J. LAKE COUNTY BOARD OF SUPERVISORS (Ed Robey)
J1 Please see responses to Comments H14 and H15 above.
J2 Please see responses to Comments H14 and H15 above.
J3 Please see response to I3.
J4 Please see to response to Comment H26.
J5 Please see responses to Comments I3 and K2.
J6 Please see response to Comment I3. The market valuation of the Geysers without divestiture could have occurred at any time after January 1, 1998. Therefore, even though divestiture may accelerate reassessment, quantifying how much sooner this may have occurred would be purely speculative.
J7 Please see response to Comment H11. The issue of potential curtailment of generation at the Geysers during periods of high hydropower availability is unrelated to the proposed divestiture of the power plants, but is addressed in the response to Comment H6. Please see the response to Comment H54 concerning noise issues. Regarding wastewater disposal, the steam field operators have contracts to accept effluent for injection into the steam fields, and these contracts will not be altered by divestiture.
J8 Please see response to Comment H14 above. The policy recommendations offered by the commenter would far exceed the authority of the CPUC. The Independent System Operator (ISO) is an independent state corporation regulated by FERC. The ISO is governed by an independent Oversight Board that periodically reviews ISO policies and makes recommendations for improvements, but major changes to ISO policies would require action by the FERC or by the Legislature or Congress. However, the commenter’s suggestion for a distribution added value charge that would compensate in a more general manner for green power such as the Geysers is already in effect, as detailed in the response to Comment H15 above. As to the commenter’s other suggestions, previous attempts by the CEC and the CPUC to quantify the real costs (i.e., the cost of environmental damage, or "externalities") of nuclear and fossil-fueled generation foundered because industry players could not reach consensus. As well, consensus could not be reached during the state’s previous attempt to mandate a set-aside for renewable energy, requiring service providers to maintain a portfolio of renewable energy resources. With the enactment of AB1890, and the CPUC’s preferred policy decision, consumers now have the power to determine the future makeup of the generating mix in California.
J9 The following responses correspond to numbered items listed in the May 13, 1998, letter from Louise Talley, Chairman of the Lake County Board of Supervisors, to the CPUC.
(1) Regarding hydro curtailment, please see response to Comment H6.
(2) Regarding noise mitigation, as stated in Section 4.10 of the DEIR (page 4.10-14), operational noise levels at the Geysers units are not expected to change, or to exceed land use standards as a result of operation by a new owner and no operational noise impacts are expected to occur as a result of operation by a new owner. Section 4.10 also states (page 4.10-15) that steam stacking can result in brief yet substantial noise events. However, a pipe manifold system installed in the mid-1980s (described on page 4.5-47 of the DEIR) has significantly reduced stacking events. The project would not affect operation of the manifold system, so the system’s benefits with respect to noise mitigation would continue. Also see response to Comment H54.
(3) Regarding mercury scrubbers, please see response to Comment H11, fourth paragraph.
(4) Regarding GAMP participation, please see response to Comment H11, second paragraph.
(5) Regarding sumpless drilling, neither PG&E nor the new power plant owners would have any drilling operations at the Geysers; any drilling in the area would be conducted by the steam field operators, whose operations are not part of the proposed project.
(6) Regarding preventive maintenance, as noted in Attachment C of the DEIR (page C-29), a non-utility plant owner would have a greater incentive than a utility (such as PG&E) to invest in plant maintenance, in order to maintain a high level of availability. Also see responses to Comments H23 and H64.
J10 Please see responses to Comments H7, H13, H14, H15, and H46 above. The commenter is correct in that PG&E’s sale of the Geysers generating units would be the first sale of a "green power" generating asset by a utility in California. However, the issues associated with the sale of the Geysers Power Plant are unique, and the CPUC will make its final decision based on the merits of this EIR, and the evidence and comments submitted in the divestiture proceeding. Any decision made in the case would likely not be precedent-setting merely because no other similar utility-owned green power generating asset exists in California (CEC, California Power Plant Data Information, June 1998).
J11 Please see responses to Comments H4, H5, and H7. The issue of economic curtailment at the Geysers is one that arises from restructuring and contract disputes among the current stakeholders, and not from divestiture in any way.
J12 Please see responses to Comments H7, H13, H14, H15, H46, and J8 above.
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