Summary of CGNP's Legal Advocacy for the Continued Safe
Operation of DCPP beyond 2025
Gene Nelson, Ph.D. CGNP Legal Assistant 07 16 19
1. PG&E failed to apply for a Coastal Development Permit (CDP) from the California Coastal Commission (CCC) before requesting permission to voluntarily close DCPP in 2025. The California Coastal Act grants plenary power to the CCC for "changes in intensity of use" of coastal power plants - and requires a CDP. PG&E followed the proper sequence for permitting when they closed their nuclear-powered Humboldt Bay Power Plant, Unit 3 which last produced power in July, 1976. A full-scope Environmental Impact Report (EIR) must be prepared first. This EIR examines the adverse environmental (and economic) impacts of voluntarily closing DCPP in 2025. Each year, DCPP produces the equivalent of more than five (5) Hoover Dams of Electricity without emitting a speck of carbon. DCPP generates this huge amount of power safely and reliably, 24/7 Sun or no Sun, wind or no wind, drought or flood. DCPP is cost-effective. It produces power at a cost that undercuts in-state fossil-fired generation. The "no project" alternative must be disclosed - it is clearly superior. A 2016 cost study commissioned by the Idaho National Lab established that DCPP's power production cost was 2.71 cents/kWh, about 1/10 the 20 cents/kWh trouble-plagued, bird-killing Ivanpah Solar-Thermal plant that burns over 1 billion cubic feet of natural gas per year. DCPP's important economic benefit is it pumps over $1 billion in direct and indirect payrolls each year into the Central Coast, per the 2013 Cal Poly economic impact study. (The 2019 UC Berkeley SB 968 study makes fallacious assumptions which invalidate the optimistic conclusions.)
2. PG&E has committed serious ethical violations in providing misleading and deceptive sworn CPUC testimony in A.16-08-006. Simply stated, PG&E lied numerous times to the CPUC. PG&E's sworn CPUC testimony in A.10-01-022 regarding DCPP's relicensing costs - and the benefit of running DCPP at least until 2045 directly contradicts PG&E's 2016 sworn testimony. Given that PG&E's profits would be boosted by billions of dollars from 2025-2045 via the CCR mechanism if four or five new 500 MW natural gas generators must be built to replace DCPP, a trier of fact would determine that PG&E materially deceived the CPUC in A.16-08-006. This information has been reported by CGNP to the Federal Monitor in PG&E's criminal probation in the case USA v PG&E being heard in the Federal District Court in the Northern District of California under Judge William Alsup. This Court is also concerned about PG&E's actions that diminish public safety. These new natural gas demands would stress PG&E's aging natural gas distribution system which failed in San Bruno on September 9, 2010.
3. DCPP's reliable power will be needed for California's public safety and welfare for northern California, particularly under PG&E's new regional public safety power cutoffs that will be occurring for many years during hot and windy conditions. DCPP will be able to supply its reliable power during most of these events.
Gene Nelson, Ph.D. CGNP Legal Assistant 07 16 19
1. PG&E failed to apply for a Coastal Development Permit (CDP) from the California Coastal Commission (CCC) before requesting permission to voluntarily close DCPP in 2025. The California Coastal Act grants plenary power to the CCC for "changes in intensity of use" of coastal power plants - and requires a CDP. PG&E followed the proper sequence for permitting when they closed their nuclear-powered Humboldt Bay Power Plant, Unit 3 which last produced power in July, 1976. A full-scope Environmental Impact Report (EIR) must be prepared first. This EIR examines the adverse environmental (and economic) impacts of voluntarily closing DCPP in 2025. Each year, DCPP produces the equivalent of more than five (5) Hoover Dams of Electricity without emitting a speck of carbon. DCPP generates this huge amount of power safely and reliably, 24/7 Sun or no Sun, wind or no wind, drought or flood. DCPP is cost-effective. It produces power at a cost that undercuts in-state fossil-fired generation. The "no project" alternative must be disclosed - it is clearly superior. A 2016 cost study commissioned by the Idaho National Lab established that DCPP's power production cost was 2.71 cents/kWh, about 1/10 the 20 cents/kWh trouble-plagued, bird-killing Ivanpah Solar-Thermal plant that burns over 1 billion cubic feet of natural gas per year. DCPP's important economic benefit is it pumps over $1 billion in direct and indirect payrolls each year into the Central Coast, per the 2013 Cal Poly economic impact study. (The 2019 UC Berkeley SB 968 study makes fallacious assumptions which invalidate the optimistic conclusions.)
2. PG&E has committed serious ethical violations in providing misleading and deceptive sworn CPUC testimony in A.16-08-006. Simply stated, PG&E lied numerous times to the CPUC. PG&E's sworn CPUC testimony in A.10-01-022 regarding DCPP's relicensing costs - and the benefit of running DCPP at least until 2045 directly contradicts PG&E's 2016 sworn testimony. Given that PG&E's profits would be boosted by billions of dollars from 2025-2045 via the CCR mechanism if four or five new 500 MW natural gas generators must be built to replace DCPP, a trier of fact would determine that PG&E materially deceived the CPUC in A.16-08-006. This information has been reported by CGNP to the Federal Monitor in PG&E's criminal probation in the case USA v PG&E being heard in the Federal District Court in the Northern District of California under Judge William Alsup. This Court is also concerned about PG&E's actions that diminish public safety. These new natural gas demands would stress PG&E's aging natural gas distribution system which failed in San Bruno on September 9, 2010.
3. DCPP's reliable power will be needed for California's public safety and welfare for northern California, particularly under PG&E's new regional public safety power cutoffs that will be occurring for many years during hot and windy conditions. DCPP will be able to supply its reliable power during most of these events.
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