This is a DRAFT response. This will be discussed and probably modified at our subcommittee meeting on October 29, 2015, and our full Planning Group Meeting on November 5, 2015.
DRAFT October 29, 2015
Comments
on CPUC Draft Environmental Impact Report on:
Sycamore-Pensasquitos 230-KV Transmission Line Project,
State
Clearinghouse No. 2014081031
Prepared
by: Scripps Miramar Ranch Planning Group
Introduction: The Scripps Miramar Ranch Planning Group
(SRPG) is one of the Community Planning Groups chartered by the City of San
Diego. The SRPG provides consultation
and recommendations to the City, County, State, and other agencies regarding
planning, land use, transportation and traffic, public safety and other issues
for the city planning areas of Scripps Miramar Ranch and Rancho Encantada.
The
SRPG has identified the following misstatements, inaccuracies, and
insufficiencies in the Draft EIR.
Issue 1: Improper CPUC Conclusion
ES.1.1: The CPUC’s conclusion that Alternative 5 is
Environmentally Superior is improper because the DEIR does not completely and
accurately analyze environmental impacts, for the reasons stated below. The DEIR does not provide an accurate and complete
basis for the CPUC’s conclusion.
Issue 2: Insufficient Public Notice
ES
4.1.1: The Notice of Preparation did not
mention Alternative 5.
ES
4.1.2: The public Scoping Meetings held
on August 25-26, 2014 made no mention of Alternative 5.
ES
4.1.2: The Scoping Report and Appendices
dated September 2014 and posted online made no mention of Alternative 5.
No
public announcement regarding the proposal or consideration of Alternative 5
was made. It was first publicly mentioned
in Data Request 8 on March 4, 2015 (but referred to as “Alternative 4”). This data request, however, was made only to
SDG&E and not to any other interested parties including SRPG. The responses from SDG&E returned
information to the CPUC but not to any other interested parties.
Additional
information about Alternative 5 was requested by the CPUC in Data Request 10 on
April 8, 2015, including specific information about EMF modelling. This is the first mention of it in the Public
Record. The SDG&E response on April
21, 2015 is particularly enlightening: it essentially says, “this would take
too long, and you don’t need it anyway.”
Instead it recommends that the CPUC withhold such information from the
public and from decision makers, arguing “there is no agreement among
scientists that EMF creates a potential health risk and there are no adopted
CEQA Standards for defining health risk from EMF.” Further, it recommends that “An EIR may
instead conclude that no accepted methodology or standards exist to measure an
impact, and such a finding may be upheld if supported by evidence and analysis
showing that a reliable method for assessing an impact is not available.” The CPUC and SDG&E should present data
and modelling results and let the public and decision makers evaluate it. Without this, the DEIR is incomplete.
It
is clear that there has been no real public involvement in the identification
or evaluation of alternatives. The
45-day comment period provided for review of the DEIR is not sufficient to
allow careful analysis and consideration of alternatives. Instead the NOP and Scoping process should
have been re-opened to allow sufficient public awareness and input regarding
alternatives.
Issue 3: Incomplete Analyses of Alternative Impacts on
Biological Resources:
ES.6.2.2(5)
and all of section 4.1.13 omit any mention of the proximity of Carroll Creek, a
federally designated wetland, which runs close to and immediately downhill from
the south side of Pomerado Road.
Construction would undoubtedly result in disturbance of this area and
contamination with dust and construction debris. Over time, the installation of the
underground line and massive splice vaults will also change hydrology of the
creek and therefore affect its biology.
There
is no mention in the DEIR of coordination or contact with any of the Federal
agencies with jurisdiction over this area, such as the Army Corps of Engineers,
the U.S. Fish and Wildlife Service and/or the Environmental Protection Agency. It appears that the engineering plans for
Alternative 5 are incomplete so that the exact routing for the line is unknown (see
below).
Issue 4: Incomplete Analyses of Aesthetics:
ES.6.3.2(5)
and Section 4.2.13 omit any mention of the installation of over 30 manhole
covers along Pomerado Road and Stonebridge Parkway. Section 4.2.15 improperly concludes that
“there is no lasting aesthetic impact from the underground transmission
line. Pomerado Road is a designated
historic roadway – old US-395. Manholes
and other pavement anomalies are unsightly and over time lead to
discontinuities in the roadway which are both visually unappealing and a hazard
to traffic.
ES.6.3.2(5)
also omits any mention of the above-ground segment over I-15 although it is
covered in section 4.2.13 where the aesthetic impact is improperly dismissed. This location is essentially the entrance to
Scripps Ranch. This alternative would
add visually unappealing towers, power lines, and marker balls in the most
visible area of Scripps Ranch, in an area visible not only from I-15 but from
many residences and businesses in Scripps Ranch.
Issue 5: Incomplete Analyses of Geology, Soils, and
Mineral Resources:
The
DEIR, Section 4.5.12 states: “…a
geotechnical investigation has not been perfomed…. Alternative 5 Route is located near surface
water resources (Carroll Canyon Creek) where shallow groundwater would be
expected; therefore, it is assumed that these areas could be subject to lateral
spreading or liquefaction.” Later it
states that a geotechnical investigation is needed and that the results would
be incorporated in the Final design.
At this point, the DEIR is incomplete.
Issue 6: Incomplete Analyses of Hydrology and Water
Resources:
ES.6.7.2(5)
notes that the transmission line would be located in a 100-year floodplain, but
the only impact mentioned is possible scour of the line. In addition, however, the line’s placement
would impact water flow in and around Carroll Creek, a federally designated
wetland, especially during heavy storm water periods (which incidentally occur
much more frequently -- at least every 10 years).
Section
4.6.12 states “The underground alignment would cross Carroll Canyon Creek via existing
roadway culverts. The underground duct bank construction and transmission line installation
would not alter the course of a stream or river because it would be located in the
existing roadway alignment above or below the stream channel.” This section is incorrect in several
respects. First, there are no existing
roadway culverts along the Pomerado Road route depicted in Figure E.6, wherein
the road crossing is shown as new construction.
Second, as discussed below, there is insufficient roadway width to
safely construct the line and vaults (particularly MH11-13) within the existing
Pomerado Road alignment, and if they are located south of the roadway, then
installation will not be impervious in the existing alignment, but instead in
the Carroll Creek area, a federally designated wetland, and a FEMA flood zone
as shown in Figure 4.6-5
Issue 7: Incomplete and Inaccurate Analyses of
Transportation and Traffic:
Pomerado
Road is a main travel route for residents of Scripps Ranch and Rancho Encantada,
as well as residents of Poway, Ramona, and other areas to the east. It is a designated historical route (US-395)
and is a designated evacuation route. It
is currently at LOS F in both directions at peak (not E as claimed in the DEIR).
Scripps
Ranch was affected by the 2003 Cedar Fire, to date the largest wildfire in
California history, and was also evacuated in 2007 during the second largest
California wildfire. Pomerado Road is a
main part of the evacuation plan approved by the San Diego Fire Safe Council,
the City of San Diego Fire / Rescue Department and Homeland Security
Department, and the San Diego City Council.
It is the only exit for many residents on the south side of Pomerado Rd,
and a main escape route for residents of Rancho Encantada, Poway, Ramona, and
eastern parts of San Diego County. The approved
evacuation plan requires three lanes of travel on Pomerado during an
emergency. While the DEIR mentions that
Pomerado Road has only two marked lanes, the pavement is barely wide enough for
three traffic lanes including the bicycle lanes in many areas. The Fire plan in Appendix I does not mention
the possibility of evacuation. The DEIR
fails to note that disturbance of the traffic along this route, including the
bicycle lanes, for a year or more of construction is absolutely
unacceptable.
At
this point, there is insufficient information in the DEIR to judge the impact
and adequacy of analysis. Appendix E
contains detailed route maps for Alternative 5.
Simple
inspection of these maps, however, reveals that they were prepared with little
knowledge of the area and little engineering analysis. For example, Figure E-6, maps 3 through 8
show a proposed route mostly along the south edge of Pomerado Road. There are two issues: First, a main wastewater line runs almost
exactly along much of that path. Second,
in many places along the route, there is a significant downslope. Several splice vaults (e.g. MH12, 13, 15,
16), because of their size, would either need to be located nearer to the
center of the roadbed (leaving insufficient safe width for two traffic lanes),
or would require shoring and major road reconstruction. In either case, construction would take
longer, and result in much more traffic impact.
Further, construction would be more likely to materially affect the
federally designated wetland immediately below.
There
is no analysis of the effect of construction on the I-15 interchanges and the
daily backups that occur, and no analysis of the traffic impact on Marshall
Middle School. Freeway on-ramp traffic is
heavily affected in the morning by MMS, and off-ramp traffic and traffic along
Pomerado Road is almost at a standstill during afternoon dismissal and into
business rush hours.
Operation
of Alternative 5 will lead to continuing unacceptable disturbance of traffic on
a designated emergency escape route. Pomerado
Road will have at least 12 large splice vaults, and at least 24 new 36”
manholes. Even if installed perfectly, manholes
will distract drivers and lead to swerving or slowing. Missing or misplaced manhole covers will
cause accidents and disrupt traffic. But
typically and especially over time, the splice vaults and manholes will result
in uneven pavement, more visual disturbance, and potholes, particularly in
light of the City of San Diego’s record on deferred street maintenance. This will result in additional disturbance to
traffic, which, because the road is at LOS F already, is a significant and
immitigable environmental impact.
Pomerado
Road has a class 2 bicycle lane in each direction not separated from
traffic. This is the first bicycle route
that provides east-west connectivity north of SR-52, and it is a main segment
from San Diego to the only north-south bicycle route to Poway, Escondido and
other points north along the old US-395 corridor. There is no other continuous north-south
bikeway near I-15. Construction of the transmission line will close this route for
at least a year during construction, because there is not sufficient roadway
width for traffic lanes.
Operation
of Alternative 5 will lead to continuing disturbance of traffic as described
above, and this will lead to unacceptable bicycle safety issues along the
Pomerado corridor. This could be
mitigated by installation of a Class 1 bicycle lane adjacent to Pomerado Road along
with the proposed transmission line.
Section
4.7.13 fails to mention that the overhead portion of the transmission line
across I-15 is immediately adjacent to Miramar Marine Corps Air Station in an
airport influence area, and in a main military helicopter transit lane. While this section claims that compliance
with FAA requirements will make the operational impact less than significant,
this is unlikely due to proximity to the Air Station.
Section
4.7.13 also fails to mention that the I-15 overhead is within about ¼ mile of
the Southern California TRACON, the FAA’s air traffic control facility for all
of Southern California, and is very near the Miramar MCAS. The TRACON serves most airports in Southern
California and guides about 2.2 million aircraft over roughly 9,000 square
miles in a year, making the facility one of the busiest in the world. The TRACON
provides radar air traffic approach control services to all arriving and
departing aircraft for most airports in Southern California. SCT's airspace
covers an area from 20 miles north of Burbank to the US/Mexican border and from
San Bernardino to Santa Catalina Island.
Ongoing electrical
and corona interference from operation of the overhead transmission line is
likely to impact radio communications at both the TRACON and Miramar MCAS.
Issue 8: Incomplete and inaccurate Analysis of Fires
and Fuels Management.
ES-6.13.2(5): The analysis completely ignores the fire
danger along Pomerado Rd, which at present is one of the most fire-prone areas
in San Diego County. Large amounts of
dry, overgrown, unmaintained brush and trees are within 10 to 20 feet of
Pomerado Road immediately adjacent to the route shown in the maps in Figure E-6. The fire danger is already under study by the
Fire Safe Council, the San Diego City Council, County Supervisor, our State
Assembly Member, and our Member of Congress.
The
Fire Plan in Appendix I makes no mention of how to accommodate a mandatory
evacuation, such as those that have been ordered twice in the last 12
years. Pomerado Road is a designated
evacuation route, not only for Scripps Ranch, but for Rancho Encantada, Poway,
Ramona and other northeast county residents.
Issue 9: Incomplete Analysis of Health and Public Safety.
There sould be a
separate health and public safety analysis for the Pomerado Road evacuation
route resulting from anything that would impact the free flow of traffic.
This would be especially true at night when there may be construction crews and
trucks in place (Construction might be done at night to avoid impact in the day
traffic).
Combine construction
crews, changed traffic work-arounds, and darkness in an emergency to aggravate
the evacuation issue. The heavy traffic (already observed during previous
evacuations) would be made substantially worse by any construction during fire
/ smoke conditions which would result in high impact effects on breathing /
pulmonary / heart conditions as well as asthma, allergies, and any stress
related illness.
Worse, any construction
that would force a re-directed evacuation would add confusion and anxiety and
increase possibilities of death or injury.
Issue 10: Incomplete Analysis of Greenhouse Gases.
ES.6.15.2(5): The analysis ignores the additional vehicle
emissions from waiting during construction due to lane restriction. Operation of Alternative 5 will lead to
increased vehicle emission due the continuing disturbance of traffic as
described earlier.
Issue 11: Incomplete Analysis of Utilities and Public
Service Systems.
ES.6.18.2(5):
Pomerado
Road is a main travel route for emergency service vehicles in Scripps Ranch and
Stonebridge estates, as well as for Poway, Ramona, and other areas to the
east. The analysis ignores the traffic
disturbance due to construction and ignores the fact that lane restrictions due
to the narrow width of Pomerado Road would continue to impede emergency
vehicles during operation.
Issue 12: Incomplete Analysis of Impact on Military
Readiness.
There
is no mention in the DEIR of any coordination or contact with the Navy or
Marine Corps regarding Alternative 5 and the impact, if any, on the Marine
Corps Air Station Miramar, the Navy Operational Support Center / Marine Corps
Reserve Center, the Lincoln Military Housing at Pomerado Road and Scripps Ranch
Row, or the East entrance to MCAS Miramar East at old Spring Canyon Rd /
Sycamore Test Rd.
Issue 13: Incomplete Analysis of Cumulative Impacts.
ES.7.3
and Table ES.7-1 ignore the following Impacts in the Scripps Ranch area associated
with Alternative 5:
·
Continuing
alteration of biology in the Carroll Creek watershed due to alteration of water
flow.
·
Continuing
degradation of visual appearance due to over 30 manhole covers installed in a
historic highway.
·
Continuing
effects due to alteration of hydrology in the Carroll Creek area.
·
Continuing
significant and unavoidable impediments to traffic flow due to pavement anomalies
from splice vaults and manholes.
·
Continuing
increased danger to cyclists due to traffic interference with current class 2
bicycle lanes.
·
Continuing
long term increase in Greenhouse Gases due to traffic restriction.
·
Continuing
interference with air traffic and communications
The
most important cumulative impact is on future Utility and Service systems. This impact is completely ignored in the
DEIR. Aside from any induced-current
effects on existing utilities, the new transmission line will prevent or
greatly increase the difficulty of construction of new or upgraded sewer,
stormwater, potable water, recycled and reclaimed water, natural gas, residential-electricity,
telephone, and data communications facilities along Pomerado Road and
Stonebridge Parkway. Physically, the
large volume of concrete and the extensive splice vaults will have to be
avoided in any future repair of existing facilities or construction of new
facilities. Induced current and magnetic
effects may preclude installation of any future systems involving metal piping
or conductors. These impacts might be
partially mitigated by coordinating with other utilities and installing new
systems at the same time and as a condition of approval as the proposed
transmission line. For example, a
reclaimed water line (“purple pipe”) extending from the present terminus on
Pomerado Road at Avenue of Nations east on Pomerado Road to Stonebridge Parkway
has been proposed for several years, and should be required as a condition of
approval. However, at this point it is
clear that no planning or coordination with the City or community has been
conducted.
Issue 14: Inaccurate and Incomplete Analysis of
Cumulative Impacts.
Table
5.4-1 lists projects which might cumulatively impact project alternatives. It is inaccurate and incomplete.
Project
No. 41, is incorrectly described. The
Carroll Canyon Commercial Center was withdrawn approximately a year ago. A mixed use complex with about 250
residential units and 12,000 square feet of commercial retail space is now pending. The DEIR is expected in 2015.
Table
5.4.1 omits at least the following approved and planned projects:
Chabad Scripps Ranch Campus of Life: Construct three multi-story dormitory
apartment buildings on site. Approved in
2009. 10785 Pomerado Rd, Construction to begin in 2015 or 2016.
Fire Station 37 Annex at Pomerado Road and
Avenida Magnifica. Construction is
planned in 2017.
SDG&E / SOCALGAS Pipeline Safety and
Reliability Project – This is a 47-mile 36” Natural Gas Transmission line filed
with the CPUC in Sept. 2015. The
recommended route includes an underground segment under Pomerado Road along the
exact route proposed for Alternative 5.
At this time it appears unlikely that both the electrical and gas
transmission lines can be installed under or near Pomerado Road.
OVERALL
CONCLUSION:
Given
the errors and omissions in the DEIR it is clear that insufficient analysis and
consultation with the community has occurred regarding Alternative 5. The DEIR is substantively deficient and
should be withdrawn, re-scoped with the new alternatives including new public
scoping meetings, rewritten with complete analyses, and reissued for public
comment before it is approved.