County of Santa Barbara
Planning and Development
123 East Anapamu Street
Santa Barbara, CA 93101-2058
September 4, 1997
Bruce Kaneshiro, Project Manager
c/o Environmental Science Associates
225 Bush Street, Suite 1700
San Francisco, California 94104
RE: Draft Mitigated Negative Declaration and Initial Study (ND/IS), Southern California Edison Plant Divestitures, Application 96-11-046
Dear Mr. Kaneshiro:
[Begin CSBPD-1]
Thank you for the chance to review and comment on this draft
ND/IS. Prior comments on the draft Initial Study were submitted
by letter dated July 2, 1997, a copy of which is attached. Our
review of the more recent draft ND/IS indicates that no changes
have been made in the project which would change the nature or
extent of these prior comments. Therefore, please enter them into
your record as comments on the current draft ND/IS.
[End CSBPD-1]
Please call me directly at (805) 568-2080 if you have any questions.
Sincerely yours,
/s/
GREGORY MOHR, Planner
Comprehensive Planning Division
Attachment
cc: Members of the Board of Supervisors
Scott Ullery (County Administrator's Office)
Ron Tan and Vijaya Jammalamadaka, APCD
Bill Douros, Michelle Gasperini, and Zoraida Abresch
(P&D/Energy)
Natasha Heifetz (P&D/Development Review)
Noel Langle and Lisa Plowman (P&D/Zoning Administration)
P&D chron
County of Santa Barbara
Planning and Development
John Patton, Director
July 2, 1997
Bruce Kaneshiro and Martha Sullivan, Co-Project
Managers
California Public Utilities Commission
c/o Environmental Science Associates
301 Brannan Street, Suite 200
San Francisco, California 94107
RE: Draft Initial Study, Southern California Edison Plant Divestitures, Application 96-11-046
Dear Mr. Kaneshiro and Ms. Sullivan:
Thank you for the chance to review and comment on this draft Initial Study (IS). The following comments pertain only to issues concerning SCE's proposed divestiture of the "Ellwood Energy Support Facility," a 50± MW gas-fired generator located in the unincorporated Goleta area of Santa Barbara County. Prior comments were submitted by letter dated April 9, 1997, a copy of which is enclosed for convenient reference.
General Comments:
[Begin CSBPD-2]
The draft IS finding of "no potentially significant
impacts" appears to be premised upon an assumption that the
plant would continue to be operated only intermittently, up to
200 hours per year as allowed by the facility's current Santa
Barbara County Air Pollution Control District (APCD) permit.
However, as noted in the APCD's letter to you dated 25 June 1997
(copy attached), a new operator could apply for a permit
modification to increase the use of the plant. This could result
in substantially greater adverse impacts than analyzed in the
draft IS, especially with regard to noise and vibration, air
pollutant emissions, electromagnetic fields, and risk of upset.
These impacts are of particular concern because of the plant's
close proximity to the Ellwood Elementary School and to both
existing and proposed residential uses.
[End CSBPD-2]
[Begin CSBPD-3]
We realize that an analysis of such impacts would be somewhat
speculative, because the intentions of some as-yet-unknown new
operator cannot be foreseen with certainty. Nevertheless, a
reasonable worst case assumption could be that a new operator
would want to run the Ellwood plant in a manner similar to other
plants of its type and size within the state, especially if there
is a consistent pattern to such operations wherever else they may
exist. This assumption could become the basis for a more useful
and forthright analysis of the plant divestiture's potential
environmental impacts. Also as noted in our previous letter,
consistency with local plans and policies, including the APCD's
Clean Air Plan, should be considered in the project's Initial
Study.
[End CSBPD-3]
Specific Comments and Questions:
- As stated on Page 3.2 of the IS, no mandate exists that requires new owners to continue to operate a plant after it is sold, unless they are "must run" plants. Is the Ellwood Peaking Station a "must run" plant? Edison has stated to the County, that the Ellwood Peaking Station provides limited and temporary electrical energy for transmission throughout the Santa Barbara area system as well as providing peak support for the Edison electrical grid. If SCE no longer has access to this peaking facility, how can it accommodate intermittent increases in demand?
- What, if any, new demands (including power supply problems or concerns) would be placed on SCE's new UCSB substation and SCE's proposed Mobil Ellwood Onshore Facility substation once SCE no longer has access to a peaking facility in this vicinity? If the proposed substation at Mobil is not permitted, or is otherwise not built, what if any demands would be placed on the Peaking Station?
- The only permit limitation on the Ellwood Peaking Station is a limit on the number of operational hours of the plant. A new owner that operates the plant at a maximum reasonable output would exceed the Santa Barbara County Air Quality threshold for NOx emissions. This should be analyzed under a reasonable worst case scenario.
- As previously noted under "General Comments," because it is reasonably foreseeable that a new owner would operate the Peaking Station at a higher or maximum capacity, the IS should address how operation of the facility at such higher capacities would affect noise/vibration, air quality, electromagnetic radiation, and risk of upset/safety impacts.
I hope that these comments are useful in your preparation of a final Initial Study and other appropriate environmental documentation, specifically insofar as the project relates to the Ellwood Peaking Station. Please call me directly at (805) 568-2080 if you have any questions.
Sincerely yours,
/s/
GREGORY MOHR, Planner
Comprehensive Planning Division
Attachments (2)
cc: Members of the Board of Supervisors
Scott Ullery (County Administrator's Office)
Ron Tan and Vijaya Jammalamadaka, APCD
Bill Douros, Michelle Gasperini, and Zoraida Abresch
(P&D/Energy)
Natasha Heifetz (P&D/Development Review)
Noel Langle and Lisa Plowman (P&D/Zoning Administration)
P&D chron
County of Santa Barbara Planning and
Development
123 East Anapamu Street
Santa Barbara, CA 93101-2058
April 9, 1997
BY FAX (213) 934-1289 (3 pp. total)
Mr. Manuel R. Gurrola
Environmental Science Associates
4221 Wilshire Boulevard, Suite 480
Los Angeles, California 90010
RE: Public Utilities Commission Initial Study, Southern California Edison Plant Divestitures
Dear Mr. Gurrola:
This letter follows up on a meeting held last Friday, April 4, between several Santa Barbara County P&D staff members and ESA staff members Dani Hamilton and Richard Masters. The topics of discussion were the CEQA and other issues of local concern for SCE's proposed divestiture of its "Ellwood Energy Support Facility," a 50± MW gas-fired generator.
CEQA Issues
As discussed at the meeting, the plant is adjacent to a tentatively-approved affordable housing project (Sandpiper) and is close to other approved residential projects and established neighborhoods. We loaned to ESA a copy of the Sandpiper EIR to provide a first-hand look at how the plant's operational characteristics were treated in Sandpiper's environmental analysis. In summary, it was expected that the plant would continue to be operated only intermittently; should a new operator increase the use of the plant, this could represent a substantial change in Sandpiper's setting, resulting in the need to prepare a Supplemental EIR when the Sandpiper project developers apply for final approval. The primary concern would be electromagnetic field exposures, since residential units are proposed in close proximity to the plant.
Other CEQA issues of concern to the Sandpiper project and to the broader local area, should the Ellwood plant see increased use, include noise, ground vibration, air quality, and possibly risk of upset. Consistency with local plans and policies also should be considered in the project's Initial Study, and ESA staff were given a copy of the Goleta Community Plan at the conclusion of last Friday's meeting. A broad range of other CEQA issues could be involved if the plant site is divested and put to some other use. Such issues would depend upon the actual proposed new use, and it wouldn't be very productive to speculate further at this time since no alternative uses are being proposed.
Permitting Issues
- If SCE no longer has access to this peaking facility, how can it accommodate intermittent increases in demand?
- What, if any, new demands would be placed on SCE's new UCSB substation and SCE's proposed Mobil Ellwood Onshore Facility substation once SCE no longer has access to a peaking facility in this vicinity?
Finally, please add to your notification list for future actions on this project: Julie Ellison, Planning & Development/Energy Division, 1226 Anacapa St., Santa Barbara, CA 93101-2010.
We hope that this feedback, although prepared in some haste, will assist ESA and the PUC in completing the divestiture project's Initial Study. Please call me directly at (805) 568-2080 if you have any questions.
Sincerely yours,
/s/
GREGORY MOHR, Planner
Comprehensive Planning Division
cc: Bill Douros & Julie Ellison
(P&D/Energy)
Natasha Heifetz (P&D/Development Review)
Noel Langle and Lisa Plowman (P&D/Zoning Administration)
Santa Barbara County
Air Pollution Control District
25 June 1997
Bruce Kaneshiro
Public Utilities Commission
State of California
505 Van Ness Avenue
San Francisco, CA 94102-3298
Regarding: Draft Initial Study for Southern California Edison Proposal for Divestiture
Dear Mr. Kaneshiro:
Thank you for the opportunity for commenting on the Draft Initial Study for Southern California Edison's Proposal for Divestiture. While the Draft I.S. is generally a well-prepared document, the statement on page 4.5.58 that there will be no air quality impact associated with the divestiture of the Ellwood Facility is incorrect. Santa Barbara County is a non-attainment area with respect to both the federal and California ozone standards. Our attainment demonstration plan assumes there will be no growth in emissions from the Ellwood Facility. While Edison's APCD permit to operate currently limits the annual operating hours, a new divested owner could request a permit modification increasing the operating hours and thus emitting more pollutants than forecasted in our attainment plan. These additional emissions, if not fully mitigated, would jeopardize Santa Barbara County's progress towards attainment of the ozone standard. If this is a reasonably foreseeable scenario, it must be addressed in your environmental document and analyzed under a reasonable worst case scenario.
If you have any questions, please contact me at (805) 961-8812.
Sincerely,
/s/
Ron Tan
cc: TEA Chron