subset
of the community is actively involved in some respect.
5.7.6.3 Project Impact
As part of the legal settlement, there is a unique opportunity in Hermosa Beach for voters to
decide for themselves whether to open the community to oil drilling. The City has encouraged
community participation throughout the entire process of evaluating the potential impacts of the
proposed Project (i.e., EIR, CBA and HIA). Community turnout at the public meetings was
respectable, with approximately 300-400 people in attendance. Additionally, approximately 300
people participated in the HIA scoping survey to identify key areas of interest to community
members. The Community Dialogue is a group of 15-30 community members who are engaged
in activities to help define the quality of life and the vision for the future of Hermosa Beach. The
public review process for the EIR and HIA will provide a vehicle for participation from a broader
community, including both those in favor of and opposed to the proposed Project.
The impact of having a community that is able to actively participate in the political process, and
ultimately decided whether the proposed Project is approved, is strongly associated with
positive health and well-being (Berger-Schmitt, 2000). Studies show that for many industrial
projects where the decision is based on government (or other regulatory) approval, there is a
loss of self-efficacy, increased stress and a feeling of no control (Frumkin, 2010). Because all
adult residents will have the chance to vote, everyone in Hermosa Beach has the opportunity to
benefit from the opportunity to influence the political process. Ultimately, the decision of whether
to move ahead with the proposed Project is in the hands of the community members
themselves, which is a rare opportunity with positive health implications. Although the option to
vote is open to all, it is unlikely that everyone will participate to the extent that they will benefit
from the positive health effects related to political engagement. It is important to note that if
community members were not allowed to vote on this issue, there would likely be higher rates of
stress and anxiety due to a lack of control and loss of self-efficacy.
The impact of the degree of political involvement afforded by the proposed Project on the health
and cohesion of the community is provided in Table 5-36.
Table 5-36 Community Livability Assessment: Political Involvement
Health Determinant Political Involvement
Potential Health Outcome Increase in self-efficacy and positive impacts on health and
well-being over communities ability to vote
Pre-Mitigation Discussion Not Applicable
EIR Mitigation Not Applicable
Geographic Extent Community
Vulnerable Populations Voters
Magnitude Medium
Adaptability High
Likelihood Possible
Post-Mitigation Health Effect Positive
Comments or Additional
Recommended Measures
None
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Due to the nature of this health determinant, there are no mitigation measures listed in the EIR
and thus, a discussion on pre-mitigation impacts is not applicable. The geographic extent of
positive impacts, it is classified as ‘community’ since all adult residents of Hermosa Beach will
have the opportunity to vote. The vulnerable populations identified for political involvement are
‘voters’. The magnitude is classified as ‘medium’ since the impact of the community being able
to vote on the decision themselves is detectable and poses a minor to moderate benefit to
health. Additionally, the ability of the community to adapt and maintain a pre-Project level of
health is considered to be ‘high’, since political involvement is anticipated to at least provide the
opportunity for pre-Project health status, if not fostering additional improvements in overall
health and well-being. This is anticipated since, regardless of the outcome, each community
member will have had the opportunity to participate in the political process and cast their vote.
This level of self-efficacy has been shown to be associated with positive psychosocial health
status (Smith et al 2008). Lastly, the likelihood of the impact is ‘possible’ since there is potential
for a positive impact to occur but political involvement is an individual decision and although the
option to vote is open to all, it is unlikely that everyone will participate. Overall, the health impact
of this type of political involvement, particularly the power to vote on the issue, is considered to
be ‘positive’. Therefore, based on findings from the political involvement assessment, no
additional measures are recommended.
5.7.7 Summary and Conclusions for Community Livability
Commercial and industrial developments have the potential to impact local property values. The
complexities around property value fluctuations make it difficult to accurately evaluate the
potential impact from one project. The
CBA concluded that property values
within Hermosa Beach could be impacted
by 0-10%; and it was suggested that any
decrease in property values is likely to be
localized. Any perceived or actual
decrease has the potential to moderately
increase stress and anxiety among
Hermosa Beach residents, which is
suggestive of a negative effect on human
health.
Access to recreational areas and green
space is an important community resource and can be a key component of overall health and
well-being. Hermosa Beach residents are considered to be very active due to their proximity to
the beach, access to parks and availability of recreation and fitness facilities. While the
proposed Project would not be removing any existing green space in the community, it will be
located adjacent to a park, near other parks, and near walking and biking travel routes.
Disturbances during pipeline and Site construction could temporarily affect ready access of
recreational resources or the quality of the recreational experience. On the other hand, Project
revenue could be used to enhance recreational resources, and it is predicted that there will be
The community livability assessment within
the HIA concludes that with implementation
of the proposed EIR mitigation measures
there is: no substantial effect on human
health with respect to social cohesion; a
potential negative effect from stress over
property values, aesthetic/visual resources;
and a potential positive effect on health from
enhanced recreation and green space,
educational funding and political
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an overall positive impact on community health in regards to recreational areas and green
space.
Aesthetic value is a complex concept that is highly subjective. There is a high degree of
individual variability when it comes to the visual impact and/or aesthetic value of an object or a
place. The presence of the electric and workover drill rigs during Phase 2 and 4 have the
potential to negatively impact health by diminishing the aesthetic appeal of the landscape. This
has the potential to influence levels of annoyance and stress. Therefore, the post-mitigation
health effect is considered negative.
Educational funding can provide improvements in some of the key indicators of socioeconomic
status (i.e., occupation and income) and has been described as a cost-effective method of
increasing health and well-being. Hermosa Beach has one of the top school districts in the
country and the modest increase in annual funding that will be provided to the schools as a
result of revenue from oil production is expected to have a positive effect on health now and in
the future.
Social cohesion is a complex concept that is difficult to measure. As an indicator of health,
social cohesion is linked to the idea of ‘quality of life’ which is associated with certain aspects of
health and well-being. Hermosa Beach residents experience higher levels of well-being than
most California cities. Although it is not expected that all residents will experience a reduction in
social cohesion due to differences of opinion, some individuals may. For those residents, this
could result in increased stress; however, social cohesion is not considered to have a
substantial effect on community health.
Active involvement in local politics is associated with increased self-efficacy and can have
positive impacts on health and well-being. Hermosa Beach residents have the unique
opportunity to decide whether the proposed Project can go ahead by voting on whether to allow
oil drilling within the City. This opportunity extends to all adult members of the community,
although only a subset of the population is actively involved in the politics and may benefit from
the positive impact on health.
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6.0 ADDITIONAL RECOMMENDATIONS, MONITORING AND EVALUATION
The EIR provided a comprehensive and detailed list of mitigation measures legally required to
be implemented if the Project moves forward. As the Lead Agency, the City would be required
to adopt a program for reporting or monitoring regarding the EIR-specific mitigation measures
for the Project, under Public Resources Code Section 21081.6(a) (Findings) and the CEQA
Guidelines Sections 15091(d) (Findings) and 15097 (Mitigation Monitoring or Reporting) (MRS,
2014).
The City could consider negotiating these recommendations in the Development Agreement
with E&B.
6.1 Recommendations
Odor
In the case that reports of odor become frequent, additional studies and/or air monitoring, for
control measures for odor may be warranted.
Upset Scenarios
The spills and blowout assessment within the HIA concludes that there is a low probability of
occurrence but in the event such an upset condition was to occur it could have significant
negative health implications. This is particularly true in the case of a well blowout. The HIA
recommends that City of Hermosa incorporate the possibility of an oil spill or well blowout into
their public preparedness awareness program. While the facility is required by regulation to
have emergency response plans in place, the preparation of an up-to-date emergency
preparedness plan for the community is the duty of the City of Hermosa Beach Emergency
Preparedness Advisory Board.
Noise and Light Emissions - Noise
For Phase 3 pipeline construction, it is recommended that local residents and schools be
provided written notification of the impending work that identifies the potential for excess noise
and outlines the location and duration (expected to be short-term: one week) of the impacts.
The notices should also indicate that construction activities would not occur during nighttime
hours.
Noise and Light Emissions - Light
For people who have a direct line-of-sight from their bedroom window to the exposed side of the
electric drill rig, there is some potential for interference with typical sleeping patterns. For these
individuals, it is recommended that E&B provide black-out blinds or curtains to eliminate the
potential for infiltration of nighttime lighting from the drill rig for those residents who request
them. This is not to suggest that it is essential that residents receive these blinds to protect their
health, rather it is a potential solution for those who consider the lighting a serious nuisance. It is
recognized that many of the residents of Hermosa Beach may sleep with windows open and this
optional measure is not intended to disrupt lifestyle choices. Such measures have also been
successful for rural communities living in proximity to wind turbines that are lit at night.
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Community Livability – Property Values
To reduce potential stress or anxiety that local property owners may experience as a result of
the proposed Project the Applicant could consider having a property value analysis conducted
prior to construction, during construction and one year into operations. This analysis would need
to take into consideration local, regional and national fluctuations in property values and
compare and contrast the data against potential changes in the value of properties located near
the proposed Project. This would help to ensure that any observed fluctuations on property
values remain within expected levels and consistent with other similar communities.
Additionally, the Applicant could consider stabilizing “proven” impacts to property values,
perhaps through an arbitration process.
During preparation of this report, a draft development agreement (City of Hermosa Beach,
2014) was released that contains some consideration of stabilizing property values. The draft
agreement states that “similar to Huntington beach, E&B proposed setting up and funding an
account that would stabilize proven impacts to property values for 5 years (during drilling) for
properties in close proximity to the project. E&B clarified that the timeframe was undecided at
this time. It further clarified that the residents would need to voluntarily apply for this program.”
(City of Hermosa Beach, 2014). This proposal is similar to the additional mitigation
recommended in the HIA to further reduce potential impacts from stress and anxiety over
property value fluctuations.
Community Livability – Access to Recreational Resources and Green Space:
To maximize health benefits from enhanced access to green space and recreational activities
the City should consider a community advisory group on how to spend revenue.
6.2 Monitoring
The requirement for the mitigation monitoring program is detailed in Section 8.0 of the EIR
(MRS, 2014). Throughout the life of the proposed Project there would be EIR mandated and
potentially additional regulatory monitoring requirements (e.g., air quality, surface water
containment, odor, noise, and contaminated soil removal). Monitoring of this nature will ensure
that predictions in the EIR (and subsequently relied upon in the HIA) were accurate and that
conclusions on environment and health were based on accurate data predictions.
The recommendations in the HIA do not require formal monitoring outside those already
required by the EIR. However, the HIA Team believes that monitoring of community livability
and quality of life indicators could be important for understanding whether the Project (Phases 1
to 4) may influence certain aspects of community livability in Hermosa Beach. The following
monitoring recommendations have been made for the City to consider including in discussions
around the Development Agreement.
Community Liaison Committee (CLC)
Consideration should be given to forming a Community Liaison Committee (CLC) if the Project
is approved, and prior to commencement of construction activities. These CLCs have proven to
be very useful in the other situations involving industrial development in proximity to
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communities, including the waste-to-energy municipal waste sector. The term CLC is used to
distinguish it from other Community Advisory Groups formed by the City. The CLC would be
comprised of a small number of City staff, E&B, and local residents. Typically, a call would go
out for interested citizens to apply to become a member of the committee, with selection of
members being conducted jointly between City staff and E&B. The CLC would serve as the
vehicle through which citizens could voice active concerns about Project activities. These
concerns could be raised indirectly through the committee representatives or directly presented
to the committee as a whole. The intention of the committee would then be to work collectively
to find ways to address residents’ concerns. The CLC could meet monthly, quarterly or semi-
annually depending on the level of concern raised within the community. Once the Project is
fully operational the CLC would still be expected to meet semi-annually to review environmental
monitoring and compliance data. In no way should the CLC replace the responsibilities or legal
requirements of the Lead Agency. The cost for such a committee would be dependent largely
on access to meeting space and on whether an external facilitator was to be used. Community
member representation would be volunteer, unpaid positions.
Follow-up Community Health Assessment
In terms of direct community health monitoring, the health statistics reported in LA County and
state-wide databases, including data on mortality, cancer rates, birth outcomes, and others,
could be monitored to assess whether or not any changes from baseline occur. Analysis of
health statistics by vulnerable population status could identify whether some groups are
disproportionately impacted by Project operations. These retrospective health reviews are
useful but it should be recognized that based on data lag times they typically report on health
outcomes two or more years after they occur. An update to the baseline health study could be
completed five years after the Project becomes operational, but its requirement would depend
on the level of concern within the community at that time. The design of the community health
assessment, including indicators to be included, analysis methodology, and timing of
monitoring, should be developed with input from stakeholders, the City and the Applicant. If the
proposed Project moves forward and community health monitoring is approved, the City should
work with the Applicant to hire the appropriate party to develop the scope and conduct the
study. Such an undertaking is difficult to scope at this point but would likely cost $50,000 to
$100,000.
Quality of Life (QOL) Health Survey
Hermosa Beach is recognized as a healthy city with favorable demographic health indicators
and mortality rates, compared to other cities in California and LA County. However, there are
limited data available to quantify potential health impacts of the Project on sleep disturbance,
stress, social cohesion and other quality of life factors. A quality of life (QOL) health survey
could be used as a tool to establish current baseline conditions, and to monitor whether health
status changes during the Project. There are well established survey tools available (SF-36 and
Pittsburgh Sleep Quality Index [PSQI]) that could be employed. The most cost-effective means
of delivering these surveys would be on-line; however, data quality collection can be
compromised. Mail drops could also be considered. This survey would then be followed up after
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operations began. The costs for a properly conducted QOL survey in the community with follow-
up would again range from $50,000 to $100,000.
6.3 Evaluation
Although not a component of all HIAs, the evaluation step can demonstrate the effectiveness of
HIA in the planning process by assessing what the HIA actually achieved. An internal evaluation
of the overall approach and effectiveness of the HIA will be conducted by Intrinsik’s HIA Team.
The City of Hermosa Beach may also wish to evaluate the utility of the HIA to identify aspects of
the process that were beneficial, and those that could be enhanced, if HIAs are going to be
conducted in the future.
As part of the internal HIA evaluation, the Intrinsik team will conduct both a process evaluation
and an impact evaluation (Taylor et al., 2003). The process evaluation is intended to provide
lessons on how and why the HIA was successful and where the process could be improved,
whereas the impact evaluation considers whether and how well the HIA fulfilled its intended
purpose. The following are key questions that will be asked as part of the process and impact
evaluations (Taylor et al., 2003):
Process Evaluation:
What resources were used for the HIA and what was the total cost?
What evidence or data were used to inform the HIA and how did they shape the
recommendations?
How were decision makers and other stakeholders involved in the process, what
influence did this have on the different steps of HIA (i.e., screening, scoping,
assessment, etc.)?
How were health inequalities (e.g., vulnerable populations) considered in the HIA?
How was the HIA communicated to decision makers and was this approach successful?
What did those involved think of the HIA process?
Did the HIA complement the EIR? Would it have been more appropriate to integrate the
HIA into the EIR?
Impact Evaluation:
Were the aims and objectives of the HIA met? If not, why?
How and when were the recommendation measures implemented by the decision
makers and what were the contributing factors?
If some measures were rejected, why did this happen? What could enhance future
recommendations?
Were there any unintended consequences associated with the HIA (positive or
negative)? For example, fostering partnerships with organizations, public health
agencies, and other stakeholder groups, or disenfranchising any of these groups?
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Overall, the results of the internal evaluation process will help to inform and enhance future
HIAs to be conducted for the City of Hermosa Beach. Although not required, it is recommended
that any discussions or outcomes from the HIA evaluation process be documented.
7.0 LIMITATIONS AND UNCERTAINTIES
The HIA was commissioned by the City without any formal regulatory requirement to do so.
Additionally, the HIA process included extensive input from community members. The HIA
Team benefited tremendously from our interaction with the citizens of Hermosa Beach. It was
clear through the open houses and community meetings that there are a great number of
people who feel passionately on both sides of this issue. Ultimately, these interactions allowed
the HIA Team to appropriately scope the assessment and focus on determinants of health that
are most important to community members.
It is believed that this is one of the most comprehensive HIAs undertaken for an oil and gas
project in North America. We know that HIA continues to be an emerging field of science in the
practice of environmental health. There is no nationally or internationally accepted guidance for
conducting HIA. Therefore, similar to quantitative chemical human health risk assessments, it is
important to document the limitations and uncertainties associated with this undertaking.
Where possible the HIA Team relied on quantitative methods to assess the potential for health
effects related to Project activities (e.g., air quality issues). However, not all determinants could
be assessed using quantitative methods and either semi-quantitative or qualitative methods
were employed based on annoyance or nuisance thresholds, public discussions, scientific /
social science literature, and professional experience. It was important to the HIA Team to
ensure that details were provided for how each determinant was assessed and the rationale
behind the outcomes of the assessment. This way regardless of the HIA’s limitations individuals,
stakeholders and decision makers can review the available information and draw their own
conclusions.
In general, HIAs seek to discuss the potential impact on vulnerable populations of society that
may be disproportionately affected by the project. Invariably, children and the elderly are
considered to be sensitive subpopulations with respect to numerous different types of
environmental exposure. This is also true for many of the determinants that were evaluated in
the HIA. Each of the assessments on health determinants included a discussion of potential
vulnerable populations. However, the exact number of people that represent a vulnerable
population for each health determinant was not available to the HIA team and this represents a
limitation of the HIA.
The HIA Team did not interview or speak with representatives of E&B directly while undertaking
this project. Further, the HIA was reliant on data, information and mitigation measures identified
in the Final EIR. Our assessment and conclusions are subject to the limitations and
uncertainties associated with their report, and are dependent on the effectiveness of the
required mitigation measures.
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Finally, the initial draft HIA was prepared concurrently with the draft EIR and CBA. This less
than ideal situation resulted in the initial draft HIA not always having assessed the determinants
of health based on the post-mitigation scenarios provided in the Final EIR. Therefore, this report
supersedes any previous draft, presentation or correspondence regarding the findings of the
HIA. While the Final HIA had the benefit of the complete analysis and mitigations presented in
the Final EIR, the CBA has not been finalized as of the release of this report. The HIA did not
rely as heavily on information from the CBA compared to the EIR. Therefore, changes from the
draft to the final version of the CBA are not expected to have a major impact on the HIA
findings.
In addition, the following limitations were noted for the baseline health assessment:
The small population in Hermosa Beach made it difficult to find data specific to the
City. For example, while information hospitalizations due to asthma were presented,
asthma rates for Hermosa Beach were not available. The lack of more specific
asthma information is a significant data gap in this assessment.
Where prevalence and mortality data were available for Hermosa Beach, they were
not presented according to categories of race, age, gender, etc. Therefore, rates
could not be adjusted for appropriate comparison to either LA County or the State of
California.
In addition, small numbers did not allow making statistical comparisons to other
geographic locations.
The pedestrian safety assessment was conducted over five years ago and many
improvements have taken place since then, including the Pier Avenue streetscape
improvements. However, other streets have not undergone similar pedestrian
improvements since that time and are considered representative of current
conditions.
Ambient air pollution data were available for the Southwest Coastal region, which
includes Hermosa Beach but also includes the Los Angeles international airport and
other facilities (i.e., the El Segundo refinery) considered to be potential sources of air
pollution. Therefore, the aggregate data may not be representative of the Hermosa
Beach and likely overestimates pollution levels within the local community.
Overall, this HIA employs standard health risk assessment and health impact approaches,
guidance and regulatory requirements, where possible. It attempts to provide an unbiased
analysis of the potential for the Project to have negative, positive or no substantial effects on the
health of the community of Hermosa Beach. It is not meant to advocate for any particular
position with respect to the proposed Project. Rather, the intention is to provide decision makers
(in this case the voting public) with health-based evidence that may help to inform their choice.
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8.0 CONCLUSIONS
The HIA considered 18 determinants of health that fall under six major categories and were
identified as community priorities. Additionally, consideration was given to those determinants
that are most likely to be impacted by the proposed Project. Each of these outcomes was
carefully assessed using a combination of quantitative, semi-quantitative and qualitative
approaches where appropriate. Ultimately, the aim of the assessment was to determine whether
the Project (post-mitigation) could potentially have a negative, positive or no substantial effect
on the health of the community (Table 8-1).
The following were the major findings for the six categories examined:
Air Quality
The air quality assessment within the HIA concludes that with implementation of the proposed
EIR mitigation measures there is no substantial effect on human health with respect to air
emissions (NO2, PM and TAC). However, periodic odor releases during production operations
(Phases 2 and 4), identified in the EIR as significant and unavoidable, were characterized as
negative near the Project Site. Odor can have various health consequences, and could result in
periodic discomfort and annoyance near the Project Site.
Water and Soil
The water and soil quality assessment within the HIA concludes that with implementation of the
proposed EIR mitigation measures, there is no substantial effect on human health with respect
to surface water quality and soil particulates during any Phase of the proposed Project..
Upset Scenarios
Upset scenarios included the possibility for a crude oil spill into the ocean or a well blowout. The
oil spill assessment concludes there is no substantial effect with implementation of the proposed
EIR mitigation measures through Phases 1 to 4. The blowout assessment within the HIA
concludes that there is a low probability of occurrence, but in the event such upset conditions
were to occur, they could have significant negative health implications. The HIA also found a
negative health effect of stress due to fear of a blowout accident. The HIA recommends that the
City incorporate the possibility of an oil spill or well blowout into its current emergency
preparedness plan.
Noise and Light
The noise assessment within the HIA concludes that, with implementation of the proposed EIR
mitigation measures, there is no substantial effect on human health from Phase 1, 2, 3a (site
construction) and 4, and a potential negative impact from pipeline construction activities in
Phase 3b. Therefore, it is recommended that written notification be provided to residents and
schools in the vicinity of these activities that identifies the potential for excess noise and outlines
the location and duration of the impacts.
The light assessment within the HIA concludes that, with implementation of the proposed EIR
mitigation measures, there is no substantial effect on human health with respect to light
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emissions; however, there is potential for nearby individuals to experience disruption of typical
sleep patterns during periods when the drill rig is present (Phase 2 and intermittently in Phase
4). Therefore, it is recommended that black-out blinds/curtains be provided as an option for
residents whose bedroom windows are in the direct line-of-sight of the exposed portion of the
electric drill rig to eliminate any infiltration of outdoor lighting.
Traffic
The traffic assessment examined the potential for increased truck and other traffic to impact
pedestrian, bicyclist, and motor vehicle safety and the potential for perceived traffic hazards to
impact people’s walking and bicycling choices. The traffic assessment within the HIA concludes
that, with implementation of the proposed EIR mitigation measures, there is no substantial effect
on human health with respect to traffic safety and perceived traffic safety hazards during any
Phase of the Project.
Community Livability
The community livability assessment evaluated a number of community aspects that are valued
by the citizens of Hermosa, including: property values, access to green space (parks and
recreation), aesthetics (view), education funding, social cohesion, and political involvement. The
community livability assessment within the HIA concludes that with implementation of the
proposed EIR mitigation measures there is: no substantial effect on human health with respect
to social cohesion; a potential negative effect from stress over property values, aesthetic/visual
resources (while drill rigs are erected in Phases 2 and 4); and a potential positive effect on
health from enhanced recreation and green space, educational funding and political involvement
activities.
Overall Conclusion
There is no simple answer to the potential impact that the Project will have on the health of
Hermosa Beach residents since different aspects of the proposed Project will impact the
community in different ways. We caution that the assessment and conclusions are based on
population health and not on single individuals. There are some aspects of the Project that may
positively influence health (e.g., increased education funding, ability to enhance green space),
and at the same time there were potential negative health outcomes identified (e.g., odor,
blowouts, property values). With the exception of accidents, the negative health outcomes were
largely nuisance related (e.g., odor, aesthetics) without irreversible health impacts. The majority
of the health determinants examined revealed that the Project (post-mitigation) would have no
substantial effect on the health of the community.
Based on the Final EIR mitigation measures and additional recommendations provided in the
HIA, on balance we do not believe that the Project will have a substantial effect on community
health in Hermosa Beach. Ultimately it is the voters of Hermosa Beach who will decide whether
the impacts described in this HIA are acceptable or not.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014 City of Hermosa Beach, CA Page 157 Table 8-1 Health Impact Assessment Summary Based on Post-Mitigation Measures Health Determinant Potential Health Outcome EIR Mitigation Measures Geographic Extent Vulnerable Populations Magnitude Adaptability Likelihood Post-Mitigation Health Effect Comments or Additional Recommended Measures Air Quality Nitrogen Dioxide (NO2) Emissions Respiratory irritation and airway constriction NOx reduction program (AQ-1b), limited flaring (AQ-3a), and air monitoring plan (AQ-5d) Localized Children; elderly; pre-existing cond Low High Unlikely No substantial effect None Particulate Matter (PM) Emissions Morbidity (e.g., cardio-pulmonary effects) and mortality. Limited flaring (AQ-3a), limited microturbine PM emissions (AQ-4), air monitoring plan (AQ-5d), and diesel emission requirements (AQ-7a) Localized Children; elderly; pre-existing cond Low High Unlikely No substantial effect. None Toxic Air Contaminants (TAC) Emissions Varies for the TACs. Includes acute effects, chronic non-carcinogenic and carcinogenic effects. Air quality mitigation measures (AQ-1a, AQ-1b, AQ-3a, AQ-3b, AQ-4, AQ-5a through AQ-5f, AQ-6, AQ-7a, AQ-7b) Localized Children; elderly; pre-existing cond Low High Unlikely No substantial effect. Cancer risks, chronic non-cancer risks and acute risks will be below threshold values post-mitigation. Odor Emissions Acute health symptoms from odiferous compounds in crude oil Air quality mitigation measures to reduce off-gassing of vapors from drilling muds (AQ-3b ) and for operational odor controls including an Odor Minimization Plan (AQ-5a through AQ-5f) Localized Odor sensitive individuals Medium Low Possible Negative Periodic discomfort and annoyance from odor releases is likely. If frequent reports of odor occur, additional study and/or periodic monitoring of odor may be warranted. Water and Soil Surface Water Acute health symptoms Storm Water Pollution Prevention Plan (HWQ 1-1a to 1-1g) Localized Beach users Medium Medium Unlikely No substantial effect None Soil Particles Varying degrees of human health risk Fugitive Dust Control Plan (AQ-1a) and soil sampling (SR-2) Localized Children Unknown Unknown Unlikely No substantial effect None Upset Scenarios Crude Oil Spill Acute health symptoms and psychological effects including stress An independent third party audit of equipment and additional upset scenario risk reduction measures (SR-1a through SR-1g) Localized People in immediate vicinity Medium Medium Unlikely No substantial effect Incorporate well blowout scenario into the City of Hermosa preparedness plan Well Blowout Injuries and/or fatalities and psychological effects including stress An independent third party audit of equipment and additional upset scenario risk reduction measures (SR-1a through SR-1g) Localized People in immediate vicinity (est. max 750 ft)1 High Low Unlikely Negative Incorporate well blowout scenario into the City of Hermosa preparedness plan Noise and Lighting Noise Emissions Annoyance, stress, sleep disturbance and hypertension and cognitive impairment at very high sound pressure levels Noise mitigation measures Phase 1: NV-1a to NV-1c Phase 2: NV-2a to NV-2j; NV-3a to NV-3d Phase 3a (site construction): NV-4a to NV-4c Phase 3b (pipeline construction): none Phase 4: NV-6a to NV-6h; NV-7a to NV-7c Phase 1-4: Localized (Project Site and truck /pipeline routes) Residents and schoolchildren in proximity to pipeline route Phase 1: Low Phase 2: Low Phase 3a: Low Phase 3b: Medium Phase 4: Low Phase 1: High Phase 2: High Phase 3a: High Phase 3b: Medium Phase 4: High Phase 1: Possible Phase 2: Possible Phase 3a: Possible Phase 3b: Probable Phase 4: Possible Phase 1: No substantial effect Phase 2: No substantial effect Phase 3a: No substantial effect Phase 3b: Negative Phase 4: No substantial effect In anticipation of potential elevated noise levels from pipeline construction activities (Phase 3b) it is recommended that local residents be provided with written notification of impending work including the dates and times of activities that may produce excessive noise. Light Emissions Annoyance, stress and possible disturbance of typical sleep cycles Light mitigation measures Phases 2-4: AE-4a to AE-4c; AE-5a to AE-5e; AE-6a to AE-6b Localized People with a direct line-of-site of the lit side of electric drill rig at night Low High Unlikely No substantial effect Although the magnitude is ‘low’ for the majority of residents, it could be higher for those individuals with a bedroom window in the direct line-of-sight of the exposed side of the electric drill rig that will be lit at night. It is recommended that these individuals be provided with the option of black-out blinds or curtains to eliminate any potential impact to typical sleep patterns.
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014 City of Hermosa Beach, CA Page 158 Table 8-1 Health Impact Assessment Summary Based on Post-Mitigation Measures (con’t) Health Determinant Potential Health Outcome EIR Mitigation Measures Geographic Extent Vulnerable Populations Magnitude Adaptability Likelihood Post-Mitigation Health Effect Comments or Additional Recommended Measures Traffic Traffic Safety Potential increase in number of pedestrian, bicycle or other injuries Traffic mitigation measures (TR-1a through TR-1d) Localized Pedestrians and cyclists (Children and the elderly) High Medium Unlikely No substantial effect None Perceived traffic hazards Decrease in active transportation Traffic mitigation measures (TR-1a through TR-1d) Localized Pedestrians and cyclists (Children) Medium Medium Unlikely No substantial effect None Community Livability Property Values Potential increase in stress and anxiety Not Applicable Localized Property owners Medium Medium Possible Negative E&B could consider evaluating housing prices for those in the immediate vicinity of the Project Site. Access to Recreational Resources and Green Space Change in physical activity levels, which can lead to other health issues Not Applicable Community None Medium High Possible Positive To maximize potential health benefits from access to green space and recreational activities the City should form a community advisory group on how to spend revenue. Aesthetics and Visual Resources Annoyance and stress from negative perceptions and anxiety over project aesthetics Aesthetic and visual mitigation measures AE-1a to AE-1b; AE-2a to AE-2d; AE3a to AE-3c Community None Medium Medium Possible Negative The overall impact is negative based on the aesthetic environmental change leading to increased levels of annoyance and stress in some individuals. Education Funding Increased resources and funding for education can indirectly lead to a more positive health status Not Applicable Community Schoolchildren Medium High Probable Positive None Social Cohesion Potential increase in stress Not Applicable Community None Low Medium Possible No substantial effect None Political Involvement Increase in self-efficacy and positive impacts on health and well-being over communities ability to vote Not Applicable Community Voters Medium High Possible Positive None 1Figures 4.8-5 and 4.8-6 of Final EIR provide estimated range and map, respectively (MRS, 2014)
Final Health Impact Assessment - Proposed E&B Oil Drilling and Production Project September 3, 2014
City of Hermosa Beach, CA Page 159
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Appendix A
Summary of Los Angeles Urban Drilling Sites
Appendix A: Summary of Los Angeles Urban Oil Drilling Sites Region Oil Field Location Production Urban Features Health and Environmental ConcernsInglewood Inglewood underneath the Baldwin Hills, between Culver City and Inglewoodproduces more than 3 million barrels of oil per year from 430 active wellslargest remaining contiguous oil production landscape (950 acres) in urbanized Los Angeles, neighbors are more than 1,000 feet from drilling activitiesin 2006, gasses entrained in drilling muds were released and detected by neighbors; 2011 CEQA lawsuit settlement resulted in: reduced drilling of new wells, increased air quality monitoring, more stringent noise limits, and mandatory health assessmentsSawtelle underneath Veterans Administration land on both side of the 405 Freeway 18 wells, extracting 175K barrels per yearaccessed on the Veterans Administration campusCheviot Hill underneath much of Century City2 well sites remain active, extracting 57K barrels per yearaccessed through sites located on two separate golf coursesBeverly Hills extends from Century City to past Fairfax, centered under Pico90 operating wells, producing more than 850K barrels per yearaccessed through three urban well sites ‐ one operates within Beverly Hills High Schoolin 2003 a suit was filed alleging the well site was responsible for a higher than average cancer rate at the highschool but the case was later dismissedSalt Lake underneath city from Beverly Hills to the Wilshire 40 operating wellsaccessed on the west side of the Beverly Center malloil field seeps caused a 1985 methane explosion at a Ross Store (across from the Fairfax Farmers Market, injuring over 20 people)Las Cienegas extends from La Brea to downtown Los Angeles27 oil and gas producing wells producing 0.5 million barrels per yearaccessed through 4 sites set among residential propertiesincreassed drilling activityon West Adams in 2004 promprted neighborhood compliants about noise and odorLos Angeles City underlies an area on the north side of downtown, from Hoover to Dodger StadiumAlmost entirely shut down, producing just 1.2K barrels of oilhundreds of wells drilled throughout the urban areamethane seeps and hydrogen sulfide odors led to safety concerns for highschool built on top of fieldLos Angeles Downtown underneath the Staples and Convention Center area12 extraction and 2 injection wells, producing 35K barrels per year well site on Hill Streetsteam injection at the site is thought to be responsible for ooze that came to the street surface in 2006, prompting street closures and evacuationsMontebello underneath Montebello hills produces over 600K barrels of oil per yearsurrounded by a shopping mall, housing, a closed dump, and Whittier Narrows dam and basinBandini underlies part of East Los Angeles 20K barrels per yearclusters of pumpjacks around rail yards south of the I‐5 and I‐710 intersectionEast Los Angeles underlies part of East Los Angeles 40K barrels per yeara dozen pumpjacks operate amidst office and warehouse spacesSanta Fe Springs under the city of Santa Fe Springs 160 wells produce 600,000 barrels per year most pumping takes place in office parking lotsWalnutsmall field in La Puente, next to the City of Industry produces around 8K barrels per year pumpjacks within golf courseWhittier along the southern base of the oil field produces around 125K barrels per yearactive oil fields have held back full suburban developmentcurrent court case and community concerns that opening the hills to drilling will result in impacts to human health and the environmentSansinenaPuente‐China corridor, between Whittier and Brea‐Olinda pruduces around 260K barrels per yearBrea‐Olinda west of Highway 57, on the LA/OC linehistoric site but still operating more than 500 active wells, producing more than 1.1 million barrels per yearEast Coyote northern Orange County 69 wells extract around 200K barrels per yearcovered over mostly by housing and a golf courseYorba Lindacontiguous with the east end of the East Coyote Oil Fieldmost wells capped but still produces 20K barrels per year has been taken over by suburban developmentRichfield just south of Yorba Lindaaround 100 active wells, around 340K barrels per yearscattered pumpjacks around the community in recently developed part of Yorba LindaOlive west of Anaheim 3 active wells, 18K barrels per yearEsperanza underlies hills east of Yorba Linda 8K barrels per yearChino‐Soquet underlies hills southwest of Chino 1.2K barrels per year near the edge of Chino Hills State ParkMahalaunderlies hills between the Prado Dam and Chino Hills State Park 1.5K barrels per year undeveloped areaWestside and DowntownEastern and Inland
Appendix A: Summary of Los Angeles Urban Oil Drilling Sites Playa del Rey underlies the marina and Ballona Creek estuaryover 100 closed and capped wells, few operating wells remain, former wells currently serve as major natural gas storage areaHyperion underneath the west end of LAXsmall oil field, only one well produces about 10K barrels of oil per year El Segundo underlies much of the community and refinery at El Segundomost wells are inactive, two producing wells yield around 15K barrels per yeartwo active wells in the industrial part of El SegundoHoward Townsite underlies an area along the 105 Freeway north of Gardena4 active wells produce less than 10K barrels per year on houselots between homes and businessesRosecrans underlies a mostly industrial area along the 110 Freeway, between Gardena and Compton produces around 150K barrels per year46 active pumpjacks along railway, freeway, in industrial yards, parking lots, and house lotsTorrance underlies a wide area of developed land in the South Bayproducing nearly 400K barrels per year, former directionally drilled oil wells in the harbor area at Redondo Beach are now capped off100 wells are scattered in residential and retail areasLong Beach underlies the Signal Hill Area, south of the Long Beach Airportnearly 300 active wells produce more than 1.5 million barrels per yearwells scattered in retail, industrial, and residential areas of Signal HillWilmington under the port and city of Wilmington, extending from Torrance to Seal Beach including offshore portionsthe most productive oil field in the Los Angeles Basin (3.5 million barrels per year), 1,300 active wells pumpjacks scattered around the cityextensive pumping has led to land subsidence over the whole of port area ‐as low as 29 feetSeal Beach underlies the estuary of the San Gabriel River130 wells producing around 500K barrels per year clusters of pumpjacks around housing and marinasHuntington Beach underlies much of Huntington Beach produces nearly 2 million barrels per yeartwo offshore platforms and 200 wells extending for over a mile along PCHother parts of the land have been restored to natural habitat (marshland)West Newport on the Coast at the mouth of the Santa Ana Riverproduces around 100,000 barrels per year from 100 wellsundeveloped Ranch site holds most of pumpjacksSource: CLUI 2010, grey shading indicates no information was available (does not indicate that health concerns are not present)Coast and South BayHarbor and Long BeachSouth Coast
Appendix B
Scoping Checklist
Health CategoryTypical Outcomes Considered in this CategoryCurrent local health consideration?How may the project impact health and wellbeing of local community?Is an in‐depth HIA necessary that examines this area in more detail?Greenhouse GasesThere are no existing facilities in Hermosa Beach with reported GHG emissions. The closest facility is the AES Power Plant that generated 93,255 metric tons CO2 equivalent in 2010.Long‐term greenhouse gas emissions exceed the SCAQMD level of significance of 10,000 metric tons CO2 equivalent No. While Hermosa has a goal of being carbon neutral, greenhouse gases cannot be adequately evaluated in this HIA given the broad implications.Air Quality ‐ fugitive dusts, criteria pollutants, VOCs, mercaptanCurrent levels of particulate air pollution in the vicinity of Hermosa Beach approach and/or exceed air quality standards.Air quality assessment will rely on the air toxics risk assessment conducted in the EIR. Close loop system indicates local emissions will not be impacted.Yes. There is strong evidence linking air quality with increase disease and death rates.Water Quality ‐ petroleum hydrocarbon contamination of groundwater, ocean waterThe Santa Monica Bay surface waters are listed as impaired under the Clean Water Act due to contamination DDT and PCBs, and coliform bacteria. The storm water plan includes the containment of all storm water during Phase 2, so that storm water infiltrates and evaporates onsite. Pollutant discharge will be contained by walls and berms onsite.Yes, community members prioritized water and other environmental quality.Soil ‐ fugitive dusts carried to surrounding areasCurrent city maintenance yard has elevated levels of lead, which are above commercial and residential risk‐based values.Residents and recreational users could be exposed to lead and other contaminants in surface soil around the SiteYes, uncertainties regarding current site contaminants and fate and transport of lead in dust require further evaluationNoiseDaytime L50 Noise Standard of 50 dBA is currently exceeded by light manufacturing propoerties to the west and residential properites to the north and east, however residential areas may still be impacted. Increase in daytime and nighttime noise levels may cause sleep disturbancesYes, nightime noise disturbances have the potential to be above current conditions. The amount of noise increase requires further evaluation.LightExisting conditions are typical of a residential neighborhood. Limited lighting at night such as streetlights. Parking lot lights illuminate the public parking area.The lighting, as proposed in the Applicant’s Lighting Plan, would be designed to be directed downward and shielded in order to avoid obtrusive light spillage beyond the Project site, reflective glare, and illumination of the nighttime sky.Yes. Although impacts may be minimal if lights are shieled and cast downwards, there is uncertainty associated with the amount of lighting that will be needed onsite. Evaluation of other nighttime work zone lighting scenarios may provide additional information.Chemical exposuresPhysical Hazards/Nuisances
VibrationVibrations may disturb surrounding light manufacturing and residential properties.10 types of equipment were modeled to produce vibration levels of 0.5 psi, as described in the project description. The EIR predicts vibration will have minimal health impact.No. Health impact not anticipated, and vibrations are not a health concern of the community.OdorNo known odor complaints in the current light manufacturing area by the proposed site.Odor events could occur from production equipment or drilling upset conditions. Main concerns are hydrogen sulfide, combustion gases and mercaptan. Yes. Odor distrubances are often reported at urban drilling sites, and may impact health in the surrounding neighborhood.Changes to groundwater/wetlands that provides habitat for vector‐borne disease No existing vulnerabilities None identifiedNo, no wetlands areas exist. There are a lack of existing surface water features in the City and surface water runoff is expected to be contained onsite.Crowded living and working conditions can increase risk for disease transmission No existing vulnerabiltiiesTotal number of workers during any given phase will be a peak of 35 employees. Not relevant to this project, because the number of employees is smallMicronutrient deficienciesHermosa Beach has access to a large amount of fresh and healthy food choices, including supermarkets and a Farmers Market. None identifiedNo, potential health impacts were not identifiedPhysical activity2 out of 5 beach cities adults do not meet the federal physical activity guidelines Environmental contamination or percieved risk of environemntal contamination may decrease physical activity frequencyYes, community values outdoor activities and healthy lifestylePedestrian ReroutingExisting sidewalks on 6th and 8th streets are interrupted and not friendly to pedestrians. Existing sidewalks along Ardmore/Valley andVeteran's Parkway greenbelt are very pedestrian family.Phase 1 ‐ sidewalks along Valley and 6th street/8th street intersectionswould be closed; Phase 2 ‐ none; Phase 3 ‐ sidewalks along Valley and 6th street, add a sidewalk on 6th street; Phase 4 ‐ none.Yes, walkable city lifestyle is an important quality of life indicator in HermosaOil pipeline rupture No existing oil pipelinesProject description estimated 2 per 10,000 per year, maximum of 778 barrelsYes. Although low probabilitiy of occurrence, could result in severe health impactsIncludes fatal and non‐fatal injury patterns No existing oil trucking activitiesTruck accident rate of 4.2 per 1,000 per year, maximum of 160 barrelsYes. Addition of truck traffic could negativiely impact safety and phsycial activity.Infectious diseaseAccidents/InjuriesFood, Nutrition, Physical Activity
Project‐related income and revenue to improve infrastructureCommunity members are interested in project revenue to support City resources such as a new sewer system, and improved school programsPossible that revenue could contribute to city projects and community programsYes. Improved community resources are linked with positive health outcomes.Increase demand on water and sanitation infrastructure because of projects need or non‐resident workers Water in California is in high demand. Need to find alternative water source.No. Alternative sources of water and improved sanitation infrastructure are both possible, if needed.Revenue from the project that supports construction and maintenance of water & sanitation facilitiesCommunity would like to improve sewer system infrastructure Positive impactNo. Not a priority listed in community comments and input.Depression, anxietyHospitalization rate due to mental illness lower than California reference populationProject‐related environmental hazards could impact psychological health through noise and odor distubrances, or reducing access to green spaces and the outdoorsYes. Include this health outcome in literature searches of possible impacts.SuicideMortality rate from suicide 1.3 per 10,000 people (2009‐2010)Depression and other psychological health impacts of project could lead to suicide.Yes. Include this health outcome in literature searches of possible impacts.Substance/alchohol abuseHospitalization rate due to alcohol‐drug use and alcohol‐drug induced mental disease higher than California reference populationSubstance abuse is associated with other adverse chronic health outcomesYes. Include this health outcome in literature searches of possible impacts.Cultural integrity/changeCurrent beach culture and lack of industrial influencePossibly change the identify of Hermosa as a "The Best Little Beach City"Yes. The city's character influence social behavior and overall wellbeing of community.EducationHigh educational attainment‐ nearly 99% of Hermosa residents over age 25 have attained highschool education or greater, nearly 70% have bachelor's degree or higherPossible revenue from project could support schools and districts.Yes. This possible outcome is important to community members, and education is one of the most important health indicators.Community Political Stress Residents are politically engagedSome feel the impending vote is dividing the community and pitting them against one another (cite personal interations with community members)Yes. Community members are interested in this health determinant being assesed.Social Determinants of HealthWater and Sanitation
Income/ Poverty Median annual household income is over $100,000; 3.6% of Hermosa reisdents living below poverty levelProperty value fluctuations may change personal revenueYes. Community members have expressed interest regarding the potential impact on property values.Healthcare Access/InsuranceIncreased demandsNo hospitals identified in Hermosa, however a large number of health resources exist within 5 miles of hermosaIncrease in disease rates could cause increase in medical costsNo. Access to health resources was not identified as a vulnerability.Earthquakes/SubsidenceCatastrophic event, emergency response capabilityNearby seismic activity from 1981 to 2010 was surveyed. There was one shallow earthquake (less than 5 miles below ground surface) in Wilmington Oil Field, and none in Torrance Oil Field including Redondo Beach area (Geosytnec 2013).Low probability and high riskNo. The project proposes sufficient mitigation measures to reduce the risk of earthquakes/subsidence. Subsidence will be monitored and project activities will stop if subsidence is measured more than 1 ft.Population health indicators (i.e. life expectancy, mortality, infant mortality, child <5 mortality, quality‐adjusted life years)Hermosa appears to have a favorable mortality profile compared to Los Angeles CountyPossible increase in mortality ratesYes. These health indicators were included in the literature search.CancerCancer rates in Hermosa do not exceed expected rates given population demographics. Lower rate of colorectal cancers observedPossible increase in cancer ratesYes. Cancer will be included in literature search of available public health data.Survey‐based measures of community well‐beingNo data availablePossible decrease in well-being factorsYes. Community well-being factors will be considered in all potential health impacts.Prematurity rateYes. Prematurity rate was included in search terms for environmental hazard literature searches.Adolescent preganancy rateSee Maternal AgeNo vulnerabilities identifiedPossible increase in prematurity rate No, no project impacts identifiedAdequacy of prenatal careNone identifiedNo, no project impacts identifiedFetal alcohol syndromeOf babies born in 2011, 88% received prenatal care beginning in the first trimesterNo vulnerabilities identifiedNone identifiedNo, no project impacts identifiedLow birth weightAir quality may impact low birth weightYes. Low birth weight was included in search terms for environmental hazard literature searches.Maternal AgeLow birth weight rate was 7% in 2011Zero births to women <20 years old, 47% of births were to women 35+ in 2011None identifiedNo, no project impacts identifiedMaternal‐Child HealthGeneral Health and WellbeingNone identified
Appendix C
Response to Public and Peer Review Comments
Appendix C-1 Response to Public Comments on Reissued Draft HIA
- 1 - APPENDIX C‐1: RESPONSE TO PUBLIC COMMENTS ON REISSUED DRAFT HIA Comment CommenterResponse Please understand that these reports seem to be very "generic" and do not take into consideration the type of city and lifestyle that the citizens of Hermosa Beach live. and citizens that live. D Andrews The type of city and lifestyle demographics of the citizenry of Hermosa Beach is an integral part of the report and assessment. The detail regarding type of city and lifestyle is begun in Section 1 under Project Introduction with the description of the City and the outdoor and activity opportunities afforded by the City. Attention to demographics and lifestyle is continued in Step 1 of the Assessment including the baseline community profile and was considered in each evaluation of determinant of health. 1. Why isn't the population density figured into any of the reports or analysis? 1. Hermosa Beach is in the 99th% in population density. The vast majority of the population is south of the pier where the drilling will occur. 2. This puts Hermosa Beach in the same percentile as New York City, Boston, and San Francisco. 3. Has any of the reports compared oil drilling to those densely populated areas with a set back of 160 feet and 30+ wells in 1.3 acres? D Andrews The commenter’s concern regarding this Project’s proximity to a densely populated area is acknowledged. Although the term population density is not used in the report, the fact that Hermosa Beach is a densely populated area is discussed. In section 1.2 Oil Development and Production Activities, other urban drilling sites in the Los Angeles Basin are discussed. Boston and San Francisco comparisons can be found in Section 6.6.1 Traffic and Health in the discussion of traffic volume and vehicle‐pedestrian injury collisions. Population density and proximity to the site are also considered in each evaluation where appropriate. 2. Hermosa Beach has a walkability score of 82 it is the 3rd highest in the State of California. 1. It puts Hermosa Beach in the 99th% for walkability in the US right with New York and San Francisco. 2. Has any of the reports compared oil drilling to those cities with a set back of 160 feet and even less feet to the sidewalk and greenbelt? 3. Has anyone looked at noise and air quality and how it will change the quality of a persons walk? 4. People walk to exercise and reduce stress, doesn't chemicals in the air, construction noise and traffic affect a persons health? D Andrews The commenter’s concernsregarding walkability, noise, and air quality as well as the effect of exercise on a person’s wellbeing are acknowledged. Regarding the comments about noise, please refer to the discussion in Section 5.5 Noise and Light. Regarding the comments about air quality, please refer to the discussion in Section 5.2 Air Quality Assessment. Regarding the comments about walkability and the effect of exercise on health, please refer to the discussion in Section 5.7.2 Community Resources: Access to Recreational Resources and Green Space. Regarding the comments about traffic, please refer to the discussion in Section 5.6 Traffic. 3. Hermosa Beach homes were designed to live with your windows open. 1. The weather is not too hot or cool. 2. We do not have air conditioners. 3. Has this report looked at densely populated homes that live D Andrews This comment provides statements to illustrate that the community lives in a climate where they leave windows open for the majority of the year. Opposition to use of blackout curtains and to running air conditioning are acknowledged. The recommendation that black‐out blinds or curtains be provided is provided as an option to those who
- 2 - Comment CommenterResponse with their windows open more than 9 months out of the year?4. The suggestion of putting up blackout curtains up and alerting residents to noise as a solution is not one I see working. 5. I work from home and leave the windows open or it gets too hot. When a garbage truck goes by it is incredibly noisy when my windows are open! 6. Many homes in Hermosa Beach are old and have single pain windows is anything factored in for those types of homes and the noise levels? 7. If I have to use blackout curtains and keep my windows shut my house gets hot and I cannot sleep. Has sleep depravation because of heat factored into the hack solution of blackout curtains? 1. For those few homes that have A/C the cost of running A/C is expensive. It is an added cost on them. Has the stress of the financial burden for additional costs of running A/C been factored into the hack blackout curtain solution? may desire it (so they don’t have to pay for them themselves). We recognize that residents may prefer to maximize air flow at night and therefore chose not to request black‐out blinds or curtains. As the recommendation is optional, we did not assess the financial stress of running air conditioning to facilitate the use of black‐out blinds or curtains. This recommendation was based on the HIA Team’s experience in rural areas that also tend to live with their windows open into which a new light source is introduced. The noise assessment considered outdoor noise levels, rather that noise levels indoor with the windows closed, and therefore noise through open windows is covered in the assessment. 4. People pay less to live near freeways because of sight, smell, and noise. The average home in Hermosa Beach is valued at over $1,000,000. The average home where the drilling is happening is valued at $1,400,000 at least. 1. The draft cost benefit analysis states that there could be at least a 10% reduction in home values. 2. Have you looked into the stress or any other health issue of someone who owns a home and have them lose $140,000 in equity? 3. Most people I know that lost $140,000 during the housing crisis were pretty stressed out. It seems like it is glossed over in your report. D Andrews Please refer to Section 5.7.1 for a discussion of the stress created by the fear of loss of value as well as stress created by loss of value itself. 5. Have you looked into the affects of a clean up of an oil spill and all of the ill effects on the citizens and the economy to compare Hermosa to cities along the gulf of Mexico? 1. People who cleaned up the spill and live in the area are having massive issues. 1. Watch "VICE" on HBO, they have many great case D Andrews There is no doubt that an oil spill – particularly one that reaches the ocean – could have a significant impact on the environment and economy of Hermosa Beach. The HIA looked specifically at the human health impacts that a spill to the ocean might have. The documented health effects from exposure to crude oil are discussed in Section 5.4.1 (Oil Spill). These effects include acute eye, throat, and skin irritation,
- 3 - Comment CommenterResponse studies that shed some real light onto the issue.2. The shrimp in the area have tumors and it is destroying their businesses. 3. The people have all kinds of serious medical issues. as well as psychological impacts. The long‐term impacts of the oil spill cleanup in the Gulf of Mexico are currently being studied; results have not yet been published. 6. Is the density of the well vs. the set back figured into this report?1. Texas has a set back of 1,500 feet for drilling. You cannot be near homes, schools, parks, churches, businesses, etc... 2. They are obviously doing that for a reason. 3. The set back law is from 1932 and they are grandfathered into this set back law. 4. Seems a little strange that there are no effects found. D Andrews Regarding setbacks, the distance between the structures in the project and other items such as roads, property lines, sidewalks, etc. must be in accordance with the governing ordinances, zoning laws, or other agreements as legally mandated. 7. There is a mention of a 35 foot wall. 1. This will block people's view of the ocean. 2. Doesn't this cause your stress to elevate if you have a $1,000,000 home and will lose value because your ocean view is blocked? D Andrews The details regarding property values are outlined in Section 5.7.1 (Property Values) and the discussion of visual resources is included in Section 5.7.3 (Community Resources: Aesthetics and Visual Resources). 8. Can Intrinsik list any negative impacts from any reports that they have done with regards to oil drilling not just for this project but ANY projects they have done? D Andrews Please note that in this report the following are listed as negative impacts: periodic odor releases, oil spills, noise regarding pipeline construction Phase 3b, stress regarding property values, and aesthetic/visual resources. Intrinsik has over 25 years of experience in the environmental health field and Intrinsik has contributed to numerous assessments that have established that without mitigation or further risk management that adverse health effects could occur. General overview comments: In my opinion, the “best” Health Impact Assessment (HIA) is one that objectively presents all the available information on a wide assortment of possible endpoints that might affect human health and prosperity, in a way accessible to the lay public, and does not take a position on the activity being evaluated. I do not think this document achieves that objective. The current HIA is written and presented with a decidedly pro‐project perspective. The document is carefully worded to minimize potential opposition, maximize uncertainty with regard to reported health concerns, and literally lead the reader to the conclusion that all is well and the project can go forward with little worry. Discussions of potential health concerns, including exposure to air E Avol The HIA authors agree that HIAs should objectively present all the available information on potential impacts to public health due to a proposed project, in a way that is accessible to the public, and not take a position on the project being evaluated. The HIA authors took a neutral stance on the proposed Project and we believe the report reflects that neutrality. This was also acknowledged by the Peer Reviewer’s comments found in Appendix C. The commenter mentions the close proximity of the proposed Project Site to residential locations, schools, and recreational venues. The HIA report examined health impacts at both the neighborhood level (adjacent the Site) and the community level. The commenter’s opposition to the way the HIA is written is noted.
- 4 - Comment CommenterResponse contaminants for which there are currently state or federal regulations (as in the case of air pollutants such as nitrogen dioxide, particle matter, hydrogen sulfide, some heavy metals and hydrocarbons associated with engine operations) have been carefully nuanced to shift public concern away from possible negative health outcomes. This may be an advantage to persuading the public to move forward with the project but does a disservice to providing information for evaluation. Other material, such as a discussion regarding the potential for ultra‐fine particle exposure to nearby community residents, is missing, ostensibly because there is no regulation or state rule specifying that it be considered…but it does remain a potential exposure in close proximity to these industrial operations and could be of health importance. Oil drilling operations in such close proximity to residential locations, schools, and recreational venues is not ideal in terms of public safety and health nor the main approach typically utilized, so careful consideration of the assorted health and safety issues associated with the proposed project seem self‐evident. From the work presented here, it is not clear that this document provides that level of public‐perspective‐oriented view. 1. Pg27 of document (Pg 1 of report), Section 1.1, para1, second to last sentence: Comment is made about the popularity of outdoor activities. An additional observation is warranted, and it might read something like the following: “There is a popular wood chip jogging/walking (“Greenbelt”) trail down the center of Valley/Ardmore Drives, one of the main transportation routes that traverses the entirety of the city of Hermosa Beach, connecting the city to its northern and southern beach city neighbors. It is regularly used by a diverse and substantial number of residents and visitors for exercise, outdoor enjoyment, and access/transport through the city and passes within ~150 feet of the City Maintenance Yard (the proposed site of drilling).” E Avol The comment suggests introducing the Greenbelt in Section 1.1 In response, the following text has been added to Section 1.1: “There is a popular wood chip jogging/walking trail (the “Greenbelt”) running north‐south along the center of Valley Drive and Ardmore Avenue, one of the main transportation routes that traverses the length of Hermosa Beach, and connecting the City to its northern and southern beach city neighbors. It is regularly used by residents and visitors for exercise, outdoor recreation, and active transport through the City.” The proximity of the Site to the Greenbelt is addressed in Section 1.3. 2. Pg 51 of document (Pg 25 of report), Section 4.2.1, para 2, second sentence;”…Construction equipment and the vehicles that transport equipment can release fine particulate and diesel…” understates physical reality; through incomplete combustion, these E Avol The commenter’s recommendation for wording changes is acknowledged, and the word “can” has been removed from the noted text.
- 5 - Comment CommenterResponse engines DO release fine particles and diesel particulate. The only issue is how much is released to the surrounding environment. 3. Pg 51 of document (Pg 25 of report), Section 4.2.1, para 2, last sentence – Similar to the comment immediately above, soil excavation and movement DO generate dust; this is not only a “possible” outcome, as the sentence is phrased. E Avol The commenter’s recommendation for wording changes is acknowledged, and the word “can” has been removed from the noted text. 4. Pg52 of document, (p26 of report), para 2 – “…these effects are dose‐dependent…”. While it is true that there is typically an increasing human health response with increasing dose, it also should be noted that pollutant‐response curves are not necessarily monotonically increasing; in other words, some pollutants do not have a simple linear response curve. There are also threshold effects for some pollutants, where there are no apparent effects up to a given concentration, and then some measurable and obvious health response presents itself. The overall phrasing in the current paragraph underplays the potential for health outcomes. For example, it is not clear why the last sentence in the paragraph (“the literature also identifies the potential impacts that odors can have on the quality of life, and at high enough levels, acute risks…” seems to avoid the possibility of chronic health outcomes associated with persistent low‐level exposures to odors. While it is true that acute health effects can result, aren’t longer‐term effects possible as well? Human detection of odors represent one of several pathways of human exposure (this one via the respiratory pathway), and both chronic and acute effects might reasonably be expected. E Avol The commenter refers to text from Section 4.2.1 (Air Quality) within the scoping step. The purpose of the scoping step of the HIA is to provide the potential pathways between the project impacts and health outcomes. The detailed assessments of the pathways presented in the scoping section, and a more thorough discussion of threshold effects, are provided in Section 5.2 (Air Quality Assessment). 5. Pg 52 of document (p26 of report), second‐to‐last paragraph, first sentence (“…in the event that exposures were uncontrolled…”). This sentence misrepresents reality, since control of emissions does not mean “zero release of emissions” or “zero exposure”. There will be gas and particle emissions associated with operations, and the question being considered is if these emissions are of significant health consequence. E Avol The HIA authors agree that the phrase “control of emissions” does not mean “zero release of emissions”. It means the change in magnitude of the exposure. 6. Pg 52 of document (p26 of report), second‐to‐last paragraph, second sentence – It is unclear what meaning that the authors intend by the comment, “…this diagram…is a preliminary effect pathway E Avol The phrase “preliminary effect pathway” is explained in the next sentence in the same paragraph, where it is stated “The next step in the HIA is the assessment step, which validates or invalidates each
- 6 - Comment CommenterResponse diagram.” Do they mean this is a draft figure that will be updated? The figure is, in fact, incomplete, since there are several other “air‐quality related diseases” associated with ambient air changes in the air pollutants listed. These include effects on neurological outcomes (learning, attention, and behavior) and metabolic outcomes (on the pathway to diabetes and obesity outcomes). Presumably the “Reproductive Health” category includes premature birth, low birth weights, and even birth defects, as opposed to fertility issues, which many might consider Reproductive Health to represent. A broader discussion of these and other health outcomes are available in the USEPA Integrated Health Assessment documents for the respective pollutants, including particulate matter (PM) and Nitrogen Dioxide (NO2) , and these are posted at a USEPA website (http://www.epa.gov/ncea/isa/). potential pathway.” Regarding the health effects listed in the figure, please see Section 5.2 Air Quality Assessment for a detailed discussion regarding health effects from air quality, including nitrogen dioxide, particulate matter, toxic air contaminants, as well as odor. 7. Pg 52 of document (p26 of report), last paragraph concerning greenhouse gas emissions – This paragraph implies that since the authors of the report don’t believe that any local project can affect world‐wide emissions, discussion or consideration of the issue can be ignored. While it may (or may not) be true that the incremental contribution of greenhouse gas (GHG) emissions from any specific project may be small compared to the global issue, there almost certainly will be emissions from this project that are rightfully considered in the GHG category. These include (but are not limited to) carbon dioxide, methane, and carbon particles. Estimates of the quantities of these constituent contributions to the local community could be useful in evaluating the overall health impact of the project, and for that reason, dismissal of any GHG emissions discussion seems inappropriate. E Avol The HIA states that “the global issue of greenhouse gas generation requires a much broader assessment of state and national sources and policies to adequately evaluate cumulative impacts of the energy sector.” Please note that it is stating that the issue requires a broader assessment to be addressed adequately. The HIA authors did not imply that there will not be greenhouse gas (GHG) emissions from the proposed Project. Please refer to the Final EIR for the estimates of quantities of GHG contributions from the proposed Project. 8. Figure 4‐3, Air Quality Pathway Diagram (p53 of document, p27 or report) – Arguably the only portion of this diagram that is in question is the health outcomes listings boxes, in light blue on the far right of the diagram. There is no question that Construction, truck traffic, and site operations will respectively result in construction equipment/activities, changes in on‐road vehicle traffic, fugitive emissions, and routine /emergency flaring events. These, in turn, will undeniably change ambient levels of air pollutants, odors, and hydrogen sulfide; whether those changes are measurable or captured E Avol The HIA authors agree with the commenter’s statementand those issues are addressed in Section 5.2 Air Quality Assessment
- 7 - Comment CommenterResponse in the monitoring record is another matter, but they will change.9. Pg 54 of document (p28 of report, last paragraph, first sentence – Similar to a previous comment (Item #5 above), the comment here regarding soil pathways misrepresents reality; the re‐entrainment and dispersal of some soil associated construction and trucking operations is inescapable. The issue is whether the amount that is released is sufficient to elicit measurable changes in soil quality or health outcomes. E Avol Regarding the soil pathways represented in this scoping step, please see Section 5.3.2 Soil Particulates for a detailed discussion regarding health effects from soil emissions. 10. Figure 4‐4, Water and Soil Quality Pathway Diagram – the posted Note on the figure is inaccurate, since changes in surface water and soil quality are not really “health determinants”, but rather, specific environmental pathway components. Health determinants are more generally agreed to be elements like policies, social factors, health services, individual behavior, and individual biology and genetics. More about this can be found in a discussion of Healthy People 2020, at http://www.healthypeople.gov/2020/about/DOHAbout.aspx E Avol The HIA authors acknowledge the commenter’s reference to Healthy People and the definition contained therein. The HIA defines health determinant as “an element of the proposed Project that has the potential to impact health in a positive or negative manner” (see Section 2.4). This definition is consistent with those provided by the World Health Organization and the United States Centers for Disease Control and Prevention: http://www.who.int/hia/evidence/doh/en/ http://www.cdc.gov/socialdeterminants/Definitions.html 11. Pg58 of document, p32 of report, Section 4.2.4 Noise and Light, first paragraph, 4th line refers to “…very high levels…” of noise being associated with hypertension, cardiovascular disease, and cognitive impairment. While this may be true, the current presentation does not acknowledge that noise at levels other than “very high” (which is not defined in the passage) have been associated with negative health outcomes in published peer‐reviewed studies (see, for example Gan et al, “Association of long‐term exposure to community noise and traffic‐related air pollution with coronary heart disease mortality”, Am J of Epidemiol (2012) 175 (9): 898‐96; http://aje.oxfordjournals.org/content/175/9/898.long. E Avol Please refer to Section 5.5.1 Noise Emissions for a discussion of noise levels and health outcomes. 12. Pg59 of document, p33 of report, Figure 4‐6 – why is a change in outdoor lighting listed as leading to a possible change in “perception of safety” as opposed to “ actual safety”. The current phrasing makes it sound as if the issue is only one of perception, and not of actual physical harm, which is an incorrect and premature conclusion at this point in time. E Avol The commenter’s recommendation for addition of the word “safety” is acknowledged, and the word “safety” has been added to Figure 4‐6. 13. Pg60 of document, p34 of report, Section 4.2.5 Traffic, paragraph 3, line 3 – as noted previously, the phrasing used to E Avol The commenter is referring to the text along with the scoping figures and the HIA authors agree that a mitigated situation does not mean
- 8 - Comment CommenterResponse introduce each of these figures implies that the figures represent situations “…in the event that exposures were uncontrolled.” This is incorrect, in that even with mitigation, some of these changes will occur, need to be quantified, and a determination will need to be made as to the severity of the outcome…but it is NOT the case that these issues will somehow disappear in the face of any, many, or perhaps even all feasible controls applied. that no change will occur. 14. Pg61 of document, p35 of report, Figure 4‐7 – The figure is incomplete and partially incorrect: a. If the figure is including a change in “safe walk” school path as a project impact, it should also include a change in community use of the belt adjacent to the construction location; b. If the figure is including a linkage between change in perceived safety and mental health/ physical activity outcomes, there should also be arrows linking changes in noise and air quality to changes in mental health, physical activity, and chronic disease; c. The listed “health determinant” of change in perceived safety is a biased and incorrect presentation ; at this point in time, the figure should present this as a change in safety (i.e., it is not just a perception of change); d. As previously noted in Item #10 above, this figure identifies “health determinants” incorrectly, or at least, uses the terminology in a fashion different from more general convention. e. The listed chronic diseases in the bottom health outcomes box are fine as examples, but do not cover the breadth of negative chronic health outcomes we have information about (and hypertension might be argued to be a sub‐category of cardiovascular disease). This box should be modified to either list a few chronic diseases as examples (e.g….), or include several others (respiratory, neurological, …) E Avol The commenter’s recommendation for linkage in figure between noise and air quality to mental health, physical activity, and chronic disease is acknowledged, and pathways have been added to Figure 4‐7. Please refer to above discussion regarding the definition of determinant of health. For a detailed discussion regarding health outcomes from changes in traffic related to this Project, please refer to Section 5.6. 15. Pg63 of document, pg37 of report, Figure 4‐8 Community Livability – under project impacts, does increased wear and tear on city road surfaces (requiring more frequent road maintenance) due to heavy truck usage merit a box of its own, perhaps as “change in city infrastructure durability, costs”? E Avol Please refer to the Cost Benefit Analysis and Environmental Impact Report for more information regarding need for increased road maintenance and associated costs. 16. Pg65 of document, pg39 of report, Section 5.1.1 Demographic E Avol By comparing demographic characteristics in Hermosa to those in Los
- 9 - Comment CommenterResponse Characteristics – It is not entirely clear that the appropriate comparison for assessing demographics in Hermosa Beach is Los Angeles County, which covers a much broader and diverse geographic and sociological breadth. Perhaps comparing Hermosa Beach to other neighboring beach cities in the South Bay (Redondo, Manhattan, El Segundo, Marina Del Rey, Playa Del Rey, Venice, Santa Monica) would be more relevant to the local region? Angeles County, we were able to provide a relative picture of demographic characteristics compared to a larger population (See Appendix E). 17. Pg66 of document, pg 40 of report, last paragraph, last sentence discussing birth profiles in Hermosa Beach and vulnerability to autism or Down’s syndrome – this may well be, but it’s not clear if the comparison being made takes into account the age distribution in Hermosa Beach compared to California, or if the comparison is just an arithmetic accounting without age distribution adjustment. E Avol The paragraph on birth profiles is clarified by defining that the comparison between birth profiles is not age‐adjusted and therefore difference in age distribution may explain some of the difference in maternal age. 18. Pg67 of document, pg 41 of report, first paragraph on traffic‐related injuries – how does the population –adjusted injury rate in Hermosa Beach compare to the County or state? Does this say anything informative about traffic safety in the area? E Avol The data on traffic‐related injury illustrates that pedestrians and bicyclists are more likely to suffer from injuries when involved in a motor‐vehicle collision in Hermosa when compared to injuries among motorists or vehicle passengers. See Appendix E Section 1.3.5 for additional information about traffic safety in the area. 19. Pg68 of document, pg42 of report, Section 5.1.5 Discussion of Vulnerable and Sensitive Populations, last paragraph, final sentence – This paragraph and sentence may be true within the pre‐project scenario, but it could also be that the changes induced by the oil drilling within the city lead young professionals to seek living accommodations elsewhere (community comments about stress and property value concerns have already been noted, for example), so the paragraph as written does not really provide much in the way of any objective assessment. E Avol The purpose of the paragraph was an assessment for the potential for an increase or shift towards new populations over the course of the 35 year life of the project. The comment that the project itself could change the demographics of the community is acknowledged and the final sentence of the paragraph has been removed. 20. Pg69 of document, pg43 of report, section 5.2.1.1 NO2 and health, first paragraph – NO2 exposures have also been associated with low lung function or slowed lung function growth in children (Urman et al, Associations of children’s lung function with ambient air pollution: joint effects of regional and near‐roadway pollutants, Thorax, 69(6):540—7 (2014), http://thorax.bmj.com/content/69/6/540.long;. Additionally, it is important to point out that the effects seen are found among both asthmatic and non‐asthmatic children (Berhane et al, Longitudinal E Avol We feel that Section 5.2.1.1 adequately addresses the effect of NO2 on lung function. The HIA authors do not feel that there is sufficient evidence in the literature to state that exposure to ambient NO2 can result in respiratory effects among non‐asthmatic children. The Berhane et al. reference does not provide sufficient evidence for causality between NO2 and respiratory effects among both asthmatic and non‐asthmatic children, as the study measures a potentially useful biomarker for
- 10 - Comment CommenterResponse effects of air pollution on exhaled nitric oxide: the Children’s Health Study, Occup Environ Med, 71(7):507‐13 (2014), http://oem.bmj.com/content/71/7/507.long. airway inflammation, which may or may not be associated with actual airway inflammation among children. 21. Pg70 of document, pg44 of report, second paragraph, last sentence “…a recent meta‐analysis…suggests…no evidence that NO2 causes clinical relevant effects in asthmatics at concentrations up to 1,100ug/m3 (585 ppb).” – This comment is accurate in its reporting of what the article stated, but the article misrepresents the current state of knowledge regarding NO2 and its effects on health. The next sentence in the HIA itself points out that the World Health Organization set a one‐hour guideline for NO2 at less than 20% of the level argued by Goodman et al as being of health consequence. A recent search of the medical literature (using PubMed and the search terms “NO2 health”) identified over 1300 citations documenting the effects of NO2 on respiratory, congenital, cardiovascular, cognitive function, and psychomotor development, to name just a few target organ systems. The USEPA science review of the available evidence addressing NO2 and health, which led to EPA’s tightening of the National Ambient Air Quality Standard for NO2 (instituting a one‐hour standard of 100ppb, in addition to the existing annual standard of 53ppb) and the directive to monitor close to busy roadways due to increased concerns about exposure and health, listed hundreds of studies showing increased effects. For example, a summary of the short‐term (acute) effects for several health outcomes is shown in the attached figure entitled, “Figure 5.3.1, Summary of epidemiologic studies examining short‐term exposure to ambient NO2 and respiratory outcomes.” (This figure was taken from the USEPA Integrated Science Assessment for Nitrogen Oxides, EPA/600/R‐08/071, July 2008, http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=194645). The line in the figure, at a risk ratio of 1.0, represents no excess risk (which can be thought of as no measurable impact on health). The preponderance of plotted lines above 1.0 suggests that the studies cited (listed on the sheet accompanying the figure and cited more completely in the EPA document) all showed increased risk – that is, a measure of health effect as a result of exposure to NO2. The current E Avol We feel that Section 5.2.1.1 accurately characterizes the current public health literature on NO2. The USEPA science review on NO2 (2008) is cited several times in this Section, as is the USEPA 1 hour NAAQS of 100 ppb. Text has been added to Section 5.2.1.1 to indicate that in the 2008 EPA NAAQS review of NO2, it was noted that “…there was little evidence of an effect threshold…”.
- 11 - Comment CommenterResponse National Ambient Air Quality Standards (NAAQS) review for nitrogen dioxide is presently underway, but a draft initial assessment, available at the USEPA website (http://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=259167#Download) suggests that additional data available from recently‐published studies (within the past four years) strengthen many of the earlier observations and concerns about NO2 and both short and long‐term effects. Additionally, it should be noted (which the HIA does not) that in the 2008 EPA NAAQS review of NO2, it was noted that “…there was little evidence of an effect threshold…”. This means that the data do not support the identification of any objective value or level below which no health effects would be expected. More recent studies have reported delayed psychomotor development in children at very young ages and very nominal changes in NO2 concentration (http://www.ncbi.nlm.nih.gov/ pubmed/24631606, http://www.ncbi.nlm.nih.gov/pubmed/25036432) Therefore, the implication in the HIA that there are only mild effects or too much uncertainty to be confident about health concerns at the levels encountered in daily activities is misleading. 22. Pg70 of document, pg44 of report, fourth paragraph, last sentence, “the annual standard was upheld due to the uncertainty with the potential long‐term effects of NO2.” This phrasing of the statement is misleading. The data reviewed by the EPA in the last NAAQS review led the Administrator to set a one‐hour standard of 100ppb NO2, based on concern that the annual standard of 53ppb was considered to be insufficient to protect the public health. The “…uncertainty with the potential long‐term effects of NO2…” did not have to do with observed health effects, of which there were several from a number of studies. The “uncertainty” had to do with the high correlation of NO2 effects with other components of motor vehicle exhaust, meaning it was difficult to separate out the unique effects of NO2 from the other constituents of the exhaust. In the context of the current HIA, the ability to uniquely separate and apportion NO2 effects from other vehicle exhaust effects may be unimportant, E Avol Text has been added to reflect that the uncertainty with potential long‐term effects of NO2, in the case of respiratory morbidity, is due to the high correlation among traffic pollutants which makes it difficult to accurately estimate the independent effects of NO2 in long‐term exposure studies.
- 12 - Comment CommenterResponse because it vehicle emissions (coming from engine operations – i.e., gasoline and diesel exhaust ‐‐ associated with drilling activities will be a key source of exposure to the surrounding community. 23. Pg71 of document, pg45 of report, Table 5‐2 – the perspective and narrative of this table is focused on acute (short‐term) exposures, with a recurring observation regarding variability among studies, inconsistencies among responses, and a general attempt to minimize observed responses (which seems counter to a true health assessment, which should be objectively presenting all the potential health risk information in ways accessible to the public). The exposure likely to be encountered if the drilling project goes forward are arguably more likely to be longer‐term, low‐level exposures for the immediate community, and the health effects for those sorts of longer‐term (days, weeks, months, years) types of exposure are also available in published reports. They include a range of organ effects including: cardiovascular [affecting blood pressure, heart‐rate variability, even cardiac events]; respiratory [low lung function in children, more asthmatic events in children, more risk for asthma symptoms]; neuro‐developmental [less focus and ability to perform learning tasks cognitive function testing lags in both young children and older adults]); reproductive [pre‐natal, low‐birth weight, premature birth, birth defects]. These effects have been reported in the range of changing levels of ambient pollution possible with the proposed level of operations and should not be ignored or discounted because they are “chronic” or long‐term exposure concerns. The duration of the proposed phased drilling efforts make these “long‐term” exposures relevant and potentially of importance. E Avol The focus of Table 5‐2 is on acute NO2 exposure because short‐term exposure studies provide more conclusive evidence for adverse health effects compared to long‐term exposure studies. The HIA does assess long‐term or chronic exposures through a comparison of the maximum predicted air concentration to the WHO annual air quality guideline (0.023 ppm). 24. P73 of document, pg47 of report, Table 5‐4 and subsequent two paragraphs – the tenor of the discussion and working assumptions of the presentation are that all mitigation strategies will operate perfectly, and that there will be no ambient exposures any health or environmental concern. This is optimistic, at best, and potentially unrealistic. The “no substantial effect” classification seems mis‐assigned and premature. E Avol The Applicant has indicated that they will comply with the mitigation measures, made part of the development agreement, and therefore the HIA has made that assumption in its analysis. In addition, the scenarios that were evaluated are predicated on the fact that the emissions levels and limits will be governed by permits and approvals. If operations were to occur outside of these permitted levels then regulatory action would be taken. 25. Pg79 of document, pg53 of report, first paragraph concluding project emission are not expected to be high enough to exacerbate health risks in the community – this conclusion seems at odds with E Avol Because the Project emissions will not have a material impact on existing PM2.5 levels, the HIA authors conclude that PM2.5 emissions from the project will not exacerbate health risks to the community. We
- 13 - Comment CommenterResponse several of the previous comments presented in the text. At the top of pg75 of document, pg49 of report, quotation just prior to Section 5.2.2.2, there is a statement acknowledging that there are no identified thresholds for PM exposures (in other words, no safe level of exposure that will protect every individual). The text goes on to present comparative monitoring information for reporting stations in the South Bay (used as a surrogate for Hermosa Beach because no regional monitoring station is located in Hermosa Beach) and reports that observed levels are just below the State or WHO standards, so no effects are anticipated. This conclusion implies a threshold‐of‐effect interpretation, which is incorrect. Based on the data presented, there will be a potential for effects in some susceptible sub‐groups of the community population – most likely, among pregnant mothers and young children. do not believe this conclusion to be at odds with no identified threshold for PM2.5 exposure, and the commenter’s views in opposition of this are acknowledged. 26. P89 of document, pg63 of report, last paragraph summarizing likely health outcomes – the second‐to‐last sentence refers to ‘odor‐sensitive” individuals as being the vulnerable population, and seems to imply that this is a small segment of the population, and possibly unimportant. Previously, in the text, however (p86 of document, pg60 of report, last paragraph), it is noted that 50% of the population can detect 8ppb H2S, so it seems like the comment about “odor‐sensitive vulnerables” and the implication that this is somehow a small portion of the population is misleading. E Avol The HIA authors did not intend to imply that odor sensitive individuals are a small part of the population nor did we intend to downplay the importance of odor. “Odor sensitive individuals” often include women who have a keener sense of smell than men and younger individuals who tend to have a keener sense of smell than the elderly. 27. P95 of document, p69 of report, last paragraph of previous page and first paragraph or this one, (last portions of Section 5.3.1.3, Project Impact for Surface Water – the conclusions (throughout this report, actually) that “no substantial effects” will occur because preventive measures will be implemented, strain credulity, since it does not allow for upset conditions, human failures, or accidental lapses. The observation that since people can swim elsewhere, there is inherent adaptability to possible changes in the local environment should not be considered an acceptable response or useful input for community planning. E Avol The Applicant has indicated that they will comply with the mitigation measures, made part of the development agreement, and therefore the HIA has made that assumption in its analysis. The commenter’s views in opposition of this assumption are acknowledged. The observation that people can avoid swimming near the storm drain was followed by the observation that people may not be aware of its location (and therefore adaptability is categorized as “medium” rather than “high”). 28. P96 of document, p70 of report, Table 5‐17,Water and Soil Quality Assessment, Soil Particulates – Once again, a potential exposure is identified (in this case, wind‐blown dust), but as in other previous presentations within this HIA, the likelihood of event is E Avol The Applicant has indicated that they will comply with the mitigation measures, made part of the development agreement, and therefore the HIA has made that assumption in its analysis. The commenter’s views in opposition of this assumption are acknowledged.
- 14 - Comment CommenterResponse minimized and “no substantial effect/no additional measures required” conclusions are reached. Construction operations, and access and egress to and from the site will almost certainly create wind‐blown dust. Denial of this occurrence defies logic. Complete assurance of flawless application of mitigation approaches also seems to strain credibility. The observation that contaminated soil exists at the site due to prior activities does not excuse or minimize the responsibilities of the proponents of proposed operations at the site from managing and controlling site emissions. Any remediation of the impacted site would be governed by best‐practices and overseen by the responsible authority. This is how impacted sites are safely remediated in California every day. 29. P98 of document, pg72 of report, last paragraph (continuing onto next page) – the comment that people present at the time of an oil spill would be unlikely to experience health effects other than minor and transient effects minimizes the potential risk to those in the immediate vicinity and ignores historical events in the past. If previous historical oil spills had always only resulted in no other “health effects other than minor, transient…” ones, the regulatory and public focus on these types of drilling activities would be considerably different. This interpretation and presentation unfairly dismisses the potential for such an event and the potential health outcomes associated with such events. E Avol As stated in the HIA, with exception of psychological impacts, the long‐term health effects of oil spills have not been well‐studied. In the wake of the BP Deepwater Horizon disaster, the National Institute of Environmental Health Sciences (NIEHS) has launched the largest study ever on the health consequences of oil spill cleanup, focusing especially on respiratory, neurological, and hematological outcomes. Depending on the results of this ongoing study, this section of the HIA may require updating in the future. Information on the study can be found online: https://gulfstudy.nih.gov/en/index.html 30. P101, of document, p74 of report, first paragraph, last sentence proclaiming that an emergency preparedness plan for the community is the duty of the City‐ this may be specifically accurate, but since the actuating event would be associated with drilling operations, doesn’t some responsibility for planning, guidance, and/or support for effective emergency plans lie with the site operations team as well? It seems like noting that “it is the responsibility of the City…” is not a responsible or useful way to address this issue. E Avol The HIA states that the facility is required by regulation to have emergency response plans in place. The preparation of a community emergency preparedness plan is an additional recommendation for the City to consider, as the existing Emergency Preparedness Advisory Board is already committed to providing advice on how the City can prepare and respond swiftly to emergencies. 31. P103 of document, pg77 of report, paragraphs describing likelihood and responsibility for well blowouts – How does the safety record of the applicant (E&B) compare to the industry norm? Do their well drilling operations have a better, equal, or worse record, in terms of spills, leaks, or problems? The section defines a blowout as “unlikely” since such events are very low probability events, but how do the frequencies quoted (once every 323 years during drilling) compare to their own company history? E Avol The HIA relied on information provided in the EIR when describing the likelihood and impact of a well blowout scenario. Please see the EIR for additional information on how the figures were determined.
- 15 - Comment CommenterResponse 32. Pg155 of document, p129 of report, first paragraph (last section of 5.6.5.3, discussing impact of proposed project on green space) – the text discusses changes in the area associated with the project, including construction, increased truck traffic, etc, acknowledges that the Greenbelt is within 55 feet of the project area and is regularly used by the community – and then suggests that increased city revenues as a result of the project would be a positive outcome for green space, so that the post‐mitigation effect is positive, and a community group should be established to decide how to spend the anticipated revenue. This perspective of minimizing the impact while emphasizing the potential for monetary income seems misplaced and not in the best interests of an impartial HIA. Local green space (the Greenbelt) will likely be affected by the construction and truck transportation activities, and shifting focus to potential monetary gains that might be available for future use seems cynical and inappropriate. E Avol The HIA addresses the impact to the Greenbelt due to construction and truck traffic activities in Section 5.6.2. The Section regarding “Access to Recreational Resources and Green Space” considers how the proposed Project may impact recreational resources (associated with physical activity and other positive health benefits) used throughout the community. The commenter’s disapproval of evaluating financial benefits to the City in the HIA is acknowledged. 33. P171 of document, p145 of report, first paragraph (beginning on previous page) describing project impact on community social cohesion – the HIA concludes that there is no substantial effect of the project on social cohesion, yet the signs across the city, letters to the local papers, street discussions, and social media postings would decidedly suggest otherwise. Although it is difficult to envision what measures might be undertaken to address this concern, it does seem apparent that there are strong feelings and considerable anxiety, on both sides of the issue, across the community, and how these get resolved remains to be seen…although the forthcoming election will obviously be a benchmark in the discussion. E Avol As stated in the social cohesion section of the HIA, although a subgroup of residents is expected to experience a disruption in social cohesion (leading to a potential increase in stress) as a result of the proposed Project, it is not anticipated to overall impact community health. Therefore, no recommendations were made to address an impact to social cohesion. The commenter’s disagreement with the HIA findings is acknowledged. How can anyone that lives in Hermosa Beach that claim that they love their city want this type of possibility looming? AND‐for 35 years to come!!??? The rest of the report cites all kind of noise, lights being used at night for drilling, trucks in and out, unhealthy emissions, smells being emitted, possibility of oil spills into our ocean, and MORE. And no one seems sure if these emissions can cause cancer, health risks, or mental issues? Everyone seems to be rolling the dice, don’t they? E&B says none of these disasters will occur….how do they know that there won’t be a spill or cancer 20 years down the road to our citizens? Do L Carter The commenter’s views in opposition to the proposed Project are acknowledged.
- 16 - Comment CommenterResponse they have some type of fancy crystal ball? And for what? MONEY?????? There is no amount of money that is worth the health of any of our citizens. If you have ever been sick, you know this. There is no amount of money worth oil on our beaches, the killing of our ocean life, and smelly air. If you love your beach, you know this too. There is no doubt that the proposed project will increase the amount of traffic, air pollution, noise pollution and light pollution in, and around, the city of Hermosa Beach. In addition to writing to you about these concerns, I will also add a dimension that is not covered in the NOP for the EIR. This project has already begun to create a threat to the citizens of Hermosa Beach that, in the psychological community, is known as an Existential Threat. Living with an existential threat brings concerns worthy of addition to the scope of this EIR and will also exacerbate the symptoms and ailments caused by the various forms of stress and pollution that will be created by this project being packed into such a densely packed community. M Collins The commenter’s concern regarding potential negative impacts of the Project as well as existential threat and the possible psychological impact on the exposed population is acknowledged. Psychological impacts such as anxiety, depression, and stress are addressed throughout the report. Air Pollution has been linked to cancer, brain damage, depression, forgetfulness, and learning and memory problems. It is paramount for the health and wellbeing of this community that we address the increased probability of this threat. I’m not certain of the threshold of acceptance that your study will utilize, but in this community’s opinion, increasing the likelihood that one citizen be asked to suffer the symptoms of depression, or that one child struggle in school as a result of learning problems exacerbated by this threat, is an unacceptable threshold. There is an abundance of studies that you can reference that will scientifically support these facts. How will the increase in air pollution caused by this project increase the probability of cancer? How will the increase in air pollution caused by this project increase the probability of brain damage? How will the increase in air pollution caused by this project increase the probability of depression? M Collins Please refer to the detailed assessment of air quality in Section 5.2 of the report.
- 17 - Comment CommenterResponse How will the increase in air pollution caused by this project increase the probability of increased forgetfulness? How will the increase in air pollution caused by this project increase the probability of a child developing learning or memory problems? How will the increase in air pollution caused by this project increase the probability of an increase to the suicide rate in the community? Noise Pollution has been linked to impaired cognitive function, reading comprehension, long term memory problems, learning disabilities and problems with both attention and communication. Several studies point to an overall delay in cognitive development for children raised near noise pollution. The risk to our children’s academic abilities is something that must be included in this study. An increase in noise pollution also creates higher levels of stress and anxiety. Stress and anxiety bring a host of physical and psychological struggles. Increases in weight, anger, violence, and substance abuse to ameliorate symptoms of anxiety are but a few. Then there is the obvious fact that the noise created by the project will absolutely affect people’s ability to sleep. There are people in this community that sleep in the day and work through the night, and then there are the rest of us, that sleep at nighttime. When you measure the level of noise created by this project, will you use the real Hermosa Beach metric? Here in Hermosa Beach we live and sleep with our windows open. We spend time outdoors and in our community. Please utilize a metric that takes into account the way we truly live our lives. We do not hide behind blackout curtains and dual paned vinyl windows. We do not wrap our houses in blue soundproof blankets. We need you to use a metric that takes into account this obvious truth. Asking us to shutter ourselves in as a way to mitigate noise will only increase the likelihood of disturbed sleep, anxiety, depression and myriad other problems associated with noise pollution. How will the increase in noise pollution caused by this project increase the probability of impaired cognitive functioning in both children and adults? M Collins Please refer to the detailed assessment of noise in Section 5.5 of the report.
- 18 - Comment CommenterResponse How will the increase in noise pollution caused by this project increase the probability of reading comprehension problems for school‐aged children? How will the increase in noise pollution caused by this project increase the probability of long‐term memory problems? How will the increase in noise pollution caused by this project increase the probability of a child developing a learning disability? How will the increase in noise pollution caused by this project increase the probability of a child developing attention problems? How will the increase in noise pollution caused by this project increase the probability of a child developing communication problems? How will the increase in noise pollution caused by this project increase the probability of citizens developing insomnia? How will the increase in noise pollution caused by this project increase the probability of citizens developing depression related to lack of sleep? How will the increase in noise pollution caused by this project increase the probability of citizens developing anxiety related to lack of sleep? How will increase in noise pollution caused by this project increase the probability of an increase in domestic violence? How will the increase in noise pollution caused by this project increase the probability of substance abuse directly caused by stress related to noise pollution, insomnia, depression or anxiety? How will the increase in noise pollution caused by this project increase the probability of an increase to the suicide rate in this
- 19 - Comment CommenterResponse community? Light Pollution has been shown to disrupt circadian rhythms, which will cause irregular sleep patterns and has been linked with a higher incidence of cancer. Fear of an increased likelihood of cancer is an obvious stressor and Existential Threat. There is an abundance of literature studying the relationship between disrupted sleep patterns and a higher incidence of stress, heart disease, cancer, depression, anxiety and poor school performance. The evidence is overwhelmingly in support of this cause and effect relationship. In addition to that, I am immediately worried that an increase of light around our community will interfere with our current sleep patterns. It would appear that there are thousands of residents that would be able to see an increase in light as a result of this project. If they can see it, this means that it is affecting them. This reality must be included as part of your metric. Will you enter several houses and study how the light of this project will enter our homes and neighborhoods? How will the increase in light pollution caused by this project increase the probability of cancer within the community? How will the increase in light pollution caused by this project increase the probability of disrupted circadian rhythms in sleeping citizens? How will the increase in light pollution caused by this project increase the probability of stress in the community? How will the increase in light pollution caused by this project increase the probability of heart disease as it relates to poor sleep? How will the increase in light pollution caused by this project increase the probability of depression as it related to poor sleep? How will the increase in light pollution caused by this project increase the probability of anxiety as it relates to poor sleep? M Collins Please refer to the detailed assessment of light in Section 5.5 of the report.
- 20 - Comment CommenterResponse How will the increase in light pollution caused by this project increase the probability of poor school performance as it relates to disrupted sleep? How will the increase in light pollution caused by this project increase the probability of an increase to the suicide rate in this community? Existential Threats come in the obvious form of how a person deals with a threat upon their life. A person with a compromised immune system living by an oilfield would certainly have an increase in fear that their body would not be able to deal with an increased amount of stress or pollution. Existential Threats are also threats to family, wellness, lifestyle and community. There is also the psychological threat that our entire community is being asked to bear as a result of living under the existential threat that was levied upon us as a result of this issue being placed back on the table. Every single community member is operating with an increased concern that the outcome of this project will effect the way that we currently live and exist. Your study is to include health and safety risks. In my business, I see people day in and day out who are seeking treatment to deal with anxiety, depression substance abuse, relationship issues, school struggles, insomnia and learning disabilities. All of these issues are listed as byproducts of living near increases in Air, Noise and Light Pollution. They are also the direct result of living with an existential threat. How will the existential threat caused by this project increase the probability of anxiety within the community? How will the existential threat caused by this project increase the probability of depression within the community? How will the existential threat caused by this project increase the probability of substance abuse and dependence within the community? How will the existential threat caused by this project increase the M Collins The commenter’s concern regarding existential threat is acknowledged. Upset Conditions were discussed in the report. Please refer to the Upset Conditions Event Pathway on page 31 as well as Section 5.4 which details information about upset conditions including psychological impacts such as anxiety, depression, and stress.
- 21 - Comment CommenterResponse probability of relationship issues within the community? How will the existential threat caused by this project increase the probability of academic struggles within the children of this community? How will the existential threat caused by this project increase the probability of insomnia within the community? How will the existential threat caused by this project increase the probability of an increase in learning disabilities within the children of this community? How will the existential threat caused by this project increase the probability of an increase to the suicide rate in this community? Air, Noise and Light pollution will be a reality of this project. As you study these factors and then offer mitigation recommendations, will WE THE PEOPLE be asked to close our windows, move our beds, stay off of our patios and roof decks, raise the sound level of conversations with our friends, family and community or alter the route that our children walk to school. If the answer is yes, then the pressing reality is that this mitigation causes a threat to the way that We Exist. If the way that a community naturally exists is threatened, all of the above mentioned questions become scientifically backed realities that must be included in the EIR. M Collins Please refer to the detailed assessment of Community Livability in Section 5.7 of the report. 1. Positive Health Benefits There are several positive health benefits that are expected to accrue from the E&B project that seem to have been omitted from the report or presented in a way that does not show the strength of the positive effect. a. Lead removal. The HIA does not consider the potential positive health benefits of E&B’s remediation of the existing lead‐contaminated soil at the City Maintenance Yard site. Lead is a known hazard, especially for children, and the removal of contaminated soil by E&B constitutes a long‐term benefit for the City and its residents. While we appreciate that the lead is currently capped in situ, the removal of lead at the E&B It is acknowledged that it is beneficial to remove lead which is present in a way that can result in human exposure. The lead is currently “capped in situ” along with other residual contamination from the former landfill. These contaminants become increasingly of concern with soil excavation and grading which mobilize contaminants. The soil excavation and grading required by the Project creates the pathway to human health impact and the necessity for remediation. Regardless, given that the contaminants are currently capped in place there is no net health benefit from the Project over baseline conditions. Section 4 (Scoping) describes the process for identifying priority
- 22 - Comment CommenterResponse site should be recognized. b. Municipal fire and hazard response capabilities. The mitigation measures for E&B’s project include making funding available to upgrade current deficiencies in the fire department, including upgrading the dispatch system, ensuring HAZMAT trained personnel are available, and funding a new full‐time Fire Marshal/Inspector. These measures will have a very real and positive effect on public safety and emergency response community wide. c. Education funding. Education funding is discussed on pages 139‐142 of the HIA. However, as evidenced in the City Council workshop, it was not clear to some audience members that the additional education funding is not at the discretion of the City (as would be the use of revenues for green space amenities) but is a contractual requirement under the Lease. d. Increase in property values. The HIA considers the adverse impacts of a drop in property values for those proximate to the project site, but does not consider the fact that the substantial increase in City revenue from the project could improve services (municipal services, recreational opportunities, pension benefits, sewers, storm drains, etc.). These improvements could make the City more desirable and potentially increase property values as well as potentially result in public health and safety benefits. health determinants of focus for the HIA. It was through this process that revenue to the City for education and recreational resources were selected for assessment in the HIA. The HIA authors acknowledge that the company has, and may continue, to offer what it believes to be positive benefits to the community. The magnitude and level of these benefits will ultimately be decided on by the community. Text has been added to Section 5.7.4 to clarify that education funding is a contractual requirement under the lease. The HIA relied on the information provided in the CBA with respect to Property Values. We found no information in the CBA that evaluated potential for increase in property values and hence it will not be included in the HIA. 2. Monitoring Program The HIA recommends the establishment of a health monitoring program, and E&B supports this idea, but any such monitoring program should consider the following factors. a. Selection of indicators. In the HIA, there are suggestions for several monitoring approaches that would be inappropriate for gauging the health effects of E&B’s project, such as using health statistics that provide a comparison to the baseline health section and using data on “mortality, cancer rates, birth outcomes and others.” Most of these health outcomes are multifactorial and are influenced by a very wide variety of genetic, behavioral, social, economic and environmental E&B The HIA authors agree that details of a monitoring program including the design of the program, indicators to be included, method of assessment, and timing of monitoring, etc. should be developed with input from stakeholders, the City and the Applicant. If the proposed Project moves forward, the City should work with the Applicant to initiate a monitoring program and hire the appropriate party to develop an appropriate scope of the study and conduct the monitoring. Text has been added to the HIA to describe how monitoring program should be developed.
- 23 - Comment CommenterResponse factors. If there is a change observed in the rates of cancer, asthma, etc., it would be enormously difficult to attribute the change to the project with any scientific rigor. We suggest using a suite of indicators that can more closely be tied to project activities, and that represent changes upstream of eventual health outcomes; for example, indicators of air quality, measured noise levels, municipal revenue devoted to various health‐related programs or projects, etc. Similarly, while a Quality of Life study approach could be informative, the HIA proposes using the SF‐36, which would be inappropriate to gauge project‐related changes in overall Quality of Life, especially if the findings are not correlated with other factors that influence population health trends, such as the aging of the population or changes in economic status of the region. b. Timing. Any monitoring should commence before project‐related construction begins to help minimize the likelihood of overestimating the impact of the project on various indicators. c. Design of the monitoring plan. In order to address the factors listed above, E&B proposes to work with the City to develop a health monitoring plan for the project. The health monitoring plan should specify not only what indicators should be tracked, but at what frequency and using what data sources, to whom the information will be reported and how transparency will be ensured, what comparison or control groups will be used, and how other societal, environmental or economic changes will be accounted for. 8.0 CONCLUSIONS The HIA considered 17 determinants of health that fall under six major categories and were identified as community priorities. Additionally, consideration was given to those determinants that are most likely to be impacted by the proposed Project. Each of these outcomes was carefully assessed using a combination of quantitative, T Fox The commenter has concerns regarding the Project’s negative influence on respiratory effects including asthma and other pulmonary diseases in vulnerable populations, specifically due to odor releases. The HIA authors believe that odors and the associated respiratory symptoms are adequately addressed in the report. Section 5.2.4.1 (Odor and Health) acknowledges that the health consequences
- 24 - Comment CommenterResponse semi‐quantitative and qualitative approaches where appropriate. Ultimately, the aim of the assessment was to determine whether the Project (post‐mitigation) could potentially have a negative, positive or no substantial effect on the health of the community (Table 8‐1). The following were the major findings for the six categories examined: Air Quality The air quality assessment within the HIA concludes that with implementation of the proposed EIR mitigation measures there is no substantial effect on human health with respect to air emissions (NO2, PM and TAC). However, periodic odor releases, identified in the EIR as significant and unavoidable, were characterized as negative near the Project Site. Odor can have various health consequences, and could result in periodic discomfort and annoyance near the Project Site. The Health Impact Assessment Draft states that "According to the census data for Hermosa Beach, approximately 25 percent of the population may be considered to be more vulnerable to certain environmental exposures, based on age (9% over the age of 65 and 16% under 18 years)." Both older and younger people are more prone to asthma and other pulmonary issues; In Los Angeles County, approximately 35% of people in that demographic listed above have asthma. For those of us with lung problems, periodic odor release could present a significant and potentially dangerous trigger for asthma and COPD. This needs to be seriously considered and evaluated. http://www.californiabreathing.org/asthma‐data/county‐asthma‐profiles/los‐angeles‐county‐asthma‐profile of odors can include symptoms of asthma exacerbation (chest tightness, shortness of breath, wheezing). The mechanism by which odors trigger asthma exacerbations is not very well understood but is thought to be a combination of psychological (stress) and physiological factors. The HIA discusses various psychological impacts of the proposed project throughout the report. Because of the health consequences of periodic odor releases, the HIA found a negative health effect from odors, even with EIR mitigation. In addition, respiratory issues including asthma were considered in detail in Section 5.2 Air Quality Assessment. Water and Soil The water and soil quality assessment within the HIA concludes that with implementation of the proposed EIR mitigation measures, there is no substantial effect on human health with respect to surface water quality and soil particulates. Upset Scenarios In the oil spill assessment concludes there is no substantial effect T Fox The HIA authors agree that low probability is not the same as no possibility. As described in the HIA, if an oil spill were to occur, the most likely health outcomes would be acute and reversible. However, if a well blowout were to occur, health outcomes could include serious injuries and mortalities. Overall, the HIA found a negative effect related to the well blowout scenario.
- 25 - Comment CommenterResponse with implementation of the proposed EIR mitigation measures. The blowout assessment within the HIA concludes that there is a low probability of occurrence, but in the event such upset conditions were to occur, they could have significant negative health implications. The HIA recommends that the City incorporate the possibility of an oil spill or well blowout into its current emergency preparedness plan. "Low probability of occurrence" still means that an oil spill is possible and if that were to happen, it would have significant health impact. The outcome of such a scenario should be completely explored and presented to the community prior to any action taken to proceed with this project. Noise and Light The noise assessment within the HIA concludes that, with implementation of the proposed EIR mitigation measures, there is no substantial effect on human health from Phase 1, 2, 3a (site construction) and 4, and a potential negative impact from pipeline construction activities in Phase 3b. Therefore, it is recommended that written notification be provided to residents and schools in the vicinity of these activities that identifies the potential for excess noise and outlines the location and duration of the impacts. The light assessment within the HIA concludes that, with implementation of the proposed EIR mitigation measures, there is no substantial effect on human health with respect to light emissions; however, there is potential for nearby individuals to experience disruption of typical sleep patterns. Therefore, it is recommended that black‐out blinds /curtains be provided for residents whose bedroom window(s) are in the direct line‐of‐sight of the exposed portion of the electric drill rig to eliminate any infiltration of outdoor lighting. There is significant documentation on the negative health impact of sleep deprivation. In an affluent area where people have paid significant amounts for their homes, to suggest that an appropriate measure is to provide blackout curtains is totally unacceptable. T Fox The commenter’s views in opposition to the proposed use of black out curtains are acknowledged. The recommendation that blackout blinds or curtains be provided is provided as an option to those who may desire it (so they don’t have to pay for them themselves). We recognize that residents may prefer to maximize air flow at night and therefore chose not to request blackout blinds or curtains.
- 26 - Comment CommenterResponse Traffic The traffic assessment within the HIA concludes that, with implementation of the proposed EIR mitigation measures, there is no substantial effect on human health with respect to traffic safety and perceived traffic safety hazards. Community Livability The community livability assessment within the HIA concludes that with implementation of the proposed EIR mitigation measures there is: no substantial effect on human health with respect to social cohesion; a potential negative effect from stress over property values, aesthetic/visual resources; and a potential positive effect on health from enhanced recreation and green space, educational funding and political involvement activities. This flies in the face of Hermosa's intention to be a "Southern Calfornia's Greenest City" and its stated goal to have zero carbon emissions. T Fox The commenter’s views in opposition to projects with carbon emissions are acknowledged. Overall Conclusion There is no simple answer to the potential impact that the Project will have on the health of Hermosa Beach residents since different aspects of the proposed Project will impact the community in different ways. We caution that the assessment and conclusions are based on population health and not on single individuals. There are a number of aspects of the Project that may positively influence health (e.g., increased education funding, ability to enhance green space), and at the same time there were potential negative health outcomes identified (e.g., odor, blowouts, property values). With the exception of accidents, the negative health outcomes were largely nuisance related (e.g., odor, aesthetics) without irreversible health impacts. The majority of the health determinants examined revealed that the Project (post‐mitigation) would have no substantial effect on the health of the community. In Los Angeles County, 23% of children from ages 1 to 17 and 12% of adults over age 65 have asthma. Asthma is a potentially fatal disease. Given that 25% of Hermosa's demographics fall within that category, T Fox The HIA authors acknowledge the commenter’s concern regarding the Project’s negative influence on respiratory effects including asthma and other pulmonary diseases in vulnerable populations. The HIA authors believe that odors and the associated respiratory symptoms are adequately addressed in the report. Section 5.2.4.1 (Odor and Health) acknowledges that the health consequences of odors can include symptoms of asthma exacerbation (chest tightness, shortness of breath, wheezing). The mechanism by which odors trigger asthma exacerbations is not very well understood but is thought to be a combination of psychological (stress) and physiological factors. The HIA discusses various psychological impacts of the proposed project throughout the report. Because of the health consequences of periodic odor releases, the HIA found a negative health effect from odors, even with EIR mitigation. In addition, respiratory issues including asthma were considered in detail in Section 5.2 Air Quality Assessment.
- 27 - Comment CommenterResponse I think that *anything* that has the potential to impact lung disease‐‐whether specifically from irritating particulates or indirectly from "periodic odor releases" ‐‐‐ should be seriously considered as having health impact. In my opinion, this report minimizes the impact on lung disease and should be revised to include potential impact on asthma and COPD. http://www.californiabreathing.org/asthma‐data/county‐asthma‐profiles/los‐angeles‐county‐asthma‐profile Please note that the Health Impact report states the following: • According to the census data for Hermosa Beach, approximately 25 percent of the population may be considered to be more vulnerable to certain environmental exposures, based on age (9% over the age of 65 and 16% under 18 years). The assessment states that the pollution levels are already above levels that can cause cancer, so why should we allow drilling in our environment that would increase the pollution further, even incrementally? C Furnberg The commenter’s opposition to any project that would results in emission of air pollutants into the air shed is acknowledged. I am concerned about the absence of specific information in the reissued draft that pertains to me, my family and my neighbors. I live approximately 500 feet from the drilling site, am pregnant, and by the time this project begins will have one or more small children. Accordingly, I assume that my family and I fall into the "vulnerable population" for most of the categories discussed in the HIA. However, the HIA fails to provide a definition for "vulnerable population," so I am forced to speculate as to whether I am part of that population. All the HIA tells me is that vulnerable populations "may be disproportionately affected by the project." Each health determinant evaluation matrix identifies a "vulnerable population," but stops there. The reissued draft does not explain how that population will be affected, nor does it provide a specific explanation of who falls into that vulnerable population. One example of a "vulnerable population" that requires more explanation is in Table 5‐19 "Upset Scenario." The reissued draft identifies the vulnerable population as "people in immediate vicinity." What radius constitutes the immediate vicinity? Does this mean immediate J Hamill The commenter’s concern regarding her family, her small children, and her risk from the Project given that her family lives 500 feet from the site are acknowledged. Vulnerable populations are defined in the HIA as “populations that could be disproportionately affected by Project activities”. Increased vulnerability depends on the health determinant. In general, age (i.e., age<18 and age>65) is an important factor for determining vulnerability. Factors such as pre‐existing disease, pregnancy, and genetics can also influence vulnerability to adverse health outcomes. The health effects associated with vulnerable populations are the same health outcomes examined for the population in general in the case of each health determinant assessed in the HIA. The difference being that vulnerable populations are at increased risk compared to the general population (children are more vulnerable to traffic injury because of slower reaction times and drivers are less likely to notice a small child). For the well blowout scenario, the EIR estimated that offsite fatalities
- 28 - Comment CommenterResponse vicinity of the drill site, the pipelines, or what? I would like to know how many people are in the "vulnerable population" for each health determinant identified. I would also like to know what health effects the "vulnerable population" can expect to experience. The reissued draft does not provide that information. Its conclusions appear to be the health effects that the "non‐vulnerable" population may expect to experience in a best case scenario. and injuries could occur as far away as 300 and 750 feet, respectively from the Project Site (Figure 4.8‐5; MRS, 2014). Text has been added to Table 5‐19 to clarify that immediate vicinity is defined as 750 feet, in the case of a well blowout. The exact number of people that represent a vulnerable population for each health determinant was not available to the HIA team and represents an information gap in the HIA. The result is laughable and untrustworthy "post‐mitigation health effects." For example, Table 5‐ 18 describes a Crude Oil Spill Upset Scenario. Through the use of the "novel" evaluation matrix, the reissued draft concludes that there is "no substantial health effect" from a crude oil spill, while admitting that the possibility of a spill occurring is not possible to mitigate completely. I am no scientist, but I believe a crude oil spill would result in a substantial health effect. J Hamill The commenter’s views in opposition to the conclusion of “no substantial health effect” from a crude oil spill are acknowledged. Another laughable item in the reissued draft is the suggestion that individuals in the direct line of site of the drill rig be provided with blackout curtains to eliminate the potential for infiltration of light emissions from the nighttime lighting on the drill rig. If I wasn't living so close to the project site, I might find this funny. Instead, I find it ridiculous and deeply disturbing. J Hamill The commenter’s views in opposition to use of blackout curtains are acknowledged. The recommendation that blackout blinds or curtains be provided is provided as an option to those who may desire it (so they don’t have to pay for them themselves). We recognize that residents may prefer to maximize air flow at night and therefore chose not to request blackout blinds or curtains. Due to the serious potential adverse health impacts described in the original draft health impact assessment, I feel that my family and I deserve to know exactly what we can expect from this project, and we deserve to have it explained in terms that we understand. Washing over it and dismissing us as a "vulnerable population," without explaining what that means for our health, is simply not enough. I am concerned about the 180 degree turn from the conclusions in the original draft, attached as Exhibit A, from the conclusions in the reissued draft. I created the table at the end of this letter to show the dramatic difference between the conclusions in each draft. The rationale for the reissuance is: "The February draft RIA was largely J Hamill The commenter’s views in opposition to the reissued report’s conclusion are acknowledged. The HIA authors do not believe that the information was reported in a manner which could be interpreted as dismissive and strived to present the information in a way that could be easily understood by the public. Please refer to the above response to comment about concerns regarding vulnerable populations for additional information regarding the meaning of that term. It was the decision of the HIA consultants to request that the City retract the initial draft HIA. While the rationale for the reissued HIA does include the more appropriate focus on post‐mitigation scenarios,
- 29 - Comment CommenterResponse based on the results of potential impacts of pre‐mitigation scenarios of the Project. .. This revised draft of the RIA ... assesses the Project on the basis of post‐mitigation scenarios." However, the original draft HIA stated that it considered these mitigation scenarios in its analysis. In fact, the original draft RIA concluded, "[m]itigation measures proposed in the EIR slightly decrease the ranking for odor, soil deposition, and traffic injury, but otherwise did not change the relative importance of the potential health impacts." I am concerned about the questionable manner in which this reissued draft came to be. Shortly after the original draft was released to the public, E&B sent a demand letter to the City through its attorneys, demanding that the City "retract and disavow" the draft. A copy of the letter is attached as Exhibit B. E&B demanded that the original draft "be immediately withdrawn by the City, with an acknowledgment by the City that it lacks scientific integrity and that it needs to be substantially revised to reflect compliance with recognized laws and scientific standards." E&B concluded with "the City must immediately retract the RIA and acknowledge that it has not been prepared in compliance with applicable laws and regulations." E&B forced the City to retract and disavow the original draft, forced the City to say that the original draft lacked scientific integrity, and forced the City to say that the original draft was not prepared in compliance with applicable laws and regulations, all under a thinly veiled threat of litigation. the changes between the initial and reissued draft were also the product of the reevaluation of the HIA by additional scientists on the HIA project team with expertise in a number of the areas assessed taking into account the written and oral comments on the February draft HIA calling for extensive revisions, and the information in the Final EIR. Both the original draft and the reissued draft acknowledge that there are no laws requiring the use of a health impact assessment, and there are no laws or globally accepted standards for health impact characterization in health impact assessment. So why did we need a reissued draft? The reissued draft admits it uses a "novel evaluation matrix." Why is that better than what was used in the original draft? If it is novel, doesn't that mean it has not been used before? Why should we trust this over the original? Strangely, the reissued draft was reformatted and rebranded to make it appear as if a different company prepared it. According to the McDaniel Lambert website, McDaniel Lambert joined Intrinsik on J Hamill While the rationale for the reissued HIA describes the need for the new report, including a more appropriate focus on post‐mitigation scenarios, and the written and oral comments on the February draft HIA calling for extensive revisions. The word “novel” has been removed from the description of the evaluation matrix. While the project team who prepared the initial report also worked on the reissued report, the team also expanded, adding additional scientists to the HIA project team with expertise in a number of the areas assessed. The McDaniel Lambert integration into Intrinsik had occurred by the time of the re‐issued draft and the company is now operating as Intrinsik, hence the update to the report format.
- 30 - Comment CommenterResponse August 16, 2013‐‐ approximately six months before the issuance of the original draft. The same people who prepared the original draft prepared the reissued draft, but instead of calling themselves McDaniel Lambert, they called themselves Intrinsik. This was pointed out by Elizabeth Hodges Snyder on page 2 of her July 2, 2014 memorandum, but it appears her comment was ignored. Why should we believe that a new draft issued by the same people would have any more scientific integrity than the original? The nature of this project is unique in that that the citizens of Hermosa will vote on whether to lift ban on drilling. Accordingly, special attention should be paid to providing an unbiased and informative presentation of all potential health issues. Anything less is irresponsible. E&B has already seized on the whitewashed conclusions in the reissued draft HIA and uses them as propaganda to persuade voters that this project is completely safe. Attached as Exhibit C is a screenshot of the E&B website touting the reissued draft conclusion that "we do not believe that the Project will have a substantial effect on community health in Hermosa Beach." That statement ignores every adverse health effect described by the same people in the original draft HIA, and every vulnerable population mentioned in the reissued draft HIA. It is irresponsible, misleading and dangerous. 1. Noise and Light: An increase in unwanted light emissions emanating from the 87 foot drilling rig is identified as having the potential to interfere with typical sleep cycles in nearby, line of site residences (page 103). Please explain how this does not have the potential to cause negative adverse health effects in these individuals.S Hebl The HIA does conclude a potential negative health effect for in those individuals with a line of site to the drill rig. Table 5‐26 states “Although the magnitude [of the health effect] is ‘low’ for the majority of residents, it could be higher for those individuals with a bedroom window in the direct line‐of‐sight of the exposed side of the electric drill rig that will be lit at night. It is recommended that these individuals be provided with blackout blinds or curtains to eliminate any potential impact to typical sleep patterns.” 2. Likewise, the notion of distributing “black‐out shades” to nearby residents affected by the unwanted light emissions is discussed. While this mitigation, if acceptable to the residents, may help with light emissions, it is likely to cause increased levels of stress, frustration, and a perception of loss of control over the home environment that would have negative health effects. S Hebl The recommendation that blackout blinds or curtains be provided is provided as an option to those who may desire it (so they don’t have to pay for them themselves). We recognize that residents may prefer to maximize air flow at night and therefore chose not to request blackout blinds or curtains. The text in the HIA is revised to clarify that the blackout curtains or shades are optional. It is acknowledged
- 31 - Comment CommenterResponse The feelings of loss of control are likely to be particularly pronounced given the high property values in the area and the undesirable idea that the city is required to distribute black out shades to residents of $1,000,000+ homes in order to shield them from negative health effects from a public nuisance (i.e unwanted night time light pollution). This is likely to elicit increased stress and frustration from the loss of control over the home environment as well as the fear of decreased property values due to the intrusive nature of the proposed mitigation. Please update table 5‐26 to take into account the practicality & limited effectiveness of the proposed mitigation (installation of black out shades in affected residences). Considering the impractical nature of this mitigation & the intrusion into the home environment, the adaptability and likelihood are misstated in the table. A conservative review would not use the black‐out mitigation measure to reduce the likelihood or increase the adaptability, as the feasibility of this mitigation is unknown (i.e acceptance by nearby residents). Likewise the increased stress and frustration due to the loss of control of the home environment and perception of impaired home values is completely missed and has the potential for negative health impacts. Please update the summary on page 105 and page ix to properly account for the potential adverse health effects due the interruption of sleep patterns and the adverse health effects due to increased stress and frustration resulting from the loss of control over the home environment due to the need to install black out shades in residences. that the opinion of the commenter is that the blackout shades have limited practicality and effectiveness. Please see Section 5.7.1 Property Values for a detailed discussion regarding negative health impacts including stress from fear of decreased property values. 3. The Upset Conditions summary (Blue Box page viii, page 78) should include the already documented (page 78) potential negative, moderate impact to health caused by elevated levels of distress over the possibility that a blowout could occur. When a post‐mitigation, potential negative effect on health is identified it should be referred to in the summary. S Hebl The text in the blue box summary has been revised to include stress due to fear of a potential blowout.
- 32 - Comment CommenterResponse 4. Upset Scenarios: Table 8‐1 (pg 157) The potential health outcomes due to Well blowout effects should be separated into two categories: a.) Injuries and/or fatalities b.) psychological effects including stress. The framework attributes (magnitude, adaptability, and likelihood) are very different for these two health outcomes and thus it is not appropriate to group them together. The assessment currently uses the same likelihood rating for injuries due to a blowout and negative psychological effects includes stress due to concern over a blowout. Clearly the likelihood of these two events is not the same. S Hebl Section 5.4.2 addresses both injuries/fatalities and psychological effects as health outcomes due to a well blowout. It was the decision of the HIA authors to assess a well blowout scenario as a single health determinant. The commenter’s views in opposition to this decision are acknowledged. 5. Community Resources: Access to Recreational Resources and Green Space: The Draft HIA does not account for the significant, unavoidable environmental impact that results from incompatible land use with existing adjacent land uses as certified in the FEIR. The FEIR states on ES‐9, ES‐10 “The drilling, construction, and potential future operations would be in close proximity to land uses zoned as open space (parks, baseball fields and the Greenbelt) and residential. Proposed Oil Project activities during all phases may generate significant noise, odor, and visual impacts that would be incompatible with these adjacent land uses.” Table 5‐32 in the draft HIA speculatively suggests that potential revenue from the project may be used to “improve or expand existing tideland recreational or green space conditions” however it does not consider the negative effect on the nearby parks and open spaces due to the nature of the incompatible land use. The certified FEIR states that certain activities that may occur during all phases of the project would be incompatible with the existing nearby parks, baseball fields & Greenbelt. This has the potential to reduce usage of the nearby parks & green space (greenbelt, Ardmore park, South Park, Bi‐Centennial Park). Likewise, on page 129 it is stated “there were no vulnerable populations identified for access to recreational resources and green space”, however the green belt is approximately 80 feet from the project site, and the nearest park (Ardmore park) is approximately 230 feet from the project site. Since local risks were identified due to residential dwellings being in close proximity to the project site (150’ to the north, 180’ to the east, 250’ to the west) the same negative S Hebl The Final EIR (FEIR) found a significant and unavoidable impact because noise, odors, and visual impacts generated from the proposed Project are incompatible with adjacent land uses (Section 4.10.4.1 Land Use). The health impacts due to noise, odors, and visual impacts are addressed in the HIA. The FEIR evaluated recreational use separately from incompatibility with adjacent land uses. In Section 4.10.4.2 (Recreation), the FEIR reads: “The Proposed Project may create noise, odor, and visual impacts nuisances to recreational users, especially users of the Veterans Parkway Greenbelt as they pass by the Project Site. However, the impacts of passing by the Project Site while using the Greenbelt would be short term, temporary, and avoidable. Therefore, this impact would be considered less than significant (Class III).” The FEIR identified a potential significant impact on recreation in the case of an oil spill from the pipeline. Therefore, we believe that the findings in the HIA are consistent with the FEIR’s findings that the proposed project would have a less than significant impact to recreational users. It is noted that the HIA does address the potential impacts to recreational users throughout the report (e.g., traffic section assessed the impact to the Greenbelt due to construction and truck traffic activities, surface water and oil spill sections assessed the impact to beach‐swimmers). Additionally, text has been added to the Final HIA to acknowledge that there will be disturbance to recreation and green space nearby the Project Site due to construction activities. The Final HIA still concludes an overall
- 33 - Comment CommenterResponse health impacts affect the parks and green space that are located 80’ and 230’ from the project site. Given that vulnerable populations frequently visit these locations (e.g children), the risks (real or perceived) from the project site will likely reduce access to nearby parks and green space. Additionally as stated elsewhere in the document the fear of fugitive emissions (particularly contaminated lead soil during drilling & clean‐up operations) and odor will likely reduce the perception of the available parks & green space in these locations. This is the very reason that the FEIR finds the proposed project to cause significant unavoidable impacts to the surrounding environment due to the nature of the incompatible land use. It is a significant oversight to not assess the effect of the incompatible land use on the surrounding parks & green space in close proximity to the proposed site. Please update this section and include this analysis in table 5‐32. The significant noise, odor, and visual impacts that may be generated during all phases of the project are likely to reduce the usage of parks & green space in the surrounding area due to a perceived reduction in quality of the nearby parks & green spaces. Likewise please remove the statement in the first paragraph on page 129 “Since there will be no impact to existing green space in Hermosa Beach”. The FEIR states exactly the opposite by certifying that there is a significant and unavoidable impact to the parks and green spaces in close proximity to the proposed site due to the incompatible nature of land use. In summary, there will be a negative impact on access to green space due to the close proximity of parks to the project site and the incompatible land use. positive impact to recreational areas and green space due to the increased revenue coming into the City, particularly with regards to the Tidelands Fund, available to improve beach and coastal areas used for community recreation. The cited text (page 129 of Draft HIA) has been revised to state “Since there will be no impact to the amount of existing green space in Hermosa Beach”. This statement reflects the fact that the proposed Project would be constructed on an existing previously developed light industrial site and no additional land (i.e. no additional green space) would be acquired for the proposed Project. 6. Community Resources: Aesthetics and Visual Resources The analysis on page 136 of the health effects due to the unavoidable significant environmental impact to visual aesthetics does not follow the decision making framework on page 18, and no substantive explanation is provided to justify this deviation. Based on the health determinant framework on page 18, there is a Post‐Mitigation Health Effect category specifically named “No Substantial Effect”, which is defined as “there is no substantial effect expected following S Hebl The text “…however, this is not anticipated to have a substantial effect on health” was removed from the HIA (page 148 of the Draft HIA).
- 34 - Comment CommenterResponse implementation of the EIR mitigation measures”. However, the assessment table 5‐33 (page 139) determines that the post mitigation health effect due to the degradation of the visual environment is Negative, which is defined as “the effect is expected to negatively influence health following implementation of EIR measures”. The summary statement in the first paragraph on page 148 states “This has the potential to influence levels of annoyance and stress; however; this is not anticipated to have a substantial effect on health.” If the health effect due to the degradation of the visual environment is not expected to have a substantial effect on health, than it should be classified in this manner using the health determinant framework. There is a specific category for this finding which is titled “No Substantial Effect (Neutral)”. However the finding in table 5‐33, as a direct result of using the health determinant framework, is that the degradation of the visual environment WILL have a Negative health effect. Please remove the unsupported commentary that states “this is not anticipated to have a substantial effect on health” on page 148. 7. Air Quality Summary (Page vi): The summary in the blue shaded block does not agree with the detailed discussion on the impacts of odor exposure on page vii and pages 63‐64. Paragraph three on page vii states “According to the WHO, odor annoyance can also affect overall quality of life” yet the summary in the blue shaded block characterizes the health consequences due to odor exposure as “periodic discomfort and annoyance near the Project site”. The summary should be strengthened to state “Odor can have various health consequences, and could result in periodic discomfort and annoyance near the Project site including a reduction in quality of life for sensitive recipients.” Likewise, Table PS‐2 classifies the Potential Health Outcome of Odor Emissions as “Acute health symptoms”. However in the comments cell on the same row and on page 64 it is stated “Periodic discomfort & annoyance from odor releases is likely”. Likely exposure to a noxious odor suggests more than an acute health risk and on the contrary suggests a longer term chronic health impact since the S Hebl The blue shaded blocks summarize the detail provided in the text. The various health consequences referred to in the statement “odor can have various health consequences” include headaches, nasal congestion, eye, nose, and throat irritation, hoarseness, sore throat, cough, chest tightness, shortness of breath, and overall quality of life. These health consequences are written out just below the shaded block in the Project Summary (and also in the odor section of the text). The HIA addresses the potential for increased stress due to the proposed Project throughout the HIA report.
- 35 - Comment CommenterResponse individual’s quality of life is hampered. Exposure to odor releases from the project should be more clearly stated as having a potential negative affect on human health for individuals near the project site with the potential to negatively affect their quality of life. Additionally increased stress and reduction in quality of life is likely to be experienced by nearby residents of the project due to loss of control over their home environment. Many Hermosa Beach residents do not have air conditioning installed in their homes and make extensive use of window ventilation during the day and night. Due to the real or perceived risk of impacted air quality, odor emissions, and fugitive contaminated soil or airborne particles, these residents may feel stress over either leaving the windows open or stress over not being able to open the windows without concern for their health. 8. Upset Conditions (Page viii, page72‐75): Please explain why an oil spill scenario resulting in leakage to the ocean is the only spill scenario used to calculate the likelihood of such an event. The analysis should focus on the likelihood of all oil spills, including pipeline & truck spills and not be constrained to spills that only result in leakage to the ocean. Leakage to the ocean is not required to cause adverse health effects. This may not change the likelihood estimate; however it is technically more appropriate. S Hebl The Upset Conditions analysis was based on identification of the incidents that could present the highest risk to the public in conjunction with the greatest stakeholder concerns which were identified during the scoping meeting and subsequent communications. 9. Housing Prices: The HIA proposes that E&B consider conducting a property value analysis then continues on to state (page 123) “This would help to ensure that any observed fluctuations on property values remain within expected levels and consistent with other similar communities”. A survey can in no way ensure that property values remain within any stated level. The survey can only document a pricing fluctuation but obviously it cannot ensure that property values remain within expected levels. Please modify this statement. S Hebl The sentence referred to by the commenter has been corrected to state “This would help document any observed fluctuations in property values and show whether they remain within expected levels consistent with other similar communities”. The Draft HIA identifies five potential negative health effects to people in close proximity to the oil & gas drilling site. However this important finding is not referenced in the executive summary or overall conclusion. The HIA should be health protective and inform the voting public of all possible post‐mitigation health impacts due to S Hebl The HIA authors acknowledge the commenter’s views regarding the content of the current summary, and an Executive Summary has been added to the report.
- 36 - Comment CommenterResponse the project in a straightforward and visible manner. Please modify the conclusion statement/summary to reflect the identified health impacts as follows: Based on the proposed mitigation measures in the EIR and additional recommendations provided by the HIA, on balance we do not believe that the Project will have a substantial effect on community‐wide health in Hermosa Beach. However five negative possible health effects were identified for local residents in close proximity to the project site. I find inconsistencies with the rationale for the overall summary conclusion in the reissued Draft HIA which states in part “… on balance we do not believe that the project will have a substantial effect on community health in Hermosa Beach.” At the public study session on July 22nd, Intrinsik personnel stated that the “no substantial effect” summary was supported by the rationale that the 5 negative health impacts were localized impacts and/or low probability and that the 3 positive health impacts were community wide. It was reasoned that the community wide effect of the 3 positive health impacts offset the localized nature of the 5 negative impacts. S Hebl The HIA authors did not intend to imply thatpositive health impacts will offset the negative impacts. It was consideration of all outcomes, negative, no substantial effect, and positive that let to this conclusion. However upon deeper analysis, there are no positive impacts identified that have a direct impact on human health. The three positive impacts identified in the report are: Recreation & Green Space, Political Involvement, and Education Funding. The proposed project would not produce positive health effects due to Recreation & Green Space. The final EIR concludes the opposite and in fact that there is a significant, unavoidable environmental impact to adjacent land uses from the proposed project activities. The FEIR specifically includes “parks, baseball fields, and the greenbelt” in the description of adjacent land. The project impacts that are identified in the HIA and referred to as “nuisance related” degrade the quality of the surrounding parks & green space and impair these resources. It is also logical to reason that given fears of other more serious risks (fugitive lead particles during site preparation and/or clean‐up, fear of a blow‐out, or other accidents) that the perception of S Hebl The commenter’s views that there are no positive health impacts resulting from the Project are acknowledged. The following statement has been removed from the HIA: “Since there are thousands of operating and proposed oil and gas wells in the state of California, particularly along the coast, it is reasonable to assume that the existence of oil project has not negatively impacted physical activity levels in other communities”. Additionally, text has been added to the Final HIA to acknowledge that there will be disturbance to recreation and green space nearby the Project Site due to construction activities. The Final HIA still concludes an overall positive impact to recreational areas and green space due to the increased revenue coming into the City, particularly with regards to the Tidelands Fund, available to improve beach and coastal areas used for community recreation.
- 37 - Comment CommenterResponse these adjacent land uses is impacted which makes these locations less desirable. The city of Hermosa Beach has twenty four parks & green spaces and of these, six are located within 600 feet of the proposed site. Thus 25% of the city’s parks & green spaces (Ardmore Park, Bi‐Centennial Park, South Park, Clark Stadium, Greenbelt, 8th street & Valley) would be degraded, per the significant unavoidable environmental impact certified in the FEIR, by the proposed project. The statement on page 128 of the Reissued Draft HIA, which states that since the coastline of California has one of the lowest rates of physical inactivity and that “thousands of operating and proposed oil and gas wells exist” in these regions that it is reasonable to assume that the existence of oil projects has not negatively impacted physical activity does not adequately support the assumption that impairment of 25% of the city’s park & green space will not negatively impact physical activity in Hermosa Beach. The comparison to physical activity levels along the coast of California in the presence of “thousands of oil wells” is seriously flawed and does not take into account the size of municipalities, location of the oil wells in relation to parks & green space, or a number of other important factors. Please remove this supposition from the report. Please update this analysis in the final report, and identify Green Space and Recreation as a negative health impact, not a positive health impact resulting from the project. As described in response to S Hebl comment 5 above, the FEIR found that the overall impact to recreation would be less than significant. The FEIR identified a potential significant impact on recreation in the case of an oil spill from the pipeline. The findings in the HIA are consistent with the FEIR’s findings that the proposed project would have a less than significant impact to recreational users. The proposed project would not produce positive health effects due to Political involvement. The decision to proceed or not proceed with the project does not fully lie in the hands of each individual resident. As such, the health benefits due to self‐efficacy do not exist at the individual level. It is widely apparent that the project is highly controversial and both the opponents and proponents are impassioned. Given that individuals have such strong feelings, but no direct, total control over the outcome, there is no increased benefit due to self‐efficacy. On the contrary, many residents feel threatened by the project due to the potential for negative health effects, and thus experience high amounts of stress and anxiety over the political involvement. Refer to the Health Impact Assessment Community Survey conducted by McDaniel Lambert, Inc (page 9 of Original draft HIA) which concludes that 93% of residents polled are concerned S Hebl The HIA authors acknowledge the commenter’s opposition to the conclusion regarding political involvement and have considered that individuals do lack complete control over the outcome of the project. The stresses involved and the potential negative health effects have also been addressed in the social cohesion section. However, the HIA authors wish to point out that unlike the vast majority of projects of this nature, it is the community that gets to decide through their vote whether the Project moves forward or not.
- 38 - Comment CommenterResponse about the potential health impacts resulting from the project. In addition, countless individuals dedicate significant amounts of their personal & leisure time to contribute to the voting debate (due to the public nature of the vote) and this impacts the health of these individuals. The lack of full control over the outcome and the stress and anxiety by those residents who feel threatened by the project have not been taken into account in your analysis. Please include this analysis in the report. These factors neutralize any potential positive benefits due to political involvement and cause this determinant to be Neutral. Please update this analysis in the final report. The Reissued Draft HIA suggests there would be a positive health benefit due to increased education funding resulting from the project, however no basis is provided to justify how the miniscule increase in funding will have a causal positive effect on human health. The Hermosa Beach City School District budget for fiscal year 2014‐2015 is $10,186,219.00 (per the 14/15 budget approved by the School Board at the June 11, 2014 Board of Education Meeting – Appendix B). Thus the forecasted project contribution of $52,000.00 per year amounts to a 0.5% increase in educational funding. In order to support the assertion that a 0.5% increase in educational funding would have a community wide positive effect on human health, details need to be provided to describe how this small increase in funding would increase the state of education to a level substantially higher than is currently present. Any increase in educational funding is beneficial, however the question is does the amount of the increase provide such a benefit to the school district that it causes a change in the quality of education provided, and therefore a benefit to human health. In a school district where the quality of education provided is already extraordinarily high, a significant increase in revenue would be required to change the quality of education such that there is a measurable impact on human health. A 0.5% increase in funding is not significant enough to change the state of education provided by HBCSD and thus have an effect on human health. In the same manner that a 0.5% decrease in annual funding would not have a community wide negative impact on human health. Clearly the extent of the health impact (magnitude) due to a 0.5% increase in annual educational funding is LOW. S Hebl The HIA authors acknowledge the commenter’s opposition tothe conclusion regarding education funding and encourage the commenter to reach their own conclusion by applying a low magnitude to the HIA decision making framework. The statement “The average annual contribution to Hermosa Beach City School District would increase funding between 4% (based on CBA expected) and 9% (based on Applicant estimates)” has been corrected to state ““The average annual contribution to Hermosa Beach City School District would increase private funding 4% (based on average CBA expected) or 9% (based on average Applicant estimates) during peak production years.”
- 39 - Comment CommenterResponse Also please correct the statement on page 141 that incorrectly states “The average annual contribution to Hermosa Beach City School District would increase funding between 4% (based on CBA expected) and 9% (based on Applicant estimates). “ These percentages were incorrectly calculated based off of the contribution from the Hermosa Beach Education Foundation, and instead should be calculated based off of the annual school district budget. Also, the same section refers to two potential figures for educational funding from the project – CBA expected and Applicant estimates. This is a biased approach since in addition to the CBA expected estimate, the highest estimate is also presented without presenting the lowest estimate (CBA low). Please remove this bias by either removing the Applicant estimate or also present the CBA low estimate. Also please review the entire report for other instances of similar bias which are present. Finally, it should be noted that the value of the annual educational funding will erode significantly over the life of the project since the $0.20 per barrel education tax is fixed and does not adjust for inflation. In summary, the magnitude of the educational funding provided by the project is LOW since based on the CBA expected estimates it would account for a 0.5% increase in annual funding, which would not increase the already high quality of education provided by HBCSD in a manner that would have an effect on human health. The result is that the educational funding provided by the project would have No Substantial Effect on human health. In conclusion, the three positive health impacts that have been identified in the Reissued Draft HIA are misclassified. The proposed project’s effects on Recreation and Green space would have a negative health impact, the miniscule increase in Educational Funding would have No Substantial Effect on human health, and the lack of full control and associated stress and anxiety would cause the effects of Political Involvement to be Neutral. Thus, there are no community wide positive impacts on human health that would offset the already identified localized negative health impacts. And in fact as my previous letter describes the number of negative health impacts is actually eight (Odor Emissions, Well Blowout – physical harm, Well S Hebl The HIA authors acknowledge the commenter’s views that there are no positive health impacts resulting from the Project, specifically the effects on recreation and green space, education funding, and political involvement. An Executive Summary has been added to the report to provide a summary of both positive and negative impacts as determined in the assessment sections of the report.
- 40 - Comment CommenterResponse Blowout – psychological effects including stress, Noise Emissions, Access to Recreation & Green Space, Light Emissions, Property Values, Aesthetic and Visual Resources) It may still be accurate that residents who do not reside in close proximity to the oil and gas drilling project would not experience any health effects related to the project. However, the fact that residents in close proximity may experience negative health impacts should be clearly mentioned in the final report summary. May I suggest the following wording which is transparent, unbiased, and accurately reflects the findings in the report: “Based on the proposed mitigation measures in the EIR and additional recommendations provided in the HIA, we do not believe that the Project will have a substantial health effect on most residents in Hermosa Beach, however residents in close proximity to the Project could experience negative health effects.” As a final point, please modify the overall summary conclusion provided in the report so that it is transparent and unbiased. Some residents may read only the summary statement of the report and thus extra care should be exercised to ensure that the summary statement transparently reflects the findings in the report. To this effect, please include the total number of potential negative and positive health impacts in the overall summary statement. This will make the findings of the report easily accessible to all readers and also less prone to misinterpretation. The current summary provided in the reissued Draft HIA is overly prone to misinterpretation, is not transparent, and disregards the finding that there is the potential for localized negative health impacts by not providing this information in the summary statement. S Hebl The HIA authors acknowledge the commenter’s views regarding the content of the overall summary conclusion statement, and an Executive Summary has been added to the report. I have lived in Hermosa Beach at the above address since 1979 (35 years). I hope the Hermosa Beach Council does not allow the decibel level of the "Keep Hermosa Hermosa" movement to be decisive in their ultimate decision. I know the former Hermosa Beach as much many, if not most, of them, and can remember when I could still buy kitchen hardware on Hermosa Avenue. The new Hermosa has chi‐ chi boutiques and semi‐affluent suburbanites hoping to increase their unearned riches by selling each other over‐priced real estate. Not much of the "old" Hermosa is left. And if a majority really wants to be free of sordid businesses such as slant drilling, that means they want B Hood The voters will make the final decision on whether or not the proposed Project is approved.
- 41 - Comment CommenterResponse other localities to soil themselves with commerce so that we can continue to bum oil in the motor vehicles that still pack our roads. Being "environmentally aware" is the orthodoxy of today, but it is often based on a superficial desire to spout whatever is considered trendy. I urge the city council to base its decision on deeper issues, such as the prosperity and future wellbeing of all citizens. As I understand it, existing levels of PM2.5 already exceed WHO levels. In table 5.7 on page 51 Intrinsik lays out their estimates of existing PM2.5 levels and the impact of the project. On each line of the table there is a significant % increase in the post project PM2.5 levels. However, because Hermosa is already over the healthy threshold they magically conclude that further increases over that healthy threshold will have no substantial effect on our health. This makes no sense at all. More of a bad thing (PM2.5), which is ALREADY at too high a level, must surely have an adverse effect on our health. Their conclusion needs to change. I Lee‐Leviten WHO recommends an annual concentration of 10 µg /m3as the annual air guideline for PM2.5 and the California and US standard is 12 µg/m3. Assuming the background annual air concentration in Hermosa is similar to South Coastal Los Angeles County levels; the predicted PM2.5 averaged across the community (baseline + project) results in concentrations of 10.46 to 10.66 µg/m3, and is within the California/US standard. As described in the HIA, in the study that the WHO guidelines were based on, there is statistical uncertainty in the PM2.5 risk estimate below approximately 13 ug/m3. Therefore, the HIA authors believe that the California/US standard provides a more appropriate health‐based benchmark. Commenter’s opposition to the conclusion in the assessment of particulate matter is noted. The HIA concludes that there is a positive health effect from enhanced recreational opportunities and from political involvement. This is so ridiculous they should have been incredibly embarrassed to write this stuff. I believe most people in Hermosa beach would feel that the recreational opportunities are already more than adequate. The idea that we need the oil royalties to enhance the recreational opportunities is just incorrect. As to the health benefits of political involvement, the people from Intrinsik obviously have not been awake during the council meetings that I've seen them at. The stress levels from this project are through the roof for many people especially for some of the "vulnerable populations" who live near the project. The ability to vote isn't reducing anybody's stress. Intrinsik needs to watch the videos of the July council meetings. The HIA cover page mentions Science, Integrity and Knowledge. These items seem to be missing from their analysis of Community Livability. They seem to be applying neither science nor common sense. I don't believe that for anyone living in Hermosa I Lee‐Leviten Comment in opposition to conclusions regarding political involvement, recreational opportunities, and community livability is acknowledged.
- 42 - Comment CommenterResponse Beach that the stress from thinking about the risk of a blowout, the noise, the light pollution, the smell, the health risks (despite what Intrinsik tells us) and all the other disadvantages of this project can in any way be reduced or offset because residents can vote. Personally, I wonder why they felt the need to go to such absurd lengths to create so‐called benefits. Odd isn't it? This section needs to be much revised or eliminated from the final draft. Hermosa Beach does not need the toxic liability caused from drilling for oil. The proposed 30 wells would waste 30 million gallons of precious water. The toxic chemicals and sand belching back up to be trucked away would inundate the traffic on Valley. Overflow would increase the traffic on Ardmore and our friendly neighbors where the traffic of toxins would try to run through their city might sue to stop the danger. If an accident were to occur the oil company and Hermosa Beach would be sued. That is not a good possibility. The healthy green belt right in front of the digging noise, water and air pollution site will do little to encourage the exercising walkers and runners. The fresh air and the quiet atmosphere will be destroyed. Next door the Clark Building used for quiet community meetings will lose its atmosphere. The outdoor lawn bowling, tennis courts, Little League field and the existence of the Farmer's Market all in danger of noise and toxic air pollution and traffic. The drilling will harm our old underground waste and water pipes and demolish our streets with cracking and breaking, and create instability of building structures. The occasional tar on our beaches now will increase to ruin our beautiful beach community. Our views will be diminished. Our water and air compromised. Our property values will be hit hard and our neighborhoods ruined. Our community since my presence here in 1962 has been gaining in building a better community, nicer housing, nicer attractive beaches. M May The commenter’s views in opposition to an oil extraction project are acknowledged.
- 43 - Comment CommenterResponse Let's keep it that way. We are not a dirty oil town. Go elsewhere. How can the City accept a report performed by company other than the one originally contracted with, and reported to be oil friendly, and whose pier review was conducted by a University who accepted $15m from Conoco. This report should be thrown out period! T Northup The consultants working on the HIA have remained the same throughout the project (McDaniel Lambert was acquired by Intrinsik). The commenter’s views in opposition to consultant and peer reviewer are acknowledged. Health Impact Assessment is a waste of public funds. One does not need HIA to affirm that the drilling site construction is located in the heart of the small city tightly surrounded by quiet neighborhood with narrow streets .. delivering necessary equipment and materials to build the site and transporting out oil during the site operation will create massive traffic of heavy tracks on residential streets of a small quiet city, destroying quality of life and wiping out property values .. .. And what is the necessity of such sacrifice?!? .. (the city was operated just fine for over 100 years without a problem) .. it is to line up coffers of public unions and city management for more wasteful spending Support of the project by Police and other union is a betrayal of city residents they are supposed to serve. Majority of people who are supporting this atrocity are not even residents of the city or property owners .. and should not be participating in this decision making, due to the conflict of interests .. they have everything to gain and nothing to loose .. The DRILLING must be stopped at ANY PRICE. L Orlov Please note that public funds were not used to produce the HIA. The City of Hermosa Beach required E&B to pay them for the HIA. The City chose McDaniel Lambert to provide the HIA. The commenter’s views in opposition to an oil extraction project are acknowledged. I am very concerned by the complete reversal of the health impact findings in the second version of the HIA. Since McDaniel Lambert was purchased by Intrinsik, a company which acknowledges that it does a great deal of work for the petroleum industry, I can only come to the conclusion that their reversal is due to the fact that they derive income from that industry and don't wish to bite the hand that feeds them. After attending the city council meeting in which their employees explained their "new" methodologies I completely lost faith in their document and believe it is highly subjective and caters to petroleum industry interests. I came to this conclusion not only because of their C Prenter The commenter’s concernsregarding the findings of the reissued Draft HIA are acknowledged. As disclosed in their proposal for the project, McDaniel Lambert, prior to the purchase by Intrinsik, also had clients in the petroleum industry. Please refer to the Rationale for Reissued HIA, which is located in the beginning of the report before the Project Summary for more information regarding why the report was reissued and the Project Summary regarding the methodology of assessment and how conclusions were reached.
- 44 - Comment CommenterResponse complete reversal of findings, but also because of the way in which they allow for acceptable risks, as if there were a number of residents whose health could be affected and the project would still be acceptable. This is rubbish. Our current risk for health impacts due to oil drilling in this city is zero. That should be the baseline. Additionally, I reject how the HIA conflicts with the impacts stated in the EIR. There is no way putting up blackout curtains and smelling petroleum odors is acceptable for residents living near the proposed drill site — period. Stating that the project is beneficial to the community while hiding negative impacts deep within paragraphs of copy is disingenuous and misleading. And, there is no way that there is open space provided by this project, either. These findings are ridiculous. This oil drilling issue has been nothing but stress for many of us dealing with it for the past two years and I resent the way that Intrinsik has completely us sold out. This Health Impact Assessments report, just received by e‐mail today, will be printed and read. However, my comments do not depend on any assessments. If you have seen "Years of Living Dangerously" (a 9 part Showtime documentary), you will understand my position regarding opposition to drilling oil in Hermosa Beach. This discussion about whether or not it can be done safely is irrelevant to our need to live sustainably without taking more fossil fuel from the earth anywhere....let alone, Hermosa Beach. We have alternatives to fossil fuel for our needs, and the pollution involved in the drilling was described in Marvin May's remarks. I take it further, because climate change is happening faster than anyone predicted. Money is not the key to our health and survival. Our city can live sustainably with better planning and the progress it has already made to make it a Green environment...eliminating smoking, styrofoam plastic, encouraging sustainable building, etc. We can do more to foster recycling grey water for our yards in this drought, not using our water for drilling for oil. Our Chamber of Commerce is not helping by making the Farmers Market Move to the Pier Plaza and including more commercial booths in the Fiesta del Artes. This seems to be in J Pulcini The commenter’s opposition to an oil extraction projectin Hermosa Beach is acknowledged.
- 45 - Comment CommenterResponse support of the oil drilling proposal and the commercial future of our city to depend on tourism, not our residents who sustain this community. We are the tax paying residents who live here, shop here, bank here, eat in our restaurants. More traffic is not welcome, especially the trucks we have seen doing assessments for oil drilling. That was a preview! We drive daily between 22nd St. and Ardmore and 5th Street. A healthy environment is a sustainable environment that would not be depending on oil revenues for our schools, city or beaches to be superior in every way....especially, healthy!!! I OPPOSE oil drilling here. The risk is too great. Please hear my voice as a 16 year resident of the beach communities. WE DON'T WANT IT. C Reinagel The opinion of the commenter in opposition to the Projectis acknowledged. Intrinsik’s treatment of the Draft HIA appears to be an introduction of pro‐industry bias to further its financial success as it “increases its presence in the United States” rather than an effort to address stakeholder comments and incorporate post‐mitigation scenarios. The Final HIA should clearly communicate the health risks of this project to the residents of Hermosa Beach. It should include an effective Executive Summary that succinctly presents potential adverse and beneficial health effects. The Executive Summary should also clearly describe the current level of pollution in Hermosa Beach. Finally, its authors should release conflict of interest disclosure statements. L Santora The revised HIA was reviewed by an outside peer reviewer Dr. Elizabeth Hodges Snyder who stated that “Neutrality in tone and content is achieved.” An Executive Summary has been added to the Final HIA. The HIA authors confirm that they had no conflict of interest in preparation of the HIA report. We note that our client in this endeavor was the City of Hermosa Beach and not the Applicant. SUMMARY The Revised HIA appears to be a compromised version of the Draft HIA. The primary purpose of HIA is to inform decision making. It should ensure that the project is designed to maximize public health benefits and minimize negative health impacts. The Draft HIA for the E&B oil drilling and production project clearly concludes in its Executive Summary that “increases in nitrogen oxides and particulate matter in air can increase mortality rates, and respiratory and cardiovascular disease rates.” In sharp contrast, the Revised HIA, which does not offer an effective Executive Summary, concludes “on balance we do not believe that the Project will have a substantial effect on community health in Hermosa Beach.” Risks to public health from oil drilling and production are part of every stage of operation. L Santora The HIA authors agree that an HIA should clearly inform the public of the findings. An Executive Summary has been added to the Final HIA. The HIA authors confirm that they had no conflict of interest in preparation of the HIA report. We note that our client in this endeavor was the City of Hermosa Beach and not the Applicant.
- 46 - Comment CommenterResponse The Final HIA should clearly inform the public of these risks. It should inform residents that some criteria air pollutants in Hermosa Beach already exceed established air quality standards (e.g., Particulate Matter [PM2.5]). Finally, Intrinsik and McDaniel Lambert should release conflict of interest disclosure statements to reassure the public that there are no real or perceived conflicts of interest (i.e., all known financial relationships with the oil industry; percentage of revenue generated from private vs. public contracts). PURPOSE OF HEALTH IMPACT ASSESSMENT (HIA)The U.S. Department of Health and Human Services (HHS) recommends HIA as a planning resource for implementing Healthy People 2020. Healthy People is a national initiative that provides science‐based, 10‐year national objectives for improving the health of all Americans. HIA supports two key directions of the Office of the Surgeon General’s National Prevention Strategy: Building Healthy and Safe Community Environments and Empowering People to Make Healthy Choices . HIA can be a useful tool for identifying the impact of a new policy, program, or major project on community and individual health. The 2011 Centers for Disease Control and Prevention co‐sponsored National Research Council report Imp roving Health in the United States: The Role of Health Impact Assessment found that the HIA holds promise for incorporating aspects of health into decision‐making because of its • Applicability to a broad array of policies, programs, plans, and projects; • Consideration of adverse and beneficial health effects; • Ability to consider and incorporate various types of evidence; and, • Engagement of communities and stakeholders in a deliberative process. L Santora The acknowledgement that HIAs can be useful tools is appreciated. The cited National Research Council Report was one of several guidance documents relied on for the HIA report. Controversy – Bias and Conflict of Interest The E&B oil drilling and production project is a contested decision proposal among polarized and disparate interests and stakeholders. It is paramount that the HIA “is conducted and the conclusions and L Santora Full disclosure of oil company experience was given to the City’s selection panel at the time of McDaniel Lambert’s initial interview. This disclosure was also given publically at two community meetings. Not only has McDaniel Lambert performed work for oil and gas
- 47 - Comment CommenterResponse recommendations that are produced at the end of the process are impartial, credible, and scientifically valid.” The National Research Council (US) Committee on Health Impact Assessment recommends that, “to the extent feasible, those who conduct the assessment should strive to avoid real and perceived conflicts of interests.” There is growing unease that consultants who produce HIAs may have an inherent conflict of interest (e.g., industry contracts are their primary revenue source). Of concern, the preparer (Intrinsik) does not provide disclaimers for its financial relationships with the oil industry. The timeline of events surrounding the E&B HIA (i.e., acquisition of McDaniel Lambert by Intrinsik after selection of McDaniel Lambert by City of Hermosa Beach) and the Revised HIA’s departure from the conclusions of the Draft HIA (e.g., Air Quality) raise concerns that the report’s integrity may have been compromised. This is further supported by the “crisis communication”‐style revisions to the report. While the findings presented in both reports are scientifically valid (the majority of which remained unchanged), negative language was removed, minimizing the adverse health impacts of this project. Moreover, groups have specifically requested that an Intrinsik expert be removed from a panel due to his industry‐ affiliations and the “reasonable apprehension of bias.” clients, but its two principals, Dr. Mary McDaniel and Dr. Charles Lambert were both employed by Unocal / Union Oil of California for 8 and 7 years respectively before forming their consulting firm in 1997. The commenter’s statement that “groups have specifically requested that an Intrinsik expert be removed from a panel” may be referring to a letter posted online from the Alberta Energy Regulator which is the provincial agency that permits oil and gas facilities. The letter confirms Dr. Davies’ (of Intrinsik but not associated with this HIA) appointment to an expert panel assembled to assess “Odours and Emissions form Heary Oil Operations in the Peace River Area. The full text of the letter from the Alberta Energy Regulator endorsing Dr. Davies appointment as an expert can be found online: http://www.aer.ca/documents/applications/hearings/1766924_AER_Letter_to_Registered_Parties.pdf That letter states: “Concerns were also raised about experts’ industry affiliations. A general suggestion was made that the panel should exclude proposed experts with industry affiliations. Shell disclosed in its submission that both Dr. Zelt and RWDI have past and ongoing working relationships with industry; however no specific concerns were raised by any party in relation to these two proposed experts. Shell also noted it had worked with Intrinsik Inc., but not directly with Dr. Donald Davies, the panel’s proposed expert. The issue of perceived neutrality is one that the panel had considered in establishing a list of proposed experts. However, the potential experts were selected based on requisite degree of expertise in the relevant field and on their availability. It was inevitable that some experts would have past affiliations with heavy oil operators. The concerns raised about neutrality of experts will be addressed in part by the fact that the panel will provide input into the issues and topics to be addressed in the expert reports, which will help to ensure that the reports are based on appropriate considerations. Further, all parties in the proceeding will be able to present questions to experts regarding the methods and findings in their reports.”
- 48 - Comment CommenterResponse Intrinsik staff has and will continue to provide balanced, independent and scientifically valid assessments of the potential health impacts associated with all types of oil and gas activities. We again note that the client for this HIA was the City of Hermosa Beach, and not E&B. COMPARISON: DRAFT VS. REVISED HIA Of utmost concern, the conclusions of the Draft HIA are markedly changed in the Revised HIA. For example, the health impact of changes in air quality is changed from significant to “no substantial effect.” In public health, it is accepted to describe the significance of an exposure to a health hazard to describe risk (e.g., epidemiological studies show a significant correlation between exposure to air pollution and the frequency of respiratory symptoms ‐‐ ranging from cough symptoms to hospital admission.”) L Santora The method for calculating riskdue to changes in air quality in the initial Draft HIA was overly conservative and not useful for the decision makers. In the revised draft the estimated volume of emissions was compared to health standards set by the South Coast Air Quality Management District (SCAQMD) and the World Health Organization (WHO). Presentation and Framework The Revised HIA is more visually appealing than the original. Overall, it improves upon the organizational structure of the Draft HIA. The Revised HIA uses a similar HIA Evaluation Framework with the following additions: EIR Mitigation, Adaptability, and Post‐Mitigation Health Effect. It removes the ranking system presented in the original. Notably, unlike the Draft HIA, the Revised HIA does not provide an Executive Summary that succinctly outlines the potential health impacts of the proposed Project. This is concerning because the primary purpose of the HIA is to help stakeholder incorporate health into decision‐making. Most residents will not read the entire HIA; therefore, it is imperative to provide an effective executive summary that analyzes and summarizes the most important points of the HIA. L Santora The HIA contains a “Report Summary” rather than an “Executive Summary”. However, to address the concern that the summary is too long, an Executive Summary of the findings in the HIA has also been prepared. Tone The tone of the Revised HIA could be perceived as “industry‐friendly”. In the Revised HIA, the significance of health impacts are obscured by many conditional statements (e.g., “could potentially impact health if they are released in sufficient quantities”). The report uses nuanced language, which minimizes the impact of the project on health (e.g., “have the potential,” “can release,” “in some circumstances.”) For example, “Construction equipment and the vehicles that transport equipment can release fine particulate and L Santora The HIA authors believe that we achieved neutrality of tone. This was independently acknowledged by the peer reviewer her comments found in Appendix C. In the quoted text quoted “can” has been deleted.
- 49 - Comment CommenterResponse diesel particulate matter into ambient air.” The scientifically accurate and direct statement would be “construction equipment and the vehicles that transport equipment release fine particulate and diesel particulate matter into ambient air.” EIR Mitigation The Revised HIA asserts the impact of the proposed mitigation measures presented in the EIR. However, it assumes the acceptability, feasibility, adoption and effectiveness of each proposed measure. There is no certainty that proposed mitigation measures will achieve the estimated reductions in pollutants. L Santora The Applicant has indicated that they will comply with the mitigation measures, made part of the development agreement, and therefore the HIA has made that assumption in its analysis. Please refer to Section 8 of the EIR which states: “As the Lead Agency under the California Environmental Quality Act (CEQA), the City of Hermosa Beach (City) is required to adopt a program for reporting or monitoring regarding the implementation of mitigation measures for this Project, if it is approved, to ensure that the adopted mitigation measures are implemented as defined in this Environmental Impact Report (EIR).” The commenter’s views in opposition of this assumption are acknowledged. Adaptability The addition of the Adaptability category is of significant concern in that it does not accurately categorize risk. It evaluates the question “How resilient is the community to this type of change; are they able to adapt?” For some measures it is subjective. For example, in the event of an oil spill, “will people be able to adapt to the change with some difficulty and maintain pre‐project level of health with some support?” For others it is not applicable. For example, the measurement of adaptability as it relates to air quality understates the health impact of pollutant exposure. Below are two examples of the impact of relatively small exposures to pollutants on adverse health outcomes. Current research demonstrates a significant relationship between particulate matter and cardiovascular Disease. Cardiovascular disease is the leading cause of premature death in Los Angeles County. A 14‐day lagged cumulative moving average of 10 microg/m3 PM (2.5) was associated with a 13.1% increase in Heart Failure admissions (Pope, 2008). PM (2.5) elevated by 10 microg/m3 was associated with increased risk of acute ischemic coronary events L Santora Adaptability is often used in HIAs as a measure of community resilience. The commenter points out that for some measures the adaptability category is subjective. By its nature, there are parts of HIA that are subjective. The adaptability to air pollutants was ranked as “high” because the pollutants (baseline plus project) did not exceed health‐based thresholds. Therefore, community members will be able to maintain pre‐project level of health. The commenter correctly describes the cardiovascular effects of particulate matter. If the concentrations of particulate matter generated by the proposed Project were high enough to result in an increase in cardiovascular disease, then adaptability would be categorized as “low” (people will not be able to adapt or maintain pre‐project level of health). The Buffalo study summarized in these comments was a cross sectional study that looked at childhood asthma incidence in the west part of Buffalo that is downwind from the Peace Bridge which is a massive roadway connecting the US and Canada. Not surprisingly, an increase of childhood asthma was noted in this area of the city. The
- 50 - Comment CommenterResponse (unstable angina and myocardial infarction) equal to 4.5% (Pope, 2006). Childhood exposure to indoor air pollution, much of which penetrated readily from outdoor sources, may contribute to the development of wheeze symptoms among children ages 5 to 7 years. Positive associations between Asthma Control Questionnaire (ACQ) scores and respirable particulate matter (PM), coarse particulate matter (PM10), fine particulate matter (PM2.5), nitrogen dioxide (NO2), and ozone (O3). In multivariate regression analysis of risk factors, residence in the west Buffalo neighborhood was an independent risk factor for asthma diagnosis (Lwebuga ‐ Mukasa et al. 2004). Furthermore, this area was shown to be downwind of putative sources of traffic‐ related pollution emanating from truck traffic (Lwebuga‐Mukasa et al. 2005). Notably, the current levels of PM2.5 in these vulnerable Buffalo neighborhoods are significantly lower than those currently reported by SCAQMD for the Hermosa Beach zip code (www.airnow.gov). Therefore, it is inaccurate to categorize adaptability as ‘high’ in reference to air pollutants, in that it wrongly asserts that people are expected to be able to easily adapt to the change in pollutant levels (i.e., people will be able to maintain their pre‐project level of health). This categorization significantly minimizes the risk of pollutant exposure, which is concerning in a community that exceeds air quality guidelines. design of the study made it difficultto tease out which of the several exhaust related air pollutants may have been responsible for the increase in childhood asthma. Post‐Mitigation Health Effect This new variable is also concerning in that it depends on major assumptions: 1. The estimated levels of pollutants are accurate (see below); 2. The significance thresholds are accurate (see below); 3. The mitigation proposed achieves expected reduction in pollutant levels; and, 4. Actual post‐mitigation pollutant exposures do not have an impact on individual health. L Santora The Applicant has indicated that they will comply with the mitigation measures, made part of the development agreement, and therefore the HIA has made that assumption in its analysis. This is detailed on page 13 where “This is because once the EIR is certified the mitigation measures must be adhered to.” Estimated post‐mitigation levels of air pollutants are compared to health protective levels used by the SCAQMD and WHO to estimate potential health impacts. While objective data are used whenever possible, there is a large part of the HIA that is subjective.
- 51 - Comment CommenterResponse Notably, the third party reviewer states “What needs to be clarified, though, is how the various aspects of the metric are weighted and totaled (or otherwise utilized) to come to a post‐mitigation health effect determination.” This remains unclear in the published document. While Figure 2‐3 was added, there are no clear, objective, evidence‐based guidelines for categorizing magnitude, adaptability, and likelihood across all measures. Hermosa Beach is an urban setting with high exposures to ambient air pollution – from stationary and mobile sources. There are established putative exposures to industrial pollutants (AES, Chevron, LAX; major traffic corridors). Baseline air quality measurements in EIR are from SCAQMD, monitoring station – LAX Hastings (6.8 miles to the north of the Project Site). This is the oldest active air quality monitoring station. SCAQMD reports need for replacement of instrumentation and sub‐systems. Additionally, the system does not support continuous monitoring of PM10/2.5. Furthermore, monitoring station location in reference to Project Site may underestimate current local pollutant levels in Hermosa Beach (e.g., location in reference to putative sources). Finally, the EIR assumes that the SCAQMD Air Quality Significance Thresholds accurately estimate health impacts. SCAQMD daily threshold (pounds per day) for particulate matter (PM) 10 and 2.5 are 150 and 55 pounds per day. Notably, in 2010, BAAQMD proposed daily thresholds of PM 10 and 2.5 at 82 and 54 pounds per day, respectively. Threshold models are now being reevaluated because (1) a theoretical assumption of wide‐ ranging human sensitivity, and (2) inability to detect thresholds in epidemiologic models. Furthermore, threshold models do not consider vulnerable populations. Despite the lowest levels of economic hardship in Los Angeles County(1 out of 201), the life expectancy in Hermosa Beach falls in the 3rd quartile (61 out of 101) [80.4 years vs. 80.3 years, LAC]. Notably, there is strong evidence of the association between reductions in fine particulate air pollution and improvement in life expectancy. This is significant since the Construction Phase of The HIA authors believe that it is very clear in the reissued Draft HIA how the aspects of the evaluation metric are weighted to come to the post‐mitigation health effect determination (see Figure 2‐3). It was the intention that the HIA be transparent about how the different categories were determined so that the reader could see how the decision was made whether or not he/she agreed with it. The HIA authors do not agree that the air monitoring station at LAX could underestimate pollutant levels in Hermosa Beach as air in Hermosa Beach and other coastal communities is generally acknowledged to be of higher quality than inland. The commenter is referred to the FEIR regarding the points about the EIR Air Quality Significance Thresholds as the HIA did not apply the same significance thresholds.
- 52 - Comment CommenterResponse Proposed Project is estimated at 5‐years. Traffic from construction and operations are marginal when compared to total mobile source emissions in Hermosa Beach. But, increases in pollutant levels could have a significant local impact. Community Livability Factors It appears that adjustments in the “Community Livability” section were intended to frame the proposed project in a positive light (e.g., educational funding and community resources). For example, the magnitude of educational funding was changed from low in the Draft HIA to medium. This appears to overestimate the impact of a new revenue stream (e.g., % of HBCSD total revenue). Also, ranking the adaptability as high is an unjustified assumption of the health impact of an additional revenue stream. Finally, it doesn’t consider the number children/families affected by new revenue as percentage of total population. Also, in the original scoping greenhouse gases were considered because “Hermosa has a goal of being carbon neutral. This health determinant is important to residents.” Rather than exclude it, it may have been more appropriately considered in the Community Livability section. For example, what would be the health effect of an approved project that is inconsistent with the City’s adopted goals (e.g., political involvement; social cohesion)? The ballot outcome would be determined by the percentage of registered voters who actually vote on the ballot measure and their casted vote (which is also not addressed in the Community Livability section). Voter turnout and its influence on the outcome could either negatively or positively affect social cohesion and political activity measures. Also, the Revised HIA changes classification of Community Resources – Recreational Resources and Green Space from negative health impact to positive health impact. The Revised HIA minimizes the impact of construction (duration and location) on typical use of the Valley Drive Corridor (e.g., relocation of City Yard; reduced access to Greenbelt during construction). Active transportation is key component of Livability; the project would affect the utilization of this corridor for non‐motorized local and thru‐traffic). Also, the L Santora The commenter’s disagreement with the selected magnitude and adaptability categorizations for education funding is acknowledged. The HIA authors encourage readers to reach their own conclusions about the magnitude, etc. Regarding greenhouse gases, the reissued Draft HIA states that the issue requires a broader assessment to be addressed adequately, not that the issue of greenhouse gasses is unimportant. The commenter’s point about how the goal of being carbon neutral as a city may be woven into the social fabric of the community is acknowledged. The commenter opposes the findings in the Recreational Resources and Green Spaces. Text has been added to the Final HIA to acknowledge that there will be disturbance to recreation and green space nearby the Project Site due to construction activities. The Final HIA still concludes an overall positive impact to recreational areas and green space due to the increased revenue coming into the City, particularly with regards to the Tidelands Fund, available to improve beach and coastal areas used for community recreation.
- 53 - Comment CommenterResponse report asserts the favorability of the project of Green Space in terms of use of Tideland funds, which is unknown at time (i.e., it is unknown whether revenue from this fund would increase recreational resources available to residents). CONCLUSION The Revised HIA understates the adverse health impacts of the proposed project. Short‐term and long‐term exposure to particulate air pollution are established environmental risk factors for cardiovascular and pulmonary morbidity and mortality. The Final HIA should clearly communicate these risks to residents to support informed decision making. L Santora The HIA authors agree that exposure to particulate air pollution can pose a health risk, including increased risk for cardiovascular and pulmonary morbidity and mortality. However, the assessment concluded that any exceedances of the WHO air quality guidelines are based on existing background levels in the area and the Project is not expected to have a material impact on existing PM2.5 related health risks. On page 26 of the revised HIA report it states the following:“In the first Draft of the HIA the potential health outcomes of greenhouse gas generation from the Project were briefly evaluated. However, the authors of the reissued draft HIA Report do not believe that localized or community health effects related to potential greenhouse gas emissions can be adequately evaluated in a project‐level HIA. Rather, the global issue of greenhouse gas generation requires a much broader assessment of state and national sources and policies to adequately evaluate cumulative impacts of the energy sector.” The authors of the reissued draft HIA Report are incorrect in their "belief" that localized or community health effects related to greenhouse gas emissions cannot be adequately evaluated in a project‐level HIA. Facts exist that make "beliefs" unnecessary and these facts should be part of the Final Health Assessment. Since oil drilling is currently banned, the crude oil that E&B proposes to recovered is presently safely sequestered and poses no greenhouse gas or health risks to our South Bay citizens. The carbon and CO2 produced by burning this now sequestered oil must be added to now existing estimates of greenhouse gas emissions. Based on the Environmental Protection Agency’s calculation*, each barrel of crude oil generates 0.43 metric tons of CO2. This project estimates 17.1 million barrels of oil to be recovered. Using the EPA South Bay 350 The HIA authors agree that climate change is associated with a number of adverse health outcomes. As such, global greenhouse gas levels do affect community health on a local scale (through the mechanisms described by the commenter including flooding and extreme heat, etc). However, it is not possible to predict the community health changes resulting from the proposed Project, which will result in a very small proportion of the cumulative CO2 released into the atmosphere world‐wide.
- 54 - Comment CommenterResponse standard calculation the 17,100,000 barrels of oil will produce 7,353,000 metric tons of CO2. http://www.epa.gov/cleanenergy/energy‐resources/refs.html Current CO2 levels are 400ppm. Climate scientists report that to maintain a civilization on par with the one we have developed to date, CO2 levels should be at 350ppm. Adding the 7,353,000 metric tons of CO2 from the oil to be recovered will accelerate the rise of CO2 levels in our atmosphere. http://350.org/about/science/ At the 2007 UN IPCC meeting in Copenhagen the only agreed upon climate goal for all participating countries was to limit global warming to 2C degrees. http://www.rollingstone.com/politics/ news/global‐warmingsterrifying‐new‐math‐20120719 Current carbon budget estimates indicate that approximately 500 gigatons of carbon can be burned before the 2C degree global warming danger zone is reached. At current burn and emission rates, we will exhaust our carbon budget at some point from 2028 to 2040. Therefore adding an additional 7,353,000 metric tons of CO2 from the currently sequestered oil in question will accelerate global temperature increases, push us to 2C degrees of global warming sooner than if that oil were not burned. Likewise it will increase the CO2 levels which are already at record levels for human history. Locally, global temperature rise is impacting Hermosa Beach through rising sea levels which threaten infrastructure and the local services. Rising sea levels cause storm surges and related flooding to increase and reach further inland from the coastline. Related local health impacts from flooding include reduced availability of fresh food and water; interruption of communication, utility, and health care services; contributions to carbon monoxide poisoning from portable electric generators used during and after flooding impacts; increased stomach and intestinal illness among evacuees; and contributions to mental health impacts such as depression and post‐traumatic stress disorder (PTSD). These impacts will worsen with the additional
- 55 - Comment CommenterResponse 7,353,000 metric tons of CO2 emitted from the E&B oil recovery project and these impacts cannot be mitigated. United States Environmental Protection Agency “Climate Impacts on Human Health” http://www.epa.gov/climatechange/impacts‐adaptation/health.html Locally, global temperature rise is impacting Hermosa Beach and South Bay residents by making our ocean more acidic and negatively impacting marine life. Fish and their food supplies are diminishing as a result, impacting the seafood supply and its related health benefits. These impacts will worsen with the additional 7,353,000 metric tons of CO2 emitted from the E&B oil recovery project and these impacts cannot be mitigated. Locally, global temperature rise is responsible for increased drought which reduces our local water supply and puts public health at risk due to compromised quantity and quality of drinking water; increased recreational risks; effects on air quality; diminished living conditions related to energy, air quality, and sanitation and hygiene; compromised food and nutrition; and increased incidence of illness and disease. Centers for Disease Control “Drought and Health” http://www.cdc.gov/nceh/drought/ Locally, global temperature rise and its associated and proven increased fire risk impacts Hermosa Beach and the entire South Bay. Local health impacts include injury and death caused by fire as well as air quality health risks from smoke and toxic material emissions. These impacts will worsen with the additional 7,353,000 metric tons of CO2 emitted from the E&B oil recovery project and these impacts cannot be mitigated. Locally, global temperature rise and related change in climate is impacting Hermosa Beach by diminishing the ability of local and state farmers to grow the food crops we rely on based on the reduced water supplies and the climate change that has altered growing conditions. These impacts will worsen with the additional 7,353,000 metric tons of CO2 emitted from the E&B oil recovery project and
- 56 - Comment CommenterResponse these impacts cannot be mitigated. Locally, global temperature rise is causing extreme weather conditions that cannot be mitigated and which will impact the health, welfare and quality of life of Hermosa Beach citizens. Specifically the EPA reports that these impacts can reduce the availability of fresh food and water; interrupt communication, utility, and health care services; contribute to carbon monoxide poisoning from portable electric generators used during and after storms; Increase stomach and intestinal illness among evacuees; and contribute to mental health impacts such as depression and post‐traumatic stress disorder (PTSD). These health impacts will worsen with the additional 7,353,000 metric tons of CO2 emitted from the E&B oil recovery project and these impacts cannot be mitigated. United States Environmental Protection Agency “Climate Impacts on Human Health” http://www.epa.gov/climatechange/impacts‐adaptation/health.html The impacts of future heat waves can be especially severe. For example, in Los Angeles, annual heat‐related deaths are projected to increase two‐ to seven‐fold by the end of the 21st century, depending on the future growth of greenhouse gas emissions. Heat waves are also often accompanied by periods of stagnant air, leading to increases in air pollution and the associated health effects. These health impacts will worsen with the additional 7,353,000 metric tons of CO2 emitted from the E&B oil recovery project and these impacts cannot be mitigated. United States Environmental Protection Agency “Climate Impacts on Human Health” http://www.epa.gov/climatechange/impacts‐adaptation/health.html Locally, global temperature rise will impact the health of Hermosa Beach and South Bay citizens with negative impacts from reduced air quality including increases in ozone, changes in allergens and changes in fine particulate matter. Additional health impacts will come from from climate‐sensitive diseases including foodborne diseases, water‐borne diseases and animal‐borne diseases Health impacts from heat waves include heat stroke and dehydration which
- 57 - Comment CommenterResponse are the most common cause of weather‐related deaths. In addition to the above proven negative local impacts caused by the greenhouse gas emissions from burning the 17.1 million barrels of oil projected to be recovered, the E&B project must also add the greenhouse gas emissions that will be added to our carbon budget from the building and operation of the oil recovery project itself. Every fossil fuel‐burning transportation truck, every fossil fuel‐powered piece of construction equipment, every fossil fuel‐powered piece of oil recovery equipment used by the E&B project throughout the life of the project must all be counted as additional CO2 and greenhouse gas emissions that would not otherwise have been emitted without overturning the current ban on oil drilling in Hermosa Beach. These additional emissions must be added to the 7,353,000 metric tons of CO2 the recovered oil will produce. These additional greenhouse gas emissions will further accelerate global temperature rise and accelerate and increase each of the negative health impacts in all the categories cited above. * EPA calculations of CO2 emissions per barrel of oil burned: http://www.epa.gov/cleanenergy/energyresources/refs.html Barrels of oil consumed ‐ Carbon dioxide emissions per barrel of crude oil are determined by multiplying heat content times the carbon coefficient times the fraction oxidized times the ratio of the molecular weight of carbon dioxide to that of carbon (44/12). The average heat content of crude oil is 5.80 mmbtu per barrel (EPA 2013). The average carbon coefficient of crude oil is 20.31 kg carbon per mmbtu (EPA 2013). The fraction oxidized is 100 percent (IPCC 2006). Calculation: 5.80 mmbtu/barrel × 20.31 kg C/mmbtu × 44 kg CO2/12 kg C × 1 metric ton/1,000 kg = 0.43 metric tons CO2/barrel
Appendix C-2 Peer Reviewer Comments and Response to Peer Reviewer Comments
1
Memo
To: Intrinsik Inc.
From: Elizabeth Hodges Snyder
Date: July 2, 2014
Re: External peer review of the June 26, 2014 Draft Health Impact
Assessment, E&B Oil Drilling and Production Project
Background
In mid-June 2014, Intrinsik Inc. contracted with me to conduct an
external peer review of the June 26, 2014 Draft Health Impact Assessment,
E&B Oil Drilling and Production Project. The peer review was requested at
two levels: initial "high level comments" by July 3, 2014 and "detailed
comments" by July 9, 2014. Review is to focus on the process, methodology,
scope, thoroughness, and neutrality of the Draft HIA for the proposed E&B
Oil Drilling and Production Project. The initial review (i.e., the focus of this
memo) is meant to serve as a preliminary evaluation of draft completeness
and acceptability prior to client submission. Detailed comments will follow in
a second memo, which will provide a more thorough treatment of areas that
would require modification prior to my recommended acceptance of the
document, as well as any minor issues that could be optionally addressed to
strengthen the assessment report.
Peer Review
There is a host of national and international resources to inform and
guide peer review of a completed HIA, many of which are cited in the Draft
HIA itself (e.g., Fredsgaard et al., 2009; Bhatia et al., 2010; Hebert et al.,
2012; and Ross et al., 2014). An additional resource particularly appropriate
for initial "high level comments", and that was developed with reference to
2
the aforementioned sources, is a rubric created by the 2012-2013 HIA Living
Library Sub-Committee within the Society of Practitioners of Health Impact
Assessment (SOPHIA) (http://hiasociety.org/?page_id=57). The relatively
simple rubric outlines a brief methodology for selecting examples of high-
quality HIAs, and identifies keys elements of HIA practice and report quality.
This tool was utilized in the preliminary evaluation of the Draft HIA for the
proposed E&B Oil Drilling and Production Project.
The following peer review discussion identifies the list of criteria by
which the Draft HIA was preliminarily evaluated, and provides select brief
comments (which will be addressed in greater detail, and added to, in the
second level of review). I use the word "recommended" several times, but
anticipate some currently cited recommendations will be identified as
"requirements for acceptance" following the second level of review.
Identifies the sponsor of the HIA, the team conducting the HIA, and all other
participants in the HIA and their roles
The sponsor of the HIA and the team conducting the HIA are well
identified, but additional details on other participants (e.g., specific decision-
makers, specific stakeholder groups) and their roles are recommended.
Worth noting, too, is some slightly incorrect wording under the
"Prepared by" heading on the second page of the document. It states
"Intrinsik Inc. (formerly McDaniel Lambert, Inc.)". While the intent is to
highlight the fact that initial HIA work was conducted by McDaniel Lambert,
Inc., which is now a part of Intrinsik Inc., the current verbiage suggests that
McDaniel Lambert, Inc. was renamed Intrinsik Inc.
Describes some level of stakeholder input
Yes, stakeholder input was collected and the input collection process is
briefly described, but additional detail is recommended in order to better
assess the thoroughness of the engagement efforts, and identify any
subgroups that may have been left out. For example, relevant details might
3
include the time of day during which meetings were scheduled, how the
meetings were advertised, how many were in attendance, how vulnerable
subpopulations were included, and how the meetings were facilitated. I do
recognize, however, that the sizes of the vulnerable subgroups are relatively
small.
Appendix C appears to be missing.
Clearly describes the methods of the HIA
Yes, in terms of the components, steps, and the general metric for
evaluating impacts. What needs to be clarified, though, is how the various
aspects of the metric are weighted and totaled (or otherwise utilized) to come
to a post-mitigation health effect determination. There are several guidance
documents available that provide methods that can support more consistent,
replicable determinations. For example, a reader, without additional
clarification, might rightfully find it perplexing that the “Odor Emissions” and
“Surface Water” health determinants both have assigned “EIR Mitigation
Measures”, and also have the exact same identified “Potential Health
Outcomes”, “Geographic Extent”, “Magnitude”, “Adaptability”, and
“Likelihood” designations, but receive different “Post-Mitigation Health Effect”
designations (i.e., “negative” and “no substantial effect”, respectively).
Includes logic model, or other articulation, linking proposal to health
determinants and health outcomes
Yes. The pre-mitigation models primarily illustrate potential adverse
health impacts (or, if the impacts could go in either direction, the negative
direction may be more obvious to the reader), and might be improved
following a fresh look at them with potential benefits also in mind (which are
indeed addressed in the text).
Throughout the HIA, describes the evidence sources used
Yes, though some in-text citations appear to be incomplete.
4
Profiles existing conditions (can be a separate baseline section or integrated
with assessment)
Yes.
Assessment includes discussion of both health determinants and health
outcomes
Yes. As is common in health discussions, however, distinctions
between “health outcome”, “health impact”, and “determinant of health”
sometimes get loose and imprecise.
Assessment: For each specific health issue analyzed, details the analytic
results
Yes, but this is where I anticipate the greatest amount of additional
feedback in the second level of review. The different categories of analyses
and discussion will benefit from an additional round of editing for consistency
in values reporting and the provision of additional details pertaining to the
success of the proposed mitigation measures in other similar development
projects. For example, in Sections 5.3.2.2 and 5.3.2.3 (Soils), lead is
discussed. In the latter section, a soil lead concentration of 9500 mg kg-1 is
mentioned as a threshold, which is actually very close to the maximum
concentration detected (9680 mg kg-1) and significantly above the reported
commercial scenario screening level of 320 mg kg-1 (not to mention that the
implications of the measurement depth of 15 feet are not addressed).
Further, it is difficult to judge the appropriateness of the “unlikely”
designation for inhalation or ingestion. The “unlikely” designation is given
based upon the expected mitigation measures, but no background
information pertaining to the historical success of such mitigation measures
in similar scenarios is provided or referred to. Thus, it follows that the
classification of “no substantial effect” could be called into question,
particularly when the mitigation measure calls for potential soil removal
5
(which could be problematic if the contamination is several feet deep) well
after soil disturbance can be expected (i.e., Phase 3).
The critiques like the ones just presented do not necessarily mean that
the conclusions are inaccurate, but that more information/discussion is
needed.
Includes recommendations clearly connected to analysis and
proposal/decision / Recommendations are prominently written
Yes, though brief and relatively few in addition to the mitigation
measures recommended in the EIR.
Report includes an executive summary or something like it
Yes. An important inconsistency to note, however, is the reference to
the Draft HIA as being, or not being, a “stand alone document”. For
example, on pages iv and 1, it is referred to as “stand alone”, but on page 17
it is explicitly stated that it is not “stand alone”. This is an important
distinction in purpose that will affect the type of appropriate content and
structure of the document.
Also, the determinants of health table seems to get cut off in printing,
which may be problematic for some members of the public.
Report is written well -- uses good grammar, spelling, punctuation, etc.
Yes, only minor, occasional grammar oversights and apparently
erroneously accepted autocorrect wording. Additionally, the report explicitly
states in multiple instances that the overarching purpose is to characterize
both potential positive and negative health impacts, and not to take a position
regarding development approval. Neutrality is achieved in the attempt to
fairly identify both positive and negative potential impacts.
6
Report is organized or written in a way that makes it easy to understand the
story
Yes.
Some discussion of possible evaluation and/or monitoring taking place in the
future is mentioned
Yes, though brief.
Recommendation
It is my opinion that the Draft HIA contains the necessary components and is
in adequate form to share with the client, providing that the issues identified
above are acknowledged and that the client is aware of the forthcoming
second level of peer review. I anticipate providing subsequent detailed
comments addressing both recommended and required (for my own
acceptance of the HIA) clarifications and modifications, but none that
necessarily preclude submitting the Draft HIA to the client for feedback.
A Review of the 6.26.14 Draft Health Impact Assessment,
E&B Oil Drilling and Production Project
A peer-review prepared in July 2014 by:
Elizabeth Hodges Snyder, MPH, PhD Assistant Professor of Public Health
Soil Scientist
University of Alaska Anchorage
Introduction and Aim of Review
In mid-June 2014, Intrinsik Inc. contracted with the author to conduct an external peer
review of the June 26, 2014 Draft Health Impact Assessment, E&B Oil Drilling and
Production Project. The peer review was requested at two levels: initial "high level
comments" by July 3, 2014 and "detailed comments" by July 9, 2014. Review was to focus
on the process, methodology, scope, thoroughness, and neutrality of the Draft HIA for the
proposed E&B Oil Drilling and Production Project.
The initial review (i.e., the focus of the July 2, 2014 memo to Intrinsik, Inc.) was meant to
serve as a preliminary evaluation of draft completeness and acceptability prior to client
submission, and utilized an HIA evaluation rubric developed by the 2012-2013 HIA Living
Library Sub-Committee within the Society of Practitioners of Health Impact Assessment
(SOPHIA) (http://hiasociety.org/?page_id=57). The relatively simple rubric outlines a brief
methodology for selecting examples of high-quality HIAs, and identifies keys elements of
HIA practice and report quality. With this rubric, I concluded that the Draft HIA contained the
necessary components and was in adequate form to share with the client, providing that the
issues identified in the “high level comments” were acknowledged and that the client who
contracted the HIA was aware of the forthcoming second level of peer review.
The “detailed comments” provided in the second review (i.e., the focus of this report) are
meant to inform final preparations of the Draft HIA for public release (on July 14, 2014) and
comment period (through August 14, 2014).
Approach to the Peer Review
There are no formal or mandated guidelines for HIA evaluation in the United States.
However, there are several resources that can serve as useful tools in assessing HIA
methodology, scope, and thoroughness, including those by Fredsgaard et al. (2009), Bhatia
et al. (2010), Hebert et al. (2012), Rhodus et al. (2013), Ross et al. (2014), and the
previously mentioned Society of Practitioners of Health Impact Assessment (SOPHIA,
http://hiasociety.org/?page_id=57). For this review, the detailed rubric developed by
Fredsgaard et al. (2009)
(https://www.scambs.gov.uk/sites/www.scambs.gov.uk/files/documents/HIA%20Review%20
Package%20-%20Ben%20Cave%20Assoc.pdf) guided the development of the “detailed
comments” in the following section.
Review Comments
Comments are provided using two approaches: 1) within Table 1, which is organized by
review area and associated subcategories, and 2) as bullet points that do not otherwise
fit within the existing Table 1 categories. In both approaches, recommendations are bolded and italicized. Those recommendations that this reviewer deems as critical for
finalizing an HIA for public review are shaded blue.
Table 1. Detailed comments organized by review area and subcategories. Adapted from Fredsgaard et al. (2009). Context Comments Response Site description and policy framework The report should describe the physical characteristics of the project site and the surrounding area Additional information pertaining to the physical characteristics of the proposed project site is needed in a single section (e.g., Section 1.3). The reader is provided details (e.g., that the site overlays a landfill, surrounding buildings) in a piecemeal fashion as the report progresses, but it would be most useful to have the information in a single section early in the report. Otherwise, it is difficult for the reader to visualize the space or assess the types of activities that occur there. Section 1.3 now provides additional details pertaining to the proposed Project Site. The report should describe the way in which the project site and the surrounding area are currently used Additional information pertaining to the ways in which the proposed project site and surrounding areas are used is needed in a single section (e.g., Section 1.3). The reader is informed that the site is the City Maintenance Yard and eventually learns of some current activities onsite (e.g., the storage of fuel tanks) and off, but it would be most useful to have the information in a single section early in the report. Further, the map in Figure 1-1 is useful, but appears to be missing a scale and only identifies schools. Additional features would allow the reader to visualize and assess other potentially important subpopulations and factors (e.g., housing density, specific businesses, vulnerable populations). As currently presented, the map feels to this reader Section 1.3 now provides additional information on surrounding land use. Figure 1-1 was replaced with Site location map (with a scale) that is more appropriate for this Section. Although a map is not needed, vulnerable and sensitive subpopulations are now discussed in further detail in Section 2.4 and 5.1.5
incomplete and tokenistic. The report should describe the policy context and state whether the project accords with significant policies that protect and promote wellbeing and public health and reduce health inequalities The report provides an appropriate context to the proposed project, community reactions, the upcoming vote, and relevant information contained in the EIR. A small point of clarification within Section 1.0: What is the relationship, if any, between Macpherson Oil Company and E&B? Macpherson Oil sold its interests to E&B at the time of the settlement agreement. Details now provided in Section 1.0 Description of project The aims and objectives of the project should be stated and the final operational characteristics of the project should be described The aims, objectives, and characteristics are well described. However, the map in Figure 1-1 would be strengthened by the inclusion of the proposed pipeline in addition to the proposed project site. Section 1.3.3 references where the reader can find a depiction of the proposed pipeline routes (Final EIR, Section 2, Figure 2.15). We note that the preferred route was not finalized at the time of certification of the EIR. The estimated duration of the construction phase, operational phase and, where appropriate, decommissioning phase should be given Well described. No response required. The relationship of the project with other proposals should be statedNo other proposals are mentioned, but the EIR and Cost-Benefit Analysis are described in relationship to the HIA. No response required. Public health profile The public health profile should establish an information base from which requirements for health protection, health No additional comment. Weaknesses and gaps are identified in Section 7.0. No response required.
improvement and health services can be assessed The profile should identify vulnerable population groups. The profile should describe, where possible, inequalities in health between population groups and should include the wider determinants of health The report acknowledges the presence of vulnerable subgroups (i.e., those living in poverty, the young, and the elderly), but sections under 5.1 would be strengthened by additional discussion, and potential visual representation if possible, of where these vulnerable subgroups are located. Otherwise, it is difficult to assess whether they would be disproportionately impacted by the proposed project. If there are no other subgroups that can be mapped, mentioning this would be equally useful. Clarification was added to Sections 2.4, 5.1.5 and the individual evaluation matrix tables in each assessment in Section 5.0. A column was also added to the summary table provided in the Project Summary and Conclusions (Section 8.0) that details each of the vulnerable populations considered. Schools were the only potential vulnerable subgroup that could be mapped and provided in Figure 5-8. The information in the profile should be specific about the timescale, the geographic location and the population group being described and links should be made with the proposed project Inclusion of the future profile of the population is recommended. Discussion has been added to Section 5.1.5 and describes that given the age demographic of Hermosa Beach that it is not anticipated that there will be a demographic shift over the life of the Project. Management Identification and prediction of health impacts The report should describe the screening and scoping stages of the HIA and the No additional comment. No response required.
methods used in these stages A description of how the quantitative and qualitative evidence was gathered and analyzed (where appropriate) should be given and its relevance to the HIA justified Additional clarification is needed pertaining to how the various aspects of the metric are weighted and totaled (or otherwise utilized) to come to a post-mitigation health effect determination. Additional clarification regarding the evaluation matrix, including details on how various elements are weighted and used to inform a Post-Mitigation Health Effect, has been provided in Section 2.4 (including the addition of Figure 2-3) of the reissued draft HIA. Governance The governance process for the HIA should be described No additional comment. No response required. The terms of reference for the HIA should be available to the reader and the geographical, temporal and population scope of the HIA should be made explicit No additional comment. No response required. Any constraints in preparing the HIA should be explained No additional comment. No response required. Engagement The report should identify relevant stakeholder groups, including organizations responsible for protecting and Specific stakeholder groups should be identified, even if they were not engaged using individualized strategies and/or they did not participate (as noted for E&B representatives in Section 7.0). An expanded discussion on stakeholders and public engagement is provided in Section 4.1.
promoting health and wellbeing that should be involved in the HIA The report should identify vulnerable population groups which should be involved in the HIA If specific vulnerable subpopulations were not involved in the HIA, it should be noted as a limitation in Section 7.0. If they were involved, it should be noted in the stakeholder engagement discussions. Clarification was added to Sections 2.4, 5.1.5 and the individual evaluation matrix tables in each assessment in Section 5.0. A column was also added to the summary table provided in the Project Summary and Conclusions (Section 8.0) that details each of the vulnerable populations considered. Details have also been added in Section 4.1 on stakeholder engagement. The report should describe the engagement strategy for the HIA Additional detail is recommended in order to better assess the thoroughness of the engagement efforts, and identify any subgroups that may have been left out. For example, relevant details might include the time of day during which meetings were scheduled, how the meetings were advertised, how many were in attendance, how vulnerable subpopulations were included, and how the meetings were facilitated. Also, there appears to be a discrepancy between the engagement activities listed in the fourth paragraph on page 18 and the third paragraph on page 17; clarification needed. Further, it is not clear what the “Community Dialogue process” is, in terms of how this fit into the overall engagement Additional detail on stakeholder engagement activities, including meeting dates, times, locations, etc. is provided in Section 4.1. Also, clarification regarding 4.1 how the Community Dialogue process fit in to overall engagement is provided in Section 4.1. No vulnerable populations or interested stakeholders were left out based on the extensive consultation efforts undertaken
strategy, particularly at its first mention in the report; clarification needed. for the Project. Assessment Description of health effects The potential health effects of the project, both beneficial and adverse, should be identified and presented in a systematic way Generally, this is accomplished. However, the timescales of short-term and long-term impacts are not provided. An attempt was made to characterize whether potential health effects would be short-term or long-term in each of the assessment sections. For example the air quality section describes both short-term (acute) and potential long-term (chronic) effects. The identification of potential health impacts should consider the wider determinants of health such as socioeconomic, physical, and mental health factors No additional comment. No response required. The causal pathway leading to health effects should be outlined along with an explanation of the underpinning evidence No additional comment. No response required. Risk Assessment The nature of the potential health effects should be detailed No additional comment. No response required. The findings of the assessment should be accompanied by a statement of the level of No additional comment. No response required.
certainty or uncertainty attached to the predictions of health effects The report should identify and justify the use of any standards and thresholds used to assess the significance of health impacts No additional comment. No response required. Analysis of distribution of effects The affected populations should be explicitly definedNo additional comment. No response required. Inequalities in the distribution of predicted health impacts should be investigated and the effects of these inequalities should be stated Vulnerable subpopulations are acknowledged throughout the HIA, but ultimately do not appear to be factored into the final assessment of post-mitigation impacts as there is no specific metric that facilitates this. If this is accurate, then this should be discussed as a limitation. If this is not accurate, additional clarification is needed. Clarification was added to Sections 2.4, 5.1.5 and the individual evaluation matrix tables in each assessment in Section 5.0. A column was also added to the summary table provided in the Project Summary and Conclusions (Section 8.0) that details each of the vulnerable populations considered. The following text was included in Section 2.4: “Vulnerable populations were also included as part of the assessment and the potential for disproportionate impacts on these individuals was
carefully considered in the classification of magnitude and adaptability. They were also taken into account when making additional recommendations.” Effects on health should be examined based on the population profile See immediately preceding comment. See above response. Reporting Discussion of Results The report should describe how the engagement undertaken has influenced the HIA, in terms of results, conclusions or approach taken No additional comment. No response required. The report should state the effect on the health and wellbeing of the population of the option and any alternatives which have been considered The assessment would be strengthened by brief discussions of the “do nothing” option (i.e. a “no project” option) for each category of impact. A brief discussion on the “No Project Alternative” is now provided in Section 4.2. The report should justify any conclusions reached, particularly where some evidence has been afforded greater weight than others No additional comment. No response required. Recommendations There should be a list of recommendations to No additional comment. No response required.
facilitate the management of health effects and the enhancement of beneficial health effects The level of commitment of the project proponent to the recommendations and mitigation methods should be stated Addressing this is recommended. Perhaps even more important is the inclusion of (or reference to) examples where the recommended mitigations have been successfully applied under similar circumstances. This type of information would help the uninitiated reader determine whether the proposed mitigations are acceptable. Section 6.0 now provides further details on responsibility for implementing recommendations and additional details on monitoring. There should be a plan for monitoring future health effects by relevant indicators and a suggested process for evaluation A follow-up community health assessment is proposed, but additional details pertaining to potential timing, responsible parties, evaluation, and application of findings are needed. Section 6.0 now provides further details on responsibility for implementing recommendations and additional details on monitoring. Communication and layout Information should be logically arranged in sections or chapter and the whereabouts of important data should be signaled in a table of contents or index Well done. The recommendation feature boxes and bolded text in determination paragraphs are helpful to the reader. No response required. There should be a lay summary (executive summary) of the main findings and conclusions of the study. Technical terms, lists of data and No additional comment. No response required.
detailed explanations of scientific reasoning should be avoided in the summaryAll evidence and data sources should be clearly referenced No additional comment. No response required.
Additional bulleted comments: Comments Response Neutrality in tone and content is achieved No response required Even in the updated July 3, 2014 draft, a discrepancy exists between the executive summary and later text with respect to the HIA being a “stand alone” document. It should be clarified which is correct. The text has now been clarified that the HIA is a complementary document to the EIR and CBA and not a stand alone document. On pg. 49 re: health risks associated with PM: what is the incremental increase in risk with specific incremental increases in concentration? Incremental risk is addressed elsewhere, but not for PM. The Project’s potential contribution to local ambient concentrations of PM2.5 was summarized in Table 5-7. On average, the Project is predicted to result in a 24-hour PM2.5 concentration of 0.5 µg/m3 and an annual PM2.5 concentration of 0.09 µg/m3 across the 1.5 x 1.5 mile air quality study area. As such, the Project itself will contribute a minor amount to the existing baseline concentrations of PM2.5, suggesting that the incremental health risks are low. There is a great deal of variability in the level of detail provided in the various “______ and Health” sections. Particularly striking is the limited depth of information for the two categories identified as of most concern to the community, i.e., oil spill and well blow out. It’s recommended that additional detail be provided in these two sections. Further, some specific contaminant concentrations and associated health risks for Section 5.2.3.1 are also needed. Additional information is provided in the following sections: ‘oil spill and health’ (Section 5.4.1.1) and ‘well blowout out and health’ (Section 5.4.2.1). The toxicity reference values for the individual TACs were provided in the EIR and the HARP model. Given that all of the hazard quotients and cancer risks were below their respective regulatory criteria additional details for individual chemicals were not provided in
Similarly, specifics are needed for naphthalene and volatile organic compounds (VOCs) in Section 5.2.4.1 and 5.2.4.2 (or an explanation for their absence), otherwise the rationale for the emphasis on hydrogen sulfide (H2S) is unclear. the HIA. Section 5.2.4.1 provides an overview as to why H2S was considered the driving compound for odor issues. Naphthalene and VOC issues were captured in the TAC section for potential health effects. The assessment recommends that soil-related health impacts be reassessed after Phase I testing – but this recommendation seems to only apply to health impacts of particulates. It is recommended that runoff also be considered. Section 5.3.2.3 in the soil assessment now notes that surface water controls and mitigation measures will prevent the runoff of soil particulates offsite. For each category of impact, it would be extremely helpful to the reader to have a map that identifies the predicted radius of impact – acknowledging that the various impacts may have different radii (e.g. radii for noise versus explosion). Currently, it is difficult to visualize the extent of impact from the proposed site. The EIR provides numerous maps for zone of influence of many of the determinants of health assessed. Therefore, in order to avoid duplication they were not provided in the HIA. Sections have been updated to identify which sections of the EIR provide pertinent figures. For each category of impact, it would be extremely helpful to the reader to have a map that identifies the predicted radius of impact – acknowledging that the various impacts may have different radii (e.g. radii for noise versus explosion). Currently, it is difficult to visualize the extent of impact from the proposed site. See above response. In the definition of “PM” in the Glossary of Terms, the diameter should be changed from “ug” to “um”. Acknowledged, the definition has been updated in the Glossary.
The assessment states that impacts to groundwater are not assessed because groundwater is not used for drinking, but other issues to consider include the connectivity of groundwater to other water resources, potential future uses of groundwater, and current uses of groundwater other than for drinking. Even if none of these issues apply to the location of the proposed project, acknowledging these potential concerns could be useful to the reader. Protection of GW resource is addressed in the EIR and details have been added to Section 4.2.2. of the HIA. Where possible, it is recommended that justification be provided whenever environmental monitoring data are generalized beyond their original point of collection (e.g., air quality in Hermosa Beach assumed to be similar to that of Hawthorne; page 42). This was the only example of where environmental data outside of Hermosa Beach was used in the assessment. It was justified in the text as being the closest station. It seems odd that stress isn’t listed as a post-mitigation health effect for upset/accident scenarios. Suggest revisiting. Sections 5.4.1 and 5.4.2 now address stress as potential post-mitigation health effects.
Appendix C-3 Peer Reviewer Letter
1
Memorandum
To: Intrinsik Inc.
From: Elizabeth Hodges Snyder
Date: 9/3/2014
Re: Review of external peer-review comment response in the July 14, 2012 Draft Health Impact
Assessment E&B Oil Drilling and Production Project
This memo is to certify that I, Elizabeth Hodges Snyder, have reviewed the July 2014 responses of Intrinsik Inc. to my previously provided peer-review of the June 26, 20414 Draft Health Impact
Assessment E&B Oil Drilling and Production Project. My concerns and comments have been adequately addressed.
Appendix C-4 Response to Public Comment on Initial Draft HIA
1 APPENDIX C-4: RESPONSE TO PUBLIC COMMENTS ON INITIAL DRAFT HIA Comment Commenter Response General Comments The initial draft of the HIA is very thorough and, in my opinion, not necessarily inaccurate. The problem I have with it is lack of proper context. I'm not sure how this can be addressed but feel it is extremely important that a context solution is found. What I'm referring to is the alarming nature of the document. For it to be thorough and accurate it seems difficult for it not to read this way. But if this firm was to complete the same evaluation of, say, an individual's commute from Hermosa to work in downtown Los Angeles, or even a walk to the grocery store, the report would undoubtedly give the same alarmist impression. D. InskeepThe revised draft HIA provides a transparentmeans of assessing potential health impacts (positive and negative) that the Project may have on the community. Consistently present the mitigated project in all tables MRSTables and text in the revised draft HIA focus on the mitigated projectas outlined in the final EIR. Pre‐mitigation effects are discussed only briefly to provide context and highlight the effort that has already gone in to mitigating community impacts. Additional recommendations were made in the revised draft HIA if potential negative health effects still exist from the mitigated project. The revised draft HIA consistently references the mitigation number from the final EIR in each of the sections. Many of the impacts are associated with vehicle emissions, dust and noise. As a comparison, they should study the associated impacts of a large construction project. For instance, there is an apartment building located at 8th and Cypress. If that was razed and another building constructed, how would that impact residents in terms of truck traffic, noise and dust? Council‐member Petty Therevised draft HIA focuses on potential health impacts of the proposed project. An assessment of health consequences of other decision‐making processes and projects is beyond the scope of this draft HIA. The revised draft HIA acknowledges that many of the health determinants assessed (i.e. noise, light, traffic) are similar to those expected during construction activities which are a common occurrence in urban areas. Please see the respective assessments (Section 5.0) in the report for further details. Issue Area: Similarities and Differences to EIRThe HIA states ‘While CEQA legally requires health‐based standards be address in the EIR, traditionally Alston & BirdThe text within the revised draft HIA has been updated to further expand on the rationale for conducting an HIA in addition to an EIR
2 Comment Commenter Response EIRs are not designed to comprehensively address health impacts, including social and economic determinants of health.’ The HIA dismisses in its entirety all of the State standards for the protection of the environment and public health, and replaces it with an assessment based on a literature review from Google searches and informally published literature. Any HIA prepared by the City must comply with existing laws and regulations, as they are the governing and recognized standards for the environment and public health. Given that this HIA does not utilize these standards, it should be retracted, and its statements disavowed by the City. and provides discussion on the value of HIA as a complimentary process in Section 2.2. Additionally, peer‐reviewed scientific literature and grey literature were the main sources of information for the revised draft HIA. The HIA expands on existing health considerations in the EIR. The rationale for the HIA lies in its unique approach to assessing a multitude of potential impacts (both positive and negative) to individual/community health. The HIA is intended to provide additional information, as well as relying on existing information provided in the EIR, to holistically evaluate health. Although the reports are complementary, in several instances the HIA provides further details on how specific aspects of the Project could positively or negatively affect the health of the community, and provides additional recommendations where necessary. In contrast to the HIA, the draft EIR does appear to utilize the applicable laws and regulations in its analysis of air quality, water resources, soils, noise, transportation and circulation. Alston & BirdThe revised draft HIA specifically notes when regulatory thresholds are considered in the analysis of air quality, water resources, soil, noise, and traffic. Please see the revised assessment (Section 5.0). To the extent that the HIA purports to address only topics that are not covered in the EIR, it should eliminate any discussion of air quality, water resources, soils, noise, vibration, lighting and traffic. These topics are addressed in the EIR pursuant to recognized laws and applicable standards, and should take precedence over guesswork and unscientific speculation. Alston & BirdThe HIA is meant to be a complementary document to the EIR and there are a number of sections that do indeed overlap. The revised draft HIA focuses on the post‐mitigation Project scenarios and provides a transparent evaluation matrix to ascertain whether the potential health effects are positive, negative or neutral for the project. Directly address the differences with the EIR/CEQA approach in the Executive Summary and in the first few paragraphs of the introduction MRSThiswas completed in the revised draft HIA.Issue Area: Summary Table The EIR concludes that all of the project's air quality impacts are less than significant, except for odors. (Draft EIR, pp. ES‐20 ‐‐ ES‐23.) The HIA's assessment of air quality, however, states, again, without any recognized scientific basis, that the magnitude of the health impact from Particulate Matter is "severe" and the likelihood of this health impact is "likely.” (HIA, Alston & BirdThe revised draft HIA contains a new assessment framework and extensive revisions to the Air Quality session have been made.
3 Comment Commenter Response Table ES‐1.) The health impact from Volatile Organic Compounds is also listed as "severe" with a likelihood of "possible." The table notes state that "severe" refers to health effects that are "chronic, irreversible or fatal.” It is completely irresponsible for the City to suggest that the air quality impacts of the project could be "fatal" when that is simply not true as demonstrated by the analysis in the draft EIR which contradicts that statement. Revise the table, if used, to address the magnitude reduction with the use of the average. MRSThe air quality assessment section in the revised draft HIA has been extensively revised and reports that no substantial health effects are anticipated based on the mitigated project scenario. Summary table – can they share the inputs for each ranking and how they were derived? As an example, at the community presentation, one of the document authors presented a slide demonstrating how the ranking for traffic was derived. One of the elements was determined to NOT have an effect YET, it was ranked ‐1. Perhaps I misunderstood, but wanted this clarified. Council‐member Petty Section 2.4 of the revised draft HIA presents a new evaluation metric to characterize potential health impacts and the definitions of the inputs to that metric. In the “Project Impact” sub‐section of each health determinant in Section 5, the revised draft HIA provides a detailed assessment of potential impacts and justification for each ‘ranking’ within the metric (i.e., geographic extent, magnitude, adaptability, and likelihood). Issue Area: Scope of HIA I do not see why GHG emissions are a health factor as indicated in the appendix – it appears they are deemed one as residents have deemed them one. But is there a real local health impact from GHG emissions? J. FaulstichGHG emissions were removed from the assessment sections of the revised draft HIA report and a rationale for their exclusion is provided in Section 4.2.1 of the revised draft HIA. Was the survey a scientifically conducted study? If not, it should be completely removed from the HIA. I would like to know how and who they reached out to for this survey. Simply from looking at the reported geographical dispersion of the results, 68% of the candidates live west of xxx. Because the text is cut off, I do not know what that that line of demarcation is. In addition to that, they need to disclose their sampling methodology to prove that this is a cross section of the community, as opposed to (for instance), purely sampling the attendees of an oil related community meeting. Otherwise, their sample would be biased, and not representative of the community as a whole. Council‐member Petty In Section 4.1, the revised draft HIA clarifies that the surveywas not a scientific study. The online survey was a convenient way to facilitate public input into the scoping process while minimizing time and expense associated with traditional survey techniques. However, we recognize that the informal online survey precluded the recruitment of a representative sample of the population. Because the survey was one method, among others, to gather input from the community and no scientific conclusions are made with the results, the fact that the respondents do not constitute a representative subsample of the population is not considered to be a significant limitation of the HIA.
4 Comment Commenter Response Issue Area: Air Quality I would recommend deleting the references to benzene studies done in China, Ecuador, and Croatia as they are flawed (as mentioned in the report) and oil fields operate under different conditions in other countries. W. BarrThe Air Quality section in the revised draft HIA has been extensively revised and references to the benzene cancer studies were removed from the revised draft HIA as they were no longer relevant. Likewise misleading is the paragraph citing WHO statistics on the deaths of 150,000 children due to climate change, while following up with the paragraph that it is difficult to predict the effect of climate change on local scales (pg 31‐32). Particularly when a previous table says that the health impact from greenhouse gases is considered to be low (table ES‐1). W. BarrGHG emissions were removed from the assessment sections of the revised draft HIA report and a rationale for their exclusion is provided in Section 4.2.1 of the revised draft HIA. I think the HIA was weak or remiss in exploring and identifying or ruling out the risk of cancer clusters surrounding oil and gas production facilities. H. SimonThe Air Quality section in the revised draft HIA has been extensively revised. The results of the Toxic Air Contaminants (TAC) assessment indicated that there would be no unacceptable cancer risk from Project‐emissions. Revise the report with the population weighted average across the City of Hermosa Beach (note: ONLY the population within the City of Hermosa Beach), but also somehow address that peak concentration associated with the mitigated project in the EIR. Revise the text to address the use of the weighted average throughout. MRSThe Air Quality assessment section in the revised draft HIA has been extensively revised and reports that no substantial health effects are anticipated based on the mitigated project scenario. Review the cancer classification for VOC of severe, as it only increases the burden by less than 0.01. Check text on this also. Note that much of the unmitigated project cancer risk comes from diesel particulate. MRSThe Air Quality assessment section in the revised draft HIA has been extensively revised and reports that no substantial health effects are anticipated based on the mitigated project scenario. With regards to the air quality analysis, it appears that they are not reviewing the impacts associated with the project. Rather, they are taking our existing conditions, layering in the potential incremental impacts, then providing an assessment of the risks associated with the resulting air quality. They should instead inform us of the impacts purely associated with the project and incorporate the probabilities of such potential impacts. Council‐member Petty The Air Quality assessment section in the revised draft HIA has been extensively revised and includes consideration of current air quality, the emissions from the Project alone and that of potential cumulative addition of the Project emissions onto the existing current conditions. Are the oil fields referenced similar projects in scope and technology? Council‐member Petty During the revisions to the draft HIA, the authors determined that the referenced benzene studies were not relevant to the assessment of TAC (toxic air contaminants) which included benzene among other
5 Comment Commenter Response contaminants and were removed from the document.Will the odors of this project be similar to hog farm odors? It would be useful to have a frame of reference. Council‐member Petty The revised draftHIA (Section 5.2.4) acknowledges that adverse health outcomes from odors, which are reported in the epidemiologic literature, are associated with facilities known for having higher and more continuous/frequent emissions of odorous compounds, such as pulp and paper‐mills, confined animal feeding operations and solid waste landfills. The odor section has been significantly updated in the revised draft HIA. The HIA purports to use a “conservative” assessment by applying a City‐wide exposure to PM10 and NO2 but such wild calculations would never be an accepted methodology, much less a conservative one, as it completely misrepresents the facts. No scientist would ever utilize the maximum concentration at stationary source and then apply that same concentration to every resident located within the City ‐ proven and tested scientific models demonstrate that this scenario would never occur. The HIA then uses that baseless methodology to determine health impacts and mortality rates throughout the City. Based on a completely fictional City‐wide exposure, the HIA concludes that N02 emissions will result in an estimated 6 additional cases of asthma incidence. (HIA, p. ii.) In truth, the N02 emissions are negligible. This same unscientific method of applying the pollution concentrations to all residents in Hermosa Beach was utilized for PM10, resulting in an ostensible mortality increase, which serves no purpose other than to cause confusion and fear. Alston & BirdThe Air Quality assessment section in the revised draft HIA has been extensively revised and reports that no substantial health effects are anticipated based on the mitigated project scenario. Another example, the HIA just assumes that H2S is “ten times higher” than the worst case used in the draft EIR (1,000 ppm v. 100 ppm) without any source or justification whatsoever. (HIA, p. 41.) In fact, the H2S is expected to be far less than 100 ppm ‐ the draft EIR notes that sampling data for other wells in the Torrance Oil Field have H2S levels of 2.5 to 6 ppm. (Draft EIR, p. 4.8‐60.) With 1,000 ppm exposure, death is likely (Draft Alston & BirdTheodor section has been significantly updated in the revised draft HIA.
6 Comment Commenter Response EIR, Table 4.8‐6, p. 4.8‐25), and the HIA's use of that number is intended to scare the reader and the resident into fearing so‐called public health effects which simply do not exist. Furthermore, any H2S release of 6 ppm would be located at the source (in the pipe) and would immediately disperse, resulting in significantly lower concentrations before it even reached the walls of the drill site. The HIA's conclusion that the "Geographic Extent" of H2S is "Community‐Wide" (HIA, Table ES‐1) is not only wrong; it is highly inflammatory and unfairly prejudicial. Will there be signs put up prior to the election outlining the “Red Zone”? If not I suggest we do so everyone can get an idea the exact size of the “Red Zone”. J. LangeThe Air Quality assessment section in the revised draft HIA has been extensively revised and reports that no substantial health effects are anticipated based on the mitigated project scenario. Increase in mortality rate – needs to be 0.0. I’m not sure how people could ethically vote on a project where there is even the slimmest percentage of possibility of people’s health being affected. S. McCallThe Air Quality assessment section in the revised draft HIA has been extensively revised and reports that no substantial health effects are anticipated based on the mitigated project scenario. Issue Area: Pipeline Rupture/Well BlowoutCould there not be more mitigations to further reduce the chance of a pipeline rupture resulting in oil loss to the ocean? Should double walled pipe should be required, maximum operating temperature and sulfur content of crude oil be specified (consistent with material of pipe including corrosion protection)? Perhaps ensure signage indicating the existence of the pipeline to reduce accidental puncture by construction equipment? Perhaps annual hydrotest requirement? J. FaulstichThis comment relates to engineering controls and mechanisms to mitigate the risk of a pipeline rupture which are outside the scope of a health impact assessment. Refer to the EIR Response To Comment for a response to these questions. I did not see an assessment or estimate of the injuries/fatalities which might occur during a worst case natural gas blowout event or sour gas loss of containment. J. FaulstichSection 4.8 of the final EIR includes a risk analysis of the likelihood of an individual fatality or injury for each release scenario. Additionally, a separate section assessing potential health impacts of accidents or upset conditions has been provided in the revised draft HIA. Issue Area: Noise/Light It would be helpful if they could correlate noise emanating from this project related to noise associated with construction projects, motorcycles, emergency vehicles and other noise that is fairly typical in dense Council‐member Petty The revised draft HIA Section 5.5.1 acknowledges that project noise emissions during the construction phase will be similar to those expected during other construction activities which are a common occurrence in urban areas.
7 Comment Commenter Response living situations. It provides a benchmark that is relevant to people. Clark Stadium is so well lit that residents can see it from Prospect in the south part of town. How does the impacts of the lighting from the site compare to this? Council‐member Petty The revised draft HIA contains a discussion of baseline lighting conditions (including Clark Stadium) as well as a detailed assessment of Project‐related light sources and potential impacts on health. Refer to Section 5.5.2. With respect to noise, the HIA concludes: "Increases in nighttime noise during drilling, testing, and production activities will likely change the quality of sleep of nearby residential neighborhoods." (HIA, p. iv.) In support of this statement, the HIA states that according to the World Health Organization, "a noise level increase of 6 to 14 dB A can change the quality of sleep and this is roughly the level of increase projected for nighttime drilling and production activities." (HIA, p. 54.) The draft EIR, however, states that half of the nighttime noise levels are less than 6 dBA, and more importantly, the draft EIR also evaluates whether the resulting noise level is less than the 45 dBA limit in the City's Oil Code, and with mitigation, most of those sites comply with that limit. The HIA improperly selects only certain information from the draft EIR (reports it incorrectly), and does not address the 45 dBA limit or whether this would change its conclusion. Alston & BirdThe revised draft HIA Section 5.5.1 evaluates noise increases from the proposed Project in the context of the 45 dBA limit in the City’s oil code. Given that the World Health Organization Nighttime Noise Interim Guideline is 55 dBA (with an ideal goal of 40 dBA), the standard set by Hermosa Beach (45 dBA) is considered a sufficient nighttime noise target. Plus, noise dissipates as the distance from the source increases, but for some reason, the HIA concludes that noise is “community‐wide”. No report exists to support the HIA's conclusion that the proposed project would result in noise across the City. Alston & BirdThe revised draft HIA Section 5.5.1 evaluates noise emissionsseparately for the project phases, and therefore separately for the short‐term pipeline construction. The geographic extent is specified as “Localized (project Site and along truck and pipeline routes)” With respect to pipeline construction and noise, the HIAfails to acknowledge that the noise in any one particular location typically lasts for less than one week, usually two or three days, not four months. Alston & BirdThe revised draft HIA Section 5.5.1 states: “According to the EIR, construction of the Pipelines is scheduled to take 17 weeks, with the time in front of any one location limited to approximately 1 week (MRS, 2014).” Issue Area: Traffic Can they choose an existing oil project and study the impacts of the community’s “walkability” factor? As an Council‐member Petty The HIA relies on existing research to assess potential health impacts of the proposed project. As far as we know, there are no existing
8 Comment Commenter Response example, there is an oil project located in Huntington Beach, among a community. Did that result in lifestyle changes for those residents? studies on oil projects in a densely populated area and the effect on community walkability. Trucks in Hermosa Beach‐ what is the current volume of trucks (garbage, etc.) and how does the proposed increase for oil transportation relate to this? S. McCallAs described in the HIA, traffic counts were collected on roadway segments of Pier Ave, Valley Drive, and Herondo Street in mid‐ July 2013 to establish baseline truck traffic in the vicinity of the proposed project Site. A daily average of 55 two and three‐axle trucks (e.g., garbage trucks) were counted. No four‐(or more) axle trucks were counted. The number of additional truck trips during the proposed project will be as many as 18 three+ axle round truck trips per day. Please see Section 5.6 for the updated traffic assessment in the revised draft HIA. Issue Area: Community Livability The HIA relies on sources which are not recognized or based on generally accepted scientific principles, or sources which have only a modest connection to the topic considered, and any HIA should utilize tested standards or regulations, or at a minimum, acknowledge that conclusions based on untested or unrelated literature have limited value. For example, with respect to social cohesion, the HIA utilizes sources regarding “social support” – which is not defined or explained and may reflect the support of family and friends rather the psyche of a city. Alston & BirdUnlike for the physical environment, there are few regulatory standards which require consideration of the social and economic determinants of health in the decision‐making framework. A key strength of HIA is the ability to fully examine the health consequences of projects by pulling from a wide range of methodologies. The revised draft HIA contains an updated assessment of social cohesion with a clearer identification of the sources relied upon and a discussion of the potential difference in interpretation (Section 5.7.5). The HIA also states that ‘political stress surrounding the impending vote on repealing oil in Hermosa Beach is very present and has already impacted social cohesion in the community.’ It seems incredible that such a conclusion could be reached based on a survey of less than 1.5% of the City's population. Alston & BirdThe purpose of the online survey conducted during the scoping step of the HIA was to understand the key health concerns related to the proposed project among community members. The survey did not inquire whether or not participants were experiencing stress surrounding the vote. A revised assessment of social cohesion and political involvement are provided in the revised draft HIA (Section 5.7). Did the avoidance of a potential $700 million damage award against the City provide any social cohesion? That, of course, is not discussed at all. Alston & BirdThe draft HIA focuses on potential health impacts of the proposed project and the vote that will occur. A retrospective assessment of health consequences of previous decision‐making processes is beyond the scope of this draft HIA.
9 Comment Commenter Response A revised assessment of social cohesion is provided in the revised draft HIA (Section 5.7.5). The HIA also lacks balance as it takes ample liberties with its many unsubstantiated negative impacts, but is woefully inadequate in its analysis of the substantial positive benefits that could result from the project, as discussed in the Cost Benefit Analysis. Alston & BirdThe revised community livability assessment (Section 5.7) provides further details and discussion of potential positive health effects of the proposed Project. Has the HIA factored into the popularity and HIGH TRAFFIC nature of the portion of the Green Belt in the “Red Zone” and the # of Hermosa and non‐Hermosa residents that pass through the “Red Zone” while using the Green Belt for exercise or recreational purposes? All day long I see Hermosa Valley students going to and from school, Elderly/Children/Infants/Pregnant Women walking on the greenbelt as well as runners and dog walkers enjoying the Greenbelt while passing in front of the projected site. We need to consider the negative impact of having a High Risk Health Impact “Zone Red” will have on the Green Belts popularity. The Green Belt needs to be treated no different than the strand. And what would happen to the # of beach goers if they knew they would be in a health risk area at the beach? Our borders are thin and if you sneeze on the north side you get sick on the south side. J. LangeThe close proximity of the Greenbelt and the use of beaches are included in the discussion of community green space in section 5.7.2 of the revised draft HIA. Issue Area: Other It would be instructive to the community if the health impacts and any proven health issues associated with the Redondo Beach drilling and oil production were studied. Council‐member Petty There are no readily available reports of health issues associated with the Redondo Beach drilling, which occurred in the 1950s. Performing original research is beyond the scope of this HIA. (Comment to EIR, CBA, and HIA) Presentation of findings ‐ can the findings be related to similar projects in other cities (Beverly Hills, Huntington Beach ... USA or outside of the USA)‐ what are the proportion of ‘successful' projects where there have been no issues and the community has been fully supportive, versus 'unsuccessful' projects where disasters have arisen, health issues, etc. Can the finding be more relatable S. McCallThe revised draft HIA will relate the E&B proposed project to other projects, when possible. There have been no previous HIAs prepared for this project to use for comparison purposes. Findings of the final HIA will be presented to the community and visuals will be used when appropriate.
10 Comment Commenter Response both in using visuals of the proposed site and buildings; as well as on matters such as noise, smell, etc. Can the findings be related to the previous time this measure was evaluated and voted on. Can the findings be presented at a public town hall event, with public Q&A.For each location listed, in the past 20 (or 10 years), how many hospitalizations and deaths were attributed to site operations? JD PreletzThere are no readily available reports quantifying hospitalizations or deaths attributable to site operations for each drilling site in the Los Angeles Basin. Performing this original research is beyond the scope of this HIA.
Appendix D
Health Impact Assessment Community Survey
Response
Percent
Response
Count
24.4% 66
44.1% 119
7.8% 21
7.0% 19
6.7% 18
10.7% 29
24
270
22
Number Other (please specify)
1 Torrance
2 Torrance
3 torrance
4 torrance, palos verdes area
5 Torrance
6 Torrance
7 Torrance
8 Torrance
9
10 Leimert Park-Baldwin Hills
11 Long Beach
12 Torrance
13 san fernando valley but go to the beach often and the air quality has gone down again
14 Hawthorne
15 Mar Vista, California
16 South Gate
17 Oceanside, Ca
18 Visit my patents there
19 rancho palos verdes
20 [Personal information removed]
21 Lawndale
22 Lakewood
23 Our lives depend on the Bay, no matter wear you live. THE BAY IS NOT FOR SALE.
24 Torrance
skipped question
Hermosa Beach - North of Pier Ave and West of the PCH
Redondo Beach
This is the ONLY serious question in this survey. Of COURSE everyone is sane enough to be"concerned" about all those things
AND nuclear warfare AND rabid dogs. I am CONCERNED about those as well
Health Impact Assessment Community Survey
Hermosa Beach - North of Pier Ave and East of the PCH
answered question
Answer Options
Manhattan Beach
Hermosa Beach - South of Pier Ave and West of the PCH
Other (please specify)
Question 1: Where do you live?
Hermosa Beach - South of Pier Ave and East of the PCH
Response
Percent
Response
Count
94.2% 274
3.8% 11
3.1% 9
291
1skipped question
No
Question 2: Are you concerned about how the proposed oil production project could impact
you and/or your family's health and quality of life?
answered question
Yes
Health Impact Assessment Community Survey
Not Sure
Answer Options
I am very
concerned
I am somewhat
concerned
I am not
concerned
I don't have an
opinion Rating Average Response
Count
247 26 9 1 1.17 283
220 39 21 3 1.32 283
177 63 32 6 1.52 278
204 47 25 6 1.41 282
248 25 8 2 1.17 283
230 45 6 2 1.22 283
195 58 23 6 1.43 282
210 51 16 5 1.35 282
234 30 15 4 1.25 283
244 22 11 3 1.19 280
259 16 10 1 1.14 286
249 27 8 1 1.16 285
254 23 6 1 1.13 284
207 55 20 2 1.36 284
212 43 16 6 1.34 277
223 33 19 4 1.30 279
210 41 24 4 1.36 279
73
286
6
Number Other (please specify)
1
2
3
4 I am concerned about all the ways this
project will negatively impact our
5 Global warming: We need to consume less
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
This project would ruin our City in all the above ways. The residents of Hermosa Beach must do everything they can to stop this project to maintain our quality
of life now and in the future.
I am concerned about potential diversion of limited water resources to the use of oil well drilling and/or potential hydraulic fracturing as is evidenced by the "Will
Serve" letter from the West Basin Municipal Water District for 375 acre feet of reclaimed water to the E&B Oil Project, since such water would otherwise be
available for other uses such as irrigation, thus placing additional demands on potable water supplies to make up for the potential loss of 375 acre feet of
reclaimed water resources. I am further concerned that such added demands on limited water supplies will help support the West Basin Municipal Water
District's plan to build a major ocean water desalination facility at the NRG facility in El Segundo.
I see only major risks and no material benefit to the citizens and property owners of Hermosa Beach. I also invite you to review the Health Impact Assessment
for Battlement Mesa Garfield County, CO: http://www.garfield-county.com/public-
health/documents/1%20%20%20Complete%20HIA%20without%20Appendix%20D.pdf - which was prepared by 7 individuals who include 2 Medical Doctors,
and collectively hold 3 MSPH, 1 PHD, 1 MPH degrees.
we all are affected because the wind comes right over the hill and into all areas and affects all of us
Particualte matter is carcinogenic. Air quality...the wind blows east. I have lived in Hawthorne for 60 years and we go to the beach, eat at the restaurants,
enjoy the entertainment and shops in HB , MB and RB. Also this is a small planet and what affects one area impacts all of us.
Impact to tourism. Do not allow drilling to happen!!
Most wonderful beach community south of malibu and north of san onofre. Some of the greatest people in l a county. They're going to put a gargantuan
blemish in the south bay and risk the welfare of it's terrific inhabitants lo the entire south bay. Its an unnecessary risk and more important to preserve an
already challenged ecosystem.
I work for a reconstructive surgeon in Beverly Hills...we have a large number of young women patients living in Manhattan Beach, addresses within 3 miles of
the oil plants that have breast cancer. Makes me wonder...because I live here too.
With solar energy in almost unlimited supply, doing this is stupidity and greed at work.
while certain aspects of the project do not affect me directly, (i.e., noise, lights, vibrations, odor, etc.), I would not want them imposed upon anyone in this
community.
Final debt incurred by the city due to mismanagement of the whole project.
the question is not IF a spill will happen, but WHEN will it happen. Ask the folks in Mayflower, Arkansas. Ask the folks who live along the Gulf of Mexico. Ask
the folks who live anywhere near an oil field.
I do not live in the immediate areas, but I am concerned for the health and safety and environmental protection----FOR ALL AREAS. Thank You, [Personal
information removed]
I am extremely worried about all the above ramifications of oil drilling.
All of the above, plus unknown factors which could potentially show up later in our (and our children's) health.
the discussions held so far seem to relate only to how this can be done successfully but without the actual dollar amounts to the city and how my life as a home
owner in HB is going to be benefited-so far it is all let us do it and there is money for you.
Oil drilling and production is a dirty, noisy and dangerous business and it has no place in such a densely populated town.
Quality of life; specifically health risks to all and , in particular , children and elderly, and the potential contamination to the air , ocean and environment
Other (please specify)
Surface water/runoff contamination
Earthquakes
Truck traffic
answered question
I am concerned about the incidences of hear disease, lung disease and cancer in our community. Will there be a benchmark study that identifies hotspots that
then has comparison studies over time?
The people already voted NO on oil drilling - - why are we still "talking about it" ???
Impact on property values
i have health concerns and my doctor told me to move if the city moves forward with this proposal.
Health Impact Assessment Community Survey
Potential impacts to the ocean or beach
Lights
Property values
Less access to community spaces (e.g., the greenbelt
Answer Options
Explosions/Spills/Accidents
Noise
Land subsidence (sinking)
Parking problems
Question 3: If you said YES or NOT SURE (to #2), please indicate your level of concern, if any, on the following issues:
Soil contamination
Vibration
Image of the City
Drinking water contamination
Air quality issues (e.g. particulate emissions)
Odor
skipped question
Oil drilling is a great idea and will bring much needed revenue to our city.
I support oil drilling.
it feels terribly wrong to release these chemicals and dig up the earth
Effects of discharges into older capped wells. Hydrogen sulfide danger. Evacuation routes. Falling drilling rigs. Cross-contamination from animals and oil
workers. Psychological and physiological effects of fear, stress and anxiety. Emotional discord from fractured relationships within the community.
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
Safety for recreation and enjoyment on Valley- baseball field, park, green belt, lawn bowling, farmers market, children walking to/ from school
cancer!
I live a couple of blocks from this site. I am a mother with two small children ages 3 and 4. I am very concerned about their health and their ability to enjoy our
neighborhood parks, such as the green belt and South Park, and the beach.
Walking and biking safety. Overall traffic not just truck traffic. Regulation of any project being overseen by a government body. Slow poisoning from Toxic
Airborne Chemicals. Health Issues like Headaches, Respiratory problems, Nosebleeds, everything from Autism to Alzheimer's but mostly kids being exposed
to the very toxic chemicals associated with Oi and Gas Drilling and Production.
SAY WHAT? If you live any place in the southbay, all of these are of concern unless you are greedy or brain dead.
Cancer, nose bleeds, birth defects
Drilling in Hermosa is a bad idea for the city. I would never vote for it
long term chronic health issues, potential for further litigation over illness, plus all of the above.
"City" in theory gets richer, but my quality of life deteriorates dramatically.
The construction phase will generate noise, traffic and i've heard E&B will need to remove the green belt from 8th street down to 2nd street to allow their tractor
trailers with supplies to come in. This phase is ongoing for 2 years and will disrupt my family, children not walking to school and noise. We live on top of 7th
street and the wind blows up our street like a wind tunnel and the noise, pollutants and light will come right up our street.
It is wrong for the City to ignore the voice of the people in 1995 vote to approve Citizens Initiative , Measure E, which restored a total ban on Oil Projects
CITYWIDE. how dare they consider any EIR before a new vote.
Exposure to lawsuits from adjacent cities from decreased property values, image of city, etc.
Quality of the company Hermosa has signed a deal with. Nobody has done a background check on a company that you are going to enter into a $1 billion+
dollar agreement. Steve Layton is the President of over 9 companies. Has anyone done their due diligence on the various companies he runs? He has
documented with the State of California at least 16 spills of 16,000 gallons over 6 years with EB! What about the other companies he runs? I just read about his
company in Huntington Beach that may have spilled 700 gallons of oil and may have gas leaks. He has already had major spills and declared bankruptcy. Is
methane blowouts of capped wells buried under homes should be #1 on your list. Do your homework!
Quality of life. Residential should be residential. A peacefull oasis with light industrial warehouses is acceptible. This is my home (right next door) this is my
greenbelt and place of refuge. This is going to be unsightly and out of place. The city screwed up on this agreement and they MUST fix it.
nosebleeds from children (like the la times story)
blowouts on capped wells
obstructed viewsmfrom tall oil derecs
The green belt trail is one of few open space areas for residents, children and visitors. It is also a nesting and hunting habitat for migratory birds, raptors and
other species of animals. This industrial site will negatively impact this space,
pipeline through Tonga lands, Redondo and Torrance
I live close to Hermosa. I already am very concerned about adverse effects of airport, vehicle traffic, and refinery pollution in south bay. If this project happens,
I will move my family out of south bay and relocate to San Diego for my job.
Will this be a 24 hr /7 days operation, Will the people nearest the drill site if passed be trained and be hired to work there
This community is too small for the amount of oil drilling and the risk is too significant. Too many examples exist of how other communities have been
negatively affected. People move to Hermosa Beach to avoid this kind of potential environmental calamity.
I am also very concerned about the effect on ocean life. I am not sure if that falls under the umbrella of "ocean or beach," but want to be sure that ocean life is
considered.It seems that truck traffic will result in an increased rate of road deterioration (especially on Valley Drive?). The road maintenance costs (and general loss of a
traffic route for any road repairs/construction) needs to be well defined & strongly considered for this proposal.
I am also concerned about ultimately adding to the amount of carbon dioxide and other greenhouse gases in the atmosphere. We are already facing a crisis
produced by the amounts released to date, and they are already having problematic health and economic impacts on the entire planet.
Also, I don't like the idea of changing a "light industrial" area of our tiny city into a heavy industrial area.
My only concern is the financial impact to the city and the ME if the oil drilling is not allowed. I have no concerns at all about health issues. My only concern is
how the city is going to pay the $17.5M fine if this doesn't pass. I don't want it coming out of my pockets. AND I would rather see the city spend it's money on
much needed repairs such as a sewer upgrade. There are so many other areas in the city that need improvement and repair. Let's spend the money where it
is needed and NOT on a $17.5M fee if this doesn't pass.
Poisonous gas leaks
Disruption due to construction of wells and pipeline
Increased risk for those at high risk for cancer (I have had it 3 times), comprimised immune symptoms, children and infants, respitory issues, seniors.
I am concerned that all of the potential health hazards are not even known yet. Companies routinely try to deny that diseases and impacts of any
drilling/contamination are their responsibility. It is always blamed on something else or postulated that the amount of poison that is released is so insignificant
that there are no health risks associated. Yet we see cancer rates rise, the rates of neurological diseases increase and many other potential health issues that
we cannot even predict occur in clusters around these toxic sites. I am very concerned!
Suggest "subsidence" be defined as having to do with sinking and not "subsidy".
The most important concern are methane blowouts. There are many abandoned wells buried under homes. Do we want to have methane alarms on our
homes like Playa Vista? I think not.
The city does not have a hospital or clinic in case of an multiple emergency, which is possible when you have this kind of business in a small town. Nor has
many ambulances for Transfers to nearby hospitals.
[Personal information removed]
I already live close to the Redondo power plant and it's an eye sore. These oil pumps will have the same impact.
I BOUGHT MY HOME IN 1984 ON 2ND & VALLEY THE SOLE PURPOSE OF NOT BEING BY IMDUSTRIES SUCH AS THIS. I LIVED THROUGH THE
MCPHEARSON NIGHTMARE AND HOPE THE CITY REALISES ONCE AGIN THAT OIL DRILLING IS NOT A GOOD CHOICE FOR HERMOSA BEACH
NOW OR EVER!!
The oil and gas industry’s exemptions to major environmental laws
http://www.shalegas.energy.gov/resources/060211_earthworks_fs_oilgasexemptions.pdf
danger of traffic for our kids going to school
Children safety with trucks on road
Keep that [Expletive] overseas or tap into Alaska!
I am opposed to the oil industry due to global warming. I believe that oil SHOULD be more expensive, so that we learn to use other fuels. finding more
sources of oil is NOT how to save this planet.
I am gravely concerned that this project would pose significant risks to our long term health - cancer, asthma, etc. There is no way this project can mitigate my
concerns to a reasonable tolerance. Absolutely no way whatsoever.
Children playing near trucks
70
71
72
73
There are so many potential risks that to even consider this project from a health and quality of life perspective is ludicrous.
Effects of inhalation of low level esulfer dioxide and benzene on small children and infants. I live 150 yards due east of the drill site. Will my families rate of
cancer and illness increase even 1 percent due to this project.
All of it. Everything about this projects scares me
Exposure to NORMs (Naturally Occurring Radioactive Material) brought to surface and stored on site during processing.
Exposure to toxic chemicals and substances.
Psychological issues and effects of stress.
Years of construction hassles, street closure, noise, flaring methane.
I am very
concerned
I am somewhat
concerned
I am not
concerned
I don't have an
opinion Rating Average Response
Count
237 28 10 4 1.22 279
249 20 7 3 1.15 279
243 22 10 3 1.18 278
256 16 6 2 1.12 280
232 22 14 4 1.23 272
44
280
12
Number Other (please specify)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
EB is not clear how long and or often the 150' rig will be installed. They said 2 weeks but every year?
The guys running E&B could have been in jail for their past failures.
When will it end?
I am not any more concerned about oil drilling than I am about new home construction and associated noise.
All phases of the project are of great concern o me and my family. The impacts to the health of the community, the local environment and the surrounding
environment (including air, water, soils) is of great concern as well. This report should be shared with residents and government of surrounding communities
such as Redondo Bch and Manhattan Bch.
I own a house on 8th Street just west of PCH and at night can hear the waves crashing on the beach. It is not loud, but just loud enough to enjoy the sound in
the early mornings when cars are not driving along the street. I don't want this sound to be replaced by construction and drilling that will occur 24/7 in Hermosa.
Although this project will bring money to Hermosa Beach, it will devalue my home.
there are 3600 24hr continuous drilling days allowed in the lease , 120 days for each well, the EIR says they will use 900 days, 30 days per well. This means
that 2700 days are 'drill credits' per the lease to be used anytime in the 35 years, this is a health impact and is not even considered in the EIR as proposed.
READ THE LEASE.PLEASE if you want to know more possible impacts, like all processes 'known or unknown' if you want a blank chemical check for example.
I am very concerned about the project not being cleaned up when production ends.
I DO NOT WANT OIL DRILLING OF ANY KIND DOWN THE STREET FROM MY HOME.
This was already defeated so now they do an end around and try to get it through again because they have the money to do so. When the wants of the
financially capable overcome the wants of the majority, we are in trouble.
Clean up of site after project ends. The City had to sue Stinnett Oil, the last driller, to clean up the site after they stopped. With the litigation, this took many
Who will clean up spills when they occur? Who will pay my medical bills when I or my family becomes sick? Who will provide fresh, safe water for me when
mine is contaminated?
I am concerned about opening up drilling into Santa Monica Bay, whether it is in Hermosa Beach, Redondo Beach, or Torrance.
I could not find any history of exploitation of oil and gas in an area as populated as Hermosa Beach, or many wells concentrated in such a small surface.
Please have some sense people. If this happens it will surely ruin a great place to live and vacation.
I suspect all phases of the proposed project will take longer than projected and that operations can be extended past the 35 year lease term. I also think it's
unconscionable to allow non-stop drilling operations (24/7) during any phase of the project.
This project will despoil the South Bay. PERIOD.
PLEASE STOP THE MADNESS
We have reached the limit of environmental destruction. STOP. The city should invest in clean, green solar energy. We have the sun....invest in that!
This project will be (and has been already) a concern on many levels. Oversight by the City officials, the project specifics and everything in between. I have
zero confidence in this company or it's management, nor do I have confidence that the City officials know enough about oil production to effectively oversee
this project.
I'm concerned that the crazy people in Hermosa Beach will start a riot if oil drilling is approved. Oil drilling is a great idea for our town. I wish everyone could
see that.
I support oil drilling.
Fear of a catastrophic accident. Ground water contamination. Cancer & other diseases. Collapse of property value. Destruction of our current idyllic quality of
Clean up could be hell. Our children & grandchildren will be stuck with this nightmare.
what are the system management procedures after the final phase of the project should it go forward?
Concerned more agressive oil stimulation/extraction techniques not currently disclosed will be used in the future as the well production decreases. Also
concerned about 30 plus capped wells after project ends.
The people already voted NO on oil drilling - - why are we still "talking about it" ???
This is insanity. This is FRACKING for both olil and natural gas. This is insanity.!
I don't want oil drilling period!!! Any phase is a bad phase. We need renewables!!!
I am concerned that this proposed project would provide no health or environmental benefits to the city of Hermosa Beach or South Bay region. Hermosa
Beach does not NEED the revenue from a project that will ABSOLUTELY have detrimental effects to the image, health, and everyday life in Hermosa Beach
and South Bay. The only question is HOW BAD those effects will be. E&B Natural Resources does not provide clear information on their site about the
harmful effects of oil production that will be caused by this project (like all oil exploration projects). I hope that the EIA and Health assessment will make those
impacts clear to the people of Hermosa Beach. Although not directly related to health, it would be interesting to better understand how this project would effect
the efforts of Hermosa Beach to become carbon neutral: http://www.easyreadernews.com/8361/carbon-neutrality-gets-push/
I am very opposed to drilling oil in the Santa Monica Bay, especially in Hermosa Beach where I own a home. There is no way we can be assured that there will
not be catastrophic consequences from extracting oil from under the ocean floor. We have a beautiful beach and ocean that needs to be preserved.
I am also concerned that should this project be approved, and complete 35 years of oil production, that after the termination of oil production and abandonment
of the site by E&B Oil, that the 30 oil production wells and 4 water injection wells will leave an ongoing risk to future generations of South Bay residents through
the potential degradation and/or damage by natural forces such as seismic activity, of the capped well bores, which could lead to future gas, oil, contaminated
water, and other potential pollutant leakage, blow outs, explosions, spills, and other unintended consequences that would otherwise not exist without these 34
Other (please specify)
spills happen wherever drilling takes place. end of discussion.
Migration of toxic elements and release into environment after leasehold is abandond.
If it ever does end!
Extremely concerned E&B will not take full financial responsibility for any accidents or damage to property or human life as a result of their prospective drilling
without extensive & costly litigation.
Health Impact Assessment Community Survey
Phase 3 -Final Design and Construction (approx. 16
skipped question
Answer Options
After the project ends
Phase 2 -Drilling and Testing/Install Production
answered question
Question 4: If you said YES or NOT SURE (to #2), please indicate if your level of concern differs based on the phase of the proposed project. If you would
like more information on each phase, please refer to Slides 9 through 14 of the EIR presentation: click here
Phase 4 -Drilling, Development and Operations (ongoing
Phase 1 -Site Preparation/Construction (approx. 6-7
37
38
39
40
41
42
43
44
Health effects for next generations
Once the oil is tapped and flows, there is no turning back. the potential for contamination is with us, and it is permanent. I have never seen a pristine oil field
recovery.
I don't want oil wells of any kind in Hermosa Beach. I don't want any oil or gas pipeline or fracking or any other type of oil drilling or excavation in Hermosa
We currently have a zero percent chance of experiencing health or safety issues related to oil drilling in Hermosa. There is no way the inherent dangers posed
by oil drilling can be mitigated except to prevent oil drilling from happening at all.
I plan to live in Hermosa Beach until I retire. Although, people focus on the immediate environmental impact of the project, I think people tend to forget to ask
"What is going to happen to this place, after these guys leave".
Lets see, if the people lived here that put this survey together lived here wouldn't they check every box "I am very concerned" ? Inane, our city and our life
blood the ocean is NOT for sale
Drilling is a bad idea. I will be voting no.
I live very close to the proposed sight, [Personal information removed]
Appendix E
Baseline Health Assessment
Appendix E: Baseline Health Assessment
TABLE OF CONTENTS
1.1 Introduction ............................................................................................................................................ 1
1.2 Demographics ......................................................................................................................................... 1
1.3 Current Health Conditions ................................................................................................................ 3
1.3.1 Cancer Data ......................................................................................................................................... 3
1.3.2 Mortality Data .................................................................................................................................... 5
1.3.3 Hospitalization Data ....................................................................................................................... 6
1.3.4 Birth Outcomes ................................................................................................................................. 7
1.3.5 Pedestrian‐Related Injury ............................................................................................................ 8
1.3.6 Health Behaviors ............................................................................................................................ 10
1.4 Environmental Quality ..................................................................................................................... 10
1.4.1 Outdoor Air ....................................................................................................................................... 10
1.4.2 Noise .................................................................................................................................................... 14
1.4.3 Surface Water .................................................................................................................................. 16
1.4.4 EnviroScreen .................................................................................................................................... 17
1.5 Access to Health Supporting Resources .................................................................................... 19
1.6 Community Health Promotion ...................................................................................................... 22
1.7 Limitations ............................................................................................................................................. 23
1.8 Conclusions ............................................................................................................................................ 23
1.9 References .............................................................................................................................................. 25
FIGURES
Figure 1: Age Distribution in Hermosa Beach vs. County of Los Angeles (embedded)
Figure 2: Pedestrian‐vehicle Collisions (2003‐2007) in Hermosa Beach
Figure 3: Southwest Coastal Los Angeles County Air Monitoring Area
Figure 4: Traffic Density in Los Angeles County by Zip Code
Figure 5: CalEnviroScreen Results for the City of Hermosa Beach
Figure 6: Licensed Healthcare Facilities near Hermosa Beach
Figure 7: Groceries and Farmers Markets in Hermosa Beach
TABLES (Embedded in Text)
Table 1: Demographic Summary
Table 2: Expected and observed numbers of cancer cases by type and race in Los
Angeles County and Hermosa Beach, 2000‐2010
Table 3: Mortality Profile in Los Angeles County and Hermosa Beach, 2009‐2010
Table 4: Hospitalizations in California and Hermosa Beach, 2010
Table 5: Birth Outcomes in California and Hermosa Beach, 2011
Table 6: Motor Vehicle Collisions and Injuries by Type of Collision in Hermosa, 2009‐
2011
Table 7: Air Quality in Southwest Coastal LA County and Central LA, 2011‐2012
Table 8: Summary of Existing Noise Levels Around the Project Site (Lmax)
ATTACHMENT 1 USC Baseline Cancer Assessment
- 1 -
1.1 INTRODUCTION
The objectives of the baseline health assessment are to establish the current health status
of the City of Hermosa Beach (Hermosa) community, and to evaluate whether the current
profile of the community reveals vulnerabilities to any of a number of health outcomes.
Understanding baseline conditions is particularly important when conducting a Health
Impact Assessment because pre‐existing conditions can mediate potential health impacts
associated with the proposed project. For example, populations with baseline exposure to
high levels of air pollutants are more vulnerable to adverse health impacts from additional
increases in air pollution.
The methods used in the baseline health assessment are based on the Guide for Health
Impact Assessment from the California Department of Public Health (CDPH 2010).
According to the CDPH Guide for HIA, the selection of indicators for the baseline
assessment should include indicators for health status, as well as indicators for known
social, economic, and environmental health determinants, and should reflect priority health
issues being addressed in the HIA. Hermosa‐specific health indicators are compared to
either Los Angeles County (LA County) or the State of California, in that order of
preference, depending on which measures were available. By comparing Hermosa data to
the same data for a larger geographic region, we were able to characterize the health status
in Hermosa relative to expected health status.
The baseline health assessment focuses on the City of Hermosa Beach, where the majority
of the proposed project activities take place. We acknowledge that similar assessments
may be valuable for the other impacted communities, due to pipeline construction and
truck routes planned through areas of Lawndale and Gardena. However, impacts outside of
Hermosa will be limited to shorter periods of the project timeline and baseline health
assessments for other cities were outside the scope of this HIA.
1.2 DEMOGRAPHICS
Data from the 2010 US Census was used to obtain demographic information for Hermosa
Beach and the County of Los Angeles, as a comparison population (US Census 2013). The
2010 population of Hermosa was 19,506 with 52.7 percent male and 47.3 percent female.
The age distribution in Hermosa according to five year age categories is compared to the
age distribution in Los Angeles County in Figure 1. The most obvious differences between
the Hermosa and Los Angeles populations are in the 15 to 19 and 25 to 29 age increments.
In Hermosa, the percentage of teenagers ages 15 to 19 is fewer than half the percentage for
LA County (3.1% vs. 7.7%), while the percentage of young adults ages 25 to 29 is nearly
double the percentage for LA County (13.4% vs. 7.7%).
Age is an important factor in determining vulnerability. According to the census data for
Hermosa, approximately 25 percent of the population may be considered to be more
vulnerable to certain environmental exposures, based on age (9% over the age of 65 and
16% under 18 years). This is less than the percentage of Los Angeles County residents
considered vulnerable to environmental exposures based on age (35%).
- 2 -
Figure 1. Age Distribution, Hermosa Beach vs. Los Angeles County
Source: US Census, 2010
Table 1 below provides both city and county level demographic indicators from the US
Census. In the 2010 US Census, 95.8 of residents in Hermosa reported one race: 86.8
percent identified as White, 5.7 as Asian, 1.2 percent as Black or African American, 0.3
percent as American Indian and Alaska Native, 0.2 percent as Native Hawaiian and Other
Pacific Islander, and 1.7 percent as some other race. Compared to the County of Los
Angeles, Hermosa is much less racially and ethnically diverse. On the county level, 48.2
percent of the population identifies as Hispanic or Latino while in Hermosa, only 8.4
percent of the population identifies as Hispanic or Latino.
Median household income in Hermosa Beach is almost double that of LA County ($102K vs.
$56K). Fewer than 4 percent of Hermosa residents live in poverty, compared to 16.3
percent of LA county residents. Nearly 70 percent of Hermosa residents have obtained a
bachelor’s degree or higher, compared to less than 30 percent in greater Los Angeles
County. In contrast to the income profile, the homeownership rate in Hermosa is less than
that of LA County (44.9 percent versus 47.8 percent). The homeownership profile is likely
explained by Hermosa as a beach tourist destination and an area highly attractive to both
renters and leasers. Further, with a median housing unit value over one million dollars,
homeownership in Hermosa is over twice as expensive in Hermosa compared to County‐
wide.
Education level, income, and housing are all components of social determinants of health.
Social determinants of health refer to the role that our social environment and economic
situation play in shaping our health, as social and economic factors are the single largest
predictor of health outcomes, compared to clinical health care, health behaviors, and the
0
2
4
6
8
10
12
14
16
Under 55 to 910 to 1415 to 1920 to 2425 to 2930 to 3435 to 3940 to 4445 to 4950 to 5455 to 5960 to 6465 to 6970 to 7475 to 7980 to 8485 years +Percent of populationAge Category
Hermosa Beach
Los Angeles County
- 3 -
Table 1. Demographic Summary
Source: US Census, 2010
physical environment (LACDPH 2013). The Los Angeles County Department of Public
Health (LACDPH) ranked 117 cities in LA County by economic hardship, using the following
indicators: (1) crowded housing, (2) percent of persons living below the Federal poverty
level, (3) unemployment, (4) percent of persons over age 25 without a high school
education, (5) dependency (percentage of the population under 18 or over 64 years), and
(6) per capita income. Based on 2005‐2009 data for the indicators listed, LACDPH ranked
Hermosa Beach number 1 out of 117 cities, that is, Hermosa Beach was determined to have
the least level of economic hardship county‐wide.
Overall, demographic indicators show that Hermosa Beach is not highly vulnerable to poor
health outcomes traditionally associated with poverty, unemployment, and low educational
attainment.
1.3 CURRENT HEALTH CONDITIONS
Information was gathered from various sources to describe the baseline physical health of
community members in Hermosa.
1.3.1 Cancer Data
The University of Southern California Cancer Surveillance Program (USC‐CSP) is the
population‐based cancer registry for Los Angeles County that was begun in 1972. By law,
2010 Census Measures
Hermosa
Beach LA County
Population 19,506 9,818,605
Persons under 18 years, percent 15.9% 23.7%
Persons 65 years and over, percent, 2010 9.0% 11.5%
Female persons, percent 47.3% 50.7%
Race
White alone, percent 86.8% 71.6%
Black or African American alone, percent 1.2% 9.3%
American Indian and Alaska Native alone, percent 0.3% 1.5%
Asian alone, percent 5.7% 14.5%
Native Hawaiian and Other Pacific Islander alone, percent 0.2% 0.4%
Ethnicity
Hispanic or Latino, percent 8.4% 48.2%
High school graduate or higher, percent of persons age 25+, 2007‐2011 98.5% 76.1%
Bachelor's degree or higher, percent of persons age 25+, 2007‐2011 69.9% 29.2%
Homeownership rate, 2007‐2011 44.9% 47.8%
Housing units in multi‐unit structures, percent, 2007‐2011 48.4% 41.9%
Median value of owner‐occupied housing units, 2007‐2011 $1,000,001 $478,300
Median household income, 2007‐2011 $102,289 $56,266
Persons below poverty level, percent, 2007‐2011 3.60% 16.30%
- 4 -
all cancers diagnosed in California since January 1, 1988 are reported to one of the regional
registries that form the California Cancer Registry (CCR), the legally mandated cancer
reporting system of California. The USC‐CSP serves as Region 9 of the CCR, and is also one
of the registries participating in the National Cancer Institute’s Surveillance, Epidemiology,
and End‐Results Program (SEER). The California Department of Public Health, the Centers
for Disease Control and Prevention, and the National Cancer Institute fund cancer
surveillance conducted by USC‐CSP. Data is collected on all new cancer patients diagnosed
in Los Angeles County since 1972 and includes information on age, race/ethnicity, patient’s
address at diagnosis, gender and specific type of cancer. All invasive cancers, excluding
non‐melanoma skin cancers, are reported, along with in situ breast and bladder cancer, and
benign brain tumors. Completeness of the reporting to the registry is estimated at over
95%.
This analysis, included as Attachment 1, is in response to a request to Dr. Cozen at the USC‐
CSP for the baseline risk of certain cancers in the City of Hermosa Beach. Cancer types
examined are those related to petroleum production (leukemia), common cancers, and
cancers identified by community members as being specific concerns. USC‐CSP examined
the expected and observed incidence of these cancers in the area of concern. The
aggregated census tracts examined were: ‐06037621001, ‐06037621002, ‐06037621004, ‐
06037621102, and ‐06037621104.
As seen in Table 2 below, the observed number of cancer cases in the City of Hermosa was
within the expected number, based on age‐, race‐ and sex‐adjusted incidence rates for Los
Angeles County, for all cancers except melanoma and breast cancer (all races only). The
observed number of colorectal cancers was significantly lower in Hermosa than expected.
The statistically significant increase in melanoma and breast cancer diagnoses among
residents of Hermosa Beach compared to Los Angeles County can largely be explained by
known lifestyle risk factors. Higher socioeconomic status is an accepted risk factor for both
of these cancers and it is likely that that Hermosa Beach residents have higher income and
education than Los Angeles County residents as a whole. In fact, in an extensive analysis
across Los Angeles County, when socioeconomic status was accounted for, neighborhood
differences in these cancers either disappeared (breast cancer) or were greatly reduced
(melanoma)1. In addition, sun exposure is the strongest risk factor for melanoma and thus
an excess of diagnoses would be expected in the Southern California beach communities,
assuming these residents spend more time in the sun during daylight hours compared to
residents elsewhere in the county. Otherwise there is no evidence that residents of
Hermosa Beach experience unusually high or low risk of common types of cancer.
- 5 -
Table 2. Expected and observed numbers of cancer cases by type and race in Los
Angeles County and Hermosa Beach, 2000‐2010
Cancer Type Race L.A. County Hermosa Beach Pchisq3
AAIR1 Observed
number of
patients
Observed
number of
patients
Expected
number of
patients2
Hodgkin
Lymphoma
White4
All Races
3.70
2.45
1213
2583
5
6
1‐11
0‐9
0.85
0.40
Non Hodgkin
Lymphoma
White4
All Races
22.27
18.56
9250
17535
27
30
18‐39
16‐38
0.85
0.53
Multiple
Myeloma
White4
All Races
5.35
5.68
2326
5242
9
11
1‐12
2‐14
0.20
0.17
Leukemia: ALL White4
All Races
1.75
1.91
448
2041
<5
<5
0‐5
0‐6
0.64
0.92
Leukemia:
AML
White4
All Races
4.01
3.62
1654
3441
<5
<5
0‐10
0‐10
0.85
0.75
Melanoma White4
All Races
49.13
23.65
19767
22616
114
122
52‐83
24‐49
<0.0001
<0.0001
Breast Cancer White4
All Races
188.03
144.65
39893
75480
117
148
99‐143
90‐120
0.78
0.00036
Prostate
Cancer
White4
All Races
148.27
147.35
29250
60242
84
107
73‐112
80‐120
0.39
0.46
Bladder
Cancer
White4
All Races
24.96
17.80
10990
16117
21
21
17‐39
13‐32
0.19
0.83
Colorectal
Cancer
White4
All Races
53.26
49.46
23193
45821
37
41
47‐79
51‐84
0.0012
0.0016
Brain/nervous
system
White4
All Races
16.74
13.07
6495
12747
23
23
13‐33
11‐33
0.90
0.51
1Average annual age‐adjusted incidence rates per 100,000 population at risk
2Based on Los Angeles County incidence rates and Hermosa Beach population in the years covered
3p‐value for observed /expected comparison using Chi‐square test
4Non‐Hispanic whites only
1.3.2 Mortality Data
The California Department of Public Health provides mortality counts of the most common
causes of death (CDPH 2013a). Mortality data were collected for the most recent two years
of data (2009 ‐2010) for the City of Hermosa Beach and LA County, as a comparison
population. Table 3 below shows mortality counts and crude mortality rates based on
2010 Census populations. Rates are unadjusted for age or race because data were
unavailable to perform adjustment calculations. The all‐cause mortality rate in Hermosa
(40.5 deaths per 10,000 people) appears to be lower than the all‐cause mortality rate in
Los Angeles County (56.9 deaths per 10,000 people). Hermosa mortality rates are also
lower for diseases of the heart (9.2 versus 15.8) and cancer (9.0 versus 13.9). While
Hermosa appears to have a favorable mortality profile, differences in population age
distribution may explain an apparent decreased risk of mortality in Hermosa Beach. For
example, age is significantly associated with both heart diseases and cancers, and the
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County of Los Angeles has a greater proportion of people age 65 years and older (11.5
percent) compared to Hermosa (9 percent).
Table 3. Mortality Profile in Los Angeles County and Hermosa Beach, 2009‐2010
Cause of Death
Hermosa Los Angeles County
No. of
deaths
Mortality
Rate*
No. of
deaths
Mortality
Rate*
All causes 158 40.5 111686 56.9
Diseases of the Heart 36 9.2 31076 15.8
Maligant Neoplasms (Cancer) 35 9.0 27294 13.9
Cerebrovascular Disease (Stroke) 8 2.1 6483 3.3
Chronic Lower Respiratory Disease 9 2.3 5712 2.9
Unintentional Injuries 9 2.3 4210 2.1
Alzheimer's Disease 8 2.1 3917 2.0
Diabetes Mellitus 2 0.5 3811 1.9
Influenza and Pneumonia 8 2.1 3979 2.0
Chronic Liver Disease 3 0.8 2345 1.2
Intentional Self Harm (Suicide) 5 1.3 1504 0.8
Essential Hypertension and Hypertensive Renal Disease 2 0.5 1823 0.9
Nephritis, Nephrotic Syndrome, and Nephrosis 5 1.3 1904 1.0
All other causes 28 7.2 17628 9.0
*per 10,000 people. 2009‐2010 data from CDPH
1.3.3 Hospitalization Data
The Office of Statewide Health Planning and Development (OSHPD) within the California
Health and Human Services Agency provides hospital discharge data records
hospitalizations by disease or injury (based on ICD‐9 codes) by the geographic area
containing the patient's home address (OSHPD 2013). OSHP data for overall
hospitalization rate and hospitalization rates for certain common conditions were available
for the City of Hermosa Beach zip code. Population statistics from the 2010 census were
used in the rate calculation. Table 4 displays Hermosa hospitalization rates next to state‐
wide rates for comparison to expected rates. Rates are unadjusted for age or race because
data were unavailable to perform adjustment calculations. Total hospitalization rate and
hospitalization rates for asthma, diabetes, acute myocardial infarction, and mental illness
were overall much lower in Hermosa compared to California. The rate of patients
categorized as having alcohol‐drug abuse/dependence is elevated in Hermosa compared to
California. While hospitalization data may indicate higher than expected alcohol and drug
use in Hermosa, these results do not allow conclusions to be made about statistical
significance.
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Table 4. Hospitalizations in California and Hermosa Beach, 2010
Hospitalization Rate in 2010 (rate per 100,000 people) Hermosa Beach
State of
California
Total Hospitalization 7,040a 10,660a
Asthma Hospitalization 35.9 94.3
Diabetes Hospitalization 15.4 145.6
Acute Myocardial Infarction/Heart Failure Hospitalization 143.5 367.1
Mental Illness Hospitalization 241 551.7
Alcohol‐Drug Use and Alcohol‐Drug Induced Mental Disease 169.2 109.1
arounded from rates of 70.4 and 106.6 per 1,000 people to estimate rate per 100,000 people
Source: OSHPD from healthycity.org
1.3.4 Birth Outcomes
A birth profile for the Hermosa ZIP code was accessed from the CDPH (CDPH 2013b). The
birth profile includes the number of live births (based on the mother’s residence at the time
of delivery), age of mother, infant birthweight, and trimester during which prenatal care
was initiated. Table 5 provides the profile in Hermosa, compared to a reference group of
the State of California for the most recent year of available data (2011). Access to prenatal
care appears slightly better in Hermosa compared to state‐wide; 88% of women in
Hermosa received prenatal care in the first trimester versus 82% of women in California.
Infants born weighing less than 2,500 grams (about 5.5 pounds) are classified as low birth
weight (LBW). LBW is associated with increased risk of later health problems as well as
infant mortality. In 2011, 7% of Hermosa births and 7% of California births were
considered LBW, representing no difference in the crude rates.
Table 5. Birth Outcomes in California and Hermosa Beach, 2011
Hermosa Beach State of California
No.
% of
births No.
% of
births
Total Births in 2011 203 ‐ 503,856 ‐
Prenatal Care Trimester
First 179 88% 411,692 82%
Second 12 6% 65,152 13%
Third 1 0% 13,537 3%
None ‐ ‐ 2,451 0.5%
Infant Birth weight
(grams)
<1500 6 3% 5,817 1%
1500‐ 2499 8 4% 28,342 6%
≥2500 189 93% 469,677 93%
Age of Mother
<20 ‐ ‐ 38,834 8%
20‐29 20 10% 238,113 47%
30‐34 88 43% 132,886 26%
35+ 95 47% 93,967 19%
Source: CDPH (2013b)
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Compared to women statewide, on average, women in Hermosa give birth at an older age.
In 2011, nearly half of births in Hermosa (47%) were to mothers age 35 and older; while
the majority of births in California were to mothers age 20 to 29 (also 47%). Typically,
public health officials are concerned about the risks associated with young maternal age;
however, advanced maternal age is also associated with several adverse health outcomes.
For example, the risk of having a child with certain developmental conditions, such as
autism or Down’s syndrome increases as women age (Shelton et al. 2010, Newberger
2000).
1.3.5 Injury from Traffic Collisions
In 2008, the City of Hermosa Beach requested that the Institute of Transportation Studies
Technology Transfer Program, the University of California Berkeley, conduct a pedestrian
safety assessment (PSA) (Brown and Mitman 2008). The objectives of the study were to
improve pedestrian safety and walkability in the City. Compared to California cities of
similar size, the California Office of Traffic Safety ranked Hermosa Beach 59 out of 101 for
the rate of pedestrian collisions in 2007 (where higher numeric ranks indicate better safety
records). Figure 2 shows locations of pedestrian‐vehicle collisions over a five year time
period (2003 to 2007) and the number of pedestrians injured or killed in each location
(there was one pedestrian fatality at PCH and 16th Street which is indicated by the red dot).
The map shows there are certain streets where pedestrians are more vulnerable to
collision with a vehicle, including PCH, Pier Avenue, Hermosa Avenue, and Beach Drive.
The California Highway Patrol operates the Statewide Integrated Traffic Records System
(SWITRS) database that collects data gathered from collision scenes in California (CHP
2014). Custom SWITRS queries were run to view collision data for Hermosa from 2009
through 2011 (see Table 6). The annual number of collisions, injuries, and severe injuries
provides important baseline risk of motor vehicle injury due to vehicle‐vehicle, vehicle‐
pedestrian, and vehicle‐bicycle accidents. Over the reported time period, the annual
number of vehicle‐pedestrian collisions ranged from three to ten, the annual number of
vehicle‐bicycle collisions ranged from six to 14, and the annual number of vehicle‐vehicle
collisions ranged from 104 to 125. From 2009 through 2011, the number of vehicle‐
pedestrian collisions appeared to decrease and the number of vehicle‐bicycle collisions
appeared to increase. While vehicle‐vehicle accidents are far more common than vehicle‐
pedestrian and vehicle‐bicycle accidents, pedestrians and bicyclists are more likely to
suffer from injuries and severe injuries as a result of the collision compared to motorists or
vehicle passengers. There were zero fatalities from any type of collision in Hermosa from
2009 through 2011. Locations of the reported collisions are not available from SWITRS.
- 9 - Figure 2: Hermosa Beach Pedestrian Collisions, 2003‐2008 Source: Brown and Mitman (2008)
- 10 -
Table 6. Motor Vehicle Collisions and Injuries by Type of Collision in Hermosa Beach,
2009‐2011
Year
Vehicle Collision w/ Injury Collisions
(% of collisions)
No. of Severe Injuries
Ped. Bicycle Vehicle or
Other
Ped. Bicycle Vehicle
or Other
Ped. Bicycle Vehicle
or Other
2009 10 6 125 10
(100%)
6
(100%)
36
(29%)
1 1 2
2010 5 10 121 5
(100%)
8
(80%)
40
(33%)
0 0 0
2011 3 14 104 3
(100%)
13
(93%)
44
(42%)
0 2 1
Source: Dept of California Highway Patrol (CHP), 2009‐2010
1.3.6 Health Behaviors
Preventable causes of disease are linked with poor diet, physical inactivity, and smoking,
and are responsible for nearly 40 percent of yearly mortality in the Unites States (BCHD
2013). The Beach Cities Health District (BCHD) seeks to promote health and prevent
diseases in the communities of Hermosa Beach, Manhattan Beach and Redondo Beach. In
2013, the BCHD reported on the health needs in community members. According to the
2013 report:
29% of boys and 25% of girls entered local kindergartens overweight or obese
during the 2011‐2012 school‐year.
Sixty percent of beach cities adults are overweight or obese.
Two out of five beach cities adults do not meet federal guideline for physical
activity.
Alcohol and drug use in the past 30 days in BCHD 11th graders was 20% higher the
11th graders across the state as a whole.
17.4% of Hermosa Beach adults are smokers.
The above statistics on health behaviors in the beach cities show community members may
be vulnerable to preventable chronic diseases such as heart disease, cancer, stroke,
diabetes, and arthritis (CDC 2009). However, as discussed in Section 1.5, community
initiatives seek to actively improve health behaviors in Hermosa and the beach cities.
1.4 ENVIRONMENTAL QUALITY
Existing environmental quality measures from regulatory agency monitoring and
reporting, and EIR baseline documents, are summarized in the sections below.
1.4.1 Outdoor Air
Air pollutants, including particulate matter, ozone, nitrogen dioxide, and diesel exhaust can
negatively impact human health. For example, asthma is both caused by and worsened by
exposure to air pollutants (CDPH, 2010). The South Coast Air Quality Management District
(SCAQMD) is the air pollution control agency for all of Orange County and the urban
portions of Los Angeles, Riverside and San Bernardino counties. SCAQMD is responsible
for determining compliance with state and federal ambient air quality standards within its
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geographical jurisdiction, and maintains a network of air monitoring stations to accomplish
that objective. Air monitoring stations provide data for localized areas around the
monitors, though not all individual cities have monitors. Hermosa does not have an air
monitoring station within its city boundaries, and is contained in the Southwest Coastal Los
Angeles County area (Area 3, Station 820), with an air monitoring station in Hawthorne
(see Figure 3).
Table 7 below presents 2011‐2012 SCAQMD data on annual average and maximum
concentrations of air pollutants, and the applicable regulatory standard, for Southwest
Coastal LA County (inclusive of Hermosa Beach) and the reference location of Central LA
(SQAMD 2012). Bold concentrations indicate the area exceeded the state and/or federal
standard for that pollutant. In 2011, all air pollutants in the Southwest Coastal LA County
area were below the regulatory thresholds, except for the annual average of PM10 (21.7
µg/m3) which slightly exceeded the California standard of 20 µg/m3. In 2012, ozone 1‐
hour and ozone 8‐hour maximum concentrations (0.106 and 0.075 ppm, respectively)
exceeded the California standards (0.09 and 0.07 ppm, respectively) in Southwest Coastal
LA County. In general, air quality in Southwest Coastal LA County tended to be similar or
better than air quality in Central LA. Central LA consistently exceeded California standards
for particulate matters in 2011 and 2012.
The Southwest Coastal LA County air monitoring station did not sample for particulate
matter with a diameter of 2.5 micrometers or less (PM2.5). Particles in this size range can
come from many sources including cars and trucks and industrial processes, and can have
adverse health effects on the heart and lungs, including lung irritation, exacerbation of
existing respiratory disease, cardiovascular effects, and premature death due to
cardiovascular effects (heart attacks, stroke, cardiac arrest, and/or congestive heart
failure) (USEPA 2012). California’s Office of Environmental Health Hazard Assessment
(OEHHA) estimated the annual mean of PM2.5 in all California zip codes based on
geostatistical methods (ordinary kriging) and using monitoring data for the years 2007‐
2009. OEHHA estimated Hermosa to have PM 2.5 levels of 13.74 ug/m3. The estimated
value exceeds the California standard of 12 ug/m3 (Cal/EPA and OEHHA 2013).
- 12 - Figure 3: Southwest Coastal Los Angeles County Air Monitoring Area Source: SCAQMD (2012) Southwest Los Angeles County Coastal (Air Monitoring Area #3)
- 13 - Table 7. Air Quality in Southwest Coastal LA County and Central LA, 2011‐2012 Southwest Coastal LA County Central LA Standards 2011 2012 2011 2012 California Federal Carbon Monoxide Max 8‐hour (ppm) 1.8 2.5 2.4 1.9 NA NA Ozone Max 1‐hour (ppm) 0.078 0.106 0.087 0.093 0.09 NA Max 8‐hour (ppm) 0.067 0.075 0.065 0.077 0.07 0.075 Nitrogen Dioxide Max 1‐hour (ppm) 0.097 0.067 0.109 0.077 0.18 0.1 Annual average (ppm) 0.0134 0.0104 0.0231 0.0248 0.03 0.053 Sulfur Dioxide Max 1‐hour (ppm) 0.012 0.0049 0.02 0.0052 0.25 0.075 PM10 Max 24‐hour (µg/m3) 41 31 55 80 50 150 Annual average (µg/m3) 21.7 19.8 29 30.2 20 NA PM2.5 Max 24‐hour (µg/m3) ‐‐ ‐‐ 49.3 58.7 NA 35 Annual average (µg/m3) ‐‐ ‐‐ 13 12.5 12 12 Lead Max. monthly average (µg/m3) 0.008 ‐‐ 0.012 ‐‐ 1.5 NA Sulfate Max 24‐hour (µg/m3) 5.9 ‐‐ 8 ‐‐ 25 NA Bold text indicates exceedance of federal and/or state standard‐‐ pollutant not monitored; N/A : no current standard; ppm= parts per million; µg/m3 = micrograms per cubic meter Source: SCAQMD 2011‐2012
- 14 -
The elevated levels of particulate air pollution in the vicinity of Hermosa Beach (PM 2.5 and
PM 10) are likely related to traffic density in the region. The California Environmental
Health Tracking Program generated data on traffic density by zip code based on the sum of
traffic volumes adjusted by road segment length (vehicle‐kilometers per hour) divided by
total road length (kilometers) within 150 meters of the ZIP code boundary. Figure 4 is a
map of traffic density for zip codes in Los Angeles County, pointing out Hermosa. In
general, the entire Los Angeles area has high traffic density; Hermosa has slightly less
traffic density compared to those areas located adjacent to freeways but has heavily
trafficked roads (Cal/EPA and OEHHA 2013).
To provide current emission source estimates for the local area around the proposed
project site, the Community Air Pollution Information System (CHAPIS) was used to map
emission sources. CHAPIS reports emission inventory statistics for a 4 x 4 kilometer grid
around the project site, which includes the combined contribution of emissions from cars
and trucks, along with industrial sites. While these emission estimates are modeled and
are not the same as actual exposure, they provide a point of reference for ambient
conditions in Hermosa Beach.
Current nitrogen oxide emissions in the project site vicinity are estimated to range
from 0 to 529 tons per year. The only industrial source of nitrogen oxide emissions
within one mile radius is the AES Redondo Beach power plant facility, which
contributes 44% of the total nitrogen oxide emissions. Cars, trucks, boats and other
recreational vehicles account for 51% of nitrogen oxides in the local Hermosa Beach
area (see Appendix E).
PM10 emissions in the local Hermosa Beach area range from 0 to 225 tons per year,
with the majority of these emissions coming from the AES Redondo Beach power
plant facility. The total PM10 emissions in the 4 km2 area around the site is 270 tons
per year (see Appendix E).
Benzene emissions in the local Hermosa Beach area range from 0 to 7150 pounds
per year, and the majority of benzene emissions are attributed to on‐road mobile
sources such as cars and trucks. The total benzene emissions in the 4 km2 area
around the site is 38,700 pounds per year (see Appendix E).
CHAPIS does not report emissions inventory gridded mapping for PM2.5, PAHs or hydrogen
sulfide.
1.4.2 Noise
Elevated noise exposure can have an effect on stress, hypertension, blood pressure, and
heart disease. As described in the draft Environmental Impact Report (EIR), baseline noise
monitoring was conducted during August and September 2013 (MRS 2013). Noise
monitoring captured existing weekday and weekend noise conditions at monitoring
locations around the proposed project site (6th St. and Cypress, 634 Loma St., 730 Cypress
St., 526 8th St., 600 6th St., Veterans Parkway). Table 8 shows the overall average Leq at each
sampling location around the project site, during daytime and nighttime hours on weekday
and weekends. The equivalent sound level, Leq is the average noise level over the period of
time, reported in dBA, or A‐weighted decibel to approximate human sensitivity to sound.
The daytime Leq around the project site ranged from 51.5 to 61.2 dBA and the nighttime Leq
- 15 - Figure 4: Traffic Density in Los Angeles County by Zip Code Source: Cal/EPA and OEHHA (2013), http://www.ehib.org/page.jsp?page_key=980 City of Hermosa
- 16 -
around the project site ranged from 46.5 to 58.5 dBA. Typical noise levels in an urban
outdoor environment are approximately 65 dBA during the day and approximately 45 dBA
during the night (MRS 2013). Daytime Leq levels are within typical noise levels and
nighttime Leq levels are within 16 dBA of typical noise levels. Of the five measurement
locations, the location on 526th 8th Street is the highest for daytime or nighttime.
Table 8. Summary of Existing Noise Levels Around the Project Site (Overall Average
Leq)
Monitoring Location
Overall Average Leq
Monday ‐ Friday
Overall Average Leq
Saturday & Sunday
Daytime
(8am ‐7pm)
Nighttime
(7pm ‐ 8 am)
Daytime
(8am ‐7pm)
Nighttime
(7pm ‐ 8 am)
6th Street & Cypress 61.2 53.0 58.0 52.2
634 Loma Dr. 55.8 48.8 51.5 47.0
730 Cypress St. 58.9 48.5 53.0 48.0
526 8th Street 63.6 58.5 63.3 58.3
600 6th Street 60.6 54.2 57.6 50.8
Veterans Parkway 56.4 47.8 52.1 46.5
All levels reported in dBA
Table adapted from EIR Table 4.11‐5 (MRS 2013)
1.4.3 Surface Water
The City of Hermosa has 2 miles of beach within the larger Santa Monica Bay. The Santa
Monica Bay stretches north to Malibu and south to Palos Verdes Peninsula. The entire
Santa Monica Bay and its beaches were listed as impaired under Section 303(d) of the
Clean Water Act because the surface waters do not meet federal water quality standards.
Impairments in the Santa Monica Bay are due to the human health risks associated with
consumption of aquatic life due to contamination from DDT and PCBs, and the recreational
health risks due to the presence of coliform bacteria (USEPA Region 9 2012).
Impairments associated with DDT and PCBs are related to historic release of DDT and PCBs
on the Palos Verdes shelf between 1937 and the 1980s, consisting of approximately 110
tons of DDT and 10 tons of PCBs. DDT and PCBs are non‐petroleum related compounds
which were previously used at high levels before the US banned DDTs in 1972 and PCBs in
1979. Due to the bioaccumulation of DDT and PCBs in aquatic tissues, the State of
California issued its first interim seafood consumption warnings in 1985. Communities of
lower socioeconomic status generally depend on fish provided by nearby surface waters to
a greater extent than the general population (NEJAC, 2002). Hermosa community
members who regularly consume fish from the Santa Monica Bay may have increased
exposure to DDT and PCBs.
The presence of coliform bacteria in the Santa Monica Bay is an indicator that water quality
may not be sufficient to use waters for human body recreation. To address the problem of
bacteria in the water, the Los Angeles Regional Water Quality Control Board established
the Santa Monica Bay bacteria Total Maximum Daily Load (TMDL) in 2003. The TMDL
- 17 -
requires cities to improve water quality through compliance with targets for bacteria in
surface water. The City of Hermosa Beach’s stormwater pollution prevention program is a
multifaceted program designed to reduce runoff and ensure compliance with the TMDL.
Efforts of the Hermosa stormwater pollution prevention program include infiltration
projects, low flow diversion to sanitary sewer, and a grease control ordinance (SBSP 2013).
1.4.4 EnviroScreen
The California Environmental Protection Agency (Cal/EPA) and the California Office of
Environmental Health Hazard Assessment (OEHHA) released a California Communities
Environmental Health Screening Tool, Version 1.1 in September 2013, known as
CalEnviroScreen (Cal/EPA and OEHHA 2013). CalEnviroScreen is an online mapping
application that can be used to identify California communities that are disproportionately
burdened by multiple sources of pollution. The tool uses existing environmental, health,
demographic and socioeconomic data to create an overall screening score for zip codes
across the state. Various secondary data sources are used by CalEnviroScreen, including
air monitoring data previously discussed in Section 1.3.1.
An area with an overall high score would be expected to experience much higher impacts
than areas with low scores. Figure 5 shows the CalEnviroScreen map for Hermosa and the
surrounding communities. The light color for Hermosa indicates that Hermosa was in the
1st to 10th percentile for lowest EnviroScreen scores, indicating an overall low pollution
burden in Hermosa Beach relative to other communities in California. Even compared to
the adjacent communities of Manhattan and Redondo, Hermosa has the lowest score. The
map clearly depicts that communities to the east of the coastal zone suffer much greater
pollution burden.
- 18 - Figure 5: CalEnviroScreen Results for the City of Hermosa Beach Source: Cal/EPA and OEHHA (2013). http://oehha.ca.gov/ej/ces11.html City of Hermosa
- 19 -
The specific pollution burden measures that went into the overall score for Hermosa are
summarized below:
Annual portion of the daily maximum 8‐hour ozone concentration over the federal
standard of 0.075 ppm: 0% (0 percentile)
Annual mean concentration of PM2.5: 13.74 (81st percentile)
Diesel particulate matter estimated emissions from on‐ and off‐road sources for a
July 2010 weekday: 3.73 kg/day (40th percentile)
Total pounds of pesticide ingredients used in production agriculture per square
mile: 0 lbs (0 percentile)
Total toxicity‐weighted pounds of chemicals released on‐site to air or water from
facilities in or near the ZIP code: 0 lbs (0 percentile)
Sum of traffic volumes adjusted by road segment length divided by total road length
within 150 meters of the ZIP code boundary: 872.3 (58th percentile)
Number of cleanup sites (due to the presence of hazardous substances) in the ZIP
code: 0 (0 percentile)
Weighted sum of sites posing a risk to groundwater in the ZIP code (underground
storage tanks, industrial sites, dry cleaners, etc.): 5 (7th percentile)
Weighted sum of permitted hazardous waste facilities and hazardous waste
generators in the ZIP Code: 0.8 (38th percentile)
Number of pollutants across all water bodies designated as impaired in the ZIP
code: 6 (64th percentile)
Weighted sum of solid waste sites and facilities: 0 (0 percentile)
1.5 ACCESS TO HEALTH SUPPORTING RESOURCES
Health supporting resources such as health care services and the availability of nutritious
foods are important indicators for various health conditions in communities. Spatial
depictions of resources in an area may suggest causal hypotheses about health outcomes.
For example, the absence of supermarkets (i.e., fresh foods) in an area may indicate that
people have to rely on fast‐food chains and convenience stores selling only high calorie
processed junk foods, putting populations at greater risk for diet‐related health problems
(CDPH 2013a). The Network for Healthy California, a mapping application that allows
users to query and view health supporting resources spatially across California, provides
some of this information for Hermosa Beach (CDPH 2013c).
Figure 6 shows the locations of licensed healthcare facilities near the area surrounding
Hermosa. Facility types include hospitals, clinics, home health agencies, and long term care
facilities (facility address information is maintained and provided by the Office of
Statewide Health Planning and Development). The map depicts a one‐mile buffer around
the City center, and shows that there are no licensed healthcare facilities within the City of
Hermosa or with the areas of the one‐mile buffer zone. However, if that zone is expanded
to 5‐miles, there are many facilities, mostly located in the City of Torrance (9 primary care
clinics, 13 home health agencies, 4 hospitals, and 5 long‐term care facilities). For those
community members who do not own a vehicle, it may be challenging to access health care
since there are no facilities directly within Hermosa.
- 20 - Figure 6: Licensed Healthcare Facilities near Hermosa Beach Source: http://gis.cdph.ca.gov/cnn2.0/cnn.html?mapid=5908695
- 21 -
Figure 7 shows the locations of grocery stores and farmers markets in the City. There are
two large chain groceries, ten other groceries, and one farmer’s market within the zip code
of 90254. Therefore, there does not appear to be a barrier to access fresh foods in Hermosa
Beach.
Figure 7: Groceries and Farmers Markets in Hermosa Beach
Source: http://gis.cdph.ca.gov/cnn2.0/cnn.html?mapid=7032543
- 22 -
1.6 COMMUNITY HEALTH PROMOTION
The City of Hermosa Beach and its community members are exceptionally committed to an
outdoor lifestyle and making their environment a healthy place to live. In 2010, the Beach
Cities Health District joined the Blue Zones ProjectTM initiative to create a beach cities
community that is healthier and more walkable, bikeable, and socially engaged. Blue Zones
uses the Gallup‐Healthways Well Being Index™ to benchmark the well‐being of the beach
cities and measure progress (Blue Zones 2010).
The baseline survey of 1,332 Beach Cities residents was conducted in 2010. Among its
major findings was that the overall well‐being rating for residents of Hermosa, Manhattan
and Redondo was higher than the California average and above the top tier of other
cities. More than 90 percent of local residents said they had access to health care, health
insurance and enough money for food, shelter and other basic needs. Two‐thirds were
found to be “thriving.” However, the survey also found that 46 percent of the Beach Cities
residents felt stressed for most of the day, a number that ranked them 176th out of 188
communities surveyed. When asked if they had significant worries, 37 percent said they
did, which ranked the Beach Cities 177th out of those 188 communities surveyed (Blue
Zones 2010).
In February 2013, the City of Hermosa Beach became the first community in the country to
achieve Blue Zones Community Policy designation – for adopting policies to improve its
residents’ well‐being. Those policies included a “Living Streets Policy” focused on making
the community more liveable, walkable, and bikeable (e.g., Pier Ave); and an action to
create a community garden. Since the 2010 program launch in the Beach Cities Health
District, more than 15,000 people and 75 businesses and restaurants in Hermosa,
Manhattan and Redondo Beaches have adopted healthier practices, and the cities have
adopted policies that promote walkable and bikeable streets. After the first two years
(2010‐2012) of commitment to the Blue Zones initiative, Gallup‐Healthways Well‐Being
Index found that across the Beach Cities Health District:
Obesity dropped 14 percent with an estimated 1,645 fewer obese adults. Lost
pounds translate to $2.35 million in healthcare‐related savings for Beach Cities
businesses and residents over two years.
Smoking rates declined more than 30 percent or 3,484 fewer smokers. This
decrease equates to $6.97 million in healthcare‐related savings between 2010 and
2012.
Exercise rates increased by more than 10 percent as more people reported
exercising at least 30 minutes three times per week.
Healthy eating habits improved 9 percent with more people reporting eating five‐
plus servings of fruits and vegetables four or more days in the past week.
Stress indicators remained largely unchanged.
In 2012, the City of Hermosa Beach launched the Healthy Air Hermosa public education
campaign to ensure residents and visitors can enjoy a smoke‐free environment in public
outdoor gathering spots such as the Pier, the Strand, the Greenbelt, Pier Plaza, City owned
- 23 -
parking lots, and all parks. Smoking was previously banned on the beach in city buildings
and inside restaurants (City of Hermosa Beach 2012).
1.7 LIMITATIONS
Some limitations of this baseline health assessment are as follows:
The small population in Hermosa Beach made it difficult to find data specific to the
City. For example, while information hospitalizations due to asthma were
presented, asthma rates for Hermosa Beach were not available. Prevalence of
asthma in Hermosa Beach, particularly in children, could be affected by increases in
air pollution due to the proposed project. The lack of more specific asthma
information is a significant data gap in this assessment.
Where prevalence and mortality data was available for Hermosa Beach, it was not
presented according to categories of race, age, gender, etc. Therefore, rates could
not be adjusted for appropriate comparison to either LA County or the State of
California.
In addition, small numbers did not allow making statistical comparisons to other
geographic locations.
The pedestrian safety assessment was conducted over five years ago and many
improvements have taken place since then, including the Pier Avenue streetscape
improvements. However, other streets have not undergone similar pedestrian
improvements since then.
Ambient air pollution data were available for the Southwest Coastal region, which
includes Hermosa Beach but also includes the Los Angeles international airport and
other facilities (i.e., the El Segundo refinery) considered sources of air pollution.
Therefore, the aggregate data may not be representative of the local Hermosa
community.
1.8 CONCLUSIONS
The objectives of the baseline health assessment were to establish the current health status
of Hermosa Beach community members, and to evaluate whether the current profile of the
community reveals vulnerabilities to any of a number of health outcomes. The major
findings of this baseline health assessment include:
According to the census data for Hermosa Beach, approximately 25 percent of the
population may be considered to be more vulnerable to certain environmental
exposures, based on age (9% over the age of 65 and 16% under 18 years).
Overall, demographic indicators show that Hermosa Beach is not highly vulnerable
to poor health outcomes traditionally associated with poverty, unemployment, and
low educational attainment.
The observed number of cancer cases in the City of Hermosa was within the
expected number, based on age‐, race‐ and sex‐adjusted incidence rates for Los
Angeles County, for all cancers except melanoma and breast cancer. The statistically
significant increase in melanoma and breast cancer diagnoses among residents of
Hermosa Beach compared to Los Angeles County can largely be explained by known
lifestyle risk factors.
- 24 -
Hermosa Beach appears to have a favorable mortality profile, according to all‐cause
mortality, diseases of the heart, and cancer, compared to LA County.
Hospitalization rates for asthma, diabetes, acute myocardial infarction, and mental
illness were overall much lower in Hermosa Beach compared to California.
Hospitalization data may indicate higher than expected alcohol and drug use in
Hermosa.
In 2011, nearly half of births in Hermosa Beach (47%) were to mothers age 35 and
older; indicating a potential vulnerability to certain developmental conditions, such
as autism or Down’s syndrome.
Pedestrians may be vulnerable to injury or mortality along the PCH, Hermosa
Avenue, and Beach Drive.
Beach Cities Health District statistics on obesity, physical activity, and alcohol, drug
and tobacco use show community members are vulnerable to preventable causes of
chronic illness.
Elevated levels of particulate air pollution in the vicinity of Hermosa Beach (PM 2.5
and PM 10) put community members at increased risk for respiratory and
cardiovascular effects. Traffic density is likely a significant contributor to
particulate air pollution.
Daytime Lmax levels are within 10 dBA and nighttime Lmax levels are within 23 dBA of
typical noise levels. The location on 526th 8th Street is the highest for daytime or
nighttime.
Hermosa Beach, located on the Santa Monica Bay, has impaired surface waters due
to contamination from DDT and PCBs, and the presence of coliform bacteria.
Compared to other California communities, Hermosa Beach has a low pollution
burden from cumulative environmental sources such as ambient air, pesticide use,
chemical releases, traffic, hazardous substances cleanup sites, risk to groundwater,
permitted hazardous waste facilities, surface water pollutants, and solid waste sites.
For those community members who do not own a vehicle, it may be challenging to
access health care since there are no facilities directly within Hermosa Beach.
Nearly half of Beach City Health District residents report being stressed.
Hermosa’s commitment to an outdoor healthy lifestyle is exemplified through
progress on the Blue Zones Project initiative and smoke‐free public areas.
Future analysis can utilize data presented in this report to evaluate any changes or
trends.
- 25 -
1.9 REFERENCES
Beach Cities Health District. 2013. Beach Cities Community Health Update. Retrieved from:
http://www.bchd.org/
Blue Zones. 2010. Blue Zones Project in the Beach Cities of California. Retrieved from:
http://www.bluezones.com/programs/blue‐zones‐communities/blue‐zones‐project‐in‐
the‐beach‐cities‐of‐california/
Brown, S. J. and Mitman, M.F. November 2008. Hermosa Beach Pedestrian Safety
Assessment: Issues, Opportunities, and Recommended Strategies. Retrieved from:
http://www.hermosabch.org/modules/showdocument.aspx?documentid=714
California Department of Public Health (CDPH). 2010. Guide for Health Impact Assessment.
Retrieved from:
http://www.cdph.ca.gov/pubsforms/Guidelines/Documents/HIA%20Guide%20FINAL%2
010‐19‐10.pdf
California Department of Public Health (CDPH). 2013a. Death Profiles by Zip Code.
Retrieved from:
http://www.cdph.ca.gov/data/statistics/Pages/DeathProfilesbyZIPCode.aspx
California Department of Public Health (CDPH). 2013b. Birth Outcomes by Zip Code.
Retrieved from:
http://www.cdph.ca.gov/data/statistics/Pages/BirthProfilesbyZIPCode.aspx
California Department of Public Health (CDPH). 2013c. Network for a Healthy California
GIS Map Viewer. Retrieved from: http://gis.cdph.ca.gov/cnn/
California Environmental Protection Agency and the Office of Environmental Health Hazard
Assessment (Cal/EPA and OEHHA). 2013. California Communities Environmental Health
Screening Tool: CalEnviroScreen 1.1. Retrieved from: http://oehha.ca.gov/ej/ces11.html
California Highway Patrol (CHP). 2014. Statewide Integrated Traffic Records System.
Retrieved from: http://iswitrs.chp.ca.gov/Reports/jsp/userLogin.jsp
Centers for Disease Control and Prevention. 2009. Chronic Diseases the Power to Prevent,
The Call to Control: At A Glance 2009. Retrieved from:
http://www.cdc.gov/chronicdisease/resources/publications/aag/chronic.htm
City of Hermosa Beach . 2012. Hermosa Beach Launches Healthy Air Hermosa Education
Program for New Smoke‐free Ordinance. Retrieved from:
http://www.hermosabch.org/modules/showdocument.aspx?documentid=1418
- 26 -
County of Los Angeles Public Health (LACDPH). 2013. How Social and Economic Factors
Affect Health. Retrieved from:
http://publichealth.lacounty.gov/epi/docs/SocialD_Final_Web.pdf
MRS Consultants, LLC. (MRS). 2013. Draft Environmental Impact Report.
Newberger, D.S. 2000. Down Syndrome: Prenatal Risk Assessment and Diagnosis. Am Fam
Physician, 62(4):825‐832.
Office of Statewide Health Planning and Development (OSHPD). 2013. Statistics generated
on HealthyCity.org, 10/28/2013.
Shelton, J. F., Tancredi, D. J. and Hertz‐Picciotto, I. 2010. Independent and dependent
contributions of advanced maternal and paternal ages to autism risk. Autism Res, 3: 30–39.
doi: 10.1002/aur.116
South Bay Stormwater Program. 2013. City of Hermosa Beach Stormwater Program
Highlights. Retrieved from: http://southbaystormwaterprogram.com/member‐agencies‐
2/hermosa‐beach/
South Coast Air Quality Management District (SCAQMD). 2012. Historical Data by Year.
Retrieved from: http://www.aqmd.gov/smog/historicaldata.htm
U.S. Environmental Protection Agency Region 9 (USEPA Region 9). 2012. Santa Monica Bay
Total Maximum Daily Loads for DDTs and PCBs. Retrieved from:
http://www.waterboards.ca.gov/losangeles/water_issues/programs/tmdl/Established/Sa
ntaMonica/FinalSantaMonicaBayDDTPCBsTMDL.pdf
U.S. Environmental Protection Agency (USEPA). 2012. Particle Pollution and Health.
Retrieved from: http://www.epa.gov/pm/2012/decfshealth.pdf
U.S. Census Bureau: State and County QuickFacts (US Census). Data derived from
Population Estimates, American Community Survey, Census of Population and Housing,
County Business Patterns, Economic Census, Survey of Business Owners, Building Permits,
Census of Governments. Last Revised: June. 2013. Retrieved from:
http://quickfacts.census.gov/qfd/states/06/0633364.html
- 27 -
ATTACHMENT 1
USC Baseline Cancer Assessment
- 28 -
- 29 -
Appendix F
Quality of Life Committee Presentation
1.4 square miles of
“The Best Little Beach City”
Quality of Life in Hermosa Beach
Community Dialogue Committee
December 3, 2013
Commi%ee
Members:
Mike
Collins
Julian
Katz
Julie
Hamill
Koch
Louisa
Cushman
Andrea
Valcourt
The
Commi%ee’s
Challenge
Answer
the
following
ques:ons
• Why
did
you
move
to
Hermosa
Beach
and
what
keeps
you
here?
• What
are
the
community’s
(the
people’s)
strengths
and
weaknesses?
• What
are
the
city’s
(the
government’s)
strengths
and
weaknesses?
• What
are
the
city’s
(the
environment’s)
strengths
and
weaknesses?
• What
would
make
you
leave?
• How
are
these
things
linked
together?
• What
do
you
hope
Hermosa
Beach
will
be
like
in
20
years?
Physically,
Hermosa
Beach
lives
up
to
its
slogan…”the
best
li%le
beach
city.”
• The
beach
is
broad
and
clean
• The
ocean
water
is
clean
(A
+
from
Heal
the
Bay)
• The
air
is
fresh
and
clean
• When
the
fog
rolls
in
you
can
hear
the
fog
horn
• The
city
is
only
1.4
miles
square
• But,
there
is
more
to
living
here…
Hermosa
is
a
clean
city
• Beach
maintenance
is
done
regularly.
• Our
streets
are
clean,
our
downtown
sidewalks
create
an
interes:ng
dialogue.
• Storm
water
basins
help
keep
contaminates
and
debris
out
of
the
ocean.
• Businesses
are
regulated
to
properly
dispose
of
oil
and
other
contaminates.
Reputa:on
for
being
a
small-‐town,
friendly
beach
community
• Surfing,
swimming,
walking,
and
volleyball
bring
like-‐minded
people
together
• Rollerblading,
biking,
jogging,
and
walking
keep
folks
talking
• Pier
Avenue,
with
its
sidewalk
dining,
promotes
camaraderie
• Art
shows
and
music
fes:vals
draw
the
people
out
of
their
homes
• Movies
in
the
Park
bring
families
together
Reputa:on
for
being
a
party
town
• Bars
a%ract
a
party
crowd
• Early
20’s
crowd
rent
in
the
south
end,
sharing
houses
or
apartments
• Late
night
patrons
are
disrup:ve
and
destruc:ve
Hermosa
is
health
conscious
• People
walk,
jog
and
bike
for
exercise,
and
to
get
from
place
to
place
• The
city
joined
the
Beach
CiNes
Health
District’s
Blue
Zone
Project
• Hermosa
was
the
first
South
Bay
city
to
be
cerNfied
as
a
Blue
Zone
city
• The
city
enhanced
the
Green
Belt
with
workout
staNons.
• The
city
maintains
several
large
and
small
parks
• CiNzens
shop
at
the
Farmers
Market
• Children
and
adults
get
exercise
playing
all
sports
Accessible
city
government
• Council
meeNngs
are
open
to
the
public
and
available
on
TV
• City
council
members
provide
office
hours
• The
council
provides
opportuniNes
for
public
input
on
major
issues
• Teenagers
asked
for
and
received
a
skate
park
• People
wanted
a
community
garden
and
that
is
in
process
• The
city
has
a
bike
plan
but
has
not
added
a
bikeway
in
four
years
Hermosa
is
a
safe
city
• Police
respond
quickly
to
calls
• The
crime
rate
is
one
of
the
lowest
• Businesses
put
products
and
produce
on
the
sidewalks,
without
supervision
• People
walk
safely
about
the
city
Hermosa
is
a
green
city
• A
major
city
goal
is
for
a
carbon
neutral
footprint
• The
city
received
awards
for
green
acNviNes
• Council
provided
storm
drain
filtraNon
systems
• Smoking
is
banned
citywide,
including
the
beach,
but
it
is
not
enforced
• Styrofoam
food
containers
are
banned
• Our
Lady
of
Guadalupe
church
uses
solar
panels
for
its
energy
source
Hermosa
schools
are
some
of
the
best
• The
schools
test
in
the
top
10
percenNle
• Parents
and
teachers
collaborate
and
support
the
students
• The
community
parNcipates
in
major
fundraisers
to
offset
state
shor[alls
Hermosa
is
a
small,
scenic
town
• Zoning
keeps
building
heights
at
30
feet
• The
town
has
kept
historic
buildings
• MansionazaNon
has
not
become
a
priority
• There
are
original
clapboard
beach
co]ages
and
newer
“beach-‐type”
homes
• The
city
conNnues
to
maintain
streets
and
infrastructure
Hermosa
has
involved
ci:zens
• People
par:cipate
at
council
mee:ngs
and
commi%ees
• Ci:zens
join
Leadership
Hermosa
and
make
a
difference
• Folks
volunteer
at
schools
and
philanthropic
organiza:ons
• Ci:zens
and
the
council
collaborate
on
the
latest
technology
and
products
• Local
business
owners
are
working
with
the
city
to
a%ract
new
businesses
Hermosa
wants
to
maintain
its
unique
character
• Maintain
or
enhance
current
building
limits
• Limit
large
developments
and/or
“big
box”
stores
• Recruit
small,
green
businesses
• Work
with
the
school
district
to
maintain
and
improve
schools
• The
Council,
police,
and
business
are
partnering
to
reduce
late
Plaza
acNviNes
• Increase
children’s
beach
play
areas
by
adding
swings
and
slides
• Encourage
arNst
development
such
as
an
art
district
Hermosa
wants
to
maintain
unique
character
without
added
cost
• ConNnue
having
a
balanced
budget.
No
debt.
• InvesNgate
whether
regionalizing
services
would
be
beneficial
• Encourage
volunteerism
for
projects,
adopt-‐a
grandparent
for
schools
• Enlist
colleges/universiNes
to
invest
in
technology
projects
here
• Seek
out
movie/TV
filming
projects
• ConNnue
to
apply
for
grants
• CiNzens
and/or
businesses
donate
roof
tops
for
solar
to
benefit
the
city
and
schools
• Rent
out
city
faciliNes
to
private
and/or
philanthropic
events
• Implement
a
strategy
to
a]ract
businesses
that
ciNzens
want
Hermosa
Beach
20
years
from
now
• The
city
a]racts
families
and
small
businesses
to
its
safe
streets.
• Hermosa
is
profitable,
with
small
businesses
as
its
base.
• The
city
has
maintained
its
small
town
feel
and
kept
large
structures
at
a
minimum.
• Hermosa
Beach’s
PCH
and
AviaNon
corridors
are
thriving.
• Pier
Plaza
is
a
more
family-‐friendly
place,
with
limited
rowdy
night
life.
• Hermosa
Beach
is
a
model
green
beach
city.
• Hermosa
is
a
consultant
to
other
ciNes,
which
want
posiNve
change.
1
September 3, 3014
Honorable Mayor and Members of the Regular Meeting of
Hermosa Beach City Council September 8, 2014
STATUS REPORT ON E&B’S PROPOSED OIL DRILLING AND PRODUCTION
PROJECT; PRESENTATION ON REVISED HEALTH IMPACT ASSESSMENT;
POSSIBLE DIRECTION TO SUBCOMMITTEE REGARDING NEGOTIATION
OF THE DEVELOPMENT AGREEMENT; AMEND THE CONTRACT WITH
STOEL RIVES BY AUTHORIZING AN ADDITIONAL $50,000 FOR
CONSULTATION SERVICES; PROVIDE DIRECTION ON THE OIL BALLOT
MEASURE LANGUAGE AND PRELIMINARY DISCUSSION REGARDING THE
OPTION OF AN ADDITIONAL BALLOT MEASURE TO RAISE TAXES
SHOULD THE OIL BALLOT MEASURE FAIL; PROVIDE DIRECTION TO
STAFF REGARDING UPCOMING MEETINGS WITH OUTSIDE AGENCIES
AND E&B; AND/OR PROVIDE DIRECTION ON OTHER MATTERS
CONCERNING THE PROJECT
Recommended Action:
Authorize the City Manager to execute a contract amendment with Stoel Rives in the amount of $50,000
for Oil Drilling and Production Project consultation services.
The Council may also desire to give its subcommittee direction pertaining to negotiation points of the
Development Agreement, and/or the Council may desire to provide direction on the Ballot Measure or
other issues addressed in this report.
Background/Analysis:
Election Issues:
The election will be March 3, 2015. It is anticipated that the Council will hold a public hearing
to consider the language of the ballot measure and Development Agreement on October 14.
Council will hold a meeting on September 30th devoted to oil issues. (No oil update will be
provided on September 23rd unless otherwise directed by the Council.)
Final Health Impact Assessment (HIA)
The final HIA is being provided for Council review on September 8th. The document is online
at www.hermosabch.org, and available at the Community Development Department and
Hermosa Beach Library. Comments received from the public on the draft HIA are also provided
online and responses to comments are provided in the final HIA. On July 22nd, Council
authorized the recommendations in the HIA to be proposed for incorporation into the
Development Agreement. At the September 30th Council meeting, staff will recommend that
Council receive and file the Final HIA.
5
Coastal Commission staff and E&B on September 15. The purpose of the meeting is to assess
the acceptability of the Coastal Land Use Plan amendment to Coastal staff as well as
responsibilities for submittal of applications to the Coastal Commission should the ballot
measure pass. If Council is concerned about the meetings, it should provide clear direction to
staff.
Political Campaign Advertising: In June 2014 a question arose regarding political campaign
advertising and Council agreed that when factual questions came up about oil campaign
advertisements (either side) the City Manager would inquire about the facts in writing. It was
further agreed by a majority of City Council that the City should not be in the position of
“referee: but rather, the City’s role is to process the project application and provide accurate and
impartial information to the community and to seek clarification when necessary.
In the interest of keeping Council informed, the City Manager made a written inquiry to E&B
regarding their ad in the Easy Reader which stated that “no permanent oil production structures
will be visible above the wall.” Staff agreed that the EIR treated these structures as temporary,
but recognized that these structures would be in place for a lengthy period of time and have
impacts as identified in the EIR. E&B responded that although construction will take some time,
given the life of the project, E&B believes they are factual in the definition and use of the term.
Consistent with the direction about not being a ‘referee’ no further action is planned on the part
of the City.
Community Involvement
The Final EIR was certified on July 8th. The Final EIR and final changes adopted by the Council
are available from the Community Development Department and online at
www.hermosabch.org.
Staff and the consultants continue to be available to answer questions and meet with individuals
and groups. Contact Community Development at (310)318-0242.
People are encouraged to sign up to receive information, on the City’s website at
www.hermosabch.org, click on E-Notification Sign-Up.
Complete information is also available on the City’s website at http://www.hermosabch.org/,
click on Proposed Oil Drilling and Production Project under “Spotlight.”
The City continues to work with Katie Casey in regards to the communication plan.
Next Steps
The Council will hold a public hearing on the language for the ballot measure and development
agreement on October 14. The proposed resolution to place the matter on the ballot, Ballot
Ordinance, and Development Agreement are attached for your review.
The final HIA and CBA will be scheduled for Council action anticipated on September 30, 2014.
After the ballot measure is submitted in October, the City’s obligations under the Settlement
Agreement for processing the project application and environmental document and submitting
the matter to the voters will essentially be met. Through this process, the City has endeavored to