FW: URGENT- CSUF Interconnection Study and CEQA ,
 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
jeff.dasovich@enron.com