PO - PORT OF OAKLAND
We refer the commentor to pages 4.1.5 and 4.1.6 of the Initial Study where the document clearly indicates that the Port of Oakland Commissioners have land use jurisdiction over Port of Oakland property. For further discussion, see response to PO-3.
As stated in the fifth paragraph of page 4.9.10 of the Initial Study, "PG&E has agreed to be responsible for any legally required remediation of existing contaminated soil and groundwater at the divested plants and therefore will be responsible for remediation activities that are part of the ownership transition." The commentor notes that on page 4.9.4 of the Initial Study, the Phase I report for the Oakland Power Plant identified 15 environmental concerns and nine impaired conditions. The Oakland Power Plant Phase II Report (Fluor Daniel GTI, 1997c), now available, shows that, for the most part, these environmental concerns and conditions are either not significant or pose no unacceptable risks to current site workers or future construction workers. The Phase II report further indicates that there are five environmental concerns at the plant site which may require remediation. Specifically these are petroleum hydrocarbons in soil and groundwater, lead in shallow soil, elimination of horizontal conduits with potential for transport of groundwater and stormwater runoff, PAHs in shallow soil, and cyanide in soil and groundwater. All of these issues and information related to them will be passed on to prospective new owners as part of the due diligence process. Also see response to PG&E-5
With regard to the commentor's issue regarding the environmental effects of repowering, the purpose of the Initial Study was to assess the impacts of the proposed divestiture. As stated on page 3.5 of the Initial Study, it is not foreseeable that repowering would occur with divestiture in any manner differently than without divestiture if the plants were retained by PG&E. Thus, repowering is not considered to be part of, or a result of, the project. As noted on page 3.2 of the Initial Study, if the Oakland Power Plant is purchased, the new owner may determine that modifications to the plant are needed. However, the same would apply to PG&E if it were to continue ownership of the facility, as discussed thoroughly in section 3.4 of Attachment C to the Initial Study. If either a new owner or PG&E decide to modify the plant, it must comply with applicable regulations, including environmental review. Based upon the type of modifications requested, either the Port of Oakland or the California Energy Commission (CEC) would be the CEQA Lead Agency. In any event, any changes proposed would be evaluated at the time an application for such changes were presented for consideration by the owner of the plant. Therefore, the Port of Oakland and other interested parties would have the opportunity to evaluate impacts to land use and other environmental effects at that time.
With respect to the issue raised by the commentor regarding the Port of Oakland's future adoption of a land use plan for the Jack London Square Area, including the Oakland Power Plant Site, the Initial Study correctly acknowledges that both the Port and the City of Oakland are jointly developing (with other agencies) an Estuary Plan and that as a consequence a land use plan may be adopted by the Port early in 1998. Recent contact with the Port of Oakland staff has indicated that the Estuary Plan would probably include a change to the land use designation for the power plant, recognizing the site as a transitional land use that could become available for commercial development at a future date (Reiner, 1997). To reflect this potential the first paragraph of page 4.1.6 of the Initial Study is revised as follows:
The Oakland power plant and surrounding vicinity are designated as M-40, Heavy Industry. However, because of the authority vested by the City Charter (Section 706) in the Board of Port Commissioners, the zoning designations of the City do not apply within the Port Area. At this time the Port of Oakland has not adopted a zoning or land use code for properties that are either under the control of the Port or private land which falls under Port of Oakland jurisdiction. There is no anticipation that such a land use plan will be adopted in near term; however,
the Port does have the authority under the Charter to do so.both the City of Oakland's General Plan and the Port's Estuary Plan may designate all or portions of the Oakland Power Plant Site for future commercial use, and a land use plan for the area may be adopted by the Port in the future.The Port has accepted the land use for the power plant and assumes that it will continue so as long as the facility remains in operation (Heffes, 1997).It is probable that the property will remain a heavy industrial use so long as the power plant remains in operation.
Regarding the issue of sensitive receptors and their location relative to the power plant, the Port staff provided information for this Initial Study indicating that a 288 unit multifamily residential development is proposed by Lincoln Properties for Port property as a future project. It was noted in the Cumulative Impacts section on page 4.16.8 of the Initial Study for PG&E. However, the Port staff did not indicate the location of the proposed (Lincoln Properties) apartment complex. Recent contact with the Port staff indicates that the site of this future project is at the Embarcadero, west of Alice Street in the Jack London Square area (Reiner, 1997). While there are lofts and live/work units within proximity to the power plant, we still believe that the nearest foreseeable residential sensitive receptor is 600 or more feet from the project site on the north and northeast side of Highway 880.
The following text changes are made to reflect corrections regarding the direction of residential sensitive receptors in relationship to the Oakland Power Plant:
The last sentence of the first paragraph on page 4.5.22 is revised as follows:
The closest sensitive receptors are located north and northeast of Highway 880.
The last sentence of the fourth paragraph on page 4.5.29 is revised as follows:
The closest sensitive receptors to the Oakland Power plant are located north and northeast of Highway 880, over 600 feet from the project site.
The last sentence on page 4.10.7 is revised as follows:
The closest sensitive receptors are located north and northeast of Highway 880, over 600 feet from the project site.
Please see response to PO-5.
The Oakland Power Plant is composed exclusively of combustion turbine (CT) units. Such units are quick start units routinely able to come up to power and be synchronized with the grid in less than 10 minutes. They are not routinely used by the California investor-owned utilities and are held in reserve to fill in for unexpected deficits in resources needed to satisfy load/generation resource imbalances as would be occasioned by unexpected unit outages and transmission disturbances. These interruptions are not expected to occur with any greater frequency after divestiture than before and, indeed, Attachment C to the Initial Study (page C.12, et al.) describes incentives that may tend to increase the availability of divested plants, thereby reducing the need for CTs to fill in for units experiencing outages.
The existing CTs are inherently less efficient than steam boilers, so CTs are not used for economic dispatch because they cost more to operate. Because the Oakland CTs burn distillate exclusively, they are even more expensive to operate than most other available CTs, which burn natural gas, a significantly less expensive fuel. Since no mechanism has been identified by which the divestiture would cause a significant tightening of the load/resource balance, it is not foreseeable that the Oakland CTs would be used in other than their traditional reserve role.
REFERENCES:
Fluor Daniel GTI, Phase II Environmental Site Assessment Oakland Power Plant, 50 Martin Luther King Jr. Way, Oakland, California, prepared for Pacific Gas and Electric Company, July 1997c.
Reiner, Steve, Personal Communication between Mr. Dail Miller of ESA and Mr. Steve Reiner of the Port of Oakland. October 2, 1997.