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Home My WebLink AboutSP 144B; SDG&E Wastewater Facility; Specific Plan (SP) (2)bcc: L.J. Brunt on w -_! J.M. Burns ^ _ ^-^ °V.J.N. DiiiowaySan Diego Gas 8t Electric «~T> M.J. Horna O P.J. Oberhaus L.D. Siebrand A. A. Sugg September 1, 1981 FILE NO M.J. Wood MUC 100 Ms. Catherine Nicholas City Planner Carlsbad, CA 92008 Dear Ms. Nicholas: Recently you telephoned and asked several questions concerning the San Diego Gas & Electric annual report on En- cina powerplant. These questions were asked by interested citizens at the Wednesday, August 26 Planning Commission meeting. Below I've attempted to answer the generic questions plus have included a couple of articles about acid rain. 1. What percentage of total fuel at Encina is natural gas versus residu- al fuel? In 1980 76.78% of the total fuel ,-^^used at the Encina plant was residu- al oil, and 23.22% was natural gas. We expect continued natural gas availability. Please see the attached graph indicating the fu- ture expected natural gas availability as compared to re- sidual oil for the entire SDG&E generation system. 2. What is the expected sulfur content for SDG&E proposed medium sulfur fuel oil test burn at Encina? We expect to obtain 1.25% sulfur fuel oil for the test burn opera- tion. Please note the actual test burn period is only six weeks in duration. Attached is a fact sheet concerning the test burn proposal. POST OFFICE BOX 1831-SAN DIEGO, CALIFORNIA 92112 • TELEPHONE: 714/232-4252 Ms. C. Nicholas -2- September 1, 1981 3. How much acid rain is there in San Diego County? We don't have that answer but I've attached two arti- cles concerning acid rain. We don't believe our test burn of medium sulfur fuel will affect the acidity of rain. 4. What direction does the wind blow at Encina Powerplant for disper- sion of pollutants? Encina is located in a coastal environment and is subject to the normal sea breeze circulation. Thus one expects great variations in wind flows with heights. How- ever, surface wind data from on- site monitor, nearby Palomar Airport and Oceanside Weather station all indicate that for most of the day, winds from the southwest through northwest domi- nate. And easterly through northeasterly winds prevail at night. Average wind speeds are approximately 5-7 mph. Since this report goes to City Council on September 15, 1981, and there might be questions, SDG&E will have rep- resentation at the meeting. Sincerely, E.M. Gabrielson Supervisor Licensing & Environmental /dc Attach 1 . • u 0 0 1 0 0 0 0 BO 0 0 t U 0 0 <• U 0 0 . 0 0 0 EXII1 141 i (.\) - l X - Oil o - Natural Gas 1976 1977 1978 1 979 I960 1962 1983 198<» SDG^E FUEL USE - NATURAL GAS IS PRESENTED IN EQUIVALENT BARRELS OF OIL ' i "•>, i - /\ standing would require continued research into air quality impacts as well as other environmental and social effects of all fuel cycles, including those of the conventional fossil fuels, of nuclear power, and of the conservation and use of renewable energy strategy. Although long-range pricing reform is a complex issue, raising serious questions related to equity, inflation, and income distribution, other impedi- ments to the conservation and renewable resource alternative can be more directly addressed. For ex- ample, corporations usually treat capital invest- ments for conservation differently from other investments; often a higher rate of return is required before the investment will be made (Schurr, 1979). Offering investment tax credits for conservation and renewable energy investments similar to those of- fered for fossil fuel energy facility construction and development is one suggested means of encourag- ing the growth of such investments. Current policy is directed toward encouraging investment in con- ventional facilities; about $150 billion in direct fed- eral subsidies has been provided to conventional energy sources in the past few decades (Hayes, 1979). An analysis of oil production tax incentives concluded that "these tax incentives effectively allow an investor to recover at least 50 percent of the capital initially invested in a new oil production ven- ture through reduced taxes11 (Alliance to Save Energy, 1980). If similar tax credits and incentives were provided for conservation efforts and the use of renewable resources, their adoption would be considerably accelerated and the benefits associated with their use could be realized more immediately. Other impediments to increased energy efficiency are based on the manner in which conservation in- vestments are viewed by many consumers, includ- ing small corporations and private investors. Initial capital costs often deter the small investor from purchasing energy-efficient processes or equipment that would prove economical in the long term. This tendency could be countered to some extent by an effective information program that would increase consumer understanding of life-cycle energy costs. Also, quality control assurance for available tech- nology would help to remove the perceived high risk associated with conservation and renewable energy investments. Subsidy programs for consumers and equipment manufacturers have also been suggested to accelerate adoption of more energy-efficient options, particularly solar power. However, such subsidies would have to be developed with great care in order to avoid biasing energy pricing away from marginal cost pricing. The Office of Technology Assessment study of residential conservation listed several changes in housing construction standards that are necessary to realize energy savings. The study concluded that regulatory requirements may be needed if present market incentives are insufficient to cause the adop- tion of such standards. However, it is possible that extensive requirements may discourage product in- novations, and the study recommends policies that are designed to provide easily understood informa- tion to homeowners and potential home buyers. The importance of effective education and infor- mation programs is shown by study findings indicat- ing that the information available at the time and place of purchase significantly affects consumer's purchase decisions. Because the federal and state governments generally have better access to reliable product information than do individual consumers, and because many energy savings do not involve equipment purchases, government programs can provide information not readily available otherwise. The early adoption of energy-efficient policies in federal agencies also would provide both a testing ground for domestic innovation and an incentive for public sector participation. Sulfate Transport and Acid Rain Assuming continuation of present air pollution control policy, sulfate transport under most energy projections is expected to decrease until 1990, when it will begin to increase. Current transport levels are expected to be exceeded by 2010. Specific regulatory alternatives designed to reduce the amount of sulfur dioxide generated in the Midwest could reduce the amount of transported sulfates through 1990 an additional 15 percent to 22 percent compared to esti- mated levels with currently required controls. After that date, sulfur dioxide emissions from that area will rise less than 5 percent by the year 2000 under both high and low national coal use forecasts (ORI, 1981). (See Part 3, Chapter 9 for more detailed dis- cussion of sulfate transport.) The amount of sulfate transported is primarily dependent on the mix of fuels and, to a lesser ex- tent, regulatory policy. Sulfate transport to the Northeast will be greater if coal consumption is high, because of the conversion of existing plants, than if more imported oil is used, assuming the same total investment in sulfur dioxide pollution control equipment. More importantly, a high degree of energy conservation and more efficient energy technology would reduce the amount of sulfate transported from the Midwest through the year 2000. 302 Visibility Degradation Visibility degradation because of regional haze has been linked to the formation and transport of sulfate. In examining forecasts of energy consump- tion patterns and regulatory policy, the Commission studied the effects of sulfate formation and transport on visibility in areas designated Class I (which in- clude national parks and wilderness areas) under the prevention of significant deterioration program. Only small additional amounts of pollution are per- mitted in these areas. At the present time, visibility is often impaired in Class I areas in southern Cali- fornia and southern Arizona. Some undesirable visibility conditions have occurred in most other Class I areas, with the exception of those in the central United States, northern New England, and Florida. Regional .haze visibility impairment is not pro- jected to differ from current levels in the Southwest through 1995, assuming continuation of current regulatory policies and the installation of additional pollution control equipment on smelters by 1990. Failure to adhere to the smelter control require- ments would significantly reduce regional visibility in the area (LASL, 1980b). All energy consumption forecasts except those stressing accelerated conservation and solar alterna- tives indicate the possibility of reduced visibility in several areas of the West, regardless of the projected fuel mix. The increased visibility degradation possi- ble in the eastern United States was found to be somewhat dependent on the fuels used; forecasts that assume high coal consumption predict a greater potential reduction in visibility for these areas than do forecasts that assume the use of less coal (ORI, 1981). Carbon Dioxide Carbon dioxide, which is emitted by the combus- tion of fossil fuels, is not a regulated air pollutant. Carbon dioxide is a natural trace constituent of the atmosphere; its concentration has been observed to increase steadily over the past 20 years (National Research Council, 1977). It is suspected that the concentration of atmospheric carbon dioxide has in- creased since the start of the Industrial Revolution. The most probable causes of this rise are the in- creased combustion of fossil fuels and changes in land-use patterns such as deforestation. Carbon dioxide absorbs infrared radiation. This absorption may, if the concentration of carbon diox- ide is sufficiently high, cause the lower atmosphere to become warmer. A warmer lower atmosphere may affect cloud formation, precipitation, and wind patterns; these changes could alter agricultural prac- tices, disturb the distribution, composition, and pro- ductivity of natural ecological systems, and cause changes in oceanic circulation. The length of lime before such changes will be ob- served is the subject of considerable speculation. Carbon dioxide is removed from the atmosphere very slowly; excess carbon dioxide can remain in the atmosphere for several hundred years. About one- half of carbon dioxide emissions remain in the atmosphere. Some investigators are concerned that significant changes in climate could occur as early as the beginning of the 21st century. Others suggest that such changes will not occur before the middle of the next century, if at all. However, such changes in climate could occur in a matter of decades if there is sufficient atmosphere warming, and the stresses applied to both biological and social systems would require significant adaptations. The amount of carbon dioxide released in the pro- duction of one unit of energy (measured in Btus) varies for different types of fuel, with natural gas producing the lowest emissions. The combustion of oil releases about 1.5 times as much carbon dioxide as the combustion of natural gas, and the combus- tion of coal about 1.8 times as much. The various synthetic fuels release between two and three times as much carbon dioxide as natural gas (Woodwell et al., 1979). As the use of coal and synthetic fuels in- creases, the amount of carbon dioxide in the atmosphere will increase proportionately. Although technologies for controlling and disposing of carbon dioxide emissions are generally not considered prac- tical at this time, the natural gas industry indicates that carbon dioxide emissions from coal gasification facilities can be collected and used for injection into depleted oil fields to enhance production (MITRE, 1980). Global carbon dioxide emissions in 1980 are esti- mated to be 20.2 billion tons. The contribution to global carbon dioxide levels from U.S. fuel combus- tion could rise dramatically even with moderate energy growth, increasing from about 16 percent in 1976 to approximately 40 percent in 2010. The amount of carbon dioxide emissions is only slightly dependent upon the relative mix of coal and oil; in- creased coal use at the expense of oil would result in an approximately 7 percent greater contribution of U.S. carbon dioxide emissions to the atmosphere. However, conservation and increased energy effi- ciency with high levels of coal development, as well as with continued use of oil at current levels, can significantly alter predicted U.S. carbon dioxide emissions, perhaps reducing them by as much as 20 percent (ORI, 1981). 303 •i! •;;£•£ Participants at a Commission workshop discussed possible public policy rt ponses to the concerns about carbon dioxide. Th;, suggestions of this work- shop included continuing support of national re- search to address the uncertainties associated with the effects of increased carbon dioxide in the atmosphere; augmenting scientific research with studies of policy options for addressing potential problems associated with increased carbon dioxide; expanding international scientific and public policy References Acurex Corporation (1980). Kern County Thermally Enhanced Oil Recovery. The Southern California Regional Study. Report lo the National Commission on Air Quality, Con- tract No. 6J-AQ-7382. Alliance to Save Energy (1980). Policy and Program Direc- tions 1980-1981. Alterman, J. (1978). The Energy/Real Gross Domestic Prod- uct Ratio. Staff Report, Bureau of Economic Analysis, Depart- ment of Commerce. Reported by S.H. Shurr, in Energy, Eco- nomic Growth and Human Welfare. EPRI Journal 3:14-18. Carter, J. (1979). Comprehensive Message on Energy and En- vironmem—Message from the President— PM93. Congressional Rnorcl. Vol. 125, No. 109-Parl II, p. 11411-11419. Congressional Research Service, The Library of Congress (1975). Energy Facts II. Dames & Moore (1981). An Investigation of Prevention of Significant Deterioration (PSD) of Air Quality and Emission Offset Permitting Process. Study of PSD and Offset Permits. Re- port lo the National Commission on Air Quality, Contract No. la-AQ-7133. Darmsladter, J., J. Dunkerly, and J. Alterman (1977). How In- dustrial Societies Use Energy. Resources For the Future. Baltimore: The Johns Hopkini-Liniversity Press. Department of Commerce (1977). Energy Conservation Policy Opportunities and Associated Impacts Study, Vol. 1 and 2. Department of Commerce (1980). Bureau of Economic Anal- ysis Survey of Current Business. Vol. 60, No. 1-12. Department of Energy, Energy Information Administration (1979a). Annual Report to Congress. Volume 2. Department of Energy, Division of Conservation «nd Solar Applications (1979b). Conservation Strategy. Department of Energy, Energy Information Administration, (1979c), Annual Report lo Congress. Volume 3: Projections. Department of Energy, Energy Information Administration (1980). Monthly Energy Review: April and September. Environmental Protection Agency, Office of Air Quality Plan- ning and Standards (1980). National Air Pollution Emission Esti- mates 1970-1978. ETA Engineering, Inc. (1980a). Identification of Alternative Development Scenarios. Twin Cities-Si. Cloud Regional Study. Report to the National Commission on Air Quality, Contract No. !2h-AQ-7705. ETA Engineering, Inc. (I980b). Analysis of Alternate Devel- opment Scenarios. Twin Cities-St. Cloud Regional Study. Report to the National Commission on Air Quality, Contract No. 12L- AQ-7705. federal Register (August 7, 1980). Requirements for Prepara- tion, Adoption, and Submittal of Implementation Plan, Ap- proval and Promulgation of Implementation Plans. Vol. 45, p. 52676. research; considering carbon dioxide emissions and possible climatic changes in the development of fu- ture energy and other national policies, such as those being considered for industrial revitalization and the siting of disposal facilities for long-lived toxic and radioactive wastes; and encouraging land- use practices such as active reforestation and mini- mal deforestation that are stabilizing factors in the global carbon cycle (Schwartz & Connolly, 1981). GCA Corporation (1980a). Evaluation of Alternate Develop- ment Scenarios. New York-New Jersey-Connecticut Regional Study. Report to the National Commission on Air Quality, Con- tract No. 13f-AQ-771g. GCA Corporation (1980b). Phase II and Phase III Analysis of TSP and SO2 for the New York Metro/Hartford Regional Study. Report to the National Commission on Air Quality, Contract No. 13k-AQ-7718. Grimes, M., et al. (1980). Clean Air Act: An Overview. Issu? Brief No. IB80078. Congressional Research Service, The Library of Congress. Gulick, F. (1'979). The Energy Problem and the Congressional Response: An Overview. Chapter I: Energy Initiatives of the 95th Congress. Congressional Research Service, The Library of Con- gress. Hayes, D. (1979). Short-Term Solar Prospects. In Energy Con- servation and Public Policy, J.C. Sawhill, Ed., Prentice-Hell. Inside EPA (December 19, 1980). Washington D.C.: Washing- ton Publishers. Lakhani, H. 0981a). Forecasting the Cost of Energy Conser- vation in the Industrial Sector. Energy-The International Journal. In press. Lakhani, H. (1981b). Forecasting the Cost of Energy Conser- vation in the Residential Sector. Applied Energy-An International Journal. In press. Lekhani, H. (1981c). Forecasting the Cost of Energy Conser- vation in the Transportation Sector. Applied Energy-An Interna- tional Journal. In press. Lakhani, H. (1981d). Forecasting Economic, Energy, and En- vironmental Impacts of National Energy Plans, 1990 • 2000. Technological Forecasting and Social Change-An International Jour- nal. In press. Los Alamos Scientific Laboratory (1980a). Air Quality Man- agement. Four Corners Regional Study. Report to the National Commission on Air Quality, Contract No. 14a-AQ-7721. Los Alamos Scientific Laboratory (1980b). Regional Air Quality in the Four Corners Study Region and Local Air Quality in the Four Corners Study Region. Four Corners Regional Study. Report to the National Commission on Air Quality, Con- tract No. 14H-AQ-7721. Los Alamos Scientific Laboratory 0980c). Alternative Devel- opment Strategies. Four Corners Regional Study. Report to the National Commission on Air Quality, Contract No. 14p-AQ- 7721. Los Alamos Scientific Laboratory (1980d). Alternative Devel- opment Scenario and Analysis. Four Corners Study Region. Re- port to the National Commission on Air Quality, Contract No. l4q-AQ-772I. Los Alamos Scientific Laboratory (1980e). Alternate Policy Evaluation. Four Corners Regional Study. Report to the Na- tional Commission on Air Quality, Contract No. 14s-AQ-7721. Marshall, E. (1980). Energy Forecasts: Sinking to New Lows. Science. Vol. 208. 304 JR.- W iill MITRE Corporation (1980). Feasibility of Utilizing Carbon Dioxide Produced During the High Blu Coal Gasification Proc- ess for Enhanced Oil Recovery. National Academy or Sciences (1979). National Research Council. Energy in Transition, 1985-2010. Final Report of the Committee on Nuclear and Alternative Energy Systems. National Research Council (1977). Energy and Climate. Wash- ington, D.C.: National Academy of Sciences. Office of Technology Assessment, U.S. Congress (1979). Resi- dential Energy Conservation. ORI (1981). Study of the Potential for Coal Use and Related Economic and Air Quality Implications of Future Energy Scenarios. Report to the National Commission on Air Quality, Contract No. 24-AQ-7744. PEDCo Environmental, Inc. (1980a). Identification of Scenarios. Ohio River Valley Regional Study. Report to the Na- tional Commission on Air Quality, Contract No. llk-AQ-7695. PEDCo Environmental, Inc. (1980b). Analysis of Emission Reductions and Air Quality Changes for Alternative Develop- ment Scenarios. Ohio River Valley Regional Study. Report to the National Commission on Air Quality, Contract No. llu-AQ- 7695.t President's Commission on Coal (1980). Recommendations and Summary Findings. Washington, D.C.: Government Printing Office. Schurr. S. (1979). Encrn\ in Amcrito's Futurr: Tin Chokes Be/ore Us. Baltimore: Johns Hopkins Press Schwartz 4 Connolly. Inc. (1981) Summary Rcpon of Ihe NCAQ Carbon Dioxide Workshop. Report to the National Com- mission on Air Quality, Contract No 30-AQ-9I56 Smith, ct ul. (I9K01. IJ'A Utility KOI) Survey, July-September 1980. Reporl prepared for the U.S. Environmental Prelection Agency by PEDCo Environmental, Inc. Slobaugh, R., and D. Yergin (1979). Enew Future. Report of Ihe Energy Project at the Harvard Business School. New York: Random House. Systems Applications, Inc. (1980). Air Quality Impacts of An- ticipated Development in Oil Shale Operations in Western Col- orado and Eastern Utah. Draft Final Report. Denver Research Institute. Trumbule, R. (1980). Acid Precipitation: A Serious and Grow- ing Environmental Problem. Issue Brief No. 1B80022. Congres- sional Research Service, The Library of Congress. Wilson, C. (1980). Coal-Bridge to the Future. Report of the World Coal Study. Cambridge, Mass.: Ballinger Publishing Co. Woodwell, G., et al. (1979). The Carbon Dioxide Problem: Implication for Policy in the Management of Energy and Other Resources. A Report to the Council on Environmental Quality. 305 Are Sierra lakes becoming acid? \ Gordon R. Bradford D Albert L Page D Ian R. Slraughan - ^-. ^ t_ 1 .«*' AS'/ I sing acidity of some laLts outside California, particularly in eastern United Stato and Canada, and in the Scandinavian countries, is attributed in ovdi-s of nitrogen and sulfur from automobile exhausts and industries The U.S. Environmental Protec- lion Agency has recently included the Sierra Nevada a* pa/t of a larger area in the United Slates considered lo be sensitive to lake acidi- fication. We have studied the problem, because of the presumed sensitivity of these lakes lo acidification. Fortunately, we obtained data on the acid content of 170 Sierra lakes in 1965 ("Trace and major element content of 170 Sierra lakes in California," Limnology and Oceanography, Vol. 13, no. 3. July 1968, by Bradford et al.). These data provide a vaJuable resource to Commodity programs, continued "plannrcned to expand, and very few intended to rat/educe size. Several researchers have ^lha^ commodity programs have been One cause c<ihe trend toward fewer and larger farms. The stated intentions indicate that California program participants are no more likely than nonparticipants to enlarge their operations, at leastNn the short run. Surprisingly few of the\urveyed partici- pants, 1.7 percent, had sought the nonre- course loans available under the •Commodity program. Apparently, the Iow-inte\st loans were not sufficiently attractive to offsw per- ceived disadvantages and were not an impor- tant inducement to program participation Survey respondents were asked to rank a list of reasons for participating or not partici- pating in the 1978 programs (tables 2 and 3). Nearly all Tanners operate with credit from a variety of sources, but only 2.7 percent of the participants listed the loan officer's influence •s their most important reason for participat- ing More than half (56.8 percent) said their most important reason was that they "ex- pected participation to result in higher net income." Nearly one-fifth (18.9 percent) "expected participation lo reduce prieeand/ or yield risk." Overall, when considered as the first or second most impopant reason for participation, expected higher' income was mentioned the mow frequently (71.6 percent), and cxpretw risk reduction was the second most mprfiioned. Higher expected income was a much less important reason for nonpanicipanu' deci- sions. Almost half (46.9 percent) indicated that they primarily were "opposed to govem- 6 CALIFORNIA AafUCUlTUAC.. MAf JUNE 1961 ment involvement in agriculture." Overall, when considered as the first or second most important reason for nonparticipation, opposition to government intervention was mentioned most frequently. Of course, gov- ernment involvement could be opposed for a number of reasons: a perception that man- agement freedom is restricted, that govern- ment control is loo pervasive, or perhaps simply that income might be higher in free markets, since many farmers believe lha government programs result in a "c food policy that discriminates intfvor of consumers and against farmers y .Conclusion ost California fanXe'rs have chosen not to patjicipate in the/federal price and income supporNprograrjre when required to set aside a portion cfa>fcir acreage. Many view the cost in foregonemcome as excessive in com- parison with program benefits. Others arc philosophically opposed to governmental in- yfervention in agriculiuraJ markets. A large number of those who choscio participate anticipated that the program wvaild enhance their income or reduce income ris> Many farmers probably will continue lo choose not to participate in the commobiH programs whenever set-asides are in effects The large investments in machinery' irrigation equipment characteristic of the stale's agriculture translate inio higher income and perhaps lower risk and thereby reduce incentives for program participation. California farmers do no! seem to gain a great deal from the commodity programs established by the Food and AgricuUure'Act of 1977. Although it is difficulti»^redici the outcome of those dclibcrajjiffis on a new an to be passed in 1981, it/appears likely that the disaster programwfflbe phased out in favor of an expands crop insurance program. Congressjidf already passed legislation to ex- pandLhe crop insurance program with subsi- premiums. Because of the stability of lelds- in California when compared with those in other stales, fanners here will prob- ably not be greatly affected by elimination of the disaster program. California taxpayers may be better off with the paid crop insurance program than with the disaster program, depending on the level of subsidization. The potential elimination of the disaster program illustrates one effect government progiams have on decision making in agricul- ture. The programs are designed in pan to reduce price and yield uncertainty in agricul- ture, but they often introduce another uncertainty — about policy. Frequen. changes in program features and require ments make long term planning more diffi cult for farmers. Randall A. Kramer, formerly Ptaifraduan Research Agricultural Economist, University ojj California. Davis, if Aatuani Professor of Ann- nXfi/ro/ Economics. Virginia Poiyin Itnic Insti'uie antl\oie Univrruly. B/ockihurf. \'irymia; Kultm U f'v^f^Jiirnierly Awslont l'rii(e\vir af Anncul- luralLcomanm at Davii. is Associate Pmfrsuirvf Africulturaf-fconomirs. Texa-, A (t M University; and H Drlivbrih Gardner is Director, Giannini foundation of Agricultural Economics, University of California. Berkeley and Davis, and Projeaor of Agricultural Economics, Davis I rompare possible changes in lake acidity thai -nay have occurred between 1965 and the pre- sent. During July and again in Oci ober 1980, 114 random lake waier sample;, were collected by JieJicopier from Yosemite, Sequoia, and Kings Canyon National Parks. Surface water samples were collected by lowering a plastic container through the open door of the heli- copter ho»ering 3 meters above the surface. Each sample was immediately transferred to a I-gallon (3.8-liter) polyethylene bottle with a tight-fitting screw cap. About 20 samples were collected before returning to the base camp «long Highway 395, where-the pH or acid content was immediately measured with a portable pH meter. Sampling by helicopter made it possible to collect more samples in less time and probably at Ins expense than by any other available methods. All samples were returned lo the laboratory within four day's, and the pH measurements repeated on two different digital pH meters. All pH mea- surements in the Held and (he laboratory were in good agreement. Rainwater is normally slightly jcid (pH 5.6)" Because of dissolved^carbon dioxide from the atmosphere. Pure water with a pH of 7.0 is neutral. The mean and median pH values listed in the table indicate that Sierra lake waters are less acid than "normal" rain- water. This is also true for the 10 lakes where fish kills were reported during the summer of 1980 (see table footnote). The mean pH of these 10 lakes was no different from the mean pH of all other lakes. The lowest pH (4.7) of one sample- col- kvied in 1965 was not observed for the same lake in the 1980 sampling nor in any other of the samples collected. No explanation can be presented for the anomalous value. The mean pH value for the October 1980 sampling was approximately one-half a pH unit higher- than (he July sampling. This probably reflects the seasonal effect of in- creased resident time of the water in the lake and associated buffering action with lake sediments. Results obtained for pH of lake waters sampled in 1980 compared with those col- lecied in 196$ are also presented in the table. It is most significant thai these data show essentially no change in the acidity of lake waters in the Sierras during the past IS years. The "acid rain" observed by low pH mea- surements made in coastal and interior vat- leys near population centers is probably diluted and possibly neutralized 10 such a low concentration by the time il reaches the high Sierra thai h has no measurable effect on the acidity of the Siena lakes. r* :»*-•>< (r- A-.d:ij PI' . '(. ••r."I6 ..* > >•»• -yr More than 100 Sierra lakes were sampled helicopter by researchers John Warnecke (lett) and Gordon Bradford Total concentrations of alkali and alkaline earth metals in both I965 and 1980 lake waier samples are very low (lessthan 5 mg per liter), indicating a very low capacity to buffer acid deposition. Complete chemical analyses of the lake waters art in progress and will be reported later. Cordon K. Bradford if Specialist, and Albert L. Page is Chemift. Deportment of Soil and Environmental Scirncrii. Um\frsity of California. Kirer- side; Ion K. Hiraughan is Manager. Envirtmmrinul Sysiemt Research, Southern California keiisnn Company, Kosetneod The I96f study of Sn'rru faies nut supported in part b\ the L'.S /'tihln Health Service Research Grant j\t>. UHKUM Jrnm ihr National Center for Urban and Industrial Health: the 1980 port of the Itudv b\ Southern California EdMin Company. The authors thank the /of/citing for emisiamr in sampling Sierra takes: Me! Hehmueller and Boh Cloud. Southern California Edison helicopter pilots: Don South word, SCL helicopter maintenance- Tom Keener. SCt' research and development: and John t Hornecke. Staff Research Associate. Department nf Soils and Environmental Science, l/nivrrsin <>f California, Riverside. -••»-*. r. .'. •• '"i^ •*"*~^i".'.".='"-" .•!"• ^^>.^-^ ( over photn by Alfred Smith. FACT SHEET TESTING MEDIUM SULFUR FUEL Program Purposes To test burn a medium sulfur fuel oil to gather facts on whether it can be used economically and safely. Program Plan: Perform a six week test burn at Encina Power Plant in Units 4§5. Unit operation, efficiency, emissions and air quality will be closely monitored in conjunction with the APCD. Test Fuel Oil; The oil to be tested will be similar to that presently being used except that it will be of domestic origin and with a sulfur content of up to 1.25%. Current regulations limit fuel oil sulfur content of 0.51. Oil Requirements: Cpnsumption of fuel oil by SDG$E is projected to continue to decline. Total oil use by SI)Gf,E peaked in 1977 at over 12 million barrels, has declined to less than 9 million in 1981, and is projected to be only 5 million in the mid-1980's. The decrease is due to the increased availability of natural gas resulting from a change in regulations, purchases of economic energy from geothermal plants in Mexico and coal plants in Arizona and New Mexico, and nuclear power from San Onofre Units Air Emissions: Because the test is limited to only Encina Units 455, and since much less fuel oil is being used by power plants in San Diego in total, the sulfur emissions during the test should be no more than that emitted in 1977, and much less than SDG£E is presently allowed to emit if all units were burning the 0.5% S fuel oil. Air Quality Ambient sulfur dioxide levels in San Diego County are presently, and historically have been at 101 or less of the federal health standards. At no time during the test should these ambient levels increase significantly and should remain far below the standards. Potential Savings Medium sulfur fuel oil is currently available at a savings of about $7 per barrel. If it is determined by the test program that the medium sulfur fuel oil could be safely used in Encina Units 4§5, it is estimated that the ratepayers could realize a savings of from $8 to $30 million annually without and significant reduction in ambient air quality. EXHIBIT (D) AMBIENT S02 LEVELS IN SAN DIEGO COUNTY Maximum 1-Hour Average Escondido El Cajon Oceanside 1980 131 131 131 (yg/m3) 1979 157 105 157 1978 157 79 79 State Standard 1310 1310 1310 Annual Average Escondido El Cajon Oceanside 1980 21 16 16 (Ug/m3) 1979 13 16 5 1978 0 8 0 Federal Standard 80 80 80 LJB 8/13/8 S02 EMISSIONS IN TONS -Assumes test is successful and medium sulfur.actually is burned as shown in Exhibit (B)- EXHIBIT (C) 1983 1984 1985 1.25% S2 Fuel Allowable Using .491 S2 Fuel 23,510 15,814 15,598 37,434 37,434 37,434 JMR 8/13/8. EXHIBIT (B) Oil Use and Potential Savings from Use of Medium Sulfur I:uc] YEAR 1982 1983 1984 1985 ESTIMATED OIL NEEDED 7. 7. 5. 4. 1 MMbbl 6 0 6 MEDIUM SULFUR OIL USED 2. 5. 3. 3. 8 MMbbl 6 8 9 ESTIMATED SAVINGS $ 8 16 26 27 .4 million .8 .6 .3 The following assumptions are made in estimating the potential savings: 1. Medium sulfur can be burned starting 7/1/82, thus including only half of 1982. 2. Savings per barrel estimated at $3.00 for 1982 and 1983 while we still have oil contract obligations. 3. Savings per barrel estimated at $7.00 for 1984, 1985 and thereafter, where there would be minimal or no contract obligations. 4. The assumption is made that this program will include the Encina Units 4fj5 only. JMB 8/13/8 EXHIBIT [A)-2 GW-hrs 9000 8000 7000 6000 5000 1976 1977 1 978 1979 1980 1981 83 1 9 fl i,1 9 .1 5 SDG5E FOSSIL FUEL GENERATION EXHIBIT (A)-1 x - Oil o - Natural Gas 1 9 7 f.1977 1978 1979 1961 1982 1983 i B U 8 5 SDGSE FUEL USE - NATURAL GAS IS PRESENTED IN EQUIVALENT BARRELS OF OIL MEMORANDUM TO: Planning Director FROM: Assistant City Manager/Developmental Services DATE: June 22, 1981 SUBJECT: ENCINA POWER PLANT - UNIT 5 Attached is a report received from San Diego Gas and Electric in conformance with conditions attached to the approval for the con- struction of Encina Unit 5. Also attached is a copy of Ordinance 9456, the document of approval. A couple of actions are required: (1) Review the report and pre- pare a transmittal to the City Manager and City Council regarding the report and the actions taken; (2) take the necessary steps as indicated in Section F of the Ordinance regarding a staff report on compliance with conditions. ' Please give me an estimated time of completion regarding the two items requested. Attachments RAB/cle San Diego Gas SL Electric June 16, 1981 FILENO RECEIVED Mr. Bill Baldwin ;' :"' 1 Assistant City Manager ^..- City of Carlsbad •-,./ ,,,_ 0 „-.,__.„ . city Hall -•'-;- CARLSBAD. < 1208 Elm Avenue "'•'olopraental .Services; | Carlsbad, California 92008 Dear Mr. Baldwin: Ordinance No. 9456, Section 3(j), dated May 4, 1976, requires SDG&E to file with the City Council an annual report regarding improvement in plant and operating procedures during the preceding year which reduce the emission of air pollutants re- sulting from the operation of Encina 1-4. The fourth such annual report is attached herewith. Should either you or the Council desire any further information, please contact me at (714) 235- 7766, or L. J. Brunton on my staff. Sincerely, E. M. Gabrielson Supervisor Licensing & Environmental Department /z Attachment cc: R. Sommerville - APCD R. Beckman - Carlsbad City Public Works POST OFFICE BOX 1831 -SAN DIEGO. CALIFORNIA 9211 2 • TELEPHONE: 714/232-4252 MEMORANDUM DATE: July 2, 1981 TO: Ron Beckman Assistant City Manager/Developmental Services FROM: Catherine Nicholas Assistant Planner SUBJECT: REPORT ENCINA POWER PLANT Conditions of approval of Specific Plan, (SP-144B), for construction of Encina Power Plant Unit 5, requires Planning Commission and City Council review of a "Report of Compliance", prepared by staff. I have scheduled this item to be heard at the Planning Commission meeting of August 26, 1981. I would suggest forwarding the SDG&E Annual Report to the City Council at the time the "Report of Compliance" is considered. CDN:ar RECEIVED JUL2 1981 r.lTY OF CARLSBAD,evelopmental Services; SAN DIEGO GAS & ELECTRIC COMPANY P.O. BOX 1331 SAN DIEGO. CALIFORNIA 92112 (714) 232-4252 FILE NO. CAB 500 December 22, 1977 City of Carlsbad Planning Department 1200 Elm Avenue Carlsbad, California 92008 Attention: . Mr. Jim Hagaman, Planning Director Gentlemen: Subject: Proposed Amendment to Encina Specific Plan (SP-144B) SDG&E does hereby make application for modifications to Ordinance Number 9456 in order to achieve the following desired results: 1. Use of the t:i.ll single 3tack to receive the exhaust gases from Encina Units 4, 3, 2 and 1, in that order, commencing in March, 1978. 2. Use of the tall single stack to receive the exhaust • gases from Encina Unit 5, commencing in April, 1978, in order to test Unit 5. This request is supported by the following facts and circumstances. BACKGROUND . Encina Unit 5 was approved by the City of Carlsbad in 1971 by Ordinance 9279 which adopted Specific Plan 144 to allow the installation of Unit 5. On May 4, 1976, the City of Carlsbad approved an amend- ment to the specific plan by the adoption of Ordinance 9456 to allow a height variance to accommodate the installation of the tall stack which would receive the exhaust gases from Encina Units 1, 2, 3, 4 and 5. Concurrent with that proceeding the APCO for the County of San Diego brought an abatement action against SDG&E to bring abgut the control of an acid fallout condition which was being experienced in connection with the 'operation of Units 1-4. AN INVESTOR OWNFO COftPOHA TION Jim Hagaman ' -2- December 22, 1977 Because these separate events were occurring at the same time the City Council of Carlsbad responded to public input by imposing conditions upon the height variance process which related to the acid fallout condition. It is those conditions from which SDG&E seeks relief. The conditions do not relate directly to the subject matter which was before the Council for approval and it will be recalled that the city staff argued against the imposition of these conditions because of their doubtful enforceability. They were imposed in response to an expression of, public concern. . The Planning Commission in approving the SP Amendments had included in it's Resolution Number 1224 a provision which would have allowed the City Council to extend the time limit for.compliance past the final building permit clearance for Unit 5 and the stack, but this was not incorporated into Ordinance 9456. OTHER OPTIONS These conditions are by no means the only remedies which were available to respond to that public concern. Additional remedies which were then and still are available include the following: Citizen Action At least four independent remedies were then and still are available to the citizens of Carlsbad who experience property damage resulting from the acid fallout. (a) Settlement of claims with SDG&E. (b) Lawsuit for the damage to property. (c) Lawsuit for inverse condemnation of citizens' property rights. (d) Lawsuit to abate a private nuisance. Carlsbad Action The City of Carlsbad, independent of the conditions in the Ordinance had and still has the option of bringing an action to. abate a public nuisance. APCO Action The Air Pollution Control Officer had the option, which it exercised, to seek an abatement order pursuant to Rule 51. This abatement order can be backed up with an enforcement action by the County of San Diego for injunctive relief or civil penalties. -3- Based on this review of other options available to remedy the fallout problem we can place the conditions imposed by the City in their true perspective. It is apparent that even if the City Council had chosen not to impose any conditions on the use of the stack in Ordinance 9456, the citizens of Carlsbad, the City of Carlsbad, the APCD and the ARE all would have, and still do retain their independent remedies against SDG&E, SDG&E'S ATTEMPT TO CLARIFY COUNCILS INTENT On November 22, 1977, SDG&E requested the City Council to clarify the Council's intent with respect to the language contained in Ordinance 9456 and expressed our desire to use the stack (i) to receive the exhaust gases from Units 4,3, 2 and 1, in that order; and (ii) to further use the stack to receive the exhaust gases from Unit 5 in order to test Unit 5 prior to the final building permit clearance of that Unit, currently scheduled to occur in October 1978. On November 29, 1977 the City Attorney rendered an opinion to the City Council that the clarification sought by SDG&E could only be achieved through public hearings and amendments to the Ordinance. A copy of that opinion is attached and incorporated herein by reference. The Council "filed" the request from SDG&E leaving SDG&E the flexibility to adopt whatever course of action it deemed appropriate. SDG&E'S OPTIONS Three separate courses of action appear to be available to SDG&E. q 1. Seek a judicial interpretation of the enforceability of the conditions contained in Ordinance 9456; 2. Seek modifications to Ordinance 9456 which would, if approved, achieve the desired results; or 3. Initiate no action and'wait for the APCO and the City Council to express that the fallout problem has been controlled to their satisfaction. The third alternative is the preferred alternative from SDG&E's point of view. However, pursuit of that alternative alone is not without risks which involve (i) our ability to deliver an adequate and reliable supply of energy to SDG&E's customers, (ii) substantial economic detriment to SDG&E's rate payers, and (iii) postponement of (postponing) the implementation of beneficial air quality measures. Should the preferred alternative, for any reason, not occur within the anticipated time frame (January 1978) then the time available to process modifications to Ordinance 9456 becomes critically short before SDG&E would encounter delays in the schedule for transferring the exhaust gases from the -4- existing stacks to the new tall stack. While the probability of these delays occurring may 'be small, the consequences, should they occur, are substantial and severe. Therefore, SDG&E has elected to commence the process of seeking the modifications in order to receive a timely decision on the requested modifications should the preferred alternative for any reason be delayed. CONSEQUENCES OF SCHEDULE DELAY At the public hearing before the Planning Commission and the City Council, SDG&E would propose to present evidence on the consequences of delays in the scheduled use of the single stack to receive the exhaust gases from, Units 4, 3, 2, and 1 and to receive the exhaust gases from Unit 5 for testing purposes prior to its scheduled commercial operation in October of 1973. Energy Supply Encina 5 will be the largest most efficient generating unit on SDG&E's system. A delay in Unit 5 will place the burden of power generation on smaller, older, less efficient units. This sacrifice in efficiency will result in the burning of an additional 50,900 BBLs of fuel, oil per month. Reserve margins necessary to supply adequate amounts of power will be jeopardized. Both the use of the tall stack and Encina 5 are scheduled ahead of peak generating periods. Any delay in the schedule will cause capacity shortages on SDG&E's system and require the purchase of costly off-system power. Operating and Maintenance Major overhauls are scheduled for equipment during the tall stack tie-in construction period. Other major over- hauls are scheduled following the commercial operation of Unit 5. Delays in these overhauls could effect system relia- bility as well .as increase maintenance and overhaul expenses when the work is eventually performed. Air Quality . The overall air quality in the Carlsbad area will be improved by the use of the tall stack. There is substantial testimony and documentation on record, to show that the use of the stack will improve air quality. The San Diego Air Pollution Control Officer, Mr. Bill Simmons has confirmed that dispersion transport of the single plume dischared at 400 ft. elevation by the tall stack will reduce ground level concentrations of both particulate matter and aerosols, he further strongly incourages the use of the tall stack as soon as possible. Overall San Diego basin air quality will be improved by utilizing Encina 5 as scheduled as the 50,900 BBLs per month fuel savings will result in a commensurate reduction of overall power plant emissions. -5- Impact on Rate Payers Increased costs attributable to inadequate reserve margins, off system purchase power, delayed scheduling of maintenance and use of less efficient generating units all contribute to the electric rates paid by each ratepayer. The incremental cost of the 50,900 BBLs of fuel oil alone is estimated to be $942,000 per month based upon an average price of residual oil in 1979 of $18.50/BBL. Interest during construction, a continuing cost until the equipment is declared commercial, amounts to $52,000 per mo. for the stack, and $617.000 per mo. for Unit 5. These costs would ultimately be borne by the ratepayer. CITY'S ABILITY TO ENFORCE CONTROL OF THE FALLOUT PROBLEM If this request goes to public hearing it will be because either the APCO or the City Council was unable to indicate that the fallout problem has been controlled to their satisfaction. It seems obvious under that assumption that prior to granting the relief requested that the City would desire to preserve a mechanism which maintains some leverage over SDG&E to control the fallout problem to the council's satisfaction. We believe that the leverage sought to be imposed through the conditions contained in Ordinance 9456 can be ratained by the City through the imposition of conditions relating exclusively to controlling the fallout problem prior to the commercial operation of Unit 5. Thus, the City can retain its control over the resolution of the fallout problem and at che same time avoid the enormous consequences assiciated with the conditions which were, in the opinion of the City Attorney, imposed on the use of the stack as well. To the extent that any of these conditions are legally enforceable, they could apply to Unit 5 rather than to the stack without jeopardizing the control measures sought to be imposed by the City. . ADDITIONAL CONDITIONS In addition to the many remedies cited in the background section above, the City could impose the additional condition of requiring SDG&E to continue to pay all valid property damage claims resulting from the fallout problem, should they occur, after the relief sought herein had been granted. The enforce- ment of this condition could easily be achieved by the City through it's ability to" control the ultimate commercial operation of Encina 5. . ENVIRONMENTAL ASSESSMENT SDG&E further requests a finding that there has been no change in circumstances requiring any additional environ- mental reviews over and above the environmental impact statement already approved and accepted in this proceeding. -6- WHEREFORE, SDG&E requests the following relief: • 1. A finding that additional, environmental reviews are not necessary; 2. That Ordinance 9456 be amended to allow SDG&E to use the tall stack to reveive the exhaust gases from , Units 4, 3, 2 and 1, in that order, commencing in March of 1978; 3. That Ordinance 0456 be amended to allow SDG&E to use the tall stack to receive the exhausts gases from Unit 5, commencing in April of 1978 in order to test Unit 5; and 4. That Ordinance 9456 be amended to impose as a condition precedent to the commercial operation of E-5 that the fallout problem be controlled to the satisfaction of the APCO and the City Council. We submit this application in anticipation that it will be considered during the January 25, 1977 Planning Commission Regular Meeting. If we can answer any questions please do not hesitate to call Mr. Jay Shepard at 232-4252, extension 1504. •Sincerely, Vx I. Dudley Land Planning Supervisor FMD:dr cc: Paul D. Bussey, City Manager City of Carlsbad San Diego Gas Sa. Electric December 10, 1979 SFH 100 4-f XCNB 100 Mr. Bill Baldwin . Assistant City Manager City of Carlsbad, City Hall 1200 Elm Avenue Carlsbad, CA 92008 Dear Mr. Baldwin: With this letter, SDG&E submits to the Carlsbad City Council its third annual report regarding emission reductions and operating improvements at Encina Power Plant. Ordinance No. 9456, Section 3(J), dated May 4, 1976, requires that SDG&E file an annual report with the City Council regarding improvements in plant and operating procedures during the preceding year which reduce the emission of air pollutants resulting from the operation of Encina Units 1, 2, 3, and 4. Once you have had an opportunity to review this report, I would like to schedule a meeting with you to review the document and to discuss future annual reports to the, Council. I will contact you by December 17, 1979, to set up a meeting. Sincerely, Robert P. Meinzer, Jr. Senior Engineer Licensing &'Environmental Dept. RPM:mdm Enclosure cc: G. A. Bishop J. M. Burns C. E. Gibson POST OFFICE BOX 1831-SAN DIEGO. CALIFORNIA 92112 • TELEPHONE 714/232-425? THIRD ANNUAL REPORT TO THE CARLSBAD CITY COUNCIL REGARDING EMISSION REDUCTION AND OPERATING IMPROVEMENTS AT ENCINA POWER PLANT San Diego Gas & Electric November, 1979 In compliance with City of Carlsbad Ordinance 9456, Section 3, "14(J)/" San Diego Gas & Electric is submitting this third annual report to the Carlsbad City Council. This report will describe work done in the past year that has resulted in an increase in power plant efficiency, thereby reducing air pollutants from Encina.Units 1, 2, 3, 4, and 5. I. INCREASED CONSUMPTION OF NATURAL GAS Due to an increase in availability of natural gas for industrial use, Encina Power Plant consumed more gas in 1979 for its operation than it did the previous year. By burning more gas and less oil, amounts of oxides of nitrogen emissions and smoke emissions are.reduced. The added quantities of natural gas that were available in 1979 were unforeseen. Availability of similar quantities of gas in the future is similarly uncertain. ) ' II. ENCINA UNIT 4 - MAJOR TURBINE OVERHAUL From March through June, 1979, Unit 4 underwent a major turbine overhaul. During a major overhaul, the entire turbine is dismantled, useable parts are cleaned and worn parts replaced or repaired. In the case of Unit 4, 280 blades in the low pressure area of the turbine were replaced. Once these replacements were made, the turbine was reassembled and put back in operation. The goal of a major turbine overhaul is to return the turbine efficiency to as close to design level as possible and. to insure reliable operation for the next four years. These types of overhauls are normally done every four years. III. BOILER OVERHAULS - ENCINA UNITS 1-5 In the last year, boiler overhauls were accomplished on all five boilers at Encina. 'Encina Unit I - January, 1979 Encina Unit II - late July, 1979 Encina Unit III - early July, 1979 Encina Unit IV - June, 1979 Encina Unit V - May, 1979 On Units 2 and 3, the air heater elements were replaced in each unit's regenerative air heater. The regenerative air heater removes heat from the exhaust gas and transmits it to the air going into the boiler for combustion. By replacing the elements, this transmission of heat is more efficient, resulting in a reduction of fuel consumption and ultimately a reduction in emissions. By cleaning and repairing burners, air registers, heat transfer surfaces, and structural components, air leakage in or out of the boilers is minimized. In this way, boiler efficiency is returned to design conditions. IV. REPLACEMENT OF CIRCULATING WATER (CW) PUMPS - ENCINA UNITS 1, 2, & 3 During the last year, the circulating water pumps on Encina Units 1, 2, and-3 were replaced. By operating more efficient pumps, more water can be run through the steam condenser, causing the turbine to be more efficient. In this way, fuel consumption is reduced, thus emissions are reduced. -2- V. MODIFICATIONS OF ENCINA UNITS- 4 & 5 CIRCULATING WATER PUMPS The impellers of the circulating water pumps were trimmed to optimize their operation. By doing this, the i pumps now circulate water through the condenser using less power, thus requiring less fuel oil to generate power to run them. The end result is lower quantities of emissions. VI. DUAL FUEL COMBUSTION IN ENCINA UNIT 4 BOILER Since June 19, 1979, dual fuel (a combination of natural gas and fuel oil) has been burned in Encina Unit 4. The natural gas was made available by an increased availability for industrial use. Boiler emissions, especially oxides of nitrogen, are reduced by burning dual fuel. VII. ELECTRIC PRODUCTION PERFORMANCE MONITORING PROGRAM As was described in the' 1977 Annual Report, the Electric Production Performance Monitoring Program is being "continued. The goal is to improve plant efficiency and cut fuel oil consumption. The method by which the Performance Program is accomplished is the monitoring of performance for each unit " so that it can be operated at its most efficient level under various loading conditions. This increased efficiency leads to reduced oil consumption and corresponding emission reduction. Operators make hourly comparisons of actual unit performance to the best attainable standards and then take corrective action when appropriate. The operator can either adjust the control setting of the unit or request that maintenance be performed. -3- VIII, CONTROL OF ACIDIC FALLOUT Acidic fallout from the Encina Power Plant is controlled by three methods: 1. Introduction of a fuel oil additive to neutralize acidic fallout that is created during boiler combustion. 2. Soot blowing in the boiler is done on a regular basis to reduce build up of material on walls of the boiler. 3. Use of viscosity controllers increase the breakup of oil fuel into very fine particles for more complete combustion of the fuel. IX. REDUCTION OF AUXILIARY PLANT LOAD Encina Power Plant has been able, in the last year, to reduce the amount of energy required to operate the 'electrically-powered equipment. By changing lighting in specific areas of the plant from incandescent to high pressure sodium" vapor lights, a reduction in those areas of lighting energy requirements by half has been accomplished. -4- SAN DIEGO GAS & ELECTRIC COMPANY P.O. BOX 1831 SAN DIEGO. CALIFORNIA 92112 (714) 232-4252 MUG 010 May 16, 1977 1977 Ci" "*' ("•' •-J 1 ; l_ • • Mr. James Hagaman Director of Planning City of Carlsbad 1200 Elm Avenue Carlsbad, California 92008 Dear Mr. Hagaman: Reference is made to City Ordinance No. 9^56 amending Ordinance No. 9279 by permitting construction of the 400 foot stack and removal of existing stacks at our Encina power plant. Condition l4(C) of this ordinance reads as follows: "Any mechanical and/or electrical equipment to be located on the roof of the structure shall be screened in a manner acceptable to:'the Planning Director. Detailed plans for said screening shall be submitted, in triplicate, to the Planning Director for approval . I wish to point out that during public hearings on Ordinance No. 9^56, the City Council reviewed the method of screening equipment atop the power plant as shown on the attached drawings. Additionally, before a building permit could be issued, City department heads were required to sign off the project. However, in order to fully comply with this condition, we are submitting three copies of aesthetic wall elevations for your review. In order that we may complete our records, we would appreciate your letter of approval. Thank you for your consideration. S'incerely, M. Dudley Land Planning Supervisor FMD:dr Attachment AN INVESTOR-OWNED CORPORATION WILLIAM SIMMONS Air Pollution Control O«icer A I/ ue C COUNTY OF SAN DIEGO 9150 Chesapeake Dnve San Diego, Calif. 92173 (714) 565-5901 (MS 01 78! January 6, 1977 Mr. Bud Plender Director of Planning (Acting) City of Carlsbad 1200 Elm Avenue Carlsbad, CA 92008 Dear Mr. Plender: Re: Source Monitoring Encina "5", Previous Communication December 24, 1976. In my previous communication, I inadvertently omitted a list of equipment to be installed and operated by the District at each of the proposed monitoring sites. The equipment 'listed in the enclosed table is considered "state of the art" and satisfies all state and federal requirements for equivalency with established reference methods. If you have any questions on the equipment selection, siting or measurement techniques, please refer them to Michael Foley at'565-3947 Sincerely, WILLIAM SIMMONS Air Pollution Control Officer WS:MIF:ba Attach. JAN 11 1077 •CITY OF cPlanning 0 ENCINA 5 MONITORING EQUIPMENT LIST Description Analyzer, Nitric Oxide Nitrogen Dioxide Total Oxides of Nitrogen Analyzer, Sulfur Dioxide Col lector, Total Participates Recorder Calibrator, Sulfur Dioxide Nitrogen Dioxide Manufacturer/Model Thermo Electron/146 Data Acquistion System 4-channel computer operated remote terminal (CORT) Thermo Electron/43 General Metals/2000 Bristol/12PH552 Monitor Labs/8500 .Newport Tech./NT 1016 Method Chemiluminescent Pulsed Fluorescent High Volume Multi-point Permeation Tube * Analog to Digital MENlOiRANIDyM February 15, 1977 TO: CITY COUNCIL FROM: PLANNING DEPARTMENT SUBJECT: AIR QUALITY MONITORING EQUIPMENT PER THE REQUIREMENTS OF ORDINANCE NO. 9456 (ENCINA POWER PLANT STACK MODIFICATION) BACKGROUND: 'City Council Ordinance No. 9456 (see attached excerpt) requires that San Diego Gas and Electric install air quality monitoring equipment as a condition of approval for the Encina Power Plant stack modification. The condition states that the type and loca- tion of the equipment is subject to the approval of the Air Pollution Control Officer and the.City Council. The equi pment":was - to be operative six months after the effective date of the Ordinance (July 20, 1976). The six-month deadline has not been met because of the time involved in selecting equipment, surveying potential sites and gaining property owner permission for use of those sites. Staff would like to point out that these delays in no way reflect a lack of diligence on the part of the applicant.' MONITORING SITES: San Diego Gas and Electric has secured property for installation of monitoring stations at these three sites recommended by the ; APCD (see Exhibit B): Ii Site #1 : is at a reservoir site located on SDG&E property southeast ' of the proposed HUB Park. The site is at an approximate elevation ; of 200 feet. You will note that in a letter to the City dated i December 24, 1976, the APCD had recommended that Site #1 be located | at Evans Point (see Exhibit B); however, this site could not be \ secured, so the APCD has recommended- the reservoir location I instead. APCD officials believe that this location is suitable < •for measuring the localized impact of the power plant. \ j Sj_te__#2_: 'is located within the Oceanside City limits on San | Francisco Peak, adjacent to -a water -.tank. This site is approximately 4.8 miles northeast of the Encina Plant. According to the Air Pollution Control District, this general area is pro- : jected to be the1 location- of'maximum impact of pollutants emitted [ from the modified facility under 'worst case1 meteorological condi- | tions. This site is at an elevation of approximately 540 feet. •' i _Sj_t_e_#3_: is located at another water tank site near the intersection FFTiTcTnitas Road (extension of Palomar Airport Road) and Rancho Santa Fe Road, in the unincorporated area midway between Carlsbad's and San Marcos' City boundaries. This site is about 7.1 miles east of the power plant, at an elevation of 700 feet. The APCD's pro- jections indicate that, because of prevailing wind conditions and. distance downwind from the plant, this area will experience the most predominant impact from the expanded power plant.. It should be noted that the APCD has recommended monitoring sites which would record maximum impacts resulting from the Power Plant's operation. Since the monitoring sites were required to specifically measure emissions from the Encina Power Plant, loca- tion of the monitoring stations in lesser impact areas would be counterproductive. The installation of the equipment prior to utilization of Unit 5 and of the single stack will enable the APCD to verify the air quality projections which have been made. MO N IlPJjIN G .JLQ U I P_M E N T : The APCD has provided a list of equipment proposed for installation at each of the monitoring sites. (See Exhibit A.) This equipment will be capable of monitoring all significant pollutants emitted by the Power Plant. As noted in the APCD's letter, all equipment is "state of the art" and satisfies state and federal monitoring requi rements. EQUIPMENT COSTS: The equipment costs have been secured from San Diego Gas and Electric, and are within the limits set by- Ordinance No. 9456. IMPLEMENTATION: The APCD has indicated that monitoring at sites #2 and #3 can be operative by mid-February, and Site #1 can be operative shortly thereafter. RECOMMENDATION; That the City Council concur with the APCD's recommendations for air quality monitoring sites and equipment, as required by " . Condition 14(D) of Ordinance No. 9456. ATTACHMENTS: Excerpt fr. Ord. 9456 Exhibit A Exhibit B DHW.-cpl (2/8/77) MEI^ORANIDUIM . February 15, 1977 TO: CITY COUNCIL FROM.: PLANNING DEPARTMENT SUBJECT: AIR QUALITY MONITORING EQUIPMENT PER THE REQUIREMENTS OF ORDINANCE NO. 9456 (ENCINA POWER PLANT STACK MODIFICATION) BACKGROUND: 'City Council Ordinance No. 9456 (see attached excerpt) requires that San Diego Gas and Electric install air quality monitoring equipment as a condition of approval for the Encina Power Plant stack modification. The condition states that the type and loca- tion of the equipment is subject to the approval of the Air Pollution Control Officer and the City Council. The equi pmer.t';was : to be operative six months after the effective date of the Ordinance (July 2Q, 1976). The six-month deadline has not been met because of the time involved in selecting equipment, surveying potential sites and gaining property owner permission for use of those sites. Staff would like to point out that these delays in no way reflect a lack of diligence on the part of the applicant. San Diego Gas and Electric has secured property for installatii of monitoring stations at these three sites recommended.by the A n r n I /-. <*. .-> r v, K 4 u -; 4- o \ . Si te_#J : is at a reservoir site located on SDG&E property southeast of the proposed' HUB Park. The site is at an approximate elevation of 200 feet. You will note that in a letter to the City dated December 24, 1976, the APCD had recommended that Site #1 be located at Evans Point (see Exhibit B); however, this site could not be secured, so the APCD has recommended the reservoir location instead. APCD-officials believe that this location is suitable for measuring the localized impact of the power plant. Site #2: 'is located within the Oceanside City limits on Sari Francisco Peak, adjacent to 'a water -.tank. This site is - . approximately 4.8 miles northeast of the Encina Plant. According to the Air Pollution Control District, this.general area is pro- jected to be the location of maximum impact of pollutants emitted from the modified facility under 'worst case1 meteorological condi- tions. This site is at an elevation of approximately 540 feet. B ^li§_jLl: is located at another .water tank site near the intersection, of Encinitas Road (extension of Palornar Airport Road) and Rancho Santa Fe Road, in the unincorporated area midway between Carlsbad's and San Marcos' City boundaries. This site is about 7.1. miles east of the power plant, at an elevation of 700 feet. The APCD's pro- jections indicate that, because of prevailing wind conditions and distance downwind from the plant, this area will experience the most predominant impact from the expanded power plant. It should be noted that th'e APCD has recommended monitoring sites which would record maximum impacts resulting from the Power Plant's operation. Since the monitoring sites were required to specifically measure emissions from the Encina Power Plant, loca- tion of the monitoring stations in lesser impact areas would be counterproductive. The installation of the equipment prior to utilization of Unit 5 and of the single stack will enable 4.he APCD to verify .the air quality projections which have been made. MONITORING EQUIPMENT: The APCD has provided a list of equipment proposed for installation at each of the monitoring sites. (See Exhibit A.) This equipment will be capable of monitoring all significant pollutants emitted by the Power Plant.. As noted in the APCD's letter, all equipment is "state of .the art" and satisfies state and federal monitoring requi rements. EQUIPMENT COSTS: . • The equipment costs have been secured from San Diego Gas and Electric, and are within the limits set by Ordinance No. 9456. .IMPLEMENTATION: The APCD has indicated that monitoring at sites #2 and #3 can be operative by mid-February, and Site #1 can be operative shortly thereafter. RECOMMENDATION: That the City Council concur with the APCD's recommendations for air quality monitoring sites and equipment, as required by " ' Condition 14(D) of Ordinance No. 9456. ATTACHMENTS: Excerpt fr. Ord. 9456 Exhibi t A Exhibit B DHW:cpl (2/8/77) n . 1200 ELM AVENUE CARLSBAD, CALIFORNIA 92008 TELEPHONE: (714)729-1181 November 19, 1975 Mr. Eel Gabriel son San Diego Gas and Electric P.O. Box 1831 San Diego, CA 92112 Ed: I wish to take this opportunity to relate the current status of SDG&E's application for an amendment to the Specific Plan for SDG&E's holdings (SP-144A), City Council Ordinance 9268. The Planning Department staff has completed the majority of the appli- cation's review to insure consistency with applicable sections of the Zoning; Specific Plan and Environmental Review Ordinances. City's However, prior to submitting the application documents to other affected departments and agencies for review, the City Manager and I wish to insure that all the necessary information on the proposed stack modifications and other related Specific Plan items are available. This is especially true in light of the recent complaints given to the San Diego County Air Pollution Control District regarding air pollution damage in the immediate vicinity of the Encina Plant.i The Staff therefore, is in the process of reviewing the EIR, certified by the City Council concurrent with the first Specific Plan Amendment for the information provided on air pollution. The staff is collecting additional data on the air pollution complaint to insure compliance with the Carlsbad Environmental Protection Ordinance so that, if necessary, the original EIR can be amended to include new air pollution and other pertinent data and then add the appropriate mitigation measures. In doing so, the stack' application information will be as complete as possible For the upcoming public hearings before the Planning Commission arid the City Council. To that end, I cannot outline a specific date for the Planning Commission Public Hearing, only to say that the staff will proceed as rapidly as possible to present the application at a Public Hearing. Any questions you may have please contact my office at your convenience. Sincerely, Donald A. Agatep PLANNING DIRECTOR DAA/vb cc: City Manager, Paul Bussey AIR POLLUTION CONTROL DISTRICT COUNTY OF SAN DIEGO WILLIAM SIMMONS 9150 Chesapeake Drive Air Pollution San DjegO( CaMf g2123 Control Officer (714) 565-5901 (MS 0176) December 24, 1976 Mr. Doug Plender Director of Planning (Acting) City of Carlsbad 1200 Elm Avenue Carlsbad, California 92008 .,.,•,*.• - --;..-• ••.-... Source Monitoring Encina "5", Carlsbad City Ordinance 9279 Dear Mr. Plender: As a condition of the Special Use Permit granted to San Diego Gas & Electric by the Carlsbad City Council for construction of a 400-foot stack at the Encina Power Plant, SDG&E was required to provide three monitoring stations downwind from the facility. The San Diego Air Pollution Control District has surveyed the area and selected sites appropriate for assessment of the air quality impact of the existing and proposed facilities (see map attached). These sites were selected based on area of projected maximum impact, exposure, and availability of the site and services. Site #1 is located at Evans Point on the property of Mr. Allan 0. Kelly. This site was selected primarily to determine the localized impact of the existing facility. The site is at an approximate elevation of 300 feet at a distance of 2.2 miles downwind with excellent exposure. Sjte #2 is located at San Francisco Peak approximately 4.8 miles northeast of the facility on local water district property. This general area is projected to be the location of maximum impact of the pollutants emitted from the modified facility under "worst case" meteorological conditions. Svte_#3_ is located approximately 7.1 miles east of the power plant in the vicinity of Encinitas Road and Rancho Santa Fe Boulevard on the western edge of San Marcos and at an elevation of 700 feet. Projections indicate that this area will experience the most predominant impact from the new facility due to the prevailing westerly wind and distance downwind. RECEIVED JAN 31977 CITY OF CARLSBAD Banning Department Mr. Doug Plender City of Carlsbad -2- December 24, 1976 San Diego Gas & Electric has been notified of the District's site preferences and has initiated an investigation into securing these sites if approved by the Carlsbad City Council. If you have any questions or desire any further information, please contact Michael Foley at 565-3947. Sincerely, WILLIAM SIMMONS Air Pollution Control Officer WS:MIF:dh Attachment cc: Ash Barnes (SDG&E) Dick Baldwin (APCD) •AIR POLLUTION CONTROL DISTRICT COUNTY OF SAN DIEGO WILLIAM SIMMONS 9150 Chesapeake Drive Air Pollution San Diego, Calif. 92123 Control Officer (714) 565-5901 (MS 01 76) January 6, 1977 Mr. Bud Plender Director of Planning (Acting) City of Carlsbad 1200 Elm Avenue Carlsbad, CA 92008 Dear Mr. Plender: Re: Source Monitoring Encina "5", Previous Communication December 24, 1976. In my previous communication, I inadvertently omitted a list of equipment to be installed and operated by the District at each of the proposed monitoring sites. The equipment listed in the enclosed table is considered "state of the art" and satisfies all state and federal requirements for equivalency with established reference methods. If you have any questions on the equipment selection, siting or measurement techniques, please refer them to Michael Foley at 565-3947 Sincerely, WILLIAM SIMMONS Air Pollution Control Officer WS:MIF:ba Attach. (SEE. JAM 1 1 ]Q7 CITY OF c Planning 0 AIR POLffijTION ft) COUNTY OF SAN DIEGO ^12#J> WILLIAM SIMMONS Air Pollution Control Officer 9150 Chesapeake Drive San Dii'90, Calif. 92123 (714) 565-5901 (MS 0176) November 10, 19 75 Mr. Paul Bussey City Manager 1200 Elm Ave. Carlsbad, CA 92008 Dear Mr. Bussey: Enclosed, as requested by your office, is a copy of the letter to the Coastal Zone Commission staff which outlines the District's planned in- vestigation at S.D.G.& E's Encina plant. Should you have any questions pertaining to this or any related matter please feel free to contact me. Sincere Iy, R!CHARD H. BALDWIN, Chief Division Surveillance & Enforcement RHB:wnm Enclosure 14 1973 MEMORANDUM. \ .. . \ . ••,'>"-. <'. t .' "' :- " i '., ^ •*' r- C". ; - '* October 23, 1975 V" • - • 1 ' • )"": \ . '".' '•• '' TO: ; PLANNING DIRECTOR ' \ FROM: DANA HI ELD [ j SUBJECT: CEQA REQUIREMENTS FOR SDG&E ENCINA POWER PLANT SPECIFIC "^ PLAN (SP-144) The sections of CEQA relevant to the recent application of SDG&E for re- newal of their Specific Plan Amendment (Stack Modification project) are: e (1) Lead Agency definition, principle and criteria - Sections 15030, 15064 and 15065 (2) Subsequent EIR - Section 15067 (3) Multiple and phased projects - Section 15069" (4) Ongoing project - Section 15070 (5) Public hearings'- Section 15165(e) Ihe following is an analysis ot the implications of these sections on the SDG&E application. LEAD AGENCY CRITERIA The lead agency is defined as the agency which has the principal responsibility for preparing environmental documents and carrying out or approving a project (Sec. 15030). When a project is to be carried out or approved by more than one agency, it is to be carried out. by the lead agency in consultation with all other affected agencies. All responsible agencies (that is, all other agencies which have discretionary control over the project.) are then required to consider the lead agency's EIR prior to acting on the project (Sec. 15064). The criteria for determining which agency is lead agency are: (1) If the project is to be carried out by a public agency, that agency is the lead agency. (2) If the project is to be carried out by a private person or entity, the lead agency is the public agency which as the greatest responsibility for approving or supervising the project as a whole. The lead agency is generally the agency with general governmental powers, as opposed to a single or limited purpose agency; (3) Where more than one agency meets the above criteria, the lead agency shall be the agency to act first on the project. (Sec. 15065) The Office of Planning and Research arbitrates lead agency dis- putes in the event that two or more agencies have an equal claim to be lead agency (Sec. 15065.5). SUBSEQUENT EIR: When an EIR has been certified for a project, no new EIR is required unless:i (1) Substantial changes are proposed to the project; (2) Substantial changes in the circumstances under which the project is to be undertaken have occurred. ^> MULTIPLE AND PHASED PROJECTS: When individual projects or a phased project is to be undertaken, the Lead Agency must prepare a single EIR for the ultimate project. Where the individual project is a necessary precedent for a larger project or commits the Lead Agency to a larger jrroject tne EIR must address itself to the scope of the larger project. (Sec. 15069)• ONGOING PROJECT: A project where permit or other entitlement was issued priur to April 5, 1973 shall not require an EIR or negative declaration, sub- ject to the following provision: Where a project involving issuance of a permit or other< entitlement has been granted discretionary governmental approval for a part of the project before April 5, .1973 and additional discretionary approval after that date, an EIR or negative declaration shall be required only if the subsequent approval(s) involve a greater degree of responsibility or control over the project as a whole. (Sec. 15070) PUBLIC HEARING: There is no requirement for a public hearing in connection with review of an EIR prepared by another agency. There are a number of policy questions which need to be answered in deter- mining .EIR requirements for this project. First and foremost is the lead agency question: (1) The CPUC acted as lead agency for Encina Unit #5, and ,yet the City acted as lead agency for the stack modification. Should the City assume the role of "responsible agency" and consider only that EIR certified by the CPUC? (2) Was the City in error by not certifying an EIR for the total pro- - ject in 1973 when the stack modification was approved? If so, would it be proper for the City to certify an EIR for the total project (according to the multiple/phased project criteria! with the present application? (3) Has the criterion of "ongoing project" been invalidated because of the stack modification proposal? (Note: An EIR may be re- quired for a project approved prior to CEQA if a subsequent discretionary approval for portion of that project involves a greater degree of "responsibility or control" over the project.) -2- (4) Has the project changed - either with respect to the project it- self or to the circumstances under which it is to be executed - since the time that the Unit 5 and stack modification EIR's were certified by the CPUC and City? ,(5) If it is determined that the City is "responsible agency" for1 the project, should the certified CPUC EIR be subject to draft EIR review and public hearings at the local level? 'I see a lot of shades of grey in the determination which must be made. A conservative determination could be made to reconsider only the previously certified stack modification EIR. CEQA requires only that the public agency consider the EIR - draft EIR review and public hearings are not required. The problem with this determination is that it violates the principle of examining a project en toto. My professional inclination (and I think it is justifiable legally also) is that a new EIR considering the total project should be required. Section 15069 states that for a multi-faceted project, all aspects and implications of that project must be examined in the EIR. Neither of the two previous EIR's do this. The "ongoing project" argument (i.e., the contention that the original Specific Plan is totally exempted by CEQA) can be countered in two ways. First, the stack modification approval does involve a greater degree of control over the project (see Sec 15070). Secondly, the new application constitutes reopening of the Specific Plan. Should the City Choose to clean up the original Specific Plan, changes in that approval could also involve a greater degree of control over the project. In summary, CEQA provides a general framework from which to determine EIR requirements, but the guidelines are not definitive in this instance. A policy decision is necessary to determine which CEQA criteria are most closely related to the present project and what course of action will most adequately serve the City's decision making needs. Dana Hi eld ASSISTANT PLANNER H/vb -3- v i' rz. o NJ M £ ^ r A u 9 ^ A L. i TV A cr (c) •-..Where an agen^? having jurisdiction byT^w ,-nust exercjuse discretionary authority over a project in order for the project to proceed, it is also a respons ible agency, see Section 15039, .1.3 or the Lead Agency, see Section 15030. 1:,0"HO. i Lead Agency. Lead Agency means the public • agency v;h.iob has ' the principal responsibility for preparing environmental documents and for carrying out or approving a project which may have a significant effect on the environment. .T.-.O.-j} . !.ocal Agency. Local agency rr.eans any public agency other ]Thari a sTate agency,.board'or commission. Local-agency . "Jv i nc.liide-c bur, Is not Mrr.J'ted to cities, counties, charter cities and counties, d-; r.i ricts , school districts, specia] district, redevelopment agencies and any board, commission, •JT organizational r.uL-d.i vi oion of a local agency v:hen so urs.Jgnated r.-y order or resolution of the governing 3 (-.? \ siati ve body oi' the Ir.cai rgency. / 115064. Lead Agency Principle. Where a project is to be carried ' out or approved~By more than one-public agency only one public agency shall be responsible for preparation of environmental documents and it will be the Lead Agency. Such environmental documents will be prepared by the Lead Agency in consultation with all other responsible agencies. The Lead Agency's environmental documents shall be the environmental documentation for all responsible agencies. Such.responsible agencies shall consider the Lead Agency's EIR or negative declaration prior to acting upon or approving the projects,- and they shall certify that their decision-making bodies have reviewed and considered the information contained in them. Ljead^Agency Criteria. . (a) If the project is to be carried out by a public agency, the Lead Agency shall be the public agency which - proposes to carry out the project. (b) If the project is to be carried out by a nongovernmental person, the Lead Agency shall be the public agency with the greatest responsibility for supervising or ( approving the project as a whole. The Lead - Agency will generally be the agency with general governmental powers rather than an agency with a single or limited purpose which is involved by reason of the need to provide a public service or public utility to the project; in such cases, the single or limited purpose agency will, upon request, provide data concerning all aspects of its activities required to furnish service to the project to the agency drafting the EIR, and no separate EIR will be required in regard to such activities. Where more than one public agency equally meet th^ criteria set forth In pA -raph b above, W-- agency which la to acW.rst on the project in question shall be the Lead Agency (following the principle that the environmental impact ohould be assessed as early as possible in governmental planning) Where the provisions of subsections (a), (b) , . '} and (c) leave two or more public agencies with an equal claim to be- the Lead Agency, the public agencies may by agreement designate which agency will be the Lead Agency. r—• 30067. f Subsequent EIR. Where an EIR has been prepared, no £ic[9i£16nal ElR need be prepared unless: (a) Substantial changes are proposed in the project which will require major revisions of the EIR, due to the Involvement of new environmental impacts not considered in a previous EIR on the project; (b) There are substantial changes with respect to the ;. circumstances under which the project is to be undertaken, such as a change in 'the proposed loca- ' tion of.the project,'which will require major revisions in the EIR due to the involvement of new environmental impacts not covered in a previous EIR. ,;.\:-;;..-.^••-.'-,.;,, - ;:.1I30G8. Use of• a Sin91 e ' EIR. . The Lead rAgency may employ a•- ::-~%--^ single EIR to describe more than on.e project, if such projects are : essentially the same in -terms of 'environmental impact. Further, the Lead Agency may use an earlier EIR prepared in connection with an earlier project to apply to a later project, if the circumstances of the projects are essentially the same. Lead Agencies may elect to write EIR's in advance for entire programs or regulations, in order to be prepared for project applications to come. Whenever an agency chooses to utilize any of these alternatives, however, it , must find that the environmental effects of the projects are similar .enough to warrant the same .'treatment in ah Elfc and that the EIR will' . adequately cover the impacts of any single project. If these tests are not met, an agency should supplement the EIR it prepares for a. program to apply it to an individ'uaT project. Multiple and Phased Projects. Where individual projects "are7~or a phased"project is, to be undertaken and where the total undertaking comprises a project with significant environmental effect, the Lead Agency must prepare a single EIR for the ultimate project. Where an individual project IB a necessary precedent for action on a larger project, or commite the Lead Agency to a larger project, with Bignlflcant environmental effect, an EIR must address itself to the scope of the larger project. Where one project io on* of several similar projects of a public agency, but 10 not deemed a .part of a larger undertaking or a larger project, the agency may prepare one EIR for all 15070. , nnn-r^^n- Py^^>+ (a) A project as |fe.jLried in Section r5037(tT) P^T~of theee Guidelines, approved prior to November 23j 1970, shall require an Environmental Impact Report or a Negative Declaration if the project may ;have a significant effect on the environment, and either of the following conditions exists: . I (l) A substantial portion of public funds allocated for the project have not been spent and it is still feasible to modify the project to mitigate . potentially adverse environmental effects, or . • . to choose feasible alternatives to the project, -. •' including the alternative of "no project" or . halting the project; provided that this .''••» ' Section (1) shall not apply to projects which coma under the jurisdiction of the National Environmental Policy Act (HEPA) and which, through regulations promulgated under liEPA, were held to be too far advanced at the time of 'NEPA's effective date to require an EIS in corn- , ipliance with those regulations. (2) ; A public agency proposes to modify the project in such a way that the -project might have a new 1 significant effect on the environment. ' 1• • . . - (b) A project as defined in Section 15037 (a) (3) or. in Section 15037 (G-) (2) as it relates to contracts, where the parzr.it or other entitlement was issued, or the contract approved, prior to April 5, 1973, shall not require an EIR or Negative Declaration, .subject to the following provisions: (1) CEQA expressly does not prohibit a public agency from considering environmental factors in connec- tion with the approval or disapproval of a project, or from imposing reasonable fees on the appropriate private person or entity for pre- paring an environmental report. Local agencies tnay require environmental reports for projects covered by this paragraph pursuant to local ordinances during this Interim period. (2) Where the issuance or approval occurred prior 'to December 5* 1972, and prior to said date'the project was legally challenged for noncornpliance with CEQA, the project shall be bound by special rules set forth in Section 21^.70 of CEQA. (3) Where a project Involving the losuance of a lease, ' . permit, license, certificate or other entitlement to use has been granted & discretionary govern- mental approval for part of the project before T- 5> 1973, and another a^ additional discre- tlBPiary governmental appro vtBL after April 5, 1973> the project shall require an EIR or Neg- ative Declaration only if the approval or approvals after April'5, 1973, Involve a greater degree of responsibility or -control over the project as a whole than did the approval or approvals prior to that date. (c). Any EIR which has been completed or on which substantial work has been performed on or before February 15>197^> in compliance tjlth procedures of a public agency consistent with CEQA and these Guidelines as adopted -on February 3, 1973, shall be / de&med to be in compliance with these Guidelines. 1 No further EIR shall be required except as provided in Subsections (a) and (b). a fei There is no requirement for a public agency to conduct a public hearing- in connection with its review of an EIR prepared by another public agency. 1200 ELM AVENUE ffl JifF. H TELEPHONE: CARLSBAD, CALIFORNIA 92008 W^&MwB (714)729-1181 Citp of Carteimb April 22, 1976 Mr. Richard Baldwin Enforcement & Surveillance Division Chief SAN DIEGO COUNTY AIR POLLUTION CONTROL DIST. 9150 Chesapeake Drive San Diego, California 92123 Subject: Encina Power Plant Single Stack Hearings Dear Dick: Thank you again for your technical assistance, consultation and long hours of testimony in regard to the SDG&E Encina single stack hearings. This entire project has been an education for all involved - staff, decision makers and citizens alike. Your assistance in researching the particu- late fallout problem, "educating" staff and spending long hours meeting with Planning Commissioners and Council members has been greatly appreciated. Sincerely, Donald A. Agatep \l " \ S* Dana Hl'eld Planning Director \ Assistant Planner DAA:SDH:mdp cc: William Simmons Air Pollution Control Officer 1200 ELM AVENUE g /W^. H TELEPHONE: CARLSBAD, CALIFORNIA 92008 Hc^LW vJf (714)729-1181 Cttp of Cartebab April 22, 1976 Mr. Michael Foley Monitoring & Technical Services Div. Chief SAN DIEGO COUNTY AIR POLLUTION CONTROL DIST. 9150 Chesapeake Drive San Diego, California 92123 Subject: Encina Power Plant Single Stack Hearings Dear Mike: We really appreciated your attendance at. the recent Planning Commission and City Council hearings on the Encina Power Plant single stack project. Your ability to explain air quality considerations in concise, understandable terms is a special talent. Your assistance has been invaluable to us in this endeavor. Sincerely, DonaTd A. Agatep \ ^ S. Dana Hield Planning Director \j Assistant Planner DAA:SDH:mdp cc : Wi11iam Simmons Air Pollution Control Officer