7. Parties Positions on Routing and Location of Substations

7.1 PG&E

PG&E continues to strongly support its proposed project in its entirety, including construction of Phase 2. In the Pleasanton area, PG&E would also support the S4/S2 or S4/S5 alternatives because, along with its proposed project, PG&E believes these routes have the least environmental impacts and could be constructed most quickly and at least cost. PG&E opposes construction of the environmentally superior D1 alternative to serve Dublin and argues that no project in North Livermore is inappropriate.

PG&E focuses much of its argument in support of its proposed project in the Pleasanton area on timing issues. For example, PG&E argues that the Commission must reject certain alternatives as infeasible because they could take additional time to build and construct or receive permits from other governmental agencies, and thus such alternatives would put at risk completion of the project by Summer 2002. PG&E argues that it has already prepared detailed engineering plans for its proposed route and begun consultations with governmental permitting agencies, which will speed completion of the project. It also stated, that it had begun similar engineering and permitting work on the S4 alternative, another route it prefers. (PG&E: Kraska, RT 1750.)

PG&E argues that the environmentally superior S2A/S2 alternative simply increases project costs without providing any additional environmental benefits because PG&E's proposed project does not present any significant environmental impacts. PG&E argues that CEQA does not require mitigation of effects that are not considered significant. In addition, PG&E argues that the S2A/S2 alternative will introduce a significant visual impact to Sycamore Grove Park users because construction of a transition station would be required on land near the park. PG&E also argues, citing its own testimony and witness, that the S2A/S2 alternative would have more biological impacts, specifically with respect to the California Red-Legged Frog and California Tiger Salamander, than its proposed route or the S4 alternative, because overhead routes can avoid drainages and habitat areas. PG&E argues that the S2A/S2 alternative, because it is constructed underground, cannot avoid drainages that provide breeding habitat for these species and thus this alternative presents more biological impacts than PG&E's proposed route.

Regarding Dublin alternatives, PG&E opposes selection of the environmentally superior D1 alternative. PG&E argues that in comparison to its proposed Dublin substation and attendant transmission facilities, D1 is more costly, less consistent with community values, and farther from the load it needs to serve. PG&E raises timing concerns, as well as safety concerns, about securing approval from the Alameda County Airport Land Use Commission (ALUC) for construction of D1. PG&E also argues that construction of D1 transmission lines through a quarry would present a significant conflict with the on-going gravel mining operations.

PG&E argues that its proposed substation location is superior because it avoids land use conflicts caused by the D1 substation location. PG&E states that locating a substation at the D1 site is "obviously incompatible with the City's planned land uses for the area" (PG&E Opening Brief, p. 61) and discusses the Dublin planning process, and the loss of commercial development land that would result from locating a Dublin substation in southern Dublin. PG&E places great weight on the testimony of Dublin city leaders who have indicated their opposition to the D1 location. For example, PG&E cites the fact that the D1 location would be located across the street from high density residential development as a reason why the substation should not be constructed. PG&E argues that, at a minimum, a conditional use permit from the City of Dublin would be required if D1 is selected, which would raise substantial timing concerns for PG&E.

PG&E argues that the D1 substation location is also less preferred, from an electrical standpoint, because of its proximity (about 2 miles) to the Vineyard Substation. PG&E argues that the Dublin substation needs to serve load primarily to the north and east of the existing developed areas of Dublin. PG&E also argues that locating the substation at D1, in southern Dublin, will require PG&E to rely on overly long distribution feeders, in violation of its distribution planning guidelines, to serve emerging load in the northern and eastern parts of Dublin. In addition, PG&E argues that 50% of the capacity at Vineyard Substation and the D1 substation location would essentially be wasted because of their overlapping "spheres of influence" (PG&E Opening Brief, p. 60). From a cost standpoint, PG&E also prefers its proposed Dublin substation as compared to D1. PG&E's cost estimate, using project specific unit costs, identifies D1 as costing 125% more than PG&E's proposed project.

Regarding North Livermore, PG&E opposes undergrounding the transmission line that will connect its proposed North Livermore substation to the Contra Costa-Newark line. PG&E argues that overhead transmission towers will not result in a significant visual impact because the area is undeveloped and undevelopable under the North Livermore Specific Plan and Measure D. (PG&E Opening Brief, p. 67.) PG&E argues that its proposed mitigation measure of undergrounding existing distribution infrastructure will allow it to avoid significant visual impacts even with an overhead connection. PG&E argues that adoption of P3 would result in potentially significant impacts on the palmate-bracted bird's beak, an endangered plant found in an area approximately 1 mile south of the P3 alternative. PG&E also opposes the P3 alternative as more costly than PG&E's proposed project in North Livermore.

7.2 ISO

The ISO does not express a position on what routes should be adopted. The ISO testified that all of the alternatives studied, with the exception of the No Project Alternative, meet the electrical needs and reliability criteria of the system. (ISO Opening Brief, p. 11.) The ISO does express concern, however, that if a route with a significantly larger amount of undergrounding than PG&E's proposed project were selected, that the project might not be completed in time to be online to serve load in Summer 2002.

7.3 Pleasanton Parties

The Pleasanton Parties begin from a premise that transmission lines should be sited in a manner that avoids impacts on residential neighborhoods, utilizes existing utility corridors or industrial areas, and avoids open space. Using these factors, the Pleasanton Parties advocate construction of the "Improved Isabel-Stanley" route in the Pleasanton area. If the Commission does not select this route, the Pleasanton Parties recommend selection of the S2A/S2/S5 alternative with certain mitigation measures, including measures designed to reduce visual impacts of the new line and existing infrastructure.

The Pleasanton Parties strongly oppose PG&E's proposed project in the Pleasanton area, as well as S2 and S2A/S2. The Pleasanton Parties argue that there will be significant adverse construction impacts from PG&E's proposed project because it would traverse narrow residential streets. PG&E will be required to avoid existing utility infrastructure (water, gas, electric) during construction, which the Pleasanton Parties assert will require extensive hand excavation, shoring, and more time than PG&E estimates. The Pleasanton Parties argue that the geological features of the proposed route make it prone to landslides, which will be exacerbated by the construction activities required by PG&E's proposed project.

The Pleasanton Parties also take issue with the fact that PG&E did not look at routing alternatives that would limit exposure to electromagnetic fields (EMF). Instead, PG&E developed an EMF mitigation plan after it selected its proposed project rather than factoring in exposure levels prior to selection of a route. The Pleasanton Parties also express concern that PG&E has never installed an underground 230 kV solid dielectric cable, and that only 9.5 circuit miles of 230 kV solid dielectric cable are in operation in the United States. The Pleasanton Parties are concerned about PG&E's lack of experience in installing this type of technology, possibility of failures, and the impacts of failure in a residential setting. The Pleasanton Parties also take issue with PG&E's cost estimates and scheduling arguments.

The Pleasanton Parties support the Improved Isabel-Stanley route because the route would utilize existing disturbed corridors, it limits impacts on existing residential neighborhoods, and minimizes impacts on open space. It is for these same reasons that these parties support one of the environmentally superior alternatives, the S2A/S2/S5 alternative. The Pleasanton Parties oppose the other environmentally superior alternative, S2A/S2, because it places underground transmission lines closer to residential neighborhoods (along Vineyard Avenue as it approaches Bernal Avenue). The Pleasanton Parties argue that the Improved Isabel-Stanley route is feasible and that an underground easement could be acquired from the California Department of Transportation (CalTrans) or private property owners that would enable PG&E to locate an underground line along Isabel Avenue.

7.4 Foley Intervenors

The Foley Intervenors focused on alternatives serving the Pleasanton area. They support either S2A/S2 or S1 and oppose PG&E's proposed project and S4. The Foley Intervenors argues that S2A/S2 and S1 are superior to PG&E's proposed project in terms of biological impacts. The Foley Intervenors point to discussion in both the DEIR and FEIR (Exhibits 1000 and 1003 respectively) to compare the S2A/S2 and S1 routes to PG&E's proposed route and S4. The Foley Intevenors argue that S2A/S2, because it travels along a disturbed roadway corridor, does not provide suitable habitat for California red-legged frog or California tiger salamander.¹⁷ The Foley Intevenors argue that PG&E purposefully did not conduct field studies of the S2A/S2 route because such studies would have demonstrated the lack of biological impacts.

In addition, the Foley Intervenors argue that PG&E's cost estimates for its proposed route are underestimated because of improper land acquisition costs. The Foley Intevenors assert that PG&E's argument regarding its preferred route turns on the cost estimates, since PG&E selected the cheapest route, and thus the underestimated costs should not be relied on by the Commission as a factor in selection of a route. The Foley Intervenors also argue that PG&E's cost estimates for alternate routes are overstated because it used project-specific unit costs from the proposed project rather than looking at the specific geographic features of the various alternate routes to asses cost information. For example, the Foley Intervenors argue on brief that the cost per mile to construct the S2A/S2 underground alternative will be less costly to construct than PG&E's proposed route "because the underground trenches will generally run along flat, easy-to-excavate routes that are not subject to the work restrictions that apply to residential neighborhoods." (Foley Opening Brief, p. 17.) In comparison, PG&E's proposed route will be constructed on a steep slope and then within narrow residential streets and will have to be constructed in a way that avoids existing utility infrastructure.

7.5 Lin Family

The Lin Family owns property throughout the Tri Valley area. The Lin Family supports PG&E's proposed project in Dublin and in North Livermore supports either PG&E's proposed project or the P1, P2, or P3 alternatives.¹⁸ The Lin Family opposes PG&E's proposed route in the Pleasanton area because of the impact on Kottinger Ranch residents during construction. The Lin Family generally recommends that the S4 alternative, with some modifications, be adopted in lieu of PG&E's proposed Project.

The Lin Family strongly opposes the environmentally superior D1 substation location. The Lin Family is the developer of Dublin Ranch, the location of the proposed D1 substation location. The Lin Family argues that locating a substation in Dublin Ranch contradicts the Visual Resources section of the Eastern Dublin Specific Plan, a policy regarding preservation of "natural open beauty of the eastern Dublin hills" (Lin Opening Brief, p. 6), the Campus-Office designation of the area, and community values. The Lin Family argues that D1 is also electrically inferior. The Lin Family summarizes their opposition to D1 by saying "the environmental benefits of Alternative D1 are insufficient to override its added cost and electric power supply inadequacies." (Lin Opening Brief, p. 10.)

7.6 City of Dublin

The City of Dublin strongly opposes the environmentally superior D1 substation alternative and associated transmission line as inconsistent with the values of Dublin, infeasible, unreliable, and unnecessarily expensive while failing to decrease the environmental impacts of PG&E's proposed project. The City of Dublin supports PG&E's proposed Dublin substation and associated transmission line as feasible, cost-effective, and consistent with community values.

The City of Dublin argues that locating a substation at the D1 location would be inconsistent with the values of the community. The City of Dublin argues that the D1 location has been zoned as Campus-Office as a result of 15 years of local planning and a substation would disrupt the vision for the area. The City of Dublin argues that because planning has occurred for the Dublin Ranch area where D1 is located, and essentially no planning has occurred for PG&E's proposed location, use of PG&E's proposed location is preferable. The City of Dublin notes that an electrical substation is not among the permitted uses in a Campus-Office area in its Development Plan, although it concedes that the zoning for Campus-Office would conditionally permit public and semi-public uses that are complementary to office buildings, residences, and warehouses. The City of Dublin also has concerns over the aesthetic impacts of the D1 substation location.

The City of Dublin argues that constructing D1 would remove from development five acres that are ideal for office or residential occupants and because of the location, that kind of development cannot be replaced. The City of Dublin also indicates that removal of five acres from development potential would impact collection of development fees and thus Dublin's ability to pay for services and facilities to serve the area.

In addition, the City of Dublin raises issues surrounding feasibility of construction of D1 before summer 2002 due to time to pursue condemnation, need to acquire a Caltrans permit for transverse encroachment, potential conflicts with future I-580 widening, and time to construct. The City of Dublin also argues that the D1 location is electrically inferior to PG&E's proposed site because it would not allow the Dublin substation to serve new demand in San Ramon or southern Contra Costa County.

The City of Dublin also opposes the FEIR's conclusion that no project should be built in North Livermore and argues that locating a Dublin substation at D1 should not be a deciding factor for selecting no project for North Livermore.

7.7 The City of Livermore

On brief, the City of Livermore supports the FEIR's conclusions with respect to the North Livermore area. Specifically, on brief, the City of Livermore supports deferral of building a North Livermore substation or selection of the environmentally superior "build" alternative if the Commission concludes this portion is needed. Livermore supports the P3 alternative, if need is demonstrated, because it is the shortest route and it preserves the scenic character of the area by eliminating overhead transmission lines while also meeting the electrical needs of system. In its reply brief, the City of Livermore has modified its position to oppose deferral of the substation. The City of Livermore now states that it has reassessed the record and supports building of the North Livermore substation.

The City of Livermore testified that there is a conflict with the overhead portion of the D1 alternative and local and federal laws and policies regarding height restrictions near airports. For this reason, the City of Livermore supports PG&E's proposed Dublin substation and opposes selection of D1. In its reply brief, the City of Livermore also cites to PG&E's Opening Brief to argue that D1 is electrically inferior to PG&E's proposed Dublin substation.

The City of Livermore supports adoption of either PG&E's proposed project, the S4 alternative, or the S5 alternative to serve the Pleasanton area.¹⁹ The City of Livermore identifies several adverse impacts it associates with both S1 and S2 as reasons to oppose these alternatives. These impacts include introduction of overhead lines and structures on Isabel Avenue and the surrounding area, adverse visual impacts, and inconsistency with local land use policies. The City of Livermore also opposes the Improved Isabel-Stanley Route supported by the Pleasanton Parties as infeasible due to permitting problems. In addition, the City of Livermore has concerns about S1 based on potential conflicts with the Livermore Municipal Airport.

7.8 City of San Ramon

The City of San Ramon opposes selection of D2 to serve Dublin. The City of San Ramon testified that it "already bears its share of overhead electric transmission impacts" (Exhibit 500, p.3) due to the large substation located in San Ramon. It argues that new development should bear its own impacts and not affect existing citizens and residents. The City of San Ramon also is concerned that selection of the D2 alternative will have negative effects upon conservation easements being processed in the Dougherty Valley.

7.9 Centex

Centex opposes the S1 and L2 alternatives identified in the FEIR because they would require construction of overhead lines along Isabel Avenue, would be more costly then other alternatives studied, and are incompatible with community and aesthetic values. Centex also opposes the Improved Isabel-Stanley alternative offered by the Pleasanton Parties because the FEIR rejected this route as infeasible.

7.10 LARPD

LARPD opposes selection of any alternative that would require construction of any towers, transition or switching stations within the boundaries of Sycamore Grove Park or Brushy Peak Regional Preserve. Thus LARPD supports most of the routes identified in the FEIR, including PG&E's proposed project for the Pleasanton area except S4 as long as they incorporate S2A as described in the FEIR. LARPD has concerns with the portion of S1 that runs along Isabel Avenue because the recreational trail along Isabel Avenue will eventually be deeded to LARPD. LARPD does point out that while an alternative utilizing S5 may be attractive from a cost standpoint in the short term, over the long term an all underground alternative seems preferable. LARPD points out that there is a plan to develop a "Chain of Lakes" as the quarries cease operations and the character of the area will shift from industrial to recreational over time. LARPD believes that the Commission must consider this tradeoff when selecting a route for Pleasanton. In the North Livermore area, LARPD focuses on PG&E's proposed project for Phase 2 and its impact on Brushy Peak Regional Preserve. LARPD opposes certification of Phase 2 at this time.

7.11 EBRPD

The EBRPD objects to any routing that includes the S5 alternative. EBRPD argues that S5 will have a significant visual impact on Shadow Cliffs Regional Recreation Area users and therefore should not be selected based on its impacts on parks and recreation.

¹⁷ PG&E's proposed route and S4 travel along undisturbed corridors with observed populations of California red-legged frogs and California tiger salamander. ¹⁸ The Lin Family expresses concern that P3 as modified in the FEIR could impact wetland mitigation efforts on their North Livermore property but do not state whether it would cause such an impact or not. ¹⁹ It is unclear from its brief whether Livermore supports S5 in combination with S2A/S2 or S4.