September 24, 1997
Mr. Bruce Kaneshiro,
Project Manager
Environmental Science Associates
225 Bush Street, Suite 1700
San Francisco, CA 94104
RE: COMMENTS ON THE
MITIGATED NEGATIVE DECLARATION FOR SOUTHERN CALIFORNIA EDISON
COMPANY'S APPLICATION FOR DIVESTITURE AND SALE OF POWER PLANTS
(Docket No. 96-11-046)
The comments of the City
of Redondo Beach on the subject application are contained in my
letter to you dated September 23, 1997, included as Exhibit
"A" to the attached Resolution of the City Council
authorizing the filing of these comments. Please notice that the
Resolution recites that these comments were reviewed and approved
by the City Council after a public meeting thereon. They reflect
the strong feelings of the City Council and the people of Redondo
Beach on this subject.
Very truly yours,
PAUL CONNOLLY
City Manager
cjl
cc: Public Utilities
Commission
RESOLUTION
NO. 7955
A
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF REDONDO BEACH,
CALIFORNIA, APPROVING AND AUTHORIZING THE FILING OF CERTAIN
DOCUMENTS IN THE PROCEEDING BEFORE THE CALIFORNIA PUBLIC
UTILITIES COMMISSION (DOCKET NO. 96-11-046) REGARDING THE
PROPOSED MITIGATED NEGATIVE DECLARATION FOR THE APPLICATION OF
SOUTHERN CALIFORNIA EDISON COMPANY FOR DIVESTITURE AND SALE OF
ITS FOSSIL FUEL GENERATING PLANTS, INCLUDING ITS REDONDO BEACH
PLANT
- - - - -
- - 
WHEREAS, on April 9,
1997 the City of Redondo Beach submitted comments on the scope
and content of environmental review for the application by
Southern California Edison (Docket No. 96-11-046) for divestiture
and sale of its fossil fuel generating plants, including its
Redondo Beach plant, as set forth in Exhibit "C"
herein; and
WHEREAS, on July 2, 1997
the City of Redondo Beach submitted further comments on the Draft
Initial Study consisting of 33 specific items covering the need
for technical corrections with requests for further study and
information on anticipated local impacts which were not addressed
in the draft document, as set forth in Exhibit "B"
herein; and
WHEREAS, on September
23, 1997, this City Council held an additional regular meeting at
which time it reviewed, with input from the public, additional
comments to be submitted for the proposed Mitigated Negative
Declaration prepared for this project, as set forth in Exhibit
"A" herein. 
NOW THEREFORE, the City
Council of the City of Redondo Beach does resolve as follows:
SECTION 1.
1. That it hereby
approves and authorizes the filing of the comments on the
proposed Mitigated Negative Declaration of the application of
Southern California Edison Company regarding the divestiture and
sale of its fossil fuel generating plants, including its Redondo
Beach plant, (Docket No. 96-11-046) as set forth in Exhibit
"A" herein.
[Begin CRB-0]
2. That this City Council, in submitting the comments set forth
in Exhibit "A" herein and resubmitting the comments set
forth in Exhibit "B" and "C" herein, hereby
expresses to the California Public Utilities Commission and its
consultant, Environmental Science Associates (ESA), its strong
belief and finding that mitigation measures have not been
incorporated into the proposed Mitigated Negative Declaration to
reduce all the reasonably foreseeable impacts of the project to
less than significant; provided, however, that this City Council
does not request that the Commission determine that an
Environmental Impact Report (EIR) be required for this project.
[End CRB-0]
SECTION 2. The City
Clerk is hereby authorized and directed to send a copy of this
Resolution with exhibits to each member of the California Public
Utilities Commission, to the Executive Director of the
Commission, to the General Counsel of the Commission, to
Environmental Science Associates (ESA), to the South Bay Council
of Governments, and to the State Clearinghouse.
SECTION 3. The City
Clerk shall certify to the passage and adoption of this
resolution, shall enter the same in the book of Resolutions of
said City, and shall cause the action for the City Council in
adopting the same to be entered in the official minutes of said
City Council.
Passed, approved, and
adopted this 23 day of September, 1997.
/s/____________________________
Mayor
ATTEST
City Clerk
(SEAL)
APPROVED AS TO FORM:
/s/
City Attorney
STATE OF CALIFORNIA
COUNTY OF LOS ANGELES ss
CITY OF REDONDO BEACH 
 
 
 
I, JOHN OLIVER, City
Clerk of the City of Redondo Beach ,California, do hereby certify
that the foregoing resolution, being Resolution No. 7955 was
passed and adopted by the City council, at an additional regular
meeting of said Council held on the 23rd day of September, 1997,
and thereafter signed and approved by the Mayor an attested to by
the City Clerk of said City, and that said resolution was adopted
by the following vote:
    
        
            AYES:
            Council members Bisignano, Sullivan, Gin Pinzler, and
            White.
            NOES: None.
            ABSENT:
            None.
            City Clerk
            of the City of 
            Redondo Beach, California
            
                
                    
                        
                            
                                
                                    
                                         
                                    
                                
                            
                        
                    
                
            
        
    
September 23, 1997
 
Bruce Kaneshiro, Project
Manager
c/o Environmental Science Associates
225 Bush Street, Suite 1700
San Francisco, California 94104
VIA: electronic mail
esa.sf@ix.netcom.com
and facsimile 415-896-0332
Dear Mr. Kaneshiro:
The City of Redondo
Beach is pleased to have the opportunity to provide comments on
the Mitigated Negative Declaration for Southern California Edison
Company's Application No. 96-11-046.
Following our review of
this document, it is our opinion that insufficient information is
contained in the Initial study to justify finding of no
significant impact in several areas. These areas are discussed in
our comments below. Absent this additional analysis, many
conclusions of this study appear unsubstantiated.
[Begin CRB-1]
    - Section 15206 of
        the California Environmental Quality Act Guidelines
        (Guidelines) prescribes that the Negative Declaration or
        EIR for projects of Statewide, Regional or Areawide
        Significance shall be submitted to the State
        Clearinghouse and the appropriate Council of Governments.
        Our review of the distribution listing does not indicate
        that these organizations have received service of the
        documents. This requirement is also contained in Section
        15073(c) of the Guidelines.
[End CRB-1]
[Begin CRB-2]
    - Appendix G of the
        Guidelines contains a listing of effects of a project,
        which are normally deemed significant. As evidenced in
        the comments listed below, it is our opinion that the
        project may have significant effects in that:
    - The project could
        conflict with adopted environmental plans and goals of
        the community where it is located.
- The project may
        encourage activities, which result in the use of large
        amounts of fuel, and water.
- The project could
        increase substantially the ambient noise levels for
        adjoining areas, and, 
- The project could
        create potential public health hazard or involve the use,
        production and disposal of materials, which pose a hazard
        to people or animal or plant populations in the area
        affected.
[End CRB-2]
[Begin CRB-3]
    - Page 4 of the
        Mitigated Negative Declaration (MND) contains a
        typographical error. The third paragraph, first sentence
        should read ". . . consultation or evaluation of
        [or] a qualified archeologist . . ."
[End CRB-3]
[Begin CRB-4]
    - Page 2.5 notes that
        Edison would provide, "An indemnity for specific
        categories of known and unknown liabilities, subject to
        certain exceptions." With respect to environmental
        liabilities, please specify what categories of known and
        unknown liabilities would be subject to indemnification
        and which would be exempted. As statement following this
        sentence notes that Edison would "generally" be
        responsible for conditions, which pre-date the sale,
        subject to certain limitations. In view of the project
        involves transfer of ownership, the assignment of
        environmental liabilities may have a significant effect
        on the timing and cost of site remediation. Therefore, a
        complete disclosure of the nature and extent of
        environmental contamination including costs of
        remediation should be included for each divested
        facility.
[End CRB-4]
[Begin CRB-5]
    - Page 4.9.13 states
        that " . . . appropriate Phase I and Phase II
        Environmental Site Investigations have been
        conducted." However, elsewhere in the document it
        states that the Phase Two Investigation is underway at
        the Redondo facility. If such analysis is complete, the
        results of such studies should be included, as such
        results were included for other plants analyzed in the
        initial study. (Example San Bernadino)
[End CRB-5]
[Begin CRB-6]
    - Page 2.8 contains a
        typographical error in the first paragraph. A space
        should be inserted between the words "easement"
        and "and".
[End CRB-6]
[Begin CRB-7]
    - Page 4.1.7 states
        that Redondo Beach's Harbor/Civic Center Specific Plan
        serves as the Local Coastal Plan. Therefore, absent local
        coastal permit authority, any project will be required to
        be submitted to the California Coastal Commission for
        consideration.
[End CRB-7]
[Begin CRB-8]
    - Page 4.11.190
        discusses the shift in regulatory structure and indicates
        that, "This new regulatory structure would shift
        regulatory authority over divested sites and facilities
        to local jurisdiction." Included in this new
        regulatory responsibility are permitting authority and
        hazardous materials oversight and regulation. Although
        local jurisdiction is desired, the impact of these
        additional responsibilities on the Planning, Building,
        Fire and Engineering Departments will be significant, as
        personnel training or the hiring of new employees with
        expertise in these fields will be required. Under current
        budgetary constraints this impact is significant.
        Appropriate mitigation to offset the service delivery
        impact should be required.
[End CRB-8]
[Begin CRB-9]
    - Pages 4.1.16,
        4.1.17 and 4.1.25 conclude that the plans are consistent
        with the uses intended under the applicable General Plans
        and Zoning Ordinances. This issue was raised in
        conjunction with the consideration of an application by
        Edison for a Lot Line Adjustment at the Redondo Beach
        facility. The Planning Commission or the City Council on
        appeal is responsible for making this determination with
        appropriate input and recommendations of staff. Since
        Edison has not proceeded to re-file an application for
        partitioning of the subject property, which potentially
        raises the issues of zoning consistency and General Plan
        conformance, a determination on this issue has not been
        made.
[End CRB-9]
[Begin CRB-10]
    - Page 3.1 of the
        Draft Initial Study stated that, "With divestiture,
        any new buyer . . . would have a strong incentive to
        operate the facility up to its available capacity. .
        ." However, Language in the Revised Initial Study
        has been revised to consider additional operation as
        "probable." Please include any new or
        additional information, modeling or other studies, which
        support the new conclusion.
[End CRB-10]
[Begin CRB-11]
    - As commented ion
        the Initial Study, the Redondo Beach facility has been
        operated as a load following plant for over 10 years,
        operating at approximately 30% of capacity. Any increase
        in operation will result in significant, quantifiable
        environmental impacts. Increased levels of operation have
        been shown to have significant environmental impacts,
        which require mitigation. Analysis of these impacts was
        performed in the environmental review process for the
        proposed merger of southern California Edison with San
        Diego Gas and Electric in 1990 and the proposed
        installation of Selective Catalytic Reduction (SCR) in
        1992. Any increase in operation of the facility is
        expected to result in significant impacts in the
        following areas: Noise, Fish Population, Air Emissions
        and Transportation and Storage of Hazardous Materials
        (particular Aqueous Ammonia and Vanadium Pentoxide
        Catalyst).
[End CRB-11]
[Begin CRB-12]
    - The Mitigated
        Negative Declaration and Initial Study now contain two
        Figures. One depicts the Redondo Beach Facility with a
        lot line adjustment the other without. Text in the
        document indicates that he project does not include the
        consideration of a lot line adjustment. Please clarify
        the correct description of the project. The
        reparcelization of the existing facility raises
        significant issues related to land use and zoning.
        Specifically, the operation of a bulk fuel storage area
        as a separate use is not recognized as a permitted
        activity under local land use standards. A determination
        as to whether this use would be considered ancillary to
        the operation of the power plant has not been made at
        this time. Further, reparcelization appears to result in
        irregular lot configuration and raises significant
        concerns with respect to access, circulation, and
        adequacy of streets, storm drains and other
        infrastructure. A determination as to conformance with
        local Zoning and Building requirements has not been made
        , due to the fact that Edison has not produced
        information to demonstrate conformance. A full analysis
        of the effects of the physical land division should be
        required to each facility proposed for divestment. (See
        comment No. 9)
[End CRB-12]
[Begin CRB-13]
    - The Redondo Beach
        General Plan and Harbor/Civic Center Specific Plan
        contain numerous primary and supplemental land use
        policies which mandate comprehensive planning for the
        reuse of the subject site for non-industrial use, in
        anticipation of the end of the economic and physical life
        of the plant. Units 1-4 were installed in 1948 and 1949
        and are in long term shutdown. Unit 4 is occasionally
        operated to provide auxiliary plant steam. The age of the
        equipment, and of the inefficient heat rate of these
        units have been stated to make these units uneconomical
        to operate. Units 7 and 8 began operation on 1967 and are
        moderately efficient when compared to new generation
        technologies. 
 
 For the
        above reasons, environmental analysis should consider two
        project alternatives; reuse of the subject property for
        non-industrial development and repowering of the facility
        with new modern and efficient equipment. Either scenario
        is reasonably foreseeable in view of the age of the
        facilities. In the event that repowering is evaluated,
        detailed analysis and modeling with respect to noise,
        vibration and emissions should be conducted on a local
        level. In evaluating reuse, the potential development of
        the transmission corridors in conjunction with the plant
        site must be considered.
[End CRB-13]
[Begin CRB-14]
    - The City of Redondo
        Beach commented on the Draft Initial Study, Page 3.4,
        which stated that preliminary analysis
        "suggests" that the Redondo Beach Station is
        likely to be repowered. The City requested a full
        discussion of repowering technologies and disclosure of
        the potential environmental effects of repowering should
        be included as the incentive to repower is directly
        related to the divestment. Page 3.3 of the current
        document limits the scope of reasonably foreseeable
        projects and considers many factors "too
        speculative". What rational was employed in
        eliminating consideration of the effects of repowering?
[End CRB-14]
[Begin CRB-15]
    - Thank you for
        correcting the zoning designation of the property.
        Originally, Page 4.1.14 state that, "The General
        Zoning requirements for the Redondo generating station
        are set forth in the City's Harbor/Civic Center Specific
        Plan." This statement was corrected to specify the
        zoning requirements are in the City's Ordinance.
[End CRB-15]
[Begin CRB-16]
    - Page 4.16.11 lists
        community projects within one mile of the project site.
        The two projects listed below are not included. Any
        discussion of surrounding uses and impacts on uses in the
        area under new operational scenarios should include two
        reasonably foreseeable projects in the immediate
        surrounding area. Specifically, the Catalina Technology
        Center, a 293,000 square foot, mixed use (retail, office
        incubator industrial and storage) projects, is approved
        and set to commence construction in October 1997. The
        project will be constructed on portions of the
        Edison-owned property immediately east of the main
        generating site. A second project consisting of a 50,000
        square foot, 16-screen cinema with 15,000 square feet of
        additional retail is in the planning stages. Under
        increased operational scenarios or repowering, the
        impacts to these projects, which were under current
        operational conditions may be significant.
[End CRB-16]
[Begin CRB-17]
    - Page 4.9.6
        specifies the content of one underground storage tank at
        the plant. The content of two other tanks is not listed.
        Please specify what products are stored in these tanks.
[End CRB-17]
[Begin CRB-18]
    - Page 4.9.7
        discusses risk of upset associated with storage and use
        of hazardous materials. It is essential that any new
        owner establishes direct communication with local Fire
        department specialists and obtains all necessary
        emergency plans and materials. In order to ensure that
        any new owner is provided with informational materials,
        training documents and local contact information, a
        mitigation measure should be included to require these
        actions.
[End CRB-18]
[Begin CRB-19]
    - Page 4.9.8
        concludes that the project is likely to affect emergency
        response plans. However, should a Lot Line Adjustment be
        approved, a reconfiguration will be required. A
        mitigation measure should be required to condition
        revision to plans in the event of approval of the
        property's reconfiguration.
[End CRB-19]
[Begin CRB-20]
    - Page 4.10.3 states
        that, "Noise from plants located more than 0.5 miles
        from an existing or anticipated noise sensitive land use
        . . . would not be expected to affect such sensitive
        uses. . ." How was this standard selected?
[End CRB-20]
[Begin CRB-21]
    - Page 4.10.9
        describes the background noise impact of Pacific Coast
        Highway. Pacific Cast Highway is greater than 0.5 miles
        from the generating station and the sensitive receptors
        identified in the study, yet the background contribution
        is still acknowledged. It is therefore logical to include
        analysis of the effects of plant noise at a greater
        distance than 0.5 miles. Historically, certain noise
        corridors have been identified which subject sensitive
        receptors to significant exposures at a greater distance.
        
[End CRB-21]
[Begin CRB-22]
    - Page 4.10.9
        describes the property line wall of the tri-level
        condominium facility as being 10 feet tall and being
        adjacent to Herondo Street. The wall in fact extends
        approximately 42" above the grade of the condominium
        and faces Catalina Avenue.
[End CRB-22]
[Begin CRB-23]
    - Page 4.10.10
        indicates that for the current study one noise
        measurement was taken in or on the north side of Herondo
        Street at Herondo Avenue then discusses surrounding uses.
        Although this measurement was taken with all units
        operating, the location of the measurement was in the
        City of Hermosa Beach and most distant from the noise
        source and the sensitive receptors in Redondo Beach.
        Therefore, this measurement does not accurately support
        any conclusion that he facility is currently in
        compliance with local noise standards.
[End CRB-23]
[Begin CRB-24]
    - Page 4.10.11
        concludes that increase operations could result in
        relatively small noise level increases. Absent
        documentation that the facility is currently in
        compliance, any increased noise could have a significant
        impact. A fully acoustical analysis to establish baseline
        data should be required as a mitigation measure to
        demonstrate compliance.
[End CRB-24]
[Begin CRB-25]
    - Page 4.11.6
        discusses private security and speculates that any new
        owner may not provide for private security. Under current
        budgetary constrains, the nee to provide police services
        to the facility is considered significant impact.
[End CRB-25]
[Begin CRB-26]
    - Page 4.12.4
        contains discussion of sewer impacts. The existing Edison
        facility presently discharges into an over-capacity
        18" sewer line, which transects the subject site.
        The minimal employment increase expected may not alone be
        significant. However, when related projects, such as the
        Catalina Technology Center, the Crown Plaza Hotel
        Expansion and the Portofino Hotel expansion are included,
        any increase in flow could be significant. The related
        projects are required to mitigate their sewer impact
        though the payment of impact fees. Mitigation of the
        impact to the sewer system should be required. The City
        has planned a sewer improvement project, and requested
        Edison's participation in the project. However, as of
        this writing Edison has declined to participate in the
        required upgrades.
[End CRB-26]
[Begin CRB-27]
    - Page 4.13.6 states
        that the plant is visually compatible with views from the
        east and surrounding industrial uses. Not acknowledged in
        this statement is that nearly all industrial uses to the
        east will be redeveloped shortly. The basis for this
        statement of compatibility is not documented. The City is
        on record over a period of at least 10 years as
        considering this view of the facility as extremely
        incompatible with the community and destructive to the
        scenic vista of the harbor.
[End CRB-27]
[Begin CRB-28]
    - Page 4.15.10 should
        discuss the fact that the City has historically utilized
        once-through cooling water to heat a public swimming
        facility, the "Seaside Lagoon". Due to damage
        from the Northridge Earthquake the supply structures are
        no longer serviceable. With the transition of the
        facility to private operation, the availability of
        heating and circulation water, to a public park facility
        is considered an impact.
[End CRB-28]
The City of Redondo
Beach looks forward to your careful consideration of these
comments and inclusion of appropriate mitigation measures
following additional study. The environmental sensitivity of the
site warrants a thorough and complete evaluation in order to
ensure that the impacts of this project can be mitigated to a
less than significant level.
Thank you for the
opportunity to provide you with this input at this stage of the
environmental review process. Please contact Aaron Jones at
310-318-0637 should you have any questions or need clarification.
Sincerely,
/s/
Paul Connolly
City Manager 
/s/
Aaron Jones
Economic Development Administrator
cc: Mayor and City
Council
Jerry Goddard, City Attorney
Steve Huang, City Engineer and Building Official
Pat Aust, Fire Chief
Mel Nichols, Chief of Police
 
City of Redondo Beach
California
415 Diamond Street
P.O. Box 270
Redondo Beach, California 90277-0270
July 2, 1997
Bruce Laneshiro and
Martha Sullivan, Co-Project Managers
California Public Utilities Commission
c/o environmental Science Associates
301 Brannan Street, Suite 200
San Francisco, CA 94107
Dear Bruce Laneshiro and
Martha Sullivan:
The City of Redondo
Beach is pleased to have the opportunity to provide comments on
the Draft Initial Study for Southern California Edison Company's
Application No. 96-11-046. We offer the following comments:
    - Page 2.7-Please
        identify which Edison Facilities presently have radial
        lines and will be subject to Radial Line Agreements.
    - Page 2.7-With
        respect to environmental liabilities, please specify what
        categories of known and unknown liabilities would be
        subject to indemnification and which would be exempted.
    - Information on the
        nature and extent of environmental contamination
        including costs of remediation should be disclosed for
        each divested facility. Property on which the Redondo
        Beach facility is located has been in industrial use
        since the early 1900's. Remediation costs will have a
        major influence on the sale of this asset, decisions on
        which portions of the facility to retain, and the
        likelihood of alternative, non-industrial development of
        the property.
    - Page 2.35 provides
        a description of facilities to be sold and those to be
        retained. The document should note that in order for
        Edison to divest the power block yet retain the
        transmission, fuel storage and switchyards approval of a
        physical land division of the subject site is required.
        Edison filed an application for Lot Line Adjustment on
        June 11, 1997 which was subsequently reviewed and
        rejected as incomplete on July 1, 1997. The impacts of
        the division of properties at each facility should be
        included in the environmental analysis. Issues related to
        conformance with building and zoning requirements are
        created as a result of the proposed reconfiguration for
        separate sale.
    - The Ormond Beach
        facilities map has been incorrectly inserted into the
        Draft document.
    - The configuration
        of the retained parcel at the Redondo Beach Station has
        been modified by Edison. Please ensure that the
        facilities map and area calculations are updated.
    - Page 3.1 states
        that, "With divestiture, any new buyer...would have
        a strong incentive to operate the facility up to its
        available capacity..." The Redondo Beach facility
        has been operated as a load following plant for over 10
        years, operating at approximately 30% of capacity. Any
        increase in operation will result is significant,
        quantifiable environmental impacts. Page 3.4 of the Draft
        Initial Study projects an expected capacity factor of
        69.9% with divestiture. Such increased levels of
        operation have been shown to have significant
        environmental impacts which require mitigation. Analysis
        of these impacts was performed in the environmental
        review process for the proposed merger of Southern
        California Edison with San Diego Gas and Electric in 1990
        and the proposed installation of Selective Catalytic
        Reduction (SCR) in 1992. Any increase in operation of the
        facility is expected to result in significant impacts in
        the following areas: Noise, Fish Population, Air
        Emissions and Transportation and Storage of Hazardous
        Materials (particularly Aqueous Ammonia and Vanadium
        Pentoxide Catalyst).
    - The proposed
        divestment documents indicate that SCE desires to
        reparcelize the present 47 acre facility and retain
        ownership of transmission facilities, certain pipelines
        and fuel oil storage tank areas. The operation of a bulk
        fuel storage area as a separate use is not recognized as
        a permitted activity under local land use standards.
        Further, reparcelization results in an irregular
        subdivision pattern and raises significant concerns with
        respect to access, circulation, adequacy of streets,
        stormdrains and other infrastructure. A full analysis of
        the effects of the physical land division should be
        required of each facility proposed for divestment.
 
 These impacts were studied in previous environmental
        documents prepared for the Proposed Merger of Southern
        California Edison with San Diego Gas and Electric and the
        Installation of Selective Catalitic Reduction (SCR)
        equipment. Impacts should be identified and analyzed
        under new operational scenarios. It is anticipated that
        significant impacts will occur in the areas of, fish and
        wildlife (entertainment), noise, air emissions, hazardous
        materials (catalist and ammonia transportation) and
        public services (fire protection, emergency management).
        Each of these issues has been the subject of significant
        past analysis and is certainly revenant and critical to
        this analysis of increased operational scenarios.
    - There is a
        typographical error in the second sentence of the second
        paragraph on page 2.7.
    - The Redondo Beach
        General Plan and Harbor/Civic Center Specific Plan
        contain numerous primary and supplemental land use
        policies which mandate comprehensive planning for the
        reuse of the subject site for non-industrial use, in
        anticipation of the end of the end of the economic and
        physical life of the plant. Units 1-4 were installed in
        1948 and 1949 and are in long term shutdown. Unit 4 is
        occasionally operated to provide auxiliary plant steam.
        The age of the equipment, and the inefficient heat rate
        of these units have been stated to make these units
        uneconomical to operate. Units 7 and 8 began operation in
        1967 and are moderately efficient when compared to new
        generation technologies.
 
 For the above reasons, environmental analysis should
        consider two project alternatives; reuse of the subject
        property for non-industrial development and repowering of
        the facility with new modern and efficient equipment.
        Either scenario is reasonably foreseeable in view of the
        age of the facilities. In the event that repowering is
        evaluated, detailed analysis and modeling with respect to
        noise, vibration and emissions should be conducted on a
        local level. In evaluating reuse, the potential
        development of the transmission corridors in conjunction
        with the plant site must be considered.
    - All full analysis
        of the site contamination including soils and ground
        water remediation requirements should be incorporated
        into the environment documents. The industrial use of the
        property since the late 1800's can be reasonably expected
        to have resulted in contamination. Contamination has been
        documented on adjacent properties. The nature and extent
        of this contamination and the potential exposure of the
        public to health risks should be disclosed and analyzed.
    - Page 3.4 states
        that preliminary analysis "suggests" that the
        Redondo Beach Station is likely to be repowered. A full
        discussion of repowering technologies and disclosure of
        the potential environmental effects of repowering should
        be included as the incentive to repower is directly
        related to the divestment.
    - In Section 4, page
        4.1.1 impacts to land use and planning are considered to
        be less than significant with the exception of
        "agricultural resources". As discussed earlier
        in these comments, the project results in significant
        land use and planning impacts, including the creation of
        a non-conforming and in fact prohibited use. These
        impacts should be considered significant and analysis of
        conformance to local General Plan and Zoning criteria
        should be included.
    - Little discussion
        or analysis of alternative reuse is included in the Draft
        Initial Study. In view of the fact that the
        "project" includes the retention of substantial
        portions of all existing generating facilities, site
        specific analysis should be included in the environmental
        documentation as to the reasonably foreseeable uses of
        the retained properties.
    - Page 4.1.14 states
        that, "The General Zoning requirements for the
        Redondo generating station are set forth in the City's
        Harbor/Civic Center Specific Plan." This statement
        should be corrected to specify the zoning requirements
        are in the City's Zoning Ordinance. Also in need of
        correction is the zoning designation of the subject
        property. The correct designation is Public-Generating
        Plant (P-GP).
    - Page 4-1-18 states
        that the, "Redondo generating station is consistent
        with the land use designated by the City of Redondo Beach
        General Plan" and that, "A review of
        environmental impact reports for the general
        plan...indicates no conflicts with environmental plans or
        policies at the local...level." As previously
        discussed, the operation of a fuel oil storage facility
        or "tank farm" is not a permitted use in this
        zone. The operation of a "private utility" also
        raises a significant question as to the conformance of
        this use with applicable zoning and General Plan
        designations. Therefore, following divestment and
        partitioning of the property, the uses will be in
        conflict. In terms of policy, the General Plan and
        Harbor/Civic Center Specific Plan clearly establish a
        policy to, "plan for the adaptive reuse in
        anticipation of the end of the useful life..."
        Therefore, the project is also inconsistent with the
        City's stated policy. The "conclusion" on Page
        4.1.22 should be modified.
 
 Any discussion of surrounding uses and impacts on uses in
        the area under new operational scenarios, should include
        two reasonably foreseeable projects in the immediate
        surrounding area. Specifically, the Catalina Technology
        Center, a 293,000 square foot, mixed-use (retail, office,
        incubator industrial and storage) project, is approved
        and set to commence construction in August, 1997. The
        project will be constructed on portions of Edison-owned
        property immediately east of the main generating site. A
        second project consisting of a 50,000 square foot,
        16 screen cinema with 15,000 square feet of additional
        retail is in the planning stages. Under increased
        operational scenarios or repowering, the impacts to these
        projects, which were assessed under current operational
        conditions may be significant.
    - Page 4.1.25
        contains a typographical error in the conclusion section.
    - Page 4.1.28 states
        that the project will not, "Include any change in
        the operational or land use conditions of the power plant
        sites..." We disagree with this conclusion for the
        reasons in the comments stated herein. An analysis of
        these changes and an assessment of the impacts of these
        changes is warranted.
    - Page 4.3.20
        acknowledges the susceptibility of the subject site to
        liquefaction. During the recent Northridge earthquake the
        Redondo Beach Seaside Lagoon, adjacent to the Edison
        facility sustained major damage and closure due to
        liquefaction. Mention of this event and analysis of the
        liquefaction potential should be included in the
        analysis.
    - Page 4.3.23 points
        out that remediation activities could have impacts
        related to erosion. The Redondo Edison facility is also
        the suite of a historical salt marsh named, "Lake
        Salina". Anthropological resources are known in the
        immediate vicinity including an ancient Gabrilenio Indian
        Village named "Engiva". Any soils disruption
        may have the potential to disrupt significant
        archaeological resources.
    - Page 4.6.4 states
        that, "continued operation of the power
        plants...would not chance access for emergency
        vehicles..." However, the proposed partitioning of
        the properties will result in a need to re-configure
        emergency vehicle access. Discussion of emergency vehicle
        access constraints should be included and appropriate
        mitigation required.
    - Page 4.7.6 appears
        to make the assumption that fisheries in the Santa Monica
        Bay are "compromised". Redondo Beach has and
        continues to derive a major revenue source from sport
        fishing. The entrainment impacts of additional cooling
        water use are significant to fish populations and should
        be included in the analysis.
    - Page 4.9.6 contains
        the statement that, "New owners are expected to
        change the operating conditions..." The degree to
        which these conditions could expose the public of risk of
        upset is stated as "unknown". As previously
        commented, any increased operation is likely to result in
        the increased use of acutely hazardous materials and the
        transportation of these products on local streets. In
        view of the degree of uncertainty, additional study is
        essential. Further, mitigation will be essential to
        ensure the public health, safety and welfare.
    - Page 4.9.8 should
        include a discussion of Vanadium Pentoxide under the
        category of hazardous waste.
    - Page 4.9.10
        indicates that future study of contamination is
        "likely to take place in the future. For reasons
        stated above, additional study is warranted immediately
        and the results of these studies should be evaluated in
        environmental documentation.
    - Page 4.11.6
        discusses private security and speculates that any new
        owner may not provide for private security. Under current
        budgetary constraints, the need to provide police
        services to the facility is considered significant
        impact.
    - Page 4.11.9
        concludes that their may be an increased demand for
        school facilities. However, no mention of the fact
        that several Redondo Beach schools are operating at
        100 percent capacity. Therefore, the addition of any
        student population is considered significant.
    - Page 4.12.2
        contains discussion of sewer impacts. The existing Edison
        facility presently discharges into an over-capacity
        18" sewer line which transects the subject site. Any
        increase in demand on this sewer line is considered
        significant. Further, the City has planned a sewer
        improvement project, and requested Edison's participation
        in the project. However, as of this writing Edison has
        declined to participate in the required upgrades.
    - Page 4.13.9
        acknowledges that any modifications to the facility could
        have adverse impacts on scenic views. In conjunction with
        recent public hearings on the Catalina Technology Center,
        surrounding residents substantiated their sensitivity to
        view obstruction. The obstruction of scenic vistas should
        be considered significant and analyzed in the subsequent
        environmental documentation.
    - Page 4.14.10 makes
        reference to ethnographic resources. As discussed in
        earlier comments, the likelihood of discovery of
        significant resources is significant. Site disruption or
        "churning" have altered the contextual record
        on adjacent sites. However, in view of the potential
        significance of this resource, appropriate mitigation
        should be required.
    - Page 4.14.14
        acknowledges that the Redondo Beach site has potential to
        yield historic resources but concludes that the impact is
        nonexistent due to lack of physical construction. This
        conclusion contradicts earlier statements in the document
        which conclude that physical construction is
        "likely" in order to separate the retained and
        divested properties and to accomplish repowering.
    - Page 4.15.10 should
        discuss the fact that the City has historically utilized
        once-through cooling water to heat a public swimming
        facility, the Seaside Lagoon". Due to damage from
        the Northridge Earthquake the supply structures are no
        longer serviceable. With the transition of the facility
        to private operation, the availability of heating and
        circulation water, to a public park facility is
        considered an impact.
    - Page 4.1.22 should
        correctly identify "Beryl Drive" as Beryl
        Street.
Thank you for the
opportunity to provide you with this preliminary input at the
start of the environmental review process. We are looking forward
to providing further comments as the process progresses. Please
contact Aaron Jones at 310-318-0637 should you have any questions
or need clarification.
Sincerely,
/s/
Aaron Jones
Economic Development
Administrator
cc: Paul Connolly, City
Manager
Jerry Goddard, City Attorney
Stan Remelmeyer, Assistant City Attorney
Steve Huang, City Engineer and Building Official
     
April 9, 1997
Julie Halligan
California Public Utilities Commission
c/o Environmental Science Associates
301 Brannan Street, Suite 200
San Francisco, California 94107
Dear Ms. Hallingan:
The City of Redondo
Beach is pleased to have the opportunity to provide comments and
input regarding environmental impacts and other issues associated
with the proposed divestiture of SCE's fossil fuel fired
generating facilities in Southern California.
The Redondo Beach
Generating Station is presently operated, and over the last 10
years has been operated as a load-following plant operating at
approximately 30% of capacity. Assuming a prospective purchaser
continues to utilize the site for electrical generation, it is
logical to conclude that they will want to maximize their return
on investment by maximizing power production from the facility.
Such increased levels of operation have been shown to have
significant environmental impacts which require mitigation.
Analysis of these impacts was performed in the environmental
review process for the proposed merger of Southern California
Edison with San Diego Gas and Electric in 1990 and the proposed
installation of Selective Catalytic Reduction (SCR) in 1992.
Any increase in
operation of the facility is expected to result in significant
impacts in the following areas: Noise, Fish Population, Air
Emissions and Transportation and Storage of Hazardous Materials
(particularly Aqueous Ammonia and Vanadium Pentoxide Catalyst).
The proposed divestment documents indicate that
SCE desires to reparcelize the present 47 acre facility and
retain ownership of transmission facilities, certain pipelines
and fuel oil storage tank areas. The operation of a bulk fuel
storage area is a separate use is not recognized as a permitted
activity under local land use standards. Further, reparcelization
results in an irregular subdivision pattern and raises
significant concerns with respect to access, circulation,
adequacy of streets, storm drains and other infrastructure. A
full analysis of the effects of the physical land division should
be required of each facility proposed for divestment.
The Redondo Beach
General Plan and Harbor/Civic Center Specific Plan contain
numerous primary and supplemental land use policies which mandate
comprehensive planning for the reuse of the subject site for
non-industrial use, in anticipation of the end of the end of the
economic and physical life of the plant. Units 1-4 were installed
in 1948 and 1949 and are in long term shutdown. Unit 4 is
occasionally operated to provide auxiliary plant steam. The age
of the equipment, and the inefficient heat rate of these unites
have been stated to make these unites uneconomical to operate.
Units 4 and 8 began operation in 1967 and are moderately
efficient when compared to new generation technologies. 
For the above reasons,
environmental analysis should consider two project alternatives;
reuse of the subject property for non-industrial development and
repowering of the facility with new modern and efficient
equipment. Either scenario is reasonably foreseeable in view of
the age of the facilities. In the event that repowering is
evaluated, detailed analysis and modeling with respect to noise,
vibration and emissions should be conducted on a local level. In
evaluating reuse, the potential development of the transmission
corridors in conjunction with the plant site must be considered.
A full analysis of site
contamination including soils and ground water remediation
requirements should be incorporated into the environmental
documents. The industrial use of the property since the late
1800's can be reasonably expected to have resulted in
contamination. Contamination has been documented on adjacent
porperties. The nature and extent of this contamination and the
potential exposure of the public to health risks should be
disclosed and analyzed.
Thank you for the
opportunity to provide you with this preliminary input at the
start of the environmental review process. We are looking forward
to providing further comments as the process progresses. Please
contact Aaron Jones at 310-318-0637 should you have any questions
or need clarification.
Sincerely,
/s/
Paul Connolly
City Manager 
/s/
Aaron Jones
Economic Development Administrator
cc: Jerry Goddard, City
Attorney
Steve Huang, City Engineer and Building Official
Pat Aust, Fire Chief