VMT project is 75% undefined!
Fairness has been talked about a lot since last Monday’s Vallejo Planning Commission meeting (Feb. 27, 2017) and the request was:
“Finishing the EIR so people can judge it fairly.”
I talked with several people holding this view and it occurred to me that this request may be coming from missing a few pieces of key information.
I will do a quick summary first and then explain the details.
Summary:
The project as VMT/Orcem presented today (March 6, 2017) is only 25% defined (I will explain the details later) and VMT acknowledged it will take them a while to attract other tenants to fill the other 75% cargo capacity.
Spending more time and money now will not answer this “75% undefined usage problem”, and this 25% partial description will not satisfy the CEQA completeness requirement.
To be fair to everyone, and be CEQA compliant, we need a fully described operation (with 100% operation defined) with all impact considered as a whole.
” To be fair, we need a new DEIR to describe the full operation; not just 25% of it”
Details:
Some of the details here may have been known to you already but it is not common knowledge for many so I included them here for completeness.
* First is the difference between a port and a water-related industry usage.
A port moves cargo through it without processing it. (e.g. the privately owned Levin-Richmond Marin Terminal that ships coal out of Richmond, CA.)
A water-related industry is one using waterway to transport its raw material or products. (e.g. Orcem, Phillips 66, C&H Sugar, etc.)
* VMT’s original business plan is one Port + one water-related industry (Orcem) and they started the EIR process in 2012 based on this 1+1 configuration.
* In a letter dated Nov. 2 2015, BCDC (San Francisco Bay Conservation and Development Commission) stated that a port use of the site is not consistent with the Bay Plan and will likely not be approved.
BCDC Letter saying port use on this site is inconsistent with the Bay Plan.
* This is the reason that VMT dropped the phase 2 project as pointed out in the public hearing part of the last Planning Commission meeting (Feb. 27, 2017).
* In a letter dated March 25, 2016. BCDC noticed that Orcem will only be using 25% of the cargo capacity and questioned the usage of the other 75%.
25% used by Orcem. Who will be using the other 75% of capacity?
* This “port use is not consistent with the Bay Plan” and “Orcem is only using 25% of the cargo capacity” forced VMT to change their original business plan from 1+1 to 0 port + several water-related industries configuration (Orcem is just one of them).
* This new business plan of 0 + Many is a major departure from the 1 + 1 configuration originally planned and submitted, and now 75% of the project is not defined under this new configuration.
* In a meeting dated April 11, 2016, VMT acknowledged that it did not have any candidates in sight and it would take time to develop other water related industrial tenants for the other 75% cargo capacity.
* Who will be using this 75% unused Cargo capacity? Nobody knows! It could be three other business similar to Orcem.
Conclusion:
Project permit application should be rejected by the City.
Port use of the site is not consistent with the Bay Plan and it would take time for VMT to attract other water-related industrial tenants.
As it stands now (March 6, 2017), the project is only 25% described (by Orcem operation) and the other 75% is undefined.
It is not a matter of a month or two to attract other water-related industry tenants to have a complete description of the full operation of the site.
Asking for finishing the current EIR (which is based on one port + one water-related industry configuration) is a waste of time and money for everyone involved. (since now the new configuration is 0 port + several water-related industry tenants)
Applicants need to submit a totally new DEIR that is consistent with their new and current plan.