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HomeMy WebLinkAboutCC AG PKT 2002-07-08 #IAGENDA REPORT DATE: July 8, 2002 TO: Honorable Mayor and City Council THRU: John B. Bahoold, City Manager FROM: Lee Whittenberg, Director of Development Services SUBJECT: APPROVAL OF COMMENT LETTER - BELLFLOWER OIL DRILL SITE DRAFT EIR (HAYNES GENERATING STATION) SUMMARY OF REOUEST: Instruct Mayor to sign Comment Letter, with any amendments determined appropriate. Forward approved comment letter to the Planning Commission, Environmental Quality Control Board and the Golden Rain Foundation for information purposes. Receive and File Staff Report. BACKGROUND: The City has received a copy of the "Bellflower Oil Drill Site Draft Environmental Impact Report", which is in the public comment stage of review. The comment period on the Draft EIR ()EIR) will close aV5:00 PM on July 15, 2002. Summary of Proposed Action and Environmental Impacts: Staff has previously provided a complete copy of the DEIR for the information of the City Council in reviewing the proposed project and draft comment letter. Project Summary: The Bellflower oil drilling project entails crude oil and gas exploratory drilling and possible well production on a disturbed, approximately 86,400 square foot easement within the Los Angeles Department of Water and Power C DWP') Haynes Steam Power Plant property. The applicant anticipates success in exploration and plans to produce up to twenty wells for a producing life of twenty years. Project activity will occur in two main phases: the exploratory drilling phase and the production phase. Agenda Item — C:Wy Docunxnn\CEQA \Bellflower Oil Drill Hite, Haynes Plant, Long B®ch, DEIR.CC. oc LWW6 -28 -02 Approval of Comment Letter re: "Draft Environmental Impact Report — Bely7merOil Drill Site "(SCH 2001101132) DEIR prepared by City of Long Beach City Council Staff Report July 8, 2001 The project will begin with a six-month exploratory drilling phase to determine the extent, if any, of crude oil and gas availability. This phase will involve the drilling of an oil well using a 160 -foot high electric drill rig. The rig will drill from the surface drill site to a bottom hole location approximately 5,000 feet to the northwest of the drill site. The bottom hole location will be approximately 11,000 feet below the surface into the anticipated center of the crude oil and gas reservoir target area. If this initial well is commercially successful, additional wells will be directionally drilled from the Same surface drill site to define the extent of the reservoir. It is anticipated that approximately 20 wells could be drilled on the site. If the initial well is not commercially Successful, this well will be plugged in accordance with California Division of Oil, Gas and Geothermal regulations and the project could be tenninated. All vehicle access will be from Westminster Avenue. The trucking of parts and assembly of the drill rig and associated equipment will take up to two weeks. The drilling operation of the initial well will take up to 60 days. The drill rig and associated equipment will occupy an area of about I -acre of the 1.98 -acre drill site. Blowout equipment will be installed, operated, and inspected in accordance with California Division of Oil, Gas and Geothermal regulations. Two non - hazardous waste streams will be generated during the drilling of the wells: drilling mud and drill cuttings. Drilling muds are used to keep the bore hole open during drilling, to cool down the drill bit, and to transport drill cuttings to the surface. Drill cuttings are the geologic materials removed from the bore hole during the drilling process. At the end of the drilling operation, both drilling muds and drill cuttings will be transported to an approved Class II disposal facility. The drilling rig will then be disassembled and removed from the site. A completion rig will then be mobilized to perforate the prospective crude oil zone in order to test the well. Completion and testing activity will take approximately four weeks per well. The completion rig is a diesel- powered vehicle, which can drive to the site. The completion rig has a mast height of 120 feet and is similar to the well work over rigs that routinely work in the Seal Beach oilfield. Initially, the well is expected to be a flowing well. As pressure declines in the reservoir, it will be necessary to install a pumping unit at each well to bring fluids to the surface. A pumping unit is the familiar "grasshopper appearing" unit commonly seen in oilfields, and is about 20 feet high. If several wells are completed, these pumping units will be spaced closely together within the confines of the drill site. Crude oil and gas production will be transported to an offsite location for processing and use in one of three ways: • By way of a truck to an offsite location for processing and use, for oil and gas • By way of an existing DWP pipeline located near the proposed drillsite, for oil. This DWP pipeline heads east and ties into an existing pipeline at the SCE power plant Bellflower Oil Dnll Site, Haynes Plant, Long Beach, DEIa CC 2 Approval of Comment Letter re.: "Dra/lEnvironmentallmpactReport- Bellflower Oil Drill Site" (SCH 2001101132) DEIR prepared by City of Lang Beach City Council Stal/'Repon July 8, 2002 site, which then heads south to tie into an existing pipeline along the north side of Westminster Boulevard; ❑ By way of new construction of both oil and gas pipelines from the proposed drillsite to tie into existing pipelines along Westminster Boulevard and Studebaker Road, respectively. If the new construction pipeline option is pursued for transport of product, subsequent environmental review by the City of Long Beach may be required to assess the impacts of this option. Principal Discretionary Actions and Approvals Required: The City of Long Beach has identified the following discretionary actions by the City of Long Beach: ❑ Certification of an Environmental Impact Report; E3 Declaration of an area for an Oil District; L3 Issuance of a Drilling Permit; u Coastal Development Permit Other agencies with discretionary and/or permit authority over some aspect of the project are identified as: ❑ California Division of Oil, Gas and Geothermal Resources (CDOGGR) ❑ Los Angeles Department of Public Works (LADPW) ❑ Los Angeles Regional Water Quality Control Board (LARWQCB) ❑ South Coast Air Quality Management District (SCAQMD). Summary of Alternatives: Section 8 of the Draft EIR includes an evaluation of the following alternatives to the proposed project: ❑ Alternatives Rejected From Further Consideration; a No Project; ❑ Edison Site; ❑ Original Bellflower Site. The Edison Site is considered potentially an environmentally superior alternative to the proposed project site. DEIR Comment Period: Be11Mwa Oil Dn115iu, Haynes Plant, Long Beach, DEIRCC 3 Approval of Comment Letter re: 'Draft Environmental Impact Report — BeltRowerOil Drill Site "(SCH2O01101132) DEIR prepared by City of Long Beach City Council Staff Report July 8, 2002 The comment period on the DEIR will conclude at 5:00 PM on July 15, 2002. Written comments may be submitted to the City of Long Beach as noted below: Mr. Gerhardt Felgemaker Environmental Planning Officer Department of Planning and Building 333 West Ocean Boulevard, 5th Floor Long Beach, CA 90802 Public Availabilitit of DEIR. A copy of the DEIR is available at the Department of Development Services for review. In addition, the DEIR is available at each library within the City. Recommended City Action: The EQCB considered a Staff Report regarding the proposed comment letter on June 26, 2002, and instructed staff to forward the comment letter, with revisions, to the City Council for final review and approval. Recommended revisions by the EQCB are noted by double - underline, bold and italics for text to be added and by deubia sWiadl ugH for text to be deleted (Refer to Attachment 1). The comment letter focuses on the identified impacts to Leisure World during the exploratory and production phases of the proposed project, potential alternative sites, project modifications to reduce impacts upon Leisure World, and technical corrections to the document. FISCAL IMPACT: No direct impacts. If increased environmental degradation upon the City is experienced as a result of the proposed project, the costs of appropriate mitigation measures should be the responsibility of the project proponent. To the extent that those impact mitigation costs are not completely the responsibility of the project sponsor, the City of Seal Beach may ultimately have to incur significant expenses to adequately mitigate unfunded environmental mitigation programs. OCINIA lu 131011Z110 MOF Instruct Mayor to sign Comment Letter, with any amendments determined appropriate. Forward approved comment letter to the Planning Commission, Environmental Quality Control Board and the Golden Rain Foundation for information purposes. Receive and File Staff Report. Bellflower at MI Site, Haynes Plant, Long Beach, DEIR.CC 4 Approval of Comment Letter re: 'Draft Environmental Impact Report — Belfower Oil Drill Site "(SCH 2001101132) DEIR prepared by City of Long Beach City Council Staff Report July 8, 2001 NOTED AND e Whittenberg John B. orski for of Development Servi City wger Attachments: (2) Attachment 1: Proposed Comment Letter re: "Draft Environmental Impact Report for the Belylower Oil Drill Site ", prepared by the City of Long Beach, dated May 2002 (indicating revisions recommended by EQCB on June 26, 2002) Attachment 2: 'Draft Environmental Impact Report for the Bely7ower Oil Drill Site', prepared by the City of Long Beach, dated May 2002 Note: Previously provided to the City Council, not provided with this Staff Report. A copy of the complete document, including the technical appendices will be available at the City Council meeting Bellflower Oil Drill Site, Ha,M Plant, Lung Beach, DEIR.CC 5 Approval of Comment Letter re: 'Draf7 Environmental Impact Report — Bellflower Oil Drill Site" (SCH 2001101131) DEIR prepared by City of Long Beach City Council&uf' Rep on July 8, 2002 ATTACHMENT 1 PROPOSED COMMENT LETTER RE: "DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE BELLFLOWER OIL DRILL SITE ", PREPARED BY THE CITY OF LONG BEACH, DATED MAY 2002 (INDICATING REVISIONS RECOMMENDED BY EQCB ON JUNE 26, 2002) Bdltl., Oil Drill Site, lf,.s Plana Inng Bach, DEIR.CC 6 July 8, 2002 Mr. Gerhardt Felgemaker Environmental Planning Officer Department of Planning and Building 333 West Ocean Boulevard, 5th Floor Long Beach, CA 90802. SUBJECT: CITY OF SEAL BEACH COMMENTS RE: "DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE BELLFLOWER OIL DRILL SITE " (SCH 2001101132) Dear Mr. Felgemaker. The City of Seal Beach has reviewed the above referenced Draft Environmental Impact Report (DEIR) prepared by the City of Long Beach and has several comments relative to the document The proposed project is close enough to the City of Seal Beach as to cause concern regarding environmental impacts upon our community, in particular the Leisure World retirement community located east of the subject property, on the easterly side of the Los Alamitos Flood Control Channel. In addition to the comments set forth within the body of the letter, several comments related to technical issues and necessary corrections are provided in "Exhibit A — Staff Technical and Correction Comments ". All comments contained within the body of the letter and Exhibits A and B should be responded to in the forthcoming "Response to Comments" to be prepared as part of the Final EIR for this project. City of Seat Beach Preference forAlternative Sites: Upon review of the DEIR document, it is the preference of the City of Seal Beach that one of two sites discussed below be re- considered as the primary project Site. The request to consider alternative sites is directly related to reducing identified environmental impacts to the Leisure World community, during both exploratory and production phases of the project. The fast preferred site is the "Edison Site ", identified and discussed within the Alternatives section of the DEIR document as "potentially an environmentally superior alternative to the proposed project site ". The second alternative site is a City of Seal Beach suggested site not evaluated within the DEIR document, located on the westerly side of the subject property. C:Wy 11mmeme\CEQANBellnower Oil Drill Sim DEIR.City Comment 6nend.c W)7 -08-02 City of Seal Beach Comment Letter re: Draft EIR — Bellflower Oil Drill Site (SCH 2001101132) July 8, 2002 Alternative Project Locations Discussed in DEIR: The DEIR provides discussion regarding "Alternatives to the Proposed Project" in Section 8, including discussion of several other sites, including the "Edison Site ", located at the northeast comer of Westminster Avenue and Studebaker Road on the AES Alamitos power plant property. ❑ "Edison Site ": This site is determined to be "potentially an environmentally superior alternative to the proposed project site" (DEIR, page 8 -9). This detemvnation is reached primarily due to the reduced noise and aesthetic/view impacts upon the Leisure World population in Seal Beach. Several concerns are discussed regarding the Edison Site, including ❑ increased potential hazards from an earthquake event, and resultant hazardous releases, as the site is nearer the Newport- Inglewood Fault Zone: ❑ lack of easement rights for the proposed drilling project, and ❑ the site not being located within an existing oil boundary. It is the position of the City of Seal Beach that this alternative has not been adequately evaluated, and requests the project proponent to initiate discussions with the property owner of the AES Alamitos facility as to the ability to obtain the necessary easement and land lease rights. In addition, this alternative should further evaluate the potential ability to amend the "Oil Boundary" with the City of Long Beach to allow this site to be utilized for the proposed project. The City of Seal Beach strongly requests this alternative site be seriously considered until it is determined that the site is not available to the project proponent and it is not possible to incorporate this alternative site into an Oil Boundary area. To not fully investigate this site does a disservice to the residents of Leisure World by not fully and completely exploring a potential "environmentally superior" viable site that results in the elimination of identified impacts to the Leisure World community. Alternative Proiect Location on DWP Haynes Power Plant Property as Discussed in DEIR: A review of Exhibit 3, `Site Location Map ", indicates what appears to be an undemtilized area west of the main power plant stacks and east of the San Gabriel River. It is requested that analysis of this area be provided as an alternative site location. This area would remove the oil drilling operations to another location on the subject property that would eliminate the noise and aesthetic impacts to Leisure World. This location would not result in the increased potential hazards from an earthquake event, and resultant hazardous releases, as the site is further from the Newport- Inglewood Fault Zone than the "Edison Site" alternative. There may be issues regarding lease and easement issues and oil boundary issues, but those may less cumbersome to overcome since the oil drilling site would still be located on the Haynes property. The City has indicated this suggested alternate project location on a copy of Exhibit 3 -3, Site Location Map, which is attached as Exhibit B of this comment letter. Bello r Oil Drill Site DEIR-City Comment Letter 2 City of Seal Beach Comment Letter re: Draft EIR — Bel�Oower Oil Drill Site (SCH 2001101132) July 8, 2002 Again, the City of Seal Beach strongly requests this alternative site be seriously considered until it is determined that the site is not available to the project proponent and it is not possible to incorporate this alternative site into an Oil Boundary area. To not fully investigate this site does a disservice to the residents of Leisure World by not fully and completely exploring a potential "environmentally superior" viable site within the proposed project property boundaries. Compliance of Proiect Alternative Locations with Provisions of "Oil Code ": In the discussion on page 5.1 -11, Community Character and Land Use Compatibility, it is indicated that "Implementation of the project will require creation of an oil operating area and acquisition of a drilling permit." This section goes on to state "In adopting an oil boundary change or creating a new oil operating area, the Planning Commission and City Council must make certain findings regarding the necessity of the project, impact on production of existing petroleum reserves, and impact on the surrounding community. With regard to land use, a finding would be required that: "The change, creation or deletion will not adversely affect the character, livability, or appropriate development of the surrounding community." (12.08.320(A)) " It seems that from the discussion either of the two site alternatives discussed immediately above would require the same "creation of an oil operating area and acquisition of a drilling permit", as would the proposed project site. If this is the case, it seems that the only substantial difference between the proposed project site and either of the alternatives discussed above is the lease land area availability. These issues need to be clarified and evaluated more clearly in the document. It is our opinion that either of the alternative sites discussed above, if determined feasible from the land lease issue, will allow for the proposed project to proceed in a manner that will " .. not adversely affect the character, livability, or appropriate development of the surrounding community" to a much greater extent than would the proposed site. Requested Modification of Mitigation Measures: If, after review and further evaluation of the project site alternatives discussed above, those sites are still determined to not be appropriate for the proposed project, then the City of Seal Beach requests the following modification to the language of the proposed "Mitigation Measures ", as set forth in Table 2 -1, and as appropriate within the body of the Final EIR document: All Mitigation Measures: The language imposing all proposed mitigation measures shall be mandatory in nature. It should not be discretionary as to whether a particular mitigation measure will be carried out. aeam.er os pall Sia pmamcaty ca =n,m Len r City of Seal Beach Comment Letter re: Draft EIR — Bel Power Oil Drill Site (SCH 1001101132) July 8. 2002 It may be discretionary as to the actual imposition of specific implementation measures, based on final determinations made by the appropriate reviewing and permuting authority. "Aesthetics" Mitigation Measure: The City of Seal Beach requests that the language of this mitigation measure be revised to read as follows: "Adherence to City Oil Code fencing and landscaping regulations will reduce potentially significant visual impacts. The following additional mitigation measure is required to reduce temporary visual impacts of the oil drilling and workover rigs as viewed from the Leisure World Community: Project landscape plans shall maximize use of closely spaced vertical trees along the eastern boundary of the project site. roiect f adu (Existing mitigation measure language requested to be deleted indicated by text with . Requested new language to mitigation measure indicated by text that is bold and do rhl tom.) Acceptance of this modification to the "Mitigation Measures" will indicate the desire of the City of Long Beach to work in a cooperative manner with Seal Beach and the residents of Leisure World to ensure that all reasonable concerns regarding the short -term construction impacts related to "Aesthetics" are thoroughly addressed in the project conditions and monitoring programs that will be established during the exploratory and production phases of the proposed project. The mitigation measure language should be mandatory, not permissive, as to the requirement of implementation. Additional Comments on Draft EM Document: Type of pumping unit: The DEIR indicates on page 2 -3 that the production pumping units are to be the familiar "grasshopper appearing" units, and it is unclear as to the power source for the pumping units. It appears the power source may be line power from an on -site electrical substation (see page 5.4 -9, second paragraph). The power source should be clearly stated within the discussion on page 2 -3. aellaower Oil Drill Sim DEIR -City Comment Letter City of Seal Beach Comment Letter re: Draft EIR —Bel y7ower Oil Drill Site (SCH2001101132) July 8, 2002 Proposed Site Plan, Exploratory and Production Phases: These site plans are presented as Exhibit 3-4 and 3 -5, respectively. In both site plans the project delivery and loading access routes are indicated along the easterly side of the lease area, closest to Leisure World. Why is it not possible to have the delivery and loading access routes located along the westerly side of the lease area, further away from Leisure World? By basically "flipping" the site plan, all of the vehicle access activities will take place approximately 150 feet further to the west of Leisure World. This would result in lessened construction- related impacts such as noise, dust, etc. It would also reduce long -term production- related impacts due to vehicle noise and air emissions. If this were to be accomplished, the requested block wall would be a continuous structure, preventing construction and vehicle noise from `leaking" into Leisure World through the necessary gate systems needed to accommodate the proposed access to the project site. Page 5.2-8, Item 6, last paragraph: This paragraph discusses potential radiant heat hazard footprints, indicating they would overlap into the Leisure World residential areas, and that "people naturally move may from radiant heat and find protection when it becomes uncomfortable". Within Leisure World the average age is 78, and many residents have physical limitations and handicaps that do not allow for rapid movement. Given a potential radiant heat hazard event, and assuming that something else is going on at the facility to cause this type of event (e.g., fire, explosion), it is a major assumption to reach that impacted residents will just be able to move out of the way. During a hazard event, any residents of Leisure World within the footprint area, may not react as precisely and quickly as is assumed in this discussion. There should be additional delineation as to the anticipated temperatures that would be experienced within the radiant heat hazard footprints, and impacts to persons within that footprint area that are not able to simply move out of the way in a reasonable time period. Vicinity Views into the Site, Exhibits 5.8 -2A through 5.8 -2G: These exhibits should be revised to also provide a simulation of the production facilities that would be constructed on the project site if full production does occur. It is indicated that the "pumping units" are about 20 -feet high, and it is unclear as to the height of the "Produced Fluids" and "Processing Equipment" tank and equipment facilities. It is the understanding of the City that the "standard" heights for processing and produced fluids tanks are either 16 or 24 -feet high. The height and diameter of the tank facilities needs to be clearly stated within the document and accurately represented in Exhibits 5.8 -2A through 5.8 -2G. The proposed color of the processing and produced fluids tanks also needs to be set forth and represented on the "Vicinity Views". The revised photo simulations should also include the necessary fencing and landscaping that will be required by the City of Long Beach in compliance with the requirements of the Oil Code, m revised by the City of Seal Beach comment on the mitigation measure for Aesthetics, above. These additional photo simulations are necessary In order to provide an aellaowa Oil Drill Sit DEIR.City Comment Leaer City of Seal Beach Comment Letter re: Draft EIR —Bel ylower Oil Drill Site (SCH 2001101132) July 8, 2001 adequate and accurate representation of the production phase visual impacts upon Leisure World. The Environmental Quality Control Board (EQCB) considered and discussed the DEIR document on June 26, 2002 and the City Council considered the DEIR document on July 8, 2002. The City Council and the EQCB authorized the Mayor and Chairman, respectively, to sign this letter indicating the official comments of the City of Seal Beach. Upon the preparation of the Final EIR for this project, please send 4 hard copies and a digital copy, if available, to Mr. Lee Whittenberg, Director of Development Services, City Hall, 211 Eighth Street, Seal Beach, 90740. Thank you for your consideration of the comments of the City of Seal Beach. If you have questions concerning this matter, please do not hesitate to contact Mr. Whittenberg at telephone (562) 431 -2527, extension 313, or by e-mail at Whittenberg@ci.seal- beach.ca.us. Sincerely, Jcvl)�AWA John Larson Mayor City of Seal Beach Attachments: (2) III Quality Control Board Exhibit A — Staff Technical And Correction Comments Exhibit B - Exhibit 3 -3, Site Location Map, indicating alternate project location suggested by City of Seal Beach Distribution: Seal Beach City Council Seal Beach Planning Commission Seal Beach Environmental Quality Control Board Seal Beach Archaeological Advisory Committee City Manager Director of Development Service Golden Rain Foundation Attn: William Narang Bellflower Oil Drill Sile DEIR.City Comment Leiter City of Seal Beach Comment Letter re: Draft EIR — Bellflower Oil Drill Site (SCH 2001101131) July 8, 2002 EXHIBIT A STAFF TECHNICAL AND CORRECTION COMMENTS Page 2 -17, Table 2 -1, Executive Summary: The second sentence of Measure 4 is incomplete. It currently states "recommendations regarding critical strata." Please revise as appropriate. Page 4 -1, first paragraph, third sentence: The concluding phrase of the sentence indicates the project site is bounded on the east and north by "Leisure World mobile home community." There is an RV storage area, however, there are no occupied mobile homes within Leisure World. Please revise the language to read as "Leisure World RV storage area ". In several other locations throughout the Draft EIR, the reference is to the "Leisure World mobile home community" or "Leisure World trailer park", please revise the language in all appropriate locations to indicate "Leisure World RV storage area ". Page 5.1 -9, first complete sentence at top of page: The sentence indicates the project site is not included within the Coastal Zone. This statement is incorrect. Please refer to Exhibit 5.1 -4, which clearly indicates the project site to be within the Coastal Zone. Page 5.2 -6, last sentence at bottom of page: Same comment as Page 4 -1 above. Please revise language as appropriate. Page 5.2 -7, last paragraph, last sentence: This sentence states that "It is noted here that the total amount of gas in the flammable vapor cloud hazard footprint would not be sufficient to allow an unconfined vapor cloud explosion to occur." It is not explained in the document what leads to that conclusion. Please revise and clarify to provide the necessary information to support the conclusion. Page 5.2 -10, second paragraph, second sentence: This sentence states that "flammable gas cloud footprints could reach the trailer park located south of Westminster Ave." There is no trailer park located south of Westminster Avenue. In the immediate vicinity, Island Village, a townhouse development is located south of Westminster Avenue. Please revise as appropriate. Page 5.3 -6, Table 5.3 -3: This table indicates that for noise measurement at location 1 the noise measured during the measurement time period was from "Airplane traffic on the Route 405 Freeway ". It is assumed the 405 Freeway noise is from vehicular traffic on the roadway. Please revise as appropriate. BeMowc Oil unit Sim DEIR.City Commem I,We 7 City of Seal Beach Comment Letter re: Draft EIR — Bellflower Oil Dn11 Site (SCH 2001101132) July 8,1002 Page 53 -10, Table 5.3 -5: The information on this table is not consistent with the information provided within Appendix C, Noise Assessment Study, page V -2. The table on this page is titled "Impact of Maximum Noise Levels, Lmax, - Without Noise Control Measures Applied ". The "Estimated Project Noise Levels, Lmax, At the Residential Location" for locations 4 and 5 are reversed between the tables. In addition, the "Significance Criteria (Daytime) db(A)" is 72.5 in the Appendix C table and 75 in the DEIR table. Please review and correct as appropriate. If the revisions result in additional significant impacts not previously identified or discussed, please revise the text of the DEIR, applicable mitigation measures, and/or the Appendix C report as applicable. Page 5.3 -12, Section 5.3.4, Cumulative Impacts: Please include table on page VII -1 of Appendix C in this section. It provides a clear understanding of the cumulative noise impacts for the reviewing public. Page 5.7 -1, Section 5.7.1, Existing Conditions: This section does not include discussion regarding the impacts on the wildlife that uses the Los Alamitos Channel on the eastern boundary of the project . The statement that the site provides low to marginal habitat for migrating birds may be true, but many different bird species have been observed foraging in the portion of the channel east of the project area throughout the year. The EIR should not overlook potential impacts from noise or dust on these foraging birds. Page 5.7 -5, Section 5.7.1, Existing Conditions, subsection "Birds ": This discussion should be revised to indicate that several bird species utilize the channel for foraging purposes, and that it is necessary to provide adequate proptection to the channel to not eliminate or disturb those foraging patterns. Page 5.9 -5, Table 5.9 -3: This table indicates the PM Peak Hour ICU/LOS in 2004 at Studebaker Road/Westminster Avenue to be 1.013/17, which is less than the 2001 condition of 1.036/17 (Refer to Table 5.9 -1, page 5.913). It is unclear as to how the 2004 indices are less than 2001 when it is indicated that the values shown in Table 5.9 -1 were increased by a factor of 1.03 to simulate Year 2004 conditions. Please revise as appropriate. Appendix B, Hazardous Materials Studies, "Emergency Response Plan ", Page 1 -3 and throughout document: The project site is referred to as "Hayes Generating Station". Please revise to "Haynes Generating Station" throughout the document. . s • e Bellflower Oil Drill Sitc DEIR.City Comment Letter City of Seal Beach Comment Letter re: Draft EIR — Belfower Oil Drill Site (SCH 2001101132) July 8, 2002 EXHIBIT B EXHIBIT 3 -3, SITE LOCATION MAP, INDICATING ALTERNATE PROJECT LOCATION SUGGESTED BY CITY OF SEAL BEACH Be1lBow Oil Drill Site DEIRCity Comment Letter Exn to 3 -3 Z00 0 300 a00 Fw, Site Location Map Approval of Comment Letter re: "Draft Environmental Impact Report — Bel[flower Oil Drill Site" (SCH2O01101132) DEIR prepared by City of L ong Beach City Council StaffReport July 8, 2002 ATTACHMENT 2 "DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE BELLFLOWER OIL DRILL SITE ", PREPARED BY THE CITY OF LONG BEACH, DATED MAY 2002 NOTE: PREVIOUSLY PROVIDED TO THE CITY COUNCIL, NOT PROVIDED WITH THIS STAFF REPORT. A COPY OF THE COMPLETE DOCUMENT, INCLUDING THE TECHNICAL APPENDICES WILL BE AVAILABLE AT THE CITY COUNCIL MEETING Bellflower Oil Dnll Site, Haynes Plant, I ng Btnh, DE[,,cc 7