Loading...
HomeMy WebLinkAboutResolution 2014-18 supporting architectural improvements and r(✓ �( of �J�n-�e�� P, Dept. ID PL 14-007 Page 1 of 2 Meeting Date:4/7/2014 r CITY OF HUNTINGTON BEACH REQUEST FOR. CITY COUNCIL ACTION MEETING DATE: 4/7/2014 SUBMITTED TO: Honorable Mayor and City Council Members SUBMITTED BY: Fred A. Wilson, City Manager PREPARED BY: Scott Hess, AICP, Director of Planning and Building SUBJECT: Adopt Resolution No. 2014-18 supporting architectural improvements and approximate 125 ft. height of the proposed Huntington Beach Energy Project (AES) and transmit the recommendation to the California Energy Commission Statement of Issue: Transmitted for your consideration is a request to confirm the City's recommendation regarding architectural improvements and the proposal to exceed maximum height limitations for the proposed Huntington Beach Energy Project. Based on action by the City Council, the City's recommendation will be transmitted to the California Energy Commission. Financial Impact: Not applicable Recommended Action: Adopt Resolution No. 2014-18, "A Resolution of the City Council of the City of Huntington Beach Supporting Proposed Architectural Improvements as Modified and Approximate 125 Foot High Structures Related to the Reconstruction of the Huntington Beach Energy Project." Alternative Action(s): The City Council may make the following alternative motion(s): 1. Deny Resolution No. 2014-18 2. Continue Resolution No. 2014-18 and direct staff accordingly. Analysis: A. PROJECT PROPOSAL: Applicant/Property Owner: AES Southland, Stephen O'Kane, Manager, Sustainability and Regulatory Compliance, 690 N. Studebaker Rd., Long Beach, CA 90803 Location: 21730 Newland Street (Northeast corner of Newland Street and Pacific Coast Highway) The existing AES Huntington Beach Generating Station (HBGS) is proposed to be replaced with a natural gas-fired, combined cycle, air-cooled, 939-megawatt electrical generating facility on the 28.6 acre site. The new Huntington Beach Energy Project (HBEP) will consist of two independently operating, three-on-one, combined-cycle gas turbine power blocks. Each power block will consist of three natural gas-fired combustion turbine generators, three supplemental fired heat recovery steam generators, one steam turbine generator, an air-cooled condenser, and related ancillary HB -375- Item 15. - 1 Dept. ID PL 14-007 Page 2 of 2 Meeting Date:4/7/2014 equipment. Each power block would be architecturally enhanced with surfboard structures, metal mesh wave screens, and trompe I'oeil ("fool the eye") painting effects. In addition, portions of the two power blocks will exceed the maximum 50' height limit as defined in the City's Zoning Ordinance. The request is to confirm the City's recommendation regarding architectural improvements and the proposal to exceed maximum height limitations for the proposed Huntington Beach Energy Project. B. STAFF ANALYSIS: In June 2012, AES Southland submitted an application to the California Energy Commission (CEC) to reconstruct the existing electrical power generating station. Although the power generating station is located in the City of Huntington Beach, the City has no permitting authority over the proposed request. The CEC does ask AES and the City to demonstrate that the proposal is in compliance with all Local Ordinances, Rules and Regulations (LORS) prior to CEC action on the proposed request. To that end, City staff has reviewed and provided comments on each stage of the proposed project and all aspects of the CEC Preliminary Staff Assessments related to the proposal. City staff and CEC staff have identified that the appearance and architectural treatment of the proposed new plant are of primary concern to the citizens of Huntington Beach. Along with identifying the importance of the architecture of the plant, City staff has identified that the maximum height limit within the Public Semi-Public zoning on the property is 50 ft. On March 21, 2014 AES submitted a letter to the City of Huntington Beach requesting the City provide support of the proposal to exceed maximum height. AES identifies that the existing HBGS consists of two power blocks each with one existing 200 foot high stack. The six proposed stacks for HBEP are each approximately 120 feet high. In addition to the six stacks, HBEP proposes two power blocks, each with three heat steam recovery generators with a proposed height of 92 feet, and each has one air cool condenser with a proposed height of 104 feet. Additionally, the proposed architectural screening consists of three surfboards, two metal mesh wave forms, and trompe I'oeil painting on the air cooled condensers. The surfboards and metal mesh forms each have an approximate height of 125 feet. Therefore, the new proposed power plant, associated structures, and architectural screening will exceed the maximum height limitations by approximately 42-75 ft. If the City had jurisdiction and approval authority over the newly proposed power plant, the applicant would be required to seek approval of a Variance to exceed maximum height limitations. In this case, because AES is asked to demonstrate compliance with local requirements, AES and the CEC have asked the City to determine whether or not a variance to exceed height would be affirmatively approved. The attached Resolution describes the typical findings necessary to approve a height variance and provides some justification for the proposed request. The attached Resolution also confirms the City's support for the proposed architectural treatment of the proposed power plant and transmits the City's recommendation to the California Energy Commission. Environmental Status: Covered by Application for Certification No. 12-AFC-02, currently being processed by the California Energy Commission. Strategic Plan Goal: Improve the City's infrastructure Attachment(s): 1. Resolution No. 2014-18 2. Letter from AES Southland received and dated March 21, 2014 SH:JJ:kdc Item 15. - 2 HB -376- : ATTACHMENT # 1 RESOLUTION NO. 2.014-18 A RESOLUTION OF THE CITY COUNCIL, OF THE CITY OF HUNTINGTON BEACH SUPPORTING PROPOSED ARCHITECTURAL IMPROVEMENTS AS MODIFIED AND APPROXIMATE 125 FOOT HIGH STRUCTURES RELATED TO THE RECONSTRUcnON OF THE HUNTINGTON BEACH ENERGY PROvTECT WHEREAS, AES Southland Development, LLC (AES) submitted an Application for Certification (AFC) to the California Energy Commission (CEC) on June 27, 2012 for new construction of the Huntington Beach Energy Project (HBEP). The proposed project will replace the existing AES Huntington Beach Generating Station (HBGS) with a natural gas-fired, combined cycle, air-cooled, 939-megawatt electrical generating facility. AES' proposed project consists of demolishing the existing 200 foot high structures and replacing the structures with two power blocks, each with three heat steam recovery generators with a proposed height of 92 feet, and each has one air cool condenser with a proposed height of 104 feet. The CEC has permitting authority for the proposed HBEP and has requested the City to identify how the project complies with Local Ordinances and Regulations (LORS). On December 6, 2012, the City of Huntington Beach submitted a comment letter to the CEC and identified that the proposed project does not comply with the City's Zoning and Subdivision ordinance (ZSO)/LORS in part because the proposed structure height exceeds 50 feet. On March 21, 2014 AES submitted a letter to the City of Huntington Beach requesting the City make findings in support of a height variance although the City has no jurisdiction over the issue. If the City had jurisdiction over this project, a proposal to exceed the City's maximurn height limits would be subject to approval of a variance by the Planning Cormnission and would have to comply with the General Plan and zoning code policies to enhance public visual resources. By this resolution, the City Council is making hypothetical findings for a variance as requested. In addition, City Council recommends CEC incorporate the architectural treatments with modifications as set forth below into their final project approvals. NOW, THEREFORE, the City Council of the City of Huntington Beach does hereby resolve as follows: SECTION 1. The existing HBGS is located on property within the PS (Public Semi- public) zoning district which allows major and minor utilities. The existing structures are approximately 200 ft high and have been operating on the subject site since the 1950s. The proposed project will eliminate the less efficient existing facility and replace it with a modern state of the art combined cycle electrical generation facility. The height of the HBEP's stacks (approximately 120 ft high) are a result of the engineering and design requirements to meet the 11-3122/107796.doc 1 Resolution No. 2014-18 air quality permitting requirements of the South Coast Air Quality Management District (AQMD). The CEC's Preliminary Staff Assessment concludes that no feasible design alternatives will eliminate the need for stacks in excess of the City's height limitations. Therefore, without the stacks at proposed height, the property cannot continue to operate as an electrical generating facility. SECTION 2. Because of special circumstances applicable to the subject property, including size, location or surroundings, the strict application of the zoning ordinance may deprive the subject property of privileges enjoyed by other properties in the vicinity and under identical zone classification. The site is unique in that an electrical generating station has been operating at the site since the 1950s and it is already serviced by a high pressure natural gas. pipeline to facilitate electrical generation and an electrical transfer station to transfer the generated power into the overall electrical grid. The presence of these infrastructure components are unique to a power plant and demonstrate the special circumstances applicable to the location and the subject property. Additionally, the requirement to eliminate ocean water for once- through cooling combined with the site's lack of access to a feasible water supply for wet- cooling, creates a unique circumstance requiring dry cooling to accommodate electrical energy generation. Furthermore, air quality regulatory requirements that apply due to the site location require the use of stacks that exceed the maximum height limit. The strict application of the zoning ordinance would deprive HBEP of the existing privileges enjoyed by the 1950s era HBGS, which operates under the same zoning classification. Additionally, there are other existing approximately 70 ft high electrical tower structures that have been approved and constructed exceeding maximum height limitations in Low Density Residential zones, Residential Agriculture zones, and Public Semi-Public zones. The strict application of the zoning ordinance would deprive HBEP of the existing privileges enjoyed by the current power generating station and other existing electrical tower structures operating under the same and other zoning classifications. SECTION 3. Exceeding maximum height limitations may be necessary to preserve the enjoyment of one or more substantial property rights because the Public Semi-Public zoning classification allows major and minor utilities and the height variance would be necessary to allow AES to demolish and reconstruct a more efficient, lower profile electrical power generating station. Exceeding the maximum 50 ft height limit for the proposed approximately 120 ft high electrical generating plant along with approximately 125 ft high architectural screening will not constitute a grant of special privilege inconsistent with limitations upon other properties in the vicinity and under an identical zone classification. There are other existing approximately 70 ft high electrical tower structures that have been approved and constructed exceeding maximum height limitations in Low Density Residential zones, Residential Agriculture zones, and Public Semi-Public zones. The strict application of the zoning ordinance would deprive HBEP of the existing privileges enjoyed by the current power generating station and other existing electrical tower structures operating under the same and other zoning classifications. 11-3122/107796.doc 2 Resolution No. 2014-18 SECTION 4. Exceeding maximum height limitations will not be materially detrimental to the public welfare or injurious to property in the same zone classification and will not adversely affect the General Plan. The overall site has favorable geology and soils suitable for the power plant development. No new offsite development would be needed for HBEP, such as upgrades or additions to the existing electric transmission system or natural gas pipeline system. The Public land use designation is consistent with power plant development. Construction of HBEP may result in the reduction of certain environmental impacts as compared to the existing HBGS. Construction of the HBEP also includes architectural enhancements to soften the view of the new structures, create a focal point through the use of surfboards and wave forms, and to blend in with the surrounding environment through the use of trompe l'oeil painting effects on the air cooled condensers. The architectural improvements serve to preserve and enhance public visual resources as required in the Coastal Zone overlay. Although the proposed structures do not comply with maximum height limitations, the portions that exceed the maximum 50 ft height limit are a small percentage of the overall improvements on the 28.6 acre site. Therefore, exceeding maximum height limitations for HBEP and associated architectural improvements will not be materially detrimental to the public welfare or injurious to property in the same zoning classification and is consistent with the General Plan. SECTION 5. The City of Huntington Beach City Council recommends that CEC's final action incorporate an architectural plan based on the visual simulations and architectural enhancements as depicted Exhibit A with the following modifications: 1. the surfboard design shall be substantially three-dimensional and of a sufficient size and proportion for a realistic representation of a surfboard; 2. the trompe l'oeil painting on the air cooled condensers be revised to be more reflective of resort hotel windows and hotel improvements; 3. The entire HBEP be painted a combination of tans and browns on the lower portions and light blue on the upper portions. 4. No signs or other identifying features be painted or attached to the stacks, air cooled condensers, or heat recovery steam generators; 5. The final architectural plan and color scheme shall be subject to review and approval by the Planning and Building Department. PASSED AND ADOPTED by the City Council of the City of Huntington Beach at a regular meeting thereof held on the 7th day of April , 2014. Mayor REVIE APPROVED: APPROVED AS TO ORM: City ' n ge City Attorney WV q INITlAfTED AND APPROVED: Dire for o Planning and Building 1 1-3 122/1 07796.doc 3 Resolution No. 2014-18 4/2/2014 Huntington Beach Energy Project March 17, 2014 • Building Height — Maximum 50 ft height in Public Semi-Public zone — Approximately 120 ft for six stacks — Approximately 125 ft for three surfboards • Architectural Improvements: Recommended Revisions — Surfboards:substantially three-dimensional and of sufficient size and proportion for realistic representation of a surfboard — Trompe I'oeil painting on ACC: more reflective of resort hotel — Entire HBEP: painted combination of tans and browns on lower portions and light blues on upper portion — No signs or other identifying features on stacks,ACCs, or HRSGs f. a..... EXHIBIT 1 Resolution No. 2014-18 4/2/2014 �AES Project Attributes ®®® Preliminary Height "Stack"—202`" Stack—120 ft' (feet) ft Unitsland2 HRSG-92ft j Boiler—152 ft ACC—104 ft Units 3 and 4 Architectural Boiler-138 approx 125 ft' ft .:_ i I 2 Resolution No. 2014-18 4/2/2014 x, } 3 Res. No. 2014-18 STATE OF CALIFORNIA COUNTY OF ORANGE ) ss: CITY OF HUNTINGTON BEACH ) I, JOAN L. FLYNN the duly elected, qualified City Clerk of the City of Huntington Beach, and ex-officio Clerk of the City Council of said City, do hereby certify that the whole number of members of the City Council of the City of Huntington Beach is seven, that the foregoing resolution was passed and adopted by the affirmative vote of at least a majority of all the members of said City Council at a Regular meeting thereof held on April 7, 2014 by the following vote: AYES: Katapodis, Hardy, Shaw, Harper, Boardman, Sullivan, Carchio NOES: None ABSENT: None ABSTAIN: None City 4trk and ex-officio Merk of the City Council of the City of Huntington Beach, California F)ATTACHMENT #2 IV AlonAES We are the energy AES Huntington Beach, LLC 21730 Newland Street Huntington Beach, CA 92646 tel 562 493 7891 fax 562 493 7320 March 21, 2014 Jane James City of Huntington Beach Planning Manager 2000 Main Street Huntington Beach, CA 92649 Re: AES Huntington Beach Energy Project—Specific Findings in Support of Height Variance Dear Ms. James: This letter provides the information you requested via electronic mail to AES Southland Development, LLC (AES) on March 6, 2014 regarding findings in support of a height variance for the Huntington Beach Energy Project (HBEP) pursuant to sections 241.02 and 241.10 of the City's Zoning Code. As requested, the below demonstrates HBEP's compliance with the requirements for a variance in accordance with the City's Zoning Code. Specifically, the information and findings below relate to the height of certain components of HBEP that will exceed the City's maximum height of 50 feet for a commercial structure in the City's Coastal Zone Overlay District (Zoning Code Section 214.08). While HBEP is under the exclusive jurisdiction of the California Energy Commission (CEC), the information and findings below demonstrate that absent the CEC's sole permitting/licensing authority, HBEP meets the variance requirements of the City's Zoning Code. BACKGROUND AND SUPPORTING INFORMATION To support the finding that HBEP will meet the variance requirements of the City's Zoning Code, AES reiterates the following information that is also set forth in the HBEP Application for Certification (AFC): - The existing Huntington Beach Generating Station (HBGS) site on which HBEP will be located is designated as Public (P) in the City of Huntington Beach General Plan, which, among other uses allows public utilities. The HBGS site and the portion of the site that will be used by HBEP is zoned Public/Semi-public (PS), which allows major and minor utilities among other various uses. Specifically, electrical generation facilities are a permitted use within the PS zoning district. Item 15. - 12 HB -386- Ms. Jane James March 19, 2014 Page 2 - The existing HBGS consists of two existing power blocks: Units 1 and 2 comprise one power block, and Units 3 and 4 comprise the second power block. The two existing HBGS power blocks are each supported by one 200-foot tall stack, so the existing HBGS has two 200 foot (ft) tall stacks. The existing HBGS pre-dates the City of Huntington Beach Zoning Ordinance that was adopted after construction of HBGS Units 1 through 4 and their supporting facilities. Therefore, the existing HBGS is a recognized pre-existing use and complies with the City's General Plan and Zoning Code due to the nature of the existing and allowable land uses at the HBGS for electrical generation since the 1950s. - HBEP will be developed on a portion of the previously disturbed HBGS site that, as noted above, is zoned PS which includes electrical generation facilities as an allowable land use. As a modern, state of the art combined-cycle electrical generation system, HBEP will replace the less efficient existing generating equipment at HBGS. The California Independent System Operators (CAISO) and the CEC specifically recognize the importance of continued electrical generation at the HBGS site with the replacement of the existing 1950s generation units with modern combined cycle electrical generation units. In addition, HBEP will use air-cooled condensers that will allow HBEP to use less than 20 percent of fresh water used by the existing HBGS generating units, and will eliminate the use of ocean water for once-through cooling that is required for the existing electrical generating units at HBGS. State law requires HBGS to discontinue once- through cooling. - The six stacks for HBEP (HBEP consists of two power generation blocks: Blocks 1 and 2, each of which have three stacks for a total of six stacks) are approximately 120 ft tall as compared to the two existing HBGS stacks which are 200 ft tall. In addition to the six stacks, HBEP Blocks 1 and 2 each have three heat steam recovery generators (HRSGs) which have a maximum height of 92 ft, and HBEP Blocks 1 and 2 each have 1 air cool condensers (ACC) that are 104 ft tall. HBEP Stack Height The height of the HBEP six stacks (approximately 120 ft tall) are a direct result of the Project's engineering and design requirements to meet the air quality permitting requirements of the South Coastal Air Quality Management District (AQMD). The height of the stacks is a direct requirement for HBEP to meet the AQMD's permitting requirements for sufficient dispersion of operational air emissions from HBEP. As noted above, the 120 ft tall HBEP stacks are significantly shorter than the existing 200 ft tall stacks at HBGS. The CEC's Preliminary Staff Assessment, Part B ("PSA Part B") discusses alternatives to HBEP and concludes there is no alternative that would eliminate the need for stacks that exceed the height limit. Thus, the site cannot enjoy the electrical generating use within the prescribed height limits. Height of HBEP's HRSGs The height of each of the six HRSGs for HBEP (92 ft) is based on the manufacturers design specifications to meet HBEP's operational parameters of the 939-megawatt (MW) of modern, high efficiency combined cycle generating units that will replace the existing 1950s-era HBGS generation equipment. HB _387- Item 15. - 13 Ms. Jane James March 19, 2014 Page 3 Height of HBEP's ACCs The height of the two ACCs for HBEP (104 ft) is based on the manufacturer's design specifications to meeting HBEP's operational parameters of the 939-megawatt (MW) of modern, high efficiency combined cycle capacity that will replace the existing 1950s-era HBGS generation equipment. As discussed above, the use of air-cooled condensers will allow HBEP to use less than 20 percent of fresh water used by the existing HBGS generating units, and will eliminate the use of ocean water for once-through cooling that is required for the existing electrical generating units at HBGS. Moreover, any air-cooled alternative to the proposed project will include ACCs that exceed the prescribed height limit. A wet cooling alternative is not feasible because once-through cooling with ocean water is prohibited and there is not a reasonably available or suitable water source located at the site for wet cooling. Thus, the site cannot enjoy the electrical generating use within the prescribed height limit. - HBEP is located within a portion of the existing HBGS that is served by infrastructure and services adequate to support additional development. The existing HBGS has various ancillary facilities that will support the HBEP, such as the Southern California Gas Company (SoCalGas) natural gas pipeline serving the site, the existing onsite Southern California Edison (SCE) 230-kV switchyard, and the existing connections to the City of Huntington Beach potable water system and sanitary sewer system. These unique site characteristics further support locating HBEP at the proposed site. - The existing HBGS is defined as a coastal-dependent energy facility within the City of Huntington Beach Local Coastal Plan (LCP). Based on the priority of the City of Huntington Beach's LCP to redevelop existing industrial parcels in the coastal zone rather than establishing new industrial parcels in the coastal zone, the repowering of the existing HBGS through the implementation of the HBEP is consistent with the City's LCP as it will reuse and connect to existing industrial infrastructure, including the: existing SCE switchyard, existing Southern California Gas Company high pressure natural gas pipeline, existing City of Huntington Beach potable water and sanitary sewer pipelines, and the existing Huntington Beach Generating Station's ocean outfall for discharge of stormwater and process water. - The overall HBGS site and, more specifically the HBEP site, has favorable geology and soils suitable for power plant development and has no significant engineering constraints. No new offsite development would be needed for HBEP, such as upgrades or additions to the existing electric transmission system or natural gas pipeline system. The land use designation of the site is consistent with power plant development. Development of HBEP and the retirement of the existing HBGS generating units will not result in any new significant impacts to public health or the environment. Rather, as documented in the AFC, the HBEP will result in the reduction of certain environmental impacts as compared to the existing HBGS. - As documented in Section 6.0 Alternatives of the AFC for HBEP, the region in which the existing HBGS is located and in which the HBEP will be located does not include suitable alternative sites. Rather the region consists of densely developed residential neighborhoods, commercial facilities, and public facilities, with little suitable open land. As noted above, the HBEP site has a strong relationship to the existing HBGS electrical generation/industrial site and the existing regional SCE electrical transmission and Item 15. - 14 HB -388- Ms. Jane James March 19, 2014 Page 4 III distribution system. As detailed in Section 6.0 -Alternatives of the HBEP AFC, HBEP will provide critical electric reliability service in a densely populated load pocket of Southern California. If a suitable brownfield alternative site were identified, it is unlikely that such a site would provide the necessary infrastructure already available at the HBEP site. Therefore, an alternative site will likely not reduce or avoid any impacts associated with the HBEP site, which, as the analysis in the AFC shows, are already below significant y y levels. Further, development on alternative sites could result in greater impacts than present with the redevelopment of a portion of the existing HBGS for the HBEP. By replacing the existing HBGS, HBEP will ensure reliable generation is maintained at a location critical to southern California, and will provide fast response, modern, clean, and efficient electrical power that fully supports and assists the region and California in achieving much greater reliance on intermittent renewable electricity generation sources, such as wind and solar. REQUIRED FINDINGS IN SUPPORT OF A VARIANCE FOR HBEP (CITY ZONING CODE SECTION 241.10) Based on the discussion and supporting information set forth above, AES provides the following findings in support of a variance for HBEP: • The granting of a variance will not constitute a grant of special privilege inconsistent with limitations upon other properties in the vicinity and under an identical zone classification. Finding: The existing HBGS site on which HBEP will be located is designated as Public (P) in the City of Huntington Beach General Plan, which, among other uses, allows public utilities. The HBGS site and the portion of the site that will be used by HBEP is zoned Public/Semi-public (PS), which allows major and minor utilities among other various uses. Specifically, electrical generation facilities, such as the existing HBGS, are a permitted use within the PS zoning district. Therefore, the granting of a variance for HBEP on the existing HBGS is consistent with the PS zoning district for the site, and does not grant HBEP a special privilege inconsistent with limitations upon other properties in the vicinity and under an identical zone classification. • Because of special circumstances applicable to the subject property, including size, shape, topography, location or surroundings, the strict application of the zoning ordinance is found to deprive the subject property of privileges enjoyed by other properties in the vicinity and under identical zone classification. Finding: The existing HBGS site on which HBEP will be located is designated as Public (P) in the City of Huntington Beach General Plan, which among other uses allows public utilities. The HBGS site and the portion of the site that will be used by HBEP is zoned Public/Semi-public (PS), which allows major and minor utilities among other various uses. Specifically, electrical generation facilities, such as the existing HBGS and the proposed HBEP, are a permitted use within the PS zoning district. The site is unique in that it is already serviced by a natural gas pipeline to facilitate electrical generation.The requirement to eliminate once-through cooling combined with the site's lack of access to a feasible water supply for wet cooling creates a unique circumstance requiring dry HB -389- Item 15. - 15 Ms. Jane James March 19, 2014 Page 5 cooling to accommodate electrical energy generation. In addition, air quality regulatory requirements that apply due to the site location require the use of stacks that exceed the height limit. Therefore, the strict application of the zoning ordinance would deprive HBEP of the existingprivileges which operates under the p eges enjoyed by the existing HBGS, ope a de identical PS zoning district classification. In addition, the granting of a variance for HBEP on the existing HBGS site is consistent with the PS zoning district for the site. • The granting of a variance is necessary to preserve the enjoyment of one or more substantial property rights. Finding: The existing HBGS site on which HBEP will be located is designated as Public (P) in the City of Huntington Beach General Plan, which among other uses allows public utilities. The HBGS site and the portion of the site that will be used by HBEP is zoned Public/Semi-public (PS), which allows major and minor utilities among other various uses. Specifically, electrical generation facilities, such as the existing HBGS and the proposed HBEP, are permitted uses within the PS zoning district. The granting of a variance is necessary to preserve AES's ability to use the site for electrical generation as permitted by the City's General Plan. Thus, granting of a variance is necessary to preserve AES's enjoyment of one or more substantial property rights. • The granting of the variance will not be materially detrimental to the public welfare or injurious to property in the same zone classification and is consistent with the General Plan. Finding: The overall HBGS site and specifically the HBEP site has favorable geology and soils suitable for power plant development and has no significant engineering constraints, No new offsite development would be needed for HBEP, such as upgrades or additions to the existing electric transmission system or natural gas pipeline system. The land use designation of the existing HBGS is consistent with power plant development. The General Plan also recognizes the existing use of the HBGS site and includes references to potential proposals to expand or alter the facility. Moreover, development of HBEP and the retirement of the existing HBGS generating units will not result in any new significant impacts to public health or the environment. Rather, HBEP will result in the reduction of certain environmental impacts as compared to the existing HBGS. Therefore, the granting of a variance for HBEP will not be materially detrimental to the public welfare or injurious to property in the same zone classification and is consistent with the General Plan. If you have any additional questions, please contact either me or Robert Mason of CH2M HILL at (714 435-6113). Sincerely, C3�;L_ Stephen O'Kane Vice-President AES Southland Development, LLC Item 15. - 16 HB -390- Ms. Jane James March 19, 2014 Page 6 cc: J. Didlo/AES J. Salamy/CH2M HILL R. Mason/CH2M HILL HB -3 9 1- Item 15. - 17