September 24, 1997

Mr. Bruce Kaneshiro, Project Manager
e/o Environmental Science Associates
225 Bush Street - Suite 1700
San Francisco, California 94104

SUBJECT: SOUTHERN CALIFORNIA EDISON'S APPLICATION NO .96-11-046 TO SELL 12 POWER PLANTS INCLUDING ETIWANDA PLANT IN THE CITY OF RANCHO CUCAMONGA - PROPOSED MITIGATED NEGATIVE DECLARATION

Dear Mr. Kaneshiro:

[Begin CRC-1]
Attached are comments made on the Initial Study for the Edison Power Plants including the Etiwanda Power Generating facility in the City of Rancho Cucamonga. Our comments on the Initial Study, as well as comments from every responding jurisdictions, have not been acknowledged or incorporated into the Environmental Assessment/Mitigated Negative Declaration document.
[End CRC-1]

[Begin CRC-2]
From the project description and Initial Study previously reviewed, staff concluded that an Environmental Impact Report should be prepared (see attached response dated July 1, 1997). On such a significant restructuring of power generation ownership in California, how can the response to comments on the Initial Study be entirely ignored. We respectfully suggest that issuance of a Negative Declaration skips an important part of the environmental review process and is, therefore, a premature and inappropriate conclusion at this time.
[End CRC-2]

Thank you for the opportunity to comment on the subject document.

Sincerely,

COMMUNITY DEVELOPMENT DEPARTMENT
PLANNING DIVISION

L.J. Henderson, AICP
Principal Planner

LJH:MB/JFS

Attachments

cc: Rick Gomez, Community Development Director
Brad Buller, City Planner

The City of Rancho Cucamonga

July 1, 1997

Bruce Kaneshiro and Martha Sullivan
California Public Utilities Commission
c/o Environmental Science Associates
301 Brannan Street, Suite 200
San Francisco, CA 94107

SUBJECT: SOUTHERN CALIFORNIA EDISON'S APPLICATION NO. 96-11-046 TO SELL 12 POWER PLANTS INCLUDING ETIWANDA PLANT IN THE CITY OF RANCHO CUCAMONGA - ENVIRONMENTAL INITIAL STUDY

Dear Mr. Kaneshiro and Ms. Sullivan:

Thank you for the opportunity to review the draft Initial Study for the subject project. SCE's Etiwanda plant is within the City of Rancho Cucamonga. In general, the draft Initial Study is comprehensive, but we are concerned about cumulative impacts and some minor omissions and incomplete statements of fact. Based on the Environmental Checklist, particularly the discussion of potential cumulative impacts, an Environmental Impact Report should be prepared.

CUMULATIVE IMPACTS. We believe the discussion of cumulative impacts should be substantially expanded and the following issues should be added to the discussion on page 4.16.2:

[Begin CRC-3]

• Demolition As to cumulative impacts, the Initial Study does not address whether some or most of the sold generating plants may be demolished. One report stated that the terms of the sale provided that two of three plants in a "bundle" may be dismantled and relocated to other countries. The study should specify whether or not demolition is permitted. If the sale contract provides for demolition, then the possibility should be addressed in the Study as to adequacy of power generation, replacement generation, and rehabilitation of the site for reuse. The provision for complete toxic cleanup and rehabilitation of a site upon removal of a generating plant is a strong concern of jurisdictions where a plant is located, such as Rancho Cucamonga

[End CRC-3]

[Begin CRC-4]

• Trigger for new plant construction A recent news release stated that four new power generation plants were being considered as a result of deregulation. Under Cumulative Impacts, the Study should address the relationship of the proposed sale as a justification for construction of new power plants. We understand that applications for new plants may not yet have been submitted and that no applications for demolition are pending, but there is a reasonable relationship between the sale and potential demolition and between demolition and new construction.

[End CRC-4]

[Begin CRC-5]

• Relationship to nuclear plants Another aspect of the sale which should be addressed under Cumulative Impacts is the relationship of existing and proposed steam generation and existing nuclear capacity and its economic viability.

[End CRC-5]

MINOR INCOMPLETE FACTS AND OMISSIONS

The following items reference specific facts by page number in the draft Initial Study.

[Begin CRC-6]

• 4.1.2. The Inland Empire area of Southern California is far from rural. The Department of Finance reports that Rancho Cucamonga, for example, had a January 1, 1997, population of 116,045 and the City of San Bernardino 180,306. The populated coastal plain area of Riverside San Bernardino PMSA, which is the service area for the Etiwanda, Highgrove, and San Bernardino plants, contains well over a million people. County wide data from the Department of Finance report for January 1, 1996 is attached.

[End CRC-6]

[Begin CRC-7]

• 4.1.10. The statement is incorrect that the Industrial Area Specific Plan (ISP) and the City of Rancho Cucamonga's Development Code do not define "Extensive Impact Utility Facilities," "Utility Services," and "Petroleum Storage" uses. These terms are defined in the ISP on pages III-16, 17, 18, which are attached.

[End CRC-7]

[Begin CRC-8]

• 4.2.4. The population projection is high compared to the City's Housing Element contained in the Rancho Cucamonga General Plan, revised May 17, 1995, which projects build-out between 2015 and 2020. The population projected is based on current zoning, vacant land, a five percent vacancy rate, and 2.9 persons per household for a buildout range between 153,668 to 162,475 with the most likely population being 158,071. The January 1, 1997, vacancy rate is stated at 7.51 percent with 3.066 persons per household.

[End CRC-8]

[Begin CRC-9]

• 4.3.8 - Table 4.3.1 The City-adopted Red Hill Fault Special Study Zone should be added: Trend Northwest; closest segment is 4.5 miles north, with a maximum credible event magnitude 6.5. See attached General Plan Geotechnical Hazard map, Figure V-4.

[End CRC-9]

[Begin CRC-10]

• 4.3.9 - Table 4.3.2 Recorded earthquakes greater than magnitude 5 near Edison Power Plants: The information in the table ends in 1970 and is very incomplete. The following events should be added: Sylmar (San Fernando) February 9, 1971, magnitude 6.5; Whittier Narrows, October 1, 1987, magnitude 5.9; Upland, February 28, 1990, magnitude 5.5; Sierra Madre, June 28, 1991, magnitude 6.0; Desert Hot Springs, April 22, 1992, magnitude 6.1; Big Bear, June 28, 1992, magnitude 6.6; Landers, June 28, 1992, magnitude 7.5; Northridge, January 17, 1994, magnitude 6.7. The Sylmar, Upland, and Sierra Madre events were on the San Gabriel Mountain thrust fault, which is a continuation of the Cucamonga Fault, located approximately five miles north of the Etiwanda generating station. See attached article on the Cucamonga fault zone scarps.

[End CRC-10]

[Begin CRC-11A, 11B]

• 4.4.36-38 Ground water resources for Etiwanda generating plant: A waste water treatment plant is under construction adjacent to the Etiwanda Generating Plant. A sewer connection should be considered a mitigation measure as a condition of change of ownership. The relationship of past and future spills and soil contamination as mentioned on page 4.9.3 under hazardous materials should be addressed in relationship to ground water.

[End CRC-11A, 11B]

[Begin CRC-12]

• 4.5.30 "Sensitive Receptors:" The statement that the closest air pollution-sensitive receptors to the Etiwanda generating station are located approximately one mile to the northwest of the site is incomplete. Multi-family residential development exists less than one-half mile directly north, beginning at the northeast corner of Etiwanda Avenue and Arrow Highway. Also a San Bernardino County prison facility is located approximately one mile directly south, at the northwest corner of Etiwanda Avenue and Fourth Street (San Bernardino Road).

[End CRC-12]

[Begin CRC-13]

• 4.7.4 Delhi Sands Habitat: The endangered fly is named for the soil type "Delhi Sand" not "Delphi". The general soil type is present, but not the specific dune type formation of Delhi Sand nor significant stands of the native vegetation association.

[End CRC-13]

[Begin CRC-14]

• 4.9.3 Hazardous material contamination on the Etiwanda site: This item is critical to the local community and discussion should be expanded. A discussion of cleanup in the event of plant demolition should be added.

[End CRC-14]

[Begin CRC-15]

• 4.15.14 Add Rancho Cucamonga Adult Sports Park, located at the northwest corner of Arrow Highway and Rochester Avenue as the facility nearest the Etiwanda generating station, as well as Northeast Park, Heritage Park, Elena Park.

[End CRC-15]

Again, thank you for the opportunity to comment on the draft Initial Study. When completed, please forward a copy of the draft Environmental Impact Report for review and comment. If you have additional questions please contact Miki Bratt, AICP, Associate Planner at (909) 477-2750.

Sincerely,

COMMUNITY DEVELOPMENT DEPARTMENT
PLANNING DIVISION
/s/
L.J. Henderson, AICP
Principal Planner

LJH:MB:taa

Attachments

cc: Rick Gomez, Community Development Director
Brad Buller, City Planner

San Bernardino County Population and Housing Estimates
January 1, 1996

Definitions:
(From the Industrial Area Specific Plan)

Petroleum Products Storage: Activities typically include, but are not limited to: bulk storage, sale and distribution of gasoline, liquefied petroleum gas, and other petroleum products.

Extensive Impact Utility Facilities: Activities typically include, but are not limited to those performed by public agencies or which are strongly vested in the public interest, and which produce or may produce a substantial impact upon the surrounding area. Uses typically include, but are not limited to the following institutions and installations:

• Electric, gas, and oil transmission facilities
• Garbage or refuse disposal facilities
• Major mail-processing centers
• Radio and television transmission facilities, including but not limited to booster or relay stations
• Railroad and bus terminals
• Railroad rights-of-way, railroad yards and bus storage areas
• Public utility corporation or truck yards
• Reserviors, water tanks, and water treatment facilities
• Sewage treatement facilities and truck lines exclusive of individual septic tanks
• Steam, fossil, or nuclear power plants
• Truck terminals operated by a public agency

Public Safety and Utility Services: Activities typically include, but are not limited to, the maintenance and operation of the following installations:

• Communications equipment installations and exchanges, except telephone exchange and switching facilities.
• Electrical substations;
• Gas substations;
• Ambulance services;
• Police stations and fire stations;
• Post offices, but excluding major mail-processing centers; and,
• Publicly operated off-street parking lots and garages available to the general public either without charge or on a fee basis.