November 12, 1998
Mr. Andrew Barnsdale, Project Manager
c/o Environmental Science Associates
225 Bush Street, Ste. 1700
San Francisco, CA 94104

SUBJECT: SDG&E DIVESTITURE MITIGATED ND COMMENTS

Dear Mr. Barnsdale:

The San Diego Unified Port District acknowledges receipt of the Notice of Publication for the California Public Utilities Commissionís (CPUC) Mitigated Negative Declaration and Initial Study for San Diego Gas & Electric Companyís Application No. 97-12-039 Proposal for Divestiture.

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While the Port District may consider the CPUCís Mitigated Negative Declaration before reaching a final decision on its proposed acquisition of the South Bay Power Plant and related facilities, the Port Districtís proposed purchase and continued operation of the existing facilities until they can be closed and decommissioned is eligible for a Class 1 categorical exemption pursuant to CEQA Guidelines Section 15301(b).

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The following are more specific comments related to the content of the Mitigated Negative Declaration.

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Page 4.1-10, 4.1-24

The discussion regarding pertinent planning documents for the South Bay Power Plant neglects to discuss the importance of the Portís jurisdictional influence on the power plant and its surrounding area. The Portís jurisdictional boundary includes land and water area located west of the historic mean high tide line. Within the Chula Vista Bayfront Ė Planning District 7, there is a small parcel of upland leased to the power plant which is designated "Marine Related Industrial." In addition, the power plant leases water area from the Port for purposes of the of the cool water intake and warm water outfall channels. The SDG&E dike which is used to separate these channels and provides access to the Chula Vista Wildlife Reserve, is also leased from the Port for power plant operations. The Chula Vista Wildlife Reserve, dike, and surrounding water area are designated as "Conservation" areas with the intent to preserve, maintain and enhance natural habitat areas so that biological productivity will be sustained. The new owner of the power plant would be required to enter into lease agreement for the upland, water, and dike area.

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Page 4.1-30

The San Diego Unified Port District Master Plan was last updated March 1998.

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Page 4.7-11

As mentioned earlier, the Port has jurisdictional authority over the adjacent water area and the Chula Vista Wildlife Reserve. Agreements to control and limit access to the Chula Vista Wildlife Reserve must be made with the Port.

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Page 4.7-12

Please refer to the Chula Vista Wildlife Island as the Chula Vista Wildlife Reserve.

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If you have any questions regarding the comments provided, please feel free to contact me at (619) 686-6471.

Sincerely,
/s/
MELISSA A. MAILANDER
Environmental Review Coordinator
cc: Dan Wilkens
Tom Morgan
David Chapman

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