Sample Comment #1: No New Wells

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• Drilling 30 new wells in 15 years is the opposite of the direction Culver City should be heading in. We should be a leader in moving away from fossil fuels, not continuing to invest in them.

• The SB32, SEC. 2. Section 38566 states: "In adopting rules and regulations to achieve the maximum technologically feasible and cost-effective greenhouse gas emissions reductions authorized by this division, the state board shall ensure that statewide greenhouse gas emissions are reduced to at least 40 percent below the statewide greenhouse gas emissions limit no later than December 31, 2030."

• This is a state-wide mandate that was implemented January 1st 2017. 

• If we are allowing the drilling 30 new wells in 15 years, we are showing the rest of the state that we are not aligned with the greater direction of moving away from fossil fuels.

• Although the mitigation measures outline steps to reduce GHG emissions from the actual drilling process, it fails to recognize the fact that all of the barrels of oil produced by these wells will be combusted and will contribute to GHG emissions and climate change. 

• I am asking the city to put a permanent moratorium on the drilling of all new wells. 

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Sample Comment #2: 2,500 ft. Setback

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• Page 3-7 of the Specific Plan states: "Allowed Drilling Area: Any area that is setback at least 400 feet from the edge of the Developed Area, and setback at least 75 feet from the edge of a public road." 

• However, there is evidence that this is too small of a setback to ensure the health and safety of the sensitive receptors. Based on the Air Quality Management District’s Rule 1148.2 staff report, wells within 1,500 feet of sensitive population centers like homes, schools, and daycare centers present a health risk and may release detectable odors.

• In 2013, Dallas passed an ordinance banning drilling within 1,500 feet of homes.

• Scientists believe most air pollutants dissipate within about half a mile, or 2640 feet, from a drilling site.

• In 2014, The University of Maryland School of Public Health performed an in-depth analysis and prepared a report for the Maryland Department of the Environment and the Department of Health & Mental Hygiene. The authors recommended a minimum setback distance of 2,000 ft from well pads.

• Knowing this, why would Culver City allow its residents to live, go to school and work within the danger zone?

• I am asking the city to demand a 2,500 ft setback between drilling and sensitive receptors.

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Sample Comment #3: 2,500 ft. Setback

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• The new LADPH study on Public Health and Safety Risks of Oil and Gas Facilities in Los Angeles County concludes that at odors resulting from oil and gas activities are still present at 1,500 ft. (p.27).

• It also says that Maryland has a 2,000 ft setback and Dallas has a 1,500 ft setback. (p. 27).

• It reveals that "...expert scientists, public health professionals and medical professionals regarding setback distances, and found that 89% of participants agreed that a minimum safe distance to unconventional oil and gas operations was a quarter of a mile (1,320 feet)." (p. 28).

• Because the above, I am urging the city to implement a 2,500 ft setback between all drilling and sensitive receptors as one of the mitigation measures of the specific plan. Culver City residents deserve for their administration to protect them against odors, noise and air pollution resulting from the oil field. We are in the position to implement the most progressive setback in the country, so let's do it!

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Sample Comment #4: 2,500 ft. Setback

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• The recent LA Department of Public Health Oil and Gas study links oil and gas activity to increased cancer risk:

  • "Oil and gas activities may expose individuals to airborne emissions of VOCs, such as benzene. Studies have shown that exposure to elevated levels of benzene over many years may increase the risk of developing cancer, particularly acute myelogenous leukemia."

  • "The Colorado Department of Public Health and Environment recently conducted a comprehensive health risk assessment using statewide air emissions data...the combined exposure to four cancer-causing substances (benzene, ethylbenzene, formaldehyde and acetaldehyde) reached the EPA risk management level of 1 excess cancer per 10,000 people exposed and exceeded the California EPA Proposition 65 risk threshold of 1 excess cancer per 100,000. The study did not calculate health risks at distances of less than 500 feet because Colorado requires a 500-foot minimum buffer distance between oil and gas activities and buildings. These findings suggest that mitigation controls may be needed in addition to the existing setback distance in order to reduce the potential health risks from air emissions from local oil and gas operations."

• This study clearly states that even at 500+ foot setbacks, the combined exposure to four cancer-causing substances reached the EPA risk management level of 1 excess cancer per 10,000 people exposed and exceeded the California EPA Proposition 65 risk threshold of 1 excess cancer per 100,000.

• This risk is present at at over 500 feet, while the Specific Plan is proposing a 400 foot setback between schools, homes and other sensitive receptors.

• Please implement a setback of at least 2,500 feet to mitigate increased cancer risk in Culver City!

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Sample Comment #5: $2.5B Surety Bond

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• Please ensure that the IOF Operators purchase a Surety Bond of $2.5 billion which would cover all Culver City Stakeholders from losses due to potential seismic, medical, and other risks associated to Oil and Gas operations.  

• The surety bond must be from a AAA credit rated Bank or Insurer and must be for probably cause—Inglewood Oil Field Operators and Owners must accept responsibility to prove that they are not t fault for any death, illness, or damages related to their operations.  

• The Surety Bond should cover a minimum of 4 billion U.S. dollars as we should plan for the possibility of a disaster at the scale of Deepwater Horizon or the Northridge Earthquake.  

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Sample Comment #6: Environmental Justice

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• I am urging the city to include a supplemental environmental justice analysis document in the final EIR and to do what is necessary to protect public safety and ensure racial equity. 

• It is undeniable that Blair Hills, the community in which residences are closest to active oil wells, has a significantly higher Black population than the rest of Culver City, whose overall demographic is only about 8% Black.

• The California Environmental Protection Agency is required by statute to “promote enforcement of all health and environmental statutes within its jurisdiction in a manner that ensures the fair treatment of all races, cultures, and income levels” (Pub. Resources Code, section 71110).

• How can Culver City ensure fairness if they don't include an environmental justice analysis in the IOF EIR?