Thursday, October 29, 2015

DRAFT Response to Sycamore-Penasquitos Transmission Line DEIR



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.

Monday, October 26, 2015



Scripps Miramar Ranch Planning Group

Agendas for Subcommittee Meetings
Scripps Ranch Community Library
10301 Scripps Lake Drive, San Diego, CA 92131


Subcommittee on Review of The Glen at Scripps Ranch 
Wednesday, October 28, 2015 , 5:00 pm

1.                  Call to Order and Parliamentary Items
2.                  Modifications to and Adoption of the Agenda (Additions/Deletions)
3.                  Public Communications – Non-Agenda Public Comment (2 min each)
4.                  Action Item: Discussion of the Glen, Development of Recommendations.
5.                  Adjournment

Subcommittee on Review of SDG&E Proposed Transmission Line Projects
Thursday, October 29, 2015, 5:00 pm

1.                  Call to Order and Parliamentary Items
2.                  Modifications to and Adoption of the Agenda (Additions/Deletions)
3.                  Public Communications – Non-Agenda Public Comment (2 min each)
4.                  Action Item: Discussion and Development of Response to DEIR.
5.                  Adjournment

Subcommittee on Review of The Glen at Scripps Ranch 
Thursday, November 5, 2015 , 5:00 pm

1.                  Call to Order and Parliamentary Items
2.                  Modifications to and Adoption of the Agenda (Additions/Deletions)
3.                  Public Communications – Non-Agenda Public Comment (2 min each)
4.                  Action Item: Discussion of the Glen, Development of Recommendations.
5.                  Adjournment

Agenda times are approximations. Items may be heard before, on, or after listed times. If you would like to receive agendas via email, send your request to sdplanninggroups@sandiego.gov and indicate your specific community planning group. This information is available in alternative formats.  To  request  an  alternative  format  (sign  language,  oral  interpreter  or  an  Assistive Listening Device) for the meeting call 619-533-3650 at least five (5) working days prior to the meeting. If you have questions concerning the SRPG please express them at the meeting or contact the CPG Chair, Wallace Wulfeck at whw@san.rr.com or City of San Diego Community Planner Tony Kempton at kemptont@sandiego.gov