Dear Editor,
I am sharing my correspondence with the LA County Supervisors and Planning Commissioners in hopes of inspiring other Culver City residents to connect on this important issue.
Esteemed Supervisors and Regional Planning Commissioners:
Thank you for being exemplars of moral leadership, embracing your fiduciary responsibilities to protect our health and safety based on scientific evidence & ongoing practices in oil & gas production.
In supporting the amendments for the Baldwin Hills/Inglewood Oil Field CSD to coordinate with updating Title 22 Land Use & Planning regulations, please be sure to close loopholes & include economic & environmental justice costs in plugging wells.
1. Close this loophole: No new drilling must include redrilling operations also. Why? Redrilling from even one well borehole opens the space for many new wells to emerge laterally by shifting the drilling trajectory, thus creating more wells in different directions – in effect bypassing the intent of the proposed regulation re no new wells.
2. Environmental Justice demands plugging/abandonment costs be prepaid:
Is it morally just to have the people whose health & safety are daily challenged, then have to also pay clean-up costs of those who have been & are profiting from non-conforming land use?
The Baldwin Hills/Inglewood Oil Field is operating on a discretionary conditional use permit, thus it is only fitting that the upcoming revisions include operationalizing the ethics & moral values embodied in Our County Sustainability Plan.
In updating these regulations, consider factoring in costs of clean-up that put the costs where they are justifiably due, rather than by default having those who have suffered the effects of these oil field operations –> then also having to pay for others’ profiting.
The “Wild West” ethics of 1924 are no longer viable in 2024 & onward! Economically- just practices today demand that our Board of Supervisors be our Moral Compass in a world crying out for justice & equity.
A recent LA Times editorial (6/5/23) shows costs can range up to $1 million per well to properly plug. The article documents that “The oil and gas wells that fossil fuel companies are leaving unplugged and idle are a multibillion-dollar problem.” The article also notes that “less than 1% of the amount needed to decommission California’s oilfields has been set aside in bonds that can be used by regulators if companies go out of business or walk away.
And as ProPublica reporter Mark Olalde wrote, “Time is running out to rectify the funding shortfall.” The report estimates that $3.65 billion — or 58% of the remaining proceeds from existing wells — will be generated during the next two years.
In closing, if Operators & Owners cannot afford to put up a bond for each well’s conditional use permit requested, please include conditions such as the following as a basis for issuing forthcoming conditional use permits:
Designating a fund for the proper closure/abandonment & plugging of wells.
Fund it with the issuance of discretionary conditional use permits for non-conforming land use – charging a quarterly fee based on that quarter’s gross income from that permitted well’s production.
Hold the fees in an escrow account for the proper plugging of wells at its end of use.
If the operator plugged all of their company’s wells to State approved levels, return excess + interest due them.
Have an actuarial firm such as Deloitte (paid from this fund) be in charge of oversight & audits.
By justifiably placing costs where they belong, this will free up the County’s budget to better implement Our County.
In effect, YOUR DECISIONS can become a model and resource for CalGem to incorporate equitable economics that reflect fairness & justice.
Respectfully submitted,
Dr Suzanne De Benedittis, PhD
