Timing: Approval by CPUC monitor of archaeological mitigation program at least 30 business days prior to transfer of ownership of the Encina and South Bay Power Plants, and at the Division Substation and Naval Station CT facilities; review implementation reports upon submittal.

In October 1996, Enova Corporation, the parent company of SDG&E, and Pacific Enterprises, the parent company of Southern California Gas Company (SoCalGas), jointly announced a plan of merger an agreement to combine their companies.

The principal utility subsidiaries of Sempra Energy include Pacific Enterprises and Enova Corporation, which are the parent companies of utility subsidiaries SoCalGas and SDG&E, respectively, which will continue to operate as independent utilities.

Electric power needed to meet the demands of SDG&E’s service territory is either (a) imported through SDG&E’s two transmission power links (i.e., the Southwest Power Link, which transports power from Arizona and the southwest, and the South-of-SONGS Path, which transports power from the San Onofre Nuclear Generating Station [SONGS]) and other sources in California and the northwest, or (b) generated at SDG&E’s Encina and South Bay Power Plants.

In addition to SDG&E’s power generating assets, qualifying facilities (QFs) on connected to SDG&E’s system add an additional 174 MW of power.²

As described in Section 1, Introduction, a series of events (namely implementation of the plan of merger that created Sempra Energy as the new corporate parent of Enova Corporation and Pacific Enterprisesthe merger of Enova Corporation, the parent company of SDG&E, and Pacific Enterprises into Sempra Energy) since the divestiture application was originally filed have resulted in the CPUC ordering the sale of SDG&E’s natural gas-fired generation assets.

The new owner would be required to take an assignment of assigned SDG&E’s "must-run" contracts with the ISO to ensure the availability of these generating facilities.

The CPUC has discretionary approval authority over the general terms of the Asset Sale Agreement, the Operation and Maintenance (O&M) Agreement, and the Facilities Services Agreement, Bidding Contractand the auction process of each proposed sale.

If the Port District does not elect to purchase the South Bay Power Plant under the terms of its agreement with SDG&E by November 14, 1998details of the negotiated sale are not finalized by November 30, 1998, 60 days after the signing of the agreement, then the agreement between SDG&E and the Port District will terminate and SDG&E would recommence the auction of the South Bay Power Plant as originally proposed in its divestiture application.

SDG&E would provide the buyer with a license to use a portion of these properties in connection with the buyer’s ownership and operation of the CTslong-term leases and related easements to these properties.

Where applicable, SDG&E is proposing a two-step process for its auctions, similar to the processes approved by the CPUC for recent divestiture applications from Edison (Application No. 96-11-046) and PG&E (Application Nos. 96-11-020 and 98-01-008). In the first step, SDG&E requests the CPUC to issue an interim decision approving SDG&E’s proposed auction process, proposed contracts, and proposed ratemaking. In the second part of the process, SDG&E would conduct the proposed auctions. SDG&E will receive and consider proposed contract changes from second round bidders prior to receipt of final bids from second round bidders. SDG&E will, at its sole discretion, adopt the final form of the contracts. Final bids will then be received. Upon selection of the winning bidder for each asset, If SDG&E will were to receive satisfactory bids for some or all of its generating assets being divested, it would then negotiate final contracts with the winning bidder(s) and submit the final executed contracts to the CPUC for approval.

8. Authorization to obtain recovery of its estimated future generation-related environmental clean-up costs as part of SDG&E’s compliance filing. in a subsequent application.

Accordingly, the new owner(s) of such facilities would be assigned of SDG&E’s "must-run" contract with the ISO to ensure that electric power would be available when needed for reliability, to maintain transmission ratings, and to prevent price manipulation during times when market power exists, for as long as such facilities remain "must-run" facilities.

SDG&E agreed to prohibit the future placement of any gas- or steam-powered turbines, heat recovery steam generators, or electric generators on portions of the South Bay Power Plant located north of Telegraph Creek (see Figure 2.7 later in this section), but to eliminate any other deed restrictions on future land uses at the South Bay Power Plant site.

Decommissioning includes the decontamination, demolition, dismantlement and removal of any portions of the plant included among the assets being sold, and remediation of the soil and groundwater below the same, as more fully described in the Asset Sales Agreement.

The Port District would also be responsible for all existing and future hazardous material contamination and soil and groundwater contamination at the LNG site and the transmission property, except that the Port District may elect to have SDG&E remediate such property to meet industrial standards subject to the terms of the agreement between the Port District and SDG&E.

The South Bay Power Plant is located on a roughly 116-acre site located at 990 Bay Boulevard in the City of Chula Vista. In addition to the South Bay Power Plant site, SDG&E owns a roughly 33-acre site just south of the power plant that includes a now-decommissioned liquid natural gas (LNG) storage facility and a roughly 16-acre transmission corridor that runs north of the power plant and adjacent to a railroad right-of-way.

...of roughly 13.9 million gallons. The displacement oil stored at the refueling facility is was formerly used to fill the pipeline between residual fuel shipments to the power plant. The pipeline now is filled with nitrogen gas between shipments. This procedure is required because...

The new owner would acquire access to the site pursuant to SDG&E’s access agreement with the Navy.

SDG&E leases one additional above-ground tank at the site to Energy Factors, Inc.

The San Onofre Nuclear Generating Station (SONGS) is located on a roughly 90-acre site next to San Onofre State Beach on the Camp Pendleton U.S. Marine Corps Base in unincorporated San Diego County, just south of the City of San Clemente. SONGS has two active generating units (Units 2 and 3) and one retired generating unit (Unit 1)., with Units 2 and 3 have a combined net generating capacity of 2,150 MW, enough power to serve the needs of roughly 2.75 million households. Unit 2 has a net capacity of 1,070 MW, while Unit 3 has a net capacity of 1,080 MW. The net generating capacities of Units 2 and 3 reflect the rated outputs of those units. The maximum output from these units, which may be higher or lower than the said net generating capacities, on any given day varies due to ambient temperatures and other operating conditions. Units 2 and 3 were constructed were placed into commercial operation in 1983 and 1984, respectively. Combined, the two units occupy approximately 53 acres of the site. Unit 1 was constructed in 1967 and retired, after 25 years of service, on November 30, 1992. Unit 1 had a net generating capacity of 436 MW and has since been decommissioned. Edison and SDG&E are currently planning to submit a request in December 1998 to the Nuclear Regulatory Commission to commence the decommissioning of Unit 1. Unit 1 was a Westinghouse pressurized water reactor, while Units 2 and 3 are both Combustion Engineering pressurized water reactors of identical design. Under their current licenses, Units 2 and 3 are authorized to operate through 2013. When the units are eventually decommissioned, the underlying land must be returned to the government in an unrestricted use condition.

As shown in Table 2.3, SDG&E’s share of SONGS’ maximum rated output is a total of 214 MW from Unit 2 and 216 MW from Unit 3, or a combined rated output of 430 MW.

…other common areas. Moreover, SDG&E and Edison are tenants-in-common with respect to Unit 1.

Edison, the City of Riverside, and the City of Anaheim each have contractual rights of first refusal to purchase SDG&E’s ownership interest in the SONGS Units 2 and 3 and associated units and facilities, while only Edison has a contractual right of first refusal to purchase SDG&E’s ownership interest in Unit 1.

…such as the Regional Water Quality Control Board for an NPDES permit the USFWS for a FESA Section 10(a) permit. The process of re-applying for these permits could also cause the new owners to make different operational and maintenance decisions that than would SDG&E if it continued to own the plants.

However, the general characteristics of the buyers of the plants previously divested by Pacific Gas and Electric Company (PG&E) and Southern California Edison Company (Edison) are known.

Cannon Park, a small neighborhood park at the corner of Carlsbad Boulevard and Cannon Road, was given leased to the City of Carlsbad by SDG&E in 1963 (Sempra Energy, 1998).

The South Bay Power Plant is located on an approximately 116-acre site at 990 Bay Boulevard within the City of Chula Vista.

SDG&E’s contract with the Navy for the use of the land on which these two CTs are located expired on September 28, 1998 was recently extended for a term of 30 months and is currently being extended on a month-to-month basis.

Although that it does not appear that the lack of an…

The new owner of the CT will be entitled to access to and continued use of the site in accordance with SDG&E’s access agreement with the Navywould be required to enter into a lease agreement with the federal government to continue to use the property.

The new owner of the CT will be entitled to access to and continued use of the site in accordance with SDG&E’s access agreement with the Navywould be required to enter into a lease agreement with the federal government to continue to use the property.

The new owner of the CT will be entitled to access to and continued use of the site in accordance with SDG&E’s access agreement with the would be required to enter into a lease agreement with the Navy for the continued use of this site.

The Encina Power Plant is located in an established community and has been a local feature along on the coast since 1954.

SDG&E has permits from the California Coastal Commission, the RWQCB, the State Lands Commission, the State Department of Parks and Recreation, and the U.S. Army Corps of Engineers for the removal by dredging of specific quantities of sand.

The beneficial uses are identified in the Regional Board’s Water Quality Control Plan: San Diego Basin (often referred to as the "Basin Plan") and the state’s Water Quality Control Plan: Ocean Waters of California (referred to as the "Ocean Plan").

The plant discharges the cooling water through a discharge canal located to the south of the plant. The discharge is regulated by the RWQCB through NPDES Permit No. CA0001368. The NPDES permit establishes the upper thermal limits, which are based on the plant’s maximum generation capacity. At full capacity, the plant is permitted to discharges 601 mgd of cooling water and 1 mgd of metal cleaning wastes and low-volume wastes (RWQCB, 1996). However, according to SDG&E, the metal cleaning wastes are related to the boiler cleanings and typically occur only once per year per unit. Low volume wastes are typically discharged at a rate of 100,000 gallons per day but may fluctuate significantly on a day-to-day basis. The metal cleaning wastes and low-volume wastes are from essentially the same plant processes as described above for the Encina Power Plant.

Metal cleaning wastes are generated from chemical cleaning operations within the power plant, including boiler fireside washes, air preheater washes, and boiler waterside acid and chelant cleanings. Wastes are collected in aboveground tanks. The effluent from the impoundments and portions of the low-volume wastes are sent to the chemical treatment facility. The treated wastewaters are collected in tanks for testing and verification of the NPDES permit limits prior to discharge to the intake basin. Sediment that accumulates in the tanks is periodically removed and disposed of as a hazardous waste (Woodward-Clyde, 1988).

Low-volume wastes include boiler blowdown and wastes from floor drains, the water softener, and the reverse osmosis brine. The low-volume wastes are conveyed to the on-site treatment plant. The power plant also maintains an Industrial Waste Permit (No. 13-0019) from the Cities of Chula Vista and San Diego, which allows discharges to the sewer system of industrial wastes of up to 100,000 gallons per day meeting certain quality requirements (SDG&E, 1997). Since December 1997, all low volume and metal cleaning wastes are discharged to the municipal sewer system (SDG&E, 1998).

SDG&E regularly adds chlorine to the cooling water to remove marine biological growth in the plant’s condenser tubes and associated pipes. Accumulated growth restricts the flow of cooling water and increases the volume of cooling water needed to maintain constant condenser temperatures. Cooling water volumes can be increased by increasing the speed of variable speed pumps or by adding additional pumps. However, once all the pumps are running at full speed, volume can no longer be increased and condenser temperatures will begin to rise, thus significantly reducing the generating efficiency of the plant and eventually damaging equipment. Each unit is equipped with two cooling water pumps. Cooling water volumes and discharge temperatures are adjusted by turning these pumps on or off (Sempra Energy, 1998).

To reduce biological growth, a sodium hypochlorite solution is injected into the cooling water immediately upstream of the cooling water pumps for each unit. The injection is conducted intermittently throughout the day on each unit that is operating on an as-needed basis. The quantity of sodium hypochlorite use depends on the rate of slime and algae formation. More treatments are needed in the summer than in the winter (RWQCB, 1996). Residual amounts of chlorine are discharged with the cooling water, and the concentration and mass loading are regulated by the plant’s NPDES permit. Chlorine decays to non-toxic chloride ions when it reacts with other constituents, such as ammonia and organic compounds. During the chlorine treatment, the cooling water from the unit being treated is blended with the cooling water from the other operating units, resulting in an average four-fold dilution even before discharge to the bay (Lauer, 1996). [new paragraph break inserted]

The allowable chlorine residual final limit for the cooling water effluent was substantially reduced in the 1996 NPDES permit compared to prior permits due to a decision by the RWQCB to use the California Ocean Plan as the basis for the permit limit. The final limit is scheduled to replace the interim limit on December 15, 1999. However, SDG&E and the RWQCB have revisited the applicability of the stricter limit. SDG&E and the Regional Board staff, with concurrence from the Deputy Attorney General and Counsel of the Regional Board, have reached resolution on the issue. The Regional Board is scheduled to adopt an amended permit with reasonably implementable limits and in October 1998, the RWQCBand public notice of the proposed amendment has been issued Addendum No. 3 to the NPDES Permit (RWQCB, 1998). This Addendum establishes a chlorine effluent limit based on a calculated receiving water limitation determined by a statistical analysis of the discharge and water quality monitoring data.

Regional Water Quality Control Board (RWQCB) San Diego Region, Addendum No. 3 to Board Order 96-05 (NPDES Permit CA0001368), October, 1998.

The discharge specifications of the permit contain numeric effluent limitations for settleable solids, turbidity, pH, and acute toxicity, as well as toxic materials. Limitations are also provided specific to the low-volume wastes and metal cleaning wastes. Limits on many constituents are based on both concentration (e.g., grams/liter) and mass emissions (e.g., lbs/day).

Each of the power plants is regulated by the San Diego RWQCB by NPDES permits for both direct discharge to receiving waters and for stormwater runoff. The NPDES permits for each of the plants allow for discharges up to the amount of water required to operate the plant at design capacity. Cooling water discharges from the power plants are the predominant sources of thermal loading to San Diego Bay and to the marine environment in the vicinity of the Encina Power Plant, although natural processes also tend to elevate the temperature of the shallow back bay in the vicinity of the South Bay plant.

The production of the low-volume and metal cleaning waste streams occurs as part of scheduled maintenance. For example, each boiler at the Encina plant normally undergoes boiler cleaning once every four years. However, the volume of metal cleaning wastes produced on an annual basis is dependent on plant operations (RWQCB, 1994). With higher production rates, maintenance may be conducted at more frequent intervals. Therefore, the project may result in the increased production of low-volume waste or metal cleaning wastes., but the However, the amount of discharge of these wastes at the Encina plant would continue to be regulated by the NPDES permit limitations, and at the South Bay plant, these wastes are discharged to the sewer.

The project could result in additional generation of energy and, therefore, require additional water for cooling. Cooling water, however, is controlled at the plants by the use of variable-speed drive multiple pumps that operate at different levels are turned on or off depending on the level of generation at the plant., or the use of multiple pumps, some of which turn off when not operating at maximum capacity. Therefore, the amount of thermal discharge from the plants has some relationship to the level of electricity being generated at the plants. If a unit is completely off, some or all of the unit’s circulation pumps are typically off, although at times a volume of water that is less than full-operation volume is kept circulating for various process needs. Therefore, additional energy generation would likely require additional time when the pumps are in full operation. The pumps would extract and subsequently discharge additional water. The additional amount of water would not correlate directly with the increase in generation, but, in general, higher generation rates would result in higher volumes of intake water and higher volumes of heated discharge water. However, these discharges would have to comply with the existing NPDES permit conditions for flow quantity, thermal limits, and effluent constituent limits.

A new air emissions permit and different SDAPCD Rule 69 requirements rule changes may cause the new owners to make different decisions (e.g., accelerated installation of selected catalytic reduction (SCR) on units, or changes in the decision-making process for selecting the fuel type used at the Encina and South Bay plants) than SDG&E would if the plants continued under SDG&E’s ownership.

Toluene Benzene is a trace contaminant, but it can be detected in stack emissions where natural gas is burned.

The Encina Power Plant also includes a gasoline dispensing facility.

According to SDG&E, most of the NOVs were dismissed by the issuing agency without further action and no NOVs are outstanding.

The results of the 1992 HRA were adjusted to reflect current (1996) emissions estimates to provide a basis for updating the estimated health risks associated with the Encina Power Plant. The current estimated cancer risk for a maximum exposed individual (MEI) at the location of highest impact and caused by existing plant emissions is lower than one in a million (0.09 0.96 in a million). The major contributing pollutant (99% 91% of the total risk) was from methylene chloride and perchloroethylene from painting and cleaning operations gasoline vapor which is associated with the gasoline dispensing facility. Other contributing pollutants were methylene chloride and perchloroethylene from painting and cleaning operations, metals from fuel oil combustion by the boilers, and formaldehyde from natural gas combustion by the boilers.

According to SDG&E, many of these NOVs were dismissed by the issuing agency without further action and no NOVs are outstanding.

They have historically been used as peaking units and, as such, operated less than 100 hours per year; however, following the commencement of the restructured electricity market in March 1998, the dispatch requirements from the ISO have required that the CTs run at higher levels are peaking units operated generally less than 50 hours per year.

Health risk assessments were performed in 1992 for three CT sites (Naval Station, Naval Training Center, and North Island). For these 1992 assessments, the SCREEN dispersion model was used to estimate ambient concentrations of TACs surrounding the facilities. These concentrations were in turn used to derive a conservative estimate of health risks. The 1992 health risk assessments were based on estimated emissions provided in SDG&E’s 1989 AB 2588 Toxic Air Contamination Report. Beginning in 1990, emissions from the combustion turbines declined substantially relative to prior years because the units began to function nearly exclusively as peaking electric power generators. In 1990, the units on average operated 3% of the total hours operated during 1989. Between 1991 and 1997, the use of the units decreased even further, but during 1998, use of the units has increased again to levels similar to those that occurred in 1990. Therefore, the emissions and calculated risks from based on the decreased use of the combustion turbines are currently about less than 3% of the reported risks in the 1992 HRAs. The referenced assessments are discussed below along with a discussion of sensitive receptors in the vicinities of the CT sites.

The 1992 HRA estimated cancer risk for the MEI, which was has found to be located approximately 400 feet from the CT.

Furthermore, SDG&E proposes to request that SDAPCD modify their permits to operate to prohibit use of fuel oil for the boilers beginning in 2001 except under certain specified circumstances.

However, throughout the past two decades of thermal effluent studies and RWQCB reviews, SDG&E has been allowed to operated Unit 5 in conjunction with, and under the same regulations as, Units 1 through 4, and continues to do so at this time.

Initial dredging occurred between 1952–1954, when approximately 4 million cubic yards of sediment were removed to create a water area of over 250 acres with a mean depth of approximately 5 feet below mean lower low water (MLLW) (USFWS, 1976).

The fuel oil pipeline connecting the 24th Street Terminal with the South Bay Power Plant runs over the 316-acre Sweetwater Marsh National Wildlife Refuge. The marsh area provides critical habitat for the California least tern, the snowy plover, and the light-footed clapper rail. USFWS personnel have recently noticed that parts of this pipeline appear to be deteriorating and may not have the structural integrity to withstand an earthquake without rupturing (Rundle, 1998). In contrast to the displacement oil that was used in the past to fill the pipeline between oil shipments, nitrogen gas is currently used for this purpose.

Since then, SDG&E sought renewal of its NPDES permit. has requested authorization from the Regional Board for a change in operations that would increase the amount of cooling water effluent at the South Bay plant. In response, the The Regional Board issued such a renewal a revised permit, CA0001368, in November 1996 under Order No. 96-05, which was amended in February and October 1998. This Order 96-05 requires SDG&E to conduct further comprehensive limited thermal effluent studies, which are currently being conducted.

Marine organisms in the vicinity of the power plants are primarily impacted by the intake and discharge of ocean and bay water for the cooling of the Encina and South Bay Power Plants. Existing NPDES permits limit the volume, temperature, and constituent concentrations of the discharge. SDG&E will apply to transfer the NPDES permits to the new owners. As NPDES permits are not directly transferable, new owners will have to apply to the Regional Board for new permits. These new permits may involve no more than a name change (i.e., new owner(s) become permittee), but may also include new conditions.

4.7.a.4: SDG&E shall provide each new owner with all available information on special status species and habitat, as well as training documents regarding biological resources at the respective facilities. This will assist new owners in knowing the location of special status the respective facilities. This will assist new owners in knowing the location of special status species and habitats, and in meeting their legal obligations regarding endangered, threatened, or rare species or their habitats.

The 24th Street Terminal and the various CT sites are generally located in highly developed urban areas and contain no sensitive biological resources. The two exceptions to this are the CTs at the Marine Corps (formerly Naval) Air Station Miramar and the former Naval Training Center. The Miramar Air Station property to the south of SDG&E’s Miramar facility contains several vernal pools, which are known to contain sensitive species. The site is otherwise highly industrialized. The site of the Naval Training Center contains a nesting colony of endangered California least tern (Sterna antillarum browni) in the vicinity of the CT site. Protection of this colony has been addressed during the environmental review process for reuse of the training center. Neither the vernal pools nor the least tern colony are affected by the operation of the Miramar and Naval Training Center CT sites.

The plant is a large-quantity generator of hazardous wastes under Environmental Protection Agency (EPA) ID# CAT0006189000. CAT000619056.

...extending north of the power plant between J and F Streets. No Environmental Site Assessments to determine the presence or absence of hazardous materials have been conducted for these sites. Phase I and limited Phase II Environmental Site Assessments have been conducted for the LNG site. No hazardous substances were determined to be present on the LNG site. No assessments were conducted for the 16-acre transmission corridor. However, as part of and prior to the divestiture or donation of the South Bay properties, a Phase I and, if necessary, a Phase II Environmental Site Assessment would be conducted. If the assessments reveal that hazardous materials are present on the parcels, SDG&E would be responsible under its sales agreement for remediating the parcels to industrial stanndards contamination levels associated with SDG&E’s operation of the facilities.

The CT can operates only on natural gas or diesel fuel oil.

...potential environmental concerns during the Phase II Environmental Site Assessment. A BHRA conducted for the CT sites concluded that risks to human health were are acceptable for continued industrial use of the CT sites, with the possible exception of arsenic which was determined to be at naturally occurring background levels in soils and groundwater.(which may occur as a natural background material, or has been transported from an upgradient source, or occurs in groundwater). However, arsenic concentrations in groundwater do not require groundwater remediation at any of the sites.

The National City pipeline is a 10-inch-diameter, underground pipeline approximately 4.3 miles in length. It connects the marine terminal tank farm with the South Bay Power Plant tank farms. This unheated pipeline is constructed of steel and has cathodic protection. The No. 6 fuel oil is heated to a temperature of 180 degrees prior to transfer to the South Bay Power Plant to prevent plugging of the pipeline. SDG&E employs electric recirculating heaters at each terminal AST, and a steam boiler that burns either diesel fuel or No. 6 fuel oil, to provide heating. During periods of non-use, the pipeline is filled with nitrogen. While the pipeline is underground for most of its length, it is exposed at the surface at the following three locations: (1) in a storm drain berm within the northeastern portions of the power plant, (2) as part of an aerial crossing of the Sweetwater River, and (3) in the base of the tidal channel in Sweetwater Marsh. For much of its length, the pipeline is centrally located within the footprint of the transmission towers of SDG&E’s high-power line system.

Furthermore, under terms of the Purchase and Sale Agreement, SDG&E would be responsible for any legally required remediation of existing contaminated soil and groundwater at the divested plants that is necessitated by on-going operations of existing facilities and, therefore, would be responsible for remediation activities that are part of the ownership transition. as defined in the Asset Sales Agreement, to an industrial level commensurate with the continued use of the property as a fossil fuel steam electric generating facility. SDG&E’s obligations in this regard arise upon the closing of the sale of each such generating assets. Therefore, this impact would be less than significant because of current agreements and the regulatory environment. To the extent that the transfer of ownership and associated due diligence would identify site contamination and lead to its remediation, a beneficial impact on the environment might result.

The project could result in increased operations at the plants. The potential increase in operations and employees at the South Bay and Encina plants could incrementally increase the volume of wastewater disposed of in the local sanitary sewer system. The potential increase in wastewater generation would not be expected to require extensions of new sewer infrastructure or alterations to existing sewer lines. All future wastewater disposal would be subject to the applicable city’s sewer permit, which would be transferred or reissued, as appropriate, to the subsequent owner. In addition, the potential small wastewater increase would not be expected to significantly decrease the capacity of the applicable city’s wastewater treatment facilities.

The project would have no effect on the volume or frequency of storm water drainage, and therefore would not be expected to require extensions of new storm water drainage infrastructure or alterations to existing drainage systems. All future storm water drainage would be subject to either the applicable city’s sewer permit or the National Pollution Discharge Elimination System Stormwater permits issued by the State Water Resources Control Board, either or both of which would be transferred or reissued, as appropriate, to the subsequent owner.

Each CEQA document would also need to address cumulative impacts and would have more information on which to base the analysis as details of the projects are developed.

For Variant 2, the construction of the new Otay Mesa plant may have biological impacts, but these impacts would depend on site-specific conditions at the chosen site, which are currently unknown. As previously discussed, permits from the RWQCB would be required for discharges from the plant to protect aquatic species and beneficial uses. Additionally, permits from the Army Corps of Engineers and streambed alteration agreements with CDFG will be required for any wetland or streambed alteration. would be required from the USFWS or the CDFG for any streambed alternatives or to protect sensitive species. There would be no cumulative impacts from decommissioning the South Bay plant, since replacing the plant with a new land use should not affect biological resources.