22 September 1997

Bruce Kaneshiro, Project Manger
California Public Utilities Commission
c/o Environmental Science Associates
225 Bush Street, Ste. 1700
San Francisco, CA 94104

Re: Mitigated Negative Declaration And Initial Study, dated august 25, 1997, PG&E Application 96-11-020, Proposal for Divestiture

Dear Mr. Kaneshiro,

[Begin ORA-1]
After reviewing the Mitigated Negative Declaration And Initial Study, the Office of Ratepayer Advocates' (ORA) main concern is the estimated cost of the proposed mitigation measures, and whether mitigation activities would delay divestiture. ORA is aware that PG&E proposed to submit to the Commission an environmental remediation cost forecast and supporting testimony on 1 October 1997.
[End ORA-1]

Sincerely yours,

/s/
Truman L. Burns

Project Manager
415/703-2932

cc: PG&E/M. Christie McManus; ALJ Careaga