November 5, 1998
Mr. Andrew Barnsdale
Project Manager
c/o Environmental Science Associates
225 Bush Street, Suite 1700
San Francisco, CA 94104

Re: MITIGATED NEGATIVE DECLARATION AND INITIAL STUDY -- SAN DIEGO GAS & ELECTRIC COMPANY APPLICATION NO. 97-12-039 FOR AUTHORITY TO SELL ELECTRICAL GENERATION FACILITIES AND POWER CONTRACTS

Dear Mr. Barnsdale:

SDG&E makes the following comments pertaining to the Commissions draft Mitigated Negative Declaration and Initial Study ("Negative Declaration") dated October 13, 1998. Each comment refers to the relevant page, paragraph, and line of the Negative Declaration. In addition, for ease in associating the comments with the Negative Declaration, each comment refers to an identifier code marked in the enclosed copy of the Negative Declaration at the relevant provision, clause, or word.

The comments set forth below do not in any way significantly affect any substantive premise, fact, or circumstance upon which the Commissions environmental analysis under the California Environmental Quality Act ("CEQA") was based. The comments are all minor in scope and if implemented will neither result in a new substantial adverse environmental impact nor substantially increase the severity of any potential environmental impact identified in the Negative Declaration.

[Begin A1]

1. Mitigated Negative Declaration, page 3, paragraph 4.5.b.1, Indentifier Code A: The relevant mitigation measures prohibit economic consumption of non-gaseous fuel after January 1, 2001 at the Encina and South Bay power plants. SDG&E seeks a minor modification to the mitigation measures to enable the owner or operator of those plants to also operate the boilers with non-gaseous fuel after January 1, 2001 for purposes of operational tests, such as testing the functioning of selective catalytic reduction units ("SCR") or other pollution control methodologies, particulate emissions compliance, and operational and reliability compliance with the terms of the ISO "must run" contract(s) as the same are associated with potential (i.e., force majeure) non-gaseous fuel use and use capability. SDG&E requests that the fourth line of each mitigation measure under this paragraph be modified to read as follows: "...because of a force majeure natural gas curtailment as defined in Section (c)(8) of District Rule 69 or as necessary to conduct operational, reliability, or regulatory compliance testing relevant to the use of non-gaseous fuel in such boilers because of a force majeure natural gas curtailment."

[End A1]

[Begin A2]

2. Mitigated Negative Declaration, page 3, paragraph 4.7.a.1, Identifier Code B: The reference to NPDES permits in this paragraph should be deleted. An NPDES permit is a transferable permit.

[End A2]

[Begin A3]

3. Mitigated Negative Declaration, page 4, paragraph 4.7.a.2, Identifier Code C: The reference to NCCP permits should be deleted. NCCP permits are not assignable.

[End A3]

[Begin A4]

4. Mitigated Negative Declaration, page 4, paragraph 4.7.a.3, Identifier Code D: The portion of the cooling water dike falling within the Chula Vista Wildlife Reserve is administered by the San Diego Unified Port District ("Port District"). Consequently, the most appropriate agency to enter the formal agreement pertaining to access is the Port District.

[End A4]

[Begin A5]

5. Mitigated Negative Declaration, page 5, paragraph 4.13.b.1 (Timing), Identifier Code E: The word "at" in the third line of the mitigation measure Timing section should be deleted.

[End A5]

[Begin A6]

6. Initial Study, page 1-4, third full paragraph, line 4, Identifier Code F: Enova Corporation and Pacific Enterprises announced a "plan of merger" rather than "an agreement to combine their companies". Under the plan of merger, Enova Corporation and Pacific Enterprises are separate wholly-owned subsidiaries of a newly formed parent corporation, namely, Sempra Energy.

[End A6]

[Begin A7]

7. Initial Study, page 1-4, third full paragraph, lines 11 and 12, Identifier Code G: SoCalGas and SDG&E are wholly-owned subsidiaries of Pacific Enterprises and Enova Corporation, respectively, rather than Sempra Energy. Also, see Comment 6.

[End A7]

[Begin A8]

8. Initial Study, pages 2-1, first full paragraph, lines 6 and 7, Identifier Code H: Lines 6 and should be modified to read as follows, "...which transports power from the San Onofre Nuclear Generating Station [SONGS] and other sources in California and the northwest,..."

[End A8]

[Begin A9]

9. Initial Study, page 2-1, third paragraph, line 4, Identifier Code I: The word "on" should be deleted and replaced with "connected to".

[End A9]

[Begin A10]

10. Initial Study, page 2-2, third full paragraph, lines 1 and 2, Identifier Code J: See Comment No. 7. The first two lines should be modified to read, "As described in Section 1, Introduction, a series of events (namely implementation of the plan of merger which created Sempra Energy as the new corporate parent of Enova Corporation and Pacific Enterprises)..." Neither Enova Corporation nor Pacific Enterprises merged "into" Sempra Energy.

[End A10]

[Begin A11]

11. Initial Study, page 2-3, second paragraph, lines 4 and 5, Identifier Code K: These lines should be modified to read as follows, "The new owner would be required to take an assignment of SDG&Es must-run contracts with the ISO...."

[End A11]

[Begin A12]

12. Initial Study, page 2-3, first paragraph, last two lines, Identifier Code L: The transaction does not involve a "Bidding Contract," though it is true the Commission must approve the auction process. Otherwise, the Commission will also approve the terms of the Asset Sale Agreements, the Operation and Maintenance Agreements, and the Facilities Services Agreements.

[End A12]

[Begin A13]

13. Initial Study, page 2-6, second paragraph, lines 4 and 5, Identifier Code M: The sentence beginning in line 4 should be modified to read as follows, "If the Port District does not elect to purchase the South Bay power plant under the terms of its agreement with SDG&E by November 14, 1998..."

[End A13]

[Begin A41]

14. Initial Study, page 2-7, first partial paragraph, lines 4 and 5, Identifier N: These lines should be modified to read as follows, "SDG&E would provide the buyer with a license to use a portion of these properties in connection with the buyers ownership and operation of the CTs."

[End A14]

[Begin A15]

15. Initial Study, page 2-7, first full paragraph, lines 6 through 8, Identifier O: Lines 6, 7 and 8 should be modified to read as follows, "SDG&E will receive and consider proposed contract changes from second round bidders prior to the receipt of final bids from the second round bidders. SDG&E will, in its sole discretion, adopt the final form of the contracts. Final bids will then be received. Upon selection of the winning bidder for each asset, SDG&E will submit the final executed contract to the Commission for approval.

[End A15]

[Begin A16]

16. Initial Study, page 2-7, subparagraph 8 of the second full paragraph, Line 2, Identifier Code P: Authorization to obtain recovery of its estimated future generation-related environmental clean-up costs will be sought under Application No. 97-12-039 as a part of SDG&Es compliance filing, rather than in a subsequent application.

[End A16]

[Begin A17]

17. Initial Study, page 2-8, subparagraph 4 of the second full paragraph, line 2, Identifier Code Q: The word "of" should be deleted after the phrase "would be assigned."

[End A17]

[Begin A18]

18. Initial Study, page 2-9, first full paragraph, line 6, Identifier Code R: After the parenthetical, the next phrase should read, "...but to eliminate any other deed restrictions..."

[End A18]

[Begin A19]

19. Initial Study, page 2-9, third full paragraph, lines 7 through 10, Identifier Code S: These lines should be modified to read as follows, "Decommissioning includes the decontamination, demolition, dismantlement, and removal of any portions of the plant included among the assets being sold, and remediation of the soil and groundwater below the same as more fully described in the Asset Sales Agreement.

[End A19]

[Begin A20]

20. Initial Study, page 2-10, lines 1 through 3, Identifier Code T: The following phrase should be added to the end of the first full sentence, "...except that the Port District may elect to have SDG&E remediate such property to meet industrial standards subject to the terms of the agreement between the Port District and SDG&E.

[End A20]

[Begin A21]

21. Initial Study, page 2-11, Table 2.1, for Encina and South Bay CT1, Identifier Code U: The capacity factors of "2.0" for the Encina and South Bay CT1 in Table 2.1 should be changed to approximately 0.2% for the Encina and South Bay CT1s.

[End A21]

[Begin A22]

22. Initial Study, page 2-12, first full paragraph, lines 4 and 5, Identifier Code V: The parenthetical should reflect that PSEG recently purchased the unit from a Bank of America affiliate, rather than from B of A itself.

[End A22]

[Begin A23]

23. Initial Study, page 2-12, third full paragraph, lines 3 and 4, Identifier Code W: These lines should be modified to read as follows, "SDG&E would retain the switchyard facilities and equipment and would reserve from the real property transfer an easement over such property providing SDG&E with rights of access for maintenance, repair, upgrade, and use of such facilities and equipment and other areas used for transmission and distribution purposes."

[End A23]

[Begin A24]

24. Initial Study, page 2-13, Table 2.3, line 8, Identifier Code X: The arrow indicating the Encina Power Plant on Table 2.3 points to the north shore of the inner lagoon, rather than the principal assets of the power plant. For clarity, either the arrow should be redirected to the principal assets or the legend should be changed to "Encina Power Plant Property."

[End A24]

[Begin A25]

25. Initial Study, page 2-16, first full paragraph, lines 1 and 4, Identifier Code Y: Please add the word "approximately" before the phrases "116-acre site." in line 1 and "16-acre transmission corridor" in line 4.

[End A25]

[Begin A26]

26. Initial Study, page 2-20, third full paragraph, lines 7 through 10, Identifier Code Z: Displacement oil is no longer used to fill the pipeline between residual fuel oil shipments to the power plant. Between shipments, the pipeline is now filled with nitrogen gas.

[End A26]

[Begin A27]

27. Initial Study, page 2-26, Figure 2.12, Identifier Code AA: The Division Street CT is located on property owned by SDG&E. The "blue" line marks the "Boundary of the SDG&E site" where the CT is located rather than the "Boundary of the combustion turbine site" as now described on Figure 2.12. The Naval Station CT is located on property owned by the Navy. The new owner of the Division Street CT will acquire a license (rather than a lease) from SDG&E providing access to the CT site. The new owner of the Naval Station CT will acquire access rights pursuant to SDG&Es access agreement with the Navy.

[End A27]

[Begin A28]

28. Initial Study, page 2-28, Figure 2.14, Identifier Code BB: The "blue" line marks the "Boundary of the SDG&E site" where the CT is located rather than the "Boundary of the combustion turbine site" as now described on Figure 2.14. The correct boundaries of the site to be licensed to the new owner for operation of the CT are reflected in Attachment A. The new owner will acquire access to the site through a license (rather than a lease) from SDG&E.

[End A28]

[Begin A29]

29. Initial Study, page 2-31, Figure 2.16, Identifier Code CC: The "blue" line marks the "Boundary of the SDG&E site" where the CTs are located rather than the "Boundary of the combustion turbine site" as now described on Figure 2.16. The new owner will acquire access to the Kearny CTs through a license (rather than a lease) from SDG&E.

[End A29]

[Begin A30]

30. Initial Study, page 2-33, Figure 2.18, Identifier Code DD: The "blue" line marks the "Boundary of the SDG&E site" where the CTs are located, rather than the "Boundary of the combustion turbine site" as now described on Figure 2.18. The correct boundaries of the site to be licensed to the new owner for operation of the CTs are reflected in Attachment B. The new owner will acquire access to the site through a license (rather than a lease) from SDG&E.

[End A30]

[Begin A31]

31. Initial Study, page 2-35, Figure 2.20, Identifier Code EE: The new owner will acquire access to the site pursuant to SDG&Es access agreement with the Navy.

[End A31]

[Begin A32]

32. Initial Study, page 2-36, first partial paragraph, lines 5 and 6, Identifier Code FF: The sentence reading, "SDG&E leases one additional above-ground tank at the site to Energy Factors, Inc." is inaccurate and should be deleted.

[End A32]

[Begin A33]

33. Initial Study, page 2-38, Figure 2.22, Identifier Code GG: See Comment No. 31.

[End A33]

[Begin A34]

34. Initial Study, page 2-36, second full paragraph, lines 7 through 9, Identifier Code HH: Lines 7 and 12 should be modified to read as follows, "Unit 1 was constructed in 1967 and retired, after 25 years of service, on November 30, 1992. Unit 1 had a net generating capacity of 436 MW. Unit 1 has not yet been decommissioned.

[End A34]

[Begin A35]

35. Initial Study, page 2-36, last partial paragraph, last line, Identifier Code II: The following sentence should be added to the last line, "Moreover, SDG&E and Edison are tenant-in-common with respect to Unit 1.

[End A35]

[Begin A36]

36. Initial Study, page 2-36, second full paragraph, lines 3 and 4, Identifier Code JJ: The sentence beginning on line 3 should be modified to read as follows, "SONGS has two active generating units (Units 2 and 3) and one retired generating unit (Unit 1). Units 2 and 3 have a combined net generating capacity of 2,150 MW, enough power to serve the needs of roughly 2.75 million households.

[End A36]

[Begin A37]

37. Initial Study, page 2-39, Table 2.3, Identifier Code KK: Table 2.3 should reflect the ownership shares of Unit 1 and the Unit 1 area in which SDG&E holds a 20% interest and in which Edison holds an 80% interest.

[End A37]

[Begin A38]

38. Initial Study, page 2-39, last partial paragraph, line 2, Identifier Code LL: This line should be modified to read, "...refusal to purchase SDG&Es ownership interest in the SONGS Units 2 and 3 facilities and Edison has a contractual right of first refusal to pruchase SDG&Es ownership interest in Unit 1."

[End A38]

[Begin A39]

39. Initial Study, page 3-6, first partial paragraph, lines 4, 5, and 6, Identifier Code MM: The phrase "...such as the Regional Water Quality Control Board for an NPDES permit" should be deleted. NPDES permits are automatically transferable (40 CFR 122.61(b)). In the 6th line, the word "that" should be "than".

[End A39]

[Begin A40]

40. Initial Study, page 3-7, second full paragraph, line 3, Identifier Code NN: After "Pacific Gas and Electric Company" the parenthetical "(PG&E)" should be added.

[End A40]

[Begin A41]

41. Initial Study, page 4.1-3, third full paragraph, lines 5 through 12, Identifier Code OO: These lines should be modified to read as follows, "A sea bass fish hatchery operated by the Hubbs-Seaworld Research Institute (which leases approximately 10 acres on the north shore) and a mussel farm are located in the outer basin. A YMCA camp is present in the middle basin. The Snugg Harbor Marina which rents equipment for jetskiing, sailboarding and waterskiing, is located in the inner basin, which is otherwise generally open to boating and jetskiing. The approximately 200 acres of wetlands at the east end of the inner basin are attractive to hikers and bird watchers. Also included at the project site is a roughly 20-acre section of beach west of Carlsbad Boulevard."

[End A41]

[Begin A42]

42. Initial Study, page 4.1-2, last partial paragraph, line 2, Identifier Code PP: Cannon Park is "leased" to the City of Carlsbad. It was not "given" to the City of Carlsbad.

[End A42]

[Begin A43]

43. Initial Study, page 4.1-4, second full paragraph, line 1, Identifier Code QQ: The word "approximately" should be inserted before the phrase "116-acre site."

[End A43]

[Begin A44]

44. Initial Study, page 4.1-6, first full paragraph, lines 9 through 11, Identifier Code RR: The contract between the Navy and SDG&E, relative to use of the land, has been extended for 30 months.

[End A44]

[Begin A45]

45. Initial Study, page 4.1-7, second full paragraph, lines 15 and 16, Identifier Code SS: The sentence reading, "It does not appear that the existing use conforms with this zoning designation" should be deleted and replaced with, "Acquaculture is permitted under zoning designation R-A-10 with a Conditional Use Permit (CUP)(Carlsbad Municipal Code 21.42.010(1)(L)). The City of Carlsbad has issued a CUP for the Hubbs-Seaworld use."

[End A45]

[Begin A46]

46. Initial Study, page 4.1-7, last partial paragraph, last line, Identifier Code TT: In the phrase, "Although that it does not appear that the lack of an ...," the first "that" should be deleted as unnecessary.

[End A46]

[Begin A47]

47. Initial Study, page 3-10, Table 3.1, Identifier Code UU: All of the steam boilers are capable of burning natural gas and oil. All of the CTs, except Division and North Island are capable of burning natural gas and diesel. Division and North Island are only capable of burning diesel.

[End A47]

[Begin A48]

48. Initial Study, page 4.1-24, fourth full paragraph, line 4, Identifier Code VV: The sentence beginning on line 3 should be modified to read as follows, "The new owner of the CT will be entitled to access to and the continued use of the site in accordance with SDG&Es access agreement with the Navy."

[End A48]

[Begin A49]

49. Initial Study, page 4.1-25, third full paragraph, lines 4 and 5, Identifier Code WW: See Comment 48.

[End A49]

[Begin A50]

50. Initial Study, page 4.1-26, second full paragraph, lines 3 and 4, Identifier Code XX: See Comment 48.

[End A50]

[Begin A51]

51. Initial Study, page 4.1-28, first full paragraph, line 2, Identifier Code YY: The word "on" should be deleted.

[End A51]

[Begin A52]

52. Initial Study, page 4.4-5, second full paragraph, lines 9 through 11, Identifier Code ZZ: In addition to permits issued by the California Coastal Commission and the U.S. Army Corps of Engineers, SDG&E holds permits or other entitlements from other State agencies, such as the Regional Water Quality Control Board, the State Lands Commission and State Parks, for its dredging activities.

[End A52]

[Begin A53]

53. Initial Study, page 4.4-7, first full paragraph, line 4, Identifier Code AAA: After the words "Regional Board" insert the words "Basin Plan" and delete the words "Water Quality Control Plan."

[End A53]

[Begin A54]

54. Initial Study, page 4.4-7, last paragraph, lines 4 and 5, Identifier Code BBB: Metal cleaning waste discharges are intermittent having a frequency associated with boiler cleanings. They are not daily. A boiler may only be cleaned once a year. Low volume wastes are typically about 100,000 gallons per day, but can be substantially higher on some days involving infrequent operations generating high volumes of low volume wastes, such as boiler blowdowns, condensor cleanings, and especially fuel line/tank hydrotesting. The permit allows up to about 1 million gallons of low volume and metal cleaning waste per day, presuming all operations generating low volume waste may occur on a single day. However, as of December 1997, all low volume and metal wastes generated at South Bay are discharged to sewer.

[End A54]

[Begin A55]

55. Initial Study, page 4.4-10, second full paragraph, lines 4 through 7, Identifier Code CCC: The cooling water pumps are not variable speed. They each have a rated capacity but are either on or off. Each unit is equipped with two cooling water pumps. Cooling water volumes and discharge temperature (depending on generating load) can be adjusted by turning these pumps on or off. The foregoing language should be used in place of the language in lines 4 through 7.

[End A55]

[Begin A56]

56. Initial Study, page 4.4-10, third full paragraph, line 11 through 19, Identifier Code DDD: The allowable concentration of residual chlorine established in the "final limits" (effective December 1999) in Regional Board Order 96-05 as issued November 1996, represented a substantial reduction from the residual chlorine limit in prior permits. The more stringent limit was due to the Regional Boards use of the California Ocean Plan as the basis for the limit. SDG&E appealed the chlorine residual limit, along with other provisions of Order 96-05, to the State Water Resources Control Board (SWRCB) and ultimately to the San Diego County Superior Court. Resolutions of all appealed issues before the SWRCB and before the Superior Court were reached among SDG&E, the Regional Board, and other interested parties and have been implemented through two addendums (amendments) to Order 96-05 adopted by the Regional Board in February and October 1998.

[End A56]

[Begin A57]

57. Initial Study, page 4.4-11, first partial paragraph, line 1, Identifier Code EEE: The treated wastewaters, after testing and verification, are discharged to the sewer and are no longer authorized under the plants NPDES permit.

[End A57]

[Begin A58]

58. Initial Study, page 4.4-13, first full paragraph, lines 4 and 5, Identifier Code FFF: The sentence beginning with "The beneficial use" should be deleted and replaced with, "The beneficial uses for the receiving water are identified in the Regional Boards Basin Plan.

[End A58]

[Begin A59]

59. Initial Study, page 4.4-13, second full paragraph, lines 2 and 3, Identifier Code GGG: See Comment 57.

[End A59]

[Begin A60]

60. Initial Study, page 4.4-15, second full paragraph, line 4, Identifier Code HHH: Please delete the words "the predominant" from line 4. Natural thermal loading, especially in the shallow back-bay environments of San Diego Bay are a major source of thermal loading.

[End A60]

[Begin A61]

61. Initial Study, page 4.4-15, third full paragraph, line 7, Identifier Code III: Metal cleaning and low volume wastes are regulated at Encina by the NPDES permit and at South Bay by the sewer permit.

[End A61]

[Begin A62]

62. Initial Study, page 4.4-15, fourth full paragraph, lines 2 through 13, Identifier Code JJJ: See Comment 55.

[End A62]

[Begin A63]

63. Initial Study, page 3-5, fifth full paragraph, lines 4 through 8, Identifier Code KKK: The SDAPCD has not announced any intention to modify Rule 69. Rule 69, as written, will require each unit transferred by SDG&E to a new owner (in which SDG&E does not hold a controlling interest) to achieve prescribed NOx emission rate limits, rather than the system-wide NOx emission cap that currently applies to SDG&E owned units.

[End A63]

[Begin A64]

64. Initial Study, pages 3-7 last line and 3-8 first line, Identifier Code LLL: Rule 69.3 limits the emissions of NOx from the CTs. Rules 68 and 69 limit NOx emissions from the power plant boilers, not the CTs.

[End A64]

[Begin A65]

65. Initial Study, page 4.5-13, Table 4.5-3, Identifier Code MMM: In footnotes "a" and "b", delete the word "state" in the second line of each.

[End A65]

[Begin A66]

66. Initial Study, page 4.5-16, first full paragraph, line 1, Identifier Code NNN: In the first line, the word "Benzene" should be deleted and replaced with the word "Toluene."

[End A65]

[Begin A67]

67. Initial Study, page 4.5-17, second full paragraph, lines 4 and 5, Identifier Code OOO: The Encina power plant does not have a gasoline dispensing facility. One does exist on adjacent SDG&E land occupied by SDG&Es North Coast Construction and Operation Center. Hence, the fourth sentence of this paragraph should be deleted.

[End A67]

[Begin A68]

68. Initial Study, page 4.5-17, fifth full paragraph, line 4, Identifier Code PPP: At the end of the paragraph add, "...and no NOVs are outstanding."

[End A68]

[Begin A69]

69. Initial Study, page 4.5-19, first partial paragraph, line 5, Identifier Code QQQ: In the fifth line, the word "fuel" should be "flue" and "NOx emissions boiler" should read "boiler Nox emissions."

[End A69]

[Begin A70]

70. Initial Study, page 4.5-21, first full paragraph, line 6, Identifier Code RRR: See Comment 67.

[End A70]

[Begin A71]

71. Initial Study, page 4.5-22, fifth full paragraph, line 4, Identifier Code SSS: See Comment 68.

[End A71]

[Begin A72]

72. Initial Study, page 4.5-26, first partial paragraph, line 2, Identifier Code TTT: With electric restructuring and ISO dispatching, the CTs are operating more often. See Combustion Turbines, on pages 2-20 and 2-23.

[End A72]

[Begin A73]

73. Initial Study, page 4.5-26, fourth full paragraph, lines 8 and 9, Identifier Code UUU: See Comment 72.

[End A73]

[Begin A74]

74. Initial Study, page 4.5-28, second full paragraph, line 1, Identifier Code VVV: The word "has" should be deleted and replaced with "was."

[End A74]

[Begin A75]

75. Initial Study, page 4.5-32 and 4.5-33, Tables 4.5.11 and 4.5.12, Identifier Code WWW: Footnote (d) should reflect that in addition to force majeure, oil may be burned for operational, regulatory compliance and reliability tests. See Comment 1.

[End A75]

[Begin A76]

76. Initial Study, pages 4.5-36, third paragraph, and 4.5-37, Table 4.5.14, Identifier Code XXX: SDG&Es 2100 ton NOx emissions cap does not apply to the CTs. Table 4.5.14 combines the NOx emissions from South Bay, Encina, and the CTs together (see third, fourth and fifth paragraphs on page 4.5-36) for purposes of estimating NOx emissions for the 1999, A-Max, and 2005 scenarios. It would be inappropriate to use Table 4.5.14 estimated emissions to predict SDG&Es compliance with Rule 69. The CTs should be excluded from any such Rule 69 analysis.

[End A76]

[Begin A77]

77. Initial Study, page 4.5-38, Identifier Code YYY: See Comment 76.

[End A77]

[Begin A78]

78. Initial Study, page 4.5-42, second full paragraph, lines 3 and 4, Identifier Code ZZZ: With regard to the "gasoline dispensing facility" please see Comment 67.

[End A78]

[Begin A79]

79. Initial Study, page 4.5-46, first full paragraph, Mitigation Measures 4.5.b.1, Identifier Code AAAA: See Comment 1.

[End A79]

[Begin A80]

80. Initial Study, page 4.5-47, fourth full paragraph, line 4, Identifier Code BBBB: See Comment 1.

[End A80]

[Begin A81]

81. Initial Study, page 4.7-6, first full paragraph, line 12, Identifier Code CCCC: The phrase "and under the same regulations as" should be deleted from line 12 as the thermal discharge requirements for Unit 5 (even other than the requested exceptions) are not the same as for Units 1, 2, 3 and 4.

[End A81]

[Begin A82]

82. Initial Study, page 4.7-6, last partial paragraph, line 1, Identifier Code DDDD: Please insert the word "approximately" before "4 million cubic yards."

[End A82]

[Begin A83]

83. Initial Study, page 4.7-10, fifth full paragraph, line 3 through 5, Identifier Code EEEE: See Comment 26.

[End A83]

[Begin A84]

84. Initial Study, page 4.7-11, third full paragraph, Identifier Code FFFF: Please delete this paragraph and replace it with the following, "Since then, SDG&E sought renewal of its NPDES permit. The Regional Board issued such renewal as Order 96-05 in November 1996, which was amended in February and October 1998. Order 96-05 requires SDG&E to conduct further limited thermal effects studies, which are being conducted.

[End A84]

[Begin A85]

85. Initial Study, page 4.7-14, last partial paragraph, line 4, Identifier Code GGGG: The last line should be modified to read "SDG&E will apply to transfer NPDES to the new owners." NPDES permits are transferable.

[End A85]

[Begin A86]

86. Initial Study, page 4.7-16, Mitigation Measure 4.7.a.1, Identifier Code HHHH: Please delete "NPDES" permits from this measure as they are transferable.

[End A86]

[Begin A87]

87. Initial Study, page 4.7-16, Mitigation Measure 4.7.a.2, Identifier Code IIII: Please delete NCCPs from this measure as they are not assignable.

[End A87]

[Begin A88]

88. Initial Study, page 4.7-16, Mitigation Measure 4.7.a.4, Identifier Code JJJJ: Delete the entire last line on page 4.7-16 as duplicative of line 1 on page 4.7-17.

[End A88]

[Begin A89]

89. Initial Study, page 4.7-13, second full paragraph, Identifier Code KKKK: The vernal pool communities are not affected by operation of the Miramar CT. The least terns at NTC are not located on the CT site and are not affected by operation of the NTC CT.

[End A89]

[Begin A90]

90. Initial Study, page 4.9-3, third full paragraph, line 7, Identifier Code LLLL: The EPA Identification number for Encina is CAT0006189000, not CAT000619056.

[End A90]

[Begin A91]

91. Initial Study, page 4.9-7, third full paragraph, lines 6 through 12, Identifier Code MMMM: "Phase I and limited Phase II Environmental Site Assessments have been conducted for the LNG site. No hazardous substances were determined to be present on the LNG site. No assessments were conducted for the 16-acre transmission corridor." The foregoing should be inserted in place of lines 6 and 7. The balance of the paragraph should be deleted. Whether SDG&E or the Port District will undertake any further assessment or any required remediation will depend upon whether the Port District exercises certain options in its agreement with SDG&E.

[End A91]

[Begin A92]

92. Initial Study, page 4.9-7, fourth full paragraph, line 5, Identifier NNNN: The Division CT is fueled only by diesel.

[End A92]

[Begin A93]

93. Initial Study, page 4.9-11, first full paragraph, lines 4 through 9, Identifier Code OOOO: Arsenic was determined to be at background (i.e., naturally occurring) levels for soils and groundwater.

[End A93]

[Begin A94]

94. Initial Study, page 4.9-12, third full paragraph, lines 6 and 7, Identifier Code PPPP: During periods of non-use the pipeline is now filled with nitrogen rather than diesel.

[End A94]

[Begin A95]

95. Initial Study, page 4.9-19, third full paragraph, line 1 through 4, Identifier Code QQQQ: SDG&Es obligations are limited to remediating Existing Soils Contamination at the fossil-fuel generating facilities, as defined in the Asset Sales Agreement, to an industrial level commensurate with the continued use of the property as a fossil fuel steam electric generating facility or a substantially similar use. SDG&ES obligations in this regard arise upon closing of the sale of each such generating asset.

[End A95]

[Begin A96]

96. Initial Study, page 4.12-13, second and fourth full paragraphs, lines 6 for each, Identifier Code RRRR: Applicable sewer and stormwater NPDES permits will be "transferred or reissued, as appropriate."

[End A96]

[Begin A97]

97. Initial Study, page 4.16-13, first full paragraph, line 9, Identifier Code SSSS: After "more information" in line 9, please insert the words "on which."

[End A97]

[Begin A98]

98. Initial Study, page 4.16-15, fifth full paragraph, lines 4 and 5, Identifier Code TTTT: The sentence beginning on line 4 should be modified to read as follows, "Additionally, permits from the U.S. Army Corps of Engineers and streambed alteration agreements with California Department of Fish and Game will be required for any streambed or wetland alterations."

[End A98]

[Begin A99]

99. Initial Study, page 2-12, second full paragraph, lines 1 through 4, Identifier Code UUUU: Approximately 380 acres are being sold with SDG&E retaining approximately 294 acres of the land comprising and surrounding Encina. These lands are depicted on Figures 2.3.

[End A99]

[Begin A100]

100. Initial Study, page 4.16-9, first full paragraph, lines 10 through 13, Identifier Code VVVV: This sentence should be modified to read as follows, "In the event that the Port District purchases the South Bay plant, the Port District may enter into an agreement with an experienced operating entity to operate the South Bay Power Plant after the two year Operation and Maintenance agreement with SDG&E expires."

[End A100]

If you have any questions, please call me at (619) 699-5106.

Sincerely,
James R. Dodson
Attorney
JRD/emh

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