CFROG Appeals New Wells in Santa Paula Canyon

March 2015

Ventura County Planning says 5 of the 19 new wells on the historic Ferndale Ranch and Chumash Village of Sisa will be on Drill pad 7. The two wells already at that location are in violation of the County ordinance for setback from a stream that floods periodically and the oil company never even completed its original promise to screen the wells from the estimated hundred thousand people who hike Santa Paula Canyon each year.

The oil company (California Resource Corporation) wants a 30 year permit. We say 5 years should be the maximum as conditions change. The proposed new wells are also very close to the students and faculty of Thomas Aquinas College as well and the county has rejected a more robust environmental review which takes into account air pollution and global warming.

This is a major gateway to the Los Padres National Forest and the first of 17 oil wells in the area was drilled in 1971.

The only Environmental Review of the area took place in 1985 and was focused on tanker  truck access to and from the drilling sites, and did not even look at impacts on southern Steelhead fish, the endangered California condor or the risk of flooding and water pollution. Under CEQA ,the California Environmental Quality Act, the County is required to update this environmental study to incorporate new information and circumstances that have emerged over the last three decades.

The proposal also fails to evaluate archeological resources even though the location is part of the original Chumash village of Sisa, the largest of the inland villages and considered to be of the “highest significance” in understanding the Chumash legacy.

Los Padres ForestWatch is also appealing the granting of this permit and will join with CFROG when a date is set for the Ventura County Planning Commission to hear the appeals.

Here are the grounds for our appeal. Please note that the proposed waste disposal well for this project is currently under investigation by the EPA.     
Grounds for appeal  of CUP :PL13-0150  CFROG

1. Two wells in the application are on the EPA list of wells being investigated for possible fresh water aquifer intrusion. The lead agency must do an analysis of the fresh water basins involved in this project and ensure the public that our water sources are indeed protected.

2. There is no commercial waste water well in the Hamp area of the Silverthread oilfield. Therefore waste water from CUP PL13-0150 cannot be transported to that location.. See Staff letter to Board of Supervisors, Jan. 27th, 2015  for clarification of private waste water well vs. commercial waste water wells. A commercial waste water well such as Hamp 72 also requires special approval from DOGGR.

3. The inability to transfer waste water off site by pipeline would greatly increase tanker truck traffic which has not been analyzed.

4. Drill pad #7 is in violation of the Non Coastal Zoning Ordinance as it is too close to a red line stream.. No further wells can be legally placed on that drill pad. See Resources Policy 1.4.2-4

5. The authorization for drilling 19 new wells is expired and there have been numerous extensions of time. Since Vintage Oil Company (Now CRC ) did not renew its permit to drill 19 new wells after three extensions of time, and now finally the entire CUP is expired, the CEQA process should begin anew with a new EIR. . Vintage has shown a lack of interest in the project and its furtherance and filed for a modification two years after the 1985 CUP had expired.

6. There is no mention of endangered species on the subject site in the MND of 1983 or 1978 and the lead agency has not provided substantial evidence that it has addressed the presence of several endangered and threatened species in a meaningful way. Especially the California Condor.

7. The cumulative effects of oil and gas wells in Upper Ojai Valley has not been studied in this century.  There is substantial evidence of changed conditions.  For instance, we are in a record breaking drought and the state of California is in a water emergency.  No further use of fresh water in quantities necessary to drill oil and gas wells should be permitted until the drought is declared over. The lead agency has provided no evidence of a review of the current status of water wells in the Upper Ojai area. Wells are going dry and  evidence in the record indicates that Thomas Aquinas College depends on the water in Santa Paula Creek and its springs for all water except that for drinking.

8.Greenhouse gas emission analysis done by staff is inadequate to meet the requirements of the law.

9. The well drilling project has never been authorized for more than a few years.The authorization time of this Addendum is overly broad particularly when the effects of Global Warming are intensifying. Simply issuing an extension of time for completion of the drilling phase of the project is not in keeping with any prior time limits for the CUP.

10. The site is part of the original Chumash village of Sisa, the largest of the inland village sites and considered by archaeologists to be of the “highest significance” . The road between Drill site #1 and Drill site #2 is going to be regraded.  The archaeological report in the FEIR found that the corridor between drill site one and two is likely to have a high incidence of cultural resources.Not only does this realignment of the road affect the high quality cultural resources that are found here, it could affect and further disturb burial grounds.