CRC - THE CITY OF RANCHO CUCAMONGA

CRC-1.

The City indicates its comments to the Draft Initial Study, submitted in its July 1 letter, were not addressed in the Mitigated Negative Declaration/Initial Study. Those comments are addressed individually below as CRC-3 through CRC-15.

Throughout its CEQA review of Edison's divestiture proposal, the CPUC has actively sought and welcomed the input of other affected jurisdictions to inform its environmental analysis. Comments on the Draft Initial Study were requested as a function of informal consultation prior to the completion of the CPUC's analysis. All of the input received was considered by the CPUC in completing the Initial Study and in determining that a Mitigated Negative Declaration was appropriate. Responses were not required nor necessary to accomplish the purpose of the informal consultation, as encouraged in CEQA Guidelines § 15063 (g).

CRC-2.

Please see response to CRC-1.

CRC-3.

As noted on page 2.7 of the Initial Study, Edison has revised its proposal such that no generating station is being offered as part of a "bundle" of facilities.

As discussed in Section 3 and Attachment C at page C.16 of the Initial Study, Edison and the new owners have similar incentives to continue operations, refurbish or repower (or implicitly, to retire) any plant, including any associated demolition activities. These incentives arise from market forces that are part of restructuring, not divestiture (see also responses to CCC-1, CCC-2, CCC-3, CRB-13, and CRB-27). For a discussion of remediation activities see CCC-2.

CRC-4.

Potential cumulative impacts were addressed in Section 4.16 of the Initial Study, including the relationship of the project with three current and certified power plant developments, and five plants with applications pending before the California Energy Commission. As noted on page 4.16.6 of the Initial Study, "These potential future power plants, once constructed, are not expected to have cumulative impacts with the project. Demand for electricity in California is not expected to significantly increase. The cumulative effect of new plants (if built) would likely inhibit the tendency of the new owners of divested plants to increase operations at individual plants because new plants would tend to increase electrical generation capacity in California. The new proposed plants would employ the latest in generating and pollution control technology and may be cleaner to operate so that they would have lower emissions. This would provide a potential positive net benefit to the environment, particularly with respect to air quality. Therefore, the cumulative impacts associated with future potential power plants and the project would be less than significant." Please also see response CCC-3.

CRC-5.

As noted in CRC-4, cumulative impacts are addressed in Section 4.16 of the Initial Study. It is unclear what, if any, physical impact the commentor is suggesting could arise from "the relationship of existing and proposed steam generation with existing nuclear capacity and its economic viability."

CRC-6.

As noted on page 4.1.2 of the Initial Study, more than 90 percent of the land in San Bernardino County, where the plant is located, is rural, vacant or recreational open space. The Initial Study notes, however, that though the percentages of land used for housing or commercial/industrial applications are relatively small, the total acreage devoted to such use in San Bernardino County is "greater numerically than comparable acreage in the City of Los Angeles." In other words, though the percentage of land used for residential, commercial or industrial applications is small, San Bernardino County is so large that the total acreage devoted to such use is still quite significant. Regardless, the exact nature of the lands of the entire county are irrelevant to the project; only the nature of the properties near the power plants proposed for sale are relevant to the project and the Initial Study, and those properties were all considered in the analysis leading to the conclusions of the Initial Study.

CRC-7.

This comment was addressed; the Initial Study was corrected (pg. 4.1.10) and makes no reference to whether such terms are defined in the ISP.

CRC-8.

The Initial Study relied on population statistics supplied by Edison in its Technical Resources Document, Background Environmental Information for the Proposed Divestiture of Edison Gas-Fired Generation Plants (ENTRIX, Inc. 1996). That document relied on the 1996 Report from the California Department of Finance's Demographic Research Unit and a 1994 report from the Southern California Associations of Governments giving population statistics (pg. 8-11 of the Technical Resources Document). In any event, the differences in the estimates between the two sources is small, and would not change any conclusion in the Initial Study. For instance, the Technical Resources Document provided an estimate of 3.09 persons per household in Rancho Cucamonga, while the City's Plan gives a figure of 3.066 persons per household, a difference of about 0.8 percent.

CRC-9.

The Red Hill Fault is included on page 4.3.6 of the Initial Study in Table 4.3.1, is listed as active, and identifies the closest segment as 5 miles north. However, the following is added to the Geologic Hazards section on page 4.3.14 to note the special study zone around the Red Hill Fault:

The City of Rancho Cucamonga has adopted an earthquake special study zone on the City’s General Plan Geotechnical hazard map for the area around the Red Hill Fault. The plant is not within this zone.

Also, column 7 of Table 4.3.1 on page 4.3.6 of the Initial Study is revised such that a Maximum Credible Earthquake of magnitude 6.5 is designated for the Red Hill fault. Neither of these revisions change the Initial Study's conclusions.

CRC-10.

Based on the information provided by the City, the following recorded earthquakes are added to Table 4.3.2 under the Etiwanda Plant. The distances to the epicenter are approximate.

The addition of this information does not change the conclusions of the Initial Study.

CRC-11A.

As noted on page 4.4.37 of the Initial Study, the plant now discharges wastewater to the Los Angeles County Sanitation District via the Chino Basin Municipal Water District (CBMWD), under a temporary permit issued by CBMWD in 1991. By law, any new owner of the plant would be required to obtain a new permit from CBMWD for continued wastewater discharge, thus ensuring compliance with all applicable rules, regulations and operating criteria. The City did not identify an environmental impact that its recommended mitigation measure would mitigate. Since there is no environmental impact associated with the project that such a measure would mitigate, there is no basis for or need to require Edison or the new owner to construct a sewer connection to the new wastewater treatment facility.

CRC-11b.

As discussed in response to CCC-2, a condition of the sale of the plants targeted for divestiture, Edison will retain responsibility for remediation of all existing soil contamination, including that which may affect groundwater. The new owner will assume responsibility for remediation of soil contamination that occurs after the sale.

CRC-12.

The second sentence of the last paragraph of the Etiwanda section of Permit Conditions and Current Emissions, on page 4.5.26 of the Initial Study, is revised as follows:

The closest air pollution-sensitive receptors to the generating station are located approximately one mile to the northwest of the site.-half mile directly north of the generating facility in multi-family residential development near the intersection of Etiwanda Avenue and Arrow Highway. Other receptors are located approximately one mile to the northwest of the site, and at a San Bernardino County Jail facility approximately one mile south of the generating facility at the intersection of Etiwanda Avenue and Fourth Street (San Bernardino Road).

However, identifying sensitive receptors that are one-half mile from the plant makes no difference in the conclusions drawn concerning air quality. For other Edison plants proposed for divestiture, many receptors are located "in close proximity (1,000 feet or less) of seven of the 12 power plants," as noted on page 4.5.39 of the Initial Study under "Local Issues." Previous health risk assessments of receptors near PG&E plants concluded that increased emissions of hazardous air pollutants (HAPs) from gas-fired boilers did not correlate to increased risk to nearby sensitive receptors. In any event, new owners of divested plants would still be required to comply with the Air Toxics "Hot Spots" Information and Assessment Act, including notification of exposed individuals if the assessments identify "significant health risk."

CRC-13.

Concerning the commentor's first point, the last sentence of the Etiwanda description under the "Local Setting" section on page 4.7.4 of the Initial Study is revised as follows:

However, the plant is within a critical habitat area for Delhi Delphi sand-flower-loving fly (federally endangered) and the residual open space could harbor several special status species such as the burrowing owl, orange-throated whiptail, the San Bernardino Merriam's kangaroo rat and the San Diego horned lizard.

The City's second point appears to state that although Delhi Sand is present at or near the Etiwanda site, the specific dune types and associated native vegetation are not present at the site; this observation does not change or affect any analysis or conclusion drawn in the Initial Study.

CRC-14.

This comment was addressed in the Initial Study. The Etiwanda description under Local Settings in the Hazards Section, found on page 4.9.3 of the Initial Study, included substantially more information than the description in the DIS, and cleanup procedures are discussed at length in the Exposure to Existing Hazards section on page 4.9.12 of the Initial Study.

CRC-15.

This concern was addressed, as all four of the parks are included in the list found on page 4.15.14 of the Initial Study.