V. Project Alternatives Studied

In its application and Proponent's Environmental Assessment, PG&E identified several alternative routings for the Jefferson-Martin project. During the EIR scoping process, numerous additional alternatives were identified, including minor routing adjustments for PG&E's Proposed Project, entirely different transmission line routes, alternative energy technologies, and non-wires alternatives. Alternatives were then screened according to CEQA guidelines to determine those alternatives to carry forward for analysis in the EIR. The Commission's environmental team rejected 26 alternatives that did not meet CEQA criteria for analysis. In Section IV, we have determined that alternative energy technologies and non-wires alternatives do not hold sufficient promise to eliminate the need for the Jefferson-Martin project. In this section, we address alternative routing configurations for the project.

A. Southern Alternatives

In addition to the overhead segment of PG&E's Proposed Project, alternative configurations considered for the southern segment include the underground Route Option 1B contained in PG&E's Proponent's Environmental Assessment, the PUA (Partial Underground Alternative) developed by the Commission's CEQA consultants, and the MPUA (Modified Partial Underground Alternative) proposed by 280 Citizens and other intervenors. The FEIR also describes several hybrid alternatives that combine portions of these configurations. The FEIR concludes that Route Option 1B is the environmentally superior route for the southern segment.

1. Proposed Project--Southern Segment

PG&E's proposed southern segment would install the 230 kV line entirely overhead and, for the most part, along the existing, but widened, right of way, on a rebuild of PG&E's 60 kV transmission line in the SFPUC watershed lands. The rebuilt line would connect to the northern underground segment of the Proposed Project at a transition station near San Bruno Avenue.

Upon leaving Jefferson substation, the rebuilt line would traverse Edgewood Park and the Pulgas Ridge Natural Preserve, cross to the west of I-280, and continue north across the watershed. At about mile point 4.1, the alignment crosses back to the east of I-280, then passes the Ralston substation. Between the Ralston and Carolands substations, residential development in The Highlands area of unincorporated San Mateo and in the Town of Hillsborough lies immediately east of the alignment. The alignment then crosses to the west of I-280 and runs along the west side of the freeway and the eastern edge of the Crystal Springs Golf Course. At mile point 9.9, the alignment crosses back to the east of I-280 and continues in watershed land adjacent to residential development in the Town of Hillsborough and the City of Burlingame. At mile point 10.7, the alignment passes west of I-280 again and remains west of I-280 in watershed land until crossing east of Skyline Boulevard to the transition station at San Bruno Avenue in the City of San Bruno.

a) Rebuild of Existing 60 kV Line

The FEIR finds that PG&E's proposed rebuild of the 60 kV line in the southern segment would have significant unmitigable (Class I) visual impacts at key viewpoints at Edgewood County Park, along southbound I-280, Lexington Avenue, Black Mountain Road, and north of the Carolands substation. It also identified Class I impacts for recreation and biological resources because of the high value of Edgewood Park habitat and recreational experiences. Because of its location within SFPUC watershed lands, the southern segment of the Proposed Project could result in permanent loss and/or temporary disturbance to sensitive plant communities and associated wildlife habitat. In particular, there is concern regarding impacts to wetlands and serpentine grasslands, which are habitats for protected species including the California Red-Legged Frog, the San Francisco Garter Snake, and the Bay Checkerspot Butterfly.

In light of the FEIR's conclusions regarding the environmentally superior route and the risk of an NPS veto (discussed in Section V.A.5), PG&E now supports Route Option 1B instead of the southern segment of the Proposed Project.

The County of San Mateo, the City of Burlingame, and 280 Citizens oppose the southern overhead segment of the Proposed Project. These parties assert that replacing 60 kV towers with taller 230 kV towers²² would create significant visual impacts in a highly valued scenic corridor. In their view, the project would exacerbate existing land use conflicts already created by the 60 kV line in residential areas, scenic corridors, and parklands. They argue that the project would compound existing conflicts with community values; the County of San Mateo asserts that the Proposed Project would be in conflict with the visual policies in the San Mateo County General Plan.

These parties are also concerned that this segment of the Proposed Project would expose residential neighborhoods to much higher EMF levels than the existing line. 280 Citizens maintains that the I-280 corridor communities now know about potential health impacts from prolonged exposure to elevated magnetic field levels and that, if the overhead portion of the Proposed Project is built, many residents of these affected neighborhoods will move rather than risk possible serious health impacts. EMF issues are discussed in more detail in Section VI.

b) Transition to Northern Segment

PG&E proposes to place a transition station between the southern overhead and northern underground segments of the Proposed Project near the intersection of San Bruno Avenue and Glenview Drive. The FEIR identifies and analyzes three alternatives to the San Bruno Avenue transition station: a Sneath Lane transition station, a West of Skyline transition station, and a Glenview Drive transition tower. The FEIR concludes that a Glenview Drive transition tower is the best transition alternative because it would minimize land use, visual, seismic, and recreation impacts due to its location in a less visible area adjacent to an existing City of San Bruno water tank and east of the main trace of the San Andreas fault.

PG&E maintains that a San Bruno Avenue transition station would have few environmental impacts because it would avoid biologically sensitive areas and utilize a low-profile design to minimize visual impacts. PG&E states that, although the site is within the San Andreas fault zone and adjacent to potentially active secondary faults, seismic impacts would not be significant and would be less than for any other transition station alternative.

The FEIR concludes that the San Bruno Avenue transition station location would have Class I (significant unmitigable) land use and visual impacts. It would conflict with planned future development at the transition station site and would introduce an industrial character, structural prominence, and view blockage when viewed from Skyline Boulevard, San Bruno Avenue, or the nearby Sky Crest shopping center.

The City of San Bruno, the City of Burlingame, and 280 Citizens oppose the San Bruno Avenue transition station site. San Bruno asserts that a transition station at this site would introduce a new blighting condition within its Redevelopment Plan Area in violation of the state Redevelopment Law. In its view, a transition station here would run roughshod over the values of the community, which desires to turn the area into a gateway to San Bruno. The transition station would be across the street from shopping and planned townhouses and would displace a planned parking lot for public access to the recently completed trail entrance and bicycle and walking paths in the adjacent San Francisco State Fish and Game Refuge. The site is zoned for neighborhood commercial uses, with a maximum height of 28 feet, whereas the transition station would be 47 feet tall. San Bruno would support either the elimination of the need for a transition station, such as Route Option 1B, or another location for a transition structure in San Bruno that is more consistent with the industrial nature of such structures.

The West of Skyline Boulevard transition station alternative would be located on SFPUC watershed lands southwest of the corner of San Bruno Avenue and Skyline Boulevard. The Sneath Lane transition station alternative would be co-located with an existing Sneath Lane substation. The FEIR states that either of these alternatives would eliminate the unmitigable Class I visual and land use impacts of the proposed San Bruno Avenue transition structure. However, both of them would lie west of the active trace of the San Andreas fault, so that an underground crossing of that trace would be required. The FEIR concludes that this underground fault crossing would cause significant unmitigable (Class I) impacts for either alternative.

The Glenview Drive transition tower alternative would be located approximately 0.5 miles south of the proposed transition station on Glenview Drive adjacent to a water tank owned by the City of San Bruno. This alternative would reduce the visual impacts and land use conflicts associated with the proposed transition station site. It would be located east of the San Andreas fault and thus would not require an underground crossing of the San Andreas fault. It would be closer than the San Bruno Avenue location to the active trace of the San Andreas fault, but the FEIR concludes that that risk can be mitigated to a less-than-significant level. The FEIR also finds that, if the underground northern portion of the project is routed down San Bruno Avenue, there would be no significant unmitigable (Class I) impacts associated with the Glenview Drive transition tower.

PG&E states that, while a Glenview Drive transition tower would raise greater seismic risks than a San Bruno Avenue transition station, it is preferable from a seismic perspective to the Sneath Lane or West of Skyline locations. As a second option, PG&E is willing to accept the Glenview Drive transition tower, so long as it is used with the Proposed Project underground route.

The City of San Bruno states that, if the Commission selects a route that requires a transition station near San Bruno Avenue, it would accept the Glenview Drive transition tower option. However, it asks that, if the Commission approves a Glenview Drive transition tower, the underground line traverse the adjacent State property along Skyline Boulevard rather than use Glenview Drive to reach San Bruno Avenue. San Bruno explains that use of the Caltrans right of way would preserve Glenview Drive as a much-needed utility corridor.

2. Route Option 1B

In Route Option 1B, the 230 kV line would be entirely underground except for a crossing of the Crystal Springs Dam. The existing 60 kV line would not be modified in any way. From the Jefferson substation, the 230 kV line would be located within Cañada Road for about 5 miles to Highway 92. It would then turn onto Highway 92 before turning onto Skyline Boulevard. The route would continue north in Skyline Boulevard, crossing over Crystal Springs Dam. Several options exist for the transmission line where Skyline Boulevard crosses Crystal Springs Dam. At Golf Course Road, the route would turn to cross under I-280, turning north into the continuation of Skyline Boulevard immediately east of I-280 and staying on Skyline until Trousdale Drive. The route would travel east on Trousdale Drive, then turn north into El Camino Real. It would remain in El Camino Real until connecting with the northern segment at San Bruno Avenue.

The FEIR identifies Route Option 1B as the environmentally superior route in the southern segment. Route Option 1B would eliminate all significant visual impacts identified for the Proposed Project's southern segment. The FEIR describes several options for crossing the Crystal Springs Dam that would have no significant unmitigable impacts, and includes a revised overhead crossing, a top of the dam crossing, and a submarine cable option within the environmentally superior alternative. Route Option 1B would also eliminate the impacts associated with the San Bruno transition station, since the entire project would be underground. The FEIR concludes that Route Option 1B would minimize permanent impacts to the most relevant areas of land use, visual resources, and biology. The FEIR finds Route Option 1B preferred on the issue of geology and seismic issues because it would avoid the known active traces of the San Andreas Fault located along Skyline Boulevard near San Bruno Avenue. The FEIR also finds that Route Option 1B has the potential to reduce EMF exposure to residences, compared to the Proposed Project.

PG&E now supports Route Option 1B on the basis that it avoids the significant visual and biological impacts of most other southern segment alternatives and the associated opposition of federal and state natural resource agencies. CCSF submits that Route Option 1B is the most environmentally prudent choice for the southern segment, since its impact to the watershed can be mitigated so that there are no significant impacts.

The City of Burlingame, the County of San Mateo, the City of Millbrae, and 280 Citizens oppose Route Option 1B. They raise numerous concerns, including construction complexities due to existing underground utilities and seismic factors; construction impacts including noise, traffic, emergency access, and business losses; residential EMF exposure; and the fact that Route Option 1B would not address concerns regarding the existing 60 kV line.

Burlingame submits that Route Option 1B, which runs through residential neighborhoods and passes two schools, a convalescent facility, and a hospital, is not good public policy. Burlingame and Millbrae assert that Route Option 1B ignores the community value of economic revitalization, which they state the FEIR did not consider under CEQA in determining the environmentally superior route. Route Option 1B would result in El Camino Real "once again being torn apart, with the already struggling businesses significantly impacted."

San Mateo submits that the most preferable route to connect the Jefferson-Martin line from the I-280 corridor to the eastern portion of the northern segment is Sneath Lane rather than Trousdale Drive. It points out that Sneath Lane east of I-280 to El Camino Real is lined by professional and medical office buildings on one side and the Golden Gate National Cemetery on the other. At El Camino Real, Sneath is flanked by regional commercial development. In its view, Option 1B should be rejected because there are less populated alternatives, in particular Sneath Lane or San Bruno Avenue, with less public facilities involving children and at-risk residents.

Burlingame, San Mateo, and 280 Citizens assert that there is not enough space due to existing utilities in Trousdale Drive, Skyline Boulevard, and El Camino Real to install Jefferson-Martin feasibly. Burlingame maintains that Trousdale Drive is already heavily congested with utilities including storm drains, water and sewer mains, electric, gas, telephone, and cable lines. Lateral lines connecting the utilities to properties along the street traverse the street at depths which vary by as much as eight feet. A 60-inch diameter Hetch Hetchy water main crosses Trousdale Drive in two locations. Skyline Boulevard, while not as congested as Trousdale, still has a number of utilities beneath the street. Burlingame maintains that this congestion will require trench depths of at least twelve feet and vault depths of at least fourteen feet below the surface of the street.

PG&E responds that the presence of existing utilities along Route Option 1B is not expected to present unusual challenges. While final engineering will reveal the exact location of existing utilities, PG&E reports that its site investigations of Trousdale Drive, El Camino Real, and Skyline Boulevard establish that Route Option 1B is feasible. It asserts that Burlingame's own plans to install a new water main supply beneath Trousdale Drive prove that there is sufficient space in that street. PG&E also points out that the PUA supported by these parties would require the transmission line to travel underground in Glenview Drive, Sneath Lane, or San Bruno Avenue and that there are underground utilities in each of these streets.

PG&E maintains that seismic issues along Route Option 1B are insignificant and in no way affect the feasibility of constructing this route option. PG&E asserts that Route Option 1B has fewer seismic risks than any other southern alternative, because it avoids the known active traces of the San Andreas fault located along Skyline Boulevard near San Bruno Avenue. Burlingame argues to the contrary that seismic risks along Trousdale Drive would be significant due to the Serra fault which crosses the street, a moderate landslide risk along the drive, and liquefaction potential near the intersection of Trousdale and El Camino Real.

The FEIR states, and Burlingame concurs, that the Serra fault is capable of displacement of up to three feet. PG&E maintains to the contrary that the fault should not slip more than a foot. PG&E agrees to install reinforced duct banks in the area of the Serra fault that would be expected to withstand up to a three foot slip if warranted by further geological investigation.

Burlingame is concerned about the adequacy for Trousdale Drive of the FEIR's Mitigation Measure G-8a, since it was designed for the San Andreas fault. Burlingame points out, first, that there are conflicting reports regarding where the Serra fault crosses Trousdale Drive. Second, the San Andreas fault is a right lateral strike slip fault, whereas the Serra fault is a thrust fault. The two types of faults exhibit different types of movement; Burlingame contends that displacements along the Serra fault could occur within a zone up to 115 wide, thereby requiring mitigation across the entire zone.

As an additional seismic mitigation measure, Burlingame wants a geologist on site to observe the trenching in the relevant portion of Trousdale Drive to determine the location of the Serra fault. It requests a geotechnical study to assess the degree of possible displacement on the Serra fault. It also requests that PG&E be required to design the duct bank and associated vaults to withstand a 7.1 magnitude earthquake on the San Andreas fault and associated movement on the Serra fault, install a fire and security alarm system and a fire suppression system in each vault within Burlingame city limits, and place seismic monitors along the duct bank.

Regarding Burlingame's concerns about liquefaction, PG&E responds that this area is not underlain by bay muds, the material most likely to liquefy. PG&E asserts that the liquefaction risk along Trousdale is "high" compared to the "very high" liquefaction risk along portions of the Collocation Alternative. It states that mitigation measures could be used to ensure that the transmission line would survive any such event.

The County of San Mateo, the City of Burlingame, and 280 Citizens assert that Route Option 1B would create unnecessary traffic impacts. San Mateo characterizes El Camino Real as a critical regional and local transportation artery and argues that traffic closures would impair access to homes and commercial businesses and resulting economic loss. Burlingame points out that PG&E has not included in its cost estimates any business disruption costs for businesses along El Camino Real.

280 Citizens maintains that construction creates inherent hazards if conducted in a residential neighborhood. 280 Citizens and Burlingame are also concerned that construction activity could increase emergency services' response times. PG&E responds that, just as Burlingame will do for its planned water main construction, PG&E will make provision for emergency access during construction along Route 1B and will ensure that any impacts are less than significant.

Burlingame states that, if the Commission approves Route Option 1B, the city will place certain conditions, pursuant to rights retained under its franchise agreement, on project installation in its city streets. Burlingame describes its Public Works Department's standard that new utility infrastructure traversing the city (but not actually serving the city) must be buried two feet below the lowest existing utility in the right of way. Burlingame states that it would also require that PG&E undertake studies to determine the impact of the line on existing cast iron water pipes and install any necessary cathodic protection systems. Burlingame requests that the Commission acknowledge these mitigations and instruct PG&E to abide thereby.

PG&E responds that Burlingame does not have the right to place its own mitigation requirements on PG&E since the Commission has exclusive jurisdiction over the siting, construction, and design of transmission line projects. PG&E urges the Commission to deny Burlingame's request to include these mitigation measures. To the extent that implementation of adopted mitigation measures may require Burlingame's approval, PG&E requests that the Commission put in place a process whereby disputes between Burlingame and PG&E on these matters may be resolved by the Commission.

Burlingame asserts that the FEIR's Mitigation Measure T-1a, which requires the development and approval of Transportation Management Plans, is inadequate. Burlingame requests several additional mitigation measures related to construction timing, school access, hospital access, parking on Trousdale and Skyline, emergency access, noise control, and the provision of information to property owners.

280 Citizens submits that Route Option 1B would create new land use conflicts by creating a new utility corridor through residential neighborhoods. Just as significantly in its view, Route Option 1B would leave the existing 60 kV line in place, which would continue to be inconsistent with the residential areas, I-280 scenic corridor, and parklands through which it is located. 280 Citizens urges the Commission not to squander this unique opportunity to reduce existing land use conflicts and enhance visual and scenic values on the Peninsula. Burlingame voices similar views.

280 Citizens recognizes that Route Option 1B would reduce magnetic field levels below those of the Proposed Project. It contends, however, that approval of Route Option 1B with the existing 60 kV line left in close proximity to residences would result in aggregate magnetic field levels that would exceed the levels produced by the PUA. It argues further that Route Option 1B would exacerbate existing concerns about EMF exposure by locating the 230 kV line along Skyline Boulevard in close proximity to homes already affected by EMF exposure from the existing line. San Mateo notes that the FEIR did not consider the health and safety factor related to EMF exposures.

PG&E asserts that Route Option 1B would have little or no biological impacts. While a consultation with the U. S. Fish and Wildlife Service (USFWS) would be needed regarding the crossing of the Crystal Springs Dam, PG&E states that it has developed a plan for constructing the crossing without negatively affecting California Red-Legged Frogs and has discussed this issue several times with USFWS. PG&E reports that USFWS has stated that it finds PG&E's proposed mitigation measures acceptable. PG&E expects compliance with the Endangered Species Act to proceed quickly and smoothly if Route Option 1B is selected.

3. Partial Underground Alternative and Modified Partial Underground Alternative

The Commission's environmental consultants developed and the EIR analyzed an alternative southern route called the PUA (Partial Underground Alternative). In the PUA, the existing double 60 kV line would be rebuilt with taller towers to carry the new 230 kV circuit and one 60 kV circuit, consistent with the southern segment of PG&E's Proposed Project. The PUA would differ from the Proposed Project, however, in that it would reroute two portions of the combined rebuilt line and would underground another portion in order to reduce impacts on sensitive areas. In this section, we describe issues arising from differences between the Proposed Project and the PUA and its variations. Issues common to the Proposed Project and the PUA, including transition station locations and NPS jurisdictional concerns are addressed elsewhere in this order.

Starting from the Jefferson substation, the PUA would reroute the initial 2.8 miles of the line to the west in order to avoid Edgewood Park and the Pulgas Ridge Preserve (called the southern reroute). In the next modification, approximately three miles of the combined line would be undergrounded (except for an overhead crossing of San Mateo Creek) between the Ralston and Carolands substations in order to reduce impacts on adjacent residences in the San Mateo Highlands and the Town of Hillsborough. The final modification (called the northern reroute) would reposition 1.5 miles of the rebuilt overhead line, between approximately the City of Burlingame city line and Trousdale Drive, to the west to avoid proximity to residences in the City of Burlingame.

The FEIR describes that the PUA would eliminate all of the significant unmitigable impacts of the Proposed Project's southern segment. The PUA would eliminate most visual impacts near residential areas²³ and would also eliminate two crossings of I-280 because the line would remain west of the freeway north of the Carolands substation. However, the FEIR finds that the PUA would create new significant unmitigable visual impacts along Cañada Road near Edgewood Road, at the I-280 crossing south of Carolands substation, and at the transition structure at Tower 7/39. For this reason, the FEIR finds the PUA less desirable than Route Option 1B.

280 Citizens supports a modification to the PUA which would move the underground portion up to 25 feet to the west in very limited areas to ensure that the lines are located at least 75 feet from residential property lines, in order to reduce EMF impacts on residences that border that portion of the transmission corridor. The PUA with that change is referred to as the MPUA (Modified Partial Underground Alternative). 280 Citizens states that the environmental impacts of the PUA's southern reroute may outweigh its benefits and, as a result, 280 Citizens would support either the Proposed Project's route through Edgewood County Park or the southern reroute, whichever the Commission deems to be superior.

In the environmental review, the FEIR rejected the underground route change in the MPUA based on its assessment that moving the underground alignment to the west would cause greater impacts than it would mitigate.

280 Citizens and the City of Burlingame assert that the PUA or the MPUA would reduce the Proposed Project's land use conflicts and would be consistent with community values by rerouting the line out of Edgewood County Park, out of residential areas, and in a way that reduces visibility of the line along I-280, which has been designated as a scenic highway. In their view, the PUA or the MPUA would minimize visual impacts, construction impacts, and health impacts far better than either the Proposed Project or Route Option 1B. 280 Citizens characterizes the MPUA as a rare opportunity for the Commission to reduce both future impacts and existing impacts and to improve the environment in both San Francisco through the closure of Hunters Point Unit 4 and the I-280 corridor.

PG&E, CCSF, and CARE oppose both the PUA and the MPUA. These parties contend that the PUA and MPUA suffer from a host of environmental, technical, legal, and regulatory feasibility infirmities and that proponents of these route alternatives have a self-interested desire to enhance their property values at ratepayer expense.

PG&E argues that the rerouted overhead utility corridors in the PUA or the MPUA would significantly worsen existing scenic viewsheds, thereby degrading the recreational experience in the project area. While acknowledging that the southern reroute would have some visual impacts in the Cañada Road corridor, 280 Citizens and Burlingame respond that either the PUA or the MPUA would provide a net improvement in visual impacts. They point out that the underground section would remove overhead lines and that the northern reroute would relocate the line from the ridge on the east side of I-280 to a topographically lower area on the west side of I-280, both of which changes would improve visual impacts on the I-280 scenic corridor. Burlingame sees the southern reroute, which would remove towers from Edgewood County Park and Pulgas Ridge, to be beneficial.

PG&E, CCSF, and CARE assert that the two overhead reroutes and trenching for the underground section of the PUA or the MPUA would have significant biological impacts. The two new overhead corridors would be in currently undeveloped SFPUC watershed lands known to support rare plant and animal species protected under state and federal law. The underground section of the PUA would require trenching through the largest remaining serpentine grassland in San Mateo County, which provides habitat for the protected Bay Checkerspot Butterfly, and the MPUA would exacerbate these biological impacts. PG&E maintains that the new utility corridors would violate the SFPUC Watershed Management Plan which discourages new utility corridors in undeveloped watershed lands.

In response to PG&E's concerns, 280 Citizens and Burlingame submit that the temporary construction and biological impacts of the PUA and the MPUA are not significant and can be mitigated. Burlingame points out that the FEIR determined that all impacts of the PUA to the serpentine grasslands and the special status species in the area would be mitigable to less than significant levels.

280 Citizens presented testimony that the serpentine habitat can be restored and even improved through revegetation with native serpentine plants and grasses. 280 Citizens points out that the serpentine habitat along the portion of the route that would be undergrounded has already been degraded significantly due to the existing access roads and SFPUC's frequent disking, mowing, and burning of broad areas maintained as firebreaks. PG&E acknowledges that the Bay Checkerspot Butterfly is no longer found north of Highway 92. It points out, however, that the USFWS Recovery Plan for Serpentine Soil Species of the San Francisco Bay Area identifies the MPUA-proposed trenching area as Priority 1 and 2 in the recovery strategy for the Bay Checkerspot Butterfly and the Marin Dwarf Flax.

280 Citizens argues that the MPUA is the only alternative that reduces EMF levels sufficiently to provide a prudent margin of safety for residents. San Mateo points out that, in finding that Route Option 1B is preferable to the PUA, the FEIR did not consider public health concerns related to exposure to EMF. San Mateo asks that, if the Commission does not choose the PUA or the MPUA, the Commission consider the potential removal of the existing 60 kV line similar to what was done in the Tri-Valley case.

PG&E argues that the multiple transitions in the PUA or the MPUA between underground and overhead configurations would decrease reliability due to the increased difficulties in locating the cause of a line outage. Burlingame responds that construction of a line with multiple overhead-to-underground transitions is not novel. It points out that utilities are working on development of a directional fault detector, which could be installed after it is developed. Since the risk of outages in an underground line is small and PG&E is exploring a manner in which to address this problem, Burlingame concludes that this reliability issue provides no basis for rejecting the PUA or MPUA.

The County of San Mateo asserts that PG&E has dramatically overstated the time that it would take for NPS approval if required, and the time and role of consultation with federal agencies under the Endangered Species Act. PG&E contests the credibility of San Mateo's time estimates, stating that San Mateo's witness had limited knowledge regarding the route options, did not know long it would take to resolve the NPS land rights dispute, agreed that plant and biological surveys would be required, and agreed that Section 7 consultations with the USFWS for the PUA or MPUA route could take a year. CARE maintains that the necessity of compliance with federal environmental regulations including NEPA would delay completion of the PUA or MPUA for several years, exacerbating San Francisco's electricity problems and creating the potential for further negative environmental impacts on residents of San Francisco's Bay View/Hunters Point neighborhoods due to continued operation of the Hunters Point power plant.

In addition to its other concerns, PG&E argues that the PUA or the MPUA cannot be legally required. PG&E asserts that undergrounding and re-routing of portions of the existing 60 kV line as proposed by the PUA and the MPUA would not mitigate a project impact or achieve a basic project objective but instead are attempts to enhance the environmental baseline. On that basis, PG&E concludes that these route proposals lack the required constitutional nexus to the Jefferson-Martin project and so violate the Takings Clause of the U.S. Constitution.

Burlingame responds that PG&E's assessment is based on an erroneous definition of the Jefferson-Martin project. Since the project, as initially proposed, would include significant modifications to the 60 kV line, Burlingame concludes that the 60 kV line is part of the project and that the PUA and MPUA may properly be considered. Burlingame's analysis is consistent with the FEIR, which states that, because modifications to the existing 60 kV line in the southern segment, as proposed by PG&E, would create adverse impacts, alternatives such as the PUA designed to mitigate those impacts may properly be considered under CEQA.

280 Citizens asserts that the Commission has authority, independent of CEQA, to require PG&E to relocate or underground the existing 60 kV line as part of its approval of the Jefferson-Martin project. It states that the Commission's authority under §§ 1001 and 1002 is much broader than the authority of most other state agencies under CEQA, and includes authority to condition its grant of a CPCN on the adoption of any changes to PG&E's existing utility plant and facilities as public convenience and necessity may require. 280 Citizens cites § 762, which empowers the Commission to direct public utilities to make changes to existing utility facilities and also invokes §§ 761, 768, and 701. 280 Citizens cites prior instances in which the Commission has required the removal and relocation of existing utility lines, including its determination in the Tri-Valley proceeding that an existing 60 kV line should be removed.

As a separate legal argument, PG&E maintains that the Commission may not select the MPUA since the FEIR rejected the MPUA from full consideration and did not analyze its impacts. A very similar alternative was identified in the Alternatives Screening Report (FEIR, Volume 2, Appendix 1) as the West of Existing Corridor, East of I-280 Alternative, and not pursued in detailed analysis.

4. Hybrid Southern Alternatives

The FEIR analyzed several hybrid alternatives for the southern segment designed to reduce or avoid biological, visual, seismic, and other impacts associated with parts of the southern segment alternatives. The FEIR concludes that Route Option 1B is environmentally superior to any of the hybrid southern alternatives.

A new Golf Course Drive transition station, west of the Carolands substation, would allow creation of a hybrid alternative using the underground Route Option 1B in the southernmost segment, which would minimize visual and biological impacts because the route would be underground and within roadways (except for the crossing of Crystal Springs Dam). From the new transition station, the overhead line would follow the route of either the PUA (including its northern reroute) or the Proposed Project to a transition station in the San Bruno Avenue area. This configuration would avoid Route 1B's effects on the residential areas along Skyline Boulevard and Trousdale Drive, as well as on businesses and traffic on El Camino Real. A Golf Course Drive transition station could also be used as a modification to the PUA to allow the 230 kV line to cross I-280 underground, thus reducing the height and mass of the transition tower at Tower 8/50 because it would be needed for only the 60 kV line.

A new transition tower at the existing tower 11/70 near the west end of Trousdale Drive could be used, similar to a Golf Course Drive transition station, to connect the southernmost portion of Route Option 1B with the portion of the Proposed Project north of the new transition tower. This would avoid effects on Trousdale Drive and El Camino Real. This transition tower alternatively could connect the southernmost portion of the Proposed Project with Route Option 1B's Trousdale Drive and El Camino Real segment. Such a hybrid would avoid the visual and biological impacts of the Proposed Project in the I-280 corridor between Trousdale Drive and San Bruno Avenue, visual concerns regarding the San Bruno transition station, seismic concerns regarding proximity to the San Andreas fault of the San Bruno transition station or its alternatives, and the use of San Bruno Avenue. Another possible transition tower location about 1,100 feet west of tower 11/70 could be used to connect the southernmost portion of the PUA or MPUA to Route Option 1B's Trousdale Drive and El Camino Real segment.

The County of San Mateo states that, if the Commission is concerned about time deadlines and NPS review, the most appropriate alternative is a hybrid that uses Route Option 1B in the southernmost portion of the route, in order to reduce impacts on watershed lands and avoid the impacts of an underground route along Trousdale Drive and El Camino Real. San Mateo prefers the Golf Course Drive transition station because it would reduce exposure to residents along Skyline Drive.

PG&E states that the feasibility of the hybrid routes and their environmental impacts are based on the feasibility of their constituent parts, but that construction of an additional transition structure would create additional impacts. PG&E points out that each of the hybrid routes would involve some overhead or underground construction in SFPUC watershed lands, so NPS objections would still apply.

5. NPS Concerns

NPS did not participate as a party in this proceeding. However, it made known its views on the proposed Jefferson-Martin project and its variations through letters, statements at the PHC, comments on the draft EIR, and statements at a Commission meeting. NPS states that conservation easements it holds for the SFPUC watershed lands provide it with discretionary authority to review and approve the Jefferson-Martin project to the extent the project would require an expansion to PG&E's existing right of way through the watershed. NPS explains that it would issue a written approval determination that would be based on a NEPA document prepared by the project proponent, but that PG&E has "refused to prepare" a NEPA document for the project.²⁴ PG&E and CCSF disagree with NPS regarding applicability of the conservation easements but are concerned that NPS efforts to exert jurisdiction could cause significant delays in the project. The FEIR also disagrees with NPS regarding the applicability of the conservation easements.

Separate from any authority arising from the conservation easements, NPS would have approval rights over any modifications within Edgewood County Park and Pulgas Ridge Open Space Preserve that convert land to non-recreation purposes, due to grants received under the federal Land and Water Conservation Fund. It appears that the Proposed Project would, Route Option 1B would not, and the PUA/MPUA may require NPS approval for this portion of their route.

NPS states that the southern segment of the Jefferson-Martin project as proposed by PG&E is incompatible with NPS's conservation easements and that it would not concur with the project as proposed. NPS contends that the Proposed Project's impact on the scenic, recreational, and biological resources of the watershed would be substantial and permanent. NPS supports undergrounding both the existing 60 kV line and the new 230 kV line along Cañada Road and disagrees with the draft EIR's decision to eliminate this option from full consideration.²⁵ NPS initially stated that the underground Route Option 1B is the only southern alternative fully examined in the FEIR that is consistent with the easements and therefore acceptable to NPS.

The County of San Mateo and 280 Citizens argue that the possibility that project alternatives may require federal environmental review provides no legal or practical justification for concluding that such alternatives are infeasible or should not be considered by the Commission. San Mateo asserts that the fact that NPS staff commented negatively on certain route alternatives does not dictate the results of any NEPA review or prevent NPS from ultimately approving one of those routes if its approval is required. 280 Citizens takes the position that a Jefferson-Martin project is not needed until at least 2012, which would provide more than enough time to comply with any federal regulations that may apply. 280 Citizens and San Mateo submit that the Commission should base its decision in this proceeding on the merits of a route, not whether NPS review would be required or whether the project could be constructed by the end of 2005 as PG&E requests.

The City of Burlingame states that the NPS claim places the Commission in a difficult position. Since a determination regarding the applicability of NEPA is outside the Commission's jurisdiction, Burlingame suggests that the Commission make a reasoned assessment regarding the potential that the NPS claim may render one or more alternatives a legal impossibility and the repercussions that the NPS claim may have on the project, including the amount of possible delay and the impact of such delay. With the view that any delay needed to resolve the NPS claim should not endanger PG&E's ability to provide reliable service, Burlingame concludes that the Commission should not reject any of the southern route alternatives because of concerns regarding the NPS claim.

In a June 4, 2004 letter and subsequent letters, the NPS states that it recognizes that changes to Route Option 1B would meet many of the local communities' concerns. The NPS suggests that a hybrid alternative traversing a limited portion of the watershed may be acceptable if there are adequate mitigation measures to compensate for the impacts to recreational and natural resources. The hybrid route it is willing to consider would use Route Option 1B in the southernmost segment, transition above-ground at the existing tower 11/70 near the west end of Trousdale Drive, and follow the existing 60 kV line from that point north to tower 14/93. The 230 kV line would exit the watershed lands at that point and would use the Glenview Drive transition tower alternative. The NPS states that it is discussing mitigation measures with PG&E and is optimistic that adequate mitigations can be identified for this alternative route. In a July 6, 2004 letter, the NPS identifies a list of mitigation measures that, in its view, "would be necessary to offset the impacts to the natural and recreational resource values of the Peninsula Watershed lands that would be affected by the Trousdale Drive/Glenview Drive hybrid route." The NPS asks that the Commission include these mitigation measures as required elements of the Jefferson-Martin project if this route is approved for the project.

The hybrid route that the NPS states it is willing to consider appears to be the one that we approve for the southern portion of the Jefferson-Martin project. However, as explained in August 3 and August 9, 2004 ALJ rulings, which we affirm in this regard, the NPS mitigation measures were not submitted in a manner that would allow their consideration in this proceeding. It would be inappropriate to accept NPS's ex parte letters submitted outside the Commission's formal proceeding process, as well as outside the CEQA process, into the record as suggested in the August 9, 2004 ALJ ruling. We do not approve the NPS mitigation measures or include them in the mitigation monitoring program. Nor do we include their costs in the cost cap adopted for the project. If the NPS imposes mitigation measures through a NEPA process subsequent to our issuance of the CPCN for the Jefferson-Martin project, we could consider such measures through a petition for modification of today's order or a PG&E application for an increase in the cost cap pursuant to Pub. Util. Code § 1005.5(b).

B. Northern Alternatives

The DEIR had identified the Collocation Alternative as the environmentally superior northern segment. However, in considering comments, it was determined that neither the PG&E proposed route nor the Collocation Alternative showed a significant environmental benefit compared to the other. Therefore, the FEIR modifies this DEIR determination and instead identifies two northern route options as environmentally superior: the northern segment of PG&E's Proposed Project with Route Option 4B and the Collocation Alternative with Route Options A, D, E, and F. The FEIR finds that the two alternatives have comparable levels of environmental impacts, with the Proposed Project's northern segment having environmental impacts greater than those of the Collocation Alternative in several issue areas, less impacts in other issue areas, and comparable impacts in yet other issue areas. No significant unmitigable (Class I) impacts are identified for either northern route alternative.

PG&E, South San Francisco, CBE-101, Golden Gate Produce Terminal, and Genentech support the Proposed Project's northern segment and oppose the Collocation Alternative. Daly City opposes the Proposed Project in the northern segment and supports either the Collocation Alternative or an alternative route collocated with the existing 60 kV Jefferson-Martin line across San Bruno Mountain.

If Route Option 1B were chosen for the southern segment, it would connect with either the northern segment of the Proposed Project or the Collocation Alternative at the intersection of El Camino Real and San Bruno Avenue. Mitigation Measure T-9a, which the FEIR suggests if needed to avoid conflict with a planned grade separation project at the corner of San Bruno Avenue and El Camino Real, would affect the route of both the Proposed Project and the Collocation Alternative. Beginning at the intersection of San Bruno Avenue and El Camino Real, the route would go north on El Camino Real and then turn east into Sneath Lane. It would rejoin the Proposed Project route by turning north into the BART right of way at Huntington Avenue. To rejoin the Collocation Alternative, the route would continue east past the end of Sneath Lane, under the railroad tracks, into Tanforan Drive and to Shaw Dive, where it would join the Collocation Alternative as originally defined.

1. Proposed Project-Northern Segment

The northern segment of PG&E's Proposed Project would head east along San Bruno Avenue from the transition station, and would turn north into Huntington Avenue to the BART right of way. From the BART right of way, it would turn east into the new Lawndale Boulevard then north into Hillside Boulevard, east into Hoffman Street, and north into Orange Street. From Orange Street, the route would turn east into East Market Street, which becomes Guadalupe Canyon Parkway and crosses San Bruno Mountain through the San Bruno Mountain State and County Park. From Guadalupe Canyon Parkway, the route would turn north on Bayshore Boulevard to the Martin substation.

The FEIR analyzes several route alternatives for portions of the northern segment of the Proposed Project. Three different underground routes could be used in conjunction with any of the four transition station alternatives (described in Section V.A.1): the proposed route down San Bruno Avenue, an alternative route down Sneath Lane, and a route continuing north on Skyline Boulevard to Westborough Boulevard. A variation of the Westborough Boulevard route, called the Junipero Serra alternative, would turn from Westborough Boulevard north into Junipero Serra Boulevard and east into Serramonte Boulevard. The Sneath Lane route and the Westborough Boulevard routes would require crossings of the San Andreas fault, and the Skyline Boulevard portion of the Westborough route is very close to the fault. The FEIR concludes that the use of San Bruno Avenue would be preferred to either Sneath Lane or Westborough Boulevard.

A Cherry Avenue/Sneath Lane alternative would avoid the proposed Huntington Avenue grade separation project by turning north from San Bruno Avenue into Cherry Avenue and then east into Sneath Lane. It would continue to the BART right of way where it would rejoin the Proposed Project. Mitigation Measure T-9a, which would route the line from San Bruno Avenue north along El Camino Real and east on Sneath Lane to the BART right of way, is a less extensive route change that would achieve the same objective.

A short East Market Street alternative, which PG&E calls Route Option 4B, would avoid the dense residential neighborhoods along Hoffman Street and Orange Street (Route Option 4A) of the Proposed Project by continuing north on Hillside (past Hoffman) and turning into East Market Street. Route Option 4B would rejoin the proposed route at Orange Street and East Market. The FEIR includes Route Option 4B rather than 4A in its environmentally superior alternative because it would reduce or avoid the construction impacts to residences along Route Option 4A. Route Option 4B would pass Pollicita Middle School and Colma Elementary School. Both Route Option 4A and 4B would pass Susan B. Anthony High School at a distance. The FEIR concludes that the wider streets in Route Option 4B would make it easier to mitigate short-term construction impacts compared to Route Option 4A and would also allow a degree of EMF mitigation by placement of the line across the street from the schools and/or by deeper burial of the line.

PG&E maintains that its Proposed Project in the northern segment is preferable to the Collocation Alternative because it would be constructed under paved streets, raises none of the technical feasibility issues associated with the Collocation Alternative, and would have no significant environmental impacts. In addition, PG&E asserts that it could be constructed on time and at less cost to ratepayers. PG&E supports the use of either Route Option 4A or 4B.

South San Francisco supports the northern segment of the Proposed Project instead of the Collocation Alternative, contending that the Proposed Project route would be less disruptive because it will be constructed for the most part along recently disturbed construction areas, would only minimally affect residences, and would raise little concern that toxic contamination would be encountered during construction. South San Francisco points to the FEIR's statement that, because the portion of the route following the BART right of way would be placed within the clean engineered fill over the BART tunnel, it is unlikely that any geologic or paleontologic issues would be encountered there except for seismically induced ground shaking. Because soils within the BART right of way were excavated and stabilized during BART construction, there is little, if any, risk of liquefaction along that portion of the route.

San Bruno opposes installation of the Proposed Project in San Bruno Avenue, arguing that San Bruno Avenue is a relatively narrow street that is already over-used by various utilities. It maintains that installation of the Jefferson-Martin line in San Bruno Avenue would interfere with the ability to relocate existing utility lines beneath the roadway when they need to be replaced.

Daly City opposes the northern segment of PG&E's Proposed Project because of its possible effect on Daly City schools. Route Option 4B, determined to be environmentally superior in the FEIR, would pass three Daly City schools. Daly City prefers Route Option 4A, which PG&E had incorporated into its Proposed Project at Daly City's request, but notes that it also passes a school playfield. In addition, the northern segment of PG&E's Proposed Project would pass John F. Kennedy Elementary School on Guadalupe Canyon Parkway, regardless of whether Route Option 4A or 4B is chosen.

PG&E takes issue with Daly City's arguments that the Proposed Project would have unacceptable impacts on residential neighborhoods and schools along its route. PG&E argues, as the FEIR found, there would be no significant impacts from construction of the project on schools or residences under either Route Option 4A or 4B.

2. Collocation Alternative

The Commission's environmental consultants developed and analyzed a Modified Underground Existing 230 kV Collocation Alternative, commonly referred to as the Collocation Alternative. This alternative would be located in primarily commercial and industrial areas. It would use approximately 1.1 miles of the route of an existing underground 230 kV transmission line in Bayshore Boulevard through the City of Brisbane, but would follow a new route segment through South San Francisco and adjacent cities to avoid several congested utility areas.

Either the Proposed Project route (at San Bruno Avenue and Huntington Avenue), Route Option 1B (at San Bruno Avenue and El Camino Real), or the Sneath Lane route alternative (boring under two railroad crossings into Tanforan Avenue to Shaw Drive) could connect to the Collocation Alternative. Mitigation Measure T-9a would connect in the same manner as the Sneath Lane route.

Starting at San Bruno Avenue and Huntington Avenue, the Collocation Alternative would follow San Bruno Avenue east and turn north into the overhead 115 kV line corridor just east of Seventh Avenue. It would then turn west into Seventh Avenue just south of I-380, continue north past where Seventh Avenue becomes Shaw Road, and then travel via a bored crossing of a tributary of Colma Creek and through a large Park'N Fly parking lot to turn into Produce Avenue. It would then turn east into Airport Boulevard, and then northeast into Gateway Boulevard. From the end of Gateway Boulevard, the route would pass through a vacant lot (the Chiltern site) and then follow the eastern edge of a Union Pacific railroad right of way past the Oyster Point development. It would cross a CCSF drainage structure using an existing emergency access road or, if needed, a bored crossing. It would turn west into Sierra Point Parkway and then use a bored crossing under the railroad tracks into Van Waters and Rodgers Road. It would then turn north into Bayshore Boulevard, continuing into the Martin substation.

Six route options (Route Options A through F) were identified in the FEIR to reduce potential impacts to land uses and transportation, based on comments on the draft EIR. The FEIR recommends that Route Options A, D, E, and F be incorporated into the Collocation Alternative, but states no preference between the original Collocation Alternative route and Route Options B and C.²⁶ From south to north, these route options are as follow:

Route Option A would avoid Produce Boulevard and the Park'N Fly lot with a bore from Shaw Road under Highway 101 and the Colma Creek tributary to Marco Way. It would continue along Marco Way, turn north into Airport Boulevard and rejoin the original route at Gateway Boulevard.

Route Option E would avoid the vacant contaminated Chiltern Site by turning east on Oyster Point Boulevard then north into Veterans Boulevard, rejoining the original route at the Union Pacific right of way.

Route Options B and C would reduce disturbance to the Sierra Point landfill cap. With Route Option B, the line would be installed in the parking lot just east of the railroad right of way. With Route Option C the line would go further east, following Shoreline Court north to Sierra Point Parkway.

Route Option D would avoid the west side loading dock area of Van Waters and Rodgers Road, with the line installed instead on the east side of the commercial facilities along Van Waters and Rodgers Road and paralleling the railroad right of way.

Route Option F would avoid use of the entrance ramp to Van Waters and Rodgers Road by continuing the line north adjacent to the railroad tracks and then west into Bayshore Boulevard.

For two blocks immediately north of San Bruno Avenue, the Collocation Alternative would be located within PG&E's overhead transmission corridor, which has residences on Seventh Avenue along its western side. With either the Sneath Lane alternative or Mitigation Measure T-9a, the Collocation Alternative would avoid this residential area. The remainder of the Collocation Alternative route consists of industrial areas and large office and hotel complexes. Within the office complexes, an existing day care center would be within approximately 100 feet of the project and a planned day care center would be within 50 feet.

Daly City strongly prefers the Collocation Alternative to the northern segment of PG&E's Proposed Project. It notes that PG&E's EMF Transmission Line Guidelines prioritize protection in eight descending categories, with schools/daycare and residential as the highest two categories. Daly City maintains that the northern segment logically should pass through Category 3 (commercial/ industrial) areas rather than by schools and residences. Opponents of the Collocation Alternative argue that it presents several significant technical challenges and regulatory obstacles that may render it infeasible.

PG&E and the City of South San Francisco contest the FEIR's finding that the Collocation Alternative is preferable to the northern segment of the Preferred Project with respect to soil conditions. The Collocation Alternative would require trenching through hazardous waste sites and a closed landfill, later maintenance of the line in such locations, and potential liability for releases of hazardous substances. These parties argue that the presence of debris in fill and bay muds affects the feasibility and cost of borings under Colma Creek Tributary and in other areas where boring is proposed. Water quality could be affected by an accidental release of drilling muds, which the FEIR states commonly occurs on bored or drilled water crossings. South San Francisco points out that areas under the water table would require dewatering during construction. The parties also point out that 60% of the Collocation Alternative route lies in an area with either a very high or high liquefaction potential during earthquakes, leading to risk of lateral spreading and associated transmission line failure.

PG&E and South San Francisco raise concerns regarding access during construction to hotels and several businesses along the Collocation Alternative route. PG&E maintains that the restriction of access may be so severe that the local fire department may order some businesses to be vacated during construction. Although PG&E states that it would contest any liability, it is concerned that it may face potential business interruption claims from businesses that potentially may lose access to their facilities as a result of construction activities.

South San Francisco takes issue with the finding in the FEIR that the Collocation Alternative is preferable to the northern segment of the Proposed Project regarding air quality because construction would be further from receptors. South San Francisco asserts that this finding ignores the childcare centers, the hotels and their guests, and the businesses and their employees located along the Collocation Alternative. It argues that the FEIR contains no discussion of the potential air quality impacts of trenching and excavating in contaminated soils.

South San Francisco also takes issue with the finding in the FEIR that the Collocation Alternative is preferable to the northern segment of the Proposed Project regarding transportation and traffic because the Collocation Alternative is 4.8 miles long instead of the Proposed Project's 7.8 miles. South San Francisco argues that the FEIR's finding is based on an erroneous assumption that because the route is shorter, the impacts are less. South San Francisco maintains that lane closures on Guadalupe Canyon Parkway would not have the same disruptive impact as a closure on Gateway Boulevard or Bayshore Boulevard.

South San Francisco contests the effectiveness of the route options identified in the FEIR to mitigate negative impacts of the Collocation Alternative. Route Option A's bored crossing beneath Highway 101 and the Colma Creek tributary could result in the accidental release of drilling muds. Options B and C would not avoid disturbance to the Sierra Point landfill. Route Option D may not be effective in avoiding impact to the loading docks along Van Waters and Rodgers Road, since the bore pit may be located in the parking lot and loading area. South San Francisco maintains that the FEIR's analysis of Route Option E fails to identify contaminated brownfields along Veterans Boulevard and contains no traffic analysis of the effect of moving the route to Veterans. While within an existing road that contains other utilities, Route Option E would still run through a portion of the HMS property and would compromise the clean soil cap, which would trigger the jurisdiction of the Regional Water Quality Control Board. South San Francisco argues in addition that Route Option E would interfere with proposed development of the HMS property and would have a negative effect on the hotels and businesses located on Veterans Boulevard. South San Francisco concludes that none of the route options would eliminate disturbance of the landfill cover at Sierra Point Landfill, the capped Homart toxic site, or soil surrounding at least three leaking storage tanks along the route.

3. Undergrounding of Existing Lines into Martin Substation

Throughout this proceeding, beginning in comments during the EIR scoping process and reiterated in its brief, Daly City asks the Commission to approve the undergrounding of existing overhead transmission lines into the Martin substation as part of the Jefferson-Martin project. In this alternative, the route for the Proposed Project would be modified to turn north off Guadalupe Canyon Parkway and follow the existing 60 kV corridor for approximately 0.4 mile down San Bruno Mountain, paralleling Linda Vista Drive into the Martin substation. The existing 60 kV power lines along this route would be undergrounded at the same time that the new 230 kV line is constructed.

The FEIR states that this alternative would not be within CEQA's "reasonable range of alternatives" and therefore is not a feasible alternative that can be evaluated in the EIR.²⁷ As a result, the alternative was eliminated from full analysis in the EIR. In addition, the FEIR describes conflicts with the current Habitat Conservation Plan for San Bruno Mountain which, it concludes, render the alternative regulatorily infeasible.

Daly City asserts that the FEIR did not study the cumulative impacts of the proposed Jefferson-Martin project and other power projects on Daly City's Bayshore neighborhood, which contains the Martin substation. Daly City describes that power lines come up the Peninsula from both the US-101 and I-280 corridors to the Martin substation. The lines cross Guadalupe Canyon Parkway and are proximate to Midway Village (the County of San Mateo's largest housing authority complex), the area's largest day care center, two public schools, and residences.

Daly City describes its Bayshore redevelopment project and appeals to the Commission to prevent its current progress from being compromised. Daly City states that undergrounding the existing overhead transmission lines would be more cost-effective now as part of the Jefferson-Martin project rather than later. It contests the legal feasibility analysis in the FEIR and maintains that the Commission retains authority and discretion to mitigate localized or long term disparate impacts on any affected community, within the Commission's "community values" consideration of § 1002 and the State's Environmental Justice Policy.

PG&E concurs with the FEIR's legal analysis and asserts further that using the Jefferson-Martin project as a vehicle for Daly City's redevelopment plans would inappropriately place the financial burden of the City's redevelopment on all California ratepayers.

We agree with the FEIR's assessment that undergrounding the existing lines into Martin substation does not fall within a "reasonable range of alternatives" which would allow it to be evaluated in the Jefferson-Martin EIR. Section 15126.6(f) of the CEQA Guidelines states, "The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project." The "project" along Guadalupe Canyon Parkway includes only the installation of a new 230 kV line and, thus, the effects of the project are limited to the impacts associated with the installation of this 230 kV line. Undergrounding of the existing 60 kV lines into Martin substation would not avoid or lessen the impacts of the 230 kV line. For this reason, we find that the EIR properly excluded Daly City's proposal from full evaluation.

Contrary to Daly City's assertion, the EIR considers cumulative impacts of the proposed project and other projects. CEQA provides that the cumulative impact from several projects is the change in the environment which results from the incremental impact of the project when added to other closely-related past, present, and reasonably foreseeable probable future projects. (CEQA Guidelines § 15355(b).) The FEIR considers cumulative impacts in terms of both approved and future projects and also the impact of the Proposed Project and its alternatives on the existing environment. In doing so, the EIR captures the cumulative impacts of "closely related past projects," as opposed to other past projects which now constitute part of the pre-existing baseline.

Because the approved route for the northern segment will be completely underground in the Daly City area, there will be no cumulative visual impact with existing lines coming into the Martin substation. The short-term construction impacts will be minimal for residences along Linda Vista Drive closest to Guadalupe Canyon Parkway, since they will be over 500 feet away from the new underground line.

4. Other Northern Alternatives

Daly City requests that an alternative be considered in which a portion of the northern segment of the Proposed Project would be rerouted and collocated with the existing Jefferson-Martin 60 kV line already crossing San Bruno Mountain to the Martin substation. Daly City explains that it requests consideration of this alternative because of the opposition to the Collocation Alternative that has arisen. It views this proposal as a compromise routing that would avoid both the schools and residences in Daly City passed by the Proposed Project and the contaminated areas in South San Francisco affected by the Collocation Alternative. Daly City suggested this alternative in its joinder to a motion requesting that the FEIR be modified in this regard and recirculated for comment. It reiterates this request in its briefs.

Daly City recognizes that this routing option was not considered in the EIR but states that this alternative would share in most respects the same general environmental characteristics and serpentine habitat as the southern segment of the Proposed Project within the SFPUC watershed. Since collocation with the existing 60 kV line across San Bruno Mountain appears to be shorter in distance than routing along Guadalupe Canyon Parkway, Daly City suggests that this alternative may be less expensive that this segment of the Proposed Project. Daly City believes that permitting across the San Bruno Mountain may take no more than a few months, noting that San Bruno Mountain has been studied comprehensively and is not subject to federal view corridor or other federal easements.

On June 8, 2004, the Assigned Commissioner issued a ruling directing that, pursuant to Pub. Util. Code § 1002, our environmental consultant undertake an analysis of the San Bruno Mountain alternative and also an alternative route segment that would use El Camino Real between San Bruno Avenue and Lawndale Boulevard/McClellan instead of the BART right of way. The resulting analysis was filed on July 6, 2004. As explained therein, the filed route analysis is not a CEQA document but rather an informational document for our consideration in determining whether a Supplemental FEIR should be prepared regarding these alternative route segments.

The consultant reports that the analyzed route segments would have greater environmental impacts than comparable portions of the route we approve today. The route analysis identifies that the San Bruno Mountain alternative would have significant and unmitigable biological, visual, and recreation impacts and would require modification to the San Bruno Mountain Habitat Conservation Plan, an undertaking that would take several years. The analysis identifies that the El Camino Real route segment would have substantially greater, though not unmitigable, environmental impacts compared to use of the BART right of way and also has feasibility concerns because of existing underground utilities in El Camino Real.

The route analysis addresses EMF exposures due to the two alternatives. The San Bruno Mountain route segment would pass residences underground along Hillside Boulevard and overhead near several streets in Daly City and Brisbane. Hillside Boulevard is 70 feet wide; if the line were placed on the northern side of Hillside adjacent to San Bruno Mountain County and State Park, EMF exposure would be minimal for the residences along the route. The consultant was not able to obtain sufficient information to calculate field levels for the overhead portion of the San Bruno Mountain alternative. The El Camino Real underground route segment would pass residences and South San Francisco High School. Because El Camino Real is 80 feet wide, EMF exposure in adjacent buildings may be significantly lower, depending on line placement, than along the BART right of way.

We do not require that a Supplemental FEIR be prepared for the San Bruno Mountain and El Camino Real route segments. It appears that, even if the environmental concerns could be overcome, the San Bruno Mountain alternative could not be approved and constructed before the Jefferson-Martin project is needed. Because we adopt specific EMF mitigation measures for the BART right of way and because of construction impacts and feasibility concerns, we see no need to consider the El Camino Real alternative further. On August 11, 2004, a newly-formed coalition of environmental groups filed a petition to intervene in this proceeding. The San Bruno Mountain Coalition states that it is primarily concerned with the San Bruno Mountain alternative and would represent the voice of the environmental community if further, in-depth study of that alternative is undertaken. Because a Supplemental FEIR will not be prepared for the San Bruno Mountain alternative, we do not grant the San Bruno Mountain Coalition's petition to intervene.

C. Other Project Alternatives

280 Citizens maintains that the FEIR fails to give sufficient consideration to the "cross-Bay" alternative presented in the San Francisco Long-Term Electric Transmission Planning Technical Study. 280 Citizens represents that the FEIR did not fully evaluate this alternative because it would not meet two of PG&E's project objectives: (1) connection of the Jefferson and Martin substations and (2) PG&E's specified on-line date. 280 Citizens asserts that PG&E's framing of the "objectives" of the Jefferson-Martin project should not limit the evaluation of potentially superior alternatives that would allow PG&E to meet future load in the Project Area. It argues in particular that, consistent with its view that the Jefferson-Martin project is not needed within the time frame identified by PG&E, there is no reason to eliminate this alternative on the grounds that it could not be constructed in time to meet future demand.

CEQA Guidelines § 15126 (a) requires the EIR to describe a reasonable range of alternatives to the project or location that would feasibly attain most of the basic project objectives of the project. CEQA Guidelines § 15364 further provides that the alternatives must be capable of being accomplished in a successful manner within a reasonable period of time taking into account economic, environmental, legal, social, and technological factors.

The FEIR did not eliminate the Moraga-Potrero Alternative (across the San Francisco Bay) from detailed analysis solely on the basis of concerns that it could not attain the applicant's objective that construction occur within the projected time-frame. 280 Citizens fails to recognize the significant feasibility concerns raised by this alternative. Separate from timing concerns, each of the Bay crossing options has regulatory and/or technical feasibility problems. A submarine crossing would be unlikely to be permitted by the BCDC due to the existence of land-based alternatives. The Bay Bridge option would require that Caltrans grant an exception to its longitudinal encroachment policy, which is very unlikely, and would also be in conflict with the Bay Bridge construction project. The BART tunnel Bay-crossing option was found to be infeasible due to BART safety concerns. Thus, we find 280 Citizens' criticism to be without merit.

²³ The FEIR suggests modifications to locations proposed in the draft EIR for transition towers/stations north and south of San Mateo Creek.

²⁷ The FEIR also explains that CEQA specifies that in order for a mitigation measure (and by inference, an alternative) to be feasible, it must meet relevant constitutional standards (CEQA Guidelines § 15124.4(a)(4)). Such standards include a requirement that there be an essential connection or relationship between an alternative and a legitimate lead agency interest dealing with the Proposed Project. The FEIR finds that such a connection is lacking in this instance.