FINAL EIR

The main document the public would be interested in is the Final Environmental Impact Report (FEIR). It consists of 879 pages and can be downloaded from the Internet as a 16 MB file. My computer froze up three times before I was able to get it.

The FEIR actually consists of thousands of pages, including the Response to Comments and the Response to Comments Appendices in combination with the Draft EIR and the Draft EIR Appendices.

An electronic copy of the FEIR is available for review below:  

• Notice of Availability (File Size: 81 KB)
• Volume 1: Draft EIR (File Size: 9 MB)
• Volume 2: Draft EIR Appendices (File Size: 16 MB)
• Volume 3: Responses to Comments (File Size: 16 MB)
• Volume 4: Technical Appendices (File Size: 4 MB)
• Volume 5: Attachments to Comment Letters (File Size: 25 MB)

Hard copies of the FEIR are also available at the following locations:

Richmond Public Library - Main Branch (Click here for hours of operation)
325 Civic Center Avenue
Richmond, CA. 94804

Richmond Planning and Building Services Department
1401 Marina Way South
Richmond, CA. 94804.

At the same time, the City has released the Agenda and Staff Report for the Design Review Board hearing on January 31. Click here for the agenda, and click here for the staff report.

I have not had time to make a detailed review of the FEIR, but it appears that Chevron avers that some changes have been made in the project to reduce the impacts.

• Chevron says there will not be an expansion in refinery capacity, after all.
• The FEIR proposes mitigating some emissions by placing domes over two tanks.
• Chevron denies the project will allow the processing of “dirtier” crude oil.

What has not changed in the project is generation of an additional 898,000 metric tons of greenhouse gases annually and an increase in the emission of CO, PM and VOCs.

The FEIR handily disposes of these disturbing facts by concluding, “ …the Proposed Project operational emissions of VOC would be mitigated to a less-than-significant level, and emissions of NOx, SO2, CO, and PM pollutants would be less than significant, “ and by stating “ …the City believes that making a significance determination with respect to GHG at this time would be speculative.” I knew that George Bush, Dick Cheney and EPA Administrator Stephen Johnson are still confused about greenhouse gases, but I thought the rest of us were convinced they are a problem!

Summary

Total emissions of NOx, SO2, CO, PM, and ROG (as VOC) from Proposed Project operations (daily and annual) and the significance thresholds established by the BAAQMD are presented in Tables 4.3-9 and 4.3-10. These summaries include the Proposed Project operations’ on-site stationary source emissions as well as the mobile source (off-site motor vehicle activities) emissions, and compares them to the thresholds of significance. Through the addition of air pollution controls and other concurrent process changes, the net effect of the Proposed Project would be to make substantive reductions of NOX, and SO2, and PM emissions compared to existing conditions and the net increase of CO and PM emissions would be below the significance thresholds. However, total VOC emissions would be above the BAAQMD significance thresholds.

The FEIR notes that Chevron’s new cogeneration capability will displace about 10 MW of electricity from the PG&E grid and allow the refinery to become self-sufficient with respect to electricity generation and use. Natural Gas use at the Refinery would increase by about 30% from the Refinery’s current use of approximately 90 million cubic feet per day. Regarding the prospect of using solar for electrical generation, the FEIR finds that generating all the refinery’s power by solar would take “315 and 632 acres of photovoltaic panels” but simply avoids any further evaluation: “Although the Chevron Refinery site is approximately 2,900 acres in size, a substantial portion of this land is either developed or is unsuitable for development. Without substantial further study and engineering of what would be a significantly different project, it is unknown if adequate space could be found on the Refinery. Huh?

My take on the FEIR is that it is essentially worthless, another product of an EIR industry that has sold out to corporate America.

DESIGN REVIEW BOARD STAFF REPORT

Now, let’s move on to the Design Review Board staff report, another disappointing piece of work.

Here are some examples of  Planning staff struggling to say something substantive with the expertise or professional assistance required to provide a really accurate and useful report :

Trees to Gobble Up Greenhouse Gases

Richmond’s Zoning Ordinance requires industrial equipment to be screened from public view. Instead of finding that the project can’t conform to Richmond’s requirements and needs, at least, a variance, The DRB staff report scores a twofer for the suggestion, “Due to the size of the proposed project, most of the outdoor equipment cannot be fully screened from view, as some process equipment, such as the CCR Reformer, will be approximately 300 feet high or extremely bulky in size. However, staff is recommending the planting of a buffer of Coastal [sic] Redwoods around the refinery perimeter to provide partial screening of the equipment from view, and supports planting a sufficient number of trees within certain areas of Richmond to screen, as much as possible, the refinery from view. If planted in enough of a quantity, the trees will also offset greenhouse gas emissions to a measurable level.”

The staff report does not quantify what that “measurable level” of greenhouse gas reduction is, how many and where this Redwood forest would be located or whether soil and other conditions around the refinery will successfully support “Coastal Redwoods” (the correct common name for Sequoia sempervirens is ”Coast Redwood,” not “Coastal Redwood,” a seemingly small error, but just one indication of a Planning Department that operates without professionals, such as landscape architects and horticulturalists. Neither does the report anticipate how long it would take the trees to grow to a height that would provide the desired screening.

Odors

The staff report notes that odors weren’t discussed in the DEIR because the BAAQMD informed the preparer, ESA, that no odor complaints related to the refinery had been received. This information was apparently accepted without question and published. The DRB staff report goes on to say “Subsequent to the release of the Draft EIR, the BAAQMD provided the accurate odor complaint information to ESA, which indicated that over 100 complaints were filed from 2002 through June 2006.” Then, ESA turned to Chevron for verification: According to Chevron, in an email dated December 24, 2007, 34 of the odor complaints were verified and were attributable to 15 specific odor events (eight of which were ‘substantiated’ by Chevron’s data) for which four notices of violation were issued by the BAAQMD. The analysis of those complaints did not lead the consultant to conclude that this information indicates the proposed Renewal Project will create objectionable odors affecting substantial numbers of people…” Well, I guess those unsubstantiated odor complaints were just people smelling their upper lips and frivolously complaining about Chevron. Did anyone think to consult the complainers to verify their reports? Of course not – they are just ordinary people. Anybody who lives around the industrial areas of Richmond knows what a joke the BAAQMD is  insofar as odor complaints go. They don’t even investigate a complaint unless at least three people complain. Even then, by the time they get out here, the odor has often dissipated, and they don’t work weekends. Give me a break! Even though hundreds of odor complaints have been actually filed over the last five years, our bureaucrats and highly paid consultants were unable to conclude that “…the proposed Renewal Project will create objectionable odors affecting substantial numbers of people.”

Light Pollution

Although the DEIR stated “Light and Glare - At night, the Refinery constitutes the principal outdoor illumination source in the western Richmond area,” the DRB staff report dismissed any opportunity to address light pollution by stating: “Few (or no) complaints of light intrusion have been reported for existing refinery operations, and the addition of the new equipment will be illuminated in the same non-intrusive manner.” Well, which is it – few or no complaints? That’s the kind of technical accuracy we get in a staff report for a major project. Regarding complaints, you can’t get the City to respond to a 9-1-1 call, a drug house, a pothole or a serious code enforcement problem next door. Who in the world would waste their time complaining to the City of Richmond about lights at Chevron?

Use of Experts

Although the Design Review Ordinance allows and even encourages the use of experts to provide information to the Design Review Board for projects like this, staff was unable to find any: “…City staff and consultants have interviewed some of the commenters for suggestions about experts available to assist the City. Due to the complex and highly specialized nature of the Refinery, the pool of interested experts is small.” Staff did, however, suggest that “…the City may want to formally request the assistance of the BAAQMD in enforcing mitigation measures and conditions of approval to the extent that experience in air quality issues is needed.” Are you kidding me? The experts at the BAAQMD are the same people who couldn’t find any odor complaints when the DEIR was prepared. The BAAQMD has long ago sold out to Chevron and other polluters and is not the agency one would have faith in to protect the citizenry. It is interesting to note that the “complex and highly specialized nature of the Refinery” is the excuse the City used for decades to justify the arrangement where Chevron checked its own plans, issued its own permits and inspected its own construction, elimination the City from any oversight whatsoever.

Thumbs Up

Finally, City staff gives the Design Review Board an enthusiastic thumbs up for the Chevron Richmond Refinery Energy and Hydrogen Renewal Project and recommends approval without conditions except for mitigations set forth in the 879-page final EIR.

Unfortunately, the thousand of hours, voluminous reports and over a million dollars spent by the City of Richmond to review the Chevron Richmond Refinery Energy and Hydrogen Renewal Project has resulted in an evaluation that has essentially been written by Chevron. The citizenry of Richmond, and indeed the public at large, have been miserably served by this pathetic effort. One only hopes that the handful of elected officials and appointed board end commission members who stand between this project and the public impact will have the wisdom and intestinal fortitude to do what is right for the public interest.