Subject: FW: URGENT- CSUF Interconnection Study and CEQA
From: [email-masked]
To: [email-masked]
Cc: [email-masked], [email-masked]
Date: Thu, 16 Dec 1999 03:10:00 -0800 (PST)

What is the matter with Bob? What does he mean by 'Enron/CSU has not made the 
decision'? Did we say that and if so, who? Dirk

-----Original Message-----
From: Fantz, Donald [SMTP:[email-masked]]
Sent: Thursday, December 16, 1999 8:49 AM
To: 'Dirk VanUlden@Enron'
Subject: FW: URGENT- CSUF Interconnection Study and CEQA

Dirk,

FYI....I didn't see you on the cc: ....Don Fantz

----------
From:  Kinert, Robert
Sent:  Wednesday, December 15, 1999 4:52 PM
To:  'Dick Smith'; 'Rob Cone'
Cc:  Fantz, Donald; Hagen, John H; Colicchia, Rocco; Raymond, Galen
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