September 20, 1998
Mr. Bruce Kaneshiro
CPUC EIR Project Manager
C/O Environmental Science Associates
225 Brush Street, Suite 1700
San Francisco, CA 94104-4207

Re: Draft Environmental Report, CPUC Application #98-01-008
Geysers Geothermal Power Plant & Other Divestitures

Dear Mr. Kaneshiro,

Thank you for having the workshop at the Little Red School House in Cobb. As you heard at that meeting most are unaware of the legal process and are unlikely to follow up in writing to restate their concerns. Therefore, for the record, I feel that it was inappropriate that people could not submit verbal comments but instead would be required to attend a hearing in San Francisco in order to do so. The purpose of this letter is to formally put on the record several of my concerns and try to repeat some of those concerns that were expressed during that workshop.

[Begin J1]

First and most importantly, our Air Pollution Control Officer stated several times that you are going forward with a sale of "green" power without an assessment of policy or the implications. While you did remark that there was a one and one-half cent per kilowatt advantage given to green power and renewables during ESA/CPUC staff’s presentation to the Board of Supervisors, our APCO has continued to contend that those moneys are not available in the Geysers and are available only for new power.

[End J1]

[Begin J2]

Some question exists as to the possibility of that even AB 1890 will not apply once the plants are sold. Please resolve this issue. Also, please identify any incentives or advantage given to green power by state policy, likely to be incorporated into the CPUC’s consideration or other state agencies, as this is an important issue to our community at large and to our state and nation. We desire this policy issue to at least be discussed and considered within the divestiture and sale of this first green power by what used to be a monopoly utility. Clearly, the CPUC can condition the sale and policy options may be available.

[End J2]

[Begin J3]

Second, the issue of the tax base changing and the manner in which you looked at the economy and the effects upon jobs, etc., was pointed out to be somewhat poorly supported, particularly the conclusion that 1-2% was insignificant causes great concern.

[End J3]

[Begin J4]

The comparison to the work force in Sonoma County versus that of Lake County was another major concern and should be corrected. The local agencies that might be heavily affected by any decision of sale that would result in lesser tax revenue includes the school district, the local fire district, as well as the county.

[End J4]

[Begin J5]

We are concerned that if this impact is significant that there be fair consideration of mitigation and compensation.

[End J5]

[Begin J6]

It is my concern that you try to quantify any such impacts realizing you will not know the selling price of the facilities, but that you have an obligation to suggest mitigation should the selling price be substantially lower than the present tax base yield value. We realize the reevaluation is likely in two years, but still two years for preparation is significant. Mitigation could perhaps include a payment from Pacific Gas and Electric as part of any sale that would compensate the fire districts, school districts, etc., and cushion the effect. Again, as far as the job market issue, we understand your approach but ask for a consideration of the effect upon Lake County where a majority of workers reside versus that of Sonoma County.

[End J6]

[Begin J7]

You heard several comments regarding the sale of the facility and the continuation of programs that are not necessarily regulatory but that have served the community such as the use of mercury scrubbers not being required, but being in place, participating in GAMP, and participating in the seismic studies associated with earthquakes. Instead of suggesting no mitigation, we would suggest a reasonable mitigation of the condition of the sale to require the owner to continue these programs until they are determined to be resolved or unnecessary after discussions with the public and effected agencies. I would also like to reiterate how the Geysers power plants are interrelated with many aspects of our community function and more than just power plants. The classic is the disposal technique we use for our sewer plants, and the other hydro-curtailment resulting in the need for waterlogged wells to be cleared and that resulting in the noise complaints that you heard during the workshop.

[End J7]

[Begin J8]

This is not a simple system, and it is more than just power plants. The Geysers have been largely developed with a realization that green power was good for the state, the county and the country. Such realization should continue through this sale and future operations of these plants. Any step that the CPUC could take in assuring that should be in the final EIR. Mitigation might include: the ISO having "a set a side" to enable them to sell sustaining amounts of power during hydro-curtailments; the state having a distribution added value charge that would compensate in a more general manner for green power such as the Geysers; a green power portfolio requirement for sellers; and/or a method of charging the real cost of nuclear and fossil fueled power. Seeking any needed mitigation early seems especially important given that California and PG&E have a significant installed green power component as part of our present power generation and distribution.

[End J8]

[Begin J9]

I would reference you to the Board’s letter of May 13, 1998, bringing up many of these issues and ask specifically that you consider mitigation for the six items identified therein, and the need for mitigation should the conclusion of "no significant impact" prove not to be the case.

[End J9]

[Begin J10]

Again, I understand that you can take a simple approach but want to reemphasize that: 1) this green power sale is the first of this type in California for a utility, it is of a precedent setting nature, and the manner in which the sale is completed may be a direction without adequate policy considerations;

[End J10]

[Begin J11]

and 2) while CPUC/ESA did a commendable job of trying to address hydro curtailment induced stacking emissions, the seriousness of hydro-curtailment and that it is incompatible with the wise operation of the Geysers steam fields and causes a variety of physical and fiscal problems seems to have been largely missed.

[End J11]

[Begin J12]

Finally, the overall profitability of green power in the future and now, cannot be ignored. When you have a company such as PG&E that has the vast majority of the customers, it is incumbent on us all to ensure the transition to market is rational and does not unfairly disadvantage indigenous green power which is small and may have special but reasonable needs to assure continued success.

[End J12]

Ed Robey
County of Lake
Supervisor District 1

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