September 21, 1998
President Richard A. Bilas
CA Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102-3298

Dear Sir:

We are grateful for the opportunity to comment on the Draft Environmental Impact Report (EIR) regarding the proposed divestiture of the Potrero Power Plant, and to articulate again the City and PG&E’s mutual objectives. These objectives include ensuring that the Potrero Plant is operated in an environmentally appropriate way, that the Hunters Point Plant is shut down as soon as possible, and that regulators and power procedures are responsive to community concerns.

[Begin F1]

The City’s main concerns regarding the divestiture, as analyzed in the Draft EIR, are the potential for human health effects due to increased particulate emissions and the regional implications of increased emissions of ozone precursors. San Franciscans should not have to endure the magnitude of increased emissions dismissed in this report as inconsequential. The public health of our citizens, and the attractiveness of the Bay Area as a place to do business, are inexorably tied to the quality of air we breathe and our attainment of environmental policy goals.

I encourage the State to consider these potential consequences in more depth, and to impose necessary mitigation measures. Appropriate measures may include (1) limiting Potrero Plant operations; and/or (2) obtaining air emission credits by achieving emission reductions in the local area.

[End F1]

Kofi S. Bonner
Chief Economic Policy Advisor

cc. Gordon R. Smith, President & CEO
Pacific Gas & Electric Company

September 21, 1998
Mr. Bruce Kaneshiro
CPUC EIR Project Manager
c/o Environmental Science Associates
225 Bush Street, Suite 1700
San Francisco, CA 94104-4207

RE: Comments on the Draft EIR on PG&E’s Electric Generation Asset Divestiture, A.988-01-008

Thank you for the opportunity to review the above referenced document. This letter and attachments provide the City and County of San Francisco’s comments regarding the Draft Environmental Impact Report (DEIR). As you will see, our greatest concern is the increase in air emissions that will result from the project and potential adverse health impacts. We believe that the final EIR should address this issue in more depth, particularly with regard to local impacts and feasible mitigation measures. Our comments also address other areas including the use of the Analytical Maximum, land use, water resources, and hazards.

General/Summary Comments:

[Begin F2]

· The final EIR should identify, for any new power plants or transmission capacity that is assumed, the specific year in which these additions or replacements are assumed to be fully operational.

[End F2]

[Begin F3]

· In the final EIR please ensure that there is a clear correlation between the tables in the Executive Summary (Tables S.1, S.3, S.4, S.5, S.6, and Part of S.6) and the tables in Appendix G. For example, in Table S-1, the column headings should indicate the tables in Appendix G relied upon. Similar annotations to Appendix G should be provided for the remaining tables in the Executive Summary.

[End F3]

[Begin F4]

· The Draft EIR correctly points out the massive changes that are occurring in the utility industry here in California. In order to not underestimate the potential impact of these changed conditions, the environmental impacts of divestiture in the final EIR should start from an analysis of each divested plant’s impact, based upon the plant’s physical maximum output. This physical maximum output would be the maximum electricity each plant could produce, taking into account down times due to forced outages, maintenance periods, and any permit restrictions. Additional comments on this item are contained in Exhibit A, attached.

[End F4]

[Begin F5]

· Page S-11, Section S.6 (Cumulative Impacts): For Alternatives 2A and 2B, what are the underlying assumptions and data for the Year 2005?

[End F5]

[Begin F6]

· Page S-16: The DEIR concludes that "the environmentally superior alternative to the project is a combination of Alternative 2A, the bundling of Potrero, Contra Costa and Pittsburg and Alternative 3, the sale of the Geysers plant to the steam field operators . . . The magnitude of the impacts would be less than with the project, but the levels of significance of the impacts would be identical to the project." This paragraph should be expanded to indicate: 1) what specific environmental impacts are decreased with Alternatives 2A and 2B and what is the level of decrease and 2) what is meant by the phrase "the levels of significance of the impacts would be identical"?

[End F6]

[Begin F7]

· Page S-21, Table S.6; Also P. S-31, Table S-2: Impact 4.5.5 is designated as significant for the proposed project and for Alternative 2A and 2B. For the proposed project the footnote states that the impact is "unavoidable". What is meant by unavoidable? As explained below in the discussion on air quality, this impact can be mitigated. The reference to "unavoidable" should be deleted and Impact 4.5.5 identified as "S/M" -- "a potentially significant impact; impact would be reduced a less than significant by mitigation measures required in this report." The final EIR should then add a discussion of available mitigation measures (plant output limits, emission offsets).

[End F7]

[Begin F8]

As discussed above re page S-16, greater explanation is needed for the designation of "L" and "G" for Alternative 2.

[End F8]

Land Use and Planning

[Begin F9]

· Figure 4.1-1 (page 4.1-3) and Figure 4.1-4 (page 4.1-8) should be amended to delete the pipeline to the Pier 70 Marine terminal and the terminal from the Potrero Plant site. Those properties are owned by the Port of San Francisco and will not be transferred with the sale. PG&E must seek an assignment of their lease to the purchase of the Potrero Plant.

[End F9]

Water Resources

[Begin F10]

· Section 4.4.2 (Local Setting) should discuss the environmental impact issues identified in the significance criteria presented in Section 4.4.3 (flood hazards, storm water runoff, public water supplies, water quality, and groundwater resources), especially the contribution of each plant to surface and groundwater quality and condition. Discussing these issues will provide support for the impact conclusions described in Section 4.4.4.

[End F10]

[Begin F11]

· For the Potrero Plant, the final EIR should include a figure illustrating monitoring wells and outfalls (in this or the Hazards section), and include any water quality data from those wells, if the information is necessary to support the impact analysis. This could be as brief as a list of chemicals of concern present in the water, with the data and figures provided in an appendix.

[End F11]

[Begin F12]

The final EIR should also include a summary of chemicals discharged and a discussion of any NPDES compliance issues.

[End F12]

[Begin F13]

· Impact 4.4-2 (page 4.4-15) introduces a new significance criteria -- violation of state or federal effluent limitations. This criteria should be included in Section 4.4.3.

[End F13]

[Begin F14]

· Section 4.4.4 should be expanded to address the proposed project’s anticipated effect on each of the impact topics identified by the significance criteria in Section 4.4.3. Impacts should be discussed separately for each of the plants.

[End F14]

[Begin F15]

· Some of the existing NPDES permits will expire during the period covered by the impacts analysis. The final EIR should clarify whether the analysis assumes that the RWQCB will renew the permits without modification and the basis for this assumption.

[End F15]

[Begin F16]

· Page 4.4-6 (Potrero Plant): this section should cross-reference Part 4.4.9 (Hazards), and vice-versa, since there are major environmental contamination issues associated with the groundwater setting.

[End F16]

Air Quality

[Begin F17]

· It was difficult to determine which version of the must-run contract for Hunters Point is assumed in the DEIR. The final EIR should assume version C, given PG&E’s Agreement with CCSF.

[End F17]

[Begin F18]

The final EIR should also clearly state how the PG&E/City Agreement regarding the shutdown of Hunter’s Point affects the assumptions and conclusions in this chapter. If the CPUC has not approved the PG&E Amendment regarding the Agreement by the time of the issuance of the final EIR, then the EIR should discuss how the scope of the project and impacts might change.

[End F18]

[Begin F19]

· The final EIR should clarify what air quality retrofits are assumed and in what year. For any retrofits assumed to have occurred in 1998, the final EIR should check that such retrofits have actually been accomplished.

[End F19]

[Begin F20]

· The figures attached as Exhibit B represent CCSF’s understanding of the emissions data assumed in the DEIR. Are these emissions calculations correct? Similar charts should be included in the final EIR.

[End F20]

[Begin F21]

· What measures are proposed to ensure that the actual emissions do not exceed those stated in the DEIR? The City suggests that regular monitoring and dissemination of monitoring results.

[End F21]

[Begin F22]

· As indicated on p. 4.5-18, the BAAQMD Regulation 9, Rule 11 establishes NOx emission rate limits for power plants within its jurisdiction. It is our understanding that any new operator of these power plants will be required to operate in compliance with these NOx emission rates, even if the new owner only purchases one plant. In year 2005, the NOx emission rate limit under the "bubble" option is 0.018 pounds per million BTU. However, several scenarios referenced in Appendix G indicate that this limit is not satisfied. Specifically, in Tables G-2 and G-8, the average NOx emissions for the Pittsburg facility are 0.020 lb/mmBTu; and in Tables G-6, and G-17, the average NOx emissions for the Pittsburg facility are 0.023 lb/mmBUT.

[End F22]

[Begin F23]

· Part 4.5.4 (Significance Criteria), page 4.5-50, second full paragraph: Given the projected increase in 1999 Potrero Plant emissions relative to the no-project baseline (for example, a 56.8% increase in NOx), did the CPUC consider whether the local area’s air quality-related health burdens constitute a "special circumstance" for significance considerations? If not, why not?

[End F23]

[Begin F24]

· Part 4.5.4 (Significance Criteria), page 4.5-50, Criteria #1: The significance criteria do not appear to account for the Bay Area’s non-attainment status for ozone and particulate matter (listed in Table 4.5-2, "Air Basin Attainment/Non-Attainment Designations"). For example, "Prevention of Significant Deterioration" (PSD) is a standard typically used for attainment areas; "New Source Review" (NSR) is typically used in non-attainment area. Are PSD standards used for all criteria pollutants? If so, what is the rationale? (For example, one difference is that significance under an NSR standard can be triggered by 100 additional tons/year of NOx; the Potrero Plant would emit 610 additional tons/year at the Analytical Maximum). Generally, it seems that the analysis should reflect the area’s non-attainment status because more stringent analyses may be appropriate for non-attainment pollutants.

[End F24]

[Begin F25]

Also, were the numerical criteria for PM-10 significance derived from BAAQMD Regulations or other sources?

[End F25]

[Begin F26]

· Table 4.5-26: Please explain the difference between the Hunters Point emissions levels in this table and in Table G-1 (334 v. 210 tons NOx/year). Which levels were used to determine significance?

[End F26]

[Begin F27]

· Page 4.5-32: Even assuming that fossil-fueled plants would emit mainly particles PM2.5 or smaller, the DEIR analysis may be incomplete, since it does not appear to have accounted for the secondary formation of PM2.5 from NOx and ROG emissions.

[End F27]

[Begin F28]

· Page 4.5-62: The DEIR appears to analyze only the primary impacts of NOx and PM. The DEIR does not evaluate the secondary pollutant formation of ozone and particulate matter (for example, by using a photochemical model such as CAMxÔ or UAMV). What is the rationale for not conducting such an evaluation?

[End F28]

[Begin F29]

· Page 4.5-75, first full paragraph: The last sentence of the paragraph states: "Based on the converse to that concept, the contribution of divestiture to overall cumulative ambient risk would be less than significant because the project-specific impact would be less than significant." This approach contradicts the purpose of a cumulative impacts analysis. CEQA calls for agencies to identify situations where impacts in themselves are not significant, but could contribute to a significant effect in combination with the impacts of other projects.

[End F29]

[Begin F30]

· Mitigation Measure 4.5-5 (page 4.5-81): The DEIR concludes that even if Regulation 9, Rule 11 or its equivalent were applied to the divested plants, the 1997 Clean Air Plan would not be met if the plants were operated at the Analytical Maximum, and that this is a significant, unavoidable, temporary (until Year 2003) impact. No mitigation is proposed. As shown in the charts attached as Exhibit B, the increase in emissions will be substantial, especially on a cumulative basis. The impact of these increased emissions can be mitigated by at least the following means: (1) restricting operating hours and/or (2) obtaining air emissions offsets. The final EIR should include these or other mitigation measures to ensure less than significant levels of emissions.

[End F30]

[Begin F31]

In addition, emissions after 2003 will still increase substantially with the project, as opposed to no project. Absent enforceable mitigation, what assurance is there that the emissions will not in fact be higher than projected after 2003, and thus trigger a significant impact?

[End F31]

[Begin F32]

· Page 4.5-70 (Cumulative (2015) Bay Area Analysis: In order to produce a valid cumulative impacts analysis, the mobile and project sources for all criteria pollutants should be added together and the effects evaluated (as was done for carbon monoxide).

[End F32]


[Begin F33]

· The analysis of hazards related to contamination of soil and groundwater at the Potrero Plant site is inadequate, and is not based on detailed information available at the time of publication of the DEIR. The Potrero Plant site is known to have substantial soil and groundwater contamination issues, as the Phase II report published in June 1998 ("Phase II Environmental Site Assessment: Pacific Gas and Electric Company, Potrero Power Pant, "by Fluor Daniel GTI) acknowledges.

[End F33]

[Begin F34]

· Section 4.9.1 (Regional Setting), page 4.9-1 et seq: This section discusses the regulatory framework for hazardous materials and site remediation (although omitting reference to Proposition 65 and local ordinances), but not any specific setting information. Please include a summary of environmental conditions at and surrounding each plant. The final EIR should identify whether there any underground storage tanks present on the Potrero property and should also indicate that polyaromatic hydrocarbons were found at the former manufactured gas plant facility at Potrero.

[End F34]

[Begin F35]

· Page 4.9-4 (Hazardous Materials And Waste): Please discuss asbestos, PCB’s, lead-based paint and electromagnetic fields at the Potrero Plant in order to support the significance conclusions.

[End F35]

[Begin F36]

· Page 4.9-5 (Potential Site Contamination): Please reference the Phase II report published in June 1998 ("Phase II environmental Site Assessment: Pacific Gas and Electric Company, Potrero Plant,’ by Fluor Daniel GTI).

[End F36]

[Begin F37]

Is there a schedule for remediation of the Potrero Plant site? If so, this should be included in the final EIR.

[End F37]

[Begin F38]

Did the PEA done by PG&E determine if the site poses any current hazards to human health or the environment? If so, this should be discussed in the final EIR.

[End F38]

[Begin F39]

· Page 4.9-6, second full paragraph: What is the current status of the "material recognized environmental conditions?"

[End F39]

[Begin F40]

· Page 4.9-6, second full paragraph and page 4.9-15, third full paragraph: Is PG&E doing the Phase II assessment and risk assessment voluntarily, or has it been directed to do these by a regulatory agency? If so, which regulatory agency is it? Who will determine what cleanup is required, and when it is performed?

[End F40]

[Begin F41]

· Impact 4.9-1 (page 4.9-14): What factors related to divestiture would accelerate remediation efforts at the Potrero Plant?

[End F41]

[Begin F42]

What are the regulatory requirements that would require remediation by either the purchaser or PG&E?

[End F42]

[Begin F43]

· The DEIR does not address how divestiture could affect the potential remedies proposed in the Phase II report for the Potrero Plant. For example, the Highest Ranking Alternative for Remedial Issue 1 -- Soil and Groundwater in the Central Site Area would require a plant shutdown of up to 30 days (see page 84 of the Phase II report). The final EIR should address the Phase II report and how such a shutdown relates to the "must-run" and economic assumptions of the analysis. The report estimates a total of over $33 million in required remediation, so it is not a minor issue. If remediation is not accomplished prior to shutdown of the Hunters Point Plant, would a less-protective remedial alternative eventually have to be implemented because of the Potrero Plant’s role in maintaining the San Francisco Operating Criteria reliability?

[End F43]

[Begin F44]

· Mitigation Measure 4.9-1 (page 4.9-17): The DEIR assumes early cleanup. The City is concerned, however, that divestiture could result in less timely and less effective remediation because of changes in site control, loss of access to records, introduction of new potentially responsible parties, and the lesser ability of a purchaser in a deregulated environment to absorb substantial increases in remediation costs.

[End F44]

[Begin F45]

Pages 4.9-16 and 17 summarize PG&E’s intentions regarding retention of legal responsibility for cleanup and describe a process of regulatory oversight that it intends to follow. However, Mitigation Measure 4.9-1 only calls for PG&E to submit each plant’s Risk Assessment to the CPUC and to the purchaser. In addition, the fourth full paragraph on page 3-5 states that "issues associated with the liability for environmental cleanup are expected to be resolved contractually between each new owner and PG&E."

An expression of intent by PG&E is inadequate, by itself, to assure that the sites will be cleaned up by PG&E once ownership is transferred. The City is concerned that PG&E’s proposed responsibility for cleanup could be transferred, diluted, or avoided as a result of the divestiture unless PG&E enters into binding remediation commitments prior to sale.

Mitigation Measure 4.9-1 should indicate requirements that PG&E include each purchase and sale agreement provisions that implement the assumptions made in the DEIR regarding PG&E’s post-transfer responsibilities, and that PG&E will enter into an enforceable remediation agreement with one or more appropriate regulatory agencies prior to transfer of title.

[End F45]

[Begin F46]

· Impact 4.9-3 (page 4.9-19); page 4.9-4: In the final EIR, the paragraphs summarizing the properties of chemicals typically found at the power plants to be divested would be useful in the setting section. For the Potrero Plant, similar information should be provided for sodium hypochlorite, sodium bisulfite, and the solvents, degreasers and petroleum-based oils that, according to the last paragraph on page 4.9-4, are hazardous materials used at the plant.

[End F46]

[Begin F47]

Lead-based paint is generally considered a hazardous material where building renovation or demolition is possible, and so should be discussed as applicable.[End F47]

[Begin F48]

· Mitigation Measure 4.9-3 (page 4.9-21): Even though PG&E personnel will continue to operate the divested plants after title is transferred, three business days seems too short a time for the new owner to review detailed documents and procedures for which it will be legally responsible as soon as title is transferred. The health and safety documents should be made available to the prospective purchasers sooner.

[End F48]

[Begin F49]

· Impact 4.9-5 (page 4.9-23): Site remediation often generates larger quantities of hazardous waste than typified by operations, although there is no information provided in the DEIR for these particular sites. The final EIR should clarify how the impact of remediation waste generation is included in Impact 4.9-1.

[End F49]

[Begin F50]

· Impact 4.9-6 (page 4.9-24): The DEIR does not provide information on whether EMF emissions at any plant would increase as a result of the project’s assumed higher operations levels. If there would be increases, then at a minimum the purchaser should be required to mitigate the emissions in accordance with CPUC policy.

[End F50]

Local Cumulative Impacts

[Begin F51]

· Table 5.1 (page 5-12) and Section 4.5 (Air Quality) should rely on a current list of local projects near the Potrero Plant. Please contact the San Francisco Planning Department and the Port of San Francisco for updates to this list.

[End F51]

[Begin F52]

· The EIR analysis does not appear to fully address the cumulative impacts of the proposed project in combination with local projects. Several of the local projects listed (and several that should be added to the list) are localized generators of PM10 emissions. The surrounding community has concerns regarding the cumulative effect of these generators when viewed in combination with the Potrero Plant. Please expand the cumulative impacts assessment to address this issue.

[End F52]

Please do not hesitate to call me at (415) 558-6384 if you have questions regarding these comments, or if I can be of further assistance.

Hillary E. Gitelman
Environmental Review Officer
cc: Kofi Bonner
Laurie Park
Elaine Warren
Dian M. Grueneich

Exhibit A
Use of the "Analytical Maximum" and
Need to Analyze Impacts Under the Physical Maximum

[Begin F53]

The DEIR (p. S-6) indicates that the new owners of the fossil-fueled plants would tend to operate at higher levels than PG&E’s continued ownership because of the following three factors: the portfolio effect; fuel procurement practices; and the ability of new owners immediately to participate in the direct access market. The DEIR also states (page S-8): "The ability of new owners to participate immediately in the direct access market is a key factor in this EIR’s assumption that new owners will tend to operate at higher levels than PG&E."

The DEIR then proceeds to define an analytical maximum that somehow is supported to take into account all three of the above factors. The DEIR states: "It is expected that divestiture of the power plants will create a tendency for new owners to operate the plants at higher levels than in the 1999 Baseline Scenario. However, it is not possible to determine with any precision of which plants operations would increase at a particular plant." (p. S-8) The report then defines a gas price level at which somehow all of the three above factors are considered, even though gas price level is really only directly related to the second factor.

Much of the remainder of the DEIR is based upon sophisticated system modeling, which produces operating levels that result from this arbitrary gas price assumption. However, many other assumptions also need to be made about the operation of the interconnected system, all of which can have an impact upon operating levels of the divested plants. Based upon all of these subjective factors, it is a stretch at best to conclude that the resulting "Analytical Maximum" and modeling results have any correlation to what can reasonably expected to be a limit to future changes in operations of the plants under divestiture.

[End F53]

[Begin F54]

In comparison, calculation of the operating level based upon the physical maximum, which the City proposes be included in the final EIR, is an easy exercise. At a minimum, the environmental effects of plant operation at the physical maximum levels (as defined above), should be displayed in the final EIR, in addition to those impacts calculated in the DEIR. The likelihood of reaching the physical maximum level of operation could be also addressed in the final EIR, so that decision makers can fully evaluate the possible impacts of divestiture.

[End F54]

The following questions and comments supporting our belief that environmental impacts should at least be investigated at the physical maximum operating level:

[Begin F55]

1. On page S-7, the DEIR states that a major assumption is that: "Both the PX and ISO continue to commit and dispatch the plants based upon minimum variable cost of operation, consistent with the requirements of the San Francisco Operating Criteria (SFOC) and the Bay Area Reliability Requirements (BARR) and local distribution system report requirements." Very little with respect to the PX and the ISO stays constant these days. The Federal Energy Regulatory Commission (FERC) is holding detailed settlement discussions with respect to the must run agreements, for all the plants that sell to the ISO, including those being divested. In addition, the ISO, in corporation with the transmission owners, are developing transmission planning criteria for the ISO system as a whole. In this process, they are trying to reconcile differences between the historical practices of each of the Transmission Owners and also interpret and apply WSCC and NERC criteria at a local level which is a change from past practice.

[End F55]

[Begin F56]

Finally, PG&E has concurrently proposed major additions to their transmission system in the Bay Area which are not accounted for in the DEIR analysis.

[End F56]

[Begin F57]

2. Other "key assumptions" in the DEIR involve powerplants being added in San Diego and Nevada. Tremendous uncertainty exists as to where and when new generation will be added in the western region. The final EIR should explain what new powerplants are being assumed, the basis for that assumption, and some indication of how the impact analysis would change if either more or fewer new powerplants are developed than is assumed in the final EIR.

[End F57]

[Begin F58]

3. Section 3.4 of Attachment C describes "Factors that Could Produce Change." These factors bolster our position that the final EIR needs to look at physical maximums for the plants being divested. The DEIR says that such factors are "too speculative to consider at this time" but it is not at all clear that these factors are more unlikely than many of the assumptions that are included in the Analytical Maximum cases.

[End F58]

[Begin F59]

4. As pointed out in the DEIR, p. C-2: "The first basic premise is that restructuring as directed through legislation and Commission decisions will lead to substantial, fundamental changes in how California’s electric utility system operates.

[End F59]

[Begin F60]

5. As pointed out in the DEIR, p. C-3, "if an operator can reduce costs by changing operating mode or reducing cost of fuel by even a small amount, sales from that unit can rise substantially." The DEIR includes on single assumption – the 25% decrease in an owner’s gas cost – which is evidently meant to capture all of the effects of changes in operating mode and fuel costs. As explained above, use of a physical maximum in the final EIR will capture the impact of such changes without requiring numerous additional operation studies.

[End F60]

[Begin F61]

6. Section 3.1 and Section 3.2 point out a litany of factors that all lead to a conclusion that no one can predict with any certainty how operation of the divested plants might change. No attempt is made to indicate how the EIR reader knows that the Analytical Maximum captures these uncertainties. Use of the physical maximum in the final EIR will account for these uncertainties.

[End F61]

Note: Original submission from the City and County of San Francisco included two figures denoted as "Exhibit B". These were provided in a form inconvient to present on this website. Should the viewer need to see these figures please contact the Webmaster for copies.

September 17, 1998
Hillary Gitelman
Office of Environmental Review
Department of City Planning
1660 Mission Street
San Francisco, CA 94103

Dear Ms. Gitelman:

The San Francisco Department of Public Health has reviewed the Draft Environmental Impact Report (EIR) for the Pacific Gas and Electric Company’s Application for Authorization to Sell Certain Generating Plants and Related Assets Application No. 98-01-008. We are specifically concerned with the sale of the Potrero Plant in San Francisco. We would like to provide you with the following written comments on the EIR:

Comment 1. General Comment

[Begin F62]

Overall, we found the assessment of health impacts due to the anticipated changes in local air quality was limited. The report based its significance criteria mainly on existing administrative rules that set permissible exposure increments and limits. This approach ignores the breadth of human health effects that have been associated with specific air pollutants, and it ignores the concept of a linear dose-effect response relationship between these adverse health outcomes and incremental increases in pollution.

[End F62]

[Begin F63]

A more complete risk assessment process of this project should reflect the avalable scientific evidence and should address the following:

A. Separate risk characterizations should be made for each criteria air pollutant. This is most important for "non-attainment" pollutants, ozone and particulates, but also relevant for nitrogen oxides for which emissions increases are the greatest.

[End F63]

[Begin F64]

B. Risk assessment should be done on a regional as well as local level.

[End F64]

[Begin F65]

C. Exposed populations should be identified and located, and sensitive subpopulations should be estimated.

[End F65]

[Begin F66]

D. The most sensitive health outcome for each pollutant should be as determined from consideration of all of the outcomes studies in the epidemiologic literature (i.e., cardio-respiratory mortality, hospital admissions and emergency room visits, exacerbation of chronic respiratory disease, etc.).

[End F66]

[Begin F67]

E. The population health burden for incremental exposure changes should be estimated utilizing the slope of the exposure-response relationship, the population at risk and background outcome frequency.

[End F67]

We believe the approach outlined above is feasible and would provide a less ambiguous estimate of the population health impact of the proposed project.

[Begin F68]

Comment 2. Page 4.5-6 Last paragraph

A. The paragraph summarizing the health effects of PM10 and PM2.5 should distinguish between health impacts due to chronic and acute exposure to PM10.

B. The paragraph should reference studies on the impact of acute exposure to PM10, specifically, daily rates of respiratory and cardiovascular mortality, hospital admissions and emergency room visits as well as probability of asthma exacerbation. Since the US EPA criteria document referred to in the Draft EIR (page 4.5-84) reviewed ALL studies relating to both acute and chronic exposure to PM, it would be appropriate to use this criteria document and the associated staff report in addition to selected studies.

[End F68]

[Begin F69]

Comment 3. Page 4.5-12 1st full paragraph, Introduction to Risk Assessment

The last sentence states, "Information on risk assessment methodology is presented in the discussion of the Potrero Power Plant setting." The page number with this information should be referenced. Also cross reference what is in Appendix G and what is in the main document in terms of risk assessment methods.

[End F69]

[Begin F70]

Comment 4. Page 4.5-25 1st full paragraph

What residences are downwind from the power plant (as related to the wind rose on page 4.5-27)? The location and approximate population size of these areas should be stated.

[End F70]

[Begin F71]

Comment 5. Page 4.5-31 2nd full paragraph, Sentence 1

The sentence obscures effects due to chronic and acute exposures, doesn’t refer to cardiovascular impacts, and downplays the relationship of daily concentrations of PM to mortality ("in some cases"). While there are still controversies in the observed PM-mortality relationships, they have been replicated in more than 50 studies, and they are at least as strong in terms of data quality as those for other outcomes.

[End F71]

[Begin F72]

Comment 6. Page 4.5-31 2nd full paragraph, Sentence 2

The sentence reads, "Most of these studies have shown relationships between PM exposure and respiratory effects during air pollution episodes in major metropolitan areas, where daily ambient air concentrations exceeded 300 m g/m3." The above statement is incorrect as relationships between PM and health effects have been shown at concentrations much lower than 300 m g/m3; furthermore, the sentence in paragraph 2 of the following page, "Typical annual average concentrations of PM-10 at these cities ranged from 18-58 m g/m3...." directly contradicts the above statement. In addition, the word, "cardiopulmonary," in the above statement should replace the word, "respiratory."

[End F72]

[Begin F73]

Comment 7. Page 4.5-31 3rd full paragraph

Sentence 1 should read, "A draft report released by...reported that 1992 hospitalization rates for ... were higher in Bayview Hunters Point than any other part of San Francisco. Sentence 2 should use the past tense. Sentence 3 should begin, "To better understand the causes of the increased hospitalization rates."

[End F73]

[Begin F74]

Comment 8. Page 4.5-32 2nd full paragraph

The first sentence states, "With regard to fine particles (PM2.5), several studies cited in the EPA report indicate that significant increased hospitalization and respiratory symptoms occur when PM-2.5 24-hour concentrations increase by 20-25 m g/m3 (Schwartz et al., 1994; 1996; Thurston et al., 1992, 1994)." There seems to be some confusion in how these studies were interpreted. These studies and others are describing linear relationships. When relative risks are presented, they use a realistic interval such as the interquartile range of concentrations in the study area or 10 or 20 mg/m3 increases which could be observed from one day to the next. These effects would be just as statistically significant with 1 mg/m3 increases.

[End F74]

[Begin F75]

Comment 9. Page 4.5-50 Significance Criteria #1

The source of the numerical criteria presented (5 m g/m3 increase 24 hour average PM10 and 1 m g/m3 annual average increase) is not referenced.

[End F75]

[Begin F76]

Comment 10 Page 4.5-50 Significance Criteria #4

In sentence three and four, a numerical interval, 24 hour 20 m g/m3 PM2.5 & annual 10 m g/m3 PM2.5, is established as the significance criteria. In sentence one, the significance criteria is the production of "increased respiratory ailments." These criteria are inconsistent because where a linear dose-effect relationship exists, any increase in exposure would be expected to result in a quantifiable increase in the burden of disease. (See comments 8 & 9.) Also, the references for the above numerical targets are not cited. It is possible that the study from which the above numerical limits have been derived may have used the term "significance" to connote significance or the term may reflect the authors own judgment. (See general comment above.) Finally, does the criteria consider only incremental increases only being considered or is the cumulative effect of air pollution being considered? How are expected number of days exceeding 20 m g/m3 determined? Why are these incremental increases for PM2.5 greater than the ones given for PM10 in Criteria #1 when PM2.5 is a subset of PM10?

[End F76]

[Begin F77]

Comment 11 Page 4.5-50 Significance Criteria #5

How does the recent Federal non-attainment designation of the Bay Area Region for ozone affect the determination of significant exposure and health impacts? Will any increases in ozone precursors, both ROG’s and Nox, be consistent with the region’s plans to come under future compliance?

[End F77]

[Begin F78]

Comment 12 Page 4.5-63 Table 4.5-29

There is an apparent error in the PM2.5 row. The power plant contributes 1.2 m g/m3 PM2.5 to ambient concentrations, but the ambient concentration after this contribution is listed as 1.2 m g/m3. There is a similar error in the next 2 columns.

[End F78]

Thank you for considering our comments. Please call Dr. Rajiv Bhatia at 252-3931 if you have any questions on our comments.

Director of Health
cc: Rajiv Bhatia, Occupational and Environmental Health, D.P.H.

October 7, 1998
Mr. Bruce Kaneshiro
CPUC EIR Project Manager
c/o Environmental Science Associates
225 Bush Street, Suite 1700
San Francisco, CA 94104-4207

RE: Comments on the Draft EIR on PG&E’s Electric Generation Asset Divestiture (A.98-01-008)

Dear Mr. Kaneshiro:

[Begin F79]

The City and County of San Francisco submitted comments on September 21, 1998 on the Draft EIR regarding PG&E’s ongoing divestiture project. We wish to offer the following supplement to those comments, with regard to the last sentence in my cover letter to President Bilas and the City’s comment on Mitigation Measure 4.5-5 (DEIR, p. 4.5-81).

The purpose of the above-referenced comments from the City was to encourage the Commission to include, in the final EIR, a discussion of mitigation measures, to the extent such measures are available or appropriate. The City defers, of course, to the Commission’s responsibility under CEQA to determine whether any mitigation measures are necessary or appropriate.

[End F79]

We thank you for the opportunity to provide this supplement to our prior comments.

Kofi S. Bonner
Chief Economic Policy Advisor
cc: President Richard A. Bilas,
California Public Utilities Commission
Gordon R. Smith, President & CEO,
Pacific Gas and Electric Company

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