General Plan Comment from 350 Ventura County Climate Hub

Susan Curtis, Lead Planner, Ventura County General Plan Update

The Ventura County General Plan sets policies for climate action and environmental Justice until 2040.
The Planning Commission will consider the Final Environmental Impact Report (FEIR) on Thursday.

Climate and environmental justice policy is much improved over the old General Plan, plenty to get going on this winter when its adopted and the proposed new Climate Emergency Council is formed. But we would like to see more that addresses the connection between racism, community well-being and environment, especially to decrease air pollution. We recommend new and stronger policies. And we say that this General Plan doesn't work as a  Climate Action Plan. We want a Climate Action Plan that makes Ventura County a leader in the state.

Thank you for reading,  signing and sharing the petition below. You can also write to Planner as soon as possible and no later than Wednesday, July 15 noon with further comments for her to distribute to the Planning Commissioners for their meeting on this topic on Thursday, July 16.

Sponsored by
San Buenaventura (Ventura), CA

To: Susan Curtis, Lead Planner, Ventura County General Plan Update
From: [Your Name]

Petition to Ventura County Planning Commission (Document in Planning Commisioner's Packet - Exhibit B Public Comments Received July 13, 2020)


There is insufficient accountability and policy to ensure that the county can achieve net-zero emissions in the urgent timeline we want. Policies must be promises of what we will achieve together. Policies that “encourage”, “promote” and “support” convey a weakness in leadership when we require clear, immediate, courageous, measurable action with benchmarks.

We want Ventura County to be a leader in the state and show how a modern, visionary Climate Action Plan should be written. Much more real, effective community engagement is required especially including those most impacted. This can be the mandate to the Climate Emergency Council to develop a Climate Action Plan for climate mitigation with an equal emphasis on a realistic visioning for climate adaptation in a process that ensures full community engagement.

We appreciate that there are many excellent new climate and environmental justice policies and programs in the General Plan that we can all now pull together and achieve in the General Plan. BUT, as a Climate Action Plan, this doesn’t work.


Because of this new understanding and experience about the impacts from Covid-19, we want a mitigation schedule included to reverse by 2025 the inequities in exposure and risk from air pollution that compromises individual response to Covid-19 and access to immune-boosting preventive health programs, especially community health workers in Disadvantaged Communities (DACs) and to help other marginalized populations.

Covid-19 has a disproportionate impact on marginalized populations, especially those with compromised health associated with air pollution, poor nutrition and service jobs where there is risk from community exposure, including on immigrant essential farm workers living in dense housing. Air quality goals should be strengthened to establish larger buffers between polluting sources and sensitive receptors including elimination of air pollution in homes with gas stoves as described below.


The EIR recognizes that low-income and people of color live in areas with greater air pollution from oil and gas production and pesticide use. This review of the literature shows that pesticides weaken the immune system: “Pesticides and the Immune System--The Public Health Risks”, Repetto and Baliga (1996).

The study “Effects of air pollutants on innate immunity”, Bauer, et al, J Allergy Clin Immunol. 2012 explains some of the biochemical mechanisms. We know that air pollution around oil and gas wells weakens the immune and respiratory systems. Benzene, toluene, ethylbenzene, and xylene (BTEX) and other toxic hydrocarbons, such as formaldehyde, released from oil and gas operations and equipment can lead to health impacts ranging from irritation of eyes, nose, mouth, and throat to aggravated asthma and other respiratory conditions, blood disorders, harm to the developing fetus, immune system-related diseases, and cancer and childhood leukemia summarized in a 2014 NRCD report containing 71 citations. Cumulative effects from pesticides and oil and gas air pollution may predispose to greater susceptibility and worse outcomes from Covid-19.

We reject that significant unmitigated air pollution is an unavoidable overriding consideration in this new era of potential ongoing crises and disregarding the directive from the State Attorney General in his comment on the Plan:

Aug 2, 2019 Comment from Attorney General Xavier Becerra to VC2040 Planning Team: “We especially encourage Ventura County to consider additional policies that would reduce disadvantaged communities’ exposure to pesticides, such as requirements for adequate buffer zones between farms and sensitive receptors and a system to notify communities of pesticide applications near homes and schools before they occur.”

A mitigating program is suggested in the AG’s comment that includes community education and a system that will send an email or text notification to parents, teachers and community members prior to a fumigant application near a pilot project school. People have a right to know when pesticides are going to be applied near where they live, learn or work. The pilot program in Monterey County should be adopted to help people try to avoid some of the risk to Covid-19 from pesticide spraying.


Regenerative agriculture practices are being increasingly recognized as the first step of Integrated Pest Management—pest prevention—that farmers are beginning to learn and practice. We recommend that Regenerative Agriculture be named in policy in Goal 3 of the Agriculture Element (not just in the goal language) to encourage and promote regenerative farming practices that produce pest and disease-resistant crops and mitigate air pollution with a program to encourage collaboration on research, develop, and demonstration


Rationale: A July 9, 2020, Ventura County Star report warns about very long-term impacts from Covid-19 to people of all ages. The data are not even being collected yet because people with residual health problems who did not seek medical treatment when they were sick with Covid-19 are experiencing new categories of long-term impact. Some now have prospects of permanent damage to organs and/or life-long debilities from the infection. These risks are higher for low-income and people of color living near multiple sources of air pollution. Science is now saying long-term immunity after an illness is variable and may be short-lived. This is a highly significant new impact layered on the findings in CalEnviroScreen 3.0, such as the elevated asthma rates in the 93030 zip code in Oxnard.
Pandemic forecasters say:
A. On July 2, 2020 Bertozi et. al. published “The challenges of modeling and forecasting the spread of COVID-19” in which they conclude that they are “capable of measuring and forecasting the impacts of social distancing” and that “these models highlight the dangers of relaxing nonpharmaceutical public health interventions in the absence of a vaccine or antiviral therapies.” There are public health experts recommending the expansion of staff with community public health workers from the communities and speaking the people’s language to provide clear information for preventive health.
B. In an article on June 11, 2020 by Ionnidis, et. al. “Forecasting for COVID-19 has failed” the authors state: “Let’s be clear: even if millions of deaths did not happen this season, they may happen in the next wave, next season, or with some new virus in the future. A doomsday forecast may come handy to protect civilization, when and if calamity hits.”


In light of the significant new level of impact from Covid-19 and an acute need to assure Environmental Justice, it follows that you should restore the 2,500 feet setback from oil wells that was reduced to 1,500 feet. Living within a mile (5,280 feet) of oil or gas operations is a risk factor for premature birth, the leading cause infant mortality. Babies born to mothers who are Black, Hispanic, or are not high school graduates are most at risk in these locations. As the state has done with pesticide drift, you must recognize every home is a sensitive site.

The requirement for a 2,500 foot setback should not just apply to new wells but also to the over 3,000 existing active wells out of 3,800 that are closer than 2,500 feet from the currently defined “sensitive sites” and to the over 1,500 out of 2,250 idle wells that are closer than 2,500 feet to “sensitive sites”.

We have stated over these years that oil and gas production must be phased out to achieve net zero carbon as soon as possible as a necessary mitigation of climate change along with aggressive Carbon Dioxide Removal (CDR). A comprehensive systemic view of climate change mitigation is the right thing to do whether or not it fits your CEQA framework. It can be organized through a program for improving air quality that immediately improves mitigation of the impact from Covid-19 by staging the decommissioning of active and idle wells. Begin immediately within 500 feet, then by 2025 within 1,000 feet, and then by 2030 all wells within 2,500 feet from any place where people live, learn or work.

The feasibility of stopping release of methane in the oilfields is addressed in this paper "Environmental Implications of Flaring and Venting in Crude Oil and Natural Gas Production" (Ngene, 2016) and in the report "Fossil Fumes: A public health analysis of toxic air pollution from the oil and gas industry" by the Clean Air Task Force (2016). There are significant negative impacts from release of both toxic gases and methane to the atmosphere. A January 7, 2019, letter from the City of Ojai argues the importance of impacts from flaring at a single local project (to the Board of Supervisors re: CUP No. LU11-0006). The prohibition of flaring should be with more specific limited exceptions in terms of the latest science and available technology rather than generic references to various categories of infeasibility. In light of the new public health vulnerabilities, it is essential to make a stronger policy about flaring with stiff fines for any flaring.


More information on our webpage:

The Ventura County General Plan should acknowledge the science from aerial surveys of methane plumes that allow precise attribution of past or potential sources of methane emissions in the county. We see high levels of methane being released throughout the oil patch, around solid waste and wastewater facilities, and along SoCalGas pipelines and delivery locations. They biggest ones need to be stopped now. The County should create a program to use best practices for top-down and bottom-up measurement of methane emissions and a reasonable process to synthesize the data in order to find and easily mitigate at least a third of such sources. A Methane MRV (Monitoring, Reporting and Verification) Program would enable the county to first acknowledge the verifiable existence of large, sometimes sporadic, but sometimes very large methane leaks and find ways to fix them. There are many cases of “low-hanging fruit” described in the United Nations Best Practice Guidance for Effective Methane Management in the Oil and Gas Sector that should be fixed now.

The recently released Environmental Impact Report (EIR) for the Ventura County General Plan states that the County will not count the leaked methane documented from the NASA-JPL aerial surveys “because there is lack of consensus among scientific experts on a technical definition for “super emitter” sources. ” It then provides citations that appear to support this reason. See the full quote below from the EIR Master Responses page 2-11.

This decision to not count super emitter methane plumes from fixed sources or to launch a process to mitigate them results in under-counting them in the Greenhouse Gas Inventory in the EIR. Hence, the County has reduced that part of the inventory based on only using the models from CA Air Resources Board. This makes the County and the public blind to these GHGs and reduces the county’s responsibility to achieve net-zero emissions. It omits needed policy and a program for cleaning up these methane leaks.

The reason given is semantic and not substantive. It misleads the reader into assuming that nothing can be done about documented methane plumes so we are told that we should ignore this significant negative environmental impact. It dismisses that there are methods and will be more methods to compare top-down and bottom-up. It is possible to run an uncertainty analysis because there generally exist multiple values for a parameter. Because scientists are struggling with the best ways to synthesize the data does not mean that we can ignore a substantial amount of climate forcing methane gas leaking now.


More on our website

We appreciate the mitigation to prohibit natural gas infrastructure in new residential and commercial projects. However, to be right in addressing the added impact of vulnerability to Covid-19 and Environmental Justice, there must be a program to replace gas stoves and indoor air pollution exposure from natural gas in existing structures, starting with low-income and people of color. These emissions significantly add to cumulative effects from multiple sources. There is urgent and critical need for a program to implement a health-based indoor air quality guideline that protects the most sensitive populations, including children, the elderly, and those with existing respiratory ailments.

Impacts from gas stoves:
1. Indoor air is largely unregulated and is more polluted than outdoor air.
2. Toxic pollutants are at levels that would be illegal outdoors.
3. Increased risks to respiratory health well documented.
4. Children are at higher risk because of their higher breathing rates and levels of physical activity, higher lung surface to body weight ratios and smaller bodies, and immature respiratory and immune systems. (See our webpage link shown above for a more complete explanation of the impacts on children.)
5. Lower-income households are at higher risk.
6. Ventilation and other strategies are critical to protect vulnerable segments of the population.
7. Electric cooking is cleaner.

Air pollutants from gas stoves include the following:
1. Particulate Matter (PM2.5) in the absence of cooking food (i.e. from the flames) can be 2X higher from gas than from electric.
2. NO2 and NO (NOx) associated with combustion sources. NOx levels are close to zero in electric homes. Average levels in homes with gas stoves are from 50% to over 400% higher than in homes with electric stoves.
3. Nitric Oxide (NO) a precursor to NO2; there are significant levels only from gas stoves.
4. Carbon Monoxide (CO) risk is substantially elevated in homes with gas stoves.
5. Formaldehyde (CH2O or HCHO) is a known human carcinogen. Exposures at levels that occur in homes have been associated with infections in the lower respiratory tract. Simmering food on low heat for multiple hours can produce significant levels of formaldehyde fumes if ventilation is lacking (or the hood fan is not turned on).

Further evidence and references to these negative impacts can be found in the April 2020 publication “Effects of residential gas appliances on indoor and outdoor air quality and public health in California,” from the UCLA Fielding School of Public Health and this May 2020 publication by the Rocky Mountain Institute Mitigations are of heightened importance in light of the connections between lung health, Covid-19 outcomes and marginalized populations.
Such mitigations will contribute to a measurable decrease in GHG emissions to help the county achieve what should be a goal of net zero carbon as soon as possible and no later than 2030.

Recommendations to mitigate significant health problems from gas stoves:

In addition to long-range state goals to decarbonize all structures, the following mitigations of indoor air pollution from gas stoves should be added as policy and programs to the General Plan:
-- The County shall provide residents with access to knowledge in all appropriate languages about the risks and available protections to be safe from harmful levels of gas stove pollution.
-- The County shall remove gas stove pollution in all publicly funded buildings as soon as practical, with a focus on buildings that house children and other at-risk populations. Public funds, including for schools and low-income housing, should not be used to purchase or install indoor appliances that expose occupants to harmful levels of gas stove pollution.
-- The County shall provide assistance to access financial incentives, such as tax credits or rebates, are provided to enable low-income homeowners to eliminate gas stove pollution, including adding plug-in induction stovetops or switching from gas to electric stoves. Prioritize homes with children and other at-risk populations.
-- The County shall require that landlords provide notice to new and existing tenants about the risk of gas stove pollution, including options to minimize gas stove pollution such as offering induction cooktops, gas stove replacement, and stovetop ventilation to the outdoors.
-- The County shall seek a REACH code that includes prohibition of gas stoves in renovation projects.


All the above mitigations should be economically feasible from two funding sources: the present Excise Tax on Oil (which should be increased) and a higher Fugitive Methane Tax. We want to see a high rate of tax and most of the revenues of the Oil and Gas Excise Tax be available to mitigate impacts of environmental racism and injustices that put low-income and people of color at higher risk of cumulative exposures to air pollution, such as living near oil wells and/or near pesticide sprays and dust from farms, busy roads and freeways, and often with unvented or poorly vented natural gas stoves, and in dense living conditions with others infected with Covid-19. To ensure enough funds for these programs, the Excise Tax on Oil and Gas production should be specified to be in substantive proportion to the social cost of oil and gas emissions, with methane properly weighted (USEPA values CO2 in 2030 between $50 and $152/tonne and methane between $1600 and $4200/t (

Once again for the record, it is essential to recognize the climate forcing of methane and tax it accordingly. Methane is a short-lived climate pollutant with an atmospheric lifetime of about 12 years. According to the 5th Assessment Report of the Intergovernmental Panel on Climate Change (IPCC) its ability to trap heat in the atmosphere, also known as the global warming potential (GWP), is 28 times greater than that of carbon dioxide (CO2) over a 100-year time horizon, and 84 times higher than CO2 when measured over a 20-year period.

We agree with CFROG's repeated demands to round up to a factor of 100, because on an instantaneous basis, methane’s GWP is actually 120 times greater than that of CO2. Methane emissions are responsible for at least one fourth of manmade global warming, and that they continue to rise and must be counted as is done throughout the scientific literature . Reducing methane emissions presents an important near-term opportunity to address climate change. Release of unburnt fugitive methane must be taxed at 100 percent of the baseline value of $4,700 of damages per ton of methane (CH4). This calculation is the recognized best science. "The social cost of atmospheric release", Drew T. Shindell, Climatic Change (2015) 130:313–326, DOI 10.1007/s10584-015-1343-0, page 319, Table 2. A tax for agriculture and landfill methane super-emitter sites can start in 2024 reach the full social cost by 2030.


We have waited too many years for the creation of the Climate Emergency Council (CEC) to start providing coherent, ambitious leadership to address the existential threat of climate change. The longer the wait the more costly to achieve climate mitigation and environmental justice goals

Please proceed with haste and ensure that the CEC’s work prioritizes programs addressing the significant impacts of environmental racism and justice.
Mitigation of injustices must consider the role of past and present racial, religious, ethnic, or economic discrimination in the development of unjust situations, and a plan for healing or reversing that discrimination as part of the mitigation. We are no longer living in a world where local officials can safely deny the connection between racism, community well-being and environment.

Marginalized populations have not had influence in local government. Our most polluting industries are almost always placed in their neighborhoods, often with cumulative negative impacts. Access to purchase of real property by virtue of price or redlining has been limited to polluted neighborhoods. Cal Enviro Screen shows the disproportionate number of low income people of color that have been unable to acquire property or afford to live away from sources of pollution. It is time to call it what it is--environmental racism--treating people of color as disposable and relegated to living and working in sacrifice zones.

The negative impacts of climate change derive from an ethos that creates sacrifice zones for those treated as disposable people. An ethos that normalizes sacrifice zones for disposable people results in atmospheric and oceanic pollution and the existential threat of global warming. A just transition requires clean-up around oil producing infrastructure, factories, waste handling facilities, farms and highways – all while we wind down the production and use of fossil fuels. It requires that the institutional racism that rationalized the siting of those activities be eradicated.

We need a VC2040 vision of transition from polluting activities to clean regenerative ones with a process that puts justice for those who have suffered in the sacrifice zones of the county at the center of climate action planning and mitigations.