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Cosumnes power plant (01-afc-19) data response, set 1A

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Submitted by


JANUARY 9, 2002

2485 Natomas Park Drive, Suite 600

Sacramento, California 95833-2937
Technical Area: Alternatives

CEC Authors: Negar Vahidi and Jacob Hawkins

CPP Authors: John Carrier and Katy Carrasco

California Environmental Quality Act (CEQA) Guidelines (§15126.6) require environmental impact reports to analyze alternatives to the proposed projects. The Energy Commission power plant siting process is a CEQA equivalent process and must also analyze alternatives to the proposed project.

Section 9 of the Application for Certification (AFC) discusses a “no project” alternative as well as alternative sites to the proposed project.

  1. Pursuant to the CEQA Guidelines, provide a detailed “no project” analysis. Include an analysis that compares the potential environmental impacts (for all technical subject areas such as agriculture, water resources, geology, etc.) between the proposed project and the “no project” alternative (i.e., a reasonably foreseeable scenario of future uses of the proposed project site). The project site’s land use and zoning designations should be considered when determining a reasonably foreseeable scenario.

Response: See Attachment Alt-1 for a more detailed No Project analysis.

AFC Sections and state that Alternative Sites 2 and 3 are too small to support the proposed facility. However, Alternative Site 1 is of sufficient size for the proposed facility.


  1. Provide a separate figure clearly illustrating the Alternative Site 1 (Carson Ice-Gen Facility) and how it would be served with water, natural gas, and transmission lines.

Response: Figure Alt-2 identifies the general area proposed for Alternative Site 1. However, based on conversations with the Sacramento Regional Wastewater Treatment Plant (SRWTP) representatives (see Attachment Alt-2), there is no room at the SRWTP for another power facility such as CPP.

  1. According to Section (page 9-3) of the AFC, Alternative Site 1 is zoned Open Space. However, in Section (page 9-5) the AFC states “…zoned land uses for the alternative sites are industrial…” Please clarify the correct zoning for Alternative Site 1.

Response: As shown in Data Response Alt-5, Alternative Site 1 is zoned Public/Utilities and is designated in the General Plan as Public/Quasi-public. The other two alternative sites (Procter & Gamble and Campbell Soup) are correctly identified as Industrial.

  1. It is difficult to determine Alternative Site 1’s proximity to residential and sensitive receptors based on Figure 9.2-1. According to page 9-6 of the AFC, the alternative sites would potentially affect more people since there are more residential land uses and other sensitive receptors. Please provide a map and/or information that supports this statement for Alternative Site 1.

Response: The Carson Ice-Gen power plant (Alternative Site 1) is located at the Sacramento Regional Wastewater Treatment Plant. Because of the nature of the WWTP, there is substantial buffer land surrounding it. However, the closest residential development is located about 0.9 mile away along Franklin Boulevard. By comparison, the closest residential development (at a much lower density) is more than a mile west of the CPP site on the south side of East Clay Road, along Kirkwood Road.

  1. For areas within a 1-mile radius of Alternative Site 1, provide a color map illustrating each of the following: general plan land use designations, zoning ordinance designations, and existing land use types.

Response: Figure Alt-5a shows the general plan land use designations for the 1-mile area surrounding Alternative Site 1. Figure Alt-5b shows the zoning ordinance designations for the 1-mile area. Existing land use is vacant open space except for the residential areas to the west of Franklin Blvd. and south of Dwight Road.


The SMUD owned property at Rancho Seco is a 2,480-acre site. Approximately 30 acres would be required for the proposed project.


  1. Describe how the proposed 30 acres of the 2,480 acres were selected as the proposed site, and if there are other alternative sites within the 2,480-acre area that would feasibly accommodate the proposed project

Response: The Applicant had numerous considerations and criteria in determining the best location for the plant within SMUD’s 2,480-acre area. This included siting criteria used by the California Energy Commission, but also additional criteria, among them: conforming with Sacramento County land use ordinances; biological impact avoidance for special status species, impact avoidance for existing water features such as ephemeral swales, streams, and vernal pools; avoidance of potential culturally sensitive features; avoidance of the vernal pool conservation easement area; proximity to roadways, property boundaries and nearby property owners; impact avoidance of Rancho Seco Park, campground, and visitor traffic; impact avoidance of the wildlife refuge (Performing Animals Welfare Society); proximity to existing features and re-usable equipment at the closed Rancho Seco Plant, including the switchyard and water supply pipeline; impact avoidance of the photovoltaic generation area and potential expansion of the photovoltaic area; impact avoidance of leased farmland and caretaker housing within the property and at Rancho Seco Park; proximity to the dry nuclear fuel storage area and impact avoidance of Rancho Seco decommissioning activities; suitable access to the proposed site for construction, operation, and emergencies; avoidance of low ground and FEMA mapped flood areas; proximity to a suitable discharge point for cooling water; visual impact avoidance to travelers along SR 104, community residents, and visitors to Rancho Seco Park; and space for a suitable laydown area resulting in minimum environmental impact.
After reviewing all of the above considerations and criteria, the parcel of land chosen for the site collectively had the least environmental impact and avoided sensitive areas, and was closest to existing Rancho Seco infrastructure. By reducing the distance to the existing Rancho Seco features, yet being far enough to avoid impacting decommissioning activities, SMUD was able to minimize the length of linear connections such as raw water piping, transmission lines and water discharge piping, and therefore, reduce environmental impacts. There were no other parcels, by a wide margin, that would feasibly accommodate the proposed project and be proximate to re-usable equipment and features of the Rancho Seco Plant. Although there is a large grassy plateau east of Rancho Seco Plant, it supports hundreds of vernal pools in a nearly natural state. In pre-consultation with the US Fish & Wildlife Service in March 2001, development of that area was strongly discouraged.

Attachment Alt-1
No Project Alternative

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