Pacific Gas and Electric Company's Notice of Intention to Seek Certification for the Combined Cycle Project. Final Report

摘要

The Committee recommends approval of Pacific Gas and Electric Company's (PG and E) Notice of Intention (NOI) for the combined cycle, but must frankly express serious doubts that the Applicant will be able to comply, during Application for Certification (AFC) proceedings, with air quality standards which comport with federal and state law. Evidence in the record shows that the project, with certain constraints, can meet the New Source Review Rule (NSR) of the Bay Area Air Pollution Control District (BAAPCD), which was the standard as of the date of filing. But the Committee chose to follow a more realistic investigation of the possibility of compliance with standards which would conform to the US Envionmental Protection Agency's (EPA) Interpretative Ruling of December, 1976. Only under a fortuitous set of regulations and events is it likely that compliance will be demonstrated. If the San Francisco Bay Area or if the vicinity of a proposed site is deemed not a non-attainment area for particulates, or if it is and trade-offs can be obtained through very diligent efforts; if ambient CO standards are being met through futher reduction of automotive pollution; and finally if NO/sub x/ offsets can be obtained through retrofitting existing PG and E facilities - a difficult task according to all parties; if all of these conditions prevail, then PG and E might demonstrate compliance. The Committee notes that it is the Staff's opinion that some of these tasks will be extremely difficult if not impossible to accomplish. The Committee recommends that the Commission approve the NOI and allow PG and E to make the decision whether or not to pursue an AFC. But for its own planning purposes, the Commission would be unwise to count on this poject. (ERA citation 05:000690)