By Jacob Klein
Phillips 66 is moving forward with plans to transition its Rodeo refinery from crude oil processing to renewable diesel, renewable gasoline, and sustainable jet fuel. Late in December, the company submitted a Notice of Preparation to Contra Costa County for the planned project, which they’ve branded Rodeo Renewed.
A Notice of Preparation (NOP) is the prelude to producing an Environmental Impact Report (EIR) as mandated by the California Environmental Quality Act (CEQA). It notifies the lead agency, in this case Contra Costa County, about the project and also invites community participation through public comments. NOPs are particularly important for community groups and environmental organizations because they allow us an opportunity to demand the EIR take into account the issues that we think need to be addressed: in this case, local emissions, feedstock sourcing, and job security for refinery workers, among others. Through a process called scoping, we can outline all the aspects we believe need to be answered for a complete EIR.
This is not an exceptional process, but the way that Phillips 66 has undertaken it is startling. The NOP was announced on December 21st, 2020, right before most people checked out for the holidays. The comment deadline was January 27th, 2021. Considering how unprecedented this project is and how complicated the technical aspects are, this didn’t allow much time for individuals to review the NOP and associated documents in order to submit comments that are as detailed as they could be. Nonetheless, the Chapter signed on to a letter enumerating as many areas of further exploration as could be identified.
Marathon Oil is also moving forward with the transition of its Martinez oil refinery to renewable diesel refining, posting its NOP on February 17th, 2021. A scoping meeting will be held on March 15th, at which the Contra Costa County Department of Conservation and Development will hear public comments on what should be considered for the Draft EIR. Public comments on the scoping process must be submitted by Monday, March 22.
While the Draft EIR for Phillips 66 isn’t expected until the end of 2021 or even early 2022, Marathon is hoping to have its permit in place — necessitating the full CEQA process to have been completed — by this summer.
Marathon has been meeting with various organizations and groups, including Sierra Club, to learn about areas of concern. This outreach will supplement, but not substitute, the CEQA process. Phillips 66, on the other hand, has not reached out to Sierra Club for a meeting — though this may have to do with the fact that we’re on opposite sides of litigation over the Richmond coal ordinance.
Much remains to be seen about the so-called renewability and sustainability of the fuels Phillips 66 and Marathon are proposing — questions that we and other environmental groups are still figuring out. One area of particular concern is feedstock. Although both companies tout their planned usage of used cooking oils, grease, and rendered fats as repurposing waste products, more and more it looks as if there may not be enough viable sources to make up the proposed production quantities. Therefore, soy oil (or other agriculturally tendered oils) will likely make up the bulk of the feedstock, begging questions about current availability, market chain displacement, monoculture agriculture, and possible deforestation — especially when foreign markets are brought into the mix. There are some who claim that these possible consequences of the transition will outweigh the potential of immediate greenhouse gas emission reductions from the refineries themselves.
As we plan for a carbon-free future, we must be judicious in considering our options while also holding firm. Certainly, transitions will be complicated and there may be compromises we’ll have to make our peace with. However, to support communities who have been impacted by the toxicity of petroleum-based fuels, and to fend off continued climate crisis, we must also be ready to push ourselves out of comfort zones and into spaces of radical imagining.
Photo credit: Soybean plant by Theo Crazzolara via Flickr Creative Commons.