Inglewood Oil Field (IOF) Specific Plan
Draft Environmental Impact Report (EIR)
Draft IOF Specific Plan EIR
2.0 Environmental Setting
3.0 Project Description
4.0 Environmental Analysis
4.2 Air Quality
4.3 Biological Resources
4.4 Cultural and Tribal Resources
4.5 Geology, Soils, and Seismicity
4.6 Greenhouse Gas Emissions
4.7 Hazards, Hazardous Materials, and Risk of Upset
4.8 Hydrology/Water Quality
4.9 Land Use and Planning
4.10 Mineral Resources
4.12 Public Services and Facilities
4.14 Transportation and Traffic
5.0 Project Alternatives
6.0 CEQA Mandated Sections
7.0 Preparers and Acronyms
Appendices to Draft IOF Specific Plan EIR
A-1: Initial Study Notice of Preparation (NOP)
A-2: NOP Comments
B-1: Specific Plan
B-2: DOGGR Draft Mitigation Policy Manual
C-1: Air Quality and GHG Tech Report
C-2: Feasibility Assessment of Air Quality Performance Standards
D: Cultural Resources Files
E-1: Geo Soils Seismicity Memo
E-2: Seismic Activity
F: Risk of Upset Analysis
G: Water Quality and Groundwater Impacts Memo
H: Noise Monitoring Data
I-1: Traffic Analysis Memo
I-2: California DOT District 7 Correspondence
I-3: Intersection Capacity Utilization Data
Other Related Documents
Submission of Comments on the Draft EIR
The public review period of the Draft EIR began on September 15, 2017 for its initial 60-day public review period. On November 13, 2017, the City Council granted a 120-day extension.
This 180-day public review period will now end at 5:30 p.m. on Wednesday, March 14, 2018.
Written comments should be labeled with “Subject: Inglewood Oil Field Specific Plan Project” and be directed as follows:
By email: IOFSpecificPlanProject@culvercity.org
By fax: (310) 253-5664
By mail: City Attorney’s Office
Attention: Heather Baker, Assistant City Attorney
Subject: Inglewood Oil Field Specific Plan Project
9770 Culver Boulevard
Culver City, CA 90232
Community Informational Meetings on the IOF Specific Plan Draft EIR
During the 180-day public review period for the Draft EIR, two informational community meetings have been held on October 24 and October 30, 2017, which provided an overview of, and assisted the public in, navigating the Specific Plan and Draft EIR, and explained the process for providing feedback on these documents. These meetings were not required as a part of the CEQA process and were intended to be informational. Attendance was voluntary and not a prerequisite for submitting comments on the Draft EIR.
The PowerPoint presented at these informational meetings is available here.
A third community meeting is scheduled for February 21, 2018 from 6:30 - 8 p.m. in the Rotunda Room at Veterans Memorial Complex, 4117 Overland Avenue, Culver City, CA 90230. For more information, please view the event flyer.
Additional meetings may be held as needed. Check back here for the latest updates regarding these meetings.
Frequently Asked Questions
Q: How do I get more information about the Culver City Inglewood Oil Field (City IOF) Specific Plan Project?
Check the City IOF webpage regularly to learn about the latest news regarding the proposed City IOF Specific Plan, the draft Drilling Regulations, the Draft Environmental Impact Report (Draft EIR) and upcoming community meetings. If you cannot find the information you need on this webpage or have additional questions, please contact Heather Baker, Assistant City Attorney, at firstname.lastname@example.org; or Melanie Doran Traxler, Specific Plan Project Manager, at IOFSpecificPlanProject@culvercity.org.
Also, for more information about the California Environmental Quality Act (CEQA) process, the proposed Specific Plan and the Draft EIR, the City held two informational community meetings on October 24 and October 30, 2017, which provided an overview of, and assisted the public in, navigating the Specific Plan and Draft EIR, and explained the process for providing feedback on these documents. These meetings were not required as a part of the CEQA process and were intended to be informational. Attendance was voluntary and not a prerequisite for submitting comments on the Draft EIR. Additional meetings may be held as needed. Check back here for the latest updates regarding these meetings.
The PowerPoint presented at these community meetings is available here.
A third community meeting has been scheduled for February 21, 2018. For more information, please view the event flyer.
Q: How can I get a copy of the Specific Plan, Drilling Regulations or Draft EIR?
The Draft EIR can be viewed or downloaded at the City’s website at www.culvercity.org/inglewoodoilfield. Technical Appendix B-1 of the Draft EIR sets forth the proposed Specific Plan and draft Drilling Regulations. Hardcopies of the proposed Specific Plan, draft Drilling Regulations, Draft EIR and Technical Appendices are available for viewing at the following locations:
Julian Dixon Library
County of Los Angeles Public Library
4975 Overland Avenue
Culver City, CA 90230
Library hours are 10:00 AM – 8:00 PM, Monday through Thursday; 10:00 AM – 6:00 PM on Friday; 10:00 AM – 5:00 PM on Saturday; closed on Sunday and holidays.
City of Culver City
9770 Culver Boulevard, 2nd Floor
Culver City, CA 90232
City Hall business hours are 7:30 AM – 5:30 PM, Monday through Friday, except the City is closed on alternate Fridays. Please telephone in advance to assure staff availability at (310) 253-5710.
Limited copies of the CD are available for pick-up at the Planning Division public counter. CDs will not be mailed.
Q: What is the Public Review Period for the City IOF Specific Plan and/or Draft EIR and how can I submit comments on these documents?
The Draft City IOF Specific Plan (including the draft Drilling Regulations) and the Draft EIR were released for public review and comment on September 15, 2017, for an initial 60-day review period ending Tuesday, November 14, 2017. The CEQA Guidelines require that an EIR be available for a 45-day public review period; however, the City voluntarily extended the Project’s Public Review Period to 60 days to accommodate a thorough public review.
At its meeting on November 13, 2017, the City Council approved a 120-day extension of the public review period, providing a total of 180 days for the public to review and comment on the Draft EIR.
Interested parties now have until 5:30 PM on March 14, 2018 to review the Draft EIR and submit written comments for consideration by the City Council. During the public review period, the City of Culver City will hold two informational community meetings (open to members of the community, agencies, landowners, and other interested parties) to address questions about the proposed City IOF Specific Plan Project and review process. In addition, at least one noticed public hearing before the City Council will be held to allow the City Council and interested parties and agencies to voice their opinions regarding the Draft EIR and proposed Specific Plan document (including the draft Drilling Regulations).
Written comments should be received by the City on or before March 14, 2018 at 5:30 PM. Written comments should be labeled with “Subject: Inglewood Oil Field Specific Plan Project” and be directed via email to IOFSpecificPlanProject@culvercity.org, by fax to (310) 253-5664, or by mail to: City Attorney’s Office, City of Culver City, 9770 Culver Boulevard, Culver City, CA 90232, Attention: Heather Baker, Assistant City Attorney, Subject: Inglewood Oil Field Specific Plan Project.
Q: What is a Specific Plan?
A Specific Plan is a regulatory tool that local governments use to implement the General Plan and to guide development in a localized area. While the General Plan is the City’s overall guide for growth and development and the Zoning Code is the tool for regulating development in the entire City, a Specific Plan focuses on the unique characteristics of a special area by customizing the planning process and land use regulations to that area.
The regulatory purpose of the City IOF Specific Plan is to govern development and operations of oil and gas exploration and production activities within the 77.8-acre portion of the Inglewood Oil Field that is within the City of Culver City (i.e., the City IOF). The proposed City IOF Specific Plan would establish development standards that are tailored to the existing and potential future oil and gas drilling and production uses, reflective of the community concerns of Culver City and consistent with the City’s long-range planning objectives for the Blair Hills neighborhood and neighborhoods along the Jefferson Boulevard corridor.
Included in the Specific Plan document are land use objectives, infrastructure guidelines, development standards and regulations, environmental protection features, and implementation measures to ensure that potential continued oil and gas operations within the City IOF will be implemented in accordance with the goals and objectives established for the Specific Plan area, and consistent with the Culver City General Plan.
Q: How is the proposed City IOF Specific Plan (and Drilling Regulations) Project different than the City’s current oil and gas regulations?
The development concepts in the proposed Specific Plan include an approach to regulation of oil and gas drilling and production activities that takes into account the physical constraints of the City IOF and seeks to address outdated field management practices through replacement with comprehensive and updated practices that improve compatibility and safety as to the adjacent community uses. An emphasis is placed on overall consolidation of oil facilities and enhancing the physical interface between oil uses and other community uses by minimizing the overall visual appearance of well drilling and oil production activity through setbacks, screening and landscape requirements.
The procedural review process and recurrent monitoring and reporting requirements provided in the proposed City IOF Specific Plan would replace the outdated elements of the current regulations, set forth in Chapter 11.12, Oil, Gas and Hydrocarbons, of the Culver City Municipal Code (CCMC). The proposed Specific Plan would require that oil operations are comprehensively coordinated to proactively plan for and seek to minimize or eliminate potential adverse environmental impacts and establish protocols to reduce odor, visual incompatibilities, noise, and health concerns, while at the same time improving the overall safety of potential continued oil uses through appropriate safeguards, controls and best operating and management practices.
Q: How have the Draft Drilling Regulations, circulated for public input in April 2013, been applied or incorporated into the proposed Specific Plan?
In April 2013, Culver City released to the public the Discussion Draft Oil Drilling Regulations for the Culver City portion of the Inglewood Oil Field (the “Draft Drilling Regulations”). Following an informal public review and comment period, the City Council adopted (in June 2014) a resolution declaring its intention to initiate preparation of the Inglewood Oil Field Specific Plan for the City IOF.
Since June 2014, City staff has worked with a team of consultants to prepare the proposed (draft) City IOF Specific Plan and the related Draft EIR. Public comments received following release of the April 2013 Draft Drilling Regulations, including comments made during community meetings held on April 17 and July 11, 2017, have been considered while preparing the revised Drilling Regulations and the proposed Specific Plan. Revisions were made to the Drilling Regulations, which are incorporated as Appendix C of the proposed Specific Plan, to address comments received.
A “track changes” version of the Draft Drilling Regulations is available on the City IOF webpage showing changes made to the April 2013 version, which are reflected in Appendix C of the City IOF Specific Plan. The proposed Specific Plan and Drilling Regulations are also subject to the 180-day Public Review Period.
Q: Has the City already made a decision about oil drilling and oil uses in the Inglewood Oil Field or within the City?
No. Public input received at the public meetings and hearings, as well as written comments received during the 60-day Public Review Period, will be used to consider and refine the proposed City IOF Specific Plan (and related Drilling Regulations) and complete the Final EIR. A final decision, whether or not to certify the EIR and approve the proposed Specific Plan will be made by the City Council following a public hearing (on a date to be determined).
Q: Would oil drilling be allowed if the Specific Plan is approved?
The proposed City IOF Specific Plan would establish development standards regulating potential future drilling of oil, gas and injection wells. Under the proposed Specific Plan, the total number of newly drilled or redrilled wells that could be allowed would be limited to two per year during the first two years; and three per year thereafter (if approved by the Community Development Director), up to a maximum of 30 new or redrilled wells that could occur over a period of 15 years (assumed to range from 2018 through 2032). At the end of the 15-year drilling period under the Specific Plan, no additional wells could be drilled or redrilled. However, reworking of existing wells and other related operational and maintenance activities would be allowed to continue in accordance with the provisions of the Specific Plan prior to abandonment.
Q: Would hydraulic fracturing (or “fracking”), or other well stimulation activities, be allowed if the Specific Plan is approved?
The short answer is “maybe.” Ultimately, the City regulations affecting oil production and operational activities within the City IOF must be consistent with state or federal regulation. The proposed City IOF Specific Plan and draft Drilling Regulations presently leave open the option to establish limitations and/or restrictions on well stimulation treatments, including the use of hydraulic fracturing techniques. In taking action on the Specific Plan, the City Council will consider whether and upon what terms the Specific Plan and Drilling Regulations (if adopted), would allow Well Stimulation Treatments, including fracking, to be conducted within the Oil Field.
Well stimulation treatment refers to any treatment of a well designed to enhance oil and gas production or recovery by increasing the permeability of the sub-surface formation. Well stimulation treatments that have been utilized within the Inglewood Oil Field during the past decade include high-volume hydraulic fracturing (commonly known as “fracking”) and high-rate gravel packing operations. Conventional hydraulic fracturing has been conducted on 21 wells in the past at the Inglewood Oil Field, while high-volume hydraulic fracturing has been documented at three well locations since 2011. None of the high-volume hydraulic fracturing well locations are located within the City IOF.
The California Division of Oil, Gas, and Geothermal Resources (DOGGR) oversees the drilling, operation, maintenance, and plugging and abandonment of oil, natural gas, and geothermal wells in the state of California through standardized engineering practices for the purpose of protecting the environment, preventing pollution, and ensuring public safety. Consistent with its charge and as required by Senate Bill 4 (SB 4, approved by the Governor of California on September 20, 2013), DOGGR has established regulatory guidance and best practices for conducting well stimulation treatments, including hydraulic fracturing. SB 4 authorizes DOGGR to allow well stimulation treatments if specific conditions are met and following completion of appropriate review under CEQA.
For more information regarding the definition of well stimulation treatments (including the difference between conventional and high-volume hydraulic fracturing or “fracking”); the type of well stimulation treatments that have been used in the IOF to date; and the DOGGR’s role in regulating fracking operations, please see Sections 2.0, 3.0 and 4.5 of the Draft EIR.
The Draft EIR evaluates the potential environmental impacts that would be anticipated if high-volume hydraulic fracturing techniques, performed in a manner consistent with DOGGR’s SB 4 regulations as of July 1, 2015, and the site-specific requirements set forth in the draft Specific Plan, are allowed under the Maximum Buildout Scenario (i.e., the full extent of oil uses and activities that could be allowed under the proposed Specific Plan). The Draft EIR also evaluates a Project Alternative (Alternative 3, discussed in Section 5.0 of the Draft EIR) that would prohibit all well stimulation treatments, including hydraulic fracturing, within the City IOF. The Draft EIR provides a comparative analysis of allowing well stimulation treatments or not.
Section 32 (Well Stimulation Treatments) of the draft Drilling Regulations serves as a placeholder for the City Council to provide specific direction and/or clarify if or how well stimulation treatments and techniques, including high-volume hydraulic fracturing, may be regulated under the Specific Plan and within the City IOF. In taking action on the Specific Plan, the City Council will consider the available information, including the Draft EIR and the evaluation of Project Alternatives included in the Draft EIR, in making a determination as to whether and upon what terms the Specific Plan and Drilling Regulations (if adopted), would allow Well Stimulation Treatments, including fracking, to be conducted within the Oil Field. It is important to note too that activities that may be prohibited or limited in the City IOF would not necessarily be prohibited or similarly restricted in the County portion of the Inglewood Oil Field.
Q: Who prepared the EIR?
On April 13, 2015, the City Council approved a professional services agreement with BonTerra Psomas (Psomas) for the preparation of an Environmental Impact Report (EIR) for the Inglewood Oil Field Specific Plan Project. Psomas has been working with City staff to develop assumptions and project considerations that accurately reflect a potential “maximum buildout scenario” project that could be developed if the City IOF Specific Plan is approved. Psomas is under contract directly through the City of Culver City.
Q: What mitigation measures and/or oversight would be required and in place if the Specific Plan is approved and oil drilling allowed to continue?
The Draft EIR identifies mitigation measures to reduce the environmental impacts of the proposed City IOF Specific Plan Project. These mitigation measures are identified in each “topical” section of the Draft EIR (i.e., Sections 4.1 through 4.15), and listed, along with a summary of each potential impact, in the Executive Summary of the Draft EIR. If the Draft EIR is certified and the Specific Plan approved, the adopted Mitigation Monitoring and Reporting Program would specify the required mitigation measures and indicate the required timing and manner for which the mitigations would be implemented.
In addition, the proposed Specific Plan and Drilling Regulations would establish a rigorous monitoring and reporting program (as discussed in Section 5.11 of the draft City IOF Specific Plan) for compliance by the Oil Field Operator and that would be overseen by the City of Culver City.
Q: How is this project different than the County’s CSD project? And why is this project needed if the County already approved the CSD project?
In October 2008, the Los Angeles County Board of Supervisors adopted the Baldwin Hills Community Standards District (CSD) establishing regulations for oil and gas production activities in the County IOF. A CSD is a supplemental district used by the County to address special issues that are unique to certain geographical areas within the unincorporated area of the County. Following the approval actions of the County Board of Supervisors, the City of Culver City and other parties joined together in a lawsuit challenging the environmental review of the CSD. In July 2011, a settlement of the litigation was reached, referred to as the Settlement Agreement, which provided for enhanced regulations to protect the public health and safety and the environment of the communities surrounding the IOF. Although the City of Culver City at one time considered developing cooperative regulations with the County, that did not occur and the regulations set forth in the CSD and in the Settlement Agreement are only applicable to the County IOF, and do not apply to the City IOF.
In April 2013, Culver City released to the public the Discussion Draft Oil Drilling Regulations for the Culver City Portion of the Inglewood Oil Field (Discussion Draft Regulations), for public review and comment, to update and replace the City’s current oil drilling regulations. Although the provisions of the Draft Drilling Regulations and Draft Specific Plan are unique to the circumstances of the City IOF, its surrounding community and desired level of City oversight, many of the reporting and monitoring requirements are modeled in part from the County CSD regulations. In general, it can be stated that the level of regulation incorporated into the proposed Specific Plan and draft Drilling Regulations for the City IOF are as at least as protective as, and for some issues more environmentally protective, than the requirements under the County CSD.
Q: Can the Specific Plan be changed in the future? And if so, who is allowed to make changes?
The procedures for implementation and administration of the City IOF Specific Plan are presented in Chapter 5.0 of the Specific Plan. These procedures include a process for the consideration of potential amendments to the Specific Plan. The Community Development Director, or the City Council, would have the authority to make recommendations for amendments to the Specific Plan, or the Oil Field Operator could request an amendment, and the City Council shall make the final determination. Any such recommendation or request for amendment would require public notice, subsequent environmental review and a public hearing.
Q: What is the public’s role in the Specific Plan and input on the decision process?
The public’s role in the Specific Plan process and potential implementation is two fold. Prior to its potential adoption, the public’s role regarding the proposed Specific Plan is advisory through participation at public meetings and providing input on the various City IOF project planning stages and draft documents. Public input on the April 2013 Discussion Draft Drilling Regulations was one such example of public input in the decision process. The current review period for the draft Specific Plan and Draft EIR, during which the public may provide written comments, is another example.
If adopted, the Specific Plan (and Drilling Regulations) also includes provisions for community input for review and consideration of the initial Comprehensive Drilling Plan, and periodic but regular opportunities for community input (annually at a minimum) for the duration of the 15-year drilling period.
Q: What if the City Council does not adopt the City IOF Specific Plan (and Drilling Regulations)?
The current oil drilling regulations set forth in CCMC Chapter 11.12 (Oil, Gas and Hydrocarbons) would remain in effect. Oil drilling and oil and gas production activities are not specifically identified as permitted uses for any zone district in Culver City. However, CCMC Section 17.610.010.D provides that oil-related development within the City IOF is recognized as a legal nonconforming use allowed in the underlying zones. As a nonconforming use, and consistent with the City’s existing regulations, the oil drilling and production use would be allowed to continue within the City IOF, provided that Drilling Permits are first obtained as required by the provisions of CCMC Chapter 11.12, and including required environmental review.
Section 5.0 of the Draft EIR includes evaluation of the “No Project” Alternative (Alternative 1), which considers the potential environmental effects of a scenario under which the City IOF Specific Plan would not be adopted and the existing City regulations as set forth in CCMC Section 17.610.010.D and Chapter 11.12 would remain and continue to regulate the nonconforming oil uses.