With worsening climate change impacts, we reiterate and amplify the concerns the people expressed in January of last year about “climate change and GHGs, and the effects of continued oil and gas extraction including secondary effects related to climate change, air quality, water quality, water supply, traffic, noise, odors, aesthetics, and hazards.”

Our county is warming faster than any other in the nation, our ocean is becoming more hostile to marine life, our last drought was the most intense and lasted longest, and our history of costly floods will be dwarfed when future atmospheric rivers pour over our valleys. Our house is on fire. We need a thorough plan and environmental impacts analysis based on the latest science.

Ventura County’s plan matters. Our larger cities are making climate action plans and look for your example of leadership. The environmental impact from what we do to mitigate climate impacts at the global scale is profoundly influential in trying to stop runaway climate change. This is explained in a new report Insights from the California Energy Policy Simulator about the role of the State of California in the world. Ventura County as a local government hit hardest by climate impacts must step up and meet serious goals. “Insights about California’s climate policies are at the forefront of global efforts to battle climate change. The state’s leadership and success so far have helped maintain momentum despite political headwinds. If California faltered, global efforts to reduce GHG emissions would be dealt a major setback. Meanwhile, the severe risks from runaway global warming are becoming more tangible as the state suffers from wildfires supercharged by climate change.”

A. Four Overall Comments:

We are grateful for the expertise at the law firm of Shute, Mihaly and Wineberger retained by CFROG regarding CEQA. We have appreciated their past comments. We join them in continuing to request the following:

1. Count ALL GHGs that result from activity in our county: Count all burning of oil and gas originating in our county and count all fugitive methane from wells in our county and from methane entering our county that was not counted at the jurisdiction of origin. Do the math on the GHG footprint for heavy exports. We want to mitigate our fair share of all climate impacts from activities within Ventura County. We have to know what they are. Worrying about double counting is not acceptable. Just worry that you haven’t counted every cause of climate impacts that we are morally and legally responsible to mitigate with a comprehensive inventory and a systematic plan.

2. Use the latest science to calculate GWP of methane: The global warming potential of GWP is nearly 40 percent greater than what you are using. The International Panel on Climate Change states that over a 20 year period, methane has a GWP of 84 compared to carbon dioxide (up from their previous estimate of 72). The US EPA estimates it at 87 and recent scientific experts put the estimate at 96. We must know the true environmental impact of methane emissions. A complete and scientifically valid GHG inventory is required for a CEQA-compliant Climate Action Plan.

3. Use the emissions reduction goal from Governor Brown’s Executive Order B-18-55 “to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter. This goal is in addition to the existing statewide targets of reducing greenhouse gas emissions.” It is an inadequate compromise, but not as much as the SB 32 goal of 80% below 1990 levels by 2050. City of LA plans to stay within a net zero carbon budget between now and 2045. The proposed GHG reductions in the VC2040 Draft of 41 percent below 2015 levels by 2030, 61 percent by 2040, and 80 percent by 2050 are not ambitious enough for us to do our part to mitigate the climate chaos happening faster than scientists have predicted.

4. Policies and programs must meet the goal: It does not take an in-depth analysis to see that this plan will not achieve the 2030 goal of 40% reduction in GHGs below 1990 levels. A new report Insights from the California Energy Policy Simulator shows that the State of California will fall short of that goal by at least 15 and as much as 45 MMT CO2e. We have and continue to advocate for a goal aligned with Governor Brown’s Executive Order to achieve carbon neutrality as soon as possible and no later than 2045.

B. Some Comments about Impacts and Mitigation

The environmental impacts that concern us are those resulting from governments not making and carrying out plans to mitigate climate change. Your draft analysis does not include most of them. Table B in the Executive Summary is not even half finished. Some of the more serious impacts are missing from the draft analysis. Here are a few of our concerns:

1. Aesthetics, Scenic Resources and Light Pollution and Agriculture and Forest Resources: Mitigation programs are needed to protect our resources from degradation from significant climate impacts. The loss of soil in particular is associated with the downfall of civilizations.

2. Air Quality: The emissions impacts from exceeding criteria pollutant thresholds and also greenhouse gases seem significant and can be mitigated.

3. Biological Resources: The new implementation program is a good start to “update the Initial Study Assessment Guidelines, Biological Resources Assessment report criteria and evaluate discretionary development that could potentially impact sensitive biological resources”. Two kinds of impacts are missing. 1) Climate Change. A major mitigation is the restoration of wetlands which should be at a 2:1 or greater ratio. Stormwater management is another mitigation that reverses the loss of vegetation from drought and floods and supports the restoration of all of the indigenous biology that makes an ecosystem function to maintain the small water cycles. 2) Toxic Pesticide and Herbicide Use and Drift. This must be part of the agenda of a Program for Protection of Sensitive Biological Resources to promulgate the mitigations provided by Integrated Pest Management. Pest management policy must align with the recommendations of the California Department of Pesticide Regulation Roadmap for Integrated Pest Management some of which have climate mitigation co-benefits.

4. Energy: We want a workshop to learn how it is deemed less than significant to allow wasteful. Inefficient, or unnecessary consumption of energy resources.

5. Greenhouse Gas Emissions: The climate change impacts are so dire that the mitigations need to be benchmarked to be achieved before it is too late to reverse runaway climate chaos. At minimum we demand a systematic plan for decarbonization of county facilities and electrification of the transportation system.

6. Hazards, Hazardous Materials, and Wildfire: The impacts of toxic explosions, leaks, and spills and the drift of regulated materials and the ignorance of the public about toxic impacts must be addressed where feasible through mitigations that regulate the use and transport of hazardous materials. We have recommended feasible mitigations for people being exposed to the risk of wildfires that have not been accepted by decision-makers.

7. Hydrology and Water Quality: Impacts from climate change and poor land management have have led to grave threats to water supply and water quality. These are highly significant--ground water overdraft, overuse and degradation of water quality, erosion, flooding, and siltation. (Impact 4.10-12) The failure to restore small water cycles to keep stormwater in the uplands and maintain forest health is one of the most serious impacts being mitigated in many places through a paradigm shift about stormwater management. Mitigation is essential--water is life. It requires an integrated water management plan that involves every sector working on every mitigation of which we are aware.

8. Land Use and Planning We want an analysis of incompatible land uses and new development with negative health implications. Closing wells near sensitive sites is a mitigation. Environmental Justice is not examined in the draft EIR.

9. Mineral and Petroleum Resources: We want an analysis of the impact of the scenario in which wells have been put on hold and the operator cannot close the wells for lack of funds. We have no choice. The wells must be closed properly. Fields must be restored to functioning ecosystems to help mitigate climate change impacts. We need insurance as well as bigger bonds.

10. Traffic and Transportation: Tailpipe emissions is an extremely significant environmental impact. The mitigation aimed for in the CTM-C: Vehicle Miles Traveled (VMT) Reduction Program needs assurances of effectiveness via a clear description of what “conditions warrant providing additional mitigations and programs”? This is far too vague to be a mitigation for this significant impact. We have no alternative but to reliably cut GHGs in the transportation sector.

11. Utilities: Failure to develop wholesale and commercial scale renewable energy generation and microgrids is a significant environmental impact because it has forced us to have to get our electricity from fossil fuels via transmission lines that spark wildfires. Community microgrids are a feasible mitigation.

12. Waste Management: Failure to properly manage waste has a highly significant environmental impact, especially when it produces methane super-emitter landfills that is driving climate change, but also the failure to reuse and recycle consumer goods and the materials and equipment discarded by commercial enterprises. We need a more comprehensive approach for mitigation of these impacts.

C. The following policy recommendations for the Draft Plan could help the Plan achieve the GHG reduction goals to mitigate climate change impacts and help the EIR be more relevant to the climate crisis.

Land Use and Community Character: We endorse the comments submitted by Bruce Smith to more firmly assure preservation of agricultural land and open space. We point out the lack of analysis of Environmental Justice policy issues.

Circulation, Transportation, and Mobility:
1. No overriding considerations should allow a project to NOT reduce VMT unless all of the vehicles have zero emissions that will use the proposed project.
2. CTM 3-9 to widen SR 118 has a significant environmental impact.
3. Benchmarks to reduce VMT need to be more clear and the plan needs a review with public input every two years until 2028 and then no longer than every five years.
4. Parking programs should be included in ways that reduce single-occupancy car trips.

Public Facilities, Services, and Infrastructure:
1. Enroll residents in a program to reduce CO2 emissions in their neighborhoods. Ex: Cool Block or Transition Streets.
2. PFS 2.1 must be revised to say include rather than encourage ‘Sustainable Plans and Operations’ in order to be considered a mitigation of climate change impacts from greenhouse gas emissions.
3. Policy PFS 7.1 should be revised to delete the need for access to gas. The environmental impact from use of natural gas requires carbonizing buildings beginning with no gas connections to new residences . It is therefore contradictory to ensure access to gas.
4. Local renewable energy generation must be part of the mitigation plan for reducing transmission facility fire hazard risk. This is not the same as “Smart Grid Technology”. You need experts who know the cutting edge of this field to help write coherent policy on this topic.
5. Zero Waste The County shall achieve zero waste (via a suite of policies to reduce, reuse, and recycle) with no organic waste going to landfills by 2023
6. Zero Waste Policy for Meetings and Events Design and implement a zero waste policy for meetings and events sponsored or permitted by the County to minimize waste and rescue surplus edible food
7. Compostable Take-Out Foodware Require that take-out foodware be made with material compostable in solid waste processing facilities within 60 days
8. Reduce Solid Waste by Phasing Out Single-Use Plastic Evaluate how to best reduce solid waste generation per capita by at least 15% by 2030 including phasing out single-use plastics including but not limited to plastic straws, plastic utensils, plastic take-out containers, and expanded polystyrene
9. Ban Expanded Polystyrene

Conservation and Open Space:
1. Reduce oil and gas production by 40% by 2025 via higher monitoring standards and 2500 ft buffer zones near sensitive sites; reduce production to zero by no later than 2040.
2. Phase-Out of Oil and Gas Production The County shall prohibit new drilling and shall regulate existing wells to assure steady closing of wells beginning near residential and commercial areas.
3. Maintain Policy COS-7.8 as recommended by the Board of Supervisors, so that all newly permitted discretionary oil wells are required to collect gases and use or remove them for sale or proper disposal instead of flaring or venting. Flaring should be allowed only in cases of emergency or for testing purposes.
4. Maintain Policy COS-7.7 as recommended by the Board of Supervisors, so that all newly permitted discretionary oil wells are required to convey oil and produced water via pipelines instead of trucking.
5. Detect and curb methane emissions from “super-emitter” sites as identified by NASA.
6. Tax oil and gas production, and related uncaptured methane to raise the needed revenues to fund urgent climate programs to replace high-emission vehicles with a priority on trucking and freight companies, fishing businesses, general contractors and K-12 schools.
7. Require a fully accountable performance bond for all new wells to cover cost of closure Cite LAT article (maybe put on website and link to it).
8. Establish an insurance fund that oil and gas producers contribute to that will cover accidents and closing wells if the producer goes bankrupt.
9. Ban gas-fueled lawn and garden equipment. (Ex: City of Ojai)
10. Accelerate capture of legacy HFCs Enlist the public and private to find and destroy existing stocks of HFC’s (refrigerant gases with extremely high Global Warming Potential).
11. Develop and adopt building codes based on best practices for use of low embodied carbon concrete and set targets for use of low GHG concrete alternatives. Ex: Bay Area Air Quality Management District and King Co, WA.
12. Encourage climate-safe and climate-resilient development through zoning reform and removal of limits on height, density, and minimum parking requirements to enable and promote walkability and a mix of uses for homes and businesses, parks and transit.
13. Create a master local clean energy siting and funding plan for wholesale distributed solar energy plus storage in commercial scale projects producing energy needs by 2030.
14. Provide energy efficiency benchmarking and rebates for low-income housing and renters as well as low-interest loans for small businesses to reduce energy use; assist owners of existing buildings to switch from natural gas to electricity.
15. Prepare sustainable building, siting, landscaping and passive heating and cooling practice guidelines, with a priority on low-income housing, that reduce consumption of non-renewable resources and that include climate and fire-safety in pre-approved plans.
16. Energy Efficiency to Reduce Electricity Use Use Energy Efficiency to Deliver 15% of Projected Needs for electricity in the county by 2023; and 30% by 2030.
17. Efficiency Building Standards for Retrofits Prioritize energy and water efficiency building standards and work to retrofit existing buildings.
18. Decarbonize County Buildings Develop a county building electrification plan eliminating natural gas use in County-owned facilities.
19. Decarbonize All Building Types Develop an electrification plan with goals for GHG emission reductions through renewable energy that evaluates and prioritizes programs for local solar, energy storage and demand response (DR) that disconnects all buildings from gas service by 2050. Include incentives for deep retrofits of inefficient buildings.

Agriculture:
1. Integrated Pest Management where toxic pesticides are a last resort. Create a program that promotes the principles (systems approach, building trust, and effective communication) and pursues the recommendations of the Roadmap for Integrated Pest Management from the University of California and CA Department of Pesticide Regulation. Environmental impacts from toxic pesticides are not described in the Background Report. The Roadmap to an Organic California Policy Report by CCOF Foundation offers information for mitigations and climate action. A workshop is needed.
2. Inorganic Nitrogen Based Fertilizers Set benchmarks for reducing use of inorganic N fertilizer and encourage optimized use of organic and inorganic fertilizer for greatest efficiency in closed nutrient cycles, monitor for nutrient runoff from fields and encourage the use of cover crops and green manure crops to reduce or avoid nitrous oxide (N2O) emissions and nutrient runoff.
3. Diversified Cropping Systems Encourage farmers to include 1 – 5% of beneficial insect attracting plants in a planted crop, and other methods, such as crop rotation, perennial mowed cover crop in orchards, and integrating multiple species or varieties to enhance the biological and economic stability by spreading economic risk and buffering against pest invasions and extreme weather events, and increase carbon sequestration.
4. Reward Regenerative Farmers with Digestate and Compost from Food Waste Research feasibility of a program for composting food waste for use by farmers and landscapers who use regenerative practices that sequester certified amounts of CO2.

Water Resources:
1. At least 30,000 acre-feet per year must come from storm water capture by 2035
2. All rainfall must be retained onsite in soil and reservoirs.
3. Slow It. Spread It. Sink It! The County shall enforce Best Management Practices (BMP) and Low Impact Development (LID) for new developments.
4. Recycle all wastewater for beneficial reuse by 2035.
5. Reduce potable water use per capita by 22% by 2025 and 25% by 2035: Offer incentives for water conservation features, including drought tolerant landscaping, permeable materials in standard parkway design guidelines, street trees, infiltration, greywater, and water-saving plumbing.
6. Close oil and gas wells and injection wells near aquifers as a top priority.
7. Create a Master Plan to develop the full potential of integrated water management to infiltrate the ground and recharge aquifers; support reforestation and restoration of watershed ecosystems; conserve and protect groundwater resources, and clean up creeks, streams, and estuaries.
8. Support Santa Clara River Loop Trail and Ventura River Trail Development

Economic Vitality:
1. Agricultural Diversification should include reference to regenerative practices to create biodiversity with opportunities for community members to visit farms.
2. Small Business Promotion. Support approval of caretaker residential space on business property to reduce VMT and more financial strength for small businesses.
3. Green Economy. Prioritize youth and immigrants for workforce development in industries that promote and enhance environmental sustainability, including GHG reductions, climate adaptation, resiliency and local renewable energy generation, storage and distribution, including solar power, wind power, wave energy, regenerative organic farming and value-added agriculture-related activities, and other appropriate renewable sources.
4. Maritime Economy. Facilitate a sustainable maritime economy using restorative aquaculture techniques that restore ocean health and biodiversity while reviving pre-human fisheries abundance. For example, restore sand-bottom kelp forests and increase kelp forests with flexible floating fishing reefs where the seafloor is otherwise too deep for kelp.
5. Promote Fire-Resistant Infill and Revitalization. Encourage infill development that serves as firebreak rather than as additional fuel for wildfires.
6. Create a Collaborative Structure for Innovation for a Resilient Future. The structure should be able to make decisions and create a way forward for zoning, building and materials and environmental health to allow options for a resilient future, include government officials, innovators and public as described in submissions from Sustainable Living Research Initiative.
7. Parking Infrastructure. Develop parking policies to reduce single occupancy trips associated with employees and business activity to reduce Vehicle Miles Traveled.
8. Master Plan for Distributed Energy Resources and Community Microgrids. Prepare a map of siting options for renewable energy generation and storage facilities and coordinate the identification of financing options for renewable energy resource development, including solar, wind, wave, storage and community microgrids both in front of and behind the meter.

In summary, with the accelerating tipping points, we cannot go half-way in our vision. We need extraordinary courage to set goals we can hang our hopes and efforts on. We want completeness and clarity so we can see how the emissions reduction plan adds up. We want respect for climate science to tell us the truth. We want more ambition. A 2016 decision of the state legislature in SB32 is just not good enough as a goal. We want to see a systematic plan that will assure carbon neutrality no later than 2045.