Requests Advice Concerning Util Application for Authorization Of

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' , , * * 8. LENNART CELERDORO A1TORNEY AT LAW SOOM SYNDif 4TE SUH.,OING '4 40 5'tOADWAr OAKtAND $2. CA12Polt,NIA

TaLape.ooes H8eAvs 4-dese DIXON In WATSON .o. ,s

. October 9, 1961 Atomic Energy Commission Washington, D. C. .

. Gentlemen: Re: Pacific Gas & Electric Gompany Power Plant Bodega Bay, California

| I am writing in behalf of Mrs. Rose S. Gaffney who owns approximately 437.85 acres adjoining the "Strow property" on Bodega Head, now owned by Pacific' Gas & Electric Company. The Pacific Gas & Electric Company is seeking through condemnation , ' Utility'sto acquire present 64.9 acres holdings. belonging to Mrs. Gaffney adjoining the I am representing Mrs. Gaffney in the condemnation suit. Will you please advise concerning the following two matters : 1 - Has Pacific Gas & Electric Company applied for and | been granted a permit or any. authorization for the purpose of constructing an atomic energy power plant on Bodega Head? , If such has been granted, kindly advise the date thereof. t 2 - In view of the extensive acreage owned by Pacific | ' Gas & Electric Company on Bodega Head, is it necessary that | | this Utility also acquire an additional 64.9 acres from Mrs. Gaffney, and if so, is the requirement being made by the Atomic Energy Commission or is it solely the desire of the Utility to acquire this additional property? I will appreciate an early reply to the above inquiry. Very truly yours, SLC/36 g /pth( ' | Reg. S. Lennart Cederborg '

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341 Market Street Cd i 6"'.,a .- m. e* ". r* , o,, u= d , ad 2 San Francisco 5, California > w ..,m.o ,,,. m EXbrook 2-1310 ar' i,t 4d"'/ < .'"*.e 4 5 * ci6' r~f- N. HEISL'::R f.: STZWART 8 h D:' u n 4', ' Lincoln at Seventh f,'' i, ? "4 " P. O. Drawer 3996 1 1933 5 Carmel, California EUSDE O. A '.'. . .. *:r ung # M.Ayfair 4 1202 '' * *' NOCWi-. "'v vr c. ass 6 Attorneys for Petitioners 7k I a IN THE SUPIRIOR COURT OF TKI STATE OF CALITCENIA g< E4 AND FOR THE COUNTY OF SCNOMA ' 10 '1 NORTHERN CALIFCRNIA ASSOC'A- ') 11 :' ; TION TO PRISIRVE 3CO20A EI!.O AND HARECR, a corporatica, W.RY ) . 12 ! LARL;ic, SIL;.S OARLMO, CHARLCS ) | i | '?h z; GCODALZ and OORIS SLOAN. N C. 4 13 } 2t . 3 1 P etiticae r s . ) ) CROIR TO EMO;-7 Cr.L:I ( ,e '4 ) )j$h 15 V8' f THC 30ARD CT SUP2RVZ15 OT TMC f COUNTY CF SONOMA, 57 .72 CF Ce. ; , $f*Ik| 16 }. ? =, rcRNIA, - : 17 - , . 3|2 Re a pcc.iaat. j| 13 ) sy ) u * I 19 a ; e ::a ri 20 , Lpon reading and fi;ir.; u.e . ..ica for Wr:: cf i:andt:e or Cer 21 herein, and it appearing t:.enfrcen On 4: is a pros,e r cause the refor: f 22 j IT IS HERE3Y O2LIRZO cat ne responden* THE 3CA3C CT SUPIR 4 i he and 23 i VISCRS OF TZO COUNTY 07 SONO;. A, STATI OF CALIFORNI.r., s O of the r.tove entMed Co rt on ne j 74 j appear in Departrnent No.

- s (v, i , 1963, at ce hour cf 1C:00 A.hL of ss.id day,1: 25 | day of 4 . 20 f the Sonom/ County Courthoase, Sar.ta Rosa. Califernia, Ben ar.d dere to I show cause, if any there be, why: 27 | 28 1. A writ of rnandate shocid r.ct issue out cf a.r.i under de seil of 21 29 I court, directed to THE EOARD OF SU?IRVISORS OF TEI COUNTY CT

30 SONOMA, STATE 07 CALIFORNIA, ccmmanding de said 30ARD to set 31 ! aside its decision granting to the Pacific Gas and I;ectric Company a use f 32 - permit on or abov.t February 9.1960, to construct a steam electric ;er.e>

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! ! l; ing plant on Sodega Head; 2 I 2. Pending judgment, the court should nct stay the operation of Resch. 3 tion Number 19032 cf the Board of Supervisors of Sonema Count',; and

4 3. A writ of certiorari should not issue from t..is ::,urt cCrected to 5, THZ SOARO CF SUPERV150RS CF TIC COUNTY OF SCNCMA, STATO C.' 6 CALIFORNIA, commandir.g it to certify fSy to tnis court, at a specifiei 7i time and place, a transcript of the record and proceedin;s of said 3 car:t tr $ 8 granting a use permit to the Pacific Gas ar.d Electric Compc.y on or thout 9 February 9,1960, to the end that same be reviewed by this court. and fur- 10 < ther why ce Resolution of the Board granting such use perrr.it should not be 11 set aside and annulled as being made and ordered without jurisdiction in ne

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i 1 CARRY, DREYFUS & McTERNAN 341 Market Street (}k 2 San Francisco 5, California .f EXbrook 2 1310 ( 3 , I HEISLER & STEWART - . 4 ; Lincoln at Seventh fugg 61%,,,* ' t Cl I | P. O. Drawe r 3996 & #fAtm ar ; j | 5 Cartnet, California ' Owg MAyfair 4-1202 M ' i a ,, ' { | 6 Attorneys for Petitioners 7 |

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11 IN THE SUPERIOR COURT OF THE STA'rE OF CALIFORNIA

g 12 IN AND FOR THE COUNTY OF SONOMA I j1 13 ' b 14 NORTHERN CALIFORNIA ASSOCIATION ) j; ag TO PRESERVE BODEGA HEAD AND ) ,jjg 15 HARBOR, a corporation, MARY DARLING, ) e y& SILAS DARLING, CHARLES GOODALE ) ! 16 and DORIS SLOAN, ) - O e *g ) i $#|; 17 Petitione rs, ) i v ) 18 vs. ) NO. ,.gg { ! 19 THE BOARD OF SUPERVISORS OF THE ) 2 COUNTY OF SONOMA, STATE OF ) . 20 CALIFORNIA, ) . ) 21 Re sponde nt. ) ' , . ) ' 22 | 23 PETITION FOR WRIT OF MANDATE OR CERT!ORARI ' 24 The verified petition of NORTHERN CALIFORNIA ASSOCIATION TO :i i 2S PRESERVE BODEGA HEAD AND HARBOR, a corporation. MARY DARLING, |

| 26 SILAS DARLING, CHARLES GOODALE and DORIS SLOAN, for a writ of * 27 mandate or certiorari renfectfully shows: 28 g | 29 Petitioner NORTHERN CALIFORNIA ASSOCIATION TO PRESERVE ' i 30 BODEGA HEAD AND HARBOR 1e a corporation organized and existing under

, 31 1 and by virtue of the laws of the State of California; its corporate purposes are 32 to protect and preserve the scenic beauty and recreational vale e of Bodega

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c . 1 .J .1 .l : i 1 , | ' | 1 ' a . .|. . i - l 1' ' I ' | . I i . t 1 Head. Sonoma County, against commercial and industrial intrusion. i | 2 u , | , ! l 3 Petitioners MARY DARLINO and SILAS DARLINO are now and have j | 4 >een at all times rnantioned herein residents, citisens and taxpayers of the , O County of Sonoma, State of California; they reside on real property owned by I' | 1 8 them situated in the town of Bodega Bay, approximately one and one-half miles I 7 from the site of a certain proposed nuclear-fueled reactor at Bodega Head. 8 hereinafter described. '

9 III ,

10 Petitioner DORIS SLOAN is now and has been at all times herein | 11 mentioned a resident, a citizen, and a taxpayer'of the County of Sonoma,

g 12 State of California; she resides on real property owned by her situated at 734 1 z! 13 Litchfield Avenue, in the City of Sebastopol, approximately eleven miles from "f 14 the site of the said proposed nuclear. fueled reactor at Bodega Head. * y, "f : 3 15 IV g 4 m le ' 1 Petitioner CHARLES OOODALE is now and has been at all times

4 g| 37 herein mentioned the owner of real property situated near Bloomfield in the ' W { | 18 i | County of Sonoma State of California, and a taxpayer on the tax rolls of i " 1p Sonoma County: his real property is approximately six miles from the site of | | 20 the said proposed nuclear-fueled reactor at Bodega Head. 21 V 22 Respondent BOARD OF SUPERVISORS OF THE COUNTY OF 23 SONOMA (hereinafter referred to as " BOARD") is compo, sed of the 24 following duly elected, qualified and acting members: E. J. Ouidotti.

' 05 Ouy King. Arthur Ruonavaara. . Leigh Shoemaker . and Carson . 26 Mitchell.

27 V1 28 PAQ FIC OAS AND ELECTRIC COMPANY was and is now a 29 corporation organised and existing under and by virtue of the laws of the , 30 State of California, with its principal place of business in the City and County 31 of San Francisco, State of Callfornia. 12

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' l 2 On or about February 9,1960 respondent BOARD did by Resolution ; 3 Number 19082 grant to the Pacific Cas and Electric Company a use permit to

, 4 construct e steam generating power plant on Bodega Head. I ! |4 5 ' VEI , \ | 6 The said use permit granted Pacific Gas and Electric Company by 1 | 1 ' 7 respondent BOARD was and is illegal in that Pacific Gas and Electric Company 8 failed to furnish to the Planning Commission of Sonoma County or to the 9 respondent BOARD, together with its appiteation for the said use permit, anL 10 sets'of plans and elevatione showing the detail of the proposed use, as

11 required by Ordinance Number $73 and the Zoning Ordinance of the County of { i . 12 Sonoma, which ordinances were at all times herein mentioned duly adopted and I r .i 13 in full force and effect. i E { I ", 14 1X

]jg*t, a 15 The said use permit granted Pacific Gas and Electric Company by e 4 2 , le respondent BOATi is illegal in that neither the Planning Commission of U g j; 17 Sonoma County 3r the respondent BOARD gave notice of hearing upon the said ' .; G i 18 application for use permit by Pacific Gas and Electric Company by publication i

I 8" 19 I i in a newspaper of general circulation, or by posting such notice in conspicuous ; ; 20 places close to the property affected thereby, or by use of the United Sta'es | , t .i 21 mails. , or in any other manner, as required by Section 65951 of the 1 22 Government Code of California.

.23 X' I 24 The said use permit granted Pacific Gas and Electric Company by

. ! , ,g 26 respondent BOARD is illegal in that neither the Planning Commission of 26 Sonoma County nor the respondent BOARD held a public hearing upon the said 27 application for the said use permit to determine whether the proposed use

. 28 | would be detrimental to the health, safety, peace, comfort and general welfare f j29 of the people of Sonoma County, or whether the proposed use would be detri.

. 30 mental to the character or development of the territory in and arour.d Bodega 31 Harbor or would not otherwise adversely affect the welfare of the said 32 territory or of the said county, all as required by Section 65951 of the

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~.'j 1 Government Code of Ca11tornia. ~| 2 XI ! I i 3 The said use permit granted Pacific Gas and Electric Company by | ' | 4 respondent BOARD is 111egal in that the respondent BOARD failed to require

! ~ | 6 the Planning Commission of Sonoma County, prior to the formulation of its - | 8 recommendations to the respondent BOARD respecting the said application for

7 use permit, to forward to tha Sonoma County Tidelands Harbor 'and Beach

8 Commission, for its review and recommendation, a copy of the said use

g permit application and a set of the plans and elevations showing the detail of I

' . 10 the proposed use, and further failed to require the said Planning Commission . |

11 ! to receive and consider the recommendations of the Harbor Commission with ; 12 respect thereto, all as required by said Ordinance Number 573. | r. 13 XII i

- 14 The said use permit granted Pacific Cas and Electric Company by the : fie 15 re spondent BOARD is illegal in that the respondent BOARD amended the 2.oning; . 2 [ 18 ordinance of Sonoma County without compliance with the requirements of the I ; O ] ! $ g '17 said Zoning Ordinance or of Chapter 4, title 7 of the Government Code of ' h 18 California, in that the respondent BOARD granted the said use permit (a) for a | 0" i 19 period of five years, and (b) without requiring the applicant to submit two sets 20 of plans and elevations showing the detail of the proposed use. . 21 XIII 22 Respondent BOARD's said issuance of the said use permit to Pacific 23 cas and Electric Company was in excess of the jurisdiction of the Board, was , 24 unlawful, improper, arbitrary ar.d capricious and constituted an abuse of the 25 Doard's power and discretion.

< 2d XIV ' i, 27 By reason of the foregoing acts and omissions of the respondent ! j 28 BOARD, petitioners were deprived of substantial rights, including t'he right to i , 29 [ notice of the said application for use permit, the right to be heard in | 30 opposition thereto, and the right not to be injured in person and property by the 31 proposed nuclear. fueled reactor, and have been deprived of property without 32 due process of the law.

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1 Purporting to act under authority of the said use permit, Pacific Gas , ,! { 2 and Electric Company now threatens to construct, and within sixty days last j 3 past h cor'nmenced construction), including necessary site preparation, and

gfV ' 4 threatens to operate, at Bodega Head a euclear-fueled boiling-water reactor i

5 electriegenerating unit. 4

6 XVI

7 If the said nuclear-fueled reactor is constructed pursuant to the said - 1

' I 8 illegal use permit, petitioners will besabstantially damaged in that the value i i ! g of their real property will be lowered and the security of their homes and

' 10 businesses menaced by radioactive materials and wastes, and will thereby be

11 d*Prived of property without due process oflaw. !

g 12 XVH ; 13 z|e Public hearing upon due and legal notice to adjoining property owners .' I i ! 14 and to the public, and plans and elevations of the proposed generating unit.J | | k 16 furnished, all would have disclosed that; | fg- 16 A. (Pacific Cas acd Electric Company proposes to construct a q f 17 nuclear fueled boiling water reactor electric generating plant at Bodega Head 18 | k constituting a serious threat to marine life in and around Bodega Bay. ., U t 19 B. (1) The proposed nuclear-fueled reactor at Bodega Head will 'I S , 20 discharge radioactive wastes into .h air and into the ocean water, contamina i I : ,

I i | 21 ting surrounding ocean waters and the atmosphere of Sonoma County. l 22 (2) Radioactivity is the name given to the processes whereby I ' 23 atoms produce certain radiation by reactions of the atomic nuclei. A material 24 containing atomic nuclei that produce these radiations is called radioactive. . 25 (3) lenising radiations are of great significance to human 26 beings because the amount of energy contained in a single unit of the radiation

, 27 i as emitted by the nucleus of an individual atom is sufficient to disrupt or ! 28 s fonite molecules by separating electrons from them or by causing other ; 29 damage to them. The effects of ionizing radiations on living cells are chemical . 30 in nature.

31 Radiations known as gamma rays are produced by radioactive 32 nuclei. In general gamma rays are highly penetrating, so that the gamma rays

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1 from a source exterior to the human body may pass through the entire body,

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. ,< . ~ 6 . Camma rays may also be produced by re.dioactive nuclei within

7 the tissues of the ?,uman body itself. Their effe' cts upon the' tissues of the body are simuar to those of th. samma rays from ==terior sources. g | 9 Beta rays or beta particles, which are electrons emitted by the f -

. 10 radioactive nuclei, have a limited range in the tissues of the human body, . Beta' i P'''I'I' ' ''** * ''dI''**I'* * **** * **** '*'I '9 'h* h"""" D*d I" 'dI''' 11 Y '"'Y ( 12 the tissues to a certain depth, and may cause skin burns and other damage., gg Beta particles from internal radioactive materials such as beta. emitters in 1 th. ,_.s. irraeist. . acen, tiss..s .na ma. ca.s. d. mag.. 7m Alpha particles, from alpha emitters in the human body produce . gg .i |A ' - 16 damage to the adjacent tissues, similar to the damage done by other forms of |> g 37 high. energy radiation. h 18 (4) The radioactive process cannot be assuy speeded up nor I 4. g, slowed down; their rates in general depend only on the nature of the radio. 1 1 20 active atomic nuclei that are involved. The rate of a particular radioactive 21 reaction of an atomic nucleus is described by its half Life. . The half-life is the

22 period of time during which half of the atomic nuclei undergo reaction. At the -

23 end of one half life one half of the nuclei have decayed, and the radioactivity of .j 24 the sample is reduced to half of its initial values at the end of two balf lives

25 three quarters have decayed, and the radioactivity le one quarter of the' ' | . 26 initial radioactivity, and so on. The half lives of some radioactive nuclei are . * 27 as high as billions of years, while the half-lives of othare are only a fraction. $ . " 28 of a second. . . ] 29 (5) From the biological point of view any quantity of radio. J 30 active fallout, no matter how small, is undesirable. ' 31 Penetrating radiation of the sort produced by radic, active j j 32 fallout does harm to the human body and the pool of human germ' plasm that .

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1 determines the nature and well-being of future generations of human beings. 2 Exposure of the reproductive organs of a living organism, in. 3 cluding a human being, results in genetic damage through the production of. 4 genetic mutations. There is no minimum amount of radiation dose that snust be 5 exceeded before mutations occur. Mutations are believed to occur in number 6 essentially in direct proportion to the dose of radiation, for small amounts with ' 7 an increase in the proportionality factor, perhaps fourfold, for very large | 8 amounts of radiation in a short period of time. 9 A genetic mutation is a change in the hereditary material of an 10 organism, a change in the genes and chromosomes on which heredity depends. 11 It is this hereditary material, germ plasm, that is transmitted to offspring,

" g 12 and that determines tho' nature of the offspring. rf 13 Almost all mutations in human beings are harmful. They re- 14 sult in fetal death, still-births, childhood deaths from various diseases of tIeo j g*u 15 hereditary origin, and serious physical and mental defects that increase the m .o . {{j 16 amount of human suffering. Extremely few mutations in human beings are ! f j j 17 beneficial. It is believed by geneticists and molecular biologists that the J' !| 18 reason that most mutations are harmful is that a mutation is essentially a *

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' $ 1 . The number of mutations produced by radiation is proport'ional . ] 2 to the amount.of radiation received by the reproductive organs,'and the proJ. ! 3 portionality between the numbe r of mutations and the amount 'of radi A}or. tiolde 4, even for small amounts of radiation. . The total harm to the population measurea 5 by the effect on future generations is proportional to the amount cf radiation - t. -) 6 received by the reproductive organs of human beings. = There Lis no such tiling

- , . . . , . |f 7 as a safe dose of ionizing radiation. ,i . Any amount of ionizing radiation, however .. 8 small, that reaches the gonads of a human being who may later reproduce

p ~ .. involves a risk proportional to that amount. The genetic damage from atomic 10 radiation is spread over a long time in the future, with only,a small fraction' { 11 '' appearing in the first generation.' -

* 12 . The average amount of exposure of the gonads of human being's - i 13 r! from the tests of nuclear weapons as they have been carried out during recent i !f- 14 years have been estimated to be in the neighborhood of 0.1' roentgen in thirty 3CIeg 1 - jjg.a 15 years from external gamma radiation and additional amounts ots oughly the 16 g . same magnitude, perhaps sornewhat smaller, possibly somewhat larger, from { gj .17 internal gamma radiation of ingested cesium 137 from the world wide fallout. ; 18 ! ' ' f= The effects of exposure of the gonads of human beings'to' ionizing radiation are *E 19 such that hundreds of seriously defective children may be expected to be p'ro. h ; 20 'l duced in Sonoma County and adjoining counties by the fallout from a nuclear pow- 1 J s 21 ered reactor. Some thousand> of additional seriously' defective children nuf be 22 expected to be produced by the mutaticns caused by this fallout of radioactive 23 wa ste s.

24 (6) There is also a'high probability that damage 1E being done 25 e. to the health of human beings now living that is comparable to the ge'netic n'imag as 26 that is being produced by fallout and that will impair future generations. There f 27 is a high probability that fallout radioactivity is producing and will produce . 28 additional cases of leukemia, bone cancer, and other diseases that will lend to I 1& 29 1.. deaths of human beings that would not have occurred or would'not occur in the | 30 absence of a nuclear reactor at Bodega Bay. ; , j L .31 Fission reactions of nuclear reacters lead to the production of .r.

-). 32 radioactive strontium, strontium-90. T e chemical properties of strontium,- :q ,+ , , 8 .J -! . , .

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| 1 L) including strontium-90, are closely similar to those of micium, Strontium 90 | 2 that drops on to the surface of the earth is taken up, together with calcium 3 (although there may be a discrimination factor that operates to decrease the

4 amount of strontium-90 taken up), by growing plants, such as vegetables that * I l. 5 are ingested by man and gr ss that is eaten bycous. The strontium-90 that has

, s |. 0 been enten by cows in considerable part is transferred to the milk produced by 1 7 the cows and that is then drunk by. human beings, especially children. The '

, . 8 strontium-90 in the vegetables eaten by human beings and in the milk that is j . 9 . drunk by them is then in considerah?e part deposited, together with calcium, in 10 the bones of the human body. All human beings who have lived durirg recent

11 ~ ! years have strontium-90 in their bones, whereds a few decades ago there was i 12 ~ ; no strontium-90 whatever in the bones of any human beings. j zf 13 The nucleus of the strontium-90 atom is radioactive. It emits z 14 beta particles. After emitting beta particles, the nucleus becomes a nucleus - ';5:| 2eo 15 , $jg of yttrium 90, which is also a beta-emitter, and which,' because of the higher 4 m u | 2 3 10 energy.of its beta particles, produces more damage than the parent strontium- 0 E E j; 17 90 beta particle. These beta particles that result from the ingestion of 18 strontium-90 do damage to the tissues in the neighborhood of the bones,'in- *1 t- *i 19 e cluding the bone marrow that produces constituents of the blood, * 20 There is a high probability that the radiation from strontium-90 21 and its daughter by decay, yttrium-90, as well as from other radioactive nuclei 22 prodaced by fallout, such as the external gamma emitters, produces cases of 23 leukemia and bone cancer. 24 (7) lodine 131 (radio active iodine) produced by nuclear, i 25 reactors concentrates in the thyroid and may cause cancer in that part of the 26 humananatomy. Scientists believe that infants amd embryos are probably 27 especially susceptible to cancer of the thyroid so generated. 28 (8) Neutrons released in the reactions occurring in a 29 nuclear reactor react with nitrogen nuclei in the air to make carbon-14 (radio- { 30 active carbon, which has a half-life of about 5,600 years). Scientists employeo 31 by the Atomic Energy Commission and others have made estimates according 32 to which carbon 14 from testing of nuclear weapons through the year 1958 will.

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1 cause substantial genetic damage to the peoples of the world and the petitioners 2 say on information and belief that they believe that the carbon-14 produced by 3 nuclear weapons tests up to and including 1958 will cause 100,000 gross defects. 4 380,000 still-births and childhood deaths and 900,000 embryonic and neo-natal 5 , deaths with some possible overlap between the still-births and the neo natal

| 6 deaths. Scientists are in substantial agreement and the petitioners state on 7 their information and belief that carbon-14 may well represent a larger genetic 8 danger than fission products from ordinary fallout if one compares an infinity 9 dose delivered over an effective period of 8,000 years (the tre an life of radio- 10 active carbon) to one delivered over an effective period of about 40 years (the 11 mean life of ordinary fission products). '

; 12 (9) The human race has always been exposed to some ioilizing g f, 13 radiation. It is continually being irradiated by radiation from natural sources z 14 t$|t eo from the general environment, such as uranium, thorium, radium, etc. , and [jj 15 e u their decay products; from cosmic radiation and from cosmic ray induced 2 31 16 ~ > |' radioactive materials. The aggregate of these radiation sources is known as 1g {fjg 17 the natural background radiation. 18 In addition to the natural background radiation, members of the #*t b 19 human race are exposed to X-rays used in the healing arts and some members S 20 thereof, because of their occupation, are exposed to X-rays in industry. 21 The radiation resulting from the two sources, namely, the 22 natural background radiation and X-ray radiation has affected and now affects 23 mankind along the lines indicated as resulting from radiation. The effect upon 24 the hums.n race resulting from the radiation produced by the reaction and re- 25 lease of radioactive gases is in addition to the effect resulting from the . 26 natural background and X-ray radiation. 27 C. ! Property owners in Sonoma County are now and will be unable 28 to insure real and personal propertyagainst risk of loss by damage from a -29 nuclear fueled reactor, whether caused by accident or ordinary operation, I 30 drastically lowering property values in Sonoma Cou.ity. * 31 D. The proposed Nuclear fuehl reactor will contain approximately 32 150 times as much fissionable material as that contained in the bomb dropped

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1 on Hiroshima,; menacing the public health, safety and general welfare of th 2 e- people of Sonoma County, and will be' detrimental to property and improvem 3 in the neighborhood. ent s 4' E. .The proposed nuclear reactor ,is to be located one quarter of a I 5

6 mile from the San Andreas Fault line, measurably increasing the possibility. of disastrous accidents, threatening communities as far away as f anta Rosa 7 ,- Petaluma, San Rafael and San Francisco with radioactive fallout or de t 8 F. s ruction. The proposed nuclear reactor at Bodega Head will cause' 9t { petitioners to suffer grave and irreparable injury to their property and business1 . 10 G. ! The proposed nuclear reactor at Bodega Heal will' despoil the 11 character of the tideland, harbor, bay and beach' areas of Bodega Bay , 12 ' . H. , t History of nuclear fueled reactors in the United States, Canada < [ 13 , z: > and Great Britain shows that accidents are not infrequent, occur witb 51 out ;ieo 14' | 3 anticipation or explanation although all prescribed safety measures ha j|| 15 ve been n ua , met, and are uniformly disastrous causing death, irradiation of persons a d ? 10 n 3 property, and contaminating substantial surrounding areas with radi j ;; 17 materials and waste, oactive

' i| 18 ! I XVIII i 19 I Petitioners have no plain, speedy or adequate remedy in the cours 20 law. e of 21 WHEREFORE, petitioners prayt

22 1 23 That a writ of mandate issue out of and under the seal of this 24 court, directed to the respondent above named, commandingn responde t BOARD to set aside its decision granting to the Pacific Gas and Electri 25 c Company a use permit on or about February 9,1960 to construct a st 26 eam electric generating plant on Bodega Head. 27 2. I That pending judgment, the court stay the operation of Resolution 28 > i Number 19082 of the Board of Supervisors of Sonoma.. County ' 29 3. 30 | That a writ of certiorari issue from this court directed to respondent BOARD, commanding it to certify fully to this court , et a specified 31 | ; I time and place, a transcript of the record and proceedings I 32 ' of said BOARD in . ' granting a use permit to the Pacific Gas and Electric Company on or about i ) ' 11 1 i

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1 February 9,1960 to the end that same be reviewed by this court, and the 2 Resolution of the Board granting such use permit be set aside and r.nnulled as 3 1 ' being made and ordered without jurisdiction in the premises. . 4 ' 4. For costa necessarily incurred by petitioners herein. 5 5, ra - ; For such other and further relief as may be meet and proper in 6 the premises. 7 j Dated: N(Ad,f"3,/7[% 8

9 GARRY, DREYFUS & McTERNAN

g By *,! k (A4 I ( ; 12 . 1 2 e 13 y HEISLER & STEWART ||: '14 Byn~;a \&A ; 8{|{|13 v - = 16 0, Attorneys for' Petitioners 5f|!|1; 17 t 5| 18 11 19 2 20

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, , . , 1108 The within instrument is a correct *. copy of the cricical en file in this office. Resolution No. 19082 faTISir FEB 10 1960 Administration Building E'4?.:3 D. WIULIAMS Santa Rosa, (,elifornia ' County Clerk & ex-officio Clerk of the j Icard of Supervisors of the State of _ Februcry 9 i ,1960 ' California, in & for, the County of .j BY $n M D*:PUIT ]

\ s% P.ESOLUTION OF 52 LOARD OF SUP!3VIS023 0F TEE COURTY OF

!' SONOMA ACCEPTIT.3 TIZ FI40EENDATIOKS 3 0F MIS E0PJiD OF ECHIIS ADJUSLEKT3 AND 1 FLANNIEG COMMI?SSION AKD GRM; TIE 3 A USE j PEPRIT TO TES P. O. & E. COMPANY FOR A | | STEAM ELECTRIC CD;;: RATING PoilD1 PLM;T ' ON BOD::GA EEAD

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, * February h,1960, recommended that the Bocrdo.125,. dated of Supervisors grantUE:|REAS, the Bosrd of toning Adjustments has, by Recolution N the Pacific Oca and Electric Company for a steca electrica use permit to f Bodess Eead, vicinity of Sodesa senercting power plant on i with Esction b of Ordinance $73 that t hnedship rould be imposedBay, cutjectj to specific conditions and in accordance p1tas cad specifications for the plcat vera requiredon r.t the thin cyplicant time if cad further ; reco=nendin'; that this Board of Supervicorn - adopt the cordition that r.nd specifications be submitted to the Boe.rd of Zoningcomplete Adjustm plans Supervisors prior to construction, and ents cad the Board of

, j 1960, did also consider said application cmde e ruarydid rctify4, theVEERIAS, the Plenning Comniscion, by Resolution Ko. 3697 oct d F b andZoning Adjustments to recommend grcating of thecetion use permit of the Board of vith specific conditions, California, has considered said application. ma, State in of cecordance with OWEIF.EAS, sc.14 Bocra of Supervisors of the County of Sorc LodegaSonoma, and Bay Interim Zone and Ordincnce 230, the Zoningrdincnce o No.di $73, r nance of the County of

determines that the establishment or nr.intenancema, finds and of thWEEREAS, caid Icard of Supervisors of the County of Sono is made vill not be injurious to property. or improvements or det ie use for which application cafety, morals, comfort, convenience, or generalr mente veltcre.1 to henith,of persons r vorking in the neighborhood of such use, now esiding or assembled this _ 9thTESREFORE EE IT RESOLVED tbst this Board of Supervisors in re day of _ February gular session icsur.nce of sc.14 Uao Fermit to the Pacific ces cal Electric C, 1960, does hereby grant the toelectric the following generating conditions: power plant on Bodega Est.d,ompacy vicinity for a steem of Eode , ga Eay, subject 1.

e priorto the to eny Zoning construction. Bot.rd of Adjustmentsu ervisors cad the Bonra of S pThct a complete plot plan, plcas and specifiestions be submitt d 2. That all necessery permits from all State emd nciesFederal ese construction.'shall be cecured and verified to the Zoning Board prior to cny .

3 . topo;r:phy in the location of the pitntn ng to es to blend thTh::.t the company chc.ll tc.he into consideration the currou di | proposed use into the existics topocrtpby. e

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!* . That the pemit be grcoted for~a period of 5 years.

. 5 Dat the insta11r. tion of the picst shall not preclude public tecess to the Tidelcada or other County lesds ,) in.the vicinity. i . . 6. '! 'that a ic.ndaemping plan be cut:itted to and approved. ! by the sttff prior to construction. ' 7. 'That this pomit be subject to revocation upon failure i to co:aply with the chove conditions.

.1, ho coved its cooption, seconded by DJpervisor _ . LemeenThe. foresoing resolution vcs introduced by Supervisor _. Cuidotti :.11 by the fonoving votes , and adopted on roll | i Supervisor Shoescher ! Supervisor King Aye i Supervisor 14::poon he 1 Supervisor Guidotti, Aye , Supervisor Mitchell ,Aye i 4e. | OS: ! 5 IES 0 12ECN/2:0T VOTn'3: - 0' . opted, 1.'E!JE7017,tsd the Chain::.n declered the chove e.nd foregoing resolution duly

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SO ORDErdD

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1 V E RI FI C A TI O N

3 1, , Wu DAVID PESONEN, make this verification on behalf of ! NORTHERN CALIFORNIA ASSOCIATION TO PRESERVE 4 + h a ,. , in the BODEGA HE AD AND HARBOR. a enrnnentine. n- a n f t h . _n .5 . above entitled action.

6 I have read the foregoing Petition for Writ of Mandate or certinvae

8 and know the contents thereof; and the same is true of rny own knowledge,

9 except as to the matters which are therein stated upon my information or I $ 10 belief, and as to those matters I believe it to be true, j

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15 , 16 I certify under penalty of perjury the foregoing is true and correct.

17 1 Executed on sgut., s icea , at en, r e n u r n . (cate) (caty) 18 California.

19 20 4" [ W" * 8 ""*"#*) 21 DAVID PESONEN, on behalf of ' I'A |. NORTHERN CALIFORNIA ASSOCIATION j 22 TO PRESERVE BODEOA HEAD AND HARBOR, a corporation 23

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. . k. That the par..it be created for a period of 5 years. , 5. That the installation of the plcat sh211 not preclude , publicin the r.ceess vicinity. to the Tidolcnds or other County it.nds . 6. That a landscaping plen be sutnitted to cad epproved by the ctnff prior to construction. , 7 That this perit be subject to revocntion upon failure to co:: Gly vith the c.bove conditions.

to moved its c.doption, seconded by SupervisorThe_ Ouidotti foregoing resolution' ve.s introduced by Supervicor __ Intteen , - . :.11 by the folloving votes , and adopted on roll | Supervisor Shoencher Supervicor Kin Aye Supervicor Lc=pson ke Supervisor Guidotti Aye Supervicor Mitchell 4e Aye IS 5 . Kor.S 0 /.BSrTI/IOT VOTIr3: - 0 . opted, and L'EIPIUPON, the Chairn:,n declared the t.bove e.nd foregoinguy resolution d l

SO ORDERED

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1 V E RI FI CA TION

| 3 1. DAVID PESONEN, make this verification on behalf of , *rn

. | 4 NORTHERN CALIlrORNIA ASSOCIATION TO PRESERVE- BODEG A HE AD AND MARMOR. a en epn vati n- . n-e nf 6. p H H m. ' in the 5 above entitled action. 6 I have read the foregoing Petition for Writ of Mandate or r'e rtin-a v4

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8 and know the contents thereof; and the same is true of my own knowledge,| 9 except as to the matters which are therein stated upon my information or 10 belief, and as to those matters I believe it to be true.

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15 a 16 I certify under penalty of perjury the foregoing is true and correct. 17 Executed on Manh 5 ion , at c , . v ,. , s . ,. m , | 18 California.

20 hw (? .1rsu ' (signature) 21 DAVID PESONEN, on behalf of NORTHERN CALIFORNIA ASSOCIATION 22 TO PRESERVE BODEOA HEAD AND HARBOR, a corporation 23 ; I 1 24 '

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VE R I FI C A TIO N - 2

3 I, MARY DARLING , arn 4 one of the petitioners in the $ above entitled action. -) 1 ! 6 ~ I have read the foregoing Petition for Writ er Mandate or certiorari ! 7 s \ 8 1 and know the contents thereof; and the same is true of my own knowledge, | 9 except as to the matters which are therein stated upon my information or 10 belief, and as to those matters I believe it to be true. |

El a 1 | 12 1 ' | 13

15 . * 4 i | 16 I certify under penalty of perjury the foregoing is true and correct. 1 .{ 17 Executed on Mr.r ch 5 , 1963 , at c;an pranenen , 18 1 California.

19 - , 20 , . 21 MARY DARLING ,, (signature) .j 22

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. i }. ' d ) l ' \ 1 ' VE RIFI CA TION 2 ! j 3 1, _ $ILAS DARLING l 4. 1 one of the petitioners ._ . am 5 above entitled action, _ in the

6 4 j 7 I have read the foregoing Petition for writ of M s andate or Certiorari _ ! 8 'k a d know the contents thereof; and the sarne is true of m i 9 y own knowledge.

' except as to the matters which are therein stated upo 10 n my information or belief, and as to those matters I believe it to be tr 11 ue, -{ j 12 '' i

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16 .' 17 I certify under penalty of perjury the foregoing i Executed on _ _yggy__4 , 1963 s true and correct. 18 California, (cate) . at _ San Francisco (caty) is 19 i i 20f , q ~ 21 d1LAs DARLING 22k (s gnature)~

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'2 V E RIFICA TION

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.. 4 CHARLES GOODALE | __ , , am _ one of the petitioners . 5 above entitled action. _ in the i 6 I have read the foregoing 7I _ pe tition (n r w He n e vn - a.,, e, e .,en .. .t 8

- 9- and know the contents thereof; and the same is true of rny own knowledge, ! ! 10 except as to the matters which are therein stated upon my information or | belief, and as to those matters I believe it to b 11 e true. ] \ 12 *

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16 \ 17 I certify under penalty of perjury the foregoi Executed on _ 'v ng is true and correct. ? ,1963 n 18 California. (uchcate) _, at _c,% .,m.q _, 19 '(city)

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_ * /l'I ' 21 W CHARLES GOODALE 22, (signature) ~

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3 I, __ * ' DOFlS SLOAN i 4 i __ _ _ . am ( 5 one of the r>etitinners l above entitled action, _ in the I ) 6 ( I have read the foregoing Petition for writ of m s ' i 7 - e , n ,. c , - 4, . , ,.1 \

8 and know the contents thereof; and the same is true of my.__ own k 9 nowledge, except as to the matters which are therein stated upon my i f 10 n ormation or belief, and as to those matters I believe it to be true 11 ,

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16j I certify under pens.Ity of perjury the foregoing is tru 1 17 Executed on e and correct. J urch _3 18 California, (datef , 1963, at__ c ,, , r ,. , ~ ; ,. , , (city) 19

, 20 d%/ _ ey cm , , .MCh. n q; ) DORIS SLOAN (signature) ~ 22

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3 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA ' 9 IN AND FOR THE COUNTY OF SONOMA 10 11 NORTHERN CALIFORNIA ASSOCIATION- )' TO PRESERVE BODEOA HEAD AND' ) 12 . HARBOR, a corporation, et al, , ) 13 ) Petitione r s, ) , NO. 14 vs. ) ) . ! 15 ) DECLARATION OF THE BOARD OF SUPERVISORS OF THE ' ) _ ROSE GAFFNEY COUNTY OF SONOMA. STATE OF 10 ) CALIFORNIA, ) ) 17 { ~ Respondents. ) 18

19 I, ROSE GAFFNEY, declare under penalty of perjury: 20 ' On February 1,1960. I owned real property at or near Bodega Head 21 in Sonoma County. 22 | 1 was given no notice of the application then made by Pacific Oas and

. 23 . Electric Company for a use permit for the construction of a steam-electric 24 generating power plant on Bodega Head, whether by publication, posting. notice . - 25 in conspicuous places close to the property, or by the United States mails, or 28 otherwise, and no such notice was given. 27 Dated Y/ I 6/ /? ' .'Y 28

29 I declare under penalty of perjury the foregoing is true and correct.

30 * ' Executed on .b'' < ,2/ /I [at /I , California. ' , ' 31 O, ' $ , c ;.? . .4 32 - fj;g; /,ij .i' .;, GAFFV")6 "..,,y%c : .c,; , ROSE Y r/

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8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA . 9 IN AND FOR THE COUNTY OF SONOMA ' 10

' 11 * NORTHERN CALIFORNIA ASSOCIATION )- TO PRESERVE BODEOA HEAD AND ) 12 . HARBOR, a corporation, et al, ) ) 1S Pe titione r s, '

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15 DECLARATION OF THE BOARD OF SUPERVISORS OF THE ) ROY K. COUNTY OF SONOhiA, STATE OF. FAUGHT 16 ) CALIFORNIA, ) 17 ) Re spondents. ) | 18 | 19 | 1, ROY K.' FAUOHT, declare under penalty of perjury: - 20 on February 1,1960. I owned real property at or near Bodega Head 21 in Sonoma County. 22 I was given no notice of the application then made by Pacific Oas and ' 23 Electric Company for a use permit for the construction of a steam-electric

24 ~ generating power plant on Bodega Head, whether by publication, posting.n'otice 25 in conspicuous places close to the property, or by the United States mails. -or 26 otherwise, and no such notice was given. 27 Dated: Februa ry 24, 1963 28

29 1 declander penalty of perjury the foregoing is true and correct. g,/, 30 . --% Exe'cuted onrD' /'. ,L/ .. / ? . at .I G,' J M /. / , . California. 31 '* ;, ,. r N's 32 . */ // tc' **/ ,.# e , fT- V ' ' _ / , <)AOY K. FAUGHTs-

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| | 7 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA . . . 9 ' IN AND FOR THE COUNTY 'OF SONOMA - 10

. ' 11 NORTHERN CALIFORNIA ASSOCIATION )' TO PRESERVE BODEGA HEAD AND ) . 12 HARBOR, a' corporation, et al., ) * 13 )- Petitione r s , ) 14 vs. -) NO. ) ) DECLARATION OF 15 , s THE BOARD OF SUPERVISORS OF THE ) 'LLOYD WOOD COUNTY OF SONOMA, STATE OF ' .| 10 . |CALIFO RNIA, ) ) 17 .) Re spondent s. ). 18 I

1 19 ! I, LLOYD WOOD,' declare under penalty of perjury: ' 20 On February 1,1960, I ' owned real property.at or near Bodega Head 'l- 21 in Sc. noma County.

22 | I was given'no notice of the application then made by Pacific Oas and- 23 i . j Electric Company for a use perrnit for the construction of a steam-electric < 24 | generating power plant on Bodega Head, whether by publication, posting notice

= { 25 | in conspicuous places close.to the property, or by the United States mails, or 26 otherwise, and no such notice was given.

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29 1 declare under penalty of perjury the foregoing is true and correct. 1 30 i Executed on 's ' ' .' r. 'd at' ' * , California. 31 . 32 's i.

LLOYD WOOD 'i

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8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF SONOMA ' 10

11 ' 1 . NORTHERN CALIFORNIA ASSOCIATION ) TO PRESERVE BODEGA HEAD AND. ) ; 12 HARBOR, a corporation, et al. , . -j y ' ) {& 13 ) z Petitione rs, }- $: 14 vs. )- ). NO. 3t|.o j j f 15 ) m COUNTYTHE BOARD OF OFSONOMA, SUPERVISORS STATE OFOF THE . ) DECLARATION OF 2g, a 16 CALIFORNIA, ) -MARY DARLING - ) 0 g ' oa; 17 ' ) , Re spondent. ) 18 h<* 19 I, MARY DAR' LINO, declare under penalty of perjury: 20 On February 1,1960, I owned real property at or near Bodega Head in - ) 21 Sonoma County.

22 ~ I was given no notice of the application then made by Pacific Gas and 23 Electric Company for a use permit for the construction of a steam-electric | i 24 | generating power plant on Bodega Head, whether by publication, posting notice 25 in conspicuous places close to the property, or by the United States mails, or 26 otherwise, and no such notice was given. 27 Dated: March 6. 1o69 28

29 1 declare under penalty of perjury the foreging is true and correct. 30 Executed on' March 6, ,1963, at - San Francisco . California. 31

* . 32 * . MARY DARLING,

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.7 | 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF SONOMA

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11 NORTHERN CALIFORNIA ASSOCIATION ) ' TO PRESERVE . BODEGA HEAD AND -) .. 12 HARBOR, a corporation, et al. , ) * 2 ) g| 13 Petitione rs. -)- 4 .z . -) $i 14 vs. J. OIag )- NO.' ) ) $jjg. 15 THE BOARD OF SUPERVISORS OF THE ) DECLARATION OF ' o A COUNTY OF SONOMA, STATE OF ) SILAS DARLINO . I 16 I CALIFORNIA, . 2 f " ) I tv ) 82ggf'17 1 Re spondent. ,: * ) ). > 18 Ek d - 19 I, SILAS DARLING, declare under penalty of perjury . 8 20 On February 1' ,1960, I owned real property at or near Bodega Head in 21 Sonoma County. 22 I was given no notice d the application then made by Pacific Gas and . 23 Electric Company for a use permit for the construction of a steam-electric 24 generating power plant on Bodega Head, whether by publication, posting notice 25 in conspicuous places close to the property, o'r by the United States mails, or

, 26 otherwise, and no such notice was given. 27 Dated: March 6.1963 28

29 I declare under penalty of perjury the foregoing is true and correct. .30 Executed on March 6, ' ,1963, at San Franelseo , C alifornia. 32 .. * 32 * SILAS DARLING

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'B | IN THE SUPERIOR COURT OF THE STATE OF CALIFOINIA 1 9 \ IN AND FOR THE COUNTY OF SONOMA l ] 10 ' i

11 ' NORTHERN CALIFORNIA ASSOCIATION )' TO PRESERVE BODEGA HEAD AND ) , g 12 , i HARBOR,- a corporation, et al. , - ) I 2| 13 - )- j Petitioners, ) 14 vs. ) $|I ) NO. tIag , 3 ' , 15 ) ! jjc THE BOARD OF SUPERVISORS OF THE ) m _. 4 COUNTY OF SONOMA, STATE OF DECLARATION OF. i 2 16 CALIFORNIA, ) CHARLES GOODALE j ' g ) ' b| {[ Elgg 17 ) gg Re spondent. ) Ej 18 ) *# I 19 2 I, CHARLES GOODALE, declare' under penalty of perjury: . 20 On February 1,1960, I owned real property at or near Bloomfield in 21 Sonoma County. 22 I was given no notice of the application then made by Pacific Oas and 23 Electric Cornpany for a use permit for +.he construction of a steam-electric 24 generating power plant on Bodega Head, whether by publication, posting notice

25 , in conspicuous places close to the property, or by the United States mails, or * 26 otherwise, and no such notice was given. 27 Dated: Me rch 7, 1963 28

29 I declare under penalty of perjury the foregoing is true and correct. . 30 . Executed on_ March 7 ,1963, at Seba stocol ' , California, ** n . ' 32 ' f |t 5|f| .. & gf|j

CHARLES GOODALE ~ . / $f| . I A ! .

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