Electric Power Development in the Southwest: a Review and Analysis

Public participation in the planning of coal-fired electric power development in the Southwest: a review and analysis

Item Type Thesis-Reproduction (electronic); text

Authors Kimball, Dan Belknap.

Publisher The University of Arizona.

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Link to Item http://hdl.handle.net/10150/191596 PUBLIC PARTICIPATION IN THE PLANNING OF COAL-FIRED

ELECTRIC POWER DEVELOPMENT IN THE SOUTHWEST: A REVIEW AND ANALYSIS

Dan Belknap Kimball

A Thesis Submitted to the Faculty of the DEPARTMENT OF HYDROLOGY AND WATER RESOURCES

In Partial Fulfillment of the Requirements For the Degree of

MASTER OF SCIENCE WITH A MAJOR IN WATER RESOURCES ADMINISTRATION In the Graduate College THE UNIVERSITY OF ARIZONA

1 97 4 STATEMENT BY AUTHOR

This thesis has been submitted in partial fulfillment of requirements for an advanced degree at The University of Arizona and is deposited in the University Library to be made available to borrowers under rules of the Library.

Brief quotations from this thesis are allowable without special permission, provided that accurate acknowledgment of source is made. Requests for permission for extended quotation from or reproduction of this manuscript in whole or in part may be granted by the head of the major department or the Dean of the Graduate College when in his judgment the proposed use of the material is in the interests of scholar- ship. In all other instances, however, permission must be obtained from the author. o

SIGNED: KWdak

APPROVAL BY THESIS DIRECTOR

This thesis has been approved on the date shown below:

47. Aw..71 97Y RUSSELL L. GUM Date Associate Professor of Hydrology and Water Resources ACKNOWLEDGMENTS

Research described in this thesis was conducted as a year-long project in the Civil Decision Quantification Program in the Department of Hydrology and Water Resources at The University of Arizona. The

Civil Decision Quantification Program is funded by the Ford Foundation.

The author wishes to express his sincere appreciation to Pro-

fessors Russell L. Gum and Theodore G. Roefs, Department of Hydrology

and Water Resources at The University of Arizona, for their professional

guidance and invaluable assistance throughout the study. Special thanks

are also extended to Professor Hasan K. Qashu, Department of Hydrology

and Water Resources at The University of Arizona, who served on the

author's graduate committee and whose comments on the study and thesis

were very helpful. Finally, the author wishes to express his gratitude

to his wife, Joey, who typed many drafts of this thesis and provided

moral support throughout the researching and writing of this work.

iii TABLE OF CONTENTS

Page

LIST OF TABLES vi

LIST OF ILLUSTRATIONS vii ABSTRACT viii

1. INTRODUCTION 1 Objectives 3 Description of Thesis 4

2. PUBLIC PARTICIPATION IN PLANNING: AN OVERVIEW 5 Legislative and Administrative Requirements for Public Participation 6 Reasons for Public Participation in Planning 8 Securing Public Participation in Planning 10 Public Participation in the Planning Process 13 Summary and Conclusions 19 Need for Public Participation in Electric Power Development Planning 20

3. COAL-FIRED ELECTRIC POWER DEVELOPMENT IN THE SOUTHWEST . . . 24 Physical Development 27 The Controversy 32

4. PLANNING FOR COAL-FIRED ELECTRIC POWER DEVELOPMENT IN THE SOUTHWEST 36 Power Company Planning Procedures 36 Role of the Federal Government 4o State Involvement 43

5. PUBLIC PARTICIPATION IN THE PLANNING OF COAL-FIRED ELECTRIC POWER DEVELOPMENT IN THE SOUTHWEST 50 Information Orientation 50 Southwest Energy Study 52 Environmental Impact Statements 53 Utility Company Reports and Brochures 55 Iv TABLE OF CONTENTS--Continued

Page

C.P.E.A.C. Newsletter 57 Private Reports and General Media 58 Public Information Meetings 59 Review Orientation 60 Public Hearings 60 Comments and Surveys 62 Interaction Orientation 63

6. FRAMEWORK AND RESULTS OF ANALYSIS 66 Evaluative Criteria 66 Evaluation Procedure 67 Results of Analysis 68 Opportunity for Public Participation 69 Awareness of Public Involvement Activities 73 Availability of Adequate Information 75

7. RECOMMENDATIONS AND CONCLUSIONS 81 APPENDIX A: EVALUATION PROCEDURE SAMPLES 91 SELECTED BIBLIOGRAPHY 94 LIST OF TABLES

Table Page 1. Public Participation Mechanisms by Primary Functional Orientation 11+

2. Public Involvement Functional Orientations in a Hypothesized Planning Process 15

3. General Power Plant Specifications: Plants in Operation . 28

4 • General Power Plant Specifications: Plants under Construction 29

5. General Power Plant Specifications: Plants in Planning Phases 31

6. Comparison of Certification and Hearing Requirements of State Public Service Commissions: 1968 and 1972. . . 45

7. Public Participation Activities in Southwestern Coal- Fired Electric Power Development by Functional Orientation 51

8. Environmental Impact Statements Relating to Coal- Fired Generating Stations and Related Facilities in the Southwest 56

vi LIST OF ILLUSTRATIONS

Figure Page

1. Operational Objectives of Public Participation Activities in Planning 11

2. Location of Coal-Fired Power Plants in the Southwest • • • • 25

vii ABSTRACT

Public participation activities have recently become an integral component of natural resource planning efforts. A definite need exists

to evaluate the adequacy in a procedural sense of such activities on a

case by case basis. This study evaluates public participation in the

planning of coal-fired electric power development in the Southwest.

An overview of public participation in planning is given, the

physical and social aspects of the development are discussed, and the

regulatory and institutional framework surrounding power development

planning are defined. Evaluative criteria for adequate public partici-

pation programs are also specified. An evaluation procedure consisting of questionnaires, interviews, and a classification and review of the

public participation activities undertaken is utilized.

Results are discussed in terms of the opportunities for public

participation; public awareness of such opportunities; and the availa-

bility, usability, and adequacy of information. Recommendations are

made regarding future public participation in power development planning

and include the need for utilizing more activities which stress the di-

rect interaction of conflicting parties, involving the public earlier

in the power development planning process, increasing public awareness

of participatory activities, and providing more available and adequate

information in a more usable form.

viii CHAPTER 1

INTRODUCTION

In recent years public participation has become a much discussed aspect of planning, particularly natural resources planning. Public participation in this sense represents more than the traditional citizen involvement mechanisms of voting and letter writing or the relationship of planning bodies with narrowly defined clientele and interest groups.

Public participation in planning today implies the involvement of members of the public in hearings, opinion surveys, information meetings, work-

shops, written reviews of reports, citizen advisory boards, and other participation measures. Public involvement in such activities is thought to improve the responsiveness of plans to public needs, insure credibil-

ity in the planning body, increase the probability of implementing plans, provide relevant information to the public, and facilitate the resolu-

tion of conflicts among segments of society. Although some fairly successful beginnings have been made in

achieving acceptable public participation in planning (Warner, 1971),

many problems remain, and systematic research on various aspects of the

"participation" process is needed. A specific area which needs further

study, on a case by case basis, is the adequacy of public participation

programs actually undertaken in the planning of natural resource develop-

ment.

1 2

In response to such a need this study reviews and analyzes, in terms of defined criteria, the public participation activities utilized in the planning of a major electric power plant complex in the semiarid region of the Southwestern United States. This region, which includes

Utah, Nevada, Arizona, New Mexico, and Colorado, is commonly referred to as the "Four Corners" area and is the site of a number of large-scale, coal-fired power plants which are on-line, are being constructed or have been planned. The controversial issues, environmental, social, legal, and institutional which have surrounded the planning and development of this power plant complex are representative of the complex energy issues which confront the United States today. The need for actively adressing these issues in the planning of power plants and transmission lines has become paramount. The Western Systems Coordinating Council (1971, p. 3)

states:

Society today depends on high energy use, and it values the convenience, safety and reliability of electric energy. There is increasing evidence that society also values healthful and pleasing surroundings and supports the ethic of leaving a good environment for succeeding generations. Broadly prevailing public attitudes and social values, therefore, must be fully and fairly factored into the development and expansion of electric generation and transmission systems, and the views of public groups concerned with the protection of environmental quality must be accorded consideration.

With respect to the planning of electric power development in

the Four Corners area, a large number of groups and individuals have

participated in public hearings, public information meetings, and other

public involvement activities. However, the adequacy of these means of

public involvement, considered in the context of power development plan-

ning in the Southwest, has yet to be determined. Specifically, an 3 evaluation is needed in regard to the adequacy of such public participa-

tion activities in providing timely and appropriate opportunities for

public input and also in making pertinent information available to the

public in a usable form. This study addresses itself to this need.

However, it should be noted that this study unlike many previous studies

of public participation does not concern itself with the attributes of

groups or individuals which would be related to their likelihood to

participate or the change in the behavior of decision-makers due to

participatory activities.

Objectives

The principal objectives of this study are to determine the ade-

quacy of public participation activities utilized in the planning of

coal-fired electric power development in the Four Corners region of the

Southwest and to specify recommendations concerning future public partic-

ipation in power development planning. Sub-objectives include:

1. The specification of the regulatory framework and institutional

structure of the electrical utility industry within which the

planning of coal-fired electric power plants in the Southwest

has taken place.

2. A review of the public participation activities utilized by the

electric utility companies and governmental entities in the

planning of electric power development in the Four Corners area.

3. The development of a framework of analysis which includes speci-

fied evaluative criteria and an evaluation procedure. Description of Thesis

Chapter 2 provides a general overview of public participation in planning. The reasons for, objectives, and mechanisms of public participation are discussed. The relation of public participation mechanisms to an hypothesized planning process and the need for public participation in power development planning are also given. Chapter 3 is devoted to a brief discussion of the physical aspects of coal-fired electric power development in the Four Corners area and also the principal issues of the Four Corners power controversy. Chapter 4 is concerned with the federal and state regulatory framework and the planning activities of utility companies with respect to fossil-fueled electric power development in the Southwest. A review of the public participation activities undertaken in the planning of the Four Corners energy complex is given in Chapter 5. A framework of analysis, including evaluative criteria and an evaluation procedure, and the results of this analysis are given in Chapter 6. Chapter 7 is devoted to recommendations and conclusions. CHAPTER 2

PUBLIC PARTICIPATION IN PLANNING: AN OVERVIEW

Public participation in planning can perhaps best be defined as an organized set of activities which seeks to improve the planning process by (1) identifying more clearly the public interests affected by a given plan, (2) providing an opportunity for an expression of those interests, and (3) transmitting information concerning a given plan to the public (Warner, 1971, p. 3; Bishop, 1970, p. iii). Participation in this sense represents the involvement of the public in a two-way communication process with the planner concerning the public's objectives and needs, the public's preferences regarding alternative plans, and general information with respect to potential plans. Methods of achieving this communication include public hearings, opinion surveys, planning reports, public meetings, workshops, citizen advisory boards, and a number of other participatory devices.

However, an inherent difficulty with all public participation activities is the identification of the "public." Although no such entity as "the public" exists, those involved in various participatory planning efforts include the lay public, concerned individuals, and interest groups and organizations. Such "publics" are most easily identified with specific issues or projects; their participation in related public involvement activities is dependent on their awareness, their stakes in the particular decision, the economic and temporal resources they have

5 6 available, their ability to influence the decision-making process, and

the types of public participation activities utilized (Warner, 1971,

p. 6). However, the question of what is a "representative" public is

still a critical problem with which planning entities must deal.

In spite of this and other problems which are intrinsic to pub-

lic participation programs, it is considered that the integration in the

planning process of public input and planner expertise will produce bet-

ter quality information on which to base planning recommendations and

will ultimately result in better decisions.

Legislative and Administrative Requirements for Public Participation

Although public hearings have historically been a fundamental

aspect of the governmental decision-making process, public participation

in planning per se had its formal beginnings in connection with welfare

and other programs affecting the poor in urban areas. Specifically, the

Economic Opportunity Act of 1964 (P. L. 88-253), the legislative package

which initiated the "War on Poverty," contains a provision for the estab-

lishment of community action programs involving the "maximum feasible

participation" of local residents while the Model Cities program of The

Department of Housing and Urban Development requires "widespread citizen

participation" as a prerequisite for urban renewal funds.

This emphasis on citizen participation has also begun to appear

in other legislative and administrative programs and most recently has

become a fundamental component of environmental and natural resources

planning programs. For example, Environmental Protection Agency (EPA) 7 regulations (1971) under the Clean Air Act of 1970 (P.L. 92-157) require that each state should, prior to the adoption of an air pollution control plan and after reasonable notice, "conduct one or more public hearings on the plan (p. 22399)." In response to requirements in the Federal

Water Pollution Control Act of 1972 (P.L. 92-500), EPA (1973) has proposed regulations concerning public participation in water pollution control programs. In addition to the public hearing requirements in the

Act, the proposed regulations refer to public access to information, assistance to the public, and a "Summary of Public Participation," a statement which must be submitted with statewide or area-wide plans, ap- plications for construction project grants, and proposed regulations, standards, and effluent limitations.

The National Environmental Policy Act (P.L. 91-190) also places emphasis on public participation. Section 102 of the Act specifically grants public access to environmental impact statements under the Free- dom of Information Act, and the Council on Environmental Quality "Guide- lines" (1973b) for the preparation of environmental impact statements express the policy of public comment on draft environmental impact statements and the provision for public hearings "whenever appropriate." In reinforcement of these provisions, Executive Order 11514 (1970) directs federal agencies to "develop procedures to ensure the fullest practicable provision of timely public information . . in order to obtain the views of interested parties (p. 4247)."

As a further example of the present emphasis on public participation in environmental and natural resources planning, the Water 8

Resources Council in its "Standards for Planning Water and Land Resources"

(1970, p. IX-1) asserts:

The success of multi-objective planning depends on meaningful participation of interests concerned with each objective at each step in the planning process. The leaders for water and land resource planning have the challenging responsibility of achieving such participation while managing effective planning studies and facilitating decision-making. This responsibility will require an aggressive program to involve all concerned interests in identifying an area's problems and needs, in planning alternative solutions, and in decisions as to action.

Reasons for Public Participation in Planning

The apparent reasons for this emphasis on public participation

in government programs are many. According to Tucker (1972, p. 258),

the principal reason for public participation in planning is to enable

people to have a greater say in decisions that directly or indirectly

affect their lives. He bases this reason on the apparent widespread

concern today that the actions of elected representatives often do not

adequately reflect the needs and desires of the public. Along similar

lines, others (dengert, 1971, 1972; Dodge, 1973) allege that the empha-

sis on public participation represents a return to a "democratic ideal"

in which citizens share in decisions that affect their destinies and

also a realization that planning in the past has been elitist and manip-

ulative. Public participation activities represent an opportunity for

expression, a means of having concerns addressed, and thus a method to

reduce citizen alienation and enhance citizen trust and confidence in

government.

In many cases this stress on public involvement appears to be a

response to the pressures of confrontation. This is especially true in 9 natural resources planning where each project represents a potential source of conflict between "environmentalists" and "developers" (Ingram,

1972, p. 1181). Such confrontation has resulted in the acceptance of dominated solutions (Thierauf, 1970, pp. 379-381), solutions to problems which are undesirable to all concerned while more desirable solutions

actually exist. The employment of public participation activities in

planning is thought to decrease the probability of the acceptance of

such dominated solutions, to avoid belated public opposition to develop-

ment after considerable funds and effort have been invested, to define

conflicting publics, and to permit constructive interaction in promoting

mutual accommodation. As Biswas and Dune indicate (1971), if public

involvement activities are utilized throughout the planning process, "the

probability of a plan being accepted by the people increases greatly

(p. 1143)." It would be naive not to think that public participation activi-

ties also serve as an opportunity for bureaucracies to broaden their

bases of support and gain legitimization for their programs (4engert,

1971, p. 28). Like other entities in government, planning agencies must

also have supporting constituents to continue to exist, and public in-

volvement activities have the potential of being an effective instrument

in the creation of a favorable public image and also to mobilize support.

The emphasis on public participation in planning, especially in

natural resources planning, is also the apparent result of the new trend

toward multi-objective planning. The consideration of goals other than

economic efficiency with an orientation toward intangibles, perception, 10 and personal value preferences represents a strong impetus for the uti- lization of public involvement activities in the planning process.

Although from this review there appears to be a plethora of reasons for public participation in planning, the basic reason for this relatively new addition to the planning process seems to be the increas-

ing complexity of the planning and decision-making processes. Public

involvement has the capacity of ameliorating this situation by providing needed information concerning social preferences and values, opportuni-

ties for expression and mutual accommodation, and a means of increasing

public understanding and plan acceptance, the principal factors on which

the success of governmental programs is based (Biswas and Dune, 1971,

P. 1143).

Securing Public Participation in Planning

To effectively involve the public in planning activities, the

planning entity must first adopt a number of specific objectives which

the activities undertaken seek to achieve. Given the preceding discus-

sion of the basic rationales for public participation in planning, opera-

tional objectives for a public participation program might include public

relations, information exchange, conflict resolution, and also a number

of second-order objectives for further clarification (see Figure 1).

The selection of the appropriate mix of public participation activities to achieve such objectives is dependent on a number of variables.

Perhaps most important is the range of "publics" involved. However, such

variables as the overall planning situation, the relevant information 11

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C..) H 12 requirements, and the time and skills of those involved must also be taken into account (Hanchey, 1972, p. 1).

With respect to appropriate public participation activities,

Warner (1971) has differentiated three major functional orientations:

(1) the Information or Education, (2) the Review or Reaction, and (3)

the Interaction or Dialogue. Although there are no "best" procedures

for structuring participation, most public participation programs consist

of a set of public involvement activities which represent a mixture of

these functional orientations.

The Information/Education Orientation (Warner, 1971, p. 20), re-

ferred to henceforth simply as the Information Orientation, emphasizes

the transfer of information from the planning agency to the public and

from the public to the agency. The information flow tends to be "one-

way" with each party attempting to influence the other with new or addi-

tional information. Types of public involvement mechanisms which are

characteristic of this functional orientation include: reports, speeches

and group presentations, brochures, newsletters, newspaper articles,

radio and television programs, films, and exhibits.

The Review/Reaction Orientation (Warner, 1971, p. 21), to be re-

ferred to henceforth as the Review Orientation, focuses on securing evaluative feedback from the public concerning proposed plans. Like the

previous orientation, this review of plans by the public is characterized is transmitting by a one-way information flow. However, only the public

information. Mechanisms characteristic of this orientation include: 13 public hearings, public opinion surveys, and public comments on planning reports.

The Interaction/Dialogue Orientation (Warner, 1971, p. 22), or simply the Interaction Orientation, can best be characterized as an information exchange where the public and the planning agency participate in a two-way flow of communication. Activities representing this functional orientation take the form of direct interaction between public and planner and range from active public-planner dialogue concerning public needs and the formulation of plans to citizen responsibility with respect to the acceptance or rejection of plan alternatives and recommendations. Interaction/Orientation mechanisms include: workshops, citi-

zen advisory boards, panel discussions, public meetings, and seminars. It should be noted, however, that many of the public involvement mechanisms specified as being representative of each functional orienta-

tion are multi-purpose in character. Table 1 depicts for comparison the

primary functional orientations with their respective public involvement mechanisms.

Public Participation in the Planning Process

Although numerous and rather explicit definitions of the planning

process have been posited (Water Resources Council, 1973, pp. 24785- 24787; Ranney, 1969, pp. 15-17), the relation of public involvement ac-

tivities to the "planning process" can perhaps best be explained by uti-

lizing the functional orientations specified in the preceding section

and a simplified, hypothesized planning process. Specifically, Table 2

depicts a planning process with six steps: (1) Definition of Problems Table 1. Public Participation Mechanisms by Primary Functional Orientation

Adapted from Warner, 1971, p. 49.

Primary Functional Orientation

Information Review Interaction

Reports Public Hearings Workshops

Speeches and Group Public Opinion Citizen Advisory Presentations Surveys Boards Brochures Comments on Reports Panel Discussions

Newsletters Public Meetings

Newspaper Articles Seminars

Radio and TV Programs

Films Exhibits 15

Table 2. Public Involvement Functional Orientations in a Hypothesized Planning Process

Adapted from Warner, 1971, p. 39.

Public Involvement Stage of Planning Process Functional Orientation

1. Definition of Problems and Objectives A, C 2. Tnformation Collection A, C

3. Development of Alternative Plans A, C

4. Evaluation of Alternative Plans 13.. „ C

5. Recommendation of Preliminary Plan A, B 6. Selection of Final Plan A, B, C

Note: A Information Orientation B Review Orientation C Interaction Orientation Also: Underscored letter represents orientation of primary emphasis; additional letters indicate secondary emphasis. 16 and Objectives; (2) Information Collection; (3) Development of Alterna- tive Plans; (4) Evaluation of Alternative Plans; (5) Recommendation of

Preliminary Plan; and (6) Selection of Final Plan. Also displayed in

Table 2 are the appropriate public involvement functional orientations of primary and secondary emphasis for each step of the hypothesized planning process.

As can be discerned in Table 2, the primary functional orienta-

tions of public involvement change as successive steps in the planning

process are undertaken. In the initial step, the Definition of Problems

and Objectives, the Interaction Orientation is of principal importance.

It is within this stage of the planning process that it is of the utmost

importance for planners to confer directly with the public so that pub-

lic problems and objectives may be defined and also so that the planners'

perceptions of public needs may be compared against those needs actually

specified by the public. The Information Orientation also represents an

integral though secondary component of the public involvement activities

undertaken in this planning stage. For example, information with respect

to various futures forms a basis for discussion regarding long-range ob-

jectives. In the second phase of the planning process, the Collection of

Information, public involvement activities should be utilized which

stress the Information Orientation. This is especially important because

planning often becomes "invisible" during this stage of the planning

process. Initial interest in the planning study has often evaporated by

this step, and the dissemination of collected data by the planning agency 17 and other public and private organizations stimulates public awareness and interest in the planning effort and also provides a common base of information on which future phases of the planning process may be based.

Public involvement activities of the Interaction Orientation are also of

importance at this stage because they provide for planner-public forums where the content and implications of the collected data may be discussed

and the relative importance of certain problems ascertained.

Public participation activities utilized in the third phase, the

Development of Alternative Plans, should stress the Interaction Orienta-

tion. As Warner (1971, p. 43) asserts:

At this point, public input to planning study efforts in the form of suggestions and an active exchange of viewpoints about appropriate constraints, priority concerns, and possible implications is vital in terms of broadening the range of alternatives considered and of developing a better understanding of their relative feasibilities (technically, economically, social- ly, and politically).

Of secondary emphasis are activities of the Information Orientation. However, these activities become of the utmost importance once the poten-

tial alternatives have been identified, and the dissemination of informa-

tion with respect to alternatives is imperative for further educated

public involvement in the planning effort.

The fourth step in the planning process, the Evaluation of Alter-

native Plans, requires public participation activities which emphasize

the Review Orientation. Activities of this nature provide the planning agency with definitive information concerning public preferences with

respect to alternative plans. The public involvement program at this

stage in the planning process should also employ activities of the 18

Interaction Orientation to provide opportunities for public-planner and public-public discussions with regard to conflicting desires. Activities of this nature allow for further clarification of the consequences of alternative plans and also for the promotion of the accommodation of conflicting interests.

In the fifth step, Recommendation of Preliminary Plan, public involvement activities stressing the Review Orientation should be utilized. At this stage of the planning process, concerned individuals and groups inevitably "come out of the woodwork" to support or oppose the recommended plan, and therefore, opportunities should be provided for the expression of these reactions. Activities stressing the Information

Orientation should also be utilized to transmit details concerning the recommended plan to interested publics.

Selection of Final Plan, the last step in the hypothesized planning process, is characterized by public involvement activities of all three functional orientations. Of key importance are the activities of the Information Orientation. Such activities increase public understand-

ing of the plan and thus increase the probability of plan acceptance and

success. Of secondary emphasis are activities of the Review and Inter- action Orientations. Public participation mechanisms of the former allow

for feedback with respect to the final plan while activities of the lat- ter provide for public-planner and public-public interaction with respect

to substantive aspects of the final plan and also issues relating to

plan implementation. 19

Summary and Conclusions

Public participation has the potential of alleviating many planning enigmas. The preceding discussion has documented the positive aspects of public participation, its objectives, mechanisms, and potential role in the planning process. However, it must be noted that public participation is not a panacea for all the problems of planning. As

Norman Wengert (1972, p. 10) states, "Citizen involvement is important, but it is hardly the balm that will heal all conflict." Public participation has been the topic of much controversial discussion in the plan-

ning literature, and some of the most frequently raised questions include:

1. Is not representative government adequate for reflecting public

needs and preferences?

2. Who or what is the "public"?

3. Is not public participation tokenism or a euphemism for manipu-

lation and/or obstructionism (Wengert, 1971, p. 27; Carroll,

1971, p. 652)?

4. What are the best means and timing of participation in the plan-

ning process?

5. What are the limits of public participation, i.e., the level of technical complexity with which the public is capable of deal-

ing)?

6. If public participation activities are actually undertaken, how

are planners to weigh conflicting opinions? 20

7. How are the problems of inequality in participation, apathy, and

further complications and inefficiency in the planning process

due to public participation to be dealt with (Verba, 1969,

p. 130)?

These questions are not answered here. However, these and other questions must be addressed by planners utilizing or contemplating the use of public participation activities.

In conclusion, although public participation in the past has often been ex post facto, negative and token in character and has involved primarily influentials public participation, if considered and integrated with planner expertise throughout the planning process in a coherent participation program, has the potential of achieving better and more responsive plans and a better educated and informed citizenry.

However, as noted in the preceding questions, an array of problems still pervade the concept and practical usage of public participation in planning.

Need for Public Participation in Electric Power Development Planning

In recent years the siting, construction, and effects of electric power plants and transmission lines have become major issues in the conflict between the demands for more electric power and greater environmental protection. Debate with respect to these issues has focused on such topics as air pollution, waste heat discharge, the adverse effects on nearby communities, hazards from nuclear power sources, aesthetic impacts, and projected electricity demands. However, given the present 21 regulatory framework and power company planning procedures (discussed in

Chapter 4), such debate has often ended in litigation which has caused delays in the construction of power plants and transmission lines and thus ultimately shortages in electric power. It must be noted, however, that the challenging of administrative decisions in formal adversary hearings and other environmental reasons have been the cause of relatively few delays, approximately 10% (U.S. Senate, Committee on Commerce,

1972, p. 140). The majority of delays have been the result of such problems as equipment delays and malperformance, shortages of skilled labor, construction costs, and fuel shortages. However, it should also be noted that delays due to public opposition and environmental reasons have in many cases resulted in delays of longer duration. Such delays have produced tremendous added costs which must be borne by the electric utility companies and ultimately the consumer. As a result, power companies are actively seeking methods of expediting the regulatory and ap-

proval process and also minimizing the probability of legal challenges.

At the other end of the spectrum, environmentalists and other

concerned individuals and groups are questioning whether regulatory agen-

cies truly represent the public interest and are also challenging the

electric utility industry with respect to the need for further develop-

ment of electric capacity and the responsiveness of its planning efforts to environmental considerations.

As a result of these concerns of the public and also the desire

of power companies to resolve conflicts in a timely fashion to avoid

costly delays, the need for public participation in electric power 22 development planning has been recognized and supported by representatives of the electric utility industry, involved government agencies, environmental groups and other concerned organizations. For example, John N.

Nassikas (1971, p. 110), Chairman of the Federal Power Commission, has stated that "early informed public participation in power supply matters, including important related environmental questions, is absolutely essential if the nation's power needs are to be met." The Office of Science and Technology (1970, p. vii) stated in its conclusive report, Electric

Power and the Environment, that "public knowledge of utility expansion plans and an opportunity for participation in the decision-making process for site selection is a vital element in any program for resolving the conflicts over power plants and . . . transmission lines." In addition to facilitating timely resolution of such conflicts, public participation in power development planning has the potential to produce better decisions, to build understanding and cooperation between the electric utility industry and the public, to allow for the input of public viewpoints in advance of large commitments of resources, and also to increase public confidence in the planning and decision-making processes with respect to electric power development.

Given this need for public participation in power development planning and the previous discussions in this chapter relating to the objectives and mechanisms of public participation in planning, the next two chapters are devoted to describing the physical and institutional factors which have formed the setting for the involvement of the public 23

In the planning of coal-fired electric power development in the Four

Corners region of the Southwest. CHAPTER 3

COAL-FIRED ELECTRIC POWER DEVELOPMENT IN THE SOUTHWEST

National electric power requirements are estimated to increase fourfold between 1970 and 1990 (Federal Power Commission, 1971). In the

Southwest increasing population and industrialism and also rising per capita consumption of electricity indicate that such estimates may well be justified. To meet such increasing load requirements, electric generating capacity in the Southwest has been expanded by the construction of a number of coal-fired electric power generating stations in the Four

Corners region (see Figure 2). At present, only two plants are in operation and account for approximately 4,000 megawatts (mw) of electric generating capacity. However, completion of all coal-fired plants which are in the construction or planning phases may ultimately provide over

30,000 mw to the region. Load centers to be supplied by these power plants include Los Angeles, San Diego, Las Vegas, Phoenix, Tucson,

Albuquerque, and Salt Lake City.

The location of additional electrical generating capacity in the

Four Corners region of the Southwest can be attributed to a number of reasons. Of prime importance is the availability of coal. Tremendous deposits of coal underlay some 500 square miles in the Four Corners region. Although the coal is low in heat energy, it is of low sulfur content and contains relatively low ash and trace components. This supply, coupled with technological advances in extra high voltage

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. 1 COLORADO 1 Salt Ile City 1 1

Huntington Canyon

0 Albuquerque

0 Phoen ix CALIFORNIA

50 0 50 0 Tucson NEW MEXICO miles A Power Plant „,.....,ARIZONA I o City

Fig. 2. Location of Coal-Fired Power Plants in the Southwest 26 transmission lines and also in strip mining and large-scale generating equipment, made the development of coal-fired electric power plants in the Four Corners region an attractive proposition for providing needed low cost electric power (Cortner, 1973, p. 26). The construction of

such )nine mouth" plants in the Four Corners area eliminates to a large

extent the high costs of coal transportation and also takes advantage of

the cooling capabilities of water from the Colorado River.

Another apparent reason for the siting of these power plants at

considerable distances from the load centers is the fact that strict

pollution control standards now exist in many of the metropolitan areas

which the plants serve or will be serving in the near future.: For ex-

ample, the air pollution regulations of the County of Los Angeles are of

such severity regarding fuel-burning units that only natural gas or nu-

clear plants may be constructed. Thus, power companies have located

fossil-fuel burning power plants in such outlying areas as the Four

Corners region to take advantage of more lenient pollution control regu-

lations and the "assimilative capacity" of rural air (Baldwin, 1973,

p. 9).

An additional reason for power development in the Four Corners

region, though surely of secondary importance, is the apparent need for

economic stimulation in the area. The region is by no means affluent

(U.S. Senate, Committee on Interior and Insular Affairs, 1972, p. 197),

and the construction of large-scale power plants has the potential of

providing employment opportunities and needed revenues to stimulate

local economic development. 27

Thus, because of the availability of fuel and water, the need for economic development, and the relative leniency of pollution control regulations, the Four Corners region represents an ideal site for large- scale, electric generating stations. However, as discussed in a later section of this chapter, how "ideal" this location is for the construction of such generating stations and associated transmission lines has been the topic of much controversy.

Physical Development

As can be discerned in the map of the Southwest (Figure 2), the

Four Corners power complex is composed of eight coal-fired generating

stations. The Four Corners and Mohave Power Plants are presently on-

line; the San Juan, Navajo, Huntington Canyon, and Cholla Generating

Stations are under construction; and the Kaiparowits and Southern Nevada

Power Plants are in the planning stages. The Arizona Power Plant, which

is not depicted on the map, is also in the planning stage but a final

site has not yet been specified. Tables 3, 4, and 5 contain general

specifications, i.e., location, ownership, date on-line, existing and

planned generating capacity, and water and coal sources, for the South- western coal-fired power plants in operation, under construction, and in

the planning stages respectively. General specifications are not includ-

ed on the Southern Nevada Generating Station due to the present paucity

of information on this facility.

Other principal components of the Four Corners energy complex

include two of the largest strip mines in the world, the Navajo and Black

Mesa Mines, and a 276-mile, coal-slurry pipeline which transports coal 28

Table 3. General Power Plant Specifications: Plants in Operation

Sources: U.S. Senate, Committee on Interior and Insular Affairs, 1972, pp. 3-5, and U.S. Department of Interior, 1972e.

1. FOUR CORNERS POWER PLANT

Location: 16 miles southwest of Farmington, New Mexico (Navajo Reservation) Ownership: Arizona Public Service Company (Units 1, 2, and 3); Southern California Edison, Arizona Public Service Company, Public Service Company of New Mexico, Salt River Project, El Paso Electric Company, and Tucson Gas and Electric Company (Units 4 and 5) Date on-line: June, 1963 Existing Generating Capacity (197)-i. ): 2162 megawatts (mw) Planned Generating Capacity (Total): 2162 mw Water Source: San Juan River Coal Source: Navajo surface mine (Navajo Reservation) 2. MOHAVE POWER PLANT

Location: Southern tip of Nevada, near Davis Dam Ownership: Southern California Edison, Los Angeles Department of Water and Power, Nevada Power Company, and Salt River Project Date on-line: April, 1971 Existing Generating Capacity (1974): 1510 mw Planned Generating Capacity (Total): 1510 mw Water Source: Colorado River and water recovered from slurry-coal pipeline Coal Source: Black Mesa surface mine in northeastern Arizona (Navajo-Hopi Reservations) 29

Table 4. General Power Plant Specifications: Plants under Construction

Sources: U.S. Senate, Committee on Interior and Insular Affairs, 1972, pp. 5-8, and U.S. Department of Interior, 1972c.

1. SAN JUAN POWER PLANT

Location: 12 miles northwest of Farmington, New Mexico (10 miles north of Four Corners Plant) Ownership: Public Service Company of New Mexico and Tucson Gas and Electric Company Date on-line: 1973 (Unit No. 2) Existing Generating Capacity (1974): 345 megawatts (mw) Planned Generating Capacity (Total) * : 1190 mw Water Source: Navajo Reservoir Coal Source: Local surface mines

2. NAVAJO POWER PLANT

Location: 4 miles east of Page, Arizona (Navajo Indian Reserva- tion) Ownership: Bureau of Reclamation, Salt River Project, and Los Angeles Department of Water and Power. Date on-line: January, 1974 Existing Generating Capacity (1974): 750 mw Planned Generating Capacity (Total): 2250 mw Water Source: Lake Powell Coal Source: Black Mesa surface mine (Navajo-Hopi Reservations) 3. HUNTINGTON CANYON POWER PLANT

Location: Huntington Canyon, Emery County, Utah Ownership: Utah Power and Light Company Date on-line: 1974 Existing Generating Capacity (1974): 430 mw Planned Generating Capacity (Total) * : 860 mw Water Source: Huntington Creek Coal Source: Local underground mine 30

Table 4--Continued

4. CHOLLA POWER PLANT

Location: Joseph City, Arizona Ownership: Arizona Public Service Company Date on-line: 1962 (One Unit) Existing Generating Capacity (1974): 115 mw Planned Generating Capacity (Total) * : 620 mw Water Source: Groundwater Coal Source: Surface mines in New Mexico

* Through Phase II of U.S. Department of Interior's Southwest Energy Study (1972c). 31

Table 5. General Power Plant Specifications: Plants in Planning Phases

Sources: U.S. Senate, Committee on Interior and Insular Affairs, 1972, pp. 8-9; U.S. Department of Interior, 1972e; and Alfred H. Colton, Salt River Project, 1974.

1. KAIPAROWITS POWER PLANT

Location: Kane County, Utah (not specified) Ownership: Southern California Edison, San Diego Gas and Electric Company, and Arizona Public Service Company Date on-line: ? Planned Generating Capacity (Total) * : 2250 megawatts (mw) Water Source: Lake Powell Coal Source: Underground mine

2. ARIZONA POWER PLANT**

Location: St. Johns, Arizona or Snowflake, Arizona (potential sites) Ownership: Salt River Project Date on-line: 1978 (projected) Planned Generating Capacity: 1050 mw Water Source: Ground water Coal Source: Surface mines in New Mexico

*Through Phase II of U.S. Department of Interior's Southwest Energy Study (1972c). Not included in U.S. Department of Interior's Southwest Energy Study (1972c). 32 to the Mohave Plant from the Black Mesa Mine. Also included in this large-scale power complex is an 80-mile, coal-haul railroad from the

Black Mesa Mine to the Navajo Plant. In addition, 345 kilovolt (Kv) and

500 Kv transmission lines radiate from the existing plants along new corridors to the distant load centers.

The Controversy

The construction of coal-fired power plants in the Southwest has sparked considerable debate and controversy. Although these polemics commenced in approximately 1970, well after most of the plants had been planned and two plants were actually on-line, the principal issues have been of a fundamental nature and have included (1) the reliability of demand projections and related utility company policies, (2) the environmental impacts of continued large-scale power production in the South- west, and (3) the effects of power development in the Four Corners region on resident Indians. A brief discussion of each of these issues follows.

The debate surrounding the first of these issues can best be characterized as those opposed to coal-fired power development in the

Southwest questioning the utility companies' electrical demand projections and the utility companies defending their methods of load projection and estimates. The former contended that much of the demand for electricity was "frivolous" in nature and partly the result of utility company advertising and electricity rate structures. Power company demand projections, which represented the prime mover for increased generating capacity in the Southwest, could not be trusted because faulty assumptions and techniques, specifically historical extrapolation methods, 33 were utilized in such estimations. This group went on to argue that even if such power demand came to exist in the future, other power

sources such as solar, fusion, and magnetohydrodynamics, would become viable alternatives and would offer more reasonable solutions than the

development of large-scale, coal-fired power plants. The power companies

countered by stating that their advertising procedures had a negligible

effect on power consumption. They also contended that even with the in-

stitution of conservation-oriented rate structures and measures such as

consumer and industry programs to promote efficient power use, demand

for electricity would continue to increase in the future due to a more

electricity-oriented society and new activities such as pollution control

and mass transit which would require electric power. In addition, the

utility companies asserted that due to the technological infeasibility

and the environmental incompatibility of alternative energy sources and

also shortages of low sulfur oil and natural gas, coal-fired electric

power generation in the Four Corners region represented the only viable

alternative to meet projected power demands.

Conjecture regarding the possible environmental impacts of large-

scale power production in the region was also very much a part of the

controversy which surrounded power development in the Four Corners re-

gion. Perhaps of principal concern was the degradation of the air qual-

ity of which the region is noted. Coal-fired power plants release a

number of airborne pollutants which, if not controlled, can have adverse

effects on visibility and health. Debate with respect to this issue

centered on the probability of exceeding air quality standards, the 34 availability of air pollution control technology, the efficiency of such equipment, and the degradation of the aesthetic environment. It was ev-

ident that serious deficiencies existed in the information with respect to present and projected air quality degradation.

Another area of concern was the impact of power development on the region's water resources. Given the apparent over-allocation of the

Colorado River and the problematical impacts of pumping groundwater in

the region, the commitment of this scarce resource at approximately 15

acre-feet per megawatt annually was a matter of considerable concern.

Also related to this issue was the question of increases in salinity con-

centrations along the Colorado River due to the reduction of dilution

capacity for downstream salinity accretions. Debate also focused on the

use of strip mines as the principal source of coal for the power plants.

The possibilities of increased erosion and successful reclamation re-

ceived considerable attention.

In a more general environmental sense, opponents of coal-fired

power development in the Southwest argued that this increased supply of electrical energy would ultimately lead to more growth in the Southwest

and thus further environmental deterioration and degradation of the re-

gion's amenities. With respect to these environmental issues, the pro-

ponents of the Four Corners energy complex admitted that the environment would be degraded to an extent, but they also argued that this degrada-

tion could be contained and would be minimized by utilizing the most ad-

vanced technology and methods. 35 The final issue which received considerable debate involved the effect of the power complex on the Indians of the area. This issue had a number of dimensions. Of considerable concern were questions concerning the economic impacts: were the Indians receiving equitable royalties on coal leases, were the provisions in the leases with respect to jobs for Indians reasonable, and were the Indians bearing the environmental costs but not receiving commensurate economic benefits? Also of prime concern was the religious significance of Black Mesa and the effects on

Indians due to strip mining on it. Another dimension of this basic issue was the validity of certain decisions concerning the Indians. Arguments were made that the coal leases were not valid because the "true" repre-

sentatives of the Indians had not participated in these agreements. It was also thought by many that the Secretary of Interior had overstepped

his fiduciary role as trustee for the Indians by being so directly in-

volved with power development in the Four Corners region (Baldwin, 1973,

P. 35). In conclusion, it can be seen from this brief discussion of the

issues that the controversy surrounding the development of coal-fired

electric power in the Southwest embraces a diverse set of complex issues.

Economic, environmental, and social considerations are intimately inter-

twined. The logical question must be: how have plans and decisions been made in such an atmosphere and what formalized procedures have existed

for inputting public concerns into the planning and decision-making proc-

esses? CHAPTER 4

PLANNING FOR COAL-FIRED ELECTRIC POWER DEVELOPMENT IN THE SOUTHWEST

To better understand the nature of the public participation activities utilized in the planning of coal-fired power plants in the

Southwest, it is necessary to describe the institutional setting in which such activities were undertaken. This setting can perhaps best be defined in terms of the planning procedures of power companies and the role of the Federal and State governments in Southwestern coal-fired power development.

Power Company Planning Procedures

In the Southwest as in other areas of the United States power companies possess most of the functional responsibilities for planning future growth in electric power systems. In general, electric utility companies decide whether new generating and transmission facilities are needed in their service areas and then plan for the type of facility and the site. Governmental agencies then review these plans.

Factors such as the tremendous capital investment, the necessity of maintaining acceptable reserve generating capacity, and long construction periods necessitate sophisticated planning for electric power development. In the Southwest electric utility companies not only engage in elaborate planning to provide needed power to their customers, but most of them also belong to a planning consortium, Weste_ca Energy Supply and 36 37

Transmission Associates, which coordinates utility plans for the entire

region.

As Ball et al. (1972, pp. 34-35) suggest, the traditional plan-

ning process for new generating plants and sites includes the following

steps:

1. Establish the need for a new power plant by forecasts and esti-

mates of future demand of electricity.

2. Estimate the amount of new generating capacity and other facil-

ities required.

3. Choose the types of generating equipment and integrate them with the existing system.

4 • Identify sites for power plants and routes for transmission

lines.

However, a new step in this process which has just begun to re-

ceive major attention is the assessment of the environmental impacts of electric power development projects and the use of this assessment in

the evaluation of potential electric power facilities and sites. Specif- ic elements characteristic of the four, traditional, planning steps in-

clude: types and sizes of generating units and distribution systems, system reliability requirements, availability of fuel and water, cost of

plant and supporting facilities, basic engineering considerations, and

the proximity of the plant site to major load centers and also to fuel

and water sources. Elements considered in the determination of the en-

vironmental impact of power plants and associated facilities include:

air and water pollution effects, biological impacts, land use 38 considerations, and the relation of the plant to other power plants and to populated areas. All of these elements represent highly technical problems which must be solved by intensive research and analysis. After careful consideration of the "traditional" and environmental factors, a plan is adopted by the power company with respect to future power system development. Such plans are subject to continuous modification due to changes in technology and economic conditions.

In the past such power development plans were developed solely by the utility companies, and they remained essentially internal docu- ments. However, given the reasons noted at the end of Chapter 2 concerning the need for public participation in electric power development planning, the planning process with respect to future electric power systems has begun to change in the last few years. Power companies have begun to surrender their "prerogative of unilateral decision-making"

(U.S. House of Representatives, 1971, p. 1179). They have begun to employ what they refer to as "open" or "participatory" planning, actively seeking public ideas and evaluations during the planning process and also disseminating information concerning plans and the planning process itself. For example, prior to 1970 the Arizona Public Service Company

(APS) was involved solely with the more traditional concerns of power development planning. However, since that time, according to Tom

Sullivan (1974), a representative of APS' Environmental Affairs Depart- ment, "APS has had a total public input commitment." Power company methods of securing this public input have included primarily public information meetings, opinion surveys, and the 39 distribution of information concerning power demand, power facilities, and the environmental impacts of such facilities. However, such dilemmas as how the ideas and evaluative information obtained from the public are transformed into engineering realities and how the public is to deal with the extremely complex and technical problems of electric power development have yet to be solved. Although many still question the power companies' motives and methods with regard to involving the public in power development planning, "open" planning is a more recent phenomenon which has the potential of changing the traditional, unilateral planning process utilized by power companies.

In terms of coal-fired power development in the Southwest, the power companies have shouldered the primary responsibility for the planning and development of these generating facilities and transmission systems. The traditional elements of power planning such as power projections, the availability of fuel and water, and the feasibility of certain generating systems were considered by the participating power companies in the 1950's and 1960's. In the late 1960's and early 1970's, the environmental impacts of coal-fired power development were also actively taken into consideration. With respect to public involvement in such planning, it can be stated unequivocally that prior to 1970 it was nonexistent. However, since that time and consequently after most of the coal-fired power development in the Southwest had been planned, power companies have taken steps to publicly define their planning procedures, to inform the public concerning the effects of power plants and related facilities, and to solicit public reaction to power development I.0 plans. How adequate such public participation activities have been will be discussed in a later chapter.

Role of the Federal Government

In general, it can be said that the role of the Federal government in the planning and development of fossil-fueled power plants in comparison with federal involvement in nuclear and hydroelectric projects is very limited. For, unlike these other power sources, fossil-fueled generating stations under ordinary circumstances do not require a federal license before construction may begin. 'However, federal involvement is likely to occur in the construction of such facilities due to a number of factors.

First, fossil-fueled generating plants are subject to national ambient air quality standards and also federal emission standards with respect to particulates, sulfur oxides, and nitrogen oxides. Under the

Clean Air Act Amendments of 1970 (P.L. 92-157) all new power plants must also conform to federal performance standards.

Second, fossil-fueled power plants must obtain and, in most cases, discharge cooling water. If this water is taken from navigable waters, a permit must be obtained from the U.S. Corps of Engineers in conformance with the Rivers and Harbors Act (Refuse Act) of 1899 (P.L.

55-)425). If this water is subsequently discharged into navigable waters, a permit must be obtained from the Environmental Protection Agency in accordance with Section 402 of the Water Pollution Control Act Amendments of 1972 (P.L. 92-500). Forthcoming Environmental Protection Agency guidelines for effluent limitations will also affect fossil-fueled power 41 plant discharges. Other Federal agencies which might be involved in the development of fossil-fueled generating stations and transmission facilities include the Bureau of Land Management, the Forest Service, the

Bureau of Indian Affairs, the National Park Service, the U.S. Geological

Survey, the National Oceanic and Atmospheric Administration, the Fish and Wildlife Service, and the National Marine Fisheries Service.

An additional source of federal involvement in this area is the

National Environmental Policy Act (NEPA) (P.L. 91-190). As noted in the preceding discussion, although there is no federal license per se with respect to fossil-fueled power plants, some federal action is almost always required. If such federal action significantly affects the environment, NEPA requires that involved Federal agencies prepare an

"environmental impact statement" which must address such topics as the environmental impact of the proposed action, alternatives, and "any ir- reversible and irretrievable commitment of resources" (NEPA Sec. 102(2)

(c), 1970, 42 U.S.C. Sec. 4332).

In summary, it can be said that the customary federal role with respect to fossil-fueled generating plants, which supply the bulk of our power needs, is generally incremental in character and that no systematic federal review ordinarily occurs.

However, in regard to coal-fired electric power development in the Four Corners region of the Southwest, a higher degree of federal involvement has occurred for a number of reasons. First, many of the generating station sites and most of the coal resources are situated on public or Indian lands. As a result, the use of such land has required 42

leases from the Department of Interior and ) in the case of Indian lands, has required leases signed by the Indians and approved by the Secretary of Interior. These agreements contain provisions for air pollution control and strip mine reclamation. Coal-fired power development in the

Southwest has also included the construction of numerous transmission lines which cross public and Indian lands. As a result, numerous right- of-ways have been granted by the Indians and affected Federal agencies.

In addition, most of the water used for cooling purposes has been obtained from Federal storage facilities on the Colorado River system. In order to acquire such water, federal water service contracts have been required. Such contracts contain provisions which require approval by the Secretary of Interior in regard to power plant designs and plans for air and water quality control. The role of the Federal government in coal-fired power development in the Southwest has also been demonstrably enlarged by the direct participation of the Bureau of Reclamation in the Navajo Power Plant. This involvement is based on provisions in the

Colorado River Basin Project Act (P.L. 90-537). The Bureau's share of

the Navajo Plant's power (2 )-i. .3%) is ultimately to provide pumping power for the Central Arizona Project. Thus, in summary, the federal role in coal-fired electric power development in the Southwest has been considerably more expansive than the normal federal involvement in the development of fossil-fueled power plants. As a result of this increased level of federal involvement, public participation in the planning of Southwestern coal-fired power development has undoubtedly been positively affected. However, it must 43 be noted that a large proportion of the federal involvement has taken the form of leases, contracts, and behind the scenes dealings with the power companies, procedures in which public participation is customarily ruled out. The high degree of federal involvement has provided the im-

petus for federally-sponsored hearings and reports and a number of Fed-

eral environmental impact statements (discussed in Chapter 5) which have

provided avenues for public participation by means of solicited comments,

related public hearings, and increased information.

State Involvement State control with respect to electric power plants and trans-

mission lines has in general had two principal sources: state public

service commissions and state environmental protection or public health

agencies. The former review utility rates and oversee the financial

arrangements and service of electric utility companies. In some states

public service commissions also certify the construction of power plants

and transmission lines, consider alternative sites, and review the need

for increased power production. Such state control is generally supple-

mented by local statutes pertaining to zoning, building codes, air pollu-

tion control, safety regulations, and other planning requirements. State

environmental protection agencies, the other principal source of state

control, have jurisdiction over such matters as air and water quality control, land use considerations, and monitoring programs in regard to

electric power plants and transmission lines. This control generally

takes the form of a number of permits which must be obtained before construction can begin. 44

With respect to the Four Corners region of the Southwest, state government agencies currently exercise a relatively wide range of con-

trols over the siting ana development of electric power plants and transmission lines. However, this has not always been the case. During the

initial planning and construction of most of the Four Corners energy

complex, state regulations concerning power plants and transmission lines

were rather limited. Although state environmental protection agencies

did exert some control, the state public service commissions of Arizona,

Nevada, and Utah in 1968 required no certification for the construction

of power plants or transmission lines (see Table 6). There was also no

opportunity for public hearings with respect to such construction. At that time the New Mexico Public Service Commission did require the certi-

fication of new power plants and transmission lines and did provide an

opportunity for public hearings. However, as noted in Table 6, this

certification process was limited in nature. As can be seen in Table 6,

by 1972 and thus by the time considerable construction had begun on the power plants and transmission lines of the Four Corners power complex,

the situation regarding state certification and also the opportunity for public hearings had changed considerably. A description of these chang-

ing requirements of Arizona, Nevada, New Mexico, and Utah follows. Although the principal environmental effects of power plants in

Arizona have been under the Jurisdiction of the State Department of

Health since the early 1960's, in the past the State Corporation Commis- sion has not required electric utility companies to obtain a certificate

before the construction of a power plant or a transmission line. However, 45 Table 6. Comparison of Certification and Hearing Requirements of State Public Service Commissions: 1968 and 1972

Sources: Office of Science and Technology, 1970, p. 56; U.S. Senate, Committee on Commerce, 1972, pp. 527-529; and Federal Power Commission, Work Committee on Utilities, 1968, Appendix 1.

Certification for Construction of: Opportunity for Power Plants Transmission Lines Public Hearings

1968

Arizona No No No Nevada No No No New Mexico Yesa Yesa Yesb Utah No No No

1972 Arizona Yes Yes Yesd Nevada Yes Yes Yesb New Mexico Yes Yes Yesd Utah Yesc Yesc Yesd

aIf constructed by electric utility under jurisdiction of New Mexico Public Service Commission. bAt discretion of Commission or if requested by an intervenor , cLimited to construction by new electric utility companies. dRequired by law in all instances. 46 in 1971 the Arizona Legislature established an 18 member Power Plant and

Transmission Line Siting Committee which must grant a Certificate of

Environmental Compatibility before construction may proceed on generating plants over 100 mw and transmission facilities over 115 KV. A public hearing is mandatory in this certification process. With respect to the certification of power plants and transmission lines of the Four Corners power complex, the Navajo Paver Plant in Page, Arizona, was under con-

struction prior to the effective date of this legislation and therefore was exempt from obtaining a certificate. However, recent additions to the Cholla Plant did come before the Siting Committee, and a public hearing was held (Kircher, 1973).

Control over power plants and transmission lines in Nevada re-

sides in the Nevada Commission of Environmental Protection, County and district air pollution hearing boards, and, most recently, the Nevada

Public Service Commission. This latest development is the result of the Utility Environmental Protection Act, which was passed by the Nevada

legislature in 1971. Under this Act a Permit to Construct must be ob-

tained from the Nevada Public Service Commission for all new electric

generating plants and associated facilities. As noted in Table 6, hear-

ings regarding the application for such a permit are held at the discre-

tion of the Commission or if requested by an intervenor. In regard to

the Mohave Generating Station in Clark County, Nevada, this legislation was enacted following the original development of the plant and related

facilities. Therefore, the Nevada Public Service Commission had no ju-

risdiction (Proksch, 1974). New Mexico's controls over power plants and transmission lines for a number of years have been more extensive than those of other states in the Southwest. Since the mid-1960's, the State Health and Social

Services Board, now the Environmental Improvement Agency, has had jurisdiction over the environmental impacts of power plants and associated facilities. The New Mexico Public Service Commission, as noted in Table

6, has had jurisdiction over power facilities which are constructed by utility companies under the jurisdiction of the Commission. However, state legislation passed in 1971 now requires that all power plants over

300 mw and transmission lines over 230 Kv, whether or not owned or operated by a public utility subject to regulation by the Commission, must receive a Certificate of Necessity and Convenience. A public hearing is mandatory in this process. With respect to coal-fired plants of the Four

Corners complex in New Mexico, since Units 1, 2, and 3 of the Four Cor- ners Plant are owned solely by Arizona Public Service Company and were constructed prior to the 1971 legislation, the New Mexico Public Service

Commission had no jurisdiction. However, since Units 4 and 5 are owned partially by utility companies under the Commission's jurisdiction, hearings were held and a certificate was issued. Similarly, since the

Public Service Company of New Mexico owns 50% of the San Juan Generating

Station, public hearings were held and a certificate was issued for the

construction of the plant (Parmelee, 197)4 ). Also subject to the new legislation was the 345 KV transmission line owned by Tucson Gas and

Electric Company from the San Juan Plant to Vail, Arizona. Hearings 4-8 were held by the Commission and the application for a certificate was approved subject to certain conditions.

In Utah state control over power plants and transmission lines has resided primarily in the state environmental protection agencies, the Air Conservation Council and the Committee on Water Pollution. Un- der the Air Conservation Act of 1967 and as amended in 1971 and 1973, the Air Conservation Council sets ambient air standards and issues certificates for pollution control devices. The Utah Committee on Water Pollution establishes water quality standards and issues permits for the construction of waste treatment works. Although the Utah Public Service

Commission has recently been granted more control over power plants and transmission lines in the state, this control is limited due to the fact that utilities now in business do not require certificates for the construction of new power facilities. However, if construction is proposed by a new utility, a Certificate of Convenience and Necessity must be obtained and hearings held. Thus, the Huntington Canyon Power Plant in Emery County, Utah, fell under the jurisdiction of the state pollution control agencies and pollution control permits were required. However, since the plant is owned and operated by Utah Power and Light Company, a certificate from the Utah Public Service Commission was not required and hearings were not held (Pruett, 1974). Thus, in summary, the involvement of Arizona, Nevada, New Mexico, and Utah in power development has been in a state of transition during the development of the Four Corners power complex. The movement toward pre-construction certification has increased the opportunity for public I9 participation in the planning and review of power plants and transmission lines. However, in the case of coal-fired power development in the Four

Corners region most of the power plants and transmission lines were already under construction at the time of the inception of these state certification regulations and therefore were exempted from such certification and public participation proceedings. CHAPTER 5

PUBLIC PARTICIPATION IN THE PLANNING OF COAL-FIRED ELECTRIC POWER DEVELOPMENT IN THE SOUTHWEST

Given the previous discussions concerning public participation

in planning and the institutional and regulatory framework in which the planning for coal-fired electric power development in the Southwest has

taken place, this chapter classifies and reviews the public participa-

tion activities actually undertaken in this planning. The activities

reviewed are limited to those utilized in relation to the planning of

coal-fired power plants and associated transmission lines in the region.

The public participation activities are classified with respect to the

three public participation functional orientations discussed in Chapter 2:

Information, Review, and Interaction (see Table 7).

Information Orientation

This orientation emphasizes the transfer of information by the

planning entity to the public and conversely from the public to the plan-

ning entity with the purpose of informing and/or influencing the recip-

ient. The principal sources of such one-way information flows in the

planning of coal-fired electric power development in the Southwest have

included the Federal government, electric utility companies, and indi-

viduals and groups concerned with the environmental impacts of this de-

velopment.• The means of conveying this information have taken a number

of different forms.

50 51

Table 7. Public Participation Activities in Southwestern Coal-Fired Electric Power Development by Functional Orientation

A. Information Orientation

1. Southwest Energy Study 2. Environmental Impact Statements 3. Utility Company Reports 4. C.P.E.A.C. Newsletter 5. Private Reports and General Media (Newspaper Articles, Films, etc.) 6. Public Information Meetings B. Review Orientation

1. Public Hearings

a) U.S. Senate, Committee on Interior and Insular Affairs b) Arizona Power Plant and Transmission Line Siting Committee c) New Mexico Public Service Commission/New Mexico State Planning Office d) U.S. Forest Service

2. Comments on Reports (Southwest Energy Study and Draft Environ- mental Impact Statements) 3. Opinion Surveys C. Interaction Orientation

1. Panel Discussions 2. Conferences (workshops) 52

Southwest Energy Study

In the spring of 1971 a number of environmental groups were threatening to sue the Department of Interior for not preparing environmental impact statements under the National Environmental Policy Act on coal-fired plants in the Southwest in which the Department was intimately involved. In response to these potential law suits Secretary of the

Interior Rogers C. B. Morton announced on May 17, 1971 that a Federal task force would be established to conduct a comprehensive, one-year study of existing and proposed coal-fired generating plants in the South- west. The study known as the Southwest Energy Study was to "include an examination of the needs for electric energy, the alternative means of supplying it, and the resulting effects upon the environment (U.S.

Department of Interior, 1972e, p. 1-1)." With the exception of limited participation by the Environmental Protection Agency and the National

Oceanic and Atmospheric Administration, the study represented the involvement of eight bureaus of the Department of Interior in 12 work groups which included: Power Development and Economics, Water Supply,

Water and Air Pollution, Water Resources Monitoring, Meteorology, Land

Use, Indians, Biota, Recreation and Aesthetics, Coal Resources, Mining, and Alternative Uses of Colorado River Basin Coals. The Task Force was

assisted by liaison representatives from state governments, universities,

Indian tribes, utility companies, and conservation groups.

The work group reports were completed in late 1971 and were available for public examination in early 1972 at Interior Department offices.

A draft of the Study Management Team's report, the Southwest Energy 53 Study, Draft (U.S. Department of Interior, 1972b), was published in

April, 1972. This document and the working group reports were made available for public examination at a number of repositories in the Southwest.

The final Summary Report (U.S. Department of Interior, 1972c) included findings and conclusions with respect to energy need and supply, resource availability, environmental impacts, the mitigation of such impacts, alternative energy sources, and information needs. Substantive weaknesses existed in the report in such areas as the evaluation of environmental

impacts and electricity demand and the consideration of alternative energy sources and the effects on Indians. However, the Southwest Energy

Study offered an opportunity for a cumulative assessment of the impacts of coal-fired power development in the Southwest, and as the Rocky Moun- tain Center on Environment stated in its comments on the draft report

(U.S. Department of Interior, 1972a, p. 219):"The present study has done much good. It has provided better information on the intentions of electrical energy producers. It has revealed the paucity of scientific in-

formation. Most importantly, it has demonstrated the magnitude of the problem and need for new approaches, commencing immediately."

Environmental Impact Statements

Although the Southwest Energy Study was undertaken to head off a number of law suits threatened by environmental groups and Indians, suits were filed on June 2, 1971 to halt the development of the Four

Corners, Mohave, Navajo, San Juan, Huntington Canyon, and Kaiparowits

Generating Stations. The suits alleged that the Federal government had violated the National Environmental Policy Act (NEPA) by not preparing 54 environmental impact statements on Federal actions involving the Four

Corners power complex. The plaintiffs sought a court injunction against future government involvement and also invalidation of past contracts and permits pending compliance with the requirements of NEPA. The suits were consolidated as Jicarilla Apache Tribe v. Morton (1971). On March 14,

1972 a decision was reached in Arizona District Court that environmental impact statements were not required for the power projects currently in operation and under construction because federal actions taken with respect to these projects had occurred prior to the effective date of NEPA on January 1, 1970. The court also held that a cumulative impact statement was not required for the Four Corners complex and also that the

Kaiparauits Project did not yet require an impact statement because major federal actions had not yet taken place. The decision was appealed.

However, the judgment was affirmed by the Ninth Circuit Court of Appeals on January 2, 1973. The initial decision has been the center of much controversy. The holding contradicts a number of other cases relating to the applicability of the NEPA process, and Anderson and Daniels decision of Jicarilla Apache Tribe v. (1973, p. 23 )+ ) assert that the

Morton (1972) represents "the most regrettable REPA district court case to date." However, three environmental impact statements were prepared while operation and construction continued on the Four Corners power complex. These statements were prepared pursuant to Section 11 of the

Council on Environmental Quality "Guidelines" (1971b, p. 7727) which states: "Where it is not practicable to reassess the basic course of 55 action, it is still important that further incremental major actions be shaped so as to minimize adverse environmental consequences." In response to Section 11 environmental impact statements were prepared on the Nava- jo, Huntington Canyon, and San Juan Generating Stations and related facilities (Table 8).

Utility Company Reports and Brochures

In addition to the Southwest Energy Study and environmental impact statements, another public participation activity of the Information

Orientation has been the dissemination of printed information by the electric utility companies. This information dissemination process has generally taken the form of printed reports and brochures which have been made available to the public.

For example, numerous studies concerning the impacts of the coal- fired plants and related facilities were undertaken by private consult-

ing firms, e.g., Bechtel Corporation, Dames and Moore, Inc., and Stearns-

Rogers Corporation, which were retained by the utility companies. The

resulting reports covered such topics as meteorology and climatology, aesthetics, air pollution, visibility effects, and water supply and qual-

ity. The utility companies also had contracts with a number of univer-

sities in the region to undertake ecological baseline studies and

archaeological studies of plant sites and right-of-ways. A number of

reports were issued by the utility companies and mining companies them-

selves on such subjects as coal mining and ash disposal, monitoring

equipment, .water use, nitrogen oxides control, sulfur dioxide and par-

ticulate removal, and vegetation and general ecological conditions. The 56

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Kaiparowits Project Environmental Report by Arizona Public Service Com- pany, Salt River Project, San Diego Gas and Electric Company, and South-

ern California Edison (1973), and Dames and Moore's Environmental Report:

The Cholla Power Project (1973) for Arizona Public Service Company. Nu- merous informational brochures concerning power demand, the environmental

aspects of the plants and transmission systems, land use considerations, and the economic benefits of the coal-fired power development were also

distributed by the involved utility companies.

C.P.E.A.C. Newsletter

Another source of information on power development in the Four

Corners region has been the Colorado Plateau Environmental Advisory

Council (C.P.E.A.C.), which was formed in mid-1970 by environmentalists

and representatives from industry, government, the academic community,

and the lay public to consult upon the future of the Colorado Plateau. C.P.E.A.C. was also to serve as a clearinghouse for information on coal-

fired power development in the Southwest. Its monthly publication, the C.P.E.A.C. Newsletter, has been mailed to approximately 475 organiza-

tions and individuals and has featured several informative articles on various aspects of the Four Corners controversy. The newsletter has also contained lists of completed reports and current studies related to coal-fired power development in the Southwest. C.P.E.A.C. has also 58 maintained a library where utility company and government reports relating to this issue have been on file and available to the public.

Private Reports and General Media

Another public participation activity of the Information Orien- tation has been the publication and distribution of brochures, pamphlets, articles, and reports relating to the Four Corners controversy by private entities, especially environmental groups. For example, the Central

Clearing House in Santa Fe, New Mexico, prepared and distributed articles and reports on the problems at Black Mesa. Other organizations such as the Black Mesa Defense Fund, the Sierra Club, the Environmental Defense

Fund, and the National Wildlife Federation were also involved in publi- cizing the problems associated with coal-fired electric power development

in the Southwest. Individual publications such as "The Rape of Black Mesa"

(Brown, 1970) and The Southwest Energy Complex: A Policy Evaluation

(Baldwin, 1973) also provided a supplementary source of information. It should also be noted that another valuable source of information has been the published transcripts of governmental hearings held in regard to the problem.

In addition to these printed sources of information, numerous articles and advertisements relnting to the controversy have appeared in newspapers of local, state, regional, and national circulation. Films .

on the power development in the Four Corners region and the resulting

controversy have also been produced by environmental groups and other

interested individuals and organizations. These films have been shown

on television and at group meetings. 59 Public Information Meetings

A principal public participation activity of the Information

Orientation has been the public information meeting. A number of such meetings concerning coal-fired power development in the Southwest have been held by involved power companies and, to a limited extent, by governmental agencies. Such public information meetings have included primarily explanations and descriptions of the physical aspects of the power plants and transmission lines, the economic benefits to the area, the major environmental considerations, and the activities which would be undertaken to solve or minimize resultant problems. Although such public information meetings have undoubtedly contained components of the

Review Orientation, e.g., verbal comments, and the Interaction Orienta- tion, e.g., group discussion, the primary function of such meetings has been to transmit information concerning new power development projects from the power companies to interested groups. For example, the Salt River Project from early 1970 to late 1972 held approximately 150 public information meetings on the Navajo Project.

These meetings, which in many cases were co-sponsored by the U.S. Bureau of Reclamation, were held with representatives of State and Federal agencies, service clubs, environmental groups, and business and academic organizations. Such meetings generally took the form of "shovel-in-the- ground" information meetings, or meetings which informed interested persons and groups of the physical constituents of the Navajo Project which were already being constructed or utilized and how ensuing environmental problems would be handled. A number of public information 6o meetings were also held by the U.S. Forest Service, the Arizona Public

Service Company, and the Los Angeles Department of Water and Power with respect to transmission lines emanating from the Navajo Generating Sta- tion. Similar meetings were held by the Public Service Company of New

Mexico in regard to its plans for the San Juan Generating Station and by Tucson Gas and Electric and the Forest Service concerning the 345 KV transmission line from the San Juan Plant to Tucson, Arizona. Utah Power and Light Company has also conducted a limited number of public information meetings to explain the physical and environmental aspects of the Huntington Canyon Generating Station and related facilities.

Review Orientation

This public participation functional orientation emphasizes the transfer of information from the public to the planner In the form of evaluative feedback on proposed plans. The principal sources of this feedback in the planning of coal-fired electric power development in the Southwest have included numerous environmental groups, business organizations, representatives of the academic and Native American communities, and other concerned individuals and groups. As can be discerned in Table 7, this type of public involvement activity has included primarily public hearings, comments on reports, and opinion surveyt.

Public Hearings Although the involvement of the Federal government in fossil- fueled electricelectric power development per se is limited, coal-fired electric power development in the Southwest, as noted in the previous chapter, 61 has engendered a higher level of federal involvement than is usually the case. As a result, a number of public hearings under the auspices of entities of the Federal government have been held concerning this development. Perhaps the most publicized hearings were the field hearings conducted on the impacts of the Four Corners power complex by the U.S.

Senate Committee on Interior and Insular Affairs which has oversight responsibility over the activities of the Department of Interior. Hear- ings were conducted in five cities in the Four Corners region in late

May, 1971. Some 259 witnesses representing all parties to the controversy appeared before the committee, and a hearing record of 1935 pages was accumulated. In addition, numerous letters, statements, and other written expressions of concern were received by the Committee and subsequently published in part. Supplementary hearings were also conducted by the Committee in Washington, D.C.

In response to the Council on Environmental Quality's "Guidelines" (1971b) for the preparation of environmental impact statements, Federal agencies also conducted a number of public hearings in the region to involve the public in the review of draft environmental impact statements. Specifically, the Forest Service conducted four hearings on the draft

statement for the San Juan--Tucson transmission line while the Bureau

of Reclamation held a public hearing with respect to the draft statement on the San Juan Power Plant itself. Hearings were also held with respect

to the draft environmental impact statement on transmission lines from the Navajo Generating Station by the Forest Service and the Bureau of

Land Management. 62

In regard to public hearings held at the state level concerning power development in the Four Corners region, governmental entities in only New Mexico and Arizona have undertaken such public involvement activities. As noted in Chapter 4, the New Mexico Palle Service Commis- sion held limited public hearings on Units 4 and 5 of the Four Corners

Plant and on the two units at the San Juan Station. However, the Commis- sion and the New Mexico State Planning Office held approximately 20 days of public hearings on the controversial 345 Ky transmission line from the San Juan Station to Tucson Arizona. In Arizona, public hearings have been conducted by the Arizona Power Plant and Transmission Line Siting

Committee. Although most of the 10 cases which have come before the

Committee thus far have dealt with small extensions of transmission lines in the Phoenix and Tucson areas, the addition to the Cholla Generating

Station, as previously noted, did come before the Siting Committee, and a public hearing was held.

Comments and Surveys Additional activities for securing feedback on proposed plsns include comments on reports and public opinion surveys. The Southwest

Energy Study Summary Report (U.S. Department of interior, 1972c) and the environmental impact statements on the Navajo, San Juan, and Hunting-

ton Canyon Generating Stations and related facilities provided an opportunity for written, public comments. With regard to the former, copies

of the draft report were sent to interested parties, and written comments were actively solicited. Comments were subsequently included in Agency

and Public Comments (U.S. Department of Interior, 1972a), a volume of 63 the final Southwest Energy Study. In accordance with the National Envi-

ronmental Policy Act, Federal agencies involved in the preparation of

environmental impact statements on power facilities in the region were

required to circulate draft statements to the public for review and com-

ment. As a result, comments were received from entities having direct

involvement in the facilities themselves and other entities which had

expressed an interest in power development in the Southwest. Where "practical," comments were considered and included in the final environ-

mental impact statements.

As previously noted, another public participation activity of

this "feedback" orientation is the public opinion survey. Although this

technique has received limited use in the planning of coal-fired power

development in the Southwest, power companies in the region have utilized this mechanism to determine general public attitudes with respect to

power development and pollution control. For example, the Salt River Project undertook a survey to determine how much individuals are willing

to pay for environmental protection while the Arizona Public Service Com-

pany has utilized a public opinion survey to determine the attitudes of Arizonans concerning nuclear power.

Interaction Orientation

As discussed in the overview on public participation in planning,

the Interaction Orientation represents activities which allow for a di-

rect, two-way flow of communication between the planner and the public.

With respect to the planning of the Four Corners power complex, public

participation mechanisms of this type have received very limited use. 64

As noted in Table 7, the utilized activities of this functional orienta-

tion have included panel discussions and conferences.

An example of the former is a panel discussion which was held at

the Colorado Plateau Environmental Advisory Council Annual Meeting at

the Museum of Northern Arizona on September 2, 1971. The panel discussed

the cumulative effects of power plants on and near the Colorado Plateau.

Participants included representatives of the Environmental Protection

Agency, the John Muir Institute, the Hopi Tribe, Peabody Coal Company,

Salt River Project, Arizona Public Service Company, and a number of oth-

er power companies and governmental agencies. Another panel discussion

entitled "Electric Power Development in the Southwest" was held at

Northern Arizona University on March 9, 1971. The panelists consisted

of representatives of the Sierra Club, Peabody Coal Company, Salt River Project, and the academic community.

During the week of May 20, 1971 the Southwest Indian Environmen-

tal Conference was held in Albuquerque, New Mexico. Discussions were to

focus on the implications of power development in the Southwest for

Native Americans. However, tribal leaders failed to appear, power company representatives were not present, and governmental participation

was scant. As a result, the conference provided a forum solely for dis-

senting Indians and environmental groups (Cortner, 1973, p. 63). Other

conferences more indirectly related to coal-fired power development in

the Southwest have included the Colorado River Basin Environmental Con- ference held in Salt Lake City, Utah, on October 15 and 16, 1973 and the

American Association for the Advancement of Science--University of 65

Arizona Energy Inquiry which was held in Tucson, Arizona, on January 17 and 18, 1974. Both of these conferences were organized by academics and attended by invited representatives of government, the power industry,

the academic community, and environmental and consumer groups. These

conferences were designed to facilitate information exchange across a

diverse spectrum of interests, and both conferences utilized group work-

shops to further facilitate this exchange. CHAPTER 6

FRAMEWORK AND RESULTS OF ANALYSIS

Given the review in the preceding chapter of the public participation activities undertaken in the planning and development of coal- fired power development in the Southwest, this chapter explain (1) the framework of analysis which is utilized to evaluate the "adequacy" of these public involvement activities, and (2) the results of this analysis. Evaluative criteria and an evaluation procedure are specified, and results are discussed in terms of defined criteria.

Evaluative Criteria

Although no single "best" set of indicators exists for evaluating the adequacy of public participation activities, a review of the literature (Warner, 1971; Tucker, 1972) did yield three requirements which seemingly characterize an "adequate" public participation program. These three requirements are adopted here as criteria by which to evaluate the adequacy of public participation activities undertaken in relation to the planning of coal-fired electric power development in the Four Corners region. The specified evaluative criteria include:

1. The planning process should provide timely opportunities for members of the public to propose, react to, and discuss poten-

tial alternatives.

2. The public should be aware of the opportunities to participate. 66 67

3. Adequate information should be made available to the public in a

usable form by the planning organization(s) to promote informed

participation.

Evaluation Procedure

Utilizing the preceding criteria, the researcher developed an evaluation procedure which was undertaken to evaluate the adequacy of the public participation activities employed by the power companies and involved governmental agencies in the planning of the Four Corners power complex. The evaluation procedure employed three principal methods: interviews, questionnaires, and a personal review of the public participation activities under consideration.

Five personal interviews were undertaken. Representatives from three power companies (Tucson Gas and Electric Company, Arizona Public Service Company, and Salt River Project); John McComb, Southwest Repre- sentative of the Sierra Club; and T. G. Roefs, a University of Arizona professor familiar with Southwestern environment-energy conferences, were interviewed. To supplement this source of evaluative information, a questionnaire was prepared which was sent with a cover letter (see Appendix A) and a self-addressed, postage-paid return envelope to 24 individuals and groups which in the past had demonstrated an interest in coal-fired power development in the Southwest. Questionnaires were also sent to South- ern California Edison, Utah Power and Light, and the Public Service

Company of New Mexico. The questionnaire (see Appendix A) contained two questions which dealt with the adequacy of past and present public 68 involvement activities related to the planning and development of the

Four Corners complex. After a return period of six weeks, the response to the questionnaire was

The evaluative information obtained by means of the interviews and questionnaires was further supplemented by a "secondary data analysis." This involved an extensive review of the public participation activities actually undertaken (Chapter 5) noting what type of activities were employed, the timeliness of such activities, and who participated.

Results of Analysis

Based on the preceding evaluative procedure and the defined eval-

uative criteria, it must be stated that public participation in the plan-

ning of coal-fired electric power development in the Southwest has been

inadequate. This was the unanimous opinion of many private organizations

and individuals who had demonstrated an historic interest in the Four Corners power complex. Representatives of the involved power companies

were of the opinion that their public involvement practices had been de- activities ficient in the past but recently adopted public participation had sufficiently minimized the "public input" problem. The specific re- in terms of the three sults of the evaluation procedure are discussed the aware- evaluative criteria, the opportunity for public participation, and the availability of adequate ness of public involvement activities,

information. 69

Opportunity for Public Participation

Although it appears from the review in Chapter 5 of utilized public participation activities that a plethora of opportunities has ex-

isted for the public to propose, react to, and discuss power development

alternatives in the Southwest, this has not actually been the case. As

can be seen in Table 7, the Information and Review Orientations have been predominant. Considerable information has been generated and trans-

mitted concerning the Four Corners problem, and the public has been giv-

en a number of opportunities to react to power development plans. However,

it appears that the public has never been given an actual opportunity to

propose alternative plans at an appropriate time in the planning process

and also has never been given the opportunity to engage in meaningful discussions and dialogues with power company representatives regarding

power development alternatives in the Southwest. The reason for this inadequacy concerning opportunities for the

public to propose and discuss power development plans are many. First,

the institutional arrangements, as discussed in Chapter 4, surrounding power development planning and decision-making have mandated, if at all,

public participation activities solely of the Review Orientation. This

participation has generally taken the form of public hearings which, al-

though a necessary element of due process and a definitive forum for a

public airing of the issues, have also been noted for their one-way communication, excessive formality, "one shot" character, and difficulties

in achieving "standing" for appearance. With respect to power develop-

ment in the Southwest, the public hearings, especially the field hearings 70 before the Senate's Committee on Interior and Insular Affairs, served a very valuable function by providing visible forums for the expression of concerns regarding the development. However, as noted in Chapter 6, most of the states in the region did not require hearings on new power plants and transmission lines at the time of the initial Four Corners power development. In regard to the review process for draft environmental impact statements, hearings were held at the discretion of the lead agency and therefore were often not conducted. Thus, given the scope of

coal-fired power development in the Southwest, relatively few public

hearings have been held. Although Arizona, New Mexico, Nevada, and Utah today require pub-

lic hearings in most cases on new power facilities, public involvement

in these proceedings is sometimes difficult. For example, according to Joe Sparks (1974), a member of the Arizona Power Plant and Transmission Line Siting Committee, in hearings before the committee "only written

statements may be made by other than incorporated organizations repre-

senting the public view. In the case of public corporations, they

must be represented by an attorney at the hearing. This procedure obvi-

ously stifles public participation in the hearings." Another institutionalized activity of the Review Orientation,

public comments on draft environmental impact statements, has also served

as a channel for public input. However, due to the excessive length, in- accessibility, and short time allowed for review of draft statements on

elements of the Four Corners power complex, responsible public comment 71 has often been difficult. Similar problems were also experienced with regard to public comments on the Southwest Energy Study.

A second major reason for the lack of opportunities for the public to propose and discuss power development plans in the Southwest involves the public participation activities undertaken by the power

companies themselves. As the utility company representatives noted In personal interviews, at the time of the initial planning of the Four Cor- ners power complex in the 1960's, the public was apparently not interest-

ed. Thus, the power companies saw no need to actively involve the public

in the initial power development plans. However, with the growth of the

environmental movement in the late 1960's and early 1970's and the re-

sultant concern about the environmental impacts of coal-fired power de-

velopment in the Southwest, the involved utility companies commenced public participation programs primarily in the form of public information

meetings. Although such meetings have had the potential of soliciting

public opinions and promoting dialogue with respect to power development,

they have served primarily as an information transfer mechanism. As a

result, the motives of the power companies for undertaking such activi-

ties have been questioned. For example, many consider such meetings to be simply "slick public relation displays" to further justify the plant

or transmission line (McComb, 1974). As Lyndon Keefer (197 )+ ), head of

the Arizona Conservation Council, asserts, "It's approval--not opinion-- these companies seek." It should be noted that although public participation activities

of the Interaction Orientation, specifically panel discussions and 72 conferences, were undertaken, they have been extremely limited in extent.

Two panel discussions, the poorly attended Southwest Indian Environmen- tal Conference, and two indirectly related conferences attended primarily by influentials hardly represented a series of forums for meaningful, public dialogue with respect to the problem. When such activities were conducted, their value in terms of information exchange was noteworthy, but definite problems with respect to the interaction and dialogue among participants were also rapidly apparent. For example, T. G. Roefs (197)-1-), a participant in two conferences on energy development in the Southwest, stated in regard to conference workshops that "there was not sufficient time to form a basis of communication between the participants and sub- stantial misinformation was presented."

Another important aspect of the opportunity for public participation is the "timeliness" of the opportunities to participate. As noted in the overview of public participation in planning in Chapter 2, public participation activities of different orientations are appropriate at specific steps in the planning process. However, with respect to the development of the Four Corners power complex, the public was not informed or involved until extremely late in the planning process and, in most cases, after implementation of the power development plans had actually commenced. That is, most of the public involvement in the planning of coal-fired power development in the Southwest has been "after the fact." For example, the field hearings of the Senate's Committee on Interior and insular Affairs in May, 1971 were conducted at a time when the Four Corners, Mohave, and Cholla Generating Stations were in operation 73 and the San juan, Navajo, and Huntington Canyon Generating Stations were already under construction. Moreover, the Southwest Energy Study and environmental impact statements where filed were prepared, reviewed, and issued while construction of the facilities was ongoing. As Baldwin

(1973, p. )4 6) asserts, "The statements have served only to bring the public up to date on the construction projects that have continued to develop without interruption." As previously noted, the public information meetings undertaken by the involved power companies were of the "shovel-

in-the-ground" type, or involvement of the public after construction on

the plants had begun.

Thus, given the time frame in which the public participation ac-

tivities have been conducted, the only facilities of the Four Corners

power complex subjected to any extent to timely public consideration have

been the proposed Kaiparowits Power Plant and the controversial trans-

mission line from the San Juan Station to Tucson, Arizona. It must be noted, however, that recent meetings held by the Salt River Project re-

garding their "Site Selection Methodology" for the proposed Arizona Power Plant, although oriented primarily toward influentials, represent an in-

itial step in a public participation program which may provide timely opportunities for public involvement.

Awareness of Public Involvement Activities Another significant characteristic of an adequate public partic-

ipation program is the awareness on the part of the Public concerning

the opportunities to participate. Although such public participation activities as the field hearings conducted by the Senate's Committee on 74

Interior and Insular Affairs and also the hearings held by the New Mexico

Public Service Commission and the New Mexico State Planning Office on the San Juan--Tucson transmission line were well publicized, it must be

stated that, on the whole, public awareness of the public involvement activities utilized in the planning of coal-fired electric power development in the Southwest has been very limited. This is the apparent re-

sult of a number of power company and governmental practices.

First, even though the involved power companies have sought to

actively involve the public primarily via public information meetings,

these activities have not been well integrated nor well defined with

respect to the planning process utilized by the power companies. For

example, the elaborate demonstration by the Salt River Project concerning

their "Site Selection Methodology" did not specify the timing and methods

of public involvement in this methodology. It appears that many public involvement activities utilized by the power companies have not been

part of a coherent, well-defined public participation program, thus lim-

iting public awareness of when and how to participate. A similar argument can be made with respect to the Federal gov-

ernment's involvement and ensuing public participation activities regard-

ing the Four Corners power complex. Due to the disorder surrounding

the environmental impact statements on portions of the complex, the non- specification of public participation activities with respect to the

Southwest Energy Study, and the lack of definition regarding the Depart- ment of Interior's decision-making process and public input to that 75 process (Raskin, 1974), public awareness of opportunities to participate

in federally sponsored activities has been inhibited.

A final factor related to this limited awareness has been the

inadequacy of notification procedures for hearings, public meetings, and

requests for written comments on reports. Notices to the public pertain-

ing to these activities have customarily taken the form of obscure public

notices in a limited number of newspapers. For example, the Arizona

Power Plant and Transmission Line Siting Committee placed public notices

in only local newspapers concerning the public hearing on the addition

to the Cholla Generating Station (Tellman, 1974). It should also be

noted that the Arizona Siting Committee's supplementary mailings to in-

dividuals requesting notice of pending hearings have also been erratic

(McComb, 1974). As a result of such shortcomings, the public has often

been unaware of public involvement activities conducted by governmental

entities and power companies regarding power development in the South-

west.

Availability of Adequate Information

A fundamental aspect of an effective public participation program

is the availability to the public of adequate information concerning the

proposed action in a usable form so that informed ana responsible public

input can be attained. As noted in the review in Chapter 5 of the public

participation activities of the Tnformation Orientation undertaken with

regard to the development of the Four Corners power complex, considerable information was generated. However, the adequacy, availability, and the

form and source of this information have been the topic of much debate. 76

Adequacy. Although numerous reports such as the Southwest Energy

Study, environmental impact statements, and utility company studies have been put forth, it must be stated that there have been definite shortcomings associated with these reports. The Senate's Committee on Inte- rior and Insular Affairs stated in its report, Problems of Electric Power

Development in the Southwest (1972, p. 24):

There has been and still is insufficient available information on which to base sound resource management decisions. This inadequacy of information relates to baseline environmental data, to the day-by-day activities associated with the planning, construction, and operation of the Southwest thermal power plant complex, and to basic knowledge of the physical and physiolog- ical environmental impacts of such developments.

Although the Committee's report was put forth prior to the completion of the Southwest Energy Study and the issuance of environmental impact statements, one of the report's basic findings, the insufficiency of available information on which to base decisions, is still applicable to a great extent to major aspects of coal-fired power development in the

Southwest.

For example, the Southwest Energy Study, billed as a comprehensive analysis of power development in the Southwest, clearly exhibited the severe time and resource restrictions under which the Department of

Interior team operated. As a result of such limitations, the Study (1) examined less than all coal-fired plants in the Southwest; (2) was, ow- ing to the inability to undertake field studies, deficient with respect to basic environmental data; and (3) inadequately considered future electricity demand and potential alternatives for power generation. En- vironmental impact statements prepared by involved Federal agencies have 77 also evoked suspicion due to their apparent reliance on utility company

information and data contained in the power companies' "applicants' analyses."

Although these information sources have been supplemented by utility and mining company reports and public information meetings, it must be concluded that, as Cortner (1973, p. 183) states, much of the

information available "contained hearsay, incomplete, and often contra-

dictory and sometimes erroneous findings."

Availability. The public has experienced a number of difficul-

ties in obtaining information concerning the development of the Four

Corners power complex. The Senate's Committee on Interior and Insular

Affairs stated in the "Findings and Recommendations" section of its re-

port, Problems of Electric Power in the Southwest (1972, p. 23): "There

is evidence . . that public information about utility plans until re-

cently has been inadequate."

For example, interested groups and individuals experienced con-

siderable difficulties in acquiring copies of mining and utility company

leases made with the Indians. Problems were also experienced regarding

the acquisition of Department of Interior reports on aspects of the de-

velopment, e.g., mining at Black Mesa, and utility company data on power plants and transmission lines. For example, the League of Women Voters, after several written and oral requests to the Arizona Public Service

Company, ultimately had to acquire the assistance of the Environmental

Protection Agency to obtain information on the Cholla Generating Station

(Wiebe, 1974). Although drafts of governmental reports such as the 78 Southwest Energy Study and environmental impact statements were available to the public on request, the general availability of the final reports was a problem. This was due primarily to the meager distribution

of reports to repositories in the Southwest, limited printing, and the

resulting necessity of ordering and paying for reports from Washington, D.C. However, it should be noted that the Colorado Plateau Environmen-

tal Advisory Council library in Flagstaff, Arizona, became a depository

for numerous utility and mining company and governmental reports and

thus improved to an extent the availability of information to the public

concerning coal-fired power development in the Southwest.

Form. Another fundamental aspect of the availability problem is

the form or mode in which power development information is transmitted

to the public. In personal interviews with power company representatives, this was defined as the "stickiest" problem of public involvement. As can be discerned from the previous review of the public participation

activities of the Information Orientation utilized in the planning of

the Four Corners power complex, the present modes of information trans-

fer have been primarily reports and, to a lesser extent, public informa-

tion meetings. However, reports such as environmental impact statements,

the Southwest Energy Study, and consulting company reports have in most

cases been voluminous and have contained considerable amounts of "boiler- plate." As a result, it has often been difficult to utilize such docu- ments to quickly comprehend the projected impacts of a given power

development alternative. The transfer of information in public informa-

tion meetings and also workshops has suffered due to a lack of "hard," 79 quickly retrievable data and an ensuing reliance on "off the top of the head" statements and suppositions. As a result, many discussions in

such forums have been extremely superficial and unproductive (McComb,

1974; Roefs, 1974).

Source. A final problem related to the adequacy and availability

of information has been the "one-sided" character of the information con-

cerning coal-fired power development in the Four Corners region. Although

environmental groups and other interested parties have developed exper-

tise and information on the subject to a degree and have attempted to

disseminate this knowledge via hearings, panel discussions, and reports,

the bulk of the available information on the impacts of the Four Corners

complex has originated from a single source, the involved utility com-

panies.

For example, even though the Southwest Energy Study and the is-

sued environmental impact statements were prepared by "independent,"

governmental agencies, these reports relied heavily on information sup-

plied by utility companies or their retained, engineering-consulting

companies. The Arizona Power Plant and Transmission Line Siting Commit-

tee represents a further example of this utility company monopolization

of power development information. Due to a shortage of funds ana person- nel, the Siting Committee is incapable of undertaking independent studies

on the impacts of proposed generating stations and transmission lines

and therefore must rely on information supplied by the power companies. Concerned private groups and individuals are faced with a similar 80 situation. Independent studies are expensive propositions and demand a level of expertise not often found outside utility or consulting companies.

Coupling this "source" problem with the previously discussed information problems clearly depicts the dilemma the public has faced in becoming "informed" on the facts and impacts of power development in the region. As a result, statements made by the public in hearings and other forums have often taken the form of emotional and philosophic appeals relating to new power plants and transmission lines. Joe Sparks

(1974), a member of the Arizona Siting Committee, states:

Most often the information is so sparse and limited that the public does not know what to criticize, and therefore, in the view of the hearing officer, the public comments are not substantive but rather take on the nature of comments for or against power plants generally. This may be partially accurate but may be merely the result of the kind of information available to the public. CHAPTER 7

RECOMMENDATIONS AND CONCLUSIONS

Given the evaluation in the preceding chapter of public participation in the planning of coal-fired electric power development in the

Southwest, it must be concluded that the public involvement activities

utilized by the involved utility companies and governmental entities

have been inadequate. Similar findings have been reported with respect

to other specific power development cases (Ball et al., 1972; Borelli et al., 1971) and general power development planning (Office of Science and

Technology, 1970; Rational Academy of Engineering, 1971). Numerous in-

dividuals representing governmental entities, the utility industry, and

environmental organizations have also voiced displeasure with the pres-

ent state of public participation in power development planning in hear-

ings at the federal level (U.S. House of Representatives, 1971; U.S.

Senate, Committee on Commerce, 1972). For example, John N. Nassikas,

Chairman of the Federal Power Commission, stated in testimony before the

Senate's Committee on Commerce (1972, p. 304): "I don't think there is

adequate public participation today in the preparation of power devel-

opment plans. I think we have made some improvements, but not enough."

Given the deficiencies defined with respect to public participation in the planning of coal-fired power development in the Southwest and the

general enigma of effectively involving the public in power development 81 82 planning, four basic recommendations for improved public participation are advanced.

ElElt, public participation activities of the Interaction Orien- tation such as workshops, seminars, task forces and citizen advisory boards should be utilized to a much greater extent in power development planning. From the review of public participation activities utilized in the planning and development of the Four Corners power complex in

Chapter 5, it can be clearly discerned that public participation has been thoroughly dominated by activities of the Review and Information

Orientations. However, interviews, written correspondence, and a review of power planning problems have emphasized the need for forums where meaningful, two-way communication can take place among individuals with different perspectives concerning power development. The Colorado Pla- teau Environmental Advisory Council (C.P.E.A.C. Newsletter, 1973, p. 4), in further defining its role in the environmental protection--energy development controversy, stated: 'More give and take opportunities should be provided among all parties by developing workshops, forums and small group sessions devoted to specific topics with a view toward estab- lishing a common meeting ground • • " Workshops and other mechanisms of the Interaction Orientation, as distinguished from the present public information meetings, would provide forums for more direct dialogue between the utility companies and the public regarding power development alternatives and the effects of those alternatives. Although, as noted, workshops and group meetings have suffered in the past from information problems and a lack of time to form the basis for suitable communication 83 between participants, their fundamental potential for providing forums

for communication among diverse parties has been confirmed (Borton,

Warner, and Wenrich, 1970). Therefore, if workshops and small group

meetings are conducted in a series, thus providing time to establish

communication, and if they include devices to rapidly obtain desired fac-

tual information, the major shortcomings of such public participation

activities should in all probability be minimized and an atmosphere con-

ducive to constructive interaction and dialogue will be available.

It should be noted that public involvement activities of the Re-

view Orientation, particularly public hearings, do play a very necessary

and important role in public participation in power development planning.

Such activities may be of even more value if they follow a series of

workshops or other activities of the interaction Orientation where power

development alternatives and effects are discussed and related informa-

tion disseminated. However, for such activities to be a truly effective

means of public participation in such a process, the present problems of

public hearings such as the difficulties in achieving "standing," repre- sentation dilemmas, e.g., Arizona Siting Committee, and the tendency to

conduct hearings outside affected areas must first be resolved.

A second, general, recommendation relates to the need to involve

the public earlier in the power development planning process. As re-

vealed in the review in Chapter 5, most of the public participation ac-

tivities undertaken have been ex post facto in nature. Public involvement

in most cases has taken the form of informing the public of on-going proj-

ects and soliciting public reaction. How ,..wer, in a Rand. Corporation. 84 study on the problems of power plant siting, Ball et al. (1972, p. xi) state that "early and continuous public involvement in power system planning is essential." The study goes on to state that delays in obtaining power plant and transmission line licenses and permits due to public opposition are closely related to the inability of the public to make their views known before the utility companies are committed or "locked In" to particular sites.

Kaufman (1971) has related this lack of public involvement in the early stages of power planning to the fragmentary regulation of power development. As noted in Chapter 4, the governmental sanctions with respect to fossil-fueled power development are limited essentially to piece- meal control at the state level; public participation activities in state regulatory proceedings, if required at all, generally take the form of public hearings on the issuance of a license or certificate for a specific plant or line. In response to such public participation problems and related delays in power plants and transmission lines, numerous legislative proposals at the federal level have been advanced to create an integrated, rational process in which the planning of power development can take place. Such proposals (U.S. House of Representatives, 1971;

U.S. Senate, Committee on Commerce, 1972; Council on Environmental Qual- ity, 1971a, 1973a) stress the need for comprehensive, coordinated institutional arrangements for long-range planning and pre-construction reviews by governmental entities at the state or regional level. Within such a planning and review framework, "one-stop" certification by a state, regional, or federal entity is provided for the benefit of the utility 85 companies and early and well-defined public involvement is specified.

For example, although variations exist in the proposals, the general trend

is to actively involve the public in (1) the review of 10-year plans submitted annually by utility companies, (2) an inventorying and review of

alternative sites conducted five years in advance of construction, and

(3) a certification proceeding relating to plant and transmission line

specifics two years before construction. This and similar planning

schemes have been criticized by the utility industry and environmental

organizations on such grounds as the "impossibility" of involving the

public early in the process, the belief that "one-stop" certification

will choke off in-depth analysis, and the presumption that review bodies

will not be "representative." However, it appears that such planning

schemes, if operated effectively and fairly, can (1) decrease the number

of delays, uncertainties, and costly design revisions experienced in the

past by utility companies, (2) provide a well-defined series of opportu-

nities for timely public involvement in the plann'ng process, and (3)

reduce the confUsion which presently reigns with respect to power devel-

opment planning and decision-making.

In addition to the need for mandated public participation activ-

ities throughout the power planning process, utility companies should

also endeavor to privately involve the public in their early planning in

the form of workshops, small group meetings, and citizen advisory boards.

The Salt River Project's "Site Selection Methodology" demonstration rep-

resents a good example of early public involvement. 86

A third, general recommendation relates to the need to increase awareness of the public concerning the opportunities to participate. As

noted in Chapter 6, the public was often not aware of public participa-

tion activities undertaken in the planning and development of coal-fired

power development in the Southwest. Specifically, better notification

procedures are imperative. Siting and review bodies and also utility

companies must go beyond the legal notice requirement and publicize pub-

lic participation activities in newspapers of local, statewide, and re-

gional circulation and on radio and television stations covering the

affected area. Such advertising mechanisms could also perhaps be supple-

mented with brief and easily read information bulletins and mailings to

interested parties. Awareness of opportunities to participate could al-

so be enhanced by the institution of a more orderly and well-defined

procedure for power development planning which specifies a coherent sched-

ule for public participation, e.g., the discussed legislative proposals

for siting and power development planning.

The fourth and final recommendation involves the need for more

available and adequate information in a more usable form. As specified

in the preceding chapter, definite shortcomings have existed in this

area with respect to data on coal-fired electric power development in

the Southwest. In regard to the availability of information, it is ap-

parent that power companies can no longer remain so secretive. They must

make their long-range plans and data on power facilities and the result-

ant impacts available to the public. The Association of the Bar of the

City of New York states in its report, Electricity and the Environment-- 87

The Reform of Legal Institutions (U.S. Senate, Committee on Commerce,

1972, p. 820): "Improved access to information is essential if the 're-

sponsible' public participation . . is to become a reality, since no

one can make an adequate presentation in the complex electricity/environ-

ment area without access to the facts." The availability of environmental

impact statements, other government reports, and also hearing transcripts

could be improved by the printing of more copies and by making them

available free of charge or at a reduced cost.

Based on the problems of the form of information available to

the public as specified in the preceding chapter, it is apparent that

new information technologies and methods must supplement the presently

sanctioned and utilized modes of information dissemination. For example,

a computer-based information retrieval system. (Layton, in prep.) now in

the process of being developed and tested at The University of Arizona

may ameliorate the information transfer situation. The system is com-

posed of remote computer terminals, i.e., cathode ray tubes, which are

capable of rapidly retrieving computerized information for display to

individuals or groups. Such a system applied to power development plans

would enable users to selectively and rapidly evaluate on a number of

different dimensions the impacts of different power development alterna-

tives. It also appears that such a computerized information system might

also be utilized in the previously recommended. workshops and other activ-

ities of the Interaction Orientation to serve as a rapid information

source and to function as a nucleus for interactio n among diverse par-

ties. 88

In regard to the substantive adequacy of the present information available concerning the Four Corners power complex, it is recommended that additional, comprehensive studies be undertaken regarding energy demand forecasts, possible alternative power generation methods, environmental effects, and the impacts on aesthetic and recreational values.

Given that such studies most likely will be undertaken by utility companies via their retained engineering -consulting companies or by gov-

ernmental agencies heavily dependent on the information provided by the utility companies and that the public will be very skeptical of such

seemingly "one-sided" information, independent studies should be under-

taken by defined outside interests and/or potential intervenors. Since

such studies are prohibitively expensive for most "public interest"

groups, funds and expertise should be provided by siting or review agen-

cies to independent task forces representing the concerned, public in-

terests to undertake appropriate studies. Although such subsidization

is undoubtedly controversial, it is hoped that studies undertaken by such

task forces will provide an independent evaluation of the impacts of pow-

er development and promote public confidence in the proceedings of siting

and review agencies. In conclusion, it is apparent that public participation in the

planning of coal-fired electric power development in the Southwest has

been, in a procedural sense, very limited and inadequate. This short-

coming is partially due to the fact that the planning and development of

the Four Corners power complex occurred in a period of transition when demands were first being advanced for increased public participation in 89 héitural resources and environmental planning. Thus, actively involving the public in power development planning was, at that time, a relatively new phenomenon, and utility companies and involved governmental entities had had relatively little experience in this venture. As a utility representative related in a personal interview, "We're new at this game."

Another reason for this "procedural" inadequacy in public participation has been the fragmentary institutional framework in which planning and decision-making for fossil-fueled power development tran- spires. Although some incremental changes have been made, e.g., the

Arizona Siting Committee, it is readily apparent that major institutional changes are imperative if power development plans and decisions are to be made in a rational and orderly manner.

Given the time frame in which the basic planning of the Four

Corners complex has occurred and the institutional setting, definitive

inadequacies in public participation have existed in regard to (1) the opportunities to participate, (2) the timeliness and public awareness of

such opportunities, and (3) the availability, form, source, and substantive nature of public information. Although such problems have existed

in the past, activities and devices are available or are being developed and institutional changes are being considered to cope with the public participation enigma. Problems not addressed in this study such as how to deal with the "silent majority," how to weigh conflicting public desires, and how to transform public concerns into engineering realities must also receive serious consideration. 90

In closing, it should be noted that although significant deficiencies have been experienced in the past, active public participation in power development planning and decision-making has the ultimate potential of arriving at power development plans and decisions more favorable to the public interest, thus minimizing costly delays due to public oppo-

sition. Public involvement programs have the capability of achieving this goal by improving the quality of power development plans and deci-

sions and increasing public confidence in both power development plans and decisions and the planning ana decision-making processes. APPENDIX A

EVALUATION PROCEDURE SAMPLES

91 92

THE UNIVERSITY OF ARIZONA TUCSON, ARIZONA 85721

COLLEGE OF EARTH SCIENCES

DEPARTMENT OF HYDROLOGY AND WATER RESOURCES TEL. (6021 R4-3131

February 8, 1974 Mr. Lyndon Keefer Arizona Conservation Council P. 0. Box 11312 Phoenix, Arizona 85061 Dear Mr. Keefer: A team of faculty and graduate students in the Department of Hydrology and Water Resources at the University of Arizona is studying coal-fired electric power development in the Southwest. At the present time, we are studying the procedures followed by power companies in the planning of large-scale, coal-fired electric power plants and associated transmission lines. We are especially interested in the public involvement activities utilized by power companies and government agencies in such planning and also how adequate such activities (for example public hearings and power company presentations) have been in informing the public and allowing for public feedback on proposed plans. Since you or members of your group were perhaps involved in such activities, would you please answer the two enclosed questions concerning the adequacy of past and present public involvement activities utilized in the planning of electric power development in the Southwest? After completing the two questions, please return the question sheet to us in the enclosed self-addressed envelope. Thank you for your time.

Dan B. Kimball Graduate Student 93

PUBLIC INVOLVEMENT EVALUATION QUESTIONS

(please attach additional pages or use opposite side if more space is necessary)

1. Do you feel that past procedures for transmitting information to the public concerning coal-fired electric power plants and associated transmission lines in the Southwest and also for involving the public in power plant planning and decision-making have been adequate? (je., the adequacy of public involvement procedures utilized in the planning and development of such coal-fired power plants as the Four Corners, Navajo, Mohave, and San Juan Generating Stations). El Yes 0 No Please Explain:

2. What is your opinion regarding the adequacy of present information dissemination and public involvement procedures utilized by power companies and such regulatory bodies as the Arizona Power Plant and Transmission Line Siting Committee? (please explain) SELECTED BIBLIOGRAPHY

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