ORA - OFFICE OF RATEPAYER ADVOCATES

ORA-1.

Five of the six mitigation measures listed in the Mitigated Negative Declaration ensure that an existing rule applies to a new owner, or the transfer of materials and documents from PG&E to the new owner. The sixth mitigation measure requires PG&E to "prepare and certify its intent to comply with a program to address potential impacts to archaeological resources from PG&E actions related to the divestiture at the Morro Bay and Moss Landing power plants, such as construction to separate the properties or soil remediation activities." PG&E is not likely to incur delay or significant expense in complying with any of these mitigation measures. Soil remediation is not a mitigation measure, but rather is PG&E's liability, with or without divestiture (see response to CCC-2). The costs associated with remediation at plants to be divested are under consideration in the CPUC's divestiture proceeding (A96-11-020), as ORA is aware.