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