Date: September 21, 1998
From: New York Landing Homeowners Association (NYLHOA)
To: Bruce Kaneshiro, Project Manager
c/o Environmental Science Associates
225 Bush St., Suite 1700
San Francisco, CA 94104

Subj: PG & E Application for Divestiture

Ref: (a) PG&E Public Meeting at PYC on 08/25/98 at 1900;
(b) PG&E "Executive Summary" for Application No. 98-01-008
(c) Application for Certification of PDEF submitted by Pittsburg District Energy Facility, L.L.C. CEC in June of 1998

Encl: (1) Copy of Ref. (c)

Reference (a) was held in accordance with applicable law and provided an oral reiteration of information contained in reference (b) with some additional commentary provided by facilitators and attendees. Reference (c) sets forth data on the PDEF power plant to be constructed by ENRON Capital & Trade Resources Corporation.

PG&E Power Plants located in Contra Costa, Pittsburg and Potrero do not exist in isolation from each other in terms of their cumulative effect relevant to current and future particulate emissions and other toxic hazardous substances. The number of existing refineries, chemical plants, other power plants and heavy industry already in place mandate that careful attention be given to the particulate matter burden already being experienced by the citizens of Pittsburg and Antioch.

Moreover, the thermal and biological effects that both the Pittsburg and Contra Costa PG&E power plants have is a significant impact now and will have in the future on all living beings; this fact cannot be overemphasized!

Specific comments made by your team and the public with regard to the information provided during reference (a) along with relevant questions that have been raised by myself and others are listed below:

[Begin R1]

Comment: (1) The proposed PDEF facility will have a generating capacity of 450 megawatts as shown on an overhead.

[End R1]

[Begin R2]

Comment: (2) Additional power generating facilities were not included in APP.No.98-01-008 to the CPUC because they would not become operational before calendar year 2005 or they would be offset by reduced PG&E power generation.

[End R2]

[Begin R3]

Comment: (3) Pittsburg and Contra Costa PG&E power plants would ideally be owned and operated by the same company due to the need for coordinated power production; but this requirement will not be a conditions of their sale.

[End R3]

[Begin R4]

Comment: (4) The Pittsburg and Contra Costa PG&E power plants will still be operated by PG&E for two years after the date of sale to new owners.

[End R4]

[Begin R5]

Comment: (5) The backup fuel for both Pittsburg and Contra Costa PG&E power plants will be residual oil while the PG&E Potrero power plant will use residual oil and distillate fuel oil for backup fuel.

[End R5]

[Begin R6]

Comment: (6) The cumulative effect of stack emission plumes and their distribution patterns for power plants located within a fixed radius of the PG&E Pittsburg/Contra Costa power plants were not calculated and were also determined to be not significant.

[End R6]

[Begin R7]

Comment: (7) The increase in noise level relevant to increased power generation will not be significant.

[End R7]

[Begin R8]

Comment: (8) The alternative of "no project" was not considered nor was demolition of the PG&E Pittsburg power plant.

[End R8]

[Begin R9]

Comment: (9) CALPINE is preparing to submit its application to the CEC for its 500 – 800 megawatt "Delta Energy Center" Power Plant located in Pittsburg. This facility will go on-line in the year 2002!

[End R9]

[Begin R10]

Question (1) Why doesn’t PG&E and/or ESA know that the proposed PDEF will produce 500 megawatts of power as stipulated in their application to the CEC?

[End R10]

[Begin R11]

Question (2) If the PDEF has submitted its application to the CEC for its 500 megawatt power plant and CALPINE has recently purchased the existing Dow Chemical 70 megawatt power plant for their current operations and will submit its application to the CEC within three months for its "new" 500 – 800 megawatt Delta Energy Center, then why weren’t these facilities included in the "Impact Study" for the PG&E Pittsburg, Contra Costa and/or Protrero power plants application to the CPUC?

[End R11]

[Begin R12]

Question (3) Given the fact that there are five GWF power plants and one mobile power plant in operation between the PG&E power plants mentioned in question (2) above plus PDEF and CALPINE plants, why wasn’t a current baseline study for particulate matter emissions done in the area surrounding the PG&E Pittsburg/ Contra Costa power for existing and proposed power plants?

[End R12]

[Begin R13]

Question (4) Why hasn’t PG&E stipulated in its application to the CPUC that it will make the purchase of offset credits by the "new" owners a condition of sale for the three PG&E power plants that it is seeking to divest in Contra Costa County? Said Offsets would be purchased from within Contra Costa County as their first priority.

[End R13]

[Begin R14]

Question (5) How does the continuance of PG&E management over the new owners of the plant effect its operational profile and/or the business plan prepared by the new owners?

[End R14]

[Begin R15]

Question (6) If the interruption of the natural gas supply has a low probability of occurrence, then why does the PG&E Pittsburg power plant fuel farm continue to maintain their tanks at full capacity when they are now using natural gas to fire their boilers?

[End R15]

[Begin R16]

Question (7) Is PG&E using the Pittsburg PG&E plant fuel farm for TOSCO refinery production storage, delivered by pipeline, and then loading tankers at their fuel pier for shipment to other locations?

Question (8) If they are using the Pittsburg PG&E fuel form for the purposes stated above, do they now have an amended USE PERMIT that allows this process to continue?

[End R16]

[Begin R17]

Question (9) Since Application No. 98-01-008 submitted to the CPUC by PG&E is based upon natural gas fuel statistics, what is the cumulative effect of particulate emissions for a five day period of operation for the three PG&E plants using residual oil and/or distillate fuel?

[End R17]

[Begin R18]

Question (10) Is the Pittsburg PG&E Plant going to be designated as a "must run" facility by the PUC?

[End R18]

[Begin R19]

Question (11) Is the Contra Costa PG&E Plant going to be designated as a "must run" facility by the PUC?

[End R19]

[Begin R20]

Question (12) Is the PG&E Plant at Potrero going to be designated as a "must run" facility by the PUC?

[End R20]

[Begin R21]

Question (13) Is the PUC aware of the fact that CALPINE is in the final stages of submitting its application to the CEC for its 500 – 700 megawatt power plant in Pittsburg?

[End R21]

Thank you for your consideration of these comments and questions.

William G. Glynn
President, NYLHOA

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