M1 The choice of Alternative 2A in combination with Alternative Three as the "environmentally superior" alternative was based on factors not necessarily reflected in the modeling results. In each divestiture scenario analyzed, the same assumption was used that the new owners could run the fossil-fueled plants up to their Analytical Maximum. Alternative 2A, selling the plants as a bundle, does not change this assumption, but it does lessen to some unquantified degree the tendency of new owners to operate more than PG&E would if it retained the plants. Alternative 3 was chosen for the Geysers because integration of the plants with the steam suppliers is likely to lead to more efficient and greater use of the available steam resource, as well as coordination between the steam fields and the generating units. This difference does show up in the model outputs when comparing this scenario (Table G-7) to the baseline (Table G-1). (The decrease in Geysers generation shown in Table G-5 is an anomaly caused by divestiture of the fossil-fueled plants, and not divestiture of the Geysers plants. Please see response to Comment H18.)

The project as proposed by PG&E (selling the plants in four packages) was indeed modeled. The Analytical Maximum capacity factors of the plants sold in the packages proposed by PG&E form the basis for the environmental analysis in the EIR.

The designation in the DEIR of an "environmentally superior alternative" is a requirement of CEQA and, therefore, this cannot be removed. However, the CPUC is not obligated to select the "environmentally superior alternative."