CIPA Challenges LA County’s Oil Ordinance EIR as Incomplete and Unsupported

CIPA this week submitted extensive comments to Los Angeles County challenging the adequacy of the Draft Environmental Impact Report (EIR) for the County’s proposed Revised Oil Well Ordinance, which would phase out oil and gas operations in unincorporated areas of the County.

The 17-page comment letter argues that the Draft EIR repeatedly reaches beneficial or less-than-significant environmental conclusions without establishing a quantitative, facility-specific baseline or adequately analyzing the foreseeable consequences of eliminating local oil production. CIPA reviewed the draft document against 18 specific issues raised during the original scoping process and found that most were either not addressed or only partially addressed.

Among the most significant deficiencies, CIPA argues that the County fails to adequately analyze the increased reliance on imported crude oil that would result from eliminating local production. The Draft EIR assumes replacement tankers carrying between 500,000 and one million barrels, substantially larger than other available estimates for tankers serving California. CIPA contends that this assumption understates the number of additional tanker trips and associated emissions from ships, tugboats, and trucks serving the Ports of Los Angeles and Long Beach. The EIR also acknowledges concerns about “carbon leakage” and impacts on disadvantaged communities near the ports but does not quantify those effects.

CIPA also sharply challenged the EIR’s characterization of existing oil production as a significant public-health concern. The comments point to years of monitoring and health-risk assessments associated with the Baldwin Hills Community Standards District and note that none of the affected oil-production facilities reported health-risk assessments above applicable notification levels for cancer, chronic or acute health concerns during 2022 through 2024. CIPA further notes that oil and gas production represents only a small fraction of Los Angeles County’s overall emissions compared with mobile sources and other activities.

Another major concern is the County’s refusal to analyze what happens to oil-field property after operations cease. CIPA argues that redevelopment is reasonably foreseeable given Los Angeles County’s severe housing shortage, existing redevelopment proposals and plans involving former oil-producing lands. Yet the County credits the ordinance with future environmental benefits from shutting down and restoring oil sites while dismissing potentially adverse consequences of subsequent redevelopment as too “speculative” to evaluate. CIPA argues that CEQA does not permit the County to have it both ways.

Finally, CIPA criticized the County for failing to meaningfully evaluate an alternative proposed by the association during scoping: extending the proven operational protections of the Baldwin Hills Community Standards District to oil operations countywide rather than eliminating production altogether. The existing CSD includes monitoring, periodic reviews, emergency preparedness, health-risk assessments, and other safeguards that have produced an extensive real-world regulatory record for the County to evaluate.

CIPA is asking Los Angeles County to revise the Draft EIR, address the identified deficiencies, recirculate the document for public review if the revisions constitute significant new information, and provide a point-by-point response to the issues CIPA raised during scoping.

The fundamental problem identified in CIPA’s comments is straightforward: Los Angeles County cannot claim environmental benefits from eliminating local oil production while refusing to fully account for where replacement crude will come from, how it will reach California, or what will ultimately replace the oil operations being shut down.