EDC - ENVIRONMENTAL DEFENSE CENTER

EDC-1.

The Initial Study addresses the potential impacts of the proposed project. The proposed project is the sale of 12 generating stations by Southern California Edison, and the Ellwood Energy Support Facility is one of those 12, so it is included in the project. EDC may have equated sale of the Ellwood Energy Support Facility with Edison's proposal to construct a new substation in the Ellwood area. Figure 2.8 in the Initial Study shows the portion of Edison's Ellwood property that is for sale. The existing substation, and the planned future substation, are not located on the property proposed for sale; therefore, the proposed substation is not part of the divestiture project. These two proposals (the sale of the Ellwood Energy Support Facility and the proposal to build a new substation) are independent and unrelated to each other. Either proposal could proceed regardless of whether the other proceeds.

EDC-2.

The attainment status of the air basins in which Edison plants are for sale are summarized in Table 4.5.2 of the Initial Study (page 4.5.6 of the Initial Study). A review of the table agrees with the commentor's statement that "Much of the State of California fails to attain either or both of the state or federal ambient air quality standards for a number of pollutants." The second sentence of the first paragraph of page 4.5.29 of the Initial Study indicates that all of the air basins affected by Edison plant emissions are nonattainment for the national and state ozone standards. The reasons the lead agency did not consider air quality impacts of the project as significant are discussed on pages 4.5.29 to 4.5.31 of the Initial Study.

The reason that the commentor has no citation for the Bay Area reclassification is that there is no such citation. According to information received from the Bay Area Air Quality Management District, the U.S.E.P.A. has proposed to redesignate the San Francisco Bay Area Air Basin from an attainment area to a nonattainment area, but to date the proposal has not been formally published in the Federal Register (Lim, 1997).

EDC-3.

CEQA does not mandate that any potential increase in emissions within nonattainment areas be considered a significant impact. Indeed, if that were the case, any project that would involve more vehicle trips, such as a single-family home, would be deemed to generate a significant impact. The Initial Study, at pages 4.5.29 to 4.5.31, explains why the project's air quality impacts are not considered significant.

EDC-4.

The reasons the lead agency did not consider air quality impacts significant are discussed on pages 4.5.29 to 4.5.31 of the Initial Study. The lead agency did not rely on inadequate Air Quality Attainment Plans. As noted in the third complete paragraph on page 4.5.31 of the Initial Study, areas that do not meet state air quality standards must update their air quality plans every three years.

EDC-5.

At the end of Comment EDC-4, the commentor states that an EIR must be prepared, and in this comment the commentor notes what information and analyses should be in such EIR. Since the CPUC determined that a Mitigated Negative Declaration is the appropriate environmental document and an EIR is not required, the contents of an EIR are not relevant in this situation. Nevertheless, the Initial Study included some of this information in Section 4.5 (see especially pages 4.5.23, 4.5.24, and 4.5.29 through 4.5.40).

EDC-6.

The comment addresses Edison's proposal to build a new substation in the Ellwood area, and not the divestiture project. Edison has not proposed to sell the substation site. The commentor's concern that the proposed substation will "possibly extend the life and/or production of Venoco's Ellwood facility" is not related to and would not be affected by the sale of Edison's Ellwood plant. The commentor also expresses concern that Venoco would purchase the Ellwood plant, & thus have access to more electric power. At this point, the identity of prospective buyers is unknown and it would be highly speculative for the CPUC to ponder on interests and motives. In any event, the CPUC will ultimately act on the sale of each plant, including the Ellwood facility. It is expected that parties will have the opportunity to submit comments on the results of Edison's auction.

However, the proposed substation project should be added to Table 4.16-1, "Local Community Projects Within 1 Mile of the Power Plants," on page 4.16.7 of the Initial Study.

The analyses and conclusions of cumulative impacts with local community projects described on pages 4.16.12 through 4.16.15 remain unchanged.

REFERENCES:

Lim, Kenneth, Bay Area Air Quality Management District, letter to Bruce Kaneshiro at the CPUC, September 25, 1997.