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Enron Mail |
Jeff
Could you please review this. PG&E is using our indecision on whether or not to carry their work on our CEQA filing, to hold up the Detailed Study. Thanks Rob Cone Project Manager Enron Energy Services 12647 Alcosta Blvd., Suite 500 San Ramon, CA 94583 Ph:925.543.3701, Fax:925.543.3550 Pager:888.397.5826 -----Original Message----- From: "Kinert, Robert" <RCK3@pge.com<@ENRON@EES Sent: Wednesday, December 15, 1999 10:52 PM To: "'Dick Smith'" <dicks@csufresno.edu<@ENRON@EES; Cone, Rob Cc: "Fantz, Donald" <DIF1@pge.com<@ENRON@EES; "Hagen, John H" <JHH4@pge.com<@ENRON@EES; "Colicchia, Rocco" <RJC9@pge.com<@ENRON@EES; "Raymond, Galen" <GLR3@pge.com<@ENRON@EES Subject: URGENT- CSUF Interconnection Study and CEQA Dick and Rob: Clearly, all of us at PG&E, CSUF and Enron want the Detailed Interconnection Study for CSUF finalized and released as soon as possible. Given your project's time line it is important for us to avoid any unnecessary delays. There are several critical path issues related to CEQA that urgently need to be resolved. In particular, we were very concerned to learn a few days ago from Enron that CSUF has not made a decision about including our interconnection work in its CEQA process. That decision has a very substantial impact on our work, and in particular jeopardizes our ability to even begin our work by October 2000, much less complete it by then. From the outset of this project we have indicated we were assuming CSUF would include PG&E's portion of the work in your CEQA filings. As we explained back in February, doing so greatly reduces both the time and cost to comply with General Order 131-D, which governs CPUC CEQA review of PG&E transmission projects. At our November 15, 1999 meeting we tried to reinforce the need to include PG&E's work in CSUF's CEQA process. While the CEQA issue has been an ongoing topic of discussion with this project, it may be helpful to summarize for you here. In brief, if the work to be performed by PG&E is included as part of the CEQA review of a larger project, under General Order 131-D the lead agency is responsible for conducting an environmental review to ensure that CEQA requirements are met, including assessment of the impacts of work to be performed by PG&E. Once that CEQA process is complete PG&E can request an exemption from the CPUC based on the environmental review completed by the lead agency. It usually only takes a few months for the CPUC to grant such an exemption. By contrast, if you do not include PG&E's work in your CEQA process, we would be required to file a PTC (Permit To Construct) with the CPUC. This process can take 12 to 18 months or more to complete, depending upon the complexity and protests of the project, would typically add $300,000 or more to the costs, and, most important, would preclude project completion by CSUF's desired date of October, 2000. I can not over emphasize the need to move forward on the CEQA issue. Even if the work performed by PG&E is included as part of CSUF's CEQA filing for the substation project and PG&E requests an exemption from the CPUC as discussed above, the time frame and outcomes for the CEQA process are uncertain because formal CPUC review and approval of our request for exemption is still required. Part of this CPUC review will require public notice of the project. If the exemption request is unchallenged, approval of the exemption will be granted within approximately 40 days of the filing. This is a best case estimate. If the exemption request is challenged by the public, the CPUC will evaluate the validity of the protest pursuant to G.O. 131D regulations. If the CPUC finds that PG&E has appropriately applied the exemption criteria to the project, then the CPUC will grant the exemption. However, should the exemption request be denied, the CPUC could subsequently direct PG&E to file for a Permit To Construct or provide the information or mitigation needed to resolve the public protest (including the possibility of requiring undergrounding of facilities, which as you know would be at CSUF's expense). As discussed above, the process of obtaining a Permit To Construct could take 12 - 18 months or more and substantially delay the project. As with the Informational Review provided last February, we are preparing our Detailed Interconnection Study with the understanding that CSUF will include PG&E's work in its CEQA process. If CSUF chooses to not include PG&E's work in its CEQA process, then PG&E would need to revise the study in terms of scope and costs before it can be finalized and released. We want to work with you to make this project a success but we need your help to do so. Please let us know how you would like to proceed. We are prepared to release the study, based on the understanding that CSUF will include PG&E's work in its CEQA process, within the next three to four business days. Sincerely, Bob Kinert
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