BILL ANALYSIS                                                                                                                                                                                                    Ó



          SENATE COMMITTEE ON ENVIRONMENTAL QUALITY
                              Senator Wieckowski, Chair
                                2015 - 2016  Regular 
           
          Bill No:            SB 1277
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          |Author:    |Hancock                                              |
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          |-----------+-----------------------+-------------+----------------|
          |Version:   |4/4/2016               |Hearing      | 4/20/2016      |
          |           |                       |Date:        |                |
          |-----------+-----------------------+-------------+----------------|
          |Urgency:   |No                     |Fiscal:      |Yes             |
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          |Consultant:|Joanne Roy                                           |
          |           |                                                     |
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          SUBJECT:  California Environmental Quality Act: supplemental  
          environmental impact report: City of Oakland: coal shipment 

            ANALYSIS:
          
          Existing law, under the California Environmental Quality Act  
          (CEQA),   
          
          1) Requires lead agencies with the principal responsibility for  
             carrying out or approving a proposed discretionary project to  
             prepare a negative declaration, mitigated negative  
             declaration, or environmental impact report (EIR) for this  
             action, unless the project is exempt from CEQA (CEQA includes  
             various statutory exemptions, as well as categorical  
             exemptions in the CEQA Guidelines).   (Public Resources Code  
             (PRC) §21000 et seq.)

          2) Requires a lead agency or responsible agency to prepare a  
             subsequent or supplemental EIR only if specified events  
             occur, such as when new information, which was not known and  
             could not have been known at the time the EIR was certified  
             as complete, becomes available.  (PRC §21166(c))

          3) Pursuant to Proposition 1B (Prop. 1B), enacts the Highway  
             Safety, Traffic Reduction, Air Quality, and Port Security  
             Bond Act of 2006 and authorizes $19.9 billion in general  
             obligation bonds to fund a variety of transportation  
             projects.  (Government Code §8879.22 et seq.)

          This bill:  







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          1) Makes several findings and declarations related to a project  
             to develop the Bulk and Oversized Terminal at the former  
             Oakland Army Base and a proposal to export coal from there.

          2) Requires a public agency with discretionary authority over  
             the project to prepare or cause to prepare a supplemental EIR  
             to consider and mitigate the environmental impacts of the  
             proposed coal terminal before approving a project that is  
             necessary for, and directly relates to, the use of the  
             terminal for the shipment of coal.

            Background
          
          1) CEQA:  Environmental review process.  

          CEQA provides a process for evaluating the environmental effects  
             of a project, and includes statutory exemptions as well as  
             categorical exemptions in the CEQA guidelines.  If a project  
             is not exempt from CEQA, an initial study is prepared to  
             determine whether a project may have a significant effect on  
             the environment.  If the initial study shows that there would  
             not be a significant effect on the environment, the lead  
             agency must prepare a negative declaration.  If the initial  
             study shows that the project may have a significant effect on  
             the environment, then the lead agency must prepare an EIR.

          Generally, an EIR must accurately describe the proposed project,  
             identify and analyze each significant environmental impact  
             expected to result from the proposed project, identify  
             mitigation measures to reduce those impacts to the extent  
             feasible, and evaluate a range of reasonable alternatives to  
             the proposed project.  Prior to approving any project that  
             has received an environmental review, an agency must make  
             certain findings.  If mitigation measures are required or  
             incorporated into a project, the agency must adopt a  
             reporting or monitoring program to ensure compliance with  
             those measures.

          If a mitigation measure would cause one or more significant  
             effects in addition to those that would be caused by the  
             proposed project, the effects of the mitigation measure must  
             be discussed but in less detail than the significant effects  
             of the proposed project.








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          2) What is analyzed in an environmental review? 

          Pursuant to CEQA, an environmental review analyzing the  
             significant direct and indirect environmental impacts of a  
             proposed project, may include water quality, surface and  
             subsurface hydrology, land use and agricultural resources,  
             transportation and circulation, air quality and greenhouse  
             gas emissions, terrestrial and aquatic biological resources,  
             aesthetics, geology and soils, recreation, public services  
             and utilities such as water supply and wastewater disposal,  
             cultural resources, and tribal cultural resources. 

          The analysis must also evaluate the cumulative impacts of any  
             past, present, and reasonably foreseeable projects/activities  
             within study areas that are applicable to the resources being  
             evaluated.  A study area for a proposed project must not be  
             limited to the footprint of the project because many  
             environmental impacts of a development extend beyond the  
             identified project boundary.  Also, CEQA stipulates that the  
             environmental impacts must be measured against existing  
             physical conditions within the project area, not future,  
             allowable conditions.

          3) CEQA:  Supplemental EIR.

          A supplemental EIR may be necessary, such as when new  
             information of substantial importance was not known or could  
             not have been known without the exercise of reasonable due  
             diligence at the time the original EIR was certified. When  
             the original EIR has been certified, comprehensive analysis  
             of the project is presumed to have already taken place and  
             the question becomes whether circumstances have changed  
             enough to justify repeating a part of the environmental  
             review process.  A supplemental EIR need only address those  
             EIR topics that require major revisions to the original EIR.   
             A supplemental EIR is subject to the same notice and public  
             review requirements as the original EIR, except a new notice  
             of preparation is not required.  If the project was approved  
             by the lead agency before the conditions that trigger a  
             supplemental EIR happened, then the supplemental EIR must be  
             prepared by the public agency that grants the next  
             discretionary approval for the project.









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          4) Coal.

          Coal consumption in the United States has been declining in  
             recent years due to the abundance of cheap natural gas, the  
             growth of renewable energy, and environmental regulation.   
             The coal industry has sought to make up for the loss of U.S.  
             demand by increasing exports.  Demand for coal globally  
             continues to grow, fueled largely by China.  While some U.S.  
             coal is exported to Japan and South Korea, it is not a major  
             player in Asia despite the relative cheapness of western U.S.  
             coal; and the lack of export terminal capacity may be viewed  
             as one of the reasons why.  Proposals over the past several  
             years to construct or expand port terminals in Oregon and  
             Washington in order to grow exports to Asia have been  
             defeated or stalled at almost every step, primarily due to  
             concerns about both local environmental impacts and global  
             climate change.

             a)    Coal and climate change.

             Coal is a fossil fuel.  When coal is burned, carbon dioxide,  
                sulfur dioxide, nitrogen oxides, and mercury compounds are  
                released.  The fifth assessment report from the  
                Intergovernmental Panel on Climate Change notes that  
                atmospheric concentrations of global warming pollutants  
                have risen to levels unseen in the past 800,000 years.   
                Carbon dioxide concentrations have increased by  
                approximately 40% since pre-industrial times.  There is  
                broad scientific consensus that these GHG emission  
                increases are leading to higher air and water temperatures  
                as well as rising sea levels, with serious consequences  
                for California.  

             In July 2015, Governor Brown spoke at the Vatican symposium  
                on climate change and modern slavery, which aimed to drive  
                awareness, dialogue, and action at the local level - among  
                his remarks, he stated that 90% of the world's coal must  
                remain unused to help avoid the dangers of global warming.

             b)    Coal dust: environmental and public health risks.

             Coal dust is a fine powdered form of coal, which is created  
                by the crushing, grinding, or pulverizing of coal.   
                Because of the brittle nature of coal, coal dust can be  








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                created during mining, transportation, or by mechanically  
                handling coal.  Also, not all coal is created equally -  
                some types break down into dust more easily than others.  

             Particulate matter from the transportation of coal can impact  
                air quality, and severe exposure to coal dust can cause  
                various pulmonary diseases.  In addition, questions may  
                arise regarding potential environmental impacts caused by  
                chronic, low-level input of coal dust that may result from  
                steady coal shipment traffic.  For example, could the  
                transportation of coal cause pollutant emissions, noise,  
                potential fires, or leaching of chemicals?  Could coal  
                dust cover the leaves of nearby vegetation and reduce its  
                photosynthesis capabilities or have toxic effects on  
                public health or wildlife?

          5) Coal shipments through California.

          According to the author, three ports in California export coal:   


             a)    Levin-Richmond Terminal:  A private terminal, which  
                exported approximately 1 million tons of coal per year for  
                the last four years; but currently unknown as to whether  
                exports are continuing in 2016.

             b)    Port of Stockton:  Coal exports have varied from 25,000  
                tons to up to 1.8 million tons.  

             c)    Port of Long Beach:  Less than one million tons.

             If the coal export terminal is built in West Oakland to  
             handle 10 million tons of coal, it would be the largest coal  
             export facility along the west coast. 

          6) West Oakland public health.

          According to the author, West Oakland has been designated as a  
             disadvantaged community by the California Environmental  
             Protection Agency via CalEnviroScreen.  The community of West  
             Oakland is impacted heavily by goods movement.  West Oakland  
             residents breathe air containing three times the amount of  
             diesel particulate matter than air in other parts of the Bay  
             Area, which translates into 2.5 times greater risk of cancer.  








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              Children in West Oakland suffer from ailments like asthma at  
             higher rates than children in other neighborhoods.  West  
             Oakland residents are two times as likely to go to the  
             emergency room with asthma as people in other parts of  
             Alameda County.

          7) History of the Oakland Bulk and Oversize Terminal (OBOT).

             a)    Redevelopment of Oakland Army Base. 

             According to the Senate Transportation and Housing Committee,  
                after the Oakland Army Base closed in 1999, part of the  
                property reverted to the City of Oakland while another  
                portion went to the Port of Oakland.  The following year,  
                the Oakland City Council designated the base and  
                surrounding properties, an area totaling 1,800 acres, as a  
                redevelopment area.  In 2009, the Port of Oakland secured  
                Trade Corridor Improvement Fund (TCIF) funding for a  
                project to develop warehouse space, logistics facilities,  
                and a rail terminal on the site.  By diverting freight  
                from trucks to trains, the new rail terminal complex was  
                expected to reduce diesel PM emissions while  
                simultaneously increasing the efficiency of goods movement  
                through the port.

             Following the dissolution of the redevelopment agency in  
                2012, the area owned by the redevelopment agency was  
                transferred to the City of Oakland.  The Port and the City  
                began working together on the site and significantly  
                expanded the scope of the redevelopment, including the  
                addition of a bulk terminal.  The Port obtained a grant  
                under the federal Transportation Investment Generating  
                Economic Recovery (TIGER) program, as well as additional  
                TCIF funds.  The expansion of the project required an  
                update to the EIR completed in 2002; an addendum was  
                prepared in 2012.


             b)    Funding.

             According to the Senate Transportation and Housing Committee,  
                the Port and the City forged an agreement with two private  
                entities, California Capital and Investment Group (CCIG)  
                and Prologis, to develop the site.  These two companies  








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                were tasked with finding additional investors and tenants  
                for the project.  Details of what commodities would be  
                transported through the bulk terminal were largely  
                contingent upon the contracts that would be executed, and  
                therefore were not reviewed in the environmental  
                documents.

             To date, the Port and the City have secured about two-thirds  
                of needed project funding.  Of this, the majority comes  
                from public funding sources, specifically:  the state TCIF  
                ($242 million); the federal TIGER program ($15 million);  
                the Port of Oakland ($16 million); and the City of Oakland  
                ($55 million).  In addition, CCIG and Prologis have  
                identified funding totaling approximately $172 million.   
                CCIG executed a contract with Terminal Logistics Solutions  
                (TLS), a company headed by Jerry Bridges, a former  
                executive director of the Port of Oakland.  It was this  
                company that negotiated the deal with Utah.

             c)    Enter Utah.

             As coal-fired power plants in the United States close or  
                switch to natural gas, access to overseas markets is  
                becoming increasingly important for coal-producing states.  
                 In spring of 2015, stories surfaced in the media  
                revealing that the state of Utah was in discussions with  
                port developers about shipping coal from Utah to China  
                through a proposed bulk terminal in Oakland.  

             In February 2016, the Utah Legislature passed SB 246 to  
                authorize and provide $53 million in Utah transportation  
                funding to aid construction for the new Oakland cargo  
                terminal.  On March 22, 2016, the Utah Governor Gary  
                Herbert signed the bill.  To fund the Oakland project,  
                Utah would use state tax revenue and then reimburse the  
                state with federal royalties from federal mineral leases.   
                However, federal mining royalties are required to go to  
                local projects such as building roads, parks, public  
                buildings, water and sewer systems-infrastructure to  
                mitigate the impact of mineral development in Utah.   
                Instead, Utah is putting tax revenue moneys into a newly  
                created, Throughput Infrastructure Fund, and then  
                reimbursing the state with mineral royalties.









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             d)    What's the plan?

             The OBOT is part of the larger redevelopment project at the  
                former Oakland Army Base, financed with a combination of  
                public and private funds.  The improvements for the OBOT  
                part of the project will cost an estimated $250 million.   
                The developer is CCIG and the long-term lessee of the  
                terminal would be TLS, which would also manage an existing  
                track network.  TLS is looking to partner with the four  
                Utah counties to export commodities including coal, giving  
                the Utah counties four million to five million tons of  
                annual shipping capacity and access to overseas markets in  
                exchange for a $53 million investment.  According to the  
                Los Angeles Times article, "Coal represents the polluted  
                past - except in the interior West," (William Yardley,  
                March 16, 2016), public records from March 2015 show that  
                at least under a plan being developed at that point, the  
                company that would operate the terminal, TLS, would be  
                controlled in part by Bowie Natural Resources, the company  
                whose Utah coal mines would serve the terminal.  TLS has  
                yet to exercise its option to develop the terminal.

            Comments
          
          1) Purpose of Bill.  

          According to the author:

               A proposed project at the former Oakland Army Base would  
               bring up to 10 million tons of coal to West Oakland each  
               year.  Coal would come on railroad lines from Utah and be  
               transferred to cargo ships for export to China and overseas  
               countries.  If built, it will be nearly four times larger  
               than any coal export terminal in the West Coast. 

               West Oakland would be impacted by this coal export facility  
               and coal dust would add to the high pollution levels in  
               West Oakland.  West Oakland residents are already 2.5 more  
               likely to get cancer due to breathing air which contains  
               three times the amount of diesel particulate matter than  
               air in other parts of the Bay Area.  West Oakland has also  
               been designated by the CalEnviroScreen as being a  
               disadvantaged community due to its high asthma rates,  
               cancer risks, and pollution levels.








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               I am certainly concerned about the impact of a large coal  
               export terminal and the impact it would have for the  
               surrounding environment, including the San Francisco Bay.   
               It is not acceptable to have the City of Oakland build a  
               large new facility to export coal to places like China  
               where people often must cover their faces or stay inside to  
               avoid breathing dirty air.

               The need for a legislative response has gotten even more  
               pronounced as a result of legislation that was just signed  
               into law in Utah that would direct $53 million from the  
               state's Community Impact Bonds to purchase ownership shares  
               in the Oakland project in order to guarantee port access  
               for Utah's coal industry.  The City of Oakland has already  
               received over $176 million in public funds from the  
               California Transportation Commission via the Trade Corridor  
               Improvement Fund from Proposition 1B.  All of which means  
               these efforts to prop up a dirty and antiquated energy  
               source are being supported through public dollars.

               SB 1277 declares that the transportation of coal through  
               West Oakland is a clear and present danger to the health  
               and safety of Oakland residents as well as to the workers  
               that would handle the coal.  It also requires, before  
               approving a project that is necessary for and directly  
               related to the use of the terminal for the shipment of  
               coal, a public agency with discretionary authority over the  
               project to prepare or cause to prepare a supplemental EIR  
               to consider and mitigate the environmental impacts through  
               the coal terminal pursuant to CEQA.

          2) Why should the state be concerned?

          Some contend that this bill is a district issue and should be  
             dealt with at the local level.  However, the impacts of coal  
             on public health and global warming are statewide concerns.   
             For example, the state has policies that prohibit utilities  
             from renewing contracts with coal-fired power plants.  Also,  
             coal transported from Utah would have to go through multiple  
             counties in the state before it reaches OBOT - would citizens  
             in those counties be affected by this project?  

          It seems appropriate for the state to have some concern about a  








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             project, which the state has provided $176 million in general  
             obligation funds.  As noted above, the Port of Oakland  
             secured TCIF funding in 2009.  Prop. 1B mandates, among other  
             things, that when allocating TCIF, emphasis must be placed on  
             projects that improve corridor mobility while reducing  
             emissions of diesel particulate and other pollutant  
             emissions.  Coal, which can have significant air quality  
             impacts, was not considered in 2009 as a potential commodity  
             to use in the facility; and, now the export terminal may be  
             built to handle up to 10 million tons of coal annually.  



          It seems reasonable that when no action has occurred at the  
             local level for almost a year to address this issue that the  
             state may wish to ensure that the law is adhered to and state  
             funds are used as intended.

          3) How much was known when?

          The developer, CCIG, explicitly stated in a December 2013  
             newsletter that CCIG "has no interest or involvement in the  
             pursuit of coal-related operations at the former Oakland Army  
             Base."  

          According to the Los Angeles Times article, "How Utah quietly  
             made plans to ship coal through California," [W]hen state and  
             county officials in southern Utah came up with an unusual  
             plan to invest $53 million in public money to help build an  
             export terminal in San Francisco Bay, they decided to tell as  
             few people as possible what commodity they planned to export.  
              'The script,' according to Jeffrey Holt, the [former]  
             chairman of the Utah Transportation Commission and a central  
             figure in arranging the $53-million loan, writing in an email  
                                                                                       last spring, 'was to downplay coal.'"  (William Yardley,  
             December 11, 2015).

          Over the past several years, with the environmental reviews,  
             contract negotiations, and public funding processes, Oakland  
             City officials claim that they were never advised that coal  
             would be part of the product mix.  CCIG did not formally  
             confirm that coal would be one of the exports from the OBOT  
             until a July 2015 letter to the Oakland Mayor.  









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          4) Need for a supplemental EIR.

          CEQA provides that a public agency must prepare a subsequent or  
             supplemental EIR for a project if the lead agency determines  
             that new information of substantial importance has come to  
             light since the EIR was certified.  CCIG states that it has  
             already complied with CEQA.  However, neither the original  
             EIR, which was certified 13 years ago, nor the CEQA addendum  
             in 2012, included any mention of coal as a commodity that  
             would pass through OBOT - there was no reason to analyze the  
             impacts of coal if coal was not even considered a potential  
             commodity to go through the facility.  As noted above, even  
             as late as December 2013, people were under the belief that  
             coal was not a commodity being deliberated.  

          The developer's July 2015 letter confirming coal to the Oakland  
             mayor and Utah's recent approval to help fund the facility  
             with $53 million show a commitment that coal is intended to  
             be shipped through the facility. Both of these show a change  
             in the project requiring supplementation to the environmental  
             review.  However, there has been no action at the local level  
             to consider this new development that coal is a commodity  
             that will be shipped through OBOT.  

             A question that arises is - in what stage of the development  
             process is this facility and what is the next discretionary  
             permitting/action required?  Because of the new information  
             regarding coal, the next public agency with discretionary  
             action cannot fully rely on the certified EIR.  Thus, the  
             next public agency will become the lead agency that must  
             prepare, or cause to be prepared, a supplemental EIR to  
             analyze and mitigate the environmental impacts related to the  
             shipment of coal.  

             The original discretionary action by the City of Oakland and  
             for which the EIR was certified is done.  Unless Oakland has  
             another discretionary action regarding the facility, the city  
             is no longer the lead agency.  For example, if the city  
             reopens the development agreement, then the city could be the  
             lead agency to prepare the supplemental EIR.

             Because there has been no movement by a local agency, for  
             almost a year now, that seeks to put on record that this is  
             new information that should be analyzed and to ensure that  








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             this does not slip through the cracks, this bill is intended  
             to clarify and make certain that this issue gets addressed.  

          DOUBLE REFERRAL:  
          
          This measure was heard in Senate Committee on Transportation &  
          Housing on April 12, 2016, and passed out of committee with a  
          vote of 7-3.

            
          SOURCE:                    Author  

           SUPPORT:               
           
           350 Bay Area
          Berkeley Climate Action Coalition
          City of Richmond
          East Bay Young Democrats
          Ecology Center
          Environment California
          Fossil Free California
          Northern California District Council of the International  
          Longshore and  
                    Warehouse Union (ILWU)
          Physicians for Social Responsibility San Francisco Bay Area  
          Chapter
          Public Advocates
          San Francisco Baykeeper
          Save the Bay
          Sierra Club California
          The Peace, Earthcare and Social Witness Committee
          West Oakland Environmental Indicators Project
          1 Individual
                      
           
          OPPOSITION:    

          American Planning Association, California Chapter
          California Building Industry Association
          California Business Properties Association
          California Chamber of Commerce
          California Manufacturers & Technology Association 
          California Railroad Industry
          California Teamsters Public Affairs Council  








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