On August 18, 1999 James R. Derryberry, Director of the City of San Jose Planning, Building, and Code Enforcement sent a memo to Lorraine White of the California Energy Commission (CEC). The memo discusses the City of San Jose's requirements for the CEC's Environmental Impact Report that will be used by the City for its approval process. Some quotes from the memo regarding the City of San Jose's concerns about air quality:

"The document should specifically identify any impacts considered by the City to be significant environmental impacts based on environmental thresholds established by the City for determining environmental significance. Environmental analysis based upon Statewide or Regional significance thresholds may be considered by the City of San Jose to be inadequate for local environmental impact analysis, which is required prior to local approvals, such as zonings, annexations, permits, etc. Other agencies may use different thresholds for determining significance, but in order for San Jose to use this document as an EIR equivalent in approving zoning and project entitlements, it is important to identify all environmental impacts considered by the City to be significant. For example: Based on City of San Jose threshold criteria (based upon Regional Air Quality District criteria), the project will result in significant air quality impacts. The CEC may allow the purchase of offset credits to mitigate regional impacts to a less than significant level, but the net result of this project will be an increase in local air pollution levels that will constitute a significant air quality impact locally. The City of San Jose would consider offset credits to be a mitigation measure that may partially reduce air quality impacts, but not to a less than significant level. Environmentally significant impacts require the City Council to adopt a resolution of overriding considerations prior to any project approvals. Based upon the information received to date, it appears the project may result in significant unavoidable environmental impacts in the area of Air Quality and Visual Resources."

"It is anticipated that as a result of the decommissioning of older plants, at the statewide level, there would be less air pollution. However, at the regional and local level the impacts of new "merchant" power plants may be less positive. In the past, there have been no major electrical generators in the Santa Clara Valley. Therefore the positive advantage of statewide air quality benefits will have to be compared with the regional and local impacts of this project."

"The Air Quality impact analysis section should show the level of emissions for the air pollutants in the area within a three mile radius surrounding the project and should compare the air quality impacts associated with the project to the existing ambient air quality in the area. Suitable graphics should be included to illustrate the analysis. The analysis should also address air quality impacts upon the future urban uses expected to develop in the long-term as part of the Coyote Valley Urban Reserve (CVUR), located just south of the NCVCIA (North Coyote Valley Campus Industrial Area) and generally downwind of the project site."

"This section is intended to discuss the environmental impacts associated with a "No Project Alternative" scenario. These environmental impacts should not be limited to statewide or regional effects, but should include local impacts. This document (considered to be the CEQA equivalent to an EIR) is intended to be used by the City of San Jose for local zoning, annexation and related permit approvals and should, therefore, address local environmental impacts. The regional/statewide issue of greater fuel consumption and air pollution associated with older power plants is not really germane to the City of San Jose, which does not have power generating facilities similar to the proposal currently within its jurisdictional boundaries. Therefore, the City of San Jose considers that local air quality impacts would be less with the No Project Alternative."

The document is not available online but is a part of the CEC docket for the proposed Metcalf Energy Center.