email to BART board re: surveillance technology (again)

For the BART Board meeting of August 9th, 2018, in reaction to recent stabbings on BART, the BART police have submitted a proposal with just three days’ notice of a kind of dragnet system similar to the DAC that activists successfully opposed a couple years ago.

I wasn’t able to make the 9am meeting, but sent in the following email comment.

Subject: don’t rush proposed surveillance technology

I understand that people are on edge from recent attacks on BART. But we should not rush into adopting new surveillance technologies without a proper period of consideration and public comment, especially not before passing a surveillance transparency ordinance.

Continue reading “email to BART board re: surveillance technology (again)”

Comments on the scope of the WesPac EIR, part 2

August 7th, 2015 – my second email submitting comments, focusing on climate change. Part one focuses on more local and regional issues.


This is the second part of my comments on the scope of the WesPac RDEIR, focusing on climate change, both the project’s effect on climate change and the effects of climate action on the project’s purpose and long-term viability.

Preface

It is not merely the manner in which the proposed WesPac project would operate that is a problem; it is its very existence itself. The purpose of the project is to increase the flexibility and capacity of the petroleum industry. It is likely to, however marginally, increase production of and reduce the costs of fossil fuels, and thereby increase the global use of those fossil fuels. And that is precisely the problem.

In a public comment of September 13, 2013, I said the following:

Even if the facility operated flawlessly, however, it would contribute to the increased global use of fossil fuels, which generates greenhouse gases that through climate change endanger our physical infrastructure, our health, our environment, and potentially the very viability of human civilization.

It is imperative that we change our energy system. To start with, we must insist on NO MORE FOSSIL FUEL INFRASTRUCTURE.

There is simply no excuse to do otherwise; any statement of environmental impact that claims low impact for additional fossil fuel infrastructure and allows its construction is extremely irresponsible.

Two years later that comment is, unfortunately, still valid. My claim that the very viability of our civilization is endangered is far from being an exaggeration. The climate change that is already “locked in” will strain our ability to adapt. The very material bases of our civilization are under assault: changing weather patterns mean that agriculture will be increasingly difficult, sea-level rise threatens many cities and much infrastructure, and more heat waves, storms, and cold spells mean more property damage and fatalities in the years ahead.

Continue reading “Comments on the scope of the WesPac EIR, part 2”

Comments on the scope of the WesPac EIR, part 1

August 7th, 2015 – my first email submitting comments, on issues other than climate change. Part two focuses on climate change.


In this document, I am listing all comments on the scope of the WesPac 2015 RDEIR other than those related to climate change.

Pipeline and tank integrity issues

When I refer to “pipelines”, I mean both the pipelines fully internal to the site, as well as the external pipelines that connect to the regional refineries and other distribution networks.

Please include detailed information about the age of all tanks and pipelines. Which of these tanks will be refurbished?

What are the limits of vapor pressure that the tanks and pipelines can handle? How does this compare to the known very high vapor pressure of Bakken shale oil?

What other effects does crude type have on pipeline or tank integrity? For example, both tar sands dilbit and Bakken shale are likely to be more corrosive than fuel oil or other crudes, and the more viscous tar sands dilbit is likely to be pumped at higher pressure than other crudes. Tar sands dilbit is also often heated to get it to flow; how does this affect pipeline integrity? It could increase corrosion and it could also increase wear-and-tear from thermal expansion and contraction.

The Mayflower spill in Arkansas was a result of the rupture of Pegasus, a 65-year-old pipeline that was intended for refined products. Exxon 1) reversed the flow and 2) sent more corrosive tar sands dilbit down the pipe 3) at high pressure. All three actions stressed the already quite old pipeline; together, they weakened it enough to rupture it.

Continue reading “Comments on the scope of the WesPac EIR, part 1”

Notes from WesPac EIR Scoping Session, 2015/07/22

WesPac is back. The proposal for an oil terminal in Pittsburg, CA has been modified, dropping the rail component. It would include a marine terminal, lots of oil storage, and pipelines to Bay Area refineries. The storage tanks are within 200 feet of homes, and there are churches and schools nearby as well.

A new EIR will be prepared, and there was a scoping session on July 22nd. Comments on the scope of the EIR will be taken until 5pm on Friday, August 7th, 2015. I took some rough notes from the scoping session.

A couple of City staffers and a representative from TRC, the consulting company doing the EIR, spoke. The purpose of the scoping session, they said, was 1) to educate the public about the process and 2) to take public comment. Significantly, the public comment was supposed to be on the scope of the EIR, and not supposed to be about the merits of the project itself. Nevertheless, many speakers did share their opinion on the project as a whole. After public comment, the TRC rep said there had been two kinds of comments: 1) impacts of the EIR, and 2) opinions. He said, “Please let your decisionmakers (City Councilmembers and Planning Commissioners) know your opinions.”

The rep introduced the rationale for the project: a California Energy Commission determination that there is a shortage of crude oil storage in the Bay Area, coupled with an increase in oil imports, and ship congestion at existing terminals. None of this holds water – the CEC determination is from several years ago, there are plenty of marine terminals at existing refineries, and in any case, California gasoline and diesel use is declining.

Public Comment

I took brief notes on each speaker. Public comment lasted about two hours. Unfortunately, the City did not provide video recording or a stenographer – they had a staffer take notes on an easel pad. I will be submitting these notes.

Continue reading “Notes from WesPac EIR Scoping Session, 2015/07/22”

Public Comment to the EPA on the Clean Power Plan

The folks over at 350 Silicon Valley have made a web page that explains really easily how to send a letter to the EPA regarding the Clean Power Plan (the plan to limit climate-related pollution from coal plants). Their aim is to send 1000 letters by the deadline of December 1st – and they already have almost 800!


 

November 12, 2014

To Whom It May Concern:

I support the Clean Power Plan and recommend that it be made as strong as possible.

Everything the climate science tells us is that things are worse than we thought: our impacts are greater, our limits are lower, than we thought just a few years ago.

There are several possible “tipping points” that we may cross soon regarding global warming that could make our planet toxic to most life as we know it.

It is imperative that we address climate change with drastic and immediate measures, harshly limiting the use of all fossil fuels, from coal to natural gas.

Please do everything in your power to curtail the use of fossil fuels and promote renewable, clean energy.

Sincerely,
Martin MacKerel

Letter to Kern County Board of Supervisors on crude-by-rail project and refinery re-opening

Apparently Kern County wants to increase crude-by-rail and re-open a refinery. That’s a horrible idea, since we need to start closing refineries and move to all clean energy, immediately. Here is my letter of comment, sent through an action page hosted by the Center for Biological Diversity.

Comment

Subject: Reject the Alon Bakerfield Project
You would do well to read California Attorney General Kamala Harris’s January 15th, 2014 letter to the City of Pittsburg, CA regarding a proposed crude-by-rail terminal there. Many of her concerns apply to this project, including:

  • the issue of cumulative emissions on an already highly-impacted community,
  • the increased and novel risks of transporting extreme crudes such as diluted tar sands bitumen and Bakken shale oil, and
  • the effects that new fossil fuel infrastructure may have on California’s ability to meet its own (legislated) greenhouse gas emissions goals.

The full letter is available at http://pittsburgdc.org/?p=655

To protect our climate and meet California’s greenhouse gas emission goals, we must not build any more fossil fuel infrastructure. Period.

Martin MacKerel

Update

The letter can be found at https://www.scribd.com/document/200688980/Letter-from-Kamala-Harris-CA-Attorney-General-to-Pittsburg-regarding-the-WesPac-EIR

Public comment on "Refining Emission Tracking Regulation" aka the fossil fuel industry is dying

The “Refining Emission Tracking Regulation” is a proposed rule for the Bay Area Air Quality Management District. Some groups are trying hard to make sure that it requires reporting of the types of crude oil the refineries take in. I agree with this goal, as you can see from the letter below.


 

February 21st, 2014

To: Stationary Source Committee
Bay Area Air Quality Management District
939 Ellis Street
San Francisco, CA 94109

Re: Comments on Petroleum Refining Emission Tracking Regulation, Greenhouse Gas Emissions, and the Regional Climate Action Strategy

As you are no doubt aware, in November the Board passed a Climate Action Resolution (Resolution No. 2013) committing to a goal of reducing greenhouse gas (GHG) emissions to 80% below 1990 levels by 2050.

Very few people have grappled with the enormity of this task. As luck would have it, just last night I was beginning to prepare for a presentation on the topic and I started working on a graph to illustrate the problem. I am not pleased with the aesthetics of the graph, but I am including it on the following page because it’s the best thing I have on hand at such short notice (I found out about this meeting and the submission deadline just a couple hours ago).

A picture is worth a thousand words, but a poor picture requires a few dozen words for clarification.

Although the graph is lightened only from 2014 onward, it is based on BAAQMD’s 2010 report, so the 2011 and 2014 numbers are projections. Nevertheless, you can see that BAAQMD was assuming a linear increase in all sources of greenhouse gases.

The thick black line goes from the 2014 point to Executive Order S-3-05’s 2020 goal (matching 1990 levels) and then to the 2050 goal. The most important point to take away from this graph is that today’s refinery emissions are by themselves almost as high as the 2050 goal for all sources.

It is clear that along with other sectors, the refineries must decrease their GHG emissions. Unlike other sectors, however, a large proportion of refineries’ emissions are inherent to the core function of the industry.

The Bay Area refinery industry will have to contract, not only to meet the lower regional emissions caps, but also because of reduced demand of fossil fuels due to other sectors reducing their GHG emissions.

It is important that BAAQMD keep a very close eye on refineries’ GHG emissions, and one of the most important determinants of their emissions is the type of crude oil (aka feedstock) that the refineries take in. BAAQMD must recognize that the Refinery Emission Tracking Regulation is a key tool to meet its own Climate Action Resolution and will be part of the Regional Climate Action Strategy currently being developed.

For this reason the Refinery Emission Tracking Regulation should be as thorough as possible, it should include reporting and monitoring of refinery feedstock as well as strong punishments for misreporting, and it should be enacted reasonably quickly.

Yours,
Martin MacKerel

Update (2018-09-06)

Four and a half years later, BAAQMD has failed to implement any such regulation.