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 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).


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.


3. Jamacha Valley Overhead B Alternative
The Jamacha Valley Overhead B Alternative (Jamacha Valley B Alternative) would replace 12 existing steel lattice structures and 126 proposed steel lattice structures with steel mono-poles.


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.


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.

B. Environmental Impacts Analysis

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 suggests an alternate route, called the "environmentally preferred route," 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 being preferred (primarily) because it reduces visual impacts.

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 of the EIR 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 mitigation to visual impacts.

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 CAISO on SDG&E customers if the project is not built.

The "Environmentally Preferred Route." 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 EIR suggests that the proposed project would be modified to include the following segments:

SDG&E Proposed Project Vs. the EIR-Proposed Route.

Comparison of Environmental Impacts Proposed Project and Jamacha Valley Underground Alternative

Issue Area

SDG&E Proposed Project

    EIR-Proposed Route

Air Quality

Preferred

  

Biological Resources

  

Preferred

Cultural Resources

Preferred

  

Geology, Soils, and Paleontology

  

Preferred

Hydrology and
Water Quality

  

Preferred

Land Use

Preferred

  

Noise and
Vibration

Preferred

  

Public Health and Safety

Preferred

  

Public Services
and Utilities

Preferred

  

Socio-Economic

No preference

No preference

Transportation
and Traffic

Preferred

  

Visual Resources

  

Preferred

Table One (Source: Modified Table E-1 from DEIR)-

The environmental review conducted for the proposed SDG&E Miguel to Mission 230kv project examined twelve potential environment impacts. More often than not, the SDG&E proposed project is environmentally favored to the so-called "environmentally preferred route" (see Jamacha Valley example, Table One). In fact, the SDG&E proposed project is actually preferred in seven of twelve categories for the Jamacha Valley alternative, while the "environmentally preferred route" is preferred in only four. For the City of Santee, the SDG&E proposed project is preferred in four of the categories, while the "environmentally preferred route" is preferred in only two categories (see Table E-2, Miguel to Mission DEIR).

In addition, neither the proposed project nor the "environmentally preferred route" would create impacts that cannot be mitigated to less than significant. Even without mitigation measures, the proposed project would not create class one impacts (most severe) to any of the environmental criteria analyzed in the EIR.

Table Two (Source Table E-5, Executive Summary to FEIR)

The DEIR determines that the undergrounding option is environmentally preferred because undergrounding the 138 kV and 69 kV circuits in the Jamacha Valley and City of Santee areas would "reduce" or "substantially eliminate" impacts to visual resources. Determination of potential visual impacts is, at best, qualitative, and there are no class one visual impacts from the proposed project (see Table Two above). Nevertheless, the DEIR favors the undergrounding alternative and suggests that there are greater long term and permanent impacts with visual resources associated with the proposed project.

Yet, it is important to note that the "environmentally preferred route" delineated in the DEIR would not remove all of the transmission lines from SDG&E's existing transmission corridor, and would not eliminate all tower structures from the sections of the right-of-way where the 138 kV and 69 kV circuits would be undergrounded. The DEIR indicates that the construction of new or relocated overhead transmission line circuits would alter the existing visual setting of the project area over the project's lifetime but would not significantly deteriorate any scenic area or other visual resources, or significantly impact any sensitive visual receptors. As such, the net environmental benefits from undergrounding the existing 138kv and 69kv transmission lines (for both the Jamacha Valley and City of Santee sections) only to replace them with the new 230kv transmission line would be minimal.

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 thus far has not established an EMF standard because the scientific community does not agree on existence or degree of health risks associated with EMF. 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.

In 1991, the Commission initiated an investigation, I.91-01-012, into EMFs associated with electric power facilities. In D.93-11-013 in that proceeding, we found that, while EMF studies available at that time did not conclude that an EMF health hazard exists, it was appropriate to adopt several EMF policies and programs because of public concern and scientific uncertainty. We required that utilities undertake no-cost EMF mitigation measures and that they implement low-cost mitigation measures to the extent approved through a project's certification process. We defined "low-cost" to be in the range of 4% of the total project cost but specified that this 4% benchmark is not an absolute cap. We found that, to be implemented, a mitigation measure should achieve some noticeable reduction in EMF but declined to adopt a specific goal for EMF reduction. We instructed that workshops be held and that the utilities develop EMF design guidelines for new transmission facilities. We adopted several EMF measurement, education, and research programs and chose the California Department of Health Services (DHS) to manage the education and research programs. The proposed project would use a line configuration that will reduce the overall EMF levels near populated areas as part of the low-cost, no-cost EMF mitigation measure.

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. If 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. There are mitigation measures recommended in the EIR for the proposed project that are adopted as part of our approval of the proposed project. 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 ensure that the environmental document is a comprehensive, accurate, and unbiased tool to be used by the lead agency and other decision-makers 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 decision-makers 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 proposal made by SDG&E to install a 35-mile 230 kv transmission circuit between Miguel Substation and Mission Substation. Between Miguel Substation and Fanita Junction (24 miles), existing138kv/69kv steel lattice tower structures would be replaced or modified to accommodate the 230 kv circuit. Between Fanita Junction and Mission Substation, the existing structures would be reconductored and the new circuit would be installed in a vacant position. The existing 138kv/69 kv circuits will be reconductored and placed on a newly constructed wood and steel poles. The entire project will be located within SDG&E's existing ROW. There will also be modifications to the Miguel and Mission substations to accommodate the new 230kv line.

This decision does not adopt the EIR's "environmentally preferred route" that undergrounds sections of the proposed transmission line in the Jamacha Valley and City of Santee. The EIR is used to guide decision-making and inform the public by providing an assessment of the potential environment impacts that may result from a proposed project, but it is up to the Commission to determine the best option, taking into consideration the totality of the issues, including the costs of delay and implication for reliable grid operations. Due to the need to develop additional engineering design and other criteria, SDG&E reports that the Jamacha Valley underground alternative could delay the project completion date by up to a year. This delay would impose additional costs on SDG&E and other ratepayers with in the SP15 zone to whom congestion management costs are allocated. Also troublesome are the operational and reliability implications of further delay in the construction of the Miguel Mission project. The chronic congestion management problems at Miguel pose serious challenges to CAISO operations and maintenance of grid reliability.

The CEQA Guidelines (Section 15126 (a)) state: "An EIR describes a reasonable range of alternatives to the project, or to the location of the project, which would feasibly (italics added) attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project." Feasibility is defined by the CEQA Guidelines as" capable of being accomplished in an successful manner within a reasonable period of time, taking into account, economic, environmental, legal, social, and technological factors."9

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). 9 CEQA Guidelines Section 15021 et seq.

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