III. Overview of Positions of the Parties

During the course of the proceeding, PG&E changed its position, so that it now recommends that the new Jefferson-Martin 230 kV line be constructed along what it calls the All-Underground Alternative (AUA) route, which would consist of PG&E's underground Route Option 1B in the southern segment and PG&E's Proposed Project in the northern segment. PG&E states that, given the risk of a veto by the NPS and the FEIR's conclusions regarding the environmentally superior route, PG&E supports the Commission's selection of the AUA despite the approximately $24 million increased capital cost compared to the Proposed Project.

The ISO states that it has found the Jefferson-Martin project will be needed by 2006 to meet applicable reliability criteria and, therefore, urges the Commission to expeditiously grant PG&E's application.

ORA recommends that the Commission include the four combustion turbines owned by CCSF in determining the appropriate supply forecast for the project area and, consequently, the need for the Jefferson-Martin project. ORA submits that either Jefferson-Martin or the CCSF turbines can meet reliability needs in the project area. It is concerned that, should the CCSF turbines and Jefferson-Martin both come online by 2006, ratepayers will overpay for reliability.

CCSF supports the Jefferson-Martin project as a cost-effective way to increase electric grid reliability for San Francisco and the upper San Francisco Peninsula. CCSF maintains that the project will help reduce energy costs by reducing reliability must run (RMR) costs, eliminating the need for air emission equipment, and reducing the potential for economic loss caused by a blackout. CCSF supports Route Option 1B in the southern segment, which it states would eliminate visual and biological impacts to the San Francisco Peninsula watershed.

WEM is working to close the Hunters Point power plants and is concerned that the Jefferson-Martin project may greatly benefit PG&E but actually hurt the Bayview Hunters Point and Potrero neighborhoods. It points to studies that indicate that the addition of Jefferson-Martin could create constraints elsewhere in the transmission system that would reduce rather than increase the load serving capability (LSC) of the system in San Francisco. PG&E's current transmission expansion plan indicates that those constraints will be corrected by 2008. WEM is concerned that Hunters Point may have to keep running in the meantime.

CARE supports the Jefferson-Martin project as an opportunity to increase the transmission capacity of San Francisco while eliminating the need for the Hunters Point and Potrero power plants. It supports the AUA as the configuration for the Jefferson-Martin project with the least environmental impact and without regulatory delays due to federal compliance issues and other obstacles.

280 Citizens maintains that there is no current need for the Jefferson-Martin project and there will be no need under reasonable planning assumptions until after 2012. 280 Citizens maintains that high voltage transmission lines are fundamentally inconsistent with residential land uses and recommends that, if the project is approved, the Commission adopt the PUA configuration or a variation thereof in the southern segment. Because of concerns regarding EMF exposure, 280 Citizens asks that the Commission adopt a standard that EMF from the existing 60 kV and new 230 kV lines should not exceed 1 milligauss (mG) at residential property boundaries.

The County of San Mateo opposes Route Option 1B because of its placement through the highly populated area along Trousdale Drive and El Camino Real. San Mateo takes issue with PG&E's assertions that siting choices are constrained by the need for construction to be completed by the end of 2005 and also by NPS concerns. San Mateo suggests that the most appropriate alternative may be one of the hybrid alternatives which minimizes biological and visual impacts in the southern portion of the watershed but still avoids placing the line adjacent to the school, day care center, hospital, residences, and commercial uses on Trousdale Drive and El Camino Real.

On September 10, 2003, the mayors of the cities of Burlingame, Millbrae, and San Bruno sent a joint letter stating a compromise position that the only acceptable alternative for the combined communities is one that goes west of Skyline Boulevard and uses Sneath Lane. This alternative would be a combination of the PUA and PG&E's proposed northern route except that it would use the Sneath Lane transition station alternative.

The City of Burlingame supports the PUA and states that it would also support the MPUA. It is concerned that the existing 60 kV Jefferson-Martin line runs right behind Burlingame neighborhoods and that, in PG&E's Proposed Project, the existing towers would be replaced with much taller towers. It is also concerned that Route Option 1B would leave the current 60 kV transmission line in place and would install the 230 kV line in other residential neighborhoods within the city, in particular, Skyline Boulevard, Trousdale Drive, and El Camino Real. Burlingame submits that, if the Commission approves Route Option 1B, it must ensure that appropriate mitigation measures are undertaken, including measures Burlingame requests in addition to those in the FEIR.

The City of Millbrae points to a series of major construction projects that have disrupted its commercial district around El Camino Real. It opposes the use of El Camino Real for the Jefferson-Martin project, stating that this alternative would cause even more severe and prolonged disruption than the previous projects.

The City of San Bruno opposes the proposed San Bruno Avenue transition station site as counter to the city's Redevelopment Plan, which aims to turn the area into a gateway to San Bruno characterized by multifamily housing, retail opportunities, and the nearby state parkland. San Bruno states that it would support either elimination of the need for a transition station, such as Route Option 1B, or another location for a transition structure in San Bruno.

As described in Section II.C, Daly City proposes a northern alternative to both the Proposed Project and the Collocation Alternative, which would collocate the new 230 kV line with the existing Jefferson-Martin 60 kV line across San Bruno Mountain. If this alternative is not explored, Daly City supports the Collocation Alternative.

The City of South San Francisco supports the northern segment of PG&E's Proposed Project and strongly opposes the Collocation Alternative. South San Francisco maintains that the northern segment of PG&E's Proposed Project would be least disruptive because it would be constructed in streets or in recently disturbed construction areas, would only minimally affect residences, and would raise little concern regarding toxic contamination. CBE-101 and Genentech express similar views. Golden Gate Produce Terminal opposes the portion of the Collocation Alternative, as originally proposed, that would disrupt its operations.

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