XIII. NO PROJECT ALTERNATIVE COST-ANALYSIS

UCAN also complains that SDG&E ignored the ALJ and failed to do a cost- analysis comparison of its Proposed Project versus the EIR's No Project Alternative. UCAN argues that because we did not have this cost analysis, we lacked a basis to evaluate the No Project Alternative. UCAN's allegation lacks merit because there is a sufficient basis to conclude that the Sunrise project is more cost-effective than the No Project alternative.

As explained in the EIR, the No Project Alternative is a menu of options that would replace the Sunrise project, but contains more options than would be required to replace Sunrise. (See EIR, at p. ES-74.) Thus, the In-Area All-Source Generation Alternative, In-Area Renewable Generation Alternative and LEAPS Transmission-Only Alternative are all possible configurations of the No Project Alternative. (Ibid.) Because the record contains cost-studies that evaluate the cost-effective of these alternatives (see Decision, at p. 161, Table 15), likely configurations of the No Project Alternative have in fact been analyzed. Therefore, contrary to UCAN's argument, the Decision has an adequate basis for judging the cost-effectiveness of the No Project Alternative.

UCAN also reprises its complaint that the EIR, as opposed to the Decision, fails to analyze the cost-effectiveness of UCAN's separate No Project Alternative, or the EIR No Project Alternative. (UCAN Rehrg. App., at p. 66.) As discussed below, and the EIR already notes, such an economic analysis is not the role of an Environmental Impact Report (EIR, 3-850), and CEQA does not require a cost-benefit analysis of the project. The only economics the EIR considers is whether the alternatives are economically feasible (possible, capable of being accomplished). (See Kings County Farm Bureau v. City of Hanford, supra, 221 Cal.App.3d at p. 736.) Outside the EIR, the Commission must consider the cost-effectiveness of project alternatives (see Pub. Util. Code, § 1002.3), but, as discussed, it has done so.