CFROG Request for EIR on Reactivation of Oil Operations in Piru's Modelo Canyon

Citizens for Responsible Oil & Gas
PO Box 114 805-556-4001
Ojai CA 93024
Piru Oil Field – Modelo Canyon 3 Exploratory Oil Wells
Permit No.:  PL-13-0046
Parcel No:  0550060010
Date Filed:  4/03/13
Permit Type:  Conditional Use Permit
Status:  Environmental Doc Prep
Case Planner:  Jay Dobrowalski  RMA staff

CFROG Comments - March 2014

In reference to the Major Modification to CUP LU08-0100 for exploratory oil operations that involves the drilling of three oil wells at two existing sites to determine the viability of reactivating the Modelo Area of the Piru Oil Field.  CFROG disagrees with the findings primarily because the mitigated negative declaration (MND) fails to address cumulative and future development based on the exploration proposed by this CUP (conditional use permit).

If approved, this CUP is the first step in the  re-industrialization of an already degraded but ecologically sensitive area. Omitting the possible future development of oil in the Modelo Canyon area is irresponsible because there is no evaluation of the cumulative impacts should the entire field be reactivated.

1) Public confidence and health

Ventura County must have access to all information about this proposal so that the public can be sure an informed decision is being made. CFROG has been advised that ‘exploratory wells’ have a special status with DOGGR (Division of Oil Gas & Geothermal Resources) that includes a confidential/proprietary status that keeps vital information on chemicals that will be used and whether unconventional industrial equipment such as high capacity pumps will be there.

However, the Ventura County Planning Division can and should ask for copies of all paperwork submitted to DOGGR and the applicant's justification for exploratory status on existing pads. 

This is important because the new regulations approved last fall for SB 4 to bring transparency to oil operations includes a statewide environmental review to be completed by the end of this year that for the final version of the law.

While we have been told verbally by staff that they "believe" the drilling will be conventional, it is also possible and even likely that extreme extraction methods such as hydraulic fracturing or acidization could be used to boost production from a more that 100 year old abandoned oil field.

2) The San Cayetano earthquake fault is adjacent to the project location

The staff report says: " 10a.   There are no known active or potentially active faults extending through the proposed lot based on State of California Earthquake Fault Zones in accordance wlth the Alquist-Priolo Earthquake Fault Zoning Act, and Ventura County General Plan Hazards Appendix -Figure 2.2.3b.

In analyzing the risk , staff uses the Ventura County General Plan Hazards Appendix-Figure 2.2.3b  which does not even show the Piru area. (attached figure 2.2.3bpg).

The DOGGR record for one of the capped wells on the project contains a map (attached san cayetano.jpg) that shows the San Cayetano Fault running immediately to the south of the canyon and it is common knowledge that it is there.

According to the Bulletin of the Seismological Society of America the eastern Modelo lobe of the fault exhibits one of the fastest slip rates of any reverse fault in California ( 3-7 mm per year ) and may be capable of a very large earthquake, even greater than magnitude 7.2.

Where is the discussion of this hazard in the report?  Where is the proposed mitigation for well casing failure, collapsed new storage or production tanks, the risk of hazardous chemicals going into the stream bed, automatic shutoffs for the production fluids pipeline that would run between the two pads,etc. etc. 

Meanwhile, the appendix to the Ventura County general plan hazards report specifically says the county goal should be protecting and monitoring all building and construction for the likelihood of earthquake shaking or liquefaction including oil pipelines and oil production facilities and equipment.

This proposed declaration ignores that admonition.

This earthquake potential is so great in this location that it calls for on a full environmental impact report (EIR ) for the entire canyon, since the stated intent of this application is to reactivate the Modelo area of the Piru oil field.  Modelo Creek is a tributary to the Santa Clara River.

In the past, there were many wells in operation in this canyon. Production was low and by the 1990's all had been plugged, buried or idled. With conventional drilling and the potential for extreme extraction methods such as hydraulic fracturing and acidization, there could be an equal or greater number of wells in the future. Ventura County controls land use above ground, not DOGGR.

If not now, when will the cumulative effects be addressed?
3)  Biological impacts

People who have visited the area tell us the landscape was very degraded over the last one hundred plus years but since the old wells were abandoned, it is now recovering with trees, other vegetation and protected or endangered animals.  

The report correctly identifies real and significant damage as just the exploratory wells are drilled and infrastructure such as tanks, roads and pipelines are added. This will harm the walnut , elderberry and sycamore trees on the property and create potential adverse impact to other trees, smooth flatsedge, coastal whiptail and coast horned lizards, western pond turtles .patch nosed snakes and most significantly the California condor.  While the proposed mitigation steps show the steps that biologists hope will try to limit the impacts, once again there is no consideration as to the impacts ,should the oil field be fully restored or greatly expanded.  

The report also fails to establish a baseline for the noise from the exploratory wells or reactivation of the field and its ability to penetrate and impact the nearby condor sanctuary and wildlife refuge.

The impact on wildlife of increased truck traffic on a much wider road (from 12 to 20 feet) crossing the Modelo creek bed has not been addressed adequately.

4) Water and Waste

The report says no domestic water will be used. Where will they get water to conventionally drill or hydraulically fracture 3 exploratory wells and any future wells?

Will domestic water be used to fill the 20 thousand gallon tank installed to mitigate unsafe fire protection? 

The report mentions solid waste but does not address the transportation and disposal of liquid waste, including produced water. How much will be coming out from a reactivated Modelo field? Will the waste water be injected into the earth? There is an old injection well, Crocker Fee #10 that is currently plugged in that location.  A letter from the Getty Oil Company to the Regional Water Quality Control Board asking permission for the injection well states, "Injected waters will gravitate southerly to depths of 4000' subsea and be confined in the syncline above the San Cayetano Fault." When the fault ruptures again will that waste water migrate into the undergound basins along the Santa Clara river?

Why is the potential for earthquakes induced by injection wells not being discussed, analyzed or mitigated?

The report fails to analyze potential impact on wells, pipelines and storage tanks from flood waters on Modelo Creek and effects of spills in the project area on Piru Creek and the Santa Clara River.

5) Mandatory Findings of Significance

CFROG disagrees with the Mandatory Findings of Significance that claim no potential short-term and long-term environmental impacts. If the proposed oil exploration is successful then this CUP is the initial part of a possible much larger industrial project. The findings also declare that there are no  "cumulatively considerable’" effects when viewed in connection with past projects, other current projects and the effect of probable future projects. This statement misses the purpose of this CUP  which is an oil exploration project.

The crucial aspect of the CUP is ignored by narrowly addressing only the first phase of an oil operation that can impact both local air quality and climate change.

The long term environmental goals of Ventura County should be in conformance with the goals of the state which call for green house gas emissions to be reduced to 1990 levels by 2020. There is no evaluation of this project on those goals and indeed no estimate of total emissions .

The findings rely on the statement of the applicant that this project will be below the 25 pounds per day threshold for reactive organic compounds and oxides of nitrogen, but offers no independent assessment of that estimate or what the cumulative discharge might be at full reactivation.

6) Conclusion

CFROG urges the Ventura County Resource Management Agency to alter its Determination of Environmental Evaluation Document to find the proposed major modification to CUP LU08-0100, individually and or cumulatively may have a significant effect on the environment.

Therefore an environmental impact report (EIR) is required.

Citizens For Responsible Oil & Gas (Ventura County)
John Brooks, President
Helen Conly, Secretary
Rain Perry, Treasurer