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HomeMy WebLinkAboutPACIFIC CITY PROJECT (2 OF 6) Additional Public Hearing Comm 6 2-, J `7 Pacific City Action Coalition 16787 Beach Blvd.,4316 Huntington Beach, Ca 92647 December 3,2003 Ms.Mary Beth Broeren City of Huntington Beach Planning Department 2000 Main St. Huntington Beach, CA 92648 Re: Pacific City Environmental Impact Report No. 02-01 Response Dear Ms.Broeren: Enclosed is the Pacific City Action Coalition's response to the Pacific City Draft Environmental Impact Report.Included in the response are consultant comments from the Urban Planning and Consulting Group and Dr.Matthew Macleod,which are included in the body of the response and Attachment A.Additional comments from Coalition members are contained in Attachments B and C. If you have any questions,please.ca4l..(714)430-8596.Thank you,for the opportunity to comment : . .on this matter.. :. This letter is being sent via fax,email and hand delivery this date.. Sinc ely, p P cific City Action Coalition s oC= c ` Q�CD - c-) w s w D r� 8 Via De La Mesa Rancho Santa Margarita, CA 92688 (949) 233-1814 (949) 459-1620 November 26, 2003 Pacific City Action Coalition 16787 Beach Blvd., #316 Huntington Beach, CA 92647 RE: Response to the Pacific City Draft Environmental Impact Report No. 02-01 We have reviewed the Draft Environmental Impact Report for the Pacific City project and present the following comments and observations. Proiect Description The project is a mixed-use visitor-serving commercial center together with a residential village located on a 31.5-acre vacant parcel in the City downtown on the inland side of Pacific Coast Highway. Major project components include: Visitor-servina Commercial Center This component would occupy approximately 10.6 acres of the site adjacent to PCH_ and provide hospitality and commercial facilities. Upscale-oriented hospitality facilities (hotels) would include up to 400 guest rooms and associated amenities, and up to 240,000 square feet of commercial uses that could include retail, office, restaurant, cultural and entertainment facilities. Approximately 2 to 8 story buildings are proposed on this site, consisting of 8-story hotel and 2 to 3 stories of retail and office uses. Residential Village The residential component would occupy the approximately 17.2-acre northeastem portion of the project site. A total of 516 condominiums would be developed at an average of 30 dwelling units per acre. Development would include 2- to 4-story structures with a variety of architecture, dwelling unit types and sizes, clustered around recreational amenities to serve the residents of the village. Parking would be provided in a subterranean garage and In surface parking areas along the interior collector street. Vehicular and Pedestrian Circulation Improvements Vehicular and pedestrian access to the project site would be provided by a combination of existing and proposed roadways. Pacific View Drive would be extended through the site in a 90-foot right of way. On Huntington Street, between Pacific View Drive and Pacific Coast Highway, additional right of way would be dedicated west of the centerline to allow for the full secondary arterial right of way with sidewalks and curb and gutter improvements. On Atlanta Avenue, between I't Street and Huntington Street, additional right of way would be dedicated south of the centerline to allow for arterial improvements. EIR for Pacific City Project EIR No.02-01 sCH No. 2003011024 November 26, 2003, Page 2 Settina Project Area is bounded by 1" Street on the west, Huntington Street on the east, Atlanta Avenue on the north, and Pacific Coast Highway to the south. The project site is also located within the California Coastal Zone and the Main-Pier Redevelopment Project Area. The project would be .constructed in major phases over a two- to ten- year period, beginning in 2004. The project site is currently vacant, although construction activities and various land uses on the project site have occurred since the late 1800s. Southern California Edison currently maintains aerial transmission lines along the 1" Street property boundary and regional 66KV transmission facilities along the Atlanta Avenue site boundary. On-site oil facilities have been abandoned and soil remediation is underway, with completion expected in 2003. A portion of the southwesterly corner of the site was recently used as a staging/storage facility for beach cleaning equipment for the City of Huntington Beach. The site is no longer used for this purpose, although a storage bin remains on the property. As of 1999, a portion of the site was listed as an archeological resource (ORO-149). Portions of the site may contain paleontological resources. Remediation In 1996, prior to the acquisition of the site by Atlanta Huntington Beach, LLC, Shea Vickers development, LLC, the prior owner, initiated an extensive site investigation and subsequent oil remediation program. Remediation of the site was performed pursuant to a Remediation Work Plan approved by the Huntington Beach Fire Department and included excavation and stockpiling of oily soil and the abandonment of several oil wells. In March 1998, an application was filed by Shea Vickers Development, LLC for a Coastal Development Permit to allow remedial grading of the property to remove oily soils and to import approximately 23,630 cubic yards of soil. This request was tabled and was not acted upon by the Zoning Administrator. CEOA In January 2003, the City of Huntington Beach issued a Notice to Prepare an Environmental Impact Report. Citing CEQA Section 15183(a), an EIR has been prepared for the project. The EIR addresses impacts related to aesthetics, air quality, biological resources, cultural resources, energy and mineral resources, hazards and hazardous materials, hydrology and water quality, land use and planning, noise, population and housing, public services and utilities, recreation, transportation and traffic, and utilities and service systems. Proiect Obiectives Several objectives were identified for the project; they include: 1. Assist in the implementation of the Citys General Plan, downtown specific plan, and redevelopment plan. EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 3 2. Enhance the downtown area as a destination for visitors by expanding hotel, retail, and entertainment opportunities. 3. Expand residential opportunities in the downtown to provide for a greater number and variety of housing options and a stronger base for the commercial sector of the downtown. 4. Enhance the community image of Huntington Beach through design and construction of high quality development consistent with the urban design element of the General Plan. S. Ensure adequate utility infrastructure and public services for new development. 6. Mitigate environmental impacts to the greatest extent possible. Analysis The following project related impacts were considered significant and unavoidable in the EIR: 1. Air Quality 2. Transportation — under the Year 2008 conditions, project would significantly affect the operating conditions of the intersection of PCH &Warner Avenue and PCH at Seapoint by increasing traffic volumes. Proiect Altematives Three project alternatives were considered; they are: 1. No Project Altemative/No Development 2. Reasonably Foreseeable Development 3. Reduced Project Alternative, which would reduce the commercial component of the proposed project and is considered by the EIR as environmentally superior alternative to the project. Project Impacts The analysis provided in the EIR for the following topics are considered weak: Air Qualily. This section omits an important threshold of significance required by CEQA, which is the creation of objectionable odors affecting a substantial number of people. If this threshold of significance were analyzed, the impacts could be considerable significant and would change the complexity of the conclusions derived from the project. This section also fails to analyze the environmental impacts of paint and other solvents that may be used during post construction of the site. Most air quality analyses have standard conditions dealing EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 4 with this issue, including type of paint to be used on buildings and the quantity that can be painted on a daily basis. Most importantly, the proposed mitigation measures are weak and inadequate for a project of this magnitude. A more thorough air quality analysis needs to be prepared, including the environmental effects of this project's pre-, during-, and posttronsbuction impacts on surrounding land uses (the mobile home park) and other sensitive receptors. For additional comments,see Attachment A Cultural Resources Because of the paleontological discoveries on the site, and potential for archaeological discoveries) the site contains a Califomla prehistoric archaeological site CA-ORA-149), adequate mitigation measures need to be in place to prevent annihilation of any precious paleontological or archaeological artifacts. These mitigation measures should include standard, acceptable measures widely used in the industry. Energy and Mineral Resources The project site is located within the Huntington Beach Oil Field and is designated as District No. 8A by the Downtown Specific Plan. The site is also identified as an oil overly "C" district to allow for existing and/or expanded oil production on the property. A Phase II environmental analysis and aerial maps of the site identified 10 aboveground storage tank, pipelines, 20 abandoned oil wells, and abandoned water well. The proposed project would result in the development of residential uses on a portion of the site underlain by mineral resources. However, the only mitigation measure proposed under this section pertains to an energy conservation plan. No mitigation measures are proposed for handling the oil and water walls identified on the site. At a minimum, this EIR should Identify a contingency plan for dealing with the potential discovery of oil wells and water wells. Geology and Sails. Groundwater was encountered at depths ranging from 5 to 24 feet below ground surface on this site. The site is also located within a methane overly district in the City's General Plan. A soils testing plan is therefore required as part of project implementation. There is a high potential for ocean-related corrosion to building materials due to the site's proximity to the Pacific Ocean (500 feet). Additionally, project implementation would locate structures on soils that are considered potentially expansive, unstable, prone to settlement, and corrosive. 15-20 feet of loose-to-medium dense alluvial deposits found in the southeastern portion of the site where the hotel and portions of the commercial development are proposed, are settlement prone. EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 5 However, only one mitigation measure was proposed. This mitigation measure requires the grading plan to include recommendations of a proposed soils and geotechnical analysis. This is not acceptable. The results of the soils and geotechnical analysis should be the driving factor in the location of buildings on the site. Mitigation measures need to be identified to deal with the issues related to expansive, unstable and corrosive soils. These measures need to be identified in the EIR and not in a separate document to be prepared in the future. For additional comments, see Attachment A Hazardous Matedals. The project site was identified in the State of California Hazardous Materials Database. There is a potential for residual oil contamination in the soil and possible methane emissions. There are also unclosed oil wells and a site investigation has revealed the presence of oil-impacbed soils with total recoverable petroleum hydrocarbon levels above allowable limits. There also is the presence of lead-impacted soil and methane gas accumulation on the site. The MM HAZ-1: This mitigation measure delays the findings of a potentially significant Impact to prior to issuance of a grading permit. The concern with this approach is that If PCB were detected, members of the public and other who have commented in this EIR would not be privileged to such information and the accepted method of remediation. Also, if the remediation delays the project or causes a significant change in the project, the EIR would not have analyzed it and there is no avenue for the public to request preparation of adequate environmental documents to address the issue. MM HAZ-2: Same comments as in MM HAZ-1, above. MM HAZ-3: The public is entitled to the contents of the remediation plan proposed under this mitigation measure. This Is delaying an impact to a future time convenient to the developer rather than the public. All related impacts of this project should be disclosed now and adequate remediation recommended. The remediation plan should be outlined in the EIR so that monitoring of the impact can be carried out is conformance with CEQA. For additional comments, see Attachment A Hydrology and Water. The project site has the potential to affect drainage facilities at the Atlanta Stormwater Pump Station and the First Street Storm Drain System. Potential water table contamination has not been adequately addressed. The EIR's position is that since the ground water in the vicinity of the project site is not potable (due to possible salt contamination from the Pacific Ocean), this impact is not significant. Our contention is that water table contamination is an environmental concern regardless of the quality of the water. There are no mitigation measures proposed to address possible groundwater contamination. In addition, the EIR mentions an oily soil remediation process currently underway on portions of the project site pursuant to CUP 00-36 and Coastal Development Permit 00-09. However, the EIR fails to incorporate the recommendations or conditions of approval of these discretionary actions into the EIR as possible mitigation measures. This is crucial since EIR for Pacific City Project EIR No.02-01 sCH No. 2003011024 November 26, 2003, Page 6 portions of the site in questions are critical to overall development of the project. The EIR should provide the link between these actions. For additional comments, see Attachments A and C Land Use and Planning. There are relatively few structures more than four-stories high along the waterfront area. The proposed hotel would add an 8-story tower to the waterfront area. The proposed development would generate approximately 601 employees and 1,419 residents. The project includes land uses more Intense than those surrounding the site and would increase development density of the area. The northerly portion of the site would be developed with high-density residential uses. The mobile home park located to the east of the project site is developed at Medium Density with up to 15 units per acre, half of the density of the proposed development. The area is identified with one-story high building; the project proposes two-to-three story buildings in some areas and four-story buildings In others. The proposed 90-foot separation between the hotel and commercial areas and the residential area is inadequate based on the level of activity proposed within these uses. This section of the EIR fails to address land use compatibility issues between existing developments within the project vicinity and the proposed project. Also, this development requires special permits to allow structures within 50-foot front yard setback from PCH. Special permits are also required for front yard setback encroachment from Pacific View Avenue and for the parking garage ramps to exceed the City standard of 10%. The EIR did not disclose why these special permits are necessary or recommend alternative designs to eliminate the need for the special permits. Also, the EIR did not disclose what the proposed parking garage ramp standard would be. Additional discussion is required in this area. The proposed project density of 30 d.u. to the acre exceeds that of any existing development within vicinity of the project. This impact is not thoroughly analyzed in the EIR and the conclusion that the proposed project would not substantially conflict with existing permitted uses can be challenged. For additional comments, see Attachment B Noise. It does not appear that the mitigation measure proposed in MM N-2 is adequate to address the noise impacts identified In the EIR. For additional comments, see Attachment C Population/Housing. The proposed project may not meet the City's affordable housing requirements. Public Services. EIR for Pacific City Project EIR No.02-01 sCH No. 2003013024 November 26, 2003, Page 7 The proposed project would add residential and visitor-serving uses to the area, and would increase demands on police protection. Mitigation Measure MM PS-4 requires that prior to building permit issuance, the applicant consult with the Huntington Beach Police Department regarding the provision of adequate crime prevention design measures. The stage prior to issuance of building permits is too late to implement any crime prevention design elements. This needs to the done at the planning stages or the design review stage to ensure that the recommendations of the Police Department are incorporated into project design. Recreation. The City's total of 906.7 park acres fall short by 48.3 acres the identified ratio of five acres of park land per 1,000 persons. Project Implementation would not provide adequate recreational facilities to meet increased demand from the project. Mitigation Measure MM REC-1 does not include language that is clear as to what the obligations of the project proponent is in regards to parkland mitigation. Transportation/Traffic Based on the current parking problems within the project area, the use of an internal capture/mode shift is unnecessary and undermines the understanding of the true impacts of this project on transportation, traffic and parking. Also, the use of a 1% growth factor in the volume of traffic at key intersections is too low to provide a true picture of conditions. A 2% or 21k% factor would provide the type of responses needed to truly analyze impacts. It is also not clear why the Future Year 2008 conditions with the proposed project are not different from the Future 2008 conditions without the project considering the project contributes an underestimated 12,002 daily trips. No analysis was presented in the EIR to support the conclusion in Impact TR-8. The parking reductions proposed in the EIR and the liberal use of off-site parking spaces for the project masks the actual parking impacts of this development and does not aid in resolving the parking situation within the project vicinity. The use of parking demand reduction is not appropriate in this case because of the existing parking conditions within the area. There is a 20% City parking code reduction, a 15% retail parking reduction, and a 5% residential parking reduction for a total proposed parking requirement of 1,482 spaces for all proposed uses. This is insufficient. For additional comments, see Attachments B and C Alternatives The EIR identified three project alternatives - a no project altemative, a reasonably foreseeable alternative and the reduced project alternative. EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 8 The impacts related to the Reasonable foreseeable alternative were found to be more severe than the proposed project. The impacts of the reduced project alternative were found to be environmentally superior to the proposed project. The reduced project was also found to meet the proposed project goals and objectives and implementation would result in a project with significantly less impacts on the environment. This alternative will provide less visitor-serving commercial uses but maintain the same level of residential development. This alternative is highly recommended. Conclusion In summary, environmental documents are informational documents required to provide detailed information on proposed developments and recommend adequate mitigation measures along with such disclosure. This EIR has not done a good job with recommending adequate mitigation measures to the project's identified impacts. Sincerely, THE URBAN PLANNING CONSULTING GROUP For comparison, the following information was presented to the City as part of public comments on the notice of preparation of the EIR earlier this year. It is clear that the recommendations in the comments have not been followed. Remediation In 1996, prior to the acquisition of the site by Atlanta Huntington Beach, LLC, Shea Vickers development, LLC, the prior owner, initiated an extensive site investigation and subsequent oil remediation program. Remediation of the site was performed pursuant to a Remediation Work Plan approved by the Huntington Beach Fire Department and included excavation and stockpiling of oily soil and the abandonment of several oil wells. In March 1998, an application was filed by Shea Vickers Development, LLC for a Coastal Development Permit to allow remedial grading of the property to remove oily soils and to import approximately 23,630 cubic yards of soil. This request was tabled and was not acted upon by the Zoning Administrator. CEOA EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 9 In January 2003, the City of Huntington Beach issued a Notice to Prepare an Environmental Impact Report. Citing CEQA Section 15183(a), the EIR being prepared for the project is considered subsequent to EIR 82-2, which is a Program EIR for the Huntington Beach Downtown Specific Plan. According to Environmental Assessment 02-05, prepared by the City of Huntington Beach, the project site has been addressed on a programmatic level of part of the analysis included in several Program EIRs prepared by the City. These documents, in addition to EIR 82-2, include: The Huntington Beach General Plan Update EIR 94-9, and the Huntington Beach Redevelopment Project EIR 96-2. Existing Analyses Traffic Linscott, Law & Greenspan, engineers, prepared a traffic impact analysis report for the Pacific City project in April 2002. The report concluded that the Pacific City project is expected to generate, Phase I and II combined, 12,076 daily vehicle trips (one half arriving, one half departing), with approximately 752 vehicle trips anticipated during AM peak hour (416 inbound, 336 outbound) and 1,122 vehicle trips (579 inbound, 543 outbound) forecast during the PM peak hour. According to the 2002 report, there are four related projects, identified from a list of 14 potential related projects provided by the City, which are included in the General Plan Update Analysis (The Strand, The Waterfront Ocean Grand Resort, The Beachside Project, and The Boardwalk Project) in the City of Huntington Beach that could impact the key study intersections and roadways. The total forecast traffic generation for the related projects in the City of Huntington Beach is estimated at 25,750 two-way vehicle trips per day with 1,752 AM peak hour trips (802 inbound, 950 outbound) and 2,297 PM peak hour trips (1,320 inbound, 977 outbound). Proposed Improvements In conjunction with development of Pacific City, the project frontages of Atlanta Avenue, 1" Street, and Pacific Coast Highway will be widened to accommodate anticipated traffic. Pacific View Avenue will be extended through the project from Huntington Street to 1" Street as a 52-foot roadway within a 90-foot right-of-way. A traffic signal will be installed at the project access driveway on Pacific Coast Highway, at the existing median break, and two pedestrian bridges are proposed across PCH for improved access to the beach. Water Supply Assessment Hunsaker & Associates prepared a Water Supply Assessment for the Pacific City Development in November 2002. The City's public works department contracted with Tetra Tech, Inc. to perform a computer model hydraulic analysis of water services for the Pacific City project site and the surrounding area based on City Planning data, and data provided by the applicant. The analysis noted various water distribution system defidencies resulting from the proposed project that will require mitigation (in the form of infrastructure improvements), to meet the demands of, and for the benefit of the proposed project and the surrounding area. The report concludes that, upon completion of the Improvements identified in the report, the City of Huntington Beach can provide adequate water supply for the proposed development, in accordance with the adopted Water Master Plan. EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 10 Analysis The City of Huntington Beach has prepared Environmental Assessment 02-05 that identified potentially significant environmental factors as a result of the proposed project. These factors are: Land Use, Population and Housing, Geology and Soils, Hydrology and Water, Air Quality, Transportation and Traffic, Biological resources, Mineral Resources, Hazards and Hazardous materials, Noise, Public Services, Utilities/Service Systems, Aesthetics, Cultural Resources, Recreation, and Mandatory findings of Significance. On the basis of this initial evaluation, the City of Huntington Beach has determined that an Environmental Impact Report is required. The Pacific Action Coalition Group would like the City of Huntington Beach, as Lead Agency in preparation of the environmental documents for this project, to consider the following recommendations: Hazards and Hazardous Materials: The Initial Study indicates that the property north of the Huntington Shores Motel was formerly occupied by a (natural) gas plant. This resulted in the presence of Benzene and Toluene leaking into the soil from the condensate due to processing of the gas. No recent tests have been conducted in this or adjacent areas of the site. The last tests occurred in 1996 and are not current enough (See Phase II Investigation Report/Remediation Plan Atlanta Areas - December 1996). Additional soil gas testing for volatile organic compounds was only conducted in certain portions of the site. With 20 oil wells scattered throughout the property, the likelihood that contamination was limited only to the region tested is remote at best (See Remediation Plan, Rev. 3 Atlanta Site - May 2002). State Division of Oil and Gas records show that the re-abandonment of the oil wells in the late 1990's was necessary to stop leaking gas. They had been previously abandoned in the late 1980's. The wells have not been tested by Oil and Gas since the re-abandonment and the agency states that their tests are only good for a one-year period. Thus the wells must be re-tested to ensure there are no leaks presently. And there remains the question of the extent of any groundwater contamination (See Remediation Plan). Because of a lack of recent extensive soil gas and oil well testing, there is a likelihood that contaminants exist which have not yet been Identified exist. Therefore, any additional excavation or movement of the soil would be premature until the site's true soil condition regarding hazardous materials Is known. Transportation/Traffic: Residents believe keeping Huntington Street in its present width and alignment, except for some curb and sidewalk improvements (on Pacific City side) will not work. Residents would also like to see some improvements into the entrance / exit of Pacific Mobile Home Park, along with curb improvements or installation of sidewalks, removal of overhead utility poles, and a retaining/sound (and for esthetics) wall on mobile home park side of Huntington Street at developers expense (without removing any homes). EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 11 • Consideration should be given to relocating the entrance/exit of Pacific Mobile Home Park to present dead-end configuration of Delaware Street, and officially abandoning the Delaware Street extension south of Atlantic Avenue to connect with Huntington Street at Pacific View Avenue. • The City should consider abandoning the extension of Delaware Street, which is currently on the Orange County Master Plan of Arterial Highways (MPAH) and Huntington Beach Precise Plan of Street Alignments (PPSA) as this new extended configuration. • The developer should be required to pay for all related traffic improvements, removing of Pacific Mobile Home Park entrance from Huntington Street to Delaware Street, and the installation of curbs, sidewalks, infrastructure improvements, underground utility poles, retaining walls, etc., all around the mobile home park. No mobile homes should be affected along Huntington Street. Developer should be required to relocate those affected with new Delaware Street entrance back into the park. • Sound walls should be constructed around and on park side because of noise from increased traffic due to Pacific City development. • Consideration should be given to Pacific View Avenue (Walnut Avenue) extension from 15` Street to 6`" Street, and Pacific View Avenue (Walnut Avenue extension from Beach Blvd. to connect with Hamilton / Victoria (Costa Mesa) and the 55 freeway. • The City should consider the possible extension of Delaware Avenue south of Atlantic Avenue. • Residents believe that the parking projections for the Hyatt/Hilton Waterfront Projects may be incorrect because it is based solely on total valet parking. Lessons learned from this development should be applied to the proposed project to avoid the same problems. • The parking garages should be designed to fit hotel tour buses and moving vans and trucks. Moving vans and trucks currently park on Pacific View Avenue because they will not fit into parking garage. • In preparation of the EIR, the City should revisit all previous reports and findings (EIR) for the Waterfront Resort and/or expansion projects in regards to Pacific City. Information need to be updated to current standards and conditions, as it appears Pacific City is now exceeding all original projections. • Residential and retail development will likely increase traffic significantly during peak commuter hours, weekends and during the summer. The EIR should consider impacts on traffic flow/congestion in the immediate vicinity of the property and regionally (e.g., Beach Blvd, Goldenwest St., PCH and freeways). EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 12 • Impacts from traffic/parking needs for site workers, materials/waste delivery to/from site need to be addressed in the EIR to minimize impacts on the neighborhood and ensure access to adjacent resident sites is not impeded. • Specifics regarding proposed pedestrian access for the public should be stated in the EIR. For example, hours that public access will be available must be stated. Also, since the pedestrian access ways are proposed to be gated, availability of the access to the public should be considered such that public access will not be further restricted than initially proposed. • Bicycle lanes should be maintained on all streets surrounding the site. No non- pedestrian access (e.g., bicycles, skates, etc.) is proposed through the facility. Therefore lanes for safe travel for bicyclists and skaters must be provided on streets surrounding the site. • Since zoning allows higher buildings on the east (Huntington Street) side than on the north (Atlanta St.) and west (First St.) sides, and since the site is surrounded on the east, west and north by residential homes, the City should consider the same height restriction on the west side as for other adjacent residential areas. This would ensure that ordinances for aesthetics (e.g., view, glare, noise, etc.) are appropriately maintained for residents adjacent to the west of the site. • Any future traffic studies must take into account peak periods for the region. This is particularly relevant to this project as the new Hyatt Hotel just south of the site hosts an 110,000 square foot convention center, which will bring thousands of business travelers to the area. The Linscott study doesn't appear to address this. • The impact of the increased density of the project on access and service to existing neighborhoods such as the adjacent Pacific Mobile Home Park, homes along Atlanta and Huntington streets as well as patrons of the commercial and residential parts of the development should be carefully studied. The Linscott study did not seem to address this issue. • Any proposed parking analysis should account for (1) project usage, (2) Hyatt's new convention facility and (3) regional parking during the height of the summer tourist season. • The anticipated increase in residential and retail population as a result of the project will impact already overcrowded parking conditions downtown. The specific number of parking spaces to be provided for residents, guests and commercial vehicles must be provided In the proposal so that the sufficiency of parking proposed can be evaluated based on the estimated demand for resident, guest and commercial visitor parking. The proposal also notes that on-street parking on adjacent streets will be allowed. Currently there is no on-street parking allowed on Atlanta and Huntington since these are single lane roads. Again, this proposal taxes the existing single lane roadways and the proposal does not state that dedicated right of way will be used for additional vehicle and bike lanes, or space for on street parking. The proposal only notes that sidewalk and curb and gutter improvements will be made. EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 13 • How will buses be accommodated along adjacent streets with the increased traffic? • The project is anticipated to increase traffic on Huntington Street and surrounding streets. Huntington Street is proposed to be widened to a 90-foot right-of-way. Where would the additional ROW be taken from? From the developer property or public and/or residential property? Public Services • In light of the $7 million City of Huntington Beach deficit due to the current State budget crisis, the EIR should identify project Impacts on current public services such as Fire, Police and Lifeguard services. • The EIR should clarify whether the proposed roadways within the residential development would be private or pubic. If the roadways are public, impacts for access for Police and Fire departments in emergency conditions should be analyzed. Public Beach Access • While not specifically addressed in the Initial Study, the issue of public beach access is critical for any coastal development. The EIR should identify the project's impacts on beach parking during peak summer months. The Linscott study does not seem to address this critical peak period. Aesthetics • The EIR should address impacts on the elimination of existing ocean views of residents in adjacent neighborhoods along Huntington, Atlanta and First streets, and propose measures to preserve the vistas the residents have had for years. • Impacts from shade and shadows, light from both the commercial and residential parts of the project, and glare should be adequately addressed, as they will severely impact surrounding neighborhoods. Recreation • With city park ratios of five acres per 1,000 persons, how is .90 acre for the project's park space allowed? Is one fifth or less of the required space acceptable? There must be both an increase in park space and reduced density to accommodate this guideline. Noise • The EIR must specifically propose mitigation measures to address the issue of excessive noise during the construction phase on neighboring development. In addition, the city should inform the public how compliance with noise regulations will be enforced. EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 14 • Noise during site operations during/following completion of the construction phase also needs to be addressed. Hotel, bars, restaurants, and other commercial facilities proposed to operate at the site will create noise that may be a nuisance to neighboring residents. Schedule for Construction and Operations • The construction schedule proposed Is basically without restrictions and does not consider the adjacent land use and quality of life of the neighbors. The proposed operating schedule is 7 a.m. to 8 p.m. Mon-Sat. This schedule should be restricted to Mon - Fri only, with working hours restricted to allow neighbors morning and evening hours undisturbed by noise. Recommend 9 a.m. to 6 p.m. operating schedule Mon - Fri. The approved schedule should remain in effect for the life of the project or until adjacent site uses change. In addition, set-up for site work should be monitored by the city so that residents are not exposed to excessive noise and emissions from Idling trucks, and loading/unloading operations at times outside the construction schedule. • The timetable for construction should be specific with regard to when public access ways and other facilities (public park space, etc.) are to be constructed. Provisions should be Included that require completion of the promised public facilities to be provided (parks, street improvements, etc.) on a specified schedule. ATTACHMENT A PACIFIC CITY DRAFT EIR RESPONSE HAZARDOUS MATERIALS The Pacific Action Coalition has researched records and interviewed Huntington Beach residents and city officials about the presence of hazardous materials on the site of the proposed Pacific City development. An environmental chemist consulting for the Pacific City EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 15 Action Coalition reviewed the Hazardous Materials section of the Pacific City Draft Environmental Impact Report and other reports describing remediation and characterization activities on the site. This document presents the Coalition's concerns related to hazardous materials on the site that are not satisfactorily addressed in the Draft Environmental Impact Report. We conclude with a recommended course of action that will ensure adequate assessment and mitigation of environmental and human health risks associated with development on the Atlanta Avenue site. THE EIR CLAIMS AREA D NEEDS INVESTIGATION,BUT THE PRIOR TESTING THERE HAS BEEN KEPT SECRET. (1)The EIR, in Section 3.7-10 states, "The area where further investigation is necessary is Area D, in the southwestern portion of the site...These areas do not include former oil wells or storage tanks. Sampling completed as part of the 1996 Phase II Investigation delineated the areas where remediation was necessary. Test results from that sampling effort did not detect that the contamination on the northern and eastern portions of the site had migrated to this area on the western portion of the site." The EIR implies that no remediation is necessary in the western part of the site while at the same time saying that further investigation is necessary. What the EIR fails to address is the testing which had been conducted in Area D by developer Makar Properties, Chevron and their consultant, Harding ESE in late 2001 or early 2002, identifying potential groundwater contamination by hydrocarbons. According to a sworn affidavit by Kamron Saremi of the California Regional Water Quality Board, Chevron's consultant, Harding ESE, approached him in 2002 with a proposal to leave contaminated soils in place which were near groundwater in the west central portion of the site. Saremi visited the site with Chevron and their consultant. He stated that Harding ESE presented groundwater testing samples to him taken from sample bores in the impacted area, the sampling area being approximately one acre. Saremi said the vertical extent of impacted soil was approximately five to ten feet below the ground surface. He stated that Chevron knew that a City of Huntington Beach requirement mandated the soil involved would have to be excavated. Saremi told the consultant that the groundwater test results necessitated them conducting more extensive testing in a larger area and suggested they submit a work plan for this purpose. Chevron said they would talk to their consultant and prepare a work plan for submittal. Chevron then contacted Saremi two weeks later and said they had decided to work with the City of Huntington Beach to implement the required soil excavation. These test records have been requested from the City and developer Makar for months and have not been disclosed to the public. A document dated January 3, 2002 was then submitted to Saremi and cc'd to the City's Fire Department, Chevron and developer Makar referencing the above discussion. The report includes a EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 16 groundwater testing plan, but references the southeastern part of the site, an area totally separate from the section visited and discussed by Saremi. (2) The EIR, in Section 3.7-17 states, "While not anticipated once closure reports have been submitted, the possibility remains for unidentified soil contamination...or for unidentified underground storage tanks to be encountered during grading or excavation activities...It is possible that underground tanks may have been in use at the project site prior to permitting and record keeping requirements." A sworn affidavit by resident John Sisker, identified six to eight narrow, cylindrical tanks with pipes extending into the ground, located near First Street, approximately halfway between Atlanta Avenue and Pacific Coast Highway, the same area as the potential groundwater contamination noted above. These tanks and pipes are believed to be the type used in distilling or separating operations that separated and distributed crude oil into gasoline and diesel fuels. It is likely that the tanks referred to are located in the west central part of the site, Area D, and were repositories for the gasoline products referenced above. There is therefore evidence that the southwestern portion of the site (Area D) is contaminated with petroleum hydrocarbons, but the extent and composition of this contamination has not been characterized in the EIR and no plan for remediation of this area has been submitted. The potential impacts of contamination in Area D on workers and residents near the development are unknown, but must be analyzed in the EIR rather than deferred until after development has already proceeded. (3) In 1990, a warning sign identifying the presence of carcinogens and chemicals which may cause birth defects was present on the site, but has since been removed. This warning was precipitated by the Proposition 65 guideline regarding potential groundwater contamination. Where are the test results or reports which generated this warning? It is believed that Chevron, who owned the property at the time, was aware of prior groundwater contamination and has reports indicating such. (4) The EIR states, in Section 3.7-10, that "groundwater beneath the project is also brackish due to saltwater intrusion, and as such, is not used as potable water by the City" as a justification for why groundwater contamination should not be a concern. This statement ignores the scientific fact that petroleum contamination on the Pacific City site could potentially pose health risks to residents of the adjacent community, particularly if there are low molecular weight carcinogenic hydrocarbons such as benzene, toluene, ethyl benzene and xylene (BTEX) at the site. If present at sufficient levels, BTEX could form a non-aqueous phase that would leach through the soil to the soil-groundwater interface and spread out along the top of the groundwater. This could lead to exposure of residents in nearby houses by infiltration of vapors and subsequent inhalation. A study released last year in the American Journal of Industrial Medicine found an increased risk of gliomas (a type of tumor) in Swedish men and women over two decades when occupationally exposed to petroleum products and other chemicals such as arsenic and mercury. EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 17 The study is indicative of current research interest in this area, and is particularly relevant given the recent cases of brain stem glioma among Huntington Beach residents who lived along Yorktown Avenue and were potentially exposed to oil field contamination. The EIR does not address the possible impacts of hydrocarbon contamination of groundwater on residents living adjacent to the site, and the extent of this groundwater contamination remains unknown. THE EIR IDENTIFIES AREA A AS HAVING COMPLETED REMEDIATION. (1) The EIR states in Section 3.7-7 that the soil involved in the 1999 export to the Hyatt (approximately 215,000 cubic yards) exceeded city specifications for hydrocarbon contamination and was either excavated or remediated on site. The EIR also states in section 3.7-17, "Residual oil could be present in the areas remediated, and this cannot be confirmed until closure reports have been submitted and accepted by the City Fire Department that verify the site has been satisfactorily remediated." The"Final Environmental Closure Report" for the Hyatt submitted to the city by Hyatt developer Robert Mayer Corporation claimed there was no evidence of contaminated soil in any of the samples tested and thus contained no documentation of either excavated or remediated soil. The Mayer Corporation conducted limited sampling in Area A during the period of August through September 1999, even though soil continued to be excavated and transported through November of that year. Residents John Sisker and Ron Satterfield completed sworn affidavits attesting to soil being vented for a period of six months to one year after being stockpiled at the Hyatt location. It is believed that the venting was carried out to purge the soil of low molecular weight hydrocarbons(BTEX chemicals). Photos of the site taken during the 1999 soil transport reveal the soil to be very dark and in some instances, nearly black. Considering the site's history of oil production, it is likely that the soil samples taken did not accurately reflect the nature and extent of the area's contamination. Furthermore, mixing of soils as a type of "remediation" does not remove contaminants from the site, leaving the possibility that high concentrations of contaminated soil could still exist. (2) Mayer Corporation has a history of non-compliance with state and local requirements spanning the last decade, including: A 1990 class action lawsuit filed by Pacific Mobile Home Park residents against the Mayer Corporation for violating AQMD dust control guidelines while constructing the Hilton hotel. Ironically, the dust which covered homes in the park came from stockpiles of soil at the Pacific City site, which at the time had signs posted warning of soil contamination. The suit was settled for $100,000. d EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 18 A 1991 AQMD lawsuit filed against the Mayer Corporation for dust control violations during the construction of the Hilton hotel which was settled for$15,000. Several neighborhood complaints were lodged with both the AQMD and the City during the 1999 soil transport. Although the Mayer Corporation had a dust control plan in place, measures to control the dust were not implemented until the surrounding homes had been covered with dust. A $55,000 fine assessed by the Regional Water Quality Control Board for stormwater runoff violations occurring in December, 2002. Among the violations were the dumping of sediment laden storm water directly into the storm drain. According to Seaside Village residents, who face the new residential development behind the Hyatt hotel, the Mayer Corporation continues to violate Water Board guidelines by allowing runoff from the project to impact their homes. The above facts raise several questions— (1) Did the City's Fire Department know that there was contaminated soil which was found and not included in Mayer's report? If so, why did they sign off on the project? (2) Was the Fire Department unaware of any such findings? (3) Where are the records to support the EIR's claim that the soil was contaminated, excavated and remediated, despite months of requests from both the city and developer Makar for more details on Mayer's report, (4) Was the contaminated soil actually excavated and remediated on site orjust transported as eyewitness accounts verify, (5) Why is the soil contamination being disclosed now despite the public being told for years that the soil involved was clean? (6) Does this mean that the "Final Environmental Closure Report" for the Hyatt was inaccurate? (7) If so, why doesn't the EIR address this issue? (3) Moreover, the 1996 Phase II Study shows four areas that were"surgically excavated" to remove hydrocarbon contaminated soil for remediation by mixing. Three of these four areas are marked in the EIR map, Figure 3.7-1, as part of Area A where remediation has been deemed complete. However, one of the four areas, Surgical Excavation Number 1 on the 1996 map, is part of Area B in the EIR map, where remediation is "currently underway." Thus, as Surgical Excavation Number I in 1996 was not effective at cleaning up the site, why would the other three excavations in Area A be considered effective? (4) In Section 3.7-5, the EIR references reports of a former gas plant, identified by a Chevron employee interviewed for the 1995 Phase I Study. The plant reportedly operated at the corner of First Street and Atlanta Avenue, north of the site. The EIR then makes two statements, (1)"...no documentation exists to support the existence of a gas plant" and, (2) "If a gas plant did exist on property adjacent to the project site, toxic contaminants associated with gas condensate from a gas plant could remain in the soil." The EIR should not use a lack of documentation from half a century ago as justification for questioning the plant's existence Via) At the same time, the EIR acknowledges that the former Chevron employee who identified the gas plant was also correct in stating that toxic contaminants could remain in the soil. EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 19 Once again, several questions are raised, (1) Where are the test results, documents or statements to support the above statement?, (2)Is the EIR relying on the Chevron employee's statement for this information?, (3) Wouldn't the Chevron employee's statement regarding the gas plant's existence then be reliable? The EIR again contradicts itself. Section 3.7-5 states, "These contaminants would be localized on the site and would not be expected to have migrated across First Street through the soil to the project site...As such, these contaminants are not expected to exist on the northwestern portion of the site or otherwise affect soils on the property site." While Section 3.7-18 states, "Due to the migratory nature of oil in the soil, the risk remains for oil contamination to exist in soil areas that have not been previously trenched for sampling and investigation." Which of these statements is accurate? If the first statement is true, are there test results to substantiate it? Is there new testing of the northwest part of the site which has not been disclosed? Or is the EIR relying on the 1996 Phase 11 testing of the northwest portion and/or the 1999 testing by Mayer, both of which have been contradicted in the EIR itself. THE TEST RESULTS ARE CONTRADICTORY AND UNRELIABLE (1) The EIR states in Section 3.7-9 that 1999 hydrocarbon testing in the southeastern part of the site revealed levels of up to 130,000 mg/kg for shallow soil and 68,000 mg/kg for deep soil. These levels are 15 to 100 times higher than the prior testing conducted in the 1996 Phase 11 Study by Chevron's consultant, Harding Lawson. As some of the areas tested in 1999 and 1996 overlap, this seems to indicate that the site became more contaminated over time. How is this possible? Or does this mean that the 1996 Phase 1I Study was inaccurate? Where are the test results and sampling maps to accompany the 1999 testing? These documents have been requested from the city and developer Makar for months and have not been disclosed to the public. (2) Developer Makar, along with Chevron and their consultant Harding Lawson made an exemption request to leave approximately 800 cubic yards of contaminated soil surrounding a water main in Area C. They wanted to rely on BTEX testing from the 1996 Phase II Study, even though no testing in the impacted area was conducted during that period. The original exemption request was recommended for approval by the city's consultant, Geosciences Analytical, whose principal, Fleet Rust was convicted in 2002 of falsifying methane monitoring data to the City. EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 20 The developer and Chevron withdrew their exemption request shortly after the Pacific City Action Coalition disclosed the above details to the public. CONCLUSIONS The Pacific City Draft Environmental Impact Report's Hazardous Materials section relies heavily on prior studies conducted by developer Makar Properties, Chevron and their consultant(s) Harding Lawson and Harding ESE, and the Robert Mayer Corporation. These studies were sanctioned and approved by the City of Huntington Beach and their consultants. As previously illustrated, the studies have been shown to be misleading, incomplete and contradictory and thus unreliable. One of the consultants involved in assessing the site was even convicted of submitting fraudulent test results for another site. The City of Huntington Beach has improperly sanctioned and distributed much of the misleading data and been negligent in it's role of ensuring compliance with established laws and regulations. The only fair conclusion is that the parties involved—developer Makar Properties, Chevron and their consultants along with the City of Huntington Beach, cannot be relied upon to provide an objective, accurate characterization of the environmental conditions at the Pacific City site. Given the potential community health risks involved as a result of not properly assessing conditions at the site, the only viable alternative is to have testing done by an independent firm, mutually selected by the developer, Chevron, the city and the Pacific City Action Coalition, paid for by the developer and Chevron, who is responsible for the site clean-up. EIR for Pacific City Project EIR No.02-01 SCH No.2003011024 November 26, 2003, Page 21 ATTACHMENT B ISSUES INVOLVING PACIFIC MOBILE HOME PARK SURROUNDING STREETS AND POTENTIAL WETLANDS These comments address the Pacific City project impacts to Pacific Mobile Home Park and the Draft EIR's failure to analyze the ultimate outcome during and after build-out of Pacific City to Pacific Mobile Home Park. This would include the Delaware Street extension, which the EIR seems to indicate would eliminate the mobile home park and the widening ofAdanta Avenue between Huntington Street and Delaware Street. According to Mayor Connie Boardman, the City has been meeting with the owners of Pacific Mobile Home Park, Mark Hodgson and brothers as to the impact Pacific City will have on the park and the residents. Any and all known future impacts to this mobile home park and the residents must be disclosed The residents have been told, both directly and indirectly, that the present owners of this park intend to keep said property as a mobile home park well into the future. Residents, acting upon this information, are putting in new homes as well as fixing up existing ones. The Environmental Impact Report fails to address the project's impact on the park. THE FOLLOWING CONCERNS HAVE NOT BEEN ADDRESSED BY THE EIR: TOTAL AND ULTIMATE IMPACT(S) TO PACIFIC MOBILE HOME PARK: Regarding Huntington Street, Atlanta Avenue, Delaware Street (extension), and Pacific View Avenue • Precise alignments and/or improvements • Mobile home park entrance/exit • Total number and identification of mobile homes to be displaced • Ingress/egress from Huntington Street and Atlanta Avenue into Pacific City and/or Pacific Mobile Home Park • Number of inlets and outlets • Set back requirements on street, restricted flow of traffic • Intended land use if not a mobile home park • Time frame EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 22 • Known factors by park owners/management company ULTIMATE EXTENSION OF DELAWARE STREET: Regarding the Master Plan of Arterial Highways and City Circulation Element from Atlanta Avenue to Pacific View/Huntington Street • Will eliminate Pacific Mobile Home Park • Time frame THE TAKING (POSSIBLE EMINENT DOMAIN) OF ANY OR ALL OF PACIFIC MOBILE HOME PARK: • Compensation to residents/ landowner • Market value • Time frame THIRTEEN, TEN AND/OR SIX FOOT EASEMENT(S) INTO PACIFIC MOBILE HOME PARK: • Parallels Huntington Street • City and/or Edison easement • Effects on mobile home park • Time frame PACIFIC VIEW /HUNTINGTON STREET: • Designated for signalized intersection • When and what configuration • Eliminate connect to pacific view/dead end • Time frame THE PRECISE WIDENING/REALIGNMENT OF HUNTINGTON STREET, ATLANTA AVENUE, AND lar STREET AND RELATED INTERSECTIONS: • All projected/future circulation elements and traffic flow patterns • Configuration for all curbs, gutters, sidewalks, pedestrian paths, bikeways, on-street parking, underground utilities and other infrastructure needs; curb cuts, bus routes, ingress / egress into development and/or surrounding communities • Needs to be determined for both sides of each street • Time frame THE EIR FAILS TO ADDRESS HOW THE PACIFIC CITY SITE AND/OR OTHER ADJACENT PROPERTIES WILL BE USED FOR ANY FUTURE PARKING ISSUES: • The Waterfront Hilton/Hyatt not providing adequate parking for guests and/or employees EIR for Pacific City Project EIR No.02-01 SCH No. 2003013024 November 2k 2003, Page 23 • Has no parking areas for tour buses and/or moving vans for convention equipment • Hotel employees still required to park off-site at peak times, and have been since the early 1990's, on the Pacific City site itself • Impact to surrounding neighborhoods when Pacific City site is no longer available for overflow Waterfront parking • It is believed Waterfront hotel employees are being charged if they do park within the parking areas that were supposed to be part on the approved on-site employees parking management plan • Some employees parking within the beach public parking lot instead, and before hours to avoid being charged TAKING OF HOUSES/PROPERTY ALONG DEVELOPED SIDE OF ATLANTIC AVENUE: • Possibly through future eminent domain • Any improvements to existing road circulation • Time frame IMPACT ON THE CITY OF NEWPORT BEACH: • With the addition of 3,000 cars per day to the Pacific City site alone, the City of Newport Beach anticipates that at least half these cars will end up in their city • This will cause increased traffic on already congested Pacific Coast Highway and other roads within their city • Concerns about the proposed 190' Street bridge across the Santa Ana River—what if the bridge isn't built? How will traffic be handled in this case? POSSIBLE SIGNIFICANT WETLANDS VEGETATION AND/OR PONDING ON SITE: • Potential wetlands vegetation and ponding identified by Mark Bixby was not adequately addressed in the EIR • Developer Makar Properties was stopped twice in September of 2003 for grading without a permit immediately after Bixby's presentation to the City Planning Commission PROPOSED MITIGATIONS EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 24 • The widening of Huntington Street, from Pacific View Drive to Atlanta Avenue, for proper traffic flow for north/south circulation (including right- and left-hand turn pockets, center landscaping, bicycle lanes) using the Pacific City developers property. We oppose any encroachments into surrounding neighborhoods including that of Pacific Mobile Home Park. • The widening of Atlanta Avenue from Huntington Street to Delaware Street to be configured so that no existing mobile homes will be effected within Pacific Mobile Home Park. • Elimination of the decades-old realigned plans and proposed Delaware Street extension, as currently projected on both the City and County master traffic plans. The extension is intended to connect Delaware Street with Huntington Street at Pacific View Drive, thus eliminating Pacific Mobile Home Park according to the Pacific City Environmental Impact Report (EIR). • Full and complete disclosure from the owners and property management company regarding impacts to Pacific Mobile Home Park. • Reducing the proposed density of 516 residential units, as this will cause major traffic and parking impacts in the region, particularly during the summer months. • Maintaining as many existing view corridors for all residents in the surrounding neighborhoods. • Perform a totally new and updated traffic study using today's actual traffic flow, street congestion, parking issues, etc., which would then be the basis for any future traffic projections because of Pacific City. • Pacific Mobile Home Park, and/or other adjacent properties, not to be used as a solution for future parking and/or other related issues, by Makar Properties, the Robert Mayers Corporation, and/or the City. ATTACHMENT C PACIFIC CITY ACTION COALITION DRAFT EIR COMMENTS • The EIR does not adequately address amplified noise from the commercial portion of the development. Significant impact has been experienced in the neighborhoods surrounding the EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 25 Hyatt as they frequently have outdoor amplified concertstevents that intrude on the generally low level noise of a residential area. • The EIR does not adequately outline "public access" to the bridge over PCH that is proposed. If the measure of"public access" experienced at the Hyatt project is an indicator, this would be deemed unacceptable. Public access and utility should include consideration of useful route, maximum width, clear signage or views indicating access, no limits/obstructions on public access i.e. events/restrictions on common beach access modalities such as bikes/roller blades/wagons. Access should be clear and functional for all these modes. • The EIR does not adequately address light contamination that results from significant use of`tip" lighting as demonstrated by the Hyatt. Impact on surrounding neighborhoods is significant at night and intolerable during the frequent foggy weather we experience near the beach. • Erosion control was poorly managed at the Hyatt development and the residential project to the North of it despite fines and significant community/public works/water quality board involvement. There needs to be clearly outlined process with active city involvement, oversight and significant negative impacts to the developer should erosion control fall out of substantial compliance. The city public works department was unable to change the gross inconsideration and impact of silted storm drainage into neighboring communities and our wetlands/ocean. • The timeline proposed is unacceptable. If the developer is hindered by finance concerns (as experienced by the Hyatt project) perhaps a more stable, more aptly funded developer should be considered. IF such a timeline is unavoidable, the impacted residents should be afforded EXTRAORDINARY accommodation in minimizing intrusion and impacts (noise blankets, temporary relocation, monitoring of air/noise/storm drain quality). • Alternatives to the proposed density were not adequately explored in the EIR. Current development at the Waterfront residential project is not as dense, yet the EIR states that lower densities would not meet current planning goals. • Pedestrian access in and around the project is not adequately address in the EIR. If this project were to be an asset to the community and not just to the developers that sell it, pedestrian issues would be a primary consideration. Sidewalks on all borders and throughways to the property, clear rights of way for pedestrian and bicycle/roller blade traffic would create a project open to area residents and facilitating access to commercial, pier, beach and downtown venues by paths other than PCH. The"commercial' aspects of the Hyatt project were oversold to the community and remain primarily hotel oriented. Sidewalks on one side of the street and not the other create an uninviting environment for local pedestrian traffic... a major source of revenue in the off-peak seasons. • The balance of commercial to residential space is too far toward residential. If this project and the city are to seek destination status, there needs to be a greater draw than very dense resident traffic/consumption. This city could use a few more active cash registers in the primary tourism areas adjacent to the coast. High quality dining absent the pricing and limitations of a hotel venue are the first opportunities that come to mind. EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 26 • Parking, while it may be in compliance with code, is inadequate for a"destination" project, and does not consider the downtown area as having been built prior to generation of current parking codes. Parking for residential and commercial uses is inconvenient and inadequate. Multi level garage parking may put money in the pockets of some and "adequately" manage focused concerns, but ample street and single level parking creates the feeling of open space and quality of life that the pier/downtown area is worthy of. It is of interest to note that the Hyatt directs its employees to park in the adjacent communities when holding large events ... presumably because the parking designed is inadequate to accommodate both employees and guests. The downtown area can ill afford this impact. • Increased traffic in the area is inevitable. While traffic studies in the EIR don't suggest a traffic light at the intersection of Atlanta and Huntington, common sense does. As frequent travelers to this intersection confidently state, summer traffic is already a concern, without the proposed development. Without a timed break in traffic, access to downtown areas becomes tenuous and crossing Atlanta via the crosswalk at Delaware to access the local park quite hazardous due to the incline, lines of sight and speed along the wide Atlanta corridor. • Significant unavoidable impact on traffic at PCH and Wamer creates a question of air quality impact on the Bolsa Chica. Idling traffic can already be a problem as commuter traffic backs up from Warner south along PCH. There is no consideration of air quality impact due to idled traffic for this avian sanctuary or for the wetland areas south of the development that will experience increasing traffic loads and idle time. • Significant conflicting messages exist regarding traffic concerns as they relate to the county plan. Most proximate is the extension of Delaware to the south. Is this being proposed and used in traffic projections? Are the traffic projections considering the 19'h street bridge over the Santa Ana River? These two issues are contentious and are not reliably prone to inclusion or exclusion when projecting traffic impact. • Impact on local schools should be considered WITH projected impacts of current and planned future development in the downtown area. • Height or number of stories above curb height should be portrayed. The 4 story limitation presented for the Hyatt was misleading to the public as the project resulted in a final height far above that presented publicly when soil compaction and parking garage additions to height were added. • Traffic impacts to the south including nearest freeway access to the 55 are not addressed in the EIR draft. EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 27 ATTACHMENT C PACIFIC CITY ACTION COALITION DRAFT EIR COMMENTS • The EIR does not adequately address amplified noise from the commercial portion of the development. Significant impact has been experienced in the neighborhoods surrounding the Hyatt as they frequently have outdoor,amplified concerts/events that intrude on the generally low level noise of a residential area. • The EIR does not adequately outline"public access" to the bridge over PCH that is proposed. If the measure of"public access"experienced at the Hyatt project is an indicator, this would be deemed unacceptable. Public access and utility should include consideration of useful route, maximum width, clear signage or views indicating access, no limits/obstructions on public access i.e. events/restrictions on common beach access modalities such as bikes/roller blades/wagons. Access should be clear and functional for all these modes. • The EIR does not adequately address light contamination that results from significant use of"up" lighting as demonstrated by the Hyatt. Impact on surrounding neighborhoods is significant at night and intolerable during the frequent foggy weather we experience near the beach. • Erosion control was poorly managed at the Hyatt development and the residential project to the North of it despite fines and significant community/public works/water quality board involvement. There needs to be clearly outlined process with active city involvement,oversight and significant negative impacts to the developer should erosion control fall out of substantial compliance. The city public works department was unable to change the gross inconsideration and impact of silted storm drainage into neighboring communities and our wetlands/ocean. • The timeline proposed is unacceptable. If the developer is hindered by finance concerns (as experienced by the Hyatt project) perhaps a more stable, more aptly funded developer should be considered. IF such a timeline is unavoidable, the impacted residents should be afforded EXTRAORDINARY accommodation in minimizing intrusion and impacts (noise blankets, temporary relocation, monitoring of air/noise/storm drain quality). • Alternatives to the proposed density were not adequately explored in the EIR. Current development at the Waterfront residential project is not as dense,yet the EIR states that lower densities would not meet current planning goals. • Pedestrian access in and around the project is not adequately address in the EIR. If this project were to be an asset to the community and not just to the developers that sell it, pedestrian issues would be a primary consideration. Sidewalks on all borders and throughways to the property, clear rights of way for pedestrian and bicycle/roller blade traffic would create a project open to area residents and facilitating access to commercial, pier, beach and downtown venues by paths other than PCH. The "commercial' aspects of the Hyatt project were oversold to the community City of Huntington Beach —Pacific City 27 The Urban Planning Consulting Group EIR for Pacific City Project EIR No. 02-01 SCN No. 2003011024 November 26, 2003, Page 28 and remain primarily hotel oriented. Sidewalks on one side of the street and not the other create an uninviting environment for local pedestrian traffic... a major source of revenue in the off-peak seasons. • The balance of commercial to residential space is too far toward residential. If this project and the city are to seek destination status,there needs to be a greater draw than very dense resident traffic/consumption. This city could use a few more active cash registers in the primary tourism areas adjacent to the coast. High quality dining absent the pricing and limitations of hotel venue are the first opportunities that come to mind. • Parking, while it may be in compliance with code, is inadequate for a"destination" project, and does not consider the downtown area as having been built prior to generation of current parking codes. Parking for residential and commercial uses is inconvenient and inadequate. Multi level garage parking may put money in the pockets of some and "adequately" manage focused concerns, but ample street and single level parking creates the feeling of open space and quality of life that the pier/downtown area is worthy of. It is of interest to note that the Hyatt directs its employees to park in the adjacent communities when holding large events ... presumably because the parking designed is inadequate to accommodate both employees and guests. The downtown area can ill afford this impact. • Increased traffic in the area is inevitable. While traffic studies in the EIR don't suggest a traffic light at the intersection of Atlanta and Huntington, common sense does. As frequent travelers to this intersection confidently state, summer traffic is already a concern, without the proposed development. Without a timed break in traffic, access to downtown areas becomes tenuous and crossing Atlanta via the crosswalk at Delaware to access the local park quite hazardous due to the incline, lines of sight and speed along the wide Atlanta corridor. • Significant unavoidable impact on traffic at PCH and Warner creates a question of air quality impact on the Bolsa Chica. Idling traffic can already be a problem as commuter traffic backs up from Warner south along PCH. There is no consideration of air quality impact due to idled traffic for this avian sanctuary or for the wetland areas south of the development that will experience increasing traffic loads and idle time. • Significant conflicting messages exist regarding traffic concerns as they relate to the county plan. Most proximate is the extension of Delaware to the south. Is this being proposed and used in traffic projections? Are the traffic projections considering the 19`° street bridge over the Santa Ana River? These two issues are contentious and are not reliably prone to inclusion or exclusion when projecting traffic impact. • Impact on local schools should be considered WITH projected impacts of current and planned future development in the downtown area. City of Huntington Beach —Paci/ic City 28 The Urban Planning Consulting Group EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Pape 29 • Height or number of stories above curb height should be portrayed. The 4 story limitation presented for the Hyatt was misleading to the public as the project resulted in a final height far above that presented publicly when soil compaction and parking garage additions to height were added. • Traffic impacts to the south including nearest freeway access to the 55 are not addressed in the EIR draft. City of Huntington Beach —Pacific City 29 The Urban Planning Consulting Croup 6 • LEWIS BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 650 TOWN CENTER DRIVE, SUITE 1400, COSTA MESA, CA 92626 PRONE: 714.545.9200 1 FAx: 714.850.1030 1 WEBSITE: wwW.lbbslaw.cum FRANK BRUCCur.ER1 June 7, 2004 DIRECT DIAL 714.668.5512 E-MAIL bnuculeri@lbbslaw.cam VIA MESSENGER RECEIVED OR AT HE AND MADE A City of Huntington Beach COUNCILMEET 0�HE CITY O CLERK 2000 Main Street COµNIE BROCKWAY,CITY CLERK Huntington Beach, California 92648 Attn: Mary Beth Broeren Re: Public Comments Re Environmental Impact Report No. 02-01frentative Tract Map No. 16338/Conditional Use Permit No. 02-20 With Special Permit No 02- 04/Coastal Development Permit No. 02-12/Conceptual Master Plan(Pacific City) Planning Commission Meeting Dated June 7, 2004. Dear Ms. Broeren: As you know from our previous correspondence, we represent the interests of South Coast Angus, LLC ("South Coast") with regard to opposition to approval of the referenced project and Environmental Impact Report. This correspondence addresses the issues raised by the letter submitted by City Attorney Jennifer McGrath to the Planning Director of the City of Huntington Beach, Mr. Howard Zelefsky on May 24, 2004. In support of its attempt to exclude from the development plan, the statutory provision requiring a 2 acre oil island, the City's May 240, 2004 letter makes two unsupportable and unconvincing arguments: 1) Given that the development does not propose oil production activities, the Downtown Specific Plan does not apply. 2) Since the General Plan dictates the overall vision of a city's growth, the Downtown Specific Plan must comport with the General Plan which does not provide for an oil island in the Oil Overlay"C" area. The City's May 24, 2004, letter asks the question: "If the project does not propose any oil production activities, must the conceptual site plan depict a two-acre oil island?" However, the question which must be asked and answered by council members is: If the statutory language of the City's Specific Plan requires that land be set aside for purposes of oil production, can the Planning Commission disregard such language?" The answer is NO. LOS ANGELES SAN FRANCLSCO SAN DIEGO COSTA MESA SAN BERNARDINO SACRAMENTO NEW YORK LAS VEGAS 213250.1800 415.362,2580 619.233.1006 714.545.9200 909.387.1130 916.564.5400 212,232.1300 702.366,9212 4815-7618-0224-1 1 A ( 0MM knic4-Tloly LE wis BRISI30IS BISGAARD K SMITII u-11 June 7, 2004 Page 2 1. THE. DOWNTOWN SPECIFIC PLAN MANDATES THE INCORPORATION OF AN OIL ISLAND WITHIN ANY TYPE. OF PROPOSED DEVELOPMENT The City's first argument that a two acre oil island can only be implemented if`oil production activities are proposed within the overlay areas" is legally unsupportable. The City does not explain how it can maintain such a position which is in direct contradiction to the statute governing requirements for developments on land over Oil Overlay"C." The language of the Downtown Specific Plan was drafted with the intent to ensure that continued extraction of oil from the oil reserves within the area. In clear and unequivocal language, Section 4.14.03, entitled "Oil Overlay 'C"' mandates that: a. A conceptual site plan for the entire overlay area must be submitted prior to pennitting any project development or subdivision of land within the overlay. b. The plan shall include at least one (1) oil island of not less than two (2) acres in size for new oil well drilling and oil production. There is no limitation in this clear language, nor in that contained in section 4.0.01, limiting the scope of the requirement that land be set aside for oil drilling and production with respect to "any project development' on land over Oil Overlay "C." Nowhere in the statute is the type of development requiring the oil island limited to "oil production activities" as argued by the City. in fact the statute suggests the contrary - that the type of development which is being contemplated by the statute is residential and commercial development. This is indicated by the language contemplating "subdivision of land". Subdivision of land is generally associated with zoning and preparation of land for construction of buildings, not `oil production activities" such as drilling oil wells. Even more obvious that "any project development" meansjust that, and not just oil production developments, is the fact that it would be nonsensical for a statute to require land to be set aside for oil islands if the development contemplated by the statute was for oil production activities. Why would oil islands be necessary if the development was for oil production? Indeed why would the legislature need to mandate the creation of at least one oil island to an oil exploration and development company whose business it is to extract oil. If the language found in Oil Overlay"C" was intended to be limited to only proposed oil projects, one would have expected it to provide a limitation on the number of wells, not a command to include at least one well. The legislature surely could not have intended to compel an oil producer to produce oil on an oil development project. As the name suggests, oil islands, are meant to be undisturbed areas of land apart from the surrounding developed area, where the land is devoted to oil production. Necessarily then, the term "project development" as contemplated in the statute can only refer to development not related to oil producing activities. The City argues that the overall intent of the statute must be looked at in determining meaning of the language used in the statute. The City makes the bare assertion that reading 4.14 4815-7618-0224.1 Lewis BKiswis BISGAARD x SMITH UY June 7, 2004 Page 3 in its entirety suggests that the development contemplated by 4.14.03 is intended to be invoked only when oil production activity is proposed. In making this argument they point to language which states: Such island(s) shall be incorporated into the overall development plan so that noise, odor and visual impacts on the residences are minimized, and safe access to the oil site(s) is provided. The City fails to explain how the requirement that the oil islands be developed so as to reduce noise, odor and visual impacts suggests and be provided safe access suggests that the development outlined in 4.14.03 must be for oil production activities. In fact the language of this statute suggests the opposite inference. if the development contemplated in 4.14.03 was for oil production activities, rather than an oil island surrounded by residential and commercial development, why would there be a need to reduce noise, odor and visual impacts on "residences?" Obviously the requirement that noise and odor pollution be minimized is for the benefit of commercial and residential occupants on the border of the oil islands. Once again this language reinforces the inescapable conclusion that the development contemplated in 4.14.03 is for types of development other than oil production activities. The City's final argument in supporting their contention that the project development referenced in 4.14.03 is limited to "oil production activities" is that the legislative history of the statute must be looked at to provide guidance as to its meaning. "The rules governing statutory construction are well established.(citation) Our objective is to ascertain and effectuate legislative intent." Cit-v of Huntington Beach v. Board of Administration (1992) 4 Cal.4th 462, 468. "in determining legislative intent we first look to the statutory language itself. We first look to the words of the statute, giving to the language its usual, ordinary import and accord significance, if possible, to every word, phrase and sentence in pursuance of the legislative purpose." DeCastro lVest Chodorow & Burns v. Superior Court (1996) 47 Cal.AppAth 410, 418. "if the language is clear, and unambiguous there is no need for construction, nor is it necessary to resort to indicia of the intent of the Legislature." Katz v. Los Gatos-Saratoga Joint High School Dist. (2004) 117 Cal.AppAth 47, 54 (citation omitted). Only when an examination of the statutory language fails to resolve an ambiguity, do courts turn to secondary rules of interpretation, such as maxims of construction and legislative intent. See 1d. at 55. The City is attempting to embed ambiguity into a statute, where no such ambiguity exists. The statute mandating that "[a] conceptual site plan for the entire overlay area must be submitted prior to pennitting any project development or subdivision of land within the overlay" cannot be any more clear. Council members need look no further than the words contained in this statute to effectuate its legislative intent. As explained above there is no need to review the statute from a historical context, however, doing so would lead to the same conclusion - that the statue contemplated continued oil production in the face of urban development in the area. The area of land upon which the current development is proposed was transferred by quitclaim deed to the Huntington Beach Company 4815-7618-0224.I LEWIS BRISBOIS BISGAAKD& SMITH u_i, June 7, 2004 Page 4 (which later became the City of Huntington Beach) on May 27, 1960. A copy of this Quitclaim Deed is attached hereto as "Exhibit A" for your review. The grantor of this deed was Pacific Electrical Railway Co. which later became know as the Union Pacific Company, known today as Southern Pacific. While the deed quit claimed the land, it retained exclusive rights: to all of the minerals and mineral ores of every kind and character, occurring five hundred feet (500') beneath the surface thereof,---including...petroleum, oil, natural gas and other hydrocarbon substances and products derived therefrom, together with the exclusive and perpetual right of said Grantor, its successors and assigns, of ingress and egress beneath the surface of said land to explore for, extract, mine and remove the same, and to make such use of said land beneath the surface as necessary.... [Pacific Electrical further reserved the] right to drill and maintain well holes through the said land for the purpose of removing oil. The area of land proposed for development was historically and is currently land which has been utilized for the production of oil. The reservation of rights within this deed to allow for continued extraction of minerals, is indicative of the contemplated importance of the mineral rich location of the land as well as its value vis-a-vis oil production. The Commission cannot simply ignore statute and history and not allow for the 2 acre oil island in their development plan. The City also fails to include years of studies and planning undertaken by the City of Huntington Beach with regards to ensuring its ability to extract its oil reserves. (See studies conducted by the City attached hereto as "Exhibit C") "The most important variable for deciding whether the City should take steps to protect surface areas for future access to iol pools in the amount of oil that would be lost if the surface is completely developed." Land Use Planning in Urban Oil-Producing Arens. February 25, 1982, held in Huntington Beach CA, p. 21, attached hereto as "Exhibit C". "Considering the long history of oil operations in Huntington Beach, as well as the benefits that oil production contributes to the community such as employment and revenues, the City's land-use regulations have traditionally accommodated oil activities." Id at 37 These statements are consistent with the requirements of having oil overlays within the City and the oil islands which allow for continued extraction of this oil. The Commission's failure to provide for an oil island over Oil Overlay"C" will result in almost one- third of the city's reserves to become unaccessible. (See map depicted in Fig. 5.8 on p.33 of the Land Use Planning in Urban Oil-Producing Areas.) 2. THE GENERAL PLAN OF THE CITY CONTEMPLATES CONTINUING OIL EXTRACTION FROM OIL OVERLAY "C" The City next argues that the city's General Plan somehow trumps the Downtown Specific Plan ("DSP"). The City bases this argument on two principles - first that the General Plan was revised 13 years after the DSP and second that the General Plan does not call for the utilization of land oil production in the Oil Overlay "C" area. 4815-761"224.I LEWIS BRISBOIS BISGAARD K SMITH L,P June 7, 2004 Page 5 Contrary to the suggestion made by the City, the DSP supercedes the General Plan for two reasons. First, the City fails to note that the DSP has been revised as late as 2002. Notwithstanding the General Plan, the language of the DSP providing for a two acre oil island remains intact in the 2002 version of the DSP. The legislative body appointed to make revisions to the DSP had, at the time of the last revision, a copy of the General Plan. Changes to the DSP could have been made to exclude the provision for an oil island if the body charged with the revision deemed it necessary so as to comport to the General Plan. However, they chose not to make such a change. Their decision to not change the language of 4.14.03 is consistent with both the historical underpinnings of the city (that of an oil producing city), as well as the beneficial gains to be had by continued oil production. The City's second argument is that the General Plan does not contemplate the inclusion of oil islands in the Oil Overlay"C" area. The City argues that the statute outlined in the City's General Plan should control the Comission's decision with respect to Oil Overlay"C"since it does not provide for reservation of land for oil production in that area. First, the City points to no specific language in the General Plan which is in direct conflict to 4.14.03. The City simply refers to the a "Table LU-4" of the General Plan stating that it does not call for oil production activities over Oil Overlay"C." A table from a site map cannot trump clear statutory language. Second, even if there was conflict between any language in the General Plan and the DSP, the latter would control under two separate principals of law. First because the DSP was revised later in time than the General Plan and secondly because "(a] cardinal rule of statutory construction holds specific statutes control over general ones." Rusheen v. Drews (2002) 99 Cal.App.4th 279, 256, citing to In re Williamson (1954) 43 Cal.2d 651, 654. If conflicting statutes cannot be reconciled, later enactments supercede earlier ones and more specific provisions take precedence over more general ones." Collection Bureau of San Jose v. Ramsey (2000) 24 CalAth 301, 310. Section 4.14.03 not only specifies the intent of the city's developmental requirements within the area of the city in question, it governs what steps need to be taken with regards to developments on land covering Oil Overlay "C" in particular. City cannot point to any statute more specific than 4.14.03, California law requires that deference be given to the more specific statute. 4.14.03 controls should the Commission determine that there is a conflict between this statute and any other. 3. DEVELOPMENT OVER THE ENTIRE OIL OVERLAY "C" AREA POSES A SUBSTANTIAL. PUBLIC SAFETY CONCERN Development of commercial and residential buildings over previously producing oil wells creates a real potential threat to life and property. Development over capped oil wells have occurred in California in the past - often resulting in property damage and loss of life. The major paths for vertical migration of gas are formed by natural faults and fractures. Gas migration from oil and gas fields and associated hazards (1993) Journal of Petroleum Science and Engineering, Vol 9, p. 229. (Attached hereto as "Exhibit B") These breaks or channels in the rock are formed by tectonic activities as well as drilling operations. Id. Wellbores of idle or improperly abandoned wells often result in literal pipeline flow of large volumes of gas to the surface. Id. This is particularly important where the abandoned wells are not properly sealed to prevent gas to 4815-76I 8-0224.I LFWIS BRISBOIS BISGAARD & SMITH UP June 7, 2004 Page 6 migrate along the old wellbore. 1d. There are 128 abandoned wells located at the site of the proposed development. Even if a single one of those is improperly sealed, it can lead to disaster. However, the potential for this problem will exist even if the wellbores are properly sealed. Over time, the ring of the cement around the well casing is damaged by deformation and by chemical decomposition. Id at 230. The breakdown of cement can open the paths for the Flow of gas and liquid behind the casing. Id. There are many examples of wells, that were abandoned to modern standards, in which casing and cement bonds have broken down after a short time due to corrosive waters or other causes. Id. Examples include the 1985 gas explosion and fire in a department store one-half mile north of the La Brea Tar Pits in Los Angeles. Id. at 234 Investigation revealed that gas had migrated up along the P Street Fault and certain wellbores. Id. Twenty three people were injured in that explosion. Id. In 1990 large quantities of methane gas were detected in the Wells Fargo Bank in the Fairfax area, forcing its closure for several months until the gas seepage could be diverted from the structure. Id. Since the 1970's several older abandoned oil wells in that area have experienced gas and oil "blowouts". Id. The wells responsible for these blowouts have had to be re-abandoned. Id. The City must allow for the continued extraction of oil from the Oil Overlay"C" area, if for no other reason than concern for public safety. 4. CONCLUSION The City of Huntington Beach has spent an inordinate amount of time, money and resources since the early 1980's setting out goals for the City. Those goals have included harmonizing oil production with urban development. The City has hosted workshops, conducted studies on the fiscal impacts of oil operations, conducted oil spill contingency planning, and prepared reports on enhancing oil recovery, all in an effort to capitalize on its resources. These goals have been consistent throughout the years. It is no surprise that statutes such as 4.14.03 allowing for continued oil production have been enacted - they are consistent with the goals of the City. By allowing urban development over Oil Ovelay "C", without so much as providing for an oil island in the area, the City will be charting a course which is 180 degrees of the direction this City has taken in the last 30 years in ensuring access to the oil it has been blessed with. If the Commission allows for the commencement of development on land over Oil Overlay"C" while disregarding the statutory mandate of 4.14.03, it is not only is making a decision contrary to long standing objectives of this City, but is preventing access to this mineral reserve forever. Once development over Oil Overlay`C" is complete, it precludes any possibility of future oil extraction from that reserve - oil production companies cannot reach that reserve by lateral or slant drilling because no other land exists within the area which would allow for extraction in this manner. Finally the potential hazards of urban development atop abandoned wells cannot be overstated. The passage of time, combined with seismic activity and improperly abandoned oil 4815-761"224.1 i LEWIS BRISBOIS BISGAARD&SMITH u.P June 7, 2004 Page 7 wells may result in disaster. South Coast respectfully requests that the City continue with the well established goal of continued oil production in the area, and set aside land for an oil island over the Oil Overlay"C" reserve. Ve truly yours, an Brucculen of LEWIS BRISBOIS BISGAARD & SMITH LLP FCB/MMV 4815.7618-0224.1 NLS��IE LE04�lW Rl O� �f` V 1!9!4x3 Jun 04 04 04: 46p SCOC OIL JGH LRW 714 378 5361 p . 2 `ag(M5413 m 446 159 770 0 QUITOLAIM FpF( FOR A VALUABLE CONSIDERATION, receipt of which is !- hereby acknowledged, PACIFIC ELECTRIC RAILWAY COMPANY, a corpora- ties, does hereby remise, release and forever quitclaim to if HCMPINGTON BEACH COMPANY, a corporation, the following described real ro p party In the City of Huntington Beach, County of Orange, 111 State of California, and more particularly described as followa: i t A parcel of land,, situate in the City of Huntington Beach, County of Omige, State of j California, In the Southwest 1/4 of the North- east 1/4 of Section 14, Township 6 satth, Range 11 West, in the Rancho Las Bolaas, as per map recorded in Book 51, Page 14 of Miscellaneous Napa, in the office of the Recorder of said •, County, being all that portion of that certain SO- foot strip of land Second described in deed to 1 S.P.R.R. Co., recorded on December 20, 1905 in Book 123, Page 96 of Deeds, in the office of the Recorder, bounded on the north by the northerly ? line of said Southwest 1/4 and bounded on the �S south by the northerly line of the land described .a In deed to the City of Huntington Beach recorded on October 7, 1931 in Book 5o6, Page 446 of Deeds, In the office of said Recorder. .yam EXCEPTING AND RESERVING, however, to the Grantor, its successors and assigns, forever, the title and exclusive right to all of the minerals and mineral ores of everyldnd and char- acter, occurring five hundred feet (5001) beneath the surface thereof, now known to exist or hereafter discovered upon, within or underlying, said land or that may be produced therefrom, Including without limiting the generality of the foregoing, all petroleum, oil, natural gas and other hydrocarbon substances and Products derived therefrom, together with the 'exclusive and Perpetual right of said. Grantor, its successors and assigns, of ingress and agrees beneath the surface of said land to explore for, extract, mine and remove the same, and to make-such use of said land beneath the surface as is necessary or useful in connection therewith; and other use thereof; which uses may include lateral or slant drilling, digging, boring or sinking of wells, shafts or _ 1 Jun W4 W4 04: 46p SCOC OIL JGH LAW 714 378 5361 p . 3 BaZ5413 vwm447 tunnels to other lands not subject to those reservations and easements; provided, however, that said Grantor, its successors and assigns, shall not use the surface of said land in the exer- cise of any of said rights and shall not disturb the surface of said land or any improvements thereon or remove or impair the i� .i lateral or subjacent support of said land or any improvements c; thereon, and shall conduct no operations within five hundred feet } (5001) of the surface of said land. i In the exercise of said reserved exclusive easements, i Y mineral rights and reservations, Grantor may pool said lands with other lands. The rights of Grantor shall include, but shall in no way be limited to, all subterranean rights necessary, incidental or convenient to the call exercise of the rights reserved by Grantor and shall include the right to drill and maintain well holes through the said land for the purpose of removing oil, gas and other hydrocarbon substances from other lands whether such other lands be adjacent, contiguous or distant from said lands. The above described property hereby remiaed, released and quitclaimed is not necessary or useful in the performance of the duties of said PACIFIC ELECTRIC RAILWAY COMPANY to the public. IN WITNESS WHEREOF, said corporation has caused its z� corporate name and seal to be affixed hereto and this instrument to be 'executed by ita ilia:=Presidad. t-and.General Manager, and i AealBtahC Secretary thexeunto. duly..authorized. DATED: This ZJ ate.,,day.of.May, 1960. ,, , . ,.. PACIFIC $LECTRIC RAILWAY COMPANY r-••- -- Vice-Pre Mdnt k Genera r.. I ATTEST: Assistant-See A. v 2 Jun 04 04 04: 460 SCOC OIL JGH LflW 714 378 5361 p. 4 Maud SL Coo*:of Lae Allsda . lipeb adrr4ptd,• Nalwy 6 rnd kr add ComIF and �. F/fw.w7F�Daraid dnowa m wr to b III, Vies ,,,� A.N. COLS ,lunm bwa b ba I% Ago It Syy PwAonm ffimmr RAI Cho CLwAy CONPAKy tim; C.bcwtw aamk miwm d dw ioatdn ItitiMwwrt� "'bcarwl�ael�ypb Imo�i .f a 8,w I °aAnetaa TVm=ap bud and ofobi md�4 (/ Namp b rsH M 5". �cRwow�mawnrt-cw_-s•.o.a am.��.ce.-t'po asa-Imr. a.ea n.« 666413 FA. 4 RECOR660 AT REQUMY OR TrtLG INS d TRUST CO. IR OFFICIAL RECORDS OF ORANGE COUNTY,CALIF, kP 1S IM0. .. �' RUBY'YdAN1AY8,Cam�1A►mnNr V Exhibit B Journal ofPeiroleurn Scienre and Engineering,9(1993)223-238 223 Elsevier Science Publishers B.V„Amsterdam Gas migration from oil and gas fields and associated hazards A.E.Gurevicha,B.L Endres',J.O.Robertson,Jr,r and G.V.Chiliagara aDryanmene of Civil Engineering,University ofSouthem Caljfo ia.Las Angeles.CA 90089, USa 6813.41orgso Drive.Los Angeles CA 90049. LSe `Farah Engineenotg Im., 15141 E Whittier Blvd..Ste.530. Whinier.C1 90603. USA (Rea:ived September S. 1992:revised version accepted]=nary I I. 1993) ABSTRACT The migration of gas from oil and gas formations to the surface is a problem that gready affects those surface areas where human activity exists. Underground gas storage facilities and oil fields have dcnsonstrated a long history of gas migration problems. Experience bas shown that the migration of gas to the surface creates a seriow potential risk of csplosion,fires,noxious odors and potential emissions of carcinogenic chemicals.These risks must be seriously rxamined for a0 oil and gas operstions located in urban areas. This paper presents the mechanics of gas migration.paths of migration and a review of a few of the risks that should be considered when operating a gas facility in an urban area.The gas can migrate in a continuous or discontinuous steam through porous.water-filled media to the surface. The primary force in this migration of gas is the difference between specific wcighu of gas and water. Intmduetion alive in order to reduce the risk of injury and property damage in this type of area. The un- Natural gas seeping to the surface has re- derground storage of natural gas in depleted sulted in fires and explosions.Over the past few oilfield reservoirs is now becoming a common years these problems have increased in urban practice in urbanized areas. Literature is full areas. In areas, such as Southern California, of examples of problems created by the escape where land has become very valuable, previ- of gas from the reservoir and its migration to ously undeveloped areas overlying existing oil the surface. fields in Los Angeles,California,are now being developed (Endres et al., 1991 ). In the past, Migration of gas gas seeping to the surface in these undevel- oped open areas was safely carried away by lo- Gas migration from the gas source to the cal air currents. Today, migrating gas may be surface is either continuous or discontinuous. contained and entrapped under paved streets, The migration of gas may be the result of dif- parking lots and aructures. In situations like fusion or mechanical mechanisms. These the Fairfax (Los Angeles, California) gas ex- mechanisms for the migration of gas may work plosion of 1985,gas gathered and was concen- either separately or in combination with each trated under paved areas and major commer- other. cial structures. In 1985, this resulted in a gas explosion and fires that burned for several Molecular diffusion mechanism days.An understanding of the mechanisms and processes involved in gas migration is imper- The diffusion of gas is a molecular process. 0920.4105/93/506.00 D 1993 Elsevier Science Publishers B.N. All rights resen'ed. zza G.v.CHIUNGAR ET AL. The driving force for this mechanism is the either unknown or cannot be physically deter- concentration gradient of gas molecules (i.e., mined.A reasonable approximation for the to- there are more molecules of gas in one area tal gas diffusion can be expressed as: than in another, see Fig. 1 ). Over geologic time,the system will seek equilibrium through 1=D h ( 1) an even distribution of gas molecules in all di- rections.This migration-force acts upon the gas where: 1=the diffusion flow intensity (cm'/ at a molecular level. This also is a fora that cm'/s); D=the diffusion coefficient for gas moves small quantities of gas over geologic moving through water-saturated porous rock time. (cm'/s); C=the concentration of gas dis- As shown in Fig. I, if one assumes the case solved in water on the upper boundary of the where gas flow by diffusion is one-dimen- oil or gas reservoir (m'/m'); and h=depth of sional, flowing in one direction only, from this boundary (cm). As this equation is only areas of higher to lower concentrations, the an approximation,the diffusion coefficient, D, largest value for diffusion flow is in this direc- is the average value for the rock through which tion of gas flow. The diffusion coefficient, D, the gas diffuses and is assumed to be uniform is strongly affected by the porosity and pres- within the whole path of travel,h. ence of fracture systems. Many other physical It is difficult to determine the exact value of properties of the rock (i.e.,tortuosity, surface the diffusion flow capacity of geologic forma- chemistry, etc.) can cause this value to vary. tions in the field; however, an approximate The exact diffusion flow rate in geologic for- value can be determined. The term C repre- mations cannot be established because the sents the solubility of gas in water and the term many variables controlling diffusion rate are C/h is in fact a solubility coefficient. Its typi- cal value would be 0.3 (m'/m')/MPa, which is equal to 0.003 (m'/m')/m for a column of Surface Z fresh water. Assuming a diffusion coefficient. D,of 10-6 cm'/s, for this example, the calcu- lated value for / is approximately 3X10-" cm/s for gas diffusion flow through a horizon- tal cross-sectional area of I cm'. This value is undoubtedly larger than the actual values of diffusion intensity in the field due to the as- sumption of maximum values for flow. Gur- Difrusion Gas Flow evich ( 1970) measured the gas-saturation val- ues of formation water samples taken during well tests at various depths above the caprock of oil reservoirs. At a distance of several me- ters above the caprock, he found that the gas content of the water was about one-half or a w�; Gas pal ,;_.. C third of the maximum gas solubility value in -:S � 1 water. The solubility of natural gas to water has �-- L been studied by many authors. Dodson and the 1. Schematic diagram of sl=conc ni diffusion I% rn in Standing ( 1944) showed the effects of water the gas pool to the surface f�=cuncentraliun of gas in Salt❑IIy and pressure upon the solubility Of ,,a,rr natural gas in water. Figure 2 can be used to GAS MlGP_4TI0N FROM 011-AND GAS FIEWS AND ASSOCIATED H VARDS 225 80 where Q=the quantity of gas absorbed by the water (cm'); lathe diffusion flow intensity NoN,W Cm (cm/s);t=time necessary for the water stream x 64 topassabove the oil or gas pool (s);L=length o�o 0 of travel path of water through the zone above to the oil or gas pool (cm);and v=water velocity 3 `D (cm/s). e Assigning typical values for a path (L)of 10 C a 2 0.o Ian and a flow rate (v)of I m/day for the water u .••• stream and substituting in Eq. 2: =wa I0,0001111 .. 500on° Im/86,400s (0.20) ° 100 19p 260 w x 5.2 x 10-'cm' Temperature, OF Thus, although some writers have given the Fig. 2.Comparisons of solubilities of methane and natu- diffusion process credit for migration of gas to talgas in water.l Modifiedafler Culberwn and McKetta, the surface from gas sources, gas diffusion I951.rig.41. through rocks yields very low quantities of gas at the surface, as demonstrated by the above calculations. estimate the solubility of natural gas in for- Smith et al. (1971 ) estimated total hydro- mation waters at various temperatures and carbon losses by diffusion from a gas accumu- pressures. lation at a depth of 1740 m (5709 ft), temper- Commonly, the upward diffusion of gas en- ature of 70°C and pressure of 172 atm, at counters moving water, associated with near- 2.8x 10' m' (99x 10' ft'). These values are surface water aquifers. If the water is not to- tally saturated with gas, the gas moving up- States.cal for oil and gas reservoirs i the United Sta Their data, shown in Table 1, indicate wards can be absorbed into the moving water that it will take 140 million years for methane and carried off to other areas. This quantity of and 170 million years for ethane to migrate to gas absorbed by a unit column of the water the surface from a depth of 1740 m. This cal- stream can be expressed as: culation assumes that the diffusion losses were L replaced by source rock generation of gases in Q=71=7 i. (2) order to maintain the accumulation at a con- stant size and composition. This would be an TABLE I optimistic assumption. i.e., the actual quan- tities of gases migrating to the surface are likely Losses of rcwrsoirgas b� stead%-state diffusion from a depth even less. Clearly. vertical diffusion from oil- of 1740m (modified after Smith et al. 19711 field reservoirs buried at depths around 1700 Time to reach surface Hate of loss to surface m (5600 ft) is not the mechanism responsible o^s) m':m / I for the migration of gas to the surface that is Mcihane 140 - being observed in typical oilfields. Ethane 170 0.16 Hunt (1979, p. 433) has also pointed out Propane _30 0.06 that the vertical diffusion of hydrocarbons autansti 2711 it 0' _ from oil and gas reservoirs is too low to ac- 226 G.v.Cl11LINGAR L r AL count for surface hydrocarbon anomalies. the top of the gas globule (see Fig. 3) that In summary, as a mechanism working on a overcomes the capillary pressure at the upper molecular level, diffusion moves quantities of gas-water interface,where gas displaces water gas much too slowly,even under the most fa- and initiates the upward movement of the vorable conditions,to be significant in driving globule. gas toward the surface. Whatever the globule's shape, this excess pressure (dp) shown in Fig.3,will be equal to Dixvotinooav-phase migration of gas the difference in pressure in the globule and in the corresponding water column. This pres- (1)Mechanism ofintergranularJlow sure is equal to the difference of globule and water specific weights times height h: The migration of oil and gas globules through dp=(y _yr)h (3) water-filled porous rocks have been investi- where y_.and y,are the specific weights of water gated by Aschenbrenner and Achauer (1960), and gas,respectively,and h is the height of the Gurevich (1969),and many others.This type gas globule. In the case where the specific of mechanism of flow (see Fig 3) consists of weight of water gas or oil globules migrating through the water- (Y.) is I.0 g/cm ,the specific filled rocks having intergranular or micro `Weight of a gas (yr) is 0.2 g/cm , and depth t (h) is 2000 in,the pressure difference is about ure porosity. It is assumed that every migrat- 200 kg/ern ing globule is sufficiently larger than the mi- The capillary pressure, P,,t e the upper gas- crofracture or pore throat so that the gas flows through water-filled rock. ment of the globule depends on the values of water interface that resists the upward move- These globules move slowly through porous surface tension, intact angle and pore rocks with small voids and, for small globules, nel the pressure losses to overcome friction,or re- radius (see Fig. 4).The capillary pressure may sistance to flow,are often negligible.Except for may be determined by the following equation: some very special cases of intensive under- Pc=20 oso (4) ground water flows,it is the excess pressure atr »e„„o Water a µr Gas eater _ tv rY1R�� ^V Rockc�' popm Fig. 3. Gas-water mtcriaa• in ua ter-wet pore throat Fig.3,Schematic diagram of ocessi,'c pressure formation. 1 capillar. channel I. GAS MIGRATION FROM OIL AND GAS FIELDS AND ASSOCIATED NAUADS 227 where a is the surface tension, 0 is the contact (2)Mechanism of buoyant flow angle and r is the radius of the pore channel. To enable the globule to move upwards, the In the situation where the gas globule size is excess pressure should exceed the capillary less than that of the flow channel, i.e., a wide pressure: fracture,the entire globule is able to float up- wards. Figure 5 shows an example of a gas dp>Pr (5) globule moving upwards due to buoyancy forces. The buoyancy force, Fb, moves the Equation 5 can be rewritten in the following globule upwards. For a spherical globule, this form: force is equal to: h> 2acosO (6) Fb=4R'(Y.—Yt) (7) row—Y9) where R is the radius of the globule. The value for surface tension at the gas—water The frictional resistance, according to interface depends on temperature and pres- Stoke's Law,is: sure. It is about 40 dynes/cm at a pressure of 200 kg/cm' and a temperature of 60°C. The Fr=6nRvu (8) angle 0 may be assumed to be 60° (water-wet). where p is the dynamic viscosity of water and The radii of pore throats in coarse, medium v is the velocity of the bubble floating up.This and very fine sands are about 0.02, 0.005 and globule will remain static in the rue of down- 0.001 cm, respectively- The values of h, nec- ward flow of water if the forces of buoyancy, essary for a gas globule to begin moving up- Fb,and friction, Fr, are equal. Equating Eqs. 7 wards in these types of sands will be 2.5, 10.2 and 8 one will obtain a formula for the critical and 51.0 cm.Clays have smaller pore openings velocity,tc and thus the gas globule height necessary to overcome capillary forces will be greater- A t,=20. —Y.)R' (9) pore radius of 10 mm and lower is common 9p for clays. Thus, initial heights, h, of at least 5 Assuming (I ) a temperature of 25°C, (2) a in are necessary. pressure of 20 kg/cm'. (3) a specific weight I gas pools or gas caps,the height of a con- of methane gas of about 0.015 g/cm', (4) a tinuous gas body almost always exceeds 5 in water viscosity under these conditions of ap- and often is 20 or 30 m. In most cases, there- fore, upward migration of gas through a cap- rock is possible. In recent unconsolidated clays that did not lose their colloidal properties,pore channels are blocked with adsorbed water, partly or completely, at depths at which tem- peratures are below 50°C. Gas cannot pene- trate such a clay mechanically, i.e.. as a free phase. After gas enters the caprock, its migration s.nf :gl rate depends on the rate of water displace- y aWaier ment. At low permeabilities of caprocks, mi- gration is very slow and geologic times are re- quired for the gas to reach the surface. Fig. 5.Gas hubble floating-up in an open fracture. 0 228 G.v.CHILNGAR Er AL proximately 10-' poise,and (5) a gas bubble kg/cm'/cm. Assuming that density, p, of gas with the radius of 0.1 cm, the critical velocity is 0.015 g/cm' (at a pressure of 20 kg/cm'), is equal to 0.22 cm/s. Thus, a bubble of gas permeability k is 10'D,and the gas viscosity can float upwards in a fracture even in a down- p is 1.5 x 10-' cP, v will be 7 x 10-' cm/s or ward moving stream of water having a veloc- 60 cm per day. Actual rates of the upward gas ity <0.22 cm/s. migration depend on the permeability of such vertical or subvertical zones of rocks and Coathmou"hase gas migration mostly on the lowest permeability along this path. Continuous gas phase from a gas pool to the surface or to another pool, lying at shallower (2) Continuous-phase migration through open depth,can flow through vertical and subverti- fractures cal zones of porous and/or microfractured rocks of higher permeability and/or through Gas flow through fractures can be thought large open fractures. of as a "pipeline" type flow. In the case of an oilfield, large fractures, faults or man-made (1) Continuous-phaseJlowofgasthrough channels (wellbores) can serve as gas-filled porous rocks paths of migration, or "pipelines". This type of gas flow occurs in the gas-filled zone be- If owing to facies variation, Iithological het- twcen the surface and the top of the water ta- erogeneity, or presence of a microfractured ble. The force moving the gas is the potential zone there is a vertical or subvertical zone or drop between the point of origin and the end sequence of zones of higher permeability above of the path or channel. a gas pool,then gradually a continuous gas flow The volume of migrating free gas along con- will be established. In such a flow, there is no tinuous gas-filled paths is dependent upon the need to overcome capillary forces and displace width of gas-filled fracture. In general,gas mi- water. Owing to lower density, pressure at the gration through gas-filled paths is capable of top end of a static gas column will always be producing significant quantities of gas. The higher than that at the top of the water static volume of gas found at the surface is depen- column through which the gas has to move (see dent upon the mechanical aspects of the path Fig. 3). traveled by the gas and the pressure gradient. It is possible to make an order of magnitude Physical features of the path such as fracture estimation of the flow rate in the subvertical width, length. saturation with water. tortuos- column of gas saturating permeable rocks. To ity,absolute and relative roughness of the frac- avoid complex calculations, associated with ture walls. etc. have a great effect upon the high compressibility of gas,a differential form quantities of gas that can move along the path. of equation is more convenient. Head loss due to friction,h, is equal to: At any depth, the flow rate of gas will be: I I" 1 _kI —grad e+,r) ! 10) rt_y III where jis the friction factor. I is the length of where k is the permeability coefficient. If bot- channel,d is equivalent diameter of cross-sec- tom and top pressures in the gas column are tional area, r is the velocity, and g is the grav- equal to water pressures, then the value of the itational acceleration. pressure gradient,grad p.will correspond to the It is obvious that fluid flow through open specific weight of water ( I g/cm'). i.e., 10-' fractures is incomparably easier. because po- GAS MrGRAr70N FROM OIL ANDGAS PELDS kXD kSSOC14rED HAZARDS ::9 rots media provide much more frictional re- clean simple break in the geologic structure. sistana to flow than open spas of a fracture. These zones of fracturing are often associated It is possible to [Hake an order of magnitude with geologic structures where beds are in- estimation of such gas migration using the tensely folded. Fractured zones are also asso- Bousainesque's formula in a differential form: ciated with localized tectonic activity or fault- w= ing. Proper evaluation of these fault zones is D 12 (-tldp+yR) (I2) essential in establishing integrity of an oilfield µ and in preventing gas migration.This evalua- where w is the fracture width.At the same val- Lion is even more important in those instances uses of presstue gradient,density and viscosity where older oilfields are converted to under- and assuming w to be I cm, v will be equal to ground gas storage fields. Usually, normal 5 m/day. faults are more permeable than reverse faults. In summary, continuous-phase gas migra- Fractures arc created in the layered rock as lion can produce the greatest volumes of mi- a direct consequence of oilfield operations, grating gas, but is less common because it re- such as drilling,cementing, acidizing, and re- quires a continuous path for the gas to migrate pressurizing of wellbores and depleted reser- through. As discussed under "paths of migra- voirs.The fractures are potential paths for the tion", man-made channels (wells) and fault migration of gas. Wellbores of idle or improp- zones are the most likely zones where this type erly abandoned wells often result in literal of gas flow will occur. pipeline flow of large volumes of gas to the sur- face. This is particularly important where the Paths of gas migration abandoned wells were not properly scaled to prevent gas to migrate along the old wellbore. The major paths for vertical migration of gas At the time of drilling the well,many fractures are formed by natural faults and fractures. are formed owing to the percussion activity of These breaks or channels in the rock were the drill bit. In addition,cementing operations formed by natural lithification processes and pressurize the wellbore further with the poten- tectonic activities. Additional avenues of mi- tial of creating additional fractures. During the gration may be created by drilling operations cement squeezing operations,the wellbore may which not only create a hole (or wellbore) be even further hydraulically fractured. These through the strata but also cause fracturing vertical fractures may extend for tens of feet around the wellbore. This problem is often from the wellhore depending upon the char- compounded by inadequately sealing the space acteristics of the formation and the injection between the wellbore and the well casing or pressures used for placement of the cement. improperly filling the fractures around the The cement will fill some of the larger frac- wellborc itself in an attempt to prevent future tures surrounding the casing, but the cement gas migration (poor cement bonding). Also, particles cannot enter the smaller fractures production of petroleum can cause subsid- away from the wellbore. The end result is that cce, which can generate fractures or cause a fracture system is created parallel to the well- movement along existing faults. bore forming a potential path for the migra- For gas migration,the most important paths tion of gas. or channels are faults, because they tend to Acidizing. a common practice in revitaliz- have wider breaks (openings) and longer con- ing oil wells, causes acid to enter the pore tinuous paths through the rock layers than channels and fractures of the reservoir,usually fractures. Many existing faults consist of a zone under high pressure. fracturing and causing of fractured and broken material rather than a etching (widening) of pre-existing fractures. 23O GY.Cf11LINGAR Er AL Over time, the ring of cement around the A fracturing zone may arise from, or be Se- well casing is damaged by deformation (caused riously aggravated by, nonuniform compac- by tectonic and seismic movements and sub- tion and subsidence of sediments. Deforma- sidence owing to oilfield operations) and by tion can also take place as a result of difference chemical decomposition. Formation fluids in the compaction rates of clays and sands. usually corrode both the cement and casing, Differential movements occur in many oil- generating paths for future migration of gas and fields, in adjoining fault blocks, because of fluids by breaking down the intended cement preferential production or injection of fluids seal. The breakdown of the cement can open within the various fault blocks. Subsidence as paths for the flow of gas and liquid behind the a direct result of oilfield production in the casing. Corrosion also results in casing leaks Wilmington Field, California, has been esti- (holes).Idle and/or abandoned wells are likely mated to have been as great as 20 f9. Even sub- candidates for channels of communication to sidence of a few feet can result in the fractur- the surface of gas because of their deteriora- ing of the subsurface layers (creation of tion with age. Oil wells drilled and completed fractura),cause enlargement of existing faults, many years ago were often abandoned accord- and facilitate gas migration to the surface. ing to different standards than those used to- Nonuniform subsidence has the added prob- day. The cementing materials used in their lem of causing cracks in sidewalks,streets,and completion were also of poorer quality, and buildings. often cement was not used at all. There are, As shown in the Wilmington Oil Field, Cal- however, many examples of wells, that were ifornia, reinjection of fluids into a depleted oil abandoned to modern standards,in which cas- reservoir not only can stop subsidence but can ing and cement bonds have broken down after also result in some rebound. Waterflooding a short time due to corrosive waters or other commonly creates fractures in the reservoir causes. and the rocks above the reservoir. In general, . ����}} Surtoco �. 2 r?+ Zone where gas can escape from welbore 7*2-:' atv-: Fig.G.Schelnallc SHUN ing wIh're gae Cart lea,e the aelnroic through holes or damaged Casing. GAS MIGRATION FROM OIL AND GAS FIELDS AND ASSOCIATED HAZARDS 231 reinjection of fluids breaks down cement bonds (1068 in), formation pressure (pb) is 200 psi in the existing wellbores and in some cases may (14 kg/CM2), temperature (T) is 307°K, and create micro-quakes which reflect the actual the supercompressibility (z) is assumed to be fracturing of the formations. Constantly 0.98. The wellhead pressure of gas filling the changing tension further widens fractures,ere- wellbore was found to be approximately 185 ating ever larger channels for gas and, possi- psi (13 kg/emu).When comparing the hydro- bly, liquid migration. In older, idle and/or static water pressure with the internal wellbore abandoned wells, repressurization of the oil casing pressure (see Fig. 6), it can be deter- reservoir often forces gas and fluids toward the mined that from the surface to a depth of 426 surface along these man-made channels. ft (130 m), the pressure within the wellbore In abandoned and idle oilfield wells, gas exceeds the pressure outside of the wellbore. gradually seeps upwards and accumulates in This zone can be called the"zone of escape". the upper portion of the wellbore (see Fig. 6). Any holes in the casing and the surrounding In time,water is squeezed downward out of the cement sheath in the annular space between the wellbore by gas which has migrated into the casing and the wellbore, within the calculated upper portion of the wellbore (replacing the "zone of escape",will result in gas leaking out water). The upper portion of the gas-filled of the wellbore and then toward the surface. wellbore has a higher pressure than that of the The authors, surveying abandoned and idle formations surrounding the well. As a result, wells in several older oil fields,have noted high the gas seeps out of any openings in the well- methane gas readings in the soil about many bore (such as those where corrosion and tec- older wells. The most likely source of this gas tonic movements have damaged the well cas- was determined to be the gas escaping from the ing and cement) into the adjoining rock layers. wellbore. Often, water in shallow fresh-water sands can be very corrosive resulting in holes in the cas- Sources of free gas for migration ing. Consequently, one can anticipate gas mi- gration into the surface soils from the older Gas held in solution in an oil reservoir is not wells. free to migrate. During the course of oilfield The gas pressure of an idle or abandoned well production operations, as fluid is produced Filled with gas can be calculated using the fol- from the reservoir about the wellbore,the drop lowing equation: in pressure liberates the gas held in solution. pr=pbexp{— (0.000341Dp): (zt)} ( 13) This frec-gas helps to replace the produced fluid.The free gas can migrate upward (due to where pg and pb are pressures at any distance differences in the specific weight between the D from the bottom and at the bottom of the gas and the surrounding fluids) to the top of wellbore, respectively (kg/cm'); D is the dis- the reservoir (Zone I) gathering under the tance from the bottom of the hole to the point caprock where it forms a free gas zone. This of interest (m);p is the gas density relative to free gas escapes through the caprock due to that of air (natural gas has a value of approxi- either the natural fractures in the caprock or mately 0.7); z is the average gas supercom- man-induced fractures. The man-made frac- pressibility (deviation of a gas from ideal gas tures in caprock arc generated by the wellbores behavior); and T is the average gas tempera- penetrating the caprock, fracturing pressures ture in the borehole (°K). occurring during oilfield operations,or by sub- An example for a well in a severely depleted sidence as a direct result of the production of reservoir is as follows: fluids. Once through the caprock, the gas can The depth of the reservoir (D) is 3500 ft follow faults and fractures found in Zone III. 232 0 V.CatUNGA ct w The major paths of gas migration in this Zone gas separates from fluids and then moves up- are the fault zones and fractures that occur dip as a consequence of the difference in spa naturally in folded and faulted reservoirs or the cific weights between the gas and fluids. This man-made paths found around wellborn as phenomena is often referred to as gravity discussed earlier. In Zone III secondary gas drainage,i.e.,oil moving downdip and gas ris- traps can often be found where layers of shale ing updip. Production of fluids from the res- or other impervious layers slow down the up- ervoir frees great volumes of gas, which then ward migration of gas and permit it to gather. becomes available for migration toward the Zone IV represents the area between the water- surface. table and the surface. Continuous gas phase The caprocks of most oilfield reservoirs do flow often occurs in this zone through frac- not have sufficient sealing capacity to stop the trues formed by subsidence. In general, the migration of free gas.Only a few reservoirs are production of oil from a reservoir generates found with primary gas caps indicating that the free gas which then is free to migrate along migration of gas through their caprocks is very various paths to the surface (see Fig. 7). slow. When wells are drilled through these In dipping oil-producing formations, as caprocks,and subsidence occurs later as a di- fluids are produced from the reservoir,the free rect result of production of reservoir fluids, FS 00 �g n_ II N-•oov'.vo:a.topes r Wma tmq T 116, 0 _ Sc condcr\'CdICCfIX 2 _e .. lore i.Desna' Cids \\\ Fig 7. Schematic diagram shooing migration of gas from resen-ou to sccondar. corator Zones and to surface. 7hc afro.,shoo.potential paths of gas migration. OAS MIGRATION FROM OIL AND GAS FIELDS AND ASSOCIATED HAZARDS 233 fractures form in the caprock,which can serve face and underlying reservoir were analyzed to as paths for the migration of gas. Most reser- determine the origin of gas and oil migrating voirs, especially prior to production, do not to the surface. It was determined that the gas have a gas cap because most of the gas is held could be migrating upward only from the oil in solution and is not free to migrate. pools below. Soil gas probe monitoring data Most secondary and tertiary recovery oper- gathered since 1985 were also examined to help ations will displace the free gas in the reser- determine the origin and paths of migration of voir. In many instances,fluids (water) are in- gas to the surface. jetted into the reservoir to increase the The Salt Lake Oil Field, California, which production of oil. These operations use water has been heavily produced since the early to supply the energy to drive oil toward pro- 1900's, underlies this area. As a result of oil during wells.This water displaces the free gas production, the reservoir pressure has sub- in the reservoir, forcing it to migrate due to stantially declined. The volume of free gas in pressure drops.This free gas is then able to mi- the reservoir has been increased by the follow- grate along the paths described above toward ing: (I ) As the fluids are produced from the the surface. Experience has shown that the lat- reservoir,they are replaced by Gee gas that was eral migration across some faults within the oil formerly dissolved in the oil (and water). (2) pool can occur when the differential pressure There has been injection of free gas into the exceeds 200 psi (also see Chapman, 1983,pp. reservoir itself. (3) Owing to production from 245-251 ). steeply dipping reservoirs with gravity drain- age drive gas moved updip and now occupies Examples of hazards resulting from migrating large portions of the reservoir. In addition, gas there has been considerable reinjection of water into the reservoir, which has displaced (1) La Brea tar pits, Los Angeles. California the free gas and pushed it toward the higher portions of the pools. Following a path similar One of the best known examples of an area to that described previously, this free gas es- of extensive oil and gas seepage to the surface caped from the reservoir along several faults is that of the La Brea Tar Pits, located in the and wellbores penetrating the field. The faults Fairfax area of Los Angeles, California. After in this area are good conduits for gas and oil a rain, bubbles of gas can be frequently ob- migration. The production history of the Salt served in the cracks of streets and other paved Lake Field also indicates that water has crossed areas. In depressed areas,a significant volume the faults where the pressure differential across of oil has migrated to the near surface, where the faults exceeded several hundred psi. The it has degraded into a thick tar-like substance. sealing properties of several faults to the [at- There is also a loss of lighter hydrocarbons ml migration of gas and fluids appear to have during the migration of oil to the surface. The been damaged by oilfield production tar, gathered in several depressions, has trap- operations. ped and preserved many now extinct animals and birds. Small accumulations of tar can also La Brea Tar Pits be found in cracks in the paved parking lots, The studies by the authors revealed that the sidewalks and streets throughout the area.The gas and oil appearing at the La Brea Tar Pits authors made a detailed study of the La Brea have migrated to the surface from the under- 'Far Pits area. Geologic, well logging, and pe- lying reservoir. The writers believe that the troleum production data were gathered and path of gas and oil migration from the reser- analyzed. Gas and oil samples from the sur- voir to the surface at the La Brea Tar Pits was 234 G.v.CH ILI NGAR Er AL. along the 6th Street Fault that intersects the until the gas seepage could be diverted from underlying oil field at a depth of approxi- the structure. High methane gas concentra- mately 4000 ft and surfaces directly under the tions have been detected under the play- tar pits. Gas and oil also appeared nearby in ground of a nearby elementary school. Since an underground parking area of a large apart- the 1970's, several older abandoned oil wells ment building. The oil and gas migration path in this area have experienced gas and oil"blow- was traced again to the 6th Street Fault. outs". These wells have had to be reaban- doned. There is oil and gas leakage from sev- Ross-Dress for-Less Department Store gas eral other abandoned wells in the area. explosion Throughout the area,there is evidence of gas At a location approximately one-half mile migration along faults and abandoned wells. north of the La Brea Tar Pits, a gas explosion There is evidence that the ongoing oilfield op- and fire destroyed the Ross Dress-for-Less erations in the underlying oilfields have aggra- Store on March 24, 1985.Twenty three people vated the problem.Production operations have were injured. Investigation by the authors freed gas that was once held in solution, pro- showed that gas had migrated up along the 3rd viding a gas source for migration to the sur- Street Fault and certain wellbores.After the gas face. Water and gas injection operations have explosion in 1985,one vent well,80 It in depth, forced gas to migrate within the reservoir and was drilled to bleed off the natural gas in the seek paths of migration toward the surface. soil. Several shallower probe holes, approxi- Wells abandoned in the 1920's through the mately 13 ft in depth, were also drilled in an 1940's were not properly sealed off and, as a effort to monitor the gas concentrations in the result, provide additional paths for gas migra- soil. tion to the surface.There is a risk of gas migra- In 1989,the soil gas monitor wells indicated tion into the homes, apartments and commer- that explosive volumes of gas again were cial structures which have been built over this building up in the soil. The concentration of area.The cost of reabandoning old wells would gas in the soil had buildup above the soil gas be very high, even though there is strong evi- explosive limits.The reason for the buildup of dencc of gas leakage throughout the entire area. gas in the soil was that the gas vent well near Much of the commercial area has been paved the Ross store had become plugged with de- over, thus trapping gas migrating to the sur- bris, preventing the accumulated gas from face and not allowing it to dissipate into the venting to the atmosphere. This situation was atmosphere. It is this trapped gas under build- corrected, resulting in a drop in gas pressure ings, parking lots and school yards that is cre- and concentration of gas in the soil. In 1992, ating a dangerous situation and potential cx- the monitoring probes revealed an overall in- plosion hazard. Detailed studies, and surface crease of gas concentrations in the subsurface gas monitoring, along with changes in oilfield near the 1985 explosion site. This highly de- production practices need to be made to pre- veloped area is situated directly over several vent future explosions. paths of gas migration from the underlying oilfield. Examples of gas problems at other proper- ties surrounding the Fairfax area are the smell (3).Sylmar tunnel explosion of gas and gas-oil-water leakages from aban- doned wells. In 1990, large quantities of meth- In 1971, a tunnel (approximately 5 miles ane gas were detected in the nearhy Well Fargo long) in the Sylmar area of southern Califor- Bank. forcing its closure for several months nia was being excavated for a future water GAS MIGRATION FROM OIL AND GAS FIELDS AND ASSOCIATED NAZSRDS 235 Project. The excavation had proceeded un- explosion hazard similar to what occurred at eventfully until the tunneling machine en- the Ross store. countered a fault plane and a huge explosion occurred. 17 workers were Wed. (1)Montebello gas storage field. California A detailed study revealed that the tunnel had intersected a fault zone that extended to a The Montebello Oil Field,California,is uti- nearby oilfield. Natural gas from that oilfield lized by a gas company to store large volumes had migrated along the fault plane and had of natural gas which is transported into the Los filled the fault zone with natural gas.The tun- Angeles basin from sources out-of-state. The neling machine,upon contacting the gas-satu- large storage facility is used to reduce the rated fault zone,set off the explosion.Consid- quantities of gas that would have to be shipped eration of gas-saturated fault zones had not into the Los Angeles area by pipeline during been a part of the design of this project. periods of high demand, namely,by pumping in more gas than required during periods of low demand. The gas storage facility also helps to Gas storage fields and related problems even out the demands for importing gas dur- ing a typical year of operation. The gas is pumped into the reservoir under high pres- It has become relatively common practice to sure, which often exceeds prior oilfield utilize depleted oilfields for the purpose of pressures. storing large volumes of natural gas under- Prior to convening the Montebello field to a ground.The economics are such that it is more gas storage facility, many of these wells had economic to store gas in underground reser- been abandoned using standards that were less voirs than construct an equivalent surface tan- stringent than those required at present. The kage. In California, for example, gas is trans- old oilfield also contains several fault planes ported in from out-of-state through pipelines. which are potential paths for gas migration. The gas is then stored in several underground The gas company began storing gas in a por- reservoirs until needed by the consumers. tion of the Montebello Field,California,in the These storage fields operate under large pres- early 1960's. By the early 1980's,significant gas sure fluctuations, dictated by seasonal varia- seepages were discovered at the surface within tions in the demand for (and usage of) natu- a large housing development above the gas ral gas.Sometimes these storage pressures even storage. Many of these gas seepages appeared exceed the original oilfield reservoir pressure. to be associated with poorly abandoned wells. This substantially increases the risk of gas The gas seepages endangered homes located on leakage because of overpressurization and re- the surface and required evacuation of fami- sultant fracturing of the geological formations. lies on numerous occasions.As a result,the gas This risk is increased even more by the pres- company undertook a gas monitoring program ence of high-density housing development over to assess those areas that were exposed to the the gas storage fields. highest risk. In some areas, the seepage was so All of the previous discussion herein relat- high that gas company purchased and tore ing to gas migration from an oilfield to the sur- down several houses in order to reabandon face is applicable to concerns associated with several previously abandoned oil wells. These underground gas storage facilities. Further- areas were then landscaped and left more, these underground gas storage facilities undeveloped. are frequently located in urban areas where gas. This gas storage project continues to operate migrating to the surface, can create a fire or today. 236 G.V.CHILINGAR F7 AL (2) Mont Belview gas storagefield, Texas (4) Briefnotes on hazardsfound in other gas storage projects In October 1980, a serious gas leak devel- El Segundo Oil Field, California oped in a gas storage field located in Mont Bel- A natural gas and propane storage was set view, Texas, a suburb of the greater Houston area. The gas seepage was detected when an up. Leakage occurred along fault planes and a housing development was threatened. A rec- explosion ripped through the kitchen of a ommendation was made for a 8 million dollar house. This explosion occurred when the venting system to protect the homes. The gas homeowner turned on the dishwasher. More storage field was shut-in. than 50 families were evacuated from their homes as a result of the explosion and associ- Honor Rancho Oil Field, California ated gas leak. The event caused severe finan- Lateral migration of gas along faults from the cial difficulties for the city that had to pay for gas storage project into the nearby Tapia Oil housing and lodging for the displaced families. Field,California, has significantly reduced oil Gas identification methods showed that the production in several Tapia producing wells. source of gas came from the gas storage facility. Vertical migration of gas has been noted along nearby faults. (3)Playa Del Rey gas storage project. California Huntsman gas storage project, Nebraska Gas leakage occurred from the gas storage project into an adjoining oil and gas producing The playa Del Rey gas storage project is in a field operated by a different company. The portion of the Playa Del Rey Field,California. large lateral migration of gas occurred through The depth of the storage zone ranges from 5400 the geological structure which had been erro- to 6400 ft. The pilot storage project was initi- neously thought to be impermeable. Legal liti- ated in 1942 and the project was expanded to gation occurred over the fact that the second full-scale operations in 1943.The State of Cal- company had resold the same gas to the gas ifornia, Division of Oil and Gas (D.O.G.) company several times over. have reported the lateral migration of signifi- cant volumes of gas to the north and west.They Summary also noted that a differential pressure of about 300 psi was required to produce the lateral Underground gas storage facilities, espe- movement of gas through the formation. It was cially those utilizing depleted oil fields, are estimated in 1953 that 25%of the injected gas subject to the same gas migration hazards as migrated to the adjoining oilfield. In this case, producing oilfields. There are two areas of the oil company returned the gas to the gas concern: (I ) existing fault planes and fracture company to keep losses at a minimum. The systems,and (2) abandoned, idle and produc- D.O.G. noted that the overall loses, including ing wells. These require a thorough evaluation the "cushion", fluid replacement, and en- to establish if the gas storage facility can be trapped gas was about 13%. safely operated.This is particularly important There have been numerous complaints by in an urban setting where there are human ac- landowners about noxious odors from this fa- tivities. It should also be recognized that even cility. The authors believe (hat a good portion if the reservoir can trap and hold fluids, it of the "lost" gas is migrating up around the might not safely hold pressurized free gas. abandoned wells and along fault planes. Generally speaking, it is not advisable to lo- GAS MIGRATION FROM OIL AND GAS FIELDS AND ASSOCIATED HAZARDS 237 sate an underground gas storage facility near (4) Underground gas storage facilities have an urban setting, because buoyant and pres- demonstrated a long history of gas migration sure differential forces will cause gas to mi- problems.Gas migration hazards,however,are grate to the surface where it can create an ex- aggravated in those facilities where pressures plosion hazard. Continuous gas monitoring is are increased to levels beyond the original oil- essential for the safe operations of these facil- field pressures. Experience has shown that gas ities, especially in areas close to fault planes storage facilities can create a serious risk of ex- and abandoned wells.The anticipated life of a plosion and fire and should not be placed un- gas storage facility is probably not more than der urban settings. It is virtually impossible to 50 years. But even if the facility does not leak assure that the gas will not migrate to the sur- initially, it will with time. The important fac- face. Especially in the case of earthquakes,the for is not"if,the storage facility will leak,but fault plane zones may become more permea- rather"when". ble and there could be an upsurge of gas to the surface. The potential fires, especially in the Conclusions presence of winds,could be disastrous and un- controllable by local fire departments. In ad- The main conclusions can be summarized as dition,the soil saturated with gas may lase its follows: cohesive properties and convert to (I) The primary force controlling the mi- "quicksands". gration of gas from the oil and/or gas reservoir To avoid catastrophic events as described in to the upper layers and traps (secondary gas this paper, a fundamental awareness and un- accumulations) and eventually to the surface derstanding of gas migration, paths of migra- is the difference between the specific weight of tion and hazards would permit taking preven- water and that of gas. tative steps,such as monitoring of(I ) soil gas, (2) Gas,oil and water do migrate along fault (2) oil and gas production from underlying planes. Gas, oil and water are also known to oilfields, (3) older improperly abandoned oil migrate along fracture systems and behind wells, and (4) all oilfield operations that gen- wellbore casings to the surface.The volume of erate free gas and fractures. gas migrating toward the surface is directly re- Continuous monitoringof soil gas usingdeep lated to the type and width of the path along probes may serve as an earthquake predictive which it migrates. technique. (3) Gas migrating along existing faults and man-made paths can create surface hazards if the gas is allowed to concentrate in localized Editorial Comment(G.V.C.) collector zones (secondary traps),especially if they are near the surface. It is not advisable to build over abandoned or idle wellbores. Over The managing editor, who is also the co-au- time, the cement and well casing deteriorate thor of this paper, firmly believes that under- resulting in the creation of paths for gas migra- ground gas storage and oil and gas production tion to the surface. Also,structures should not in urban areas can be conducted safely if be built over fault planes,especially those that proper procedures are followed. The analysis intersect oilfield reservoirs which contain sig- presented here is a big step in the right direc- nificant quantities of natural gas. In urban tion. After recognition of the existing problem areas, this migrating gas can cause fires and/ proper safety operating procedures can be eas- or explosions when it migrates into confined ily developed. The writers are engaged in the areas of the structure. research in this area. 238 G.V.CHILINGAR ET AL References ume-temperature and solubility relations for natural gas-water mixtures. Drilling and Production Prac- Aschenbrenner, B.C. and Achauer, C.W., 1960- Mini. trees,API,pp. 173-179. mum conditions for migration of oil in water-wet car- Endres,B.. Chilingarian,G.V.and Yen,T.F., 1992. En- bonate rocks.AAPG Bull.,44(2):235-243 vironmental hazards of urban oilfield operations, J. Carlisle,C.T.,Bayliss,G.S.and Van Delinder,D.G., 1975- Pet.Set.Eng.,6:95-106. Distribution of light hydrocarbons in sea Boor wdi. Gurevich,A.E., 1969-Processes of Groundwater,Oil and ments: Correlations between geochemistry, seismic Gas Migration.Nedra Pub1., 112 pp. (in Russian). structure and possible reservoir oil and gas. In: Proc. Gurevich,A.E., 1970. Processes of groundwater,oil and Conf. 1975 Offshore Technology.Dallas,Tex.,Vol. 3: gas migration in the petroliferous basins of Mangysh- 65-70. lak.Ph.D.diss.,VNIGRI,Leningrad,Russia. Chapman.R.E., 1993.Petroleum Geology.Elsevier,Am- Hunt,1.M.. 1979.Petroleum Geochemistry and Geology. sterdam,pp.245-25 L Freeman and Co.,San Francisco,Calif,617 pp. Chiligarian, G.V. and Vorabutr, P., 1983- Drilling and Muskat, M., 1937. The Flow of Homogeneous Fluids Drilling Fluids.Elsevier,Amsterdam,pp.71-79. Through Porous Media. McGraw-Hill, New York, Chilingarian,G.V.,M=ullo,S.J.and Rieke,H.H., 1992. N.Y.,763 pp. Carbonate Reservoir Characterization: a Geologic- Riegle,J.R., 1953. Gas storage in the Playa Del Rey Oil Engineering Analysis. Pan I, 30. Elsevier, Amster- Field. In: Summary of Operations, California Oil dam,639 pp. Fields.State of California Division of Oil and Gas,San Chiligprian, G V., Robertson, 1.0., Jr. and Kumar, S. Francisco,Calif, 39(2): 17-33. 1987.Surface Operations in Petroleum Production,I, Smith,l.E.,Erdman.J.G.and Marris,D.A., 1971.Migra. Developments in Petroleum Science, 19A, Elsevier, lion,accumulation and retention of petroleum in the Amsterdam,pp. 146;416-420. earth. In: Proc. 8th World Petroleum Congress, Mos- Culberson,O.L.and McKetta,J.J.,Jr., 1951. Phase equi- cow.Applied Science Publishers, London.pp. 13-26. librium in hydrocarbon-water systems. 111—Thc sot- Wilkinson,E.R.. 1982.Oil production in urban environ- ubility of methane in water at pressures to 10.000 psi. menls.In:Proc.Land Use Planning in Urban Oil-Pro- Trans.AIMS, 192:223-226. ducing Areas.Workshop,Feb.25, Huntington Beach, Dodson, C.R. and Standing, M.R., 1944. Pressure-vol- California Division of Oil and Gas.Publ.TR31: 5-13. Exhibit C PUBLICATION NO. TR31 LAND USE PLANNING IN URBAN OIL- PRODUCING AREAS PROCEEDINGS OF THE WORKSHOP HELD ON FEBRUARY 250982 IN HUNTINGTON BEACH, CALIFORNIA s y E3e 8 ® ® ® s. a ---------------------------- ---------------------- - ' _ _-___________ _______--_ ___ rug; ____ -_-_ r' 't', `.\i\/\ 1�\/_�\i�l:\� I` \r\/ / j_♦ CITY OF HUNTINGTON BEACH, DEPARTMENT OF DEVELOPMENT SERVICES, PLANNING DIVISION STATE OF CALIFORNIA, DEPARTMENT OF CONSERVATION, DIVISION OF OIL AND GAS oW HUNTINGTON 13EACH ENERGY SERIES REPORT 1!1 PRESERVING SURFACE ACCESS TO UNDERGROUND OIL RESERVES W DEVELOPED AREAS CITY OF HUNTINGTON BEACH DEPARTMENT OF DEVELOPMENT SERVICES JAMES W. PALIN, DIRECTOR FEBRUARY, 1981 Table of Contents PAGE FORWARD 1 DEFINITIONS 2 1.0 INTRODUCTION 4 2.0 COASTAL ZONE MANAGEMENT AND ACCESS TO OIL RESERVES 7 3.0 UNITIZATION, WATERFLOOOS, AND THE ACCESS PROBLEM 9 3.1 Primary, Secondary, and Enhanced Oil Recovery Technology 10 3.2 Difficulties in Achieving Unit Operations 11 3.3 Voluntary Unitization: Difficulties in Assigning Costs and Benefits 12 3.4 Compulsory Unitization 14 3.5 Advantage of Unitization 15 4.0 ROLES FOR CITY GOVERNMENTS IN PROTECTING ACCESS 17 TO UNDERGROUND OIL POOLS 5.0 TOWNLOT/DOWNTOWN ANALYSIS 19 5.1 Brief History 19 5.2 Remaining, Recoverable Oil 22 5.3 The Possibility of a Unitization and Enhanced Recovery Projec t 27 5.4 Surface Area Requirements 30 6.0 POLICY OPTIONS FOR THE CITY 36 6.1 Existing Land Use Regulations 37 6.2 Strategies to Help Preserve Existing Drill Sites 37 6.3 Strategies to Help Preserve Other Oil Operation Sites 39 6.4 Permitting New Wells in the Townlot Area 39 6.5 New Oil Sites 40 6.6 Other Possible Actions 42 7.0 CONCLUSION 43 8.0 NOTES 44 A111DCNUICES 45 Appendix A: Questionnaire and Cover Letter 45 Appendix 13: Bibliography 48 Foreword This is the first in a series of discussion papers on energy-related issues prepared by the Planning Division of the City of Huntington Beach. Huntington Beach is a center for many energy-related activities including onshore and offshore oil production, an electricity-generating power plant, and increasingly, solar and conservation technologies. The purpose of these reports is to help the City to accommodate the continued production of so vital a resource as energy while at the same time mitigating as much as possible any adverse impacts on the community that such activities might incur. Other reports in this series include the following: #2 Fiscal Impacts of Oil Operations in Huntington Beach #3 Oil Spill Contingency Planning in Huntington Beach #4 Enhanced Oil Recovery Technology #5 Solar and Conservation Policies at the Local Level This puhlication was prepared with financial assistance from the U.S. Office of Coastal Zone Management, National Oceanic and Atmospheric Adininislrntinn, urnlcr thr. provisions of the Federal Coastal Zone Management Act of 1972, as amended, and Irum the California Coastal Commission under the provisions of the Coastal Act of 1976. 1 i• i• - De"ons _ This report necessarily discusses some technical aspects of the oil industry. Consequently, some terms are used which may not be familiar to the reader. The following definitions section was prepared to help clarify the meaning of some of these terms. To ease reference, all words defined in this section are italicized the first time they appear in the report's text. Consolidation: The practice of concentrating oil facilities into relatively small, intensively-used surface areas. Economies of scale: Lower average costs or greater average profits resulting from a larger business entity rather than a smaller one undertaking a particular function. Enhanced recover technology: In its broadest sense, any method which is used to recover more oil rom a petroleum reservoir that would be obtained by primary methods; sometimes used to mean tertiary recovery.only. Free-rider problem: Situation in which one party gains from the efforts of another party, without contributing to those efforts. Injectors: Wells through which pressurized water, steam or other fluids are driven or "injected' into an oil reservoir. Joint or anization: A cooperative group formed by several oil operators working a common reservoir for the purpose of investigating the feasibility of forming a unit. Participation formula: An agreement among oil operators who have formed a unit regarding the proportion of expenses and profits of the unit each operator will be allocated. Primary production: Oil driven up through wells by natural pressure in the formation or by pumping units, without .injecting water or other fluids to help farce the oil to the surface. Producers: Wells used to pump out oil from a reservoir. Recycling: In this context, refers to the redevelopment of the surface area of an oil field or uses such as housing or commerce. Secondary production: Oil extracted after primary production usually by injecting gas or water into the reservoir. Technical committee: A committee established by a joint organization of oil operators prior to the formation of a unit which is responsible for investigating variables such as the geology of the oil reservoir, characteristics of the oil and the best potential recovery techniques. Tertiary methods: Oil recovery methods applied after secondary production which usually involve the injection of chemicals with water into the reservoir to help push out more oil than water alone can. In some cases, these methods are applied after primary production. 2 Unit: The entity formed by several different oil companies which work a common oil pool in order to share equipment and mineral interests to produce the reservoir as a single party. When the interests in a pool are fragmented, touts are essential for the use of most enhanced oil recovery methods which can only be applied on a coordinated, pool-wide basis. Unitization: The process of forming a unit. Water flood. A secondary recovery program through which pressurized water is injected into a reservoir in order to push more oil from the pores in the rock. Water injection: Another term for "waterflood." Well-bore: The hole drilled from the surface into the underground oil pool for the purpose o injecting materials into the pool and/or extracting materials out of it. Zones: The underground rock strata which contain oil. 3 1.0 Introduction The City of Huntington Beach overlies an production rates. Thus, many parts of the old and very productive oil field which, field are recycling to new uses, especially to since its discovery in 1920, has produced housing. almost a billion barrels of oil. Although the field passed its productive peak decades In most rases, however, the recoverable oil ago, it still produced enough oil during 1979 in the underground reservoir has not been to rank seventh among all California oil exhausted when the surface area is fields in annual output. Over 1,000 wells developed. . For example, primary are still active in the field and production, simply pumping as much oil as approximately 472 acres of the City are possible, without injecting water or other used for oil operations. substances to help force it out, typically extracts only 15 to 20 percent of the oil in For several years, however, the amount of place. Consequently, when an oil field in land devoted to oil extraction in Huntington which only primary production techniques f3each !ins declined. The reasons for this are have been utilized recycles to new uses, the Ir;ir. 1;) tln,Sc p>vts of the oil fie.lri where. great majority of the oil usually remains in wui3r i.rf•?ccion �r :,t.hcr enhanced recovery the ground. technologies hove not been applied, rru,lu.-tinu Levels 11.1ve dropped Existing and well-known secondary ::iiplilwot At the sarne time, the vslue production techniques, such as water of t.!Ir surface area for new use; -- injection, can recover an additional itl to 30 especially for housing here in coastal, percent of the oil. In addition, several new suburban Southern California -- has risen technologies, tertiary methods, are being dramatically. Building on the oil field developed and tested to extract the oil surface has become more profitable than remaining after secondary production. continued oil extraction at very low 4 tertiary methods as well. Figure 1.1 When the interests in an oil pool are highly fragmented, however, the numerous parties Secondary must act as a unit before these advanced technologies can be applied. The operators encounter several difficulties in forming a coordinated "unit," and often cannot act Tertiary\ together to apply these more efficient production methods. \Primary These difficulties are discussed later in this report. However, if these problems are overcome, unitization can he achieved and Remaining Oil-- enhanced recovrry methods applied to Recovery by Future provide large amounts of oil. Technology? Oil may not be recovered (even if unitization becornes economically feasible) if there are no surface areas from which extraction can be accomplished. It is precisely those areas where secondary methods are not currently used that Percentage of Oil in the Ground production has declined so much that Which is Usually Recovered by abandonment of the field for redevelopment Different Extraction Methods. is more profitable than continued oil extraction. Thus, the parts of the field Source: Petroleum Engineer, which are most likely to be developed for January, 1.976 residential or commercial uses and to lose future access from the surface are also the ones where secondary methods have not been tried and where their application could potentially produce large amounts of oil in Several of these methods are being tried in the future. parts of the Huntington Beach field. Domestic oil supplies are an increasingly Secondary and most tertiary techniques scarce and valuable resource. Their value cannot be applied on an individual well derives not only from their economic worth basis. Fluids, such as water or water but from other, less-tangible, benefits treated with cheinirals, are fnn_ed through related to the decreased reliance on foreign several wells (injectors), swerpinq the oil sources. These benefits reach beyond residual oil out of the pore spacrs and then the local community and have a regional and to several other well; (producers) which even a national importance. The pump the oil to the surfur.r,. The injectors greater-than-local importance of domestic and producers are typically r;rrnnged in oil would argue that the preservation of patterns so that the injected fluids can significant oil production opportunities efficiently sweep through an oil pool. Thus, should be the concern of the State or the entire oil pools must be treated as a whole federal government, and not primarily of or a unit and these methods must be applied the City. in a coordinated way. Local governments, however, traditionally When the entire pool is owned by a single have control over land use. It is the City company, use of these methods is relatively which must control surface activities if land easy. In fact, the major operators in for future oil extraction needs to be Huntington Beach -- ArTrinoil, USA and protected. The local government also Chevron, USA -- have been waterj'iooding shares the responsibility of protecting the their parts of the field for over two interests of the present and future decades, and both companies are tcsting community surrounding oil operations. Consequently, another reason for City continuation of a very valuable revenue involvement in this issue is to ensure that source in the community. The purpose of any adverse impacts on nearby uses from this report is to discuss the protection of future oil operations are reduced to access to oil resources as an important reasonable levels. One other consideration consideration for local land use policies. It that the City must weigh in assessing the discusses the numerous variables on which access issue is that oil production generates access preservation can be based, suggests a substantial tax revenues to the local range of protection strategies, and analyzes government. Protecting access and the specific areas in Huntington Beach where option to apply future extraction they could be applied. technologies may be crucial for the 6 2.0 Coastal Zone Management and Access to Oa Reserves The California Coastal Act of 1976 calls for Among the considerations relevant to the the protection of the natural resources of long-term utilization of these coastal California's coastal zone. Among the goals resources is the need to protect surface of the Act is to: access to the oil reserves. The area of the City where the most significant deposits "Assure orderly, balanced utilization and still in primary production are found, and conservation of coastal zone resources where future access is most jeopardized, is taking into account the social and economic the Town lot/Downtown area, which is needs of the people of the state."1 partially in the coastal zone. (See figure 2.1). The City recognized this issue in the Certainly the most significant natural Land Use Plan of its LCP, which includes resources in and near the Huntington Beach policies to amend the municipal code, if coastal zone include the long-productive necessary, to help ensure that such surface. deposits of oil. In accordance with the access is reserved, if it is essential to the intent of the Coastal Act, the City is future development of significant oil concerned with the orderly utilization of resources. This report is intended to help these deposits. The City's Local Coastal the City analyze these issues, as a step Plan (LCP) policies are intended to toward refining its policies and ordinances accommodate the legitimate needs of the aimed at ensuring the efficient, long-term oil industry while also protecting other use of these important coastal resources. important coastal resources such as the recreational and visual amenities of the shoreline. 7 Coastal Zone Boundary � �.c ❑ ❑ .[E.DaOODDDODD.DD.DO.[. DO ME] M ❑ ❑ CUDODOD❑ DOODCrDOD � L�.� DODO M ❑ M ❑ [EMUDDOOD [ODODODDLIUDD0 o0 ._ �OUIMIJ M DO M M M DO DO DO I DO M I UU UU DU UD [EU �� C��CO�[��CO��I�IOO��I❑��❑DDf� OD€DDGOIDDIOO�� s Figure 2.1 Townlot/Downtown, Huntington Beach. Source: Huntington Beach Planning Division. huntington beach planning division 3.0 Unitization, Enhanced Recovery and the Access Problem Providing future access to underdeveloped apply secondary or tertiary production oil reserves is usually a concern only where technologies. Consequently, a discussior of many operators work a common reservoir how unitization is related to these meth )-1 and they !lave not been oble to nnitizc and and why unitization is sometimes diffi, Pressurized Figure 3.1 Oil water Injection Pump Producing Injection Well Well I i i i I I Oil Pushed by injected Water Pressurized Water Enters Oil Zone Side View of a Waterflood Section. Snurce: Chevron, USA. 9 to achieve is very importari-E-to an analysis Much more of the oil can often be recovered of the access issue. if pressurized water is injected into the oil pool. The water helps to move the oil 3.1 Primary, Secondary and "Enhanced" through the pores in the rock. In this Oil Recovery Technology technique, the pressurized water is forced into the reservoir through "injector" wells. The simplest and most common method of The water moves out in all directions from extracting oil is to drill a well into the these wells, sweeping oil in front of it. (See oil-laden rock (usually sandstone in this Figure 3.1.) area) and pump as much of the oil as possible. However, oil is a sticky, thick Other wells, called "producing," are substance which does not flow very easily arranged around the injectors to pump out through the pores between the grains of the oil and water. (See Figure 3.2.) sand in the rock. Often, more than 80 percent of the original oil in place remains To efficiently use the pressurized water, in the reservoir after this "primary" producing and injector wells are arranged in technique is accomplished. patterns which allow most of the oil pushed by the water to be pumped out. (See Figure 3.3.) Figure 3.2 a.%r. Figure 3.3 1 1 �((+'j X X X X X y " 0 0 0 0 Y x x x x X 0 0 0 0 © x x x x x water :y,,, ✓ x injection well o production well 1 >•. �r n Example of Well Pattern in Waterflood Program. ` Source: Oil Well Drillin Techrology, Mc ray and Pressurized water from the Cole, 1973. j injection well © forces oil toward the producing wells O . i Top View of Waterflood. These patterns are not always reflected in the surface locations of the wells because Source: Huntington Beach Planning wells can be drilled "directionally," that is, at an angle, and it is the location of the Division. bottoms of the wells in the oil pool itself which is so important to the application of these techniques. An advantage of directional drilling is that a few, centralized surface parcels can sometimes The practice of concentrating facilities accommodate many directionally-drilled inh, small, intensively-used surface areas, is wells through which much larger 10 L'101.'r consolidation, underground areas can be tapped.* W � Clearly, this method which is called "water program. In fact, an important reason why injection" or "waterflood," cannot be applied unitization is not tried in many cases is that through a single well. Rather, many wells there is no large company with enough of an are involved which must be worked in a interest in the reservoir to warrant the coordinated way; the location and depth of costs and risks of trying to form a unit. the wells, the timing of the injecting and Small oil companies usually do not have the producing phases, the pressure applied at technical or financial resources to instigate different times and locations, and many a unit. other variables must be planned together to get the best use of the technique. The However, even when a large corporation has entire pool must be treated as a whole, or as an interest in the pool, it must overcome a "unit" -- otherwise a significant part of several barriers before unitization can be the investment in drilling the well and achieved. injecting water under pressure .may be lost because much of the oil tea+ fie Pushed First of all, there is a significant incentive about but not eeNec�e' for any individual operator not to participate in a unit while hoping that his WhAfi a single company works an entire oil`• more numerous neighbors instigate the pdol, this type of production method is project anyway. In this situation, the, other easily accomplished. When several operators in the field incur the cost of operators are pumping from the same pool, - developing the secondary recovery program, .they must agree to work together as a unit. while at the same time, if his wells are This, however, is often very difficult. These favorably located, the hold-out is able to difficulties will be discussed more fully i6 recover some of the oil swept by the unit's tfle next section. injection pattern. The hold-out does not . share in the costs of implementing the Even aTter s@conoary recovery, mgte" ..._n program, but he shares in the increased 50 percent of the oil rams a in one ground. production. Often, so many operators New methods are being developed to refuse to join a unit for this reason, that the recover some of this oil. Many of these program cannot be undertaken. This involve injecting substances into the oil predicament is often referred to as the zones along with water; these substances free-rider problem. help push out more oil than water can alone. Again, however, these techniques are Federal price controls on oil have often most efficiently applied on a pool-wide been cited as inhibiting unitization. The basis.* These technologies are often federal government has recently taken steps called "tertiary production" when they to deregulate the price of all domestic follow an earlier water injection program. production, so price controls are no longer However, in a reservoir where water an important consideration in analyzing a injection has not occured, these techniques unit's potential profits. might be applied simultaneously with or instead of a simple waterflood, to increase Some parties may not be interested in oe efficiency of production. joining a unit because the oil operations are, in fact, owned by firms whose principal 3.2 Difficulties In Achieving Unit interest is in redeveloping the very valuable Operations surface land at a time when it is most profitable. Such firms do not want to A large oil company which holds a commit their surface holdings to a substantial fraction of an oil pool will be the long-term unit agreement for oil ,party most IikPly to try ❑ uniti7ntinn production. This problem could be overcome if these operators are willing to join on the basis of mineral rights, but not * However, not all such technologies are so surface area or equipment -- provided applied. See Report 4 in this series, enough surface land still remains to produce "Er nced Oil Recovery," for a fuller, the field economically. -4 n of these methods. 11 Another potential problem involves the that could be recovered and the suitability liability of a unit for production decline of the reservoir to secondary arnong non-participants. If enough production--and hence the potential profits operators are willing to participate that a that could be realized from a unitization unit waterflood is undertaken, the program—leads some of the parties holding operations could result in a non-participant's an interest in the reservoir to pursue a production declining (although often it voluntary unit agreement. increases as explained above).* The unit may then be liable for the loss in Usually, a major operator holding a production. Court cases in Texas and substantial fraction of the interest in the Kansas have absolved units of such liability; reservoir contacts other ownership interests however, some companies have cited the and invites them to a meeting to explain risk that the unit (night be held liable as a why a unit operation and a field-wide reason for not participating. recovery project may be desirable. Often, many operators are not interested ,because Thus, for all these reasons, it is difficult to they have no first-hand unitization get all the parties that hold an interest in an experience, or they do not have the oil pool to join a unit voluntarily. In light of technical background to assess the potential this, and the fact that unitization and value of the project. Many operators are enhanced recovery is the most efficient simply suspicious of the true intentions of a method of extracting a very valuable major company, doubting that small firms resource, most states have established will get fair treatment in the joint compulsory unitization laws. These require arrangement. Other reasons why individual hold-outs to join a unit if a certain operators might not express even a percentage of the total interest in a field is tentative interest in the project were willing to participate. This percentage discussed above. varies from 60 percent to 85 percent. (See Table 3.1.) In some cases, however, several of the parties are tentatively interested in a The compulsory unitization laws in common operation and they begin to work California, however, are limited in their on a unitization agreement. This is usually application and may not be relevant to a very long, difficult and costly process. Huntington Beach. Voluntary and The first step is the initiation of a joint compulsory unitization are the topics of the organization. ext sections. The joint organization usually establishes 3. Voluntary Unitization: Difficulties in several committees to research information Assigning Costs and Benefits necessary for developing the unit. The most important of these is probably the technical Despite the risks and costs of trying to put committee whose task is to determine the together a unit, sometimes the amount of oil geology of the reservoir and to recommend the best recovery technique to be applied. This committee analyzes such factors as the *This could occur if the hold-out's well were areal extent of the oil zones, their depth so rinse to the unit's injectors that the oil in and thickness, faulting patterns, existing the zone near his well is swept away by the well-bore distribution, and surface areas pressurised water. The result would' be a available for new wells and equipment. The Iarrlr. increase in the amount of water committee then evaluates possible recovery fxrmped fro(n his well, but not in the amount rnethods. Historically, most units were put of nil. together to apply simple water 12 Perr_ent of Working Percent of Working Percent of Working Interest Required Interest Required Interest Required State For Compulsory Unit State For Compulsory Unit State For Compulsory Unit Alabama 75 Louisiana 75 Ohio 65 Alaska 62.5 Maine 85 Oklahoma 63 �..� Arizona 63 Michigan 75 Oregon 75 .` Arkansas 75 Missouri 75 South Dakota 75 California 75 Montana 80 Tennessee 50 Colorado 80 Nebraska 75 Utah 80 Florida 75 Nevada 62.5 West Virginia 75 Illinois 75 New Mexico. 75 Wyoming 80 Kansas 75 New York 60 Kentucky 75 North Dakota 80 s� AIJILk Table 3.1 Percent of Working Interest Required for Compulsory Unitization Statutes. Source: FOR Potential in U.S., OTA, 1976 W huntington beach planning division injection. However, future units may use Surface areas are likewise unequally valued enhanced recovery technology with the -- some locations are more critical than waterflood to recover more oil quicker, others. Different operators will also rather than waiting to apply such contribute more wells, more mineral rights, technologies after a simple injection more storage or processing equipment or project. The collection of data and the more surface area than others. Pride in evaluation may take years, depending on the property ownership or in control over complexity of the geology and whether the individual operations is another less tangible field is well-known or not. The committee's factor affecting the value an individual may recommendations must be brought before place on his interests in the reservoir. the full joint organization for approval. Clearly, assigning costs and benefits in a A legal committee researches land and way that is considered fair by all parties is a interest titles and royalty agreements and very difficult process involving long-term tries to determine if there are any legal negotiations. Usually, the greater the restrictions or problems related to property number of parties, the.more difficult it is to rights which could jeopardize the unit reach an acceptable agreement project. This committee is also responsible for working with the Division of Oil and Once a participation formula is arrived at, Gas, the State regulatory agency, to ensure unit agreements are drawn up for the that the proposed unit satisfies any operators and the royalty owners. statutory and administrative requirements related to multi-company oil operations. The time from initiation, through negotiations, to agreement can take up to A land committee identifies all the parties four or more years. The length of time and holding surface and mineral rights and concurrent expense of these negotiations, as informs them of the possible unit agreement. well as the risk that the negotiations may reach an impasse and the project may be An accounting committee records the precluded, contribute to the reluctance of expenses of the joint organization during many operators to try to initiate or this planning process. This committee will Ogrticipate in such a program. work with the technical committee in determining the most profitable technique 3.A Compulsory Unitization to be applied (considering tax and depreciation regulations, etc.). Many states, recognizing that unitization increases the efficiency of production as Probably the most difficult part of the well as the total amount of oil ultimately voluntary unit agreement is to determine recovered, have enacted compulsory the participation formula -- the share of the unitization statutes. These laws require all costs each participant must pay and the interest-holding parties in an oil pool to join amount each will later receive from the in a unit, if a certain majority percentage of unit's profits. The input of the technical the parties agree to unitize. committee is very important in this determination. The value to the unit of California actually has two compulsory certain mineral rights, for example, will unitization laws. The first requires depend on how much of the oil reservoir is unitization in order to waterflood and thus included and where it is located in the to repressurize an oil field if subsidence is oil-laden formation. The same is true for injuring or imperiling buildings, harbors and the valuation of existing wells -- the other improvements or may be interferring location, depth, age and condition of a well with commerce, navigation or fishery, or will affect how important it is to a unit. where subsidence-induced inundation could 14 endanger life, health, safety, public peace, There are numerous related advantages that welfare or property. result from this. This law is inapplicable to Huntington Beach First, by all measures, this is a more at this time because there are presently no efficient production technique: the total serious threats from subsidence in the City. volume of oil recovered increases; the time it takes to produce that oil is reduced; the The second statute is sometimes referred to amount of capital invested (equipment, as the Townsite Law. If 75 percent of the well-bores) per volume of oil is reduced. working interest of an oil pool agree to a unit operation, this law enables the State to Second, consolidation of surface area require the remaining interests to join the usually accompanies unitization. By state unit as well. The Townsite law, however, law, a unit agreement can only be approved applies only to fields which were discovered if it provides: before 1934 and which are at least 75 percent within an incorporated city. It is "To the full extent practical, for the not clear that this law could be applied in organization and consolidation of surface Huntington Beach because large parts of facilities, including oil production, storage, this field extend offshore and into the Boise treatment and transportation facilities, in Chica which is unincorporated county land. such a manner as will eliminate wasteful and excessive use of land surface areas, The rationale behind the law is "that the freeing such areas for other productive use management, development and operation of and development ..."3 lands as a unit for the production of oil and gas aids in preventing waste, increases the For example, the many small tank systems ultimate recovery of oil and gas, and associated with small groups of wells can be facilitates increased concurrent use of eliminated and a larger, centralized surface lands for other beneficial separation and treatment plant utilized. purposes."2 New wells and redrills can often be consolidated into walled and landscaped Under the law, non-joiners may sell their islands. Existing wells which are not interest in the pool at a fair-market value. important to the injection pattern may be This value is determined by an assessment plugged and abandoned. of the "primary tract value" based on the projected future primary production if no A workshop on urban oil development held in secondary were undertaken, plus the the Southern California area recognized "secondary tract value" based on estimates these kinds of advantages to unitization, of secondary recovery. The members of the concluding: unit must . purchase these interests if they are offered for sale. If the buyer and seller unitization was a beneficial tool to be disagree on a fair selling price, an used in older fields for improving oil arbitration procedure has been established recovery, aesthetically improving oil field to determine a fair valuation. operations and eliminating deserted, idle or unneeded wells."4 J.5 Advantages of Unitization The benefits of unitization extend to the It is clear that unitization is important for fiscal status of the City as well. In another the application of waterfloodine and other study, the Huntington Beach Planning enhanced recovery techniques. Division has analyzed the fiscal impact of oil operations on the City. The findings indicate that consolidated facilities, employing waterflood and other enhanced 15 recovery technologies are significant plant may require the laying of new net-revenue generators.* For example, pipelines in public right-of-way, causing Aminoil and Chevron, with highly temporary disruption of the street system. consolidated operations, use about, 60 Increased waterflooding may increase percent of the wells in the City to produce demand on public sewerage and water about 85 percent of the oil and 85 percent disposal systems. Nonetheless, from a fiscal of the oil-related revenues. The reasons for perspective, the revenues generated by this are that costs tend to decrease as the unitization usually greatly outweigh the few facilities are consolidated and less acreage costly effects. is used and that revenues increase as production increases. The operations also tend to improve because the oil pool is now worked by a larger The cost of police patroling, for example, is company or unit with a wider financial base more sensitive to the number of oil sites than many of the individual operators. This than to the number of oil wells. Thus, in a tends to make financing of mitigations for unitization and consolidation project if the adverse aesthetic and environmental number of wells stay the same or even impacts associated with oil production increase, but less sites are used, police costs easier. The unit can typically provide attributable to oil can decline. For another better fencing and landscaping, example, the costs of the City for sound-proofing and odor emission controls recordkeeping, inspection, taxation and than individual operators. The higher billing all tend to decline when the City can production experienced with a unit and deal with a large, single entity rather than waterflood allows the larger companies or scores of individual oil companies. units to expend monies for better equipment and maintenance so that the newer Revenues to the City are tied especially to operations are usually quieter, cleaner and the property tax on the mineral rights and less polluting than older facilities. Larger to severance or "per barrel" tax on companies or units also experience production. Interestingly, mineral rights economies of scale -- it is less expensive to assessment is tied to past productivity; thus, landscape or soundproof a few intensively if productivity rises, mineral rights used islands than hundreds of individual well valuation rises, too. (Although there are and tank sites; the one larger unit can deal important limits to how quickly valuation with these problems more efficiently than can rise as a result of Proposition 13.) Also, dozens of individual operators. as productivity increases, revenues from the severance tax which is simply a production In summary, unitization and consolidation of tax must increase, too. urban oil operations can be desirable for the following reasons: Of course, there are some negative impacts. Use of a centralized treatment - Oil production increases. - Less land is used and unnecessary or inefficient tanks and wells are removed. * iea: Report #2 in this series, "The Fiscal - The appearance of the operations Impacts of Oil Operations in Huntington improves; better mitigation of other Beach," Huntington Beach Planning adverse impacts is usually achieved. Division, March, 1981. - Costs to the City tend to decline but revenues tend to increase. 16 4.0 Roles for City Governments in Protecting Access to ON Pools The value of the increased domestic oil De-regulation and the rapidly escalating production that may be afforded by price of oil should help to improve the enhanced recovery technologies, as well as profitability of potential units in the the advantages of unitization and future. Another pricing problem is that the consolidation discussed above, argue that value of domestic oil to the society may not protecting surface access to underground oil be fully reflected in its (even de-regulated) pools and encouraging the formation of unit price because domestic production provides operations to work those pools may be other, less tangible, benefits to the country desirable policy objectives. This section related to the reduction of our reliance on discusses the kinds of roles which might be foreign sources for oil. This situation might appropriate for local governments in argue for federal incentives for increased promoting these objectives. domestic production. First of all, it should be noted that two of All these considerations, however, are the principal problems which have inhibited national in scope and lie within the unitization and the subsequent application jurisdiction of the federal government, not of secondary and tertiary recovery methods the municipality. are clearly outside the purview of the local jurisdiction. Another important problem related to unitization is the cost of forming a unit, Many oil companies have cited low oil especially the cost of getting enough prices, compounded by price controls, as an operators to join. The existing State important reason why many potential units compulsory unitization laws are examples of would not have been profitable in the past. ways to reduce these costs. 17 Note that the State regulates mineral rights solutions to these problems lie outside the and the unitization of oil pools; thus, the City's purview. However, the City can help State, and not the City, is the appropriate to implement any future corrective jurisdiction for instigating policies and measures by the State or federal statutes aimed at reducing the costs governments by not excessively restricting currently associated with forming a unit. future oil operations from the surface of the field and by developing ordinances and In both of these cases, the appropriate role policies aimed at keeping enough surface of the local government could be to adopt area open in the face of encroaching ordinances and policies which would not urbanization to accomodate future preclude future ameliorative actions by the unitization and enhanced recovery programs. federal or State governments. The principal tools for achieving this are the Traditionally, control over land use has been City's General Plan and its zoning the domain of the local government ordinances. Options for Huntington Beach (although legally, States have pre-emptive regarding its land use policies are discussed control over land use.) The City should in Section 6.0. Before reviewing policy recognize the two problems noted above: options, however, it is important to discuss inappropriate pricing and the sometimes the particular situation in Huntington Beach excessive costs of forming a unit. The City where these issues are especially relevant. should also understand that the appropriate That is the topic of the next section. 18 5.0 Townlot/Downtown Analysis As , mentioned in Section 2.0, the Over 35 oil companies operate only 9B 07ownIot/Downtown"' part of Huntington active wells. Chevron has the largest single 5each appears to be the most likely interest in this part of the field, but it candidate for a unitization and secondary accounts for less than 20 percent of the recovery project. It is also an area where total interest. Aminoil, the other major oil rapid redevelopmeryc of oil - parcels and company in the City, has virtually no vacant land is probable. Therefore, this holdings in this part of the oil field; area was analyzed specifically with regard (Aminoil does own some surface areas there �o the importance of preserving access to from which wells have been directionally refraining oil r%erves. drilled to offshore pools). The ales studied is located between Pacific Thus, unitization has been difficult not only Coast Highway and Palm Avenue, from because there are so many operators, but Goldenwest to Lake Street. Also, a also because neither of the large companies relatively large oil lease near Lake Street which have the resources to instigate a and Atlanta Avenue was included. A large unitization program has a particularly large portion of this area lies within the coastal stake in this part of the field. zone. (See Figure 2.1). Of the approximately 350 acres, only about 14 are 5.1 A Brief History still being used for oil production. Oil was first discovered in Huntington Beach This part of the field has never been in 1920i at a site near the present waterflooded, largely because ownership of intersection of Goldenwest Street and Clay the field is highly fragmented and Avenue. During the next several years, oil unitization has not been achieved. was discovered throughout Huntington 19 Beach but the City prohibite•l drilling in Since that timeproduction has declined to the Townlot and Downtown areas. However, a relative trickle. In 1979-80, 138,983 the continued success of oil operations north barrels were recovered, an average of only of 23rd Street (Goldenwest Street) in a 380 barrels per day for the entire area and barley field (which is now the "Seacliff" golf only about four barrels per day per well.8 course and residential development) prompted the City to lift these restrictions In other parts of the City, notably the leases in 1926 and to allow drilling between 23rd north of Goldenwest, the two major and 17th Streets. Two very important oil companies, Chevron and Aminoil, run highly zone.% the "Jones" and the "Main," were consolidated operations which tap very large quickly discovered. The State Division of underground areas. These companies began Oil and Gas noted that: applying water injection in the late 1950's and now have extensive water and steam "Intensive drilling activity followed flood projects as well as several tertiary these two discoveries, resulting in the recovery pilot programs. These companies fastest development and closest spacing have employed these technologies to work experienced in California to that date. these areas much more completely and Some wells were drilled on 25-foot efficiently than other areas in the field lots."5 where fragmented ownership has precluded unitization. The Townlot is one of those Another important zone, the "Tar" or areas which has not yet been waterflooded "Bolsa," was found later in 1926. In because the large number of operators there November of that year, the City opened the have not formed a unit. rest of the Townlot and Downtown to drilling, except for a "fire zone" between In recent years, the increasing value of land 5th and 3rd Streets which was excluded in near the coast for new uses (especially for order to protect the City's principal housing) along with declining production commercial district - - a short strip along have prompted many oil operators in the Main Street. On December 24, 1926 Townlot to abandon their wells and to production peaked at 63,400 barrels from 78 redevelop their sites. Also, after the Local wells. Production dropped quickly from this Coastal Plan is completed, development early peak and then gradually declined until pressures on the many oil sites in the the late 1940's.6 coastal zone will likely intensify. In light of these effects, it appears very possible that During the early years of the field, so many of the oil sites in the Townlot area development of the Tar zone was inhibited will be redeveloped that there will not be because the oil in these pools is very thick. enough active well holes nor enough The viscous ooze carried large amounts of available surface area for a future sand in it which often clogged the wells and secondary recovery project. complicated later processing. The growth in automobile use after World War 11 spurred This possibility raises several questions. such a high demand for oil that even thick First, how much oil could be recovered if an crude became profitable to extract and enhanced recovery program were process. This prompted a second drilling undertaken? Second, even if there is a large campaign in the Townlot area as operators amount of remaining oil, how likely is began to exploit the previously neglected unitization and a future secondary recovery Tar zones. program? Third, should the City take steps to help preserve access to these oil reserves In 1954 oil pools were located farther south and, if so, what should those steps be? The in the field, near the Downtown. Intensive remainder of this report tries to give drilling in this "southeast extension" of the tentative answers to each of these questions. Townlot resulted in another production peak in the mid-1950's.7 20 5.2 Remaining, Recoverable Oil Figure 5.1 The most important variable for decidingPCH Palm Ave whether the City should take steps to protect surface areas for future access to oil pools is the amount of oil that would be lost if the surface is completely developed. Using data from the State Division of Oil and Gas (DOG) and from the major oil -1000 companies in Huntington Beach, the City Planning Division estimated the remaining, recoverable oil in the Townlot area. The purpose of these studies is not to establish an exact numerical figure for the remaining ddle bolsa oil, but to indicate whether there is enough oil to make an enhanced recovery program "- ° -- 000... passible and, thus, if protecting surface lower - .... ....._...... . . areas and access for such a program is important. stray The first technique used to estimate the -3000 remaining reserves is the volumetric method," which uses data about the physical parameters of the field to estimate the volume of the original oil in place (OOIP). Jones Then, certain "recovery factors" -- estimates of the percentage of the oil that -4000 can be recovered by different extraction technologies -- are applied to the OOIP main estimate. In this way, one can determine how much oil could be recovered by an enchanced recovery program. This method requires much geologic information. First, one must know what oil zones underlie this part of the field. Example of Cross-Section Underlying Figure 5.1 illustrates a typical cross-section Townlot. under the Townlot area, and Figures 5.2 and Source: Division of Oil and Gas. 5.3 show their areal extent. The important oil-bearing strata include the Middle Bolsa, Lower Bolsa, Stray or AC, Upper Jones and Main zones. However, because of the lack of course, are not liquid pryfli% :cur. )re rock., of reliable data, the Stray and Main zones which contain oil in small pores !>etwcen were not included in the volumetric grains of solid material. Thus, the total estimates. Thus, the results should be on volume in acre-feet must be multiplied by a the conservative side. "porosity factor" -- the percentage of the rock which is not solid, but is actually By multiplying the area of a zone in acres spaces or pores between the solid materials, by its net thickness in feet, the total volume and can hold the fluids. However, not all of of the zone can be determined. The zones, that space is filled with oil. Water is also 21 � �® � � No 1 ) found in the pores between the solid Table 5.2 summarizes the data and materials. Thus, the total volume must be calcuations for DOIP in the Townlot. The further reduced by a "water saturation" OOIP is estimated at 112.1 million barrels. factor. By multiplying area by: 1) thi ss, 2) porosity percentage, and 3) a The next step is to determine how much of � ter saturation factor, the number of the OOIP can still be recovered by V581 f et" of oil is determined. There are secondary and tertiary technologies. After b rrelsofoilin an acre-foot and one discussing the performance of different imate barrels by using this factor. extraction techniques in Huntington Beach Fine , another variable called an "oil and other nearby fields with engineers from ation volume factor" must be the DOG, Amincil and Chevron, the considered. This simply adjusts for any following recovery factors were established . difference between the volume of the oil for the Townlot/Downtown area: primary, underground and its volume at the surface. .30; secondary, .12; and tertiary, .07 of OOIP. Usually, the primary rate is lower and Table 5.1 summarizes these variables and secondary rate higher; however, the the formula used to determine OOIP. engineers suggested that the very long term and unusually intensive production has Table 5.1 probably accounted for a higher primary rate and bus -a tower �tential secondary one jn-the Townlot area. VOLUMETRIC METHOD These data and these recovery factors suggest that over 20 million barrel: of oil A = area in acres may still be recovered in the Townlod area P porosity if secondary and tertiary technologies can H = net thickness in feet be applied. Sw = water saturation B = oil formation factor , To he* -confirm t.ba -reasonableness of this 7,758 = bbls/acre-foot estimate, the Planning Division calculated OOIP = original oil in place recoverable reserves using another method, the "decline curve technique." This method uses the past performance of the field for A x h x P x (1-Sw) x 7,758 = OOIP estimating future production. B Formula for Volumetric Method. The estimate would be most accurate if the annual production records of every well ever Source: "Valuation of Oil Producing drilled in the Townlot/Downtown since 1926 Properties", State Board of were located, reviewed and totaled. This Equalization, 1972. kind of research is very difficult and time-consuming. Instead, the Planning Reliable data for these variables were Division researched the production difficult to obtain. Net thicknesses of the summaries for this part of the field found in zones in the Townlot area were unavailable, several DOG Annual Summary of Operations and were estimated from cross-sections and and the recent production records of active from discussions in several DOG reports. wells. A reasonable decline curve was then Areal extent was estimated from contour interpolated between the few known data maps of the zones in DOG reports. The points. Cummulative production was then other variables were obtained from DOG estimated from this decline curve. See and industry estimates. As mentioned Figure 5.4. The total production for the above, the Stray and Main zones were Townlot/Downtown is approximately 43 excluded due to lack of data; thus the million barrels. estimates are probably low. 23 �A 111 Ii lil 1'1111111 I I \� •'� , ��� 1.11!I 1I lip i Average W/day 90,000 Townlot @D.000 Discovery Total for Tovnlot; 40-50 milion JaM 70,0010 / Field-.vide onshorepoductioo 60,000 r 50,000 S-Points D Dotal a 2nd Townlot Maternood 40,000 Discovery y (Tar) Begins i 30,000 /1 ♦ Known data points 11 11 1 1 210,000 1 1 1 6 M6 average � ; Townlol Production � 10.0010 1 1 1 -- - 1920 1930 1940 1950 1960 1970 Figure 5.4 Decline Curve for Townlot/Downtown. . Source: Huntington Beach Planning Division and DOG. huntington beach planning division Table 5.2 ZONE Al H2 P3 Sw4 B5 ' Middle Balsa 350 80 .28 .30 1.07 Lower Balsa 350 100 .28 .30 1.07 Upper Jones 150 100 .32 .35 1.07 1 DOG "Summary of Operations", 1958, contour maps 2 Estimated from various DOG reports 3 DOG and industry estimates 4 DOG estimates 5 DOG estimates OOIP = A In P (1-Sw) 7,758 1.07 = Middle Balsa 350 x 80 x .28 (1 - .30) (7,758) ' 1.07 = 39.8 million barrels Lower Balsa 350 x 100 x .28 (1 - .30) (7,758) . 1.07 = 49.7 million barrels Upper Jones 150 x 100 x .32 (1 - .35) (7,758) a 1.07 = 22.6 million barrels TOTAL 112.1 million barrels Recovery factors Primary 30 percent 33.6 million Secondary 12 percent 13.5 million Tertiary 7 percent 7.8 million Remaining recoverable oil = Secondary and Tertiary = 21.3 million barrels Calculation of OOIP and Remaining Recoverable Oil Using Volumetric Method. Source: Huntington Beach Planning Division. 26 The curve clearly indicates that production barrels could still be extracted if unitization in this area using current extraction and the application of enhanced methods is approaching its limit. Thus, technologies were successful. cumulative production should approximate all of primary production, which is (using These calculations were reviewed by the same recovery factor as in the engineers at the DOG, Aminoil and volumetric method) .30 of OOIP. If 43 Chevron. They concurred with City staff million barrels is .30 of OOIP, then OOIP that the methods used were sound, but that must be 143 million barrels. Using the same the available data may not be completely recovery factors as the volumetric method accurate. Thus, the value of the analysis is for secondary (•12) and tertiary (.07) not so much in the exact numbers as in recovery, the staff estimates that about 17 providing an indication that considerable oil million barrels could be extracted by reserves probably remain beneath this part secondary and an additional 10 million by of the City. tertiary. Remaining recoverable oil would be about 27 million barrels. See Table 5.3. 5.3 The Possibility of a Unitization and Enhanced Recovery Project. The decline curve method suggests somewhat larger reserves than the The analysis above suggests that there is volumetric, which is not surprising because probably enough oil remaining in the certain known producing zones were Town lot/Downtown area to make an excluded from the volumetric study due to enhanced recovery project profitable if lack of data. Thus, the two methods give unitization could be achieved. The next surprisingly similar estimates of recoverable step, then, is to try to determine what the reserves, indicating that perhaps 25 million obstacles to unitization are and if they are likely to be overcome in the future. Table 5.3 Primary Production = .30 OOIP = 43 million OOIP = 43 million (1/.30) 143 million Secondary Production = .12 OOIP = .12 (143 million) = 17 million bbl Tertiary Production = .07 OOIP = .07 (143 million) = 10 million bbl Total remaining, recoverable oil = 27 million bbls. Calculations of Remaining Recoverable Oil Using Decline Curve Method. Source: Huntington Beach Planning Division. 27 In order to do this, the City Planning The operators were also asked to indicate Division sent a questionnaire to all the oil the reasons why unitization has never been operators in the Townlot/Downtown area. achieved here. Most felt that too many of The questionnaire and cover letter are the operators were unwilling to join a unit inrluded in Appendix A. and that past price controls on oil rendered such an undertaking unprofitable. Several The results of the questionnaire are respondents felt that City zoning summarized in Table 5.4. Note that these restrictions related to drilling new wells had results can he measured in two ways: the contributed to the problem. Other reasons first is simply by the number of operators given included the difficulty in securing who gave different responses. A problem approval from land owners to encumber with this is that all companies are weighted their property for many years. Another equally, although a few own 10 or more respondent suggested that the lack of wells while many have only one. The second reliable engineering data would hinder any method is to calculate the percentage of the unitization attempts. total interest in the field held by the operators who gave a particular response. The City staff also noted this lack of readily This is a somewhat more meaningful available data. measure because the response of the relatively large operations will be more When asked if these difficulties could be important to a unitization project than the overcome in the future and unitization made very small companies. This method weighs possible, the companies were equivocal. each operator's response in proportion to the Seven operators, accounting for 21 percent percentage of the field he owns. Interest in of the interest in the field, answered "yes"; the field was considered to correspond to six operators, accounting for 41 percent of mineral rights valuations made for this area the field, said, "maybe"; and five companies, by the Orange County Assessor's office for accounting for 12 percent of the interest in property tax purposes. the field, responded "no." Questionnaires were sent to the 36 Finally, when asked if the company would be operators in the Townlot/Downtown area; 21 interested in joining a voluntary unit, seven responded. This response is indicative of said "yes"; five, "maybe" and nine, "no." one of the principal problems facing a Yet those responding "yes" and "maybe" unitization program: getting enough account for 61 percent of the total interest operators to consider even the possibility of in the field, while those answering "no" forming a unit. However, most of the larger account for 19 percent of the total operators did fill out the questionnaire; the interest. Interestingly, some operators who 21 respondents account for about 80 pecent felt there was likely to be enough oil to of the total interest in the Townlot field. make a unitization project profitable, and some who felt such a project might be The oil companies generally concur with the feasible in the future, were also definitely analysis in Section 5.2 that there may be not interested in joining a unit -- at least at significant oil reserves remaining in this this time. nro,i. Only throe respnndents felt that it was "very unlikely" that there is enough oil The results of this survey indicate that a to mare a waterflood economically voluntary unitization project in the Townlot profitable, and only one cited the lack of oil area is not imminent. Although a majority ;is a reason preventing a waterflood at this of the working interest in the field appears tirnc. Thirteen of the respondents, to be interested in such a project, a accmiming for about 62 percent of the significant minority is opposed to it. In workinrl interest in the field, answered "very addition, many of the operators (who hold likely" or "perhaps" when asked if there was about 20 percent of the interest in the field) enough oil to make a waterflood profitable. did not respond to the questionnaire at all. 28 1. Do you think there is enough recoverable oil in the Townlot/ Downtown part of the Huntington Beach Field so that a water- flood would be economically profitable (if unitization could be achieved? % Working Interest No. of Respondents in Townlot Field very likely 9 36% perhaps 4 26% very unlikely 3 5% don ' t know 5 13% 2. If you think there is enough oil to make unitization and water- flooding in the Townlot area profitable, do you think other obstacles can be overcome so that such a project is possible in the future? % .Working Interest No.. of Respondents in Townlot Field yes 7 21% maybe, 6 41% no 6 12% don' t know 3 6% 3 . Which of the following reasons do you think have prevented a waterflood program from happening in the Townlot area? No. of Respondents not enough oil 1 not enough operators 12 willing to ioin price controls on oil 11 g?nin restrictions 6 er: answer included: lack of data, difficulty in getting approval of land owners to encumber surface properties. 4. Would your company be interested in joining a voluntary unit for the purpose of waterflooding? % working Interest No. of Respondents of Townlot Field definitely inter- 7 24% P Rt Pt3 maybe interested 5 37% definitely not 9 19% interested Table 5.4 Questionnaire Results. Source: Huntington Beach Planning Division. 29 This _lack of response underlines the Figure 5.5 illustrates the areas in and near difficulty in achieving unitization at this the Townlot area where oil well drilling is time. The companies are also equivocal on currently allowed. These are limited to the whether unitization can be achieved in the leases operated by Chevron and Aminoil future. The principal reason holding up northwest of Goldenwest (sites #1 and #2), unitization, now that price decontrols are an island operated by Chevron at 17th effected, will be the inability to get enough Street and Palm Avenue (site #3), a operators interested. The many reasons why relatively large area operated by Chevron operators may not join a unit have been near Lake Street and Atlantas Avenue (site discussed above. #4) and a small island owned by Aminoil between 18th and 19th Streets along Pacific A unitization project in the future is still Coast Highway (site #5). This last site is possible, especially if either of the following intensively used for wells directionally "scenarios" develops. First, as the value of drilled under the ocean and it is unclear the land increases many of the operators whether this area would be available for will choose to sell their sites. The smaller wells tapping the Townlot area, at least in companies with few wells and low the near term. All of the other sites would productivity will tend to recycle their land very likely be able to accomodate wells and first. Increasingly, the working interests in other facilities in a Townlot unitization and the field will be held by companies secondary recovery project. Figure 5.5 interested in continued oil production. shows all the existing oil sites in the Townlot area. City ordinances currently Second, in the face of domestic oil allow existing wells and redrilling on most shortages, the State or federal government of these parcels, but prohibit new wells. may enact a strict compulsory unitization law so that secondary and tertiary The surface area needed for an enhanced extraction technologies can be applied to recovery project depends largely on the domestic oil fields. These laws would number of wells needed to produce the require agreement among a smaller majority pool. As discussed in Section 3.0 above, percentage of the operators before enacting injection and production wells are usually compulsory unitization. For example, some arranged in patterns to facilitate the States require as little as 60 percent of the efficient sweeping and subsequent collection interest of the field to agree to a unit of oil in the zone. Consequently, rough before forcing the remainder to join. estimates of the number of wells needed in Currently, companies holding more than 60 an enhanced recovery project can be made percent of the Townlot working interest by calculating the spacing of wells in a may be already, at least tentatively, pattern and dividing that factor into the interested in a unit project. total number of acres in the zone to be worked. For example, engineers at the 5.4 Surface Area Requirements Division of Oil and Gas estimated that the spacing for a waterflood project in the As the City considers the issue of helping to Jones zone would be approximately one well preserve surface areas for future oil per 10 acres; and that only about 25 wells operations in the Townlot, two key questions would be necessary for this kind of project arise: 1) how much area is needed to there. accomodate a waterflood or enhanced recovery project? and 2) where must these The characteristics of the zone will affect sites be located? Much of the information the kind of recovery method used, which used in answering these questions was could in turn affect the spacing and the supplied by the DOG and by Eastman number of wells needed. The Balsa zone, Whipstock, Incorporated, a company for example, holds a very viscous oil; thus, involved in directional drilling projects. steam, rather than water, would likely be 30 Drill sites (zoned 01 or 02) Other oil Sites--No New Wells Allowed (zoned 0) ................ 3 . (ILIc � �� � �'� o :c� c :� �.c� c c� �.® OU IE IE MMUM .off o 6 zc1c � E, cIc14ccc � oacoc000aaM11c���° o , L—I F, [� 711-7c� , 0 � 00� I . W-1 Lil L 00 P9, AMIN Figure 5.5 Drill Sites and Other Oil Operation Sites in Townlot/DownLown. mm Source: Huntington Beach Planning Division. huntington beach planning division iA? l injected into the formation because the hot Thus, the surface area currently afforded by steam helps the thick oil to flow more the drill sites (111-5 in Figure 5.5) in and freely. Because the oil must be kept warm near the Town lot/Downtown could probably for this technique to work, and because the accomodate the wells needed in a secondary steam and oil tends to cool as it moves or tertiary recovery project, even in a through a formation, the spacing of the closely spaced steamflood. wells must usually be much closer in a steam program than in a waterflood. Another important consideration, though, is Engineers at the DOG estimated that one the location of these surface areas relative well per 5 acres or even one well per 2.5 to the underground oil pools. As mentioned acres might be needed to effect this kind of in Section 1.0, wells can be directionally program. Thus, from 64 to as many as 128 drilled so that a few centralized surface wells might be needed in a steamflood of areas can accomodate wells that produce a the Townlot Bolsa zones. much larger subsurface area. The most important constraint on how far a well can Considering the usual setbacks from public extend from a surface site is the depth of right-of-way and from nearby uses, the the zone the well is tapping. The shallower surface area needed for well drilling and zones are more difficult to reach because maintenance, 25 wells or more could be the angle of the well must be more acute. easily accomodated on an oil operation site Eastman Whipstock calculated the distance roughly the size of a square block in the that a well could be drilled in the Townlot Town lot area. area under usual economic and geologic conditions. Wells tapping the Bolsa zone could reach only about 1,500 feet from the Figure 5.6 surface bore hole; wells into the much deeper Jones zone could extend about 2,400 feet from the bore hole; (see Figures 5.6 and 5.7� Using these estimates, Figures 5.8 and Depth : 5.9 illustrate how much of the subsurface Town lot/Downtown field can be reached from the existing drill sites. If part of site — 1000 #5 is considered available for this kind of project, then virtually all of the Jones zone can be reached from the presently available drilling sites. Likewise, a very substantial part of the Bolsa zone is also accessible _ 2000 from the existing sites, although a considerable area in the middle of the Townlot may be inaccessible. Engineers from Chevron and Aminoil 3000 indicated that wells could be extended even farther than these estimated limits if necessary, although such wells would be 1000 2000 nore difficult to drill and more expensive. Lateral Extent A stearr. .project adds a further factor into the analysis. As discussed above, steam Lends to lose its Tsat after it moves away ` Directional Drilling Pattern for Wells from its source (a bailer). The bottom of f the steam injection well cannot be more f Reaching the Bolsa Zone. than 1,000 - 1,500 feet from the boiler, otherwise the steam• loses so much heat as Source: Eastman Whipstock. it travels through the well that it is ineffective when it reaches the oil pool. Portion of the zone not within 2400 feer. of an existino drill site Drill site ........... ► r7 _IGLU LJ L L�- L' L -_j L-j' L--; L-�; ILI] 1 . 1 j [I F U IrE [0 MA, F-I .1 IM L I---I F--i PI j 9 91,........................... AM16 Figure 5.8 Approximate Coverage of Jones Zone from Exist Source: Huntington Beach Planning Division and huntington beach planning division iifii • . • • • 11 II fl � ' r � � t k= Kul 11 •.���� 1 ��- Another way of looking at the situation is Figure 5.7 that in order to undertake a comprehensive enhanced recovery program for the Town lot/Downtown, new wells or the Depth redrilling of existing wells may be needed in the area roughly between 6th and 13th Streets. Furthermore, because of the problem of heat loss in a steam projec t, a 1000 steam generator (boiler) may also need to be located in this area. The current zoning laws affecting the existing oil sites in this area allow the boiler .equipment . and — 2000 redrilling, but do not permit new wells. In summary, a waterflood or other enhanced recovery project for the Jones zone, and presumably for the deeper Main zone, could probably be accomodated from the existing 3000 drilling sites .in the Townlot/Downtown area. A comprehensive program for the shallower Boise zone would probably involve steaming, and might require some new --4000 wells, the redrilling of existing wells and the location of steam producing equipment outside the existing .drill sites in an area 1000 2000 between 6th and 13th St-eets. Lateral Extent There are currently several oil operation sites in this area which could be utilized in Directional Drilling Pattern for Wells such a project. The zoning on these sites Reaching the Jones Zone. allows the redrilling of wells and the installation of oil recovery equipment, but Source: Eastman Whipstock. does not allow for the drilling of new wells. This fact suggests that a secondary recovery program ' (steamflood), which utilized only the existing drill sites, might not be able to include a significant part of the Bolas zone, (roughly between 6th and 13th Streets). 35 6.0 Policy Options for the City The discussion in Section 5.0 suggests that a urbanization for the facilities necessary for considerable amount of oil can probably be an enhanced recovery project if unitization recovered from the Town lot/Downtown area is realized in the future, and Z) ensuring if unitization occured and enhanced that any adverse impacts on nearby uses recovery methods were applied. Although a such as housing and coastal recreation are majority of the oil operators there have mitigated to acceptable levels.* indicated a tentative interest in such a project, unitization does not appear likely in the short-term. * Analysis by the City Planning staff Section 4.0 argued that the kinds of indicates that potentially adverse government policies which would directly impacts resulting from an enhanced encourage unitization and enhanced recovery project can usually be recovery do not lie within the jurisdiction of mitigated; and, in fact, such projects the local government. Still, there are tend to reduce undesirable effects and important roles for a City government; increase beneficial ones in areas like namely, 1) helping to preserve enough the Town lot/Downtown. A discussion surface, area in the face of rapid of potential impacts and their mitigations is included in another report in this series, 114: "Enhanced Oil Recovery Technology". 36 60) This section discusses the policy options greater than three acres. Drill site #1 in available to the City for preserving surface Figure 5.� is designated 0-2. For purposes areas until a future unitization project is of this discussion, there is no practical instigated or until it is apparent that such a difference between 0-1 and 0-2. The project is so unlikely that restrictive important point is that both permit new land-use policies are unreasonable or unwise. wells, while the O suffix does not. 6.1 Existinq Land-use Regulations The discussion in Section 5.4 indicated that Affecting Oil Operations in the the five existing drill sites could probably Town of Downtown accommodate an enhanced recovery program, except perhaps for a Considering the long history of oil comprehensive steamflood in the Bolsa operations in Huntington Beach, as. well as zone. The steamflood might require the benefits that oil production contributes additional surface area outside the drill. to the community such as employment and sites, somewhere between 13th and 6th revenues, the City's land-use regulations Streets. There are several existing oil have traditionally accommodated oil operation sites in -this area which are zoned activities. O; thus steam equipment and redrilling are permitted, but no new wells. The City currently uses three zoning districts, called "O," "O-1" and "O-2," to This indicates that current regulations allow oil operations. More specifically, would allow unitization and enhanced each of these is a zone suffix which is recovery. The relevant question, however, attached to a base zoning designation such is how long will these sites be available for as residential, commercial or industrial. such a project? Both the uses permitted in the base zone, as well as the oil-related activities permitted Because the O, D-1 and 0-2 districts are by the suffix zone, can be legally conducted only suffixes, other uses are already on the site. permitted on these sites. At any time, the operator may abandon, his oil operations, and The "O" is the most restrictive of the oil new development can be constructed on the suffixes. It permits wells and other site. The loss of any of the remaining drill oil-related equipment, including those which sites and the loss of the other oil operation might be used in an enhanced recovery sites, particularly in some parts of the project. It allows the redrilling of existing Townlot, could potentially preclude a future wells, but does not allow any new wells to enhanced recovery project. be drilled. The principal purpose of this suffix is to allow existing wells and the Through its land use regulations the City kinds of activities which could be reasonably can go beyond simply accomodating expected in association with these wells. enhanced recovery projects now, and help to This is the designation on most of the oil keep sites available for such use in the operation sites remaining in the future. Strategies for achieving this are Townlot/Downtown area. They are shown in discussed in the following sections. black in Figure 5.5. 6.2 Strategies to Help Preserve Existing The "0-1" designation allows all the uses Drill Sites permitted under the O suffix, but also allows new wells to be drilled. Drill sites 2 Any enhanced recovery project will require through 5 in Figure 5.5 are designated 0-1. a significant number of new wells. The "0-2" suffix allows the same uses as The existing drill sites are large enough 0-1, but applies to oil operation sites 37 to accommodate the antic-Oed number of Permit • new uses which do 'not wells and are distributed over the oil zones cover the drill site (or parts of the drill in such a way that most of the strata can be site) extensively with permanent reached by directionally drilled wells. Thus, structures. These uses might include protection of these existing drill sites is commercial recreation facilities such probably highest priority for keeping open as "miniature golf," or other t ptiori-Of a future enhanced recovery commercial establishments like garden p olect�The Mowing strategies might help supply outlets, or self-serve gas to protect' sites: stations. Such uses would have to be reasonably feasible considering their Chan e O-1 to ase desi nation rather than location and appropriate considering a suffix: If t existing base zone were other nearby uses. removed, and e O-1 suffix were to become the base zon for the site, then a developer The City..might also establish regular review would need o come to the City for a zone eriods after which the owner. or developer change efore ' new uses could be ould request a re-evaluation of the site for \constr ed on the drill site. Before the n enhanced recovery project. If the City � change would be permitted, the termined that an enhanced recovery Planning Commission and City Council p ject was no longer practical or that the would have to approve the zone change and si a was no longer important for the success the new use. The City might require one or o su h a p e restrictions on the use all of the following before allowing new uses of e s ace could removed. on the drill site: C n e General Plan de i nation on all drill An analysis by a petroleum engineer si es to "Resource Pro uction": Another showing whether an enhanced recovery i ortant "tool" for re ulating land uses project in the Townlot area is bes s zoning is the City General Plan. impractical or not. If such a project is still possible, the analysis should The Ge P indicates, in general indicate whether the drill site in terms, the kinds of uses which are question is necessary for such a appropriate in different parts of the City. project. The analysis should also For example, drill site #1 in Figure 5.5 is indicate if only part of the surface area currently. designated "resource production." in the drill site is essential to such a This means that activities related to oil project. extraction are the most appropriate ones in this area during the "planning period" (which Retention of part of the drill site is usually 20 years). Before other uses surface as open space, available for would be permitted there, the developer future oil operations. This open surface would have to obtain a General Plan area should be large enough to not only amendment from the City. Drill site #2 is accommodate the equipment necessary designated "planned development" and drill for the enhanced recovery project, but sites #3-5 are in residential designations. If also any buffers, walls, screens and these sites were also changed to "resource sound-proofing barriers used to protect production" then oil extraction would be the the nearby uses from any adverse principal permitted use, and a General Plan impacts related to the future oil amendment would be necessary before new operations. These open spaces could be uses would be allowed. incorporated into the design of the. new development and used for such things as The advantage of requiring a General Plan recreation facilities or gardens, so long amendment rather than a zone change is as there were a clear understanding that the former usually entails a much more that such areas might also be used for extensive review by the City's staff and oil operations at a future date. policy-makers. 38 . This might ensure that considerations like A disadvantage to this approach is that it future recovery projects will be more adds, (almost literally), a new layer of City completely analyzed before changes are land use restrictions, in addition to the permitted. The kinds of restrictions that existing General Plan and zoning might be placed on the site by the City ordinances. New review procedures would before allowing new uses would be the 'same need to be developed in order to implement as in the zone change case discussed above. this approach. The advantage of the overlay However, the mechanisms for the detailed is that .it emphasizes the importance of review which would be required in that case protecting areas for enhanced recovery are already established for General Plan projects and it helps to focus the analysis of amendments, but are not normally exercised new uses on the enhanced recovery issue and currently for zone changes. not other peripheral ones. A disadvantage is that the General Plan 6.3 Preservin Other Oil O eration Sites currently does not usually differentiate land Zoned O in the Townlot Downtown use categories on areas smaller than 20 acres. The intent of the General Plan is to The City may want to consider applying the indicate general uses for relatively large strategies discussed above to . the other oil areas in the City, leaving more detailed operation sites in the Townlot/Downtown restrictions on a site-by-site basis to zoning area which are currently zoned O. Some of ordinances. A significant exception to this these sites could be important to a is the coastal zone, where land use comprehensive enhanced recovery project. designations have been applied to sites much Many of these sites, however, are .very small smaller than 20 acres because of the special and very close to other uses. The minimum resources associated with the coast which surface area necessary to accommodate a require more detailed planning, even at the drilling rig .recommended by numerous oil General Plan level. Drill sites #1, 2, 4, and companies and well drilling companies is 5 are in the coastal zone, so this kind of approximately 100 by 200 feet.* Sites specificity in the land use designation would which are smaller than this minimum may not be unprecedented. not be appropriate for future re-drilling and, thus, might be excluded from consideration Overlays and conditional-use permits: in a future enhanced recovery project. Another method by which the City could help protect surface areas for future oil 6.4 Permitting New Wells in the Townlot operations would be through an 'overlay" and a conditional-use permit. The City Besides protecting the existing .drill sites could indicate that the Townlot/Downtown and some of the larger O-zoned sites, the area is a special resource production district City might also consider allowing new wells by a general 'overlay" designation. Before in the Townlot, if the new wells were part certain sites in the overlay district could be of a unitization and consolidation program. used for activities other than oil operations, New wells outside an existing drill site may the developer would be required to apply for be important to an enhanced recovery and receive a conditional use permit -- that is, a permit allowing new uses, but only after a City review and analysis, and only if any conditions placed on the new uses by the City are accepted by the developer. These * Planning staff contacted the following conditions could include the enhanced companies: Chevron, Aminoil and recovery analysis and reservation of open California Production Services, as well space which were discussed in the zone as the DOG. change option above. �9 project if existing wells c-dnnot be redrilled The aim of this policy is to protect and. or if there are simply insufficient existing enhance the visual and recreational wells to complete the injection patterns. amenities afforded by the beach while New wells should only be permitted if they permitting oil activities which must be meet the following _criteria: 1) the site is located there. In view of this approach, larger than a minimum size; 2) mitigations reservation of Bolsa Chica Beach for future of any potential adverse impacts are oil facilities appears inappropriate. incorporated into the project; and '3) the However, if new .facilities essential to the new well is part of an overall unitization or recovery of the oil deposits underneath the consolidation program. Implementing Townlot could not be sited any where else, strategies include developing a .new zoning then the City may still permit those ordinance or utilizing . an overlay district facilities to be located on the beach if all of with a conditional-use permit requirement, the conditions listed above are met. similar to the strategies discussed in Section However, because this is a State beach, the 6.2. California Department of Parks and Recreation would also have to give its 6.5 Other Possibilities for New Drill Sites permission before new wells could be drilled. Besides the drill sites discussed above, there Offshore Locations: Another possible are other possiblities which should be location far oil facilities needed in an discussed. enhanced recovery project is offshore. Bolsa Chica State Beach: Part of Bolsa In this case, preserving surface locations in Chica State Beach lies across Pacific Coast the Townlot itself would not be important, Highway along a large section of the although some onshore sites might: be Town lot/Downtown area. Several wells and necessary to tap the more inland related equipment are active in this area extremities of the oil pools. Wells and which is currently zoned O. Wells related equipment can be located on directionally drilled inland from this strip offshore platforms, man-made islands or could cover a large part of the Townlot and piers extending from the shore. Because could be very useful in a comprehensive these wells would be reaching inland, they enhanced recovery project. A serious would be located as close as possible to the' problem with using this area for more shore. Thus, a pier would be the most likely intensive oil operations is the conflict facility used if an offshore location were between those activities and the area's use chosen. as a heavily-visited, public recreation facility. In light of the high priority in.the The disadvantages of using a pier for oil Coastal Act given to public recreation along facilities include the following: 1) risk of the shoreline, the City's LCP includes spills which could adversely affect the policies which encourage the "phase-out" of recreation beaches, 2) degradation of visual wells on Bolsa Chica Beach. New wells are resources associated with the shoreline, 3) not prohibited from locating on the beach, conflict between industrial and recreational but can only be sited there if all the uses of the shoreline and.. 4) conflicts following condition are met: between mobile, portable oil equipment and 1) The resources are not recoverable from other traffic. any other onshore location or existing Advantages of using a pier include the platform, 2) the site is improved to. become following: 1) valuable surface areas onshore compatible with recreation uses of the could be freed for other uses, and 2) the pier beach, 3) public health, safety and welfare could be designed to accommodate public are not jeopardized, 4) adverse recreation facilities such as fishing areas environmental impacts are mitigated to the and look-outs, and the private sector would maximum extent feasible, 5) the net overall probably be willing to finance the entire impact of oil production facilities on visual proposal. The pier would have to be resources is improved, and 6) safe access to designed to reduce any conflicts between the beach is provided. the oil activities and the public recreation facilities. 40 Park J pid \ Fire Hous tUILU Mm . � o [] [11 C] El [�] 01 [0 10 n0 C0 10 [1 �I L7LJib LJ 0 -� 7.7 ran nn I f� 1- 1 r`i^] ��^l I—: �; Senior Center Senior Rec . Cente� [] [] [] [] [J Lu 1 4 uu , f R I _O -� l_'J LU l : i L.J u L L.J �LI Mobile Home Par r ] [] 1] Ir r� L [] r] 10 Parking�.o (�(� Q Motel [ Cl �'� �� �� [� ['� L�1J ' SJ " n ULnI (UnU ULI LJL 1 �� UU pFri, r�`��!��![�I : �!r]I[�IL I[ ? ELI]� ;Jf�'J�LJU LJ Lease, �I Commercial V Co ! L.J'L, 1 LJ'� rn CD �- CD 'rl C� C� 7 ❑ vacant- Vacant Lease, Commercial ��- Public Beach Figure 6.1 City-owned Properties in Town lot/Downtown. Source: Huntington Beach Planning Division. huntington beach planning division The City's planning and zoning jurisdiction 6.6 Other Possible Actions does not extend beyond the mean high tide line. The State Land Commission regulates There are other kinds of actions related to development in this area. Thus, the City protecting surface areas which the City can only discourage or encourage offshore should consider. First, the City may want development, but cannot regulate such to hire a professional petroleum engineer -to development directly. analyze the possibility of unitization and enhanced recovery in the City-owned Pro ert : Another option for Townlot/Downtown more completely before preserving sur ace areas for future oil enacting zoning ordinances or other land use facilities is for the City to retain properties restrictions. Such a study may establish it owns itself and to restrict uses on the more exactly the likelihood of such a surface or.parts of the surface. Figure 6.1 project, as well as its surface area shows the City-owned properties in and near requirements. This in turn could allow for the Town lot/Downtown and indicates the the development of more precise regulations. uses currently located on each. The implementation approach would be to limit Secondly, an analysis of the remainder of structures so that sections of these the City may be helpful to locate other properties are preserved until such time parts of the field where unitization and that an enhanced recovery project is enhanced recovery projects are possible and proposed. The City would then sell or lease where protection strategies similar to those the surface areas to the unit proposing the discussed for the Townlot might be project. The City could still use these appropriate. properties until that time for facilities like parks or parking lots which leave large parts of the surface free of permanent structures. The City would periodically review the properties reserved for potential enhanced recovery projects to determine if such projects are still possible and if particular properties would be important for the projects. 42 7.0 Conclusion For the forseeable future, energy sources -- The City's principal role in this issue is to and especially oil — will continue to be control land uses so that enough surface increasingly more expensive. New area is preserved until , these technologies technologies will also continue to be can be applied or until it is clear that developed to help increase energy supplies. application of those technologies is In light of this situation, oil remaining in the impractical. More direct actions which ground after primary production which may would encourage unitization and the use of be recovered by new technology is a very enhanced recovery methods are more valuable natural resource. appropriately within the jurisdictions of State and federal governments. The City This report shows that the should monitor policy and legislative Townlot/Downtown area of Huntington developments at these levels of government Beach may overlie such oil resources. It related to unitization and enhanced also discussed strategies for protecting recovery, as well as to developments in the surface areas necessary for access to those oil industry itself, to better determine if resources in the face of encroaching such programs are likely in Huntington development, so that new technologies may Beach. By watching these developments, as someday be applied to recover the well as by periodically evaluating the remaining oil. The City should consider potential for new projects in Huntington evaluating other areas in the Huntington Beach, the City can continue to promote Beach oil field where conditions are similar policies which help to protect and carefully to those in the Townlot; namely, where 1) utilize its important oil resources. significant quantities of oil may still exist in the ground because secondary and other enhanced recovery methods have not been applied, and where 2) new development is rapidly encroaching on the oil field, threatening to cover the surface to such an extent that the necessary extraction equipment can not be accomodated. 43 NOTES 1. California Coastal Act of 1976. 2. California Public Resources Code, Division 3; Chapter 3.5. 3. Ibid. 4. Hill, F. L., Proceedings: Workshop on Urban Oil and Gas Development, 1978. 5. Hagenbush, G. C., and Allen D. R., "Huntington Beach Oil Field," Summary of Operations, Vol. 44, 1958. 6. Ibid. 7. Hunter, A. L., Bradford, W. C., and Allen, D. R., "Southeast Extension of the Townlot Area," Summary of Operations,.Vol. 41, 1955. B. Huntington Beach Planning Division, "Fiscal Impacts of Oil Operations in Huntington Beach," 1981. a 44 APPENDIX A Questionnaire.and Cover Letter 45 COMPANY NAME: A g• DEFINITIONS: Waterflood: A method for increasing oil production by injecting water into oil zones. Unitization: An agreement among several oil operators to treat a shared oil pool as a1uunit"and to produce the pool together in a coordinated way, as if they were a single company. Unitization is usually required before a waterflood project can be undertaken in all areas where many operators work the some reservoir. I. Do you think there is enough recoverable oil in the Townlot-Downtown part of She Huntington Beach Field so that a waterflood would be economically profitable (if unitizations could be achieved): Very likely Perhaps Very unlikely Don't know 2. If you think there is enough oil to make unitization and waterflooding in the Townlot area profitable, do you think other obstacles can be overcome so that such a project is possible in the future? Yes _ Maybe No Don't know — 3. Which of the following reasons do.you think have prevented a waterflood program from happening in the Townlot area? Not enough oil _ Not enough operators willing to join Price controls on oil Zoning restrictions Other 4. Would your company be interested in joining a voluntary unit for the purpose of waterflooding? Definitely interested _ Maybe interested _ Definitely not interested 46 ;, CITY OF HUNTINGTON BEACH. . P.O. BOX 190 DEPARTMENT OF DEVELOPMENT SERVICES CALIFORNIA 92648 BUILDING DIVISION(714)6364 M1 PLANNING DIVISION 1714) 5388271 Dear Sir: A problem facing oil producers in urban areas is the pressure for new development on the surface of oil fields. Houses and commercial structures are built near active oil operations; surface areas, from which new wells could be drilled and new technology could be tried, are covered over. This pressure for new development on oil fields is certainly evident in the City of Huntington Beach, and the City is concerned that potentially valuable oil reserves may be lost in the future if oil fields are completely covered by development. The City Planning Division is studying this potential problem. As part of this study, we are trying to determine if a unitization and waterflood project is possible in the Townlot and Downtown parts of the City. (This is the area bounded by Pacific Coast Highway, Palm Avenue, Goldenwest Street and Lake Street.) Our records show that your company operates a well or wells in this part of the City, and we would very much appreciate your answering the questions on the enclosed sheet. You can just check off your answers on the sheet, put it in the enclosed envelope and drop it in a mailbox. If you have other comments or ideas about the possibility of a waterflood program in the Townlot, or if you have any questions about the City's study, please feel free to write the Planning Division or simply call Mike Multari of our staff at 536-5279. Thank you very much for your help. Sincerely, �l /damoels W. Paartment of Development Services /MM:cw 47 APPENDIX B Bibliography "Coastal Energy Impact Program for the City of Huntington Beach," Huntington Bech Planning Division, 1980. Enhanced Oil Recovery Potential in the U.S., Office of Technology Assessment, GPO, 1976. "Estimate of Natural Gas Reserves -- Huntington Beach," California Railroad Commission, 1946. "Huntington Beach Oil Field," DOG, Summary of Operations, Vol. 44, 1958. "Huntington Beach Oil Field — Old Field Portion," DOG, Summary of Operations, Vol. 26, 1942. "Huntington Beach Oil Field -- Southeast Extension of Townlot Area," DOG, Summary of Operations, Vol. 41, 1955. Oil Property Valuation, Paul Paine, 1942, Procedings- Workshop on Urban Oil and Gas Development, F. L. Hill (Editor), DOG and ' Federal Energy Administration, 1978. "Recent Developments in Huntington Beach Oil Field," DOG, Summary of Operations, Vol. 12, 1927. "Recent Developments in the Tar Sands in the Townlot Area, Huntington Beach," Division of Oil and Gas, Summary of Operations, Vol. 35, 1949. "Tar Sands in the Townlot Area of Huntington Beach Oil Field," DOG, Summary of Operations, Vol. 13, 1928. Valuation of Oil Producing Properties, California Board of Equalization, 1972. 48 0 0 HUNTINGTON BEACH ENERGY SERIES REPORT #2 FISCAL IMPACTS OF OIL OPERATIONS IN HUNTINGTON BEACH CITY OF HUNTINGTON BEACH DEPARTMENT OF DEVELOPMENT SERVICES JAMES W. PALIN, DIRECTOR MARCH, 1981 TABLE OF CONTENTS PAGE FORWARD 1 DEFINITIONS 2 1.0 INTRODUCTION 3 2.0 CURRENT CITY REVENUES AN EXPENDITURES RELATED TO OIL OPERATIONS IN HUNTINGTON BEACH 5 2. 1 Expenditures 6 2.2 Revenues 8 2.3 Conclusion 12 3.0 FISCAL IMPACTS OF CONTINUING OIL OPERATIONS 13 3.1 Predicting Future Oil Operations 13 3.2 Assumptions about Variables Affecting Future Revenues and Expenditures 14 3.3 Analysis of Scenarios • 15 3.4 Summary 19 3.5 Garfield/Goldenwest and Townlot/Downtown Areas 20 4.0 BEYOND FISCAL IMPACTS 25 4.1 Non-fiscal Costs 25 4.2 Non-fiscal Benefits 26 4.3 Federal and Local Perspectives on Non-fiscal Costs and Benefits 26 5.0 CONCLUSION 27 APPENDICES Appendix A: City Expenditure Models 29 Appendix B: Revenues from Other Energy Facilities 35 NOTES 38 BIBLIOGRAPHY 40 ADDENDUM Report #2: Fiscal inpact of Oil Operations in Huntington Beach August, 1981 Fiscal impact modeling is a rapidly developing field; modeling techniques and methods for measuring complex fiscal effects are continuously being improved. The methodology used in Report #2 was developed as part of an ongoing effort to increase the accuracy and usefulness of the fiscal models available to the City. The purpose of this addendum, then, is to identify areas where further improvements can be made in the methodology, and to update the analysis with new information that has become available. MULTIPLIER EFFECTS The methodology used in Report #2 does not take into account secondary costs and benefits or "multiplier effects." Multiplier effects are the indirect benefits (or costs) to the City caused by an activity. For example, a company generates direct revenues for the City, but also supports the City indirectly by providing jobs and making purchases from other local businesses, who in turn, pay taxes and buy still other goods and services. In this way, each business (or household) may generate revenues for the community beyond the taxes and fees it pays directly to the City. In the case of some uses, such as oil production, these secondary effects may be significant. The City is currently working on a fiscal model which will include multiplier effects. As this methodology is refined, more accurate analyses of the overall impacts of different land uses on the City's budget and local economy will be possible. It should also be stressed that, based on direct fiscal impacts, oil operations have a very favorable revenue/cost ratio, particularly in comparison to other uses. If secondary or multiplier effects are integrated into the analysis, the additional benefit oil activities bring the City could be quantified. Then a more accurate comparison of the overall impacts of all uses could be made. NEW INFORMATION: UTILITY TAXES A significant direct revenue generated by oil activities, which was not included in the earlier publication of Report #2, is the electric utility tax paid by oil companies. This is a tax on all electricity-using customers in Huntington Beach, equal to five percent of the customer's electric bill, that goes directly to the City. Therefore, it is correct to attribute the revenue generated by this tax to the electricity user, not to the utility. In 1979-80, the oil companies paid approximately $500,000 to the City in electic utility taxes. Accordingly, the total revenues in Table I (page 5) should read $2,172,477; net revenues should read $ 1,301,484. The revenue/cost ratio for oil uses -- ,already considered favorable -- is better than previously shown (from about 2: 1 to about 2.5:1). i. Foreword This is another in a series of discussion papers on energy-related issues prepared by the Planning Division of the City, of Huntington Beach. Huntington Beach is a. center for many energy-related activities including onshore and offshore oil production, an electricity-generating power plant, and increasingly, solar and conservation technologies. The purpose of these reports is to help the City to accommodate the continued,production of so vital a resource as energy while at the some time mitigating as much as possible any adverse impacts on the community that such activities might incur. Other reports in this series include the following: #1 Preserving Surface Access to Underground Oil Reserves in Developed. Areas #3 Oil Spill Contingency Planning in Huntington Beach #4 Enhanced Oil Recovery Technology #5 Solar and Conservation Policies'ot the Local Level #6 Low Temperature GeotheFinal 'Resources In Huntington Beach This publication was prepared with financial assistance from the U.S. Office of Coastal Zone Management, National Oceanic and Atmospheric Administration, under the provisions of the Federal Coastal Zone Management Act of 1972, as amended, and from the California Coastal Commission under the provisions of the Coastal Act of 1976. 1 Definitions This report necessarily discusses some technical aspects of the oil industry and of fiscal impact analysis. Consequently, some terms are used which may not be familiar to the reader. The following definitions section was prepared to help clarify the meaning of some of these terms. To ease reference, all words defined in this section are italicized the first time They appear in the report's text. Enhanced Recovery: Any production method which is used to recover more oil from a petroleum reservoir than could be obtained by natural reservoir energy or simple pumping. Includes water flood, steam flood and other techniques involving injection of fluids into the reservoir to recover additional oil. Expenditures: Monies spent by the City to provide goods and services to the landowners, residents, workers and visitors of the City. Fiscal Impacts: In this report refers to revenues received and expenditures incurred by the City as a result of particular land uses or activities occurring in Huntington Beach. Net Revenues: The revenues remaining and available to the City after total expenditures are subtracted from total revenues. Opportunity Cost: Costs associated with choosing one option over other ones when that choice precludes the alternatives. By making that choice, benefits that might have resulted from the precluded alternatives are lost. . Primary Production: Oil driven up through wells by natural pressure in the formation or by pumping units, without injecting water or other fluids to help force the oil to the surface. Recycling: In this context, refers to the redevelopment of the surface area of an oil field for uses such as housing or commerce. Revenues: The monies or income the City receives; sources include taxes, fees, rents and franchises. Scenarios: In this report, refers to a set of events or conditions possible in the future; a future Possibility. Unitization: The process of forming a "unit"; a unit is an entity composed of several all operators which work a common oil pool in order to share equipment and mineral interests to produce the reservoir as a single party. When the interests in the pool are fragmented, units are essential for the use of most enhanced recovery methods which can best be applied on a coordinated, non-competitive basis. Water food: An enhanced recovery program through which water is injected into a reservoir in order to force more oil from the pores in the rock. Water Injection: Another term for "waterflood". 2 1 .0 Introduction Numerous energy-related facilities occupy in Huntington Beach. In addition, the City significant land area in the City of faces important decisions regarding land Huntington Beach, especially in and near use as the oil in the field continues to be the coastal zone. These facilities include depleted and pressure increases to abandon onshore and offshore oil production ports of the field and to redevelop the operations, a tanker unloading terminal, a surface. Fiscal impacts are important power plant, pipelines, and electricity and factors in determining the best use of the natural gas distribution systems. All of land and the City's policy toward continued these have fiscal impacts on the City. oil operations. In this report, fiscal impacts refer to the The City's other major energy revenues the City receives and the facilities--the power plant and marine expenditures it incurs as a result of terminal—are, practically speaking, particular land uses. Revenues are the permanent facilities which will continue to funds generated for the City through serve regional and state interests. City various taxes and fees (for example, actions are not likely to significantly property taxes, production taxes and encourage or discourage continued license fees) paid by the owners and users operations of these facilities. Thus, they of land in the City. Expenditures are the do not present significant land use options monies spent by the City to provide to the City at this time. services for these land uses (for example, fire and police protection). This study has been carried out in conjunction with the development of a The principal purpose of this study is to City-wide computer model which assesses estimate the fiscal impacts of the fiscal impacts of various land uses. energy-related facilities and especially of While the City-wide model may be useful oil production operations. The report for analyzing most activities, it does not focuses on oil operations because they take into account certain peculiarities of occupy a great deal of very valuable land oil operations. 3 For example, oil revenues are more closely Section 3.0 projects the fiscal impacts of related to -.he amount of oil produced by continuing oil operations through 1990 the wells than the acreage they occupy. under four different .scenarios. Special The City-wide model, however, is largely attention is given to the Townlot/ based on developed acres, and generally Downtown and Garfield/ Goldenwest areas does not relate changing revenues to where the status of oil operations is likely changing production levels. Thus, a better to change. way of computing the impacts of oil operations has been developed as part of Finally, Section 4.0 discusses issues besides this study. (See Appendix A). fiscal impacts which are also important for making decisions about land uses in the The following section discusses the City. revenues and expenditures related to oil operations in Huntington Beach for fiscal year 1979-80. 4 2.0 Current City Revenues and Expenditures Related to Oil Operations in Huntington Beach Table 2.1 summarizes the revenues and 1979-80. Oil activities generated net expenditures attributable to oil production revenues (revenues exceeded costs) of in Huntington Beach for fiscal year approximately $800,000 for the year. TABLE 2.1 City Revenues and E enditures Related to Oil Operations or isca ear 9 9-8 Revenues Expenditures row perty taxes $ 382,068 enera overnment and Oil Production and Administration S203,340 Business License Fees 1,076,996 Public Works 135,465 Royalties and Easements 120,000 Police Department Inspection Fees 73,000 Directly Assignable 1.4,360 Wastewater Permits 9,660 Not Directly Assignable 150,903 Dri I ling/Redril ling Fire Department Permits 6,500 Directly Assignable 28,309 Pipeline Franchises 4,253 Oil Inspector 45,800 Special Equipment TOTAL REVENUES $ 1,672,477 and Personnel 210,000 Not Directly Assignable 82,816 TOTAL EXPENDITURES $ 870,993 $ 1,672,477 (Total Revenues) - $870,933 (Total Expenditures) = +$801,484 (Net Revenue). Refer to Section 2.2 and 2.3 for discussion and calculation of these figures. CORRECTION: Oil operations contribute other significant direct and indirect benefits which are not included in this analysis. Please see 5 the "Addendum" on page i. The following sections explain how these expenditures and revenues were estimated. TABLE 2.2 2.1 Expenditures Distribution of Fire De artment Ca11s by Type of Land Calendar Year 1978 . Local governments provide a wide range of vital public goods and services. In 1979-80, Type of for example, the City of Huntington Beach Land Use 11 of Calls (1) % of Total spent over $30 million to provide businesses, industry, residents and visitors Residential 2,937 34.5 of Huntington Beach with fire and police protection, streets, sewers, garbage Streets & Highways 537 6.3 disposal, animal control, building inspections, consumer protection, and Industrial 269 3.2 many other important services. This section discusses the City's expenditures City Beach & Pier 257 3.0 related to oil operations. Commercial 240 2.8 Directly Assicinable Expenditures: A, key problem in this kind of fiscal analysis is Oil 51 .6 determining what portion of the total City budget should be attributed to different City Parks 126 1.5 land uses. In only a few cases is it relatively easy to measure the amount of Miscellaneous 520 6.1 public services provided directly to certain kinds of land uses. The principal examples Other of these directly assignable costs are those Unassigned (2) 3,588 42.0 related to police and fire calls. The City keeps records of the number of such calls TOTALS 8,525 100.0% and also notes, among other data, the land uses located on the site of each call. We then assume that the proportion of calls generated by each land use category is a reasonable estimate of the proportion of the City's costs in responding to all calls (1) Includes all fire, emergency/ medical that should be attributed to each land uses assistance, and non-fire and type. non-emergency/medical incidents. Table 2.2 shows the distribution of Fire (2) These are emergency/medical Department calls by land use type. It incidents that could not be assigned to indicates that only .6 percent of all calls a particular land use. were related to oil operations. The total City expenditures on the budget items Source: City of Huntington Beach Fire related to Fire Department emergency Department and Planning Staff. calls were $4,718,248 in 1979. Those items are Fire Control (account number 302)* and Medical Aid Paramedic (304). Considering the discussion above, oil uses then should be assigned .6 percent of the * Paranthesis indicates the account total, or $28,309. numbers in the City budget for these items. 6 Table 2.3 shows the distribution of Police The following budget items were Department calls among land uses in the considered related to the costs of City. Note that oil operations are not responding to criminal activity: Crime broken out into a separate category; they Analysis (330), Vice and Organized Crime are included in the "industrial" group. All (328), Investigative (329), Scientific industries accounted for only .2 percent of Investigation ,(331), Patrol (332), Traffic police calls. Because there are other (335) and Aero (337). The City expended industries in Huntington Beach besides oil, $7,190,105 to provide these services in the share of the expense of these services 1979-80. Oil's share, .2 percent of the attributed to oil facilities must be some total, is $ 14,360. fraction of .2 percent. For the purposes of this analysis, however, the full .2 percent A very large proportion of fire and police is assigned to oil activities to ensure.that calls are included under "streets and their share is not underestimated. highways," "miscellaneous" or "unassigned" categories. Expenditures in these TABLE 2.3 categories cannot be assigned to specific land uses directly. This is true for most Distribution of Police De Mai rtment other City expenditures as well. These will Calls y o a se a en or be discussed again below. Year Another group of City expenditures which # of Calls % of Total can be reasonably assumed to be directly related to oil operations are the costs of Streets & Highways 29,386 40.2 the City's oil inspection and regulation activities. The City Oil Inspector, who Residential 23,917 32.7 works in the Fire Department, enforces the City Oil Code, inspects every well Commercial 13,457 18.4 annually, responds to oil-related emergencies and performs other duties City Beach & Pier 908 1.2 related to oil operations. The Fire Department estimates that oil inspection City Parks 446 .5 costs (including inspector's salary and overtime, benefits, car, uniforms and State Beach 129 .3 office support) were approximately $45,800 in 1979-80. Industrial 125 .2 (including oil) Finally, because there is a potential petroleum fire hazard associated with the Miscellaneous 42717 6.5 oil production facilities, pipelines and tank farms in Huntington Beach, the Fire TOTALS 73,085 100.0 Department has an engine company that is specially trained and equipped to handle oil fires. If not for its oil field responsibility, the Fire Department would not maintain this company. Therefore, the cost of this Source: City of Huntington Beach Police protection, estimated at $210,000 for Department and Planning Staff. 1979-80, is added to City expenditures on oil activities.1 7 t Not DirectI no Assi ble Expenditures: TABLE 2.4 Most expen itures cannot be directly assigned to particular land uses. Many of Distribution of Costs these represent the Citys "overhead" or Using Weighted Kv—erage Model the cost of having services available, should they be needed. Economist George % of Total Patterson helps clarify this point: Expenditures % of Acreage Assigned by . .the basic purpose of a fire in City Model department is protection, which is available to all whether or not they Residential 65% 87.3% actually have a fire. It is not logical to assume that a fire department is Commercial 9% 5.2% paid only when it is fighting a fire."2 Industrial 6% 2.3% Thus, while expenditures on fighting fires can be reasonably attributed to different Oil 3% 2.3% users, the costs of having the equipment and personnel ready to fight any fire are Vacant 17% 2.9% not, but are borne by all members of the community. Total 100% 100.0% The City has developed an expenditure model as part of the preparation of this report for estimating the "fair share" of these costs that can be reasonably In 1979-80, expenditures on budget items attributed to different kinds of land uses. which cannot be directly traced to specific A detailed discussion of this model and of land uses totaled $24,982,308." Oil's share alternatives that were examined by the of this, 2.3 percent, equals $572,523. City for this study is included in Appendix Table 2.5 lists all the budget items A. A brief summary of the model and its included in this analysis. assumptions follows: 2.2 Revenues The model takes into account several factors in assigning the appropriate share Oil operations generate significant of City expenditures to different land uses, revenues for the City from a number of including the amount of acreage in the sources, including the following: City each land use type occupies and the intensity of use on that acreage (that is, the number of residences, businesses or oil facilities per acre). The assumption * Library, Parks & Recreation, and utilized in the model is that more Harbors and Beaches are not included intensively developed areas tend to require in the analysis because these three more services (and, thus, more groups of services are attributed expenditures) per acre then less densely primarily to residential uses and are developed areas. This approach, called the not considered in the calculations of "Weighted.Average Model" estimates that expenditures attributable to oil oil operations can accounf for about 2.3 operations. Water Department percent of the City's budget (for items expenditures and revenues from water which cannot be directly traced to specific sales are also excluded, because oil land uses). See Table 2.4. activities consume relatively small quantities of water and the estimated revenues are not important to this analysis. 8 BUDGET ITEMS FOR "UNASSIGNED" EXPENDURES General Government and Administration Police Department ' (100) City Council (230) Development Services Adm. (320) Administration (101) Non-departmental (231) Current Planning (321) General Support (102) Civic Promotions (232) Advance Planning (322) Personnel (109) City Administrator (233) Land Use (323) Public Affairs (110) Internal Auditor (234) Plan Reveiw (324) Records (111) Budget and Research ' (325) Training (112) Council Support (326) Research (113) Public Information Pubiic Works (333) Communication (114 Economic Development (115) Civil Defense (410) Administration Fire Department (116) Data Processing (412) Surveying (117) Purchasing (415) Traffic Engineering (300) Administration (118) Central Services (420) Maintenance Administration (301) Fire Prevention (119) Word Processing (430) Mechanical Maintenance (304) Joint Powers (120) Chashier (462) Vehicle Repair (485) Fire Station (121) Risk Management (560) Sewer Maintenance (122) Animal License (561) (591) Sewer Pump Station Also inclive. (130) City Attorney (431) Mechanical Fabrication ' percent of assignable' eels at .M tri- (140) City Clerk (433) Pool Car Maintenance �� to •streets and high (141) Elections (453) Special Repairs .wm". lareous, and (160) Personnel (450, ,Unnasignsd. (170) Finance 460, Refs to Tables 2.2 and 2.3. (171) Accounting 470, (172) Business License 480, Building Maintenance 482, 487, 489, Summer for 1979-80 490) �Unass gne Expenditure. General Government $8,840,880 Public Works 5,899,762 Police 6,560,980 Fire 3,600,868 Total $ ,89 , TW TABLE 2.5 RM huntington beach planning division Assessed Value of Oil Properties in Huntington Beach, 1979-80 Tax Rate Mineral Secured Unsecured Tax Tax Area Land Rights Improvements Improvements Total Rate Collected 001 . 4,255,667 20,653,010 8,974,280 457,970 34,340,927 4.7767% 1,640,363 007 13,742 66,690 1,940 207,360 289,732 4.8309% 13,997 I� 010 47,053 228,350 13,270 9,450 298,123 4.8426% 14,437 013 & 014 585,204 2,840,030 237,990 26,380 3,689,604 4.7884% 176,673 Totals 4,901,666 23,788,080 9,227,480 701,160 36,618,386 1,845,740 " Land surface was distributed among tax rate areas in the same proportions as mineral rights. Source: Orange County Assessor's Office. 4 TABLE 2.6 r huntington beach planning division 1) property taxes (including tax on surface of an oil field or oil parcel is considered in areas, mineral rights and improvements), 2) use for oil production, and how much could business license and oil production license reasonably be considered vacant and fees, 3) inspection fees, 4) pipeline available for other uses. In many cases, a franchises, 5) wastewater permit fees, 6) parcel is so densely populated with wells drilling/redrilling permit fees and 7) and tanks that the entire area can be royalties and easements.33 considered oil production land. In other instances, however, open spaces between Property Tax: The City's property tax wells are large enough to permit revenues are primarily dependent on three development of other uses. For example, key variables, 1) the assessment or it would be unreasonable to think of a valuation of property in the City, 2) the ten-acre parcel with three oil wells on it as tax rate applied to those valuations or devoted entirely to oil. Vacant portions of assessments, and 3) the percentage of the such a parcel could be developed for other total property taxes collected in uses. This has happened in areas Huntington Beach which actually go to the throughout the City. City. In order to accurately estimate the surface Proposition 13 "rolled-back" property area of the City used for oil activities, the valuations to 1975 levels and limits characteristics of the oil fields and parcels re-assessment to two percent per year. in the City were analyzed to determine if However, if o property is sold, it is the land around the wells and tanks could re-assessed at that time at its selling be developed for other uses. Those areas price. Generally, because of the two which could be considered available for percent annual limit, valuations do not other uses were counted as vacant land. keep pace'with inflation. The frequency at The remaining portions of oil fields and which properties "turn-over" (are sold), and parcels were counted as oil areas. Through thus are re-assessed, greatly affects how this process, staff estimated that .about closely the overall valuation for properties 472 acres are actually used for oil can keep pace with inflation 4 production in .Huntington Beach. The estimated assessed value of this surface Proposition 13 generally limits property area for 1979-80 is 54,901,666 (See Table tax rates to one percent of market value. 2.6). Voters in any tax rate area can approve additional taxes beyond this base rate. Besides the surface land, property taxes Table 2.6 below shows the distribution of are also assessed on mineral rights, secured oil holdings among tax rate areas, the rates improvements, and unsecured for each area and the tax collected by the improvements. The assessments on each of county. these in 1979-80 were the following: $23,788,080 for mineral rights; $9,227,480 Many jurisdictions other than the City for secured improvements; and $701 , 160 (such as the school districts) are also for unsecured improvements. funded by property taxes. Thus, only a fraction of the total property taxes The City receives a 20.7 percent share of collected in Huntington Beach actually go the total property taxes on oil operations to the City. The share of the property in Huntington Beach collected by the taxes which went to the City was 20.7 County, which amounted to $382,068 for percent in 1979-80. 1979-80.5 The most difficult problem in estimating Business License and Oil Production the City's property tax revenues related to License Fees: of production ee is a oil is determining how much surface area Barg a for each barrel of oil produced. It is linked to the 10 71 consumer price index, and, thus, increases (Some pipelines are not related to oil as the cost of living rises. The oil production here - that is, even if there production license fee rates for 1979-80 were no oil production in Huntington Beach were 11.054�/barrel for "non-stripper" wells these pipelines would continue to be used. (wells that produce more than ten barrels They are used for transporting crude oil per day) and 8.W/barrel for "stripper". delivered by tanker or for carrying gas or wells (wells that produce less than 10 refined products.) barrels per day). Each oil operator also pays an annual $100 business license fee Royalties and Easements: As a result of per well. legislation in t 's, the City receives royalty payments from the sale of oil The oil production fee is paid quarterly, produced on offshore lease Public and the operator may deduct up to $25 per Resources Code 392. The royalty is quarter as reimbursement for the license approximately .25 percent of those sales, fee. In other words, the first $25 of the and therefore, contingent on oil prices and quarterly oil production fee is paid in the amount produced - two variables that advance, in the form of a business license are very, difficult to redict. In 1979-80, fee. The total revenue collected from this the City received M0,000 from this source was $1,076,996 for 1979-80.6 source.lo Oil Well Ins ection Fee: Each oil well is 2.3 Conclusion inspect annua ly for compliance with the Huntington Beach Oil Code. The . oil The analysis for 1979-80 indicates that oil inspector must approve each well before a production contributes significant revenues business license is issued. There is a $50 to the City, totaling approximately $1 .67 inspection fee per well. Total revenue million. Approximately two-thirds of these from oil well inspections was $73,000 for revenues come from The oil production fee 1979-80. (per barrel) which is tied directly to production. This fee also increases Wastewater Permits: Every well that uses annually with . an index of the inflation the City's wastewater system must pay an rate; thus, this revenue source can keep annual $30 wastewater fee. There are 322 pace to a significant degree with rising wells using the system. Total revenues expenditure levels. were $9,660 for 1979-80.7 The estimated City expenditures related to Drillin /Redrillin Permits: In order to oil production for 1979-80 were ril or re ri an of we , an operator must approximately $.87 million. Three secure a permit from the oil inspector. departments--fire, police and public There is a $500 fee for each permit works--account for about two-thirds of approved. In 1979-80, 13 dril ling/redril ling these; expenditures by all other permits were issued, generating a revenue departments combined for the remaining of $6,500.8 one third of the total. Pipeline Franchises: Oil companies that Clearly, oil production activities currently have pipelines in Huntington Beach pay generate net revenues to the City. The franchise taxes whose rates are established next section analyzes how this fiscal by contracts with the City. The term of situation might change in the future, the contracts vary from franchise to considering- variables such as changing franchise. Revenues from this source were production levels, inflation, and pressures $4,253 for 1 979-80 for pipelines directly to redevelop the oil fields to new uses. related to oil production in Huntington Beach.9 12 3.0 Fiscal Impacts of Continuing Oil Operations Estimates of the fiscal impacts of In light of these changing variables and continued oil activities in Huntington different, possibilities, several "scenarios" Beach depend largely on the predicted of oil operations over the next decade have future of those activities. This can be a been analyzed. The first assumes, overall, problem because many variables important that the number of wells, acreage and to a fiscal analysis, such as the number of production levels remain relatively barrels produced, the number of wells, the unchanged. This could come about if the actual acreage devoted to oil facilities and decline of production in some parts of the the inflation rate, are difficult to foresee. field are balanced by new waterflood projects and other enhanced recovery 3.1 Predicting Future Oil Operations programs. Production among small independents is assumed to continue The lack of available open space in this dropping, but the "recycling" of their area and the growing housing shortage parcels to new uses would proceed very create pressure to abandon oilfields and to slowly, largely due to the increasing price redevelop them for housing. At the same of oil. Thus, the number of wells, acreage, time, rising oil prices and the relaxation of and overall oil production would remain price controls on domestic oil make relatively constant for the next ten years. continued oil production, even at low levels, increasingly attractive. Higher prices may also make more expensive production techniques (such as water * Two other reports in this series are injection) profitable in parts of the field highly relevant to the discussion of where - they have not yet been applied. new technologies: Report #1 Further, while production in the "Preserving Surface Access to Huntington Beach field has been declining, Underground Oil Reserves in new technologies are being tested here Developed Areas", and Report A, which might rejuvenate the field.* "Enhanced Oil Recovery Technologies". 13 The second scenario envisions a gradual Underground Oil Reserves in Developed phase-out of oil operations in the Townlot Areas," analyzes this possibility in detail. and Downtown during the 1980's, but operations elsewhere in the City continue Before discussing each of these scenarios, relatively unchanged. This was analyzed some assumptions about how revenues and because the Townlot and Downtown areas expenditures will change over time should are especially valuable parts of the City, be reviewed. . and pressures for redevelopment there will be stronger than elsewhere. Also, with the 3.2 Assumptions about Variables Affecting completion of the Local Coastal Plan Future-'Revenues and Expenditures during the early part of the decade, now dormant efforts to develop and redevelop Several assumptions about some key that area should intensify. variables affecting future revenues and expenditures have been made in this The third scenario sees a phase-out of the analysis. small-scale independent operations during the next decade, while the major oil First of all, Proposition 13's limits on the companies continue operating near their property tax rate and property value present levels. In many ways, this scenario assessment are assumed to remain in may best approximate what will actually effect. We also assume that most oil happen. Discussions with the major oil properties that remain productive will not. companies in Huntington Beach indicate change owners, thus limiting re-assessment that they expect to continue operating at of the surface areas to annual increases of least another 20 years, and that the two percent per year. (See Section 2.3 application of enhanced recovery above.) The City's share of overall technologies may not dramatically increase property tax revenues collected in production, but will offset recent declines Huntington Beach was assumed to remain and keep production levels up for several approximately 20.7 percent. years. At the some time, the production of the independents has continued to decline. Changes in the . amounts charged for Generally speaking, they cannot apply the drilling, inspection and waste water enhanced recovery technologies available permits were not incorporated into the to the larger companies. As their analysis because these fees account for production drops and the value of the only a small percentage of total annual surface for housing continues to rise, these revenues. parcels would gradually recycle. On the expenditure side, the costs to the The last scenario considers the possibility City for providing services to future oil that, rather than abandoning their operations will be a function of how much operations, the small independent oil of the land remains in oil production, the companies in the Townlot, along with one number of wells and related facilities to be or more of the majors, join together and served, the level of service to be provided, form a "unit." By combining the resources and the inflation rate. In the following of all the participants, the unit has the analysis, the level of service is assumed to capital and the surface acreage to apply remain constant; consequently, total City waterflood and other enhanced recovery expenditures are assumed to increase techniques. Thus, production increases and according to the inflation rate and the the operations continue throughout the City's overall growth pattern. In the 19801s. Report #1 in this series, following analysis, total City expenditures "Preserving Surface Access to over the next ten years were projected 14 using the City-wide Fiscal Impact Model Weighted Average Model's expenditure line and the City's General Plan, which helps as our best estimate of what City define the future growth pattern and mix expenditures will actually be, and the of uses in the City. These total annual City-wide Model's expenditure line as an expenditure estimates were used to estimate of `the probable maximum or calculate oi1's share of City expenditures upper limit of actual expenditures. which are not directly assignable. Scenario I - Oil Revenues and A ten percent inflation rate is alsoExpenditures, i Operations assumed.l l Remain Relatively Unchanged. In summary, the following assumptions In this scenario, the current number of have been made for the analysis in Sections wells (1460) remains through 1990. The 3.2 - 3.5: area devoted to oil stays at 472 acres and overall production is constant. - Proposition 13 controls on tax rates and property assessments will apply. Revenues derived from the oil production fees and royalties rise 10 percent per year - The City's share of the property tax which is the assumed inflation rate. will remain 20.7 percent. Property tax revenues rise at only two percent per year due to Proposition 13 - Rates on drilling permits and other fees limitations. All other revenues remain the will not change. some, assuming that the some number of permits is issued each year, and that fee - Total City expenditures are estimated rates do not change. Overall, revenues using the City-wide Fiscal Model and increase, but not as fast as expenditures. the General Plan. Figure 3.Ia shows oil revenues and - Level of City services stays constant. expenditures for 1980-90. Under Scenario I, oil operations are a net revenue - Inflation will average ten percent per generator for the City under the assurned year. conditions primarily because the oil production fee, which makes up two-thirds 3.3 Analysis of Scenarios of the revenue, is tied to the Consumer Price Index; therefore, this portion of the In all of the following scenarios, revenues keeps pace with inflation. expenditures are calculated two ways. The first method uses the "Weighted Average Figure 3.Ib shows the some scenario in Model" developed in Appendix A because it "constant (1979) dollars," that is, the is probably the most accurate and revenues and expenditures are adjusted for reasonable of the available models for inflation. This figure shows more clearly calculating oil-related expenditures. that net revenues (reflected in the distance Expenditures are also predicted based on between the revenue line and the the City-wide Model because it is the expenditure lines) decrease over time. technique used in many previous analyses This is because one-third of the revenues and it gives the highest cost estimates of generated by oil are not indexed to the all the models analyzed in Appendix A. inflation rate. In other words, total Both models were used to plot expenditure revenues simply do not keep up with curves in all of the figures in this section; inflation. Despite this decline, oil thus, each figure shows two expenditure operations would continue to contribute lines. Perhaps the best way to interpret net revenues throughout the decade. these graphs is to view the 15 Z31,(.,e) Scenario 2 - Phase Out Oil Operations from aso t Townlot. a°oThe Townlot and Downtown areas include some of the most valuable real estate in Huntington Beach. Currently, they are also among the poorest. sections of the oil field in terms of production. A feasible scenario, then, is one where the value of the surface for other uses (e.g. housing) outweighs the value of the oil being recovered. In such a situation, it is .. r•"• reasonable to assume that the oil producers too will gradually abandon their wells in this area and sell the land for development. ° There are 13.8 acres of oil land in the Townlot. Aminoil owns approximately .8 acres) for wells that a•e directionally IVeo n n u n usee v meeo 0o drilled under the ocean. Since these wells do not derive their oil from the field under ne,-.,,m,,,e ww N oaad:w u, e9e0-19": m, t mn a+. the Townlot, they are assumed to remain. The other 13 acres are presumed to phase out as follows: one ocre per year, the first " 10 years, and three acres in the last year. Figure 3.1(b) The 95 wells are assumed to phase out as follows: Nine wells per year the first 10 years, and five wells in the last year. Conditions in the rest of the City remain 1.° unchanged. 120 As the wells and acreage decrease, oil revenues from oil production fees, property ,............ ......... taxes, and permit fees decrease . '°° accordingly. It is assumed that every well in this area is paying wastewater fees, but ,O that no drilling or redrilling is done here. ••••••••••••••••••••••••••••••••••••••••••••-•••»••»••• The overall City revenues from oil decline only slightly. Very little revenue is currently derived from this part of the field due to its low productivity (see Figure .° 3.2a). Expenditures also decrease slightly as the ° number of oil acres and oil wells in the Townlot decrease. roe° u tl ❑ 4 es Ie V U ev a° Figure 3.2b shows revenues and W) "' ""'""""`°' °'ao-'°° ` ' t """ expenditures for this scenario in 1979 "'a"""""'' dollars (adjusted for inflation). key 01110 Revenues see Expenditures, Weighted Average Model sew Expenditures, City-Wide Model 16 f w,°oo'• Figure 3.2(e) Note that although both revenues and expenditures decline, net revenues (total revenue minus total costs) are slightly less / than under Scenario I.°° sr' From a fiscal standpoint, although net ,,, revenues are slightly less in this scenario than in Scenario I, the City continues to net a high level .of revenue from oil. At the same time, valuable land is mode available for other uses. -"'� •"'� Scenario 3 - All Independents Phase Out; • N�•M •.• '" Only Majors Hemain. There are 95 acres containing 268 wells that belong to oil producers other than the three major companies. Scenario 3 could be realized if the value of all real estate in Huntington Beach ,increases such that oil moo " 1 2 " " 'f '° " Is °° °0 production by the independents is less profitable than other land uses. Figure c.i>^.�oil <.,�..M , ��. ,9fo-,.� �,a .. .... 3.3a shows what happens to oil revenues and expenditures if the independents phase 1 10 000' out as follows: nine acres phase out per Figure 3.2(b) year for the first 10 years, then five in the last year; 24 wells phase out per year for the first ID years, then 28 in the last year. ° Oil revenues from the oil production fees, property tax, and, permit fees decline as wells and acreage decrease. All independents are assumed to need wastewater permits, and revenues derived °^ from them are reduced along with the wells. The number of drilling and redrilling w permits is not affected. The amount of revenue lost related to total revenue is " • ... small because these wells do not, on the ~ average, produce large quantities of oil. ° Costs, however, are borne according to number of wells and/or acreage. A well that produces large quantities of oil ]° requires approximately the some City services as a well that produces very 191C .1 " " " '1 '° " Is 19 °p little. However, the better producing well generates greater revenues to the City. city l&oil Wrvt !$W" Lq.r.liturn. 198o-1990: t lot �t Thus, the ratio of revenues to costs is 11979°u1Lr.1. greater for highly productive wells. key NEW RsvenW� fr• BRyendltorems, Weighted Average Model sees tkpenditu es, city-ride Model 17 Figure 3.3(a)', Because the independent wells generally produce less oil per well than those of the majors, phasing them out removes most of s0O the wells with the worst revenue to cost ratios. This means that although total / revenues overall are lower because there are fewer active wells, total costs are .• °� reduced even more, thus improving the �° ",,••^" overall revenue-cost ratio. Therefore, net -,,r•' revenues in real dollars decline less in "••.•••'• ,.•' Scenario 3 than in either previous scenario. ISO ..•''"_ (See Figure 3.3b). ,SO ,,.�••"••• Scenario 4 - Unitization of the Townlot Area; ter Oil Areas Do Not Change. o Unitization is a method by which several independents can legally join together to act as if they were a single company. This 19e0 e1 e] a s. es M s) se e9 ro allows them to apply enhanced recovery technologies and increase their CIWy im Oil 19 9 0-19 901 weep m. production.* Enhanced recovery often involves pumping water into an oil pool in $10.000" which primary prockLetion is nearly Figure 3.3(b) completed. By injecting water at certain points in the field, oil production in all wells can be dramatically improved. To do this in an area with several owners, all 140 operators must cooperate and help finance the venture. Unitization is often the only way additional oil can be recovered in significant quantities. In this scenario, unitization takes place in goo ....... the Townlot area. The number of wells remains the same because while some new '° wells are drilled, some existing, inefficient ............... wells are abandoned. In the first two so •• • . , years, drilling and redrilling activity • increases. Overall acreage drops by five acres because of the abandonment of some i0 old facilities and the consolidation of most new ones. Production levels are unchanged. 90 11 .J H .s M V .. .e eo „ ; ;, n ., "N Vy+•fi[urrv+. 19PW1990: Idy..dmwPmcaut IS See Report #1 in the series, "Preserving 0979 [tiller.,. Surface Access to Underground Oil Reserves in Developed Areas." key aaa Lnpandituraa, Weighted Average Modal wing Upandituraa, city-wide Modal 18 Figure 3.4(a) Beginnning in the third year, acreage is stable at 8.8, and all other factors are the same except annual production, which increases by one million barrels. / Figure 3.4a shows the jump in revenues caused by the increase in oil production fee revenue from a million extra taxable barrels of oil. Because the number of wells is the same, and total acreage stabilizes at an only slightly lower level than before, ,. •'� costs over the 10 year period are nearly "° y.-•'� the some as in Scenario I. "� �•. •'" Figure 3.4b shows that in real dollars, net "�• revenue is greater in Scenario 4 than in any of the previous scenarios, while costs actually decline. Clearly, unitization could increase revenues while reducing costs by increasing productivity without increasing 1900 n n a .. n .e v u w the overall number of wells or acreage.12 atY` oil Pe mom eN UGa.11rum• lqY lm: 9 Ict unitl'u.i•a.. 3.4 Summary These scenarios represent four possible "°°°°'' Figure 3Ab) futures for oil operations in Huntington Beach. It is not known which, if any, of them will take place. Most likely, none of them will occur exactly as portrayed in this analysis. However, some conclusions can be drawn from these scenarios. First, in any of these cases or combination ................................ of them, it is clear that continued oil """ operations will generate significant net revenues for the City. Second, if unitization and enhanced w ......................................................... recovery projects do occur and are successful, they can help increase the w revenues to the City without significantly increasing service costs. In some cases, City expenditures associated with . oil operations could even decline slightly, while revenues would dramatically increase. Third, the independent operators do not 1 9 1 0 „ „ ,• " ,6 " eA I, •0 contribute a large portion of the revenues generated by oil operations, and unless Clt Vi ebll fl ,y.. panl¢urte, 19flM119411: V ilnt nliizu n., unitization takes place, they will not in the future. The three major oil companies in key w� aeveowe ... EKpendit"e., Weighted Aver&g* Model ... lxpemlture., city-wide Model 19 Huntington Beach -- Aminoil USA, Chevron - USA and Union Oil -- are chiefly 3.5 Garfield/Goldenwest and responsible for the significant net revenues Town I of owntown Areas afforded the City by current and continued oil operations. (See Figure 3.5 .) The Garfield/Goldenwest and the Townlot/Downtown parts of the City were analyzed specifically because they are examples of areas where the existing oil operations may be changing (See Figure Figure 3.5 3.5a). Both of these areas are of great interest for future development other than oil. Union 98 chevron 12% Downtown/Townlot: As mentioned above, ,.... the Towniot/Downtown area is especially interesting in light of the possiblity of it recycling to new uses and its potential for ":..v unitization and enhanced recovery. These possibilities were analyzed in Scenarios 3 11� and 4. This section simply separates out ' Inde endent the Townl at/Downtown from the rest of r,! the City to help highlight the fiscal impacts specific to that area. Figures 3.6a to 3.6c illustrate the following possibilities: 1) the existing oil operations remain active during the next decade, 2) the oil operations gradually phase out during the 198(Ys and 3) a unitization and enhanced recovery program is undertaken. Aminoil 68% The analysis indicates that oil operations in this part of the City currently generate net revenues. However, rising service costs, and the fact that total revenues Oil Revenues , 1979-80; cannot keep up with .inflation, will make these smaller operations net "losers" Majors vs . Independents . sometime during the 19801s, even if production remains at today's level. However, if a unitization program is undertaken and is successful, the oil operations would become significant net "winners" throughout the decade. Garfield/Goldenwest: The future use of the Garfield/Golenwest area has been the subject of considerable debate in the City. One factor which could be considered in any decision about the best use of this land is the fiscal impact of continued use as 20 i Townlot/Downtown Garfield/Goldenwest Q { 6 i f 8 i CITY OF HUNTINGTON BEACH \_\ /`- ORANGE COUNTY CALIFORNIA HUNTINGTON BEACH, C4LIFORNIA PLANNING DIVISION Figure 3.5(a) 21 Figure 3.6(a) -Tigure 3.6(c) 1.0 .0 IN p IW w eo to w m 19e0 el ex U e. es ee e! u 1, 90 „ . .. . ... ........... ... ..............«.... p 4........... ♦ nn♦nnunnumuunnnunuunm.munuvo.. 19e0 el a eJ e• Its ee v to S9 90 oil h m u.l eq.reltures, 19110-1990: Oantv,t O %JiUau ' liot hrm Oil nmm X utl f nuen. I9B0-1990: lmltlsetim 11999 ooll.r.l. ll9'19 poi lenl . f1,wo. Figure 3.6(b) key � Xeventsee eee UpeeAlturea, Weighted Average Model 50 Items Expenditures, City—Wide Model .o I ' an oil production area. Figures 3.7a and 3.7b indicate the probable impacts of 1) oil operations continuing unchanged in this '•.«.... area for the next 10 years and 2) the operations gradually phasing out. At this ,o time, the oil pool under this area does not appear to be a likely candidate for �ti unitization, so such a project was not analyzed. ,9eo a u u e. es a. u 9. ea ao The figures indicate that current fiscal impacts are quite insignificant -- the operations demand few costs but contribute little revenue. During the decade, even if production could be I, ,I ....... maintained at current levels, the „ ,,,, ,,,;r,,,_,_ operations tend to become net losers; but again, the impacts are so small that they are essentially inconsequential. 22 11 COW. f1000. - Figure 3.7(a) Figure 3.7(b) >o W .0 10 la 20 20 .e.eeww.ww...ewww.wee.ee.e.ewrwe.wNe.e..eww NMee ........................ 10rra•u• r.•.u•.•.•. 1p , Neaaee ..Nee rnb.nu•nn,eNN • eeNNeeeeNNeNee Mo 11 tl 93 Y I9 10 .1 la 10 00 1010 11 tl Il 1• e3 1. Ir O 19 90 :.wrt telWU.ltivacat .tree Oil Pasancs end FY..nff t:uw, Gert ield.Tnldeac+[A[as Oil aswales vd o9vSltww. )990-19901 N .It Rmitiau 1910-1990: 011 c'.uuu Rnae-wc 11999 Wtlanl, (1979 Do1Lo). key 11000 IIIIIIII pevenoes Figure 3.8 ese Expenditures, Weighted Average Model WON Expenditures, City-Wide Model 50 Alternative Development in the Townlot/ Downtown Area: Another aspect of the eD question of whether oil production should be encouraged to continue centers around the development that should replace oil 30 operations. This section compares the fiscal impacts of oil operations in the 70 Townlot/ Downtown to [hose of likely alternate uses there.' 10 The Town[ot/Downtown area is predominantly medium-density residential, and oil lands are zoned to recycle Into the 19e0 n 19 a as la u 91 as 90 same kind of use. This, combined with an acute housing shortage, make it very probable that any oil land in this area that recycles will become medium density residential. Tovnle[ Medium-dansfty Mnslden[fal Revenues and Espnndttures, 1990-1990: Phase-in Tftfrteen Acres 11979 Dollars), It The Garfield/Goldenwest area is a special case. A study is now being conducted to determine the best future use of the land in that area. 23 Using the City-wide Fiscal impact Model, in the Townlot (Figure 3.5a) follow a revenues and expenditures resulting from similar trend at a similar magnitude (after recycling of the 13 oil acres in the Townlot 1988) as the revenues and expenditures area to medium density residential can be from medium density residential in that approximated. This is illustrated in Figure area (Figure 3.8). Further, it should be 3.8, with half of the acreage recycling in noted that neither of these development 1980, and the other half in 1982. types has a very large negative fiscal impact -- in the range of five to 10 The numbers shown are rough estimates, thousand dollars per year. but the trends and general magnitudes are clear. As time goes on, revenues decrease The conclusion is that fiscal impacts, while and expenditures increase slightly. It is important, do not provide a criterion for apparent that this type of development choosing one of these development types generates net revenues in the year it is over the other. This underscores the built, but because of rising costs, inflation limitations of fiscal analysis -- it is a very and limits on property tax rates and important input into the decision-making assessments, it tends to become a net loser process - but there are other shortly afterward. (See Section 2.3) considerations of great importance that are involved. Section 4.0 discusses these The most revealing aspect of this issues more fully. projection is that the revenues and expenditures from oil operations remaining 24 4.0 Beyond Fiscal Impacts Previous sections have discussed the 4.1 Non-Fiscol Costs importance of fiscal impact analysis in land use decisions. Although knowledge of Aesthetics: Oil wells impose adverse fiscal impacts is important, that visuo , noise and odor impacts. Pumping information alone is not sufficient for the units and tanks impose the negative visual decision-maker. The effects of a land use impacts associated with onshore oil on the City's budget must be balanced with production. They' are large, unattractive other possible impacts brought about by facilities that give an "industrial" look to choosing one land use over another. This any area in which they are located. section, while not intended to discount the value of fiscal analysis, underlines its Occasionally, oil wells emit gases that limitations by briefly presenting some have a sulphurous odor. Although the odors major "non-fiscal" costs and benefits. may not occur daily (and depend, of course, on the direction of the wind), when they Certain aspects of oil production are are present, the smell can be offensive. known to have impacts on the quality of life that are difficult to express in terms Finally, the pumping units, injectors, of dollars. Market forces alone do not compressors and drilling rigs can be noisy. usually recognize these effects and fiscal The severity of noise impact varies with analysis is not intended to account for one's proximity to the equipment and the them. They must be recognized and type of equipment. introduced into the discussion through some other mechanism (e.g. the political The costs associated with these kinds of process). adverse impacts include the diminished enjoyment of recreation areas, lowered Some of these "unpriced" costs and property values and reduced visitors to benefits associated with oil production are nearby commercial areas.13 discussed briefly below. 2'5 Some extreme odor and noise impacts can Im roved Balance Of Payments When the .also impose adverse health effects on nice btates spends more money on persons near the offending site. imports than other countries spend on American exports, there is a net flow of O ortunit Costs: An opportunity cost is dollars out of the country. This is called inevito ly imposed in any situation where a an unfavorable balance of payments. The choice is made between two or more undesirable ramifications of this situation alternatives. By choosing any of the are well known -- it aggravates inflation alternatives, the opportunity to have one and weakens the dollar. Because imported of the others is necessarily foregone. In oil is our single largest import, substituting the case of oil production in Huntington domestic oil for imported oil is a Beach, an opportunity cost is incurred by significant step to help reduce inflation using land for oil production rather than and strengthen the dollar. some other kind of development. EmEm l�: A third benefit the City All land in Southern California is becoming erives rom oil operations is the increasingly valuable. Housing is in employment the industry brings to the particularly short supply. In light of this area. About 600 persons are directly situation, the opportunity cost of oil employed in oil operations in Huntington production may be too high in some parts Beach.14 In addition, oil operators of the City. On the other hand, developing support local businesses by purchasing the surface precludes the opportunity for goods and services in the City. (This is oil production. Unless it is clear that oil sometimes called a "multiplier effect".) production is less valuable than another use of the land, preserving access to the oil 4.3 Federal and Local Perspectives on from the surface is quite important. For Non-Tis-Fa I Costs and Renefits example, if all oil surface in the Townlot were recycled to other uses, unitization Interestingly, two of the major benefits of (and recovery of millions of barrels of oil) oil production (reduced dependence on would no longer be possible. (See Report imported oil and improved balance - of - #1, entitled "Preserving Surface Access to payments) are greater - than - local in Underground Oil Reserves in Developed scope. This means that the City's oil Areas", for a detailed discussion of this production protects the national interest problem.) by helping to improve the economy and contributing to national security. 4.2 Non-fiscal Benefits However, many of the costs, such as offensive odors, visual impacts and reduced Reduced De endence On Foreign Oil: 'A property values, are local in nature. widely ac nowle problem facing the nation is the uncertainty of our energy The fact that the positive and negative supply in an emergency. Every barrel of impacts of oil operations are primarily felt oil produced in the United States is at different levels of government, potentially a substitute for an imported increases the difficulty in assessing them. one, and the importance of small fields in Coastal Energy Impact grants, such as the contributing to the domestic oil supply one funding this study, provide funding should not be understated. For example, from the federal government, which the Huntington Beach field is the seventh benefits from increasing energy largest oil producer in California and production, to local governments to help produces three percent of the state's oil. them analyze and mitigate the adverse Thirty-five percent of California's oil effects of increased energy production production comes from fields even smaller which tend to impact the local community. than Huntington Beach. 26 Or 5.0 Conclusion Before concluding this report, two This trend should continue through the important qualifications to the analysis 1980's — oil activities will generate must be stressed. The first is to reiterate revenues of similar magnitude for the next the simplifying assumptions made decade. However, even if production throughout the report. The second is to levels stay The same, these revenues tend emphasize the limitations of fiscal analysis to decline slightly over the next ten years, — it is only one important input to the because property tax revenues fall behind decision-making process. the inflation rate. This report set out to answer the general An important finding in this analysis is that question, what are the fiscal impacts most of the oil-related revenues are tied to resulting from oil operations on the City of production levels. Thus, the three major Huntington Beach? This question was oil companies with operations in the City addressed for 1979-80, as well as for the (Aminoil, Chevron, Union), which account next decade under four different for over 90 percent of total field-wide scenarios. Further, specific attention was production, contribute most of these given to the Townlot/Downtown and revenues to the City. Even if all the Garfield/ Goldenwest areas, including how independent oil operators were to oil operations might compare to other land phase-out of production by 1990, net uses. revenues would remain about the some through the 1980's (see Section 3.3). As emphasized by the first qualificaton above, the exact numerical figures may be Other noteworthy findings are the subject to discussion, but the general consequences of unitization in the trends and magnitudes are clear. Oil Townlot. Such a project would activities are a net revenue generator for dramatically increase the production of the City. In 1979-80, the City received many of the less efficient wells and, about $800,000 in net revenues from oil although net revenues would be declining operations (see Section 2.0). by the late 1980's, total net revenues 27 generated for the decade are greatest in in those areas are likely to involve revenue this scenario (see Section 3.3). losses as well. On the basis of fiscal impact, neither land use option is The study of oil revenues and expenditures necessarily preferred. Although the fiscal in the Garfield/ Goldenwest and Townlot/ impacts of both uses are important, a Downtown areas are quite revealing. With decision to encourage one over the other the exception of a future where unitization will depend on other considerations beyond of the Townlot takes place, oil operations fiscal analysis (See Section 4.0). in these two areas will be net revenue losers for the City. However, the oil This is not true, however, if the Townlot is activities in these areas cannot be unitized and enhanced recovery is considered a major financial burden to the successful. In that case, the City may gain City. The magnitude of funds gained or significant revenues from oil activities in lost by the City in these two cases is in the the area (See Figure 3.5c). range of $5,000-$10,000 (see Figures 3.5a, b, c, and Figures 3.6a, b). Further, based As a result of Proposition 13, property tax on the City-wide model's estimate of revenues, which have been the traditional expenditures and revenues generated by financial base of local governments, will medium-density residential development, not easily keep pace with inflation. it, too, is a net revenue loser of similar Consequently, for some land uses, the costs magnitude (See Figure 3.7). to the City in providing services will tend to exceed the revenues generated by those Here again, the limitations of fiscal uses. This study indicates, however, that analysis are confronted. Oil activities in at least for the next decade, City-wide oil the Garfield/ Goldenwest and Townlot/ operations will not fall into this category Downtown areas will probably result in and will continue to generate significant revenue losses for the City. net revenues to the City of Huntington Medium-density residential developments Beach. 28 APPENDIX A Models for Distributing City Expenditures to Different Land Use Types An important part of fiscal impact analysis is trying to determine what proportion of City expenditures can reasonably be attributed to the different land uses and related activities in the City. As discussed in the text (Section 2.2), a few types of expenditures can be traced more or less directly to different land uses. Examples were expenditures on police and fire calls where the City keeps records of the locations of the calls. We assumed that the percentage of total calls generated by each land use category was a reasonable measure of the percentage of total expenditures on those calls that each land use category generated. Another example was the expenditures for the salary and benefits of the City oil inspector. We assumed that his duties were tied directly to oil production activities in the City and that those expenditures could be "assigned" to oil production uses. the great majority of expenditures, however, cannot be traced to particular uses. Consequently, a model for estimating the proportions of expenditures, among different land uses, which are not otherwise directly assignable to those land uses, was developed. EXPENDITURE MODEL A Wad on Models Models are approximations of reality. They are tools" for making complex problems comprehensible. This necessarily means that simplifying assumptions must be made about the problem to be modeled. It is very important, therefore, to make reasonable, defensible assumptions. The key to building a good model is to maximize its accuracy without making it too complex. A good model is accurate enough to be useful, and simple enough to be clearly understood. The expenditure model used in the analysis was designed with this as a goal. Some important issues were considered in constructing the model. The first is the information required by the model, because the available data limit the range of models possible. The model sought is the most sensitive possible with information that is readily available. Secondly, the expenditure model must distribute costs among the various types of land uses in a way consistent with expectations formed by reasonable assumptions and informed opinion. Although the purpose of this model is to estimate unassignable expenditures attributable to oil activities, it cannot be used for that purpose unless it distributes costs among all land use types in a way that is reasonable. Finally, the model and analysis should be reproducible.15 Any reader should be able to understand "where the numbers came from," and another analyst should be able to accumulate the data and use the model at some time in the future. If this is not possible, the usefulness of the study is questionable. 29 The Expenditure Model for Distributin Unassi noble Costs Two major assumptions were made in designing a model to distribute unossignable costs. First, unassignable costs should be borne by all members of the City, according to some determination of each member's "fair share." Services whose costs are unassignable are treated as "public goods".16 A public good makes the community as a whole better off, no matter how much of the good each member of the community actually "consumes". Benefits from these goods accrue to all as members of the community, and not solely on the basis of consumption. Therefore, all who live, do business, or own property in the City should contribute their share to the community. To determine each segment's "fair share", we next assumed that two key factors can be used to estimate the share of City expenditures for each land use type. These are 1) the area of the City a particular land use type occupies, and 2) the number of units of that land use type located in the City. Area is simply the acreage a particular land use type occupies. It can be argued that.os more area in the City develops, expenditures increase, and that the acreage devoted to different uses reflects their share of community expenses. "Units" are measures of-the degree of development of a particular land use. For residential uses, a "unit" is a dwelling unit. For commercial and industrial uses, the number of "units" is assumed to equal the number of business permits issued to that particular use; for oil, it is the number of wells; (obviously, vacant land has no "units"). The logic for this is that each "unit" is an entity that does business with the City, and each unit generates costs to the City. As units increase (i.e., as development increases), costs increase. The relationship between acreage and units is called "density" and refers to the ratio of units to acreage (e.g.: dwelling units per acre, oil wells per acre, etc.). We assume that as density increases, total City expenditures increased (although the average expenditure per unit may decline). The models analyzed use acreage or units or both (density) as measures of the share of total unassigned costs that cm be attributed to different land uses. Analyzing Historic Data The first approach for estimating unassigned costs for different land uses was to use cr computer to analyze historic data. By using a statistical technique called "stepwise regression", we tried to see how the City's total budget has changed over time and to relate those changes to changes in the units and/or developed acreage of different land use types. Unfortunately, accurate information is available for only the last few years, and despite adjustments for time and inflation, the variables were so similar to one another (highly correlated), that no inference could be made from the results with any degree of confidence.* Therefore, efforts to design a model based strictly on past data trends and regression analysis were abandoned. * Residuals and Pearson correlation coefficients were analyzed. The consumer price index was used to adjust for inflation and an attempt to "detrend" the data by using "dummy" variables was made. The variables were too highly correlated to give meaningful results. 30 Four other models were tried. The first uses only the proportions in total developed acreage to estimate the share of unassignable costs for different land use. The second uses only units. The last two use both acreage and units (density) to estimate the proportion of expenditures for different Land uses, one simply averaging acreage and units, and the other relating the two factors by a "weighted average" technique. These are discussed below. 1. Developed Acreage or City-wide Model Model I determines the fair share of unassigned expenditures by the acreage of each land use type; each land use receives a share of unassigned costs equal to the portion of total developed acreage occupied. This is the approach used in the Ultrasystems or "City-wide" Fiscal Impact Mode1.11 For example, since residential use occupy 78 percent of developed acreage in Huntington Beach, 78 percent of unassigned expenditures are attributed to residences. By the same method, 10 percent of unassigned costs are attributed to commercial uses, 8 percent to industrial uses, and 4 percent to oil. Note that vacant land receives no share of costs. This model is considered one extreme, taking only area into account. Advantages: This model is simple, easy to understand, and reproducible. The data requirements can be readily fulfilled. Disadvantages: It accounts for only one of the key determinants; it assumes that degree of development is not an important factor in distributing unassigned costs. It also implies that every acre generates costs equally. Further, since it is only concerned with developed acreage, it does not account for vacant land. I1. Units Model Model 11 relies solely on degree of development to apportion unassigned costs among different land uses. Recall that "units" are a measure of degree of development, and that residential "units" refer to dwelling units, commercial, and industrial "units" are equated with business licenses, and an oil "unit" is an oil well.12 Note, again, vacant land is assumed to be costless. This model is considered the other extreme, taking only degree of development into account. Advantages: This model is also simple, easy to understand, reproducible, and has minimal data requirements. Disadvantages: It completely discounts area as a cost factor, and assumes each unit generates costs equally, regardless of density. Since there are no units on vacant land (by definition), it is left out of the analysis. Most importantly, the distribution of costs among the uses seems skewed - residential is assigned nearly all costs, while industrial gets almost none. The next two models try to account for both area and units. 31 III. Simple Averaging Model Model III simply averages the first two. For example, residential uses are allocated 78 percent and 92 percent shares by the first and second models, respectively. This averages to 85 percent. By the some process, commercial receives 7.3 percent, industrial 4.7 percent and oil 3.0 percent. Advantages: This model does not severely increase complexity, data requirements, or effect reproducibility. It is still comprehensible, and more sensitive to factors that actually affect costs. Disadvantages: Area and degree of development are given equal importance in determining the share of unassigned costs attributable to each use. This means that costs do not vary according to the density of use and assumes the some average density for all uses. Further, vacant land is unaccounted for. IV. Weighted Average Model Model IV accounts for area and degree of development in a different way. It weighs the two factors so that it is more sensitive to density. This is done by adding the number of units assigned to a particular use to the number of acres assigned to that use. This sum is divided by the total of all units plus all acres in the City. This "weighted average" gives slightly more importance to degree of development as a factor than acreage. This means . that more densely developed acres are more costly than those less densely developed. (This is true even if average cost per unit is less in more densely developed areas; overall costs tend to be higher in higher density areas.) This model attributes 87.3 percent of unassignable costs to residential, 5.2 percent to commercial, 2.3 percent to industrial, 2.3 percent to oil, and 2.9 to vacant land. See Table A.I below. Advantages: This model has the same data requirements and reproducibility as the previous models. It is slightly more complex, but its increased complexity can be justified by gains in sensitivity and accuracy. It is superior to the third model for two reasons. First, it can account for vacant land in a reasonable way. Second, by giving slightly more weight to the degree of development factor, the model is more sensitive to density of use - i.e., higher densities are considered more costly. This is a more realistic treatment of how the type of land use is likely to effect costs. 32 Distribution of Unassignable Costs Using Weighted Average Model Acres Units Sum % of Total Residential 65 9,207 62,251 71,458 87.3% Commercial 9 1,197 3,027 4,224 5.2 Industrial 6 925 965 1,890 2.3 Oil 3 472 1,460 1,932 2.3 Vacant 17 22,410 0 22410 2.9 TOTALS 14,211 67,703 81,914 100.0% Source: City of Huntington Beach Planning Division. TABLE A.1 huntington beach planning division 33 Disadvantages: Model IV is the least burdened by the disadvantages discussed above. Arguments of a more general nature about the assumptions and level of sophistication of all these models are discussed elsewhere in this section. For the purposes of this analysis, the last model meets the criteria for a good model laid out at the beginning of this section better than the others considered. Among the models developed, this "Weighted Average Model" is the most accurate, with least confusion and with minimal data requirements. It generates reasonable results. This is the model used to carry on the analysis (although cost calculations using the "City-wide Model' are also presented for comparison). 34 APPENDIX 8 Revenues From Other Energy Facilities Although this report focuses on oil operations, there are other energy facilities in the City and coastal zone. These include a Gulf Oil Company tank farm and affiliated pipeline franchises; a Chevron USA tank farm; a Southern California Edison Company power plant, tank farm and pipeline and utility franchises; and other pipeline and utility franchises. These facilities are likely to remain in Huntington Beach for some time. Because of their permanent nature, a fiscal analysis of these operations is much less relevant than a similar analysis of the "less permanent" oil operations. It is important to note, however, that the. City derives significant revenues from these facilities. These revenues figures are presented below. The revenues for 1979-80 are as follows. Gulf Tank Farm: Property Tax $ 6,690 Pipeline Franchise 6,047 TOTAL $T=1 Chevron Tank Farm: Property Tax $ 4281 TOTAL $ u,1tSl Edison Plant and Tank Farm: Property Tax $364,263 Pipeline Franchise 4,362 Utility Franchise 198 131 TOTAL $�b6i9�b Southern California Gas: Utility Franchise $529 642 TOTAL $ Other Pipeline Franchises: Pacific Lighting $ 12,540 Standard Gas $ 108 TOTAL $ Terri$ Total revenues to the City from these facilities is $ 1,126,064 for 1979-80. Pipeline and utility franchise tax rates are set by contracts between the City and the various companies. The major factors that affect pipeline rates are size and length of pipe, and the yearly flow through the pipe. Utility rates are based on gross sales of the product carried by the franchise (e.g. gas, electricity). 35 Many of the contracts are old, and •set rates that are quite low. One strategy for increasing revenues from these sources is renegotiation of the contracts when they expire. A City ordinance passed in 1978 established pipeline franchise rates to be applied in future contracts. The base rates are higher than those set in the past, but more importantly, they are adjusted annually according to the "Wholesale 'Producer' Price" index - a measure of the inflation rate. As the old franchise agreements are renegotiated in accordance with this ordinance, the City can expect increased revenues that will keep pace with inflation. Finally, some of the contracts are "indeterminate", i.e. they have no termination date. It may be possible for the City to renegotiate these by mutual agreement. Table B.1 shows more explicitly the terms of each franchise. 36 s HUNTINGTON BEACH PIPELINE ANO UTILITY FRANCHISES Length of Monies to City Classification Franchise Term FY 79-80 Commentary Regarding Franchise/Terms Utility So Cal Gas 40 yre ending S 529,642 Agreement contains provision that faquires a 2007 rate of return no lees than the highest percentile received by any other city being served by So Cal Gas. Utility So Cal Edison Indeterminate 198,131 The aggregate effect of the fixed minimal rate (adopted in of return, Indeterminate length of term, and the 1949) geometrically increasing costs to the City for street lighting has resulted in perhaps the poorest ratio of franchise revenue to energy costs of any city dealing with So Cal Edison. Pipeline Union Oil- 25 yrs ending 422 Virtual fixed return to City--unchanged since 1989 1964-- based on 112 cent per inch of pipeline diameter/pr lineal foot, or 2% of the gross annual receipts arising per use of franchise, whichever is greater. Pipeline Atlantic 25 yrs ending 1,249 Same terms as above. Richfield- 1988 Pipeline Texaco" 25 yra ending 2,882 Some terms as above. 1988 Pipeline Gulf 50 yrs ending Present rate of return--fixed since 1933--has 1983 3,647 been $.04 per barrel X 2%. (Combined) 'Pipeline Gulf 50 yre ending Present rate of return—fixed since 1956--has 2006 been 11.04 per barrel X 2%. Pipeline Gulf 25 yrs ending 2,400 Present rate of return is fixed at $2,400 per (tank farm) 1900 annum. Pipeline Standard Gas 50 yrs ending 108 Present rate of return--fixed since 1956--hee 2006 been 2% of the revenue derived from use of Franchise. Pipeline So Cal Edison Indeterminate 4,362 Current rate of return Is derived from 2% of (1958) the gross annual receipts arising from use of franchise. Pipeline Pacific 40 yre ending 12,540 Current rate of return is derived from 2% of Lighting 2010 the gross annual receipts, and/or 1% of the Service Co, revenues from the sale of gas within limits of City under Franchise. • These franchisee are related to oil production in the City, and were included in oil revenues. Source: Memorandum from Internal Auditor to City Administrator, July 8, 1977, updated with figures from the City Finance Department, August, 1980. TABLE B.1 Mp huntington beach planning division 37 NOTES 1) Although this engine company has a special petroleum fire capability, it is frequently used to fight structural fires, thereby providing extra service to the City as a whole. Further, the tank farms and pipelines that are not directly related to oil. production in the City (see Appendix B) require the protection provided by the company. The expenditure figure shown above is a staff estimate of the oil production share of total costs for this company. 2) Patterson, George M., "Allocating Expenditures to Land Use Categories", p. 137, Municipal Finance 36, May 1964, p.p. 136-9. Also see Patterson, George M., "Where Does the City Spend its Money?" Western City, September, 1963, pp. 46-47. 3) The City receives additional annual revenue from' the State of California Lands Commission equal to one percent of state royalties on tideland oil leases. This fund is revenue budget (604) "State Oil and Gas Lease", and was equal to approximately $ 100,000 in 1979-80. However, these monies are not general fund revenues - i.e. they are to be used for purposes specified by the State. Therefore, they were not included in calculations of oil revenues. 4. The State Board of Equalization rule 468 allows County assessors to reassess mineral rights valuations as oil prices rise. Since Proposition 13 permits assessments of new construction, the rule argues that an increase in the price of oil changes the value of an oil deposit such that it is treated as "new construction". This ruling is currently under litigation and, for the purpose of this report, it is assumed that the two percent limit on reassessment applies to mineral rights. Should the courts rule in favor of the Board of Equalization, City Revenues from property taxes on mineral rights would be higher than those shown. 5) This figure was obtained from Mr. Chuck Kruger at the Orange County Assessor's office. 6) This figure was obtained from Mr. Dan Brennan in the City Finance Department. 7) The number of wells connected to the wastewater system was provided by Mr. Rick Grunbaum, the City Oil Inspector. 8) This figure was obtained from the oil inspector, Mr. Rick Grunbaum. 9) The specific franchises responsible for these revenues are shown in Table B.1, of this report. The figures were obtained from Mr. Dan Brennan at the City Finance Department. 10) In 1933, Southwest Exploration Company began to produce oil from wells in the townlot directionally drilled to deposits under the ocean. When the State discovered (later that year) that Southwest was depleting an oil pool in State tidelands, it obtained a court order restraining Southwest from operating these wells. The 1938 State Lands Commission Act specified terms under which production of tidelands deposits could resume. However, to reach the oil field from the townlot, the wells were drilled under land owned by the City. The City granted Southwest Exploration rights of way under City land in an "Agreement and Easement for Right of Ways" in late 1938. This agreement provides the City a monthly royalty "equal to two percent of total royalties paid to the State of California" for oil production on Public Resources Code 392. The State's royalty is approximately 13 percent of total sales; two percent of this (the City's royalty) is .2642 percent. Aminoil, USA now 38 operates the wells and pays the royalty as specified in the agreement. 11) It should be noted that other analysts may use different inflation figures. However, it is unlikely that a different inflation rate would significantly affect the general conclusions drawn from the analysis. 12) The City owns mineral rights to 125 parcels in the Townlot/Downtown area. If an enhanced recovery project is undertaken there (and is successful), the City will receive additional revenue from royalties earned by its mineral rights interest. The amount of the royalty will depend on the quantity of oil produced, the profit on that production, the portion of the total interest in the project owned by the City and the terms of the unitization agreement. Because these factors are not yet known, the estimate of City revenues shown in this scenario do not include receipts from royalties paid by the unit. 13) Edwin S. Mills, in The Economics of Environmental Quality, W. W. Norton Co., N.Y., 1973, p.p. 141- 146, describes a method of estimating the health and property damages from air pollution by using property values. The theory is that rents and sale value of homes will be lower in heavily polluted areas, and that this reflects the value people place on cleaner air. This theory could be applied to the aesthetic impacts of oil operations in Huntington.Beach. If it were, one would expect rents and property values of dwellings adjacent to oil wells to be lower than similar dwellings elsewhere. This is a reasonable expectation for which we have some preliminary evidence, and a study of actual property values in Huntington Beach would be most interesting. 14) See "Coastal Energy Impact Program" Report, February, 1980, City of Huntington Beach, Section 8.4.0. 15) See Burchell, Robert W., and David Listokin, The Fiscal Im act Handbook, Center for Urban Policy Research, New Brunswich, NJ, 15P78, p.p. -10. 16) In this particular case, the term "public good" is defined by Charles M. Tiebout in "A Pure Theory of Local Expenditures", Journal of Political Ecoriom 64, 1956, 41b-24, as follows. ". . . a public good is one w is s u e pro uce , but for which there is no feasible method of charging the consumers." (p. 417). This definition makes sense in terms of the previous discussion on "assignable" vs. "unassignable" costs, if one reads it as "...a public good is one which should be produced, but for which There is no feasible method of measuring each user's demand." Since "assignable" costs are those which can be measure according to eat user's demand, then Those which cannot be measured are "unassignable". Hence, by the above definition, unassignable costs can be thought of as expenditures for "public goods". 17) See "Final Report on the Development and Application of a Land Use Fiscal Impact Methodology for the City of Huntington Beach" Vol. 1, November, 1979, prepared by Ultrasystems, Inc. Irvine, CA. 18) The wells that are located on the platforms offshore are included in the total counted as oil "units". This is done, because offshore oil operations require onshore support facilities that should be accounted for in the analysis. One example is a separation facility onshore that is used for Union's offshore production. Another example is the helipad located onshore that the oil companies use to carry on their offshore operations. The extent of these onshore support activities is assumed to be reflected in The number of wells offshore. For this reason, the offshore wells are counted as expenditure generating oil "units". 39 BIBLIOGRAPHY "Allocating Expenditures to Land Use Categories", George M. Patterson, Municipal Finance 36, May 1964, p.p. 136-9. "Coastal Energy Impact Program" Report, City of Huntington Beach, February, 1980. The Economics of Environmental Quality, Edwin S. Mills, W.W. Norton Co., NY, 1973. "Final Report on the Development and Application of a Land Use Fiscal Impact Methodology for the City of Huntington Beach", Vol. I, Ultrasystems, Inc., November, 1979. The Fiscal Impact Handbook, Robert W. Burchell and David Listokin, Center for Urban Policy Research, New Brunswich, NJ, 1978. "A Pure Theory of Local Expenditures", Charles M. Tiebout, Journal of Political Economy 64, p.p. 416-24, 1956. "Where Does the City Spend Its Money?" George M. Patterson, Western City, September, 1963, p.p. 46-47. 40 Other Sources "Annual Budget, F isal Year. 1979-80", City of Huntington Beach. "Garfield-Goldenwest Study", Huntington Beach Planning Department, March, 1978. "Growth Policy Study, General Plan Background Report", Huntington Beach Planning Department, October, 1973. "Draft Housing Element, Huntington Beach General Pion", Department of Development Services, September, 1979. "Housing Element Background Report", Huntington Beach Planning Department, August, 1976. "Land Use Element Amendment 80-11', Huntington Beach Department of Development Services, January, 1980. "Revenue/Expenditures Analysis of Land Uses", Huntington Beach Planning Department, October, 1973. " 1976 Revenue/Expenditure Analysis of Land Uses", Huntington Beach Planning Department, August, 1976. "Urban Land Institute Panel Advance Kit 2", City of Huntington Beach, November, 1%5. 41 0 0 HUNTINGTON BEACH ENERGY SERIES REPORT #3 OIL SPILL CONTINGENCY PLANNING IN HUNTINGTON BEACH CITY OF HUNTINGTON BEACH DEPARTMENT OF DEVELOPMENT SERVICES JAMES W. PALIN, DIRECTOR AUGUST, 1981 TABLE OF CONTENTS PAGE FOREWORD 1 DEFINITIONS 2 1.0 INTRODUCTION 3 2.0 OIL SPILL PLANNING, PREVENTION AND CLEAN-UP 7 2.1 Federal Role 7 2.2 State Role 9 2.3 Local Role 9 County Plan 10 Spill Plans in Huntington Beach 10 Cost Recovery 11 Bonds 12 2.4 Industry Role 12 2.5 Conclusions 13 3.0 OFFSHORE SPILLS 15 3.1 Spill Cleen-up and Containment 16 Local Equipment Resources 17 Co-Op Equipment Resources 17 Disposal Sites 18 3.2 Sensitive Areas: Huntington Beach 1B Santa Ana River Estuary 1B Anaheim Bay/Huntington Harbour 19 Balsa Bay/Bolsa Chica Ecological Reserve 19 Beaches 19 Southern California Edison Intake System 24 Conclusion 24 4.0 ONSHORE SPILLS 27 4.1 Spill Containment and Clean-up 27 4.2 Tank Farms 28 Dike Systems 29 Adjacent Areas 29 Storm Drains and Sanitary Sewers 31 Company Oil Spill Contingency Plans 31 Fire Department Reviews 32 Evacuation Plans 32 5.0 CONCLUSIONS/RECOMMENDATIONS 33 APPENDICES NOTES 35 BIBLIOGRAPHY 37 List of Figures and Tables Figures PAGE 1.1 Energy Facilities in Huntington.Beach 4 21 Organizational Hierarchy for Oil Spill Planning 8 2.2 Community Services Organizational Chart 11 3.1 Boom Placement During an Oil Spill 16 3.2 Santa Ana River Boom Placement 20 3.3 Anaheim Bay Boom Placement 21 3.4 Beaches within Huntington Beach 23 3.5 Access Points to Beaches 25 4.1 Typical Street Dam 28 4.2 Environmentally Sensitive Habitats as Depicted by the Department of Fish and Game 30 Tables 3.1 Alternatives in Oil Spill Containment and 22 Cleanup with Different Beaches Foreword - This is another in a series of discussion papers on energy-related issues prepared by the Planning Division of .the City of Huntington Beach. Huntington Beach is a center for many energy-related activities including onshore and offshore oil ,production, an electricity-generating power plant, and increasingly, solar and .conservation technologies. The purpose of these reports is to help the City to accommodate the continued production of so vital a resource as energy while at the same time mitigating as much as possible any adverse impacts on the community that such activities might incur. Other reports in this series include.the following: U1 Preserving Surface Access to Underground Oil Reserves in Developed Areas #2 Fiscal Impact of Oil Operations in Huntington Beach #4 Enhanced Oil Recovery Technology #5 Solar and Conservation Policies at the Local Level This publication was prepared with financial assistance from the U.S. Office of Coastal Zone Management, National Oceanic and Atmospheric Administration, under the provisions of the Federal Coastal Zone Management Act of 1972, as amended, and from the California Coastal Commission under the provisions of the Coastal Act of 1976. -Definitions This report necessarily discusses some technical aspects of oil spill planning. Consequently, some terms are used which may not be familiar to the reader. The following definitions section was prepared to help clarify the meaning of some of these terms. To ease reference, all words defined in this section are italicized the first time they appear in the report's text. Boom - A mechanical device used to contain a spill on a water body by forming a barrier extending both above and below the surface. Cash Bond - A cash deposit that will transfer to the City in case an oil handling company fails to comply with the Municipal Code; the transferred monies would be used for remedying the violation of the Code. Estu - A water passage where the ocean tides meet a river current; the mouth o a river. Sewer - A pipe, conduit or other physical facility used to transport wastewater. Skimming - A process of recovering spilled oil from the surface of the water. Storm drain - A pipe or conduit which carries storm water, surface water, and street wash, but excludes sewage and industrial wastes. Surety bond - A written contract between an oil company and a State licensed bond company to help guarantee the oil company's commitment to meeting the Municipal Code. If the oil company fails to comply with the Code, the bonding comparry is obligated to answer to the City and may be required to turn over all or party of the sum in the bond to pay for compliance with the Code. 1 .0 Introduction- The Coastal Energy Impact Program (CEIP) Several small-scale spills from these provides federal funds to State and local facilities occur each year, and the continued governments to help them plan for and transportation, storage, and production of mitigate potential adverse impacts of petroleum and related products may result increased energy-production activities in in future spills which could have adverse the coastal zone. Among the most serious impacts on the City's shoreline. For potential impacts on the coastal zone are oil example, oil leaks or spills can impede spills. This report, which is funded through recreational and economic activities in the CEIP, is concerned with oil spill contingency coastal zone. Environmentally sensitive planning in and near the coastal zone. areas, such as nesting areas for endangered species, could also be damaged. Residences Several major oil-related facilities are and commercial establishments could face located in the City's coastal area (see the possible hazards of fires and fumes, and Figure 1.1). Oil production platforms have owners could experience related problems been built offshore on the Outer Continental such as the inconvenience of an evacuation Shelf (OCS) and in State tidelands. Oil in an emergency situation or of clean-up tankers unload their cargo at a nearshore operations after a spill. marine terminal, and oil is stored in tank farms within the City. Pipelines carrying The prevention, containment and clean-up gas, oil and refined products lie under the of oil spills involves all levels of government City. A large power plant is located in the as well as oil companies. Each level of coastal zone, and another tank farm stores government has certain jurisdictional the fuel oil for that facility. Extensive responsibilities and authority concerning onshore oil production also exists in the spills and it is possible that the City's coastal zone.l responsibilities overlap with another level of government. The goals of this report are / Separation Plant Tank Farm Principal Oil Producing Areas Se aration Plants O o / O O� Oil "Islands" O Offshore Platforms Power Plant / Mud Dump Marine Terminal awwpo* Tank Farms % Figure 1 . 1 Energy Facilities in Huntington Beach Source: City of Huntington Beach, Coastal Element huntington beach planning division 4 1) to ;clarify the roles, capabilities and Section 2.0 discusses, in general terms, the authority of federal, state and local roles usually expected of the different governments concerning oil spills, 2) to levels of government during an oil spill. review existing governmental oil spill Section 3.0, discusses offshore spills and contingency plans and identify, where includes the following topics: 1) appropriate, the role of the City's personnel containment and clean-up strategies for and equipment, and 3) to recommend beaches and at-sea oil spills, 2) equipment improved measures, if necessary, to ensure available for clean-up activity, and 3) that important resources, including specific sensitive areas within Huntington recreational beaches, waterways, Beach. Section 4.0, discusses topics related residences, commerce and environmentally to onshore spills, including 1) spill sensitive areas are adequately protected containment and clean-up strategies, 2) from spills. tank farms and adjacent areas, and 3) spill. impacts on storm drains and sanitary sewers. Section 5.0 presents some conclusions and recommendations. 5 2.0 Oil Spill Planning; Prevention and Clean-up Determining which agencies will be involved responsible for coastal and navigable waters in containing and/or cleaning a spill depends and the EPA is responsible for inland largely upon the severity of the spill and its spills.3 location. Figure 2.1 summarizes the general relationship among different levels of The National Plan divides the country government for responding to oil spills.2 geographically into regions for the purpose of spill planning. Within each region is a The following sections describe the roles Regional Response Team (RRT) which and authority the different levels of develops its own Oil and Hazardous government assume in a spill emergency and Pollution Contingency Plan to provide a highlight how local government may coordinated response by federal, state and interact with State and federal agencies. local agencies. The RRT's plan is activated when there is a major spill or when the 2.1 Federal Role potential for such a spill occurs. The team is comprised of representatives of federal The Federal Water Pollution Control Act and state agencies, and some local (FWPCA) includes provisions establishing governments. Each agency is allowed one the National Oil and Hazardous Pollution member and at least one alternate. The Contingency Plan (National Plan), a On-Scene Coordinator (OSC) designated by nationwide system of regional contingency the RRT acts as the federal OSC for the plans and federal policies for oil spill spill incident in accordance with the containment and clean-up procedures. national plan. The RRT is jointly chaired by Under the national plan, an On-Scene the Coast Guard and EPA except during a Coordinator (OSC) from the Coast Guard or spill emergency at which time the agency in Environmental Protection Agency (EPA) can whose jurisdiction the spill occurred will be sent to a spill to monitor and/or direct head the team. clean-up efforts. The Coast Guard is 7 IF SPILLER IS KNOWN: Spill is noticed by On Shore----- responsible party, - Off Shore---- gov ' t agency or N4ify citizen I Not iify OFS* Initial containment OECS* i I I i EPA Local Gov' t and/or Crew on-scene Coast Guard i at incident Monitor Monitor Progress Progress L------------Clean-up by responsible party--------------- IF SPILLER IS NOT KNOWN: Spill is noticed by c---On Shore----- a gov t agency or--------Off Shore----i i Notify Notify i I Initial containment i OFS Local Gov' t an Coast Guard Oy EPA Clean-up by co-op or private Coasts Guard i firm contracted b Coast Guard i. Monitor or EPA y Monitor ------- ---------Progress Progress *State Office of Emergency Services; they will notify other federal and state agencies Figure 2. 1 Organizational Hierarchy AMN for Oil Spill Planning Source : Huntington Beach Planning Division huntington beach planning division 8 When not '.activated, the RRT serves as a coordinate actions of State agencies and to standing committee to 1) review regional provide local governments, the public and emergency response operations and news media with information regarding the equipment to ensure preparedness, 2) spill. review the OSC's functions to ensure regional plans are developed and The State plan establishes a State coordinated with involved agencies, 3) Interagency Oil Spill Committee (SIOSC) promote coordination among all levels of composed of several. State agencies.6 government and private agencies, and 4) SIOSC designates a State Agency recommend and implement policy Coordinator (SAC) who is responsible for changes.5 administrating the State plan. The plan 'also establishes a State Operations Team (SOT), A revolving fund has been established by the headed by the SAC, which also consists of FWPCA to pay for expenses incurred during several state agencies? The SOT does clean-up operations when the spiller is not have funds available to clean a spill, but unknown or not taking appropriate clean-up personnel and equipment are available from action. The fund is under management of various state agencies during an emergency. the Coast Guard; federal OSC's; whether Coast Guard or EPA, have access to the The State's operations team owns very little fund. Once the . spill is cleaned, the clean-up equipment and relies on other responsible party, if known, is billed for the parties, such as the oil companies, other expenses. private contractors or, occasionally, federal and local agencies to conduct the actual "Strike Teams" are also available to the clean-up. The State Contingency Plan also OSC under the national plan to provide recognizes the importance of local 'assistance and technical advice as needed government involvement and encourages during a major spill. The teams include: 1) communities to prepare their own plan the National Strike Force established and which will coordinate with the State and maintained by the Coast Guard with national plans. The State plan acknowledges expertise in communications, damage that the federal government is the lead control, oil and hazardous substance agency during the containment and clean-up removal, (the Pacific Strike Team, located process of a major spill. in San Francisco, is responsible for spills in California); 2) the Environmental Response California is currently revising this oil spill Team established by EPA with expertise in plan with funding from a Coastal Energy biology, chemistry, and engineering, and 3) Impact Program grant. The purpose of the Scientific Support Teams, organized by EPA revision is to clarify the State's and the National Oceanic and Atmospheric responsibility during a spill, to improve Administration to provide scientific coordination with local governments and to expertise in oceanography, locating establish better containment and clean-up environmentally sensitive areas, and procedures for spills of hazardous assessing environmental damage. Once substances other than oil. activated, a team can be on the scene of a major spill in this area within four to six 2.3 Local Role hours.4 The role of local governments in a spill 2.2 State Role emergency focuses on 1) discovery and evaluation of the spill, 2) immediate action California has an Oil Spill Contingency Plan to limit damage and protect the public, 3) that can operate simultaneously with or notification of appropriate state and federal independently from the national plan. The agencies, and 4) providing support for objectives of the State plan are to clean-up operations by private industry. 9 Both the federal and State plans stress the Services and Fire Departments. Generally, need for municipalities to initiate the Community Services is responsible for spills containment process, especially with involving the shoreline, the harbor or any onshore spills. On the other hand, saltwater area, and the Fire Department is municipalities are rarely involved with spills responsible for spills, on land. Because of at sea and, if the spill does come ashore, the this division of responsibility, the City has local government may not have the needed two plans related to oil spills: the "Civil equipment for effective clean-up and may Defense/Emergency Services Plan" for have to wait for assistance from the Coast Community Services and an "Incident Guard. Command System - Operational'Guide" for the Fire Department. County Plan: The County of Orange has developed a Hazardous Material Response The Community Services' "Emergency Plan for oil and toxic chemical spills. The Services Plan" is compiled from. various plan is intended to be a planning guide based operational plans for different emergency on the mutual aid concept, (that is, situations. O-Plan 16, "Major Oil Spills" providing the affected local jurisdiction outlines assignments, defines different with additional support from higher levels of categories of spills and establishes operating government and other municipalities ' as instructions for other departments within needed or requested). According to the the City, should they become involved. The plan, the spill is the responsibility of the Director of Community Services is affected jurisdiction, and the local fire designated as the Incident Officer who department is assumed to be the lead oversees the entire incident within the agency In controlling the incident. City. He or she is responsible for assigning actions based on the situation and on If the fire department determines that the information provided by the Coast Guard, situation is beyond its scope and which is recognized as the coordinating capabilities, county support and resources agency for all offshore spills. will be requested. When the situation is beyond the scope of both the city and Spill situations are evaluated to determine county, State and federal assistance will be which of the following responses are rnost requested. However, control will be appropriate: 1) to correct or eliminate the maintained by the jurisdiction where the cause of the spill, 2) to divert and/or incident occurred. minimize the effects of the spill and 3) to begin recovery operations. The teen "control" is not defined in the county plan but it appears to mean "lead A simplified staff organizational chart is agency". Consequently, the county plan shown in Figure 2.2 which highlights the contrasts with the State and national plans responsibilities within the Department and which recognize either the EPA or Coast outside agencies notified in case of a spill. Guard as the lead agency for spill response. (Detailed operating instructions for other city departments are outlined in O-Plan 16 Spill Plans in Huntington Beach: The City's which is available upon request.) primary functions in case of a spill are to contain the spill, to ensure public safety and The Fire Department Incident Command to limit damage. The actual clean-up System (ICS) is a standardized system used process is usually undertaken by the for six emergency situations including all responsible party or a private firm. The hazardous materials spills. In conjunction City divides the responsibility of overseeing with the ICS, the department has an the containment and cleanup of oil and operation plan for Chemical/Hazardous hazardous spills between the Community Materials - Leaks and Spills (O-Plan 4). 10 City Administrator Director Deputy Director ------------- --=----I-----------I-----------------� Calif . Regional SC—PCO U.S. Calif . Dept. City of Huntington Water Quality or Coast Fish & Game Beach, Dept. of Control Board CCW Guard Civil Defense Harbor and Ocean Beach Communication Oil Field Coordinator Coordinator Coordinator Inspector Boat Lifeguard Personnel Personnel ------ lines of communication lines of authority Figure 2. 2 Community Services Organizational Chart Source: Department of Community Services City of Huntington Beach O-Plan 4 provides a formalized check sheet Cost Recovery: The spiller, if known, is for procedures to minimize adverse impacts financially responsible for containment and from leaks or spills of chemical or clean-up of spills. If the spiller is not known hazardous materials, including oil. or does not respond quickly enough, the City will begin containment of the spill. In such Although the department informs other cases, the responsible party is billed later agencies of a spill, it generally operates for the City's time and services. To date, independently from the county, state and establishing responsibility for onshore spills federal agencies during the containment or collecting payments for City services has process. The Fire Department assumes not been a problem.8 responsibility for these kinds of emergency situations within the City as a part of their In order to be reimbursed through the day-to-day duties. If the Fire Department national revolving fund for services related cannot contain the spill, assistance is to containment and/or clean-up of an requested through the county's mutual aid onshore spill or an offshore spill that washes system. ashore, the municipality must notify the federal OSC of its request. Before monies may be drawn from the revolving fund, the 11 OSC must determine that��de following however, it i bible to apply the bond to conditions have been met: 1) oil has been any section of the Municipal Code, including discharged into U.S. waters or an adjoining spill prevention and clean-up. A problem shoreline, and 2) the responsible party has with surety.bonds is that unles's the operator been given legal notification of improper or agrees to the charges of wrongdoing, the inadequate action and has failed to City must sue the operator in Superior voluntarily conduct adequate clean-up Court to collect money from the surety action, or the spiller is unknown. company. This can be a lengthy process. Individuals who suffer damage to personal Alternatives to surety bonds which the City property and businesses losing earning may want to consider are cash bonds. This capacity as a direct result of the spill may ' system would require operators of oil wells be eligible for compensation. Damages for to have an agreed upon sum of cash to which intangible losses, such as aesthetics, are the City would have access in case a restricted to real property owners whose violation in the Municipal Code were not property interests were physically harmed. corrected or eliminated. A major problem with cash bonds is that requiring large surns Requests for reimbursement must be of money to be held in escrow accounts may submitted to the OSC or SAC. Requests be too burdensome for small independent must be clearly and completely documented operators. By using surety bonds these and directly related to costs incurred during operators arrange with bond companies to the clean-up operation. "insure" them for the required sum. If cash bonds were required, each operator would Following the Santa Barbara oil spill in have to put up that sum independently. 1969, several lawsuits concerning reimbursement for loss of business earning 2.4 Industry Role capacity, damage to property, and intangible losses were filed. Some Although the focus of this discussion is on interesting findings resulted from these government spill contingency plans and on cases. Damages for recovery of economic the role of the local government in spill loss were limited to waterfront property emergencies, it should be recognized that directly affected by the spill; businesses the oil companies themselves have the most which had a decline attributable to the spill, significant role in spill prevention and but which were not physically affected by clean-up. The "spiller," that is the private it, were not able to recover the loss of company which owns the facility from which profits. State and local governments were the accidental spill originates, is usually able to recover damages for loss of responsible for containment and clean-up, proprietary income, such as fees paid by and is liable for direct damages caused by park visitors, concessionaire and leasehold the spill. The federal government also income. However, the right of governments requires the operators of major oil handling to recover damages for marine environment facilities to have a Spill Prevention Control and tax revenue losses were contested.9 and Countermeasure (SPCC) plan if oil could be discharged into navigable waters or Bonds adjoining shorelines; (these are discussed again in section 4.0). The City of Huntington Beach requires a surety bond of $10,000 for each oil well These plans typically include information on within the City. The purpose of the bond is the types of oil handling facilities on-site, to secure the City against all costs, charges the kinds and amounts of fluids that might and expenses incurred if the oil company be spilled in an accident, containment does not fully comply with the Huntington equipment and procedures, and requirements Beach Municipal Code. for notifying public agencies involved in monitoring containment and clean-up To date, bonds have only been used for safely plugging improperly abandoned wells; 12 operations.. Many plans also require periodic 2.5 Conclusion drills to ensure that containment, clean-up and notification procedures are effective. In most cases, the responsible company will Some plans discuss the resource areas that contain and clean the spill. In addition, all might be affected by a spill and prescribe three levels of government may be involved, special protection measures for especially each having two or three agencies sensitive areas. representing the interest of a particular functional area (e.g., water, air, or marine All of the major oil companies in Huntington life). The location of the spill, amount Beach have SPCC plans. Aminoil's plan spilled, the potential danger and the covers their onshore lease areas as well as threatened resources will often be deciding their offshore platform. Chevron has a plan factors for determining which . agencies for their onshore production areas. Gulf has become involved. Most of the agencies do two plans, one for its offshore tanker not actually assist with clean-up activity, unloading terminal and one for its onshore rather they observe to ensure that the tank farm. Union and Shell also have SPCC interest they are responsible for overseeing plans for their offshore platforms. is adequately protected. Southern California Edison stores and Municipalities have several options available transports considerable quantities of fuel to recover expenditures related to spills. oil. The Huntington Beach generating These include: 1) billing the responsible station site is broken into two major party, 2) using the national revolving fund components, the System Fuel Oil Facility if the OSC has determined that the and the Generating Station proper. SPCC requirements for tapping this fund have plans exist for both areas. The Edison been met, and 3) attempting to collect on facility is discussed further in Section 4.0. surety bonds. In Huntington Beach, the City has billed the responsible party for excessive costs related to containment and clean-up, a practice that has generally been effective in recovering such costs. 13 3.0 Offshore Spills Oil spills and leaks in offshore waters are 3. Marine mammals and fish usually avoid impossible to predict. The cause of a spill is the spill, and therefore are not severely not always known, especially with the affected. Increased hydrocarbon smaller spills of one or two barrels. Sources concentrations in fish food chains may of spills include equipment failure, oil and affect some species; the eggs and larva gas well blowouts, tanker operations, of fish tend to be killed. The extent of pipeline leaks, accidents caused by human adverse effects on plankton and error and by natural phenomena such as invertebrates is not clear. However, earthquakes and storms. these impacts tend to be short term and localized. Oil spills can adversely affect several important resources. The following briefly 4. Birds, for the most part, will avoid describes the principal impacts which could spills. However, certain species which occur in Huntington Beach. normally catch fish by swimming or diving into the ocean are particularly 1. Air quality is affected when susceptible. These include grebes, hydrocarbons evaporate from the loons, cormorants, and alcids. Their surface of the spill. This impact tends feathers can be coated with oil which to be short term, disappearing when the impedes their swimming and flying oil sinks or is cleaned up. ability. Birds may also be poisoned when attempting to clean the oil from 2. Water quality is degraded when their feathers. hydrocarbons float on the surface and the oil mixes through the water, usually a short term impact. 5. Habitat areas used byes and other wildlife could be affected. Their food may be contaminated by the spill and breeding habitats disturbed by the noise from equipment used to contain and clean the spill. These impacts could be long term. DOMINANT 6. Beaches would be affected in two WIND OR ways: 1) recreation activities may be CURRENT curtailed and 2) intertidal sand habitat for crabs, clams, and worms may be damaged. These impacts would generally be short term. Several documents discuss these impacts in ['%•,'` '• ` 'i detail and should be referred to for further in formation.10 SPILL`.• 3.1 Spill Clean-up and Containment .';•`; ;" 't:_ Containment and Clean-up Methods: The method used to contain and clean-up offshore spills will depend on several variables such as: 1) location, size and B06M source of the spill, 2) weather conditions, and 3) currents and tides. The first priority is to contain the spill or Figure 3 . 1 Boom Placement During mitigate its effects at sea. The techniques an Oil Spill commonly employed are booming, skimming and, occasionally, the use of chemical Source : Huntington Beach Planning dispersants. A boom is a floating barrier, _ _ -- extending both above and below the water _ _ - surface, which corrals and confines the spill (see Figure 3.1). Booms perform most effectively when the wind and ocean are to be removed from the water. These calm. Choppy waters and strong winds tend skimmers employ a disc, drum or continuous to push portions of the oil slick over the belt and are less susceptible to wave action boom barrier, reducing its effectiveness. than the weir and suction types. However, they are generally more expensive, harder Skimming is a process of recovering spilled to obtain and rel uire highly trained oil from the water once it has been personnel to overate. contained. There are three general types of skimmers: 1) Weir skimmers that depend on In some cases, chemical dispersants are used gravity to drain oil off the water surface to slow the movement of the oil and to into a sump below the surface; these are reduce its volatility or toxicity. Dispersants simple to use and extremely mobile, but break down the oil so it can mix vertically their efficiency decreases in choppy through the water column, thus decreasing waters. 2) Floating suction skimmers which its toxicity and mobility. Because of the employ a suction pump as opposed to controversy concerning the effects of gravity; these are adjustable and can be dispersants, California and federal calibrated to operate- just at the water/oil authorities have adopted regulations interface. Again, their effectiveness is restricting, but not prohibiting, their reduced in choppy waters. 3) Sorbent use.12 Approval is required from the surface skimmers, which provide a surface California Department of Fish and Game to which the oil can adhere, allowing the oil and the EPA or Coast Guard before chemicals can be used. 1r If the spill cannot be contained at sea, oil the arrival of specialized personnel and may drift toward the shore. In these equipment, and can assist responsible. ' circumstances diversion booming -- that is, parties involved in the clean-up operation, using booms to divert the oil to a section of even in the case of a major spill. the shoreline where 'damage is minimal and access for clean-up is good -- may be In the event of an oil spill, City equipment employed. Generally speaking, it is normally used for day-today operations in preferable to divert the spill to a sandy Fire, Police, Community Services, and beach with good access, while avoiding Public Works Departments will be made rocky areas, wetlands, and areas that lack available upon request. Equipment includes: access for clean-Lip equipment and workers. Section 3.2 discusses the areas in - a fleet of cars, pickups, vans, jeeps and Huntington Beach where spilled oil should trucks not be landed if at all possible, as well as - tractors, trailers, caterpillars, and those areas where adverse impacts can be vacuum sweepers minimized and clean-up can be performed - police mobile command unit bus and more easily. helicopter - rakes and. discs used for discing oil on If the spill lands on shore, discing, plowing sandy beaches and turning over the oily sand may be performed. The oil may also be removed by Co-Op Equipment Resources absorbents and. adsorbents. Absorbent materials soak up oil while adsorbents The National Plan requires the party provide surfaces for the sticky oil to cling responsible for the oil spill to undertake the to, allowing subsequent removal. Straw, clean-up operation under the supervision of .foamed plastics, cotton waste, talc and the U.S. Coast Guard. Oil companies are dried volcanic rock are often used to help required by federal regulation to have clean up oil from the shoreline.13 These booms and skimmers available at offshore materials reduce the amount of oil in the drilling sites and platforms with the sand and assist with the discing technique. capability to contain small (less than 238 After a large spill, however, discing is barrels) and medium (less than 2,381 �arrels) usually ineffective and the sand may have to size spills. For any spill beyond the be.removed. This method is therefore used capacity of on-site containment equipment, primarily for small spills. oil company cooperatives have been established to clean-up major spills.` In Huntington Beach, the affected beach area is not closed to the public after a spill Thirteen West Coast cooperatives have been unless .there is a high concentration of oil, established to prevent, contain, and clean or unless heavy equipment poses a hazard to spilled oil. Clean Coastal Waters (CCW) and public safety. In most cases the Community the Southern California Petroleum Services Department uses mobile units to Contingency Organization (SC-PCO) are the inform beach patrons of the spill, advising cooperatives for the Los Angeles-Orange them to avoid the impacted area until County shorelines. Members of the co-ops clean-up is completed. generally include offshore producers and other potential spillers. They pay an annual Local Equipment Resources fee based on their level of offshore activity. The funds are used to purchase The City of Huntington Beach has specific specialty equipment not expected to be equipment that could be used in the event of owned by individual member companies and a minor offshore oil spill that washes to train industry personnel to use the onshore. Although it does . not have the equipment. In the event of a spill, the equipment or manpower to conduct a major cooperative will deliver any equipment clean-up operation, the City can provide requested. initial containment ,and protection prior to 17 The equipment is also available to - Boise Bey/Bolsa . Chico Ecological non-member . companies upon request from Reserve the Coast Guard, and a fee is charged to the - Beaches within Huntington Beach and non-member company. the Municipal Pier - Southern California Edison Cooling The available offshore equipment includes Water Intake System (offshore) boats, booms, chemical dispersants, aircraft, skimmers and other vessels. Santa Ana River Estuary Disposal Sites The Santa Ana River empties into the ocean between Huntington Beach and Newport The disposal of recovered oil and Beach. A flood control channel also oil-contaminated materials can pose discharges into the ocean, parallel to the . immediate and long range problems. Santa Ana River. A lowland, marshlike Occasionally, oil/water mixtures can be area extends upstream along the flood separated in treatment tanks at local oil control channel. A debate has ensued over production facilities and the recovered oil whether or not this' area is a functional sent to a refinery. wetland. Further study and a final determination `by the Coastal Commission In most cases, however, the disposal of oil may.be necessary. and contaminated debris is more complicated. Legal requirements for Marshes and wetlands provide. both disposal are established by the California economic and environmental benefits. They Regional Water Quality Control Board. Oil provide shelter and food for migratory birds contaminated wastes cannot be burned, but as well as nesting and habitat for residential must be buried safely on land in Class I species. Some lowlands and estuaries are disposal sites. breeding grounds for commercial fish and invertebrates. Wetlands may also protect According to the Board, Orange County does against flooding to some extent by trapping not have a Class I site which would be excess storm waters and thereby recharging impermeable to stored oil. The nearest the groundwater table. suitable landfill is in West Covina, approximately 50 miles from Huntington The dominant vegetation in the lowlands Beach. The lack of suitable disposal sites near the Santa Ana River is pickleweed, may be a very serious impediment to although other plant species are present. effective oil spill clean-up in this area. Portions of the lowlands are used for nesting by the Belding's Savannah Sparrow, an 3.2 Sensitive Areas: Huntington Beach endangered species. This lowland area does not have direct tidal flushing, and this limits Many resources can be affected by offshore its biological productivity. However, spills. Although the entire coastline is improvement measures could be taken to. susceptible to oil spill damage, certain areas increase productivity. The river mouth are more susceptible and sensitive to itself is the feeding area for the California damage because of environmental impacts, Least Tem, also an endangered species. economic and recreational disruption, or difficulty with clean-up operations. Protection of the Santa Ana River and flood control channel are a high priority. This section discusses the following areas Booming will be the most effective method which may be impacted by offshore oil spills of protection. Separate booms will be in Huntington Beach. needed for the river and the flood control channel. Placement of the boom will be Santa Ana River Estuary inland of Pacific Coast Highway because Anaheim Bay/Huntington Harbour wave action near the ocean entrance will 18 reduce the effectiveness of the booms. The Reserve is valuable because it provides Vehicle access is available on service roads 1) breeding and "nursery" areas for marine (see Figure 3.2). If clean-up is necessary, species with commercial and recreational law pressure water flushing is value, 2) habitat for various wildlife recommended.14 species, including rare and endangered species, 3) natural flood control, and 4) Small boat access is possible from the aesthetic amenities. The protection .of shorelines of Huntington State Beach or scarce ecosystems is recognized in the Newport Beach. California Coastal Act as an important greater-than-local goal. At this time, the Anaheim Bay/Huntington Harbour/Bolsa Reserve is not likely to be affected by an Bay/Bolsa-Chica Ecological Reserve offshore spill because of its distance from an ocean entrance. However, the County of Anaheim Bay lies just northwest of Orange Local Coastal Plan (LCP) has. Huntington Beach (see Figure 3.3). proposed a channel which would open the Channels from .the Bay connect the Seal Reserve to the ocean waters. If this plan Beach Wildlife Preserve, Sunset Aquatic were pursued, the Reserve would be much Park and Huntington Harbour. Huntington more susceptible to offshore . spills and Harbour is an 860-acre residential would warrant the highest priority of development oriented around a network of protection. manmade water channels. It is. adjacent to the Seal Beach Wildlife Refuge and Bolsa If the oil cannot be completely. contained by Bay. Protection of this area is a high the primary boom located ,at the entrance to priority. Anaheim Bay, clean-up may be necessary in other sections of the bays and .channels. The entrance to Anaheim Bay is always Booms and skimmers may be used to collect open; therefore,. its protection should be a oil spreading into Anaheim Bay and high priority. Boom placement across the Huntington Harbour. Many clean-up channel can serve as the primary techniques in the marshes themselves may containment measure; see Figure 3.3. be more environmentally detrimental than However, secondary booms may be needed the oil itself due to destruction of wildlife at the entrances to Huntington Harbour and habitat by mowing and trampling. Low Seal Beach Wildlife Refuge if the oil is not pressure water flushing with small boats fully contained by the first boom. may be an acceptable, if not highly effective, technique for removing some of The north .bank can be reached by an the oil entering the marsh.15 unnamed road into the Naval Weapons Station via Seal Beach Boulevard, south of Beaches Pacific Coast Highway. The south bank may be reached by Pacific Coast Highway. Each The City's shoreline stretches over nine approach requires passage through a gate miles, encompassing approximately 380 controlled by the Navy, and allows ample acres of beaches. Sandy areas are used year room for storage of equipment and round for swimming, sunning, fishing, supplies.15 surfing, clamming and camping. A major spill reaching the shoreline _would disrupt Boise Bay, located southwest of Huntington these numerous recreational activities. Harbour, is connected to Anaheim Bay by a Spill containment and clean-up strategies narrow channel. Within the bay is Bolsa are explained in Table 3.1. The following Chica Ecological Reserve which consists of section describes the beaches within 563 acres adjacent to the City's coastal Huntington Beach beginning with the north zone, inland from Boise Chica State Beach. end of the City (see Figure 3.4) and Sections of the marsh have been reflooded discusses a priority for protection in case an in an effort to restore the wetlands habitat. offshore spill must be diverted to the shoreline. 19 En � N c 0 � r x 'i O Q O 3 Q) O z �4 m A F� c Co • as / l•x--:, ..••• •••••%S;4'::(i'Jiv:4'i:W:iJl Liii. \ ,Edison Plant / i2Mi:.Y:}2' n.tv: ij>:ij.i::v`j:;+.«{.Y ;/i,/; I• ?.,,;; ?:•>:'<»:^.: . flood control channel a r ?fs:}:.Y.;;^:vv RL'�n::}:NJ:ii:::%._.._Y:J i'f.:i%v:v J::i.Ai:ivv�:i:;i:y., 'I{''r ♦ n1. 1 .se.r ice m !:MMi road -.}.i.i?:•: iif::S: iig.J:::;>::::ii£i.<.>? S:iti::::';;n:E:z>:i;, ''r,/•.."r� s , r ♦ r' c >::< :>:::>`:is:::i::#€': €<-; > ;> ' '•> >' , ♦ service }•J+}v s r oad 1, Y.4. I 1 ..,.3.::.... 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Contingency Organization Elm hluntington beach planning division N N TABLE 3. 1 ALTERNATIVES IN OIL SPILL CONTAINMENT AND CLEANUP WITH DIFFERENT BEACHES PROTECTIVE STRATEGY BEACH FIRST SECOND THIRD FOURTH FIFTH CRITERIA FOR COMPLE- TYPE PREFERENCE PREFERENCE PREFERENCE PREFERENCE PREFERENCE TION OF CLEANUP Rock Face Prevent strand- Disperse off- Mop up stran- Displace by high pres- Permit Remove gross con- ing. Contain shore before ded oil with sure (1000 lb/ing) natural tamination (resi- and skim or stranding absorbent pads cold water; start at weather- dual stain per- contain and di- or materials low tide and work up ing and missible) vert to sand as tide floods; mop dispersal beaches at strand line as tide recedes Sand Prevent strand- Disperse off- Rake up Bury by .disc or Permit Remove all visually ing. Contain shore before stranded oil suitable tech- natural evident traces of and skim or stranding or capture nique to cover oiled weather- sand on beach or contain and di- with pads sand ing and bury to prevent vert to sand dispersal exposure beaches Wetlands, Prevent entry If oil enters Only in extra- Cleanup where pos- Bays, Estu- with booms or these areas, ordinary cir= sible and not dis- aries by containment it may be con- cumstances would ruptive of natural tained and burial be resources stranded on considered the most ap- propriate beach Acceptable cleanup of spilled oil will result in a gradation from visually evident residual contamination to no apparent contamination. Every effort must be made to keep oil from stranding on rocky areas and to quickly clean it from sandy areas. Birds contaminated with oil must be isolated, boxed, and transported to cleanup and rehabilitation facilities, e.g. Marineland, Department of Fish and Game, Municipal ' or County Animal Shelter, the Orange County and Los. Angeles Zoos. SOURCE: County of Los Angeles, Oil Spill Contingency Plan l f .L_. w i BOLSA CHICA W STATE BEACH J { ROCK ,BLUUFFF�, F � \ /MUNICIPAL HUNTINGTON CITY BEACH HUNTINGTON STATE BEACH / I/ SANTA ANA RIVER iael Figure 3 . 4 Beaches within Huntington Beach Source : Huntington Beach Planning Division huntington beach planning division n Boise Chica State Beach in�:udes six miles nearby could`Arupt the nesting behavior of of shoreline between Warner Avenue and the this endangered species. Diversion booming Municipal Pier. Approximately three miles should be used to keep the oil as far away as are developed with recreation facilities and possible from the preserve. If a spill were further development is planned. The beach to land in this area during the nesting experiences heavy recreational use season, adverse effects of clean-up activity throughout the year. Entrance to the State on the nesting birds should be assessed prior Beach is from Pacific Coast Highway. to permitting such activity. Vehicle access is available along a road inside the State Beach; the. beach itself . Both State Beaches and the City beach can connects with Sunset Beach and access is be used, if necessary, to launch small boats afforded via the sand. Further vehicle for spill containment. access is possible from Pacific Coast Highway (see Figure 3.5.). Southern California Edison Cooling Water Intake System Within the State Beach beginning at Goldenwest Street and extending The Southern California Edison generating approximately one mile north, steep bluffs plant collects ocean water for cooling rise above a narrow sandy beach. During purposes through a pipe which extends the high tide, water washes against the approximately 1.3 miles offshore, twenty bluffs which would limit access for clean-up feet below the surface. equipment. Cleaning a rock face is much more difficult than a sandy shoreline. For The ocean water remains in the pipe through these reasons, the rocky areas should be the entire cooling process, and does not mix avoided in case of an oil spill. with the plant's own water. The purpose of the ocean water is to cool vapors and Huntington City Beach includes condense them back to a liquid. The cooling approximately one mile of sandy shoreline water is used once and then returned to the between the Municipal Pier and Beads ocean. Boulevard. Recreational intensity and economic activity are high and warrant The City has discussed with the Edison priority protection measures. The municipal Company the possibility that oil spilled pier is located an this beach. The area offshore might be drawn into the cooling immediately surrounding the pier is heavily system, fouling the mechanisms and forcing used for recreational purposes, such as closure of the plant. Edison officials agreed swimming, surfing and fishing. Due to the that a potential problem exists. They have large amount of recreational use and the explained that if the quantity of oil difficulty of cleaning the pilings, the pier entrained is small, no immediate effects should be especially protected in case of a may be noticed. However, continuous spill. exposure to oil would foul the heat exchange and associated equipment, requiring partial Huntington State Beach encompasses the or total shutdown of the generating station two mile area between Beach Boulevard and to perform clean-up activities. the Santa Ana River. Vehicle access is possible along a road inside the State Beach, Conclusion entered at the intersection of Pacific Coast Highway and Beach Boulevard. If an offshore oil spill which cannot be contained at sea threatens an area which is This beach includes a five-acre California sensitive or difficult to clean, diversion Least Tern nesting preserve adjacent to the booming, if possible, should be used to river. The sensitivity of the nesting direct the spill to another shoreline preserve warrants a high priority location. in most circumstances, the oil protection. Even if the oil does not directly slick will do the least damage if it lands at a reach the nesting area, the clean-up activity sandy beach with good vehicle access. 24 A. a parking lot for Sunset Beach, but access is available to Bolsa Chica State Beach via the sand B. a traffic signal for the entrance of Bolsa Chica State Beach; a road extends along the length of the beach and parking is available C. the sand extends to Coast Highway; access is possible to the bluffs at low tide D. a service road extends to the sand until 21st Street E. a service road extends to the sand; close to the c?F lc pier c0 F. parking lots to the north and south; vehicle �S�T sT yI access available at the south lot c vWv4p WARNER G. a parking lot with access to the sand A H. entrance to Huntington State Beach; a road extends to the south along the length of the beach; parking is available �o Z . two wide gates can be opened to the g road inside the State Beach; close to the Santa Ana River. In October 1982, y1� it is scheduled to be opened as one of s� the State Beach entrances J. scheduled to be a State Beach C y� S entrance in October 1983 B K. scheduled to be a State Beach entrance in October 1982 oC, FFrti UQ ' z i o yaS¢y Woo O yam`1 z i xw � i &��c r`YCTo b � Is, dF�CyT�jNOTON Figure 3 . 5 Vehicular Access Points to Beach Source: Huntington Beach Planning Division huntington beach planning division 25 The highest priority for protection should be the municipal pier because of its high given to the Least Tern nesting preserve and recreation use and the rocky bluffs because estuaries because of their wildlife habitat of the difficulty with their clean-up. value. Next in priority for protection are 26 4.0 Onshore Spills Onshore spills include all spills and leaks on In the event of an oil spill, human safety land. There are numerous facilities in takes precedence over all other concerns. If Huntington Beach which store, transport and needed, the City's evacuation plan will be process oil and related fluids. Accidents, implemented through the fire Department - human error and equipment or material Civil Defense. Rapid and effective failures can result in spills from these containment of the spill and subsequent facilities. Approximately three such spills clean-up is the best way of protecting public or leaks are reported in Huntington Beach safety. each year. Most of these are very small, amounting to less than a barrel. Oil that threatens a sensitive area may have to be diverted before it is contained and 4.1 Spill Containment and Clean-up cleaned up. A spill may be diverted down a side street or into a ditch by constructing a An onshore oil spill in urbanized areas street diversion barrier (see Figure 4.1). presents a potential hazard to human When selecting a diversion area, ease of safety. Prior to initiating control, recovering the oil and the comparative protection, or containment actions in an safety of the area must be considered. urbanized area, the following factors must Diversion areas may be flooded with water be considered: for two reasons: 1) it may be possible to skim the oil floating on the water, and 2) - the presence of volatile hydrocarbons water may result in less oil actually - the potential hazard a spill presents to contacting the street surface, making individuals and their safety clean-up easier. Also, where there is no - the potential sources of oil ignition pavement the amount of oil reaching such as running automobiles, pilot subsurface soil layers will be reduced, lights, and sparks. thereby minimizing groundwater contamination. 27 -ow o axWw Y.•wr Figure 4 . 1 Typical Street Dam Source: Huntington Beach Planning Division 4.2 Tank Farms The Gulf Oil Company operates a marine terminal (an oil tanker unloading facility) There are two major tank farms in or near off the shore of the City. Oil unloaded the City's coastal zone, each of which store there is transported by pipeline to a tank hundreds of thousands of barrels of oil. farm north of Hamilton Avenue and west of They are located adjacent to vacant Newland Street where it is temporarily , lowlands, flood control channels and stored until it can be piped to Gulf's residential areas. Spills or leaks at these refinery in Santa Fe Springs. The tank farm tank farms are rare, and no major spill has consists of three large tanks, each holding occurred. However, because large amounts 164,000 barrels of oil, and five smaller tanks of oil are stored so near valuable coastal with capacities ranging from 10,000 to resources, the possible impacts from tank 53,000 barrels. This facility is not located farm spills and related accidents warrant within the coastal zone, but is situated on detailed analysis. the coastal zone boundary. The Southern California Edison Company Although there has not been a major spill at operates a power plant in the coastal zone the Huntington Beach tank farms, there are near Newland and Magnolia Streets. Several rare events which could result in a serious large storage tanks hold the fuel oil used in spill: major earthquake, violent storms, the boilers of the power plant. Four fuel oil floods, and liquefaction. tanks, each with a capacity of 230,000 barrels, a jet fuel tank (used for certain Severe seismic activity could 1) "slosh" the turbine units) with a capacity of 21,225 liquids in a tank so that the roof is damaged barrels, and an ammonia tank (used for and the materials spill out, 2) stretch or pollution control devices) containing 14,650 strain tank materials, perhaps shearing gallons, are located immediately adjacent to bolts, 3) shear pipelines or, 4) collapse the power plant. East of the flood control structures. This type of damage has channel are three larger tanks holding fuel occurred in past California earthquakes, oil, each with a capacity of over 500,000 sometimes resulting in spills or leaks. barrels. All of these tanks are in the coastal zone. 28 The Huntington Beach tank farms are Fortunately, construction crews working on located near active faults, as is the entire the channel downstream from the tank farm City. Although no earthquake induced were notified, and the gasoline was accidents have been recorded at these contained before further damage could facilities, the potential exists. result. Both of the City's tank farms are located in It should be noted that both the crude and low-lying areas which are considered to be the fuel oils stored at the tank farms within susceptible to flooding. Although it is very Huntington Beach are much less volatile and unlikely, severe flooding could damage these flammable and are more viscous than facilities. gasoline. Spilled oil will not flow quickly unless it is set afire, thus reducing the These tank farms are also sited in areas hazard that could result from an accidential with known liquefaction potential. spill. Because of the potential seriousness Liquefaction refers to the collapse of of one of these types of rare accidents, unconsolidated soils causing surface however, areas adjacent to the tank farms depressions. Clearly, structures an the were reviewed to determine what protection collapsing surface could be damaged, and is available to them in case of an accident. this could result in spills. Adjacent Areas Dike Systems Both tank farms are situated within the If an unusual event did lead to a major spill, flood plain of the Santa Ana River, land that nearby areas would most likely be protected was once an extensive salt water marsh. by dike systems which surround both tank (See Figure 4.2). As discussed earlier, large farms. These dikes range in height from expanses of the vacant lowlands adjacent to four to 10 feet and are generally made of these sites may be viable wetlands. These mounded and compacted soil. A dike areas support several wildlife species, surrounding a tank or tanks containing crude including the endangered California Least petroleum with boil-over characteristics Tem and the Belding's Savanna Sparrow. must be able to contain 100 percent of the County flood control channels run between contents. For all other tanks, the dike must the tank farms and through the lowlands to be able to contain 100 percent of the largest the Santa Ana River, from just above its tank and the volume of the smaller tanks mouth to the ocean. These channels and the below the height of the diked area.16 river are important feeding and nesting areas for water bird species. The edges of A concern raised in the preparation of the these channels are surrounded by dikes Local Coastal Plan was that an unusual several feet high. Although the primary event which damaged a large tank would purpose of these dikes is to contain have the potential of breaking the dike floodwaters in the channel, they would also system as well. This type of spill potential act as barriers to any spilled oil. Thus, even can be illustrated in the case of a tank farm if a major spill and damage to the tank farm accident in Rialto. A pump hose system were to occur, the oil would malfunction at this tank farm erroneously probably not enter the waterway because of transferred gasoline into a storage tank that the dikes surrounding the channels. was already full. As a result, 90,000 gallons Similarly, the lowlands on the oceanside of of gasoline overflowed into the holding area the flood control channel would be surrounded by a dike. Subsidence and protected from spills from the Gulf and erosion from recent rains had weakened the Edison facilities. Fuel oil escaping from the base of the dike, which in turn collapsed older tanks at the Edison plant, however, from the weight and volume of the spill. could conceivably reach the lowlands south Fires ignited as the gasoline flowed freely of Newland and west of Magnolia. into a nearby flood control channel. 29 - ��o� •9 ��r . ,• N LEGEND COASTAL SALT MASM COASTAL SALT PLAT IL NAM . WARMAN MIA OAIXMMWATUAND for `F • twtl COASTAL SOME BOUNDARY CALIF.LEAST TERMS-ACRF f pry • RtMORANA AV*" Nam"a SANCTUARY Lappa q;,�•it $ .�'`�fir. ���� O � r♦ray'♦� p� 'ri` ��f 1. • �i��' •��1�♦0,1j: • �7•rj .• + . fig• I :�� ••� fulT f � i r • i Nplavowsm r r- 5.,• rr' Damage to lowlands from spilled oil can be 100 feet of the dikes. In both cases, the catastrophic. Clean-up is very difficult potentially vulnerable areas are downslope because of the moist soils and sensitive from the tanks and dike systems, with the vegetation. Afterward, the habitats may be containment dikes acting as the only barrier seriously, if not permanently, harmed. Fuel in case of a major spill. In the case of the oil is generally more toxic and damaging residences, however, the spilled oil would than crude oil to the species inhabiting have to cross an open field and a street wetlands. before reaching them. Thus, there would be opportunities to contain a spill before the As discussed earlier, a study conducted as oil reached structures. part of the Local Coastal Program suggested that the biological and aesthetic Storm Drains and Sanitary Sewers potential of these lowlands might be improved if active tidal flushing were If at all possible, spills should not enter restored. Flushing would most likely be storm drains or sanitary sewers. In a accomplished by opening culverts or pipes confined sewer, explosive concentrations of from the flood control channels to the hydrocarbons may be ignited and flash back lowlands. Brackish water would .then flow in along the sewer line. Also, in most sewage and out of the low-lying land with the ebb treatment plants, oil can severely disrupt and flaw of the tide. If this improvement the process by clogging the system or killing were undertaken, the channel and the the bacteria used in the treatment plant. lowlands would be much more susceptible to oil spills than they are now because the If a spill enters a storm drain, it may not be culverts or pipes would provide a conduit for possible to prevent the spill from entering the oil to reach these areas. In that case, the ocean. There are no shut-off valves all the lowland areas and the mouth of the within the storm drains, and if water is Santa Ana River could be seriously impacted present within the drain, the spill will .be by a major spill. Any plans to restore tidal carried out to the ocean. For this reason, it flushing should include consideration of a is important to protect the openings to valve system by which culverts or pipes storm drains in the area where the spill could be closed off in the case of a major occurs. spill with damage to the tank farm dike system. Company Oil Spill Contingency Plans Some industrial and residential areas may The FWPCA requires operators of oil also be vulnerable in an uncontrolled spill. storage or processing facilities to prepare a The residential area northeast of the Gulf Spill Prevention Control and tank farm is very close to the dike wall, but Countermeasure (SPCC) Plan if a spill could is separated from the dike by a six-foot conceivably reach a waterway and if the masonry wall. This barrier would help aggregate capacity of the facility is over protect the nearby houses even if the dike 1,320 gallons or if any tank holds 660 gallons system failed. Similarly, it is unlikely that or more (this applies only to facilities with leaks from the dikes around the newer unburied tanks). The purpose of the plan is Edison tanks would reach any homes, due to to ensure that personnel respond quickly and the nature of surrounding uses and effectively during a spill. The SPCC plan topography. must include an inventory of potential spill sources, estimates of the . anticipated Between the flood control channel and quantities which could spill from each Edison Avenue immediately northwest of source, probable direction of flow, Edison tank farm are mixed industrial uses. containment systems and equipment Immediately adjacent to the northeast inspection procedures. corner of Gulf's tank farm is another residential area, with houses located within Presently, oil spill plans for tank farms recognize the use of a dike system for 31 t containment, but they do not explicitly and the location of access points and on-site acknowledge the importance of protecting fire-fighting equipment. The Fire land uses in susceptible adjacent areas. All . Department requires these facilities to spill plans should include specific procedures meet minimum standards for building for protecting these areas in the case of a materials, dike system capacities, access threatening spill. provisions, and the presence of on-site hoses, hydrants and other fire prevention A considerable amount of controversy exists and containment equipment. over whether the lowlands adjacent to the tank farms are potential wetlands. The Evacuation Plans California Coastal Commission may be required to make the final determination on Even if a major spill were contained in the whether or not these lowlands are able to dike systems, nearby areas could be support a productive wetland habitat. seriously threatened if the oil were to ignite or explode. The heat and burning debris If the lowlands are found to be wetlands, the could threaten life and set nearby structures City should petition the EPA to require tank on fire. The smoke and fumes could cause farm facilities to prepare SPCC plans that serious property damage and would certainly include the following provisions: be a health hazard. A tank farm fire in Torrance in December 1979 killed three - A written commitment to expedite people, including one.person driving in a car containment and clean-up of any oil near the conflagration. The fire raged for discharged. two days, forcing the evacuation of 306 nearby . residences before the dangerous - Recognition of adjacent areas that are situation was safely under control. especially sensitive to spill damage: 1) Santa Ana River mouth and flood Residences and public roads are just as close control channel; 2) the wetlands and to the tanks in Huntington Beach as they are residential/industrial areas; and 3) in Torrance, although most of the storm and sanitary sewers. substances stored here, such as crude oil, are significantly less flammable. - A topographical map outlining the direction oil would flow should a dike Clearly, a major concern if such an accident system fail. were to occur would be the evacuation of nearby residents. The City's Civil Defense - A diversion system that would prevent Division, in cooperation with the Fire and oil or any harmful substance from Police Departments, has a general reaching the flood control channel, evacuation contingency plan which would be wetlands, or sewer lines in the event of employed if a fire or explosion threatened an uncontrolled spill. surrounding areas. - Provision for detailed inspection of the The Planning Division consulted with the diked areas following heavy rains to Civil Defense Division -- which has assure impermeability of the dikes and expertise in emergency planning -- on to verify functional operation of runoff whether evacuation plans specific to the valves. tank farm sites should be developed. Their conclusion was that such plans would be no Fire Department Reviews more effective than the existing plan, which is sufficient to safely evacuate those areas. The City Fire Department reviews the site plans for the tank farms which identify the types of substances stored in each tank 32 5.0 Conclusions and Recommendations 5.1 Conclusions The dike systems around the tanks provide the primary source of protection should a Local governments have significant tank accident occur. Even if a dike system involvement with the containment and should fail, nearby residential and clean-up of spills, particularly smaller commercial areas have additional protection onshore spills. Often, the Fire Department from masonry walls and topography. The will be the first agency to respond to the high viscosity and low flammability of most incident. Once the spiller is identified and of the liquids stored in the facilities reduces notified, the company usually assumes the hazard potential. Existing evacuation responsibility for containment and plans were reviewed and found to be clean-up. But, if the spiller is not known, adequate in case of an emergency. the Fire Department may actually contain the spill and will determine if assistance 5.2 Recommendations from higher levels of government is needed The City is continually working on ways to Existing oil spill plans in Huntington Beach improve the spill protection afforded its are generally adequate for spills which resources. The following recommendations occur onshore or wash ashore. The City is are based on the research and analysis prepared to respond to such spills and to conducted in this project. initiate , the containment process if necessary. If a spill remains at sea, the - Communication should be improved responsible party or Coast Guard will among levels of government and assume responsibility as discussed in Section agencies involved in containing and 2.3. 33 i10 1, 0 cleaning a spill. The City should disposal sites for spilled oil and other support efforts to revise the State Spill hazardous substances as discussed in Plan to increase state-local Section 3.1. coordination in spill emergency planning and, as much as possible, - Protection priorities for offshore spills participate in such efforts. should be established on a regional basis since it is possible that a major spill Periodic drills for mock emergencies will affect more than one jurisdiction's should be included in the City's offshore shoreline. The priorities may include spill plan. diversion booming as discussed in Section 3.2, and preferred areas to land To date, a major spill has not washed the oil. ashore on a City beach. Periodic drills would ensure that the plan can be - The City should petition EPA to require effectively carried out in the event of a SPCC plans for the tank farms near major spill. lowland areas and storm drains, especially if restoration programs in Industry and co-op spill contingency those lowlands are undertaken. plans should recognize the protection priority for different shoreline - The City should restrict new resources discussed in Section 3.0. development near tank farms unless secondary barriers and other protective The Coastal Commission should be measures are incorporated, as requested to require that the State spill necessary. plan address the problem of inadequate 34 NOTES 1 Huntington Beach Planning Division, Coastal Energy Impact Program, 1980. 2 The actual process for notification may be different given the size and location of the spill. 3 EPA does not have the personnel to send a representative to the location of every inland spill in this area; (EPA's office is located in San Francisco). Thus, for spills under 10,000 gallons, EPA requests the Coast Guard to represent them as the first federal agency on scene. If the spill is over 10,000 gallons, or if it is small but severe, the EPA will usually send its own representative. 4 Marvin Waterstone, "Oil Spills: Legal and Technical Response", New Jersey Department of Energy, Coastal Energy Impact Program, 1981. 5 The regional response plan for this area is the U.S. Coast Guard's "Los Angeles, Long Beach Oil and Hazardous Pollution Contingency Plan". 6 Attorney General California Highway Patrol California National Guard Department of Conservation Department of Fish and Game Department of Health Department of Transportation Department of Parks and Recreation Department of Water Resources Department of Forestry Office of Emergency Services State Lands Division State Water Resources Control Board 7 Attorney General California Department of Forestry California Highway Patrol California National Guard Department of Fish and Game Department of Health Department of Transportation Department of Parks and Recreation Department of Water Resources Division of Oil and Gas Office of Emergency Services Regional Water Quality Control Board State Lands Division Representatives of other governmental agencies as appropriate. Representatives of industry as appropriate. 35 Op � 8 Oral communication, Huntington Beach Fire Department. 9 State of California, Office of Planning and Research, Offshore Oil and Gas Development: Southern California, 1977 10 Coastal Energy Impact Program, op.cit. and Offshore Oil and Gas, op.cit. 11 Waterston; op.cit. 12 Offshore Oil and Gas, op.cit. 13 Waterstone, op.cit. 14 Southern California - Petroleum Contingency Organization, Response Measures for Selected Economic and Biologically Sensitive Areas. 15 Ibid. 16 As required by the Huntington Beach Fire Code. 36 BIBLIOGRAPHY Coastal Energy Impact Program, City of Huntinton Beach Planning Division, 1980. Offshore Oil and Gas Development: Southern California, State of California, Office of Planning and Research, 1977. Oil Spill Contingency Plan, Department of Beaches, County of Los Angeles, 1979. Oil Spill Contingency Plan, State of California, 1977. Oil Spill Contingency Plan, Beta Unit Complex, San Pedro Bay, Shell Oil Company, 1980. Oil Spill Response Plan, California Regional Water Quality Control Board, Santa Ana Region, 1975. "Oil Spills: Legal and Technical Response", Marvin Waterstone, New Jersey Department of Energy, 1981. Region IX, Oil, and Hazardous Substances Pollution Contingency Plan, United States Coast Guard. Response Measures for Selected Economic and Biologically Sensitive Areas, Southern California - Petroleum Contingency Organization. 37 HUNTINGTON BEACH ENERGY SERIES REPORT #4 ENHANCED OIL RECOVERY IN HUNTINGTON BEACH CITY.OF HUNTINGTON BEACH DEPARTMENT OF DEVELOPMENT SERVICES JAMES W. PALIN, DIRECTOR SEPTEMBER, 1981 TABLE OF CONTENTS PAGE FOREWORD 1 DEFINITIONS 2 1.0 INTRODUCTION 5 2.0 ENHANCED RECOVERY TECHNIQUES 9 2.1 Why EOR? 10 2.2 Chemical Flood 11 2.3 Miscible Gas 14 2.4 Thermal Recovery 15 3.0 PROGRAMS IN THE HUNTINGTON BEACH FIELD 19 3.1 Steam Soak Programs 19 3.2 Steam Drive Programs 20 3.3 Polymer Flood 20 3.4 Alkaline Flood 20 3.5 Carbon Dioxide Program 21 4.0 IMPACTS FROM ENHANCED RECOVERY PROGRAMS 23 5.0 CONCLUSIONS AND RECOMMENDATIONS 29 NOTES 32 BIBLIOGRAPHY 34 Foreword This is another in a series of discussion papers on energy-related issues prepared by the Planning Division of the City of Huntington Beach. Huntington Beach is a center for many energy-related activities including onshore and offshore oil production, an electricity-generating power plant, and increasingly, solar and conservation technologies. The purpose of these reports is to help the City to accommodate the continued production of so vital a resource as energy while at the same time mitigating as much as possible any adverse impacts on the community that such activities might incur. Other reports in this series include the following: #1 Preserving Surface Access to Underground Oil Reserves in Developed Areas #2 Fiscal Impacts of Oil Operations in Huntington Beach #3 Oil Spill Contingency Planning in Huntington Beach #5 Solar and Conservation Policies at the Local Level This publication was prepared with financial assistance from the U.S. Office of Coastal Zone Management, National Oceanic and Atmospheric Administration, under the provisions of the Federal Coastal Zone Management Act of 1972, as amended, and from the California Coastal Commission under the provisions of the Coastal Act of 1976. Definitions This report necessarily discusses some technical aspects of the oil industry and of enhanced oil recovery techniques. Consequently, some terms are used which may not be familiar to the reader. The following definitions section was prepared to help clarify the meaning of some of these terms. To ease refernce, all words defined in this section are italicized the first time they appear in the text of the report. Alkaline Floods: An enhanced recovery method utilizing injection of chemicals into the oil pool which neutralize acids in the oil. These changes in the chemical character of the oil formation allow more oil to be extracted. Areal Sweep: Refers to the effectiveness with which an injection fluid can disperse throughout an oil formation and "wash out" remaining oil. Incomplete areal sweep is particularly common in waterfiood operations because water flows through a formation more easily than oil. Thus, areal sweep can be improved by increasing the viscosity of the injection fluid. Channeli : A phenomenon which occurs when fluid injected into oil strata does not spread uniformly through the rock, leaving oil behind. Co-surfactants: Chemicals injected with surfactants to help adjust viscosity and other chemical characteristics of the flooding solution. Enhanced Oil Recovery: Any production method which is used to recover more oil from a petroleum reservoir than could be obtained by natural reservoir energy or simple pumping. This includes waterfiood, steam injection and other techniques involving injection of fluids into the reservoir to recover additional oil. EOR: See "Enhanced Oil Recovery.' Fire Flooding: Another term for "in-situ combustion.' Incom lete Contact: Occurs when a flooding solution caruiot contact and "wash out" pockets of oil because they are geologically isolated from the rest of the oil pool. Injector Wells: Wells through which pressurized water, steam, or other fluids are driven or "injected" into an oil reservoir. In-situ Combustion: A thermal recovery technique in which oil is ignited in-place, creating a ire r no t which moves through the reservoir. The heat and gases created by this firefront lower the viscosity of the rest of the oil in the pool, enabling it to flow more easily to production wells. In-situ Surfactants: A phenomenon in which injection fluids react with naturally occurring chemicals in the reservoir to create surfactants in-place. Micellar Flooding: A chemical flood technique in which polymers are used in conjunction with sur actants. Generally, a thin slug of surfactant is "driven" through the reservoir by a polymer slug and water. Miscible Gas Drive. Injection of gas that is mixable with oil. The slug of oil and gas that is created is then driven to production wells by additional injections of gas or water. 2 Oil Emulsification: A chemical mechanism which, by allowing oil and water to mix, reduces the ability of .water to flow rapidly through the reservoir. When the mobility of water is reduced through emulsification, more oil can be reached and swept out. Polymer Injection: Polymers are a thickening agent which, when mixed with water, create a viscous injection fluid. By reducing the mobility of the flooding solution, polymers help recover more residual oil from the reservoir. Primary Production: Oil driven up through wells by natural pressure in the formation or by pumping units, without injecting water or other fluids to help force the oil to the surface. Producers: Wells used to pump out oil from a reservoir. Secondary Production: Oil extracted after primary production, usually by injecting water into the reservoir. Steam Drive: A form of steam injection in which superheated steam is forced through an oil reservoir via injector wells and is driven toward producers. Steam Injection: A thermal recovery technique whereby steam is either soaked into or driven through a reservoir to lower the viscosity of the oil and increase its ability to flow. Steam Soak: A type of steam injection wherein the well is shut down for a period of time a ter the injection of superheated steam. During this time, the steam "soaks" the oil bearing stratum. When the steam has freed the remaining oil, the same well is used to produce the oil. Surfactants: A "surface active agent" which behaves like a detergent by chemically reducing the interfacial tension between oil and water. Tertiary Production: Oil recovery methods applied after secondary production which usually involve the injection of chemicals with water into the reservoir to help push out more oil than water alone can. Thermal Recove Technl ues: FOR methods which utilize heat to change the viscosity 0 oil and there ore its mobility. Steam soak and steam drive are two thermal recovery techniques. Water flood: A secondary recovery program through which pressurized water is injected into a reservoir in order to push more oil from the pores in the rock. Water Injection: Another term for "waterflood." Wettability: Refers to the level of permeability of the rock by water. 1 .0 Introduction One of the most intriguing and Many methods have been developed to important new sources of domestic oil recover portions of the oil remaining is the residual petroleum left in after primary production. By far the existing fields after "conventional" most common of these is the extraction technologies have been waterpood. In this process, applied. This comprises a surprisingly pressurized water is injected into the large percentage of the original total oil-bearing stratum. The water helps to volume of oil in a pool. In the most drive out additional oil. Depending on basic and widespread production the characteristics of the oil and the method, a well is drilled into oil-laden geology of the rock stratum, an rock. The oil, along with any gases or additional 10 to 20 percent of the oil water in the rock, is driven to the can be recovered. However, even after surface by natural sub-surface waterflood, over half of the oil still pressures. When natural pressures are remains in the ground. (See Figure 1.1) exhausted, a pump is placed in the well to pull up more oil. Although the Oil recovered after primary production pumping may continue for decades, is referred to as secondary typically only 20 to 30 percent of the production. As the price of oil has oil in the pool can be extracted this increased, technologies have been way. Oil recovered in this manner is developed to extract some of the oil called primary production. remaining after secondary production; this is known as tertiary production. Y the pr( y and even much of its Figure 1.1 secondary production potential has already been realized. However, as the \ price of oil has increased, FOR techniques have , become increasingly JeCOndary attractive and man FOR y projects are being conducted in Huntington Beach. Tertiary The City is interested in FOR for several reasons. First, oil is an Primar \ \\ important natural resource; increased \\ domestic production is important to this country, which is currently reliant on foreign energy sources. The local Remaining Oil— community has also benefited from the Recovery by Future revenues generated by oil production Technology? and by the employment opportunities and increased business oil activities bring here. Thus, the City has tried to accommodate oil production as long as the operations are conducted in ways which are not detrimental to the public health, safety or welfare. The City Percentage of Oil in the Ground should be concerned that FOR can Which is Usually Recovered by likewise be accommodated so long as it Different Extraction Methods. is conducted in a responsible way. Source: Petroleum Engineer, January, 1976 Secondly, many FOR techniques are relatively new or untested. Several of the FOR projects in Huntington Beach are, in fact, "pilot programs" which may have impacts that are different lEnchanced oil recovery,___ or FOR from more conventional operations. usually refers to all extraction The City should be concerned that any techniques except simple pumping and such impacts are mitigated as much as waterflood.* Often "EOR" and possible and that its regulations related "tertiary production techniques" are to FOR are adequate to protect the used interchangeably, but this is community. correct only when FOR occurs after secondary production. Often an FOR Third, FOR techniques may technique is applied after primary significantly affect the longevity of oil production in which case it is secondary production as a major land use in production. In some unusual Huntington Beach. This information circumstance, where simple pumping is will be important in the City's ineffective, FOR may be used as a long-term land use planning and related primary production method. policy-making. This report discusses FOR in the Huntington Beach oil field. The field is + Technically, waterflood can also be an old and very productive one. Almost considered EOR; but generally, one billion barrels of oil have been waterflood is differentiated from other recovered here since its discovery in FOR methods because it has been used 1926. Waterflood has been used for a long time in many areas, unlike successfully here since 1958. Most of most other FOR techniques. 6 The next section of this report from .EOR programs and evaluates the discusses FOR techniques in general. existing regulatory process controlling Section 3.0 reviews the FOR programs FOR here. .The final section suggests which are being tried in Huntington some actions and policies for the City Beach. Section 4.0 analyzes the related to future FOR in Huntington possible impacts which could occur Beach. 2.0 Enhanced Recovery Techniques FOR technologies are often applied much of the fluid oil as possible. after primary and secondary However, oil is a thick, viscous production; they are generally used to substance and these pores provide only overcome the limitations of these more very small passageways for its conventional recovery methods. Thus, movement. Consequently, only the it is useful to understand how a simple most mobile oil, in the largest pore waterflood works and why such a spaces and closest to the pump, tends program leaves so much oil in the to be extracted. ground. In a waterflood or water injection Oil is not found in liquid pools, but is program, several wells are arranged to contained in the pores of permeable form patterns within the oil pool. Some rocks such as sandstone or of these are injector wells, through conglomerate. These pores are which pressurized water is forced or widespread through the rock and to injected .into the oil-laden rock. The some degree are interconnected. The water pushes out in all directions, goal of all oil extraction processes is to driving some of the oil out of the pores remove fluid oil from these small pores. in front of it. Other wells, called producers, pump out the oil driven by In primary production, pumps are the pressurized water from the lowered into the ground to pull out as injectors. See Figure 2.1. T Pressurized Figure 2 . la Water oil IQ Injection Pump Producing Injection Well well 5 Oil Pushed by Pressurized Water injected Water Enters Oil Zone Side View of a Waterflood Sectinn. Source: Chevron, USA. 2.1 Why EOR? Although a waterflood helps to force never makes contact with the oil in additional oil from the pores in the them. This condition, called formation, the water cannot push out incomplete contact, _ is the second all of the oil in the pool. There are reason why waterfloods leave oil in the three principal reasons for this. First, ground. Sometimes it is possible to the injected water flows through the interconnect the islands to the rest of formation more easily than the oil, the pool by fracturinq the rock and leaving large areas of the deposit creating passageways for the oil and untouched by the water. This water to flow through. phenomenon is called incomplete areal sweep. One goal of an FOR project, Incomplete contact can also occur when then, is to increase the areal sweep of the water, which is much less viscous the waterflood. This can be done by than the oil, flows through relatively increasing the viscosity (or "thickness") wide passageways in the sandstone and of the water, or by decreasing the does not spread throughout the rock viscosity of the oil.1 uniformly. This problem, called channeling,-.— is common in the Within the area that is swept by the unconsolided sandstones in the waterflood, some pockets or "islands" Huntington Beach Field. may exist that are geologically isolated from the rest of the pool. Thus, the The solution to channeling is the same water travels around these islands and as for incomplete areal sweep: 10 paintbrush soaked in oil-base paint with water. The water runs through the Figure 2 . lb bristles pushing some of the paint out, but much of the paint sticks to the r" n brush. � r w To overcome this problem, the solution pushing the oil out of the rock is made u r+?Jr soluble or mixable with oil, reducing the surface tension between ..s... them. This can be done by adding chemicals to the injected water. or by injecting other liquids or gases which water © are more mixable with oil than water. The next sections discuss more specifically different FOR techniques. tuf?� r� 2.2 Chemical Floods One of the most common FOR techniques is to inject substances other `r.[r..•_ '��•"'�` �_'�'� - than water, or water treated with Chemicals, in place of a simple Pressurized water from the waterflood. injection well © forces oil toward the producing wells Polymer-Micellar Flood: Polymer . injectionlis one of the easiest and most economical FOR techniques to Top View of Waterflood. implement. Polymers are generally used in FOR as thickening agents. They Source: Huntington Beach Planning are mixed with water to create a more Division. viscous or gelatin-like injection fluid. The result is very much like adding corn starch to thicken a stew or sauce. (In fact, starch is a kind of polymer.) The increase the mobility of the oil so that polymers reduce the mobility of the it can flow through the small channels flooding solution which increases the easier, or increase the viscosity of the sweep efficiency. As more of the water so that it does not flow through reservoir is swept by the solution, more the wide channels so easily. oil is encountered and recovered.2 There are two kinds of polymers used in The third reason for the inefficiency of EOR: "biopolymers," which are simple waterfloods is the "surface polysaccharides produced by tension" between oil and water that microscopic organisms, and prevents them from mixing easily. The polyacrylamides which are commonly effect of surface tension is that the derived from petroleum (although other water does not push the oil perfectly, sources, such as wood by-products, are and a significant amount of oil can be being developed). trapped in the pores of the rock. The physics of this phenomenom is Often a year or more of preparation somewhat difficult to explain, but it is precedes the actual polymer injection. essentially the same problem one For example, the reservoir is often encounters when trying to clean a "preflushed" with fresh water or with water treated with s14�.1 amounts of Another !ess, called micelles salts. The . preflush helps prevent flooding, uses polymers in conjunction unwanted interaction between the with chemicals called surfactants. polymer and chemicals in the natural Surfactants, or surface active agents, reservoir water. are chemicals that can reduce the interfacial tension between oil and A "slug" of very highly concentrated water. This enables the surfactant to polymer solution is then injected into "attract" oil and water at the same the oil laden rock. Water is injected time, a property common to soaps and behind the polymer slug to drive it detergents. In effect, the process uses through the reservoir (see Figure 2.2). a detergent-like substance to "wash The use of a "slug" driven by untreated out" more oil than water could alone. water helps keep the costs down; a The most common surfactants are continual injection of polymer mixture petroleum sulfanates (derived from oil) could be economically prohibitive. and lignosulfanates (derived from wood Figure 2 . 2 SIDE VIEW OF POLYMER INJECTION I � r rl.11i 1 ,l Ill I { t I �.1 1 I l {.I . I I I: I {`141 Ill`'I:lt,I+ IJ ,I� I jl i 11 tilil �I. l, Ilhililf ll.j' IIl'I lI I11 '.I' Li 11 �IHlljf -, II-II F I I I II ,. (• II .III 'lllll 'j 1 {': Il1i 111{ ICI I( Il lliJ �• ll4 lr pull 1�111.1 1 . it .I li llj,ll 111 �l Lf 1: 41 Jill. ]' FI {rll . J,i , G,I l I I ,.IL I,.14. I, 0 Water o : Eddional Preflush to I„ ; I Drive Polymer Condition l : l Ira Polymer Slug ered #I ICI •- ,•. . , .'• I . I Source: Chevron, U.S.A. and Huntington Beach Planning Division 12 b roducts) and are very ensive.Y-P 1 Y � The application of surfactant/polymer Thus, very small slugs of these flooding will be generally successful in materials are used to form a thin, reservoirs that have responded to reactive surface which is pushed secondary waterflooding. There are, through the pool by a less a)pensive however, a few disadvantages polymer slug which is in turn driven by associated with polymers and untreated injection water (see Figure surfactant solutions. 2.3). Other chemicals, which help adjust the The main disadvantage of micellarflooding is the high cost of surfactants. viscosity and other characteristics of Because these chemicals are often the solutions, may be injected with the surfactants. These are called derived from oil, their cost follows the trend in oil prices. The high cost of co-surfactants and consist mainly of surfactants is an especially difficult alcohols. mime to t . dissolved salts problem when reservoir conditions may also be addedd to the flood solution. degrade the surfactant slug. This can Figure 2 . 3 SIDE VIEW OF MICELLAR FLOOD 1 1•; r�i tilt i ijl V111 Ji1,j_I`tlfiHlilf'liFl�I'l 'IIII � pll'jI �Illl'.IIIJ�tllf 1i11 � I� �' I�ILI,IIj I11. II �'Iilll I II I I F I IA I � I j 1. 1 l f l l l 11 I L l l l I.J. . 1 J ,1 41, 'il II �.I II1 ' l11' :I= JI III jl I ,IIII� I .I } •� _o ° o c •of•. I 11 f I Drive : Polymer Micellar Oil I Water I • I II 0I Water :'• Slug , Slug Bank preflush 1/ 'I led • ' e o n o ° O o '• • I III r ..� o0 00 °°• ,.. III I Source: Chevron, U.S.A. and Huntington Beach Planning Division 13 happen when the slug rbed by the ltafl.ffect• ever, is the formation of rock in the formationtr a high rate, or in-situ surfactants,_ In other words, when the natural chemistry of the the alkaline injection fluid reacts with deposit reacts with the surfactant, naturally occurring chemicals in the, reducing its effectiveness. The reservoir to create a detergent-like absorption problem can be partially substance. This reduces the formation's controlled by the addition of the ability to retain the oil, much like a co-surfactants mentioned above; the surf actant flood. effects of in-situ reactions can be reduced by a freshwater preflush. Thus far, alkaline floods have had Ultimately, the solution to the cost limited application. Recent tests are problem may be in the use of chemicals encouraging, but the oil industry has that are not derived from petroleum, less experience with this technology such as the lignosulfanates than with some other FOR techniques manufactured from paper product (e.g. thermal processes). It appears waste. however, that alkaline floods are most effective in reservoirs containing high Polymers also tend to degrade easily, viscosity crudes that are very acidic - a and suffer many of the problems of condition found in the Huntington surfactants. Improper handling (e.g., Beach field. In the future, this injection at excessive pressure) of the technology may be useful here and in material can reduce its effectiveness. many California oil fields. Biopolymers, while less sensitive to handling, are suseptible to bacterial The principal drawbacks to this process infection that can reduce effectiveness are related to the handling and. disposal and cause clogging in the well bore. of the caustic materials. Sodium Filtration with diatomaceous earth and hydroxide (the chemical name for lye) treatment with biocides (e.g. chlorine) and other caustic chemicals can cause can combat these effects, but again, severe burns to the skin if not the cost of the process increases. sufficiently diluted. These compounds are usually shipped and stored in high Alkaline Floods: In alkaline floods, a concentrations; however, in the actual chemical such as sodium hydroxide) is injection fluid, the NaOH is greatly added to injection water to make it diluted with water, reducing its caustic "alkaline" or 'basic". "Base" chemicals properties. Field workers handling this have the property of neutralizing material will have to wear protective acids. When the alkaline solution is clothing. The greatest danger of injected into the oil pool, it neutralizes harmful environmental effects and the acid in the oil. As a result of the human injury would occur if the chemical changes this causes in the oil undiluted solution were spilled. formation, more oil can be forced out of the reservoir.3 Disposal of used chemicals is not a severe problem. Most of the residual There are two mechanisms at work in remains in the oil formation. The rest this process. The first is called oil can be reinjected into the pool and, if emulsification, which reduces the the wells are properly sealed, it will ability of the water to flow rapidly remain isolated from other strata. This through the formation. As mentioned procedure has been used quite in Section 2.1, reducing the water's successfully in the past to protect fresh mobility increases areal sweep water aquifers from brine and other efficiency and contact. Thus, the flood pollutants. reaches more of the oil in the pool. 2.3 Miscible Gas Techniques The second mechanism at work in an alkaline flood is not well understood. Miscible gas drive, another method of 14 tertiary oil extraction, uses a gas that finish of a project; others follow the is miscible, or "mixable" with reservoir CO2 slug with alternating water and oil as the injection fluid. In this CO2 injections (see figure 2,4); in a technique, the formation is injected third scheme, CO2 is injected and with a gas that can overcome the allowed to "soak" the formation for a surface tension that traps oil in the period of time before the oil and gas pores of the rock. The gas mixes with are pumped out (see Section 3.5). the residual oil droplets and creates a 'foam slug" that is driven to production Although sources of CO2 suitable for wells by additional gas or water tertiary recovery are available from injections. Several miscible substances facilities such as refineries, power have been tried in tertiary oil recovery; plants and smelters, less than 10 the three most common are Liquified percent of U.S. oil fields have access-to petroleum gas (LPG), carbon dioxide such low-price sources. Limited access (CO2), and nitrogen (N2).4 to low cost sources of CO2 may constrain the use of this method in Liquified Petroleum Gas (LPG): some areas. Liquified petroleum gas, which includes An additional problem is encountered ethane, butane and propane, mixes with with the use of CO2 .in fields that oil immediately on contact. have been waterflooded. When CO2 Consequently, it can be successfully reaches a wet wellbore and wet used as an injection fluid in FOR reservoir, it forms a corrosive called projects. First, a slug of LPG is carbonic acid (H2CO3). Thus, a injected in an oil reservoir. This LPG CO2 injection program undertaken slug is followed by natural gas or a after waterflooding requires expensive combination of gas and water which noncorroding trims and coatings on all pushes the slug through the reservoir, piping and extraction components. freeing residual oil. Reservoir temperatures, as well as LPG injection Nitrogen (ND: Miscible displacement pressures, are critical in keeping the using nitrogen, injected at slightly slug miscible with the crude to allow higher pressure and slightly greater effective oil recovery.5 volume than CO2, offers another alternative in tertiary oil recovery. Although LPG injection can increase oil Nitrogen can be obtained from air and production in some fields, the gas itself does not exhibit the corrosive qualities is valuable as a clean-burning fuel, and associated with CO2 injection. The is expensive. The high cost of LPG may processing and transportation costs of prohibit its widespread use in FOR CO2, combined with the corrosion projects. Control measures necessary for CO2 injection, put its production costs well Carbon Dioxide (CO2): Carbon above those assocated with N2. dioxide is a common compound, usually However, in laboratory experiments, in a gaseous state when used for the effectiveness of N2 in miscible miscible displacement. Although oil recovery has not been firmly strongly attracted to oil, CO2 does established. not mix with oil at first. With favorable conditions of temperature, 2.4 Thermal Recovery pressure and formation chemistry, however, CO2 provides an effective Thermal recovery techniques use heat miscible gas for many reservoirs.6 to change the viscosity of the oil and improve its ability to flow through the Several ways of injecting carbon rock formation. Two kinds of thermal dioxide are currently used in tertiary processes have been tried: in-situ recovery. One method continuously combustion and steam injection. These injects CO2 from the start to the methods are described below.? 15 In Situ Combustion or;�Cre Floodino": other mean. Once the oil-in-place In situ combustion, or fire flooding, is begins to bum, hot combustion gases one thermal recovery technique used to are created which lower crude viscosity introduce heat and pressure into a and cause residual oil to flow toward reservoir. It is considered only production wells. Through controlled partially effective, and plays a air injection into the reservoir, the diminishing role in tertiary recovery. combustion is maintained at about 900OF as the burning oil front The process begins when air is injected proceeds slowly through the reservoir. into the oil pool, and the residual oil is induced to burn. Often, the Although numerous in-situ pilot introduction of air into the formation is programs have been conducted in the enough to cause spontaneous U.S., particularly in California, early combustion; occasionally, the oil must efforts provide generally discouraging be ignited by an electric heater or results. Problems commonly Figure 2. 4 SIDE VIEW OF CARBON DIOXIDE INJECTION I r t.11'�i �-'il + 'rt il �'.(-�11 l 1; 19 l: •I 'I 'l I tl. tl ' '1 I j jJ II ..1f141 . •�Irli i. itllt� l 'itl' ll 1 Ir1:4t III I-Illtr'H t '(tllirl IIII� Flltllllll ltlltt{ (f t( Iflii..l i�Ill�.l.l LII. t. Intl. I fl t o I I I tll I •I I, L.t I I I LI1 l J II rl trt Ilr II! �. j' 1 ;Itil I . I , 1 Il r:ili l,li. t. tf,•III 'tll-I . 1•il � lllllrll•i .l (jIII-tt'.Irl{ IjIIIIII .II � III. l.11 LI L l7. IIIDrive °CO2 . Water CO2 , Miscible + Oil I . I II 11 Water e:�• ;� o Zone Bank ° sn• •+.'. • ' son..s° 1 • °° ° D : ,: o° ° •"4°.•.}� orb... 1 I o• •o oc'•. o o . o II of r' o ° o o � •. .moo . . 1. ,\ . . I II /1 - °nV°u ,. ° D c � •�,•'•D•a ... .. ,; III 00 o s •n O • 01� ..� .�•. O Source: Chevron, U.S.A. and Huntington Beach Planning Division 16 encountered are hi for 9h costs injection: The steam drive and compressor equipment; the relatively sfaam soak_ processes are two forms low sweep efficiency of the fire front of steam injection that are described in because of its unstable frontal advance; a later section of this report. Both the high incidence of corrosion and processes work in the same manner to burnouts at producing wells causing coax more of the residual oil out of the heat damage to downhole equipment; formation. air pollution from combustion gases produced with the oil. Also, additional Steam injection begins when equipment is required: a "quench' superheated steam is injected into an system to cool downhole hardware, and oil pool, raising the temperature of the a vent system to allow dissipation of oil. As the oil is heated, its viscosity combustion gases. decreases and it flows through the formation with less resistance. In Steam Injection: The most widely used addition, expansion of the heated oil thermal recovery method is steam helps drive it toward the producing v wells (see figure 2.5). Figure 2 .5 SIDE VIEW OF STEAM INJECTION 11: 1'1 � l I II I 1141' rli criylill' I ' I•Ia1� � � � J l lllllli Iflrl II I'lli ' Lil ' Ii. 11 ICI!,111i4�Hijrlh '.ill {Ill� illijlll'lll'�il�llll.tlll �llllll'III.I� ikli'} I• II'�'. 11 171 il� lr l l' '' .IIJ � ,Ili r Fllji Ill ll•, h. Ill lijlll{ I� il.f j i I It. 1. i FII.i/II . J i14�1 � ! f I1. ILlllli�l ,ltl� lll;lllil .l lilj7 I. I� • : ti;i :l ICI Steam and Hot ' •��' Oil , Condensed Water • �' Bank f, %, :I� :I i� Water Source Chevron, U.S.A. and Huntington Beach- Planning Division Steam injection works bin shallow, temperatures and pressures, noise and low pressure reservoirs that permit steam plumes from generators and steam with high heat content to injectors, and odors from oil contact the oil before losing its distillation. All of these can be effective temperature and pressure., mitigated to an extent. Furthermore, greater viscosity reductions can be achieved if the An interesting new technology is being reservoir contains highly viscous crude. developed that may overcome some of Thus, steam injection is most the principal drawbacks of conventional successfully applied in reservoirs with steam methods. This device, called a characteristics commonly found in "downhole generator," generates the California's oil fields - very viscous steam underground, in the formation. deposits lying near the surface. Preliminary tests indicate that by using Consequently, many steam injection the downhole generator, steam flood is projects have been undertaken in applicable to deposits as deep as 6,000 . California, including Huntington Beach. feet; the steam reaches the oil at a higher temperature, making it more Although in many ways this technology effective; combustion gases from the is well suited to the geology found in generator help the steam move the oil these reservoirs, there are some through the rock; chemical reactions problems with steam injection. The between exhaust gases and the most notable among them are crude oil reservoir rock significantly reduce consumption and resultant air pollution emissions. Further tests will soon be from steam generators, increased conducted in Long Beach. safety risks to field workers from high 18 3.0 FOR Programs in the Huntington Beach Field In this section, the principal FOR employed by both Aminoil, USA and programs currently being undertaken in Chevron, USA - the two largest oil Huntington Beach are briefly discussed. companies operating in Huntington Beach. In this process, superheated 3.1 Steam Soak steam is injected into the reservoir over the course of several weeks. By far the most widespread and Next, the well is shut down for a period successful FOR program in the of time while the heat frees the oil. Huntington Beach field is steam Then the same well is used to produce injection. The field contains shallow the heated oil. zones which hold a highly viscous crude in relatively unconsolidated sandstone. After this process is repeated several The heat carried by the steam lowers times, its effectiveness drops and it the viscosity of the oil, permitting becomes unprofitable to continue the more complete recovery. project. The reservoir may then be a candidate for a steam drive program. Steam soak or "huff-and-puff" is the most common technique and it . is Steam soak has t( successfully 3.3 Palymel hod employed in Huntingto?f'each since the mid 1960's, and is still frequently tried The only example of polymer flood in in shallow zones throughout the field. Huntington Beach is a very simple pilot Current steam soak projects are being program undertaken by Chevron conducted onshore by Chevron; Aminoil involving a ' single injector and is steaming offshore deposits with producer. After a freshwater preflush, equipment located onshore at their a polymer slug (containing a chemical main lease. called Hydroxyethylcellulose) is injected and driven towards the 3.2 Steam Drive producer. This should improve sweep efficiency and push more oil out of the Another related thermal recovery reservoir. method is steam drive. This technique is similar to a simple water flood. The project was recently terminated Injectors and producing wells are drilled after it demonstrated that the polymer in patterns, and superheated steam is can be successfully mixed and injected, forced through the injectors. The and that it can stimulate additional oil steam gradually condenses to hot water production. The Huntington Beach site forming a slug of hot water and oil. is now on a conventional waterflood, The heat lowers the viscosity of the oil but Chevron plans to do a larger while the hot water and steam help polymer experiment in its La Habra drive the oil to the producers. field. In August, 1981, Aminoil began a steam 3.4 Alkaline Flood drive project in some areas of the field that have already been steam soaked. Aminoil has tried another kind of If the initial results are promising, they chemical flood that uses an alkaline expect to undertake a full steam drive (either sodium hydroxide or sodium program with equipment located both silicate). After a one and one-half year onshore (in their main lease) and softwater preflush, the alkaline offshore (on platform EMMY). chemical is diluted in, a slightly saline solution and injected into the The offshore steam operation is a most formation. The alkalines used in the interesting example of this kind of project are stored in high program. A five spot pattern of wells concentrations on the surface, and may has been drilled from EMMY into a be corrosive in this form. However, shallow zone containing a viscous oil. they are highly diluted in the injection Steam will be injected into the four solution. injector wells over a period of several months; a soak and injection program It is not clear how the process works. will be continued for over a year, after Aminoil engineers suspect that three which the producing well will be opened effects may be occurring. First, the and begin pumping. alkaline-saline solution may be reacting with chemicals in the rock to form an This is one of the first examples of "in-situ" surfactant, which reduces the steam drive being conducted from an surface tension between the injection offshore platform. An extension to the water and the oil. platform was built earlier this year to accommodate the steam generator. Another effect may be that the Results of this pilot are not expected injected- solution increases the until 1983; however, if it is successful, wettability of the formation rock. new platforms may be constructed to This would help the water to more conduct further offshore thermal completely penetrate the formation and programs. displace the oil. 20 A third possibility is that the caustic in the formation, taking up space solution reacts with salts and other normally held by water and helping to chemicals in the formation to form force the oil to the surface. Secondly, precipitates - small solid compounds. the viscosity of the oil seems to be These can act to "thicken" the solution reduced as some .of the oil is dissolvEd and improve sweep efficiency. with the gas and then driven up the Aminoil's pilot began in February 1980; producing well. results will not be available until the end of 1984. An important_ constraint on the use of this technique is the source of 3.5 Carbon Dioxide inexpensive CO2. The CO2 for these pilots is brought in by truck and Aminoil is also experimenting with a injected into the formation with small scale CO2 miscible gas portable compressors; further projects technique. In a fashion similar to the will require large amounts of CO2. steam soak, pressurized CO2 is One local source of CO2 is the Edison injected into the formation over several power plant, but use of its exhaust gas weeks. The well is capped and the for oil recovery will not be feasible CO2 "soaks" the formation for up to unless large scale CO2 miscible six months. Then, the oil and gas projects are begun. Aminoil will begin mixture is recovered through the same a pilot program late in the Fall, 1981. well. Aminoil engineers explained that two events may account for the improved recovery. First, the gas "swells" the oil 4.0 Impacts From Enhanced Recovery Programs This section contains a more detailed polluted and subject to stringent air discussion of the possible impacts FOR emissions regulations. Any new may have on the air, water, land and stationary source of air pollution (such aesthetic environment of Huntington as a steam generator) requires a "new Beach. source review" before it can be constructed or operated. This review 4.1 Air Impacts determines the emissions standard applicable to the new source based on Combustion Products: Emissions that the nature of the project, its size and adversely affect air quality are the type of fuel it burns. Permits to greatest in steam injection projects, construct and operate the facility are particularly if crude oil produced issued only if the project can meet the on-site is burned to generate the standards, or if emissions from other steam. The amount of pollution sources can be reduced to offset the produced may be significant, depending new pollution. on the size of the project. Although pollution control devices can reduce Chevron's steam projects in Huntington these emissions to a degree, a large Beach use small steam generators project would have adverse impacts, (approximately 22 million BTU per especially in an area where the air hour) and burn natural gas. This quality is poor.8 combination of generator size and fuel type exempts these steam operations Huntington Beach is under the from new source performance jurisdiction of the South Coast Air standards. Aminoil's steam drive Quality Management District, which project will burn lease crude in larger includes Orange, Los Angeles, San generators (approximately 50 million Bernardino and Riverside Counties. BTU per hour) that are equipped with The airshed in this district is heavily exhaust stack scrubbers. In addition, �o Aminoil has reO omissions The S61_4koest 'Air Quality Control elsewhere in their oper ions to offset Board regulates hydrocarbon emissions any new pollution. The net result is into the atmosphere. Once CO2 is that steam projects in Huntington used as an injection fluid, it contains Beach do not produce significant various hydrocarbon gases and cannot amounts of new air pollution.9 be vented into the air. Thus, when Aminoil undertakes its CO2 soak Other Gaseous Emissions: There are program later this year, it will use a two gases that may be emitted from "closed system" that captures the some FOR projects that can pose health CO2 (and other gases) produced with hazards: carbon dioxide (CO2) and the oil and use it for the next hydrogen sulfide (H2S). Although injection. This system will also reduce CO2 is a major constituent of air, it the cost of the project by reusing the can be dangerous in a rare combination expensive CO2. of circumstances. CO2 is heavier than air and, under very still wind 4.2 Water Impacts conditions, could . accumulate in a pocket or depression. Persons Ground Water: Ground water supplies breathing the accumulated gas could can be threatened if wastewater from suffocate.10 injection projects is not isolated from strata containing fresh water. After an Hydrogen sulfide (H2S) is sometimes injection project, most of the injection found in oil deposits, and produced with fluids remain in the formation, but the oil. H2S is toxic, but should some are produced with the oil. These present no danger in the concentrations are usually reinjected into the pool but naturally occurring in Huntington may be stored in sumps on the surface. Beach. In low concentrations, H2S is The threat of ground water naturally malodorous and can be contamination from surface disposal is detected by its smell. However, small, if the sumps that contain the further safety measures are necessary wastes are properly constructed.12 to protect people from H2S in higher concentrations. All wastewater disposal programs require a California Regional Water There is no danger from these gases Quality Control Board waste discharge unless three factors occur permit. Before the permit is issued, simultaneously: a large, undetected the applicant must specify the leak of the gas, very still atmospheric pollutants contained in the water, and conditions, and the presence of persons file a spill contingency plan. The Board in the affected area. It is unlikely that requires that sumps be lined to prevent all three of these factors will occur at the contaminants from percolating into the same time; however, precautions groundwater supplies. In addition, are taken to assure this. Oil sites disposal sites are diked to confine spills where H2S is present have vapor to the immediate area. recovery systems to minimize the volume of gases escaping into the air. All wastewater disposal sumps in In addition, the California Occupational Huntington Beach are lined and diked, Safety and Health Administration although much of the locally produced requires that these sites be well wastewater is not stored in them. Most ventilated and equipped with H2S of the wastewater from oil production detectors and alarms. The Division of here is treated and purified so that it Oil and Gas has published guidelines for can be used again as an injection fluid, safely conducting oil operations in discharged into the ocean or a storm fields where H2S is found.1 drain, or deposited in the City's 24 sewer system. Ocean discharge protected.. After the injection 'is requires a Regional Water Quality completed, the Division regulates the Control Board permit; storm drain abandonment and monitoring of wells to disposal is permitted through the insure that they remain intact.15 County Environmental Management Agency; the Huntington Beach Public Second, the. age and condition of wells Works Department issues local drilled into or through the treated wastewater permits based on municipal formation affect ' the chance of code regulations.13 leakage. This is of particular concern in fields with older, abandoned wells Ground water can also be contaminated that may not withstand the pressure by an improperly sealed well or a faulty from FOR injections. Sometimes, well casing that allows chemicals or repressurizing the field can cause brines to migrate from an oil zone to a cracks to develop in the cement around fresh water aquifer. However, it should the casings of older wells, .and allow be noted that this rarely occurs. For pollutants to migrate to other strata. example, in a Texas oil field with extensive injection projects, the rate of The Division of Oil and Gas requires well failure was 1 in 10,000 per year that the operator locate all abandoned between 1960 and 1975.14 wells that will be affected . by an injection project, and show that they The risk of well leakage and subsequent were properly abandoned. A monitoring ground water .contamination depends on system must be devised to assure that three factors. First, the nature of the the injection fluid remains in its waste materials left in the ground and intended zone or zones. the problem of containing them are determined in part by the FOR process Finally, a seismically active area such used. For instance, the CO2 miscible as Southern California may face a risk process makes the formation water of well damage from earthquakes. It is acidic. This promotes corrosion of the possible that an earthquake of well casing and, after several years, a sufficient magnitude could fracture the leak could develop. On the other hand, cement used to seal the wells. A well some chemicals used in polymer or damaged by an earthquake may have to surfactant floods readily degrade by be redrilled or abandoned to prevent natural processes (absorption, dilution, leakage. entrapment, etc.). Thus, the probability of a leak and the potential Surface Water: Some of the materials hazard the leak presents depend on the used in chemical floods could adversely FOR technology employed. affect surface water resources. These materials are usually shipped and stored The State Division of Oil and Gas on-site in concentrated form; an regulates all injections of materials accidental spill of concentrated into the ground, to secure human health chemicals could enter a body of water and safety, and the preservation and and contaminate it. There is an protection of fresh water resources, additional danger to persons, animals among other goals. Before any and plants that come in contact with injection can take place, the operator the spill. If safe handling procedures must file an injection plan, show what and adequate spill containment materials will be injected, the location measures are employed, the likelihood and quality of subsurface water, and of severe damage can be minimized.16 how the water resources will be 25 The Fire DepartmerAgulates the the Cri.'_Oublic Works Department. storage of hazardous chemicals and The wastewater permitting processes highly toxic materials. The fire code are designed to prevent improper calls for storage, handling and use of disposal practices that could result in these materials in accordance with the contamination of surface water. national standards, unless more stringent requirements are specified A third potential . impact on surface (e.g., corrosive materials require water could harm marine life. If a provisions for spill containment). An submerged CO2 . pipeline leaks, the operator must obtain a permit from the water around it becomes acidic. The Fire Department to store these resulting damage to wildlife depends on substances on-site. Thus, the the amount of gas released, the body of Department is aware of the nature and water receiving the gas and the species location of the chemicals, and how they inhabiting the affected area. There are are stored, before an accident occurs. no CO2 pipelines in Huntington Beach In the event of a spill, the Fire at this time. Department sends emergency equipment to the site to minimize Water Consumption: Perhaps the most damage and injuries.17 important water impact related to FOR activities is fresh water consumption. Other agencies concerned with the use With the exception of some miscible of hazardous materials are: the gas techniques, all of the FOR methods California Occupational Safety and discussed above use water as an Health Administration, which protects injection fluid. Also, some of the worker safety and requires measures processes are incompatible with brines such as labeling the materials, often found in oil formations, and providing proper training and equipment require a freshwater preflush to reduce to handle them, and emergency the salinity of the reservoir water. procedures; the Regional Water Quality This can mean a combined expenditure Control Board and the County of fresh water equal to several tirnes Environmental Management Agency act the core volume of the deposit. The to prevent pollutants from reaching fresh water demands of FOR projects storm drains or surface water, and can will compete with other uses for a require spill plans, diking, or other resource that is scarce in this region, safeguards. and could affect the future growth and development patterns of the area.18 Another possible threat to surface water is posed by leakage of The magnitude of the problem may be wastewater stored in sumps above reduced by using a different process ground. For example, heavy rains could (e.g. miscible gas), recycling injection cause an overflow; some other force water, or developing chemicals that are (e.g. earthquake) could fracture the compatible with formation brines or sea sump itself, releasing the pollutants. water. For example, Chevron's polymer Again, the actual danger involved experiment (Section 3.3) used a depends on the nature of the materials chemical that is brine compatible. At and their concentrations. present, almost all of the water used in waterflood and steam projects in the As discussed in the previous section, City is formation water that has been wastewater disposal on the surface is treated, or recycled injection water. carefully regulated by the Regional Therefore, the impact of oil activities Water Quality Control Board, the in Huntington Beach on local fresh Environmental Management Agency and water supplies has been small. 26 4.3 Land Impacts areas is noise from at earn generators, compressors and new drilling A spill of concentrated chemicals can activities. Drilling noise is temporary, have adverse impacts on the land, but steam generators and compressors affecting the flora and fauna in the are used for the life of the project. spill area. As described in the previous Noise can be abated to some extent by section, several agencies (including the muffling, but workers are likely to need Fire Department, the Regional Water hearing protection. In a field where Quality Control Board, and the there is residential' development near Environmental Management Agency) oil sites, noise could be a major impact regulate the storage and handling of where these techniques are used. these materials to prevent spills and minimize damage after a spill Excessive noise is regulated in the occurs.19 City's noise control ordinance and in the City oil code. The noise control Another major impact on the land is in ordinance provides guidelines for the construction of new pipelines to maximum sound levels permitted near carry on FOR projects. If the pipelines the various land uses. The oil code are carefully placed, the disturbance specifically requires the muffling of should be temporary; in fact, sounds created by oil field equipment. constructing new lines may offer the Overly noisy operations can be declared opportunity to relocate older pipes that a nuisance and shut down until they interfere with the environment. The comply.21 City has adopted policies regarding the environmental effects of new pipeline A second potential aesthetic impact is construction in the coastal zone. The a by-product of steam processes. Coastal Element of the City's General Occasionally, the generators and Plan requires that environmental injectors emit steam plumes which are damage from this construction be held visible at great distances. The to a minimum. Wherever feasible, new condition is aggravated when the .air is pipelines in the coastal zone must be moist and cool (as it often is in coastal consolidated with those already in areas). However, steps can be taken to place.20 reduce the amount of steam released and make steam emissions disperse The most significant impact on the land quickly. will be the effects of FOR on land use options. If FOR is successful in pilot The oil code requires landscaping and programs, it may be applied to areas of improvement of oil field appearance, the field that would be abandoned but does not specifically address steam without the new technologies. This plumes. It may be desirable to regulate means that areas currently expected to steam emissions in certain areas of the recycle into other uses may remain in City (e.g., within a specified distance oil production for many more years. On of residential or commercial uses). the other hand, if FOR is not successfully applied in Huntington Another visual impact is possible if the Beach, areas of the field that have been platforms off the coast of Huntington waterflooded will recycle quickly. Beach are expanded to accomodate Long range land use planning should FOR equipment. A platform extension account for the impact that FOR will constructed earlier this year was added have on land use decisions. to the seaward side, to minimize its impact on the view from the shore. 4.4 Aesthetic Impacts The effect of future expansion (should it take place) will depend on its size Probably the most serious aesthetic and location. impact from FOR projects in inhabited 27 5.0 Conclusions and Recommendations Significant quantities of oil remain in As discussed in Section 4.4, steam the ground after conventional recovery projects will emit plumes of water methods (primary and secondary vapor. The visual impact of these production) have been applied. emissions is a potential problem, Enhanced oil recovery technologies can especially when they occur near recover some of this residual oil, and residential and commercial areas. It is make these remaining deposits an not possible to completely eliminate important source of domestic steam emissions, but there are petroleum production. As oil prices techniques that encourage the steam to rise, FOR processes become more disperse quickly. The adverse effects economically feasible and are more can be minimized by oil code likely to be employed. amendments specifying steam plume dispersion standards and mitigation Several FOR methods are being tried in techniques. The City should work with Huntington Beach, including steam the oil companies and the Division of flood, steam soak, polymer flood, Oil and Gas to formulate suitable caustic flood and CO2 soak (see amendments to the oil code which Section 3.0). All of these processes address steam plumes near commercial have impacts on the quality of life in and residential areas. the City that should be mitigated as much as possible. There are several ways to control steam plumes, and the oil code need not Current State, county and local specify the method of abatement. The regulations appear adequate to protect companies can then choose the the community (see Section 4.0). The emissions control technique that is City recently updated its oil code to most efficient and best suited to their explicitly include FOR projects among operations. the oil facilities covered by the code. Additional local ordinances addressing The most important remaining policy FOR impacts are unnecessary, except issues presented by FOR in Huntington in the case of visible steam plumes. Beach involve land use options and 29 planning. Areas of the Aa that were The City-caf5 control land uses in these previously thought to be near the end of areas to preserve access until FOR is their productive lives may, if FOR is applied or until it is clear that these successfully applied, continue producing methods are not practical. For specific. for years to come. If FOR is not strategies to achieve this goal, see applicable in Huntington Beach, many Report #1 of this series, "Preserving oil parcels will recycle (especially those Surface Access to Underground Oil which have already been Reserves in Developed Areas." waterflooded). The success of FOR will affect land use decisions in many parts 5.2 Compatability of Uses of the City. This is particularly important because land in Huntington Local government has an obligation to Beach is valuable, housing is scarce, protect the segments of the community and most of the remaining vacant land that are located near oil operations, in Huntington Beach is in older oil both now and in the future. Thus, the fields. second key policy issue is to insure the long-range compatability of oil and 5.1 Preserving Access adjacent uses. The City benefits from the revenues Successful FOR programs will extend generated by oil production, as well as the productive life of the field, and it is from the commerce and employment oil crucial that the negative impacts of operations bring here (see Report #2 of these programs be mitigated.* The this series, "Fiscal Impacts of Oil mitigation measures that are Operations in Huntington Beach"). appropriate will depend on the FOR There are greater-than-local benefits method employed, the uses around the from domestic oil production as well, site, and their likely interaction effects such as reducing the country's over time. For example, oil operations dependence on foreign oil supplies. that remain in areas designated for Thus, the City is interested in future oil residential uses will require different production. However, land is valuable visual improvements and more noise for other uses, and oil fields may be abatement than oil in industrial areas. covered over before FOR can be used The principle task of planning efforts to recover this resource. One area of will be to anticipate the needs of concern for.policy-makers, therefore, is specific areas of the city, so that the the preservation of surface areas for necessary actions can be taken to future FOR projects that are carried protect the welfare of the community. out in ways compatible with other uses developed near them. If FOR is impractical here, some areas of the City will recycle to new uses. Local governments, which traditionally This will generate a different set of control land use, can take steps to needs that planning efforts will have to preserve land for future oil extraction. address. For instance, rapid recycling This is especially important in areas where significant quantities of oil still exist and secondary recovery or other FOR techniques have not been tried, * Some FOR projects will r_onsolidatr; and where new development on the oil wells and tanks, and significantly field is so extensive that FOR may soon reduce some of the negative impacts be precluded. associated with onshore oil activities. 30 of oil lands may present the voluntarily complete a questionnaire or City with opportunties to encourage form that would provide an annual planned developments. Planned update on FOR and consolidation developments are advantageous, activities. This procedure would because they use land and energy formalize existing practices and, efficiently, and they foster the orderly considering the high degree of integration of uses. cooperation typical in these matters, no new regulations should be necessary. 5.3 Information Needs Huntington Beach has recognized the The City needs information on FOR in benefits (both local and Huntington Beach to plan for future greater-than-local) derived from oil access to oil reserves and the future production here. Accordingly, while compatibility of uses. The City should demanding that oil extraction be maintain an ongoing effort to conducted in a responsible way, the determine 1) whether further FOR City has accommodated oil. Given the programs are likely to occur in FOR potential in this field, the City Huntington Beach, 2) where these can adopt policies that allow both the programs would be located, and 3) utilization of a valuable energy which technologies might be employed resource, and an improved quality of in the projects. At this time, it appears life in Huntington Beach. that the best way to collect this important data on an ongoing basis is to request that the oil companies 31 NOTES �`• 1. See Herbeck, E. F., R: C. Heintz, and J. R. Hastings, "Fundamentals of Tertiary Oil Recovery. Part 1: Why Tertiary Recovery?" Petroleum Engineer, January, 1976, pp. 33-46; Office of Technology Assessment, "Enhanced Oil Recovery Potential in the United States." January, 1976, pp. 1-78. 2. See Herbeck, et. al., "Fundamentals of Tertiary Oil Recovery. Part 6: Micellar Solution Flooding." Petroleum Engineer, June, 1976 pp. 44-56; Herbeck, at. al., "Fundamentals of Tertiary Oil Recovery. Part 7: Polymer Flooding." Petroleum Engineer, July, 1976 pp. 48-59; U.S. Environmental Protection Agency Office of Planning and Evaluation, "Potential Environmental Consequences of Tertiary Oil Recovery." July, 1976, pp. 16-42; Office of Technology Assessment, op. cit., p. 31; National Petroleum Council, "Enchanced Oil Recovery." December, 1976, pp. 16-17 and 95-140. 3. See Office of Technology Assessment, op. cit. p. 31; National Petroleum Council, op. cit. pp. 16-17 and 95-140. 4. See Herbeck, at. al. "Fundamentals of Tertiary Oil Recovery. Part2: LPG Miscible Slug Process." Petroleum Engineer, February, 1976, pp 58-66; Office of Technology Assessment, op. cit. pp. 29-30. 5. See Herbeck, at. al. op. cit. Petroleum Enqineer, February, 1976, pp. 58-66; Herbeck, et. al., "Fundamentals of Tertiary Oil Recovery. Part 3: Enriched Gas Miscible Process." Petroleum Enqineer, March, 1976, pp. 84-87. 6. See Herbeck, et. al., "Fundamentals of Tertiary Oil Recovery. Part 5: Carbon Dioxide Miscible Process." Petroleum Engineer, May, 1976, pp. 114-119; U.S. Environmental Protection Agency Office of Planning and Evaluation, op. cit. pp. 54-56; National Petroleum Council, op. cit. pp. 13-16 and 141-168. 7. See Herbeck, et. al, "Fundamentals of Tertiary Oil Recovery. Part 8: Thermal Recovery by Hot Fluid Injection." Petroleum Engineer, August, 1976, pp. 24-34; U S. Environmental Protection Agency Office of Planning and Evaluation, op. cit. pp. 43-53; Office of Technology Assessment, cit., pp. 27-28; National Petroleum Council, op. cit., pp. 12-13 and 169-203. B. See U.S. Environmental Protection Agency Office of Planning and Evaluation, op. cit. pp. 6 and 163-199; Office of Technology Assessment, op• cit., pp. 94-97; National Petroleum Council, op. cit., p. 68. 9. See the South Coast Air Quality Management District Rules and Regulations, particularly Regulations 11, IV, IX, X111. 32 10. See National Petroleum Council, op. cit., pp. 13-16 and 141-168; Office of Technology Assessment, op. cit., pp. 103-1114. 11. Dosch, Murry W. and Susan F. Hodgson, "Drilling and Operating Oil, Gas and Geothermal Wells in an H2S Environment," California Division of Oil and Gas, 1981. 12. See U.S. Environmental Protection Agency Office of Planning and Evaluation, op. cit. pp. 4-5, 33-35, 89-93, and 133-163; Office of Technology Assessment, op. cit., pp. 100-105; National Petroleum Council, op. cit. pp. 67-68. 13. See the Huntington Beach Municipal Code, Chapter 14.24, and Chapter 15.12.050. 14. See Office of Technology Assessment, op. cit., pp. 98-99. 15. See "Environmental Quality Act," California Public Resources Code, section 21100; "California Laws for the Conservation of Oil and Gas," Public Resources Code sections 3000-3787; California Administrative Code, Title 14, "Natural Resources," sections 1710-17B0. 16. See U.S. Environmental Protection Agency Office of Planning and Evaluation, op. cit. pp. 4-5, 33-35, 89-93, and 133-163; Office of Technology Assessment, op. cit., pp. 98-99; National Petroleum Council, op. cit., pp. 67-68 and 107. 17. See Uniform Fire Code sections 4.101-4.107 and 80.101-80.112; U.S. Environmental Protection Agency, op. cit., pp. 96-132. 18. See U.S. Environmental Protection Agency, op. cit. pp. 4-5, 33-35, 89-93, and 133-163; Office of Technology ' Assessment, op. cit., pp. 100-105; National Petroleum Council, op. cit. pp. 16-17 and 95-140. 19. See Office of Technology Assessment, op. cit., p. 180. 20. See City of Huntington Beach, "Coastal Element, Huntington Beach General Plan," August, 1980, p.p. 145-151. 21. See Huntington Beach Municipal Code, Chapter 8.40 and Chapters 15.20.220-15.20.240; Office of Technology Assessment, op. cit.> pp. 103-104. 33 BIBLIOGRAPHY "Coastal Element, Huntington Beach General Plan", City of Huntington Beach, p. 145-151, August, 1980. "Drilling and Operating Oil, Gas and Geothermal Wells in an H2S Environment", Murry W. Dosch and Susan F. Hodgson, California Division of Oil and Gas", 1981. "Enhanced Oil Recovery", National Petroleum Council, p. 16-17 and 95-140, December, 1976. "Enhanced Oil Recovery Potential in the United States", Office of Technology Assessment, January, 1976, p. 1-78. "Fundamentals of Tertiary Oil Recovery", Parts 1-8, E. F. Herbeck and J. R. Hastings, Petroleum Engineer, January-August, 1976. "Potential Environmental Consequences of Tertiary Oil Recovery", Environmental Protection Agency Office of Planning and Evaluation, p. 16-42, July, 1976. LAND USE PLANNING IN URBAN OIL-PRODUCING AREAS Proceedings of the Workshop Held on February 25, 1982 in Huntington Beach, California City of Huntington Beach,Department of Development Services, Planning Division State of California,Department of Conservation,Division of Oil and Gas 1983 Sacramento d SUMMARY This workshop on land Use Planning in Urban Oil. Producing Areas, co-sponsored by the California Divi- sion of Oil and Gas and the City of Huntington Beach, was held in Huntington Beach on February 25, 1982. The issues addressed by the workshop included the in- creasing encroachment of urban development into oil- field areas, the importance of preserving access to urban oil fields, the advantages to be realized from oil- field unitization and the consolidation of surface opera- tions. It was recognized that urban oil production poses unique land use issues, but that careful planning can in- crease land use compatibility and help ensure that adverse impacts are mitigated to the greatest degree possible. The workshop brought together people from throughout the State who are interested in developing better land use planning and regulatory practices for urban oil-production areas. iii FINDINGS AND RECOMMENDATIONS Preserving Surface Access to Petroleum Owners of surface land areasdesignated as"oil islands" Resources should not have to bear unreasonable costs or hard- ships as a result of the planning or regulatory process. FINDINGS: Where the surface landowner has no financial interest The escalation of urban encroachment into oil fields is in the mineral resource,some incentive, possibly in the form of a fractional interest in the oil produced or a occurring not only in larger metropolitan areas but in transfer of development rights by local government, some rural and suburban communities as well. It was might be provided. generally agreed that local government planning departments have a principal role in determining how access will be retained and preserved through develop- ment of land use policies. Consolidation of Oilfield Operations It was also apparent that where subsurface mineral FINDINGS: rights are severed from surface ownership, the surface owner, unless receiving some benefit, has little incen- Consolidating surface operations frees land areas for tive to cooperate with either the oil operator or local other uses, and increases compatibility between oil government planners to preserve access. operations and other urban land uses. At the present time, neither State nor local laws ade- Older oil fields have become increasingly important quately address the issue of preserving surface access candidates for some form of enhanced recovery, which to the subsurface petroleum resource. may extend the life of the field considerably.Consolida- tion of new operations in older fields would allow con- RECOMMENDATIONS: tinued production of the field, and also provide local government with assurance that the oil activities will be Oil fields within areas of urban encroachment should be more compatible with the surrounding area. examined geologically to determine their suitability and potential for consolidating surface operations. RECOMMENDATION: Geologic studies, as well as planning considerations, Where oilfield conditions permit, consolidation of sur- should be taken into account in determining the sur- face operations should be encouraged by local govern- face location of areas to be preserved for access to the menu. subsurface petroleum resource. In planning for oilfield areas,local governments should employ land use regulations to preserve surface access Compulsory Unitization to the subsurface resource. Among the planning and regulatory techniques discussed were conditional use FINDINGS: permits, transfer of development rights, zoning, and general plan designations. If possible, these measures The mineral rights of oil fields are generally divided should be undertaken before urbanization of an oil field among several owners.Consolidation of surface opera- takes place. tions is dependent upon combining the individually owned portions of the subsurface oil-producing reser- There Is a need for legislation that would require local voir into one unit under one operator. governments to take petroleum resources and access preservation Into consideration when planning for land Unitization may be voluntary or compulsory; however, use in their jurisdictional areas.The State,without man- the State's compulsory unitization law is unwieldy and dating what methods local governments must use, provides so many disincentives that is has never been should enact legislation to ensure that this important used to unitize an oil field and is not an effective tool to issue is addressed by local governments. induce unitization. v RECOMMENDATIONS: Compatibility 01, �rations Where oilfield surface operations cannot remain FINDINGS: separated from other land uses, provision should be made by local and State regulatory agencies to en- In most cases, modern drilling techniques and produc- courage unitization of the mineral leases involved and ing methods now enable operators to drill wells and the consolidation of surface operations. produce oil in ways that can be compatible with other land uses and the environment. Consolidation of older, existing primary operations may not be justified economically. Generally, consoli- Noise, odors, and vibration from oil operations can dation of secondary or enhanced recovery operations is usually be mitigated to a large degree, and are gener- warranted and feasible; therefore, such operations ally not objectionable under most circumstances. should be encouraged as vehicles to eventual consoli- dation of all surface operations throughout the oil field. Where voluntary unitization has failed, the State's com- Local government should review any local codes or pulsory.unitization law may be invoked: however, regulations pertaining to oil operations, or conditions because it has proved to be virtually unusable in its pre- that have been imposed on such operations in the past, to sent form, that portion of the Public Resources Code ensure that these statutes do not unreasonably preclude should be amended to correct the deficiencies of the preclude or restrict oil operations that may be con- law as soon as possible. An effective State unitization ducted with new or improved technology and that they law would enable local government to develop land use reflect the best practical impact mitigation measures. guidelines that would permit continued development Consideration should be given to developing perform- and recovery of the petroleum resource through ance zoning standards for oil operations in areas where enhanced recovery methods. compatibility is a significant issue. vi ACKNOWLEDGMENTS Jan Denton Workshop Coordinators Director,California Department of Conservation H.Diane Border M.G.Mefferd Planner,City of Huntington Beach State Oil and Gas Supervisor, California Division of Ed Brannon Oil and Gas Energy and Mineral Resources Engineer, Ruth Finley California Division of Oil and Gas Mayor,City of Huntington Beach Charles W.Thompson Proceedings Editors City Administrator,City of Huntington Beach H.Diane Border James W. Palin City of Huntington Beach Director, Development Services, City of Huntington Michael J.Multari Beach City of Huntington Beach Project Directors ER Wilkinson California Division of Oil and Gas Michael J.Multari Associate Planner,City of Huntington Beach Special Assistance E.R.Wilkinson Alan V.Hager Special Representative,California Division of Oil Deputy Attorney General, and Gas California Department of Justice vii TABLE OF CONTENTS PAGE PREFACE .............................................................. ................................................................ xi INTRODUCTORY REMARKS.............................................................. 1 OIL PRODUCTION IN URBAN ENVIRONMENTS, E.R. Wilkinson ........................................................ 5 PLANNING GOALS AND APPROACHES, Michael Multari...................................................... .......... 15 CASE STUDIES #1 OIL FACILITIES IN A DEVELOPEDAREA .............................................................................................. 17 #2 PLANNING FOR OIL AREAS ON THEURBAN EDGE................................................................................................. 29 #3 RELOCATING INAPPROPRIATELY SITED OIL . FACILITIES...................................................................................................................... 37 WORKSHOP PARTICIPANTS............................................................. 41 SELECTED REFERENCES ................................................................... 43 ix PREFACE A workshop on Land Use Planning in Urban Oil- ban areas prompted the Division of Oil and Gas and the Producing Areas, co-sponsored by the City of Hunt- City of Huntington Beach to co-sponsor this workshop, ington Beach and the California Department of Conser- which brought together people from throughout the vation, Division of Oil and Gas, was held in Huntington State to begin to develop better land use planning and Beach on February 25, 1982.The principal goals of the regulatory practices for urban oil production areas workshop were: 1) to recognize present problems based on current technology and the best available associated with oil production in urban areas; and 2)to information. discuss the importance of surface access preservation in oil fields and how oil production activities can occur The City of Huntington Beach has long been an area of more compatibly with urban activities through unitiz- significant oil production. It was also among the fastest ation and consolidation. growing cities in the country during the 1960's and 1970's. This rapid growth brought new houses and As the City of Huntington Beach was working with the commerce into once-open oil fields. Urban develop- Division of Oil and Gas to solve these problems in a ment of this type not only creates land use compatibility practical manner, it became apparent that other problems, but also covers so much of the surface of jurisdictions in the State were having similar ex- some oil fields that their potential for future oil extrac- periences with urban encroachment into oil fields. tion may be jeopardized. Growing concern over the future of oil production in ur- xi INTRODUCTORY REMARKS James W. Palin, Director, Department of constraints these technologies put on the production Development Services, City o Huntington process, as well as some of the opportunities they Beach: afford. Next,we will discuss case studies of situations in "Several factors have contributed to the urgency of Huntington Beach which we think will illustrate some of planning now for continued oil production in urban the problems—and some of the approaches to solving areas:the rising price of oil and the development of new those problems— that we have experienced here:' extraction technologies have made the residual oil Ruth Finley, Mayor, Huntington Beach found in oil Fields underlying many urban areas an important source for future production of domestic "I want to thank you for coming to this workshop and petroleum products. Consequently, we are seeing the for joining with us to discuss these important planning life of existing Fields lengthening, and some areas that issues. The Department of Conservation has co- were once considered to be near depletion are now sponsored this workshop with our City and has being eyed as long term producers. In several places provided both technical and financial support in there is a new interest in drilling and production. helping to make this session possible. We appreciate "At the same time,the value of land—especially in and the State's interest in these planning problems and its near urban areas— has increased too, in a large part in support in working with us toward acceptable solutions. response to housing demands. In many places,older oil I hope that today will provide a much needed Fields constitute the only remaining open space within opportunity for State and local planners to share their an urban area. The urban and suburban uses are experiences,and to develop strategies for effective land expanding into oil producing areas. This results in use planning in urban oil areas. situations where oil facilities are in proximity to other "We in Huntington Beach are clearly interested in land uses, especially residential ones, which in turn can use planning for oil areas. The City's early history was produce problems and conflicts for both uses. Ways to tied to oilfield development. The field here currently reduce these conflicts while accommodating mixed use ranks seventh in the state in annual oil production and and protection of the valuable natural resource are the is the third largest California field in terms of concerns of this workshop:' cumulative production,having recently topped the one billion barrel mark. During much of this time, the oil Michael Multari, Associate Planner, City of wells were in open and undeveloped areas and there Huntington Beach: were few conflicts between oil and urban uses.However, during the 1960's and 70's, Huntington Beach was "The following is a summary of the format for today's among the fastest growing cities in the United States workshop. First of all, I want to emphasize that this is a and now has a population of over 170,000.The fact that workshop. We who work on oil activities in Huntington such a large and quickly growing community Beach and the people with the Division of Oil and Gas developed in the midst of widespread oil operations has do not presume to have the definitive answers for these forced us to deal with many of the problems that you kinds of problems. Rather, we have tried to create an will be discussing today, and some of our experiences, opportunity for people to talk about and share their both good and bad, will be used as case studies in experiences. We hope to get insights from each other's today's session. I hope that the dialogue afforded by work on how to solve problems related to oil this workshop will help all of us in developing sound production in urban contexts. land use planning and regulatory approaches for better "Today's agenda calls for some opening remarks by accommodating oil and other urban activities:' Ruth Finley, our Mayor, and then some introductory comments by Jan Denton,the Director of the California Jan Denton, Director, California Department Department of Conservation,and by Marty Mefferd who of Conservation' is the State Oil and Gas Supervisor. Then, 'Wilky' Wilkinson from the Division of Oil and Gas is going to "As community planners and participants in today's discuss some of the technologies related to oil workshop, I hope you realize the importance of the production in an urban context and some of the individual contributions you make to the public. As 1 1M ' - South sell Las, Sag L,sr $65 f 111 3-2MMbbl $6 Yictnlr AIMMbhl Los 4 f62 s,rtNe 2.3M bl • g� , S12 / $53 ��.,16 �MMbbl on SUlion 2.OMM CsSs6 _f 12 $12 1MM661 f101 1.7M b1 S31MM6blI Lo, Angela owntown 3.]MMbbl Inpr od $93r— ).1MMbb1 $21 NSMMbbI f $3 Angrlet 1138 e aMMbbl `-� f240 $10 1 S3 wlwlie. f138 IIa3a Del ■erg ` 4111, E.9MMbh1 /MMGEI lM!Meb ` _ f155 ••/S.1MMI61 �rmrebbi I S,gMMbp ems•(" 13i,1eM S12 Sant,r,sp..,gt ( .spiMeel $453 — Wdl To a eMMGe lofe<r,M • )wea�l•Ma / lb.gMMbel 1.2 u Srd do f116 z9MMepl /f6 IM $8 yy :.)MMbbl • 26.1MMbbl .3MMbb /L,.rnd"11 a. —South golrc„ns �� \ftpeunu $3 $10 ` -I [,,1 (.tote $4 .1MM6� AMMb $181t r� .1MMpbl �7 '.ONMbpI ,guen n S259�r • L.n¢ gr,<b ` f ol., $480� $BntMeel 9.pMMppl %f 1,2Q6 \ 39 1J.1MMbb1 II.i MMbbl 1 YIMI'hi r orranlr —lollgg guc1� npnl $496 511 1,IMMIi 1b . Mbb ��'Im'"KID'^ Sul beech $11.013 f IM \ $11,01 1MM66 Hunenglon gr,rh m 2,246 HIS., ont ,pHIS., g12MMbbl \33.OMMhbI DOLLAR AMOUNTS IN MILLIONS W al Hrwp.n BARREL AMOUNTS IN MILLIONS ( RESERVES ) $483 17 9MMbbl as of 12/31/81 �\ Figure 1. Oil fields in the Los Angeles Orange County Basin. planners, you play a very significant role in guiding the "The Department of Conservation,through our Division State's locally elected officials towards conscientious of Oil and Gas, is mandated by the Public Resources decisions about local land use. What we all share as public Code to prevent damage to and waste of our employees, regardless of whether we work at the Federal, underground oil resources, and to encourage the wise State or local level, is the responsibility to serve what we development of these resources. Thus we are sincerely believe to be the public interest.Sometimes these concerned with the competition between urban growth interests conflict, and we must seek creative solutions in and oil production. But local government has the order to accommodate the variety of needs, the public ultimate land use authority, and we must look to city wishes to have addressed.We are here today to seek a and county planning departments to provide for balance between the need to retain access to our petroleum continued and compatible oilfield operations. Recent resources and the need to plan for housing and other experience, however, has demonstrated that this does community development projects. not have to be a win-lose issue. An excellent model is the experience of the City of Huntington Beach, which 'The old axiom, 'oil is where you find it', has had contains valuable oil resources beneath a considerable particularly significant implications for California. Our area of its boundaries. As elsewhere, there is increasing State's oil production ranks fourth highest among the demand for surface uses other than oil development. 50 states, yet this production is obtained from less than And many of the problems related to urban oil one half of one percent of the lands in California. Of production here are similar to those in other local importance to all of us today is that a large portion of jurisdictions where oil is being produced. this production is occurring from reservoirs beneath our cities. Growing demand for residential and "The City of Huntington Beach has shown that these commercial development has come into conflict with competing land use demands are not necessarily retaining adequate surface access to our underground incompatible. Subsurface petroleum resources can be oil resources.This conflict threatens a resource that not recovered safely while accommodating traditional only represents our principal source of energy, but also surface uses. Huntington Beach's experience has provides a considerable source of revenue to both State provided some valuable lessons. The City's efforts have and local governments. not only raised interesting questions, but produced 2 CITY OF HUNTING TON BEACH, CALIFORNIA DIVISION OF OIL AND GAS creative solutions as well. The Department of and administrators. But as urban development Conservation and the City of Huntington Beach hope .continues and available open space decreases, the that today's workshop can provide some guidance and pressures for that space become more and more assistance to enable you to better cope with the intense, a fact of which I am sure you are all aware. conflicts between urban demands and efficient recovery However, it is important that all of us—planners, of our oil and gas resources:' administrators and regulators alike—be aware of the existence of our valuable resources and of the fact that M.G. Mefferd, State Oil and Gas Supervisor, there is a significant amount of oil left in the ground to California Division of Oil and Gas: be recovered. "Petroleum is the principal source of energy for both "One of the major responsibilities of the Division of Oil the State and the Nation. In 1980, oil supplied both and Gas is to make reserve estimates for all of the fields percent of California's total energy. Daily demand for n California. By a 'reserve; I mean that amount of oil oil in California is approximately 1.84 million barrels,of that we expect to be recovered under current economic which a little over 1 million barrels is produced of the and technological conditions. As of December 31, State. So, California's domestic oil production makes a Californiaestimated the recoverable reserve for significant contribution to our total energy supply. alifoia price be , s billion barrels. If you were to give this oil a price of, say, $25 abarrel—putting aside for a "The Los Angeles Basin, besides being a huge moment the cost associated with getting it out of the metropolitan area, is also one of California's major ground—it would represent a resource valued at petroleum producing provinces. Oil production began approximately $130 billion. in the downtown Los Angeles area in 1893, almost 90 "To focus in on an urban area—the Los Angeles Basin years ago, and since that time oil fields have been has a recoverable reserve of 854 million barrels. Figure discovered throughout the Basin. Today,there are over 1 shows the productive limits of many of the fields in 50 active fields in the greater Los Angeles area. These the Basin along with their estimated reserves. I think fields contain 8,300 wells that produced in excess of 83 you will find this figure interesting, for it shows that the million barrels of oil in That represents about 25 magnitude and the value of the resource is significant. percent of the State's tottalal production. But, more importantly, I think it highlights the need for "Now the mere fact that all of this is taking place in a all of us to be aware of petroleum's potential and its huge urban complex is in itself a credit to local planners value in the State's urban areas:' LAND USE PLANNING IN URBAN OIL PRODUCING AREAS 3 OIL PRODUCTION IN URBAN ENVIRONMENTS E.R. Wilkinson, California Division of Oil "Figure 2 shows a cutaway cross section of a geological and Gas: feature called an 'anticline: An anticline is one of several different types of geologic traps.As oil migrates "Today, I am going to talk about petroleum geology, into a sandstone bed, it will tend to separate from the basic engineering principles and their application as saltwater which is also present in the sandstone, and related to oil, as well as how oil occurs, and how it is 'float' upward. If there is an impervious layer of rock removed from the earth. I will also discuss oil sites that over the reservoir, the oil will probably be dispersed have been designed to blend with the surrounding throughout a porous and permeable sandstone bed,but community,and, finally,I'll talk about one of the project if a geologic trap is formed, oil will collect in one areas here in Huntington Beach. portion of the bed and form a pool. Thus, the three "You may ask: 'Why do we have oil in our community?' basic requirements for entrapment are:(1)a source bed There are three conditions necessary to create an oil for the oil; (2) a granular rock in which the oil can field: (1) a source bed, (2) a reservoir bed, and (3) a collect and move; and(3) a trap. geologic trap. The currently accepted theory among "Figure 3 depicts an enlargement of the reservoir rock geologists is that oil originates in a shale stratum, the showing individual grains of sand. This rock satisfies. source bed, and migrates out of the shale through the requirement for a reservoir rock because there are capillary action into a reservoir which, in California, is spaces between the grains where oil can accumulate. generally a sandstone. These beds originated as flat This property is called 'porosity'. To obtain oil or gas sedimentary deposits on a sea floor. Layers of very fine from a reservoir, the rock must have both porosity and sediment became shales, and alternated with coarser permeability. granular sediments, which became sandstones. This is a fortunate series of sediments because the shales not "Figure 3 also illustrates a typical situation where gas is only provide the source beds for the oil, but also serve present with oil that overlies salt water. The pumping as an impervious cap or seal which is necessary for the unit shown here is the most common mechanical entrapment of oil in the sandstone reservoir. device used for removing oil from the reservoir. Each LI Si VALCVEL I \ �„•. _ _ _ ____ _ i=�n,. ..tiii I?ii Ji:Yf `a�'Yl�`�i 6 .Q'r'i"t ). �Y; r U;v i�'F-r h�ri�, e`v`` r ♦i K�Yy\� .,�+' ' t i` � .J -�*•fttF � rll C'dgl'�„)t ?� tH a? . ] 1%'V '•IVY n�F \ �••'! -. _ L ♦\ 71)',� Z x -- 1 4 _ li r 1LY.r Y •. Y _ .. _ �{.L Y� '•"' tlt~- $ALl YIPIER: _ _I 1 I $Rll Wnl[R Figure 2. Cross-sectional view of an anticline with an oil- Figure 3. Cross-sectional view of an anticlinal geologic saturated reservoir. structure with magnified view of the sandstone reservoir. Note various types of producing methods. (AND USE PLANNING IN URBAN OIL-PRODUCING AREAS 5 dissolved gas cap water gas pressure A - _ A A // / l r,,1.� 1 ' +<y•'w /' f s ' ltVsa 4•vVY ivy s ' �fK Yyy - ii. A. OIL RESERVOIR y+ )rt' i_..1 .'Irrh N M a� } r1 ,��'JA T•'1 G`"�f A st•4 'Y sr.tip'4>i ..y t yj.. x 'c�� �t�r 1C ♦'r y;�rrJ� C r yK�++ � 't`ic y M a. '�>4Y . y i1.�' r ti V .'+s V-. ,OIL R�yE'�S'ERVOIR } �ryr 'K ,,;,_y.L,•� � ,� v ;,;,. - '' z' Tt�*yy'• sA}a' 7'J yt nary OIL RESERVOIR y"'Infi'tir l.�nvtyiy!t . 1 Sf'Y lfl i` r� 4,^f} :s. ; . i rrrj _�:•`.�` �' 1`laffy3�.yt'\^.Y . . A i �'! •.WATER �i� --� ''::N/A TER .'.�:; i Figure 4. Natural forces that move oil through a reservoir to wells. stroke of the pump literally lifts a few feet of oil up the is similar to the high pressure solution gas situation. pipe. In some instances, where the natural pressure in When reservoir pressure is lowered, the gas cap the reservoir is high enough, pumps are not necessary. expands and forces the oil into and up the well. Instead, a completion head called a 'Christmas Tree' is ••In California,the Division of Oil and Gas is required to placed on the top of the well. The fluids simply now to monitor the amount of gas and oil produced from each the surface as a result of the natural pressure within the well to ensure that oil wells are not produced with too reservoir. high a ratio of gas to oil. In other words, we don't "Even if the wells will not flow by natural pressure, want the pressure reduced in that gas cap too surface pumping units are not always necessary. quickly because such action reduces the natural driving Sometimes down-hole pumps are used which are force in the reservoir,which in turn reduces the amount driven by electricity or hydraulic power. This is more of oil that might ultimately be recovered from that expensive, but if the economics justify it, high volumes reservoir. If anything, we prefer that operators of oil can be pumped while maintaining a relatively low repressure the gas cap with produced gas and maintain surface profile. the drive in the reservoir. "What makes the oil in the reservoir move into the "Finally, Figure 4 illustrates 'water drive, which is a well? Figure 4 shows the three basic reservoir 'drives. relatively common drive mechanism in many fields, The first one is the 'solution gas drive' where gas is especially older ones.There are many oil fields that do dissolved in the oil under great pressure, perhaps not have enough gas to create a gas drive situation. several thousand pounds per square inch. As soon as a However, the natural pressure of the underlying salt well penetrates the sandstone reservoir, the pressure is water pushes against the oil and moves it toward the lowered in the area immediately around the well. This well,which is the area of low pressure. Formation water provides an area of relief from the extremely high pressure is usually the result of the weight of overlying subsurface pressure, and the gas begins to expand, rocks.However, it could also be caused by a hydrostatic driving the oil into and up the well. This is known as a change in pressure, which may occur as a result of 'flowing well'. gravity in instances where the reservoir beds, or strata, slope downward from a higher elevation. The pressure "The second method of moving oil to the well occurs that results from water in the reservoir rocks flowing when gas has already separated from the oil and a 'gas 'downslope' in turn applies pressure to the formation cap' has formed above the oil in the reservoir (Fig. 4). water underlying the oil and causes it to move to the Gas caps help push oil out of the reservoir in a way that low pressure area in the well. 6 CITY 0F HUNTINGTON BEACH: CALIFORNIA DIVISION OF OIL AND GAS OIL PRODUCER GAS INJECTOR WATER INJECTOR px PRODUCER F A y SHALE GAS' GASH'' .: '../ / / LLx" YI�;,;•-:)I)r.4,y. V ''.1,.�L� OIL /// uJr 't�: l;_Jk.. SHALE i U��_ `,`'`..•I ///. ,I E � �� r- _,' •li,• �- `,/// Figure 5. Injecting gas into an oil reservoir to maintain Figure 6. Injecting water into a reservoir to enhance the reservoir pressure and increase the production of oil. natural water drive and improve the recovery of oil. 'These, then, are the three natural phenomena that r '' move oil into a well.Anything wecan do to duplicate or S� enhance these systems will increase the life of the well and the field. One such method is a pressure maintenance operation where gas is injected into the top of the zone, duplicating a natural gas cap condition and helping to drive the oil to the well (Fig. 5). California has a long history of gas conservation, established by the legislature many years ago through the Gas Wastage Act.If a field produces gas with the oil, the gas can be separated from the oil and sold.Some of the gas may be used on the lease to operate equipment, or it can be reinjected to increase subsurface pressure. However,State law will not allow an operator to blow or flare gas except during temporary and very special conditions. "Another method of increasing the life of the field is 'water injection'(Fig.6).This is a procedure where large amounts of water are forced into the oil zone under pressure. This process duplicates and, .to varying • e� tw _ degrees, enhances the natural water drive system. 7. Contour lines showing Water injection projects serve several purposes. First, Figure amount and extent of they help an operator get rid of produced water in an land subsidence over the Wilmington oil field. acceptable way. Furthermore, injected water increases pressure in the zone to Flush more,oil out of the tends to be rather viscous.By reducing the viscosity,oil reservoir and into the well.Water injection also reduces flows more easily, making it possible for more oil to the possibility of land subsidence that, under certain move from the reservoir into the well. The industry has circumstances, might be caused by extracting large tried various ways of heating oil in the reservoir to volumes of fluid from the reservoir without reduce its viscosity. replacement. -One type of thermal stimulation is accomplished when "Another form of stimulation for oil fields is achieved oil in the reservoir is ignited by pumping air under high through the use of heat. Much of the oil in California pressure into the reservoir until the oil itself begins to LAND USE PLANNING IN URBAN OIL-PRODUCING AREA5 7 1. CRUDE OIL i. NATURAL GA._ �� 7. NATURAL GAS L1.,­D5 IA4 V A. GAS PLANT PRODUCTS -Iwo C. \ �I � dl•W v.Wlkn B. LEASE CONDENSATE PmY wM Pasl M f1Yr-.�-�� IM I,[i Y,IwwW Imm M M, CM.�d 4,Ivxx.ly+ LEGEND CRUDE DEE ... •NnillRd GAS llO1,V5 — tiAIURAi,GAS — MY GAS — WAIER Figure 8. Oilfield production and processing facility with typical layout and equipment. burn. This method is called 'in situ combustion, a Many prominent scientists, in addition to the Division's procedure that increases the pressure and heats the geologists and engineers, were brought in to find a way zone, thereby lowering viscosity and helping to move to halt the subsidence, which was finally accomplished the oil. As soon as the injection air is shut off, the fire by selectively injecting the producing zones with water goes out. However, this technique sometimes creates and then carefully monitoring the operation. However, mechanical problems and, as a result, is not used before the repress urization program could be extensively. implemented, a problem was encountered. There were "Steam injection is much more common and effective. many different landowners and oil operators, and the Steam is injected under high temperature and high State had to bring all of them into a single operation. pressure down the well. The superheated steam goes This is called 'unitization' or forming a 'unit'. The legal gut into the reservoir in all directions, heating the oil problems of getting the different parties to join this unit and making it flow more easily. In some cases, this and to decide on what their fair share of the produced method has increased production over 300 percent. oil would be became very complicated. However, the This technique is costly though, because the process field was finally unitized using the compulsory requires large amounts of energy to create steam, unitization law set forth in the Subsidence Abatement which is then used to extract another energy source.An Act. The Wilmington unit is the world's largest water engineer has to examine each project closely to ensure Injection program and was probably the world's most that more energy is produced than expended. One difficult operation to unitize, but subsidence has been important point to consider when evaluating steam halted. injection projects from a land use planning perspective Incidental) I should tell you that we have not noted is that high-pressure, high-temperature steam lines y' should be separated from other land uses that might subsidence of the magnitude that occurred at place people in close proximity to these potentially Wilmington in any other oil field in the State, and most hazardous steam lines. fields have no subsidence-at all. I don't want you to think that simply because there is an oil field in your "Land subsidence is a potential problem that might area, subsidence will necessarily occur. One reason occur in areas overlying an oil field. Figure 7 shows the subsidence has not been a problem elsewhere is Wilmington oil field where, over a period of years, the because most operators are injecting water back land slowly subsided until the epicenter finally reached into the reservoirs. Also, rock strata in the Wilmington a depth of almost 30 feet below its original elevation. field include what geologists call'incompetent'bedding You can imagine the problems this caused in the Long or formations. The beds form a relatively low, Beach Harbor area. During high tide,wharves and piers somewhat flexible arch, and do not really support were awash or actually submerged. To mitigate this themselves very well.When fluid was removed from the situation, the State legislature enacted the Subsidence reservoir, compaction occurred, allowing the overlying Abatement Act which is administered by our Division. beds to subside.Fields comprised of strongly arched, 8 CITY OF HUNTINGTON BEACH; CALIFORNIA DIVISION OF OIL AND GAS cts r Wa r. Photo 1.Urban oil pn�tu,-tAA1 vte ui a golf cnurle.!'tote coverea Photo 2. Urban drill site on Long Beads Recreation Park Of well cellars with wellheads below ground le%,el. tours, hidden on three sides by landscaped terrain. firmly bedded strata tend to resist the effects of "Photo b shows one of the four offshore oil islands near compaction and downwarping. Long Beach. This is an example of a large,consolidated "Figure S shows the types of equipment that may be oilfield operation. One island can accommodate as required at an oil production site. This includes not only many as 200 wells and four drilling rigs. All of the wells and pumps, but storage and treatment tanks, as production facilities and processing equipment are on well as equipment to separate the water, oil, and gas. In the island. A great deal has been learned about addition, the water produced in association with the centralized drilling locations from this type of oil must be either injected back into the reservoir or operation. The area is also a good example of multiple transported elsewhere for disposal. Temporary storage land use. In the immediate vicinity, there is a of the oil must be provided unless both oil and pro recreational beach, and a harbor that includes duced gas are transported to a central facility, usually recreational, industrial, and commercial uses,as well as by pipeline. The following photos of existing oil op the oil drilling and producing operations. This, of eration sites in urban areas illustrate how facilities can course' is the result of extensive planning by the City, be concentrated. and also how they can be made to the State,and the oil industry. blend compatibly with their surroundings. "Photo 6 shows one of the latest urban oil sites,which is located in the Torrance area. The site has been graded "Photo 1 is a site on a golf course in West Los Angeles which shows the concentrated nature of a production about h feet below ground level and is surrounded by ffect operation. The wells are drilled six feet apart, and the an earthen berm with a block wall se top.The , thereby is to lower the entire operation several feet, thereby wellheads are below the surface of the ground. This allows the site to be well landscaped and hidden. People on the golf course are generally unaware of the operation. Note the large amount of equipment that can be concentrated into a small area. Photo 2 is a site -r on a City golf course in Long Beach. From three sides the site appears to be a gently sloping hill or landscaped berm, but behind that berm is a well hidden oil operation. Photo 3 shows a different treatment. This is Occidental's site on West Pico Boulevard in West Los Angeles. The structure is not as well designed from a camouflage standpoint as it might have been. partly f because of the exposed guy wires. However, people passing by are totally unaware of the oil operation. This is a very quiet and unobtrusive type of operation. Photo _ 4 is a street view of Chevron's Packard drill site in Los Angeles. Besides being well designed for visual compatibility with the surrounding area, it is virtually -_ soundproof. Even when two workover rigs are Photo 3. OcciduAal Petrolam's urban drill site in Wes Los operating inside the building at the same time. none of Angeles.The single derrick is housed in the tall,building like sruc- the sounds of the operation can be heard outside of the lure. building. LAND USE PLANNING IN URBAN OIL-PRODUCING AREAS 9 providing sound Ling as well as creating an attractively landscar-dbarrier around the site. 'Although it has been demonstrated that oil drilling t and production operations can be conducted in a 1'Y safe and compatible manner, local government must be aware of the potential for problems when other types of surface development are proposed for areas within the I boundaries of oil fields. Until comparatively recent times, oil fields were either in rural areas or, in urban areas, were isolated from other forms of development.However,during the last several years, many urban oil fields have been subjected to intense residential and industrial encroachment. The possibility of placing a permanent =a structure over an abandoned or inadequately abandoned well increases as the density of development increases. "Earlier wells were abandoned to specifications established for oil fields located in rural areas. The Photo 4.Chevron Oil Comparry's drill site in West Los Angeles.The possibilitythat form of urban Packard drill site can accommodate two drilling units at the same any uraneve development would time occur in an oil field was considered highly unlikely. In addition, many wells in our older fields, drilled prior to r= 1915, were not regulated by State law. As a result, t '' � y records of exact well location or mechanical condition may be sketchy or inaccurate. On the other hand, records of wells drilled since 1915 are maintained by our Division, and should provide sufficient information to evaluate the current condition of any well that may be in an area proposed for surface development. "We urgently request that any planning or building permit issuing department contact the nearest district office of the Division of Oil and Gas whenever a land use other than oil or gas operations is proposed within the boundaries of an oil field. Our Division also encourages local government to place well locations on their land use and zoning maps so that permit issuing personnel will be alerted to the presence of a well, or Photo 5. THUMS drilling island 'Grissom is one d four such wells,within a proposed development. islands in Lag Beach Harbor. More than 200 wells have been "Under resent taw, an oil o rator who abandoned a drilled from this site.Landscaping and beautification costs exceed P Pe ed $1.000,000. well under archaic standards cannot be required to reabandon that well unless it is leaking or presents an obvious hazard. However, through the building permit process, local governments can, if recommended by the Division of Oil and Gas, require that a well be reabandoned to the current State standard before any permanent structure is placed over or near it. As an example, the City of Signal Hill works closely with the '. Division to ensure that old wells are plugged to current ' Division standards. When buildings will be placed over a well, a cellar around the wellhead is excavated and gravel is placed in the cellar and covered by an impervious membrane which is then covered by cement. A perforated section of polyvinyl chloride y (P.V.C.) pipe is placed in the gravel to vent any gases that may leak from the well beneath the building to a point outside. Ideally, no building should be constructed over any well. City and county planning Photo 6. Urban drill site in City of Torrance. The location was and building departments must be aware of such situa- designed for simultaneous drilling by two rigs. The site is 15 feet tions, because our Division has no way of knowing below ground level and surrounded by a high landscaped earthen when a building may be placed over a well unless it is berm topped by a wall. brought to our attention. 10 CITY OF HUNTINGTON BEACH; CALIFORNIA DIVISION OF OIL AHD GA5 r i i d �V „4 Street view ofARCO Oil Company sS1 James production Photo B. Interior view of the St- James I. ,;,r,,,,, All site within a residential area in Los Angeles. wellheads are below ground level.and covered. "in addition to proper well abandonment, correct oil feet of dirt over whatever was in the sump. If the oil is sump abandonment is important and of concern to the buried too deeply, the bacteria stop working and State. Today, chances of improper sump abandonment further alteration of the oil is halted. However, if the oil are slight. There was a time. however, when an oilfield can be exposed to oxygen, bacteria will consume it and sump was abandoned by simply throwing two or three clean,nitrogen-rich soil will be left. _ r .v r l � I t,w m r s+ v Fgure 9.Three::, :ir:.u:i .a . r.. :a a.I:rm1i xial dri La.,.gxratb from two centralized ar M sites w iu i n the Huntington Beach project area. The area overlies two productive oil tortes. LAND USE PLANNING IN URBAN OIL PRODUCING AREAS I I "There is an example of good s )abandonment in available at locatid �at will provide access to all the City of Santa Fe Springs. T�te-sump was large— subsurface areas capable of producing oil. In this probably a couple of hundred feet square—and quite project area example, there are two oil zones deep. The contaminated material was excavated, underlying the property. Unfortunately, the upper zone spread out, and dehydrated. After bacteria reduced the is shallow, and one of the problems encountered with oil, the material was put back into the sump and shallow zones is that the areal, or horizontal, reach of compacted to engineering standards. It was an directional drilling from one site is limited. The deeper excellent)ob, and also resulted in restoring the site to a the zone,the greater the distance around a drill site that usable land area. The alternative is to remove the can be reached. In this case, if it were not for that material, take it to a Class I dump site, and bring in shallow zone, access to oil under the entire project area clean fill. However, this is expensive and can be a very could possibly have been preserved with one drilling messy operation if the sump is large. island. As it is, at least two centralized drill sites are "Figure 9 depicts a simplified underground view of an needed to reach all of the oil. The surface locations of area that will be discussed later,in more detail in Case the islands in the project area are flexible to some Study �2. This is a large parcel in central Huntington degree, which allows planners to take other land use Beach, currently the site of scattered oil operations. and planning constraints into consideration. The area will soon be developed for residential use, but "It is absolute) essential that surface access to urban petroleum resource. e. The most logical way to do this is the City wants preserve access to the underlying oil fields be retained. Oil is one of our most valuable to consolidate operations into oil 'islands' from which resources. Other types of development that would be directional drilling can take place. The term 'islands' incompatible with continued oilfield operations should refers to relatively small areas, usually one to five acres, not be allowed to occur within existing oilfield that are screened, landscaped, and buffered from other boundaries. It is essential that the State, local surrounding uses and that are used for consolidating a government, and the oil industry work together to solve large number of wells and related facilities. these problems. With the drilling and producing technology available today, innovative planning by "Before access sites or islands can be established, it is local government, and the cooperation of all parties necessary to study the underlying geology and the oil involved, the production of oil can indeed be continued reservoirs, in particular, so that sites will be made compatibly with other land uses:' DISCUSSION QUESTION: all the high-pressure lines are contained inside a walled What would you say is a safe distance between steam enclosure, residential uses can be safely located nearby. operations and a residential development project? Steam operations can occur safely even in an urban context with proper planning and mitigations. We are COMMENTS: currently working with an oil company on this type of project for downtown Huntington Beach. Jose Osuna, City of Long Beach: The Uniform Fire Code states that a residential structure cannot be built QUESTION: within 100 feet, or a meeting hall or school within 300 feet, of an existing well. These distances are Is steam injection something that is going to be more recommended whether the well is involved with steam common in the future? operations or not. Wilkinson: Steam does not pose the same threat that COMMENTS: fire does, so we look at the safety factor from another Wilkinson: Generally, yes. Unfortunately, however, it viewpoint. Even though steam lines are insulated, they doesn't work for every field. As a rule of thumb, steam are hot and under pressure. There is always the injection works best in a zone that is less than 4,000 possibility that a steam leak could occur, and at those feet deep with a 15 or 20 foot thickness of oil sand and pressures it could be quite dangerous. Therefore, all a gravity of around 14 degrees, although higher gravity access should be controlled. However, a steam oil is now being steamed'with considerable success. generator can be installed so that the steam plant and Steaming works well in places with characteristics like all high-temperature, high-pressure lines are enclosed these. However, because conditions differ in each zone, within a central production site. different methods will have to be applied for different Multarr I'd like to reiterate that point. In cases where an situations. As a result, a variety of enhanced recovery open field exists with steam lines on the surface, other processes will become increasingly popular. kinds of development should, of course, be prohibited As it is now, we're lucky if primary pumping recovers until the lines are deeply buried, enclosed,or fenced. In 30 percent of the oil in place. This means that a very Huntington Beach, the steam operations are large percentage of the oil is still in the reservoirs of all consolidated and enclosed in islands and separated our fields, and this is a tempting target.Each enhanced from all other uses by walls and buffer areas. Because recovery method retrieves a little more oil. For 12 CITY OF HUNTINGTON BEACH; CALIFORNIA DIVISION OF OIL AND GAS instance, waterflooding might pick up another ten producing well to an injection well. Although you can percent, and then a more sophisticated method would return an injection well to production, the injected zone need to be applied.This fact is keeping a lot of research would be saturated with injection water.The Division of departments busy trying to develop systems that will Oil and Gas must review all proposals in considerable flush out a greater percentage of the oil. geologic and mechanical detail prior to approving injection, and extensive requirements and conditions Bud��Tippppeens, American Petrofina: I would like to say are established at that time. t as an ei�USA are putting a tremendous amount of money into testing a down-hole QUESTION: steam generator. For steam operations in urban areas, this is the true answer. At American Petrofina, this is You showed several pictures of different kinds of what we are looking at down the road.Once all the bugs drilling rig enclosures.Could you give me a price range are out of the system, it will be the best way to for this type of equipment? steamflood the fields in urban environments. COMMENT: Wilkinson: The underlying factor, of course, is economics. Down-hole generators are expensive, but Hilman Walker,Chevron USA: Chevron USA is building you have to spend money to make money. A down-hole a rig enclosure on t e axton drill site off the Golden steam generator could make a big difference in the State Freeway in the San Fernando Valley. Our cost to development of oil resources in urban areas. date—and we haven't even spudded yet—is 30 million dollars. We anticipate drilling 26 wells, and we have a Bill Sheffield, Aminoil USA: I would like to make one block wall around the perimeter of the site. I don't know comment: you shouldn't expect the development of a what the final cost will be—with inflation it could sky- commercial down-hole steam generator next week! rocket.The drilling rigs will look like mission-style bell Downhole generators are still a long way off, but the towers. As drilling occurs, they will be moved from idea is a good one. drillsite to drillsite. Furthermore, the rigs are triple insulated, so nothing will be heard. QUESTION: Are injection wells normally former producing wells QUESTiON- and, if so, are there either regulatory or practical What kind of sound-deadening equipment can be put limitations to converting them back to producing on a portable drilling rig? wells? COMMENT: COMMENT: Multari:' In some cases in Huntington Beach, Wilkinson: Normally, injection wells are former soundproofing is not put on the rig itself. Instead, producing wells. Occasionally, a well is drilled for wooden poles are placed around the site and beams are injection purposes only, but in most cases it is a strung between them on which acoustical material is relatively minor mechanical change to convert a hung. LAND USE PLANNING IN URBAN OIL-PRODUCING AREAS 13 PLANNING GOALS AND APPROACHES Michael Multari, Planner, City of Huntington extracted once the economics and technology make it Beach: feasible. We will be analyzing this further in the case studies.Related to protecting access,we are also trying "I would like to discuss the principal goals that the City to allow for new and expanded oil facilities, as of Huntington Beach is trying to achieve through its necessary, in appropriate locations. This requires land planning efforts for oil production areas,and some careful advance planning. of the approaches we have used to implement those „We are trying to promote the unitization of oil fields goals. where ownership of the mineral rights is highly "Most of the City's planning goals are articulated fragmented. This means parties with an interest in the through policies in the General Plan and our Coastal field have to join together as a unit before consolidation Plan. First of all we are trying to accommodate mixed strategies can effectively be implemented. Again, we uses in the City. We want to continue to accommodate will discuss this issue in the case studies. oil as well as other urban uses, particularly residential "Finally, another goal of the City is to increase the fiscal and commercial development. We feel, of course, that benefits it receives from continued oil production. this a fuller and more efficient use of our land.But we Although the City does provide some costly services for are always careful in ordinances,codes,and planning to oil operations, just as it does for any business or make sure that public health and safety are protected industry, it also derives significant revenues from before permitting such mixed use development.Further, as our oil fields are recycling to new uses, we various taxes and fees on these activities._ are trying to encourage comprehensive planning of "I would also like to list the planning and regulatory large parcels of land rather than piecemeal tools that we are using in Huntington Beach to achieve development. This is sometimes difficult to do when these goals. I don't think this list of approaches is ownership is fragmented. exhaustive; these are simply the ones with which we are "We are also trying to consolidate oil facilities to reduce most familiar. the land area used for oil production.Consolidation is a -First is the General Plan, which sets out the general theme that is going to recur through all the case policies and land uses for the City. Included in our land studies. The advantages of consolidation are: 1) the use element is a resource production designation which freeing of more land for other uses; 2) reduction of the sets aside certain parts of the City for oil extraction. interface between oil activities and other land uses, "Of course,we use zoning,too.In Huntington Beach we thereby making the potentially adverse impacts from have two zoning suffixes that allow oil facilities. The oil easier to mitigate; and 3)the opportunity for greater first suffix district allows existing wells and attendant buffers and separations between oil and other uses. facilities, such as tanks, as well as the reworking or This last benefit is best achieved in cases where the oil redrilling of existing wells. This suffix is applied to facilities are consolidated into small islands and the most of the old oilfield areas, and allows the existing residential uses are concentrated through techniques operations to continue while they gradually 'recycle' as like clustering. This leaves more open space for buffer production declines and the surface value increases. zones and transition areas between the two uses. New wells, however, are only allowed in the second "Another thing we are trying to achieve is increased suffix district. This district includes a much smaller compatibility between oil and other uses. There are portion of City; it is applied primarily to relatively small many ways to do this, such as requiring screening, sites of one to three acres, which are distributed landscaping, and soundproofing of operations. Wilky approximately one for every 20 to 40acres over the oil- discussed several of these techniques earlier, and field surface. This has the effect of concentrating new others will be illustrated in the case studies. wells into these smaller sites, freeing the areas in "We are also trying to preserve surface access to between for new uses, and still affording access to the underground oil reserves. Oil is an important natural subsurface resource. resource, and we feel it is important to preserve "Huntington Beach is a coastal city, so we have a Local adequate surface areas so that residual oil can be Coastal Plan in addition to our General Plan and LAND USE PLANNING IN URBAN OIL-PRODUCING AREA5 15 zoning. Because the California 1*O sed�f al Act puts a high the City has set •pegard to oil operations. these priority on continued energy j_ uction, our Local standards are u evaluating permit applications. Coastal Plan has been an important medium through which goals and policies related to oilfield planning "Finally, as an alternative to regulatory solutions, we have been articulated. have tried to solve some of the incompatibility problems that we face in a voluntary manner by "Another approach that we are using increasingi, in implementing cooperative strategies with the private Huntington Beach is the specific plan. Through sector. We have had encouraging, if somewhat mixed, traditional zoning, a class of uses is identified. and -esults with this method that will be discussed again designated as appropriate to various locations. For later. example,certain kinds of commercial uses are typically found to be appropriate along all larger arterials. But a "As I said before, there are numerous other strategies specific plan uses a site-by-site, block-by-block analysis which could be useful in planning or regulating oil of the peculiarities of a particular area. Regulations are production in urban contexts.Transfer of development written especially for each individual area. rights strategies and redevelopment law come to mind. "Besides planning and zoning, we also require special We are always looking for better and more creative permits for oil operations. For example, no well in the ways to promote equitable and efficient land planning. City can be drilled, redrilled, or reworked without a Maybe some of these approaches will be explored special permit. The permit application is reviewed by further today. our Fire, Public Works, and Planning Departments. "What we would like to do for the rest of the day is Each of these departments has certain responsibilities present three case studies of situations here in in regard to land use,noise,and safety. With input from Huntington Beach, which we think illustrate issues that the Division of Oil and Gas and industry other jurisdictions are facing or may soon face. As I representatives, we have developed an oil code and said earlier, solutions to every problem encountered noise ordinance which state the performance standards have not yet been found:' 16 CITY OF HUNTINGTON BEACH; CALIFORNIA DIVISION OF OIL AND GAS CASE STUDY #1 OIL FACILITIES IN A DEVELOPED AREA Michael Multari: Huntington Beach is a city of about and commercial uses. We are also concerned about the 170,000 people in the Los Angeles/Orange County effects existing oil operations may have on metropolitan region. Although its early history was that reinvestment strategies for revitalizing the downtown of oilfield development, it was among the fastest area. The oil operations, as they now exist, have two growing cities in the United States during the 1960's, adverse effects on revitalization. First, because oil The rapid residential and commercial growth during operations can be unattractive, noisy, and odoriferous, the last two decades encroached into the open oil fields, the area is under-valued, thus discouraging investment. resulting ;n numerous conflicts between the oil Secondly,because many of the lots are encumbered by operations and the newer urban uses. oil and often have different lessors and lessees, they Let. me describe our downtown area. Main Street, have become highly fragmented, making it very hard to which is the focal point of the downtown, extends consolidate a piece of land large enough to allow for perpendicularly to the shoreline and ends at the foot of construction of a high .quality development. In many a long municipal pier. Commercial uses Flank both cases, an oil encumbrance on a small lot has kept a full sides of the street, which are in turn surrounded by block or half block from being consolidated for new medium-density residential areas. There are large development. parcels of land very close to Main Street that are not In the short term, our approach to solving the problem developed because they are within an active oil field. of incompatibility was to revise our oil code and our Mixed uses have occurred in the area, often with zoning ordinances to reduce noise and odor problems undesirable consequences. For example, there are and to mitigate adverse visual impacts. For example, pumping units in backyards and next to commercial our oil code was changed to require that all oil facilities establishments, and tank farms in alleys. in the City be landscaped and screened within two We know, however, that these problems can be years.We also revised our noise ordinance, making the avoided, and that compatibility between oil and other hours of operation more restrictive and giving our oil activities can be increased if we do careful, advance inspectors more latitude in requiring soundproofing. planning. Figure 10 is an example of how oil and Further, we changed our zoning districts so that there residential uses can exist compatibly. This is a map of `could be a minimum lot size required before a new well an actual residential development here in the City, not could be drilled. This should prevent the creation of very far from the ocean.Oil islands are surrounded by a more situations like those that presently exist in the pleasant residential area,which includes a country club downtown area with oil and residential uses being too and a golf course. At street level, the oil islands are near each other. relatively unobtrusive. It is interesting to note, as shown In the long term, our approach is to eii�uurage unitiza- in Figure 10, that this development is adjacent to a tion and consolidation, while preserving access to the resource production area that is the most highly underground reserves. I would like to spend some time concentrated oil site in the City. About 300 wells are discussing this long term approach, beginning with the located on this strip, along with tanks, steam question of preserving access. Why should planners generators, water injection pumps, separation plants, worry about access? The reason is that there is a lot of and drilling rigs. The residential area is buffered from oil still existing in the fields. Primary production—the these highly concentrated operations by a wide street, oil extracted using only natural reservoir pressure and setbacks, a small berm, and some vegetation. While simple pumping—typically accounts for only about 20 this area still has some problems due to the or 30 percent of the oil in a reservoir. Application of proximity of oil, it is a useful model of how both uses secondary recovery techniques—waterflooding or can be accommodated. steam injection, for example—allows production of One of the major goals we have for our downtown area perhaps another 15 percent of the potential resource. is to try to improve the compatibility between existing There are now other technologies that are being applied oil operations and existing and proposed residential after the waterflooding, such as chemical Floods, to get LAND USE PLANNING IN URBAN OIL-PRODUCING AREAS 17 Q 4 �Yy - RFSII7FNTTAL .. OIL ISLANDS _ ,fjLl_,COi7Ft5'E= - VACANP/PLANNED FOR _ RESID=IAL a 8 IMMSIVE OIL PRODl1CTICN OPERATIONS PACIFIC COAST HIGH AY Figure 10. A schematic depiction of a resioenuai area in proximity to oil operations. Oil islands are surrounded by homes aM a golf course. Adjacent to the south is the most higniy concentrates oil operation site in ttuntington Beach. 18 CITY OF HUNTINGTON BF-ACH: CALIFORNIA DIVISION OF OIL AND GAS ... .. ...... ..... ... .... . ... .. } = injection well Figure 11.More than half the oil in the reservoir remains untapped even after all presently known technologies are employed.This oil = production well may one day be recoverable with technologies yet to be developed. Figure 13.Top view of a typical pattern of production and in- jection wells. I should note that this is hardly only a local concern—it i f w's o state-wide e and perhaps a s evennational ' i aon I importance. r lance. We are worried about the possibility that in places like A�. ... our downtown, there will be n9 rapid recycling of the oil ec sites and in of the remaining vacant land with new development to the point that there will be so much of the surface area covered that it will be imprac- tical for an oil company to come in and extract the water it resource when it becomes technologically possible to do so. If IF the land is built over, access to the underlying oil reserves could only be gained by razing houses or com- mercial establishments. Clearly, this would add enor- mously to the price of extracting that oil. You can also imagine, I am sure, the kind of tumult that would result in an established tabl shed resid ential I r i a area if oi l company came in and wante d a block f oc o house s torn down so that an oil island could be created. We are trying to do some advance planning so that people will know oil ex- ists in the area, that it is likely to be extracted in the future, and that access is going to be preserved now for Figure 12.Pressurized water from the injection weP } rorces oil that possibility. toward the producing wells j''Z. One of the ways to preserve access might be to h++' designate a few carefully located areas as "islands" on still more oil out. Research continues on development which the necessary oil facilities could be concentrated. of new technologies. Figure 11 illustrates that more This approach would have the added benefit of siting than half the oil remains in the ground even after all the wells and equipment in a few locations, thereby practical known technologies are employed. What we realizing the advantages of consolidation discussed are concerned about is preserving access to a signifi- earlier. cant reservoir of domestic oil that will someday be If the application of enhanced recovery technologies recoverable with technologies that have yet to be and the consolidation of oil operations into islands is so developed. beneficial, why hasn't it happened yet in downtown LAND USE PLANNING IN URBAN OIL-PRODUCING AREAS 19 • Huntington Beach? Figures 12 and 13 are helpful in and the large area of concentrated oil operations. The answering this question. Figure 12 is an example of a new wells and related facilities of the unit can be con- typical waterflood pattern, and it applies to many other centrated into a few locations. Thus, the interface be- enhanced recovery technologies, too. A pattern of wells tween oil operations and other uses is minimized., is established and water is forced through the injection which makes it easier to mitigate problems. Also, it is a wells to drive the oil toward the producing wells which lot less expensive to landscape, berm, and soundproof pump.out the oil-water mixture. Figure 13 shows a top one oil island that holds perhaps 20 or 30 wells than it view of what this subsurface pattern of injection and would be to similarly treat 20 or 30 individual well sites. producing wells looks like. Obviously,these techniques Another important factor is related to the fact that the cannot be implemented on a well-by-well basis; they application of secondary and tertiary recovery tech- must be done on a pool-wide basis. The problem in our niques from concentrated facilities produces a lot more downtown area is that the oil pool is not under the oil. The resulting increases in profits mean that some ownership of just one company or person. Ownership of the more expensive mitigation measures that might of the pool is fragmented among many parties. For be out of the question for a small operator can be im- enhanced recovery to occur, all parties must get plemented. For example, our recent code revisions re- together and agree to participate so that these methods quire operators to screen and landscape their facilities can be employed. This is called "unitization". at a cost of roughly $2,000 per site, and several small There are a lot of difficulties associated with putting a operators thought this was a severe economic hardship. unit'together;chief among them is the"free rider prob- But if you have one unit working on an entire pool, this lem". This occurs when one party tries to enjoy the kind of expense is certainly not going to be an benefits of unitization without actually joining the unit. economic hardship and could be done quickly. The For example, suppose the owner of a well realizes that if same is true of soundproofing; sometimes the sound. everybody else will bear the costs of drilling injection proofing that might be required on an individual site is wells and putting fluid down into the pool, oil will be too expensive for a single operator to install. With a pushed out in the direction of his well regardless of unit, such soundproofing would be economically whether he joins the unit. Production from this well possible. may increase, but the operator has not paid for any of Another advantage of unitization,and one that is of par- the new equipment or wells. ticular interest to local government, is that significant Sometimes so many people hold out as free riders that fiscal benefits are recognized from this kind of situa- the unit cannot be put together. This makes it risky for tion. We have done a fiscal impact analysis of oil opera- a company to try to start a unit project. It is costly to in- tions in Huntington Beach.' The City receives revenues itiate a unitization project, lease the required mineral rights, promote interested investment companies, and 510 .. ...... Es:3nnrE0 EXPENDITURES do the necessary geologic studies. In an area like our downtown, there are about 30 oil companies that EsrrnnrED REVEVUES operate roughly 100 wells, and the actual mineral in- so terests are owned by about 2,000 different parties. So to put together a unit, you would have to unitize those 2,000 leases plus those 30 working companies.Clearly, 40 this is a substantial task. „•,,,,,, ,_,,,,,,,,,,,,•,,,,,,,,,,,,•,•„ Also, many people may want to hold out just because they think they will get a better deal.Their thinking will 0 be,"There are 30 of us here who have to join the unit to make the project work, and maybe if I wait to be the 30 30th party, compensation for my participation will be a little bit greater" Obviously, if everyone is thinking this way,a unit cannot be put together. 30 Another situation might involve a small oil company that feels it may not get a good deal out of unitization. Sometimes the reason for not joining is the pride of 19eu e3 e3 83 94 es es 97 BB E9 90 ownership in having an independent oil company that is not subsumed into a unit with a major oil corporation. u9 9 Clearly, there are a lot of reasons why units can be dif- ficult to assemble. Yet, there are several benefits that Figure 14. Relationship between net City expenditures and can come from a unit project. I have already mentioned revenues from non-unitized oil operations. Revenues, which that production can be increased by implementation of are tied to production, are decreasing while costs are rising enhanced recovery technologies, and that oil facilities slightly above inflation.(Expenditures were estimated using a can be consolidated. Reference back to Figure 10 will weighted average model). remind you of this. It is the area we were talking about Energy Series Report^2:Fiscal Impacts of oil Operations in Hunt. before—the residential oil islands and the golf course ington Beach".Huntington Beach Planning Division, 1981. 20 CITY OF HUNTINGTON BEACH:CALIFORNIA DIVISION OF OIL AND GAS '0 from an oil production fee, prop }axes, drilling fees, we first asked thE% )stion, "is there enough oil to and utility taxes. We looked at the revenues and expen- worry about?" Using data from the Division of Oil and ditures that we are incurring now and projected them Gas and from some of the oil companies in the City, we out over the next decade. It was important to note the estimated that about 25 million additional barrels of oil significant difference in revenues generated by oil could be recovered from the area. This is a significant operations with and without unitization. Figure 14 amount of oil. We then asked, "If we are really concern- shows the fiscal picture in the downtown area if unitiza- ed about preserving access to oil in the downtown, how lion does not occur. The expenditure line reflects the many sites will we need to do this, how big will they amount of money the City is spending for the provision have to be, and where should they be located?" Figure of services to these operations. You can see that costs 16 shows the existing drill sites in the area. We con- are going up slightly above inflation while revenues, sulted with a drilling company and, using their informa- which are tied to production, are slowing down and tion and other data regarding the depth of the various dropping inconstant dollars. oil pools, estimated the areal extent, or reach, of direc- tionally drilled wells from these existing sites. This is il- Figure 15 illustrates the fiscal picture for the same area lustrated in Figure 17. It shows that most of the oil zone under a unit operation. The revenues have gone up could be covered from the existing drill sites if they dramatically and the costs have declined slightly. were available and if all the wells could fit on them. Us- Revenues are largely tied to production: as more oil is ing data on typical waterfloods and steam projects, we produced, more revenue is generated. Costs are tied also estimated the number of wells that would be need- largely to the number of operators and sites, and the ed. With a little more research, we learned that many land area occupied. For example, if you have 100 com- wells can be drilled in a small area—on the order of 20 panies,you have to bill them for certain services.That's to 50 on a two-acre site. Therefore,only a very few sites 100 bills that must be prepared. But if you had one unit, would be needed to accommodate all the wells involved you would only have to write one bill. So your cost of in a unit project. providing services is less,yet revenues have gone up. We concluded that if we could preserve the existing drill When we began considering ways to promote a unitiza- sites, we could accommodate a future unit project. Our tion and consolidation program for our downtown area, City Council then appointed an Oil Committee to deal with this issue.The kinds of options that the Committee looked at were zoning, General Plan designations, and 310°0'• conditional use permits. For example, drill sites could Esrl.utEo REVENUES be zoned so that no other uses except oil operations ..... Esr7w,rE° EYPENUITUE[S would be allowed there. A General Plan designation could be applied to the islands, making them resource 160 production areas.Before other uses would be allowed,a General Plan amendment would have to be filed and an assessment of the site for future access could be a con- 120 dition of approval. If the site were important to future access,the amendment would be denied. The option to require a conditional use permit would likewise involve too a permit review before other uses could be introduced. The Committee also looked at City-owned property in 60 the area, thinking that if no other method effectively preserved access, the City could lease its own land for future oil production. The Committee even considered 60 the feasibility of creating offshore islands like those in Long Beach to directionally drill back into the onshore pool. 60 While we were analyzing these options and the Oil •••••"......•............................................ Committee was wrestling with what it would recom- mend to the City Council, an oil company indicated 20 that it wanted to put a unit together in the downtown area. Suddenly, the problem changed from the theoretical issue of preserving access for the future to the reality of trying to find sites for this particular oil 1960 61 62 63 64 E5 66 67 66 E9 90 company. The City is presently working with the oil (1979 a711.1 company in question, trying to determine whether ex- Figure 15. Estimated fiscal impact from unitization of isting sites or other additional sites are going to be downtown Huntington Beach oil field. Revenues to the City suitable for the project. We are also working on refine- rise dramatically because oil production is greatly increased ment of our zoning to allow the unit to take place, and under a unit project. (Expenditures were estimated using a mitigation requirements regarding noise, design, land- weighted average model). scaping and odors. LAND USE PLANNING IN URBAN OIL-PRODUCING AREAS 21 CalIt F F:::JigF I CH F::�eFmzmm� CEE�F:: of LJ❑Ej�oOE�OC_ CEBElPm�oPm�86 o = EEIF �( a �oo �oo' `�000HEd COL =L71 CH, CCH, E Figure 16. Location of existing drill sites in the downtown Huntington Beach area. 22 CITY OF HUNTINGTON BEACH. CALIFORNIA DIVISION OF OIL AND GAS f A /� E� OH E� F�®� CAB S ���F::� Cho � �B CAB O O C E8® ® Ei g F] �00000 � C� oo �oo` moo s� � nr oa .� •� Figure 17. Directional drilling allows a large subsurface area to be tapped from a central site. This figure depicts the approximate areal extent of directional drilling from existing drill sites in downtown Huntington Beach. LAND USE PLANNING 1N URBAN OIL-PRODUCING AREAS 23 An interesting footnote to this story is that the City City Council felt that this put the City in the driver's seat itself owns the mineral rights on about 125 lots in the in terms of demanding a royalty interest higher than downtown. When the oil company proposed the unit that of other parties. This was resolved after several project, the City's position changed from that of look- months of negotiation, but the point is that even the ing at a long term solution to consolidation and access City, which ostensibly takes a broader view of the com- problems, to that of being a potential mineral rights munity interest, saw the money that was involved and lessor trying to get the best deal for its properties. Peo- was tempted to hold out. As I mentioned earlier, hold ple were looking to the City for guidance as to whether outs are a problem that can block the formation of unit they should join the unit, and some members of the projects. DISCUSSION QUESTION: QUESTION: Do existing wells in the area where the consolidated oil Is it fair to say that existing State law focuses more on sites are located have a different status after consolida- new wells and their distances to structures than the tion? proximity of new structures to existing wells? COMMENT: COMMENTS: Multari: They could, but in our approach they do not. Wilkinson:The Division of Oil and Gas does not specify The drill sites are especially zoned to allow new wells. If such requirements.That is an issue normally dealt with a company wants to drill a new well, it must locate it in through local ordinances. one of the designated drill sites or change the zoning to Michael McKay, Huntin ton Beach Fire Department: allow new wells on other properties. Most of the ex- a ni orm ire e a-daressed only the prox- isting wells are in a different zoning district in which ex- imity of new wells to existing buildings. The 1979 isting wells can remain and be redrilled but in which no Uniform Fire Code now has a provision that if you have new wells are permitted. The same zoning and related an existing well,a new structure cannot be built within a regulations that are placed on these wells now would certain distance of that well. I realize, however, that the apply to them after a consolidation project. However, in Code is a model—it is not really State law and cities most unit projects,many of the existing wells and tanks are abandoned because they are no longer needed. have the option of adopting it. I'd like to know if any cities have been challenged on issues of inverse con- QUESTION: demnation that could occur in cases where the sug- gested 100 foot distance is imposed around existing Do you intend to protect the right of mineral owners to wells in an area where there are small lots. Would these derive an economic benefit from their subsurface pro- regulations amount to inverse condemnation if they perty, even while you restrict new drilling on the sur- prevented people from building on surrounding lots? face? Multari: I think that the fear of just such a situation in COMMENTS: Huntington Beach accounts for a footnote in the ver- sion of the Uniform Fire Code which was adopted by Multari: If a P the City. Under certain circumstances, such as the to drill a new well, he would go to the owners of the development of fireproof walls and sprinkler systems, closest islands and negotiate a lease to drill from one of the City permits the 100 foot minimum separation be- them. Let me introduce Alan Hager from the State At- tween new structures and existing wells to be waived. torney General's office. He may be able to help us with This is not a very satisfactory solution in some respects, some legal questions. because it has allowed some buildings to get very close Alan Ha er, State Attorne General's Office: A legal to oil facilities. This can result in noise, vibrations, or question t at is raise y this kind of approach regards odor problems, but it does avoid the potential inverse owners of mineral rights that cannot be reached by condemnation situation. directional drilling from the centralized oil islands. Can you deprive a person of the right to recover that oil? QUESTION; Perhaps we have denied the owner the right to the mineral and, at the same time, allowed it to be drained Do you have any problems with odors from oil facilities by other people.I question whether that would be legal. in close proximity to houses?If you do have these prob- Jose Osuna,Cit of Lon Beach: It is justified under the lems,how do you solve them? police powers o a city to provide different zones that COMMENTS: allow residential uses in one area, commercial uses in another, and oil extraction elsewhere. I think in the case Multari: We have high sulphur content oil in some of study that was just presented, the real problem is not tie zones, and when the wind conditions are right we that the oil could not be recovered from the available have a lot of problems with odors.I can say from my ex- sites,.but that hold outs would be a real impediment to perience that odor is the hardest problem to mitigate. It the formation of a unit. is even worse than noise problems. Noise mitigation is 24 CITY OF HUNTINGTON BEACH: CALIFORNIA DIVISION OF OIL AND GAS expensive,but it is possible.Odj, ligation is very dif- ing system at the le • side of one of the leases.The ficult to achieve. monitors will detect hydrogen sulfide gas in offensive Some of the kinds of things that have been done here or dangerous concentrations so that the oil operator regarding odors are not entirely satisfactory, but they can contact City officials and let them know whether or are improvements. In one instance, we found that the not there is a problem. most severe odor problems were occurring when cer- The detectors will do two things. One, of course, is to tain steam-related gases were vented into the air. If the notify the operator that there is a problem. The wind conditions are right, odor can become very con- operator can then look for the source and correct it. centrated. In some cases, loud complaints were Also, when we call an operator about an odor problem registered, and some people actually got ill. What we we think is coming from his lease, he can say, "Sorry, have been able to work out with the company in- go knock on someone else's door because our detec- volved—actually, they did it more on their own in- tors have not picked anything up from our operations" itiative—was a system whereby the gases could be held So it helps the operators and it helps us,too. in condensation tanks if they were so severe as to cause Dressler: Does the Air Quality Management District, complaints. AQMD, get involved with this? Do the citizens call the One oil company in the City is putting up hydrogen AQMD?And what is its policy? sulfide, H,S,monitors around the periphery of its lease. gill Sheffield,Aminoil USA:The AQMD has been out to After H,S concentrations in the atmosphere reach a cer- tain point, this device will signal some kind of a warn- suspected were emanating from our lease. The AQMD ing. This would allow the location of the gas source to will cite us if we create a public nuisance. be pinpointed, and the operation shut down until the wind conditions change or the H,S content of gases on QUESTION: the lease change. I don't know exactly how this system is being implemented at this time or how practical it is. Are you saying that the sulphur detectors will actually Terry Dressler, Air Pollution Control District, San Luis detect the presence of these gases before the human (Jbispo Count If you have installed the best available nose will?We have been told by the air pollution people contro tec nology for the mitigation of odors and that there is no such detector. gases and you still have odor complaints coming in,the COMMENTS: Air Pollution Control District must enter into things.The District will have no other choice but to shut the gill Sheffield, Aminoil USA: Thedev ces will detect the operation down, or to cite it and issue a violation for sulphur and mercaptan content of gases before they being a public nuisance. Odor seems to be an almost become toxic, but not before they become odoriferous. unmitigable problem in some areas. The odors are too strong. Multari: In some places and under certain conditions, I Wilkinson: It is practically impossible to build an instru- think you are right. We also have a provision in our ment more sensitive than the human nose. We have a code that allows the oil inspector to shut down an very sensitive hydrogen sulfide detection instrument operation for excessive odor problems. that will measure less than one part per million of H,S gas, but although that concentration is very noxious, it Randall Abbott, Kern Count :We had a situation in Kern barely registers on the meter. Detection equipment is ounty where di iculties in locating the source of odors designed to indicate toxic concentrations rather than caused problems in our mitigating them. We knew the the odor or noxious level of the gas. I do not think there odors were most likely coming from an oilfield waste is an instrument that can detect small concentrations of disposal site, but because there were other possible H,S more sensitively than the human nose. sources in the area, we could not specify the offending source. We lacked the capability of pinpointing the Sheffield: We are investigating the usefulness of am. culprit, and were therefore unable to bring action bient air monitors. There are ambient air monitors that against that party. Another advantage of unitization is will sense down to a few parts per million successfully. that instead of several different operators of potentially We are investigating these monitors and will probably offensive operations pointing their fingers at each put several of them on our lease to see if they will be other, there is only one party responsible for the pro. beneficial to us and if we can get them at a reasonable blem, cost. As soon as we get any kind of information,we will Multari: A related point is that through consolidation be glad to share it with the rest of you. a�nitization, you are concentrating the facilities to a QUESTION: few locations, rather than having several wells scattered throughout another kind of district. Putting oil facilities At what stage of production or drilling of the well are in just a few locations makes problems easier to solve these odors most likely to occur? than when the facilities are spread out over numerous sites. COMMENTS: Michael McKay, Huntington Beach Fire Department: Wilkinson: Normally, noxious odors are not produced Earlier, you mentioned a sulphur compoun monitor- when a well is being drilled. If a diesel engine is used, LAND USE PLANNING IN URBAN OIL-PRODUCING AREAS 25 some exhaust odors may come from the engine, but 25 feet of it.We'll build a six-foot wall so that the people other than that there are no particular odors that come who will be living in these condos will not see the from a well until a point is reached where gas is en- oilfield facilities". Until they built those homes, that oil countered. If it is pure methane, it will be odorless, but operator could drill and make all the noise he wanted to there are other compounds that may be mixed with because there was nobody nearby. If allowed by the zone gas that have a characteristic "oilfield City,a developer will come in and build on this land. smell"—particularly sulphur compounds. However, this gill Sheffield, Aminoil USA: This is really just evidence would normally be of short duration. of what you planners can do: plan so that you do not Unfortunately, a lot of California crude oil has sulphur have residential encroachment right next to heavy oil in it, which causes the rotten egg smell. In the produc- uses. As I understand it, the purpose of this meeting is ing phase—if you are producing oil with a sulphur con- to help you solve these kinds of problems in your com- tent— hydrogen sulfide gas usually comes out along munity ahead of time. with the oil and water. This is not only smelly, but can, Bud TippensI American Petrofina: As I see it, the City of at certain concentrations, be toxic. Hydrogen sulfide is Huntington Beach is starting to take care of noise prob- extremely poisonous, even in fairly small quantities, if lems. It has a noise ordinance that limits the noise per- it is trapped in a confined area. milted at the property line to 50 decibels for residential, In an open area, HZS gas diffuses rapidly so it is not 55 decibels for commercial, and 60 decibels for in- harmful, although it is still quite odoriferous.Typically, dustrial. These are decibel readings from the property the well and the production system are designed so that line, and it is up to the operator to find the best way to they can be closed to avoid leaking gases in hazardous meet those standards. quantities. It is usually only when something malfunc- Linda Melton, Aminoil USA: I think our-problems in tions that a leak occurs in the system and HZS odors are Huntington Beach are exacerbated by the fact that we noticeable. have people surrounding us who do not close their win- Normally, the strongest smells are either sulphur diox- dows at night and put on their air conditioning. They ide or hydrogen sulfide gases in combination with want to open all their windows on a nice,clear night and some of the other normal petroleum smells—what we feel the breeze from the ocean. This is a problem call "oily smells"—that occur in oil fields. If wells are because they can then hear absolutely every sound.The being steamed, some strong odors can be produced escalation of residential encroachment is definitely a from sulfides. As I mentioned, however, the systems problem that is going to take a lot of compromise and a today are usually closed, and tanks generally have lot of understanding. I expect that, things being what some type of vapor recovery system. Hence, there is they are, most of the compromise is going to have to be really no reason for excessively noxious odors around on the part of the oil companies and we will just have to an oil lease. Most severe smells should be transient include it in our cost estimates for operation. events. Wilkinson:We have two types of situations.We have the `Michael McKa , Hunti ton Beach Fire De artment: I ur a-n situation in which we have less room to work, woul just like to draw rom some o t e expertise in and we have the more open, rural areas that have not the room regarding noise problems related to drilling yet been encroached upon.You planners have some im- and redrilling. Our problem is that if we allow develop- portant decisions to make. Are you going to keep the ment close to wells, those wells are eventually rework- area intact as an oil field, but allow development within ed or redrilled and the owner of the residence will come some reasonable distance of the oil operations? Or are to the City and say,"Stop that guy, he's interrupting my you going to preserve some access areas to the subsur- sleep". Do we just tell this guy to live with it, or do we face as the field is infiltrated with urban development? tell the oil people to do something about the noise?The Decisions must be made as to how the oil operator can oil operator says, "I've been here for 40 years. That continue operating without being penalized excessively. building has been therefor year'. Jose Osuna, City of Long Beach: We had a case that in- QUESTION: volved a marina t at surrounds an area with six existing Does the City have ways to encourage unitization? wells. The company is going to drill about four more wells,but the operations can be shut down if there is ex- COMMENT: cessive noise. Wilkinson: In regard to your sound problem, that oil Multari: That is a good question and one that we company has an obligation to meet the noise or- wanted to ask everybody here. What attracts an oil dinance. Certain operations can be curtailed during company to an area to form a unit? One of the ways to nighttime hours if necessary. However,there has to be a encourage unitization that occurred to us was to try to reasonabledistance between the public area and the oil preserve some access sites so that in the future an oil operations,and a reasonable noise limit. company would not be scared away by the prospect of having to tear down houses or commercial McKay: A problem, though, is that the developers say, establishments to start drilling operations. We thought at all the land not being used around this little that the most important thing the City could do was to pumping unit.It is very quiet,so we want to build within set aside districts that could be used for oil and to set 26 CITY OF HUNTINGTON BEACH;CALIFORNIA DIVISION OF OIL AND GAS up a policy to make it clear that N concerned about ticipants who are M)g up the money. Often times, preserving access for any unit prolec that could occur too, there is a penany placed against the hold outs sometime in the future. I believe, however, that the because of their unwillingness to put up the money. State must play an important role in encouraging Really,there are statutes in other states that are far bet- unitization. The State does have a compulsory unitiza- ter than ours. The California law as it exists now might lion law which could require hold outs to join a unit or as well not be there.I think it is that bad. be bought out by the majority if a certain percentage of I would also like to clarify something about subsidence the owners decide to participate. However, this law is and unitization.The subsidence and unitization laws are quite restrictive and has not been very effective. different statutes. There is a special Subsidence Act QUESTION: that was designed for the Wilmington field to deal with the subsidence problem there. The State can force What percentage of the participants do you have to unitization to provide for a repressuring operation or have before unitization can be forced on the whole? waterflood to prevent subsidence, but the law can be applied only in areas subject to inundation by the sea COMMENTS: that are already subsiding. Bud Ti ns, American Petrofina: I am with the com- Multari: Is the State doing anything about compulsory any t at is trying to unitize the City's downtown area. unitization? There are certain things that cities cannot There is a statute in California that provides for forced do. Matters regarding the subsurface are generally the unitization if 75 percent of the leasable lots, 75 percent State's responsibility. of the independent operators, and 75 percent of the royalty owners who are receiving royalties from those Richard Weaver, Cit of-Santta Fe S tin s: The unit in independent operators all agree to the unit. No one has Santa a prings is cop ee y wit in City limits. The ever tried to force-pool into a unit in California, and we compulsory unit law could have been applied—they at American Petrofina really don't want to be the first to had the required 75 percent of all the various necessary try that. So what we are trying to do is put together a parties. But they chose not to apply it,and they are cur- voluntary unit. This means getting 100 percent rently operating the unit without the participation of the cooperation out of the 30-odd independent operators other 25 percent. There were apparently enough pro- producing in the downtown. Voluntary unitization can blems that they figured it would have been more expen- be difficult; it took Texaco seven years of negotiations sive to try to force everyone in than to operate without before it put its Signal Hill West unit together. them. So they are operating without 25 percent of the production being in the unit, and some of the holdout Would any of the independents try to block us by saying blocks are right in the middle of the field!There is a lot it is unconstitutional and that the State does not have of free riding,but apparently it is not significant. the power to force units? I think the State does have the power to do it, because it is in the best interests of the Multari: It is possible, for example, that a hold out s owners and the public. In all the other oil-producing welts could begin producing more water than his equip- states there are force-pooling statutes. As a matter of ment can handle after unitization has occurred. In a fact, they are even more stringent than those here in situation where the hold out's wells are not so for- California. tuitously located and their oil production decreases as a Jose Osuna,City of Long Beach: I don't see State courts result of unitization, would this operator be able to sue ruling force-pooling unconstitutional; that s not the the unit for damages? problem. The California force-pooling statute was in- Alan Ha er, State Attorne General's Office: They can stituted in 1972. It was billed as something great,but its a ways sue,butt a question is are t ey going to win?In success, I think, can be measured by the number of California, there is no recent law on it. The perspective times it has been used—zero. There are also limits on of California law in the pas[ has been that this would where it can be applied, based on the age of the field constitute trespass and that it was actionable in court. and its location relative to incorporated cities. There are not many fields to which the mandatory unitization Trespassing occurs if you are injecting water and that injected water moves onto somebody else's land. law applies. However, I think Texas and some other states have Another thing we have that most other states do not declared that if there is such a trespass caused by a unit have is a provision that the owners who agree to unitize operation, it is not actionable and you cannot recover have to be willing to buy out the people who don't go damages. The policy is that the imposition of liability along. Our law has an arbitration mechanism to settle discourages the same unit operations that the State on the fair value of the land to be bought out. In other wants to encourage. I think the equitable and rational states, hold outs are forced into the unit, and they don't approach is to not impose liability. Again, I don't know get any money from the oil produced until their share what the answer is in California, because there just isn't of the expense has been captured by the unit par- any law on it. LAND USE PLANNING IN URBAN OIL PRODUCING AREAS 27 CASE STUDY #2 PLANNING FOR OIL AREAS ON THE URBAN EDGE Multari: This second case study focuses on an oil field in wells, the Division of Oil and Gas suggested that all the ano�ier part of the City that, unlike our downtown area, is necessary wells could be located on two sites of about one not yet developed. In this case, we have the chance to do or two acres each.The Division of Oil and Gas advised us some advance planning before urban development starts to as to the general areas where each of these sites should be encroach upon the field. placed.They suggested that one site be located on the west The area is largely vacant, except for oil wells, associated side of the area and another toward the east,as was seen in tanks, and a few horse stables.The site is about 300 acres Figure 9. We were then able to apply surface planning con- in size, surrounded by "suburbia", with mostly residential straints to determine the best specific locations for the and some light industrial uses nearby.Recently,a developer islands. came to the City wanting to subdivide 20 acres within the The method we used to do this is a basic planning tech. 300 acre area. The Planning Commission and the City nique: a composite constraints map. We first analyzed Council decided that this was a good time to start doing geologic hazards; however, these proved to be mitigable some detailed,comprehensive planning for the area.Figure problems. Secondly, we reviewed our topographic con. 18 illustrates the draft plan that our staff has put together. It straints. .We wanted to take advantage of the little bit of is still in a preliminary stage. The Planning Commission topography afforded in this area by preserving the drainage directed staff to develop a concept for low-density"estate" saaes,the bluff area which overlooks the wetlands and the residential with equestrian uses. From an oilfield planning ocean to west,and the other higher points.Third,we look- perspective, we were most concerned with incorporating ed at the Proposed public facility systems: roads, sewers, the following into the concept plan: 1)trying to concentrate trails,drainage,public open space,and recreation areas.We the existing and future facilities into a few locations so that wanted to pick sites for the oil operations that had access to the oil pool can continue to be tapped; 2) freeing most of one of the major collector streets, and we did not want to the land for other uses; and 3)trying to provide adequate put them directly on a proposed equestrian trail or sewer buffers between new uses and the remaining oil operations. line. Fourth, we analyzed ownership patterns and property In this case study, we would like to focus especially on the lines.We did not want our site in a location where three or problem of preserving surface access so that certain areas more properties intersect, for example. Finally, we were in the future will be reserved for oil operations.Three basic concerned about the location of the existing oil facilities. questions need to be answered: 1) how many future sites We did not want to choose a site where there are currently are needed; 2)how large do they have to be; and 3)where no oil wells, but rather a location where some of the ex- do they have to be located? The Division of Oil and Gas isting facilities could be included in an island. provided help in answering these questions. B taking all these things Y g rxjs into consideration, we came up Based on typical well spacing, there are some rules of with the composite constraints map shown in Figure 19. thumb for estimating how many wells will be needed for Using the general locations suggested by Division of Oil application of secondary or enhanced recovery techniques and Gas engineers, we picked the two locations shown in in a particular area.For example,in other parts of the Hunt- Figure 20 for the specific oil island sites. These sites are ington Beach field employing similar technologies, the outside all the important topographical and open space wells are spaced about one every ten acres. So this 300 areas that we felt needed to be preserved.They are adjacent acre site would require about 30 wells. If steam techniques to collector streets that we have planned for the area. We are to be used,the spacing is typically closer,perhaps a well tried to get a comer location for both islands so that we every five acres. In that case, 60 wells may be needed for would have buffers on two sides of the site,but we- were this area. unable to find a location for the west site at an intersection Next,we wanted to know how many sites would be needed that would not jeopardize other goals. and where they should be located. By analyzing the depth After we determined where these sites should be,we had to Of the oil zones and the typical reach of directionally drilled devise ways to effectively preserve them in a manner that LAND USE PLANNING IN URBAN OIL-PRODUCING AREAS 29 EUJFF AREA OPEN SPAN CORRIDOR G SENSITIVE DEVELOMETT AREA PROPOSED COLLE)rIIOR STREETS 1 r t01, y ' " a � \ t y.� .�/ H Figure 18. A portion of the draft land-use plan for a 300-acre undeveloped oil field on the urban edge. Planning goals for the area include preserving access to oil resources by consolidating existing operations and providing adequate buffers between new land uses and remaining oil operations. Figure 19. This composite constraints map,resulting from the consideration of surface planning constraints, was used to determine the best specific locations for oil islands. Areas with one or more constraints were shaded. Considered were geologic hazards,topography,proposed public facilities,property lines, and the location of existing oil facilities. 30 CITY OF HUNTINGTON BEACH: CALIFORNIA DNISION OF OIL AND GAS t BLUFF AREA OPEN SPACE CORRIDOR rzx� t SENSITIVE DEVELOPMENT AREA l--J PRDP(]SED (AI.I.ES.'lOR STREETS l� JJ 1 �> h\ � �- ♦ n �� Pi AItr iP.�r{er 1 �R1 v ... 3 Figure 20. The two locations chosen as sites for oil islands based upon the composite constraints map and the general locations suggested by the Division of Oil and Gas. was fair to the property owners.Diane Border,another plan- Let me begin with the General Plan designation because,of ner working on this project,will outline some of the options the three, it is probably the most stringent and may be the City explored. useful in areas where there are only a few existing wells left. Diane Border, Planner,Ci of Huntin on Beach: You have Designating an area "resource production', a land use seen ow we too a n r o surface constraints,as well category we use in Huntington Beach, would make oil ex- as the geology of the area,into consideration. Next,we had traction the principal permitted use. A General Plan to decide what mechanism we could use to create and amendment would then be necessary before new uses maintain access on the chosen islands.I would like to brief- could be introduced. One condition for approving the ly discuss some of the options we examined for doing this. amendment could be the submission of an engineering No one solution will work in all situations,but these options report explaining why the site is not important to future ac- should give you an idea of the range of alternatives cess• Because a General Plan amendment requires a much available to you in preserving oil access, more extensive review by policynnakers than a zone change or conditional use permit,drill sites may be more effective- To start at one extreme, we looked at the exercise of emi- ly preserved.A possible drawback to this method,however, nent domain for maintaining oil sites. Clearly, condemn- is the fad that General Plans usually do not differentiate tion has a number of drawbacks, not the least of which is land uses on parcels smaller than 20 acres. So, depending political sensitivity. Perhaps the use of eminent domain on the extent and configuration of the oil zone in your area, should be looked upon as a method of last resort for use in this option may be cumbersome to work with. areas where only a few existing wells or access points re- main. In these cases,however, it would likely be difficult to Base zoning, too,can be an effective way of preserving oil make a convincing argument that there is an overriding sites and may afford more Flexibility than the General Plan local public good in condemning the site for oil. designation As we discussed earlier, Huntington Beach currently allows oil uses under a zoning suffix which is at- Moving into the realm of the more likely,we identified three tached to the base zoning designation- Both uses are traditional types of land use controls that can be used for allowable, but because oil is permitted under a suffix only, preserving oil access. These are: 1) the General Plan oil operations can at any time be abandoned in favor of the designation; 2) zoning; and 3) overlay districts requiring base zoning use.Greater control can be exercised by mak- conditionl use permits. ing oil itself the base zone. This would then require a zone LAND USE PLANNING IN URBAN OIL-PRODUCING AREAS 31 change before other uses could be permitted on the site. A related form of TDR is"averaging This is used when the Again,consideration of access preservation can be made a entire parcel has one owner.The surface area necessary for condition of granting a zone change. access is kept open and the development that could other- A third method is an overlay district with a conditional use wise have occurred there is distributed or "averaged" permit.Under this option,oil districts would be defined by a throughout the rest of the site so that the owner bears no general overlay designation which would require that a con- penalty for maintaining access on one portion of the pro- ditional use permit be obtained for all uses other than oil. pew. The granting of a conditional use permit is contingent upon Multari: Our Planning Commission is considering a re- the applicant agreeing to certain conditions. For our pur- quirement, for reasons unrelated to access preserva- poses,these conditions could be preservation of existing oil tion, that new development projects be at least ten uses or not permanently encumbering the land so as to acres in size before they can be approved. We decided allow for future oil access. When considering this option, that, in light of this approach,an acceptable strategy for keep in mind that it almost literally creates a whole new preserving future access would be to take the sug- layer of regulation in the affected area. gested oil sites and allow them to be part of a minimum Another option that should be mentioned is using land ten acre project. The overall density of the ten acres owned by the city or county for oil access islands.On pro would not be changed, and the area designated for oil perry that it owns or acquires,a jurisdiction can restrict sur- could be part of the open space requirements for the face uses to preserve access for future oil facilities.The sur- overall project so that developers would not lose any- face,or parts of the surface,can be kept free of permanent thing by keeping the sites open. However, we had some encumbrances until such time as drilling or an enhanced concern about allowing oil islands to count toward recovery project is proposed for the site—or is determined open space. An alternative would be to not let the oil to be impractical. At that time, the parcel can be sold or site count towards open space, and instead to increase leased to the parties proposing the project. Remember, the overall allowable density on the rest of the site.This though, that most enhanced recovery projects will require would create a density bonus for keeping the oil site more than one site,and the cost of acquiring a number of open. usable parcels for this purpose is likely to be prohibitively We also proposed that, in addition to the two man- expensive for most jurisdictions. Another drawback to us- datory oil sites required to be kept open for future ing parcels that are already owned by the city is that they use, there also be three other optional oil sites may simply not be in an oil zone or be of the correct con- created by suffix zoning on a base district.The prop- figuration for enhanced recovery projects. erty owners of the optional sites could then decide We then looked at some nonregulatory, incentive-based ap- whether to use the property for oil operations or for proaches to access preservation. First, some types of tax the base district use; both would be permitted. We abatement strategies may produce enough incentive to are worried about creating an artificial monopoly. If keep sites open for future oil operations or to keep existing we limit drilling to the two mandatory sites, that operations in production. Depending on your jurisdiction's means there are only two parties to go to for a new tax stricture,there are a number of taxes or fees that could well from now on. The two parties could possibly be reduced. Property taxes; severance taxes, fees for a hold out for a pretty steep price, and the City, by its number of services like well inspections,drilling and redrill- zoning, will have artificially created a near- ing permits,and wastewater permits could all be subject to monopoly -condition. This is one of the reasons abatement,either singly or as a package. we've considered expansion to five islands—three of A concept that we found particularly interesting in this case them optional—instead of just two mandatory ones. was transfer of development rights, or TDR. Under this Before we begin the general discussion, let me method, development rights can be severed from one backtrack just a little bit to tell you about another parcel and transferred to another. For example, if the pro problem that we tried to address while planning for posed island,which is to be kept undeveloped,would other- this area. As I have already mentioned, there are a wise have accommodated three residential units,the owner lot of existing wells scattered throughout the area. would be able to transfer his right to build three units to We were worried about problems arising from new another property, thereby increasing the allowable density, development near these wells.To help ameliorate and value,of that other property.Normally,total restriction such problems, the City revised its municipal code of development on a parcel would constitute a taking, but to require that the developer prepare a plan which with TDR the severed development rights are marketed addresses compatibility concerns and the future and transferred to another parcel. Proceeds from the sale disposition of oil facilities before any development. compensate the owner of the restricted parcel.Generally,a The concerns the plan must address include the size transfer zone must be defined into which transferred rights of the site set aside for oil activities to make sure can be accepted. The result will be somewhat higher den- that it is large enough to accommodate the existing sities in some parts of the area in exchange for keeping a facilities and any expansion that would be allowed portion or portions of it open. The overall density of the under the existing zoning, accessibility to oil sites area is not increased—just the density in some parts of it from public roads, and access for emergency Care must be used in setting up a TDR scheme so that den- vehicles and oil equipment. The plan must also sities greatly out of character with the planning goals for identify the type of soundproofing treatment that is that area are not created. going to be used to ensure minimal potential noise 32 CITY OF HUNTINGTON BEACH. CALIFORNIA DIVISION OF OIL AND GAS conflicts between the oil areasr the residential ties to get togethei, brepare a satisfactory plan so area. that these kinds of concerns will have been con. sidered before houses are built and people move in. Any type of spacing requirements that the Fire to them. If an oil operator decides not to approve the Department would require with regard to access or plan, it can be submitted to the Planning Commis- public safety would have to be incorporated into the sion with a report explaining why the operator would plan. A landscaping plan must also be submitted not approve it. If the Commission can make findings which describes setbacks and buffer areas, and how that all the considerations have been adequately ad- they are going to be incorporated into the overall dressed by the developer, it may grant the develop- project design. The developer must have the oil ment or subdivision entitlement without the oil operator approve the plan before it is submitted to operator's approval. The decision of the Planning the City. This way, we feel that this forces both par- Commission could be appealed to the City Council. DISCUSSION QUESTION: COMMENT: Are you talking about relocating existing wells, or Multari: First, there is an underlying base zone just the siting of new wells? district. Then a "suffix" is applied which allows another kind of use. For example, if the base zone is COMMENT: residential, and there is an oil district suffix, either Multari: Only the siting of new wells. The next case oil wells or new residential uses are permitted. It is we are going to present does address relocating ex- up to the property owner to decide what to use the isting wells and the problems that we are having land for. with that. In this case, we know there is a lot of oil under the area in question and that it is going to be QUESTION: valuable in the future. The pool has never been waterflooded; enhanced recovery techniques have In a new situation like this,would you put conditions never been employed. We are concerned about on the new well sites that are not applied on existing allowing future operations to get that oil out, but at wells? the same time concentrating the oil facilities into a few locations. COMMENT: QUESTION: Multari: Yes. Our standards for new facilities are much stricter than for existing ones. The City just Are you proposing to prohibit new oil wells outside reviewed its oil ordinance and zoningdistricts this the islands? past year. From now on, new wells in Huntington Beach are going to have to conform with these COMMENT: stricter standards. Oil operators are going to have to Multari: Yes. New wells would be prohibited outside weigh the costs of meeting these standards in tTose Tive islands, and we would not allow new wells deciding whether or not to go ahead with the pro- elsewhere without a zone change. ject. QUESTION: Another problem, however, has been to find ways to Do the oil companies or the developers pay for the get operators who have been conducting business abandonment of non-unitized wells and the con. here for 30 or years to make improvements to or solidation of new wells? their facilities or their property. did establish landscaping and screening requirements which are COMMENT: not very expensive to meet, and for which there is a two year timeline for compliance.We will be much Multari: In the case of a unitization project, the oil more strict with new operations, especially if they company — the unit operator — typically pays for are in proximity to residential areas. Our standards abandonment and consolidation. In a case where differentiate between wells that are going to be drill- new development is planned around existing ed in residential areas and those that are going to be facilities, the developer would probably be required drilled in industrial zones. to make the necessary changes. QUESTION: QUESTION: Did you mention that the Division of Oil and Gas Can you explain your suffix zoning to me? I don't helped you determine how many more wells were understand how it works. needed to extract the resource? LAND USE PLANNING IN URBAN OIL-PRODUCING AREAS 33 COMMENTS: QUESTION; Multari: The Division of Oil and Gas advised us on Can you run into problems in an older oil field that the owing: 1) how many wells can be accom- is going into secondary recovery? Is it possible that modated per site; 2) how many sites are necessary; the old wells would not withstand the steam and 3)how big they have to be; and 4)where they should pressure?Could steam escape through the casing of be located. old wells or through small fissures in the ground? Wilkinson:I would Like to point out that although we made the study for this project area, we cannot pro- COMMENTS: vide that level of detail for all cities due to the Wilkinson: When steaming operations were first amount of time and effort involved. Normally, you tried several years ago, things like that sometimes would bring in a consultant to assist you. However, occurred, particularly when steaming very shallow we will provide all the assistance we possibly can. Zones. Today, not only does the Division of Oil and Multari: One can get an idea of the number of wells Gas require that injection be confined to the approv. needed by looking at similar operations close to the ed zone, but the economics of the project prohibit area in question. For example, we went to another area such an inefficient and costly waste of the heat close to this one that was used in a waterflood by a energy. major company. We asked this company what their Multari: I was under the impression that when a spacing was for water and steam injection. We were company wants to do a secondary project requiring then able to calculate the number of wells necessary in some injection, they have to submit their plan to the our planning area, and this gave us a pretty close, Division of Oil and Gas first. Wouldn't your Division usable estimate. Similarly, you can estimate the check to make sure the integrity of the casings were number of sites and their locations using data from such that they could withstand the kind of project other fields with similar projects. For detailed analysis that was being submitted to you? of a particular area, however, a petroleum engineer shouldprobably be consulted. Wilkinson: All secondary recovery and water injec- QUESTION: tionstimulation projects must be submitted to the Division for approval by the State Oil and Gas Are you saying that the existing wells would be Supervisor. Cyclic steaming, because of its tem- allowed to remain? porary and periodic nature, is considered as a heat COMMENT: treatment rather than a waterflood operation. However, steamflooding projects are treated as full- Multari: Existing wells would be allowed to remain. fledged secondary recovery projects and, as such, Mo—new wells would be allowed unless they are drill- are subject to a full-scale review by the geologists ed from islands. Relocating existing wells is very ex- and engineers of the Division. Following the Divi- pensive, and for many of these wells, the value of sion's review, which is extensive, the proposal may the oil they can recover would not justify drilling a be approved subject to a number of conditions, new well. The next case study is about a situation which include regular monitoring of the project to where we tried to encourage the relocation of ex- ensure that no damage to natural resources or the isting wells. environment is occurring. QUESTION: Jose Osuna, City of Long Beach: You are supposed to Are the new wells more productive than the old submit your p an tote i�n� Gas Supervisor. The ones? question is: What does he do with it. Does he approve t, or does he acknowledge that it is appropriate? He COMMENT: should say: "This is an appropriate recovery method, Multari: Yes, if they are part of a secondary recovery and I accept it:' project. if they are primary production wells, they Wilkinson: The State Oil and Gas Supervisor is re- would likely extract no more oil than the other ex- quired by law to determine whether or not any pro- isting primary production wells, and therefore posed secondary recovery project will result in would probably never be drilled.That highlights the damage to life, health, property, or natural underlying problem with relocating these existing resources, including freshwater aquifers. Our Divi- primary production wells, which average only five sion engineers make every effort to determine barrels of oil per day. It may cost hundreds of whether or not a proposed project might have an thousands of dollars to drill a replacement well in a adverse effect upon oil-or gas-producing reservoirs. new location, and the low production of these When a project meets established requirements and primary wells simply cannot justify the expense of a otherwise complies with our regulations, the Super- new well. Only in secondary or other enhanced oil visor then approves the project. It is not within the recovery projects, through which production will scope of the Supervisor's authority to determine or substantially increase, are new wells likely to be designate which secondary recovery method would economically viable in this area. be themost effective or successful. 34 CITY OF HUNTINGTON BEACH;CALIFORNIA DIVISION OF OIL AND GAS QUESTION: ;•) out there, unless aflis put together and second- Has the City ever worked out the cost/benefit ratio ary or tertiary recovery techniques are applied. of purchasing those one-and two-acre oil islands, Wilkinson: I'd like to mention some things about simply holding them as the last two available places making an operation like this a little more palatable. to drill from, and waiting for industry to come When surface rights are separated from the mineral around to that point? rights and the surface owner gets little or no com- pensation, regardless of how much oil is produced, COMMENT: that surface owner has no interest in whether or not Multari: No, we did not analyze the possibility of the the operation lives or dies. The oil company could City purchasing those sites, but I think such a study sweeten the pot in some way, bring the surface would be useful. owner into the picture to a degree by offering a frac- tional share of the oil income. I think that would in- QUESTION: crease cooperation. Is the City primarily concerned with access fora Richard Weaver,City of Santa Fe Springs: In a situa- secondary recovery project? lion wTinowner o t e property has no in- terest in the minerals any more, he may have COMMENTS: nothing coming in from the oil operation. But the old lease has tied up the surface, and development Multari: Yes. The existing wells in primary produc- cannot occur due to the oil encumbrance. This is tion are really not benefiting the City much. As we very crucial to encouraging new development. The saw in the fiscal analysis, they are not going to pro- oil companies are becoming much more duce enough revenue over the long tens to cover cooperative—although we think they could be a lit- the service costs to them. They detract from the tle more cooperative—in releasing superfluous sur- property values of adjacent lots, and they also in- face rights that they no longer need for their opera- hibit the consolidation of parcels for new kinds of tions, We have, on some occasions, even used emi- development. So the primary production wells are nent domain to condemn the surface where there not the ones we are really worried about preserving seems to be no other way to achieve its release in access for. It is the wells in a secondary recovery or Santa Fe Springs. enhanced oil recovery project that we are concerned about. This is where all the benefits occur—increas- QUESTION: ing production, cleaner operations, improved fiscal What is the State's interest in preserving access and benefits. Nevertheless, somebody has made an in, what are they doing? Is there any role that they can vestment in those primary production wells and take to help local government? If the State can take they are private property. The City is sensitive to a role in unitization by drafting legislation, what can that and tries to protect the operators' interests. it do about access? As times change and the land gets more valuable, COMMENTS: someone may come in and start buying those wells because it will be more valuable to build con. Nilkinson: Well, it would be easy if we had a State law dominiums, for example, than to pump five barrels saying that surface access must be retained over every of oil a day. In some places in the City this has oil field. This would be like a resource preserve. But already occurred and wells have been abandoned. before we would even attempt to get legislation like Alan Ha er, State Attorne General's Office: Would that, we would be around to all local governments af- allthe sur ace owners a in avor o removing the oil fected by such a law to see how they are going to feel operations in the case study area? about having the State pre-empt some of their authori- ty. It would certainly make our job easier if we could Multari: Most of them. The surface owners are say- just come to a city and say, "We have got to have two ing, get little or no royalty from the oil operator acres here and two acres over here zoned for oil". It who is producing five barrels a day, so who cares? If I would, in a sense, make the city's job easier because it- can get the oil operations off my lot, I can build a would take some of the pressure off local officials. But million dollar housing project on it:' That is why we the realities of such a law are not so simple, unfor- are concerned about this entire area being built over tunately. and never being able to implement a secondary Alan Hager, State Attorney General's Office: There are recovery program. several possi i hies or preserving access. Maybe the Then too, this is an old field that has been in produc- most intrusive into local government authority and tion for a long time, and it will cost a couple of hun- development interests is the resource preserve. There dred thousand dollars to drill a new well. If you are are precedents to this, such as the Williamson Act, producing five barrels a day, it is going to take a where local governments can contract with property pretty long time to recoup that kind of capital in- owners so communities can keep land in agricultural vestment, especially with the current interest rates. use. As a consequence, the owner gets a property tax So we don't see very many new wells being drilled benefit from agricultural use, although this is not LAND USE PLANNING IN URBAN OIL-PRODUCING AREAS 35 r . r •I necessarily the highest and best use of the land. The area with a multitude of small ownerships and in- owner's property tax is lost for the local government, dependent wells. You would really be tying up so and made up by subvention from the State. much land that you would not be achieving a local good as far as land use is concerned. I feel access Another option is to mandate, through the general preservation should be tied to unitization and state zoning law, that oil 'access be taken into con- secondary recovery. You don't have as much of a sideration when zoning any area overlying an oil problem providing access if you have a unitized field. The mandate would be that the city or county field. must make some provision for retaining surface ac- cess. The local government would determine exact- Multari: You can provide access for the future and it ly how and where that is to be done. The Division of on es not have to be on all the individual sites. Just Oil and Gas could provide information on where the as we have proposed, a few sites can be set aside to oil fields are, how much space for access is needed, provide enough space so that it is technically possi- andwhere. ble to reach those oil pools in the future. I think Multari: That points out something that we have Celia is right: access and unitization must eventual- been worried about in terms of zoning—choosing ly go hand in hand. By analogy, redevelopment law the sites for future access to oil resources. When we says that if you have to consolidate surface areas to are talking about most resources to be protected— promote the public good in revitalizing an area, you sand and gravel resources or prime agricultural can use eminent domain to acquire the holdouts. It land, for example— they are on or close to the sur- seems that the State should strengthen its com- face and there is really little doubt about what area pulsory unitization law to force hold outs to join a has to be retained to protect them or to preserve unit for the public benefit. them. With oil and gas, however, there is significant James Lopes,San Luis Obispo Cou : I don't think flexibility in choosing where the access sites can be our Boara of Supervisors wou 1001 favorably on located, and this raises the question of being iar-es the State totally pre-empting the County, but they bitrary and capricious in zoning certain properties ,Mould probably support a requirement that oil as oil access preserves. We should be establishing resources be considered in planning and zoning. It criteria, related both to the surface and the subsur- would be up to the local jurisdiction to address the face, for evaluating potential access sites. problem of providing access, yet there would be an Todd Collart, Ventura County: There hasn't been element of compulsion in addressing the issue. pressure on local government to look at these issues. Nobody is looking far enough ahead to these Collart: At a recent meeting in our County with problems. We all agree that the problem will come citizens in an anti-oil committee and with represent- about over time, but we are not getting the initiative atives of the oil companies, both parties apparently from the State saying we should address the issue saw the value of having this kind of access require- now. ment as part of the General Plan, but for just the op- posite reasons: one group saw it as a way to preserve Wilkinson: You've put your finger right on the issue. oil, and the other to eliminate or reduce it. I think This is the principal reason for our meeting today. that having such a requirement will mandate that We feel the same way—there are a lot of areas where the issue be addressed, and force local government access problems are not yet as pressing as those and all interested parties to sit down and resolve it, here in Huntington Beach, but they are coming. The instead of allowing it to exacerbate over time until Bakersfield ar:a has experienced these problems there is no good answer. Hopefully, in the rural recently. Kern County prepared a new General Plan counties, we'can get a head start on this. that involved several oil fields and, all at once, it was a potentially serious situation for future oil opera- Wilkinson: That's the point I was making. Obispo and Monterey Counties, new development lions. In the more rural areas such San Luis omew ere down the line you are going to have to and expanding towns are moving out into oil fields. face up to this. The main thing is that you cannot You people have a chance to do something now that wait until it is too late. You have got to do it while Perhaps the City of Huntington Beach wishes it had the space is there. done 20 or 30 years ago. It is an opportunity to ad- Collart: Rural areas not only have more time, dress a potential problem while you still have time also got more ways to innovate because they le t they ve plan properly and carefully. the State did enact legislation that would require local have more available space. The situations we'vecal governments to provide areas surface access to the subsurface oil been discussing in Huntington Beach today are much more constrained. So let's sit down now and resound d how do you think your jurisdictions would plan . . . not 20 years from now when it is all built respond. over. We are suggesting that there be a law simply Celia Weaver,Califomia Coastal Commission: I don't requiring that counties and cities address the oil ac- think we would be in favor o requiring access in an cess problem, not how they must address it. 36 CITY OF HUNTINGTON BEACH:CALIFORNIA DIVISION OF OIL AND GAS CASE STUDY #3 RELOCATING INAPPROPRIATELY SITED OIL FACILITIES Multari: This last case involves a situation in which ple were having a hard time getting to it, and the area wells and related facilities were located on a site that was also ugly and dangerous.The City Council adopted the City Council decided was inappropriate for such policies to:a)phase out existing wells on the ocean side uses. The City developed policies encouraging the of Pacific Coast Highway; b) pursue strategies with the removal of those facilities from that location,while pro- oil companies and the State Parks Department to im- viding alternate locations for them. prove the recreational value and visual quality of the The area in question is part of Bolsa Chica State Beach, site; and c)to approve new wells or recirilling of existing across from the City's downtown area on the ocean side "'ells on the ocean side of Pacific Coast Highway only if of Pacific Coast Highway.Several wells are-strung-out•' all of the following conditions are met: that the along the bluffline between the highway and the ocean, resources are not recoverable from any other onshore with numerous exposed pipelines lying along the bluffs. location or offshore platform; that the site is improved It is not an attractive sight.This area is located near one to become compatible with the recreational uses of the of our prime residential areas, and is a heavily used beach; that public health, safety, and welfare are not public beach. jeopardized;that all adverse environmental impacts are mitigated to the maximum extent feasible; that the net On a half block—about 1.5 acres—on the inland side of overall impact of oil production facilities on visual Pacific Coast Highway is an oil island owned by one of resources is improved; that safe access to the beach is the principal oil companies in the City.There are about provided. 20 wells in this island, directionally drilled under the bluff area into offshore oil pools. The same company In summary,the goals that we were trying to implement were: 1) to remove and bury the pipelines; 2 to im- also owns some of the wells a the beach that are also prove the appearance of the site; 3) to provide safe ac- pools. Another company owns the remainder of the directionally drilled under the shoreline into offshore cess—not trying to get some stairways and ramps down to the only by removing the pipelines, but also by i wells on the beach,and those wells are generally drilled sand; 4) to restrict new oil facilities unless there is ab- solutely no other feasible location; and 5)to encourage This bluff area is State property, but the oil companies relocation of the existing wells by phasing them out have surface leases which allow them to continue their through some kind of an incentive program. activities there for as long as they can produce oil.The pumping units are all visually exposed to the public. The first step was to meet with the two oil companies There is no screening or landscaping, nor is there safe and the State Parks and Recreation Department. We public access from the bluff down to the sand. People were able to develop a concept plan that all parties who want to go to this beach must cross Pacific Coast agreed to. The concept plan called for the eventual Highway, climb over exposed pipelines, slide down the creation of a bike trail along the bluffs, an accessway bluff between the pumping units, and jump down the system, a landscaped blufftop park, and some kind of seawall before they finally get to the sand. So unless screening of the remaining oil facilities. Although we you are a nimble teenager, it is pretty hard to get to that had an approval in concept for the plan at that time, we sand. Old or handicapped people, and families with did not get any commitment for action. No funds from small children were excluded from this beach, and they any party were yet available. were unhappy about it. The City contended that some of these improvements, During the public participation process related to the especially the burial of the exposed pipelines and the preparation of our Local Coastal Program, there were landscaping of the oil facility sites, were clearly the numerous complaints that the community had a beach responsibility of the oil companies. Rather than simply adjacent to its most populous residential area, yet peo- require these improvements by ordinance, the City LAND USE PLANNING IN URBAN OIL-PRODUCING AREAS 37 V tried to get the companies to comply on a voluntary no redrilling of these wells is allowed unless the com- basis through a Memorandum of Understanding pany submits some kind of documentation proving that whereby the companies would make improvements to no other location for drilling is feasible. The City even- the beach in exchange for some benefits from the City, tually passed new ordinances requiring burial of the such as rezoning other inland sites for oil operations or lines and landscaping of the sites. After these became the relaxation of deadlines for compliance with other mandatory, the company complied in a cooperative requirements. manner. We were able to find the necessary incentives for the Another positive event occurred as a result of these ef- company with wells directionally drilled offshore. This forts. The City unsuccessfully applied for an Urban company wanted to use steaming in an offshore pool, Forestry Grant to help landscape the blufftop. When and new wells were needed to do this. What we pro- funds from this source were denied,one of the oil com- posed was to create, through rezoning, an inland loca- panies decided to put up a"matching grant"of its own, tion which would allow the new wells to be drilled if the contributing one dollar for every dollar donated by company met certain standards regarding soundproof- local businesses and citizens. Fund raising went on for ing and landscaping at the new site and also submitted four months, and more than $80,000 was raised. Once a schedule for the eventual phase-out of the wells on the this community response was elicited, there was a beach while burying their exposed pipelines there. snowball effect. The City itself contributed an addi- What we were really saying to them was, "You can put tional $50,000,and the County will add another sizable more wells in this inland area for your project, but you contribution. There are now substantial funds available have to take your wells off the beach over some to help transform parts of this once unsightly area into reasonable time frame, and bury the exposed pipelines an attractive blufftop park. now. Thus, some positive results did occur from our efforts, We were not able to find any incentive to induce the but the overall picture is mixed. Where one of the com- other company to relocate its beach wells or make panies was willing, we were able to find an alternate other improvements on a voluntary basis. Part of the drill location and an accelerated phase-out of that com- problem was that the pools tapped by this company's pany's wells on the beach. With the other company, we wells were so marginal that, in the company's opinion, were not so fortunate.We will allow their existing beach drilling or redrilling from inland locations would never wells to remain, of course, but no expansion on the be profitable.Consequently, the City continues to allow beach will be allowed unless very strict policies are these existing wells to remain on the beach; however, followed. DISCUSSION QUESTION: that we are forging a lot of new ground here. In 1960, the population of Huntington Beach was Multari: One question I would like to discuss is why a about 11,000. Since then, there has been tremen- city would want to enter into voluntary agreement when dous growth in an area where oil operators had been it can just pass a law and force compliance? Our ex- working on their leases for 30 or 35 years. When perience was that of spending a year working on a they started, there wasn't anybody around. A lot of voluntary agreement which was never accepted. We them are still not used to dealing with the restric- thought we would cooperate with the oil companies and tions and regulations placed on oil operations in an provide incentives for them to make improvements, urban environment. I think the process—and I know it without forcing them to do it. In the end, though, a law was a lengthy one and that you ended up passing regu- was passed anyway, lations anyway—did result in some benefits.There was Putting myself in their place, I know that I would not better understanding of strengths and goals. I think we want to tell my boss,"Let's do a project costing one and have established some good working relationships, not a half million dollars, that we don't really have to do.' only with the City and some of the major oil companies, But if I say, "We've got at do it or the City is going ." but with some of the smaller companies as well. For in- pull our permits and shut our wells down", I would prob- stance, i n the workbluffed t park' fund raising, everybody ablycar m case to corporate pitched in and worked together. I think there is going to carry y porate management a little be a lot more of this type of cooperation. It has started better. So is there any reason then why a city should not the ball rolling for public sector/private sector cooper• adopt this attitude from the beginning and just lay the ation here in Huntington Beach, and I think the end law down? result will benefit everybody. COMMENTS: Bud Ti ns, American Petrofina: I think one of the Linda Melton, Aminoil USA: I think there could be a t mgs you can o is combine the rulemaking process number of good results from instigating voluntary, and cooperative agreements. It is important to get the cooperative projects. One thing we have to realize is oil companies in on the ground floor of the rulemaking 38 CITY OF HLINTINGTON BEACH;CALIFORNIA DIV15ION OF OIL AND GAS process. That way, even if som �erning body is because we, [he stz ded up knowing a lot more ultimately going to pass a law, it will have been for- about oilfield problerr��an we previously had. We cer- mulated with information on the technological and tainly have a much better relationship with the economic constraints facing the companies. operators than we did before. I agree with Linda Melton's comment about how increased cooperation Vic Byers, Chevron USA: I think that's a good point for other projects has resulted from our earlier efforts. because in t e course ot our discussions with the City valuable information was shared that was used in mak- JamesSan Luis Obis County: In San Luis ing up the ordinance—what we could live with,what we Obispo County, we ave an app (cation or 200 new oil couldn't live with. In this case, the City then knew what wells which will double the size of an existing field.The was workable and feasible when the time came to for- existing field is old, and was inherited by a company mulate regulations. that is making great strides in cleaning it up. But there are still a number of older wells along a commuter road Terry Dressler, Air Pollution Control District, San Luis through the area. The road is not designated a scenic Obispo County: The Air Resources Board has a new highway by the County, but it is what we call a "scenic program to remodel rules. The local district will road" in one of our plans. The County's policy is to try spearhead it, and representatives from both industry to have the appearance of that road improved, just as and the Board will sit down and hash out issues. We the beachfront here in Huntington Beach was improv. hope that by the time a rule gets to the Board for a vote, ed. Could a requirement that the operator relocate everybody will agree. Now, that doesn't always happen, some of the wells immediately adjacent to the road be but it's a lot better than a regulatory agency sitting tied to approving the request for new wells? down and writing the rule with no communication. In Alan Hager, State Attorne General's Office: It is prob. Huntington Beach's case,did the City Council make the ably a question o egree. eep in min that in aban- oil companies aware at the outset that staff had n later doning a well, you are asking the operator to give up date to get results, if not by voluntary means,then later somethingthat is still producingmoney.The economic through an ordinance? tradeoff must be worthwhile for the operator before it Multari: The Local Coastal Plan policies had been will be done. adopted, and they included policies regarding the pro- Multari: This concludes our workshop. I hope that the vision of safe beach access and pursuing strategies with issues we have discussed today will be useful in your State Parks and Recreation and the oil companies.These were explicit policies. Also, the companies w planning efforts. I think we have seen that although ur- ere ban oil production creates some unique land use issues, aware, through informal channels, that this was impor- tant careful planning can mitigate impacts and increase to the community. compatibility to a great degree. Thank you for your in- 1 think, overall, the process produced beneficial results terest and participation. LAND USE PLANNING IN URBAN OIL-PRODOCING AREAS 39 WORKSHOP PARTICIPANTS Mr. Randall Abbott Mr. Alan Hager Planning Director, Kern County Deputy Attorney General, California Department Mr. Charles Antos of Justice Associate Planner, City of Seal Beach Mr. Dennis Hawkins Mr. Glen Barnhill Associate Planner, Ventura County Principal Planner, Kern County Mr. Luis Hernandez Mr. Randy Bissell Assistant Planner, City of Inglewood Planner, City of Montebello Mr. Richard Hoffman Ms. Diane Border Building and Safety Bureau, City of Long Beach Planner, City of Huntington Beach Ms. Carol Inge Mr. Ed Brannon Planner, City of Huntington Beach Energy and Mineral Resources Engineer, Mr. James Lopes California Division of Oil and Gas Associate Planner, San Luis Obispo County Mr. Mike Burnham Ms. Lorena Margoles Planner, City of Whittier Planner, City of Los Angeles Mr. Vic Byers Mr. William Master Land Development, Chevron USA, Inc. Senior Planner, Santa Barbara County Ms. June Catalano Mr. Michael McKay Director of Community Development, Fire Prevention Specialist, City of City of Laguna Beach Huntington Beach Mr. David Cleveland Mr. M.G. Mefferd Planner, City of Torrance State Oil and Gas Supervisor, California Division Mr. Todd Collart of Oil and Gas Associate Planner, Ventura County Ms. Linda Melton Ms. Jan Denton Manager, Community Affairs, Aminoil USA, Inc. Director, California Department of Conservation Mr. Dick Morton Director of Development Services, Mr. Dave Doerner City of Fullerton Environmental Geologist, Santa Barbara County Mr. Michael Multari Mr. Terry Dressler Planner, City of Huntington Beach Air Pollution Control District, San Luis Obispo County Mr. Jim Orr Administrative Assistant to State Assemblyman Ms. Claudette Dupuy Nolan Frizzelle Planner, City of Huntington Beach Mr. Jose Osuna Mr. Barry Eaton Building and Safety Bureau, City of Long Beach Chief Planner, City of Fullerton Mr. Robert Poteet Ms. Kathleen Faubion Associate Planner, City of Montebello Senior Planner, Santa Barbara County Ms. Ellen Rognas Environmental Coordinator, San Luis Ms. Jeanine Frank Obispo County Planner, City of Huntington Beach Mr. Bill Sheffield Mr. Herb Glasgow Environmental Compliance Officer, Aminoil Planner, City of Los Angeles USA, Inc. LAND USE PLANNING IN URBAN OIL-PRODUCING AREAS 41 _! -• _ j 1 Ms.Christine Shingleton Mr. Hilman Walker Director of Planning and Community District Land Supervisor, Chevron USA. Inc. Development, City of Signal Hill Ms. Celia Weaver Ms. Dana Stoic Energy Analyst, California Coastal Commission Planner, City of Hermosa Beach Mr. Richard Weaver Mr. Bud Tippens Planner, City of Santa Fe Springs American Petrofina, Inc. Mr. E.R. Wilkinson Mr. Ron Tippets Special Representative, California Division of Oil Project Planner, Orange County and Gas Mr. James Tucker Planner. City of Santa Fe Sprinqs 42 CITY OF HUNTINGTON BEACH; CALIFORNIA DIVISION OF OIL AND GAS SELECTED REFERENCES 1. California Oil, Gas, and Geothermal Resources: An Introduction, California Division of Oil and Gas, 1983. 2. Coastal Energy Development: The California Experience, California Coastal Commission, September 1981. 3. Coastal Energy Impact Program, City of Huntington Beach, February, 1980. 4. Huntington Beach Energy Series Report 01: Preserving Surface Access to Underground Oil Reserves in Developed Areas, City of Huntington Beach, February 1981. 5. Huntington Beach Energy Series Report +2: Fiscal Impacts of Oil Operations in Huntington Beach, City of Huntington Beach, March 1981. 6. Huntington Beach Energy Series Report 04: Enhanced Oil Recovery in Hunt- ington Beach, City of Huntington Beach, September 1981. LAND USE PLANNING IN URBAN OIL-PRODUCING AREAS TR31(8-83-DWRR-1 M) 43 May 31, 2004 City of Huntington Beach City Council 2000 Main Street Huntington Beach, CA 92648 RE: Pacific City Dear City Council, g t c Today I made another visit to the Pacific City site in order to report on any new vegetation of note that has appeared since my previous visit on April 26, 2004. The bad- faith vegetation clearing work started by the applicant on Friday, May 28i°was still in progress but had not yet reached the area where I do most of my vegetation surveying. The most significant change over the past month was the appearance of seaside heliotrope(Heliotropium curassavicum) in plentiful quantities halfway between the entrance to Pacific Mobile Home Park and Pacific View Ave. Seaside heliotrope is an obligate (OBL) wetland indicator species, which means that 99% or more of locations with this species are considered to be wetlands. I have seen this high-value wetland indicator species on multiple previous visits to the Pacific City site, and yet this species is not listed in the EIR as being present (except as noted in my DEIR comment letter). See below for a picture of one of today's white heliotrope blooms: �"� �3• '*!e�O}. �„?tom- Ka. Ay i Two new plant species were noted today: • Italian ryegrass (Lolium perenne ssp. multii lorwn), a facultative (FAC) wetland indicator species, was observed growing in the northeastern portion of the property adjacent to Huntington St. • Tat-weed (Hemil,onia sp.) was observed growing approximately opposite of the entrance to Pacific Mobile Home Park. The plants are too far away from my observation point on Huntington St. for me to make an exact species determination. I do not think this is the special-status southern tarplant (Hemizonia porrvi s.sp. australis) that is found at Bolsa Chica. However, the applicant's biological consultants should probably make another site visit to pin down the exact species. The EIR should not be certified because it still does not acknowledge the presence of certain wetland indicator vegetation species that I have seen: • Alkali mallow (Malvella leprosa, FAC)— large quantities • Italian ryegrass (Lolimn perenne ssp. multiflorum, FAC) —scattered individuals • Seaside heliotrope (Heliotropium curassavicum, OBL) - plentiful • Spreading alkaliweed (Cressa trikvillensis, FACW) — tentative sighting of several large aggregations • Tree tobacco (Nicotiana Slauca, FAC) —scattered individuals There are 17 wetland indicator vegetation species present on the property as documented in the EIR and by my site visits. I believe a strong case exists by virtue of the vegetation alone that portions of the site should be considered to be wetlands (albeit highly degraded). See attached for my previous post-EIR vegetation surveys. City LCP policies and Section 30233 of the Coastal Act forbid the filling of wetlands for projects such as Pacific City. If this project is allowed to move forward, the CUP should be modified to mitigate for the loss of the highly degraded natural wetlands by requiring the applicant to incorporate the progressive water quality BMP of constructing one or more bio-swales or mini-wetlands as part of the overall WQMP for treating the project's urban runoff. Yours truly, Mzk DI gzvl$�/ Mark D. Bixby 17451 Hillgate Ln Huntington Beach, CA 92649-4707 714-625-0876 mark@bixby.org Attachments April 26, 2004 City of Huntington Beach Department of Planning 2000 Main Street Huntington Beach, CA 92648 RE: Pacific City Dear Planning Commission and staff, 1 wanted to update you with the findings from my Pacific City site visit on April 24, 2004. There was noticeably more vegetation present on the site compared to my previous visit on March 14, 2004. Vegetation species that were present last month had become more numerous and lush. Perhaps the most striking difference was the large quantities of curved sicklegrass (Parapholis incurva,OBL) that 1 observed growing adjacent to the southern half of Huntington Street. Here is a photo of one such specimen located at the edge of one of the remediation depressions: r .1 Additional vegetation species observed were: • Fivehom smotherweed (Bassia hyssopifolia, FAC)—moderate to large quantities adjacent to the entire length of Huntington Street. • Alkali mallow (Malvella leprosa, FAC)—observed in large quantities in the same general locations as on my previous visit. • Salt sandspurry (Spergularia marina, OBL)— moderate quantities in the same remediation depression as on my previous visit, with additional areas scattered along the southern portion of Huntington Street. • Spreading alkaliweed (Cressy imwillensis, FACW)—tentative sighting of several large aggregations scattered along the southern portion of Huntington Street. This is a new species that I have not previously seen at this site. • Annual rabbitsfoot grass (Mypogon monspeliensis. FACW+) —a few scattered individuals. • Tree tobacco (Nicotiana glauca, FAC) —at the edge of the deep remediation pit at the intersection of PCH and Huntington Street. This is a new species that 1 have not previously seen at this site. All of the species mentioned in this report are also enjoying their annual springtime growth season at the Shea Parkside site at Bolsa Chica, which is not surprising given the coastal and near-coastal locations of both sites. Yours truly, n, ;a Mark D. Bixby 17451 Hillgate Ln Huntington Beach, CA 92649-4707 714-625-0876 mark@bixby.org March 21.2004 City of Huntington Beach Department of Planning 2000 Main Street Huntington Beach, CA 92648 RE: Pacific City Dear Planning Commission and staff, 1 wanted to update you with the findings from my most recent Pacific City site visits. On March 14, 2004, 1 conducted a vegetation survey of the eastern portion of the property adjacent to Huntington Ave. Vegetation was fairly sparse, with the biggest change since my November 28, 2003 site being the presence of moderate amounts of Erodium sp. (common name 'filaree"or"stork's bill"), a non-wetland plant. I also observed a shallow pond (and associated vegetation) measuring approximately 8 feet by 10 feet a little bit north of the intersection of Huntington & Pacific View as shown in the photo below: Ad- 711 _ = On March 21. 2004, 1 made another site visit to check to see if the pond was still present, and it was as shown in the photo below: s � s The vegetation growing in and around this pond had multiplied since my previous visit. The following close-up shot of the plants indicates that the species may possibly be Spergularia marina (common name "salt sandspurry"), an obligate wetland indicator plant(found in wetlands 99% of the time): Please note that this pond has persisted for at least 7 days, the threshold the Coastal Commission uses to make a wetlands determination based on hydrology alone. Given that the last time any rain fell in Huntington Beach was March 2, 2004, it seems likely that this particular pond is being fed by groundwater. The site is currently in a highly disturbed state, with soil remediation in progress. It is difficult to tell what the true grade of the property is at the location of this pond. I estimate that the surface of the water is approximately 2 or 3 feet below the current ground surface. Regulatory bodies talk about "consecutive days of ponding" as a wetland indicator parameter, but the actual standard is soil saturation to within 12 inches below ground surface. If the Pacific City site was level at its true grade, how far below ground surface would soil saturation be found? If the we grade was restored and the pond was covered over, moisture would no longer be lost due to evaporation via direct contact with the air. Increased moisture would then be available and be expected to migrate upwards in the soil a bit due to capillary action. So how high would the moisture migrate? I do not know since I am not a soils or hydrology expert. But it seems likely that the saturation line would be closer to the ground surface than the current 2-3 foot level. If the true grade of the pending area is 6 inches less than today's adjacent grade, and if the saturation line rises by 6 inches, then this portion of the site may be meeting the 12 inches below ground surface wetland standard. I strongly urge the Planning Commission to give close scrutiny to this project which is being proposed for one of the lowest areas of the city in combination with one of the highest water tables. As I explained in my EIR comment letter, 1 do not believe this project to date has adequately explored these wetland issues or offered meaningful mitigation in terms of incorporating bio-swates and other more natural means of improving both aesthetics and runoff water quality. Yours truly, Ac4 D,Mark D. Bixby 17451 Hillgate Ln Huntington Beach, CA 926494707 714-625-0876 mark@bixby.org PS: During my site visit today there was a noticeable petrochemical odor plainly evident at the Huntington Ave boundary fence downwind from the soil remediation zone. 1 hope that the Planning Commission gives due consideration to the soil contamination and cleanup concerns of the Pacific City Action Coalition and other residents who live adjacent to the property. project but also benefit the larger downtown area. The current design calls for the majority of the runoff from the site to be directed through stromdrains to the beach at first street. Since the beach is the economic engine of the city it is paramount that it be protected from any kind of damage. The applicant had requested that they be allowed to build a treatment area at the base of first street that would treat some stormwater runoff from the project along with having the ability to treat runoff from other parts of the downtown a ua area using state of the art technology. However the city has instead instructed the applicant to eliminate the treatment area and send the �. 1 untreated runoff to the beach until some unknown time (early estimates are five years from now) when the cit y plans to divert the first street stormdrain - ` into the trunk sewer line under PCH. After the applicant expressed concerns regarding this option the city suggested they run the dry weather runoff from the project area uphill to the Atlanta St. sewer where it would be sent off to Z o treatment. This leaves the stormwater from the project untreated and the rest of downtown with no water quality benefit from the proposed project. It is no secret that runoff from the downtown area is a problem. Why the city would pass up the opportunity to develop an integrated plan utilizing the development occurring in the downtown area to address the known water quality issues in the area is a mystery. We all are aware of the fiscal issues that the city is dealing with right now, however the redevelopment agency has money and this project is in the redevelopment area. There is a small parcel of land just behind the Dairy Queen that is owned by the city that could be used to develop a treatment area for runoff from the proposed project along with the downtown area. The applicant has expressed their willingness to fund a fair portion of the treatment facility if the city will allow it. The city, however is only allowing the applicant to do the bare minimum required under the law instead of looking out of the box to a system that could benefit the entire downtown area. If this project was being built in Brea the city's stand would be understandable, but to pass up the option to get more protection for the most visited and visible part of the city by refusing to look at alternatives that are not part of the everyday procedure is inexcusable. With the cumulative impacts of the recent and proposed development in the area, the city must make every effort to protect our beach. The planning commission should direct the staff to take another look at the alternatives suggested by the applicant considering creative ways the city could participate in protecting the beach and our water quality. 2. Erosion Issues: In previous comments O.C. Coastkeeper brought up the issue of potential beach erosion from the project. The project call for flows from the project exceeding 20 cfs to be stored in a cistern that will store the runoff from up to 3/4 in of rain and discharge it to the beach while not exceeding the 20 cfs maximum of the current configuration. However the EIR does not address the impact of the extended period of time that the runoff will be rv\\ss\ � l Pam — �� Scr� �Q h�.ee )� � G ��O�� `� c\ \ 1 Fikes, Cathy From: Khov-James, Mindy [KhovJamesM@metro.net] Sent: Thursday, June 03, 2004 4:14 PM To: cfikes@surfcity-hb.org' Subject: Pacific City support I'm in support of the Pacific City and I hope that the city approves this project. 0 b t C_ C I J T. v t.. 4/0 � - 1 / ^ /�/�T� (?OMtJLo4J/ Cvl--7?04)J Pa_e 1 of I Fikes, Cathy From: PacSale513@aol.com Sent: Thursday, June 03, 2004 4:20 PM To: cfikes@surfcity-hb.org Subject: (no subject) Huntington Beach City Council. As a resident of of Huntington Beach for nearly 35 years. I would like to encourage the city council and planning commission to approve the Pacific City project The benefits are many and inlcude the economic impact plus very wise use of extremely valuable land. As the owner of three properties in Huntington Beach(one in downtown HB). With the proper parking, environmental, and traffic plans, this can be the "showplace of Huntington Beach". Enough said: An overwhelming "YES" is how I vote. Thank you, Charlie Wilson 6/3/2004 a� Fikes, Cathy From: Janice Lynne [risktkrl6@msn.com] Sent: Thursday, June 03, 2004 4:29 PM To: cfikes@surfcity-hb.org we are really looking forward to the project, not necessacarily the noise and dirt and traffic, but the completion of it, as we would love to move in to it, it appears to be a beautiful and well planned project. Pablo and Janice Ortiz 0 c c_ J TJ fV V N ' 1 0 Email Page 1 of 1 Fikes, Cathy From: Lorinda McClure [lorinda.mcclurea@att.net] Sent: Thursday, June 03, 2004 4:35 PM To: makes®surfcity-hb.org Subject: We want Pacific City in Our City Lorincbn F. Med"re I ! .11. ty mce WA AnEmail:i loanda,mccl L'mad: lurinda.mcclurr(gett.net Website: ochomemfo.cum Hello, My husband and I have been residents in Huntington Beach for a few years. We love Huntington but there is desperately a need for a environment like Pacific City... With the homes, restaurants, shops, walking areas. What could be better for our city. We are very much in favor of PACIFIC CITY....YOU HAVE BOTH OF OUR Votes If you need any confirmation we would be happy to assist. Our direct line is 714-960-5200. Thank You Tom and Lorinda McClure Real Estate Executive Star Real Estate 19"0 Golden West Street Huntington Beach CA 92648 x Ofce: 714-500-3300 S �_ Fax: 714-3744296 c Mobile:714-299-6688 z t V1i IV W n N D 6/3/2004 Pa_c 1 of l Fikes, Cathy From: J. Edwards [Interstar@interstar.info] Sent: Thursday, June 03, 2004 4:30 PM To: cfikes@surfcity-hb.org Subject: Pacific City! HB City Council Hi Folks, Good to hear you are taking a look again at the Pacific City project... As a close-by neighbor, we like the project and hope you can give your support. It will be great for our community. Joseph Edwards & Cindy King 315 Huntington St, HB 92468 949-442-4349 o - c z i J T tV w. C* N n 6/3/2004 1 Page I of I Fikes, Cathy From: Jennifer Wong Dwong@strada properties.com] Sent: Thursday. June 03, 2004 5.11 PM To: cfikes@surfcity-hb.org Subject: Pacific Cities Hello- Just wanted to show support the new project of Pacific Cities in Huntington Beach, as it will help out with the much need for housing and would create revenue for the city of Huntington Beach and jobs for the community with its retail and new homes. Thanks, Jennifer Wong 949.721.5426 Direct Line 949.640.3610 Fax T 140 Newport Center Drive, Suite 100 c Newport Beach, CA 92660 t c z i J - T FZ W 0 3 2004 Page I of 1 Fakes, Cathy From: William Blum [bblum@socal.rr.com] Sent: Thursday, June 03, 2004 6:06 PM To: cfikes@surfcity-hb.org Subject: Pacific City Dear Sir/Madam I am favor of the Pacific City please let it pass (we need the revenue) William & Bengie Blum 6411 Silent Harbor Dr Huntington Beach Gi3.2004 Page 1 of 1 Fikes, Cathy From: Mannyschultz@aol.com Sent: Thursday, June 03, 2004 7:21 PM To: cfikes@surfcity-hb.org Subject: Pacific City Dear City Councel Members, My wife andl for approving the Pacific City development. It will add beauty, bring visitors and add money to the city budget. Sincerely yours, Manfred and Elizabeth Schultz 7881 Seawall Circle Huntington Beach, Ca. 92648 e e - r - L = C Z N -- W r 6/3/2004 Page I of l Fikes, Cathy From: Hau Do Idohau@yahoo.comj Sent: Thursday, June 03, 2004 8:24 PM To: cfikes@surfcity-hb.org Subject: SUPPORT FOR PACIFIC CITY PROJECT. I am supporting the PACIFIC CITY projerct. JOHN-PAUL DO, ESQ., dohau(;gyahoo.com Do you Yahoo!? Friends. Fun Try the all-new Yahoo! Messenger ti r - L ' C Z J fV lw. n w � 6/4/2004 G Page I of I Fikes, Cathy From: Seni Lawi [senilawi@yahoo.com] Sent: Thursday, June 03, 2004 8:34 PM To: makes@surfcity-hb.org Subject: pacific city I believe this is a great project and 1 am looking forward to lease a retail space for this project. Do you Yahool? Friends. Fun. Try the all-new Yahoo! Messenger t c z i J Z IV W ' 6/4/2004 0- Page I of 1 Fikes, Cathy From: Michelle H Imhardy@socal rr com] Sent: Thursday, June 03, 2004 8:34 PM To: cfikes@surfcity-hb.org Subject: Pacific City Please approve Pacific City! It would add to the downtown area tremendously. As a teacher and homeowner in H8, I fully support this development. Michelle Hardy 0 c c L C 1 JT l IV � L 6/4/2004 �/ Page I of I Fikes, Cathy From: Suzanne Christy [adreamcometruesc@msn.com] Sent: Thursday, June 03, 2004 9 39 PM To: cfikes@surfcity-hb.org Subject: Pacific City To Whom It May Concern: I do not understand why this project has not been approved. Obviously it will bring an enormous amount of money into our city as well as increase the beauty of the downtown area. Please don't delay in approving this. Thank you, Suzanne Christy-Goldberg 5142 Warner #211 92649 c z JT � - U - ` n N 6/4/2004 Page 1 of' ] Fikes, Cathy From: Haidanny@aol.com Sent: Thursday, June 03, 2004 9:45 PM To: cfikes@surfcity-hb.org Cc: info@pacificcityhb.com Subject: support the pacific city building Dear Sir/Madam My Name Frank Nguyen , we live at 6411 Fairwind Cir, Huntington Beach, we would like to support the building of pacific city in HB. With this new building the city will have more benefits and make city more attractive and beautiful. I hope the coucil of the city will approve the building of pacific city. Thank you, Frank Nguyen 6411 Fauwind Cir, Huntington Beach, Ca. 92648 1714 636 8166 = c i= - t '. c z J 1V 4. c- 6/4/2004 _, Page I of I Fikes, Cathy From: Mandie Bernthal imandiebernthal@socal.rr.comj Sent: Thursday, June 03, 2004 9 54 PM To: cfikes@surfcity-hb org Subject: pacific city I am writing to show my support for the building of pacific city in downtown Huntington beach. Yours sincerely Mandie Bernthal. 0 o - L C= I J " Z C > 6/4/2004 ��, Page I of 1 Fikes, Cathy From: David [dcal@att.net) Sent: Thursday, June 03, 2004 10 25 PM To: cfikes@surfcity-hb org Subject: support I support the concept of Pacific City. Unable to make the meeting.david Ascher x 0 o - L _ c J - T ' N 6/4/2004 AT Page 1 of 1 Fikes, Cathy From: Don Williams[883xlh@sbcglobal.net] Sent: Thursday, June 03, 2004 10:38 PM To: cfikes@surfcity-hb.org Subject: Please support Pacific City As a former resident and Homeowner in Huntington Beach, I would like to ask you to approve the proposal for Pacific City. 1 am currently looking for a property to buy in Huntington Beach, and was thrilled when 1 saw the sign for the potential development. We need more developments like this one--I hope to be one of the first residents! g - z i 'n; IV W n � D 6/4/2004 �� Page 1 of 1 Fikes, Cathy From: PHILNCAT@aol.com Sent: Friday, June 04, 2004 4:47 AM To: cfikes@surfcity-hb.org Subject: Pacific City Project I will be unable to attend the next City Council meeting but would like to express my support for the Pacific City Project. I have been watching recent meetings on the television and think that you are not hearing from the general public. I live four blocks from the area and think that it would be a great addition to our downtown. Cathleen Hunter o - 0 o - C Z - -.A i y W r D 6/4/2004 7 Fikes, Cathy From: Thomas & Joan Smith boantomsmith@hotmail.com] Sent: Friday, June 04, 2004 6:41 AM To: cfikes@surfcity-hb.org Subject: Pacific City - YES! PLEASE support "Pacific City" ! (But make certain there are some required ' low income' residential units available to us regular folks who make up the majority of people who frequent the area but can't afford several hundreds of thousands of dollars for a condo! ! ) Sincerely, The SMITH family Is your PC infected? Get a FREE online computer virus scan from McAfeem Security. http://clinic.mcafee.com/clinic/ibuy/campaign.asp?cid=3963 g -- L c z N - W n � a 1 Fikes, Cathy From: Inna Lokshin (ilokshin1@yahoo.com) Sent: Friday, June 04, 2004 7:30 AM To: cfikes@surfcity-hb.org Subject: in support of Pacific City We would like to express our support for the Pacific City development . We believe it will enrich our town by bringing more revenues . And it looks so beautiful ! Anatole and Inna Lokshin, 214 7th St . , H.B. Do you Yahoo! ? Friends. Fun. Try the all-new Yahoo! Messenger. http://messenger.yahoo.com/ ti 0 0 c i 1 Fikes, Cathy From: Kathy Liscom [khscom@yahoo comj Sent: Friday, June 04, 2004 7:50 AM To: cfikes@surfcity-hb.org Subject: Pacific City On June 7, 2004 you will be Hearing discussions on approving or denying Pacific City. I would like to show my support for this project . It is with great enthusiasm that I am actively interested in living in such a wonderful environment I strongly endorse the Pacific City Plan. 0 e - t L - C „ Z Do you Yahoo!? i Friends. Fun. Try the all-new Yahoo! Messenger. -J ' http://messenger.yahoo.com/ N - lw. > v 1 020. Page I of I Fikes, Cathy From: DAVE LARSON [bestarm@yahoo.comj Sent: Friday, June 04, 2004 8:51 AM To: makes@surfcity-hb.org Subject: Pacific City—Yes 1 cannot attend the meeting on June 7th. However, I favor the plan for the development of Pacific City. Dave Larson Do you Yahoo!? Friends. Fun. Try the all-new Yahoo! Messenger x g z _J _ V r1 6/4/2004 Page 1 of 1 Fikes, Cathy From: ROSESUMER@aol com Sent: Friday, June 04, 2004 9 32 AM To: cfikes@surfcity-hb.org Subject: support for Pacific City My husband and I are homeowners in the city of Huntington Beach and can't wait for the Pacific City project to be complete. We think this project will bring great things for the city and look forward to many years of enjoying the amenities. Pacific City has our 100% support. Thank you. Nicole &Alexander Frank 6405 Dogwood Drive Huntington Beach, CA 92648 714-374-8715 0 e c L _ C 2 1 J Z' N W r� rl � 6/4/2004 Page I of I Fikes, Cathy From: HCSDALLEN@aol.com Sent: Friday, June 04, 2004 9:55 AM To: cfikes@surfcity-hb org Subject: June 7th City Council Hearing/ Pacific City My name is Denise Allen, I am a 15 year resident of Huntington Beach and I am very much in favor of the Pacific City project. Unfortunately I cannot attend the June 7th City Council Hearing, however. I would appreciate my opinion to be considered. Thank you, Denise Allen N C - T . NV W c n 6/4/2004 13 Page 1 of 1 Fikes, Cathy From: Nadia Atalah [nadial 1 @socal.rr.com] Sent: Friday, June 04, 2004 10:08 AM To: cfikes@surfcity-hb.org Subject: We are looking forward Our names are: Gordon and Nadia Doddridge and we live in Huntington Beach We are looking forward very much to see the beautiful project of Pacific City being completed. We believe very strongly that it will be so beautiful and will enhance the City of Huntington Beach. We also believe that many, many city residents believe the same way. Please make this project happen. Gordon and Nadia Doddridge 6252 Seabourne Drive Huntington Beach, CA 92648 (714)960-9870 e - t c z t JT l - N LI n Cn 6/4/2004 02 Page I of I Fikes, Cathy From: Robert Evans [robertevans@worldnet.att net] Sent: Friday, June 04, 2004 2:56 PM To: cfikes@surfcity-hb.org Subject: Pacific City I think that Pacific City is an excellent project for Huntington Beach, and will greatly enhance our city. Robert Evans, 6921 Garden Circle, HB, 92648 ti 0 e - t- L C Z I J T l r IN - l. � �n 6/4/2004 Page 1 of 1 Fikes, Cathy From: jfp photography Dfp@jfpphotography.comj Sent: Friday, June 04, 2004 3:00 PM To: cfikes@surfcity-hb.org Subject: support I support Pacific City x �v r_ John Partridge 562-277-4480 www.jfpphotography.com = c- J 2-, T c,_ '.T �M1i n 6/4/2004 �� Page I of 1 Fikes, Cathy From: JakmoslQaol.com Sent: Friday, June 04, 2004 10:47 AM To: cfikes@surfcity-hb.org Subject: Pacific City Please approve all measures for this great project, Pacific City. It will enhance our city and beautify PCH. Jack Mossler (local resident) Page 1 of i Fikes, Cathy From: Gary Curran [garyc@sterlingbmw.com] Sent: Friday, June 04, 2004 1:11 PM To: cfikes@surfcity-hb.org Subject: pacific city h.b. dear h.b. city council i am very much in suport of the proposed development pacific city i truly believe it will add needed housing and provide jobs, recreation and greater pride to the residents of h.b. not to mention tax revenue. h.b. is the jewel of o.c. coast line and many people including myself feel the need to bring the standard of excellence in not only housing, but recreation which is the nature and certainly the soul of a beach community. i believe that everyone will benefit as a result of pacific city gary f.curran 0 o C c L 1 J n- - iV '- l n T T 6/4/2004 p Fikes, Cathy From: Eric Gut [EricGut@SoCal.rr.com] Sent: Friday, June 04, 2004 12:45 PM To: dikes@surfcity-hb.org City Council, I am interested in having the oppertunity to purchase a condo in the Pacific City development and urge your support of the project. Thank You, Eric Gut ZE o - t- _ C- Z N - 4 r 1 C Paer I of I Fikes, Cathy From: PSCLOUNHB@aol com Sent: Friday, June 04, 2004 4 50 PM To: cfikes@surfcity-hb.org Subject: Pacific City We are longtime residentsof Huntington Beach and unable to attend the meeting set for June 7th regarding Pacific City.We would like to go on record that we support this very important and overdue project. Please consider this a vote if favor of the development of this property. Bill & Paulette Haggerty 6641 Brentwood Drive Huntington Beach CA 92648 e o - t J N 4 r - 0 7 2004 3� , Page 1 of I Fikes, Cathy From: NMCCOLLINS@aol.com Sent: Friday, June 04, 2004 5:30 PM To: cfikes@surfcity-hb.org Subject: Pacific City Development I will be out of town during Monday's meeting on the above project. however, I just want to send a quick note to indicate my support. I believe this project will continue the (long) effort to improve the downtown and overall environment of Huntington Beach. As a 23 year resident I'd like to see us to continue to develop the downtown area in an upscale manner. Jack Collins 6731 Shetland Circle HB 92648 z o o _ L C Z N - ln n 6/4/2004 31. Fikes, Cathy From Yen Lee [yenlee3382@hotmad corn] Sent: Saturday, June 05, 2004 7 02 AM To cfikes@surfcity-hb.org Subject: re: Meeting 6/7/04 Dear Sir, We are supporting the development of Pacific City. We can't be at the meeting on June 7, 2004 . Please let us know what else we could do to support this plan. thank you. Yen & Bao Le 7085 Rockaway Ct . Huntington Beach, Ca. 92648 (713) 841-4843 Get fast, reliable Internet access with MSN 9 Dial-up - now 3 months FREE! http://join.msn.click-url .com/go/onm00200361ave/direct/ol/ 0 e - c L C I J Z N 1 ,32. Pa L!c t of t Fikes, Cathy From: Danny Palumbo [dannypalumbo@cox.net] Sent: Saturday, June 05, 2004 8:54 AM To: cfikes@surfcity-hb.org Subject: Pacific City in Huntington Beach I will not be able to make the hearing on Monday due to work but I do want to express my approval for this community hopefully coming to Huntington Beach. Thank you, Danny Palumbo S rti e - o c- C 1 J " Ti - fV m ' 6/7/2004 3� Page I of I Fikes, Cathy From: Art& Elaine Rosen ires0agf7@verizon.net] Sent: Sunday, June 06, 2004 9:50 AM To: cfikes@surfcity-hb.org Subject: Pacific City Development Dear City Council Members, We would like to show our support for the development of Pacific City. We believe it would be a benefit to the city of Huntington Beach, particularly to the downtown area. Having the type of retail and commercial additions that Pacific City is offering our area would be greatly appreciated and utilized by the residents of our downtown community. We urge you to allow Pacific City plans to go forward. Thank you, c Arthur and Elaine Rosen `c 514 9th Street ` H.B. 92648 J (714)969-0194 T: N l.. r T 6i7,'2004 �� Page I of I Fikes, Cathy From: Chieu Trankiem [ctrankiem@msn.com] Sent: Sunday, June 06, 2004 3:42 PM To: makes®surfcity-hb.org Subject: The TRANKIEM's are support PacificcityHB To: City Council, This Email is showing our support Pacific City In Hungtington Beach. This City will be a perfect place for us to be there & will be the good benefits for the City of Huntington Beach, Please approve the plan. The Trankiem family 4 Royal Tern Lane Aliso Viejo CA 92656 c - c L C I J Z 1. 6/7/2004 Fikes, Cathy From: derick mitre (dbmitre@hotmail.comj Sant: Sunday, June 06, 2004 5 17 PM To: cfikes@surfcity-hb.org Subject: pacific city project I recently purchased property at the sea cove community and was very happy to here that they where going to develop the property where pacific city is asking the city for the ok to do so. I think it would be a ashame not to do something with such a nice piece of property. I belive the people at pacific city would be a very good choice to have someone with so much experince in this area of devlopment Is your PC infected? Get a FREE online computer virus scan from McAfeem Security. http://clinic.mcafee .com/clinic/ibuy/campaign.asp?cid=3963 o o - c i J L -J u 1 3L Page 1 of 1 Fikes, Cathy From: Jeremy Beal a.beal®sbcglobal.netj Sent: Sunday, June 06, 2004 9:59 PM To: cfikes®surfcity-hb.org Subject: Pacific City Dear Huntington Beach City Council Members: I am writing to express my strong support for the Pacific City housing project. My wife was raised in Huntington Beach, and would love to return. I have exhaustively reviewed the Pacific City web site, and I am overwhelmed by the amount of effort that has gone into planning, design, aesthetics, and environmental issues. My family would relish the opportunity to live in such a community so close to the beach, where my wife was raised. Please consider strongly approving the current proposal. Thank you, Jeremy E. Beal a c i J - 6/7/2004 3 3, Page I of I Fikes, Cathy From: Nancy Glass [nancyglass@earthIink net] Sent: Monday, June 07, 2004 9:40 AM To: cfikes@surfcity-hb.org Subject: Pacific City As a long time resident and business owner in Huntington Beach I am in favor of the Pacific City Project. Nancy Glass Resident and Business Owner 0 o c- C 1 IV '- lw n J I. 0 7 2004 ,3�, Page 1 of 1 Fikes, Cathy From: joymichael@msn.com Sent: Monday, June 07, 2004 10:39 AM To: cfikes@surfcity-hb.org Subject: pacific city Please vote to approve the Pacific City project. _ wr r o Michael Doyle c c „ J T N 4 n J T. 6/7/2004 Page 1 of 1 Fakes, Cathy From: Kelly McClain [KellyMcClain@cox.net[ Sent: Monday, June 07, 2004 11 07 AM To: makes@surfcity-hb.org Subject: City Council Meeting I am unable to attend the city council hearing for tonight regarding Pacific City. I would like to support the project for Pacific City. Huntington Beach needs this-it's well thought out and maintains the beauty of the beach. I've never considered living in Huntington Beach, but after seeing the plans for PC, it seems very exciting. Please approve Pacific City. This would only benefit Huntington Beach. Thank You, Kelly 0 c L I J Z N lw J 2, 6/7/2004 �5(d Page i of l Fikes, Cathy From: Chris Willis Icwillis1974@yahoo.com] Sent: Monday, June 07, 2004 11:12 AM To: dikes@surfcity-hb.org Subject: support of P.C. l am in full support of Pacific City coming to our community of Huntington Beach. Chris Willis Do You Yahoo!? Tired of spam? Yahoo! Mail has the best spam protection around http://maii.yahoo.com J ,1 1 6/7/2004 Past I of' I Fikes, Cathy From: Michael EiJbert [meilbert@socal.rr.com] Sent: Monday, June 07, 2004 11:19 AM To: cfikes@surfcity-hb.org Subject: Support for Pacific City As a homeowner in the Downtown area, I am very much in support of the further development of the downtown area. Please take my note as an individual vote of support to proceed with this project. .v e .c - L C 1 J Z N l J - 6/7/2004 Fikes, Cathy From: KEVIN SCOTT [otterscott@hotmail.com] Sent: Monday, June 07, 2004 11:21 AM To: cfikes@surfcity-hb.org Subject: Support for Pacific City As a local resident of Huntington Beach (Pier Colony) I would like to voice my support of Pacific City. Huntington Beach is poised to be THE premier beach community in California. With recent addictions such as the Hyatt and upgrades to the boardwalk, Huntington is already on it 's way to being the #1 beach resort in California. By adding Pacific City and The Strand, we' ll be #1 . This will mean a thriving economy allowing for plenty of small and large business opportunities not to mention tax benefits for the city. Please consider support from local residents. Thank you. --Kevin Scott Stop worrying about overloading your inbox - get MSN Hotmail Extra Storage! http://join.msn.click-url .com/go/onm00200362ave/direct/ol/ 0 o c i _J t 1 Fikes, Cathy From: Kathy_Ryder@URSCorp.com Sent: Monday, June 07, 2004 11:22 AM To: cfikes@surfcity-hb.org Subject: Pacific City I am writing to indicate support for the approval of the Pacific City Development at tonight 's council meeting. My husband and I have been Huntington Beach residents for more than 30 years. we are quite excited about the recent development in the downtown area. Pacifc City would be a major addition. John and Kathleen Ryder 10141 Edy Drive Huntington Beach, Ca. 92646 714 968 2545 jryder0927@aol .com x 0 o - c - t_ C .. I J fV -J - 1 Page 1 of 1 Fikes, Cathy From: MachineRebuild@aol.com Sent: Monday, June 07, 2004 11:32 AM To: cfkes@surfcity-hb org Subject: Pacific City I cosider Hunrington Beach not only a great place to live but also to invest. The city is doing a gral job of making our city one of the best in the nation that is why I'm supporting 100% this project Pacific City I feel we can all benefit from this project. george Villano 714 969 8891 or 714 596 5914 0 7 2004 Page 1 of I Fikes, Cathy From: Beverly Reilly [bareilly@hotmail.com] Sent: Monday, June 07. 2004 11:34 AM To: cfikes@surfcity-hb.org I am a long-time resident of Huntington Beach, and I support the Pacific City concept. Beverly Reilly 0 c z i J rV 4 _ 6/7/2004 C Page 1 of 1 Fikes, Cathy From: InsureGal@aol.com Sent: Monday, June 07, 2004 11:43 AM To: cfikes@surfcity-hb.org Subject: We cannot attend tonight's meeting, but we support Pacific City Inasmuch as the Hyatt and Hilton complexes have added to our beautiful waterfront, we think Pacific City will tie the two together beautifully. Thanks Dee Dee Brooks Surf City Insurance.com g t c _ z J IV ro Page 1 of 1 Fikes, Cathy From: Fabian, Jill @ Anaheim [Jill.Fabian@cbre.com) Sent: Monday, June 07, 2004 11:51 AM To: 'cfikes@surfcity-hb.org' Cc: 'info@pacificcityhb.com' Subject: Pacific City I am not sure that I can make the City Council meeting tonight but I am definitely in favor of this development. The renderings show it as a great looking Village that reminds me of Europe and I think it would enhance that corner at First and Pacific Coast Highway which has been such an eyesore for such a long time. I think you need to give them approval immediately because we tear down old businesses and then you make everyone wait for years before you continue with something new, let's stop dragging our feet. To my way of thinking the city is losing tax dollars by letting empty pieces of land just sit waiting for approval from the city council which most of you probably were not in office when this all started, we need to get things done quicker. I have been a resident of Huntington Beach since 1969 and I have seen many changes and I do not think anyone loves this city as much as I do, my daughter was born and raised in the city is now a teacher and homeowner in HB. I originally did not want any changes to my wonderful city but I have to say when I walk on the bike path along the beach I like the hotels and all the redevelopment but if you would have asked me to approve something fifteen years ago I would have said no because like others I am apprehensive of change. Huntington Beach is known all over the world and I think we should give Pacific City the opportunity to complete this mixed use development which would probably bring a lot of tax dollars to our wonderful city, we need to draw businesses to HB rather than push them away. We have so many tourists at the new hotels and we do not want them shopping in Newport Beach or Costa Mesa, they need to stay in HB. We need to finish what we started and I think Pacific City is exactly what we need to complete the strip from Beach Blvd to Main Street. Lets all vote yes! You can contact me @ 714 939-2160(days) or 714 536-0423 (eves) Jillian Fabian 21292 Sand Dollar Lane Huntington Beach, California 92646 0 Jillian Fabian I Listing Secretary Z c CB Richard Ellis I Transaction Department z 2125 E. Katella Avenue. Suite 1001 Anaheim, CA 92806 T 714 939 2160 1 F 714 939 2226 Z > jill.tabian@cbre.com I www.cbre.com w r' � D 6/7/2004 Pagc I of I Fikes, Cathy From: Devra Barnes [dbarnes8@socal.rr.comj Sent: Monday, June 07, 2004 11:50 AM To: cfikes@surfcity-hb.org Subject: Pacific City I am in total support of Pacific City. It will bring a different dimension to downtown. Devra Barnes 7912 Nomad Circle Huntington Beach, CA 92648 0 o - c i J - Z N 4 'JO ' 7 2004 4 _ Page I o1 I Fikes, Cathy From: Hectorleano@aol.com Sent: Monday, June 07, 2004 12:06 PM To: cfikes@surfcity-hb org Subject: Pacific City Dear Sirs. Please consider how the proposed Pacific City development can be made a reality. The features that this site would offer would be a dream come true for those seeking to combine the best of both commercial and residential in HB. It would be like the best of the Irvine Spectrum combined with the best of an European beach town. It would therefore enhance the already high tourist and local appeal of Huntington Beach Regards, Hector Leano Anaheim, CA (714) 778-2249 c i J Z rN m n Fikes, Cathy From: maureen seibel [hbdo112002@yahoo.com] Sent: Monday, June 07, 2004 2:29 PM To: cfikes@surfcity-hb.org Subject: Pacific City Hello, Here is a "vote of support" for the proposed Pacific City Development . I am a long time renter who desires a place to call my own and frankly Pacific City sounds very nice for me and others in my situation. Please approve the project . Thank you, 0 Maureen Seibel c i J - Do you Yahoo! ? t " Friends. Fun. Try the all-new Yahoo! Messenger. w http: //messenger.yahoo.com/ N r> J > 1 CS. . Page 1 of 1 Fikes, Cathy From: JAMES READ bread@prodigy.net] Sent: Monday, June 07, 2004 1:42 PM To: makes®surfcity-hb.org Subject: Pacific City I'm just showing my support for Pacific City. Thank You Jim Read z g X G C� c_ r. w - n' 6/7/2004 �J Message Pagc I of I Fikes, Cathy From: Mike [pontrellis.int@gte.net] Sent: Monday, June 07, 2004 1:27 PM To: cfikes@surfcity-hb.org Subject: Pacific City I vote YES We need this project to happen,.....Mike Pontrelli G J - "Ci � 7 6rn2004 53 Fikes, Cathy From: linhk nguyen [kay152@hotmail.com] Sent: Monday, June 07, 2004 1:26 PM To: cfikes@surfcity-hb.org Honorable Councilwomen, Honorable councilmen: We strongly support Pacific City project. Steven Phan and Lynn Nguyen. Thanks. kay152®hotmail .com. Is your PC infected? Get a FREE online computer virus scan from McAfee Security. http://clinic.mcafee.com/clinic/ibuy/campaign.asp?cid=3963 ti�V 1 S�. Fikes. Cathy From: William A. Lyons [walyons@energy-consultation com] Sent: Monday, June 07, 2004 12:31 PM To: cfikes@surfcity-hb.org Subject: Pacific City .he preliminary information I 've seen on Pacific City sounds very attractive, This project could go a long way to compensate for the missed opportunities along Beach Blvd. A village center as opposed to a purely commercial center would seem to be the right prescription for HB. Minimal traffic increases (most people walk) , families in the beach area (not boisterous young adults) and increased tax revenue from property plus a continuing stream of sales tax revenue from upper end retail . Wha'ts not to like? William A. Lyons Former HS 30yr-resident 0 c C z J t W r n: _J 1 SS. Strong support for Pacific City! Page 1 of 1 Fikes, Cathy From: Leslie Alsenz llalsenz@socal.rr.com] Sent: Monday, June 07, 2004 1 03 PM To: cfikes@surfcity-hb.org Subject: Strong support for Pacific City! Dear Council members, I live on Second street very close to the Pacific City site. I am strongly enthusiastic towards this terrific project. Please vote in favor of Pacific City. Sincerely, Leslie Sarac 234 2nd Street HB, CA 92648 0 o - t L C I J " Ti W - 1� > J '' 6/7/2004 S� Fikes, Cathy From: Kenna Masuda [mkenna@hotmail.com] Sent: Monday, June 07, 2004 2:48 PM To: cfikes@surfcity-hb org Subject: Pacific City Support To Whom It May Concern, My family has been part of the HB community for over 80 years. We have watched the city go through many stages of improvement. I believe that Pacific City will be yet another area to beautify and enrich our diverse community. Please accept my pledge of support. Sincerely, Kenna Masuda Getting married? Find great tips, tools and the latest trends at MSN Life Events. http://lifeevents.msn.com/category.aspx?cid=married 0 o t L C I rJ l W N J - 1 S I• Fikes, Cathy From Dann Remsing [dannremsing@yahoo.com] Sent: Monday, June 07. 2004 3 18 PM To: cfikes@surfcity-hb.org Subject: I support Pacific City! 2 N � O = C— z - i " - t c=- J Z�: m n w N n J D l S8' Jones, Dale From: Fikes, Cathy Sent: Monday, June 07, 2004 4 26 PM To: Jones, Dale Subject: FW: Pacific City --- - -Original Message----- From: Wayne LeFors [mailto:7474979msn.com] L Sent: Monday, June 07, 2004 4 :23 PM To: cfikes®surfcity-hb.org Subject : Pacific City r i Planning Commission-An exciting and needed development to cogplete the upgrade of the downtown area. Wayne LeFors-resident 1 S�1 Jones, Dale From: Fikes, Cathy Sent: Monday, June 07, 2004 3 45 PM g To: Jones, Dale Subject: FW In Favor of Pacific City z i J TJ -----Original Message----- c From: Diane Lenning Imailto:dianealenning.com] n Sent : Monday, June 07, 2004 3 :41 PM J > To: OC Register Wave; Independent; HB News; cfikes®surfcity- hb.org; diane®lenning.com Subject: In Favor of Pacific City In this time of economic dependency in our City of Huntington Beach upon tourist dollars for our city's income, it is imperative we pass the agenda item "FOR" THE PACIFIC CITY PROJECT. Everyone is aware of the shortage of allocation of money from Sacramento at this time of financial crisis. The recall of California's previous Governor Davis is a constant reminder to all of us of the dire need of economic income from an increased, supported business climate. This is a mandate of all the people of California. To vote against this great improvement to our city, at a time of dire need for business income, ignores the will of the people, and would be COMPLETELY IRRESPONSIBLE on the part of any City Council Member who would vote against it. This is not a time for personal Partisanship and personal agendas. Council Members must remember you are voting for your constituents and Also for those constituents who did Not vote for you as well . You represent ALL of the people, not just the ones who voted for you. What you do here today, will have far-reaching ramifications upon all people in our city, in our county, and in our State of California. You simply cannot be so short sighted to ignore the Obvious. we need Pacific City in order to continue forward with the goals and achievements the 1 people of Huntington Beach desire. After you vote to approve Pacific City, you can make adjustments with any difficulties you may have with the project. To allow this valuable income to sit dormant due to one's own personal agenda is more than "self-serving, it is negligent in representing the people of Huntington Beach. This project would beautify our city and help in the completion goals of making Huntington Beach a destination of which we can all be proud. I strongly urge all Huntington Beach City Council members to vote "YES" on the Pacific City Project. Diane Lenning Huntington Beach Resident 6 7 04 2 THE ROBERT MAYER RECCEfIi�Ep y y CORPORATION JUN 0 3 2004 4 of Nuntlngton 8e City COUMN nwMdcfl June 3, 2004 BY HAND DELIVERY Honorable Mayor Green and City Council City of Huntington Beach L" 2000 Main Street Huntington Beach, Ca 92648 = J Re: Inadequacy of Environmental Impact Report 02-01 ("EIR") (Pacific City) T Inadequate Reponses to Comments Dear Honorable Mayor: On March 23, 2004, the Planning Commission certified Environmental Impact Report No. 02-01 (the "EIR") for the Pacific City project in Huntington Beach (the "proposed Project"). The Robert Mayer Corporation has filed an appeal to such certification of the EIR to the City Council. Additionally, on May 5, 2004, the Planning Commission approved the Conditional Use Permit and other related entitlements for the proposed Project, and The Robert Mayer Corporation has also appealed those approvals to the City Council. In the appeal letters we filed, we stated several reasons why we believe that the EIR was deficient. The purpose of this letter is to expand on certain of those remarks, and in addition, to explain why several of the responses by the preparers of the EIR to this ftrm's earlier written comments to the draft EIR were inaccurate and misleading. As a result, the EIR is inadequate, and as a result, the proposed Project is in various ways inconsistent with the General Plan, the Downtown Specific Plan, and certain Zoning Ordinances. By way of specific examples, such inaccurate and misleading responses include, but are not limited to, the following: With respect to traffic and parking impacts: We have previously noted that the City's own peer-review traffic consultant (who was listed in the EIR as a preparer of documents for the EIR) questioned key assumptions made by the developer's traffic engineer. Nonetheless, that report was not included in the documents released to the public or the Planning Commission, contrary to the requirements of CEQA. A copy of page 4 of that review is attached hereto and 4,+7r-7 660 Newport Center Drive . Suite 1050 . Newport Beach,CA 92660 / P.O. Box 8680 . Newport Beach,CA 92658.6680 tel 949.759.8091 . fax 949.720.1017 Honorable Mayor and City Council Inadequacy of EIR No. 02-01 Page 2 of 12 incorporated herein as Exhibit "A" to this letter. However, in response to our complaint over this issue, the preparers of the EIR stated in its "Topical Response to Traffic Generation" on page 3-177 of the final EIR that "CEQA practice permits disagreement among experts in the analysis" and goes on to summarize regulations and case law that provide, in essence, that the EIR must fairly disclose and summarize the disagreements between experts. However, the response never properly discloses and summarizes the actual disagreement, choosing only to state that "public commenters have identified disagreement with the conclusions". The EIR response should have disclosed clearly the fact that the City hired an independent firm to review the developer's consultant's study, and that independent reviewer identified that key assumptions were lacking any empirical data or citation of a professional source to support them, and the reviewer called for more data to assure that such assumptions were reasonable. It should then go on to explain that no empirical data or citation from a professional source has been provided. Instead, the response provides a protracted rationalization of the dubious, unsubstantiated assumptions undertaken by the developer's consultant, while never addressing the substance.of the original comment. We provided as commentary to the draft EIR a detailed analysis of the developer's traffic and parking study by a qualified third party engineer, Kimley-Horn and Associates, Inc. The bulk of the responses to the comments provided by that consultant was inadequate and generally referred the reader to the "Topical Response" portion of the Final EIR rather than providing a meaningful response or correction to the draft EIR. Rather than deal with the specific commentary from Kimley Hom, the central argument of the Topical Response portion is that the ITE Trip Generation Handbook gives latitude to the analyst to make assumptions and modify procedures regarding mixed use development, as if a carte-blanch authority is given for any assumption the analyst might make. Instead, it must also be noted that the ITE Trip Generation Handbook also implores the analyst to "use good professional judgment". Further, we attach hereto as Exhibit "B" which is incorporated herein by this reference a further review by still another expert third party traffic engineer, Katz, Okitsu & Associates. The author of the Katz Okitsu report, Mr. Rock Miller, is a highly regarded transportation engineer and currently serves as an International Director for ITE. His review states, "It is essential that the trip generation for the project be forecasted as precisely as possible. It is not appropriate to make arbitrary and unsubstantiated reductions without clear and acceptable justification. The reductions taken in the Pacific City impact analysis are not substantiated They are defended as the study author's professional opinion and that experts may disagree about analysis points. However, we are concerned that LLG's professional's opinion mats have been affected by a desire or goal to reduce the potential impact of the project at the onset of analysis. The review also concludes, "We are very concerned that some key assumptions have been taken during the preparation of the traffic and parking analyses for this project. These key assumptions serve to underestimate the traffic impacts and parking demands for Honorable Mayor and City Council Inadequacy of EIR No. 02-01 Page 3 of 12 the project. We do not believe that the analysis prepared can be used to reliably estimate impacts in these areas. There is too high a potential that impacts have been overlooked, underestimated, or not fully mitigated. Deviation from accepted analysis techniques should not be taken, simply because the analyst feels that they are appropriate. Any deviation from measured and standard behavior for normal land uses should only be taken based upon a satisfactory and representative number of measurements of comparable uses in comparable settings. Reductions based upon opinions alone are highly likely to cause unintended consequences. We believe that the City and its agents should base the analysis upon widely accepted traffic generation rates and parking demand analysis techniques, supplemented by local data to justify deviations from the key provisions of these procedures." The Kimlev-Horn review noted that the traffic analysis assumes that 3,000 people per day, and over 300 people in a single evening peak hour will leave their original downtown or beach area destination to walk to the proposed Project and back again. The review suggested that it was an overly optimistic assumption and that it was more likely that patrons of the proposed Project will make it their primary destination, and perhaps walk to the beach or downtown area as a secondary destination. The EIR response notes that the comment correctly defines the calculated walk-in traffic on a daily and hourly basis. However, the response is also incorrect in the following statements: o The EIR response incorrectly asserts that the calculations "conform to ITE recommendations" when in fact, as summarized in the Katz Okitsu review, "There is no basis for this arbitrary adjustment to be applied in the manner taken" and "a reduction for mixture of uses should not exceed the amount suggested by the ITE Report." o Further, the EIR response claims, "The mode shift percentages ... reflect traffic engineer and City experience with the unique combination of the proposed project's mixed use land characteristics and proximity to the beach, as experienced in Main Street/Downtown and adjacent hotel land uses." However, no statistics, survey data or evidence of any kind is cited to support such claimed "experience", and the claim is made even more unbelievable by claiming that similar mode shift percentages occur with the "adjacent hotel land uses." The adjacent hotel land uses are the Hilton and Hyatt hotels owned and operated by The Robert Mayer Corporation. Our direct operational experience is that we receive virtually no walk-in traffic jar hotel or restaurant use. When we noted this fact elsewhere in our comments, the EIR response did not refute that fact, and instead claimed that the proposed Project would offer different restaurants more likely to attract beachgoers. However, the EIR can't have it both ways, claiming that the City has experience with significant mode shift use at the Hilton and Hyatt hotels in one instance, and then later explaining that the lack of mode shift use experienced at the Hilton and Hyatt hotels is because they are different than the proposed Project. Honorable Mayor and City Council Inadequacy of EIR No. 02-01 Page 4 of 12 The Katz Okitsu review shows that the shared parking analvsis omits at least 200 parking spaces based on the assumption: that .such customers of the proposed Project will instead park in the Downtown area or beach parking lot. However, the EIR's Topical Response on Shared Parking claims, "The analysis does not rely on the use of off-site parking facilities to meet project needs." Instead it argues that the mode shift assumption is reasonable. However, the EIR can't have it both ways, claiming that the project should be allowed to assume that a significant portion of its parking needs will be satisfied offsite, while at the same time claiming that the proposed Project does not rely on the use of off-site parking facilities. The above-referenced EIR response that rationalizes the substitution offsite parking for onsite parking is made even more absurd by the EIR failing to disclose that the DTSP states that, "District(s) ... 7 ... shall provide one-hundred(100)percent of the required parking on-site,pursuant to the Huntington Beach Ordinance Code." (emphasis added) This failure of the proposed Project to conform to the DTSP is again a reason that the proposed Project should not be approved. Both the Kimley-Horn review and the Katz Okitsu review have concluded that there is a substantial shortage of parking in the proposed Project. The attached Katz Okitsu review concludes that even with the "Reduced Alternative" project and the proposed total parking of 1,542 spaces, there is a shortage of 213 to 160 parking spaces. As a result of the shortage of parking, the project should be denied because it is inconsistent with the Huntington Beach General Plan, the Downtown Specific Plan ("DTSP"), and the City Zoning Ordinance. The General Plan sets forth express policies that: o An adequate supply of parking must be maintained in the coastal zone that supports the present level of demand and allows for the expected increase in private transportation use; o Adequate parking must be maintained and provided for in all new development in the coastal zone; and o In the coastal zone, the City must apply the City's parking standards at a minimum, and any new parking standards must be approved by the California Coastal Commission. (Natural Resources Chapter, Coastal Element, Policies C 2.4.1 and C 2.4.2.) o Because the project does not comply with the City's minimum parking standards, and because the Coastal Commission has not approved any new parking standards for this project, the project is inconsistent with the General Plan. o Similarly, whereas the Downtown Parking Master Plan for the DTSP is based upon a "shared parking" concept which has been approved by the California Coastal Commission, the subject project site lies outside of the Downtown Parking Master Plan boundary and is not authorized to use parking located in the downtown area as a substitute for onsite parking. Indeed, the DTSP expressly provides that development within Districts 7 and 8, where the project is located, is Honorable Mayor and City Council Inadequacy of EIR No. 02-01 Page 5 of 12 required to meet the minimum off-street parking standards of the Huntington Beach Ordinance Code and must provide 100% of the required parking onsite. The project is inconsistent with these requirements because the shared parking analysis specifically calculates a reduction of 200 or more parking spaces based on the assumption that customers will park in the downtown area or at the beach. By informally extending the "shared parking" concept to this project site, the City in effect would be amending the Downtown Parking Master Plan, the DTSP, and the Zoning Ordinance without going through proper procedures. As is more fully described in the attached Katz Okitsu report, the shared parking analysis assumes a reduction in base parking demand totaling 480 spaces before ever considering shared use of parking between the various uses at the proposed Project. The EIR Topical Response on Shared Parking fails to disclose this fact, and instead infers that the shared parking analysis is consistent with the City Zone Code Chapter 231 regarding off-street parking. However, City Zoning Code 231.06 "Joint Use Parking" provides that, "the total requirement for off-street parking shall be the sum of each individual use computed separately except as provided in this section" and that a reduction may only be granted when, "the applicant can demonstrate that the various uses have divergent needs in terms of daytime versus nighttime hours or weekday versus weekend hours." Nothing in this portion of the Zoning Code allows for other substantial reductions unrelated to the timing of use which are assumed in the developer's shared parking analysis. Other provisions within the City's Zoning Code might allow reductions to the City's standard rates, but the information required for such an action was not a part of the shared parking study, and the Planning Commission made no findings to support such a reduction as required by the Zoning Code. As a result, the project should be denied because it is inconsistent with City Zoning Section 231.06. With respect to water quality impacts of runoff from the proposed Proiect onto the Citv beach: - As was stated in the appeal letter from this firm dated May 14, 2004, the EIR falsely states that no water quality standards have been set for bacterial levels in runoff. Please see the letter from Richard Watson & Associates, Inc. dated June 3, 2004, which is attached hereto as Exhibit `B" and incorporated herein by this reference. As the letter describes, standards for bacterial levels in runoff do in fact exist and are incorporated into the Water Quality Control Plan for the Santa Ana Region (the Basin Plan). - As a result of the EIR's error with regard to correctly disclosing the existing standards for bacterial levels in runoff, the proposed Project's additional conditions of approval fail to address any Best Management Practices with regard to bacterial levels. As a result, the attached letter concludes, "There remains a high probability that discharges from the First Street Drain to the beach will violate water quality standards." Honorable Mayor and City Council Inadequacy of EIR No. 02-01 Page 6 of 12 With respect to the consideration of project alternatives. as required under CEOA: The responses give unduly short shrift to the comment that the EIR has not evaluated a reasonable range of alternatives, including the failure to evaluate a "reduced hotel project." The responses suggest that an alternative need not be evaluated if it (i) would not reduce the unavoidable significant impacts of the project, or (ii) if it would not reduce significant impacts to a level of insignificance. Both assumptions are incorrect for the following reasons: o First, the EIR has artificially limited consideration of alternatives by focusing on just alternatives that could avoid air quality and traffic impacts, the two unavoidable significant impacts of the project. By narrowing its focus, the EIR fails to inform the decision makers of other reasonable alternatives that are actually available to accomplish the goals and objectives of the project in a more environmentally beneficial way. CEQA does not allow the lead agency to focus on only the unavoidable significant impacts of a proposed project when discussing alternatives. The California Supreme Court expressly rejected this approach when it invalidated the certification of an FIR by the Regents of the University of California. The Regents had determined that since all of the project's significant impacts would be avoided by mitigation measures, the EIR did not have to discuss any alternatives to the project. The court rejected this argument, holding that an EIR must include a discussion of project alternatives even where there are no unavoidable significant environmental impacts. Such a discussion must be included so that the decision makers will be provided with adequate information about the range of options available. (Laurel Heights v. Regents of Univ. of California (1988) 47 Cal.3d 376, 403.) if CEQA required that an EIR evaluate only alternatives that addressed the unavoidable significant impacts of a project (as the EIR assumes here), the California Supreme Court obviously would not have found the EIR in the Laurel Heights case to be deficient since there were no unavoidable significant impacts from the project in that case. o Second, alternatives must be discussed even if they would not reduce significant impacts to below a level of significance, but would merely substantially lessen the impacts of the project. (CEQA Guidelines, § 15126.6(b).) o The above misconceptions in the responses to comments deprive the decision makers of adequate information about a reasonable range of alternatives to the project. For example, the DTSP, which governs the site, specifically states that a 200-room hotel (as opposed to one double that size in the proposed project) meets the objectives of the DTSP. Further, a reduced hotel project would promote the goals and objectives of the certified Land Use Plan and the Local Coastal Program, which require that the City consider and protect the scenic and visual qualities of the coastal areas as a resource of public importance. As the California Coastal Commission stated in its March 18, 2004 comment letter on the project, the hotel structure "should be articulated to reduce the apparent mass and scale of the development from public vantage points. Lower profile, less massive Honorable Mayor and City Council Inadequacy of EIR No. 02-01 Page 7 of 12 development would be preferred." (emphasis added) Thus, although a reduced hotel alternative would meet the objectives of the project, while reducing the traffic, air quality, and visual impacts of the proposed project, and would promote the goals and objectives of the LUP and LCP, this alternative was not evaluated in the EIR. o As stated above, the DTSP, which governs the site, specifically states that a 200- room hotel (as opposed to one double that size in the proposed Project) meets the objectives of the DTSP. The EIR's response to comments on the alternatives analysis states that the concepts and objectives contained in Chapter 3.0 of the DTSP are outdated and pending review, and therefore it incorrectly reasons that the stated goals of the DTSP on this site are not worthy of consideration when determining potential project alternatives. However, Chapter 3.0 of the DTSP which contains that goal has never been repealed and is legally effective. And though the City staff has indicated that it is under review, it has been "under review" since 1995. Presumably, if revisions were necessary, they would have made them by now. Further, the significant change made to the DTSP in 1995 was to change development standards in the downtown core area. No significant changes to the development standards were made for project site; as a result, changes to the goals for the project site should not be assumed in the EIR. o Moreover, the reduced hotel alternative was rejected for evaluation based on conclusory, unfounded opinion. The responses to comments state in conclusory fashion that if the hotel is reduced by half and 1,125 daily trips are eliminated, this would not substantially reduce impacts to traffic or air quality. No empirical evidence or quantified traffic information is provided to support this statement. Rather, the response is based on a "ratio theory," a comparison of the reduced trips as a percentage of the total project trips. The response finds the reduction would be insignificant because it is less than 10% of total project traffic (although actually over 1 1% of the non-residential traffic). The"ratio theory," however, has been thoroughly rejected by the courts as a method for determining the significance of environmental impacts. (See, e.g., Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 718.) Instead, the response should evaluate the actual (reduced) numbers of trips at actual intersections, and compare those impacts with the proposed project's impacts, to determine whether there is actually a substantial lessening of traffic impacts that could be attained under the reduced hotel alternative. It should also be noted that the attached report by Katz Okitsu highlighted the fact that the EIR's traffic study assumed unrealistically low traffic generation rates, and as a result, "if the initial trip generation understates the potential impacts of the project, such alternatives may be seen as unnecessary and therefore are overlooked." o Simply put, the EIR fails to document with supporting facts and analysis its finding that the reduced hotel alternative need not be evaluated. It seems only reasonable that the EIR evaluate a project that has been expressly determined to meet project objectives; would provide a lower profile, less massive development Honorable Mayor and City Council Inadequacy of EIR No. 02-01 Page 8 of 12 to promote the goals and objectives of the City's LCP. and would substantially lessen the number of traffic trips per day caused by the project, thus substantially reducing the air quality and traffic impacts of the project. The responses in the EIR also fail to adequately answer our comment that the EIR did not evaluate a reasonable range of alternative sites, for the following reasons: o The responses admit that there are significant traffic impacts from the project at Warner Avenue/PCH and at Seapoint/PCH. Although the responses briefly discuss a couple of alternative sites, the responses also concede that other unidentified sites exist, but reject the call to evaluate these other alternative sites based upon speculation and dubious assumptions. For example, the responses state that the other, unnamed sites were not evaluated because the project's trip generation would be the same no matter where the project was located. and thus relocating the project would not "necessarily" eliminate traffic impacts of the project, as it is "likely" that any other location in the City would have the same impacts to intersection operations. Uses of the terms "necessarily" and "likely" reveal the speculative nature of these conclusions. Instead of actually evaluating these alternative sites, the EIR simply speculates that the traffic impacts would be the same at the sites. o Moreover, the conclusion that the traffic impacts would be the same necessarily assumes that the existing levels of service for all intersections in the City are the same. There is no evidence that this is the case. The law provides that a conclusory discussion of hypothetical alternatives is not adequate under CEQA. (Laurel Heights v. Regents, supra, 47 Cal.3d at 404 [Court determined there was no meaningful assessment of the capability of alternative sites to house the proposed project or to reduce its environmental impacts because alternative sites were not identified]; San Joaquin Raptor/Wildlife Resource Cert. v. County of Stanislous (1994) 27 Cal.AppAth 713, 736 [Court invalidated EIR that simply referred to alternative sites but did not identify any, discuss their attributes, or indicate why they would or would not be feasible]: San Bernardino Vollev Audubon Soc. v. County of San Bernardino (1984) 155 Cal.App.3d 738, 750 [although it discussed the potential to locate the project on an alternative sites, the EIR was invalid because it did not discuss specific locations or their attributes].) o Because the responses to comments did not specifically identify potential locations, did not discuss their attributes, and did not indicate why they would or would not be feasible, the discussion of alternative sites is deficient under CEQA. With respect to the possible identification of wetlands on the proposed Project site: Our appeal letter dated May 14`s, 2004, contained several reasons why we believe that the approach adopted by the Planning Commission calling for a wetland delineation to be performed at a later date is flawed. We must further note that the EIR itself and the post- Honorable Mayor and City Council Inadequacy of EIR No. 02-01 Page 9 of 12 approval wetland delineation approach adopted by the Planning Commission are also improper for the following reasons: o The purpose of an EIR is to provide enough information about a project so that the decision makers can make an informed decision thereon. The EIR must contain sufficient information about the proposed project, the site, and the projected environmental impacts arising as a result of the proposed project to allow for an informed decision. (San Joaquin Raptor/Wildlife Rescue Center v. Counry of Stanislaus (1994) 27 Cal.AppAth 713, 718.) State CEQA Guidelines section 15125 provides that an EIR must include a description of the environment as it exists before the commencement of the project. Special emphasis should be placed on environmental resources that are rare or unique and would be affected by the project. Wetlands are this very type of environmental resource, and because they are particularly susceptible to adjacent land uses that alter surface and groundwater availability, it is important that an EIR provide adequate information concerning wetlands from which the reader could derive an understanding of their locations and the environmental effects they may suffer as a result of construction of the development project. o Here, the EIR's description of the existing environmental setting of the project is deficient because it is impossible to determine from the EIR document whether wetlands exist on the site, and if so, the location and extent of those wetlands. Without accurate and complete information pertaining to the setting of the project, an accurate description of the impacts of the project cannot be stated; i.e., the EIR's failure to provide a clear and definite analysis of the location, extent, and character of wetlands that possibly exist within the development project makes it impossible for the City Council to conclude that all environmental impacts of the project were identified and analyzed in the EIR. o Although the EIR concedes that wetlands may exist on the project site, it fails to detail the specific location and extent of the wetlands. CEQA Guidelines section 15144 provides that a lead agency "must use its best efforts to find out and disclose all that it reasonably can" about a project's potential environmental impacts. Here, there is no indication that a proper delineation for wetlands was conducted on the site. If a proper survey was done, there is no description of the qualifications of the person or entity conducting the survey, or a summary of the results of the survey. Nor is there any indication that the City met with experienced biological consultants or the California Coastal Commission regarding the possible wetlands on site. Apparently, such meetings were not held because the California Coastal Commission in its March 18, 2004 comment letter points up the lack of information regarding wetlands in the EIR, in that it states, "In order to determine the character and function of these [wetlands] areas, additional information should be made available for consideration. The location and extent of these areas should be mapped In addition, the city should fully evaluate the potential that the site has historically contained Honorable Mayor and City Council Inadequacy of EIR No. 02-01 Page 10 of 12 wetlands and whether there is the possibility that these are re-emergent wetlands." (emphasis added) - If an investigation into the existence of wetlands was conducted, the investigation should have been documented in the draft EIR and reference made to the specific activities undertaken and the findings reached to support the crucial assertion that wetlands are not located within the site. Comments could have then been made addressing the adequacy of the investigation and responses prepared to these comments. The final EIR would then have provided information sufficient for the City and the general public to intelligently assess the conclusion that there are no wetlands within the site that would be impacted by the project and to make an informed decision. - The description of the environmental setting is thus not only inadequate as a matter of law, but it also renders the identification of environmental impacts legally inadequate and would preclude any determination that substantial evidence supports a finding that the environmental impacts on biological resources have been mitigated to insignificance. Finally, the EIR's statement that the wetlands issue will be revisited after project approval to see if wetlands exist once the remediation project is completed, points up the serious deficiencies in the EIR: Because the record indicates that there may be wetlands within the site and because the extent and exact location of the wetlands have not been adequately explored, the commencement of further soil remediation work or other project construction on the site could result in an adverse and irreparable change in the physical environment. Wetlands could be destroyed even before they are adequately identified - The risk that wetlands may be destroyed prior to their proper delineation is underscored by the fact that the developer conducted indiscriminate clearing of vegetation from the site as recently as Afay 18, 2004, just days prior to the previously scheduled hearing before the City Council. Please find attached a complaint to the City dated May 28, 2004 which is attached hereto as Exhibit "D" and incorporated herein by this reference. As stated in the complaint, the clearing of vegetation at the site at this time may be a violation of law and in any event it may prevent the proper study of the site for potential wetland habitat. - All of these above points are supported by the holdings in San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus, supra, 27 Cal.AppAth 713, where the court granted an injunction prohibiting the county and a developer from approving or carrying out a residential development project because the EIR gave an incomplete, inaccurate, and misleading description of the site by ignoring the possible existence of wetlands thereon. The court determined that because there might be wetlands within the site and the extent and exact location of the wetlands were not adequately explored, further activities on the site could result in an adverse and irreparable change in the physical environment, destroying wetlands before they were adequately identified. The same rationale would seem to clearly apply in this case. With respect to Oil Overlav Zoning Regulations: Honorable Mayor and City Council Inadequacy of EIR No. 02-01 Paee 11 of 12 Other parties commented on the draft EIR with respect to the existence of Oil Overlay C in the DTSP which is shown on the project site. We believe that responses to those comments were inaccurate and dismissive for the following reasons: o The responses to comments assert that the 2-acre oil island need be included in a concept plan for the site only when a project proposes oil drilling, which this project does not. This conclusion is contradicted by the express language of the DTSP, which states that a "conceptual site plan for the entire overlay area must be submitted prior to permitting any project development or subdivision of land within the overlay." The project here proposes such development. The DTSP further provides that the Planning Commission must make a finding that the requisite oil island has been incorporated into a concept plan "before approving any development project." Thus, the DTSP does not limit the requirement for a 2- acre oil island to projects where oil drilling is proposed, as the responses indicate. Indeed, the express terms of the policy require that the oil island be included for any project. o The project is also inconsistent with the City's Coastal Element policies regarding (i) the consolidation of oil operations, and (ii) the retention of access to underground oil reserves. The oil overlay consolidation project (Municipal Code section 15.50) was implemented to address the effects of dispersed oil recovery operations in the City. (FEIR 3-216.) The number one purpose of the oil operations consolidation policy set forth in section 15.50.010 is to avoid adverse impacts by "consolidat[ing] oil operations onto specified locations," such as Oil Overlay C, which was made part of the zoning for the project site. That overlay zone requires that any development project for the site maintain at least a 2-acre oil island within the overlay area. o Moreover, the City's oil access retention policy states: "Through the development permit process, ensure that new development provides for the retention of access to underground oil reserves where needed." (Coastal Element, Policy C 8.1.9.) The permit process on the proposed Project, however, does not ensure that the new development will provide for the retention of access to underground oil as required in the Oil Overlay Zone. The response to comments suggests that access will be maintained because slant drilling is feasible to access the minerals. Accessing the Oil Overlay Zone via offsite slant drilling, however, hardly accomplishes the purpose stated in the Municipal Code of consolidating oil operations onto specified locations; on the contrary, slant drilling forces oil operations away from the specified location (Oil Overlay C), thus decentralizing oil operations rather than consolidating them. Clearly, retaining access through the development permit process means that the City should ensure the retention of onsite access since the retention requirement is tied to the permit process, which by definition concerns onsite development. Moreover. the DTSP provides that any development plan "shall include" the 2-acre oil island, which must be incorporated into the overall development plan to minimize impacts and provide Honorable Mayor and City Council Inadequacy of EIR No. 02-01 Page 12 of 12 safe access to the oil site(s). This requirement again illustrates that the policy envisions onsite access, not slant drilling from offsite. In conclusion, we do not believe that many responses to comments incorporated into EIR No. 02-01 are adequate or accurate. As a result, we believe that the EIR is inadequate and should not be certified. Additionally, for the many reasons stated in this letter, and our prior appeal letters, the proposed Project is inconsistent with the General Plan, the DTSP, and the Zoning Ordinance. Therefore, the City should not approve the proposed Project. Thank you for your consideration. THE ROO/BBERT MAYER CORPORATION 0 Shawn K. Millbern Senior Vice President, Development EXHIBIT "A" TO LETTER DATED JUNE 3, 2004 Page 4 of independent review of traffic analysis by City's consultant, LSA Associates, Inc. Dated April 14, 2003 tee enocu.rae. INC. 17th Street/Pacific Coast Highway. 9ffi Street!Pacific Coast Highway Main SbieW Pacific Coast Highway Beach Boulevard/ladianapolis Beach Buulevard/Atlarita Avenue Lake S1r"VAdams Avenue Values in the table.sbould match values in ApWdix D, 2001 Existi:iw Traffc. 16. Table 6 and throughout: Add daily traffic volume and volume m capacilY ealeulati=for Pacific Coast Highway, Ninth Street to First Street for all scenarios analyzed- 17. Page 29: In the third paragraph,.revisa the table number to Table 10, 19. Table 10: Provide an explanation for Internal Capture and Mode Shift percentages that are used for each land use.There are no empirical data provided in the analysis of.fn.any citation Of professional source to support the assumptions that are included in the picture in Appendix C. In cider to,provide some level of assurance aced reasonability, more date and'ainelysie should be included to justify the Trip Reduction Flow Diagram and the resulting adjustments to the gro3s trip generation. 19. As rnemioemd earlier in Comment 9, revise volumes with project trailer far Exhibit 14 and throughout far the following intersections in addition to the inim.cctions prtviously meeeioned: Main Strest/Utim Avenue Main 9treeVAdama Avenue Lake StreetlAdams Avenue 20. Page 51, Table 12_Revise ICU values for Year 2000 Bai:hgrvand Conditions and.Background Plus Project for the following interswions: Main Stroct/Pacifie Coast Highway IN 5ereet/Pacifsc Coast Highway In addition, pages 79 and S.A Table I5, need revision on ICU values for Year 202.0.with Project Traffic for the following intersections: 1 st Street/pacific Coast highway Beach Bouievard/Pacifie Coast Highway Incorrect values are circled in red on the Traffic Study. 21. Page,55: In the second paragraph,add the word"controlled"after the word'"state"in the first semence. The sentence should be ". . . at adverse service levels at two ofthe nineteen state- controlled study intersections.- antRJHPHCIpSOCammeedetur.upd)+ 4 EXHIBIT "B" TO LETTER DATED JUNE 3. 2004 Independent review of traffic and parking analysis by Katz Okitsu & Associates Dated June 3, 2004 Katz, Okitsu & Associates Tra;(i:i::rcrn.rn,rrd Tr.ucics•.:;;ien Plms::> June 3, 2004 Mr. Shawn Millbern 17852 17°i Street The Robert Mayer Corporation Suite 102 660 Newport Center Drive, Suite 1050 Tustin,CA Newport Beach, CA 92660 2780 714.573.0317 Subject: Pacific City Development and EIR. fax:714.573.9534 koaoc@katzokitsu.com www.katzokitsu.com Dear Mr. Ivlillbern: You have requested that Katz, Okitsu & Associates conduct an evaluation of the traffic impact assessment for the subject development in the City of Huntington Beach. Katz, Okitsu & Associates specializes in traffic engineering and transportation planning and has offices in Orange, San Bernardino and San Diego counties. As Vice President and Principal Engineer of this firm, I have conducted this evaluation. My resume is attached for your reference. The traffic impact assessment and documentation that was prepared for the City by Linscott, Law, and Greenspan (LLG), have already been reviewed by two other independent firms, LSA under a City peer review, and Kimley Hom, under your authorization. Both of these firms noted that the traffic impact analysis deviates from generally accepted practices in several critical areas. We have completed our own review of the documentation and find that the issues raised by these other firms have not been addressed in the most recent version of the EIR and its traffic and parking studies. The primary areas of concern relate to traffic generation and parking demand for the proposed projects. Los Angeles 323.260.4703 The LLG traffic study initially evaluates trip generation by citing the accepted reference fax:323.260.4705 for this subject, the Institute of Transportation Engineers (ITE) Trip Generation report. But the study proceeds to discount (reduce) the projected trip generation in a manner San Bernardino that is highly subjective, unsubstantiated, and unrealistic. 909.890.9693 fax:909.890.9694 A 5-15% discount is first claimed for internal trips, defined as trips between differing uses within the proposed development. This discount is taken in an arbitrary manner San Diego that is clearly inconsistent with the generally accepted procedure that is identified in 619.683.2933 fax:619.683.7982 the ITE Trip Generation report. A subsequent 10-25% adjustment is also taken to further reduce the peak hour trip generation based upon the site location and proximity to walking trips. There is no basis for this arbitrary adjustment to be applied in the manner taken. Katz, Okitsu & IKatz. Okitsu S Associates Page 2 of 8 7 cq%'n!irpxnn nnJ Tr.vnr•nvvx A]mi.n Associates recommends strongly that no discount is appropriate for walk in traffic during the AM & PM peak hours, and that a reduction for mixture of uses should not exceed the amount suggested by the ITE Report. These two adjustments combine to reduce the estimated traffic generation for the project by 25% below the amount that would be estimated under generally accepted practices. Adjustments of this type are appropriate for certain hours for other projects, however these adjustments are generally not taken liberally during peak traffic hours, because the behavior of traffic during peak periods is not conducive to the reductions that are being advocated during peak hours. Why is Trip Generation Important Trip generation is an estimate of the overall traffic activity that will result from the project. This traffic activity is a key input in the impact and mitigation process. Underestimation of trip generation is a key assumption that can result in unintended additional project-related impacts. It should not be reduced without strong and reasonable justification. The general areas are as follows: • Increased impacts in Air Quality and other areas that are based on Traffic Generation • Omission of locations where impacts should properly be analyzed based on proper traffic generation • Underestimation of impacts at locations where impacts are overlooked due to low traffic generation estimates and where mitigation measures should be identified or needed. • Underestimation of mitigation measures where impacts are identified or needed. • Failure to properly consider alternative project designs that may substantially reduce traffic impacts. It is essential to use the best available information on traffic generation to properly and adequately analyze impacts. It is not proper to presume a significantly lower traffic generation without carefully and fully justified analysis. If traffic generation is presumed to be low, it is virtually certain that impacts will be overlooked or underestimated. We start with Air Quality, not because of its importance, but because Air Quality is already shown to be a significant impact of project development. Trip generation is a fundamental input into Air Quality Analysis. If trip generation is underestimated, then air quality impacts are also underestimated. The amount of Air Quality impact will increase if the trip generation is corrected. Trip generation is used to identify or screen locations where detailed traffic analyses are needed. if the trip generation is too low it is probable that additional intersections could be Katz. Okitsu & Associates Page 3 of 8 '::;n :a:rr>naJ Lemr:•n.rm-c J4.xnrr, potentially impacted and require mitigation. If any potentially impacted locations are not identified and analyzed, an impact would be created but not disclosed in advance. Trip generation generally determines by how much each analyzed intersection is impacted. if the project's trip generation is corrected, the impact at each intersection will be greater. There is thus a greater potential for significant impact at additional intersections. These impacts may not be identified if a lower trip generation is used. Trip generation is fundamental in determining whether a mitigation measure is effective in fully mitigating the condition. If trip generation is corrected, a potential mitigation measure may no longer be found to be effective in mitigating an impact. As a result locations that are assumed to be fully mitigated may still be impacted. Proper trip generation also allows an accurate assessment of potential alternative project designs. For instance, a lower intensity project may substantially reduce traffic impacts, but if the initial trip generation understates the potential impacts of the project, such alternatives may be seen as unnecessary and therefore are overlooked. It is essential that the trip generation for the project be forecasted as precisely as possible. It is not appropriate to make arbitrary and unsubstantiated reductions without clear and acceptable justification. The reductions taken in the Pacific City impact analysis are not substantiated. They are defended as the study author's professional opinion and that experts may disagree about analysis points. However, we are concerned that LLG's professional's opinion may have been affected by a desire or goal to reduce the potential impact of the project at the onset of analysis. The Walking Adjustment The study offers that a 10-25% reduction is appropriate for all uses due to proximity to the beach, to downtown, and the nearby uses. This adjustment is normally considered only for developments in areas that already experience heavy pedestrian traffic adjacent to the site, normally a downtown area and a service-oriented use. The arguments for a walk-in trip adjustment for this project are not strong, especially for intersection peak hour analysis. The beach is not heavily used during the AM peak. There is no expectation that any significant amount of traffic will be reduced due to walk-in traffic from the Beach during the AM peak hour. Any person can judge the reasonableness of this adjustment by observing and quantifying existing usage of the Beach during the AM peak hour directly across from the project site. A few summer weekdays may have modest beach use, however the walking adjustment is being claimed for every working day of the year, while beach use is highly seasonal. The trip generation is being reduced by 100's of trips during this peak period claiming that they will walk from the beach rather than drive to the site. Katz. Okitsu & Associates Page 4 of 8 Tn:, _ .csr.a.:J!mvvc•w:nc PWan:n Beach use is highest during mid-day; weekends, and holidays. These are the only times that substantial walk-in traffic may occur. There is now limited use of the Beach in the project vicinity during weekday PM peak periods; however at this time the rate of beach use is not high enough to assume beach users will reduce the traffic generation for the proposed project. The project will likely cause increased use of the immediate vicinity of beach, since it will increase population in the project vicinity. Some of these new users may park across PCH from the project, however it would not be correct to discount these users. If the project is not built, the traffic will not occur. In this setting, it is not appropriate to assume traffic generation will be reduced in the AM and PM peak hour by beach traffic, simply because the new traffic chooses to park in beach lots. Downtown Huntington Beach is a very long walk from the project site. The potential for a high number of walking trips from downtown during the AM and PM peak period is low. A reduction by 10-25% peak from trips by walking downtown is not realistic. This level of pedestrian traffic today only occurs between Main Street and the Pier; a distance of less than 300 feet and it does not occur during the AM peak. The Internal Trip Adjustment The project proposes to apply a 5-15%discount to traffic generation based upon a mixture of uses that are expected to attract traffic from each other. The ITE Trip Generation Report provides guidance for this type of discount. Trip Generation provides for no discount during the AM peak period, due to the nature of AM peak hour traffic. It provides for a modest discount during the PM peak, however this discount relies upon testing the suitability and size of the competing uses to insure the amount of adjustment is reasonable. If not carefully analyzed; it is possible to conclude in error that every residential trip will be absorbed by a nearby non-residential use, nearby. The ITE report would allow an adjustment in the PM peak hour for this site, however it would be lower than the amount indicated in the LLG report. Parking Demand Up-Front Reductions The internal trip and pedestrian trip adjustments have also been applied to the parking demand and shared parking analysis. The base parking demand for the sum of the retail; restaurant and office uses has been reduced by at least 200 parking spaces' (prior to consideration of shared use) using the same justification as the Traffic analysis. That is; it is assumed that customers representing 200 parking spaces will park in the downtown area or ' 200 spaces reduced in the 'Reduced Alternative Plana and 208 spaces reduced in the `Full Buildout Plan` per footnotes 2 and 3 in tables 5 and 6 in the LLG study. Katz. Okitsu & Associates Page 5 of 8 beach parking lots and walk to the project. There is no basis for applying this kind of adjustment to a parking demand analysis. Parking reductions are taken only when it is logical and assured to assume that the project will either (1) not be popular, or (2) that a substantial amount of site users will be able to arrive at the site using alternate transportation. This type of reduction is normally done in areas that are heavily served by high quality public transportation or for uses where a clear need for less parking can be proven. It should not be presumed in areas where parking may be found to be at a premium during periods of peak demand. If parking demand is underestimated for this project and if the project is constructed, the overflow parking will utilize public and beach parking areas. This will deprive the public of access to the beach, a serious impact to overlook. It is very important for any reduction in parking to be realistic and based upon clearly justified principles. It is very unrealistic to assume that any significant percentage of hotel traffic will arrive at this hotel in a manner that is significantly different than other hotels in comparable areas. Hotel parking presumes a normal demand for parking by room guests and employees, and this already takes into account room occupancy and arrival of some guests by hotel shuttles or tour busses. Downtown business hotels often experience lower parking demand since many arrivals are by group transportation and local trips are often made by walking or taxi, however this type of trip is not expected for a beach-oriented development that may also attract tourists who will use private transportation to travel to other popular Southern California destinations. Specific and special circumstances may result in lower parking demand at some times. On a particular day a large group may arrive at the hotel by tour bus and require minimal parking. However parking facilities must be sized to meet a wide variety of expected demands. On other days, tour bus usage may be very minimal and events at hotel conference facilities may be of low interest to hotel guests. Parking must be provided for a wide variety of reasonably expected uses, not reduced due to a special situation that will not occur every day. Shared Parking Analysis There is a widely accepted process for analyzing parking adjustments for uses that may share their parking areas. The process is documented in a well-known resource, Shared Parking, published by the Urban land Institute (ULI). This study indicates precise measures for expected time-of-day usage of different land uses. It provides for specific reductions in parking for hotels based upon use of conference and restaurant facilities by hotel guests. However these adjustments are founded upon realistic estimates of parking demand for the component uses. The LLG study has applied a 25%discount to component parking demands Katz. Okitsu & Associates Page 6 of 8 prior to shared parking analysis, and then proceeded to further reduce the parking demands through the provisions of the ULI study. We have carefully compared the shared parking analysis with the ULI study and noted several key differences. ULI provides specific percentages for most of the land uses proposed. Many of the shared parking reduction percentages are identical to the ULI study, however percentages for some uses in some time periods are higher than ULI and percentages in other time periods are lower than ULI. It is common and reasonable to increase ULI percentages to be conservative and provide excess parking where there are parking concerns. It is not common to lower the percentages of peak demand suggested in the ULI study, except based upon documented experience of comparable developments. In the rare occasion where such reductions are assumed, it is standard practice that these types of reductions are clearly noted and the back-up documentation is provided to allow for an evaluation of its appropriateness. The Shared Parking analysis includes an 'Adjustments" row that does not appear in the traditional ULI analysis. This row has apparently been used to further reduce parking demand by as much as 90% for some of the component uses without explanation. On the weekday calculations, it results in a reduction of 38 parking spaces attributed to the hotel restaurant, 19 spaces attributed to the hotel meeting space and 81 parking spaces attributed to the hotel spa, for a total of 138 parking spaces being omitted prior to the consideration of joint use. The Shared parking analysis also makes assumptions about meeting room occupancy (1 person per 30 sq. ft. of meeting space) and auto occupancy (2.5 persons per vehicle) to forecast conference parking requirements. The ULI procedure does not specify these assumptions. Conference parking is normally well estimated by City code requirements (1 stall per 35 sq, ft., typically) for assembly areas. Use of an alternate approach produces a great risk of underestimation. For example, what happens if auto occupancy is not 2.5 persons per vehicle for a large proportion of events or if attendance at events is greater than the assumed 1 person per 30 sq. ft. of meeting space. Banquets typically seat approximately 1 person per 12 sq. It., a much higher density than presumed. As a result of the unsubstantiated assumptions in the LLG study the base parking demand for the meeting space at the hotel has been reduced an additional 142 parking spaces below City code, again prior to the consideration of joint use. As a result of these assumptions of upfront reduction in parking demand arising from (1) internal and pedestrian trip adjustments regarding retail, restaurant and office uses (200 spaces), (2) the unsubstantiated reduction in the base demand rate for hotel meeting space (142.spaces), and (3) the further unsubstantiated adjustments to base demand of hotel restaurant, meeting space and spa (138 spaces), the LLG analysis reduces the base parking demand by at least 480 parking spaces before eiving consideration to shared parking reductions. Therefore, even if one accepts the basic joint use reduction calculations contained Katz. Okitsu & Associates Page 7 of 8 in the LLG study (even though questions still remain as to the appropriateness of certain assumptions in those calculations'), the study likely understates the actual parking needs by approximately 389 spaces'. Therefore; even if the City should zpprove the "Reduced Alternative' while requiring the greater amount of parking based on the "Full Buildout" scenario; a shortage of approximately 213 parking spaces is probable. As an alternative perspective; if one excludes the unsubstantiated reductions in base demand, but otherwise duplicates the LLG calculations for the "Reduced Alternative` weekday scenario (LLG Table 6A), a total demand of 1,749 spaces results. One must additionally add 53 spaces for the relocation of lost street parking identified in the EIR for a total requirement of 1,802 parking spaces. However, with a total supply proposed of 1,542 spaces, a shortage of 260 spaces results. Lastly, it should be noted that shared parking assumes that all parking spaces are equally accessible and attractive to all potential users generally. In many cases this is not true. It is normally necessary to produce a parking management plan that demonstrates that the sharing of parking facilities is reasonable and will not require persons to behave in unusual manners to obtain parking. Comparison to City Parking Code The LLG analysis understates the City of Huntington Beach Code requirements for parking for the project. The last sentence on page 3 of the LLG report states correctly that the City code requirement for parking for hotels is, "1.1 spaces per room of hotel use plus one space per passenger transport vehicle (minimum of two) and any additional uses within the hotel (i.e. banquet/meeting/ballroom, restaurant; and spa)'. However, in the later Tables 2A and 2B where City Code parking requirements are calculated, the hotel restaurant is considered, but the hotel meeting space and spa is omitted from the calculations; resulting in an understatement of 356 spaces of code requirement. (266 spaces for meeting use at 1 space / 35 sq. ft. plus 90 spaces for spa use per the LLG shared parking tables 5 and 6.) As a result, the claimed modest reductions in parking based on the shared parking analysis are in fact considerably greater, and the claimed parking surplus is in fact a substantial parking deficit. '- For instance, hotel room occupancy is assumed to be lower on weekends than weekdays, which is contrary to the experience reported by you at the Hilton and Hyatt hotels at the same location. s The LLG shared parking calculation results in a reduction of approximately 19% when excluding the unsubstantiated base demand rate reductions. Therefore, reducing the initial shortage of 480 parking spaces by 19%, a net shortage of approximately 389 parking spaces results. ' The difference in base demand between the 'Maximum BuildouC scenario and the "Reduced Alternative' scenario is approximately 176 spaces. 389 spaces minus 176 spaces of reduced demand equals a net shortage of 213 spaces. Katz. Okiisu & Associates Page 8 of 8 . _�rar..ad'Lee,rr•ri:r:c..rmvn Conclusion We are very concerned that some key assumptions have been taken during the preparation of the traffic and parking analyses for this project. These key assumptions serve to underestimate the traffic impacts and parking demands for the project. We do not believe that the analysis prepared can be used to reliably estimate impacts in these areas. There is too high a potential that impacts have been overlooked, underestimated; or not fully mitigated. Deviation from accepted analysis techniques should not be taken, simply because the analyst feels that they are appropriate. Any deviation from measured and standard behavior for normal land uses should only be taken based upon a satisfactory and representative number of measurements of comparable uses in comparable settings. Reductions based upon opinions alone are highly likely to cause unintended consequences. We believe that the City and its agents should base the analysis upon widely accepted traffic generation rates and parking demand analysis techniques, supplemented by local data to justify deviations from the key provisions of these procedures. Please contact me if you have any questions. Sincerely, Rock Miller, P.E. Principal Attachment: Resume J:VREi411HB PacificCiry.JA46i0.doc Katz, Okitsu & Associates Tragic EnCirrnn and Tmmronmion PMnrse.6 Rock E. Miller, P.E., P.T.O.E. VICE PRESIDENT/PRINCIPAL ENGINEER Education 1976 ,M.S. (Civil Engineering), University of California, Davis 1973/B.S. (Civil Engineering), University of California, Davis Registration 1999/Professional Traffic Operations Engineer: Institute of Transportation Engineers (No. 205) 1980/Professional Engineer: California No. 1139 (Traffic—Exp 9/30/2004) 1979/Professional Engineer: California No. 29493 (Civil—Exp 3/31/2007) Professional Memberships Fellow, Institute of Transportation Engineers Institute of Transportation Engineers, District 6, International Director (2004-2006) Institute of Transportation Engineers, District 6, President (2000-2001) Institute of Transportation Engineers, Section President (1990-1991) City Traffic Engineers Association, President(1986) Orange County Traffic Engineering Council, Chairman(1982-1983) Employment History 1990-present - Vice President, Katz, Okitsu & Associates, (formerly Firm Principal at Rock E. Miller and Associates), Tustin, California. Previously founder and proprietor of a Transportation Engineering Consulting firm; Presently Regional Manager of the Orange County/San Bernardino County offices for Katz, Okitsu & Associates Traffic Engineering and Transportation Planners firm. Manager/Engineer for all projects undertaken by the firm, including Design projects, traffic operations studies, impact studies, litigation, special studies, signal timing, and assistance to municipalities. 1987-1990 - Principal Transportation Engineer, Basmacivan-Darnell Inc., Irvine, California. Project Engineer and Project Manager for over 100 transportation projects, ranging from site impact studies to major transportation improvement projects, including several contracts in excess of S50,000.00 1979-1987 - Transportation Services Manager/Traffic Engineer, City of Costa Mesa, California. Head of Transportation Services Division, supervised 15 full time employees, and administered over S20 million in capital improvements. Performed all transportation planning for South Coast Plaza/Metro developments, including a 2.7 million square foot shopping center and over 5 million square feet of office space. 1976-1979 - Associate Civil Engineer, County of Orange, California. Performed assignments in traffic engineering and transportation planning. Developed first uniform criteria for environmental impact traffic studies and traffic generation. Developed several traffic forecasting models using UTPS and Planpac software. Katz, Okitsu & Associates Trrfc&tme i nnJTmnfycnmicn Plannat Rock E. Miller, P.E., P.T.O.E Continued(page 2) Professional Experience Mr. Miller has over 25 years of experience in Traffic and Transportation Engineering, including design services for traffic signals and traffic signal systems, signal system operation and timing. He has served as the former City Traffic Engineer for Costa Mesa and Traffic Engineer with the County of Orange County, as well as having over 15 years of experience in Consulting Traffic Engineering. He has been recognized as an expert in pedestrian safety and circulation enhancement design in Southern California. Mr. Miller recently completed 4 years of service to the ITE District 6 Board, and now is servicing as an International Director for ITE for the years 2004-2006. Below are several projects he has worked on: Citywide Pedestrian Safety Study(Phase I &II), Santa Ana,California Expert Witness. City of Santa Ana, Pedestrian Accident Claims, Santa Ana,Califomia On-Call Traffic Signal Designs,Anaheim,California On-Call Traffic Calming Services,Culver City, California Mission Valley ATMS/ATIS, San Diego.California U.S. 101 at Victoria Avenue, Ventura, California Harbor Boulevard Surveillance Project, Santa Ana, California Harbor Corridor Entertainment Center Study,Garden Grove, California : Highland Traffic Studies, Highland,California : Honolulu Signal Timing, Honolulu, Hawaii Terminal Island Transportation Study, Port of Long Beach.California Dominguez Hills Village,Carson,California : Mater Dei High School Study, Santa Ana,California : Glendora High School Study, Glendora, California Alameda Corridor EIR and EIS, Los Angeles County,California Dana Point Harbor Parking Master Plan, Dana Point.California Irvine Entertainment Center, Irvine,California Downtown Traffic Signal Timing Coordination, Long Beach,California : Perris Boulevard Signal Timing Coordination, Moreno Valley,California • District 21 Interceptor Sewer Rehabilitation, Los Angeles County, California : Enhanced Pedestrian Crosswalk Study(Phase I & II), Santa Monica, California 3-Car Train Study, Design, & Implementation, Long Beach,California Special Skills Operation of Various Traffic Signal Systems Traffic Signal Timing Software, including PASSER2, TRANSYT, SYNCHRO, etc. Traffic Forecasting Software Numerous PC Based Computer Programs, including advanced CAD applications Traffic engineering design services in Oregon, Arizona, Hawaii, and in over 150 cities in California Katz, Okitsu & Associates Trnf:irCinnn rind T'j."n.uraa TTnirem Rock E. Miller, P.E., P.T.O.E Continued(page 3) Presentations Mr. Miller has made presentations to technical and walk-advocacy groups about pedestrian safety and engineering issues. These include the following: ❑ Santa Ana Crosswalk Study, multiple presentations to Institute of Transportation Engineers, including International Annual Meeting, International Mid Year Meeting, California Border Section, Southern California Section, and Orange County Transportation Engineering Council. ❑ Crosswalk Safety Studies, presentations to Institute of Transportation Engineers District 6 Annual Meeting, Metropolitan Transportation Authority (Oakland, CA) Pedestrian Task Force, Las Vegas Fall Transportation Conference, and other groups. The presentation included a review of the findings of a series of old and new pedestrian studies. It shows how misunderstood some of the legacy findings have become, and how conservative some of the implementing agencies have become. It also shows how pedestrian facilities can often be enhanced without great risk or great investment. ❑ Fountain Valley Illuminated Crosswalk Study, presentations to Orange County Traffic Engineering Council and to Southern California Section, Institute of Transportation Engineers, 2001. ❑ "Designing for Pedestrians" Seminar on July 31, 2003. Rock Miller presented and sponsored a seminar for the City of Santa Ana and other Cities. Over 70 attended. Articles I Studies for ITE I Awards Mr. Miller has written and chaired several articles for the Institute of Transportation Engineers (ITE). These include the following: ❑ Safety in Marked and Unmarked Crosswalks, Article in Institute of Transportation Engineers, Traffic Engineering Council Newsletter. May 2000. ❑ Active Control of Nighwav/Rail Grade Crossings, Chaired an "Informational Report Committee" to provide an overview and summary of traffic controls used at active crossings, with particular emphasis upon new and supplemental treatments that are being considered or demonstrated at this time. LRT crossings were treated with equal weight as other crossings ❑ 2002 WesternlTE Editors Award - Institute of Transportation Engineers District 6 — For the Article In Pavement Flashing Crosswalks — State of the Art by Rock Miller, PE and George Dore, PE. Article Published in WesternlTE November-December 2001. References A11r. T.C. Suiaria, City of Santa Ana, (714) 647-5604 Ms. Ellen Gelbard, City of Santa Monica, (310) 458-2216 Mr. Taherjalai, City of Anaheim, (744) 765-3183 Mr. Nazir Lalant, County of Ventura, (805) 654-2080 EXHIBIT "C" TO LETTER DATED JUNE 3, 2004 Additional comment letter from Richard Watson & Associates Dated June 3, 2004 RICHARD WATSON & ASSOCIATES, INC. Urban & Regional Planning 3 June 2004 Shawn K. Millbem Senior Vice President The Robert Mayer Corporation 660 Newport Center Drive, Suite 1050 Newport Beach, CA 92660 Dear Mr. Millbem: Per your request, I have reviewed sections of the Final Environmental Impact Report (EIR) prepared for the City of Huntington Beach by EIP Associates for the Pacific City project, and the Conditions of Approval related to water quality adopted by the City of Huntington Beach Planning Commission on May 5, 2004. I have focused on water quality issues, particularly to responses to my letter report of 02 December 2003. Inaccurate Statements Concerning Water Oualitv Standards A false statement was added to the brief discussion of the Basin Plan on page 3.8-11 of the Draft EIR. It is highlighted on page 2-49 of Volume III of the Final Environmental Impact Report. The added sentence says "No water quality standards have been set for bacteria levels." The error is compounded by a sentence added to the expanded discussion of the Orange County Drainage Area Management Plan. A sentence added near the end of the section states that "BMPs can serve to address bacterial contaminants in addition to other contaminants, although there are no water quality standards for bacteria levels." The preparers of the Final EIR were either unfamiliar with the bacteria objectives of the Water Quality Control Plan for the Santa Ana Region (the Basin Plan) and the Water Quality Control Plan for Ocean Waters of California (the Ocean Plan), or chose to interpret the use of indicator bacteria in water quality objectives as "no water quality standards." On January 24, 1997, the Santa Ana Regional Water Quality Control Board (SARWQCB) conducted a Basin Plan amendment workshop concerning bacterial water quality objectives. The focus of this workshop was the difference in bacterial water quality objectives between the Basin Plan and the Ocean Plan. As a result of discussion at this workshop, Regional Board staff was directed to prepare an amendment to the Basin Plan that would delete the bacterial objectives then in the Basin Plan, and instead, rely on the bacterial objectives in the Ocean Plan. DEVELOPMENT SERVICES • STORM WATER QUALITY • STRATEGIC PLANNING 21922 Viso Lane • Mission Viejo, CA 92691-1318 USA • 949.855.6272 - Fax 949.855.0403 www.rwaplanning.com • rwatsonarwaplanning.com Mr. Shawn K. Millbern 3 June 2004 Page 2 of 3 On .April 18, 199T the SARWQCB adopted Resolution No. 97-20, which deleted the specific bacterial water quality objectives in the Basin Plan; but left in place the incorporation of Ocean Plan Water Quality Objectives by reference. The Ocean Plan contains a comprehensive set of bacterial water quality objectives specifying total and fecal coliform densities as water-contact standards and total cohform densities as shellfish harvesting standards. Amendments to these standards are currently being considered by the State Water Resources Control Board. Compliance with these indicator bacteria water quality standards, especially the total coliform standards. is very difficult. A great deal of effort is being expended to develop better standards that more accurately measure human pathogens, but until they are changed, the broad bacterial indicator standards are the measures that must be met to be in compliance with the Ocean Plan and Basin Plan. The erroneous statements concerning water quality standards for bacteria should be removed from the Final EIR by the City Council. The City should also correct the statement on page 2-55 (page 3.8-25 from the Draft EIR) that"cumulative development is not expected to otherwise substantially degrade water quality." As explained in my letter report of 2 December 2003, unless a BNIP to kill indicator bacteria is installed to treat discharges to the First Street Drain, there is a high probability that the diversion of urban runoff from 26.9 acres of Pacific City to the First Street Drain will result in violations of bacterial water quality standards where the drain discharges to the beach. In the response to comments on my letter of 2 December, the Final EIR refers to Topical Response to Water Quality on page 3-173 for a discussion of why dry weather runoff is not required to be treated by the Orange County Sanitation District (OCSD). This discussion is inaccurate because it is based on erroneous statements concerning bacterial water quality standards discussed above. Furthermore, the response to comments indicates that "the dry weather flow for Drainage Area B can be routed into the Atlanta Stonmvater Pump Station (AS WPS), in order that, at the City's discretion, these flows may be routed for Treatment by OCSD." 1 am surprised that the City agreed to the phrase "at the City's discretion." That phrase appears to set the City up for a future liability if the dry season flows to the First Street Drain are not diverted to the OCSD and there is another long-term beach closure due to bacterial contamination of the discharge from the storm drain. Inadequate Condition of Approval The Condition of Approval specifying the contents of the Project Water Quality Management Plan (WQNIP) to be submitted to the Director of Public Works prior to the issuance of grading permits partially addresses issues of dry weather, first flush, and storm flow discharges. However, the requirement for treatment focuses only on a "structural filtration system." Treatment control BMPs to control indicator bacteria and Mr. Shawn K. Millbern 3 June 2004 Page 3 of') human pathogens are not required. Further, there appears to be no assurance that the diversion of dry weather flows from drainage area B and the First Street Watershed to the OCSD for treatment will actually be implemented. A system designed to do so will be described in the WQMP, but the language in response to comments suggests that implementation will be at the City's discretion. Also. the Condition of Approval requires the applicant to develop a concept for a regional urban runoff treatment solution for the First Street Watershed flows and to prepare plans and estimated costs for the system. The applicant is required to post a bond for 1/7 of the capital construction and to include in the Pacific City CC&Rs that the project will pay 1/7 of the operation and maintenance costs for the system. It appears that this system is not intended to treat urban runoff from drainage area B within the project. An earlier portion of the Condition of Approval specifies drainage areas A, B, and the First Street Watershed, while the requirements related to a regional urban runoff treatment solution only refer to the First Street Watershed storm flows. Conclusion The discussion of water quality in the Final EIR is inadequate. It is based, in part, on misstatements about bacterial water quality standards. The WQMP Condition of Approval provides specific direction to the applicant for preparation of the WQMP, but it does not address the need to treat dry weather and first flush discharges to kill indicator bacteria and human pathogens. There remains a high probability that discharges from the First Street Drain to the beach will violate water quality standards. Sincerely, RICHAN WATSON & ASSOCIIA/TES, INC. (RWA) Richard A. Watson, .A.I.C.P President RAW/jwm r EXHIBIT "D" TO LETTER DATED NNE 3, 2004 Complaint regarding clearing of vegetation Dated May 28, 2004 THE ROBERT MAYER CORPORATION May 28, 2004 BY FACSIMILE TRAiNtSMISSIONT 2:00 P.M. City of Huntington Beach Public Works Department 2000 Main Street Huntington Beach, CA 92648 Attn: Terry Elliot Dave Webb Re: Pacific City Development Site Dear Sirs: The purpose of this letter is to memorialize my complaint to your department placed by telephone call at approximately 1:30 PM and again at 2:00 PM today. I have observed and photographed three workmen on the Pacific City site using motorized tools to remove vegetation from the site. As you know, entitlements for this proposed project are currently on appeal to the City Council. The grounds for appeal include concern that potential wetlands exist at the site, and that a proper wetland delineation has not yet been performed. It is possible that this clearing activity may remove wetland indicator species and damage areas which are, or may in the future be identified as, wetland habitat. The clearing of vegetation at the site at this time may be a violation of law, and in any event is a gross violation of good faith on the part of the project applicant in that it is an obvious effort to prevent the proper study of the site for potential wetland habitat. I request that you department immediately cause this activity to cease and that you order the project applicant to refrain from such activity until all appeals and litigation regarding the project EIR and entitlements, including an appeal to the California Coastal Commission if applicable, are concluded. Yours Truly, Shawn K. Millbem Senior Vice President The Robert Mayer Corporation cc: Meg Vaughn, California Coastal Commission 660 Newport Center Drive . Suite 1050. Newport Beach, CA 92660 P.O. Box 8680 . Newport Beach, CA 92658.8680 tel 949.759.8091 . fax 949.720.1017 Fikes, Cathy From: Debora George (customerservice@wireacake.com] Sent: Thursday, June 03, 2004 10:18 PM To: cfikes@surfcity-hb.org Subject: we are opposed to pacific city I Importance: High Dear City Council members Thank you for this opportunity to be heard. As recent proud homeowners and tax payers of Orange county (address at Huntington Bayshore Condo) Huntington Beach, we are opposed to the Pacific City Planned development . Reasons are simple and most obvious: increased traffic . . . . resulting in increased pollution: Environmental and Noise. . . the streets are already congested on weekends the cars on PCH , 1st, Orange & Main are steady and backed up to each intersection. We appreciate the presence of local law enforcement on the streets and we fear they will be burdened by the increased traffic and foot population with potential for rowdiness leading to mischief and crime. The elevated buildings on PCH proposed by PC will obstruct the beauty of the pacific shoreline. There are limited unobstructed coastline views and PC project will destroy the view for many local residents. Sacrifice of the environment for expansion . . . what a price to pay. We have faith in you, the City Council members to limit the PC plans. Dr & Mrs Stan Tsakoumakis cell 661-904-2243 c 0 c -- L i C C 2 - 1 Z_ J n_ = IV LO C ) D Jun-07-2004 01:24pm iron-CaIiforn,a CoutaI Cor,tnor. T-765 F M/504 F-362 A . / qaQrrgC=1 ri-NCY Amofd ehw, ne^e^^^ Gn....m. CALIFOWNIA COASTti CONDIISSION South Cola A-M pfTce 200 C)papnyeie.Suite:000 l^ tuna 0eeerr,CA 90Y024302 (562)590-5071 June 7, 2004 Scott Hess City of Huntington Bea Department of Commur ity Development 2000 Main Street Huntington Beach, CA 2648 Re: Coastal Developmo nt Permit 02-12, Pacific City Dear Mr. Hess: The City Council will be heairing an appeal of the Planning Commission's approval of coastal development pe it No. 02-12 (as well as additional, related approvals) for a project commonly known as Pacific City. On April 13, 2004 1 sent a letter raising specific questions with regard to the project's appealability to the Coastal Commission. The April 13, 2004 letter is included herein for reference. We have not received a formal response from the City to the questions raised in that letter. Nevertheless, the issue of whether the development is appealable to the Coastal Commission needs to be resolved. Please be sure the record of any a tian the City takes on this matter contains a clear response to our April 13'n letter. Please do rot hesitate to contact me at the above rumber with any questions regarding this matter. Sincerely, rWaA Meg Vaughn Staff Analyst MNS Pctcry Itr 6.7.04 my Jun-07-2004 01:240m From-California Coactal Commiccian T-765 F.003/004 F-362 S"A1'17.nV rA I IFORNIA -TN[BIS(ICR FR rpNry A nfd Sc W oen- ., Cm✓"nnr CALIFORNIA COASTAL COMMISSION Soul11 Cow Area Office , 2000:eangare.Suite 1000 n Leng RCJCe .CA 90902•4102 , (562)J90.5071 April 13, 2004 Scott Hess Department of Commu ity Development 2000 Main Street Huntington Beach, CA 2648 Re: Pacific City Appeal bility Dear Mr. Hess: This letter is intended to clarify the Coastal Commission staff position on whether the local action on a coastal dev lopment permit for the project known as Pacific City is appealable to the Coastal Commiss on. In reviewing new and/or more specific information available to staff, the proposal appe rs to contain development appealable to the Coastal Commission. For example, pursuant to a wetland delineation based on the Coastal Commission wetland standards, if wetlands a e found to exist on the subject site, the projectwould be appealable to the Coast I Commission. The definition of "wetland" is found in the appendices.of the certified Land Use Plan, Section 216.04-F of the City's certified Implementation Plan, a d also in Section 4.0.04 of the Downtown Specific Plan. Section 30603(a)(2) of the Coas al Act states that developments approved by local governments that are "within 100 feet f any wetland" are appealable to the Coastal Commission. If wetlands are found to a ist on site, an approval of development within 100 feet of those wetlands would be app alable. Please forward any wetland delineation made using the definition of wetland in t e certified LCP so that our staff can assist in the evaluation of the appealability of the proj ct based on this factor. In addition, pursuant to ection 30603(a)(5).of the Coastal Act,approval of a local coastal development permit for'any development which constitutes a major public works project or a major energy facility" i1 appealable to the Coastal Commission. The project includes widening of Pacific Coa t Highway, which may constitute a "major public works" project if it meets the definition of a "major public works" project as defined in Section 13012 of the California Code of Regu ations (CCR). Section 13012(a) of the CCR states: (a) "Major public woi ks" and Major energy facilities" mean facilities that cost more than one hundred thousand dollars ($100,000) with an automatic annual increase in accordance with he Engineering News Record Construction Cost Index, except for those governed qy the provisions of Public Resources Code Sections 30610, 30610.5, 30611 r 30624. (Note: The exempt s.identified ir> the PRC Sections above are not applicable in this case.] Jun-07-2004 0I:24pm From-California Coastal Commission T-765 P.004/004 F-362 Pacific City Appealability Page 2 Given the scope of dev opment contemplated, the highway widening aspect of the proposed project likely Jualifies as a "major public works" project, and thus the project would be appeatabie fol this reason. Please advise if you believe the cost of the development wouldn't e ceed the threshold for it to qualify as a "major public works" project. In addition, developme t "between the sea and the first public road paralleling the sea" is appealable to the Coas al Commission. According to Section 13577(i) of the CCR: "When based on a road designated pursuant to this section, the precise boundary of the permit and appeal jurisdiction shall be located along the inland right-of-way of such road." Thus, approval of a coastal CIE velopment permit for development, such as roadway widening within the road right-of- ay, Is appealable to the-Commission. Furthermore, if the widening of the roadway necessitates the transfer of private land to a public entity (such as the City or Caltrans), th approval of the land division for this conveyance may be appealable to the Coas I Commission. An approval of the Paci is City project which meets the requirements noted above would be appealable. Accordi gly, any public notices pertaining to the coastal development permit application for th project should reflect the appealable nature of the development. Also, please note that a I aspects of the project, including off site project related development such as d in pipes or infiltration bubblers on-the beach, must be described and evaluated as part o the project review process. Please do not hesitate t 3 contact me at the above number with any questions regarding this matter. Sincerely, Meg Vaughn Staff Analyst HNS PdCty IV 4.13.04 my t- Subject QOGI FI _ tT To t P 2�0 V G."TtaN Ova! O I A6r2 Af2n . . . Job z • GYp7 1 33 Sheets of E N G I N E E R 5 Made by L f»I Date _Checked by F2 5 Oate_-_7,�o Z D RECEIVED FROM � AND MADE APART OF THE RE 0 DAT THE 0 COUNCIL MEETING OF OFFICE OF THE CITYCLtRK C044*•BR8fl4ONAY,CITY CLERK ti h o \ cxN _ 0\. S �i✓�I G� HO"ram(___ O� i S 0 0- tti y� �3 , 37 (Zrvat_ C�P"CJ 2t= 142 SPACE REDUCTION 480 SPACE REDUCTION BEFORE JOINT-USE CALCULATIONS 138 SPACE REDUCTION E N G I N S TABLE 6A 200 SPACE REDUCTION - 'JED FROM ADE A PART OF THE CO�111�l THE WEEKDAY MIXED-USESHARED PARKIN DEMAND ANALYSIS: DUCED ALTERNA LAN .,.IL MEETING OF �ILL1— OFFICE OF THE CITY CLERK Pacific Ity, Huntington Beach COMGlF4N49CKMMT,CITY CLERK fp (2) (3) (4) (5) (6) (7) (g) Signature Hotel('anference/ Land Else Hotel Hotel Restaurant Nleelin Rooms Hotel Spin Retail Restaurant Office Size(SF) 400 Keys 5,000 SF 9,300 SF 30 Treatment Rooms 112,200 SF 55ANSF 30,000 SF Pk Rate 1.1 S Key 1.0 Sp/100 SF See Note I 3 SP/IEm ® 1 SPf200 SF 1 SP1100 IF 5) 1 SP/250 SF [Adjustments S aces 442 S aces SO S aces 124 S aces 90 Spaces121 477 m 2 440 �I Spaces131 114 a/a 25%Is -guests 85% non-guests 10%non-non-guests 100% 100% 100% Seasonal Ad'. 100% 100% 100% 100% 1000". 100% 10o5a lbmt Percent No.of Percent No.of Percent No.of Percent No.of Percent No. of Pcrccnl No.of Percent No.of Shared Time of Peak Ps ling of Pcak Parking of Peak Parking of Peak Parking of Peak Psi lung of Peak Puling of Peak Parking Parking of Das Demand S Aces Drmand Spaces Demand S acts Demand Spaces Demand Spaces Demand Spaces Demand Sraca Demand 6:OOAM 1000/a 442 204/0 3 0% 0 5% 0 0*E 0 0% 0 3% 3 448 7:OOAM 85% 376 20% 3 0% 0 10% 1 So. 38 2% 9 20% 23 4 S 0 S:OO AM 65% 287 201/6 3 0a/a 0 4054 4 17°. 81 5% 22 63% 72 469 9:00 AM 55% 243 20%. 3 5% 5 55% 5 40% 191 100/. 44 93% 106 397 10:00 AM 45% 199 200/. 3 109/0 1I 75% 7 65% 310 20% 88 100% 114 732 11:00 AM 60% 265 30%. 4 50% 53 90% 8 8)% 396 300/6 132 100% 114 972 NOON 75% 332 506% 6 0 100% 105 1004/6 9 92% 439 70% 308 90% 103 1.302 1:00PM 75 332 70% 9 )Do% Jos 100% 1 95% 433 70% 308 90% 103 1,319 2 00 PM 55% 243 60%. 8 50%a 9 9 60% 264 97% 111 1,127 3.00 PM 35% 155 55% 7 101% OINI — ! Q k.glk..t.- - N C 606% 264 93% 106 981 4.00 PM 45%. 1" 50% 6 5% 5 85% 8 83% 396 300/0 220 77% 88 922 5,00 PM 60%. 265 70% 9 10%. 11 65% 6 75% 358 70%a 308 47% 54 ),011 6 00 PM 70% 309 9056 11 50%. 53 35% 3 79% 372 901/6 396 23% 26 1,1 'n 7T.00 Ph1 75% 332 100%4 13 1009% 105 15% 1 85% 405 100% 440 7% 8 1.104 8.00 PM 90% 398 100% 13 100%. 105 ID% 1 83% 396 1000% 440 7% 8 L36I 900PM 95% 420 1005: 13 100%. 105 5% 0 58% 277 100% 440 3% 3 1,2S8 10.00 PM I W% 442 90': 11 75% 79 0%a 0 30% 143 90%. 396 3% 3 1,074 11 00 PM 100°: 442 70°: 9 50% 53 0% 0 12% 57 700/. 308 Dub 0 869 MIDNIGHT IWO. 442 509 6 25% 26 0% 0 OS. 0 5w. 220 0°0 0 694 1 R uucd uktn sus dcmrtntn<d based on 1 person per 30 SF and 2.5 persons per rehklc f [2)The requited puking space calculanwss fw the retail and rotswaat uses assume a 15%and 20%discomr,respectively.to scawm for walk-in parsons 6om the adjacent beach community,dwwwwwaM saga sik (31 The oequated puking space calculations for the office use nsunse a 5%discount to account fw walk-in paoonn town the Adyccnt beach cotmounity a:12 1001200 2 1 3 5Yabkst2 03 Weekday Shared Parking 630-03.a1s RECEIVED FROM '� Pacific City Action CoalitionAND MADE A PART OF ERECORD AT THE �/ COUNCIL MEETING OF OFFICE OF THE CITY CLERK Coastal Development Permit Appeaffo�Y-CITY CLERK The City of Huntington Beach's Local Coastal Plan in the General Resource Protection Policies states, "When policies within the Coastal Element conflict, such conflicts shall be resolved in a manner which on balance is the most protective of significant coastal resources." The Land Use section CIA goes on to state, "Ensure that adverse impacts associated with coastal zone development are mitigated or minimized to the greatest extent feasible." The Pacific City Action Coalition believes that the approval of Coastal Development Permit #02-12 based on documented site testing and remediation conducted thus far by Chevron and developer Makar Properties is out of compliance with the City's Local Coastal Plan. It is misleading, incomplete and contradictory. It is the Coalition's position that the best means to effectively mitigate adverse coastal impacts is to have an independent consultant, chosen jointly by the Coalition, Makar, Chevron and the City, oversee the site's testing and clean-up. Huntington Beach residents are becoming extremely concerned by the increasing numbers of cancers afflicting neighborhoods in our city. In addition to the children whose faces we've seen in the papers battling leukemia or rare brainstem tumors, we're taking a closer look at our adult friends and neighbors who are battling, or in some cases have lost, the battle with cancer. Many residents are working together to survey and document cancer cases. In a recent survey of our own, we've found 6 cases of cancer out of 12 homes on the same block of the Pacific Mobile Home Park (adjacent the Pacific City site). On one street in Seaside Village (neighbors to the mobile home park), 11 cases of cancer out of 36 homes uncovered thus far. Given the above stated cases, other cases close to the Ascon-Nesi site, and the publicized children's cases, we feel that these numbers are extremely high in relation to UCI's overall Orange County data. With Chevron's past involvement with the residents in Lufkin, Texas, do we really think they have or will treat us differently? Our residents no longer wish to rely on Chevron, developers or their significant influence on our city to oversee, clean up and protect our coast. We demand an independent consultant, not one selected from the City's pre-approved list, most of which have close ties to Chevron or other oil companies. RECEIVED FROAq �`_ AND MADE A?q,=;i THE RECO;tu AT THE G/ COUNCIL 6d7=TINl9 JF 7 '��"J.E.�OF THE CITYCLERL O� L� O Y. CITY CLERK Pacific City Action Coalition City Council Presentation June 7, 2004 www . pacificcityactioncoal ition . info With Chevron , developer Makar Properties and the City's dismissal of the Coalition 's push for a truly independent site review, Chevron 's power and influence over this development in particular and the City in general has become increasingly clear. Designed to protect the community's health and safety, an independent site review is essential to this project. A survey of residents living in a five block area near Ascon-Nesi , a Federal Superfund site known to contain cancer causing chemicals revealed : Fourteen cancer cases occurred in the last 15 years, 7 of which surfaced in the last 5 years 12 cases occurred in a 3 block area These rates are 10 to 87 times higher (depending on the cancer type) than the overall cancer rates in Orange County Chevron 's failure to disclose what is contained on the Pacific City site is strikingly similar to their past practices in nearby Texas In fact, residents of Lufkin , Texas, have filed lawsuits against Chevron Pipeline Company for environmental health related damages in their neighborhood which they allege are linked to a 20 mile pipeline that carried crude oil , diesel fuel and gasoline through their property. According to the Lufkin Daily News, "the contamination site was discovered in 2002 when a local housing contractor requested that Chevron remove the pipelines. The contaminated soil was removed and monitoring wells were installed . The mobile homes were removed and Chevron purchased the property, as well as the neighboring property. Such incidents are required by law to be reported to the Texas Commission on Environmental Quality (TCEQ). But it was more than a year before Chevron submitted its report on the 2002 discovery to TCEQ." The city of Lufkin then conducted soil and groundwater tests in January and July of 2003 at depths of two and 30 feet and found high levels of benzene. The attorney representing families in the lawsuit, reports the Daily News, has videotape evidence of Chevron attempting to excavate a portion of their pipeline in the middle of the night. The Coalition has uncovered evidence of (1 ) Chevron's secret request of the state Water Board for an exemption from cleaning up contaminated soil potentially in contact with groundwater and then submitting documents detailing a completely different part of the site and (2) signs warning of cancer causing chemicals on the site which were inexplicably removed without the disclosure of records warranting their posting. The Coalition demands that the E I R #02=01 , Conditional Use Permit #02w20 with Special Permit #02-04 a n d Coastal Development Permit #02- 12 for this project not be approved . The community will not tolerate such secrecy and lack of disclosure when the lives of both children and adults are at stake. We will continue to aggressively push for the selection of a truly independent consultant. RECEIVED FRCdA p p T THE AND MADE A PART OF THE COUNCIL MEETING OF OFFICE O THE CI CITY CLERK S4RN r-(YAn PACIFIC CITY ACTUAL CODE REQUIRED PARKING CODE REDUCED ALT REQUIRED USE REQUIRED PLAN SPACES Office 1250 s.f. 30,000 s.f. 120 Restaurant 1/100 s.f. 48,900 s.f. 489 Outdoor Dining 1/100 s.f. 6.100 s.f. 61 Retail 1200 s.f. 112,200 s.f. 561 Hotel 1.1/Room 400 Rooms 442 -Restaurant 1/100 s.f. 5.000 s.f. 50 -Banquet 1/35 s.f. 9,300 s.f. (net) 266 -Health Spa 3hreatment room 30 treatment rooms 90 On-Street Parkin 1/1 replacement 53 TOTAL 2,132 PROPOSED 1,542 Difference 1 (590) Cvrj�c'7�Cfl�� OFF-STREET PARKING SPACES REQUIRED. SCHEDULE A(� ti.wd) (33346197) se assifica Off�treet king Spaces Visitor Accommodations(cont.) 1 Hotels, Motels 1.1 per guest room;plus I per passenger transport vehicle (minimum of 2 stalls) and 2 spaces for ) any manager's unit and parking for other uses as required by this schedule Single Room Occupancy, 1.0 per unit, 10% shall be designated as visitor Residential Hotels parking; 1 per passenger transport vehicle (minimum of 1 stall)one loading space, and 2 spaces for any manager's unit,plus 0.5 per all remaining personnel (3+94.5ro1) Warehouse and Sales Outlets 1 per 200 sq. ft. Industrial Speculative buildings 1 per 500 sq. ft. (maximum 101/6 office area) Manufacturing, research assembly, 1 per 500 sq. ft. packaging Wholesaling, warehousing and I per 1,000 sq. ft. distributing space Offices 1 per 250 sq. ft. if office area exceeds 10 percent of gross floor area Outside uses: Storage,wrecking/ 1 per 5,000 square feet of lot area,but no less salvage and lumber yards than 5 Mini-storage facilities Single-story i per 5,000 square feet Each additional story 1 per 2,000 square feet plus 2 spaces for any caretaker's unit 231.06 Joint Use Parking In the event that two(2)or more uses occupy the same building, lot or parcel of land, the total requirement for off-street parking shall be the sum of each individual use computed separately except as provided in this section. (3334-&e7) The Planning Commission or Zoning Administrator may grant a reduction in the total number of required spaces as part of the entitlement for the use or uses,or by conditional use permit when no other entitlement is required, when the applicant can demonstrate that the various uses have divergent needs in terms of daytime versus nighttime hours or weekday versus weekend hours. Such joint use approvals shall be subject to the following: (33344&97) Huntington Beach zmng ar4 Subdivision Ordinance Chapter 231 231-10 Sro1 9606(a)H--9606(a)R 04 Hotels and motels 1 per guest sleeping room, \ { 1 employee space per 10 \1 guest rooms; 2 spaces for —� any manager' s unit I . Industrial uses ( 1 ) Manufacturing , re- 1 /500 square feet search assembly, packaging, specula- tive buildings (2) Wholesaling , ware- 1/1000 square feet housing and dis- tributing space (3) Storage, wrecking/sal- 1 /5000 square feet, but no vage and lumber yards less than 5 (4) Offices ancillary to 1 /300 square feet industrial uses if square feet exceeds 10 percent of gross floor area (5) Ministorage facilities Single story 1/5000 square feet Multistory 1 /2000 square feet Plus 2 spaces for any caretaker' s unit M. Medical /dental office 1 /175 square feet 0. Office uses , general ( 1 ) Less than 250,000 1 /300 square feet square feet (2) Greater than 250,000 1 /350 square feet square feet R. Rest or nursing homes 1 per 3 beds Retail uses not otherwise 1 /200 square feet specified, including de- partment stores , arcades , gymnasiums and health spas , financial institutions , food and beverage establishments with 12 seats or less 8/88 RECEIVED FROM AND MADE A PART OF THE RE O �I AT THE COUNCIL MEETING OF uY OFFICE OF THE CITV CLERK coNwE-&A0GKWAY.CITY CLERK Fogg) F/ynn PACIFIC CITY INTERNAL CAPTURE AND MODE SHIFT INTERNAL CAPTURE RESIDENTIAL OFFICE HOTEL RETAIL RESIDENTIAL 96 0 556 OFFICE x - 0 187 HOTEL X X - 711 RETAIL x X X 1,550 TRIPS INTERNALLY CAPTURED MODE SHIFT TO/FROM OFF-SITE. TOTAL IN OUT RESIDENTIAL 268 134 134 OFFICE 92 46 46 HOTEL 652 326 326 RETAIL 1,988 994 994 TOTAL 3,000 1,500 1,500 MODE SHIFT DENOTES TRIPS TO AND FROM THE SITE NOT UTILIZING A MOTOR VEHICLE G:\rmnsponation DivisionUannsiL%Icmos\Pacific City Handout ldo CITY OF COSTA MESA CALIFORNIA 92825-1200 PC Box 1200 CRCM THE OFFICE OF THE "dAYCR Junel, 2004 RECEIVED Cathy Green, Mayor JUN 02 2004 City of Huntington Beach 2000 Main Street CitY of Huntington Beach Huntington Beach, CA 92648 C)h CounA nh:,,_ SUBJECT: PACIFIC CITY ENVIRONMENTAL IMPACT REPORT Dear Mayor Green: The City of Costa Mesa has recently become aware of the processing of an Environmental Impact Report (EIR) No. 02-01 for the Pacific City development in Huntington Beach. Unfortunately, the City did not receive notice of this document and the public comment period that ended this past December and, thus, did not have an opportunity to provide comments on this proposed project. However, the Huntington Beach City Council consideration of an appeal scheduled for the June 7 meeting may be a timely opportunity for our City to provide comments. While the time to submit official public comment on the adequacy of the EIR has passed, the City of Costa Mesa is sincerely concerned with the impacts this project may have on the surrounding transportation network system. As you are well aware, both the cities of Huntington Beach and Costa Nlesa City Councils have been actively and aggressively pursuing a variety of avenues in opposition to the Banning Avenue/19'h Street Bridge as well as the Garfield Avenue/Gisler Avenue Bridge. Both cities have worked diligently through the Santa Ana River Crossings (SARX) study to accomplish the deletion of these bridges. With inference to the proposed Pacific City development, the EIR has provided a traffic analysis assuming the full build out of your General Plan and the future Master Plan of Arterial Highways (MPAH). Considering both cities have expressed concerns with the build out of the MPAH, and the impacts of the construction of the Banning Avenue/19`h Street Bridge, it is of utmost importance to determine the traffic impacts of the above major project to our two communities without the Banning Avenue/191h Street Bridge. As both cities will continue to oppose construction of this bridge, it is only reasonable to assume that this bridge will not be constructed in the foreseeable future, if at all. Accordingly, to gauge the "true impacts" of the proposed Pacific City development, the City of Costa Mesa hereby requests that the City of Huntington Beach require the addition of a second alternative that excludes the Banning Avenue/191h Street Bridge in its traffic analysis. It would also be appropriate to require the developer to construct or to contribute towards any mitigation that may be needed due to the absence of the bridge. Z-14 1-7--:-,, Co M n7 c c /tJi C0+7-2&P�) Cm b/-? /o 77 FAIR DRIVE PHONE (714)754-5285 FAX (714)754-5770 TOO (714)754.52" . v .axosta-mesa.f .us Mayor Cathy Green Page 2 June 1, 2004 The City of Costa Mesa welcomes the opportunity for any additional input should any further review of the project become possible. If you should have any questions regarding this matter, please contact me at 714-754-5285, or Peter Naghavi, Manager, Transportation Services, at 714- 754-5182. . Si rely, CJ� Gary Monahan Mayor /ch c Orange County Supervisor, James Silva Huntington Beach City Council Members Penny Culbreth-Graft, City Administrator, City of Huntington Beach Bob Stachelski, Transportation Manager, City of Huntington Beach Costa Mesa City Council Members Allan Roeder, City Manager William J. Morris, Director of Public Services Peter Naghavi, Manager, Transportation Services Mike Robinson, Planning & Redevelopment Manager Raja Sethuraman, Associate Engineer Dennis Johnson, Assistant Engineer City of Huntington Beach t'/r/ // l_IA Office of the City Clerk f `� P.O. Box Huntington Beach,, CA 92648 �% =• - 6 939 502 85 711 �pNTING Tpy Thomas Kotiranla 410 Lake St R203 Huntington Beach CA 92648 RETURt< RETURtr � 1. O �; 6FpppNTY � TO SENDER, 4: _ Tfl SFNf1FR4' �L'E6 EARING� > >-ari 'j S46 II!Irn II!I!I�nIIu�I!rI!Ilnnu��Illn�In(IIII IIInnr�!iI Office of the City Clerk --; _ P.O. Box 190 Huntington Beach, CA 92648 6 ` D 939 502 41 667 Lisa Stitt 430 Lake St "106 �pNTINGTpy Huntington Beach CA 9264U iE ..0... to v F URh cFt.nFev' - 1 _ _ 'L'EGAL NOTICE � ...--; 32cq a�-p 13r� �Illlln�!�I��n IIn�I!II!�Inln!I�Irinll!I II!�u l�n!!rl!II k City of Huntington Beach Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 937 151 54 �pt►TING jp� David Guzman & Karen Stein-Cueva 7971 Southwind Cir. Huntin.ton Beach, CA 92648 ca rFY,�'_�^o oQ EJPtt : . LEGAL NOTICE - PUB L�,G H. INC: r, 92 T4z -T 'a rJ _�v�: il!Ii!III!III111III liIIi II IIIII I!f II I!iIIII IIIIIII III!Ir!!ili Office of the City Clerk P.O. Box 190 / Huntington Beach, CA 92648 r � 93950386 812 �VNTIN6Tpy Rustin Guild 310 Lake St -215 Huntington Beach CA 92648 7. V ' GUIL310 9264d5007 � 303 42 06/03/ FORWARD TIME EXP RTN TO SEND GUILD -RUSTIN b3b1 BALMORAL DR HUNTINGTON BEACH CA 92647-6556 �oulrrr ca LEGAL NOTICE - PUBLIC HEARING_ c II.L11J11111:111tILtIIII:1,1tn11iltiIIIJ,II!Hill:lltH Office of the City Clerk f' ' N T /✓ n :l P.O. Box 190 Huntington Beach, CA 92648 V •�^r� = •' ` " l� 939 503 47 773 INGTpy Jason Macdonald �� " • e�y 320 Lake St#306 MACD320 926465007 .1203 42 06/03/i %►` �I. Q FORWARD TIME EXP RTN TO SEND .1�. MACDONALD JASON Q 245 7TP AVE OA VENICE CA 90291-2766 CO�NTY �� OCTI IOII Tf1 LFI,If1F0 LEGAL NOTICE - PUBLIC H€A6lN , 3zeoa— ,r��.., "' II;i:..JJ�1111J1tIIIIJl1t:1111li1L;1L,1Lllllll:t,ilii City of Huntington Beach r Office of the City Clerk = `�T %• I' P.O. Box 190 • • `� "' Huntington Beach, CA 92648 � \ - — Gi2��F�2� 939 503 68 794 Weston Chandler ,�uh1INGTp� 310 Lek- 5! #3 3 CA 92648 �pUN.T.Y.GP` CF....rl: ;i. SP G G P,UL LEGAL NOTICE - PUBLIC HEARING. flit I I ! II Ili Ili I II 1 i,il it : :lih1i a It 1 ulIII : It t:[II ::III.::: City of Huntington Beach r'" P,-Q�) K/ �✓ �. Office the City Clerk �C`�J��? • " '' P.O. Box 190 Huntington Beach, CA92648 93715275 572 Dennis Tr Reicks 7832 Seaglen Dr �QNTINGTpy Huntinaton Beach CA 92�48 iE .w•ro••.,a BF9 NL I Sti`64c;SUUS 130y 06 06i NOTIFY ENDER OF NEW ADDRESS I URI 91• /--'; Q. pT r•r-,�(.- I E 551 N 5 NT.A FE 5T APT 85 Cf, •,t �•p. \�0 1-IEMET C 54:9-3073 �puNTV p� ADDRESSEE LEG WwG�1_ R � tfIIN�, - - . 32b40-U130 Ii1!nu11111!n,!nilnl,llull nll 111 nl!ul!Ilnl!nn1!III vny vl I IVI lal lylvll Llpalil, i_ Office of the City Clerk ( V t -•v�- P.O. Box 190 VVVVIIIIIII I ' ' '' Huntington Beach, CA 92648 , La x / 024 202 14 113 Michael Gorman r — �VNTINGT y 217 Chicago Ave p Huntington Beach CA 92648 RETURN NTY Q LEGAL NOTICE IPUKJG HEARINQ - A-'�t,��" ��r-c, 1 sc;26'j: IIIII1111,1,1111,111111111111111111111111111111111111,11111111 City of Huntington Beach ^ u { yr N \ Office of the City Clerk i P.O. Box 190 Huntington Beach, CA 92648 �C�/�V�%�f/IN = „ •^•-: ' n_../. 6 � � VhTINGjp 939 505 64 875 Daniel & f\atali a Finnerty ,.w•ro••., 9F .. y 9F4 Haminn..,o.i f1. 9 FORWARD ME EX R 15TO 15 06/01/C FORWARD TIME E/.P RTN TO SEND p Q FINNER HA 9 Z 17408 INDAN DR 'NHdA L1NUA CH 92666-1663 O FTI 101�1 TI"f CFf1,lFo �uuxTY ca LEGAL NOTICE PUB�IC�}i EAR IN�; _ Huntington Beach City of WQ � i,/ Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 �*z ' C Wq 939 502 48 674 Char!es Cashmere 430 Laken ',205 to S ING Huntington BeoJl 0-. CA 5PL4 3 0 q26481006 1303 07 06/01 FORWARD TIME EXP RTN TO SEND czk CASHMERE IbOO HOPE ST SAN MARCOS CA 92078-1.030 BOUNTY LEGAL NOTICE -,�441q.jOEARINq ZE.4 ...................... Office of the City Clerk If .j P.O. Box 190 L Huntington Beach, CA 92648 �1 W� U A!templed Unknown No Such Number Insufficient Address L ING Forwarding Order Expired p 024 16204 1. M-4 BF9 vacant OCCUPANT ?i Dote No—Date 239 1ST Cart_ 92648- 05 HUNTINGTON BEACH CA 92648 .2 Ira It lot HUNTINGTON BEACH CA R THPI,l IC E PUBLIC HEARING E - 2 S 4 8- 1111111111 11 Illtil I'll Pill 11411111 1111111 111111 ]I'll 1[]11 11 11 j Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 937 150 45 342 w 2XI, uNTyB INGT0 hu 3117 Hemlock - Sat-i '_z_-rnardi,-,o C;, 342zlQ4 CHU-717 924045044 ICOR 06 06/C FORWARD TIME EXP RTN TO SEND CHU 194,1 SYCAMORE HILL OR Zito RIVERSIDE CA 92506-4669 F�ouNTY LEGAL NOTICE PUBLIC HEARING RETURN TO SENDER ccr:r.e orocK:vay.-ciry--crerx--- p �.f �r / N -1 !� City of Huntington Beach ►r d Office of the City Clerk \ P.O. Box 190 f l Huntington Beach, CA 92648 oE,IAp IN6Tp�e 939506_9 A•+, ' 940 �. .. PUTR860 923547013 t303 15 06/03/i PUTRARD TIME EXP RTN TO SEND 937 CREEK VIES) LN REDLANDS CA 92373-6974 FCUUNTY RETURN TO SENDER LEGAL NOTICE - PUBLIC HEARING 4Ca`9-*'OrTfP19r0 5/2-=z4 City of Huntington Beach Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 �� '�j� • �" i - "AP 939 505 17 828 Francisco& Norma Fabrregas INGTpy 200 Pacific Coast Hwy#1 Huntington Beach CA 92648 —^ RET; :-� ETUR C`` CUUNTY' �a�\�O �RIN LEGAL NOTICE - P KIC�;I�F�I�G:" Office of the City Clerk / V1 V[ P.O. Box 190 QJ Huntington Beach, CA 92648 . �ppT I NGTpy 024 162 17 a`� •.w+ro+.ro B�9 Occupant s 220 2nd St Huntington Beach CA 92648 ` _ . . : T _ _ .,LEEGAL-NOTIAUBLIC. HEARING N 7U City of Huntington Beach Office of the City Clerk P.O. Box 190 — Huntington Beach, CA 92648 " ;' (� 1 024 261 24 �NTINGTp Occupant 401 Atlanta Ave Huntington Beach CA 92648 V � S Z OQ FpoUNTV LEGAL NOTICE - PUBLIC HEARING 3y==it Il,l....Jr},Il. •.1..11.,1,1111,11„1,1.,...Jill'.:1..1.1 City of Huntington Beach Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 ( i _ �• 939 505 93 904 �VNTINGTpy Michael Bar5om 200 Pacific Coast Hwy#322 _ y Huntington Beach CA 92648 c '^'►`► Fn ETU LEGAL.NOTICE -YltB(r1C lCARING,, �nti Office of the City Clerk fv r P.O. Box 190 Huntington Beach, CA 92648 6 � 939 505 79 TINGTpyB Rosena Invest LLP 200 Pacific Coast H� Huntington Beach, CA 92 64, Unit 385 1 90 y T_.. Q t- jlw� TURN � ETU — yC c�0 F n c f' O NTrLEGAL NOTICE - LIC HEARING 1. . �:7_c-: 11.1....1.1.tl...l..lt..1.lt......ln.l..lt...l.f..n..,,.l,ll airy of hunungton Beach Ll (-1 J I i y /ter Office the City Clerk j��/�Q�r i� rl C/J/ P.O. Box 190 Huntington Beach, CA 92648 6 � 024 204 24 OCCUPANT 211-D ATLANT; INGTpy HUN7ili •: °= U A r. C S RETURN i2C� C tA� Tll SE" LEGAL NOTICE - � ��.It}#i ARC - r << o lf,J..,.1.I.11..,1„11..1,J1,,,,,.11•„11JI,\,...1J11::,J..1.1 ury or nunungton rseacn Office the City Clerk ��� n r P.O. Box 190 Wv` Huntington Beach, CA 92648 6 - " 939 505 57 868 'TING Tpy Michael Colacarro Jr. OE 44,,e BF 200 Pacific Coast Hwy#1 c( cl Huntington Beach CA 92648 97yCf �,' "�s Eon RETURN /�- `"�i t -` CpUN:TY LP` TO SE•';nro LEGAL NOTICE - PUBLI�TEA WC 32e4 _ 11111111„II,1 fill IIlll„l'I'II City of Huntington Beach Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 �C��✓�; vV� J 6 � a 939 505 81 David Berokoff �dVNTINGTp�e 200 Pacific Coast Highway n306 `a •` �q� Huntington Beach, CA 92648-5123 RETUR �purrTr LEGAL N -TICE_ PUBLIC HEARING - - -- -� II,II,III,LII,I,I„II„11111,.,I11114,1ii1111,1„IIl,I,.I,ii ury of Huntington Beach Ll Office the City Clerk P.O. Box 190 � � i - • Huntington Beach, CA 92648 TING 937 15245 542 Kris Olson _ ` �92 21046 Poolside Ln Huntington Beach CA 92648 9 ^�-�� c - NTYSNDE:R. :r LEG C'fJOTIC6_:PUBLIC HEARING ._ . --. ._._ s-iiFln('lY. 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Box 190 Huntington Beach, CA 92648 I 4 .�p h —v� 024 204 24 �J OCCUPANT 213-A ATLANTA ��pNTINGTOy HUNTINGTOPf � — Z CD -- 9sC� F: . ♦� Gam,_ ` ...�._� RETURN -,-- - ;iec a,l'J: r ��.� ;:... •. �.. z _.__�.���� _: t;,i::::isl:il:::i::li::I,IL:::::IILLJi:::L1:�iL,::,l:i! City of Huntington Beach / LT Office of the City Clerk f .4�/°� P.O. Box 190 Huntington Beach, CA 92648 ;:; 024 261 24 OCCUPANT Z) 401 ATLANTA AVE #32 INGTp HUNTINGTON BEACH CA 92648 �GGNTY LEGAL NOTICE ,'P �PEARIN92:, City of of theHuntingtonCity beacClerk r 1 ` •�� 1 Office of the City Clerk ¢J � y P.O. Box 190 Huntington Beach, CA 92648 lam. 939 503 42 Occupant ^ pled Unknown pNiINGTp 320 Lake St i;; Such Number `t` y d g 1 ,Huntington BeaGti k `fi 648 in ucientAddress er „°a o "orwarding Order Expired 1/ar.�-nt 5�F HU4fJNGT0NBEACH CA �ouNTr gyp` LEGAL NOTICE - P,- aj�L , WING __.4a city or Huntington Beach Office of the City Clerk l \ _- �� - P.O. Box 190 Huntington Beach, CA 92648 937 15069 366 Q �uN TINS Karlene Larson Tpy PO Box2593 �� q� �� "'• �Ey While City OR 97503 9 Q LEGAL N G 3 - - - _ � - City of Huntington Beach Office of the City Clerk qq P.O. Box 190 Huntington Beach, CA 92648 INGTpy 024 204 24 Occupant 211 Atlanta Ave,4,Q 4.7- Huntington Beach CA 92648 NTV 6a�� LEGAL NOTICE - PUBLIC HEARING _ L- 'ri rtr y III , I I II III I, I I II II I,IIIIIII fillip lilt ll Office of the City Clerk U ` P.O. Box 190 Huntington Beach, CA 92648C��%�`� 024 261 24 ) -f OCCUPANT pt�UNwIN,T�,T�yB 401 ATLANTA AVE #3 -' ^ F9� HUNTINGTON BEACH CA 92648 9 _ Q `��ouNTr ILP`� LEGAL NOTICE - PUBLIC HI ARING _ II1,li1l1l1l,Il1111III lilt ll,i,l1ll,ll1„i City of Huntington Beach - Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 v 024 261 24 OCCUPANT 401 ATLANTA AVE #5 HUNTINGTON BEACH CA 9264.8 zoC2 F�pp NTI LEGAL NOTICE -PUELIC HEARINO City of Huntington Beach Office of the City Clerk P.O. Box 190 x Huntington Beach, CA 92648 024261 24 ING OCCUPANT 401 ATLANTA AVE 46 HUNTINGTON BEACH CA 92648 �OUNT1 ry - LEGAL NOTICE --PUBLIC HEARING 2 4 a ILI tt ItLl6ttittlLtltt1Jtttll,tttlllt6tiltt,tiit1ltttli k-Ity UI nut fill Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 024 16301 57 �uNTING CITY OF HUNTINGTON BEACH PO Box 190 Huntington Beach CA 92648 C2 'UUMT1 LEGAL NOTICEL- POEIJ_Qj�.4 RLOG HIIIIiIIIIIIiii 1 111111111 HIM if IIIIIII III It 11 1'.1!..1"1 �J'y �' nulloilgion neacn Office of the City Clerk tj �a4k P.O. Box 190 Huntington Beach, CA 92648 C 4/ 7/41- Dinora Castillo HERE, Lot 689 I N G 2001 S. Haster, Apt. 39 Anaheim CA 92802 C= 'A10 �ho NTY , LEGAL N6TICE Gewiie 1;Feeimaj, G4y Glerk City of Huntington Beach Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 939 503 22 748 Christopher Garberg ING 320 Lake St #101 K Huntington Beach CA 92648 GARBBao �26485007 1403 42 06/03/ FORWARD TIME EXP RTN TO SEND 00 GARBERG L420 MONTE5,50RI AVE 4 0VEOQ PLACENTIA CA P2870-18a7 F�DU NTI LEGAL NOTICE - PUBLIC HEARING 32c6ti;Ux, 4 kIkIIH!ill'i'dill I Ii III 111,!1,I'll F.U. t3ox 190 Huntington Beach, CA 92648 IF 6 0 024 202 20 118 Hugh 3rd Foster PO Box 3606 ��NTIN6Tpy Huntington Beach CA 92605 To , i iE ITI LEGAL NOTICE City of Huntington Beach Office of the City Clerk P-O. Box 190 Huntington Beach, CA 92648 ,��NTIN6Tpye 024 291 16 _"'"""'• �`q RESIDENT 80 INGTON ST#254 HUNT,TN( _-, /N BEACH CA 92648 pOUNTV LEGAL NOTICE - PUBLIC HEARING --41 ri iir 7= s� Il lr rrlrlrllr rlrrllrrlr.l�t;;ll lrrirrlrlrlrlrrlrrll lrl City of Huntington Beach Office of the City Clerk i•, vJ �� P.O. Box 190 Huntington Beach, CA 92648 � Z % __-.•.:; ' TING T0y 024 291 16 a B� RESIDENT 9 y 80 HUNTINGTON SJ HUNTINGTON BEACH;CA 92648 •c -•-7►r►�-=— c FOOUNTV `P`�E LEGAL NOTICE - PUBLIC HEARING %—n('1 ii('i r' 7='��'+.�. Ilrin ulr lrlln rin lln lr rl rinrlln rllrlrl nrlulnrllrllul Office of the City Clerk W J P-O. Box 190 Huntington Beach, CA 92648 �pNTINGTpy \� o� 1.4W M1111� B� C�_ _ qy 024 291 16 ; RESIDENT y 80 HUNTINGTON S7 \: �= ? HUNTINGTON BEACH CA9�2648 OOUNTY gyp` LEGAL NOTICE - PUBLIC HEARING -�iinilr y•=1. � Il�lr�rrlri�lir��l�rllrrl,rlrlrr�llr��llrl„I,,,II,,,II.,II..I City of Huntington Beach Office of the City Clerk P.O. Box Huntington Beach,, CA 92648 f11 ��N11N6Tpy 024 291 16 RESIDENT ' 80 HUNTINGTON ST #118 '. l s HUNTINGTON BEACH CA 92648 9yc�pUUN� LEGAL NOTICE -PU%IC.UEARIN�- . ;rtr �'_:•;; IilllllllllllllllilllllllllllllllllllllllIIIIII)IIIIIIIIJI111 y� (- City of Huntington Beach Office of the City Clerk P.O. Box 190 l Huntington Beach, CA 92648 y :_ 024 291 16 � �NTINGTp. y RESIDENT a� "°�""'• ��q 80 HUNTINGTON ST HUNTINGTON BEACH CA 92648 �oUN ` LEGAL NOTICE - PUBLIC HEARING -A-r�itiPiP 3c=.: � Il,il,lllllllll,lIIIIII,IIIIIillllllllllllllllllllllllllllllll City or mumington Deeal Office of the City Clerk P.O. Box 190 r(J i Huntington Beach, CA 92648 T' 7 024 291 16 -3`' 1N6Tpy RESIDENT '4 80 HUNTINGTON ST #168 HUNTINGTON BEACH CA 92648 Q FpUUNTY LEGAL NOTICE -,PUBL.IC.UEARING_. „ " t't~ '�_-4 II IIIIIII IIIIIIIIIIIIIIIIIIIII II IIIIIIIIIII III IIIIIII IIel lllll City of Huntington Beach J / �( r I) y Office of the City Clerk ` /i P.O, Box 190 l Huntington Beach, CA 92648 I/jJ /I(J� 1 024 291 16 y ° INGTpy RESIDENT / QE ,wn..,is d� 80 HUNTINGTON ST#1 f0'�� ya -=_ 9i HUNTINGTON BEACH CA 92648 Z �pUNTY �a` LEGAL NOTICE - PUBLIC HEARING S- rierir 5 64 Ilrl ri l,Il rrlrrll lrrl,I,r llrr,llrl„rlrrllrrl lrri lrl City of Huntington Beach Office of the City Clerk ///�✓✓✓C��%�G� P.O. Box190 ' Huntington Beach, CA 92648 _, . i If 6 / � ��pNTINGTpy 024 291 16 RESIDENT 80 HUNTINGTON ST #104 HUNTINGTON BEACH CA 92648 �pUNTY gyp` LEGAL NOTICE - PUBLIC HEARING E-^ri iiA 322A45 IIrI rrlrlrllr 111FillIIIIIIlrrriitIIIIIIIIIIIIII11rirrrr1111 urrice of uie airy %.rein P.O. Box 190 1 w l�(//yn�/��)� Huntington Beach, CA 92648 E��t►SINGTpyC 02,' ` 92648 �pUNTY cp LEGAL NOTICE - PUBLIC.HEARING _-phi=rlr �_�>a II,Irr�IrLllrrrL�ILJr,. .��IIr��II��IIr�rrl�N��l�rl�rli Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 TINGTp 39 505 56 867 tichard Tr Theil Jr. .00 Pacific Coast Hvry ji/¢Fr y iuntington Beach CA 92648 �C �� t !ms pQ REIURN ✓��_ �:�cTj;n!i �CDUNTY CP`�E �TO SEND `. _9.._ _ .. _ _. _ City of Huntington Beach Office of the City Clerk = P.O. Box 190 r Huntington Beach, CA 92648 6 � o RICK SHAFER �VpTINGTpf 713 ALABANIA AVE-. "B HUNTINGTON BEACH, CA 92648 v _ Z t.!!D-R ,to Nt LEGAL NOTICE PUBLIC HEARING ! t :1EIE2� � 013rr ` ? # I�! !ni�il!��!n�ul{n�!I{nunll�!�!rllu!I!I!ilin!ui!II City of Huntington Beach { / // '� Z-" Office of the City Clerk -- P.O. Box 190 ; Huntington Beach, CA 92648 939 506 15 926 ?L' pNTING Tp Maurice Gerard 8311 Snowbird Dr p Huntington Beach CA 92646 GERA311'h 926461026 1103 07 Ob/OS FORWARD TIME EXP RTN TO SEND 9 GERARD ' MAURICL k, 200 PACIFIC COAST FiWY UNIT 402 C�, i,�. t ,p�.�a \EO HUNT ING TON BEAcN CA 9264 8-5 195 or Huntington Beach O [/C� � f✓ v� C/ �: ;; •� Office of the City Clerk p P.O. Box 190 - Huntington Beach, CA 92648 024 291 16 RESIDENT INGTpy 80 HUNTINGTON ST #711 HUNTINGTON BEACH CA 92648 t NTV �p� RETURN LEGAL NOTICE - RVBbl�, 1 ARINWGISFIf p - ,0 ,�,-_ City of Huntington Beach L`Vib c Office of the City Clerk \t , P.O. Box 190 ; Huntington Beach, CA 92648 17 024 204 23 OCCUPANT 221-4 ATLANTA ING HUNTINGTON BEACH CA 92648 ,�pt1iTp,�. 9�cF 'X lot' -``doe - .... . .. - RETURN pOUNTV LP LEGA! RETURN .}C-d NOTW�P _ �.�EARE 11.1...J:J.11..,1.,11..1.11......J11,J..11...J. —P.. ..J.11 City of Huntington Beach Office the City Clerk P.O. Box 190 Huntington Beach, CA 92648 6 ' � - w v 7 937 151 12 409 GOLGART SANDY TING Tp� 7981-Moonmist Cir d� Huntington Beach CA 92648 City of Huntington Beach p — 1 , 1n r (/ ��• � \ Office of the City Clerk CC�V�J• r J, 7� P.O. Box 190 =� Huntington Beach, CA 92648 937 152 15 512 phTINGTp Harou & Yoko Miyano 7926 Waterfall Cir Huntington Beach CA 92648 City of Huntington Beach Office the City Clerk P.O. Box 190 Huntington Beach, CA 92648 INGTp) 024 291 16 o�` eFq RESIDENT . = y 80 HUNTINGTON ST 4203 HUNTINGTON BEACH CA 92648 - �pUNTY gyp` LEGAL NOTICE - PUBLIC HEARING CQppia City of Huntington Beach T �"f s ^tqb - \ Office of the City Clerk " = P.O. Box Huntington Beach,each, CA 92648 , � � y INGTpy 024 291 16 `o```,•�•'•<,, B�q� RESIDENT 80 HUNTINGTON ST #210 HUNTINGTON BEACH CA 92648 F�puNTI �0`� LEGAL NOTICE - PUBLIC HEARING "V»uaz.' wvayrCuj CJsck n _ "- -- City of Huntington Beach Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 6 Dy E,JphiINGT0yB 024 291 16 RESIDENT _ s 80 HUNTINGTON ST #633 Ica HUNTINGTON BEACH CA 92641 City of Huntington Beach U �Q Vh ';_"• ' " Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 P r �- ~Dy T yB 024 291 16 INGT �M 0 RESIDENT i ;'"'p"''• �`y 80 HUNTINGTON ST #353 HUNTINGTON BEACH CA 92648 z t OOUNTV �p� RETURN LEGAL NOTICE �U TC�� � _ �a•g 'r��S's�1'9f �G�� t 11.J.,_ � 1.1F.,,.J..11..1,J' .. -'tt•' JF_.r.�..�i. ...i ,i (' a lark City of Huntington Beach Office the City Clerk `��✓� "�" ' P.O. Box 190 Huntington Beach, CA 92648 _ r% �MTINGTO 024 291 16 f RESIDENT 80 HUNTINGTON ST#842 - - i HUNTINGTON BEACH CA 92648 Q �OOUNTV CPS\ LEGAL NOTICE - PUBLIC• HEARING ..iAPj._Y - - - = ... .v_ 111 1111 1 11 1II 1111 11 . 11 11 i11 City of Huntington Beach Office of the City Clerk P.O. Box i Huntington Beach,, CA 92648 6 c\X o y INC CC r \ 024 291 16 RESIDENT C/ 80 HUNTINGTON ST#521 o = �n►.:� o HUNTINGTON y � NGTON BEACH '1C '%•„:;:.� .c0 - -- ---- -� -_.. . A 92648=� City of Huntington Beach Office of the City Clerk / P.O. Box 190 Huntington Beach, CA 92648 "�2 �24 162 �pNTIMGTpy� OCCUPANT 116 PAC. COAST HWy HUNTINGTON BEACH CA 92648 = City of Huntington Beach qa Office of the City Clerk P.O. Box 1 g0 Huntington Beach, CA 92648 INGlpy 024 291 16 O� _.WA..,,, *4 RESIDENT 80 HUNTINGTON ST#215 HUNTINGTON BEACH CA 92648 \ F 7Uft,l r L NOTICE - PUBLIC HEARING - .t;,.n City of Huntington Beach / / "l �'9 —r N Office of the City Clerk IIIVVV P.O. Box 190 Huntington Beach, CA 92648 qwvo 6 Vy 937 15233 530 t�pNTINGTpy Kira Houten-Gurnee 7911 Waterfall Cir##233 Huntington Beach CA 92648 V S GUkNy I 9c'643900t� 1303 06 06/0 9 ;�.�, ` FORWARD TIME --XP RTN TO SEND 9 GURNEE _ OQ 2020 SREYER LN uB REDONDO BEACH CA 90275-491- ppUMTV gyp` ..__. ,..., _.. «.,..�.. LEGAL NOTICE - PypV'4ARINGG City of Huntington Beach 1 1 d4b Y Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 6 - � - 0 ,�pNTINGTp� 939 506 05 916 OKACH! SHOJI CO LTD _ 200 Pacific Coast Hwy 93 3cl Huntington Beach CA 92648 -- - ni got I( HFADimr, City of Huntington Beach 1;'< —, Office of the City Clerk - P.O. Huntington Beach,each, CA 92648 939 505 10 821 TINGTpy _ d i/iariiyn ;J;o e;o 200 Pacific Coast H,,;V4'✓( s Huntinglcn Beach Ci, 9:vS City of Huntington Beach �O of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 h O 7 024 291 16 t� RESIDENT IN6lpy 80 HUNTINGTON ST #11 499� HUNTINGTON BEACH CA 92648 b Ar City of Huntington Beach Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 024 291 16 IN6lpy RESIDENT _ � 1 E B�, 80 HUNTINGTON ST#2-'',- . HUNTINGTON BEACH CA 92 48"- f�Quxrr �p`� I rnnl unTlnC MIDI Ir UCADIAIG City of Huntington Beach Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 - - j ,�p11TIN6lpy 024 291 16 ;. of ,.w•A•.,,, 94 RESIDENT 80 HUNTINGTON ST#4 HUNTINGTON BEACH CA 92648 co r FppUMTr p`�� LEGAL NOTICE - PUBLIC HEARING —icy of nunungton Beach / I / / .. Office of the City Clerk / / P.O. Box 790 !lIJJJ U Huntington Beach, CA 92648 kkk) TIMsrp� _ 024291 16 RESIDENT v .2 80 HUNTINGTON ST #6 HUNTINGTON BEACH CA 92648 �pppNTY CPN� LEGAL NOTICE - PUBLIC HEARING 72- 4E City of Huntington Beach / /� Office of the City Clerk V{ P.O. Box 190 _ 1 Huntington Beach, CA 92648 024 291 16 `--, IN6rpye RESIDENT ti =��p• "° F9� 80 HUNTINGTON ST #218 s HUNTINGTON BEACH CA 92648 9 .►-..ems Q z City of Huntington Beach Office of the City Clerk ► J ] ��// // LLLJJJ , P.O. Box 190 �CGd - Huntington Beach, CA 92648 024 291 16 -� l _I Resident 80 Huntington St. g8 �pNTIN6rpy Huntington Beach, CA 92648 .' 13 Z yC�ppUNTY `p`�F i rnni KinTinr niint in IIrnnIKI(N City of Huntington Beach Office of the City Clerk P.O. Box 190 - Huntington Beach, CA 92648 =024 291 16 1 ! 1 RESIDENT 80 HUNTINGTON ST #313 ' �. IN6TpyB HUNTINGTON BEACH CA 92648 City Glw* _ Q City of Huntington Beach01 Office of the City Clerk �r,,,grdhrc drdgr�xplr? _: P.O. Box 190 I D Huntington Beach, CA 92648 Resident G 8 S unnnggton St. 49 7o �VNSINGTpy uht on Beach, CA 92�u C� 1 L • l- CURRRES IONAL ADD ES OR 05/29/ AT : -� �, 'o "/I ' MAIL PIECE ADDRESS FORMAT : �'•�""� y ':, / `� MAIL PIECE TO BE DELIVERED ZP y __ i ;r AS ADDRESSED UNLESS SPECIFIC yT_ ..o �OQ` • 1'� FJ REASON ,FOR NON-DELIVERY EXIS : S . City of of the City Beach Office of the City Clerk P.O. Box Huntington Beach,, CA 92648 N6Tp� 93950512 823 I a� •� d Michael & Pi Zu Tsai F9 1678 Calie La Paz s Row;ar,d 'Heights CA 91748 ppUNTY gyp` LEGAL NOTICE - PUBLIC HEARING City of Huntington Beach Office of the City - , V Clerk P h 7L P.O. Box 190 d Huntington Beach, CA 92 ��fl'(.��� — 28 648 r 024 291 16 RESIDENT �pNTIN6Tp 80 HUNTINGTpN--S.T.9464` HUNTJNGT6N BEACH CA 92648 City of Huntington Beach Office of the City Clerk P.O. Box 190 :3- 7, Huntington Beach, CA 92648 PAC ING h 939 505 52 863 HOLTZCLAW 200 Pacific Coast Hwy#23- ---Huntington.Beach-CA-92648--- RETLIP,!, T 0 1r. City of Huntington Beach Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 �G/��J�{'/ fir , 024291 16 RESIDENT 80 HUNTINGTON- S-T,#36 i HUNTINGTON BEACH CA 92648 kk �ouNTI LEGAL NOTICE - PUBLIC HEARING �-' z .- z 11 1 lilt lill 11 111111 It III] City of Huntington Beach - Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 ,�pNTINSTpy D 0 24 16202 OCCUPANT r , 9y 231-613T c•. �, ,,; 3 C' HUNTINGTON BEACH CA 92648.1 Z �puNTr ca LEGAL NOTICE - PUBLIC HEARING C-n'ri%iiP �== 4a II�I� � IIII,�,I��II��I��II� �Il��ll : IIIIII���III vCity of Huntington Beach Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 6V 024 291 16 ,�pNTINGTpy RESIDENT E. 1 80 HUNTINGTON ST#31,4 HUNTINGTON BEACH CA 92648,:., k / City of Huntington Beach ` - Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 _ ' oy 024 291 16 f RESIDENT ` INSTpy � . 80 HUNTINGTON ST #465 HUNTINGTON BEACH CA 92648 Q �pUNTV I Fr_el nlnrlrr _ of IRI Ir uCnoinic City of Huntington Beach Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 TIN6T 024 16202 huh py OCCUPANT / .. . .:: ��==wnoi�a efq� 231-41ST HUNTINGTON BEACH CA 92648 ,Cnnnia RmrLnvn riffea(`l+ urk City of Huntington—Beach R _ �� n ` Office of the City Clerk 1 P.O. Box 190 r l Huntington Beach, CA 92648 J ' — Nl_. / INGTOy 024 162 02 �x Bye OCCUPANT qy 231-3 1ST ��4, HUNTINGTON BEACH CA 92648 d �,.-��►-�r,. Q Z NTY �a I Fr-Ai NinTirl: . of 101 it UFADINIr City of Huntington Beach Office of the City Clerk P.O. Box 190 Huntington Beach, CA 92648 ` • ' = j 6 _ -� - OV BOB TRAVER INGTpy 7402 COHO DR. it_ —��� •`B�q2 HUNL MNGTON BEACH, CA 92648 z LEGAL NOTICE -R-�".j1 EARINQ�,_":: eo , City of Huntington Beach Office of the City Clerk � _,•._. P.O. Box 190 Huntington Beach, CA 92648 �r fPAO ,- •.f _- i TINGTpy 024 204 12 - Occupant q2 209 Atianta Ave Huntington Beach CA 92648 9 Q �puNTr gyp` LEGAL NOTICE - PUBLIC HEARING_ —fir1:;r�P 7% +1 II�IIIII �i��ll �l„il �llll��� illl ��ll,���fl�l Office of the City City of Huntington Beach Clerk P.O. Box /1C�%I� # ' Huntington Beach,, CA 92648 D �/ 2420423 JCCUF'AN'f �VhTINGTpj 221-5ATLANTA ` HUNTINGTON B=FACH C,; 3'''-12 . City of Huntington Beach Office of the City Clerk l•� P.O. Box 190 Huntington Beach, CA 92648 I94 6 - 7 OV 024 20412 ING 1ae TpyB Janine Walkup Al _•" "• ., F9 209 Atlanta Ave Huntington Beach CA 92648 �ppUMTr ��\ t Cr AI MOTire of tot it ueAoinir P.O. Box 190 Huntington Beach, CA 92648 - ' - PAO d - � ` o � !/ 024 202 1'1 111 ioE�,NNTIN6Tpy David Monica BF 302-31 Alabama St Huntington Beach CA 92648 �ppNTr LEGAL NOTICE - PUBLIC HEARIND_ =' 4 II,I„.,I,I,II,„I..II„i„1 Connie grnrk�n City of Huntington Beach Office of the City Clerk �/ U ;.•.• P.O. Box 190 Huntington Beach, CA 92648 1 P,w4k) ���NTIN6Tpy 024 291 16' RESIDENT _ 80 HUNTINGTON ST#66 C, 0� HUNTINGTON BEACH CA 92648 CitYof Huntington Beach p - yb Office of the City Clerk — P.O. Box 190 / Huntington Beach, CA 92648 p l ° _ INsrpy ..' , 024 291 16 RESIDENT " - s 80 HUNTINGTON ST #629 y ^�+►+�= Q HUNTINGTON BEACH CA 92648 e �paNTr gyp` I Frai MITI(' _ Di 1Q1 it u[ADwr, Gonnie City of Huntington Beach Office of the City Clerk P.O. Box 1 g0 Huntington Beach, CA 92648 is :__ •- SIN6T 024 291 16 Dy o Resident J 80 Huntington St. °440%,i,, -- Huntington Beach, CA 92648 - 9 0 T Z �ouNTr c°` LEGAL NOTICE - PUBLIC HEARING — ;iSEiir 5Z1-46 II i,,,.I.I.It...I..II..I„I,fII,HI,IIIII I I„ ,III r`nnnio Rrnrkwn)jr Ciif f�lcrk City of Huntington Beach Office of the City Clerk i b P.O. Box 190 Huntington Beach, CA 92648 If 6 v, o � ING 024 291 16 RESIDENT �17,7, Y� — 9y 80 HUNTINGTON ST #638 HUNTINGTON BEACH CA 92648' 03 Q Q �oouNrr ca`` LEGAL NOTICE -,PUBI,IQ.HEARING _ . _ . AMHHtlr �_= 4a 11 11 111 11 0 11111,1I11II11111I,i,I1I1111f,,,,,lIIIIII,1111111111 �9��xo clT�a� c n F o mooc ; -+ I jI C?2 CD CO eft I 1: 4' � � ng o n �9N/A Ned r C) cCD ' m A co = p Q cq—_ _ Z (D O cnHZF- 6tC) `� �• Z F- U` rn W Z Z Cq N Oo ? _ co tip fif ff. f) 1 j r,.l Z �\ cC:) m r) Z�NI l W ZS (n lam. L 22 Z � m:[[ O-iz -qrn ca O . ..._ . I 1 U l M Z I U n CD y ff CD ? 11 w CO 1 m a ¢ p�N VIpdO f U rnU x U �O C 0). m co N i Y co 't 1 1 H I� — I r u a m vo o U zyO�11 IIO�p�b� G� A71 June 28, 2004 16787 Beach Blvd., #316 Huntington Beach, CA 92647 City Clerk Joan Flynn City of Huntington Beach 2000 Main St. -- Huntington Beach, CA 92649- — Re: Appeal of the Pacific City Coastal Development Permit #CDP 02-12 Dear Ms. Flynn: Enclosed is the appeal of Pacific City Coastal Development Permit #CDP 02-12 by the Pacific City Action Coalition. If you have any questions, please call (714) 430-8596. Sincerely, Pacific City Action Coalition cc: Meg Vaughn - California Coastal Commission June 25, 2004 16787 Beach Blvd., m316 Huntington Beach, CA 92647 i\9s. leg Vaughn California Coastal Commission 200 Ocean-ate, 10"' Floor Long Beach, CA 90802 Re: Appeal of the Pacific City Coastal Development Permit #CDP 02-12 Dear Ms. Vaughn: Enclosed is the appeal of Pacific City Coastal Development Permit mCDP 02-12 by the Pacific City Action Coalition. If you have any questions, please call (714) 430-3596. Sincerely, � Pacific City Action Coalition cc: City Clerk - City of Huntington Beach STATE OF CA,FORNIA - THE RESOURCES AGENCY CALIFORNIA COASTAL COMMISSION 1 .' South Gast Area Office 20C Oceancate. 10tn Floor �s- Long Beacn, CA90802-r702 APPEAL FROM COASTAL PERMIT (562) 5ees0 DECISION OF LOCAL GOVERNMENT (Commission Form D) Please Review Attached Appeal Information Sheet Prior To Completing This Form. SECTION I . Appellant(s) Name , mailing address and telephone number of appellant(s) : r g 6;<� z� 0r-- - i'f 1 ,C C. i riu��rJ r N Zip Area' /0 ' Ph Code` one No. SECTION II . Decision Being Appealed 1 . Name of local /,port government: �. IT�1 C mt )I ffcaol �EAe j 2 . Bri f d scri tion of development be in appealed: d� G 0 / f1 CIAL L A or 06 /ith C. OR A N 0 3. Development' s location (street address , assessor' s ��rcel np. , cross stre t, etc. ) : oZIOUy� /1C5�) C. L�V)AST' WT -aut(`P.4 M2LJ kACN�, (�Rc�L cJa4 - a o�Ter� o� r•�c)�lC Cu�.si X� . 4. Description of decision being appealed : a. Approval ; no special conditions : b. Approval with special conditions : t/ c . Denial : Note: For jurisdictions with a total LCP, denial decisions by a local government cannot be appealed unless the development is a major energy or public works project. Denial decisions by port governments are not appealable. TO BE COMPLETED BY COMMISSION : APPEAL NO: DATE FILED: DISTRICT: H5: 4/88 CQACTAL PERMIT DECeSION OF LnCAL ( 1yrRNMENT (Pagp 2) 5 . Decision being appealed was made by (check one) : a . _Planning Director/Zoning c . _Planning Commission /Administrator b . V City Council /Board of d. _Other Supervisors 5 . Date of local government' s decision : 7 7. Local government ' s file number (if any) : SECTION III . identification of Other Intorpttpd Parsons Give the names and addresses of the following parties . (Use additional paper as necessary. ) a. Name and mail ng address of permit appli ant: UN�N 7D e ec b. Names and mailing addresses as available of those who testified (either verbally or in writing) at the city/county/port hearing(s) . Include other parties which you know to be interested and should receive notice of this appeal . ( 1 ) Gil" CLUZ I _Md L`j'10 - Cr" a' 4 t'6 . o00 v — A (2) (3) (4) SECTION Iv. Rga5_Qn5 Supporting This Appeal Note : Appeals of local government coastal permit decisions are limited by a variety of factors and requirements of the Coastal Act. Please review the appeal information sheet for assistance in completing this section, which continues on the next Page. APPEAL FROM COASTAL PERMIT DECISION OF 1 OCAL t1VERNMENT (Page it State briefly your reatnn for hic a�� l Include a summary description of Local Coastal Program, Land Use Plan , or Port Master Plan policies and requirements in which you believe the project is inconsistent and the reasons the decision warrants a new hearing. (Use additional paper as necessary. ) SI c AT7 A CJ n cv, r�i�rvr5 — Ps;CI i rrY RCM 0Pj ww IOAJ Co aSr � cF,JF�Pm ��ivll i �cP��� LWO upI c- CLI DRritr Lip, HAZz ru) aVLc Note: The above description need not be a complete or exhaustive statement of your reasons of appeal ; however, there must be sufficient discussion for staff to determine that the appeal is allowed by law. The appellant, subsequent to filing the appeal , may submit additional information to the staff and/or Commission to support the appeal request. SECTION V. Certificating The information and facts stated above are correct to the best of my/our knowledge. SignaturQ6 of Appellant(s) or Au horized Agent Date a NOTE: If signed by agent, appellant(s) must also sign below. Section Vi Agent Author_ izni I/We hereby authorize to act as my/our representative and to bind me/us in all matters concerning this appeal . Signature of Appellant(s) Date Pacific City Action Coalition Coastal Development Permit Appeal The City of Huntington Beach's Local Coastal Plan in the General Resource Protection Policies states, "When policies within the Coastal Element conflict, such conflicts shall be resolved in a manner which on balance is the most protective of significant coastal resources." The Land Use section C1.1 goes on to state, "Ensure that adverse impacts associated with coastal zone development are mitigated or minimized to the greatest extent feasible." ._The Pacific City Action Coalition believes that the approval of Coastal Development Permit #02-12 based on documented site testing and remediation conducted thus far by Chevron and developer Makar Properties is out of compliance with the City's Local Coastal Plan. It is misleading, incomplete and contradictory. It is the Coalition's position that the best means to effectively mitigate adverse coastal impacts is to have an independent consultant oversee the site's testing and clean-up. California Coastal Commission South Coast Area Office3f�/Ixk�/L� 2000ceangate. IdhFloor Long Beach, CA 908014302 RL Appeal of Final Action of Huntington Beach City Council Action Approving Coastal Development Permit No 02-12, and Petition for the Coastal Commission to assume jurisdiction over the matter By letter dated June 18, 2004.the city clerk of the city of Huntington Beach notified you of the final action of the city council of Huntington Beach approving Coastal lyelopment Permit No 02-12, relative to the so called Pacific City project Enclosed is my appeal of that final action The city of Huntington Beach asserts that their action can not be appealed to the Coastal Commission Pacific City is within 300 fed of the sand and the city action is not precluded from your review Further, regardless of the distance of the project from the sand, the city's action violates the scope of its delegation of authority from the Coastal Commission Accordingly, also presented for your consideration is a petition requesting the Coastal Commission to assert jurisdiction because the final action of the city of Huntington Beach is"ultra vires" in certain material respects l� Paul Cross 109 Huntington Street, Huntington Beach, CA 92648 Petition Requesting the Coastal Commission to Assume Jurisdiction Over Permit No 02-12 By your letter dated March 20,1995, concerning Local Coastal Program Amendment No. 3-94,you adopted certain mandates for the city of Huntington Beach pertaining Pacific City Districts 7 and 8 .Among these was a limitation of 30 units per acre on a fully developed block This requirement is violated because their will be 50 units per acre on a fully developed block identified as residential section I of Pacific City .Also, you required dedication of a twenty(20)foot corridor between Atlanta .Avenue and PCH which might be waived if an alternative public use is provided The requirement requires the exercise of discretion and at least entrusts that the city should seek to identify the location of the corridor before giving it away This was not done You also approved a height limitation of four stories for the residential buildings measured from the highest adjacent street The city would allow 25 more feet to he added to the four-story limitation and totally ignores the downward slope of the land Other items of city disregard of your requirements exist The most blatant of these is that your letter approval of Huntington Beach Local Coastal Program ,Amendment No 3-94, was preceded by a letter dated November 17, 1944,to the Coastal Commission from Melanie Fallon, H B Community Development Director In that letter the city committed that it would encourage the development of a transportation center in the coastal zone The Fallon letter was pan and parcel of your approval of LCP No.3-94. which is the predicate for the June 7, 2004, approval action of the H B city council here sought to be challenged Over 150 busses traverse the perimeter of the Pacific City project each day All of them are virtually empty No effort has been made by the city to create a transportation center for these busses other than pullouts on PCH. There is no land now available where a terminal arrangement might be created for these under-used busses, or for passengers who might be encouraged to ride them Pacific City is designed, in fact to discourage bus service, no doubt in major pan because the city wants to collect parking fees at downtown and beach locations. Pacific City would soak up all available land needed to create a transportation hub and you should not tolerate such a disregard of your requirements HERE KEEP IN MIND THAT TRAFFIC AND PARKING ARE THE TWO MOST UNANSWERED PROBLEMS CONFRONTING THE COASTAL AREA STATE OF CALIFORNIA- THE RESOURCES AC;:NCY AQ Nf11_i] S(;HWAR"/.ENI;GGER__. ' Govemc" CALIFORNIA COASTAL COMMISSION South Coast Area Office ti 2C0 Oceangate, loth Floor Long Beach,CA 90802.4302 APPEAL FROM COASTAL PERMIT (562) s90-5071 DECISION OF LOCAL GOVERNMENT (Commission Form D) Please Review Attached Appeal Information Sheet Prior To Completing This Form. SECTION I . Appellant(s - Name, mailing address anti telephone number of appellant(s) : PAT 6 h a 'n (, I o q Alv" 7)A o E ,.�1 'Al2LA16' o/ E v/ 4h' i-aa�3 Zip Area Code Phone No. SECTION II . Decision Being Appealed i . Name of local /port government:e/ ;!�,Z Ogr " ( � uA/ AAAr- 2_ Brief desc� ript9on of development ¢eingEA C_/F) appealed: 3 / � GiQE S,' r� !t',t���yi 5 '� 3. Development' s location (street address , assessor' s parcel no. , cross street, etc. ) : R-c-4 1;.�` ST. /iT; ri/iA Avg G/yivTi,�✓�j�� , y" 4. Description of decision being appealed: a. Approval ; no special conditions: b. Approval with special conditions: C . Denial : Note: For jurisdictions with a total LCP, denial decisions by a local government cannot be appealed unless the development is a major energy or public works project. Denial decisions by port governments are not appealable. TO BE COMPLETED BY COMMISSION: APPEAL NO: DATE FILED: DISTRICT: 115: 4/88 APPEAL FROM COASTAL PERMIT DECISION OF LOCAL COVERNMENI (Page 2) 5. Decision being appealed was made by (check one) : a. _Planning Director/Zoning c. Planning Commission F° vZ- A�dministrator b. -City Council /Beard of d. _Other Supervisors 6. Date of local government' s decision: 7. Local government' s file number (if any) : CIIX /t/L . oI - 0/ 71vAflv,163s e,)A10/;Ic11AL c,g� PA/AI417' Nv. 02 -- Zv . GoHfT,�I� oEcl v.o�srr r Pd�ui7 w.a 2: 2<ri ! � " Ali. 4-- SECTION III . IdentiU CAtion of Other Interacted Persons Give the names and addresses of the following parties . (Use additional paper as necessary. ) a. Name and mailing address of permit applicant- AA A_Ir-A L G a N TGA n/iA v y^ o � C �L C) Bl_vp- 20 .66- k' "cldTr G 921!540 b. Names and mailing addresses as available of those who testified (either verbally or in writing) at the city/county/port hearing(s) . Include other parties_ which you know to be interested and should receive notice of this appeal . c 1 > 'ci r , y _�., i4,1 e /ZOd,7 iu G// (2) (3) (4) SECTION IV. Reasons LUpp rting This Appeal Note: Appeals of lociil government coastal permit decisions are limited by a variety of factors and requirements of the Coastal Act. Please review the appeal information sheet for assistance in completing this section, which continues on the next page,. { AP AL FSOM TAL PERMIT DECISION OF LOCAi GQVEBNlENT (Page 3) l State briefly y r r Include a summary description of Locai Coastal Program, Land Use Plan, or Port Master Plan policies and requirements in which you believe the project is inconsistent and the reasons the decision warrants a new hearing. (Use additional paper as necessary. ) Z� I yM i, Jai /� �JV a ti _ ids rt/ A Tr c 69�J/y✓ r`� Note: The above descriptio statement of You), reasons need not be a complete or exhaustive f reas for staff to deter mons o appeal ; however, there must be sufficient apeal is allowedby law. The nappellant, subsequentntoie tfilinghat hethepappeal , ma J submit additional information to the staff and/or Commission y on to support the appeal request, j?jc6A SECTION V. T'�/CS, Certifi i i A/C G�r//A/(�. The information and facts stated above are correct to the best of no �tinF / my/our knowledge. a �P � J v f4 STjF%d a• r1/14/AY5'g / Signature o Appellant(s) or ciJ� / Authorized Agent 1' .'/ Date p `. —/9 - o -17 NOTE: If signed by agent, appellant(s) tf;� must also sign below. Section VIAuthorization ----A9 '^: I/We hereby authorize representative and to bind me/us in all matters co appeal . ncerningsthysour i.N'. 1,i, /� r= flu ' S1 of'Appellant(s) "A q•i". Date � ,� L.,13. Bus pullouts should be provided along PCH and Pacific View Drive. Currently 138 buses use Atlanta Avenue between Huntington and 1 " Street each weekday. Most make a circuit north up Huntington St, west onto Atlanta Avenue, south onto I " Street and finally east onto PCH where they await their next run. These buses simply are repositioning and make stops only on PCH and at the extreme south ends of Huntington and I" Street. These are four separate bus routes, and three of them reposition as described. The fourth bus route actually has a stop on Atlanta-Orange, but that one is west of l st Street. As a result, all of the 138 of the daily buses could shorten their runs by about one half a mile via the proposed extension of Pacific View Drive. This fuel- saving, less-polluting route should be mandated by the environmental impact statement. It would be egregiously improper to dismiss this beneficial effect by asserting that the rerouting decision is entirely up to Orange County Transit Authority. The city of Huntington Beach and Pacific City must be required to obtain approval from OCTA for such bus rerouting prior to the commencement of construction. A savings of 18,000 bus miles a year at oceanside Huntington Beach with no diminution of service is more than a trivial issue. At present, Pacific City appears to oppose the presence of OCTA bus stops on Pacific View Drive and seems to insist that all bus riding workers and visitors destined to Pacific City disembark on perimeter streets including most notably the south side of PCH. Trekking across the highway should not be required of bus passengers. v 4. The proposed pedestrian 20ft p walkway through the project from the vicinity of Alabama Street south to Pacific View Drive should be granted to the city as a permanent easement, not subject to closure by condo residents or by the city itself, except for temporary repairs or maintenance that may be required from time to time. Comments Of Paul Cross On Draft Environmental Impact Report No. 02.01 For The Pacific City Project I_ The project will destroy existing public sight-lines to the ocean enjoyed by users and residents of Huntington Street and Alabama Avenue. Statements in the EIR that there are no existing views of the ocean at any point north of Atlanta Avenue are false and must be corrected. Pacific City will extend two and one-half city blocks, with a maze of buildings reaching 90 feet above sea level. For an unbroken quarter of mile, nD view of the ocean,will remain for anyone north of Atlanta Avenue. There is no sense of city planning. Instead, the interest of the developer is placed ahead of the interest of the neighborhood north of Atlanta Avenue. 2. The project will overload vehicular traffic on Huntington Street. This overload is not properly remedied by an existing proposal to extend Delaware Avenue through the middle of adiacent Pacific View Mobile Home Park. Two additional Huntington Street traffic lanes are required,both to be taken from the Pacific City project, not the adjacent mobile home park. 3. The extreme height of the buildings proposed for the Pacific City residential units(90 feet above sea level versus 10 feet for other homes along Huntington Street)will cast shadows over the first tier of mobile homes, and in some cases as far as the second and third tiers of the mobile home park. Therefore, for this additional reason., Huntington Street must be widened by two lanes into the Pacific City project. As well, a landscaped median strip along Huntington Street is necessary to filter the view / / downward from the condos to the mobile homes and upward from the mobile homes to the condos.. �/ 4. The public walkway through the project from Alabama Avenue to Pacific Coast Highway will not provide a view of the ocean accept at the extreme south end of the walkway. This walkway is mandated by order of the California Coastal Commission and by an order of the City of Huntington Beach;and is the right-of-wey of a former passenger railroad. Destruction of the ocean sight-line along the old railway righto'way is contrary to the clear intent of City and Coastal Commission orders entered in 1995. Nothing is offered as recompense for this loss. Instead, the City appears eager to reward the developer at the expense of residents who would use the old railway trail. 5. The Pacific City project is to be constructed on a podium or platform rising 30 to 32 feet above sea level, and will not follow thy; natural downward slope of the land. For example. Huntington Street at its intersection with Pacific View Avenue is only 5 feet above sea level, yet except for a single tier of condos immediately adjacent to Huntington Street, all of the residential buildings will be placed on top of the 30-foot platform, and Al except the tier directly along Huntington Street will be up to 60 feet higher than the podium level. Of the proposed 516 residential units, about 95 percent will be encased in a four story configuration. More specifically, only 10 of the units will present a two-story face and only about 15 more(those directly facing Atlanta Avenue)will rise three stories. Thus, the ambient height of the residential project will be 90 feet abuve sea level and not in keeping with the downward slope of the terrain. Although, there is a nominal 50-foot height limitation for four story residential units, that limitation permits a 3 or 4 foot addition at the base of a building and another 5 to 10 foot addition at the roof. Couple those extensions with a 30 to 32 foot high podium and there is a building of up to 6 stories tall, much higher than anticipated by the California Coastal Commission. In this regard, the mounding of din to encompass a two story garage, with four floors of condos above, is still a six story building. By an order entered in 1995,the Coastal Commission contemplated that there would be an extension of Walnut Street which would follow the natural downward slope of the land from I° Street to Huntington Street. Instead, the developer proposes to mound the land along virtually the entire length of a different street, Pacific View Avenue, thereby raising the level of the new east- west roadway to 29 to 30 feet above sea level for most of its length through ttte project. Only at the extreme east-end does Pacific View Avenue finally dip down to meet Huntington Street, which as noted is about 5 feet above sea level at that point. Thus,by eliminating the anticipated extension of Walnut Street, the builder seeks to obtain building heights not authorized by the Coastal Commission. Reasonably, the developer must be compelled to reduce the elevation of the buildings which otherwise would be sited 25 or more fee:below the podium level. That is, should the builder wish to adhere to a concept of placing buildings on a tall artificial platform, sight-lines and air movements must not be thereby impaired. In this regard it is important to remember that the Coastal Commission rejected pre- 1995 proposals to erect tall stntctures on the residential ponions of Pacific City. The explicit four story height limitation of the Coastal Commission must be respected, and not corrupted by a pretense that the proposed podium level is something other than a third floor cover for six story buildings. Y v. Bus pullouts must be provided along Pacific View Avenue,together with bus shelters,benches, and kiosks for the posting of bus s.hedules. Over 150 busses traverse the perimeter of Pacific City each day. The failure to adequately accommodate public transit at the site is shocking. The routing of busses along Pacific View Avenue will shorten the route of one-half of the daily busses by about one- half mile. and will save fuel and reduce pollution. As well, access to the site by handicapped individuals will be enhanced. Also, some automobile traffic will be eliminated and parking needs will be reduced. Indeed, merchants located at the commercial center of Pacific City could participate in a bus pass system for their bits using customers in addition to validation of parking for automobile using customers. 7. First Street is designed to be up to 100 feet wide, and at its endpoint with Atlanta presently has a cross-walk of 130 feet. This is far too wide and is unacceptable. Apart from being dangerous,the wide girth of the street transforms Pacific City into an island separate from downtown Huntington Beach. A median strip and it light will help but more needs to be done to make crossing Ist Street pedestrian friendly. The needed elimination of two lanes of 1" Street would only cause the loss of 16 parking spaces on the east side of 1" Street and 13 more on the west side of 1" Street. There still would be four traffic lanes,plus a m=dian strip. The City owned sliver of land located at the corner of IstStreet, at its intersection with Atlanta-Orange, would provide supplemental parking to replace the !oss of 29 parking spaces on I" Street, if such should prove to be necessary. The two eliminated lanes of roadwav could easily be coded back to the developer. In return, some of the mitigating measures enumerated herein could be imposed as a tradeoff for the benefit of the City and its residents. 8. The proposed 516 residential .snits require 6.9 acres of additional city parkland. The developer seeks to meet that obligation by the payment to the city of"in lieu of fees" which may reach as high as$12,000,000. The money would be spent at some indefinite point in the future for parkland located somewhere in Huntington Beach,but unfortunately not in the vicinity of the area impacted by Pacific City. "there simply is no land available anywhere near Pacific City which can be converted to the required amount of public parkland. The ocean is not a proper substitute. Accordingly, the necessary parkland should come out of the Pacific City project itself. The outlines of an acceptable Pacific City parkland dedication is contained in a City of Huntington Beach Planning Department, Subdivision Committee publication dated October 2!,2003. Therein, as Item 3 a o;Pacific City Subdivision, Suggested Conditions Of Approval—Tentative Tract Map No. 16338,the center of the residential complex would be fully opened to the public and would become part of downtown Huntington Beach, not an isolated island as presently ofamied by the builder. Inasmuch as the proper treatment of Huntington Street(wider by two lanes and a median strip)and a proper respect for the downward sloping nature of the terrain(true four and two story buildings, in place of six story buildings over much of the project),would cause the loss of some residential units, imposition of suggested condition of approval(Item 3 a) need not entail the loss of any additional residential units. Of course, if Huntington Street is not widened and if buildings five or six stories high measured from the natural slope of the land are allowed, then Item 3 a would require the loss of 60 units as specified therein, so as not to violate public parkland requirements. 9. Residential areas to the nonh of Pacific City may contain up to 25 units per acre, and can not exceed three stories. Except for Pacific City, no surrounding land is zoned to. multiple family high density. There is a tract of land located behind the new Hyatt Hotel on Pacific View Avenue which was similarly Chapter Responses to Comments As discussed in Impact AFS-3 on pages 3. 1-31 through 3. 1-32 of the Draft EIR, the proposed eight-story hotel rowers would also be within the height limits specified in the DTSP and would be constructed proximate to the adjacent hotel, providing a transition to the Io%ver-scale, three-story commercial development on the westcru portion of Dissict Ne. 7, which is similar in size and massing to the commercial development n,:ar the Downto%%n core. As discussed on page 2-30 of the Draft EIR, the project requires a Coastal Development Permit, Conditional Use Permit, and Design Review Board approval, each of which addresses the building heights of development on the project site. The comment asserts that the proposed Pacific View Avenue is `an entirely different street" from the Walnut Avenue extension described in the DTSP. -file proposed Pacific View Avenue in fact serves as the Walnut Avenue extension, as depicted by the contours of Districts 7 and SA on pages 50 and S3, respectively, of the DTSP, and for which setback and ROW dedication requirements are described in Scctiuns 4.O9.08 and 4.10.06 of the DTSP for Districts 7 and 8A, respectively. Further, as described on page 2-22 of the Draft EIR, the proposed alignment of Pacific View Avenue would comply with Precise Plan of Street Alignment (PPSA) 88-1 that was previousl) adopted by the City fur the roadway. Although the proposed street does not precisely follow the natural contour of the site, the contour along the proposed street alignment has been extensiveiy modified by erosion and previous excavation. However, notwithstanding this, the proposed Pacific View Avenuc would generally follow the existing dovt'nhill slope of the site from First Street to Huntington Sti-eet, though H'ith a slightly steeper initial grade at Huntington Street. Please also refer to the Responses to Comments Cross-I on page 3-31 3 and Cross-4 on page 3.314 for discussion of public views and view con idors from and through the project site, and -he effects of the proposed project on scenic views. Cross-6 The proposed project would satisfy all requirements provided by OCTA regarding bus — facility improvements. A bus turnout would be provided along PCH, north of Huntington Street, which would adequately serve the proposed project. _ Cross-7 As discussed under Impact TR-10 on pages 3.14-73 and 3.14-76 of the Dralt EIR, the proposed project would not substantially increase roadway hazards, including J 3 316 City of Huntington Beach �4 . I Chapter 3 Responses to Comments ---- — - e shadow icnderings provided ht Appendix !( to the Draft EiR, shadows on Cross-3 Based on th the mobile home park .Would be picsent at one of the four times during the year for _ yhich diagrams ss'erc made, the `Y''inter Solstice. As ties on pane 3.1-34 of the Draft FIR, the, thresltolcl of significance for shadow imp lets is three hours of shadow on adjacent residential or other light-sensitive uses, a threshold that is consistent with previous environmental studies prepared by the City and is an accepted industry standard. Impact AES-4 on pages 3.1-34 through 3.1-37 of the Draft EIR concluded that shadows cast by proposed project would not result in a significant impact from shading of the mobile home residences. These shado«s would have a duration of less than three hours oetween the hours of 9:00 A.-1. and 3:00 P-M , and would not, therefore, exceed the threshold of significance for the iinpact. Consequently, no further mitigation would he required. With regard to the request for a landscaped median strip along Huntington Street, the Draft EIR concluded, as described on pages 3.1 -32 to :5.1-34, that the proposed project yould not suhstantialh' de�-ade the existinv visual duality of the project site or its surroundings. A discussion specific to the yic%vs of tlrc project frorn the Pacific Mobile Home Park (Viewpoint I ) is provided on page 3.1-3.'. of the Draft EIR and concludes that the proposed landscaping (which would include a mix of trees and shrubs) would, in combination with the proposed setbacks and yn'iations in building height and rooflines, sufFicientls soften the appearance of the proposed development, and no significant impact yyould occur. Further, the land uie impact analysis concluded, on page 3,9-21 of the Draft EIR, that, "While the intensity of development would increase, in terms of the rumher of units per acre and the total mass of development. the increased intensity in land use would not result in inherent conflicts with similar ach,accnt ji.e... residentialj uses,' and also that "existing residential uses would be tial uses on the west, east, and north by roadways a separated Fru:r, nonresiden minimum of So feet in pavement width, !andscaping, and screening vegetation,' and no significant land use compatibility impact was determined to occur. Consequently, no additional mitigation, such as a landscaped median strip, would be required to reduce this impact with respect to the Pacific Nlobile Home Park. Cross-4 As described oil pages 2-23 to 2-26 of the Draft Elli, pedestrian access improvements provided cyith the proposed project include a series of pedestrian pathways that would L/ connect the residential component of the Ill oject..o the commercia! component and to of Huntington Beach ".y 3-314 --- Chapter 3 Responses to Comments the beach parking lot. As required by the DTSP, these padtways include "the dedication, ca a waiver thereof, of a 20-foot-wide corridor betnveen Adanta Avenue / and PCH for public access bemeen the southern end of the Pacific Electric ROW and / PCId" (empbasis added). The purpose t f the ROW is the provision of public access to the coast through the project site. .As discussed on hake 3.14-37 of the Draft EIR, a 20- foot-wide pedestrian access easement would be dedicated through the project site that extends from the south side of Atlanta Ave-mue, at Alabama, to Pacific View Avenue at he easterly residential access driveway. This would allow pedestrians to cross at the all-way stop sign to access the project site. As discussed in Table 3.1-2 on page 3.1-26 of the Draft EIR, no public view corridors currently exist front the project site, and as discussed on page 3.1-31 of the Draft EIR, °access to tae Pacific Ocean as a scenic resource from the project site is currently unavailable, and the project would provide access to these t;ewire opporrwtities." No loss of coastal access from or through the projec:t site «ould occur as a result of the proposed project, and the Cite has detennined that the propused project would be consistent t:ith the intent and requu-ements of the CCC and the City regarding the provision of a public access corridor. Consequentk, no significant impact would occur with respec,: to access, and no mitigation would be required. Cross-i The propos•-d project would raise the existing T-owtd surface level for portions of the site to accommodate devzlopment, including building pads and subterranean gar apes. However, the datum for the height of the proposed structures is set at the highest adjacent street level along the front proper tv !ape (i.e., at the curb of First Street for the residential portion of the project), as required by Section 4.0.04, "Height" and "Street Level" deftuitions of the DTSP. The height limits imposed b; the DTSP for Districts 7 and 8A are, therefore, measured itont this point and were understood by the CCC to be measured from these points when the CCC approved the DTSP, therebc authorizing the height limits set forth. When measured from these points, the heights of the buildings of the proposed residential village \could not, as discussed on page 2-16 of the Draft EIR, exceed the height bmit of 30 feet and a ould, therefore, be consistent nvith the DTSP and ttith the intent of the CCC, The Applicant neither proposes nor seeks approval fcr six-stort building heights in the residential village portion of the project (DTSP Disirict 8A). Pacific City EIR 3-315 never will be possible to connect Pacific City to downtown Main Street and the pier area when pedestrians are confronted with a super-wide arterial highway as is proposed for 1" Street. Clearly the intersection of 1" Street and Orange-Atlanta is exceedingly dangerous, and is a nightmare of highway planning With thousands of additional autos to be crammed onto this proposed seven-lane arterial, the thought of Pacific City becoming part of the dowmown area is unrealistic. Thus, sufficient parking is not provided. Few visitors will want to walk to a site surrounded by busy arterial roadways. Keep in mind too that neither the Hilton nor the Hyatt Hotels presently have sufficient parking for their quests when occupied with a special event such as a wedding. Sharer parking will not work when all of the Hotels, including the second hotel tower already approved for the Hilton and the new 400 room, plus ballroom, hotel proposed to be built by Makar are up and running. Again too much is being crammed into a small and busy place. (3)Public transit is not ever,oorsidered for the project. Over 150 busses traverse the perimeter of the site every day and insufficient consideration is given to the means by which access to the site will be gained by handicapped individuals, again in disregard of CCC requirements. Not even a single bus route will gain access to Pacific View Drive. (4) Project traffic studies- assume destruction of the Pacific Mobile Home Park on Huntington Street because of a planned extension of Delaware Avenue through the heart of the mobile home community. The vaffic studies also contemplate construction of bridges across the Santa Ana River and a freeway across Big Shell wetland and Talbert Marsh. In addition to the Pacific Mobile Home Park, it appears that Cabrillo Mobile Home Park is threatened by the large scale of the proposed project, and the resulting need to disperse a large volume of additional traffic. Again. too much is planned for a small space. (5)The city proposes to donate a strip of land fronting PCH to Makar. The city gets nothing in return.No sidewalk on the north side of Atlanta. No burial of the 66-K power lines along Atlanta, no bridge over PCH. The answer to all of Ellis is to downsize the project. (6) The hotel is too large, the offices planned overtop ofthe commercial area are not necessary, ,he residential area is too dense. A smaller project can be built without the d.;lay of eight years inherent in the grand project proposed by Makar. The land in back of the Hilton and Hyatt in common with the subject Pacific City tract also was set aside for high-density development, but is now proceeding rapidly to completion as a moderate density housing project. Circumstances have changed greatly since the 1995 zoning action of the city, and such change is properly recognized in the case oi.' the land behind the Hyatt. (7) Makar warns a eight-year window for Apru 13. 2004 will contaminate the city beach. Neighbors close to Pacific City relate that the project does not follow t o natural downward slope of the land and is ui violation of California Coastal Commission requ'iements for measuring the maximum allowable height Other neighbors observe that ocean view and air corridors on Huntington and Alabama Streets unnecessadly,will be destroyed.Additional reskients affirm that the 31,acre site needs independent tesft for the presence of soli contamination. The record,before you also establishes a lack of accommodation for public transit and handicap access. As well,the expense of asphalt at 1a and Orange Streets will remain as an Inhospitable barrier for pedestrians,while Huntington Strset will continue to exist as a street too skinny for safety. Please heed the evidence inupporting the corn menial development of Pacific City but opposing the giant scale of the hotel,office and residential aspects of the project I urge you to do the righMing.Substantially downsire the office,'residantial and hotel components and thus make the project conform to a realistic assessment of the present and future needs of Huntington Beach.Wiih just a few seconds left,I note that you have compared yourself with judges.Thus,may I say that a conflict of interast Is not something that is measured merely by counting-off 600 feet from the 31-acre site. I submit that if you have a substantial present or future economic interest In Pacific City,you must examine whether thet economic interest is materially greater than the economk: interest ofthe public generally. Thank you for this opportunity to speak.As wall,thank you for your service to our beautiful community. 3 Request of Paul Cross to the City Council of Iuntington Beach that the Pacific City project which is set for public hearing before the Council on June 7, 2004, be remanded back to the Planning Commission In support thereof, I submit the fo.lowing: One former Planning Commissioner participated in this matter in the face of a factual showing which goes beyond mere speculation. Another Planning Commissioner was busy with E-mail under a fictitious name and appeared to be concerned with expedition at the expense of extended consideration of the project. Two Planning Commissioners had so little time to review the project that they were required to do their study of the submitted materials while on vacation. Another Planning Commissioner was so unfamiliar with the project as to make a recommendation for a traffic circle at the intersection of Huntington Street and Atlanta Avenue. The most amazing aspect of the planning process is that not one of the neighborhood suggestions for improvement of the project was adopted by the Planning Commission, leading one to a strained conclusion that this huge undertaking is perfectly planned. A California Coastal Commission requirement as to a maximum height of four stories for the residential area is exceeded along the southeast quadrant of the project because Huntington Street is the highest street adjacent to that quadrant. (The intersection of First Street and Atlanta Avenue, is almost a quarter of a mile away from the southeast quadrant, and is erroneously used as a benchmark.) The Planning Commission failed :o exercise its discretion concerning the public use of the former Pacific Electric ROW.(The location of the ROW was never identified and it was impossible for the Commission to exercise any discretion without knowing the true scope of the ROW.)Even a city finding that the ROW is unnecessary cannot be made with-)ut a clear understanding of what is being given away. City owned land(once owned by Pacific Electric)along the north side of PCH and fronting the proposed hotel site also is being given to the developer(Makar)with nothing given back to the city in return. A 20-year traffic study was not done as required by law. The EIR approved by the Planning Commission assumes construction of a new bridge over the Santa Ana River which the Council opposes The EIR assumes construction of a highway across Big Shell wetland connecting Hamilton Street with Pacific View Avenue, something the California Coastal Commission is unlikely to approve. The configuration of I"Street as a major arterial highway[Hakes it apparent that the concept of shared parking between the project and downtown is seriously Flawed / ✓ The absence ot'public transit ftugh the project will materially disadvantage disabled individuals. The lack of a sidewalk on the north side of Atlanta Avenue between Huntington Street and Alabama makes pedestrian access through the prcject difficult,especially in the absence of a crosswalk at the intersection of Alabama and Atlanta .Avenues There is no land in the vicinity of the project upon which in lieu of fees can be expended to ease the parkland shortfall of about six acres resulting from residential density of the project. / R ght Of Way(ROW)Of The Pacific Electric Railroad Within The 31-Acre Site Know As Pacific City f/ With this statement you will find a roadmap and historical data identifying the pertinent ROW of the Pacific Electric which I obtained from the official records of the Southern Pacific railroad which is now owned by the Union Pacific railroad. I regret that neither the developer nor the city could provide the Planning Commission with this valuable document. How could the Planning Commission exercise its discretion to provide for an"alternative public use", while sitting in ignorance of the scope and location of the ROW? The California Coastal Commission(CCC)provides in a letter dated March 16, 1995,that Huntington Beach shall have a corridor dedication as follows: Development in District k7 Mull require the dedication of a twenty(20)foot corridor between Atlanta Avenue and PCH for public access between the southern end of the Pacific Electric ROW and PCH for public access between the south,:m end of the Pacific Electric ROW and PCH. This requirement may be waived if an alternative"public use" is provided or if the corridor is deemed unnecessary by the City. Any proposal for an alternative"public use" must be approved by the Planning Commission. Is it the position of the City that the corridor is unnecessary without even knowing where it is?Does the City even want to know the locttion? A majority of the Planning Commission seemed to care less. Be that as it may,the corridor enters the 31-acres at the exact intersection of Atlanta Avenue and Huntington Street and proceeds in a southwest dire.tion to the intersection of I" Street and PCH. 'fltis is a great diagonal corridor for citizens and visitors and it is impossible understand why such an asset should be given away by the Planning Commission or the City. Please review the attachments for confirmation. You will find that even the intersection of Huntington Street and Atlanta Avenue is the result of a grant to the city by the Pacific Electric. In addition to the Pacific Electric passenger ROW noted above, there was a Pacific Electric freight line to Stanton which was acquired from the Southern Pacific, as well as Pacific Electric car storage facilities in the Lake Street-Alabama Avenue area. In fact. except for some gates and walls,the old route of the Stanton freight line h;still available to the City for trail use. Granted, it would take some cooperation with two gated condo associations(The passage of one group of condo buildings appears constricted to a 10 foot but still useable gated way.), plus the fire department and residents who have come to regard the ROW as their own property,in order to perfect a protected pedestrian pathway of over a mile in length through old town Huntington Beach. What a blessing this would be for residents who could bike Mayor Green and Members of the City Council, my name is Paul Cross. Everyone is excited about Pacific City, but there are problems which must be resolved. Almost all difficulties,with the exception of soil and storm-water clean-up, are eliminated by making the project less dense. Some of the unintended consequences of Pacific City are easy to foresee,out other results of it are more obscure. For example, an environmental plan for Talbert Marsh to revert to much its former broad reach from the Santa Ana River to Beach Boulevard will become an empty dream. In the years to come, the electric power plant and the surrounding tank farm,which pre:.emly occupy much of the Talbert wetlands, will disappear because of obsolescence. But instead of rehabilitation of this essential wetland habitat,there will be roadways, connecting with bridges into Costa Mesa.Wealthy developers are waiting with plans for southeast Huntington Beach.With the new bridges and highways, 100 or more acres of south-beach wetlands wild be open to intensive develop nent. I urge you not abandon your opposition to new bridges across the Santa Ana River. Of course,without additional river crossings, Pacific City must be downsized. However,even with a smaller project,there still is ample room for the developer to realize large profits. As you are aware, without any subsidies, old town Huntington Beach is alive and well with in-fill construction. The thought that the city must provide incentives to the developer is nonsense_ It is not /necessary to give the developer two city owned Frontages along PCH, a city owned easement through the project, special permits alfowim,encroachment into setbacks, high street facing walls, and four story buildings placed on top of two story platforms. Please put a halt to these giveaways of city assets and or stroll all the way to the ocean along the former ROW. I sere the track charts I have obtained show that the Stanton ROW enters the 31-acres at a midpoint proximate to 11 Smet and Alabama Avenue and curves south where connection is made with the Santa Ana ROW. The ROW then continues through the 31- acres to an exit at N`Street and PCH. What a great benefit such a pedestrian walkway would be for old town residents. If there are public: safety concerns, it would be possible to close the condo portion of the trail during the night. Even thou;h this is, after all, one of the safest cities in America. Please do not accept the tiny pale imitation of public use offered by the developer. Protect the valuable assets of the City, and return this matter to the Planning Commission with instructions to exercise the discretion mandated by the CCC. Paul Cross EIR for Pacific City Project EIR No. 02-01 SCH No. 2003011024 November 26, 2003, Page 16 ATTACHMENT A PACIFIC CITY DRAFT EIR RESPONSE 1-IAZARDOUS 1IMATERIALS The Pacffic :lciion Coalition has researched recorcis aril itrtervieu,ed Huntington Beach resiclents and city officials about the presence of hazat'dotts materials oil the site of the proposect Pacific City development. An environmenlal chemist consulting for the Pacific City Action Coalition reviewed the Hcr_cn•dou.s i'vfeuerials section of'the Pacific City Draft Environmental Impact Report and other reports clescribing renredicuion and chat-acteriaation activities on the site. This docunrent presents the Coalition 's concerns relcrtecl to ha=ardous materials on the site that are not satisfactorily acicb•essed in the Draft Environmental Impact Report. We conclude with a recommended coarse of action that will ensure crcleguate assessment cord mitigation of environmental and human health risks associated with cevelopment our the Atlanta Avenue site. THE EIR CLAItVIS AREA D NEEDS INVESTIGATION, BUT THE PRIOR TESTING THERE HAS BEEN KEPT SECRET. (I) The EIR, in Section 3.7-10 states, "The area where further investigation is necessary is Area D, in the southwestern portion of the site...These areas do not include former oil wells or storage tanks. Sampling completed as part of the 1996 Phase 11 Investigation delineated the areas where remediation was necessary. Test results from that sampling effort did not detect that the contamination on the northern and eastern portions of the site had migrated to this area on the western portion of the site." The EIR implies that no remediation is necessary in the western part of the site while at the same time saying that further investigation is necessary. What the EIR fails to address is the testing which had been conducted in Area D by developer Vlakar Properties, Chevron and their consultant, Harding ESE in late 2001 or early 2002, identifying potential groundwater contamination by hydrocarbons. According to a sworn affidavit by Kamron Saremi of the California Regional Water Quality Board, Chevron's consultant, Harding ESE, approached him in 2002 with a proposal to leave contaminated soils in place which were near groundwater in the west central portion of the site. Saremi visited the site with Chevron and their consultant. He stated that Harding ESE presented groundwater testing samples to him taken from sample bores in the impacted area, the sampling area being approximately one acre. Saremi said the vertical extent of impacted soil was approximately five to ten feet below the ground surface. He stated that Chevron knew that a City of Huntington Beach requirement mandated the soil involved would have to be excavated. City oflhcruintton Brach — Pacific City t6 The Urban Pbrrtning Consulting Groin EIR for Pacific City Project EIR No. 02-01 SCH No. 2003011024 November 26, 2003, Page 17 Saremi told the consultant that the groundwater test results necessitated them conducting more extensive testing in a larger area and suggested they submit a work plan for this purpose. Chevron said they would talk to their consultant and prepare a work plan for submittal. Chevron then contacted Saremi two weeks later and said they had decided to work with the City of Huntington Beach to implement the required soil excavation. These test records have been requested from the City and developer Nlakar for months and have not been disclosed to the public. A document dated January 3, 2002 was then submitted to Saremi and cc'd to the City's Fire ____Department, Chevron and developer Makar referencing the above discussion. The report includes a groundwater testing plan, but references the southeastern pan ofthe site, an area totally separate from the section visited and discussed by Saremi. (2) The EIR, in Section 3.7-17 states, "While not anticipated once closure reports have been submitted, the possibility remains for unidentified soil contamination...or for unidentified underground storage tanks to be encountered during grading or excavation activities...It is possible that underground tanks may have been in use at the project site prior to permitting and record keeping requirements." A sworn affidavit by resident John Sisker, identified six to eight narrow, cylindrical tanks with pipes extending into the ground, located near First Street, approximately halfway between Atlanta Avenue and Pacific Coast Highway, the same area as the potential groundwater contamination noted above. These tanks and pipes are believed to be the type used in distilling or separating operations that separated and distributed crude oil into gasoline and diesel fuels. It is likely that the tanks referred to are located in the west central part of the site, Area D, and were repositories for the gasoline products referenced above. There is therefore evidence that the southwestern portion of the site (Area D) is contaminated with petroleum hydrocarbons, but the extent and composition of this contamination has not beer] characterized in the EIR and no plan for remediation of this area has been submitted. The potential impacts of contamination in Area D on workers and residents near the development are unknown, but must be analyzed in the EIR rather than deferred until after development has already proceeded. (3) In 1990, a warning sign identifying the presence of carcinogens and chemicals which may cause birth defects was present on the site, but has since been removed. This warning was precipitated by the Proposition 65 guideline regarding potential groundwater contamination. Where are the test results or reports which generated this warning? It is believed that Chevron, who owned the property at the time, was aware of prior groundwater contamination and has reports indicating such. City of Huntington Beach — Pacific City 17 The Urban Pkinning Consulting Group EIR for Pacific City Project EIR No. 02-01 SCH No. 2003011024 November 26, 2003, Page 18 (4) The EIR states, in Section 3.7-10, that "groundwater beneath the project is also brackish due to saltwater intrusion, and as such, is not used as potable water by the City" as ajustification for why groundwater contamination should not be a concern. This statement ignores the scientific fact that petroleum contamination on the Pacific City site could potentially pose health risks to residents of the adjacent community, particularly if there are low molecular weight carcinogenic hydrocarbons such as benzene, toluene, ethyl benzene and xylene (BTE\) at the site. If present at sufficient levels, BTE\ could form a non-aqueous phase that would leach through the soil to the soil-groundwater interface and spread out along the top of the groundwater. This could lead to_esposure of residents_in_nearby houses by infiltration of vapors and subsequent inhalation. A study released last year in the American Journal of Industrial \Medicine found an increased risk of gliomas (a type of tumor) in Swedish men and women over two decades when occupationally exposed to petroleum products and other chemicals such as arsenic and mercury. The study is indicative of current research interest in this area, and is particularly relevant given the recent cases of brain stern glionta among Huntington Beach residents who lived along Yorktown Avenue and were potentially exposed to oil field contamination. The EIR does not address the possible impacts of hydrocarbon contamination of groundwater on residents living adjacent to the site, and the extent of this groundwater contamination remains unknown. THE EIR IDENTIFIES AREA A AS HAVING CODIPLETED RENIEDIATION. (1) The ELR states in Section 3.7-7 that the soil invoked in the 1999 export to the Hyatt (approximately 215,000 cubic yards) exceeded city specifications for hydrocarbon contamination and was either excavated or remediated on site. The EIR also states in section 3.7-17, "Residual oil could be present in the areas remediated, and this cannot be confirmed until closure reports have been submitted and accepted by the City Fire Department that verify the site has been satisfactorily remediated." The "Final Environmental Closure Report" for the Hyatt submitted to the city by Hyatt developer Robert \layer Corporation claimed there was no evidence of contaminated soil in any of the samples tested and thus contained no documentation of either excavated or remediated soil. The Nlayer Corporation conducted limited sampling in Area A during the period of August through September 1999, even though soil continued to be excavated and transported through November of that year. City of Huntington Beach — Pacific City 15 Ttr Urban Pbznnitlg Consulting Group EIR for Pacific City Project EIR No. 02-01 SCH No. 2003011024 November 26, 2003, Page 19 Residents John Sisker and Ron Satterfield completed sworn affidavits attesting to soil being vented for a period of six months to one year after being stockpiled at the Hyatt location. It is believed that the venting was carried out to purge the soil oflow molecular weight hydrocarbons (BTEX chemicals). Photos of the site taken during the 1999 soil transport reveal the soil to be very dark and in some instances, nearly black. Considering the site's history of oil production, it is likely that the soil samples taken did not accurately reflect the nature and extent of the area's contamination. Furthermore, mixing of soils as a type of "remediation" does not remove contaminants from the site, leaving the possibility that high concentrations of contaminated soil could still exist. (2) .N-layer Corporation has a history of non-compliance with state and local requirements spanning the last decade, including: A 1990 class action lawsuit filed by Pacific Mobile Home Park residents against the Mayer Corporation for violating AQi%-fD dust control guidelines while constructing the Hilton hotel. Ironically, the dust which covered homes in the park came from stockpiles of soil at the Pacific City site, which at the time had signs posted warning of soil contamination. The suit was settled for S 100,000. A 1991 AQMD lawsuit tiled against the Mayer Corporation for dust control violations during the constriction of the Hilton hotel which was settled for S 15,000. Several neighborhood complaints were lodged with both the AQMD and the City during the 1999 soil transport. Although the iNlayer Corporation had a dust control plan in place, measures to control the dust were not implemented until the surrounding homes had been covered with dust. A S55,000 fine assessed by the Regional Water Quality Control Board for stormwater runoff violations occurring in December, 2002. Among the violations were the dumping of sediment laden storm water directly into the storm drain. According to Seaside Village residents, who face the new residential development behind the Hyatt hotel, the Mayer Corporation continues to violate Water Board guidelines by allowing runoff from the project to impact their homes. The above facts raise several questions — (1) Did the City's Fire Department know that there was contaminated soil which was found and not included in Mayer's report? If so, why did they sign off on the project? (2) Was the Fire Department unaware of any such findings? (3) Where are the records to support the EIR's claim that the soil was contaminated, excavated and remediated, despite months of requests from both the city and developer Makar for more details on A9ayers report, (4) Was the contaminated soil actually excavated and remediated on site orjust transported as eyewitness accounts verify, (5) Why is the soil contamination being disclosed now despite the public being told City of 1,11�11 ngton 6racL —Pacifc City 19 TGe Urban Pkznnini� Consulting Group EIR for Pacific City Project EIR No. 02-01 SCH No. 2003011024 November 26, 2003, Page 20 for years that the soil involved was clean? (6) Does this mean that the "Final Environmental Closure Report" for the Hyatt was inaccurate? (7) Ifso, why doesn't the EIR address this issue? (3) \Moreover, the 1996 Phase II Study Shows fOUt' areas that were "surgically excavated" to remove hydrocarbon contaminated soil for remediation by mixing. Three of these tour areas are marked in the EIR map, Figure 3.7-1, as part ofArea A where remediation has been deemed complete. Flo wever, one of the four areas, SufgicaI Excavation Number I on the 1996 map, is part of Area B in the EIR map, where remediation is "currently underway." Thus, as Surgical Excavation Number 1 in 1996 was not effective at cleaning up the site, why would the other three excavations in Area A be considered effective? (4) In Section 3.7-5, the EIR references reports of a former gas plant, identified by a Chevron employee interviewed for the 1995 Phase I Study. The plant reportedly operated at the corner of First Street and Atlanta Avenue, north of the site. The EIR then makes two statements, (I) "...no documentation exists to support the existence of gas plant" and, (2) "If a gas plant did exist on property adjacent to the project site, toxic contaminants associated with gas condensate from a gas plant could remain in the soil." The EIR should not use a lack of documentation from half a century ago as justification for questioning the plant's existence At the same time, the EIR acknowledges that the former Chevron employee who identified the gas plant was also correct in stating that toxic contaminants could remain in the soil. Once again, several questions are raised, (1) Where are the test results, documents or statements to support the above statement?, (2) Is the EIR relying on the Chevron employee's statement for this information?, (3) Wouldn't the Chevron employee's statement regarding the gas plant's existence then be reliable? The EFR again contradicts itself. Section 3.7-5 states, "These contaminants would be localized on the site and would not be expected to have migrated across First Street through the soil to the project site...As such, these contaminants are not expected to exist on the northwestern portion of the site or otherwise affect soils on the property site." While Section 3.7-18 states, "Due to the migratory nature of oil in the soil, the risk remains for oil contamination to exist in soil areas that have not been previously trenched for sampling and investigation." Which of these statements is accurate? If the first statement is true, are there test results to substantiate it? Is there new testing of the northwest part of the site which has not been disclosed? City ol*Huntington Beach — Pacific City 20 The Urban Planning Consulting Group r EIR for Pacific City Project EIR No. 02-01 SCH No. 2003011024 November 26, 2003, Page 21 Or is the EIR relying on the 1996 Phase II testing of die northwest portion and/or the 1999 testing by \layer, both of which have been contradicted in the EIR itself. THE TEST RESULTS ARE CONTRADICTOR17 AND UNRELIABLE (f) The EIR states in Section 3.7-9 that 1999 hydrocarbon testing in the southeastern part of the site revealed levels of up to 130,000 mg/kg for shallow soil and 68,000 mg/kg for deep soil. These levels are 15 to 100 times higher than the prior testing conducted in the 1996 Phase II Study by Chevron's consultant, Harding Lawson. As some of the areas tested in 1999 and 1996 overlap, this seems to indicate that the site became more contaminated over time. I-low is this possible? Or does this mean that the 1996 Phase If Study was inaccurate? Where are the test results and sampling maps to accompany the 1999 testing? These documents have been requested from the city and developer itlakar for months and have not been disclosed to the public. (2) Developer Makar, along with Chevron and their consultant Harding Lawson made an exemption request to leave approximately 300 cubic yards of contaminated soil surrounding a water main in Area C. They wanted to rely on BTEY testing from the 1996 Phase If Study, even though no testing in the impacted area was conducted during that period. The original exemption request was recommended for approval by the city's consultant, Geosciences Analytical, whose principal, Fleet Rust was convicted in 2002 of falsifying methane monitoring data to the City. The developer and Chevron withdrew their exemption request shortly after the Pacific City Action Coalition disclosed the above details to the public. City of Huntington Beach— Pacific City 21 The Urban PGtnning Consultitrg Group EIR for Pacific City Project EIR No. 02-01 SCH No. 2003011024 November 26, 2003, Page 22 CONCLUSIONS The Pacific City Draft Environmental Impact Report's Hazardous Materials section relies heavily on prior studies conducted by developer Makar Properties, Chevron and their consultant(s) Harding- Lawson and I-larding ESE, and the Robert Nlaver Corporation. These studies were sanctioned and approved by the City of Huntington Beach and their consultants. As previously illustrated, the studies have been shown to be misleading, incomplete and contradictory and thus unreliable. One of the consultants involved in assessing the site was even convicted of submitting fraudulent test results for another site. The_City_of Huntington_Beach has improperly sanctioned and,distributed_ much of the misleading_data and been negligent in it's role of ensuring compliance with established laws and regulations. The only fair conclusion is that the parties involved — developer Makar Properties, Chevron and their consultants along with the City of Huntington Beach, cannot be relied upon to provide an objective, accurate characterization of the environmental conditions at the Pacific City site. Given the potential community health risks involved as a result of not properly assessing conditions at the site, the only viable alternative is to have testing done by an independent firm, mutually selected by the developer, Chevron, the city and the Pacific City Action Coalition, paid for by the developer and Chevron, who is responsible for the site clean-up. City of Huntington Beacb— Pacific City 22 The Urban Planning Consulting Group Notice of Preparation State Cleannghousc 1400 Tenth Street Sacramento,CA 95814 (916)445-0613 Subject: Notice of Preparation of a Draft environmental Impact Report Lead Agency: Consulting Firm(if applicable): Agency Nana: City of Huntington Beach Firm Name: EIP Associates Street Address: 2000 Main Street Street Address: 12301 Wilshire Boulevard,Suite 430 City/State/Zip: Huntington Beach,CA 92W City/State/Zip: Los Angeles, CA 90025 Contact: Mary Beth Broeren, Principal Planner Contact: Terri Vitar, Regional Vice President Marianne Tanzer, Associate Manager The City of Huntington Beach will be the Lead Agency and will prepare an environmental impact report (EIR) for the project identified below. We need to know the views of your agency as to the scope and content of the environmental information which is germane to your agency's statutory responsibilities in connection with the proposed project. Your agency will need to use the EIR prepared by our agency when considering your permit or other approval for the project. The project description, location, and the potential environmental effects are contained in the attached materials. A copy of the Initial Study(© is ❑ is not)attached. Due to the time limits mandated by State law, your response must be sent at the earliest possible date but not later than 30 days after receipt of this notice. Please send your response to Mary Beth Broeren, Principal Planner, at the address shown above. Agency responses to this NOP should include the name, address, and phone number of the person who will serve as the primary point of contact for this project within the commenting agency. A scoping meeting to discuss the environmental issues to be addressed in the EIR for the proposed project will be held on Monday, January 27, 2002. The meeting will be held at the Huntington Beach Central Library, 7111 Talbert Avenue in the City of Huntington Beach, Rooms C and D on the lower level. The meeting will take place between the hours of 6:00 and 8:00 p.m- Project Title: Pacific City Project Location: City of Huntington Beach,County of Orange Project Description: The proposed project is a mixed-use visitor-serving commercial center together with a residential village located on a 31.5-acre vacant parcel in the City of Huntington Beach downtown on the inland side of Pacific Coast Highway. Major project components include: ■ Visitor-seeing commercial center: 400-room hospitality component (i.e., hotel) and associated amenities, and up to 240,000 square feet of commercial uses that could include retail, office, restaurant,cultural, and entertainment facilities ■ Residential village: 516 condominiums • Vehicular and pedestnan circulation improvements Existing On-Site Uses Reference California Code of Regulations,Title 14(CEQA Guidelines)Sections 15082(a), 15103, 15375. 1 The project site is currently vacant, although construction activities and various land uses on the project site have occurred since the late 1800s. Southern California Edison currently maintains aerial transmission lines along the Ist Street property boundary and regional 66kV transmission facilities along the Atlanta Avenue site boundary. On-site oil facilities have been abandoned and soil remediation is underway, with completion expected in early 2003. A portion of the southwesterly comer of the site was recently uses as a staging/storage facility for beach cleaning equipment for the City of Huntington Beach. The site is no longer used for this purpose, although a storage bin remains on the property. Land Use and Planning Designations The General Plan subarea designation of 4C applies to the portion of the site fronting PCH. It specifies visitor-and community-serving commercial uses, development at a maximum height of eight stones, and design/development charactenstics for development. The subarea 41 designation applies to the northern portion of the site and specifies multi-family residential and open space uses, development at a maximum height of four stones, and design/development characteristics for development. The Downtown Specific Plan includes development regulations and zoning standards that are intended to supplement and/or supersede the City's Zoning Ordinance. The Specific Plan area is divided into a number of Districts, and the project site is located in two of these districts, the boundaries of which correlate with the General Plan subareas. The southwestern portion of the site that fronts PCH and extends northeast to the proposed extension of Pacific View Dnve (Walnut Avenue) is within District 7, "Visitor-Serving Commercial." The balance of the site is the area inland of the future Pacific View Drive extension and is designated as Downtown Specific Plan District 8A, "High Density Residential." The Precise Plan of Street Alignment (PPSA No. 88-1) and Ordinance 2961 establishes the alignment for the extension of Pacific View Drive through the project. The project site is also located within the California Coastal Zone and the Main-Pier Redevelopment Project Area. Project Components The proposed project is anticipated to be constructed in major phases over a two to ten-year period, depending on prevailing market conditions. Each of the project components is described below. Visitor-Serving Commercial Center This component would occupy approximately 10.6 acres of the site adjacent to PCH and provide hospitality and commercial facilities. Upscale-oriented hospitality (i.e., hotel) facilities would include up to 400 guest rooms, a pool, spa, fitness and yoga center, restaurant, lounge and bar, pool area grille, resort retail shops, and meeting/banquet and conference facilities. Commercial uses would include development of up to 240,000 square feet. Uses may include retail shops, grocery, dining, entertainment facilities, International Surfing Museum, and office uses on the second floor. Development would be housed in several structures up to three stories in height, with the exception of the hotel building that would be eight stones in height. The proposed conceptual site plan also includes plazas and courtyards. Parking would be provided in a subterranean garage. Residential Village The residential component would occupy the approximately 17.2-acre northeastern portion of the project site. A total of 516 condominiums would be developed at an average of 30 dwelling units per acre. Development would include 2-to 4-story structures with a variety of architecture, dwelling unit types and 2 sizes, all clustered around recreational amenities to serve the residents of the village. Public open space would also be provided, including a public access corridor that traverses the site. Parking would be provided in a subterranean garage and in surface parking areas along the interior collector street. A minimum of two parking spaces in the subterranean garage would be provided for each unit. In addition, subterranean and surface parking would be provided to serve guests of the community. Affordable Housing would be provided by either on- or off-site units, or some combination thereof, in compliance with the City's Housing Element of the General Plan and redevelopment policies. Vehicular and Pedestrian Circulation Improvements Vehicular and pedestrian access to the project site would be provided by a combination of existing and proposed roadways. Pacific View Drive would be extended through the site in a 90-foot right of way. On Huntington Street, between Pacific View Drive and Pacific Coast Highway, additional right of way would be dedicated west of the centerline to allow for the full secondary arterial right-of-way with sidewalks and curb and gutter improvements. On Atlanta Avenue, between 1" Street and Huntington Street, additional right of way would be dedicated south of the centerline to allow for arterial improvements. Vehicular access to the visitor-serving uses would be from lst Street (service access only), the extension of Pacific View Drive (two visitor and one service access), and Huntington Street (service and employee access only). No vehicular access is proposed from PCH. Vehicular access to the residential uses would be provided from Pacific View Drive (residents and guests) and First Street and Huntington Street (residents only). The residential village includes a private community collector street off of Pacific View Drive that would be gated for vehicles, but accessible to pedestrians. Pedestrian access improvements include pedestrian corridors throughout the project site, including linkages between the surrounding residential communities and the proposed residential component. Consistent with the Specific Plan, a 20-foot corridor between Atlanta Avenue and PCH (between the southern end of the Pacific Electric right-of-way and PCH) would be dedicated for public access. Pedestrian pathways would also connect to the commercial component. Several crossings to the beach area to the south are proposed, including two at-grade crossings at the existing signalized intersections of PCH and Huntington and Ist Streets, and a grade-separated pedestrian bridge crossing in the center of the visitor-serving commercial district. ��"����,� p Date: January 8, 2003 Signature: `IIIl.t.�Ca l f_ Q�fdYDQre Title: Principal Planner Telephone: (714) 536-5550 3 17 .Z . . .. . .. ­71 _7 A', PLANNINGD,.EPARTMENU T Z 'NTALASS A 1. PROJECT TITLE: Pacific City Concurrent Entitlements: Commercial Master Site Plan Master Conceptual Plan Tentative Parcel Map Coastal Development Permit 2. LEAD AGENCY: City of Huntington Beach Department of Planning 2000 Main Street Huntington Beach, CA 92648 Contact: Mary Beth Broeren, Principal Planner Phone: (714) 536-5550 3. PROJECT LOCATION: Area bounded by I st Street on the west, Huntington Street on the east, Atlanta Avenue on the north, and Pacific Coast Highway(PCH) on the south. 4. PROJECT PROPONENTS: Makallon Atlanta Huntington Beach, LLC 4 100 MacArthur Boulevard, Suite 150 Newport Beach, California 92660 5. GENERAL PLAN DESIGNATION: RH-30-sp (Residential High Density—maximum 30 units/acre—Specific Plan) and CV-F7-sp (Commercial Visitor—maximum floor area ratio of 3.0— Specific Plan). The project site is also designated as General Plan Subareas 4C and 41. 6. ZONING: Downtown Specific Plan—District 8A (High Density Residential), District 7 (Visitor- Serving Commercial). 7. PROJECT DESCRIPTION (Describe the whole action involved, including, but not limited to, later phases of the project, and secondary support, or off-site features necessary for implementation): The proposed project is a mixed-use visitor-serving commercial center together with a residential village located on a 31.5-acre vacant parcel in the City of Huntington Beach downtown on the inland side of Pacific Coast Highway(Figure 1). Major project components include: WENVIRONMCHECKLST Page I u ' R E G I O NAL LOCATION YORKTOWN AV wE+wuEE tour., ..� Eui oEwuaa.0 couvn ,� �\WVEa3Rl CIXJv^r O� No 51ject / GOB. 0 Huntlnpton '•.� w li Stitch / 1 ' rye r. ti U y� Orange County INDIANAPOLIS AV '• 'C 9C ti FRANKFORT ear y N N o HUWING TOM O''c.C� A r 1' g� a z W CITY 001 BEACH y/y` "�Q O ATLANTA V 2 HuxnxcrGN BEACH j pgC/P/C PIER jj Project o,71 Site F 9,y HUNTINGTON STALE BEACH FIGURE 1 .._-EI-P- Project Vicinity & Regional Location Map Not to Swle _N-' SCURCL EIP As..i 10261-W City of Huntirgm BO ch-Pxiflc Gry El ■ Visitor-serving commercial center: 400-room hospitality component (i.e., hotel) and associated amenities, and up to 240,000 square feet of commercial uses that could include retail, office, restaurant, cultural, and entertainment facilities ■ Residential village: 516 condominiums ■ Vehicular and pedestrian circulation improvements Existing On-Site Uses The project site is currently vacant, although construction activities and various land uses on the project site have occurred since the late 1800s. Southern California Edison currently maintains aerial transmission lines along the 1 st Street property boundary and regional 66kV transmission facilities along the Atlanta Avenue site boundary. On-site oil facilities have been abandoned and soil remediation is underway, with completion expected in early 2003. A portion of the southwesterly comer of the site was recently uses as a staging/storage facility for beach cleaning equipment for the City of Huntington Beach. The site is no longer used for this purpose, although a storage bin remains on the property. Land Use and Planning Designations The General Plan subarea designation of 4C applies to the portion of the site fronting PCH. It specifies visitor- and community-serving commercial uses, development at a maximum height of eight stories, and design/development characteristics for development. The subarea 4I designation applies to the northern portion of the site and specifies multi-family residential and open space uses, development at a maximum height of four stories, and design/development characteristics for development. The Downtown Specific Plan includes development regulations and zoning standards that are intended to supplement and/or supersede the City's Zoning Ordinance. The Specific Plan area is divided into a number of Districts, and the project site is located in two of these districts (Figure 2), the boundaries of which correlate with the General Plan subareas. The southwestern portion of the site that fronts PCH and extends northeast to the proposed extension of Pacific View Drive (Walnut Avenue) is within District 7, "Visitor-Serving Commercial." The balance of the site is the area inland of the future Pacific View Drive extension and is designated as Downtown Specific Plan District 8A, "High Density Residential." The Precise Plan of Street Alignment (PPSA No. 88-1) and Ordinance 2961 establishes the alignment for the extension of Pacific View Drive through the project. The project site is also located within the California Coastal Zone and the Main-Pier Redevelopment Project Area. Project Components The proposed project is anticipated to be constructed in major phases over a two to ten-year period, depending on prevailing market conditions. A Conceptual Site Plan is shown in Figure 3, and each of the project components is described below. Visitor-Serving Commercial Center This component would occupy approximately 10.6 acres of the site adjacent to PCH and provide hospitality and commercial facilities. Upscale-oriented hospitality (i.e., hotel) facilities would include up to 400 guest rooms, a pool, spa, fitness and yoga center, restaurant, lounge and bar, pool area grille, resort retail shops, and meetingfbanquet and conference facilities. Commercial uses would include development of up to 240,000 square feet. Uses may include retail shops, grocery, dining, entertainment Page 3 LEGEND .•.•. Project Blte Boundary Cn � C cs O E 0) (� C �a = Residential Atlanta Ave ................... Residential Project Site h%4 0 �Oc9�cT8 OF sT,q-9 � Mobile Home Park c04 O FRc, cr # T0*9 c, FrC 0� Oc, 9 ti FIGURE 2 Not to Scale � — — Existing Site Overlays and Surrounding Uses -EIP SWRCE:EIP ksaum t026t.00 Cityof Huntirgton Beach•Pacific City EIR LEGEND Site Boundary .. 1�. 0 "� Visitor Serving ... ... Commercial ✓,.'� '� ':j ..... Residential Village fJf '47 IJ Qbl f nQ I�/.•� W )/,�Q ]��� R`.'.//� lei • �_� RESID6. ENTIAL OLIVE AVENUE Y3�—r,, `[`q• r„—t. �I_� Q3,1�«^' � l 4 � 1 . HOTEL - J ,rNNr'�N flS -LEI `COMMERCIAL/ OFFICEL_ RESTAURANT COMMERCIAL • P•CIi1C CO ,,Lln�ullll141�,111'111�4Hn���`llRiint���Il - I r r FIGURE 3 Not to Scnlo _ ��j. --LJR Proposed Site Plan SOURCE:MVE&Padners moe+.GG """ " City of Huntington Beach•Pacific City EIR facilities, International Surfing Museum, and office uses on the second floor. Development would be housed in several structures up to three stories in height, with the exception of the hotel building that would be eight stories in height. The proposed conceptual site plan also includes plazas and courtyards. Parking would be provided in a subterranean garage. Residential Villaee The residential component would occupy the approximately 17.2-acre northeastern portion of the project site. A total of 516 condominiums would be developed at an average of 30 dwelling units per acre. Development would include 2- to 4-story structures with a variety of architecture, dwelling unit tvpes and sizes, all clustered around recreational amenities to serve the residents of the village. Public open space would also be provided, including a public access corridor that traverses the site. Parking would be provided in a subterranean garage and in surface parking areas along the interior collector street. A minimum of two parking spaces in the subterranean garage would be provided for each unit. In addition, subterranean and surface parking would be provided to serve guests of the community. Affordable Housing would be provided by either on- or off-site units, or some combination thereof, in compliance with the City's Housing Element of the General Plan and redevelopment policies. Vehicular and Pedestrian Circulation Improvements Vehicular and pedestrian access to the project site would be provided by a combination of existing and proposed roadways. Pacific View Drive would be extended through the site in a 90-foot right of way. On Huntington Street, between Pacific View Drive and Pacific Coast Highway, additional right of way would be dedicated west of the centerline to allow for the full secondary arterial right-of-way with sidewalks and curb and gutter improvements. On Atlanta Avenue, between I" Street and Huntington Street, additional right of way would be dedicated south of the centerline to allow for arterial improvements. Vehicular access to the visitor-serving uses would be from 1st Street (service access only), the extension of Pacific View Drive (two visitor and one service access), and Huntington Street (service and employee access only). No vehicular access is proposed from PCH. Vehicular access to the residential uses would be provided from Pacific View Drive (residents and guests) and First Street and Huntington Street (residents only). The residential village includes a private community collector street off of Pacific View Drive that would be gated for vehicles, but accessible to pedestrians. Pedestrian access improvements include pedestrian corridors throughout the project site, including linkages between the surrounding residential communities and the proposed residential component. Consistent with the Specific Plan, a 20-foot corridor between Atlanta Avenue and PCH (between the southern end of the Pacific Electric right-of-way and PCH) would be dedicated for public access. Pedestrian pathways would also connect to the commercial component. Several crossings to the beach area to the south are proposed, including two at-grade crossings at the existing signalized intersections of PCH and Huntington and 1st Streets, and a grade-separated pedestrian bridge crossing in the center of the visitor-serving commercial district. 8. SURROUNDING LAND USES AND SETTING: Existing land uses surrounding the project site include the following: ■ East (across Huntington Street): The Hilton Waterfront Beach Resort and the Pacific Mobile Home Park Page 6 ■ North (across Atlanta Street): Single- and multi-family residential uses ■ West (across Ist Street): Vacant lots, oil production and storage facilities, small apartment units and single-family homes, and a fast food restaurant ■ South (across PCH): Beach, open space, vehicle parking, and beach-related uses 9. OTHER PREVIOUS RELATED ENVIRONMENTAL DOCUMENTATION: The project site has been addressed on a programmatic level as part of the analysis included in several Program EIRs prepared by the City. These documents include: (1) The Huntington Beach Downtown Specific Plan EIR 82-2 and Addendum to SEIR 82-2; (2) The Huntington Beach General Plan Update EIR 94-9; and (3) The Huntington Beach Redevelopment Project EIR 96-2. Each of these documents includes analysis that accounts for development at the project site. The General Plan Update EIR analyzes the theoretical buildout of the entire City. The Redevelopment Project EIR analyzes buildout of the Redevelopment Project Area, which includes 619 acres over five redevelopment sub-areas within the City. The Downtown Specific Plan EIR analyzes buildout of the City's downtown area. Therefore, the Downtown Specific Plan EIR provides the most localized analysis of the area. However, impacts particular to the project site require analysis that was not provided in previous documentation. Therefore, the EIR prepared for the proposed project would be considered a Subsequent EfR to EIR 82-2. Section 21166 of CEQA requires preparation of a subsequent EIR due to changes in the existing conditions in the Downtown Specific Plan Area and the proposed project description. The proposed project is consistent with the zoning and general plan land use designations for the project site. However, changes with respect to the circumstances under which the project is being undertaken (i.e., changes to existing conditions) and new information, in the form of project details, has become available since the completion of EIR 82-2. Therefore, impacts particular to the project site require analysis that was not provided in previous documentation. A subsequent EIR is required pursuant to Section 15183(a) of the State CEQA Guidelines, which states: CEQA mandates that projects which are consistent with the development density established in the existing zoning, community plan, or general plan policies for which an EIR was certified shall not require additional environmental review, except as might be necessary to examine whether there are project-specific significant effects which are peculiar to the project or its site. In addition to the programmatic environmental documents that consider the ultimate development of the site, a Mitigated Negative Declaration (MND) was prepared to address short-term soil export activities from the project site in conjunction with hotel development to the east Q 1 Acre Site Soil Export, Environmental Assessment No. 99-1). Soil removal activities involved the export of approximately 226,000 cubic yards of soil from the project site. This activity occurred independent of the development currently proposed for the project site. Soil export was completed in 1999, and there are no remaining on-site activities associated with this work. 10. OTHER AGENCIES WHOSE APPROVAL IS REQUIRED (AND PERMITS NEEDED) (i.e., permits, financing approval, or participating agreement): Other agencies whose approval may be required include, but are not limited to: ■ California Department of Transportation (for any encroachment in PCH right of way and/or pedestrian bridge construction); Page 7 ■ California Regional Water Quality Control Board (permit for dewatering during construction and operation of the subterranean parking structure, National Pollutant Discharge Elimination System (NPDES) permit ■ State Water Resources Control Board (General Construction Activity Stormwater Permit) ■ South Coast Air Quality Management District (Authority to Construct, Operating Permit) Page 8 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED: The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a "Potentially Significant Impact" or is "Potentially Significant Unless Mitigated," as indicated by the checklist on the following pages. Land Use/ Planning Transportation/Traffic ❑X Public Services Population / Housing 0 Biological Resources Utilities/ Service Systems ❑% Geology/Soils Mineral Resources ❑x Aesthetics ❑x Hydrology/Water Quality Hazards and Hazardous Materials ❑X Cultural Resources 0 Air Quality ❑x Noise ❑X Recreation ❑ Agriculture Resources ❑x Mandatory Findings of Significance DETERMINATION (To be completed by the Lead Agency) On the basis of this initial evaluation: 1 find that the proposed project COULD NOT have a significant effect on the environment, ❑ and a NEGATIVE DECLARATION will be prepared. I find that although the proposed project could have a significant.effect on the environment, there will not be a significant effect in this case because the mitigation measures described on ❑ an attached sheet have been added to the project. A MITIGATED NEGATIVE DECLARATION will be prepared. I find that the proposed project MAY have a significant effect on the environment, and an ❑ ENVIRONMENTAL IMPACT REPORT is required. I find that the proposed project NIAY have a "potentially significant impact' or a "potentially significant unless mitigated impact"on the environment, but at least one impact (1)has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed. I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects(a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided ❑ or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required. Januah�T� Signature Date �0rMarq pie fre.n anner Printed Naak Title Page 9 EVALUATION OF ENVIRONMENTAL IMPACTS: 1. A brief explanation is required for all answers except "No Impact" answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question. A "No Impact" answer is adequately supported if the referenced information sources show that the impact simply does not apply to the project. A "No Impact' answer should be explained where it is based on project-specific factors as well as general standards. 2. All answers must take account of the whole action involved. Answers should address off-site as well as on- site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts. 3. "Potentially Significant Impact' is appropriate, if an effect is significant or potentially significant, or if the lead agency lacks information to make a finding of insignificance. If there are one or more "Potentially Significant Impact' entries when the determination is made, preparation of an Environmental Impact Report is warranted. 4. Potentially Significant Impact Unless Mitigated" applies where the incorporation of mitigation measures has reduced an effect from "Potentially Significant Impact' to a "Less than Significant Impact." The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from Section XVIII, "Earlier Analyses,"may be cross-referenced). 5. Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D). Earlier analyses are discussed in Section XVM at the end of the checklist. 6. References to information sources for potential impacts (e.g., general plans, zoning ordinances) have been incorporated into the checklist. A source list has been provided in Section XVIII. Other sources used or individuals contacted have been cited in the respective discussions. 7. The following checklist has been formatted after Appendix G of Chapter 3, Title 14, California Code of Regulations, but has been augmented to reflect the City of Huntington Beach's requirements. (Note: Standard Conditions of Approval -The City imposes standard conditions of approval on projects which are considered to be components of or modifications to the project, some of these standard conditions also result in reducing or minimizing environmental impacts to a level of insignificance. However, because they are considered part of the project, they have not been identified as mitigation measures.) SAMPLE QUESTION: Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES(and Supporting Information Sources): Impact Incorporated Impact No bnpact Would the proposal result in or expose people to potential impacts involving: Landslides? (Sources: 1, 6) ❑ El ❑X Discussion. The attached source list explains that 1 is the Huntington Beach General Plan and 6 is a topographical snap of the area which show that the area is located in a fat area. (Note: This response probably would not require fuvther explanation). Page 10 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact I. LAND USE AND PLANNING. Would the project: a) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project(including, but not limited to the general plan,specific plan, local coastal program,or zoning ordinance)adopted for the purpose of avoiding or mitigating an environmental effect?(Sources: 7, 8, 10, 11) Discussion: The General Plan Overlays and land use designations that apply to the proposed project property include RH-30-sp (Residential High (Density)—maximum 30 units/acre—Specific Plan), CV-F7-sp (Commercial Visitor—maximum floor area ratio of 3.0—Specific Plan), and subareas 4C and 41. The Downtown Specific Plan designates the portion of the proposed site fronting PCH and extending back to the proposed extension of Pacific View Drive (Walnut Avenue)between Huntington Street and 1st Street as District 7 (Visitor-Serving Commercial). In addition, the area of the project site located inland of the future Pacific View Drive extension is designated by the Downtown Specific Plan as District 8A (High Density Residential). The project is designed to be compatible with the existing zoning and general plan land use designations and is expected to have a less-than-significant impact. However, to ensure compatibility with applicable land use regulations, an analysis of the proposed project's consistency with applicable land use plans, policies, and regulations will be included in the EIR. b) Conflict with any applicable habitat conservation plan or ❑ ❑X natural community conservation plan? (Sources: 7, 8) Discussion: No habitat conservation plan or natural community conservation plan includes the project site. No impact would occur, and no further analysis of this issue is required. c) Physically divide an established community? (Sources: 7, 9) ❑ ❑ 0 ❑ Discussion: The proposed project would not physically divide an established community. The project involves development of a vacant parcel of land in the city. Project development would include extension of Pacific View Drive through the site, providing an additional linkage between the areas east and west of the project site. In addition, the visitor-serving commercial district access would be provided through proposed service entrances on Ist Street and Huntington Street and visitor entrances on the Pacific View extension. Pedestrian corridors would be located throughout the project to link the surrounding residential communities and to provide access to the beach. As such, the proposed project would not disrupt or physically divide an established community. Impacts would be less than significant, and no further analysis is required. 11. POPULATION AND HOUSING. Would the project: a) Induce substantial population growth in an area,either directly ❑X ❑ ❑ ❑ (e.g.,by proposing new homes and businesses)or indirectly (e.g.,through extensions of roads or other infrastructure)? (Sources: 9) Page /I Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: The residential component of the proposed project consists of the construction of 516 condominium homes, which could result in a direct increase in population growth. In addition, employment opportunities that could indirectly increase population would result from commercial development. The proposed project would be consistent with uses planned for the site, and, as such, population changes associated with the project have been anticipated in growth projections. The proposed project's effect on population and housing projections for the City of Huntington Beach will be evaluated in the EIR. b) Displace substantial numbers of existing housing, necessitating ❑ ❑ ❑ ❑X the construction of replacement housing elsewhere? (Sources: N/A) Discussion: The proposed project site is currently vacant and would not result in the displacement of any existing housing. No impact would occur, and no further analysis of this issue is required. c) Displace substantial numbers of people, necessitating the ❑ ❑ ❑ ❑K construction of replacement housing elsewhere? (Sources: N/A) Discussion: The proposed project site is currently vacant and would not result in the displacement of any existing households. No impact would occur, and no further analysis of this issue is required. III. GEOLOGY AND SOILS. would the project: a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: i) Rupture of a known earthquake fault,as delineated on the ❑X most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault?(Sources: 7, 24) Discussion: The City of Huntington Beach General Plan EIR states that fault rupture constitutes a direct impact to affected areas within the City of Huntington Beach. The most likely areas for fault rupture are the more restricted Alquist•Priolo zones, and "engineering, geologic, and geotechnical engineering investigation report requirements are in place to mandate studies as a means of developing mitigation measures (usually avoidance) for construction." The project site is neither located within an identified Alquist-Priolo zone nor any areas in which evidence of a fault exists. No impacts from fault rupture would result;therefore,no further analysis is required. ii) Strong seismic ground shaking?(Sources: 7, 24) Page 12 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: The site is located 0.6 mile from the Newport-Inglewood Fault zone. Consequently, the proposed project may expose on-site structures to significant seismic hazards (e.g. shaking) if an earthquake occurs along this fault. Impacts associated with seismic hazards would generally be addressed through adherence to applicable regulations (i.e., Uniform Building Code) and design, grading and structural recommendations identified in the Preliminary Geotechnical Investigation performed by Zeiser Kling Consultants, Inc. The EIR will include an analysis of impacts associated with seismic hazards. iii) Seismic-related ground failure, including liquefaction? ❑X (Sources: 24) Discussion: According to the Preliminary Geotechnical Investigation performed by Zeiser Kling Consultants, Inc. for the proposed project site, the alluvial soils that are located in the southeastern corner of the site are located within a State of California Seismic Hazard Zone Map for Liquefaction. While the majority of the site is generally underlain by terrace and engineered fill (which are, in turn, underlain by terrace deposits)and is considered to have a low potential for liquefaction, the southeastern comer of the site is generally underlain by loose to medium dense alluvial deposits that have a moderate to high potential for liquefaction. These risks could generally be addressed through adherence to applicable regulations (i.e., Uniform Building Code) and design, grading and structural recommendations identified in the Preliminary Geotechnical Investigation. The EIR will analyze the potential for liquefaction hazards to affect the project. iv) Landslides? (Sources: 24) ❑ ❑ ❑ Discussion: The proposed project site and surrounding area are generally Flat and the project site is not located within a State of California-designated Seismic Hazard Zone Map for Slope Stability. Therefore, the potential for seismically induced slope instability is considered low to remote. Therefore, no impact would occur,and no further analysis is required. b) Result in substantial soil erosion,loss of topsoil,or changes in topography or unstable soil conditions from excavation, grading, or fill? (Sources: N/A) Discussion: The project site is currently undeveloped and consists primarily of exposed and disturbed vegetation. As such, grading for above-ground project components and excavation at the site would expose soil to erosional processes during construction. Once construction is completed, the site would be fully developed and would include minimal areas of exposed soil. Excavation activities would be required to prepare the site for subterranean parking, which would affect soil stability. These impacts could be addressed through the implementation of Best Management Practices during construction activities and adherence to design, grading and structural recommendations identified in the Preliminary Geotechnical Investigation. The EIR will analyze the potential for erosional impacts from construction activities. c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? (Sources: 24) Page 13 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: The geologic units at the project site consist mostly of dense to overconsolidated terrace and fill materials, while the southeastern portion of the site consists of medium dense alluvial deposits. The Preliminary Geotechnical Investigation concluded that the potential for ground lurching, cracking, or seismically induced spreading or compaction effects within these areas are considered low, with the anticipation that engineering controls and corrective grading would be implemented for the proposed project. As discussed in item Ill.a.iii., above, the majority of the site has a low potential for liquefaction, with the exception of the southeastern comer of the site, which has a moderate to high potential for liquefaction. In addition, the project site is not within an area that has been impacted by long-term subsidence due to local oil extraction according to the Huntington Beach General Plan. However, the settlement potential of the buildings exists, and the EIR will address this issue. In addition, the EIR will address the ability for engineering controls to appropriately address geologic stability. d) Be located on expansive soil,as defined in Table 18-1-B of the a Uniform Building Code (1994), creating substantial risks to life or property? (Sources: 24) Discussion: Refer to the discussion for Item III.c.,above. e) Have soils incapable of adequately supporting the use of septic ❑ ❑ ❑X tanks or alternative waste water disposal systems where sewers are not available for the disposal of wastewater(Sources: 18) Discussion: The proposed project would be provided sanitary sewer service by the City of Huntington Beach and no septic tanks or alternative wastewater systems are proposed. No impact would occur,and no further analysis of this issue is required. IV. HYDROLOGY AND WATER QUALITY. would the project: a) Violate any water quality standards or waste discharge ❑ ❑X Cl ❑ requirements? (Sources: 6, 7, 8) Discussion: Project development would change the character of the site from an undeveloped parcel of land to a mixed-use development with roadways,buildings,paved surfaces, and landscaping. Potential development would potentially result in site characteristics that could cause runoff to adversely affect water quality. The City's Standard Conditions of Approval require the preparation of a water quality management plan pursuant to the National Pollutant Discharge Elimination System(NPDES) requirements, that would address impacts on water quality. The ability of the project to meet applicable waste discharge and water quality requirements will be addressed in the EIR. Page 14 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact b) Substantially deplete groundwater supplies or interfere ❑ Q substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level(e.g., the production rate of pre- existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted? (Sources: 6, 7, 8) Discussion: According to City staff, groundwater wells currently supply 75 percent of the City's water; the remaining 25 percent is imported. Project development would increase impervious surfaces, which could reduce groundwater recharge. However, the City's groundwater wells are located a minimum of two miles inland from the project site and the City does not rely on groundwater that close to the ocean due to saltwater intrusion. Therefore, the potential reduction in groundwater recharge would not affect City groundwater wells. Impacts would be less than significant, and no further analysis is necessary. c) Substantially alter the existing drainage pattern of the site or ❑ ❑X ❑ ❑ area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on or off-site? (Sources: 6, 7, 8) Discussion: The project site contains no streams or rivers. The site currently drains via sheetflow due to the lack of any on-site development. Erosion or siltation could occur during construction-related earthmoving activities. Proposed development would result in the introduction of roadways, buildings, paved surfaces, and landscaping, whereby runoff would be collected and conveyed via roof and building drains and curbs and gutters. These impacts could be addressed through the incorporation of Best Management Practices during construction and water quality management practices. However, potential erosion due to changes in drainage patterns will be analyzed in the EIR. d) Substantially alter the existing drainage pattern of the site or Q area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount or surface runoff in a manner which would result in flooding on or off- site? (Sources: 6, 7, 8) Discussion: As the proposed project site is currently undeveloped, development of the proposed project would increase impervious surfaces at the site associated with the addition of roadways, buildings, and other paved surfaces. This, in turn, would modify local drainage patterns and increase the rate and/or volume of surface runoff at the site. As such,the existing storm drainage facilities serving the site may not be adequate to accommodate the project's operation-related surface runoff, leading to flooding either on- or off-site. These impacts could be addressed through incorporation of design features on the project site to control peak discharge. A hydrology report for the project is currently in preparation, and an analysis of potential flooding due to project runoff will be provided in the EIR. e) Create or contribute runoff water which would exceed the ❑ ❑ capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? (Sources: 6,7, 8) Page 15 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: The project would comply with all waste discharge requirements and water quality objectives of State and Federal agencies as part of the City's Standard Conditions of Approval. While no uses are proposed that would result in substantial polluted runoff, the proposed project would alter the drainage pattern of the site (as discussed in items IV.c. and IVA. above), which would result in additional runoff that could exceed the capacity of existing stormwater systems. These impacts could be addressed through incorporation of design features on the project site to control peak discharge or infrastructure upgrades. Potential impacts to the stormwater drainage system will be addressed in the EIR. f) Otherwise substantially degrade water quality? (Sources: 6, 7, ❑ ❑ 8) Discussion: Project development would change the character of the site from an undeveloped parcel of land to a rr xed-use development with roadways, buildings, paved surfaces, and landscaping. Potential development would potentially result in site characteristics that could cause runoff to adversely affect water quality. The City's Standard Conditions of Approval require the preparation of a water quality management plan pursuant to NPDES requirements, which would address impacts on water quality. The ability of the project to meet applicable waste discharge and water quality requirements will be addressed in the EIR. g) Place housing within a 100-year flood hazard area as mapped ❑ ❑ on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? (Sources: 14) Discussion: The location of the residential component within the project site is within Flood Zone "X" pursuant to the FEMA Flood Insurance Rate Map dated January 3, 1997, and revised by Letter of Map Revision dated February 13, 2002, which indicates that it is outside of the 500 year floodplain. As such, the proposed project would not place housing within a 100-year flood hazard area. No impact would occur, and no further analysis of this issue is required. h) Place within a 100-year flood hazard area structures which ❑ would impede or redirect flood flows? (Sources: 6, 7, 8, 14) Discussion: The Flood Zone "X" designation, which is given to the project site, applies to areas of rr nimal to moderate flood hazard (where flood insurance is available but not required by federally regulated lenders). The project site is currently in Zone "X" according to the FEMA Flood insurance Rate Map dated January 3, 1997, and revised by Letter of Map Revision dated February 13, 2002, which indicates that it is outside of the 500-year floodplain. Therefore, substantial flood flows would not be redirected by the placement of structures on the project site. No impact would occur, and no further analysis is required. i) Expose people or structures to a significant risk of loss, injury El ❑ or death involving flooding, including flooding as a result of the failure of a levee or dam? (Sources: 6, 7,8, 14) Page 16 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: The flood risk and potential flood level assessments for the City include the possibility of the failure of Prado Dam, which, while located in Riverside County, provides the primary flood protection means for downstream areas. The levees constructed along the Santa Ana River also tr nimize the flood risks to areas within the City that include the project site. FENIA revised the flood maps for areas within the City of Huntington Beach, including the project site, in 1997 and through 2002 in recognition of the improvements to the Santa Ana River Channel: these revisions actually reduced the anticipated flood level by 6.5 feet, which estimated the flood level below the elevation of the project site. Additionally, the channelization of the Santa Ana River from Weir Canyon Road to the Pacific Ocean has improved the capacity of the channel sufficiently that the channel can convey the water volume associated with a 190-year flood event. Therefore, the possibility of significant risk of loss, injury, or death from flooding would be remote. Impacts would be less than significant, and no further analysis is required. j) Inundation by seiche, tsunami, or mudflow? (Sources: 6,7, 8, 24) Discussion: The site is located on a flat area that is not expected to generate or be exposed to mudflows. The tsunami hazard for the City is classified as "very low." However, the site is located within an area of"moderate" tsunami run-up. Due to the lack of land-locked bodies of water (i.e., ponds or lakes), the potential for seiches is considered to be non-existent. Potential impacts from tsunamis on the proposed project will be analyzed in the EIR. V. AIR QUALITY. The city has identified the significance criteria established by the applicable air quality management district as appropriate to make the following detemunations. Would the project: a) Conflict with or obstruct implementation of the applicable air ❑ ❑ quality plan? (Sources: Project Application, 6, 7, 8) Discussion: The project as proposed would entail substantial earth movement and construction activities. In addition,project operation would result in increased vehicular trips in the area. Increased emissions associated with these vehicular trips and other on-site emissions could potentially conflict with the Southern California Air Quality Management District's (SCAQMD) Au Quality Management Plan. The EIR will address potential project exceedance of the SCAQMD thresholds of significance, which may result in a conflict with or obstruct the implementation of the AQMP, and violation of any local and regional air quality standards during construction and operation. b) Violate any air quality standard or contribute substantially to an 0 existing or projected air quality violation? (Sources: 6, 7, 8) Page 17 Potentially Significant Potentially unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: Refer to the discussion for item V.a., above. In addition, grading at the project site (including excavation for the subterranean parking) and other construction activities resulting from implementation of the proposed project could result in significant temporary, short-term impacts to air quality due to fugitive dust and construction equipment emissions. Currently the non-attainment pollutants in the South Coast Air Basin, which includes Orange County, are ozone, carbon monoxide (CO), and fine particulate matter (PMro). Construction-related activities and traffic generated by operation of the proposed project could contribute to these existing violations. These impacts to air quality from project construction and operation will be evaluated in the EIR. c) Expose sensitive receptors to substantial pollutant ❑ ❑ ❑ concentrations? (Sources: 6, 7, 8) Discussion: Project-generated traffic could contribute to decreased levels of service at nearby intersections, resulting in CO hot spots. The potential for the project to result in these substantial pollution concentrations will be addressed in the EIR. d) Create objectionable odors affecting a substantial number of people? (Sources: 6, 7, 8) Discussion: The project does not propose, and would not facilitate, uses that are significant sources of objectionable odors. The only potential source of odor associated with the proposed project may result from construction equipment exhaust during construction activities, the storage of solid waste associated with the commercial and residential uses, and potential odors from restaurant uses. The proposed project is anticipated to be constructed in major phases over a two-to ten-year period. Standard construction requirements would address odors from construction imposed on the applicant, and impacts associated with construction-generated odors are expected to be less than significant. It is expected that any project- generated refuse would be stored in covered containers and removed at regular intervals in compliance with the City's solid waste regulations. Therefore, odors associated with the proposed project would be less than significant, and no further analysis is required. e) Result in a cumulatively considerable net increase of any 19 ❑ ❑ criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? (Sources: 6, 7,8) Discussion: Refer to the discussion for item V.a., above. VI. TRANSPORTATION/TRAFFIC. would the project: a) Cause an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system(e.g., result in a substantial increase in either the number of vehicle trips,the volume to capacity ratio on roads,or congestion at intersections? (Sources: 6, 7, 8) Page 18 Potentially Significant Potentially Unless Less,than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: The proposed project is planned to be constructed in several major phases over a two- to ten-year period. During this construction period, impacts on traffic from construction vehicles queuing at and entering and exiting the site could occur. In addition, the project would generate additional vehicular trips that could potentially result in a substantial traffic increase in the area. This increase in traffic would further add to the existing traffic load and would impact the existing capacity of the street system. The potential impacts due to increased trip generation, changes to the volume to capacity ratio on roads, and congestion at intersections will be analyzed in the EIR. b) Exceed,either individually or cumulatively,a level of service ❑ standard established by the county congestion management agency for designated roads or highways? (Sources: 6, 7, 8) Discussion: Refer to the discussion for item VI.a, above. Increased trip generation could potentially exceed LOS standards on Congestion Management Program roads,and the EIR will address this potential impact. c) Result in a change in air traffic parents, including either an El ❑ ❑ increase in traffic levels or a change in location that results in substantial safety risks? (Sources: 22) Discussion: Although the City is located within the Airport Environs Land Use Plan for Joint Forces Training Base Los Alamitos, the project site is not located within 2 miles of any known public or private airstrip. The proposed project does not propose any structures whose height would interfere with existing airspace or flight patterns. No impact would occur, and no further analysis of this issue is required.. d) Substantially increase hazards due to a design feature(e.g., ❑X ❑ ❑ sharp curves or dangerous intersections)or incompatible uses? (Sources: 6,7, 8) Discussion: Pacific View Drive would be extended through the 31.5-acre project site. The project design is not anticipated to include any design features that would result in vehicular hazards. Pedestrian corridors would be provided throughout the project site, including linkages between the surrounding residential communities and the proposed residential component and the visitor-serving commercial district. In addition to the above-grade pedestrian overcrossing that is proposed, at-grade crossings are proposed at the existing signalized intersections of PCH and Huntington and Ist Streets to the beach. Potential impacts could be addressed through the implementation of a pedestrian safety plan. Pedestrian safety, particularly related to the interface between pedestrian areas and roadways/project access points, will be evaluated in the EIR. e) Result in inadequate emergency access? (Sources: 6, 7, 8) ❑ ❑X Page 19 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: Vehicular access to the visitor-serving commercial district of the proposed project would be provided by proposed entrances on 1st Street, the Pacific View extension, and Huntington Street. Access to the residential component would be from 1st Street. Huntington Street, and Pacific View Drive. In addition, the residential component includes a private community collector street(loop road)off of Pacific View Drive that would be gated for vehicles. Impacts to access could be addressed through review by the Huntington Beach Police Department and Huntington Beach Fire Department and conformance with the City's emergency access requirements. The EIR will analyze project impacts to emergency access. f) Result in inadequate parking capacity? (Sources: 6, 7, 8) El ❑ ❑ Discussion: The proposed project would include parking in conformance with City requirements. In addition, any existing on-street parking that is removed from the adjacent arterial streets in association with City-required street improvements would be replaced on a one for one basis on-site within the project. However, parking constraints could arise if there are competing demands for parking spaces from multiple uses. As such, the operational adequacy of the parking plan to meet demand associated with various on-site uses will be addressed in the EIR. g) Conflict with adopted policies supporting alternative El El ❑ transportation(e.g.,bus turnouts, bicycle racks)? (Sources: 6, 7, 8) Discussion: The proposed project is compatible with and supported by the City's General Plan. The mixed-use visitor-serving commercial district together with a residential component fulfills the designated land uses of the General Plan and Downtown Specific Plan. The proposed project is compatible with regional policies to promote alternative modes of transportation by encouraging a pedestrian-friendly environment. Numerous pedestrian pathways would be provided between the surrounding residential communities and the proposed residential component. These pedestrian pathways would then be connected to the visitor-serving commercial district by intersections and clearly delineated entrances to the retail, entertainment, restaurant, and hospitality amenities. While the project is not anticipated to conflict with policies supporting alternative transportation and impacts are considered less than significant, the EIR will provide an analysis of project compliance with these policies. VI I. BIOLOGICAL RESOURCES. Would the project: a) Have a substantial adverse effect,either directly or through ❑ ❑ habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies,or regulations,or by the California Department of Fish and Game or U.S,Fish and Wildlife Service? (Sources: 3) Page 20 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: According to the Biological Technical Report prepared for the proposed project, no special status plant species are expected to occur on the project site. However, three of the 29 special status plant species known to occur in the region have a limited potential to occur on the project site because they are known to occur in disturbed habitats. These species are the southern tarplant(Cenrromadia parryi ssp. Australis), vernal barley(Hordeunt intercedens),and Coulter's golfields (Lasthenia glabrata ssp. Coulteri). to addition, 11 of the 51 special status wildlife species known to occur in the proposed project region have the potential to occur on the proposed project site. All of these 11 special status wildlife species, with the exception of the monarch butterfly, are birds. However, most of these wildlife species are expected to occur briefly on the site for foraging only and have no potential to nest on the proposed project site. The Biological Technical Report concludes that impacts to special status wildlife species would be less than significant. The potential exists for special status plant species to have occurred on the project site since the completion of the Biological Technical Report (February 2002), and impacts to those species, if present on-site, would be potentially significant. Site surveys prior to construction would determine the presence of these species on-site. If special status plant species are identified, impacts could be addressed through avoidance of species on-site, relocation, or purchase of offsite populations. The EIR will include an analysis of potential impacts to special status species. b) Have a substantial adverse effect on any riparian habitat or ❑ ❑ ❑ X❑ other sensitive natural community identified in local or regional plans,policies,regulations, or by the California Department of Fish and Game or US Fish and Wildlife Service? (Sources: 3, 6, 7, 8) Discussion: No riparian habitat or other sensitive natural community exists on-site. The project site has been graded various times over the past 100+ years in connection with prior development of the site, which has included commercial, residential, industrial, and agricultural uses. As such, the project would not have any effect on any riparian habitat or other sensitive natural communities. No impact would occur,and no further analysis of this issue is required. c) Have a substantial adverse effect on federally protected ❑ El ❑X wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh,vernal pool, coastal,etc.) through direct removal, filling, hydrological interruption,or other means? (Sources: 6, 7, 8) Discussion: The project site contains no wetland habitat, as defined by the Clean Water Act or the Fish and Game Code of California. No impact would occur,and no further analysis of this issue is required. d) Interfere substantially with the movement of any native resident ❑ Q or migratory fish or wildlife species or with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites? (Sources: 3) Page 21 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: Although the site is currently undeveloped, various developments have occurred at the site over the past 100+ years. The site currently consists of ornamental and disturbed vegetation types along with developed areas consisting of paved parking lots. The Biological Technical Report concludes that no wildlife movement is expected on the proposed project site as the surrounding area is urbanized. As such, the proposed project site does not function as a movement corridor and the project would not impact wildlife movement. No impact would occur,and no further analysis of this issue is required. e) Conflict with any local policies or ordinances protecting El ❑ ❑X ❑ biological resources, such as a tree preservation policy or ordinance? (Sources: 6, 7, 8) Discussion: There are currently no biological resources within the project site, which is an infill site in an urbanized area. The proposed project would be consistent with the City's General Plan and zoning designations. However, as a shoreline community with a portion lying within the State's defined Coastal Zone, the City of Huntington Beach is subject to the coastal resource preservation policies of the Coastal Act. Therefore, the EIR will address the project's compliance with coastal resource policies of the Coastal Act. f) Conflict with the provisions of an adopted Habitat ❑ ❑ ❑X Conservation Plan, Natural Community Conservation Plan,or other approved local, regional, or state habitat conservation plan? (Sources: 6, 7, 8) Discussion: No habitat conservation plan or natural community conservation plan affects the project site, therefore, no impact would occur. No further analysis of this issue is required. VIII. MINERAL RESOURCES. would the project: a) Result in the loss of availability of a known mineral resource ❑ that would be of value to the region and the residents of the state? (Sources: 9, 13) Discussion: The site was used as an operating oil field by Chevron, containing 21 oil production facilities, although it has been shut down for a number of years. Several abandoned oil wells exist within the site, and oil well abandonment occurred over a number of years,beginning in 1976 and occurring through 1999. The majority of on-site wells were initially abandoned in 1988 and subsequently re-abandoned in 1998. Oil Overlay "C" has been identified on a portion of the site within the Downtown Specific Plan. The purpose of the overlay is to allow for existing and/or expanded oil production on the property. The Oil Overlay Specifications identify conditions that must be met in order for this to occur. However, the proposed project does not propose to renew any oil drilling activities on the subject site. Therefore, the EIR will address the loss of availability of on-site mineral resources. b) Result in the loss of availability of a locally-important mineral ❑ resource recovery site delineated on a local general plan, specific plan, or other land use plan? (Sources: 14) Page 22 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: As discussed in item VIII.a., above, the site is identified as an Oil Overlay"C" in the City's Downtown Specific Plan, and proposed development would result in the loss of availability of this oil overlay area. The EIR will address the loss of this on-site resource. IX. HAZARDS AND HAZARDOUS MATERIALS. Would the project: a) Create a significant hazard to the public or the environment El ❑ X❑ ❑ through the routine transport,use, or disposal of hazardous materials? (Sources: 6, 7, 8) Discussion: The proposed project includes the development of mixed-use (residential and commercial) structures and would not introduce any unusual hazardous materials to the area. Proposed construction and operation would comply with CalOSHA (California Occupational Safety and Health Administration) requirements, the Hazardous Materials Management Act (HMMA), and other State and local requirements. Commercial uses handling or storing certain amounts of hazardous materials would prepare a Hazardous !Materials Business Plan (HMBP) consistent with the HMMA, which includes an inventory of hazardous materials stored on-site, an emergency response plan, and an employee training program. Compliance with local, State, and federal regulations would minimize risks associated with accident conditions involving the release of hazardous materials into the environment. Therefore, impacts would be less than significant, and no further analysis of this issue is required. b) Create a significant hazard to the public or the environment ❑ ❑ ❑X ❑ through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? (Sources: 6,7, 8) Discussion: Refer to discussion item IX.a., above. The proposed project would not include use of large quantities of hazardous materials, and hazardous materials would be used and stored in accordance with applicable regulations. The project would include residential, hotel, and commercial uses that typically do not involve handling of hazardous materials in a manner that would result in reasonably foreseeable upset and accident conditions. Therefore, impacts would be less than significant,and no further analysis of this issue is required. c) Emit hazardous emissions or handle hazardous or acutely ❑ El ❑ hazardous material, substances, or waste within one-quarter mile of an existing or proposed school? (Sources: 6, 7, 8, 22) Discussion: No schools are located within 1/4 mile of the project site. In addition, refer to discussion item IX.a., above. No impact would occur, and no further analysis of this issue is required. Page 23 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and,as a result, would it create a significant hazard to the public or the environment? (Sources: 6. 7, 8, 15, 17) Discussion: The project site is not on the State's Hazardous Waste and Substances Sites List (CORTESE). However, an Environmental Site Assessment prepared for the Huntington Shores Motel, which was formerly located on the project site, revealed that there are two listed properties within 1/8 mile of the site that have had documented Underground Storage Tank (UST) releases: the City of Huntington Beach Maintenance Yard and an ARCO service station. The Maintenance Yard release has been cleaned up and the case is closed, while the ARCO release is currently being remediated. Additionally, there are five listed properties between 1/8 and 1/2 mile of the project site that are on the California Environmental Protection Agency(CaUEPA) Leaking Underground Storage Tanks (LUST) List. Two of these properties have been cleaned up and the cases are closed. The other three are either being characterized or remediated. Although the project site is currently undeveloped,a number of prior uses have occurred on the site, including agricultural, commercial, and industrial uses. Among the industrial land uses that once occupied the site were 21 oil production facilities. The oil facilities have been abandoned. A Phase II Investigation of the project site was performed in 1996, which resulted in a subsequent soil remediation plan for the project site. Due to the presence of oil-impacted soil at the project site, remediation efforts in the northwestern portion of the project site were completed in 1999. Soil remediation is currently underway in the southeastern portion of the site, and remediation efforts are expected to be completed in early 2003. Remediation at the site is following EPA guidelines and standards, and consists of cleanup of all TRPH-impacted soil. Excavated areas are being backfilled with mechanically treated soil that is within acceptable TRPH concentrations. An estimated total of 12,686 cubic.yards of oily soil is projected to be excavated at the site. Aside from soil contamination from oil, the adjacent property north of the Huntington Shores Motel was reportedly occupied by a gas plant, and contaminants such as benzene and toluene may have remained in the soil from the gas condensate. As such, the EIR will assess the potential for discovery of any undetected contamination at the project site in the future upon project implementation. These impacts could be addressed through development of a health and safety plan,as necessary, if contamination is discovered. e) For a project located within an airport land use plan or, where ❑ such a plan has not been adopted, within two miles of a public airport or pubic use airport, would the project result in a safety hazard for people residing or working in the project area? (Sources: 6, 7,8, 22) Discussion: Although the project site is located within the Airport Environs Land Use Plan for Joint Forces Training Base Los Alamitos, it is not located within 2 miles of any known public or private airstrip. Additionally, the proposed structures would not exceed heights that require review and approval by the Federal Aviation Administration(FAA)or Airport Land Use Commission(ALUC). The project would not, therefore, result in a safety hazard for people residing or working in the project area. No impact would occur, and no further analysis of this issue is required. f) For a project within the vicinity of a private airstrip, would the ❑ ❑ project result in a safety hazard for people residing or working in the project area? (Sources: 6, 7, 8, 22) Page 24 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: Refer to discussion for item IX.e., above. No impact would occur, and no further analysis of this issue is required. g) Impair implementation of or physically interfere with an X❑ ❑ adopted emergency response plan or emergency evacuation plan? (Sources: 6, 7, 8) Discussion: With regard to emergency response plans, the project site does not serve a function in any emergency response or evacuation plan (schools are typically employed for this purpose). The project site is located adjacent to PCH, which could serve as a major thoroughfare in an emergency situation. In addition, a portion of the project site borders Atlanta Avenue, a major thoroughfare in the city. However, no project accesses are located along either of these streets. Therefore, no constraints to emergency response plans would result. Impacts would be less than significant, and no further analysis is required. h) Expose people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? (Sources: 6, 7, 8) Discussion: The project is not located within the vicinity of any wildland areas. No impact would occur, and no futher analysis of this issue is required. X. NOISE. Would the project result in: a) Exposure of persons to or generation of noise levels in excess M of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? (Sources: 8, 11) Discussion: Over the long term, noise would be generated at the proposed project site due to increased traffic during project operation and by activity at the site once it is built and occupied. The noise created by the project could affect residences across 1st Street, Atlanta Avenue, and Huntington Street (the nearest sensitive receptors), the commercial uses along PCH, and other land uses in the Downtown Core area. Noise from mechanical equipment (such as air conditioning systems) associated with operation of the project would be required to comply with the State Building Code requirements pertaining to noise attenuation such that interior noise levels do not exceed 45 dB in any habitable room(including hotels), and with City regulations requiring adequate buffering of such equipment. However, the noise generated by vehicles and human use associated with operation of the site may exceed noise thresholds. This issue will be addressed in the EIR. Page 25 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Temporary increases in ambient noise levels would occur during periods of construction at the project site. Chapter 8.40 of the Municipal Code for Noise Control generally prohibits construction activity between the hours of 8 P..m. and 7 A.bt. on weekdays and Saturdays, and all day on Sundays (§8.40.090). Certain after-hours construction is allowed provided that the noise standards (§8.40.050) of the ordinance are met. Daytime noise greater than 75 dBA in residential areas and greater than 80 dBA in commercial areas is prohibited by the ordinance. Additionally, a permit for construction activities (which requires a review of the proposed activities) must be obtained from the City. Reference data for construction equipment noise illustrates that operation of typical heavy equipment would result in noise levels between approximately 75 dBA and 100 dBA when measured 50 feet from the source, depending primarily on the type of equipment in operation. Noise levels from a single piece of equipment tend to drop off at a rate of 6 decibels per doubling of distance: therefore, distance to sensitive receptors would help to reduce the construction noise. Due to the potential equipment mix, noise could still be perceptible in the Downtown Core area, and to the residences across lst Street, Atlanta Avenue, and Huntington Street. Since the proposed project is anticipated to be constructed over a two- to ten-year period, the duration of noise generated by construction of the proposed project may be considered significant despite compliance with the Noise Control ordinance and other conditions of project approval. This issue will be addressed in the EIR. b) Exposure of persons to or generation of excessive groundbome ❑X ❑ ❑ ❑ vibration or groundbome noise levels? (Sources: 6, 7, 8, 11) Discussion: In the project vicinity, the only existing source of perceptible ground-bome vibration is travel of heavy trucks or buses over bumps on the adjacent streets and the Pacific Coast Highway. Potential impacts could occur due to some construction activities. However, project operation would not include uses that would result in groundbourne vibration. Vibration impacts during project construction will be addressed in the FIR. c) A substantial permanent increase in ambient noise levels in the ❑X ❑ ❑ ❑ project vicinity above levels existing without the project? (Sources: 6, 7, 8, 11) Discussion: Existing noise levels in the project area are dominated by traffic and by the activities of people throughout the Downtown Core area. As stated above in the discussion for item Ka., the project would contribute to the traffic noise and would cause additional noise from human activity at the project site, operation of mechanical equipment, and other facilities, and increased vehicular traffic. Noise from the project's mechanical equipment would be regulated by the Noise Control ordinance. However, the noise generated by project traffic once the project is built could substantially increase noise levels in the area. Noise increases due to increased human activity and vehicular trips associated with the project will be addressed in the EIR. d) A substantial temporary or periodic increase in ambient noise ❑ levels in the project vicinity above levels existing without the project? (Sources: 6, 7, 8, 11) Discussion: Project construction activities would cause a temporary increase in ambient noise, however the construction noise would be regulated by the Noise Control ordinance as discussed in item Ka, above. As the period of construction for the proposed project could range from between two to ten years, the construction noise generated at the project site may be considered significant. Noise impacts from construction will be addressed in the EIR. e) For a project located within an airport land use plan or, where ❑ ❑ El ❑X such a plan has not been adopted, within two miles of a public airport or public use airport,would the project expose people residing or working in the project area to excessive noise levels'? (Sources: 6, 7, 8, 21) Page 26 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: The project site is not located within two miles of a public airport, public use airport,or private airstrip. The project site is about ten miles from the Los Alamitos Armed Forces Reserve Center and the John Wayne Airport. Although the City is included within the Airport Environs Land Use Plan for Joint Forces Training Base Los Alamitos, the project site is outside of the 60 dB CNEL contour for the Los Alamitos Armed Forces Reserve Center. The project would not, therefore, expose people to excessive noise from airports. No impact would occur,and no further analysis of this issue is required. 0 For a project within the vicinity of a private airstrip, would the ❑ project expose people residing or working in the project area to excessive noise levels? (Sources: 6, 7, 8, 21) Discussion: Refer to discussion for item X.e.,above. No impact would occur, and no further analysis of this issue is required. XI. PUBLIC SERVICES. would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios,response times or other performance objectives for any of the public services: a) Fire protection? (Sources: 6, 7, 8) ❑ ❑ Discussion: The proposed project is located within the Department's 5-minute response time area. Due to the volume of development in the project area, which consists of 516 condomimurn homes, a 400-room hotel, and up to 240,000 square feet of commercial uses, the proposed development could result in an increased demand on additional fire protection services. Therefore, an analysis of project demand on fire protection services will be provided in the EIR. b) Police Protection? (Sources: 6,7, 8) ❑X ❑ Discussion: Proposed development would include 516 residential units, up to 240,000 square feet of commercial uses, and a 400-room hotel. The addition of these uses to the presently vacant site could increase demands on police protection services in the area. The EIR will provide an analysis of potential impacts to police services resulting from the proposed project. c) Schools? (Sources: Project Application) Discussion: The proposed project includes the development of 516 condominium homes. This would increase population in the area, which would, in turn, increase demands on existing schools. The project site would be served by the Huntington Beach City School District and the Huntington Beach Union High School District, and would be subject to school impact fee requirements. The potential increase in students, and the effect of the project on the existing school system, will be addressed in the EIR. Page 27 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact d) Parks? (Sources: N/A) ❑X ❑ El ❑ Discussion: The proposed project includes the development of 516 condominium homes, which would increase population in the area. This may, in turn, increase demands on existing parks serving the area. The proposed project includes recreational amenities to serve project residents and will be subject to standard park requirements. The ability of on-site parks to meet recreational needs of residents,and potential impacts to neighborhood parks, will be addressed in the EIR. e) Other public facilities or governmental services? (Sources: 11 ❑ N/A) Discussion: The proposed project includes development of 516 condominium homes and a 400-room hotel. These uses may induce an increase in demand for recreation on the adjacent beach area. Impacts to beach use will be addressed in the EIR. XII. UTILITIES AND SERVICE SYSTEMS. Would the project: a) Exceed wastewater treatment requirements of the applicable El 11 ❑ Regional Water Quality Control Board? (Sources: 6, 7, 8) Discussion: The proposed project would change the project site from an undeveloped parcel of land to a mixed-use development with roadways, buildings, paved surfaces, and landscaping. Thus, increased runoff could adversely affect water quality. However,the City's Standard Conditions of Approval require the preparation of a water quality management plan pursuant to NPDES requirements. This plan would address impacts on water quality. The ability of the project to meet applicable waste discharge and water quality requirements wilt be addressed in the EIR. b) Require or result in the construction of new water or ❑ M El El wastewater treatment facilities or expansion of existing facilities,the construction of which could cause significant environmental effects? (Sources: 6, 7, 8) Discussion: Due to the volume of residential and commercial development in the 31.5-acre project site, the proposed project would require incremental extensions of water and wastewater infrastructure to the site, which would be provided by the developer and by respective governmental agencies and utility companies. All utility connections to the proposed uses would be in accordance with all applicable Uniform Codes, City ordinances, Public Works standards, and Water Division criteria. Water and wastewater treatment would be served by existing facilities. While it is expected that impacts could be addressed through either design of the project to control peak flows or infrastructure upgrades, the ability for these facilities to meet increased demand associated with the proposed project will be addressed in the EIR. c) Require or result in the construction of new storm water ❑ ❑ drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? (Sources: 6, 7, 8) Page 28 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: Refer to the discussion for Item IV.e, above. The increase in impervious surfaces from development under the proposed project would alter the existing drainage pattern at the site, and would result in additional runoff that could exceed the capacity of existing storm water systems. The potential impacts to the storm water drainage system by the proposed project«iIl be addressed in the EIR. d) Have sufficient water supplies available to serve the project ❑ El from existing entitlements and resources, or are new or expanded entitlements needed? (Sources: 6, 7, 8) Discussion: As required by Senate Bill 610, any project exceeding 500 residential units must receive a Water Supply Assessment from the water purveyor prior to project approval to ensure that the available water supply would be sufficient to serve the project. Increased water demands would result from residential, hotel, and commercial uses at the project site. The City's General Plan EIR identifies the cumulative theoretical build-out scenario as exacerbating current inadequacies in water distribution and storage capacity. This issue will be addressed and results of the Water Supply Assessment will be provided in the EIR. e) Result in a determination by the wastewater treatment provider El ❑X ❑ which serves or may serve the project that it has adequate capacity to serve the project's projected demand in addition to the provider's existing commitments? (Sources: 6, 7, 8) Discussion: Refer to the discussion for Item XII.b., above. t) Be served by a landfill with sufficient permitted capacity to ❑X ❑ ❑ ❑ accommodate the project's solid waste disposal needs? (Sources: 6,7, 8) Discussion: Solid waste collection service for the City of Huntington Beach is provided by Rainbow Disposal. Collected solid waste is transported to a transfer station where the solid waste is sorted and processed through a Materials Recovery Facility where recyclable materials are removed. The remaining solid waste is transported to the Frank R. Bowerman Landfill located in the City of Irvine. The landfill has a remaining capacity in excess of 30 years based on present solid waste generation rates. The proposed project would result in an intensification of land use and increase solid waste generation. The project's potential impacts on landfill capacity will be analyzed in the EIR. g) Comply with federal,state,and local statutes and regulations related to solid waste? (Sources: 6, 7, 8) Discussion: Although participation in City and/or County recycling programs is assumed, design of project features are not yet finalized. Therefore, an analysis of the project's consistency with applicable regulations related to solid waste will be included in the EIR. Page 29 Potential Iv Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact XIII. AESTHETICS. would the project: a) Have a substantial adverse effect on a scenic vista? (Sources: ❑X ❑ 6, T8) Discussion: The project site is located adjacent to Pacific Coast Highway in the vicinity of the Huntington Beach pier. As stated within the General Plan, the Huntington Beach Pier and Pierside Pavilion are considered a "landmark;" which is defined as a significant reference point that helps to identify a particular area in the City. In addition, views from areas adjacent to the Project site include panoramic vistas of the beach area. The proposed project would result in construction of new commercial and residential facilities that may affect public view points and view corridors from these and other adjacent areas. The potential for the proposed project to modify existing scenic vistas will be evaluated in the EIR. b) Substantially damage scenic resources, including,but not 9 ❑ limited to, trees,rock outcroppings, and historic buildings within a state scenic highway? (Sources: 6, 7,8) Discussion: PCH is designated by the State of California as a Scenic Highway, containing visual amenities that enhance the visual quality and ambiance of the City. Scenic resources associated with PCH primarily include the Pacific Ocean to the south. The project proposes a grade-separated pedestrian bridge that would cross over PCH. This project component may affect views front PCH. Therefore, the potential for proposed development to affect the overall character of the viewing experience from PCH will be addressed in the EIR. c) Substantially degrade the existing visual character or quality of the site and its surroundings? (Sources: 6, 7,8) Discussion: Proposed development would transform the project site from a vacant parcel of land to a residential and commercial development with most structures from one to four stories in height, with the exception of the hotel that would be eight stories in height. The visual character of the area, including shade and shadows generated by the proposed development, would be substantially modified due to the increased development density of the area. The EIR will address the potential for these changes to adversely impact the area. d) Create a new source of substantial light or glare which would ❑X adversely affect day or nighttime views in the area? (Sources: 678) Discussion: Light impacts could result from new commercial and residential building activities, security lighting, such as along the buildings' perimeter, in the subterranean parking garage, and for surface parking along the interior collector street of the residential component. Lighting from the proposed project commercial and residential buildings may be visible from the street or light-sensitive receptors immediately surrounding the project site, including the existing adjacent residences and the Pier, which could be potentially affected by the new lighting system. This issue will be analyzed in the EIR. Glare can result from daytime reflection of sunlight off flat building surfaces. The proposed project may include reflective surfaces (e.g., windows, brightly colored or bare concrete building fagade treatments) due to large building faces. The visual impact of glare created by the project site will be addressed in the EIR. Page 30 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact XIV. CULTURAL RESOURCES. Would the project: a) Cause a substantial adverse change in the significance of a historical resource as defined in 515064.5? (Sources: 1) Discussion: There are no above-ground structures located on the site. The cultural resources report prepared for the project site reported two archaeological sites that had been previously identified on the project site: one prehistoric site (CA-ORA-149) and one historic site (CA-ORA-1582H). CA-ORA-1582H was determined not to be an historical resource under CEQA and any project-related impact to the known components of this archaeological site would be considered less than significant. However, site CA-ORA-149 has been determined to be potentially eligible for the California Register of Historic Resources (CRHR). The Archaeological Evaluation completed for the proposed project concludes that impacts to this site could be addressed through data recovery excavations and construction monitoring. The EIR will include an analysis of potential impacts to on-site cultural resources. b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to 615064.5? (Sources: 1) Discussion: Refer to the discussion for Item XIV.a., above. c) Directly or indirectly destroy a unique paleontological resource ❑ ❑X 11 ❑ or site unique geologic feature? (Sources: 2, 5) Discussion: The proposed project site is underlain by two sedimentary rock units, Pleistocene Marine Terrace Deposits and Holocene Alluvium and Colluvium. A paleontological resources impact mitigation program was conducted during the grading and soil export from the borrow area of the site in 1999. The mitigation program associated with the 1999 soil export activities resulted in the recovery of fossils from eight new sites identified during grading. As such, grading and other earth moving activities associated with the proposed project could result in the loss of scientifically important paleontological resources, such as previously unrecorded fossil sites, fossil remains, and associated geologic and geographic site data. The potential impacts to paleontological resources will be analyzed in the EIR. d) Disturb any human remains,including those interred outside of formal cemeteries? (Sources: 1) Discussion: As stated above under item(a), the project site includes two archaeological sites. The potential for discovery for human remains, while not anticipated, could occur due to construction activities on the project site. While this impact could be addressed through construction monitoring, the potential impacts to human remains will be analyzed in the EIR. XV. RECREATION. Would the project: a) Would the project increase the use of existing neighborhood, 19 ❑ ❑ 11 community and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? (Sources: 6, 7, 8, 12, 13) Page 31 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: Population increases associated with development of 516 condominium homes would increase demands on recreational facilities. The project proposes 0.9 acre of recreational and park areas in addition to common open space and would be subject to standard park requirements. Approximately 0.35 acre of park areas would be designated for private use by the residents of the proposed project. Approximately 0.55 acre of park areas on the project site would be accessible to the public. The current park per capita ratio for the City is 5 acres per 1,000 persons. As a result, on-site recreational resources may not adequately serve project residents. The EIR will analyze the potential for increased demands of off-site recreational facilities. In addition, significant impacts from the project could occur if the demand or need for lifeguard services from increased beach use exceeds the capacity of the existing level of service. Intensified development and additional parking could result in improved public access and increased beach use. The existing lifeguard staff and resources may not be sufficient to provide protection for an increased beach user population. Analysis of impacts to beach resources will be included in the EIR. b) Does the project include recreational facilities or require the El ❑ ❑ construction or expansion of recreational facilities which might have an adverse physical effect on the environment? (Sources: 6, 7,8, 12, 13) Discussion: The proposed project would include park areas that are for both public and private use. See item XV.a., above. The provision of a total of 0.90 acre of parkland on the project site is a component of the proposed project that could contribute to the potential impacts identified in this Initial Study. The provision of parks on-site will be analyzed as part of the overall project analysis included in the EIR. c) Affect existing recreational opportunities?(Sources: 6, 7, 8) ❑X ❑ Discussion: Population increases associated with development of 516 condominium homes would increase demands on recreational facilities. The project proposes 0.9 acre of recreational and park areas in addition to common open space. The current park per capita ratio for the City is 5 acres per 1,000 persons. As a result, on-site recreational resources tray not adequately serve project residents. In addition, the 400-room hotel could increase demands at nearby recreational resources. The EIR will analyze the potential for increased demands of off-site recreational facilities. XVI. AGRICULTURE RESOURCES. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997)prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. Would the project: a) Convert Prime Farmland,Unique Farmland,or Farmland of Q Statewide Importance(Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency,to non- agricultural use? (Sources: 4) Page 31 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: There is no Prime Farmland, Farmland of Statewide Importance, or Unique Famtland is located on-site. No impact would occur,and no further analysis of this issue is required. b) Conflict with existing zoning for agricultural use, or a El ❑ ❑ Williamson Act contract? (Sources: 4) Discussion: The project site is currently zoned as District 7 (Visitor-Serving Commercial) and District 8A (High Density Residential) in the Downtown Specific Plan and is not a Williamson Act contract. No impact would occur, and no further analysis of this issue is required. c) Involve other changes in the existing environment which, due ❑ ❑ to their location or nature, could result in conversion of Farmland, to non-agricultural use? (Sources: 23) Discussion: Although agricultural uses have once existed on the site in the form of potato crops and livery stables, the site has been graded various times over the past 100+ years in connection with prior development that has also included residential, industrial, and commercial uses, and is not adjacent to active farmland. This site is currently undeveloped. No environmental changes associated with the proposed project would result in the conversion of farmland to non-agricultural uses. No impact would occur,and no further analysis of this issue is required. XVII. MANDATORY FINDINGS OF SIGNIFICANCE. a) Does the project have the potential to degrade the quality of the ❑ ❑ environment,substantially reduce the habitat of a fish or wildlife species,cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community,reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? (Sources: 6, 7, 8) Discussion: As discussed above in sections IV, V, XIII, VII, XIV, and XV, the proposed project could potentially affect hydrology/ water quality, air quality, aesthetics, biological, cultural resources, and recreation. Additionally, impacts to any of the issue areas described above (for which potentially significant impacts have been identified) could be considered to affect the quality of the environment. These issues will be further analyzed in the EIR. b) Does the project have impacts that are individually limited, but cumulatively considerable? ("Cumulatively considerable" 19 El ❑ means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.) (Sources: 6, 7, 8) Page 33 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant ISSUES (and Supporting Information Sources): Impact Incorporated Impact No Impact Discussion: Proposed project impacts could contribute to cumulative impacts that would result from related development in the vicinity of the proposed project. The EIR will discuss the potential for cumulative impacts to all resource areas analyzed in the EIR. c) Does the project have environmental effects which will cause a ❑ ❑ substantial adverse effects on human beings, either directly or indirectly? (Sources: 6, 7, 8) Discussion: Potential impacts to human beings could occur through the potential environmental impacts on resources identified in this Initial Study. These impacts will be evaluated in the EIR. Page 34 XVIII. EARLIER ANALYSIS. Earlier analyses may be used where, pursuant to tiering, program EIR, or other CEQA process, one or more effects have been adequately analyzed in an earlier EIR or negative declaration (CEQA Guidelines Section 15063 [c][3][D]). The following earlier documents have been prepared and utilized in this analysis and are available for review at the City of Huntington Beach Planning Department: Reference # Document Title 1 Barros, P. and S. Call. 2002. Evaluation of Prehistoric Archaeological Site CA-ORA-149 and Historical Archaeological Site CA-ORA-1582H. January 2002. 2 Barros, P. and M. Roeder. 2001. Paleontologic Resource Impact Mitigation program Final Report. July 2001. 3 BonTerra Consulting. 2002. Revised Pacific City Biological Technical Report with cover letter. February 6,2002. 4 California, State of Department of Conservation, Office of Land Conservation. 1998 Orange County Important Farmland Map. 1999. 5 City of Huntington Beach. 1999. Mitigated Negative Declaration for the 31 Acre Site Soil Export. Environmental Assessment No. 99-1. 6 . 1996a. Huntington Beach Redevelopment Project Environmental Impact Report. State Clearinghouse No. 96041075. Prepared by LSA Associates. 7 1996b. General Plan. Prepared by Envicom Corporation. May 13. 8 1995a. General Plan Update Draft Environmental Impact Report. State Clearinghouse No. 94091018. Prepared by Envicom Corporation. 9 1995b. Downtown Specific Plan. 10 1994. Zoning and Subdivision Ordinance. www.ci.huntington-beach.ca.us/ElectedOfticials/CityClerk/ ZoningCode/ 11 1990. Municipal Code. www.ci.huntington-beachca.us/ElectedOfficials/CityClerk/MunicipalCode/ 12 1988. Warerfront Ocean Grand Resort Environmental Impact Report. Prepared by LSA Associates. 13 . 1983. Downtown Specific Plan Final Environmental Impact Report. 14 Federal Emergency Management Agency. 1997. Flood Insurance Rate Maps. Orange County, California. . http://map l.msc.fema.gov/idnis/Intra V iew.cgi?KEY=34534903&IFIT=1 15 Harding ESE. 2001. Revised Remediation Plan. June 15, 2001. 16 Harding Lawson Associates. 1996. Phase II Investigation Report/Remediation Plan. December 18, 1996. 17 1995. Environmental Site Assessment(Huntington Shores Motel). October 18, 1995. 18 Makallon Atlanta Huntington Beach, LLC. 2002a. Pacific City Master Plan. December 17,2002. 19 . 2002b. Pacific City Project Description. December 18, 2002. 20 Monte J. Meltebarger. 2002. Cover letter dated January 28, 2002, and package of will serve letters for dry utilities. January 28, 2002. 21 Orange, County of 2002. Airport Environs Land Use Plan for Joint Forces Training Base Los Alamitos. October 17, 2002. 22 Thomas Bros. Maps. 2001. Los Angeles and Orange Counties. 23 United States Department of Agriculture. 1974. Soil Survey of Orange County and the Western Part of Riverside County, California. Page 35 Reference # Document Title 24 Zeiser Kling Consultants, Inc. 2002. Preliminary Geotechnical Investigation. November 19, 2002. Page 36 1