15. Plaintiff seeks damages, restitution, contribution, and any and all other relief  the Court deems proper related to provable lost profits due to Defendant’s  failures and violations.    43. According to a report prepared in 2013 for Visit Santa Barbara by Destination  Analysts, Inc. entitled Visit Santa Barbara – Santa Barbara South Coast  Visitor Profile Study, (the “South Coast Report”), approximately 6.1 million  individuals visit the Santa Barbara South Coast annually. The South Coast  Study found that this results in direct visitor spending of at least $4.0 Million,  the generation and support of more than 12,000 jobs, and an annual generation  of at least $46 Million in tax revenue. 10    58. Plaintiff realleges and incorporates by reference all allegations contained  herein as if fully set forth herein.    59. Plaintiff brings this action, on behalf of itself and all others similarly situated  (the “Class”).    65. Plaintiff realleges and incorporates by reference all allegations contained  herein as if fully set forth below.   66. The Federal Oil Pollution Act defines a responsible party as including “any  person owning or operating a pipeline.” (33 U.S.C. § 2701(32)(E)). At all  relevant times, Defendant has owned and operated Line 901, AKA the Failed  Pipeline, qualifying Defendant as a responsible party under the Federal Oil  Pollution Act.    67. Defendant also qualifies as a responsible party under the Federal Pollution Act  as a transporter of petroleum and petroleum byproducts via acceptance for  transport of oil by way of the Failed Pipeline. Defendant also dictates the  destination of this transport.    68. The Federal Oil Pollution Act defines facility expansively, and includes any  device used for “producing, storing, handling, transferring, processing, or  transporting oil.” (Id. at (9)). Line 901, AKA the Failed Pipeline, qualifies as a  facility under the Federal Oil Pollution Act.    69. Defendant is both the owner and operator of a facility for purposes of the  Federal Oil Pollution Act.    70. Defendant’s Failure described herein, specifically its failure to adequately  maintain, oversee, replace, repair, monitor, or operate the Failed Pipeline,  caused the discharging, spilling, leaking, pouring, omitting, and releasing of  oil from the Failed Pipeline into the surrounding environment, including the  Pacific Ocean.    77. Plaintiff realleges and incorporates by reference all allegations contained  herein as if fully set forth below.    78. Defendant is a responsible party as defined in Ca. Gov. Code Section  8670.3(w) because Defendant is the transporter of oil and Defendant is an  entity that accepts responsibility for oil and its transport.    79. Oil is defined within the Act to include “any kind of petroleum, liquid  hydrocarbons, or petroleum products” (Cal. Gov. Code 8670.3(n)), which  Defendant accepted for transport and determined the destination facility.    85. Plaintiff realleges and incorporates by reference all allegations contained  herein as if fully set forth below.    93. Plaintiff realleges and incorporates by reference all allegations contained  herein as if fully set forth below.   94. Plaintiff is informed and believes, and thereon alleges, that Defendant’s Failed  Pipeline caused sudden and accidental releases of petroleum and petroleum  byproducts and associated hazardous substances into the surrounding  environment, which was then able to travel towards and onto Refugio Beach  and surrounding beaches and into the Pacific Ocean. It is estimated that the  contamination plume has spread multiple miles down the coastline. As a direct  and proximate result of Defendant’s sudden and accidental releases due to  Defendant’s negligent oversight, supervision, monitoring, repair, replacement,  and/or operation of the Failed Pipeline, the tourism industry in Santa Barbara  County has and will continue to be negatively impacted.    95. Defendant, particularly in dealing with hazardous substances, owed a duty to  Plaintiff and other members of the community to exercise reasonable and  ordinary care, which it failed to do with respect to Defendant’s negligent  oversight, supervision, monitoring, repair, replacement, and/or operation of its  Failed Pipeline.    96. Defendant breached its duty by negligently causing, permitting, failing to  abate, and/or contributing to the contamination described herein.    NEGLIGENCE   STRICT LIABILITY DUE TO ULTRAHAZARDOUS ACTIVITIES   STRICT LIABILITY UNDER CAL. GOV. CODE § 8670, ET SEQ.    VIOLATION OF OIL POLLUTION ACT OF 1990, 33 U.S.C. § 2701, ET SEQ.  