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HomeMy WebLinkAboutAGENDA REPORT 1992 0115 CC REG ITEM 11El I ITEM ' / / E MOORPARK 799 Moorpark Avenue Moorpark, California 93021 (805) 529 -6864 J ^PARK, CALIFOPMA C; IY Council M Ming of ACTION: MEMORANDUM eG TO: The Honorable City Council BY FROM: Patrick J. Richards, Director of Community Developmen DATE: January 7, 1992 (CC meeting of January 15, 1992) SUBJECT: PACIFIC PIPELINE SYSTEM, INC. PROPOSED CRUDE OIL TRANSPORTATION PIPELINE Background On October 10, 1991, Pacific Pipeline System, Inc. submitted an application to the California Public Utilities Commission (CPUC) proposing a 170 mile long oil transportation pipeline that would extend from the Gaviota Marine Terminal to refinery locations in E1 Segundo and Wilmington. While the CPUC is Lead Agency, the proposed pipeline will traverse many city and county jurisdictions, all of whom have specific permitting requirements. Discussion The proposed pipeline will have a capacity of approximately 130,000 barrels per day. The primary proposed route, which does not enter the City of Moorpark's jurisdictional boundary will enter Ventura County within the Southern Pacific Transportation Company rights - of -way (ROW) along the coast to the Ventura area, where it will utilize an existing 22 inch pipeline for approximately 11.5 miles. The route would then follow the SPRR ROW to Piru, which generally parallels California State Highway 126. At Piru, the route would then follow former railroad or highway ROW to Santa Clarita. The alternate route (Southern Pacific Route) would continue on the SPTC ROW (instead of the SPRR ROW to Piru) near the Victoria Avenue interchange with Highway 101 at Montalvo. This alternative route would continue along the SPTC ROW through Montalvo, across the Santa Clara River floodplain, and through the City of Oxnard. From Oxnard, the pipeline would proceed through the cities of Camarillo and Moorpark. The ROW is adjacent to Oak Park on the border between the cities of Moorpark and Simi Valley. At the eastern city limit of Simi Valley, the route would leave the SPTC ROW and follow Santa Susana Pass Road. 01:07 :92 14:44pmA:\PIPELN&.MEN 1 PAUL W. LAWRASON JR. JOHN E. WOZNIAK SCOTT MONTGOMERY BERNARDO M. PEREZ ROY E. TALLEY JR. u..,.,. Mavor Pro Tern Councilmember Councilmember Councilmember The Resource Management Agency for the County of Ventura will be having a meeting at 9:00 a.m. on January 16, 1992 in Room 311 in the Administration Building at the Ventura County Government Center. The purpose of this meeting will be to discuss the proposed project in an effort to develop a common understanding of the CPUC process, to share information, and to determine how each jurisdiction or involved agency intends to proceed in terms of project review and permitting. A CPUC Prehearing Conference is scheduled for February 3, 1992 in Santa Barbara. Participation in this Prehearing Conference is essential for those jurisdictions desirous of securing legal standing in the case. Administrative Law Judge (Ryerson) will be presiding. To obtain legal standing in this case, it is necessary to attend this Prehearing Conference and file an "appearance" requesting status as an "Interested Party" to the proceedings for this application. "Appearances" can only be filed at a hearing or a Prehearing Conference. Each person making an "appearance" will have "legal standing" in the proceedings. "Legal standing" entitles each "party" to begin the process of discovery (written request for more information from the applicant to learn more about the factual basis which supports the position of the applicant). "Legal standing" provides each "party" with the ability to do the following: 1. Participate in all hearings, including evidentiary 2. Make data requests 3. Receive data requests from other parties 4. File testimony and present witnesses and exhibits 5. Cross - examine other witnesses 6. File briefs and comments regarding a proposed decision After the hearings, during which briefs and oral arguments are presented, the Administrative Law Judge will close the evidentiary hearings and will write a proposed decision. "Legal standing" also provides each "party" with the ability to: 1. Receive a copy of the proposed Administrative Law Judge decision 2. Submit comments pointing out errors 02:07:92 14:44pmA:\PIPBLM.MEM 2 After the Commission meets and vote on the case, legal standing further provides each "party" with the ability to: 1. Apply for a rehearing of the decision 2. Once the decision on the case is issued, file an appeal in the form of a petition for a "writ of review" with the California Supreme Court. Staff intends to send a representative to both the meeting at the County on January 16, 1992 and to the Prehearing Conference, on February 3, 1992. Recommendation Receive and File Attachment: Letter from County of Ventura dated 12/20/90 with attachments PJr /PP It 1 01:07:92 14:44pmA:\PZPELNE.MEM 3 RESOURCE MANAGEMENT AGENCY county of vEntura December 20, 1991 Moorpark Community Development Department Attn: Mr. Patrick J. Richards 799 Moorpark Avenue Moorpark, CA 93021 Re: Pacific Pipeline System Inc.'s Transportation Pipeline (CPUC Case Dear Pat, THOMAS BERG Agency Director -- RECEIVED — J A. 2 - sc22 City of Moorpark Proposed Crude Oil # A.91 -10 -013) As you are aware, Pacific Pipeline System, Inc. submitted an application to the California Public Utilities Commission (CPUC) on October 10, 1991, proposing a 170 mile long oil transportation Terminal to refinery destinations in Ei Segundo and Wilmington. While the CPUC is Lead Agency, the proposed project traverses many city and county jurisdictions, all of whom may have specific permitting requirements. This being the case, -I suggest it would be in our collective interest to work together in an effort to develop a common understanding of the CPUC process, to share information, and to determine how each of us intends regarding project review and permitting. To this end, I am writing to invite you and representatives of other affected cities to meet together on this important issue (list enclosed). I have taken the-liberty of setting a time and place for the first meeting: 9:00 AM on January 16, 1992 in Room 311 in the Administration Building, Ventura County Government, Center. In terms of preparation, your copy of the Proponent's Environmental Assessment will provide you with considerable information about the project. To advise you of our efforts to date, I am enclosing an information summary and project chronology. I am also writing to call your attention to the CPUC Prehearing Conference scheduled for February 3, 1992 in Santa Barbara. CPUC Project Manager Martha Sullivan (415- 703 -2126) has advised us that participation in this Prehearing Conference is essential for those who wish to secure legal standing in the case. Administrative Law Judge (Ryerson) will be presiding and, to obtain legal standing in this case, it is necessary to attend this Prehearing Conference and file an "appearance" requesting status as an "Interested Party" to the proceedings for this application. "Appearances" can only be Government Center, Hall of Administration Building, L » 1 700 © 800 South Victoria Avenue, Ventura, CA 93009 (805) 654 -2661 FAX (805) 648 -9212 Printed on RrCrded P ,3per Pacific Pipeline Project 2 December 20, 1991 filed at a hearing or a prehearing conference and it is recommended that this be done at the earliest possible stage: the Prehearing Conference. Each person /agency making an "appearance" will have "legal standing" in the proceedings and will be, thereafter, known as a "party" to the proceedings. Legal standing entitles each "party" to begin the process of discovery. Discovery is a written request for information made to the applicant or parties to learn more about the factual basis which supports that position of the participant. Legal standing provides each "party" with the ability to: 1) participate in all hearings, including evidentiary; 2) make data requests; Ile:G 4) file testimony and present witnesses and exhibits; 5) cross - examine other witnesses; and 6) file briefs and comments regarding a proposed decision. After the hearings, briefs and oral arguments are presented, the Administrative Law Judge will close the evidentiary hearings and will write a proposed decision. Legal standing also provides each "party" with the ability to: 1) receive a copy of the proposed Administrative Law Judge decision; and 2) submit comments pointing out errors. After the Commissions meet and vote on the case, legal standing further provides each "party" with the ability to: 1) apply for a rehearing of the decision; and 2) once a decision is issued, file an appeal in the form of a petition for a writ of review with the California Supreme Court. Should you wish more information on the CPUC process, I suggest YOU call the CPUC (415) 703 -252- and request the follo%,incJ tWO documents: Pacific Pipeline Project December 20, 1991 3 California Public Utilities Commission: Guide for PUC Intervenors; and State of California Public Utilities Commission: Rules of Practice and Procedure (January 7, 1989). The case planner, for Ventura County, assigned to the Pacific Pipeline Project is Lou Merzario who has recently joined the Planning Division staff from Santa Barbara County's RMD - Energy Division. -If you have any questions, please call Lou Merzario at (805) 645 -1389 or Tom Rooney (Pacific Pipeline System, Inc.) at (805) 658 -0742. Sincerely, Thomas Berg, Di ctor Resource Management Agency enclosures LM:PACIFIC \12- 20- 91.LTR ENCLOSURE 1 MAILING LIST DECEMBER 20, 1991 LETTER THOMAS BERG TO CITY PLANNING DIRECTORS Camarillo Planning and Community Development Department Attn: Mr. Matthew A. Boden P.O. Box 248 Camarillo, CA 93010 -0248 Fillmore Planning and Community Development Department Attn: Ms. Mary Ann Krause P.O. Box 487 Fillmore, CA 93015 Moorpark Community Development Department Attn: Mr. Patrick J. Richards 799 Moorpark Avenue Moorpark, CA 93021 Oxnard Community Development Department Attn: Mr. Richard J. Maggio 305 West Third Street Oxnard, CA 93030 Santa Paula Planning Department Attn: Ms. Joan E. Kus P.O. Box 569 Santa Paula, CA 93060 Simi Valley Planning Division Attn: Mr. D. James Peterson 2929 Tapo Canyon Road Simi Valley, CA 93063 Ventura Community Development Department Attn: Mr. Everett Millais P.O. Box 99 Ventura, CA 93002 Pacltic Pipeline project Chronology (cpUC Came • A.91 -10 -011) The scoping hearings are scheduled as follows: 02- 04 -92: Santa Barbara County Scoping Hearing (suggested time 10 AM) 02- 05 -92: Ventura County Scoping Hearing (Lower Plaza Assembly Room, 10 AM) 02- 06 -92: Los Angeles County Scoping Hearing (suggested time 10 AM) 02- 10 -92: San Francisco Scoping Hearing to provide an opportunity for anyone who happened to miss the other hearings (suggested time 10 AM) 4 12 -12 -91 Jeff Walker memo to Supervisors Lacey and Kildee advising them of the project proposal and the hearing schedule. 12 -12 -91 Martha Sullivan FAX to Lou Merzario transmitting a fact sheet regarding the CPUC decision making process. 12 -17 -91 Ventura County receives a copy of the RFP. 12 -17 -91 Ventura County receives a package of information from the CPUC which included a copy of: California Public Utilities Commission: Guide for PUC Intervenors; and State of California Public Utilities Commission: Rules of Practice and Procedure (January 7, 1989). 12 -18 -91 Lou Merzario met with Tom Rooney (PPSI) to discuss the project proposal and to clarify needs. After this meeting, the Planning Division met to discuss the proposed project and to identify and assign tasks. 12 -19 -91 Memo from Lou Merzario to the file documenting 12 -18 -91 meeting. 12 -20 -91 Letter from Thomas Berg (Ventura County Director of RMA) to the Planning Directors of the Cities of Camarillo, Fillmore, Moorpark, Oxnard, Santa Paula, Simi Valley, and Ventura. The proposed pipeline passes through each of these cities and the letter provides an information summary, this chronology and an invitation to participate in a meeting with County planners on 01- 16 -92. LM:PACIPIC \CHROMLCY Pacific Pipeline Project Chronology (CPUC case / A.91 -10 -013) 3 11 -26 -91 Robert E. Weiss letter to Judge Ryerson responding to SBCo's letter of 11- 21 -91. In this letter Weiss notes that he does interpret the SBCo 11 -05 -91 letter as meaning that SBCo "would consider assuming Lead Agency status if the PUC disclaims jurisdiction." 11 -27 -91 PPSI supplements the PEA with additional information (revised pages) 12 -02 -91 CPUC issues the Request For Proposal For An Environmental Analysis of The Pacific Pipeline Project (I.D. #PS -1227) - (RFP). (Received by Ventura County 12- 17 -91.) 12 -06 -91 PPSI supplements the PEA with additional information (revised pages) 12 -07 -91 CPUC (Martha Sullivan) letter regarding RFP and the firms requesting RFP information (list was enclosed). 12 -11 -91 Lou Merzario /Martha Sullivan telephone discussions regarding CPUC scheduled pre- conference hearings and public scoping hearings in February. 12 -11 -91 memo documents this discussion and the Lower Assembly Room was reserved for a public scoping hearing on 02- 05 -91. Two different types of hearings are scheduled for February. The first is scheduled for 02 -03 -91 in Santa Barbara and is referred to as a "Pre- Conference Hearing." The pre- conference hearing will be a formal proceeding with Judge Ryerson presiding where the CPUC will initiate the permitting process (testimony will be transcribed). At that time it is essential that Ventura County step forward and reauest "Party of Record" status in all CPUC considerations of the Pacific Pipeline System, Inc. Failure to do so will remove the County from the process loog.. At that time, we will also be provided the opportunity to advise Judge Ryerson of County permitting needs and any issues and concerns we have identified at that point. The filing of briefs and cross - examinations also take place at this hearing. The second type of hearing will provide an opportunity to make comments on the scope environmental document to be prepare. The County will also need to be prepared for and submit testimony (written or verbal) at this hearing. Pacific Pipeline Project- Chronology (CPUC Case / A.91 -10 -013) 2 11 -08 -91 SBCO letter to Gene Kjellberg (Ventura County) transmitting SBCols 11 -06 -91 letter to Judge Ryerson regarding application completeness. 11 -18 -91 Robert E. Weiss (attorney) letter to Judge Ryerson, challenging the PPSI assertion that this project is " intea- state" (within state), basing his challenge on specific case law. Specifically, he notes that the Pacific Pipeline would serve as a link between OCS facilities already defined as "inter- state" (between -states). As such, Weiss maintains that the Pacific Pipeline is also "inter- state" and therefore not within CPUC jurisdiction. Rather, he maintains the project applicant is "forum shopping" and that the project should be reviewed be a Lead Agency defined by that agency with the "greatest responsibility for supervising or approving the project as a whole." (CEQA Guidelines, para. 15050(b) . (Note: This is the letter that has created the perception that SBCo is trying to take over the project ) 11 -21 -91 CPUC letter to Peter W. Hanschen (attorney for the proponent) providing him with financial and securities information and advising him of the process to be followed prior to the granting of approval to issue stock. 11 -21 -91 SBCo letter to Judge Ryerson re: Robert E. Weiss' letter of 11- 18 -91. In this letter SBCo notes that Weiss misrepresents information contained in the 11 -05 -91 SBCo letter to Judge Ryerson. Specifically, SBCo had stated: "Should the interstate aspect of the transportation of OCS- produced crude to Los Angeles through the Pacific Pipeline System preclude the PUC from retaining jurisdiction on this project the County would. of course, reassess its role under CEOA " SBCo emphasized in this 11 -21 -91 letter that it believed Lead Agency status was a matter best left to the CPUC. 11 -21 -91 Exxon Company, USA letter from James P. Flynn to Norm Rooney (project proponent) noting that the approval of the Development Plan for Exxon's Santa Ynez Unit Project (SYU) was not based upon a commitment to build a pipeline to Los Angeles. M E M O R A N D U M TO: Pacific Pipeline Project Files FROM: Lou Merzario DATE: December 20, 1991 (updated with each entry) RE: Proposed Pacific Pipeline Project - Chronology and Correspondence (CPUC Case # A.91 -10 -013) 10 -10 -91 Pacific Pipeline System, Inc. (PPSI) submitted an application to the California Public Utilities Commission (CPUC) to build a 170 mile long pipeline along existing railroad rights -of -way from Gaviota in Santa Barbara County, through Ventura County, to Wilmington and E1 • Segundo in Los Angeles County. This application requests that the CPUC serve as Lead Agency during the environmental review and permitting process. At the time of application, PPSI also submitted a two volume Proponent's Environmental Assessment (PEA). 10 -10 -91 PPSI issues press release describing the proposed project 11 -05 -91 Santa Barbara County (SBCo) letter to Administrative Law Judge Victor Ryerson (who will be presiding on this case), requesting that all SBCo correspondence on this project be included in the formal files for the proceedings. SBCo pointed out that the PEA incorrectly described permitting requirements (also incorrectly noted for Ventura County) and noted their status as a Responsible Agency under CEQA. SBCo also proposed the use of a Joint Review Panel in order to better coordinate project review and the preparation of the environmental document ... the CPUC has rejected this suggestion. 11 -06 -91 SBCo submits, to the CPUC, detailed comments on the completeness of the PPSI application and comments on the PEA (the later are reflected in the Request for Proposals). 11 -07 -91 SBCo letter to Tom Rooney, project proponent, advising of the need for a Development Plan and a Conditional Use Permit (Planning Commission approval). Pacific Pipeline Project Information Summary Labor Force - participation in the Tri- County Socioeconomic Monitoring and Mitigation Program (SEMP) SUGGESTED NEEDS: Oil Spill Contingency Plan _ Emergency Response Plan Operations, Inspection and Maintenance Plan Abandonment Plan /Bonded Commitment Cost reimbursed field monitors /inspectors during /after construction and at least during the including initial operation of the pipeline. This topic warrants a coordinated review and possibly a single contracted inspection team for the entire project. OTHER-PERTINENT INFORMATION: Proposals in reply to the Request for Proposals are due 01- 03 -92. The Notice of Preparation of an Environmental Impact Report will be issued soon. An opposition group has formed, calling themselves the Coalition Against Pipelines and Pollution (CAPP). PPSI has already met with CAPP and will continue to do so in an effort to address their concerns. PPSI is also working with various interest groups -along the Santa Clara River area. It has been suggested that Ventura County invite the affected cities within the County to participate with the County in a Joint Review Panel in an effort to better coordinate our collective reviews, comments, and permitting needs. Lx:PACIFIC \INFO N Pacific Pipeline Project Information summary Operation of pig receivers /disposition of pig receiver wastes Inspection of pipe bending, laying and welding Future ROW uses preempted by this project (i.e., mass transit, among others). For example, a Supervisor's Task Force is currently working on the subject of future uses of the existing SPRR ROW along the Santa Clara River. Also, there is coordination currently underway regarding a proposed water line along the Santa Clara River to the City of Ventura -- Casitas to United. Operating temperature - are heater treaters needed? Clearing and grading of the ROW: determine how excavated material will be sifted to remove rocks or other material that could damage the pipeline tree removal (needs /permits) temporary diversion of streams (needs /CDF &G permits) 5 waste disposal sites and types /amounts of waste generated top soil salvage to protect riparian vegetation and previously undisturbed areas (the later being minimal) Public Services: water districts and emergency service providers such as the Environmental Health Division and Emergency Services which would serve the pipeline area fire fighting and toxic clean -up capabilities /facilities offered by the emergency service providers, including response times upgrades to existing services that are required for or as a result of the proposed project Construction disruption to: existing commerce neighboring homes transportation and traffic construction staging and storage areas Pacific Pipeline Project Information Summary 4 PARCEL INFORMATION NEEDS AT THE TIME OF PERMIT APPLICATION: In addition to a CUP application, we will need a cost reimbursement agreement, an Assessor's Parcel list (including the General Plan designation, zoning and surrounding parcels for notification), and a Legal Lot determinations for all lots associated with the permit request. In the interim, PPSI entered into a pre - submittal agreement with Ventura County on December 20, 1991 which enables review by the various County agencies. INITIAL PROJECT RELATED ISSUES: (Full County review is needed to identify the scope project related issues. The listing below is preliminary and far from complete.) Jurisdiction and applicable plans, policies and permits Environmental effects: Air quality during pipeline operation (especially at the pump station) Sensitive habitats, streams and wetlands Construction equipment emissions, noise and dust Visual Disposition /treatment of hydrostatic test water Safety: Especially seismic safety, flood and channel scour Pipeline safety within railroad ROW Hydrostatic testing Operation - potential for spills and resulting impacts Risk of upset Condition of the existing 22" pipeline which was constructed in 1969 - need to determine whether the existing pipeline is up to current engineering specifications and, if so, whether it will be sufficient through the expected life of the Pacific Pipeline. If not, we need to determine what is needed /recommended. Pacific Pipeline Project Information Summary Engineered for seismic and other hazards (the adequacy of which has yet to be evaluated) A pipeline depth of 5 feet is proposed in the PEA ALTERNATIVES TO THE PACIFIC PIPELINE PROPOSAL: All- American Pipeline Four Corners Pipeline Company Line 90 Reversal and Line 63 Cajon Pipeline Angeles Pipeline (this pipeline proposal failed once before) VENTURA COUNTY COASTAL AREA PERMITTING: This project is not exempt under Section 30610 of the Coastal Act. Division 8, Chapter 1.1 of the Coastal Zoning Ordinance clearly indicates this project requires a: Conditional Use Permit (Sec. 8175 - 5.7.1); Development Plan (Sec. 8175- 5.7.7); and Grading Plan (Sec. 8175 - 5.7.7). The "matrix" notes that a "pipeline" requires a Conditional Use Permit (Planning Commission approval) in zones COS, CA, CR, and CM and is not permitted elsewhere (matrix). Note: Other agencies or departments may impose requirements (e.g., a Business Plan must be.filed with the Environmental Health Division and the Fire Department will have permitting requirements). NON - COASTAL AREA PERMITTING: 3 Division 8, Chapter 1, Section 8105 -4 of the Planning and Development Ordinance notes that a "pipeline" requires a Planning Director Approved Conditional Use Permit in all zones but C1 where pipelines are not permitted (matrix). Section 8107 -5.5.5 provides specific guidelines for oil pipelines. Note: Other agencies or departments may impose requirements (e.g., a Business Plan must be filed with the Environmental Health Division and the Fire Department will have permitting requirements). Pacific Pipeline Project Information summary L route would continue along the SPTC ROW through Montalvo, across the Santa Clara River floodplain, and through the City of Oxnard. After leaving Oxnard, it then would proceed through cities of Camarillo and Moorpark. The ROW is adjacent to Oak Park on the border between the cities of Moorpark and Simi Valley. At the eastern city limit of Simi Valley, the route would leave the SPTC ROW and follow the Santa Susana Pass Road. This. •route would involve the construction of Lagol Pump Station between Oxnard and Simi Valley (centrifugal pumps). Estimated cost = $215 million Construction time = estimated 18 months (proponent estimates the pipeline could be operational in April or May of 1994) Anticipated tariff = $2.25 per barrel Pipeline heating = the proponent proposes none The lack of pipeline heating has come into question. The PEA assumes a Gaviota oil temperature of 140° F. However, the All- American Pipeline (AAPL) is currently receiving crude at no higher than 125° F which is already somewhat of a compromise. Though, AAPL would like oil to be delivered at 130° F or higher, Chevron has been trying to lower the temperature of the deliverable crude to try to facilitate other oil processing plant processes. This raises questions about the PEA assumed 140° F temperature of oil, delivered at Gaviota. System Safety: PPSI proposes to install a Supervisory Control and Data Acquisition (SCADA) system in order to detect leaks and affect pipeline shutdown should leaks occur. It is essential that this system include duplicate system controls and an uninterrupted power supply. Also, since the SCADA communications system is via microwave and satellite dish, there may be other and possibly off -site permitting requirements (and possibly visual impacts). SCADA will be controlled via pump station interrogation may wish to evaluated whether more locations are needed (i.e., at each block valve). Cathodic protection and internal inspection Block Valves: Proposed Route = 10 ( ?) Sea Cliff = 1 Alternative Route = 13 ( ?) Sea Cliff = 2 Check Valves: Proposed Route = 12 Alternative Route = 9 ENCLOSURE 2 PACIFIC PIPELINE SYSTEM, INC. PROPOSED CRUDE OIL TRANSPORTATION PIPELINE CALIFORNIA PUBIC UTILITIES COMMISSION (LEAD AGENCY) (CPUC CASE # A.91 -10 -013) INFORMATION SUMMARY December 19, 1991 - information summary is subject to update PACIFIC PIPELINE PROJECT PROPOSAL: Application_ and Proponent's Environmental Assessment filed with the California Public Utilities Commission (CPUC) on 10 -10 -91 for the following: Crude oil transportation pipeline, routed largely on existing Southern Pacific Transportation Company rights -of -way (ROW) 170 miles long, providing a link between the Gaviota Marine Terminal and refineries in E1 Segundo and Wilmington "Common Carrier" status, though the pipeline is expected to largely serve the crude oil transportation needs of the Point Arguello and Santa Ynez Unit project. The Point Arguello Project has named the Los Angeles area as its refinery destination of choice and the Santa Ynez Unit Project has expressed similar interest in Los Angeles area refineries. 158.5 miles of new 20" (OD) pipeline and 11.5 miles of existing 22" (OD) pipeline in the County of Ventura and the City of Ventura (constructed in 1969) 130,000 barrel per day capacity Proposed Ventura County route: Entering the County within the SPTC ROW along the coast to the Ventura area, where it would utilize an existing 22" (OD) pipeline for about 11.5 miles. The route would then on the SPRR ROW to Piru, which would generally parallels California State Highway 126. At Piru, the route would follow former railroad or highway rights -of -way to Santa Clarita. This route would involve a construction of Keith Pump Station at Fillmore (centrifugal pumps). Alternative route (Southern Pipeline Route): Instead of using the SPRR ROW to Piru, the route would continue on the SPTC ROW near the Victoria Avenue interchange with Highway 101 at Montalvo. This alternative