OCRed excerpt from ENVIRONMENTAL ASSESSMENT FOR HYDROPOWER LICENSE, Kern River No. 3 Hydroelectric Project, FERC Project No. 2290, California.

FERC RESPONSE TO AWA COMMENTS REGARDING POWER PRODUCTION. PAGE D-87.

Comments must be postmarked no later than November 22, 1996 to be considered. Comments should be directed to:

Forest Supervisor
Attn: Erik Ostly
Sequoia National Forest
900 West Grand Avenue
Porterville, CA 93257-2035

(This transcribed document may contain errors not found in the original document.)

D-87

Responses to American Whitewater Affiliation May 12, 1995,
Comments on the Kern River No. 3 Draft Environmental Assessment

B. We do not agree that the lack of need for immediate additional capacity suggests cutting existing capacity. Edison is not adding capacity to its system by relicensing Kern River No. 3; it is maintaining existing capacity that is currently necessary for its operations and that would need to be replaced should a license be denied. The argument that the Kern Rive No. 3 Project's 36.8 MW of installed capacity is only 3.2 percent of Edison's 1,153 MW of hydroelectric capacity and only 0.2 percent of Edison's 20,615 MW of total generating resources is not relevant. The size of the rest of Edison's system has no bearing on the merits of whether or not to issue a license for the Kern River No. 3 Project. Likewise, if Edison had a small system, the fact that Kern River No. 3 would then be a large percentage of its generating resources would not enhance its chances of licensure.

Our analysis indicates that continued operation of the Kern River No. 3 generating facility, even with the recommended environmental enhancements, is less expensive than the least expensive alternative, which currently is power from plants using natural gas combined-cycle combustion turbines. Even if our economics did not show this, under the FERC's current policy, this would not, per se, be sufficient reason for license denial.

Regarding potential effects of planned or possible future changes, such as changes in the power market and growth patterns or he potential sale of federal power marketing agencies by Congress, any estimates we might derive would be pure speculation. From a practical standpoint, the possibility of changes that might occur during the course of a license period are virtually limitless. That fact makes choosing which future possibilities to analyze very difficult. This difficulty and our inability to accurately predict what might happen make inclusion of such analyses speculative at best and misleading at worst.

Developing detailed forecasts regarding recreation trends is similarly fraught with uncertainty. The FS has analyzed recreation development availability, use patterns, and growth in the 1988 Sequoia National Forest Land and Resource Management Plan. The licensee has developed a recreation plan for the project area .to augment existing facilities.