September 1, 1998
Mr. Bruce Kaneshiro
CPUC EIR Project Manager
c/o Environmental Science Associates
225 Bush Street, Ste. 1700
San Francisco, CA 94104-4207

Dear Mr. Kaneshiro,

The Office of Ratepayer Advocates (ORA) presents its comments and questions regarding the Draft Environmental Impact Report (DEIR) for Pacific Gas and Electric Companys (PG&E) Application for authorization to sell certain generating plants and related assets. (Application 98-01-008). Essentially, ORA is concerned that the Hunters Point Agreement will result in significant environmental impacts at Potrero or in other parts of San Francisco that are not analyzed in the DEIR.

Comments & Questions Regarding PG&Es DEIR

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Chapter 2, Project Description: Initially PG&E proposed to divest Hunters Point, but has since changed its position on that.

PG&E now proposes as part of this overall divestiture to:

1. reduce the amount of generation from Hunters Point to the minimum required by the ISO,

2. retire Hunters Point as soon as the ISO will let PG&E,

3. promise not to use the Hunters Point site for a new generating plant and attach a restriction on the title of the Hunters Point site that would prevent a new owner from using the site for a power plant.

The above is relevant because items 1 and 2 will probably lead to an increase in the generation from Potrero resulting in increased air emissions at that power plant site. These are not analyzed in the DEIR. Item 3 is relevant because it affects the reliability of the electric system, and may create a need to increase generation (and associated emissions) at the Potrero site and/or a new transmission line corridor. All of these impacts are the direct cumulative impacts associated with PG&Es divestiture proposal. Under CEQA Guidelines section 15378, "project" is defined as "the whole of an action which has a potential for resulting in physical change in the environment..." Clearly, PG&Es actions re: the Hunters Point plant are part of the whole of the action and have a potential for resulting in physical change in the environment.

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Cumulative Scenario, page 3-3: The DEIR states "In light of the July 9, 1998 agreement between PG&E and the City...the cumulative analysis assumes that the Hunters Point Power no longer operating by 2005. In order to successfully model the Analytical Maximum capacities of the plants to be sold, the cumulative analysis assumes that new generating facilities (totaling 480 MW) have been constructed and are operating somewhere north of the Martin Substation (in San Mateo County) in order to replace the Hunters Point plant and to meet anticipated increases in electricity demand." (emphasis added)

This statement assumes away precisely the impact that the EIR is supposed to measure. If PG&Es action to shut down Hunters Point permanently and prematurely as part of this Application triggers the need for the rapid construction of a large power plant in the northern part of the S.F. peninsula, that construction and operation is a significant impact of the agreement with CCSF, not part of the baseline.

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1999 Baseline Scenario, section 3.6.1: This scenario is defined at pp. 3-9 to 3-11 in a confusing and unsupported manner. For example:

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Chapter 5, Cumulative Impacts

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Future Plant Development, Section 5.2.2: The DEIR states that "In light of the [PG&E-CCSF] agreement, it appears reasonable foreseeable that, by 2005, generation and/or transmission facilities to serve the City of San Francisco will have been approved and constructed, and the Hunters Point Power Plant will no longer be operating." The DEIR argues this assumption is justified given the 4-5 year lead time for a new power plant (footnote 1, page 5-3)

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The DEIR identifies (at p. 5-4) the "San Francisco Energy Facility" as the only project which has been publicly proposed which would provide even part of the local generation requirements that would result from the closure of Hunters Point. The project has been proposed for many years, but has never been able to get all the necessary permits.

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Referring to Table 5.2 on p. 5-18 footnote "c", the DEIR states that this scenario assumes that PG&E will operate its Hunters Point plant at minimum capacity per the agreement with CCSF. Yet Hunters Point is not shown at all on Table 5.2. This is an error. Projected capacity factors for Hunters Point should be included in Table 5.2.

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Chapter 6, Alternatives Evaluated: The alternative proposed by PG&E in its Amendment regarding immediate change in the operation of the Hunters Point plant, and its early retirement must be considered if it is likely to change the environmental impacts relative to the no project alternative. The DEIR should add and analyze the proposed changed operations at Hunters Point as Alternative #4.

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Sincerely yours,
Truman L. Burns
ORA Project Coordinator

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