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HomeMy WebLinkAboutC_Public_Comment_19_180317.email_attch3of31. The CAG and EIS process have not adequately established the need for this project. The public has voiced concern about this since the beginning of this process and they have spent their own money and time to retain independent industry experts to conduct independent studies that have brought a more realistic assessment of need and viability of the alternatives because the city agencies leading this process have not done so. The current process is so flawed and biased in favor of the VERY costly and VERY d angerous Transmission Line Alternative PSE wants that it should be thrown out and restarted with a new and independently verified assessment of need that is aligned with state and regional authori ties using a new publically transparent Load Flow Study. 2. The demand forecast should be updated and verified by independent industry experts. The current PSE demand forecast is out of date and is inconsistent, varying depending on what agency PSE is submitting information to. PSE used forecast growth of 2.4% per year to justify the project. PSE sent WECC a forecast of only 0.5% per year. Can this discrepancy be explained? If you use PSE’s own forecast to WECC, it clearly indicates the project is not needed. Further, the final version of the Seventh Power Plan from the Northwest Power and Conservation Council will be released in late February. They are concluding Energy Eastside is not needed. Bellevue as the host of the EIS has the authority to require a pause in the EIS and to get an independent assessment done. 3. The Transmission Line Alternative needs to: a. Be scaled to meet more realistic demand forecast for the local area only. Not for the region or future customers of PSE. b. Demonstrate full compliance with contemporary safety requirements for collocating transmission lines and gas pipelines. c. Fully document how construction will be done safely and not damage the pipeline using independently verified analysis and industry standard data d. Demonstrate specifically how operation will not speed up corrosion of the pipeline. e. Demonstrate specifically how it will be safe from earthquake damage f. Demonstrate how the pipeline and transmission line will behave in various earthquake scenarios g. Demonstrate how the transmission lines will be safe from lightning strikes h. How the transmission lines will not transmit lighting to the pipeline i. Specific locations j. Specific keep out areas and right of ways k. Specific tree removal l. Specific eminent domain acquisition of homes and property m. Specific environmental impacts n. Carbon emission and mitigation plans from removal of trees o. Carbon emission and mitigation plans from construction p. View impact – Not just from the view neighborhoods – but from a regional perspective q. Full lifetime cost to rate payers over the life of the project and how much profit PSE will make over the lifetime 4. We need CENSE Alternative 2B to be officially added to the scope of this project as promised. This alternative should be independently assessed by renewable/alternative energy industry experts and not by PSE. 2B should be fully analyzed and vetted to determine if it can meet the updated demand forecast. A serious and full designed 2B should compete with the transmission line alternative and be fully considered as a serious solution. Not simple dismissed. 5. CENSE Alternative 2B should be officially added to the scope of this project as promised and should be analyzed on par with transmission line alternatives including a. Be scaled to meet more realistic demand forecast for the local area only. Not for the region or future customers of PSE. b. Demonstrate full compliance with contemporary safety requirements for collocating around gas pipelines if applicable c. Fully document how construction will be done safely and not damage the pipeline using independently verified analysis and industry standard data if applicable d. Demonstrate specifically how operation will not speed up corrosion of the pipeline if applicable e. Demonstrate specifically how it will be safe from earthquake damage if applicable f. Demonstrate how the solution will behave in various earthquake scenarios if applicable g. Demonstrate how the solution lines will be safe from lightning strikes if applicable h. How the solution lines will not transmit lighting to the pipeline if applicable i. Specific locations j. Specific keep out areas and right of ways k. Specific tree removal l. Specific eminent domain acquisition of homes and property m. Specific environmental impacts n. Carbon emission and mitigation plans from removal of trees o. Carbon emission and mitigation plans from construction p. View impact – Not just from the view neighborhoods – but from a regional perspective q. Full lifetime cost to rate payers over the life of the project and how much profit PSE will make over the lifetime 6. Last, the Scope needs to include a recommendation that all the cities, including Bellevue should update their land use zoning and safety laws to reflect contemporary safety requir ements for collocating transmission lines and gas pipelines prior to any permitting of a project with this level of risk to the public's safety. The Scope needs to include a recommendation for laws and oversight processes that should be put on place to insure PSE and BP Olympic Pipeline comply with this laws and requirements. Otherwise, PSE, Bellevue City Council and the other City Councils would seem to be grossly negligent in their duty to project the public's safety. 7. The No Action Alternative needs to be a seriously scoped and vetted alternative and not just dismissed. It needs to include options for dealing with any peak demands PSE is concerned about. I believe the official statement is winter peak demand, but lately PSE has been changing its story to include summer peak demand too. The assumption that we need to ship 1500MW to Canada during a temporary power shortage seems downright dishonest. If we actually experienced this scenario, we would decrease the flow to Canada temporarily and avoid the problem. This therefore eliminates the need for the project. The EIS process should clearly establish the facts about what we need to ship to Canada and the commitments around that and include this analysis in the No Action Alternative 8. The EIS should include for Alternatives – No Action and CENSE Alternative 2B - making Bellevue and the other eastside communities national leaders in energy conservation and management. This should examine the impact of upgrading our city codes, ordinances, building standards and zoning rules for both commercial and residential to include implementing LEED standards for ALL new construction. Requiring buildings to retrofit. Requiring retrofits and remodels to comply with LEED or other energy conversation and management standards. Requiring all new construction to be net zero construction. Requiring public buildings to produce and sell energy. Adding energy storage solutions to store this energy for peak demand situations. 9. The EIS should include for Alternatives – No Action and CENSE Alternative 2B - an analysis of the current power lines in this right of way and the risk/benefit of shutting them down to reduce the safety issues with pipeline collocation, especially since the City of Bellevue just signed a 10-year agreement with Olympic Pipeline. The EIS should include an independent study to dismantle the current power poles that run in the right of way and remove them from the grid altogether. I suspect that an independent study would reveal that given the collective capacity already running through the eastside, from all providers, provides more than enough power to meet future demand. The antiquated poles should be removed and no transmission lines should ever be put through that corridor. The EIS should recommend that the City of Bellevue and the other cities, pass a moratorium on construction of anything in the pipeline right of way. 10. I object to the process being used for the EIS. We have not gotten any response from the EIS phase 1. We are not moving into phase 2. IT looks like decisions have been made when the public was told this is not the process. The process is unclear and I think illegal. 11. It is not clear what Alternatives are in scope. I received in writing from the City of Bellevue (submitted to this process already) that CENCSE Alternative 2B is in scope for Phase 2, but that is not documented in the Scope document. Also Alternative No Action is not clearly defined and scoped for assessment. It appears the EIS is glossing over the serious consideration of all viable Alternatives.