VIII. Environmental Analysis

As required by CEQA, we cannot approve PG&E's Proposed Project or an alternative unless we find that the project has been modified to mitigate or avoid each significant effect on the environment or that specific considerations make the mitigation measures or alternatives identified in the FEIR infeasible, and that specific overriding economic, legal, social, technological, or other benefits of the project outweigh the significant effects on the environment. In this section, we address mitigation measures recommended in the EIR and suggested by the parties during the evidentiary hearings.

In Section VII, we describe the approved route for the Jefferson-Martin project and the specific reasons to support this choice based on the FEIR and other information in the record. The adopted mitigation measures reduce the environmental effects of the approved Jefferson-Martin project to less than significant levels. As a result, no Statement of Overriding Considerations is needed.

Finally, we certify the FEIR in this section.

A. Mitigation and Mitigation Monitoring

The conclusions in the FEIR regarding environmental impacts of the Proposed Project and its alternatives assume that the mitigation measures recommended in the FEIR and the impact-reduction measures proposed in the Proponent's Environmental Assessment, called Applicant Proposed Measures, are implemented. Certain modifications to the FEIR's mitigation measures are adopted in this section and included in an Addendum to the FEIR attached as Appendix A. Implementation of the Applicant Proposed Measures and the adopted mitigation measures, including the Addendum in Appendix A, is a condition of the approval of this project. All of the applicable FEIR mitigation measures, including those in Appendix A, are included in Appendix B.

PG&E asks that Mitigation Measure G-8a be revised to state that it applies only to a crossing of an active trace of the San Andreas fault. Mitigation Measure G-8a was intended to require the double-vault design only for the San Andreas fault, and the text of this measure is clarified in Appendix A in this regard. The measure is further clarified with an additional sentence addressing the Serra fault crossing that allows more flexibility in the design, but requires PG&E to take into consideration new fault analysis on the Serra fault.  New fault analysis is required because of the disagreement between PG&E and the City of Burlingame about the displacement potential at the Serra fault and to ensure that an adequate structure is designed for the Serra fault crossing.

PG&E requests that Mitigation Measure L-7a, aimed at mitigating disrupted access to businesses and residences, be modified. PG&E is concerned that the requirement to provide access "at all times" by "quickly" laying a temporary steel bridge over the trench may not be feasible and may affect the construction schedule and project cost. PG&E maintains that compliance, to the extent feasible, may be counterproductive and could create, in certain situations, more significant adverse impact to traffic and create unsafe situations. In Appendix A, Mitigation Measure L-7a has been modified to allow more flexibility in the construction process while allowing construction to proceed as quickly as possible.

PG&E proposes modification to four biological resource mitigation measures and deletion of ten visual resource mitigation measures. These measures apply to the overhead portions of the southern segment, and all were modified in the FEIR in response to PG&E's concerns about the original measures. We modify Mitigation Measures B-5a and B-8a to include the option to obtain a permit to remove and relocate wildlife to a wildlife shelter if other portions of the measures cannot be implemented. We also modify Mitigation Measure B-8b to require that PG&E recommend to the USFWS that the County of San Mateo be involved in any consultations regarding project-related construction in Edgewood Park or San Bruno Mountain Park. We do not delete or further modify the other measures as modified in the FEIR.

The City of Burlingame requests that several mitigation measures be adopted in addition to those outlined in the FEIR. With adoption of the hybrid route in the southern segment which avoids Trousdale Drive and El Camino Real, some of Burlingame's requested mitigation measures may be of reduced importance. We address each of them in turn.

Depth of the duct bank. The City of Burlingame states that a 12-foot burial depth may be required because of existing utilities in Trousdale Drive and Skyline Boulevard. This concern would continue to apply along Skyline Boulevard with the approved route. Burlingame requested that the duct bank be installed in a manner consistent with its Public Works Department's standard that new utility infrastructure traversing the city (but not actually serving the city) within city streets be buried two feet below the lowest existing utility in the right of way. Pursuant to Mitigation Measure U-1b, PG&E will be required to submit to the Commission documentation that appropriate jurisdictions have reviewed the project plans with respect to protection of existing underground utilities. Documentation must specifically include evidence that the project meets all necessary local requirements, that it complies with design standards, and that affected jurisdictions (e.g., Burlingame's PG&E Public Works Department) approve the final plans. Thus, Mitigation Measure U-1b will ensure, subject to Section XIV of G.O. 131-D as discussed below, that PG&E complies with the subject Public Works Department standard.

Installation of cathodic protection systems. Burlingame is concerned that proximity of cast iron pipes to magnetic fields from the line would reduce the life expectancy of these pipes. Mitigation Measure U-1c already addresses Burlingame's concern.

Duration of disruption. Burlingame requests that the Commission require that PG&E commit to the completion of construction on both Skyline Boulevard and Trousdale Drive within six months of commencement of work on each of those roadways or establish a phased construction of the portion of the project which will travel down these streets. Requiring PG&E to commit to completing work on Skyline Boulevard streets within six months could conflict with other mitigation measures and increase impacts in other issue areas. If construction delays occur, construction would be forced to weekends and possibly nights, causing more noise impacts. We see phased construction as a preferable approach which also accomplish the City's goal. Pursuant to Mitigation Measure T-1a and Applicant Proposed Measure 13.3, PG&E will be required to develop a Transportation Management Plan that will include limits on the length of open cuts. PG&E will need to obtain Burlingame's input regarding and, subject to Section XIV of G.O. 131-D, approval of the Transportation Management Plan for all construction areas within the City's public right of way. PG&E and Burlingame should agree upon a construction schedule during development and review of the Transportation Management Plan.

EMF management measures. In addition to deeper placement of the line, Burlingame requests that PG&E be required to mail specified EMF information to property owners within 300 feet of the line at least 90 days prior to commencement of construction. Mitigation Measure L-4a requires PG&E or its construction contractor to provide advance notice to residents or property owners within 300 feet of the alignment prior to the commencement of construction. We require that, as part of the mailing required by Mitigation Measure L-4a, PG&E disseminate EMF information comparable to its previous EMF-related bill inserts but modified to reflect EMF management policies we adopt in Section VI.C for the Jefferson-Martin project. This requirement is not included in Appendix A, however, because it is not a CEQA-related mitigation measure.

Access to Franklin Elementary School and Hope Technology School. Burlingame's requested limitations on construction during school hours are not applicable to the adopted project route, since it bypasses these schools.

Access to Mills Peninsula Hospital. Burlingame's requests regarding access at the Mills Peninsula Hospital are not applicable to the adopted project route, since it bypasses this hospital.

Interference with parking. Burlingame requests that PG&E be required to provide alternative parking and compensation if access to a driveway is blocked for longer than specified times, and for a requirement that driveway access not be blocked for more than 72 consecutive hours. We believe existing mitigation measures are adequate in this regard. Pursuant to Applicant Proposed Measure 13.7, PG&E will be required to include details within its Transportation Management Plan regarding its residential notification process for temporary parking impacts and will minimize the length of any parking restrictions. Applicant Proposed Measure 13.6 requires PG&E to develop a plan to ensure adequate access at all times to affected businesses, homes, and other facilities. In addition, the Transportation Management Plan pursuant to Mitigation Measure T-1a requires the review and approval of all applicable jurisdictions such as the City of Burlingame.

Emergency access. Burlingame requests that 20 feet of clearance be maintained on city streets for emergency access at all times. We believe that Mitigation Measure T-6a will ensure that sufficient emergency vehicle access will be maintained. PG&E will be required to accommodate emergency vehicles with provisions such as plating over excavations, short detours, and alternate routes at all locations where access is blocked. These emergency response vehicle provisions will be presented in the Transportation Management Plan, which will require the review and approval of all applicable jurisdictions such as the City of Burlingame

Noise control. Burlingame asks for restrictions on the times that construction activity may occur, limits on noise levels, and a prohibition on the use of pile drivers within Burlingame's city limits. Applicant Proposed Measure 15.1 and Mitigation Measures L-4a and L-4b provide adequate mitigation of noise impacts to all communities, including Burlingame. However, given Burlingame's specific concerns, Commission staff recommends, and we concur, that a new mitigation measure be adopted consistent with Burlingame's recommendations. New Mitigation Measure N-1a is included in Appendix A.

Information to property owners. Burlingame requests that there be at least two public meetings prior to commencement of construction within the city, and that PG&E be required to place a "door hanger" notice at each residence along Skyline Boulevard and Trousdale Drive prior to construction. Mitigation Measures L-4a and L-4b provide assurance that the public receives adequate notice regarding construction activities. However, the additional measures requested by Burlingame have been added to Mitigation Measure L-4a in response to the City of Burlingame's specific concerns.

We note that many of the FEIR Mitigation Measures and Applicant Proposed Measures that include the development of a plan (e.g., Mitigation Measures T-1a and T-6a and Application Proposed Measure 13.6) require that PG&E obtain approval of the plan from the applicable local jurisdictions, such as the City of Burlingame. Although we believe that the combination of FEIR Mitigation Measures, modified FEIR Mitigation Measures, and Applicant Proposed Measures adequately address issues raised by the City of Burlingame, any unresolved concerns can also be addressed during the agency review period of the plans. Consistent with G.O. 131-D, Section XIV, public utilities are regularly required to consult with local agencies regarding land use matters. However, should the utility and agencies be unable to resolve their differences, the dispute may be brought to the Commission for resolution pursuant to the process outlined in the General Order.

Based on its assessment of the mitigation-related requests of PG&E and the City of Burlingame, the Commission's Energy Division staff has prepared an Addendum to the FEIR (attached as Appendix A) that documents the adopted modifications to the FEIR mitigation measures. The Addendum concludes that the adopted modifications to the FEIR mitigation measures will not result in a significant impact to the environment. The staff concluded that preparation of the Addendum was appropriate under CEQA Guidelines §§ 15162, 15163, and 15264, because an Addendum is required under CEQA to incorporate minor technical changes to the FEIR where there are no new significant impacts. Given the findings of staff, we approve the Addendum to the FEIR. The Addendum documents modifications of Mitigation Measures G-8a, L-4a, L-7a, B-5a, B-8a, and B-8b and addition of Mitigation Measure N-1a.

The FEIR includes a Mitigation Monitoring, Compliance, and Reporting Program, which presents the process for monitoring the implementation of the recommended mitigation measures and Applicant Proposed Measures.

B. Adequacy and Certification of the FEIR

The FEIR must contain specific information according to the CEQA Guidelines, §§ 15120 through 15132. The various elements of the FEIR satisfy these CEQA requirements. The FEIR consists of the draft EIR, with revisions in response to comments and other information received. Volume 3 of the FEIR contains the comments received on the draft EIR and individual responses to these comments.32

The Commission must conclude that the FEIR is in compliance with CEQA before approving PG&E's request for a CPCN. The basic purpose is to ensure that the environmental document is a comprehensive, accurate, and unbiased tool to be used by the lead agency and other decisionmakers in addressing the merits of the project. The document should embody "an interdisciplinary approach that will ensure the integrated use of the natural and social sciences and the consideration of qualitative as well as quantitative factors."33 It must be prepared in a clear format and in plain language.34 It must be analytical rather than encyclopedic, and emphasize alternatives over unnecessary description of the project.35 Most importantly, it must be "organized and written in such a manner that [it] will be meaningful and useful to decisionmakers and the public."36

We believe that the FEIR meets these tests. It is a comprehensive, detailed, and complete document that clearly discusses the advantages and disadvantages of the environmentally superior routes, PG&E's proposed route, and various alternatives. We find that the FEIR is a competent and comprehensive informational tool that CEQA requires it to be. The quality of the information therein is such that we are confident of its accuracy. We have considered that information in approving the Jefferson-Martin project as described in this decision.

As described in Section II.C, we deny the motion and joinder seeking that the FEIR be recirculated.

The Commission should certify the FEIR and the Addendum contained in Appendix A.

32 CEQA Guidelines, §15132. 33 Id., § 15142. 34 Id., §§ 15006(q) and (r), 15120, 15140. 35 Id., §§ 15006, 15141; Pub. Res. Code § 21003(c). 36 Pub. Res. Code § 21003(b).

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