September 13, 2013 Kristin Pollot, Associate Planner City of Pittsburg, Planning Department 65 Civic Avenue Pittsburg, CA 94565

Re: Comments on WesPac Pittsburg Energy Infrastructure Project, Recirculated Draft Environmental Impact Report (EIR) Dear Ms. Pollot: We, the undersigned, are writing to you as residents of Pittsburg and the Bay Area and on behalf of our organizations to express concern over the potential for grave environmental and public health impacts of the proposed WesPac Pittsburg Energy Infrastructure Project (WesPac), for which a Recirculated Draft Environmental Impact Report (DEIR) was issued on July 23rd, 2013. The Recirculated DEIR for this project is seriously deficient in its environmental analysis in many regards, including adverse impacts to air quality, public health, public safety, noise, general hazards and ecological risks, not only to residents of Pittsburg but also to the entire San Francisco Bay Area, especially including communities near refineries. The Final EIR must address these deficiencies and propose adequate and appropriate mitigation before this project can move forward. The Recirculated DEIR fails to address potentially significant environmental and community health impacts of the project in several significant ways. First, the specific characteristics of the crude oil that will be handled by the project are not discussed anywhere in the volumes of documentation on the proposed project. Without this information, it is impossible to accurately assess the potential increases in air pollution, elevated risk of accidents or increased health hazards associated with handling various types of crude oil. Second, the analysis does not include any discussion or analysis of the downstream impacts that could occur around refineries receiving new types of crude oil from the WesPac project. The region could see a sudden increase in the supply of dirtier, more dangerous crude oil, like Canadian tar sands. Third, the analysis does not consider the full range of potential hazards, and therefore greatly underestimates potential impacts. Independent market research has confirmed that new crude by rail terminals in the Bay Area are likely to import significant volumes of very low quality price advantaged (cheap) crude oil blends, including tar sands.1 This new crude supply could pose serious environmental and community hazards that the Recirculated DEIR fails to discuss or evaluate. Transporting and facilitating the refining of increased volumes of tar sands crudes, such as Western Canadian diluted bitumen, could present many additional and significant air quality, public health, safety and ecological and water quality impacts discussed below. Toxic Air Emissions: The diluent used to make heavy bitumen or tar sands flow into and out of railcars contains highly volatile organic chemicals including extremely toxic ones, like benzene at much higher concentrations than conventional crude oil. The additional toxic emissions would affect Pittsburg

See for example, reports by the Goodman Group and Dr. Phyllis Fox, July 1, 2013.

residents during transport to the proposed WesPac facility, as well as residents in communities around the refineries that ultimately receive the crude oil from WesPac. Strong Odors: Diluted bitumen (tar sands), or dilbits are associated with greater levels of strong odors due to their composition including a variety of sulfur containing compounds, such as mercaptans, at higher levels. However, the Recirculated DEIR dismisses concerns over odors based on anecdotal evidence from former workers at the tank farm asserting that there have been few complaints historically. There is no analysis of different types of crude oil that may be imported by the WesPac project or assessment of potential odors. Higher Risk of Accidents and Spills: Rail accidents have steadily become more common with increasing transport of oil by rail, with tragic results in a recent derailment in Quebec. The risk of rail accidents and derailments affect communities along the entire rail line leading to and including Pittsburg. Rail car spills of dilbit are also a threat to the fragile San Francisco Bay Delta. This is because the diluent typically natural gas condensates acting as a solvent helps the oil spread on surface waters. The diluent typically evaporates leaving the very heavy bitumen to sink, creating an exceptionally difficult and expensive clean-up. This was found to be the case in Kalamazoo, Michigan after a 2010 pipeline ruptured, releasing bitumen and causing welldocumented and widespread public health impacts and lasting contamination to this day (three years later). Dilbits are more corrosive than conventional crude oil, increasing the risk of leaks and accidents throughout the transport system and at refineries. For example, lower quality crude oil was found to be a contributing factor of the severe corrosion that led to the August 6, 2012 fire at Chevron Richmond. Additional Downstream Impacts around Refineries: Bay Area communities around refineries receiving new crude oil shipments from WesPac could experience elevated air pollution and associated health impacts asthma and other respiratory problems as well as cancer - due to the project, if dirtier crudes are transported. The heavy bitumen component of the tar sands oil, for example, contains many toxic constituents including heavy metals such as lead at much higher concentrations than conventional crude oil and which are likely to be released during the refining process. Dirtier crudes are also much more energy intensive to refine than conventional crude, due to the composition of heavier, longer chain hydrocarbons that require greater use of heaters, boilers, hydro-treating and cracking and greater hydrogen use. Essentially, refineries will have to run harder to process dirtier crudes, which would create greater emissions of smog- and sootforming pollutants and toxic chemicals. Refining dirty crudes like tar sands also leads to increased production of coke, a hazardous compound. This creates storage and disposal issues including the potential for coke dust from storage piles to impact nearby residents, as has been documented near the Marathon refinery in Detroit, Michigan. Underestimated Health Impacts: The DEIR underestimates the health impacts of the project by choosing the most favorable set of circumstances to model instead of acknowledging a range of conditions and crude oil characteristics. For example, the analysis only includes four toxic air contaminants related to crude oil vapors, despite the fact that there are dozens of toxic chemical constituents of crude oil. Further, the emissions analysis incorporates assumptions of clean technology without any commitment to or any mandate for such technology. For example, the DEIR asserts that marine vessels will use clean engines meeting US EPA tier IV standards; however, there are no tier IV standards that apply to large ships like oil tankers.

Undisclosed and Unmitigated Noise Impacts: The Recirculated DEIR also fails to fully consider the noise impacts of this project, which will include a significant increase in industrial activity in very close proximity to homes and other sensitive sites, like schools and churches. There is no discussion of horns and noise from trains; instead the document asserts that rail activity is exempt from local or regional analysis or mitigation. It is not clear whether trains and accompanying horns might operate at night and how frequently noise would occur. There is also no indication of whether church services may be disrupted by construction or other noise related to the Project; no mitigation is proposed. Further, there is no discussion of how often and for how long roadways might be blocked due to trains crossing and whether this could be a nuisance and potentially a safety issue to the nearby community. Vulnerable Populations in Close Proximity to Increased Pollution: In addition to substantial residential proximity to the proposed project, there are also many sensitive sites within one quarter of a mile of the proposed project including daycare and preschool facilities, schools, parks and churches (St. Peter Martyr School and Extended Care Facility, First Baptist Head Start, Parkside Elementary School, the Stewart Memorial Methodist Church, the First Baptist Church, City Park, Riverview Park and Marina Park). The Pittsburg area has already been identified by the Bay Area Air Quality Management District as a disproportionately impacted community with a pollution-vulnerability index within the highest 15% of the Bay Area. Thus the area is not a suitable location for increased industrial operations and increased air pollution. Due to all of the serious potential impacts from the WesPac project listed here, the lack of sufficient information to properly evaluate the project and the potential for serious and irreversible harm to Pittsburg and the greater San Francisco Bay Area caused by the import of exceptionally toxic substances through this Project, we urge the City of Pittsburg not to approve this project. At a minimum the City must revise and supplement the EIR to evaluate these impacts and all appropriate mitigation options before proceeding. The significant environmental and health impacts of this proposed project must be fully mitigated before it can be approved. We strongly urge your consideration of the comments and concerns submitted by expert agencies including the Bay Area Air Quality Management District as well as those discussed here. Sincerely, Greg Karras, Senior Scientist, Communities for a Better Environment Jessica Hendricks, Program Manager, Global Community Monitor Michelle Myers, Director, Sierra Club San Francisco Bay Chapter Jess Dervin-Ackerman, Chair, 350 Bay Area Adrian Badger, Owner, Steeltown Coffee & Tea and President of Old Town Pittsburg Business District Association Glenda Barnhart, Owner, Bay Area Bikes and Treasurer of Old Town Pittsburg BDA

Clay Wagers, Owner, Bay Area Bikes Christine Cordero, former long-time resident of Pittsburg Marilyn Bardet, member, Good Neighbor Steering Committee, Benicia Kathy Kerridge, member, Good Neighbor Steering Committee, Benicia Mary Frances Kelly-Poh, member, Good Neighbor Steering Committee, Benicia Constance Beutel EdD, member, Good Neighbor Steering Committee, Benicia Roger D. Straw, Resident of Benicia and Editor of The Benicia Independent Jill Ratner, Rose Foundation for Communities & the Environment Myesha Williams, New Voices Are Rising Angelo Logan, Executive Director, East Yards Communities for Environmental Justice David Schonbrunn, President, Transportation Solutions Defense and Education Fund (TRANSDEF) Margaret Gordon, Co-Chair, West Oakland Environmental Indicators Project Joel Ervice, Associate Director, Regional Asthma Management & Prevention (RAMP)