MBUAPCD - MONTEREY BAY UNIFIED AIR POLLUTION CONTROL DISTRICT
On page 4 of the Mitigated Negative Declaration, the first sentence of the third paragraph of mitigation measure 4.5.a.2 is revised as follows:
PG&E agrees that the transfer of title for
Morro BayMoss Landing Power Plant will not occur until either Rule 431 or the plant’sispermit to operate has been so modified.
No changes are needed to the table for ozone, sulfur dioxide, and PM10. To reflect the information provided by the MBUAPCD, Table 4.5.2 for the North Central Coast is revised for carbon monoxide and nitrogen dioxide as follows:
| North Central Coast Air Basin | ||
| Pollutant | National | State |
| Ozone | Attainment | Nonattainment |
| Carbon Monoxide | Unclassified/attainment | Monterey-Attainment San Benito-Unclassified Santa Cruz-Unclassified |
| Nitrogen Dioxide | Unclassified/attainment | Attainment |
| Sulfur Dioxide | Unclassified | Attainment |
| Particulate Matter (PM10) | Unclassified | Nonattainment |
On page 4.5.12 of the Initial Study, the first two paragraphs of the Regulations, Plans and Policies Section are revised as follows:
Regulations, Plans, and Policies
The 1991 Air Quality Management Plan (AQMP) for the Monterey Bay Region addresses attainment of air quality standards for ozone and inhalable particulate matter (PM10) within Monterey, San Benito, and Santa Cruz counties. The AQMP addresses state planning requirements and establishes the basis for meeting federal requirements. CARB determined that a 30% reduction of those emissions leading to the formation of ozone is required to achieve the standard in the North Central Coast Air Basin. The 1991 AQMP was updated in 1994, and the 1994 AQMP addresses attainment of the State ozone standard only. The 1994 AQMP includes a revised design value which reduced emission reductions needed to achieve the State ozone standard from 30% to 20%. With the revised design value, no additional control measures were needed beyond those adopted between 1991 and 1994 (Brennan, 1997).
The wind speed and direction data cited on page 4.5.19 of the Initial Study were taken verbatim from PG&E’s Proponent's Environmental Assessment (PEA). Further review of the PEA data show the wind direction data referenced was taken from Monterey and Salinas. Regardless of which data set is more suitable, the result will not change the conclusions with respect to the Moss Landing Plant under divestiture. The Moss West site data mentioned appears more representative and will be used. Use of the Moss West site data does not change the conclusion that air quality impacts of the project would still be less than significant.
The last two sentences of the first full paragraph on page 4.5.19 is revised as follows:
The predominant wind direction at the site is from the west
north northwest, withandan average windspeeds range from 4 toof 8 miles per hour. An important secondary wind flow component is also observed from the east-southeast which is typically observed at night as a nocturnal drainage flow. Daily and seasonal variations are small.
To provide clarification the second sentence of the fifth paragraph on page 4.5.19 is revised as follows:
In 1993, units 6 and 7 together had a capacity factor of 54.4%
were utilized approximately 54.4% of the time.
As noted on page 4.5.20 of the Initial Study, the source of Table 4.5.5 was PG&E's Proponent's Environmental Assessment: Pacific Gas and Electric Company's Proposed Sale of Four Generating Plants, with minor modifications by Environmental Science Associates. The District suggests potential problems with the underlying data and analytical approach in this comment and in Comments MBUAPCD-7 and MBUAPCD-8. Each of the suggested changes in these three comments would decrease the percentage contribution of the Moss Landing Power Plant in comparison to county-wide emissions or, as this comment suggests, total air basin-wide emissions. A decrease in the relative contribution of the Moss Landing Power Plant emissions to other sources would not change the conclusion of the Initial Study that air quality impacts of the project would be less than significant.
Please refer to response to MBUAPCD-6. The described changes would increase mobile source emissions shown in Table 4.5.5 of the Initial Study and reduce the percentage contribution of the Moss Landing Power Plant to total emission sources in the entire air basin. A decrease in the relative contribution of the Moss Landing Power Plant emissions to other sources would not change the conclusion of the Initial Study that air quality impacts of the project would be less than significant.
Please refer to response to MBUAPCD-6 and MBUAPCD-7. The described changes would increase emissions from natural sources above the levels shown in Table 4.5.5 of the Initial Study and reduce the percentage contribution of the Moss Landing Power Plant to total emission sources in the entire air basin. A decrease in the relative contribution of the Moss Landing Power Plant emissions to other sources would not change the conclusion of the Initial Study that air quality impacts of the project would be less than significant.
REFERENCES:
Brennan, Janet, Supervising Air Quality Planner, Monterey Bay Unified Air Pollution Control District, Planning and Air Monitoring Division, letter to CPUC, September 4, 1997.