In the Mercury News� editorial on June 13, 1999 titled "In our back yard? Considering overall picture, this plant would not be an environmental threat" the Mercury News said:

"The Calpine plant would produce enough pollution to increase the total nitrogen oxide emissions in the county four-tenths of 1 percent."

As I was looking through the California Environmental Quality Act (CEQA) review of the proposed sale of four of Pacific Gas and Electric Company's (PG&E) power plants at http://www.pgedivest.com/, I found the comments from the SAEJ (Southeast Alliance for Environmental Justice) provided a new way of looking at the Mercury News� claim.

From http://www.pgedivest.com/eirtc/comments/u.html:

"A project�s impact cannot be considered insignificant because it�s contribution to air quality is insignificant when compared to other sources. Kings County Farm Bureau v. City of Hanford 221 Cal. App.3d 692, 720 (5th Dist. 1990). The Court of Appeals held inadequate the cumulative impact analysis prepared for an EIR for a proposed coal-fired cogeneration power plant. The Court called this method of finding an impact insignificant because it was small compared to other sources, the incorrect approach. Id. This "ratio" theory of impact analysis allows a large pollution problem to make a project�s contribution appear less significant in a cumulative impact analysis. But the Court strongly disagreed, holding that such a method would "avoid analyzing the severity of the problem and allow approval of projects which, when taken in isolation, appear insignificant, but when viewed together, appear startling." It is invalid and terribly misleading of the DEIR to conclude that the impacts to air quality are insignificant because it is less then one percent of regional emissions. (Pg 4.5-59). In fact, the more severe existing environmental problems are, the lower the threshold should be for treating a project�s cumulative impacts as significant. Id. at 721. See discussion of Los Angeles Unified School District v. Los Angeles (1997) 58 Cal. App. 1019, supra."

In other words, in areas with high levels of pollutants in the air, new sources of pollution look less significant from the "ratio theory" point of view used by the Mercury News.

Sincerely,

Steven Nelson