7.0 OTHER CEQA CONCERNS
7.0
OTHER CEQA CONCERNS
7.1
SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGE
According to the California Environmental Quality Act (CEQA) Guidelines Section 15126.2(c),
“[u]ses of nonrenewable resources during the initial and continued phases of the project may be
irreversible since a large commitment of such resources makes removal or nonuse thereafter
unlikely.” Both primary and secondary impacts generally commit future generations to similar
uses. Also, irreversible damage can result from environmental accidents associated with a
proposed project. Irretrievable commitments of resources should be evaluated to assure that such
current consumption is justified. Therefore, the purpose of this analysis is to identify any
significant irreversible environmental effects of project implementation that cannot be avoided.
Primary impacts will result from the consumption of non-renewable resources during
construction and operation of the proposed project. Non-renewable petroleum resources, as well
as sand, gravel, steel, and renewable resources such as lumber will be consumed and irreversibly
committed during project construction and operations. These same resources are used for
vehicles and heating/cooling equipment during operations. The continued use of these resources
associated with project operations represents a long-term obligation.
Construction of the project would consume limited amounts of certain types of lumber; other raw
materials in steel, metals such as copper and lead; aggregate materials used in concrete and
asphalt such as sand and stone, water; petrochemical construction materials such as plastic,
petroleum-based construction materials, and other similar slowly renewable or nonrenewable
resources. Additionally, fossil fuels for construction vehicles and equipment would be consumed.
In terms of project operations, the following slowly renewable and nonrenewable resources
would be required: natural gas and electricity, petroleum-based fuels, fossil fuels, and water. The
consumption of such resources would represent a long-term commitment of those resources.
7.2
GROWTH INDUCEMENT
Section 15126.2(d) of the State CEQA Guidelines states that growth-inducing impacts of the
proposed Project must be discussed in the EIR. In general terms, a project may induce spatial,
economic, or population growth in a geographic area if it meets any one of the four criteria
identified below:
1. Removal of an impediment to growth, e.g., establishment of an essential public service or
the provisions of new access to an area;
2. Economic expansion or growth, e.g., changes in revenue base or employment expansion;
3. Establishment of a precedent-setting action, e.g., an innovation, a change in zoning, or
general plan amendment approval; or
4. Development or encroachment in an isolated area or one adjacent to open space (being
different from an “infill” type of project).
Should a project meet any one of the criteria listed above, it can be considered growth-inducing.
The impacts of the proposed Project are evaluated below with regard to these four growthERG Operating Company Foxen Petroleum Pipeline
13EIR-00000-00002 / SCH #2013061011
Proposed Final EIR
February 2015
7-1
7.0 OTHER CEQA CONCERNS
inducing criteria.
The proposed Project involves installation of a pipeline system which would allow for the
transportation of crude oil from the Cat Canyon area to the Santa Maria Refinery via pipeline.
There would be construction of new facilities and modifications to existing facilities at the
Cantin Lease and construction activities along the pipeline route from the Cantin Lease to the tiein location just north of Garey. The Project would allow for the transportation of crude oil by
pipeline instead of by truck.
The proposed Project would not result in the establishment of an essential public service, and it
would not provide new access to an area previously inaccessible.
Crude production in the Cat Canyon area is driven more by crude oil prices and market
conditions, as well s technological improvements in drilling and extraction technology, than by
the ability to transport the crude oil to markets. The proposed Project pipeline would not allow
for the transportation of crude oil to new markets or new refineries. It would only connect from
an existing facility (the Cantin and GWP Leases), where trucks are loaded, to an existing facility
(SMPS) where the same trucks are unloaded. It is possible that this might lower the
transportation costs of the crude oil somewhat, but that this would not be a deciding factor in
whether an oil field operator developes a resource or not. Therefore, the pipeline would not
remove an impediment to growth.
The Project would not result in increased employment in the area. No increase in personnel is
proposed as part of the Project. Economic growth associated with the specifics of the proposed
Project pipeline itself is not considered to be significant, although future increased crude
production levels may contribute substantially to an increase in the revenue base for the State of
California and the County of Santa Barbara via oil and gas royalties sharing. As noted above,
the installation of the pipeline and associated facilities, while potentially enhancing the market
situation for development of resources in the area by lowering transportation costs, would not be
a driver or a significant factor in the development of those resources.
The Project would not establish a precedent-setting action such as a change in zoning or an
innovation. Nor would the Project develop or encroach in an isolated area or one adjacent to
open space. The Cantin lease has been developed for oil production for a long period of time
and the proposed Project would utilize existing disturbed oil field spaces. Development of open
space is considered growth-inducing when it encroaches upon urban-rural interfaces or in
isolated localities. All surface project activities would be limited to the existing developed
facilities.
Accordingly, the proposed Project is not considered to be growth-inducing.
ERG Operating Company Foxen Petroleum Pipeline
13EIR-00000-00002 / SCH #2013061011
Proposed Final EIR
February 2015
7-2