SITE INFORMATION AND CORRESPONDENCE

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SECTION 6.0 Alternatives The following section discusses alternatives to the Lodi Energy Center (LEC) as proposed in this Application for Certification (AFC). These include the"no project" alternative,power plant site alternatives, linear facility route alternatives,technology alternatives,water supply alternatives, and wastewater disposal alternatives. These alternatives are discussed in relation to the environmental,public policy,and business considerations involved in developing the project.The main objective of the LEC is to produce economical,reliable, and environmentally sound baseload electrical energy for the Northern California Power Agency's (NCPA) project participants. The Energy Facilities Siting Regulations (Title 20, California Code of Regulations [CCR], Appendix B) guidelines titled Information Requirements for an Application require: A discussion of the range of reasonable alternatives to the project,including the no project alternative... which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project,and an evaluation of the comparative merits of the alternatives. The regulations also require: A discussion of the applicant's site selection criteria, any alternative sites considered for the project and the reasons why the applicant chose the proposed site. According to the Warren-Alquist Act,evaluation of alternative sites is not required when a natural gas-fired thermal power plant is (1) proposed for development at an existing industrial site, and (2) the project has a strong relationship to the existing industrial site [Public Resource Code 25540.6(b)]. LEC is the type of project that was envisioned by this code section. LEC would be sited on a 4.4-acre parcel sited between the City of Lodi s White Slough Water Pollution Control Facility (WPCF) to the east,treatment and holding ponds associated with the WPCF to the north, the existing NCPA Combustion Turbine Project#2 (STIG plant) to the west,and the San Joaquin County Mosquito and Vector Control facility to the south. The LEC project site is within a 1,040-acre parcel owned by and incorporated into the City of Lodi. LEC will be sharing some infrastructure with the current STIG plant, will tie in to the existing STIG switchyard, and will obtain process water from the WPCF. Due to these strong relationships, evaluation of alternative sites outside the boundaries of the LEC is not legally required. However, in order to provide some level of information to the CEC Staff and in accordance with pre-filing guidance from CEC Staff,a description of some alternative sites has been provided. SAC/371322/082330003(LEC_6.0_ALTERNATIVES.DOC) 6-1