September 18, 1998
Mr. Bruce Kaneshiro
c/o Environmental Science Associates
225 Bush Street, Suite 1700
San Francisco, CA 94104

Dear Mr. Kaneshiro,

The County of Lake recognizes and appreciates the extensive research and quality presentation that Environmental Science Associates has devoted to the DEIR. The individualized attention given to the Geysers power plants in Lake County was warranted. Also, the public hearing in the Cobb Mountain area was helpful to Lake County officials and residents.

The Community Development Department has the following comments on the DEIR:

1) During the 9/2/98 public meeting at the Cobb Community Center, Lake County Supervisors and residents discussed concerns over the possible abandonment of a power plant due to a new operator going bankrupt or "skipping town". Such a situation would be devastating to the County if the County were to be burdened with clean-up and restoration costs of an abandoned, defunct power plant. Can the Final EIR answer the following questions?

a) Is the County or is the CPUC the lead agency with regard to clean-up of an abandoned power plant?

b) Can the Final EIR discuss the feasibility of requiring a new operator to post to the lead agency a financial assurance mechanism such as a surety bond? This would insure that any restoration and environmental clean-up will be funded in case of operator bankruptcy.

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2) On page 4.11-16 the DEIR discusses impacts on public services. The DEIR notes "The Geysers Power Plant generates an estimated $920,000 per year in property taxes to Lake County, which is about 2.8% of the County’s total property tax revenues. Proportionately, the Geysers generates more property tax revenues to Lake County than any of the other power plants being considered for divestiture." The DEIR goes on to conclude that "... it is unlikely that the decrease (property tax revenue) would lead to adverse physical effects on government services." A decrease in property tax revenue would be a significant impact to Lake County government services. The County is not a wealthy county and has a high percentage of retirees and individuals on various social welfare programs. The current County budget already falls short of funding needs.

Can the FEIR recognize that a decrease in property tax revenue would be a significant impact to Lake County and evaluate the following proposed Mitigation Measure?

a) Should property tax revenues to Lake County decrease, the CPUC shall fund the amount of the decrease to Lake County for three years to allow the county to maintain government services while seeking a long term solution to the decrease in property tax revenue.

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3) Page 5-10 discusses the Basin 2000 Project. It is my understanding that this project has been subject to budgetary cuts when the last state budget was finalized. If so, can the FEIR discuss how these budgets cuts will impact the future operations and planning for the Lake County units?

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Thank you for taking my comments under consideration. Please feel free to contact me at (707) 263-2221 if you have any questions.

Sincerely
/s/
Dave Wappler
Environmental Officer

cc: Lake County Board of Supervisors
Robert Cervantes, Community Development Director