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Stan Ych CEQA Project Manager/Consultant Los Angeles Unified School District Office of Environmental Health and Safety 355 S. Gr

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Stan Ych CEQA Project Manager/Consultant Los Angeles Unified School District Office of Environmental Health and Safety 355 S. Gr Carson Gore EIR 1 PXP September 28, 2005 Stan Ych CEQA Project Manager/Consultant Los Angeles Unified School District Office of Environmental Health and Safety 355 S. Grand Avenue, 15'° Floor Los Angeles, CA 90071 Fax: 213.633.7001 [email protected] Central R¢gion Elementary School No. 13 To Whom It May Concern: Refenmc.e is mad~;: to the Draft Environmental Impact Report (ElR), Central Region, Elementary School No. 13. Please be advised that Plains Exploration &.Production Company (PXP) deems D-1 the draft E!R to ]:le deficient, as the impacts to its existing oil and natural gas facility lo.cated .at 3304 West Washingto.n Boulevard, Lo.sAngeles, CA 90018 have no.tbeen adequately addressed. The.passage AREAS OF K,.'\!OWN CONTROVERSY contained in the Executive Summary of 1 the EIR does not address the existinglocl!tion ofthe 4 h Avenue Drillsite located directly across the street from the proposed school project site. Further, the concern raiso;:d during the public D-2 comment hearing (co.ntained in the dr11ft EIR) regarding the location ofa school between an oil drilling repository and a gas station was also not addresSed. In general, the draft EIR failed to address impacts of the proposed school on StJITOtiilding existinj facilities, a._nd further, did not adequately address the impacts on the proposed school by the D-3 surrounding facilities. Backgrou11d, Curre11t «f!il Fr,~ture ()perqtf011cS: 1 PXP operates the 4 h Avenue drill site .ofLas Cienegas Oil Field. PXP purchaso;:d the field from Betttley-Simonson, Inc. on April!, 20()5, and plans to increase production of the field via the reworking of existing wells, utilizing modern, state-of-the art re-drilling and re-completion techniques. D-4 The field has been producing oil and gas since 1960. The facility is pem1itted and equipped to accommodate 20 total wells. Potentiallmpacts to PXP~~ Curre1rt ftlld Future Operations: ~~ The lo.cation o.fthe pro.posed school would create significant and potentially unavoidable impacts D-5 to. PXP's existing and future operatio.ns. The distance of the pro.posed school lies within I 000 Plains Exploration & Pn>duction C<)mpany 5640 Sooth Fairthx Ave. a Lns Angdes. CA 90056 a .12.3-298-2200. s Fax 323~293-2941 Carson Gore EIR 2 feetofthe 4'h Avenue drillsite, triggering: AQMD Rule #1148.1, emissions from well cellars involving sensitivereceptors; Rule #212, notification of the public with regard to air cw1.taminates; Rule #1402, which could potentially require PXP to make extensive changes to its equipment in order to meet AQMD requirements for sensitive receptors. The impact of these 0 _5 n1ies woUld not only 11lake itdiffici.ili; and possibly predude us from making necessary modifications or upgrades to our facility, it would also make it difficult to operate a viable business. Coilclusion: While the need for additional educational facilities in California is essential, just as significant, it is essential for Calitornia to produce as much energy frotil as many sources possible; it is not in California's best interest to red11ce the potential production of existing oil and gas resources. California is a net importer of oil. D-6 PXP is not .opposed to the !()clition a new sch()ol in an a).'ea badly needing new facilities; rather, it is opposed to locating it within a zolle considered by the South Q:;ast AQMD to be pot!lmially hartnful to sensitive receptors, such as schools. Other alternative sites are noted in the EIR and PXI' believes one ofthose sites would represent the envirenmentallysuperior lllternativ~. Cleat'!y avoidance, rather than use of undefined and unidentified mitigation, is preterred in this instance. Ifaschoolwas in place and a proposed drilling and producing oil and l;?l!Sfacility was proposed within 1000 feet, would the proposed facility be approved? Conversely, ifthe drilling faci1ity is in place and a school was proposed within lOQO feet, shotild the,schoollocation be approved? Clearly the AQMD is considering new rules that may prohibit the fo)11ler -trom occurring; therefore, logically it would follow thatthe latter would. als() be prohibited. PXP is considered to be a good operator by the California DepartTilerttofConservation, Division 0 _7 of Oil, (~as, & Geothennal Resources (DOGGR). fu.fortrtation on maintenance efforts to .enhance le;~sesafety and en'Virorunental protection (in el(cess ofn:quiredlevels}canbe attested by the Oil and Gas District No. l office, District Engineer Mr. Floyd Leeson. The DOGGR website for information on oil and ..gasrules and reg11lations is consrV.CI!.gov/dog. Pleas.e contact the undersigned at [email protected]. or by telephone, at 323.2982449 if you should have any questi<ms or comments. Carson Gore EIR 3 From: Rusch, Steve [mailto: SRusch@olain~_£_~~} Sent: Thursday, September 29, 2005 8:57 AM To: McCauley, Carlos Cc: Salazar, Edgar; Salway, Candace; Huff, Del Subject: FW: Central Region Elementary School No. 13 Mr. Mccauley, I understand from Ms. Huff at Supervisor Burke's office, that you are the appropriate contact to forward our concerns about the proposed location of Elementary School No. 13. As we note in the attached comment letter (below), in light of concerns raised by entities such as South Coast Air Quality Management District (AQMD) about locating F-1 schools next to oil and gas facilities and vice versa (assuming those concerns are valid), we believe the proposed location directly across the street from our active oil and gas production and drilling site is less environmentally preferred (including health risks identified by AQMD) than the other two alternative locations evaluated in the EIR. Note that we did not hear about this proposal until just recently, so I apologize for what may seem like last minute comments. Unfortunately zoning and development laws don't require notification of mineral F-2 lessees, including operators like PXP, when development in adjacent and surrounding areas is contemplated. We only found out via another government agency that happened to give us a heads up. I b'elieve that it may be helpful for us to meet, as I'm sure there are] many considerations concerning this project that would be helpful to us F-3 to understand how it go.t to where it is now. I'm available to discuss at any time. Regards, Steve Rusch Vice !?resident, Environmental, Health & Safety and Governmental Affairs Plains Exploration & Production Company (PXP) 5640 S. Fairfax Ave. Los Angeles, CA 90056 (323) 298-2223 work (323) 697-2060 cell (323) 296-9375 fax [email protected] Carson Gore EIR 4 Chapter 8 Response to Comments Iii Response to Comment Reference F: Plains Exploration and Production Company Email Email Regarding: Central Region Elementary School No. 13 F-1 Comment noted. Prior to issuance of the IS/NOP, the LAUSD conducted a I-IRA for the proposed project. Based on the results of the I-IRA performed for the proposed project that were summarized in the IS/NOP (Appendix A of the Draft EIR), the drill site located across the street from the proposed project site was not determined to be an "Area of Known Controversy." Furthermore, the concern raised at the scoping meeting (held during the public review period for the IS) regarding the location of a school between an oil drilling repository and a gas station was also addressed by the I-IRA and summarized in the IS. However, the commentor' s preference for the location of the proposed school at one of the two alternative sites will be forwarded to the Board of Education for their consideration during the decision-making process. F-2 Notice was provided to PXP, listed as Torch Operating Company per the I-IRA, at 3304 Washington Boulevard. As this was the only available address for this business, two attempts were made to provide the document to PXP, however both mailings were returned. Copies of the returned letters with a US Postal Service return stamp are included immediately following responses to this letter. F-3 Public meetings and a public process was followed in compliance with CEQA and I-IRA requirements. Interviews were made with Torch Operating Company in February 2005 during the conduct of the I-IRA and information was provided by Torch Operating Company for the completion of the study. In addition, the following community meetings took place from 2003 to 2005: • August 2003 Presentation of Phase II Seat Need in the Los Angeles High School Complexes (Los Angeles High School) • September 2003 Presentation of Phase II Recommended Potential Project Definitions (Burbank Middle School) • October 2003 Presentation of Phase II Recommended Preferred Project Definitions (Burbank Middle School) • February 2004 Presentation of Phase II Site Selection Kickoff Meeting (Pio Pi co Span School) • July 2004 Site Selection Meeting #2 (Pio Pico Span School) • September 2004 Site Selection Meeting #3 (Pio Pico Span School) • September 2004 Preferred Site Meeting (Pio Pico Span School) • December 2004 Preliminary Design Meeting (Pio Pico Span School) • January 2005 Schematic Design Meeting (Pio Pico Span School) • April 2005 CEQA Scoping Meeting (Pio Pico Span School) • April 2005 Acquisition and Relocation Meeting (Thomas Senior Center) • July 2005 Acquisition and Relocation Meeting (Thomas Senior Center) • August 2005 CEQA Draft EIR Meeting (Pio Pico Span School) The LAUSD does not intend to meet individually with commentors outside of the public comment process. December 2005 8-20 Central Region Elementary School No. 13 DOGGR & FMOG 5 DOGGR & FMOG 6 7 DOGGR & FMOG 8 DOGGR & FMOG 9 DOGGR & FMOG 10 DOGGR & FMOG 11 DOGGR & FMOG 12 DOGGR & FMOG 13 DOGGR & FMOG 14 DOGGR & FMOG 15 DOGGR & FMOG 16 DOGGR & FMOG 17 DOGGR & FMOG LAFD Notice to FMOG 18 LAFD Notice to FMOG 19 LOCAL / LACALIFORNIA Times 20 Oil and gas firm reactivates long-idle wells near L.A.
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