18. Please state whether approval of A.04-05-039 will result in (a) new construction, (b) changes to the operations of COTC or its subsidiaries, and/or (c) changes in the use of existing assets or facilities. If so, please provide (a) a detailed description of (i) the new construction, (ii) changes in operations, and/or (iii) changes in use of existing assets or facilities, and (b) a detailed description of why the Applicants believe the California Environmental Quality Act does not apply. (A.04-05-039, p. 6)