September 18, 1998

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

First of all, we believe that it was a mistake to fold the analytical treatment of The Geysers plants into one document with PGandE’s fossil-fueled plants. The Lake County Board of Supervisors, the Lake County Air Quality Management District and Friends of Cobb Mountain all requested a separate document. The differences between The Geysers plants and the others, and the issues appertaining to them, are considerable, and as a consequence of the combination, several important issues have been lost and receive no treatment at all.

[End Q1]

A number of these issues are discussed in the comments which have been submitted to you by the Lake County Air Quality Management District. There is no point in our outlining these issues here, but in representation of the occasionally impacted residential public in the Cobb and Anderson Spring areas we request that they be given full treatment in the Final EIR.

[End Q2]

Another important cluster of issues surrounds aging of The Geysers power plants, the declining pressures in the steam field, and the inevitable and consequent progressive need for plant closures and abandonment. These are issues which you may deem to be beyond the scope of the EIR as they are matters that PGandE would have to deal with if the plants were not to be sold, but we believe that they are highly relevant to the consideration of a change of ownership because of consequences of which both the prospective buyers and the public should be informed through objective outside analysis. The impacts will be real, and they will be significant environmentally, economically and socially. For the protection of the public and of the environment, the Final EIR should provide guidelines and stipulations for their mitigation by prospective buyers.

[End Q3]

The level of seismic activity presently induced by commercial operations in The Geysers field may increase substantially with the implementation of the now approved City of Santa Rosa Geysers waste water injection plan. This also you have apparently considered to be outside the scope of the EIR because the plan will go forward whether there is a new operator or whether PGandE retains ownership. Here again a proposed new ownership would be moving into a new and largely unknown situation with potentially significant consequences. Again, we believe that guidelines and stipulations for mitigation are called for for the protection of the public by the agency which is in fact the Public Utilities Commission.

[End Q4]

An ambiguity of silence runs through the DEIR with regard to the possible eventuality of PGandE selling its Geysers facilities to several parties if a single buyer is not available. We raised this issue at the recent informational meeting regarding the DEIR at Cobb on September 2nd, and were assured that a new DEIR or an addendum to the present one would be prepared in order to address the numerous additional issues that would arise if multiple ownerships should be proposed. We ask that this be clearly stated in the Final EIR.

[End Q5]

Friends of Cobb Mountain appreciate the opportunity to participate in these proceedings and we ask that we be retained throughout as a party of interest.

Submitted by
/s/
Hamilton Hess
Vice Chairman