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Resolution of support for the City of Culver City in their development and implementation of oil and gas regulations

On July 9, 2017, the West Los Angeles Group of the Sierra Club adopted the following resolution of support for the City of Culver City in their development and implementation of oil and gas regulations and associated Specific Plan land uses and conditions.

The Sierra Club recommends that the City of Culver City proceed immediately with the process of adopting an Oil and Gas Specific Plan, Regulations, and CEQA requirements and that the developments include the following:

Accessibility/Participation - The City shall immediately circulate current drafts of relevant documents and promote public comments on such throughout the period of the applicant's development of their related project(s) and shall circulate appropriate final environmentally and community preferred alternatives in a "Subsequent or Supplemental EIR".

Applicability - The City shall establish appropriate planning areas for the City and various oil and gas fields, areas, and pools - EAST: East of Ballona Creek, north and west of LACo-IOF, west of LaBrea, and south of Blair Hills; WEST: West of Culver Blvd. to City boundary; CENTRAL: West of Ballona Creek, east of Culver Blvd. , and south of National to City boundary; GEOLOGICALLY: Depth from Ground Surface to Conductor casing or 100ft depths whichever greater.

Permit Processing - The City shall require a temporary hold on all new constructed, reconstructed, drilled, redrilled physical facilities or physically modify from their 2015 as-built conditions without a construction permit until regulations are approved. Physical Facilities - The City shall require all new and redrilled wells be located on contained and enclosed production pads. All remaining facilities shall be provided with impervious secondary containment. All well heads shall individually or in groups of 1-10 wells be contained for gaseous emissions and releases which shall be treated to SCAQMD emissions levels (e.g., <10 ppm TPH, 1 cu ft/sec) before venting. All well heads shall individually or in groups of 1-10 wells be enclosed by primary barrier and a secondary impervious barrier with sufficient short-term detention equal to 2 days of fluid production.

Buffer zone: We are deeply concerned about the health impacts of oil and gas production on Culver City residents. We have read studies coming out of Pennsylvania and around the country about the grave risks these operations pose. These studies show that distance matters and we believe a buffer between these sites and sensitive receptors is appropriate for our city. We applaud the city in taking the step of developing a specific plan, and urge the city to forward with enacting such a specific plan that includes a buffer.

Mineral Resources - As an element of both CEQA assessment and the project description, the applicant(s) may continue development and improvements of subsurface resources and integrate such with surface requirements and fully describe such in CEQA documents. Abandonment/Plugging shall be upgraded by using 100 percent (%) sulfur-resistant foundation grade concrete in all annuli and open spaces from the depth of the bottom of the Conductor Casing or 100ft zone whichever greater.

Operations - Ongoing and shorter-term periodic operations and maintenance - Within one year of implementation, all oil and gas production and injection operations shall be fully documented, and related existing facilities shall be fully verified as built for relevant current State and regional permits and approvals.

Spill/Release Prevention/Control/Recovery Plans shall be included within the Mitigation Monitoring and Reporting Plan which will be included in the Draft EIR or other CEQA and shall assure that surface risks and events are identified, mitigated, and contained within the immediate vicinity or cellars and pad-perimeter.

Emergency Response Plans shall be included within the Mitigation Monitoring and Reporting Plan and shall assure that surface risks are identified, mitigated, and containment of events within the immediate vicinity or cellars and pad-perimeter.

Geological Surface Context - Based on current geological information, the applicant shall delineate all known subsurface fractures (e.g., displacements of >5 feet) and shall project all such fractures laterally and vertically to the current ground surface and show such on an oil field map. The CEQA documents shall display surface traces and current/prospective facilities and locate new facilities based on a thorough review and avoidance of facilities being located on expected/confirmed fractures. The operator shall install suitable equipment until regulations are approved to measure and record microseismicity (+1 to -2 RM) within one mile of CC-IOF.


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