October 26, 2021
Sent via Electronic Mail
RE: World Oil Tank Installation Project
C oastal Commission Staff Comments on Final IS/ND
Port of Long Beach Commissioners and Staff,
Thank you for the invitation to comment on the Final Initial Study and Negative Declaration (IS/ND), including the Application Summary Report, for the World Oil Tank Installation Project (Project). The project site is located within the Port of Long Beach’s permit jurisdiction area where new development, such as the subject project, must conform with the Chapter 8 policies of the Coastal Act and those of the certified Port Master Plan (PMP) in order to receive a Harbor Development Permit (HDP). The following comments address the Coastal Act and PMP Consistency Analyses included in the IS/ND that begin on page 5-1 of the document.
Section 30708(a) requires new development to be located, designed, and constructed to minimize substantial adverse environmental impacts. If damaged or not appropriately designed to withstand natural coastal hazards, the proposed development could create hazardous conditions that could adversely affect water quality, marine habitats and wildlife, and human health. The IS/ND concludes that the project would result in less than significant impacts on the environment.
However, while the initial study analyzed the project in terms of a 100-year storm event and tsunami threat, it did not take climate change into consideration. The proposed location of the two new petroleum storage tanks is seaward of the existing fuel tanks in a low-lying part of the port that would be flooded with as little as 2.5 feet of sea level rise and where groundwater may begin to emerge under the same scenario. Best available science suggests that sea levels could have risen approximately 2.5 feet as early as 30 years from now. The IS/ND finds that the project is designed for a 100-year storm event under existing conditions without a flood control system, but not under conditions that account for sea level rise and longer-term inundation. There is no evidence provided in the IS/ND that suggests the project is located and designed in a way that will avoid adverse impacts on the environment and port-adjacent communities under conditions where sea and groundwater levels are higher and storm events are more frequent and severe.
A component of the certified Port Master Plan that is not included in the PMP Consistency Analysis, the certified Risk Management Plan (RMP; 1981), also includes policies for siting new development that involves hazardous materials, including liquid bulk facilities like the subject petroleum storage facility. For example, the certified PMP prohibits the Port from permitting new hazardous liquid bulk cargo development that would create a hazard footprint overlying existing vulnerable resources and prohibits expansion of existing hazardous liquid bulk cargo facilities that would increase the risk of casualty within the hazard footprint. The standard of review for the HDP that would need to be processed for this project, is Chapter 8 of the Coastal Act and the certified PMP, which includes the RMP, Implementation Guidelines, and the PMP document with all past amendments.
Another environmental impact that could be further reduced is the project’s proposed increase in intensity of use of the site and, thus, increase in greenhouse gas emissions. The IS/ND states that the project would result in three additional truck trips per day. The emissions from the proposed intensified use of the site disproportionately affects communities that disproportionately bear the APPX_000568
World Oil Tank Installation Project (SCH # 2020100119)
Coastal Commission Staff Comments on Notice of Intent to Adopt Final IS/ND
burdens of environmental pollution caused by the Port’s operations. When processing the HDP for the proposed development, to avoid or minimize adverse impacts, the Port should consider, for example, not allowing the expansion of the intensity of use or imposing a condition on the project to require trucks accessing the site to be zero-emission vehicles.
When processing the HDP application for this project, the Port must analyze the proposed project’s consistency with the Coastal Act and the entire certified PMP. This analysis should include full consideration of the potential impacts described above. In addition, for the Port to adequately evaluate whether a proposed project minimizes adverse impacts to coastal resources, the Port must consider project alternatives including a no project alternative.
Please note that the comments provided herein are preliminary in nature. More specific comments may be appropriate as the project develops. Coastal Commission staff requests notification of any future activity associated with this project or related projects. Thank you for the opportunity to comment on the Final IS/ND. Please feel free to contact me at [email protected] with any questions.
Sincerely,
Dani Ziff
Coastal Program Analyst
cc: Matt Arms, Director of Environmental Planning (EP)
James Vernon, Asst. Director to EP
Tony Chan, Master Planning
Allyson Teramoto, Manager CEQA/NEPA Practices
Jennifer Blanchard, Project Manager
APPX_000569