Final environmental impact report : Southern California Edison's West of Devers Upgrade Project

2016·115.6 MB·English

by  United States. Bureau of Land Management

FINAL
Environmental Impact Statement
Southern California Edison’s
West of Devers Upgrade Project
BLM/CA/PL-2015/012+1793
DOI-BLM-CA-060-0015-0021
VOLUME 4
Comments and Responses
U.S. Department of the Interior
Bureau of Land Management
ieral Center
X>521
July 2016
.5047
O 80225
ITEM HAS BEEN DIGITIZED
West of Devers Upgrade Project
Contents - Volume 4
Contents of Volume 4
Comments and Responses to Comments.l
Purpose of Response to Comments Volume.3
Organization of this Volume.4
General Responses.4
GR-1. Project Need.4
GR-2. Agency-defined Basic Project Objectives.5
GR-3. Renewable Energy Accommodated by the Phased Build Alternative.8
GR-5. Property Values.12
GR-6: Electric and Magnetic Fields (EMF).14
Comments from Public Agencies
Comment Set A1 - San Bernardino County Department of Public Works.17
Responses.19
Comment Set A2 - U.S. Environmental Protection Agency.21
Responses.27
Comment Set A3 - California Department of Transportation, District 8.31
Responses.33
Comment Set A4 - City of Colton.34
Responses.37
Comment Set A5 - City of Redlands.40
Responses.44
Comment Set A6 - CPUC Office of Ratepayer Advocates.;.49
Responses.60
Comment Set A7 - U.S. Fish & Wildlife Service.62
Responses.72
Comments from Community Groups, Organizations, and Companies
Comment Set B1 - Southern California Gas Company.83
Responses.84
Comment Set B2 - Seven Oaks Medical Center.85
Responses.86
Comment Set B3 - Arrowhead Orthopaedics.88
Responses.89
Comment Set B4 - Palen Solar Holdings LLC.90
Responses.98
Comment Set B5 - Natural Resources Defense Council.101
Responses.103
Comment Set B6 - Seven Oaks Medical Center (Tim Delinger).104
Responses.105
Comment Set B7 - Independent Energy Producers Association.106
Responses.108
Comment Set B8 - NextEra Energy Resources LLC.109
Responses.112
Comment Set B9 - California Independent System Operator Corporation.114
Responses.128
July 2016 Final EIS
West of Devers Upgrade Project
Contents - Volume 4
Comments from Tribal Governments
Comment Set Cl - Morongo Band of Mission Indians.135
Responses.137
Comment Set C2 - Colorado River Indian Tribes.139
Responses.145
Comments Received at Public Workshops
Comment Set D1 - Workshop Transcript - Banning 9/1/15.151
Responses to Comments from Mr. Swerdlow.158
Responses to Comments from Mr. Kierspe.158
Comments from Private Individuals
Comment Set El - Joe E. Rose.159
Responses.160
Comment Set E2 - Dennis Rice.161
Responses.162
Comment Set E3 - Regina Tierney.163
Responses.164
Comment Set E4 - Carol Doyle.165
Responses.166
Comment Set E5 - Gary M. Stoh.167
Responses.168
Comment Set E6 -John Christensen.169
Responses.170
Comment Set E7 - Bernard Dale.171
Responses.172
Comment Set E8 - Nick Gercis.173
Responses.174
Comment Set E9 - Steve Mehlman.175
Responses.176
Comment Set E10 - Michael Gilbert.177
Responses.178
Comment Set Ell - Stan Fogg.179
Responses.180
Comment Set E12 - Kathy Kelehan.181
Responses.182
Comment Set E13 - Susan and Helmuth Fritz.183
Responses.184
Comment Set E14 - Gary and Kathleen Frisbie.185
Responses.186
Comment Set E15 - Sandi Joel.187
Responses.188
Comment Set E16 - Lane Joel.189
Responses.190
Comment Set E17 - George Newlin.191
Responses.192
Comment Set E18 - John T. and Carolyn A. Washburn.193
Responses.194
Final EIS II July 2016
West of Devers Upgrade Project
Contents - Volume 4
Comment Set E19 - Carla Bracken.195
Responses.196
Comment Set E20 - Anthony and Frances Germana.197
Responses.198
Comment Set E21 - Ron Roy.199
Responses.201
Comment Set E22 - Linda Hall.203
Responses.204
Comment Set E23 - Rodolfo N. and Yolanda M. Velasco.205
Responses.206
Comment Set E24 - Harry Smallwood.207
Responses.208
Comment Set E25 - Sharon Waitman.209
Responses.210
Comment Set E26 - Corinne Slusser.211
Responses.219
Comment Set E27 - Marcia Tulledge.220
Responses.221
Comment Set E28 - Fran Zimmerman.222
Responses.223
Comment Set E29 - David Doherty.224
Responses.228
Comment Set E30 - Udo Kierspe.230
Responses.233
Comment Set E31 - Kathie Dyson.234
Responses.235
Comment Set E32 - Timothy J. Pavlian.236
Responses.237
Comment Set E33 - W Elaine Morgan.238
Responses.239
Comment Set E34 - Leanne Weisskoff.240
Responses.241
Comment Set E35 - Susan Diamond.242
Responses.243
Comment Set E36- Ann Hasbargen.244
Responses.245
Comments from the Applicant (Southern California Edison)
Comment Set FI - Cover Letter.247
Responses.275
Comment Set F2 - Transmission Planning.289
Responses.306
Comment Set F3 - Detailed Comments.289
Executive Summary.311
Responses.316
Section A Introduction.317
Responses.322
July 2016 iii Final EIS
West of Devers Upgrade Project
Contents - Volume 4
Section B Description of the Proposed Project.324
Responses.359
Section C Alternatives.367
Responses.369
Section D.2 Agriculture.370
Responses. 381
Section D.3 Air Quality.383
Responses.394
Section D.4 Biological Resources-Vegetation.396
Responses.440
Section D.5 Biological Resources - Wildlife.454
Responses.481
Section D.6 Climate Change.487
Responses.489
Section D.7 Cultural Resources.490
Responses.517
Section D.8 Socioeconomics and Environmental Justice.522
Responses.523
Section D.9 Geology and Soils.524
Responses.526
Section D.10 Hazards and Hazardous Materials.527
Responses.538
Section D.ll Land Use and BLM Realty.540
Responses.546
Section D.12 Mineral Resources.547
Responses.549
Section D.13 Noise.550
Responses.559
Section D.14 Paleontological Resources.562
Responses.574
Section D.15 Recreation.577
Responses.582
Section D.16 Transportation and Traffic.584
Responses.594
Section D.17 Utilities and Public Services.596
Responses.599
Section D.18 Visual Resources.600
Responses.!.636
Section D.19 Water Resources and Hydrology.643
Responses.657
Section D.20 Wildland Fire.661
Responses.667
Section D.21 Electrical Interference and Safety.669
Responses.691
Section E Cumulative Scenario and Impacts.697
Responses.705
Section F Other NEPA Considerations.707
Responses.708
Final EIS iv July 2016
West of Devers Upgrade Project
Contents-Volume 4
Section G Comparison of Alternatives.709
Responses.716
Section H Mitigation Monitoring and Reporting.717
Responses.719
Appendix 1 Project Description Information.720
Responses.723
Appendix 5 Alternatives Screening Report.724
Responses.727
Appendix 6 Air Quality.728
Responses.733
Appendix 7 Biological Resources.734
Responses.736
Appendix 9 Policy Screening Report.737
Responses.739
Comment Set F4 - Additional Comments.741
Responses.791
Tables
Table 1. Comments Received on the Draft EIR/EIS.1
Table GR-1. Agency-defined Basic Project Objectives and SCE Project Objectives.6
July 2016 V Final EIS
SCE West of Devers Upgrade Project
Volume 4. Response to Comments
Table 1. Comments Received on the Draft EIR/EIS
Letter No. Date Commenter
E21 9/10/15 Ron Roy
E22 9/10/15 Linda Hall
E23 9/11/15 Rodolfo N. & Yolanda M. Velasco
E24 9/11/15 Harry Smallwood
E25 9/11/15 Sharon Waitman
E26 9/11/15 Corinne Slusser
E27 9/5/15 Marcia Tulledge
E28 9/12/15 Fran Zimmerman
E29 9/18/15 David Doherty #1
E30 9/19/15 Udo Kierspe
E31 9/19/15 Kathie Dyson
E32 9/20/15 Timothy J. Pavlian
E33 9/21/15 W. Elaine Morgan
E34 9/23/15 Leanne Weisskoff
E35 9/17/15 Susan Diamond
E36 9/1/15 Ann C. Hasbargen
Category F - The Applicant
F1-F4 9/22/15 Southern California Edison
Purpose of Response to Comments Volume
The Final EIS includes the West of Devers Upgrade Project Draft EIR/EIS (August 2015) as revised,
comments received on the Draft EIR/EIS, and responses to those comments. The Final EIS has been
prepared pursuant to NEPA (42 U.S.C. § 4321 etseq.). CEQ Regulations (20 CFR Parts 1500-1508), and BLM's
NEPA Flandbook (FI-1780-1). The Notice of Intent (NOI) to prepare an EIS was published in July 2014.
Receiving and responding to comments on the Draft EIS is an essential part of the environmental review
process, with comments and responses becoming part of the Final EIS. The Final EIS will be used by the BLM
in its decision process, which will be documented in a Record of Decision (ROD) issued pursuant to NEPA.
Separately, the CPUC, as the Lead State Agency, published a Final EIR in December 2015, and will be
responsible for ensuring compliance with all requirements of CEQA and any decision by the California
Public Utility Commissioners, including any conditions of approval.
The BLM's Final EIS contains all comments on the Draft EIR/EIS and responses thereto. The focus of the
responses to comments is on the disposition of environmental issues as raised in the comments, as
specified by NEPA (40 CFR 1503.4). Where comments related only to CEQA, the responses from the CPUC
are included in the EIS for information only; these are not considered BLM responses..
July 2016 3 Final EIS
SCE West of Devers Upgrade Project
Volume 4. Response to Comments
Organization of this Volume.
The remainder of this volume is organized as follows:
■ General Responses to Frequently Made Comments
■ A: Comments by Agencies; Responses to Agency Comments
■ B: Comments by Organizations; Responses to Organization Comments
■ C: Comments by Native American Tribes; Responses to Native American Tribe Comments
■ D: Comments Made at Public Workshops; Responses to Workshop Comments
■ E: Comments by Members of the Public; Responses to Comments by Members of the Public
■ FI: Comments by SCE (Cover Letter); Responses to SCE's Cover Letter Comments
■ F2: Comments by SCE (Power Flow Modeling); Responses to SCE's Power Flow Modeling Comments
■ F3: Comments by SCE (EIR/EIS Details); Responses to SCE's Detailed Comments
■ F4: Comments by SCE (Project Description); Responses to SCE's Project Description Comments
General Responses
This section presents detailed responses to comments that were made by many commenters. General
Responses address the following topics:
■ GR-1. Project Need
■ GR-2. Agency-defined Basic Project Objectives
■ GR-3. Renewable Energy Accommodated by the Phased Build Alternative
■ GR-4. Analysis of Potential Future Construction under the Phased Build Alternative
■ GR-5. Property Values
■ GR-6. Electric and Magnetic Fields (EMF)
GR-1. Project Need
Responding to comments from: SCE (Comment Fl-1, Fl-5, Fl-13, and Comment F2-8); CAISO
(Comment B9); Independent Energy Producers Association (Comment B7-1); and others.
Some commenters stated that one alternative, the Phased Build Alternative, may not meet or satisfy the
need for the Proposed Project, and that the capacity of Phased Build Alternative may restrict development
of renewable energy projects located electrically upstream of the WOD corridor in eastern Riverside
County or Imperial County. In contrast, comments submitted by the CPUC Office of Ratepayer Advocates
(ORA) stated that the EIR should consider an additional project alternative with a reduced capacity.
These comments reflect the positions of the various commenters on the need for the West of Devers
Upgrade Project. The EIS presents SCE's Purpose and Need in Section A.2.1.1 and the BLM and CPUC Project
Objectives in Section A.2.2.
This General Response focuses on the question of project need in the context of the environmental review
process. The scope of the Final EIS is limited to satisfying the specific requirements of NEPA.
Final EIS 4
July Z016
SCE West of Devers Upgrade Project
Volume 4. Response to Comments
See General Response GR-2 and other individual responses to comments for discussions showing how the
Phased Build Alternative would be a potentially feasible means of satisfying most or all of the objectives.
Projects Contributing to the Need for the Proposed Project and Connected Actions
Various renewable energy projects and other electric transmission projects are planned to be developed
in the area that would be served by transmission within the WOD corridor (primarily east of the Devers
Substation). The level of renewable energy development that may be facilitated by the Proposed Project
is addressed in the EIS for the limited purpose of disclosing environmental impacts that may occur at
locations outside of the project corridor. A wide range of generation and transmission projects that con¬
tribute to the need for the Proposed Project appear in the EIS (Section A.2.1.4), and some projects will
drive the need for the Proposed Project more than others (Table A-4, Projects Contributing to Need for
WOD Upgrade Project). However, it is not appropriate for the EIS to attempt to define the overall level of
need or to speculate on the level of development that must be accommodated.
The EIS, in Section B.7.1, Definition of Connected Action Projects, recognizes that some generation proj¬
ects are so closely related to the Proposed Project as to be considered "connected actions" under NEPA.
Accordingly, the environmental analysis discloses a range of potential impacts for the Connected Action
projects because their construction and operation is directly reliant on the transmission capacity of the
Proposed Project. The total generation capacity of the Connected Action projects is shown to be
1,474 MW (EIS Section A.3, Table A-6 and Table B-22).
GR-2. Agency-defined Basic Project Objectives
Responding to comments from: SCE (Comment Fl-1, Fl-5, Fl-7, Fl-8, and Comment F2-8);
CAISO (Comment B9-1, B9-3, B9-8); Palen Solar Holdings (Comment B4-1); and others.
Commenters stated that the Phased Build Alternative would not meet project objectives, and therefore it
would not be a feasible alternative. Comments from owners of power generation projects, specifically
Palen Solar Holdings (Comment Set B4), also assert that the agency-defined objectives should reflect SCE's
proposal. This General Response focuses on the project objectives that are agency-defined for the
environmental review process, and how the Phased Build Alternative is potentially feasible means of
satisfying the objectives, with a focus on Basic Project Objective 1. Other individual responses to comments
provide information on how the Phased Build Alternative would reduce or avoid environmental impacts.
This General Response reviews the requirement that an EIS evaluate a reasonable range of alternatives.
It also explains how the BLM and CPUC established three "Basic Project Objectives" as a means of
determining whether each alternative could accomplish most or all of basic the objectives.
Background on NEPA Requirements
The Council on Environmental Quality's (CEQ's) NEPA Regulations (40 CFR 1502.14) requires analysis of
alternatives. The Phased Build Alternative was developed and analyzed in the Draft EIR/EIS because it is
potentially feasible, it substantially satisfies all three basic project objectives, and it would reduce or avoid
certain environmental effects of the Proposed Project.
The CPUC and BLM developed the Basic Project Objectives for the purposes of environmental review, and
more specifically, to ensure that the scope of alternatives was not unduly limited. The transmission
alternatives originally identified by SCE in the October 2013 Proponent's Environmental Assessment (PEA)
were limited to two minor route adjustments, one of which could have resulted in closure of the Banning
Airport, and two major transmission system modifications that would have substantially more severe
July 2016 5 Final EIS
SCE West of Devers Upgrade Project
Volume 4. Response to Comments
environmental impacts than the Proposed Project (EIS Section C.5.6, Devers-Beaumont 500 kV
Alternative, and Section C.5.7, Red Bluff-Valley-Serrano 500 kV Alternative). The Phased Build Alternative
helps to constitute a reasonable range of potentially feasible alternatives designed to reduce the project's
environmental impacts.
Rationale for the CPUC and BLM Basic Project Objectives
SCE's PEA defined six project objectives, presented in EIS Section A.2.1. The reasons these objectives were
modified are explained in Table GR-1, and in more detail following the table.
Table GR-1. Agency-defined Basic Project Objectives and SCE Project Objectives
SCE Objectives EIS Basic Project Objectives
1. Allow SCE to meet its obligation to integrate and fully deliver • Retained but modified as EIS Basic Project
the output of new generation projects located in the Blythe and Objective 1 to specify a minimum level of
Desert Center areas that have requested to interconnect to the deliverability driven by specific projects
electrical transmission grid. defined by CAISOin 2010.
2. Consistent with prudent transmission planning, maximize the • Retained as EIS Basic Project Objective 3
use of existing transmission line rights-of-way to the extent
practicable.
3. Meet project need while minimizing environmental impacts. • Eliminated because this is the purpose of
both CEQA and NEPA; unnecessary to
repeat this legal requirement
4. Facilitate progress toward achieving California’s RPS goals in • Retained as EIS Basic Project Objective 2
a timely and cost-effective manner by SCE and other
California utilities.
5. Comply with applicable Reliability Standards and Regional • Eliminated because the Lead Agencies
Business Practice developed by NERC, WECC, and the could not permit a transmission project
CAIS0; and design and construct the project in conformance unless it did comply with the applicable
with SCE’s approved engineering, design, and construction safety requirements
standards for substation, transmission, subtransmission, and
distribution system projects.
6. Construct facilities in a timely and cost-effective manner by • Eliminated because these best construction
minimizing service interruptions to the extent practicable. management practices principles apply to
all transmission projects approved by the
Lead Agencies
As shown in Table GR-1, the EIS establishes three "Basic Project Objectives" (taken from the six objectives
defined by SCE) in order to define a range of reasonable alternatives (Draft EIR/EIS, Section A.2.3). The
NEPA directs the BLM to "study, develop, and describe appropriate alternatives to recommended courses
of action in any proposal that involves unresolved conflicts concerning alternative uses of available
resources..." (NEPA Sec 102(2)(E)). When working with cooperating agencies, the range of alternatives
may need to reflect the decision space and authority of other agencies, if decisions are being made by
more than one agency. In determining the alternatives to be considered, the emphasis is on what is
"reasonable" rather than on whether the proponent or applicant likes or is itself capable of implementing
an alternative. "Reasonable alternatives include those that are practical or feasible from the technical and
economic standpoint and using common sense, rather than simply desirable from the standpoint of the
applicant." (Question 2a, CEQ, Forty Most Asked Questions Concerning CEQ's NEPA Regulations, March 23,
Final EIS 6 July 2016