Santa Ynez Unit Resumption of Operations EIS

Commenters cite the 2015 Refugio spill record, internal corrosion data from Plains All American, and the 1987 vintage of the original pipeline to argue the proposed inspection regime is inadequate. Many request a hard requirement for replacement of Line 901/903 prior to any restart.

Concentrated technical critique of the lifecycle GHG methodology. Commenters target the use of a 3% discount rate for the social cost of carbon and the exclusion of downstream combustion emissions from the project's direct accounting.

NOAA-affiliated researchers and Channel-based whale-watch operators provide observation data showing increased blue and fin whale presence in the Channel since 2018. Commenters argue the DEIS underestimates baseline density and recommend a Level B harassment authorization.

The Santa Ynez Band and affiliated Chumash organizations support the FEIS pipeline reroute and tribal monitor program. They request formal co-management of the cultural resources management plan and a binding role in any future incident response.

Building trades councils, IPAA, and local chambers cite 1,840 direct and indirect jobs, $94M in annual county tax revenue, and the strategic role of California production in domestic energy security.

EPA Region 9 EJ analysis and resident comments highlight disproportionate exposure to processing-facility emissions in low-income census blocks. Concern centers on cumulative impact alongside the ExxonMobil refinery and El Capitán processing.

California Coastal Commission and several finance-focused commenters argue $1.4B is insufficient against a credible 2035 to 2040 decommissioning scenario. Requests for third-party cost validation and inflation-indexed bonds.

Academic and NGO commenters challenge the 30-mile cumulative impact radius as too narrow, particularly because Channel currents transport impacts to the Northern Channel Islands sanctuary.

Commenters argue the DEIS dismisses a phased decommissioning alternative without sufficient analysis, and that the four alternatives studied represent insufficient variation in operational scope.

Channel-based ecotourism operators, surf-tourism businesses, and the Santa Barbara Conference & Visitors Bureau cite the $2.1B regional tourism economy and the role of the post-spill recovery in current bookings.

Multiple NGOs and the California Attorney General's office object to the 75-day DEIS comment window as inadequate given the 1,840-page document. They challenge the no-additional-FEIS-comment posture.