AA. PAULETTE M. LAGANA (c/o CAP-IT)

AA1 The commenter is concerned that the EIR did not consider in its analysis the possibility that the Pittsburg Power Plant could be closed, as was considered with the Hunters Point Power Plant. The closing of the Hunters Point plant was considered a possibility in light of the June 9, 1998 agreement between PG&E and the City and County of San Francisco, in which PG&E agreed to shut down the plant when it was no longer needed for system reliability. Without a comparable agreement between PG&E (or the future plant owners once such party is known) and the local government, the prospect that any of the plants proposed for divestiture may close in the near future is too speculative to consider in the EIR. (As noted in the DEIR, all of the plants proposed for divestiture are designated as "must-run" plants for system reliability by the Independent System Operator [ISO].)

AA2 The commenter does not state the nature of her concern about the baseline and analytical maximum capacities assumed in the analysis of the Pittsburg and Contra Costa Power Plants. However, the baseline for these plants is based on an economic model that reflects operation of the Delta plants in 1999, and includes projections on future demand, future natural gas prices, operating expenses, regulatory restrictions, and a host of other assumptions which are documented in Attachment G of the DEIR. As noted in the DEIR, in order to conservatively depict the greatest potential project impacts in 1999, the 1999 Analytical Maximum scenario assumes that the plants would operate at their maximum capacities, within the parameters of their existing air permits and water discharge permits. This scenario also takes into account other limiting factors, such as scheduled and forced outages of units for maintenance; contractual limitations, including must-take contracts that favor power generated by qualifying facilities; and demand constraints (i.e., the finite demand for electricity at any particular time on any give day). Contrary to the commenter’s assertion, detailed discussions on project-related increases in traffic and noise are presented in Sections 4.6 (pages 4.6-1 through 4.6-5) and 4.10 (pages 4.10-1 through 4.10-16), respectively, of the DEIR. An entire chapter (Chapter 5, pages 5-1 through 5-42) is devoted to an analysis of cumulative impacts. Please refer to these sections of the DEIR for additional information.

AA3 The Pittsburg Power Plant is currently designated as a "must-run" facility by the ISO and must remain on-line during certain times in order to ensure system reliability. However, the ISO will annually re-evaluate its determination of must-run status for the Pittsburg plant and all other plants designated as must-run. The ISO bases its must-run determination on several factors, but generally chooses the most efficient generating units available to meet the reliability requirement. As new, more efficient power plant units are constructed and come on-line in the Contra Costa County area (if that occurs), the ISO would likely choose one or more of such new units for designation as must-run, and would remove such designation from any Pittsburg unit. Thus, no legal obligation would then exist to prevent the Pittsburg plant from being retired.

AA4 The power-generating equipment used at the Pittsburg and Contra Costa Power Plants is not the subject of this DEIR, which is focused on the potential environmental effects that would result from divestiture of the plants by PG&E. It should be noted that an existing regulatory structure governs and limits potential emissions to water, air, and soil by these power plants. For example, the Bay Area Air Quality Management District (BAAQMD) regulations impose requirements on the plants that limit their air emissions, such as Regulation 9, Rule 11, which requires the use of cleaner-burning natural gas to fire the generator boilers. Stormwater runoff and water discharges are regulated by the Regional Water Quality Control Board. For additional information on existing regulatory controls at the Delta power plants and potential impacts that would result from implementation of the project, see Sections 4.4, Water Resources; 4.5, Air Quality; and 4.9, Hazards, of the DEIR.

AA5 Although the new owner of the Pittsburg and Contra Costa Power Plants (the Delta plants) would not be required to guarantee that no jobs would be lost, they would be required to enter into an Operations and Maintenance (O/M) Agreement with PG&E for PG&E to operate and maintain the plants for two years following closing of the sale. It is PG&E’s intent to staff the plant during the O/M agreement period with existing PG&E employees. After this period, the new owner would develop a staffing plan to operate and maintain the facility. Although it is unknown at this time if the future owner would increase or decrease the number of employees at the Delta plants, as noted in the DEIR, it is likely that operational levels at the plants would increase in the future. It is therefore unlikely that a substantial number of jobs would be lost at those plants.

AA6 Please see responses to Comments B6 and R11, and pages 5-39 through 5-42 of the DEIR.

AA7 The issues raised by the commenter are addressed in the DEIR. Noise impacts are discussed in Section 4.10, beginning on page 4.10-10. Impacts of emissions are discussed in Section 4.5, beginning on page 4.5-51. Traffic impacts are discussed in Section 4.6, starting on page 4.6-2.

AA8 When evaluating health risks from exposure to emissions from industrial sources, especially risks from exposure to carcinogens, the background risk is usually not included in the analysis, because there typically is little or no information available on overall risks from exposure to toxics in a region. However, in the past few years, BAAQMD has been gathering information on exposure to air toxics. The Agency has relied on toxics emissions inventories that were prepared for most of the stationary industrial facilities in the Bay Area as part of the Air Toxics "Hot Spots" legislation (AB 2588), and also on health risk analyses that were carried out for sources with significant toxics emissions. This information was supplemented with air toxics measurements. Based on these data, the BAAQMD combined the health risk results and estimated that the maximum health risk in the air basin from industrial facilities is about 300 in a million. This health risk estimate does not consider other factors not related to industrial sources, such as mobile sources, diet, smoking, lifestyle, and exposure to chemicals by other pathways besides the air pathway. As reported in the DEIR, PG&E’s maximum contribution to health risks that was included as part of the total airshed health risk analysis was less than one in a million. In any event, the EIR focused primarily on the risks posed by the project (sale of power plants) since the purpose of the California Environmental Quality Act is to consider the change to the environment that will be affected by the project. The project’s maximum contribution to health risks were also found to be less than one in a million (pages 4.5-72 through 4.5-74).