V. Summary of EIR and EIR Alternative Projects

The Commission staff determined that CEQA requires the development of an EIR for this project. CEQA guidelines require that a project EIR "shall describe a reasonable range of alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project." (CEQA Guidelines Section 1512(a).) The EIR studies the proposed project, five route alternatives and the No Project alternative, as required by CEQA. It then compares each alternative with the proposed project applying several environmental criteria to that comparative analysis.

A. Project Alternatives

The EIR developed alternatives on the basis of comments and suggestions by the general public, and federal and State agencies. The EIR preparers developed additional alternatives and the proposals included in SDG&E's PEA. Of 16 identified alternatives, the EIR follows the CEQA screening process for alternatives and eliminates 11 on the basis that they are in some way not feasible, inconsistent with project objectives, or would not mitigate environmental impacts. Consistent with CEQA guidelines, the EIR does not discount any alternative on the basis of costs or other economic factors (CEQA Guidelines Section 16126.6(b)). Among the alternatives rejected were demand-side management, renewable generation resources, and certain routing options.

The EIR includes a detailed analysis of the remaining five alternatives. These five project alternatives to be studied in the EIR were chosen on the basis that each is technically and legally feasible, consistent with the objectives of the project, and either avoid or reduce potentially significant environmental effects. They are as follows:


1. Jamacha Valley 138 kV/69 kV Underground Alternative The Jamacha Underground Alternative would underground 3.5 miles of circuit from Willow Glen Drive to new wood or steel poles in the exiting right of way. The alternative would address the concerns of local residents regarding long-term visual impacts and EMF emissions associated with the proposed project. The project would eliminate the need for any new poles through the Jamacha Valley and would reduce the final number of overhead conductors from nine to six (three for the existing 230 kV line and three for the new 230 kV line). The Jamacha Undergrounding Alternative would reduce construction impacts in the Cottonwood area, avoiding eight known cultural resources sites and impacts on local habitat. The project would reduce corona noise levels where lines would be undergrounded. This alternative is consistent with SDG&E's project objectives.


2. Jamacha Valley Overhead A Alternative
The Jamacha Valley Overhead A Alternative (Jamacha Valley A Alternative) would locate the 138 kV and 69 kV circuits on new steel poles on the east side of the right of way, downslope from the location of the proposed project along Herrick Center at Steele Canyon Road and Jamul Drive to Hillsdale Road. This project alternative would reduce visual impacts for residents of the Cottonwood community.


3. Jamacha Valley Overhead B Alternative
The Jamacha Valley Overhead B Alternative (Jamacha Valley B Alternative) would replace 12 existing steel lattice structures and 12 proposed steel lattice structures with steel mono-poles. This alternative would mitigate visual impacts near the Herrick Center at Steele Canyon Road and Jamul Drive.


4. City of Santee 138 kV/69kV Underground Alternative
The City of Santee 138/69 kV Underground Alternative (Santee Underground Alternative) would eliminate the need to install three 138 kV wood and steel poles and eliminate two existing 138 kV wood poles. Instead, the existing circuits would be relocated underground for approximately .6 miles outside the Miguel Mission right of way and .75 miles along the length of Princess Joann Road. An existing 138 kV circuit would be relocated underground along Princess Joann Road to Magnolia Avenue. This alternative would improve visual impacts to residents of Santee and reduce biological impacts, soil erosion and impacts on known cultural resources because construction would occur in city streets rather than within the existing SDG&E right of way. It would reduce corona noise levels along the right of way on Willow Glen Drive.


5. City of Santee 230 kV Overhead Northern Right of Way
Boundary Alternative
The City of Santee 230 kV Overhead Northern Right of Way Boundary Alternative (Santee Overhead Alternative) would site the 230 kV circuits along the northern side of the existing right of way near Princess Joann Road. Because the circuits would be sited further from the residents of Santee, this alternative would reduce visual impacts, corona noise and construction activity for those residents.

B. Environmentally Preferred Alternative

The EIR analyzes and compares each alternative route by considering several types of environmental impacts:

The EIR does not consider project or mitigation costs and does not analyze the impacts of EMFs on human health. The EIR develops the preferred routes by comparing SDG&E's proposed project to the alternatives through the Jamacha Valley, on the one hand, and the City of Santee, on the other, as discussed below.

Jamacha Valley Routes. The EIR compares the proposed project with three alternatives considered for the area around Jamacha Valley: Jamacha Valley 138 kV/69 kV Undergrounding Alternative, Jamacha Valley Overhead A Alternative, and Jamacha Valley B Alternative. Table A of the EIR shows a summary comparison of the proposed project and three alternatives for various environmental impacts. For this portion of the route, the EIR identifies the Jamacha Valley 138 kV/69 kV Undergrounding Alternative as preferred because it eliminates long-term and permanent visual impacts. It is also preferred with respect to impacts associated with biological resources, geology, soils and paleontology, and hydrology and water quality.

City of Santee Routes. The EIR compares the proposed project with two alternatives considered for the area around the City of Santee: the Santee 138 kV/69 kV Underground Alternative and the Santee 230 kV Overhead Northern ROW Boundary Alternative. Table B shows a summary comparison of the project for various environmental impacts. The EIR concludes that the Santee 138 kV/69 kV Undergrounding Alternative is preferred because it would provide long term and permanent mitigation to visual impacts, as well as avoid or reduce impacts to biological resources and known cultural resources. Although it would increase other construction-related impacts due to the slower pace of underground work, the impacts may be mitigated and are short-term.

No Project Alternative. The EIR also considered the impacts of not building the Miguel Mission Project or some variation of it. The EIR finds that not building the project would require SDG&E or another entity to augment existing facilities with new transmission or generation capacity to compensate for existing system limitations. It notes the possibility that without the project some generation projects may have to be cancelled if new transmission capacity were not available and that new generation capacity could be necessary to compensate for existing transmission system limitations and projected loads. However, it would be speculative to predict specific developments at this time. It refers to the likelihood of increased congestion fees imposed by the California ISO on SDG&E customers if the project is not built.

The Environmentally Preferred Project. The EIR recommends that if the project is approved, the proposed project should be modified to include the Santee 138 kV/69 kV Undergrounding Alternative and the Jamacha Valley 138 kV/69 kV Underground Alternative. The proposed project would be modified to include the following segments:

Jamacha Valley to City of Santee Proposed Project

C. Electric and Magnetic Fields

The Commission's CEQA review does not consider electric and magnetic fields (EMF) or their impacts on health and the environment. The Commission has thus far declined to conduct such analysis because the scientific community does not agree as to whether EMF creates a potential health risk. However, recognizing that there is a great deal of public interest and concern regarding potential health effects from exposure to EMF from power lines, the EIR provides information regarding EMF associated with electric utility facilities and the potential effects of the proposed project and alternatives related to public health and safety.

EMFs are present in the existing environment both naturally and as a result of human activities that use electricity. Research on ambient magnetic fields in homes in several western states found average magnetic field levels to be approximately 1 milligauss (mG), while in the immediate area of appliances, the measured levels ranged from 9 to 20 mG. The project will generate EMFs above and beyond ambient levels, but within the range anticipated for power lines of this type and size. The fields from the project will be very localized since field strength attenuates rapidly as distance from the source increases. Generally, in the Miguel Mission project area, the magnetic field levels for the existing 230/138/69 kV line range from 3 to 8 mG at a distance of 50 feet from the right of way. Field levels are estimated to range from 8 to 27 mG for the rebuilt lines (the proposed project) at a distance of 50 feet from the right of way.

While there is still no consensus in the scientific community regarding health risks of EMF exposure, DHS reported troubling indications that EMF exposure may increase risk of certain diseases and other health problems. We believe the time is ripe to update our earlier investigation and, in particular, to address the policy implications of DHS' findings. There is value in addressing such issues in an investigatory setting in order to avoid the need for such ad hoc treatment in future certificate proceedings. To this end, we plan to issue, either concurrently with this order or shortly thereof, an Order Instituting Investigation into EMF issues. We contemplate that this investigation will address a range of EMF-related issues comparable to those examined in I.91-01-012. EMF levels from transmission lines are not regulated nationally although several states have established maximum electric and magnetic field levels, for transmission lines, maximum magnetic field exposure levels are generally 150 mG or greater at the edge of the right of way.

The Commission has not adopted any specific limits on EMF. However, in D.93-11-013, the Commission directed the utilities to fund a research program on the health effects of EMFs, and we required utilities to adopt "low-cost" or "no-cost" EMF mitigation measures for transmission lines and substations, up to approximately 4% of total project cost, such as those included in the proposed project and alternatives.

D.93-11-013 created the California Electric and Magnetic Fields Program to research and provides education and technical assistance on the possible health effects of exposure to electric and magnetic fields from power lines and other uses of electricity. The California Department of Health Services (DHS) is leading ongoing research and policy analysis for this program. In addition to funding research and policy analysis on this issue, the EMF program provides education and technical assistance to government agencies, professional organizations, businesses, and members of the general public. A recent report issued by DHS, funded by the Commission, raises concerns that prolonged exposure to EMFs may be associated with childhood leukemia, brain cancer, Lou Gherig's disease and miscarriages. The Commission has not considered the public policy implications of this report.

Although the use of underground transmission is not proposed here to specifically address EMF levels, placing transmission lines underground can produce EMF reduction benefits. Although underground EMF field levels can be quite high directly over the centerline of the cable route, when compared to field levels from overhead lines, those from underground lines decrease much more rapidly with lateral distance.

D. Statement of Overriding Considerations and Recommended Mitigation Measures

CEQA requires that agency approval of SDG&E's proposed project or an alternative may require modifications or mitigations to avoid significant effects on the environment. It specified considerations make the mitigation measures or alternatives identified in the FEIR infeasible, they must be identified and the agency must explain how benefits of the project outweigh significant effects on the environment.

The EIR identified potential environmental impacts for the proposed project and various alternatives in the areas of air quality, biological resources, cultural resources, land use and recreations, hydrology and water quality, visual resources, transportation and traffic, public services and utilities, public health and safety, geology, and noise and vibration. The mitigation measures recommended in the EIR for the proposed project as modified by the alternatives adopted are summarized in the Attachment. The adoption and implementation of these mitigation measures was assumed in the determination of impact levels in the EIR. With mitigation, it was concluded that all potential environmental effects could be mitigated to less than significant levels. Therefore, implementation of these mitigation measures is a condition of the approval of this project.

In addition to the mitigation measures, the EIR assumes that the additional mitigation measures proposed by SDG&E in its Proponent's Environmental Assessment will be implemented as part of the project description. These measures, called Applicant Proposed Measures, and those additional mitigation measures recommended by the EIR would reduce impacts to an acceptable level. The Commission assures compliance according to the associated Mitigation Monitoring, Compliance and Reporting Program.

The EIR concludes that neither the proposed project nor the recommended preferred alternative route will have a significant impact that cannot be mitigated if the project is built in conformance with the EIR and PEA. Therefore, we do not need to justify the project with a statement of overriding considerations in order to approve the project.

E. Adequacy and Certification of the FEIR

The lead agency must certify the FEIR before a project may be approved. Certification consists of two steps. First, the agency must conclude that the document has been completed in compliance with CEQA, and second, the agency must have reviewed and considered the FEIR prior to approving the project. Additionally, the lead agency must find that the FEIR reflects its independent judgment (Pub. Res. Code § 21082.1(c)(3).)

The FEIR must contain specific information according to the CEQA Guidelines, Sections 15120 through 15132 (CEQA Guidelines).4 The various elements of the FEIR satisfy these CEQA requirements. The FEIR consists of the DEIR, with revisions in response to comments and other information received. The FEIR contains the comments received on the DEIR and individual responses to these comments.

The Commission must conclude that the FEIR is in compliance with CEQA before finally approving SDG&E's request for a CPCN. The basic purpose is to insure 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."5 It must be prepared in a clear format and in plain language.6 It must be analytical rather than encyclopedic, and emphasize alternatives over unnecessary description of the project.7 Most importantly, it must be "organized and written in such a manner that [it] will be meaningful and useful to decisionmakers and the public."8

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, SDG&E's proposed route, and various alternatives. We find that the FEIR is a competent and comprehensive informational document, as required by CEQA.

We herein certify the FEIR for the Miguel Mission Project.

F. Adopted Miguel Mission Project

This decision approves the "environmentally-preferred alternative" (EPA) identified in Table ES-1 of the final EIR for the Miguel Mission Project. The EPA differs from the proposed project mainly by requiring SDG&E to underground 3.5 miles of circuits in the Jamacha Valley and about 1.35 miles of circuits through the City of Santee. These project modifications eliminate the project's visual impacts in residential neighborhoods. Compared to the proposed project, the EPA would also mitigate certain construction impacts, noise from conductors, and EMF levels. While placing circuits underground may increase some environmental impacts during construction, these impacts are short term and, as the EIR describes, are readily mitigated. The improvements in visual impacts and the reductions in EMF exposure are, on the other hand, permanent and long term. We concur with the final EIR's assessment that long-term project impacts should be weighted more heavily than those that are associated with construction or are otherwise temporary.

4 Cal. Admin. Code §§ 15122-131. 5 Id., § 15142 6 Id., §§ 15006 (q) and (r), 15120, 15140. 7 Id., §§ 15006, 15141; Pub. Res. Code § 21003(c). 8 Pub. Res. Code § 21003(b).

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