World Oil Tank
Installation Project
Appeal from:
Earthjustice | Center for Biological Diversity | Communities for a Better Environment East Yard Communities for Environmental Justice | Coalition for Clean Air Center for Community Action and Environmental Justice | Sierra Club EIR Requirement: A “Low Threshold”
“All local agencies shall prepare…
an environmental impact report on
any project… which may have a
significant effect on the
environment.”
- CEQA Statute (Cal. Pub. Res. Code § 21151)
World Oil Project Impacts
• Project tanks have 50-year lifespan
• 200,000 pounds of VOC air pollutants
• 15,000 barrels of hazardous tank sludge
What this Project is about: Marine Fuel Oil
• World Oil’s refinery produces marine diesel fuel
• Project frees up to 188,000 barrels of oil storage
for lease to oil refineries
What this Project is about: Marine Fuel Oil
Left image (Bunker oil sample): https://upload.wikimedia.org/wikipedia/commons/thumb/6/6a/Residual_fuel_oil.JPG/1200px -Residual_fuel_oil.JPG Right image (Large ship smokestack): https://commons.wikimedia.org/wiki/File:Port-Saint-Louis-du-Rh%C3%B4ne_Navire_entrant_dans_le_port.jpg Nearby Vulnerable
Populations:
Elementary
Schools & Parks
What CEQA Requires
“If there is disagreement among expert
opinion supported by facts over the
significance of an effect on the
environment, the Lead Agency shall treat
the effect as significant and shall prepare
an EIR.”
- Official CEQA Guidelines (14 CCR § 15064(g))
Experts disputing the Port’s analysis:
• Dani Ziff, M.M.A., Coastal Program Analyst at California Coastal Commission:
“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.”
Experts disputing the Port’s analysis:
•Julia May, Senior Scientist at Communities
for a Better Environment:
“The Project has clear potential to cause
significantly increased hazards, air and water
pollution, and cumulative impacts.”
Experts disputing the Port’s analysis:
•Phyllis Fox, Ph.D. (Environmental/Civil
Engineering):
“In my opinion, the IS/ND has failed to identify
and mitigate significant environmental
impacts.”
Flooding Risks
October 2021
Oil Spill
Image: Ringo H.W. Chiu, Associate Press.
Cumulative Impacts
• Port must consider “closely related past, present, and reasonably foreseeable probable future projects.”
• “Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time.”
- Official CEQA Guidelines (14 CCR § 15355(b))
Port Ignored Existing Infrastructure
• Total capacity with Project:
552,000 barrels (nine
tanks)
• Port only analyzed:
50,000 barrels (two tanks)
Cumulative Impacts: Community Burden
Cumulative Impacts: Oil Storage Tanks
Cumulative Impacts: Oil Storage Tanks
SCAQMD Studies: Underestimated Emissions
Image: SCAQMD Working Group for Rule 1178 Amendment, Presentation on Dec. 3, 2021, Slide 17. http://www.aqmd.gov/docs/default -source/rule-book/Proposed-Rules/1178/par1178-wgm3-final.pdf?sfvrsn=6.
Conclusion
The Port must
prepare an EIR for
the World Oil Project
under CEQA.