Press Release - 08/21/24
August 21, 2024
Santa Barbara County Supervisors
105 East Anapamu Street, 4th Floor
Santa Barbara 93101
Via email: sbcob@countyofsb.org
RE: 2030 Climate Action Plan
Dear Santa Barbara County Supervisors,
We the undersigned representing thousands of County residents thank you for considering the updated Climate Action Plan (CAP), which outlines actions we can take to help meet the goal of reducing greenhouse gas emissions by 50% by 2030. However, there is a significant omission: The greenhouse gas (GHG) inventory excludes emissions from oil and gas facilities. We are writing to ask you to direct staff to include these emissions in the GHG inventory.
The draft CAP states that these stationary source emissions from oil and gas facilities are, “excluded because the County lacks primary regulatory control over many of these facilities.” (pg 22)
This is not an adequate rationale for exclusion because:
1. A GHG inventory should include all emissions, not just ones the County directly controls. The protocols for community GHG inventories are broad. For instance, “Any physical process inside the jurisdictional boundary that releases GHG emissions into the atmosphere” (ICLEI US Community GHG Protocols pg 15) or “emissions occurring as a result of activities and consumption patterns of the city” (Global Protocol for Community-Scale Greenhouse Gas Inventories, pg 29) CEQA Guidelines section 15183.5(a) requires that plans to reduce GHG emissions should “Quantify greenhouse gas emissions, both existing and projected over a specified time period, resulting from activities within a defined geographic area.”
2. To comply with CEQA, the inventory must be complete. For instance, in California Riverwatch vs. County of Sonoma, the court found that Sonoma County’s CAP violated CEQA in part because the “inventory of greenhouse gas emissions is based on insufficient information.”
3. The fact that there are State or Federal regulations that apply to the operation of these facilities does not negate the County’s ability to control emissions from their operation through its permitting authority. If emission sources the County primarily controls were the only ones included, there would be virtually no GHG inventory at all.
In fact, the CAP itself recognizes that the County influences these emissions. Page 40 of the CAP says, “The County does have a role to play in overseeing the oil and gas operations within its jurisdiction.” And on page 41 it gives examples of what the County and City of Los Angeles are doing to phase out oil. Another example is Ventura County which requires electrification and prohibits venting and flaring of gas if feasible — regulations that survived settlement with the oil industry and that will lower GHG emissions in the oil and gas sector.
Santa Barbara County regulates and permits oil and gas facilities. The County set a GHG threshold of significance of 1,000 metric tons CO2e and has considered emissions in permitting decisions. At the Board of Supervisors meeting on June 27, 2023 when the draft Climate Action Plan was last discussed, there was unanimous agreement that County actions have led to a decline in emissions from the sector.
The exclusion of oil and gas emissions is a continuing omission dating back to the 2015 Climate Plan that enables the County to avoid considering industry emissions, but it provides a false picture of GHG emissions in the County. Our long-awaited 2030 Climate Plan should be both ambitious and accurate. As the UN’s International Panel on Climate Change reports,”The evidence is clear: the time for action is now. We can halve emissions by 2030…The next few years are critical.” At this critical juncture, continuing to exclude and ignore a major GHG emissions source in the County is not acceptable.
Failing to include these emissions also makes the CAP non-CEQA compliant. Any county project that tries to rely on consistency with the CAP could be challenged based on this omission. This will unnecessarily delay and handicap climate actions and makes the time and expense spent on the CAP CEQA compliance thus far a waste. Please direct staff to include emissions from oil and gas production and processing in the GHG inventory in the 2030 Climate Action Plan and mitigation measures before it can be approved.
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