Knock LA

To Culver City City Council –

We are writing to provide public comment on the Inglewood Oil Field Specific Plan Project. We request the council implement the following:

• A 2,500 ft setback from residences and other sensitive land use

• At least a $2.5 billion disaster bond

• The requests made by Gabrielino/Tongva San Gabriel Band of Mission Indians and Wishtoyo Foundation to protect Tongva cultural resources

• The inclusion of a supplemental environmental justice analysis document in the final EIR

No doubt you will be receiving many public comments that explain the significance of the first three requests, so we’d like to focus on the last, the formal recognition of environmental justice in the form of a supplemental document in the Environmental Impact Report (EIR). Environmental justice is defined by California law as “the fair treatment of people of all races, cultures, and incomes with respect to the development, adoption, implementation, and enforcement of environmental laws and policies” (Government Code, section 65040.12). The pursuit of environmental justice arises from the unmistakable reality that some communities are disproportionately burdened by environmental harms and more vulnerable to the effects of those harms due to socio-economic marginalization.

While CEQA does not legally require that environmental justice be measured in an EIR for the type of project in question, there is still compelling legal precedent and ethical rationale for why Culver City should conduct the research required to include this supplemental document. Federally, the analysis of adverse human health or environmental effects on low-income or minority populations is consistent with the environmental justice guidelines in the National Environmental Policy Act (Council on Environmental Quality 1997). Statewide, the California Environmental Protection Agency is required by statute to “promote enforcement of all health and environmental statutes within its jurisdiction in a manner that ensures the fair treatment of all races, cultures, and income levels” (Pub. Resources Code, section 71110). At the city level, The City of Los Angeles General Plan has adopted environmental justice policies in the Framework Element and the Transportation Element (City of Los Angeles, 2002a). For your review, we have provided you with a few examples of environmental justice-related supplemental documents from environmental impact analyses of recent CA projects.

As a racial justice group, White People 4 Black Lives/Showing Up for Racial Justice LA is predominantly concerned about the high percentages of Black residents and patrons in the areas most impacted by the specific plan. We are particularly concerned about the communities of Blair Hills and Baldwin Hills, as well as the student population of West Los Angeles College who are majority people of color.

Please reference Figures 1 and 2. Within 400 ft of IOF Specific Plan AREA 1 is the southern section of the community of Blair Hills. 2010 US Census demographic data (per census block group) indicates that Blair Hills is approximately 30% Black. City-Data, a website which combine census data and citizen research, suggests that the specific subsection of Blair Hills closest to the oil field may have a much higher percentage (as high as 66%) of Black residents than the northern region. This claim is supported by the general racial demographic trend of the larger region. While the portion of Baldwin Hills on the southeast side of La Cienega Boulevard has a high to extremely high population of Black residents (ranging from 29% to 78%), the area to the northwest of La Cienega Boulevard has an extremely high Caucasian population (ranging from 52% to 76%), and a very low Black population (ranging from approximately 2% to 8%). Furthermore, it is undeniable that Blair Hills has a significantly higher Black population than the rest of Culver City, whose overall demographic is only about 8% Black. While Blair Hills may not technically qualify as an environmental justice community by CA EPA standards, according to environmental justice guidelines set by the US EPA Interagency Working Group on Environmental Justice, minority populations should be identified in an affected area when they are “meaningfully greater than the minority population percentage in the general population or other appropriate unit of geographic analysis.”

There is a growing body of scientific evidence to suggest that a 400 ft setback is incredibly insufficient to protect communities from the harms of oil fields. A newly released study from the LA Department of Public Health indicates that there are negative impacts of oil and gas still present at 1,500 ft. The study also indicates that when surveyed, a vast majority of expert scientists, public health professionals, and medical professionals believe a quarter-mile setback is the bare minimum necessary to protect communities from harm. Based on a detailed analysis of available research, a coalition of neighborhood and environmental groups known as Stand Together Against Neighborhood Drilling (STAND-LA) is currently advocating that the Los Angeles City Council adopt a 2,500 ft setback.

In accordance with the aforementioned scientific analysis, in addition to all of Blair Hills, the community of Baldwin Hills also falls within the range of harm of AREA 1. According to 2010 census data, Baldwin Hills has a high to extremely high percentage of Black residents (ranging from approximately 32% to 82%). While not within Culver City’s jurisdiction, because of its geographic proximity to the Inglewood oil field, this community stands to be impacted by Culver City’s decision in this case.

Furthermore, a portion of the West Los Angeles College campus is within 2,500 ft of the proposed IOF Specific Plan Areas. West Los Angeles College is predominantly attended by non-white students. According to their 2016 Student Profile, 87% of students are non-white, with over 44% identifying as Latinx and over 27% as African American. Again, while not within the jurisdictional boundaries of Culver City, the Culver City portion of the Inglewood oil field stands to directly impact the college because of its close geographic proximity.

While the bare minimum of the law in this particular case may suggest that a colorblind approach is sufficient, we believe that the City has an ethical responsibility to acknowledge and address racial inequities. We know that Culver City officials share this viewpoint, as Culver City is a member of the Government Alliance on Race and Equity (GARE), demonstrating a commitment to using a racial equity framework that articulates individual, institutional and structural racism. This a perfect occasion for the City to exercise such a racial equity framework and set precedent for the inclusion of environmental justice analysis in applicable government decision-making.

Submitted on behalf of the Environmental Justice Workgroup of White People 4 Black Lives (WP4BL). WP4BL is a white anti-racist collective and activist project of the Alliance of White Anti-Racists Everywhere (AWARE-LA) and operates within a national network of white anti-racists called Showing Up for Racial Justice (SURJ). WP4BL is rooted in acting in solidarity with Black Lives Matter: Los Angeles. For more information, visit www.awarela.org