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HomeMy WebLinkAboutRenton CUP Response Letter - Final Puget Sound Energy P.O. Box 97034 Bellevue, WA 98009-9734 PSE.com September 18, 2018 Jill Ding, Senior Planner City of Renton 1055 South Grady Way Renton, WA 98057 RE: Energize Eastside – CUP Responses to Public Comments Dear Ms. Ding: The City of Renton (City) has requested that PSE provide responses to comments received by the City during the Conditional Use Permit (CUP) comment period for the Energize Eastside project. PSE is responding to the comments by topic as the majority of commenters used a form letter or have made similar comments. The common themes raised in public comment (and addressed below) are as follows: project need, pipeline safety, vegetation removal, and project alternatives. The attached comment response narrative, which is summarized below, addresses these topics. Additional information that addresses the more specific comments is also contained in this letter. Project Need Renton received public comments arguing alternatively that the Energize Eastside project is not needed and has limited impact on improving reliability. The need for the Energize Eastside project has been questioned by a few members of the public for more than five years. Every independent review, including in litigation, has confirmed that PSE’s project need assessment conforms to industry planning standards and that the project is needed. To assist in a smooth administration of the City’s process, PSE provides additional information on project need as background, but notes that Renton’s CUP Permit decision criteria do not require a demonstration of project need or an improvement in reliability. See RMC 4-9-030.D. As such, we understand that this question is outside the scope of the City’s CUP decision-making. That said, the Energize Eastside project is both needed and improves reliability by bringing the system into conformance with required federal planning standards. PSE’s system planning analysis has been peer-reviewed, both prior to and during the SEPA Environmental Impact Statement (EIS) process. The Phase 1 DEIS specifically states: The EIS Consultant Team, represented by Stantec (an electrical system planning and engineering subconsultant working in support of the Energize Eastside EIS effort), has reviewed this background information and studied the process used by PSE to establish a need for the Ms. Jill Ding September 17, 2018 Page 2 proposed Energize Eastside Project. Stantec prepared a memorandum evaluating the stated need for the project, and confirmed that PSE’s Eastside Needs Assessment was conducted in accordance with industry standards for utility planning (Stantec, 2015). In 2015, the Federal Energy Regulatory Commission (FERC) also reviewed a challenge to PSE’s project need and held that despite allegations of flaws in PSE’s load flow studies, the complainants failed to “demonstrate that the studies violate any applicable transmission planning requirements, or were otherwise, unjust, unreasonable, or unduly discriminator or preferential.” FERC, Docket No. EL15-74- 000, Order Dismissing Complaint (October 21, 2015). PSE understands the public’s interest in this project. Respectfully, however, the comments made by the public on project need have not been independently validated using applicable, required engineering/planning standards or otherwise subject to any form of peer review. In contrast, PSE’s project has been heavily evaluated (both internally and externally) and subjected to multiple rounds of peer review. It is PSE’s sole responsibility to plan, make improvements to, and operate the electrical system. The Energize Eastside project is needed. Pipeline Collocation When evaluating route alternatives in the replacement of the existing 115 kV transmission lines with 230 kV lines, one of the key factors that PSE studied was potential interaction between the collocated transmission lines and petroleum pipelines, which are operated by Olympic Pipeline Company (Olympic). Safety is PSE’s top priority, and when Energize Eastside is built, the new transmission lines will safely co- exist with Olympic Pipeline as the current transmission lines do today. Customer safety is always the first priority at PSE. We have a long history of working closely with Olympic to ensure the continued safe operations of the collocated utilities, which have shared this corridor for decades. Within Renton, PSE’s and Olympic’s facilities are collocated for a distance of less than 0.4 miles. Extensive engineering analysis has been performed to evaluate risk and ensure the safe construction and operation of the collocated utilities. See DNV-GL, Corrosion Report (Dec. 2016). The proposed collocation will be similar to the existing collocation of Seattle City Light’s dual 230 kV transmission lines and Olympic pipelines. The SCL/OPL joint corridor is about 3.4 miles long through Renton and located east of the PSE transmission line corridor. During the EIS process, these same questions were raised during scoping, and the EIS addresses these questions in detail. Appendix J of the FEIS addresses many of these comments (see page J1-28 and J1- 51). In addition, sections 4.9, 5.9, 6.12, 7.9, 8.9, and Appendix I of the FEIS address pipeline safety. PSE refers the City to the EIS as it sets forth the partner cities’ independent review of this technical data. Vegetation Removal By using the existing corridor, Energize Eastside affects the fewest number of trees and avoids the construction of new utility corridors. The existing corridor was first developed during the late 1920s and Ms. Jill Ding September 17, 2018 Page 3 early 1930s. Neighborhoods have since built up around it and, for decades, PSE has topped and/or trimmed the trees underneath the existing high voltage 115 kV transmission lines to prevent the trees from causing safety and/or reliability issues. Although vegetation will be removed within the corridor as part of the project, the trees will be replaced with transmission line compatible species. Outside of the corridor, opportunities exist to replace removed trees with taller growing species. In addition, potential impacts to vegetation have principally been addressed in sections 4.2, 4.4, 4.5, 5.4, 5.5, 7.4, 7.10, 8.4, 8.5, and 8.10 of the FEIS. PSE continues to work with the City to ensure that vegetation impacts are fully mitigated. Project Bifurcation Comments were submitted criticizing the “bifurcation” of the project into a north and a south segment. PSE appreciates the public’s interest in the permitting process. As a linear facility traversing more than 16 miles and four cities, permitting and construction planning are necessarily complicated processes. PSE’s CUP application covers all project activities proposed by PSE in Renton – there is no proposal to bifurcate or phase the project in Renton. PSE has submitted the necessary information to meet Renton’s CUP application requirements as denoted by the Letter of Complete Application dated March 14th, 2018. PSE’s proposed construction and permitting of the Energize Eastside project is for operational and logistical reasons and is wholly consistent with the law. Comments dated June 21, 2017, from T. Anderson, et al. These comments were submitted verbatim during the Phase 2 DEIS comment period and were responded to in the FEIS. See Appendix K, starting on page K-617. Comments dated April 30, 2018, from T. Anderson, et.al. 1. PSE respectfully disagrees with the commenter’s characterization of Carol Helland’s recorded statements and the project. The State Environmental Policy Act (SEPA) review process for PSE’s Energize Eastside project concluded upon issuance of the Final EIS on March 1, 2018. The City of Bellevue’s role as SEPA lead is substantially complete and the partner cities are still party to an interagency agreement on the administration of the EIS. Comments related to the City of Bellevue should be addressed directly to that city. 2. PSE respectfully disagrees with the commenter’s characterization of the public meeting and EIS contractor. The Energize Eastside EIS Team project manager is an independent contractor employed by the partner cities. PSE did not contract for or guide the EIS process. Environmental Science Associates (ESA) did not work for PSE. ESA worked independently for the partner cities, including the City of Renton. Ms. Jill Ding September 17, 2018 Page 4 3. On April 2, 2018, Renton extended the comment period associated with the Conditional Use Permit. See http://rp.rentonwa.gov/weblink/3,3/edoc/1124574/NOA_Notice_of_ Application_Comment_Extention_180402.pdf. 4. PSE is committed to the safe construction and operation of the Energize Eastside project. PSE respectfully disagrees with the commenter’s characterization of the EIS’s assessment of safety impacts and allegations of fraudulent behavior. PSE has thoroughly studied the potential for interaction between the proposed transmission lines and Olympic Pipeline Company’s petroleum pipelines. Based on third party modeling analysis by nationally recognized experts at DNV GL, as well as independent analysis in the EIS by EDM Services, with the implementation of mitigation (e.g., operating both transmission lines at 230 kV), conductor configuration, and appropriate set back distances, the EIS concluded that no substantial increase in risk compared to the existing conditions was identified. The analysis in the EIS on pipeline safety was performed at the direction of the partner cities, including the peer review by Stantec of DNV GL’s study. PSE did not scope the studies that were performed as part of the EIS process. 5. Comment is incomplete and unfortunately lacks sufficient information to be decipherable. PSE is unable to respond to this comment at this time. 6. See response to Comment 4 above. PSE again respectfully disagrees with commenter’s characterization of the pipeline safety analysis undertaken by the partner cities. Comments from K. and D. Ossenkop on March 9, 2018 and Lorene Conner on June 9, 2018 See the attached project narrative. The potential for environmental impacts related to electro-magnetic fields (EMF) was addressed during the EIS process. The EIS states, “[t]here are no known health effects from power frequency EMF. For all proposed segments and options, the calculated magnetic field levels would be well below reference guidelines. Therefore, under PSE’s Proposed Alignment, impacts would be less-than-significant.” The EIS also states that: “Operation of the proposed transmission lines would result in a decrease of magnetic field levels for PSE’s Proposed Alignment relative to the No Action Alternative” (i.e., current conditions). FEIS at page 4.8-9. Comments from King County Wastewater Treatment Division on March 27, 2018 The Energize Eastside project will not have any construction related impacts along the Maple Valley Highway. At this location, the existing transmission lines will be replaced with new lines that span over the highway. Comments from J. DeMund on March 27, 2018 See the attached project narrative. Ms. Jill Ding September 17, 2018 Page 5 1. – 3. PSE respectfully disagrees with the statement that the project is to address only electrical needs in downtown Bellevue. The electrical grid is interconnected and therefore, all of the Eastside cities, including Renton, will benefit from the improved reliability that will result from the Energize Eastside project. 4. Vegetation in the existing transmission line corridor has been managed for more than 80 years. In general, more than 80 percent of the existing trees in the corridor are in poor to fair condition as they have been extensively trimmed or topped over the years. As stated above, PSE will work with the City to ensure that the vegetation impacts are mitigated. To the extent practicable, PSE will work on repurposing the removed poles; however, over the serviceable life of the Energize Eastside project, which is more than 100 years, the amount of solid waste will decrease as the serviceable life of wood poles is typically around 40 years. Regarding potential “visual degradation” or more specifically visual and scenic view impacts, the FEIS states (at 4.2-44): “Overall, impacts to the aesthetic environment from the Renton Segment would be less- than significant. Although the poles would typically be taller (up to 40 feet taller depending on the pole location and configuration) and larger in diameter than existing poles, the segment would be located entirely within PSE’s existing corridor, resulting in low contrast with existing conditions. Although adopted policies address general aesthetic qualities and public views, overall viewer sensitivity is considered low because development in the area has all occurred around the existing transmission lines, and the project would not be inconsistent with policies related to aesthetics and public views. Impacts to the aesthetic environment would be less-than-significant.” Additionally, the FEIS states: “Impacts to scenic views would be less-than-significant because the degree of additional obstruction would be minimal compared with existing conditions.” Comments from Karen Walter on March 28, 2018 Based on recent conversations with the City of Renton, mitigation plans will need to be modified to accommodate the City’s request to avoid mitigation on City-owned property. We are happy to provide additional information in response to Karen Walter’s comments once we have prepared revised mitigation plans and have gotten feedback from the City. Comments from R. Lauckhart on June 14, 2018 These comments question project need. The need for the project is not a CUP evaluation criteria. Many of these comments were provided during the Phase 2 DEIS comment period and were responded to in the FEIS. See Appendix K, starting on page K-141. Ms. Jill Ding September 17, 2018 Page 6 We hope this fulfills the City’s information request; please let us know if additional clarification is needed. Sincerely, Brad Strauch Senior Land Planner