B-2 Permit Compliance Effectiveness Process
In the mid-1980s, the County approved five major projects for production,
processing, and transporting offshore oil and gas, including the Point
Arguello, and Santa
Ynez Unit projects, the Gaviota
Interim Marine Terminal, and the All
American Pipeline. Each project carried many permit conditions
designed to eliminate or reduce significant impacts to public health
and safety and the environment during the project's construction and
operations. Several innovative tools evolved either to implement or
to monitor and enforce these permit conditions.
The "B-2 provision" in each discretionary
permit (also called the II-2 provision for Santa Ynez Unit project)
instituted a process to evaluate the effectiveness of the permit
conditions in mitigating adverse impacts to the environment over
the project's life. It also evaluates the extent to which a permittee
has complied with all requirements of the permit. The County may
impose additional reasonable conditions to mitigate impacts if existing
permit conditions are inadequate or recently proven technological
advances provide substantial additional mitigation not available
when the project was initially approved.
B-2 evaluations differ in level of effort, depending upon the complexity
of a project and the extent to which permittees have complied with
conditions. Each evaluation typically begins with a preliminary
screening analysis to determine which conditions of the permit are
achieving their intended purpose. Conditions not determined to be
achieving their purpose are then subject to further in-depth analysis.
The County may then select to modify the conditions, or its enforcement
of the condition, should this second round of analysis reveal that
any condition is not achieving its intended purpose. The findings
of each review are subject to a hearing before the Planning Commission.