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Energize Eastside Project
Final Environmental Impact Statement
VOLUME 2: APPENDICES
MARCH 2018
PREPARED FOR:
The Cities of Bellevue, Newcastle,
Redmond and Renton
PREPARED BY:
ESA
FINAL EIS
TABLE OF CONTENTS MARCH 2018
VOLUME 2: APPENDICES
APPENDIX A: Construction and Access
APPENDIX B: Supplemental Information: Land Use
APPENDIX C: Scenic Views and Aesthetic Environment Methodology
APPENDIX D: Critical Areas Regulations by City
APPENDIX E: Supplemental Information: Vegetation
APPENDIX F: Recreation Policies
APPENDIX G: Supplemental Information: Historic Resources
APPENDIX H: Supplemental Information: EMF
APPENDIX I: Supplemental Information: Pipeline Safety
APPENDIX J: Comments and Responses on the Phase 1 Draft EIS*
APPENDIX K: Comments and Responses on the Phase 2 Draft EIS*
APPENDIX L: Comparison of Data Sources
APPENDIX M: Mitigation Measures
* For printed copies of the Final EIS, Appendix J‐2 and Appendix K are bound separately as Volume 3 and
Volume 4, respectively
Appendix A:
General Construction and Access
A
FINAL EIS PAGE A‐1
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
APPENDIX A-1. GENERAL CONSTRUCTION AND
ACCESS DESCRIPTION
Note: Information provided by PSE
Construction of transmission lines require pre-construction field surveying, site preparation,
construction (i.e., installation of new structures, removal of existing structures), demobilization, and
property restoration, which are performed following a relatively standardized sequence.
PSE aims to avoid or minimize impacts where practicable through project design considerations (e.g.,
pole types and access routes). Along some route segments, PSE has easement rights that outline access
agreements for the purpose of maintaining PSE’s existing facilities and/or accessing PSE’s right-of-way
(ROW). Depending on the segments chosen for the project, PSE plans to exercise these rights and, if
necessary, acquire additional rights for construction of the project. To the extent possible, PSE uses
existing or acquires new easement rights to provide access necessary to maintain and/or construct
facilities.
TYPICAL CONSTRUCTION SEQUENCING
Construction of a transmission line typically occurs in the following sequence:
1) Pre-construction surveying
a. Conducting environmental surveys and obtaining geotechnical data by
conducting soil borings
b. Identifying pole locations
c. Surveying, including ROW and boundary and structure locations (i.e.,
footings, underground utilities)
2) Site preparation
a. Staking the ROW, critical areas, and pole locations
b. Installing temporary erosion control measures
c. If necessary, constructing access routes to the pole sites and developing
installation sites
d. Brushing, trimming, and clearing of vegetation in the ROW to ensure the
safe operation of the line
3) Construction
a. Installing pole foundations or auger holes for direct embedment
b. Assembling and erecting the poles
c. Stringing the conductor and wires
d. Removing existing structures, if necessary
FINAL EIS PAGE A‐2
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
4) Demobilization and clean up
5) Restoration and re-planting vegetation
The general process for the various types of poles being proposed are essentially the same, except for
poles with engineered foundations (e.g., drilled piers), which require additional steps.
The subsequent sections describe specific construction activities in further detail.
PRE-CONSTRUCTION - IDENTIFYING POLE LOCATIONS
The placement, or “spotting,” of poles depends on factors such as available ROW width, location of
access routes, topography, and obstacle avoidance. In turn, the height, loading, foundation type, and
overall size of each structure will be greatly affected by the location of the structures.
The process for the spotting of poles is as follows:
During the engineering process, PSE will work with individual landowners to adjust pole
locations where practicable to reduce impacts for the landowners.
Proposed pole locations discussed with landowners will represent where poles are generally
expected to be located, pending geographical and site-specific environmental review
following city or county approval of a route. Unforeseen subsurface obstacles, such as
geologic erratics, can cause a pole to be moved up or down the corridor (typically less than
20 feet).
In general, PSE considers the following factors when locating poles:
Technical considerations, including electrical clearances, severe terrain accommodations,
structural loading, manufacturability of structures, constructability of the line, and code
requirements.
Critical areas (e.g., wetlands and streams) so as to locate poles outside of critical areas
and their buffers to the extent possible.
Electrical effects to maintain additional buffers or install mitigation measures when co-
located with other facilities (e.g., pipelines).
Landowner considerations by moving poles farther away from residences and/or
locating poles on property lines and edges of tree lines.
Cost to provide a cost-effective and feasible design within set parameters.
To reduce the environmental impacts of pole locations, where practicable, PSE will:
Place new poles in approximately the same location of the existing poles.
Locate poles near existing accessible routes to minimize construction traffic impacts.
Avoid placing poles in areas that require significant access disturbance.
Avoid environmental features by making small adjustments in the route and through
careful structure placement.
Avoid critical areas unless another constraint forces a pole into such areas.
FINAL EIS PAGE A‐3
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
SITE PREPARATION
Vegetation Management and Maintenance
Using the existing transmission line ROW is one of PSE’s preferred routing criteria, as the vegetation in
such corridors is already maintained to some degree. This includes selective removal of problem trees
from beneath power lines or removal of hazardous trees that may fall into the electrical system as part of
regular maintenance on all power line ROW. Proper pruning and discriminating use of growth
regulators and herbicides are also among the methods employed. The method selected depends on
factors such as location, property use, and access. Growth regulators and herbicides are not commonly
used in urban environments.
Emphasis is placed on the removal of large, problem-tree species, especially those that have disease or
insect infestation that can result in irreversible decline. Tree removal is especially important where
pruning alone cannot achieve safe clearance from power lines.
Trimming, natural pruning techniques, or directional trimming will be used if proper line clearances can
be achieved. Directional trimming concentrates on removing limbs and branches where the tree would
normally shed them and direct future growth out and away from the electrical wires. While a newly
pruned tree might look different to some, natural pruning is designed to protect the health of the tree. It
minimizes re-growth and reduces trimming costs.
Directional trimming is the recommended method of the International Society of Arboriculture (ISA),
American National Standards Institute (ANSI), and the National Arbor Day Foundation.
Both tree removal and natural pruning would be performed by specially trained contract crews. Upon
completing of tree work, the crews would clean up the site and any wood that is cut would be left on site
in pieces of manageable size at the property owner’s request or taken off site.
Guidelines for 230 KV Lines
Vegetation within a utility corridor that has transmission line(s) with an operational voltage of more
than 200 kV must be managed in compliance with federal requirements. The fines/penalties associated
with having a power outage caused by vegetation can be substantial. To ensure compliance with the
North American Electric Reliability Corporation (NERC) standard, PSE allows vegetation with a
mature height of no greater than 15 feet within the wire zone. For evaluation purposes, the same
vegetation requirement was applied to the managed ROW zone. The area outside of the managed ROW,
but still within the legal ROW, is subject to select clearing of trees that pose a risk of damaging the line.
The wire zone is the area measured 10 feet away from the outermost conductor(s) in a static position,
whereas the managed ROW zone is the area that extends roughly 16 feet from the outside of the
transmission wires in their static position.
The vegetation impact assessment used GIS analysis to evaluate the tree inventory data and the
preliminary transmission line design to assess the number of trees that would likely require removal
within a specific route.
FINAL EIS PAGE A‐4
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
Guidelines for 115 kV Lines
Some of the alternatives for the Energize Eastside project include rebuilding or relocating 115 kV lines.
NERC vegetation standards do not apply to PSE’s 115 kV transmission or distribution line rights-of-
way; however, in general, PSE will remove trees that mature at a height of greater than 25 feet near 115
kV lines. It should be noted that, some trees within the corridor or along roadways with a height of
greater than 25 feet, may be allowed to remain in the wire zone if they can be pruned in a manner that
allows sufficient clearance from the lines.
Access
Use of existing access routes is preferred as that is typically the best way to minimize impacts. When a
project entails replacement of an existing transmission line, such as Energize Eastside, efforts are made
to identify the existing or historic access routes. During initial construction of the transmission line,
access routes are established along the corridor. As an area develops and structures are built along the
corridor, some of the original access points are no longer viable and new ones need to be established to
replace or maintain existing transmission line equipment.
Access to each structure location is identified in the field with a preference to those areas that require the
least amount of improvement (e.g., use of existing roads or trails). The field-identified access routes are
mapped using handheld GPS units. The GPS data are imported into the surveyed route maps for
reference. Each route will be assessed on site with the affected property owners to gather site-specific
limitations and if necessary, identify improvement and restoration details.
Along the corridor, the access and pole locations are identified by the land surveyor and engineering
team. As necessary, the access to each pole location is improved or created. Preliminary access routes
for construction and maintenance are shown on figures at the end of this appendix, by segment.
The typical width of access roads is 20 feet.
Utility Locates and Civil Work
As required by state law, utility locates are performed prior to ground-disturbing activities. Appropriate
temporary erosion control measures may be installed prior to and during work activities. Initial
vegetation management activities then commence, removing those species that are incompatible with the
safe operation of the transmission line. If civil work is required to establish either a temporary or
permanent construction area, that work typically takes place following vegetation removal.
A work area with an approximate radius of 50 feet around the new pole location would be typical. This
area would provide a safe working space for placing equipment, vehicles, and materials.
CONSTRUCTION
PSE will work to restore property impacted by construction to its previous or an improved state, as
practical and required under applicable law. PSE will mitigate in-kind when restoration is not possible,
as required by applicable law. PSE will comply with local codes related to construction noise. PSE will
work with property owners to minimize impacts during construction as much as practicable.
FINAL EIS PAGE A‐5
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
Pole Installation
Each steel pole will be installed either by direct embedment or placed on a drilled pier foundation.
(Based on design and construction limitations, other foundation types may be utilized as well.) The type
of foundation that will be used to support the poles will depend on the structural loading, structural
strength of the soil, and site accessibility. In areas near co-located underground utilities, such as the
Olympic pipeline system, the proposed pole design and location is reviewed with BP, the pipeline
operator. As appropriate, BP’s general construction procedures will be followed when construction
activities take place in the area of the Olympic pipeline system, which includes on-site inspection.
The hole for the transmission pole is typically initiated using a vacuum excavator (typically called a
Vactor truck), which is one of the least invasive methods of excavation. If soil conditions allow, the
entire hole could be excavated using a Vactor truck; however, it may be necessary to use traditional
auger equipment to achieve the necessary depth. Typical hole diameter is approximately 18 inches
greater than the diameter of the base of the pole. Generally, the depth of the hole will be 10 percent of
the pole height plus 4 feet.
In areas of soft soils, a steel casing may be used during drilling to hold the excavation open, after which
the steel casing would be cut below grade and backfilled upon completion.
For direct embed poles, the base section of the pole is installed in the hole and the annulus filled with
select backfill. When backfill must be imported, material is obtained from commercial sources.
For poles that require drilled pier foundations, the hole is advanced in the same manner as that for the
direct embed poles. Reinforced-steel anchor bolt and rebar cages are then installed in the excavation.
These cages are inserted in the holes prior to pouring concrete and are designed to strengthen the
structural integrity of the foundations and are delivered to the structure site via flatbed truck. The
excavated holes containing the reinforcing anchor bolt cages would be filled with concrete and be left to
cure for 28 days.
To construct the actual steel structure, two methods of assembly can be used, the first of which is to
assemble the poles, braces, cross arms, hardware, and insulators on the ground. A crane is then used to
set the fully framed structure by placing the poles in the excavated holes or on the drilled pier
foundation. Alternatively, aerial framing can be used by setting the first pole section in the ground or on
the foundation, and subsequently adding the remaining sections and equipment via a crane. It may be
more efficient and less disruptive to adjacent property owners in some locations to use a helicopter to
install poles. This is identified as a mitigation measure in Section 5.1.3 of the Final EIS.
Stringing
Installation of the conductor, shield wire, and communication fiber on the transmission line support
structures is called stringing. The first step of wire stringing would be to install insulators (if not already
installed on the structures during ground assembly) and stringing pulleys, which are temporarily
attached to the lower portion of the insulators at each transmission line support structure to allow
conductors to be pulled along the line. When an existing transmission line is being replaced, the new
poles will be installed and the existing wires could be transferred to them from the existing poles that
will be removed. This is done so that the existing conductor can be used to pull in the new conductor in
a more efficient manner. In some instances, where the existing conductor is not suitable to pull in the
new wire, a rope (called a sock line) may be used.
FINAL EIS PAGE A‐6
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
Once the existing conductors have been transferred to the stringing sheaves, they would be attached to
the new conductors and used to pull them through the sheaves into their final location. Pulling the lines
may be accomplished by attaching them to a specialized wire stringing vehicle. Following the initial
stringing operation, pulling and sagging of the line would be required to achieve the correct tension of
the transmission lines between support structures. After the new lines have been set, the existing poles
and old conductors are then removed.
Where a sock line is needed, workers would need to carry the line from pole to pole, requiring access to
properties between poles. It may be more efficient and less disruptive to adjacent property owners in
some locations to use a helicopter to string the sock line. This is identified as a mitigation measure in
Section 5.1.3 of the Final EIS.
Pulling and tensioning sites are expected to be required approximately every 2 miles along the corridor.
Equipment at sites required for pulling and tensioning activities would include tractors and trailers with
spooled reels that hold the conductors and trucks with the tensioning equipment. To the extent
practicable, pulling and tensioning sites would be located within the existing corridor.
Depending on topography, minor grading may be required at some sites to create level pads for
equipment. Finally, the tension and sag of conductors and wires would be fine-tuned, stringing sheaves
would be removed, and the conductors would be permanently attached to the insulators at the support
structures.
Removal of Existing Poles and Lines
The existing 115 kV poles are expected to temporarily remain during and after construction of the
230 kV system to support the existing conductors and dedicated fiber optic line. The existing fiber optic
line will need to stay in service throughout construction as it is used for substation controls. Once the
new fiber optic (OPGW) lines are installed, the old fiber optic lines and poles can be removed. PSE
expects that the old poles would be removed any time from a couple of days to a few months after the
construction of the new lines. Some of the existing poles have joint tenant utilities, typically
telecommunications. These are not owned by PSE and will need to be relocated by their respective
owners. In those situations, the existing poles would remain until the joint facilities are relocated. This
is typically a 90-day process; however, it can take longer depending on joint facility crew availability.
Demobilization and Restoration
Construction sites, staging areas, material storage yards, and access roads would be kept in an orderly
condition throughout the construction period. Disturbed areas not required for access roads and
maintenance areas around structures would be restored and revegetated, as agreed to with the property
owner or land management agency.
FINAL EIS PAGE A‐7
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
APPENDIX A-2. PRELIMINARY CONSTRUCTION
ACCESS ROUTES AND PROPOSED POLE
LOCATIONS
On the following maps, locations of preliminary construction access routes are based on a single dataset
provided by PSE in August 2017 and do not reflect coordination with individual property owners (PSE,
2017, specifically data layer titled Proposed_Access_Route_v2). Locations of proposed pole locations
are based on several datasets provided by PSE in 2017, depending on segment (including files titled
energize eastside non-variance (4-1 to RIC)_plan strs only_rev p and North_8-3-17.dxf and South_8-3-
17.dxf).
Interactive maps of the latest data showing proposed pole locations and surveyed trees are also
available on the internet (www.energizeeastsideeis.org/), allowing the user to zoom into site-specific
locations. Specific pole locations may be refined as PSE completes its final design during the
permitting process.
FINAL EIS PAGE A‐8
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
Preliminary Construction Access Routes Prior to Property Owner Consultation and Proposed Pole
Locations – Redmond Segment
FINAL EIS PAGE A‐9
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
Preliminary Construction Access Routes Prior to Property Owner Consultation and Proposed Pole
Locations – Bellevue North Segment
FINAL EIS PAGE A‐10
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
Preliminary Construction Access Routes Prior to Property Owner Consultation and Proposed Pole
Locations – Bellevue Central Segment
FINAL EIS PAGE A‐11
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
Preliminary Construction Access Routes Prior to Property Owner Consultation and Proposed Pole
Locations– Bellevue South Segment
FINAL EIS PAGE A‐12
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
Preliminary Construction Access Routes Prior to Property Owner Consultation and Proposed Pole
Locations– Newcastle Segment
FINAL EIS PAGE A‐13
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
Preliminary Construction Access Routes Prior to Property Owner Consultation and Proposed Pole
Locations– Renton Segment
FINAL EIS PAGE A‐14
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
APPENDIX A-3. INFORMATION FROM PSE ON
HELICOPTER USE
FINAL EIS PAGE A‐15
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
FINAL EIS PAGE A‐16
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
FINAL EIS PAGE A‐17
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
FINAL EIS PAGE A‐18
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
FINAL EIS PAGE A‐19
APPENDIX A CONSTRUCTION AND ACCESS MARCH 2018
APPENDIX A-4. ESA TECHNICAL MEMORANDUM
ON HELICOPTER NOISE FROM POWERLINE
STRINGING AND POLE INSTALLATION
550 Kearny Street
Suite 800
San Francisco, CA 94108
415.896.5900 phone
415.896.0332 fax
www.esassoc.com
Technical memorandum
date January 16, 2018
to Reema Shakra, Project Manager
cc Mark Johnson, Project Director
from Chris Sanchez, Senior Technical Associate
subject Helicopter Noise from the Installation of Transmission Poles and Lines
In response to your e-mail, this memorandum responds to your request for impact analysis of noise from
transmission pole/line installations using helicopters. The following is a synopsis of potential noise impacts and
how they may apply to elements of the Energize Eastside Project. ESA estimated the 1-hour equivalent sound level
(Hourly Leq) values that would be associated with pole/line installations as well as landing zone areas.
It is assumed that the pole installation would be conducted using a heavy duty helicopter, such as CH47D
Chinook, and line installation would be conducted using a light duty helicopter, such as Hughes 500D. The
Federal Aviation Administration’s (FAA) Aviation Environmental Design Tool version 2d (AEDT 2d) includes a
set of data called Noise-Power-Distance (NPD) data for both helicopters. NPD data includes A-weighted
maximum noise levels (LAMAX) for hovering operations at the distances from 200 feet to 25,000 feet. For this
study, the following are used as a reference noise level for helicopter activities:
CH47D – 86 dBA LAMAX at 200 feet
H500D – 80 dBA LAMAX at 200 feet
These maximum noise levels were then used to estimate average hourly noise levels associated with helicopter
construction activity. For pole installation, it was assumed that a CH47D helicopter would be hovering at one
location for the entire hour. For line installation, it was assumed that the H500D helicopter operating time would
be approximately 15 minutes per hour at tubular steel pole (TSP) sites during sock line stringing. At the landing
zone, it was assumed that helicopters would take 15 minutes per hour related to helicopter landing and takeoff. For
both pole and line installation, it was assumed that the helicopter would hover approximately 250 feet above the
ground. Based on the above assumptions, following hourly Leq levels will be used:
CH47D Hovering – 86 dBA Hourly Leq at 200 feet
CH47D at Landing Zone – 80 dBA Hourly Leq at 200 feet
H500D Hovering and at Landing Zone – 74 dBA Hourly Leq at 200 feet
Helicopter Noise from the Installation of Transmission Poles and Lines
2
As shown in Table 1, Construction Noise Levels at Sensitive Receptor Locations, hourly average helicopter noise
levels associated with these construction activities at the closest sensitive receptor locations would range from 69
dBA to 82 dBA for helicopter activities at a lateral distance of 200 to 350 feet.
For the Energize Eastside Project, a mitigation measure to avoid some non-noise related impacts would involve
the use of helicopters for pole installation and line stringing. At some locations, sensitive receptors could be as
close as 15 feet laterally from the proposed alignment. Consequently, noise levels at immediately adjacent
receptors to pole installation and line stringing would essentially be the same as the reference noise level at a
height of 200 feet. Assuming that helicopter landing zones would have a 350-foot buffer from the nearest
sensitive receptor, noise levels at such receptors would be the same as predicted in Table 1, below.
Most cities in the project area have a noise ordinance that limits the hours of construction activity but do not
establish a quantitative noise standard. As an example, under the Bellevue City Code (BCC), noise emanating
from construction sites is prohibited outside of the hours of 7 a.m. to 6 p.m. Monday through Friday, and 9 a.m.
to 6 p.m. on Saturdays. No construction site noise is permitted on Sundays and legal holidays. If after-hours
sounds from a construction site are clearly audible across a real property boundary or at least 75 feet from their
source, it will be considered a noise disturbance (BCC 9.18.040.A.4) Additionally, sounds created by the repair or
installation of essential utility services and streets are exempt from the restrictions of the noise ordinance (BCC
9.18.020.B.2) as are sounds originating from aircraft in flight (BCC 9.18.020.A.6).
Consequently, while helicopter noise would likely be clearly audible at the nearest receptors it would still be
consistent with the restrictions of local noise ordinances and would be temporary in nature as construction
activities would take less than three days to complete at any given location, with the exception of activities at the
helicopter landing zones.
TABLE 1
CONSTRUCTION NOISE LEVELS AT SENSITIVE RECEPTOR LOCATIONS
Construction Noise Source
Distance to
Closest Sensitive
Receptora
Hourly Leq at
Closest Sensitive
Receptor
CH47D – Pole Installationb 320 feet 82 dBA
H500D – Line Installationc 320 feet 70 dBA
CH47D at Landing Zoned 350 feet 75 dBA
H500D at Landing Zoned 350 feet 69 dBA
a Direct distances between a helicopter and a receptor based on the hovering height of 250 feet and horizontal distance to a receptor of
200 feet with the assumption of 6 dB noise propagation rate per doubling the distance.
b Helicopter Hourly Leq values near pole installation are calculated assuming the helicopter would hover above the site at an elevation
of approximately 250 feet above the ground surface for an hour.
c Helicopter Hourly Leq values near TSP locations are calculated assuming the helicopter would hover above the site at an elevation of
approximately 250 feet above the ground surface for up to 15 minutes per hour.
d Helicopter Hourly Leq values are calculated assuming the helicopter would operate in the immediate vicinity of the helicopter landing
zone for up to 15 minutes per hour.
SOURCE: ESA, 2018
Appendix B:
Supplemental Information:
Land Use
B
FINAL EIS PAGE B‐1
APPENDIX B SUPPLEMENTAL INFORMATION: LAND USE MARCH 2018
APPENDIX B-1. METHODS FOR DETERMINING
STUDY AREA
The adjacent parcel study area was created for the right-of-way by selecting all parcels adjoining the
right-of-way where the corridor will be running. For areas not in a current right-of-way, a qualitative
approach was used. The goal was to capture all of the parcels that were next to or adjoining the PSE
easement. This included both the parcel the easement runs through (easement parcel) and the
adjoining parcels, within a reasonable distance. A reasonable distance methodology assumes that if
the easement parcel is large, the adjoining parcels on the nearby side are brought in, while those on
the far side are left out. A common example is represented in Figure B-1. Here, it is reasonable to
assume that the parcels on the east are close enough to be adjacent, but the parcels on the west are
not.
Figure B-1. Adjacent Parcels for Study Area Example
FINAL EIS PAGE B‐2
APPENDIX B SUPPLEMENTAL INFORMATION: LAND USE MARCH 2018
APPENDIX B-2. APPLICABLE ZONING REGULATIONS
BY STUDY AREA CITY
The tables below list the zoning districts of parcels included in the study area, shown by segment and
option. In each zoning district, an electric utility facility would either be designated as a permitted,
conditional, or prohibited use. If an electrical facility is considered a conditional use, the applicable
jurisdiction would require a public hearing in front of the hearing examiner. Also included in the
tables is each jurisdiction’s definition of an electrical utility facility or utility.
Redmond Segment
Electrical Utility
Facility
Electrical Utility Facility defined as: unstaffed facilities, except for the presence
of security personnel, that are used for or in connection with or to facilitate the
transmission, distribution, sale, or furnishing of electricity, including but not
limited to electric power substations (RZC 21.78)
Zoning Districts Permitted Conditionally Permitted Prohibited
R-1 X
R-4 X
R-5 X
R-6 X
R-12 X
BP X
MP X
Source: City of Redmond Municipal Code. Accessed August 2016. Available at:
http://online.encodeplus.com/regs/redmond-wa/doc-viewer.aspx?tocid=003#secid-1067.
FINAL EIS PAGE B‐3
APPENDIX B SUPPLEMENTAL INFORMATION: LAND USE MARCH 2018
Bellevue Segments
Electrical Utility
Facility
Electrical Utility Facility defined as: distribution substations, transmission
stations, transmission switching stations, or transmission lines that are built,
installed, or established. (Bellevue LUC 20.50.018 E)
Zoning Districts Permitted Conditionally Permitted Prohibited
R-1 X
R-1.8 X
R-2.5 X
R-3.5 X
R-5 X
R-10 X
R-15 X
R-20 X
R-30 X
BR-GC X
CB X
O X
OLB X
PO X
LI X
BR-CR X
BR-ORT X
Source: http://www.codepublishing.com/WA/Bellevue/LUC/BellevueLUC2020.html#20.20.255
FINAL EIS PAGE B‐4
APPENDIX B SUPPLEMENTAL INFORMATION: LAND USE MARCH 2018
Newcastle Segment
Electrical Utility
Facility
(Regional)
Electrical Utility Facility (Regional) defined as: a facility for the distribution or
transmission of services from or to an area beyond Newcastle; including but
not limited to: electrical distribution substations, electrical transmission
stations, electrical transmission switching stations, electrical transmission lines
greater than 115 kV and maintenance and utility yards (NMC 18.96.689).
Zoning Districts Permitted Conditionally
Permitted1
Prohibited
R-1 X
R-4 X
R-6 X
R-6-P X
R-18 X
CB X
O X
LOS X
1 Subject to additional criteria listed in NMC 18.44.052.
Source: http://www.codepublishing.com/WA/Newcastle/#!/Newcastle18/Newcastle1808.html#18.08.060
Renton Segment
Utilities Large Utilities Large defined as: Utilities Large includes large-scale facilities with
either major above-ground visual impacts, or serving a regional need such as
two hundred thirty (230) kV power transmission lines, natural gas transmission
lines, and regional water storage tanks and reservoirs, regional water
transmission lines or regional sewer collectors and interceptors. (RMC4-11-
210)
Zoning Districts Permitted Conditionally Permitted Prohibited
R-1 X
R-4 X
R-6 X
R-8 X
R-10 X
R-14 X
IL X
RC X
COR X
CV X
CA X
Source: http://www.codepublishing.com/WA/Renton/#!/renton04/Renton0403/Renton0403090.html#4-3-090
FINAL EIS PAGE B‐5
APPENDIX B SUPPLEMENTAL INFORMATION: LAND USE MARCH 2018
APPENDIX B-3. APPLICABLE POLICIES BY STUDY
AREA CITY
Policies by Subarea Plan
Subarea Plan Policy
Redmond
Comprehensive Plan Infrastructure and services meet the needs of a growing population and
promote a safe and healthy community. The planning and placement of
utilities in Redmond has supported the community’s vision for the
location and amount of growth. Long-term planning for utilities has
contributed to a high quality of life for Redmond residents and
businesses by ensuring efficient utility delivery. Proper utility planning has
also protected Redmond’s natural environment and resources.
FW-12: Ensure that the land use pattern accommodates carefully
planned levels of development, fits with existing uses, safeguards the
environment, reduces sprawl, promotes efficient use and best
management practices of land, provides opportunities to improve human
health and equitable provision of services and facilities, encourages an
appropriate mix of housing and jobs, and helps maintain Redmond’s
sense of community and character.
FW-13: Ensure that the land use pattern in Redmond meets the following
objectives:
Takes into account the land’s characteristics and directs
development away from environmentally critical areas and
important natural resources;
Supports the preservation of land north and east of the city
outside of the Urban Growth Area, for long-term agricultural use,
recreation and uses consistent with rural character;
Provides for attractive, affordable, high-quality and stable
residential neighborhoods that include a variety of housing
choices;
Advances sustainable land development and best management
practices, multimodal travel and a high quality natural environment.
FW-22: Make each neighborhood a better place to live or work by
preserving and fostering each neighborhood’s unique character and
preparation for a sustainable future, while providing for compatible
growth in residences and other land uses, such as businesses, services
or parks.
FINAL EIS PAGE B‐6
APPENDIX B SUPPLEMENTAL INFORMATION: LAND USE MARCH 2018
Subarea Plan Policy
CF-18: Identify lands useful for public purposes in functional plans and in
the appropriate elements of the Comprehensive Plan. Identify alternative
sites or lands more generally where acquisition is not immediate. Identify
lands specifically when acquired and used for public purposes on the
Land Use Map, or in the appropriate elements of the Comprehensive Plan
where not otherwise identified by City or other governmental agency
functional plans.
LU-14: Encourage the provision of needed facilities that serve the general
public, such as facilities for education, libraries, parks, culture and
recreation, police and fire, transportation and utilities. Ensure that these
facilities are located in a manner that is compatible with the City’s
preferred land use pattern.
UT-58: Work with energy service providers to ensure energy facility plans
reflect and support Redmond’s Land Use Plan and that energy resources
are available to support the Land Use Plan.
UT-61: Recognize the current Electrical Facilities Plan, authored by Puget
Sound Energy, as the facility plan for electrical utilities serving Redmond
and the vicinity. Use this plan, where it is consistent with Redmond’s land
use goals, as a guide in identifying and preserving utility corridors and
locating electrical facilities.
UT-63: Coordinate with Puget Sound Energy or any successor when
considering land use designations or new development in the vicinity of
proposed facility locations that might affect the suitability of the
designated areas for location of facilities.
UT-59: Work with energy service providers to promote an affordable,
reliable, and secure energy supply that increases development and use of
renewable and less carbon-intensive sources, and that minimizes
demand and consumption.
Bellevue
Comprehensive Plan CE-4: Balance the interests of the commercial and residential
communities when considering modifications to zoning or development
regulations.
LU-2: Retain the city’s park-like character through the preservation and
enhancement of parks, open space, and tree canopy throughout the
city.
LU-29: Help communities to maintain their local, distinctive
neighborhood character, while recognizing that some neighborhoods
may evolve.
LU-1: Promote a clear strategy for focusing the city’s growth and
development as follows:
1. Direct most of the city’s growth to the Downtown regional growth
center and to other areas designated for compact, mixed use
development served by a full range of transportation options.
FINAL EIS PAGE B‐7
APPENDIX B SUPPLEMENTAL INFORMATION: LAND USE MARCH 2018
Subarea Plan Policy
2. Enhance the health and vitality of existing single family and
multifamily residential neighborhoods.
3. Continue to provide for commercial uses and development that
serve community needs.
UT-8: Design, construct, and maintain facilities to minimize their impact
on surrounding neighborhoods.
UT-45: Coordinate with non-city utility providers to ensure planning for
system growth consistent with the city’s Comprehensive Plan and
growth forecasts.
UT-47: Defer to the serving utility the implementation sequence of utility
plan components.
UT-48: Coordinate with the appropriate jurisdictions and governmental
entities in the planning and implementation of multi-jurisdictional utility
facility additions and improvements.
UT-58: Require the undergrounding of all new electrical distribution lines
except that interim installation of new aerial facilities may be allowed if
accompanied by a program to underground through coordination with
the city and other utilities. Require the undergrounding of all existing
electrical distribution lines where a change in use or intensification of an
existing use occurs, unless delayed installation is approved as part of a
specific program to coordinate undergrounding of several utilities or in
conjunction with an undergrounding program for several sites or when
related to street improvements.
UT-62: Support neighborhood efforts to underground existing electrical
transmission and distribution lines.
UT-63: Support neighborhood efforts to form financial arrangements,
such as local improvement districts, to cover the non-utility share of
project costs for undergrounding electrical lines.
UT-64: Require the reasonable screening and/or architecturally
compatible integration of all new utility and telecommunication facilities.
UT-66: Encourage directional pruning of trees and phased replacement
of improperly located vegetation in the right-of-way. Perform pruning
and trimming of trees in an environmentally sensitive and aesthetically
acceptable manner and according to professional arboricultural
specifications and standards.
UT-67: Encourage consolidation on existing facilities where reasonably
feasible and where such consolidation leads to fewer impacts than
would construction of separate facilities. Examples of facilities that
could be shared are towers, electrical, telephone and light poles,
antenna, substation sites, trenches, and easements.
UT-68: Encourage the use of utility corridors as non-motorized trails.
The city and utility company should coordinate the acquisition, use, and
enhancement of utility corridors for pedestrian, bicycle and equestrian
trails and for wildlife corridors and habitat.
FINAL EIS PAGE B‐8
APPENDIX B SUPPLEMENTAL INFORMATION: LAND USE MARCH 2018
Subarea Plan Policy
UT-69: Avoid, when reasonably possible, locating overhead lines in
greenbelt and open spaces as identified in the Parks and Open Space
System Plan.
UT-72: Encourage cooperation with other jurisdictions in the planning
and implementation of multi-jurisdictional utility facility additions and
improvements. Decisions made regarding utility facilities shall be made
in a manner consistent with, and complementary to, regional demand
and resources, and shall reinforce an interconnected regional
distribution network.
UT-74: Encourage system practices intended to minimize the number
and duration of interruptions to customer service.
UT-75: Prior to seeking city approval for facilities, encourage utilities
service providers to solicit community input on the siting of proposed
facilities which may have a significant adverse impact on the
surrounding community.
UT-77: Require all utility equipment support facilities to be aesthetically
compatible with the area in which they are placed by using landscape
screening and/or architecturally compatible details and integration.
UT-94: Require in the planning, siting, and construction of all electrical
facilities, systems, lines, and substations that the electrical utility strike a
reasonable balance between potential health effects and the cost and
impacts of mitigating those effects by taking reasonable cost-effective
steps.
UT-95: Work with Puget Sound Energy to implement the electrical
service system serving Bellevue in such a manner that new and
expanded transmission and substation facilities are compatible and
consistent with the local context and the land use pattern established in
the Comprehensive Plan.
UT-96: Require siting analysis through the development review process
for new facilities, and expanded facilities at sensitive sites, including a
consideration of alternative sites and collocation.
UT-98: Discourage new aerial facilities within corridors that have no
existing aerial facilities.
Bel-Red Corridor Plan Utility-related cabinets that occur in the right-of-way should not call
attention to themselves, and therefore should not be decorated.
Wilburton Grand
Connection Initiative
No policies that could impact the project.
Bel-Red Subarea Plan No policies that could impact the project.
Bridle Trails Subarea Plan
Policy S-BT-34: Provide Bellevue-owned utility service to surrounding
jurisdictions in accordance with the Annexation Element of the
Comprehensive Plan.
FINAL EIS PAGE B‐9
APPENDIX B SUPPLEMENTAL INFORMATION: LAND USE MARCH 2018
Subarea Plan Policy
Eastgate Subarea Plan No policies that could impact the project.
Factoria Subarea Plan Policy S-FA-24: Encourage the undergrounding of utility distribution
lines in areas of new development and redevelopment.
Policy S-FA-35: Minimize disruptive effects of utility construction non
property owners, motorists, and pedestrians.
Policy S-FA-49: Incorporate infrastructure improvements and implement
design guidelines that will enhance pedestrian crossings (respecting the
significant traffic volumes and multiple turning movements at these
intersections), improve transit amenities, and develop an active building
frontage along Factoria Boulevard with direct pedestrian routes to retail
storefronts from the public sidewalk and weather protection for
pedestrians.
Policy S-FA-52. Allow buildings to abut the Factoria Boulevard public
right-of-way, so long as there is adequate space for the arterial
sidewalks.
Policy S-FA-51: Consider establishing a maximum building setback from
the right-of-way for structures along the Factoria Boulevard commercial
corridor.
Newport Hills Plan Policy S-NH-55: Encourage undergrounding of utility distribution lines
on existing development where reasonably feasible.
Policy S-NH-50. Include the following elements in a redeveloped
commercial district: new commercial buildings at the street edge
Richards Valley Plan Policy S-RV-19. Encourage the combination of utility and transportation
rights-of-way in common corridors and coordinate utility construction
with planned street and bike lane improvements which could result in a
more efficient allocation of funds.
Policy S-RV-20. Use common corridors for new utilities if needed.
Discussion: If new power lines are needed in the Subarea, they should
be developed in areas that already contain power lines, rather than
causing visual impacts in new areas.
SE Bellevue Plan N/A
Wilburton/NE 8th St Plan Policy S-WI-43: Encourage the undergrounding of utility distribution
lines in developed areas and require the undergrounding of utility
distribution lines in new developments when practical.
Policy S-WI-49. Allow flexibility for commercial buildings to be sited near
frontage property lines.
FINAL EIS PAGE B‐10
APPENDIX B SUPPLEMENTAL INFORMATION: LAND USE MARCH 2018
Subarea Plan Policy
Newcastle
Comprehensive Plan UT-P1: The City shall require that the undergrounding of new utility
distribution lines, with the exception of high voltage electrical
transmission lines.
UT-P2: The City shall require the undergrounding of existing utility
distribution lines where physically feasible as streets are widened and/or
areas are redeveloped based on coordination with local utilities.
UT-P3: The City shall promote collocation of major utility transmission
facilities such as high voltage electrical transmission lines and water and
natural gas trunk pipe lines within shared utility corridors, to minimize
the amount of land allocated for this purpose and the tendency of such
corridors to divide neighborhoods.
UT-P10 The City should require utility providers to design and construct
overhead transmission lines in a manner that is environmentally
sensitive, safe, and aesthetically compatible with surrounding land uses.
UT-P12: The City should encourage the replacement of outdated
equipment with technologically updated or advanced alternatives,
providing that the cost of the updated equipment is fiscally reasonable.
UT-P14 The City should require utility providers to minimize visual and
other impacts of transmission towers and overhead transmission lines
on adjacent land uses through careful siting and design.
UT-P17 The City should require an analysis from utilities that states
either the direct benefits to the City of high capacity transmission lines
or the necessity of high capacity transmission lines through the City.
LU-G3: preserve the existing character, scale, and neighborhood quality
as new development occurs
LU-G8: Strive to preserve and enhance natural features, such as stream
channels, that contribute to the City’s scenic beauty.
LU-G13: The City shall identify lands useful for public purposes such as
utility and transportation corridors, landfills, sewage treatment facilities,
storm water management facilities, recreation, schools, and other public
uses.
LU-P17: Non-residential uses may be allowed in new residential
developments when proposed uses are determined to be both viable
and beneficial to the surrounding neighborhood.
HO-P2: The City shall protect the quality and character of existing single
family neighborhoods as described in the Land Use Element.
Newcastle Subarea Plan Policy S-NC-44: Encourage the use of utility and railroad easements and
rights-of-way for hiking, biking, and equestrian trails wherever
appropriate in the Subarea.
FINAL EIS PAGE B‐11
APPENDIX B SUPPLEMENTAL INFORMATION: LAND USE MARCH 2018
Subarea Plan Policy
Renton
Comprehensive Plan L-48: Accommodate change within the Renton community in a way that
maintains Renton’s livability and natural beauty.
L-55: Protect public scenic views and public view corridors, including
Renton’s physical, visual and perceptual linkages to Lake Washington
and the Cedar River.
L-56: Preserve natural landforms, vegetation, distinctive stands of trees,
natural slopes, and scenic areas that contribute to the City’s identity,
preserve property values, and visually define the community and
neighborhoods.
U-2: Protect the health and safety of Renton citizens from
environmental hazards associated with utility systems through the
proper design and siting of utility facilities.
U-3: Promote the co-location of new utility infrastructure within rights-
of-way and utility corridors and coordinate construction and
replacement of utility systems with other public infrastructure projects
to minimize construction-related costs and disruptions.
U-7: Non-City utility systems should be constructed in a manner that
minimizes negative impacts to existing development and should not
interfere with operation of City utilities. City development regulations
should otherwise not impair the ability of utility providers to adequately
serve customers.
U-72: Coordinate with local and regional electricity providers to ensure
the siting and location of transmission and distribution facilities is
accomplished in a manner that minimizes adverse impacts on the
environment and adjacent land uses.
U-73: Encourage electricity purveyors to make facility improvements
and additions within existing utility corridors wherever possible.
4-3-090 City of Renton Shoreline Master Program Regulations
In addition to the various plan policies listed in the table above, the Shoreline Master Program
applies for any portion of the project that is in a designated Shoreline of the State or within 200 feet
of the ordinary high water mark or the floodway, whichever is greater. As a portion of the project
crosses the Cedar River shoreline (in Renton), the following regulations would apply to any structure
that lies within the Shoreline jurisdiction.
Part 4-3-090(C)(2)(c) Shoreline High Intensity Overlay District Acceptable Activities and
Uses
Acceptable Activities and Uses: As listed in RMC 4-3-090E Use Regulations.
FINAL EIS PAGE B‐12
APPENDIX B SUPPLEMENTAL INFORMATION: LAND USE MARCH 2018
Part 4-3-090(C)(4)(c) Shoreline High Intensity Overlay District Acceptable Activities and
Uses
Subject to RMC 4-3-090E Use Regulations, which allows land uses in RMC Chapter 4-2 in this
overlay district, subject to the preference for water-dependent and water-oriented uses. Uses adjacent
to the water's edge and within buffer areas are reserved for water oriented development,
public/community access, and/or ecological restoration.
Part 4-3-090(D)(2)(a) General Development Standards, Environmental Effects, No Net
Loss of Ecological Functions
i. No net loss required: Shoreline use and development shall be carried out in a manner that prevents
or mitigates adverse impacts to ensure no net loss of ecological functions and processes in all
development and use. Permitted uses are designed and conducted to minimize, in so far as practical,
any resultant damage to the ecology and environment (RCW 90.58.020). Shoreline ecological
functions that shall be protected include, but are not limited to, fish and wildlife habitat, food chain
support, and water temperature maintenance. Shoreline processes that shall be protected include, but
are not limited to, water flow; erosion and accretion; infiltration; ground water recharge and
discharge; sediment delivery, transport, and storage; large woody debris recruitment; organic matter
input; nutrient and pathogen removal; and stream channel formation/maintenance. ii. Impact
Evaluation Required: In assessing the potential for net loss of ecological functions or processes,
project-specific and cumulative impacts shall be considered and mitigated on- or off-site. iii.
Evaluation of Mitigation Sequencing Required: An application for any permit or approval shall
demonstrate all reasonable efforts have been taken to provide sufficient mitigation such that the
activity does not result in net loss of ecological functions. Mitigation shall occur in the following
prioritized order: (a) Avoiding the adverse impact altogether by not taking a certain action or parts of
an action, or moving the action. (b) Minimizing adverse impacts by limiting the degree or magnitude
of the action and its implementation by using appropriate technology and engineering, or by taking
affirmative steps to avoid or reduce adverse impacts. (c) Rectifying the adverse impact by repairing,
rehabilitating, or restoring the affected environment. (d) Reducing or eliminating the adverse impact
over time by preservation and maintenance operations during the life of the action. (e) Compensating
for the adverse impact by replacing, enhancing, or providing similar substitute resources or
environments and monitoring the adverse impact and taking appropriate corrective measures.
Part 4-3-090(D)(2)(c) General Development Standards, Environmental Effects, Critical
Areas within Shoreline Jurisdiction
i. Applicable Critical Area Regulations: The following critical areas shall be regulated in
accordance with the provisions of RMC 4-3-050 Critical Area Regulations, adopted by reference
except for the provisions excluded in subsection 2, below. Said provisions shall apply to any use,
alteration, or development within shoreline jurisdiction whether or not a shoreline permit or
written statement of exemption is required. Unless otherwise stated, no development shall be
constructed, located, extended, modified, converted, or altered, or land divided without full
compliance with the provision adopted by reference and the Shoreline Master Program. Within
shoreline jurisdiction, the regulations of RMC 4-3-050 shall be liberally construed together with
the Shoreline Master Program to give full effect to the objectives and purposes of the provisions
of the Shoreline Master Program and the Shoreline Management Act.
FINAL EIS PAGE B‐13
APPENDIX B SUPPLEMENTAL INFORMATION: LAND USE MARCH 2018
If there is a conflict or inconsistency between any of the adopted provisions below and the
Shoreline Master Program, the most restrictive provisions shall prevail.
(a) Aquifer protection areas.
(b) Areas of special flood hazard.
(c) Sensitive slopes, twenty-five percent (25%) to forty percent (40%), and protected slopes,
forty percent (40%) or greater.
(d) Landslide hazard areas.
(e) High erosion hazards.
(f) High seismic hazards.
(g) Coal mine hazards.
(h) Fish and wildlife habitat conservation areas: Critical habitats.
(i) Fish and wildlife habitat conservation areas: Streams and Lakes: Classes 2 through 5 only.
ii. Inapplicable Critical Area Regulations: The following provisions of RMC 4-3-050 Critical Area
Regulations shall not apply within shoreline jurisdiction:
(a) RMC 4-3-050N Alternates, Modifications and Variances, Subsections 1 and 3 Variances, and
(b) RMC 4-9-250 Variances, Waivers, Modifications and Alternatives.
(c) Wetlands, including shoreline associated wetlands, unless specified below.
iii. Critical Area Regulations for Class 1 Fish Habitat Conservation Areas: Environments designated
as Natural or Urban Conservancy shall be considered Class 1 Fish Habitat Conservation Areas.
Regulations for fish habitat conservation areas Class 1 Streams and Lakes are contained within
the development standards and use standards of the Shoreline Master Program, including but not
limited to RMC 4-3-090F.1 Vegetation Conservation, which establishes vegetated buffers
adjacent to water bodies and specific provisions for use and for shoreline modification in
Subsections 4-3-090E and 4-3-090F. There shall be no modification of the required setback and
buffer for non-water dependent uses in Class 1 Fish Habitat Conservation areas without an
approved shoreline conditional use permit.
iv. Alternate Mitigation Approaches: To provide for flexibility in the administration of the
ecological protection provisions of the Shoreline Master Program, alternative mitigation
approaches may be applied for as provided in RMC 4-3-050N Alternates, Modifications and
Variances, subsection 2. Modifications within shoreline jurisdiction may be approved for those
critical areas regulated by that section as a Shoreline Conditional Use Permit where such
approaches provide increased protection of shoreline ecological functions and processes over the
standard provisions of the Shoreline Master Program and are scientifically supported by specific
studies performed by qualified professionals.
Appendix C:
Scenic Views and Aesthetic
Environment Methodology
C
FINAL EIS PAGE C‐1
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
APPENDIX C-1. SCENIC VIEWS AND AESTHETIC
ENVIRONMENT METHODOLOGY
1. INTRODUCTION
This appendix describes the process for assessing impacts to scenic views and the aesthetic
environment as a result of the Energize Eastside project. Scenic views are the observation of a visual
resource from a particular location, with visual resources generally defined as natural and constructed
features of a landscape that are viewed by the public and contribute to the overall visual quality and
character of an area. Such features often include distinctive landforms, water bodies, vegetation, or
components of the built environment that provide a sense of place, such as city skylines. The
aesthetic environment is the portion of the environment that influences human perception of the
world. It is comprised of the natural (topography, presence of trees, water bodies) and built
(buildings, utility infrastructure) environments. This appendix details the process used to identify
impacts to scenic views and the aesthetic environment and how significance was assigned.
2. GUIDANCE USED
SEPA (WAC 197-11) requires all major actions sponsored, funded, permitted, or approved by state
and/or local agencies to undergo planning to ensure that environmental considerations, such as
impacts related to scenic views and the aesthetic environment, are given due weight in decision-
making. Because the value of scenic views and the aesthetic environment is subjective, based on the
viewer, it is difficult to quantify or estimate impacts. In particular, little guidance exists supporting a
standard methodology for assessing visual impacts associated with transmission line projects. A
number of methodologies were reviewed to inform the methodology used for this project. For this
project, the assessment of impacts was generally based on methods described in the Federal Highway
Administration (FHWA) Guidelines for Visual Impact Assessment (FHWA, 2015). FHWA
guidelines do not specify thresholds for determining significant impacts, nor do state or local
regulations. Therefore, significance was assigned based on criteria similar to those described in The
State Clean Energy Program Guide: A Visual Impact Assessment Process for Wind Energy Projects
(Vissering et al., 2011).
3. STUDY AREA
The FHWA Guidance suggests identifying an Area of Visual Effect
(AVE) based on the physical constraints of the environment and the
physiological limits of human sight (FHWA, 2015). This concept
was used for determining the study area, which takes into account
where the project would be visible given the topographical and
human sight constraints. Impacts to scenic views and the aesthetic
environment would only occur in places where the project would be
visible. To identify areas where the project would be visible, a
geographic information system (GIS) analysis was conducted.
Key Changes from Phase 2
Draft EIS
The study area was refined to
focus on PSE’s Proposed
Alignment.
FINAL EIS PAGE C‐2
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Two sets of tools in ArcMap allow a user to run such an
analysis: (1) Viewshed, and (2) Observer Points (ESRI, 2016).
For this analysis, the viewshed tool was used because it allows
use of lines as key visual elements. The viewshed tool creates a
raster1 that records the number of times an input point or
polyline feature2 can be viewed from a particular area. When
polyline input is used, every node3 and vertex4 along each input
line is processed as an individual observation point, so an area
where multiple vertices can be viewed would have a higher
raster value.
For this analysis, the EIS Consultant Team used the PSE alignment data (a GIS file that shows where
the project would be located) as the input polyline to determine what areas of the landscape have line
of sight to the proposed transmission line.5 Applying an offset informs the viewshed model that the
line being observed would be located above the ground (Figure C-1). The heights identified in Table
C-1 were used to prescribe an offset height to the polyline in the viewshed analysis.6
Table C-1. PSE GIS Alignment Data - Proposed Maximum Pole Height by Segment
Segment Option(s) Proposed Maximum Pole
Height (feet)
Redmond N/A 120’
Bellevue North N/A 100’
Bellevue Central Existing Corridor 115’
Bellevue Central Bypass 1 115’
Bellevue Central Bypass 2 115’
Bellevue South Existing Corridor 95’
Bellevue South SE Newport Way 80’
Bellevue South SE 30th St | Factoria Blvd | Coal Creek Parkway 125’
Bellevue South 124th Ave SE 80’
Newcastle N/A 100’
Renton N/A 125’
Source: PSE, 2016b.
1 A raster is a matrix of cells (or pixels) organized into a grid where each cell contains a value representing
information, such as whether or not a view can be seen.
2 A polyline feature is a continuous line composed of one or more line segments.
3 A node is a point at which lines intersect or branch.
4 A vertex is an angular point of a polygon.
5 Note: line of sight does not necessarily mean the object is within the range of human sight.
6 Pole heights were assigned at the “option(s)” level, with the highest proposed pole option being used.
Data Used to Determine
Study Area
King County 2002/2003 Digital
Surface Model (DSM) (King
County, 2003a)
PSE GIS Alignment Data (PSE,
2016a)
FINAL EIS PAGE C‐3
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Figure C-1. Factoring Line Heights (ESRI, 2016)
The data used as the “ground” for this analysis were the King County Digital Surface Model (DSM).
The King County DSM was used instead of bare earth data because it gives the heights of vegetation
and buildings, in addition to taking into account the underlying topography. The EIS Consultant
Team used DSM data because in urban environments views are often obstructed by vegetation and
buildings, rather than by the topography of the landscape alone (GIS Geography, 2016).
Figure C-2 shows the output from the GIS analysis described above. The GIS analysis provides a
rough approximation of where the project would be visible. It includes areas where the line would be
so small that it is unrealistic that it would be distinguishable on the horizon. Also, in some instances
dense areas of tree stands were misinterpreted by the GIS analysis as being a rise in topography from
which views could be had, skewing the results to show more areas as being potentially impacted than
would actually occur. In general, the highest concentrations of areas with views of the project
corridor would be within one-quarter mile of the corridor. This is consistent with what is commonly
found for transportation projects (FHWA, 2015).
For the purposes of this project, a study area with a one-quarter mile radius from the centerline of the
proposed transmission line corridor (including all segment options) was used. However, Interstate
405 (I-405) and all areas to the west of I-405 were removed because the freeway provides such a
wide separation that the project is not expected to visually impact I-405 drivers or the neighborhoods
west of the freeway. The study area focuses on areas where the proposed transmission line would be
within the foreground view, where viewers are most likely to experience the scale of the project and
observe details and materials. While the project would be visible at greater distances, significant
scenic or aesthetic impacts are not probable given the project’s scale relative to its largely mixed
urban context.
The study area used for the Phase 2 Draft EIS included route options in central and south Bellevue
outside of PSE’s existing corridor that are not included in the Final EIS because the Final EIS
focuses on PSE's Proposed Alignment (Figure C-2). Figure C-3 shows the study area used for the
Final EIS.
FINAL EIS PAGE C‐4
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Figure C-2. Study Area for the Phase 2 Draft EIS
FINAL EIS PAGE C‐5
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Figure C-3. Study Area for the Final EIS
FINAL EIS PAGE C‐6
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
4. CHARACTERIZING THE AESTHETIC ENVIRONMENT
The existing aesthetic environment was characterized through
an assessment of the visual character (what is present in the
built and natural environments), the affected population
(viewers), and the existing visual quality. Visual quality is
based on consistency of visual character with viewer
preferences. To assess the visual quality of the study area, the
visual quality criteria described in the FHWA Guidance were
used. These concepts were applied by the EIS Consultant
Team in the manner described in the table below based on
professional experience and consideration of viewer preferences stated in study area comprehensive
plans and public comments received during the EIS process.
Table C-2. Application of FHWA Methodology to Determine Visual Quality
FHWA Visual
Quality Criteria FHWA Description Application
Natural Harmony What a viewer likes and dislikes
about the natural environment.
The viewer labels the natural
environment as being either
harmonious or inharmonious.
Harmony is considered
desirable; disharmony is
undesirable.
High: A natural area that is relatively
undisturbed by development. Could include
secluded lakes, open plains, forests, etc.
Medium: An area with a small amount of
development that blends with the natural
environment and does not disrupt the natural
harmony of the area.
Low: An area with a large amount of
development where the built environment
takes precedence in the viewshed over the
underlying natural environment.
Built Order What a viewer likes and dislikes
about the built environment. The
viewer labels the built
environment as being either
orderly or disorderly. Orderly is
considered desirable; disorderly
is undesirable.
High: A built environment with urban design
that is identified in a comprehensive plan or
other planning document as being
aesthetically pleasing.
Medium: An area with consistent building
height and form. It does not overtly meet any
set design standards, but also is not
inconsistent with set design standards.
Low: An area with inconsistent building
height and form that does not meet set
design standards (if they exist).
Utility Coherence What the viewer likes and
dislikes about the utility
environment, which is
comprised of the utility’s
geometrics, structures, and
fixtures. The viewer labels the
utility environment as being
either coherent or incoherent.
High: Minimal utility presence, small poles
with few wires*. Configuration is consistent in
height and form. Utility infrastructure blends
with the rest of the aesthetic environment.
Medium: Moderate utility presence. There
could be larger, taller poles or more wires.*
Configuration is consistent in height and
Key Changes from Phase 2
Draft EIS
Additional analysis of utility
coherence based on design
refinements.
FINAL EIS PAGE C‐7
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
FHWA Visual
Quality Criteria FHWA Description Application
Coherent is considered
desirable; incoherent is
undesirable.
form. Utility infrastructure blends with the
rest of the aesthetic environment for the
most part.
Low: High utility presence. There are larger,
taller poles with configurations that are
inconsistent in height and form. The utility
infrastructure is the prominent feature in the
viewshed and does not blend with the rest of
the aesthetic environment.
*Note: Changes in wire diameter are not expected to be perceivable and therefore are not considered as part of this analysis
(see Appendix C‐2).
5. CHARACTERIZING SCENIC VIEWS
Scenic views are views of visual resources that are considered special attributes of the study area and
region. Visual resources associated with the study area were identified in the Phase 1 Draft EIS based
on study area plans, regulatory codes (as summarized in Section 9), and scoping comments. These
are listed in Table C-3. The visual resources evaluated in the Phase 2 Draft EIS were selected
because there was the potential for significant scenic view impacts under the proposed project. The
EIS Consultant Team determined that some of the visual resources identified in the Phase 1 Draft
EIS were no longer applicable due to distance, topographic constraints, or the presence of dense
vegetation between viewers and the visual resources. Table C-3 details why scenic views of certain
Phase 1 visual resources were not evaluated further in the Phase 2 EIS.
Table C-3. Identification of Study Area Scenic Views
Visual Resource
Identified in Phase 1
Included in
Phase 2 GIS
Analysis?
Reason
Mount Rainier Yes Scenic views could be impacted by the project.
Cascade Mountain Range Yes Scenic views could be impacted by the project.
Issaquah Alps
(Cougar Mountain, Tiger
Mountain, and Squak Mountain)
Yes Scenic views could be impacted by the project.
Used Cougar Mountain because it is in the
foreground.
Lake Washington Yes Scenic views could be impacted by the project.
Lake Sammamish Yes Scenic views could be impacted by the project.
Seattle skyline Yes Scenic views could be impacted by the project.
Bellevue skyline Yes Scenic views could be impacted by the project.
Lake Sammamish Yes Scenic views could be impacted by the project.
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APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Visual Resource
Identified in Phase 1
Included in
Phase 2 GIS
Analysis?
Reason
Sammamish Valley No Topography makes is unlikely that scenic views
would be impacted with the powerline in the
foreground and background views would not be
significant because the line would be too far away
from the viewer.
Cedar River No Due to topographic constraints and the presence
of dense vegetation within the Cedar River ravine,
scenic views of the Cedar River are unlikely from
outside of the ravine. No residential views of the
river would be obstructed by the lines and, due to
the topography, the line would be located high
enough above the roadway that it would not
impact drivers’ views of the river. Therefore,
impacts to views of the Cedar River are assessed
as impacts to the aesthetic environment, with the
primary viewers considered being users of the
Cedar River Trail or Riverview Park.
Beaver Lake No Visual resource would not be visible from the
Phase 2 study area.
Pine Lake No Visual resource would not be visible from the
Phase 2 study area.
6. IMPACTS TO THE AESTHETIC
ENVIRONMENT
The assessment of impacts to the aesthetic environment was
based on the FHWA concepts of compatibility of impact (degree
of contrast), sensitivity to the impact (viewer sensitivity), and
degree of impact (whether it would result in a beneficial, neutral,
or adverse impact).
6.1 Degree of Contrast
To assess impacts to the aesthetic environment, tree removal data
(The Watershed Company, 2016, 2017), proposed pole
configurations and locations (PSE, 2017), and visual simulations
(Power Engineers, 2017) were used to determine the degree of
contrast produced by the project. The degree of contrast is the
extent to which a viewer can distinguish between an object and its
background. It was assessed by taking into consideration the project form, materials, and visual
character in comparison to existing conditions and the surrounding areas (Table C-4).
Key Changes from Phase 2
Draft EIS
Additional analysis of
utility coherence based on
design refinements.
Updated simulations and
key viewpoints specific to
PSE’s Proposed
Alignment.
Updated tree removal
data for Bellevue Central
and Bellevue South
Segments and the
Newcastle options.
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APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Table C-4. Contrast Evaluation
FHWA Visual
Quality
Criteria
What Constitutes a
Change? Potential for impacts
Method Used
Natural
Harmony
Tree removal Volume: A large number of
trees would be removed within
a small area.
Location: Occurs in a location
where other trees would not
hide the tree removal from
view or where there isn’t
currently tree management,
resulting in a noticeable
cleared area.
Reviewed tree removal
data against the
existing presence of
trees.
Built Order Project’s height and
scale makes it a
dominant visual feature
in the built environment
Height: Project height is
substantially taller than
surrounding built features.
Form: form is noticeably
different than surrounding built
features.
Visual simulations.
Utility
Coherence
Change in pole
configuration: Going
from pairs of single-
circuit monopoles to
one double-circuit
monopole
Frequency: Occurs numerous
times within a short distance.
Location: Occurs in a location
with high viewer sensitivity.
Assessing PSE data for
pole location and the
associated
configuration.
Natural Harmony
To assess tree removal, GIS data from The Watershed Company were reviewed to assess where tree
removal would occur and how it might result in visual changes based on presence of existing
vegetation. Tree removal is the same in the Final EIS as was assessed in the Phase 2 Draft EIS for the
Redmond, Bellevue North, and Redmond Segments; therefore, no new analysis was conducted.
Updated tree removal data were available for the Bellevue Central and Bellevue South Segments and
both Newcastle options (see Appendix L).
Built Order
The tool of identifying landscape units was not employed due to the length of the corridor and the
diversity of the natural, cultural, and project landscapes; however, the concept of identifying unique
natural, cultural, and project landscapes to select key views was used. For this assessment, the
discussion was divided into the natural (topographic, land cover, water bodies) and built (building
form, utility infrastructure) environments to reduce confusion associated with use of the terms
“cultural” and “project” environments.
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APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
To assess changes to each component of the aesthetic
environment, viewpoints were selected at various
locations along the transmission line corridor to show
different ways the natural and built environments could be
impacted; for instance, areas where the project corridor
would cross unique topography, water bodies, vegetation,
land uses (different land uses typically have different
building forms and impacted viewers), or where the
existing transmission infrastructure would be changed
(e.g., different pole heights or configurations). Areas
identified as being sensitive during the public scoping
period were also used as viewpoints (Table C-5).
Additional simulations were also provided in response to
comments on the Phase 2 Draft EIS (Table C-6).
Visual simulations of what the project would look like at
these viewpoints provide the foundation for assessing
aesthetic impacts. The concept of discussing dynamic versus static viewsheds was adopted as part of
the impacts analysis (view duration), but viewsheds were not identified as being dynamic or static.
Table C-5. Public Comments From Phase 2 Scoping that Requested Visual Simulations
Suggested Viewpoint Location Rationale behind why it
was or was not included
Lower Somerset homeowners’ view of Willow 2. Included – covered via the Somerset Drive SE
simulation.
Factoria Boulevard and Coal Creek Pkwy. Included – covered via the 5365 Coal Creek
Parkway simulation.
West viewing section of Somerset in Bellevue. Included – covered via the Somerset Drive SE
simulation.
Newport Way SE corridor from the on the west
side of the street.
Included – covered via the 12919 SE Newport
Way simulation.
Public parks and rights-of-way. Included – covered via the Lake Boren Park
simulation and 8030 128th Ave SE simulation.
Because of the topography of Newcastle,
vantage points should include locations on the
west and east boundaries of the route.
Included – 8030 128th Ave SE simulation looks to
the east and Lake Boren Park simulation looks to
the west.
Because of the topography of Newcastle,
vantage points should include vantage points to
the east of Coal Creek Parkway from which the
project would be visible.
Not included – the transmission line would not
be visible due to topography and the presence of
dense vegetation.
Houses that line Somerset Drive SE, all of which
will have the lines parallel to the view sides of the
houses.
Included – covered via the Somerset Drive SE
simulation.
Data Used to Assess Impacts to
the Aesthetic Environment
GIS Shapefiles:
- Parks (Bellevue, 2015; Newcastle,
2015; Renton, 2015; Issaquah, 2015;
Kirkland, 2015; Redmond, 2015; King
County, 2015b)
- Water Bodies (Ecology, 2014)
- Land Use (King County, 2015a)
- Land Cover (NOAA, 2011)
- Topography (King County, 2003b)
Public Comments
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APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Suggested Viewpoint Location Rationale behind why it
was or was not included
Newport Way at the driveway of Monthaven
Community.
Included – covered via the 13357 SE Newport
Way simulation.
Skyridge/College Hill and Sunset communities. Included – covered via the Skyridge Park (1990
134th Pl SE, Bellevue) simulation.
Skyridge hiking trail, which starts at the end of
134th Ave SE (dead end) and ends at the Skyridge
Park playground. This is a new trail and has views
of Richard's Valley, especially in the winter.
Included – covered via the Skyridge Park (1990
134th Pl SE, Bellevue) simulation.
Sunset Park should be considered for Route 2. Not included – Sunset Park was considered, but
a simulation was not created. The EIS Consultant
Team visited that portion of the site and
determined that the presence of dense vegetation
would reduce the likelihood that the project
would be visible. The substation simulation
provides a representative simulation.
Grand Connection just east of I-405 and the
viewing platform at the western edge of the
Bellevue Botanical Garden are two of these --
and high tension poles are unsightly.
Not included – There are no aesthetic guidelines
applicable to the project that are associated with
the Grand Connection. The Lake Hills Connector
simulation is considered to be sufficient for
representing the highest degree of adverse
aesthetic impacts in this portion of the study
area.
The viewing platform at the western edge of the
Bellevue Botanical Garden.
Not included – EIS Consultant Team visited the
site and confirmed that the project would not be
visible due to the topography and presence of
dense vegetation.
Residents east of 108th Street. Not included – outside of study area. Assume
commenter meant “108th Avenue.”
Residents in western Wilburton. Included – covered via NE 8th Street simulation.
Residents in the Spring District. Included - covered via Spring District simulation.
Residents looking east from the central business
district, west from Wilburton and southwest and
south from the Spring District.
Not included – outside of study area.
Drivers on I-405. Not included – outside of study area.
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APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Table C-6. Public Comments On Phase 2 Draft EIS that Requested Visual Simulations
Suggested Simulation Rationale behind why it
was or was not included
The west end of NE 42nd St, west of 140th Ave
between NE 40th St and NE 44th Pl.
Not included – topography and vegetation cover
along the Bellevue North Segment were
reassessed to identify another simulation
location, and 13508 NE 29th Pl, Bellevue, was
selected due to the relatively high amount of
potential vegetation removal and downhill
topography, resulting in the potential for a longer
line of sight.
More views from Bridle Trails. Included – additional simulation provided for
Bridle Trails. See 13508 NE 29th Pl, Bellevue,
simulation.
Somerset Hill North Panorama. Included – similar view covered via the 13300 SE
44th Pl, Bellevue simulation.
Somerset Hill South Panorama. Included – similar view covered via the 4411
Somerset Dr SE, Bellevue simulation.
Tyee Middle School Ballfield. Included – similar view covered via the 13630 SE
Allen Rd, Bellevue simulation.
Kelsey Creek Farm Included – similar view covered via the 703 130th
Pl SE, Bellevue simulation.
Forest Hill Park Included – similar view covered via the 13233 SE
51st Pl, Bellevue simulation.
Change in view of Mt. Rainier from homes along
the transmission line in Newcastle.
Not included – simulations were not used to
evaluate impacts to scenic views. They were
used to evaluate impacts to the aesthetic
environment. Impacts to scenic views were
evaluated using the GIS analysis described in
Section 7.
Outside of the 0.25-mile study area. Included – covered via the 703 130th Pl SE,
Bellevue simulation.
Shows telecommunications equipment. * Included – covered via the 13630 SE Allen Rd,
Bellevue simulation.
*Note: This simulation shows what it would look like if the cell equipment were placed in the middle wire zone. Appendix C‐2
includes a diagram that shows what it would look like if cellular equipment were to be placed above the wire zone
(approximately 10 feet higher than if it were placed in the middle wire zone).
Table C-7 provides the list of viewpoints used in the Final EIS, the segment they are viewing, and the
reasons supporting the selection of each viewpoint (i.e., unique natural or built environment or
scoping comment). Table C-8 provides a list of viewpoints that were used to inform the analysis, but
were not incorporated directly into the EIS. Figure C-4 shows all of the simulations created by Power
Engineers and their locations, and the simulations area included as Appendix C-3.
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APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
To the extent possible, these viewpoints were selected to align with visual simulations that had
already been completed for the project. The visual simulations were created by Power Engineers.
Their methods for creating the visual simulations are detailed in Appendix C-3. Power Engineers
collected photos using a full frame Canon 5D Mark II or III professional Digital Camera. All photos
were taken with a 50mm. lens. In some extreme foreground situations, a 28mm. lens may be used.
Power Engineers developed an existing conditions 3D Model of the study area, including terrain and
structures. The photos were registered into a 3D modeling program and 3D sun and atmosphere
conditions were applied based on notes taken when the photo was shot. Power Engineers then used
PLS-CAD model data (3D engineering designs developed for each transmission line structure)
provided by PSE to create a 3D rendering. Photoshop was used to create foreground screening
elements (e.g., trees, structures, etc.) (Power Engineers, 2016). For the Phase 2 Draft EIS, all of the
renderings show brown poles because it was determined that patina7 would be applied under all of
the segment options. However, for the Final EIS, galvanized (light gray), self-weathering (reddish
brown), or painted (powder coat) finishes are considered to be equally likely. Pole finishes could
vary throughout the project corridor and have not been decided at this point. Appendix C-3 provides
simulations showing galvanized steel and self-weathering steel poles for select viewpoints.
Utility Coherence
As a result, the assessment of visual coherence of the utility lines themselves focused primarily on
where the general pole types would change in each segment (i.e., where there would not be consistent
height and form). For this Final EIS, due to design refinements, there is a greater understanding of
what pole types would be used within each segment than was known during the Draft EIS. Because
of the greater diversity of pole types used within each segment, there is a higher likelihood of
inconsistent height and form (non-coherence). For the Final EIS, the following criteria were used to
determine utility coherence.
For identifying adverse impacts, the probability of impacts was highest for transitions from pairs of
single-circuit monopoles to one double-circuit because these two groups of configurations differ
more in height and form than so other transitions. If such transitions occur in locations at great
distances from each other, they are not considered to be significant because the inconsistency would
not be as noticeable to the viewer. However, if the change occurs in an area frequently within a short
distance, and occurs in a location with high viewer sensitivity, it has the potential to result in adverse
impacts due to visual clutter.
6.2 Viewer Sensitivity
The evaluation of viewer sensitivity was also based on FHWA guidance, and considered viewer
exposure and viewer awareness. Exposure considers the proximity, extent, and duration of views.
Awareness considers viewer attention and focus, and whether affected views are protected by policy,
regulation, or custom (FHWA, 2015). All viewers within the study area were considered to be close
to the project. Viewer extent is specific to each component because it depends on the number of
viewers impacted. This was assessed by identifying areas with higher residential density and
recreational resources that are heavily used. The viewer extent of residential viewers was determined
by assigning areas of high, medium, and low population density by assessing American Community
Survey 2014 Census block data on a segment-by-segment basis within the quarter-mile radius study
area (U.S. Census Bureau, 2014). Figure C-5 shows areas with high, medium, and low population
7 Patina is a film applied to the surface of metals that turns brown as oxidation occurs over long periods
of time.
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APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
density. The viewer extent of recreational users was assessed by identifying those recreation areas
(parks, trails, outdoor recreation facilities) that lie within the study area, and determining whether or
not the view or natural setting of the recreation areas is identified as a defining feature (based on
findings in the Phase 1 Draft EIS; see Table 11-1 in the Phase 1 Draft EIS, and the recreation
analysis in the Phase 2 Draft EIS; see Section 3.6)8. If a recreation area that is used for its views or
natural setting would be impacted, how frequently the recreation area is used was assessed. The
duration of views is consistent for all components, with residential viewers experiencing the longest
view duration due to their stationary nature and fixed views of the transmission line. Recreational
users have a shorter view duration that is confined to the time spent at the recreational resource, with
park users having longer view duration and trail users, who are more mobile, having shorter view
duration. Drivers would have the shortest view duration due to the speed at which they travel.
It was assumed that two groups were the most sensitive to changes in the aesthetic environment and
scenic views: residents and recreational users in parks and other recreational settings. These two
groups would have the greatest exposure to the project because they are often located near the project
and would observe the project for longer durations (particularly residential viewers). They would
also likely have the greatest awareness, given that these two types of viewers are most often
protected by city policies (Section 9).
Table C-7. List of Viewpoints and Rationale for Selection
Key
Viewpoint
(KVP)
Location Segment/ Option
Reason for selecting viewpoint
(Natural Environment or Built
Environment and why)
1 SE 30th St All Segments/ Options Shows the new substation when
taking into account grading and
clearing.
2 Redmond Way Redmond Representative of the natural
environment along the segment
(topography and vegetation).
Representative of the built
environment.
3 13540 NE 54th Pl Bellevue North Representative of the natural
environment along the segment
(topography and vegetation).
Representative of the built
environment (single-family residential
development; project configuration
and height for most of segment).
4 13508 NE 29th Pl Bellevue North Commenters requested another
simulation of the Bellevue North
Segment.
Shows a different pole configuration
than what would be typical.
8 Please note: the study area for the scenic views and aesthetic environment assessment is larger than
the study area used for the recreation analysis.
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APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Key
Viewpoint
(KVP)
Location Segment/ Option
Reason for selecting viewpoint
(Natural Environment or Built
Environment and why)
Shows an area where there is a bend
in the corridor, change in
topography, and where a higher
degree of vegetation removal would
be required than other areas of the
segment.
5 13606 Main St Bellevue Central Shows project from rise in
topography.
Is identified in the Wilburton Subarea
Plan as a key view.
6 13636 Main St Bellevue Central Shows project from rise in
topography, but from a side view.
Is identified in the Wilburton Subarea
Plan as a key view.
7 703 130th Pl SE Bellevue Central From Kelsey Creek Park.
Developed in response to comments
on the Phase 2 Draft EIS.
8 2160 135th Pl SE Bellevue Central Shows pole variation near substation.
9 4411 Somerset Dr
SE
Bellevue South Shows the project following the
ridge.
10 13300 SE 44th Pl Bellevue South Shows project looking east toward
Somerset from downhill.
11 4730 134th Pl SE Bellevue South Identified via public comment.
12 8446 128th Ave SE Newcastle – Options 1
and 2
Representative of the built
environment (single-family residential
development; project configuration
and height for entire segment).
Shows the project from the ridge
near the corridor.
13 Lake Boren Park Newcastle – Options 1
and 2
View from recreational use.
Shows the project from a lower
elevation looking up at the project.
14 1026 Monroe Ave
NE
Renton Shows project surrounded by
institutional and single-family
residences.
15 318 Glennwood
Court SE
Renton Shows project surrounded by single-
family residential development and
placed on a ridge.
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APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Table C-8. List of Other Simulations that Informed the Analysis
Location Segment/Option
13505 NE 75th St Redmond
267 140th Ave NE Bellevue Central
106 136th Ave SE Bellevue Central
13600 SE 5th St Bellevue Central
13633 SE 5th St Bellevue Central
13711 SE 18th St Bellevue Central
1990 134th Pl SE Bellevue Central
13630 SE Allen Rd Bellevue South
13744 SE Allen Rd Bellevue South
4411 137th Ave SE Bellevue South
4489 137th Ave SE Bellevue South
13233 SE 51st Pl Bellevue South
12727 SE 73rd Pl Newcastle – Options 1 and 2
SE 84th St Newcastle – Options 1 and 2
12732 SE 80th Way Newcastle – Options 1 and 2
7954 129th Pl SE Newcastle – Options 1 and 2
3000 NE 4th St Renton
FINAL EIS PAGE C‐17
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Figure C-4. Viewpoint Map
FINAL EIS PAGE C‐18
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Figure C-5. Population Density Map
FINAL EIS PAGE C‐19
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
7. IMPACTS TO SCENIC VIEWS
The assessment of impacts to scenic views was based the potential for view obstruction and the
FHWA concept of sensitivity to the impact (viewer sensitivity).
7.1 Scenic View Obstruction
A GIS analysis was conducted to identify areas from which a
portion of the proposed transmission line would obstruct the
view of an identified visual resource. This GIS analysis
identified where visual resources can be seen based on the
location and height of the visual resource and the topography
of the surrounding area. This area was further refined based
on a similar analysis that determined where the proposed
transmission line could be seen based on the location of the
segment, the proposed height of the poles, and the
surrounding topography. The outputs from these two analyses were overlaid to determine where the
project may impact scenic views. This is a conservative estimate that was qualitatively refined
through identification of barriers to views (dense tree stands, etc.).
For this analysis, the viewshed tool was also used. To determine the area where scenic views can be
observed, a process similar to the one used for the aesthetic environment study area was adopted.
However, for this analysis, visual resources were used as observation points and their unique offsets
were applied (Table C-9).
Table C-9. Visual Resources input into Viewshed Tool
Visual Resource Offset Applied
Mount Rainier Line of frontage at 14,411 feet (based on mountain height)
Cascade Mountain
Range
Line of frontage at 5,000 feet (based on Typical King County DEM data
height)
Issaquah Alps
(Cougar Mountain)
Line of frontage at 1,600 feet (based on Typical King County DEM data
height)
Lake Washington Line along the eastern shoreline at 20 feet above sea level
Lake Sammamish Line along the western shoreline at 30 feet above sea level
Seattle skyline Line of downtown frontage with a height of 650 feet (slightly higher than
Safeco Plaza)
Bellevue skyline Line encompassing downtown Bellevue at 460 feet (slightly higher than
Bellevue Towers Two)
To assess the areas that would be affected under different build scenarios, the heights of the existing
and proposed lines were “burned” into the DSM to identify which areas with scenic views are
already impacted by views of a transmission line and which areas with scenic views are not currently
impacted, but would be after construction of the project (Table C-10).
Key Changes from Phase 2
Draft EIS
Updated scenic view
obstruction analysis specific
to PSE’s Proposed Alignment.
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APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Table C-10. Existing and Proposed Maximum Pole Height by Segment
Segment
Existing Height Used
for the GIS Analysis
Height Used for the GIS
Analysis
Redmond 61’ 109'
Bellevue North 54’ 105'
Bellevue Central 56’ 113'
Bellevue South 60’ North of SE Allen Road (95’)
SE Allen Road to SE 43rd (103’)
SE 43rd to Somerset Substation (92’)
Somerset Substation (103’)
Somerset substation to SE 60th St
(108’)
SE 60th St to end of segment (92’)
Newcastle 55’ 97’
Renton 55’ 118’
Source: PSE, 2017.
To burn the lines into the DSM, a raster of the proposed alignment was created with a value of 0
assigned to everywhere except along the line, which was assigned a value equal to pole height
(specified in Table C-10). Then, using a raster calculator, the line height was burned into the DSM to
get a DSM+LINE (DLI) raster (Figure C-6).
Figure C-6. Factoring Line Heights
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APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
The following DLIs were created:
One DLI as if no lines were present.
One DLI where the existing transmission heights would be burned in.
One DLI with the heights for the Redmond, North Bellevue, Newcastle, and Renton
segments. These segments can be grouped into one DLI because there are no different pole
height options.
Four DLIs for the Bellevue South Segment options.
Three DLIs for bypass Bellevue Central Segment options.
Each of the DLIs was used as the ground raster for a viewshed analysis to identify where the scenic
resources would be viewable on the landscape, creating results for each pole height scenario. To
understand the areas where views would be negatively impacted by the project, areas where scenic
views are already impacted by the transmission line were subtracted from the area with scenic views
that would be impacted by the proposed transmission line.
Figure C-7 shows the output from the GIS analysis described above. Similar to the GIS analysis
conducted for the study area, some areas may have been identified as having scenic view impacts but
in reality should not have been included because the line would be so small that it is unrealistic that it
would be distinguishable on the horizon, or dense areas of tree stands were misinterpreted by the GIS
analysis as being a rise in topography from which views could be had (rather than being considered
hindrances to views). For areas where it was questionable if scenic views would actually be
impacted, a field survey was conducted to verify. In general, areas where potential scenic views were
identified had scenic views in the approximate vicinity; however, in some cases these views were
less frequent than may have been shown by the analysis depending on the presence of dense
vegetation. The only area that was completely eliminated from consideration was where scenic views
were identified in the Liberty Ridge area. A field visit conducted on October 7, 2016 confirmed that
scenic views from that location were not present due to the topography of the area. The EIS
Consultant Team believes that the reason the GIS analysis identified this area as an area with
potential scenic view impacts was because the DSM used was from 2002/2003. Since that time,
significant grading has occurred to support development of the Liberty Ridge neighborhood. These
changes to the topography are thought to have resulted in the loss of scenic views.
7.2 Viewer Sensitivity
Viewer sensitivity was evaluated as described in Section 6.2.
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APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Figure C-7. Potential Areas Where Scenic Views May Be Impacted
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APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
8. THRESHOLD OF SIGNIFICANCE
The value of scenic views and the aesthetic environment is subjective, making it difficult to quantify
or estimate impacts. There is no widely accepted definition of significant visual effects because the
significance of an activity varies with the setting and viewer preferences. For this project,
significance was determined based on criteria similar to those described in The State Clean Energy
Program Guide: A Visual Impact Assessment Process for Wind Energy Projects (Vissering et al.,
2011). These criteria, while not developed for transmission lines, were used for wind turbines, which
can be similar in height and scale to utility poles and are widely studied for visual impacts. This
guide suggests that the following criteria be considered when determining if a project would result in
undue or unreasonable visual impacts: violation of aesthetic standards, dominance of the project in
views from highly sensitive viewing areas, and failure to take reasonable mitigation measures
(Vissering et al., 2011).
A review of policies and regulations applicable to the study area revealed that the existing regulatory
framework was insufficient for determining significance because no clear written standards are
included for impacts to scenic views or the aesthetic environment.
To develop a threshold for significance that reflects the policies of the Partner Cities, the EIS
Consultant Team held a workshop in August 2016 with staff from the Partner Cities that would
potentially experience scenic view or aesthetic impacts (Redmond, Bellevue, Newcastle, and
Renton). The purpose of the workshop was to collaboratively define significance thresholds based on
policies, past precedent, and practice within the Partner City jurisdictions.
During the workshop, city staff were provided with the following:
A map showing where scenic views would be impacted along the entire corridor.
Visual simulations showing key examples of how the project could change the aesthetic
environment.
A handout with each city’s applicable policies and regulations.
The EIS Consultant Team walked through examples for each segment/option, and the group as a
whole refined a set of significance criteria. The following significance criteria were adopted for the
EIS evaluation and incorporate findings from the Partner Cities workshop:
Less-than-Significant:
Aesthetic environment - The degree of contrast between the project and the existing
aesthetic environment would be minimal, or viewer sensitivity is low.
Scenic views - The area with impacted scenic views would not include a substantial number
of sensitive viewers, including residential viewers, viewers from parks and trails, or viewers
from outdoor recreation facilities; or the degree of additional obstruction of views compared
to existing conditions would be minimal.
FINAL EIS PAGE C‐24
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Significant:
Aesthetic environment - The degree of contrast between the project and the existing
aesthetic environment would be substantial and viewer sensitivity is high.
Scenic views - The area with scenic views impacted includes a substantial number of
sensitive viewers, including residential viewers, viewers from parks and trails, or viewers
from outdoor recreation facilities; and the degree of additional obstruction of views compared
to existing conditions would be substantial.
It was agreed that significant impacts should be assigned on a sub-option level.
FINAL EIS PAGE C‐25 APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018 9. SUMMARY OF PLANNING POLICIES AND CODE REQUIREMENTS Table C-11. Planning Policies and Code Requirements Plans Protected Views and Visual Resources Guidance for Reducing Visual Impacts Redmond Vision 2030 City of Redmond Comprehensive Plan Views of Mount Rainier, the Cascade Mountains, and Lake Sammamish. N/A Unique public views that provide a sense of place N/A Scenic, public view corridors toward the Cascades and the Sammamish Valley (Plan Policy NR-10). N/A Views of surrounding hillsides, mountains, and tree line N/A Tree stands and views from the valley (Plan Policy N-SV-4) N/A Woodland views from neighborhood residences N/A N/A Throughout the plan, landscaping is encouraged to provide aesthetic value, unify site design, and soften or disguise “less aesthetically pleasing features of a site” (Policy CC-23). The Plan requires “reasonable screening or architecturally compatible design of above ground utility facilities, such as transformers and associated vaults” (Policy UT-15). It suggests promoting well-designed utility facilities through use of color, varied and interesting materials, art work, and superior landscape design. Key Changes from Phase 2 Draft EIS Policies updated to reflect the revised study area.
FINAL EIS PAGE C‐26 APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018 Plans Protected Views and Visual Resources Guidance for Reducing Visual Impacts Redmond Zoning Code (RZC) Current through June 16, 2015 Appearance of Public Ways Underground electrical facilities if economically-feasible (RZC 21.17). Public view corridors and gateways should be protected (RZC 21.42) N/A Bellevue Bellevue Comprehensive Plan 2015 Urban design that exemplifies a “City in a Park” with tree-lined streets, public art, vast parks, natural areas, wooded neighborhoods, two large lakes, and mountain views. N/A Views of water, mountains, and skylines from public places (Plan Policy UD-62). Link increased intensity of development with increased view preservation (Plan Policy UD-48). N/A Implement new and expanded transmission and substation facilities in such a manner that they are compatible and consistent with the local context and the land use pattern established in the Comprehensive Plan (Plan Policy UT-95). N/A Conduct a siting analysis for new facilities and expanded facilities at sensitive sites (areas in close proximity to residentially-zoned districts) (Plan Policy UT-96). N/A States preference for use of new technology to reduce visual impacts. Green belts and open spaces per Parks and Open Space System Plan. Avoid locating overhead lines in greenbelts or open spaces (Plan Policy UT-69). Distinctive neighborhood character within Bellevue’s diverse neighborhoods (Plan Policy N-9). Design, construct, and maintain facilities to minimize their impact on surrounding neighborhoods (Plan Policy UT-8).
FINAL EIS PAGE C‐27 APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018 Plans Protected Views and Visual Resources Guidance for Reducing Visual Impacts Design boulevards adjacent to parks, natural areas and open spaces to reflect scenic elements of the surrounding areas and neighborhoods. Streetscape design should promote a safe and comfortable park-like experience for all users (Plan Policy UD-70). This includes: Bel-Red Road Lake Hills Connector Coal Creek Parkway SE Newport Way N/A Bridle Trails Subarea Plan 2015 Wooded, natural, rural, and equestrian character of the Subarea (Plan Policy S-BT-3). N/A N/A Encourage retention of vegetation on the lower slopes of the bluff adjacent to SR 520 at approximately 136th Avenue NE to provide a visual separator between residential areas and the freeway (Plan Policy S-BT-42).* Roadsides in Bridle Trails Subarea. Improve roadsides to create a unified visual appearance (Plan Policy S-BT-43). Bel-Red Subarea Plan 2015 Bel-Red Subarea street environment (Plan Policy S-BR-25; S-BR-39; S-BR-59). N/A Bel-Red Subarea parks and open space system (Plan Policy S-BR-35). N/A Wilburton/NE 8th St Subarea Plan 2015 N/A Utilities should be provided to serve the present and future needs of the Subarea in a way that enhances the visual quality of the community (where practical) (Plan Policy S-WI-44) Significant views from park lands (Plan Policy S-WI-11) N/A
FINAL EIS PAGE C‐28 APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018 Plans Protected Views and Visual Resources Guidance for Reducing Visual Impacts Views of prominent landforms, vegetation, watersheds, drainage ways, Downtown and significant panoramas in the Subarea (Plan Policy S-WI-40). Key views include: From SE 1st Street and Main Street at the power line right-of-way at 136th Avenue. N/A Southeast Bellevue Subarea Plan 2015 Existing residential character (Plan Policy S-SE-2) N/A Richards Valley Subarea Plan 2015 Views of the wooded areas and wetlands in the valley. Retain the remaining wetlands within the 100-year floodplain along Richards Creek and Kelsey Creek for the aesthetic value and character of the community (Plan Policy S-RV-5). Develop sites in accordance with Sensitive Areas Regulations (Plan Policy S-RV-12). N/A Use common corridors for new utilities if needed (Plan Policy S-RV-20). N/A New development, should install a dense visual vegetative screen along Richards Road (Plan Policy S-RV-31). Eastgate I-90 Corridor Encourage site design that includes visibly recognizable natural features such as green walls, façade treatments, green roofs, and abundant natural landscaping (Plan Policy S-RV-24). Streets and arterials Disturb as little of the natural character as possible when improving streets and arterials (Plan Policy S-RV-26).
FINAL EIS PAGE C‐29 APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018 Plans Protected Views and Visual Resources Guidance for Reducing Visual Impacts Eastgate Subarea Plan 2015 View amenities of adjacent single-family neighborhoods (Plan Policy S-EG-22). N/A N/A Discourage new development from blocking existing views from public spaces (Plan Policy S-EG-23). Factoria Subarea Plan 2015 Natural setting for residential areas N/A Cohesiveness and compatibility of commercial districts Manage change in the commercial district N/A Protect single family neighborhoods from encroachment by more intense uses (Plan Policy S-FA-2). Pathways and access points with views of Sunset Creek, Richards Creek, Coal Creek, (Plan Policy S-FA-18). N/A Visual connections along Factoria Boulevard(Plan Policy S-FA-32). N/A N/AMinimize disruptive effects of utility construction on property owners, motorists, and pedestrians (Plan Policy S-FA-35). Newport Hills Subarea Plan 2015 Emphasize as a distinct visual element thepreservation of existing trees on protected slopes and hilltops (Plan Policy S-NH-44). Use these trees to screen incompatible land uses. N/AMake edges between different land uses distinct without interfering with security or visual access (Plan Policy S-NH-48). Existing visual features such as trees andhilltops, views of water, and passive open space (Plan Policy S-NH-54). N/A Bellevue City Code Current through August 3, 2015 N/A Electrical utility facilities shall be sight-screened through landscaping and fencing (BCC 20.20.255.F).
FINAL EIS PAGE C‐30 APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018 Plans Protected Views and Visual Resources Guidance for Reducing Visual Impacts Newcastle City of Newcastle 2035 Comprehensive Plan Existing character, scale, and neighborhood quality (Plan Policy LU-G3). N/A Open space, wildlife habitats, recreational areas, trails, connection of critical areas, natural and scenic resources, as well as shoreline areas (Plan Policy LU-G6). N/A Natural features that contribute to the City’s scenic beauty (Plan Policy LU-G8). N/A N/A The City shall promote collocation of major utilitytransmission facilities such as high voltage electrical transmission lines and water and natural gas trunk pipe lines within shared utility corridors, to minimize the amount of land allocated for this purpose and the tendency of such corridors to divide neighborhoods (Plan Policy UT-P3). N/A The City shall encourage utility providers to limitdisturbance to vegetation within major utility transmission corridors to what is necessary for the safety and maintenance of transmission facilities (Plan Policy UT-P8). N/A The City should encourage utility providers to exerciserestraint and sensitivity to neighborhood character in planting appropriate varieties and trimming tree limbs around aerial lines (Plan Policy UT-P9). N/A The City should require utility providers to design andconstruct overhead transmission lines in a manner that is environmentally sensitive, safe, and aesthetically compatible with surrounding land uses (Plan Policy UT-P10). N/A The City should require utility providers to minimize visualand other impacts of transmission towers and overhead transmission lines on adjacent land uses through careful siting and design (Plan Policy UT-P14).
FINAL EIS PAGE C‐31 APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018 Plans Protected Views and Visual Resources Guidance for Reducing Visual Impacts N/A The City should require new, modified, or replacementtransmission structures (such as lattice towers, monopoles, and the like) to be designed to minimize aesthetic impacts appropriate to the immediate surrounding area whenever practical (Plan Policy UT-P16). N/A The City shall, where appropriate, require reasonablelandscape screening of site-specific above-ground utility facilities in order to diminish visual impacts (Plan Policy UT-P20). N/A Design and operate regional utility facilities to minimize impacts on the surrounding uses, the environment, and the city (NMC 18.44.052.C.1). N/A Work with the City of Newcastle to adopt any conditions imposed relating to the location, development, design, use, or operation of a utility facility to mitigate environmental, public safety, or other identifiable impacts. Mitigation measures may include, but are not limited to, natural features that may serve as buffers, or other site design elements such as fencing and site landscaping (NMC 18.44.052.D). Newcastle Municipal Code (NMC) Current through September 19, 2017 N/A Design and operate regional utility facilities to minimize impacts on the surrounding uses, the environment, and the city (NMC 18.44.052.C.1). High volume of trees and clear mountain views. N/A
FINAL EIS PAGE C‐32 APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018 Plans Protected Views and Visual Resources Guidance for Reducing Visual Impacts Renton City of Renton Comprehensive Plan (2015) Accommodate change within the Renton community in a way that maintains Renton’s livability and natural beauty (Plan Policy L-48). Public scenic views and public view corridors, such as “physical, visual, and perceptual linkages to Lake Washington and Cedar River” (Plan Policy L-55). N/A Natural forms, vegetation, distinctive stands of trees, natural slops, and scenic areas that “contribute to the City’s identity, preserve property values, and visually define the community neighborhoods” (Plan Policy L-56). N/A Lakes and shorelines. N/A Views of the water from public property or views enjoyed by a substantial number of residences. N/A N/A Design shoreline developments to maintain or enhance aesthetic values and scenic views (Plan Policy SH-16). N/A Ensure the siting and location of transmission is accomplished in a manner that minimizes adverse impacts on the environment and adjacent land uses (Plan Policy U-72). N/A Make facility improvements and additions within existing corridors wherever possible (Plan Policy U-73). Shoreline Design shoreline use and development to maintain shoreline scenic and aesthetic qualities derived from natural features, such as shore forms and vegetative cover (RMC 4-3-090.D.3.a).
FINAL EIS PAGE C‐33 APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018 Plans Protected Views and Visual Resources Guidance for Reducing Visual Impacts N/A Prohibits utilities in the Shoreline Natural shoreline environment designation (RMC 4-3-090.E.1). City of Renton Municipal Code (RMC) Current through November 16, 2015 N/A Visual prominence of structures must be minimized, including light, glare, and reflected light (RMC 4-3-090.D.3.b.vii). N/A Aboveground utilities must be screened with masonry, decorative panels, and/or evergreen trees, shrubs, and landscaping sufficient to form an effective sight barrier within a period of five (5) years (RMC 4-6-090.11.a.xvi). City of Renton SMP 2011 Scenic and aesthetic qualities derived from natural features of the shoreline, such as vegetative cover and shore forms (Ordinance No. 5633). N/A Note: * There is a discrepancy as to whether this street is called 136th Avenue NE or 136th Place NE. For the purposes of this EIS, the location is described as 136th Avenue NE, for consistency with the City of Bellevue policy.
FINAL EIS PAGE C‐34
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
10. REFERENCES
City of Bellevue. 2015. Parks GIS Data.
City of Issaquah. 2015. Parks GIS Data.
City of Kirkland. 2015. Parks GIS Data.
City of Newcastle. 2015. Parks GIS Data.
City of Redmond. 2015. Parks GIS Data.
City of Renton. 2015. Parks GIS Data.
Ecology (Washington State Department of Ecology). 2014. Water Resources GIS Data.
ESRI. 2016. Using Viewshed and Observer Points for visibility analysis.
http://pro.arcgis.com/en/pro-app/tool-reference/3d-analyst/using-viewshed-and-observer-
points-for-visibility.htm.
FHWA (Federal Highway Administration). 2015. Guidelines for the Visual Impact Assessment of
Highway Projects.
GIS Geography. 2016. DEM, DSM, DTM Differences. http://gisgeography.com/dem-dsm-dtm-
differences/.
King County. 2003a. King County 2002/2003 Digital Surface Model (DSM).
King County. 2003b. King County 100-foot contours. GIS Data.
King County. 2015a. 2012 Assessor Real Property Data and 2015 Parcel Data, updated July 10,
2015.
King County. 2015b. Parks GIS Data.
NOAA (National Oceanic and Atmospheric Administration). 2011. LandCoverClip.tif. GIS Data.
PSE (Puget Sound Energy). 2016a. Segment Alignment GIS Data. Provided to ESA in June 2016.
PSE (Puget Sound Energy). 2016b. Segment Data Table. Provided to ESA on July 15, 2016.
PSE (Puget Sound Energy). 2017. Email from Bradley Strauch, Energize Eastside Project Manager,
PSE, to Reema Shakra and Mark Johnson, ESA. August 23, 2017.
Power Engineers. 2016. Energize Eastside Photo Simulation Methodology. Memorandum from Jason
Pfaff, Department Manager, to Puget Sound Energy. June 10, 2016.
Power Engineers. 2017. Visual simulations of the Energize Eastside project. Prepared for PSE,
Bellevue, WA; prepared by Power Engineers, Kent, WA; provided to ESA, Seattle, WA.
Various dates, July through September 2017.
The Watershed Company. 2016. GIS Dataset Labeled as twc_ee_veg_impact_results_20160914.
September 14, 2016.
FINAL EIS PAGE C‐35
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
The Watershed Company. 2017. GIS Dataset Labeled as 2017-12-15 Data for EIS Consultant.
December 15, 2017.
U.S. Census Bureau. 2014. Total Population, 2010–2014 American Community Survey 5-Year
Estimates.
Available: http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=
ACS_10_5YR_B01003&prodType=table. Accessed: Aug. 16, 2016.
Vissering, Jean; Mark Sinclair; and Anne Margolis. 2011. State Clean Energy Program Guide: A
Visual Impact Assessment Process for Wind Energy Projects. Clean Energy States Alliance.
May 2011.
FINAL EIS PAGE C‐36
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
APPENDIX C-2. REPRESENTATIVE DIAGRAMS
(provided by PSE)
Diagram 1. Diameter of Existing Wire and Proposed Wire
FINAL EIS PAGE C‐37
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
Diagram 2. Cellular Equipment Above the Wire Zone
FINAL EIS PAGE C‐38
APPENDIX C SCENIC VIEWS AND AESTHETIC ENVIRONMENT METHODOLOGY MARCH 2018
APPENDIX C-3. VISUAL SIMULATIONS
● Central 18 (updated)
● Central 15 (updated) ● Central 30 (updated)
● South 25 Segment 2 (updated)
●South 24 (updated)
● South 19 (updated)
● South 12 (updated)
South 23 ● (updated)
Central 3 (updated) ●
● North 3 (updated)
● Richards Creek Sub (updated)
● South 24 Segment 2 (updated)
● South 20 (updated) ● South 21 (updated)
● South 26 (updated)
South 27 (updated) ●
● North 15 (new)
● North 16 (updated)
Central 37 ● (new)
Central 40 (new)●
● Central 38 (updated)
● Central 39 (new)
South 25 (updated)●
Central 20 (updated) ● ● Central 21 (updated)
● Central 22 (updated)
● Central 28 (updated)
● Central 31 (updated)
● Central 32 (updated)
● Central 4 (updated)
● Central 5 (updated)
● North 14 (updated)
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
8/4/2017
Conceptual Project
Time
Viewing Direction
Date
Address
2:59 PM
Northwest
3/8/2016
Redmond Way, Redmond
Existing Pole Heights ~50 feet
Proposed Pole Heights ~100 feet
1
KOP
SEGMENT
NORTH 15
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
Conceptual Project
8/22/2017
KOP NORTH 14Time
Viewing Direction
Date
Address
2:41 PM
South
3/8/2016
13505 NE 75th St, Redmond
Existing Pole Heights ~75 feet
Proposed Pole Heights ~100 feet
SEGMENT 1
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
Conceptual Project
8/30/2017
KOP NORTH 14Time
Viewing Direction
Date
Address
2:41 PM
South
3/8/2016
13505 NE 75th St, Redmond
Existing Pole Heights ~75 feet
Proposed Pole Heights ~100 feet
SEGMENT 1
Photo si mulations are for discussion purposes only
and may change pending public, re gul atory and utility review
Existing Conditions
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review 7/7/2017
Conceptual Project
Time
Viewing Direction
Date
Address
10:49 AM
North
3/31/2014
13540 NE 54th Pl, Bellevue
Existing Pole Heights ~55 feet
Proposed Pole Heights ~90 feet
1
KOP
SEGMENT
NORTH 3
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
8/10/2017
Conceptual Project
Time
Viewing Direction
Date
Address
11:38 AM
South
7/24/2017
13508 NE 29th Pl, Bellevue
Existing Pole Heights ~55 feet
Proposed Pole Heights ~100 feet
1
KOP
SEGMENT
NORTH 16
Existing Conditions
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Conceptual Project
Time
Viewing Direction
Date
Address
10:40 AM
North
5/13/2016
267 140th Ave NE, Bellevue
1
KOP
SEGMENT
CENTRAL 22
Existing Pole Heights ~60 feet
Proposed Pole Heights ~90 feet
8/22/2017
Existing Conditions
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Conceptual Project
1
KOP
SEGMENT
CENTRAL 20
8/22/2017
Time
Viewing Direction
Date
Address
3:52 PM
North
3/30/2016
13606 Main St, Bellevue
Existing Pole Heights ~50 feet
Proposed Pole Heights ~95 feet
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
Conceptual Project
CENTRAL 31KOP
8/22/2017
SEGMENT 1
Time
Viewing Direction
Date
Address
12:02 PM
West
9/12/2016
13636 Main St, Bellvue
Existing Pole Heights ~55 feet
Proposed Pole Heights ~95 feet
Existing Conditions
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Conceptual Project
1
KOP
SEGMENT
CENTRAL 21
8/22/2017
Time
Viewing Direction
Date
Address
3:48 PM
South
3/30/2016
106 136th Ave, Bellevue
Existing Pole Heights ~75 feet
Proposed Pole Heights ~100 feet
Existing Conditions
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Conceptual Project
7/7/2017
Time
Viewing Direction
Date
Address
2:54 PM
North
4/2/2014
13600 SE 5th St, Bellevue
Existing Pole Heights ~60 feet
Proposed Pole Heights ~100 feet
1
KOP
SEGMENT
CENTRAL 3
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
8/22/2017
Conceptual Project
KOP CENTRAL 32
SEGMENT 1
Time
Viewing Direction
Date
Address
12:12 PM
West
9/12/2016
13633 SE 5th St, Bellevue
Existing Pole Heights ~55 feet
Proposed Pole Heights ~100 feet
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
8/4/2017
Conceptual Project
Time
Viewing Direction
Date
Address
1:40 PM
East
7/24/2017
703 130th Pl SE, Bellevue
Existing Pole Heights ~75 feet
Proposed Pole Heights ~90 feet
1
KOP
SEGMENT
CENTRAL 37
Existing Conditions
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Conceptual Project
Time
Viewing Direction
Date
Address
3:19 PM
West
4/2/2014
13711 SE 18th St, Bellevue
1
KOP
SEGMENT
CENTRAL 4
Existing Pole Heights ~55 feet
Proposed Pole Heights ~95 feet
8/22/2017
Existing Conditions
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Conceptual Project
KOP CENTRAL 28
SEGMENT 1
8/22/2017
Time
Viewing Direction
Date
Address
3:22 PM
South
3/30/2016
1990 134th Pl SE, Bellevue
Existing Pole Heights ~55 feet
Proposed Pole Heights ~90 feet
Photo simulations are for discussion purposes only and may change pending public, regulatory and utility review
Existing Conditions
Conceptual Project
Time
Viewing Direction
Date
Address
4:00 PM
Southeast
3/31/2014
2160 135th Pl SE, Bellevue
1
KOP
SEGMENT
CENTRAL 5
Existing Pole Heights ~55 feet
Proposed Pole Heights ~100 feet
9/6/2017
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
8/22/2017
Conceptual Project
Time
Viewing Direction
Date
Address
1:23 PM
East
7/24/2017
13440 SE 30th St, Bellevue
Existing Pole Heights ~65-70 feet
Proposed Pole Heights ~70-100 feet
SUBSTATION
Richards Creek
Photo simulations are for discussion purposes only and may change pending public, regulatory and utility review
Existing Conditions
11/30/2017
Conceptual Project
KOP SOUTH 24Time
Viewing Direction
Date
Address
1:44 PM
Northeast
3/30/2016
13630 SE Allen Rd, Bellevue
Existing Pole Heights ~60 feet
Proposed Pole Heights ~95 feet
SEGMENT 2
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 25Time
Viewing Direction
Date
Address
1:42 PM
Northeast
3/30/2016
13744 SE Allen Rd, Bellevue
Existing Pole Heights ~65 feet
Proposed Pole Heights ~90 feet
SEGMENT 2
KOP CENTRAL 18
Time
Viewing Direction
Date
Address
10:53 AM
Northwest
5/7/2014
4411 137th Ave SE, Bellevue
Existing Pole Heights ~55 feet
Proposed Pole Heights ~80 feet
SEGMENT 2
7/6/2017
KOP CENTRAL 18
Time
Viewing Direction
Date
Address
10:53 AM
Northwest
5/7/2014
4411 137th Ave SE, Bellevue
Existing Pole Heights ~55 feet
Proposed Pole Heights ~80 feet
SEGMENT 2
7/6/2017
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
8/4/2017
Conceptual Project
Time
Viewing Direction
Date
Address
2:05 PM
East
7/24/2017
13300 SE 44th Pl, Bellevue
Existing Pole Heights ~55 feet
Proposed Pole Heights ~75 feet
2
KOP
SEGMENT
CENTRAL 40
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
8/4/2017
Conceptual Project
Time
Viewing Direction
Date
Address
9:26 AM
South
7/24/2017
4411 Somerset Dr SE, Bellevue
Existing Pole Heights ~55 feet
Proposed Pole Heights ~75 feet
2
KOP
SEGMENT
CENTRAL 39
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
2
7/6/2017
Conceptual Project
KOP
SEGMENT
CENTRAL 15Time
Viewing Direction
Date
Address
9:32 AM
North
4/10/2014
4489 137th Ave SE, Bellevue
Existing Pole Heights ~55 feet
Proposed Pole Heights ~80 feet
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
2
7/6/2017
Conceptual Project
KOP
SEGMENT
CENTRAL 15Time
Viewing Direction
Date
Address
9:32 AM
North
4/10/2014
4489 137th Ave SE, Bellevue
Existing Pole Heights ~55 feet
Proposed Pole Heights ~80 feet
Existing Conditions
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Conceptual Project
7/13/2017
Time
Viewing Direction
Date
Address
3:28 PM
West
8/24/2016
4730 134th Place SE, Bellevue
KOP CENTRAL 30
Existing Pole Heights ~44 feet
Proposed Pole Heights ~75 feet
SEGMENT 2
Existing Conditions
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Conceptual Project
7/13/2017
Time
Viewing Direction
Date
Address
3:28 PM
West
8/24/2016
4730 134th Place SE, Bellevue
KOP CENTRAL 30
Existing Pole Heights ~44 feet
Proposed Pole Heights ~75 feet
SEGMENT 2
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
8/4/2017
Conceptual Project
Time
Viewing Direction
Date
Address
2:21 PM
Northwest
7/24/2017
13233 SE 51st Pl, Bellevue
Existing Pole Heights ~55 feet
Proposed Pole Heights ~65 feet
2
KOP
SEGMENT
CENTRAL 38
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 20Time
Viewing Direction
Date
Address
11:42 AM
South
3/8/2016
12727 SE 73rd Pl, Newcastle
Existing Pole Heights ~55 feet
Proposed Pole Heights ~85 feet
SEGMENT 3
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
10/18/2017
Conceptual Project
KOP SOUTH 20Time
Viewing Direction
Date
Address
11:42 AM
South
3/8/2016
12727 SE 73rd Pl, Newcastle
Existing Pole Heights ~55 feet
Proposed Pole Heights ~75 feet
SEGMENT 3
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
10/16/2017
Conceptual Project
KOP SOUTH 20Time
Viewing Direction
Date
Address
11:42 AM
South
3/8/2016
12727 SE 73rd Pl, Newcastle
Existing Pole Heights ~55 feet
Proposed Pole Heights ~85 feet
SEGMENT 3
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 20Time
Viewing Direction
Date
Address
11:42 AM
South
3/8/2016
12727 SE 73rd Pl, Newcastle
Existing Pole Heights ~55 feet
Proposed Pole Heights ~75 feet
SEGMENT 3
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 25
SEGMENT 3
Time
Viewing Direction
Date
Address
5:28 PM
Southeast
9/12/2016
12732 SE 80th Way, Newcastle
Existing Pole Heights ~52 feet
Proposed Pole Heights ~95 feet
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 25
SEGMENT 3
Time
Viewing Direction
Date
Address
5:28 PM
Southeast
9/12/2016
12732 SE 80th Way, Newcastle
Existing Pole Heights ~52 feet
Proposed Pole Heights ~95 feet
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 25
SEGMENT 3
Time
Viewing Direction
Date
Address
5:28 PM
Southeast
9/12/2016
12732 SE 80th Way, Newcastle
Existing Pole Heights ~52 feet
Proposed Pole Heights ~80 feet
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 25
SEGMENT 3
Time
Viewing Direction
Date
Address
5:28 PM
Southeast
9/12/2016
12732 SE 80th Way, Newcastle
Existing Pole Heights ~52 feet
Proposed Pole Heights ~80 feet
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
10/18/2017
Conceptual Project
KOP SOUTH 25
SEGMENT 3
Time
Viewing Direction
Date
Address
5:28 PM
Southeast
9/12/2016
12732 SE 80th Way, Newcastle
Existing Pole Heights ~52 feet
Proposed Pole Heights ~80 feet
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 21Time
Viewing Direction
Date
Address
11:20 AM
Southwest
3/8/2016
Lake Boren Park, Newcastle
Existing Pole Heights ~50 feet
Proposed Pole Heights ~95 feet
SEGMENT 3
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 21Time
Viewing Direction
Date
Address
11:20 AM
Southwest
3/8/2016
Lake Boren Park, Newcastle
Existing Pole Heights ~50 feet
Proposed Pole Heights ~80 feet
SEGMENT 3
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
11/6/2017
Conceptual Project
KOP SOUTH 21Time
Viewing Direction
Date
Address
11:20 AM
Southwest
3/8/2016
Lake Boren Park, Newcastle
Existing Pole Heights ~50 feet
Proposed Pole Heights ~80 feet
SEGMENT 3
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 27
SEGMENT 3
Time
Viewing Direction
Date
Address
10:48 AM
Southwest
1/5/2017
7954 129th Pl SE, Newcastle
Existing Pole Heights ~52 feet
Proposed Pole Heights ~95 feet
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 27
SEGMENT 3
Time
Viewing Direction
Date
Address
10:48 AM
Southwest
1/5/2017
7954 129th Pl SE, Newcastle
Existing Pole Heights ~52 feet
Proposed Pole Heights ~85 feet
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
11/6/2017
Conceptual Project
KOP SOUTH 27
SEGMENT 3
Time
Viewing Direction
Date
Address
10:48 AM
Southwest
1/5/2017
7954 129th Pl SE, Newcastle
Existing Pole Heights ~52 feet
Proposed Pole Heights ~85 feet
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/7/2017
Conceptual Project
KOP SOUTH 19Time
Viewing Direction
Date
Address
10:28 AM
South
3/8/2016
SE 84th St, Newcastle
Existing Pole Heights ~55 feet
Proposed Pole Heights ~95 feet
SEGMENT 3
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/7/2017
Conceptual Project
KOP SOUTH 19Time
Viewing Direction
Date
Address
10:28 AM
South
3/8/2016
SE 84th St, Newcastle
Existing Pole Heights ~55 feet
Proposed Pole Heights ~85 feet
SEGMENT 3
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
10/18/2017
Conceptual Project
KOP SOUTH 19Time
Viewing Direction
Date
Address
10:28 AM
South
3/8/2016
SE 84th St, Newcastle
Existing Pole Heights ~55 feet
Proposed Pole Heights ~85 feet
SEGMENT 3
KOP SOUTH 26
Time
Viewing Direction
Date
Address
2:24 PM
Northeast
1/5/2017
8446 128th Ave SE, Newcastle
Existing Pole Heights ~55 feet
Proposed Pole Heights ~95 feet
SEGMENT 3
7/13/2017
KOP SOUTH 26
Time
Viewing Direction
Date
Address
2:24 PM
Northeast
1/5/2017
8446 128th Ave SE, Newcastle
Existing Pole Heights ~55 feet
Proposed Pole Heights ~95 feet
SEGMENT 3
7/13/2017
KOP SOUTH 26
Time
Viewing Direction
Date
Address
2:24 PM
Northeast
1/5/2017
8446 128th Ave SE, Newcastle
Existing Pole Heights ~55 feet
Proposed Pole Heights ~85 feet
SEGMENT 3
7/13/2017
KOP SOUTH 26
Time
Viewing Direction
Date
Address
2:24 PM
Northeast
1/5/2017
8446 128th Ave SE, Newcastle
Existing Pole Heights ~55 feet
Proposed Pole Heights ~85 feet
SEGMENT 3
7/13/2017
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/7/2017
Conceptual Project
Time
Viewing Direction
Date
Address
3:07 PM
North
4/1/2014
1026 Monroe Ave NE, Renton
Existing Pole Heights ~55 feet
Proposed Pole Heights ~90 feet
3
KOP
SEGMENT
SOUTH 12
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/7/2017
Conceptual Project
Time
Viewing Direction
Date
Address
3:07 PM
North
4/1/2014
1026 Monroe Ave NE, Renton
Existing Pole Heights ~55 feet
Proposed Pole Heights ~90 feet
3
KOP
SEGMENT
SOUTH 12
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 23
SEGMENT 3
Time
Viewing Direction
Date
Address
1:55 PM
North
3/8/2016
3000 NE 4th St, Renton
Existing Pole Heights ~65 feet
Proposed Pole Heights ~90 feet
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 23
SEGMENT 3
Time
Viewing Direction
Date
Address
1:55 PM
North
3/8/2016
3000 NE 4th St, Renton
Existing Pole Heights ~65 feet
Proposed Pole Heights ~90 feet
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 24 - W
SEGMENT 3
Time
Viewing Direction
Date
Address
10:20 AM
North
8/24/2016
318 Glennwood Ct SE, Renton
Existing Pole Heights ~50-70 feet
Proposed Pole Heights ~75 feet
Photo simul ati ons are for discussion purpose s onl y and may change pending public, re gul atory and utility review
Existing Conditions
7/13/2017
Conceptual Project
KOP SOUTH 24 - G
SEGMENT 3
Time
Viewing Direction
Date
Address
10:20 AM
North
8/24/2016
318 Glennwood Ct SE, Renton
Existing Pole Heights ~50-70 feet
Proposed Pole Heights ~75 feet
Appendix D:
Critical Areas Regulations
D
FINAL EIS PAGE D‐1 APPENDIX D CRITICAL AREAS REGULATIONS BY CITY MARCH 2018 APPENDIX D. CRITICAL AREAS REGULATIONS BY CITY City/County Critical Area Description Mitigation City of Redmond (Redmond Zoning Code (RZC) Section 21.64.010) General (applicable to all critical areas) Utility installation, construction, and associated facilities and lines are exempt from CAO regulations if located in City road ROWs and are subject to restoration. If not exempt, then utilities project (facilities and poles) are prohibited from locating in critical areas but are allowed in critical area buffers provided mitigation standards are met. Mitigation is required (for all critical areas) to be provided on-site, in-kind if feasible. If not feasible, then off-site (within Redmond city limits), out-of-kind mitigation may be considered. RZC 21.64.030 Wetlands Wetlands are categorized according to Category I, II, III, and IV based on the Ecology Wetland Rating System. Buffers range from 25-300 feet. Alterations to category I wetlands are prohibited, alterations to II, III, and IV may be allowed subject to performance standards and mitigation. Wetland acreage replacement ratios are required for mitigation (in addition to general mitigation requirements) and determined according to mitigation activity (creation, reestablishment, rehabilitation, and/or enhancement) and Category. RZC 21.64.020 Streams Streams are classified according to Class I, II, III, and IV based on fish use. Buffers range from 25 to 200 feet. Utility facilities and poles may be permitted within the stream buffer if no feasible alternative location exists. Additional specific mitigation standards (outside of general requirements) apply in restoration or enhancement of stream corridors, including: using native, adaptable, and perennial plants; depth and type of substrate; planting densities; fertilizer application; pesticide use limitations, etc.
FINAL EIS PAGE D‐2 APPENDIX D CRITICAL AREAS REGULATIONS BY CITY MARCH 2018 City/County Critical Area Description Mitigation RZC 21.64.020 Fish and Wildlife Habitat Conservation Areas (FWHCAs) Classification of FWHCAs determined by adopted City maps, Washington Department of Fish and Wildlife Priority Habitats and Species maps, Washington State Conservation Commission habitat-limiting factors reports, federal and state info, and technical reports. Alterations to FWHCAs may be permitted subject to mitigation. Additional mitigation measures are required during mitigation planning: a)consider habitat in site planning and design; b) locating buildings and structures that preserve and minimize adverse impacts to important habitat areas; c)integrate retained habitat into open space and landscaping consistent with RZC 21.32; d)where possible, consolidate habitat and vegetated open space in contiguous blocks; e)Locate habitat contiguous to other habitat, open space, or landscaped areas to contribute to a continuous system or corridor that provides connections to adjacent habitat areas; f) Use native species in any landscaping of disturbed or undeveloped areas and in any enhancement of habitat or buffers; g) Emphasize heterogeneity and structural diversity of vegetation in landscaping; h) Remove and/or control any noxious weeds or animals as defined by the City; and i). Preserve significant trees, preferably in groups, consistent with RZC 21.72, Tree Preservation, and with achieving the objectives of these standards. RZC 21.64.050 Critical Aquifer Recharge Areas (CARAs) CARAs are classified into Wellhead Protection Zone 1, 2, 3, and 4 based on proximity to and travel time of groundwater to City's public water source wells. Utility facilities and poles are permitted for location within these zones subject to the performance standards specific to each zone in RZC 21.64.050.D. No additional mitigation measures.
FINAL EIS PAGE D‐3 APPENDIX D CRITICAL AREAS REGULATIONS BY CITY MARCH 2018 City/County Critical Area Description Mitigation City of Bellevue Land Use Code (LUC) Part 20.25H LUC 20.25H.215 (mitigation sequencing) 20.25H.220 (Mitigation and restoration plan requirements) General Critical Areas Land Use Permit is required for any utility facilities and poles located in any of the designated critical areas and/or buffers. New or expanded facilities and systems are allowed within the critical area or buffer only where no technically feasible alternative with less impact on the critical area or buffer exists (LUC 20.25.H.055.C.2.a). Require mitigation or restoration plan, and mitigation sequencing LUC 20.25H.095 (designation of critical area and buffers) 20.25H.100 (performance standards) 20.025H.105 (Mitigation and monitoring - additional provisions) Wetlands Wetlands are classified according to Category I, II, III, and IV using the Ecology Wetland Rating System. Buffers range from 40 to 225 feet. Structure setbacks range from 0-20 feet. Utility facilities and poles may be allowed in a wetland and/or wetland buffer subject to performance standards (20.25H.100) and mitigation. Mitigation actions that require compensation of impacted critical area buffer are required to occur in the following order of preference and in the following locations: a. On-site, through replacement of lost critical area buffer; b. On-site, through enhancement of the functions and values of remaining critical area buffer; c. Off-site, through replacement or enhancement, in the same sub-drainage basin; d. Off-site, through replacement or enhancement, out of the sub-drainage basin but in the same drainage basin. Wetland Acreage replacement ratios apply to creation or restoration mitigation activities: Category I, 6-to-1; Category II, 3-to-1; Category III, 2-to-1; Category IV, 1.5-to-1. Enhancement of existing significantly degraded wetlands may also be allowed subject to a critical areas report.
FINAL EIS PAGE D‐4 APPENDIX D CRITICAL AREAS REGULATIONS BY CITY MARCH 2018 City/County Critical Area Description Mitigation LUC 20.25H.075 (designation of critical areas and buffers) 20.25H.080 (performance standards) Streams Streams are classified according to Type S, F, N and O based on the Washington State Department of Natural Resources (WDNR) typing. Buffers range from 25-100 feet. Structure setbacks range from 0-50 feet. Stream channels can be modified for new or expanded utility facilities and poles, subject to performance standards (LUC 20.25H.080) and mitigation. A. Mitigation plans for streams and stream critical area buffers are required to provide mitigation for impacts to critical area functions and values in the following order of preference: 1. On-site, through replacement of lost critical area buffer; 2. On-site, through enhancement of the functions and values of remaining critical area buffer; 3. Off-site, through replacement or enhancement, in the same sub-drainage basin; 4. Off-site, through replacement or enhancement, out of the sub-drainage basin but in the same drainage basin. Mitigation off-site and out of the drainage basin shall be permitted only through a critical areas report. B. Buffer Mitigation Ratio. Critical area buffer disturbed or impacted under this part shall be replaced at a ratio of one-to-one.
FINAL EIS PAGE D‐5 APPENDIX D CRITICAL AREAS REGULATIONS BY CITY MARCH 2018 City/County Critical Area Description Mitigation LUC 20.25H.150 (Designation of critical area) 20.25H.155 (uses in habitat for species of local importance) 20.25H.160 (performance standards) Habitat Associated with Species of Local Importance Buffers depend if they're required for known species or are 35 feet for naturally occurring ponds w/o any other CA designation. Utility facilities and poles are allowed within habitat associated with species of local importance subject to the following performance standards (LUC 20.25H.160): If habitat associated with species of local importance will be impacted by a proposal, the proposal shall implement the wildlife management plan developed by the Department of Fish and Wildlife for such species. Where the habitat does not include any other critical area or critical area buffer, compliance with the wildlife management plan shall constitute compliance with this part. No additional mitigation measures. City of Newcastle Municipal Code (NMC), Chapter 18.24 Critical Areas NMC 18.24.130 (mitigation and monitoring) 18.24.135 (off-site mitigation) General A. If mitigation is required to compensate for adverse impacts, unless otherwise provided, an applicant shall: 1. Mitigate adverse impacts to: a. Critical areas and their buffers; and b. The development proposal as a result of the proposed alterations on or near the critical areas; and 2. Monitor the performance of any required mitigation. On-site mitigation is preferred, but off-site mitigation (in same drainage subbasin as development proposal site) can be approved if on-site isn't practical and off-site mitigation will achieve equivalent or greater hydrological, water quality and wetland or aquatic area functions.
FINAL EIS PAGE D‐6 APPENDIX D CRITICAL AREAS REGULATIONS BY CITY MARCH 2018 City/County Critical Area Description Mitigation NMC 18.24.310 (categories) 18.24.315 (Buffers) 18.24.316 (development standards) 18.24.320 (permitted alterations) 18.24.325 (specific mitigation requirements) Wetlands Wetlands are classified into Category I, II, III, and IV based on the Ecology Wetland Rating System. Buffers range between 25 and 225 feet depending on Category and land use. If no practical alternative location exists utility facilities and poles can be located within wetland buffers if: 1. The utility corridor is not located in a buffer where the buffer or associated wetland is used as a fish spawning area or by species listed as endangered or threatened by the state or federal government or contains critical or outstanding actual habitat for those species or heron rookeries or raptor nesting trees; 2. The construction area and resulting utility corridor are the minimum widths practical; 3. Except as provided in subsection (G) of this section, the utility corridor is located within the outer 25 percent of the buffer or within a roadway, the improved area of an existing utility corridor or the improved area of an approved trail; 4. The wetland and its buffer are protected during utility corridor construction and maintenance; 5. The utility corridor is aligned to avoid cutting significant trees, to the maximum extent practical; 6. Vegetation removal is limited to the minimum necessary to construct the corridor; 7. Vegetation removal for the purpose of corridor maintenance is the minimum necessary to maintain the utility’s function; 8. Any corridor access for maintenance is at specific points into the buffer rather than by a parallel road, to the maximum extent In addition to general mitigation requirements, mitigation for wetland or wetland buffer impacts: A. Mitigation measures must achieve equivalent or greater wetland functions, including, but not limited to: 1. Habitat complexity, connectivity and other biological functions; and 2. Seasonal hydrological dynamics, as provided in the King County Surface Water Design Manual; B. The following ratios of area of mitigation to area of alteration apply to mitigation measures: 1. For alterations to a wetland buffer, a ratio of one to one; and 2. For alterations to a wetland, proposed mitigation shall be in compliance with the acreage replacement ratios in NMC 18.24.325. C. Credit/Debit Method. To more fully protect functions and values, and as an alternative to the mitigation ratios found in the joint guidance Wetland Mitigation in Washington State Parts I and II (Ecology Publication No. 06-06-011a-b, Olympia, WA, March 2006), the administrator may allow mitigation based on the “credit/debit” method developed by the Department of Ecology in Calculating Credits and Debits for Compensatory Mitigation in Wetlands of Western Washington: Final Report.
FINAL EIS PAGE D‐7 APPENDIX D CRITICAL AREAS REGULATIONS BY CITY MARCH 2018 City/County Critical Area Description Mitigation practical; 9. If the department determines that a parallel maintenance road is necessary, the following conditions shall be complied with: a. The width of the roadway shall be as small as possible and not greater than 15 feet; and b. The location of the roadway shall be contiguous to the utility corridor on the side farthest from the wetland; Development subject to performance standards (18.24.316) and mitigation. NMC 18.24.306 (classifications) 18.24.307 (development standards) 18.24.308 (permitted alterations) 18.24.309 (specific mitigation requirements) Streams Streams are classified as Types, F, Np, and Ns based on the WDNR typing system. Buffers range between 25 and 200 feet. If no practical alternative location exists utility corridors in stream buffers are allowed if: 1. The utility corridor is not located in a buffer where the buffer or associated stream is used by species listed as endangered or threatened by the state or federal government or contains critical or outstanding actual habitat for those species or heron rookeries or raptor nesting trees: 2. The construction area and resulting utility corridor are the minimum widths practical; 3. Except as provided in subsection (E) of this section, the utility corridor is located within the outer 25 percent of the buffer or within a roadway, the improved area of an existing utility corridor or the improved area of an approved trail; 4. The stream and its buffer are protected during utility corridor construction and maintenance; 5. The utility corridor is aligned to avoid In addition to general mitigation requirements, mitigation for streams or their buffers is required to include: 1. For permanent alterations, restoration or enhancement of the altered stream or buffer, as determined by the city, using the following formulae: a. For mitigation on site: i. Correcting the adverse impact to any class of stream by repairing, rehabilitating or restoring the affected stream or buffer shall be on a 1:1 areal and functional basis; ii. Enhancement or restoration which is not mitigation of an alteration associated with a Type F, Np or Ns stream shall be on a 1.5:1 area and functional basis; iii. Enhancement or restoration which is not mitigation of an alteration associated with a Type S stream shall be on a 2:1 area and functional basis; b. For mitigation off site: i. Enhancement or restoration which is not mitigation of an alteration associated with a Type F, Np or Ns stream shall be on a 2:1 area and functional basis; ii. Enhancement or restoration which is not mitigation of an
FINAL EIS PAGE D‐8 APPENDIX D CRITICAL AREAS REGULATIONS BY CITY MARCH 2018 City/County Critical Area Description Mitigation cutting significant trees, to the maximum extent practical; 6. Vegetation removal is limited to the minimum necessary to construct the corridor; 7. Vegetation removal for the purpose of corridor maintenance is the minimum necessary to maintain the utility’s function; 8. Any corridor access for maintenance is at specific points into the buffer rather than by a parallel road, to the maximum extent practical; 9. If the department determines that a parallel maintenance road is necessary, the following conditions shall be complied with: a. The width of the roadway shall be as small as possible and not greater than 15 feet; and b. The location of the roadway shall be contiguous to the utility corridor on the side farthest from the stream; and subject to mitigation alteration associated with a Type S stream shall be on a 3:1 area and functional basis; and 2. For temporary alterations, restoration of the altered stream or buffer, as determined by the city; Off-site mitigation is only approved if it isn't practical to mitigate on site and it will achieve biologic, habitat, and hydrologic functions equivalent to or better than on-site mitigation. NMC 18.24.302 Fish and Wildlife Habitat Conservation Areas Designated FWHCAs include: areas with which state or federally designated endangered, threatened, and sensitive species have a primary association; state priority habitats and areas associated with state priority species; state-designated priority habitat or critical habitat for state-designated species; habitats and species of local importance; naturally occurring ponds under 20 acres; waters of the state; lakes, ponds, streams, and rivers planted with game fish; and land useful for preserving habitat and open space connections. Buffers based on a CAR. Utility facilities and poles located in FWHCAs subject to Mitigation of alterations to habitat conservation areas shall achieve equivalent or greater biological functions. Mitigation shall address each function affected by the alteration to achieve functional equivalency or improvement on a per function basis. Mitigation shall be detailed in a fish and wildlife habitat conservation area mitigation plan, which may include the following as necessary: a. A native vegetation plan; b. Plans for retention, enhancement or restoration of specific habitat features; c. Plans for control of nonnative invasive plant or wildlife species; and d. Stipulations for use of innovative, sustainable building practices.
FINAL EIS PAGE D‐9 APPENDIX D CRITICAL AREAS REGULATIONS BY CITY MARCH 2018 City/County Critical Area Description Mitigation development standards (18.24.305) and mitigation. City of Renton Municipal Code (RMC) Chapter 4-3-050 RMC 4-3-050.C.3 (exemptions - critical areas and buffers) RMC 4-3-050.G.2 (critical area buffers and structure setbacks from buffers) RMC 4-3-050.L. (mitigation maintenance and monitoring) General Utilities may be located within geologic hazard areas, habitat conservation areas, streams and lakes (Types F, Np, & Ns), and wetlands when they area within existing and improved public road rights-of-way or easements. If activities exceed the existing improved area or the public right-of-way, this exemption does not apply. Where applicable, restoration of disturbed areas would need to be conducted. Overbuilding or replacement of existing utility systems may occur in geologic hazard areas, habitat conservation areas, or wetlands if the work does not increase the footprint of the structure or line by more than 10% within the critical area and/or buffer areas, and occurs in the existing right-of-way boundary or easement boundary. Mitigation shall be provided on site, unless on-site mitigation is not scientifically feasible due to physical features of the property. The burden of proof shall be on the applicant to demonstrate that mitigation cannot be provided on site. When mitigation cannot be provided on site, mitigation shall be provided in the immediate vicinity of the permitted activity on property owned or controlled by the applicant, and identified as such through a recorded document such as an easement or covenant, provided such mitigation is beneficial to the habitat area and associated resources. In-kind mitigation shall be provided except when the applicant demonstrates and the City concurs that greater functional and habitat value can be achieved through out-of-kind mitigation. When a mitigation plan is required, the proponent shall submit a final mitigation plan for the approval of the Administrator prior to the issuance of building or construction permits for development. The proponent shall receive written approval of the mitigation plan prior to commencement of any construction activity. Where the City requires increased buffers rather than standard buffers, it shall be noted on the subdivision plan and/or site plan.
FINAL EIS PAGE D‐10 APPENDIX D CRITICAL AREAS REGULATIONS BY CITY MARCH 2018 City/County Critical Area Description Mitigation RMC 4-3-050.G.2 (critical area buffers and structure setbacks from buffers) RMC 4-3-050.6 Habitat Conservation Areas Critical Habitats are habitats that have a primary association with the documented presence of non-salmonid or salmonid species (RMC 4-3-090.L1)) species proposed or listed by the Federal government or State of Washington as endangered, threatened, sensitive and/or of local importance. Buffers consist of an undisturbed area of native vegetation, or areas identified for restoration, established to protect the integrity, functions and values of the affected habitat. Critical area buffer widths are established based on: (1) the type and intensity of human activity proposed, (2) recommendations contained within a habitat assessment report, and (3) management recommendations issued by the Washington Department of Fish and Wildlife. Structure setback beyond the buffer is 15 ft. The Administrator may approve mitigation to compensate for adverse impacts of a development proposal to habitat conservation areas through use of a federally and/or state certified mitigation bank or in-lieu fee program. See RMC 4-3-050.L. RMC 4-3-050.G.2 (critical area buffers and structure setbacks from buffers) RMC 4-3-050.G.7 (streams and lakes) RMC 4-3-050.J.2 (Alterations to Critical Areas) 4-3-050.I.2 (Alterations to Critical Areas Buffers) Streams and Lakes Streams are classified as Type S, F, Np, and Ns based on the WDNR permanent water typing system (WAC 222-16-030). Buffers range between 50 and 175 feet. Structure setback beyond the buffer is 15 ft. Permit approval for projects on or near regulated Type F, Np and Ns water bodies are only granted if no net loss of regulated riparian area or shoreline ecological function in the drainage basin would occur and one of the following conditions is met: (1) project would meet the standard provisions of RMC 4-3-050.7, (2) project would meet alternative administrative standard provisions of
FINAL EIS PAGE D‐11 APPENDIX D CRITICAL AREAS REGULATIONS BY CITY MARCH 2018 City/County Critical Area Description Mitigation RMC 4-3-050.7, or (3) a variance is acquired. New utility lines and facilities may be permitted to cross water bodies in accordance with an approved stream/lake study, if : fish and wildlife habitat areas are avoided to the maximum extent possible; utilities are designed to bore beneath the scour depth and hyporheic zone of the water body and channel migration zone, cross at the centerline of the stream channel at an angle greater than 60 degrees, or have crossings be contained within the footprint of an existing road or utility crossing; new utility routes avoid paralleling the stream or following a down-valley course near the channel; utility installation does not increase or decrease the natural rate of shore migration or channel migration; seasonal work windows are determined and made a condition of approval; and mitigation criteria of subsection L of RMC 4-3-050 are met. RMC 4-3-050.G.2 (critical area buffers and structure setbacks from buffers) RMC 4-3-050.G.8 (wellhead protection areas) Wellhead Protection Areas Wellhead Protection Areas are the portion of an aquifer within the zone of capture and recharge area for a well or well field owned or operated by the City. They are delineated into zones based on the Renton Wellhead Protection Plan. These include Zone 1, Zone 1 Modified, and Zone 2. There are no critical area buffers. Construction activities within zones 1 and 2 must comply with RMC 4-3-050.G.8.
FINAL EIS PAGE D‐12 APPENDIX D CRITICAL AREAS REGULATIONS BY CITY MARCH 2018 City/County Critical Area Description Mitigation RMC 4-3-050.G.2 (critical area buffers and structure setbacks from buffers) RMC 4-3-050.G.9 (wetlands) RMC 4-3.050.J.4 RMC 4-3-050.I.3 (Alterations to Critical Areas Buffers) Wetlands Wetlands are classified into Category I, II, III, and IV based on the Ecology Wetland Rating System. Buffers range between 0 and 200 feet depending on Category and land use. Structure setback beyond the buffer is 15 ft. for all uses and all wetland types. Utilities can be located within wetland buffers if they are located within an existing and improved public road rights-of-way or easements. Overbuilding or replacement of existing utility systems may occur in wetlands if the work does not increase the footprint of the structure or line by more than 10% within the critical area and/or buffer areas and occurs in the existing right-of-way or easement boundary. Development subject to performance standards (4-3-050.G) and mitigation. Compensatory mitigation for wetland alterations shall be based on the wetland category and the type of mitigation activity proposed. The replacement ratio shall be based on wetland category. The created, re-established, rehabilitated, or enhanced wetland area shall at a minimum provide a level of functions equivalent to the wetland being altered and shall be located in an appropriate landscape setting.
Appendix E:
Supplemental Information:
Plants & Animals
E
FINAL EIS PAGE E‐1 APPENDIX E VEGETATION MANAGEMENT STANDARDS MARCH 2018 APPENDIX E-1. PSE VEGETATION MANAGEMENT STANDARDS
FINAL EIS PAGE E‐2 APPENDIX E VEGETATION MANAGEMENT STANDARDS MARCH 2018
FINAL EIS PAGE E‐3 APPENDIX E VEGETATION MANAGEMENT STANDARDS MARCH 2018
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APPENDIX E TREE INVENTORY METHODOLOGY MARCH 2018
APPENDIX E-2. TREE INVENTORY AND REMOVAL
ANALYSIS METHODOLOGY
This appendix documents the steps taken by Environmental Science Associates (ESA) to determine the
tree removal numbers for the Phase 2 Draft EIS and Final EIS. The methodology is divided into five
phases or parts for ease of understanding: Inventory, Impact Analysis, Phase 2 Draft EIS Analysis, Data
Analysis Review, and Final EIS. Figure E2‐1 shows the legal right‐of‐way, the managed right‐of‐way, and
wire zone for 230 kV transmission lines, which were used to determine the areas where trees could be
affected by the project.
Part 1: Inventory
The Watershed Company (TWC) outlined its methodology for the tree inventory in a series of Tree
Inventory Reports (TWC, 2016a), published in May or July 2016; see the referenced reports for detailed
description. Below is a summary of these methods:
1. Boundaries for the tree inventory study area were established and included the following:
a. Trees within the 100‐foot‐wide legal right‐of‐way along the existing 115 kV transmission
line corridor.
b. For project segments that are outside the existing corridor, trees within the road right‐
of‐way plus a 30‐foot‐wide strip extending outward from either side of the road right‐of‐
way where both sides of the street were inventoried. If only one side of the street was
inventoried, only the right‐of‐way plus one 30‐foot strip was included.
2. Trees within the inventory study area were surveyed and mapped as geospatial points and
assigned a unique identification number. The identification number was marked on a tree tag
attached to each tree (e.g., 3908).
3. Arborists in the field collected detailed information for each inventoried tree within the study
area (e.g., tree species, tree health, etc.). There were 38 properties in the study area outside of
the existing corridor that were wholly or partially inaccessible to the arborist and/or survey
field crews. Tree locations on these properties were not captured completely, and/or detailed
inventory data may not have been collected. Arborists used orthophotos and observations
from off‐site to determine tree location and inventory data as best as feasible for these
properties.
4. Inventoried trees were assigned a maximum potential height (MPH). MPH was determined
based on species, according to best available resources to determine mature vegetation
growth potential.
FINAL EIS PAGE E‐5 APPENDIX E TREE INVENTORY METHODOLOGY MARCH 2018 Figure E2-1. Legal Right-of-Way, Managed Right-of-Way, and Wire Zone for 230 kV Transmission Lines
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APPENDIX E TREE INVENTORY METHODOLOGY MARCH 2018
Part 2: Impact Analysis
TWC outlined its methodology for the impact analysis in Methodology for Vegetation Impact Analysis
(TWC, 2016b); see the referenced reports for detailed description. Below is a summary of these
methods:
1. TWC placed the surveyed tree points on a georeferenced base map and overlaid it with the
proposed conductor and pole alignments establishing the wire zone and managed right‐of‐way.
2. Trees that met the following criteria were flagged for removal:
a. Dead and dying trees.
b. Trees within the legal right‐of‐way but outside of the managed right‐of‐way with an
MPH exceeding 70 feet.
c. Trees within the managed right‐of‐way and wire zone with an MPH exceeding 15 feet.
3. TWC identified trees flagged for removal that were located in a critical area or critical area
buffer, using a combination of publicly available GIS layers, wetland delineations, and stream
surveys conducted by TWC.
See the referenced report for a detailed description for limitations of the data, including errors.
Part 3: Draft EIS Analysis
The Tree Inventory Reports (TWC, 2016a), Methodology for Vegetation Impact Analysis (TWC, 2016b), a
GIS data worksheet, and GIS data layers were provided to ESA to use for the analysis in the Phase 2 Draft
EIS. ESA took the following steps to review TWC results:
1. Google Earth and street view, combined with ArcGIS Desktop, were used to review surveyed
trees to generally confirm that the number of trees surveyed within the study area matched the
number of trees present in the corridor, and to confirm that trees flagged for removal matched
the proposed project alignment.
2. Surveyed trees were cross‐checked against the Phase 2 Draft EIS segments and options to
confirm that the TWC study area was consistent with the project description evaluated in the
Phase 2 Draft EIS.
3. ESA ecologists visited five locations within the study area on 10/6/2016 by to confirm that data
provided by TWC were consistent with on‐the‐ground conditions. ESA ecologists checked tree
species, height, and location of trees at each site and cross checked with data provided. They
visited the following locations:
a. Redmond Segment – existing easement between the Sammamish substation and
Redmond Way, near Willows Creek.
b. Bellevue Central Segment – existing easement from SE 2nd Street to SE 7th Street along
Lake to Lake Trail.
c. Richards Creek substation site.
d. Bellevue South Segment – existing easement north and south of Forest Drive.
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APPENDIX E TREE INVENTORY METHODOLOGY MARCH 2018
e. Newcastle Segment – existing easement from SE 95th Way to the May Creek crossing
and existing easement near Newcastle Way.
4. ESA confirmed that the tree inventory and impact analysis methodology was consistent with
standard practice.
5. To identify the number of pole centroids that would be located within critical areas and critical
area buffers, ESA used the pole location centroid data provided by PSE, applied a 25‐foot square
centered on each pole location centroid, and overlaid the wetland/stream and wetland/stream
buffer layers provided by TWC. If any portion of the 25‐foot square was located outside a
wetland, stream, or associated buffer, the pole centroid was excluded from the overall pole
counts in critical areas and critical area buffers. This exclusion was made because PSE has the
flexibility to adjust the precise location of a pole and would avoid impacts to wetlands, streams,
or associated buffers where possible. The numbers of poles proposed in a wetland, stream, or
associated buffer were presented in the Water Resources and Plants and Animals sections of
the Phase 2 Draft EIS (Sections 3.3 and 3.4, respectively).
6. To identify tree removal within recreation sites, using GIS ESA overlaid trees identified for
removal by TWC with a parks layer and reported in the Recreation section of the Phase 2 Draft
EIS (Section 3.6).
Part 4: Data Analysis Review after Phase 2 Draft EIS
In response to public comment on the Phase 2 Draft EIS that suggested inconsistencies in the tree
removal analysis, ESA worked with TWC to review its data analysis. TWC sent ESA the following GIS
layers: legal right‐of‐way, managed right‐of‐way, wire zone, inventoried trees, and supporting attributes
and metadata. Metadata provides definitions for various attributes like unique identifiers, tree species,
MPH, notes, and trees flagged for removal. In GIS, ESA conducted the following queries to review the
analysis done by TWC:
1. Trees flagged for removal:
a. Checked to see if trees flagged for removal were located within the managed right‐of‐
way or the wire zone (including checking if any trees were flagged for removal outside
of these two zones).
b. ESA reviewed the attributes of the trees flagged for removal within the managed right‐
of‐way and wire zone to see if they met the removal criteria (i.e., had an MPH greater
than 15 feet or were dead/dying).
c. Checked to see if trees flagged for removal outside of the managed right‐of‐way and
wire zone (but within the legal right‐of‐way) had an MPH exceeding 70 feet or were
dead/dying.
2. Trees not flagged for removal:
a. Checked to see if trees not flagged for removal within the managed right‐of way or wire
zone met the removal criteria (had an MPH greater than 15 feet or were dead/dying).
b. Checked to see if trees not flagged for removal outside of the managed right‐of‐way and
wire zones (but within the legal right‐of‐way) had an MPH exceeding 70 feet or were
dead/dying.
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APPENDIX E TREE INVENTORY METHODOLOGY MARCH 2018
3. In response to the review by ESA, TWC provided clarification regarding trees that did not appear
to be categorized correctly. There were no changes to TWC’s tree impact numbers as a result of
this review. Differences in ESA’s results were caused by slight differences in the way ESA had
interpreted and analyzed the information provided by TWC. TWC documented this review and
changes in a memo, Energize Eastside Vegetation Impact Analysis (TWC, 2017).
4. ESA then checked the tree removal numbers and calculations used in the Phase 2 Draft EIS
against the updated GIS data provided by TWC and presented the revised information in
Chapter 3, Errata, of this Final EIS. While this corrected the Phase 2 Draft EIS analysis, it was not
intended to provide the full analysis of PSE’s Proposed Alignment for the Final EIS, which is
described in Part 5 below.
Part 5: Final EIS
ESA presented the tree inventory and removal numbers in the Final EIS based on revised GIS data
provided by TWC. Two sets of GIS data were used for the Final EIS: tree inventory data collected and
analyzed during 2015 and 2016, and tree inventory data that were collected and analyzed in 2017. The
tree data from 2017 were only available for portions of the alignment being considered for permits (i.e.,
in South Bellevue and Newcastle). The following subsections summarize what was included in the two
datasets, and how the data are presented in the Final EIS.
The Watershed Company GIS Data (2016)
This tree inventory was conducted for the Phase 2 Draft EIS and data were collected as described above.
For the Final EIS, these data were used for the Redmond Segment, Bellevue North Segment, Bellevue
Central Segment north of Lakeside substation, and the Renton Segment.
To determine which trees were associated with each segment, ESA created a GIS attribute field called
“Seg.” An ESA GIS analyst conducted a spatial assessment of the data and identified the segment with
which each tree was associated. TWC provided information as to whether a tree would be removed
under any of the Phase 2 alternatives/options. For the Final EIS, the only option that was considered was
“A1_Exesmt.” Filters were applied based on “Seg” and whether or not the “A1_Exesmt” field said
“remove.” The “Signfcnt” field provided in TWC’s attribute data denotes if a tree was marked as being
significant or not (as defined by local regulations). “Critical_A” indicated if the tree is located in a critical
area. “CA_Buffer” indicated if the tree is located in a critical area buffer. The following values were
counted as being in the buffer: (In, LIKELY IN, POSSBLY IN, Y).
The Watershed Company GIS Data (2017)
The tree data from 2017 were only available for portions of the alignment being considered for permits,
which included the following:
The portion of the Bellevue Central Segment that included the Lakeside substation.
Richards Creek substation site.
Bellevue South Segment.
Newcastle Segment, Option 1 (No Code Variance).
Newcastle Segment, Option 2 (Code Variance).
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APPENDIX E TREE INVENTORY METHODOLOGY MARCH 2018
TWC used a different, more refined methodology to analyze the tree data for these sections (TWC,
2018).
The Bellevue South dataset from the Watershed Company included the Bellevue Central Segment
associated with the Lakeside substation and the Richards Creek substation. A GIS analyst at ESA created
a “Seg” field and conducted a spatial analysis to determine which trees are associated with the Lakeside
substation (in the Bellevue Central Segment), which are associated with the Richards Creek substation
site, and which are associated with the Bellevue South Segment (as defined in the Final EIS). The data
had similar fields to those associated with the 2016 attribute data, so similar filters were applied.
References:
TWC (The Watershed Company). 2016a. Tree Inventory: Energize Eastside Project. Includes the following
separate reports: City of Bellevue Tree Inventory Report; King County Tree Inventory Report; City of
Newcastle Tree Inventory Report; City of Redmond Tree Inventory Report; City of Renton Tree
Inventory Report; Richards Creek Parcel Tree Inventory Report; Segment O Tree Inventory Report;
Segment P Tree Inventory Report; and Bypass Routes 1 and 2 Tree Inventory and Analysis Report.
Prepared for Puget Sound Energy, Bellevue, WA. Prepared by The Watershed Company, Kirkland,
WA. May and July 2016.
TWC (The Watershed Company). 2016b. Methodology for Vegetation Impact Analysis. Prepared for
Puget Sound Energy, Bellevue, WA. Prepared by The Watershed Company, Kirkland, WA.
September 2016.
TWC (The Watershed Company). 2016c. GIS Dataset Labeled as twc_ee_veg_impact_results_20160914.
September 14, 2016.
TWC (The Watershed Company). 2017. Energize Eastside Vegetation Impact Analysis. Prepared for Puget
Sound Energy, Bellevue, WA. Prepared by The Watershed Company, Kirkland, WA. November 2017.
TWC (The Watershed Company). 2018. Energize Eastside Tree Impact Assessment, Draft Methodology
for Vegetation Impact Analysis memorandum. Prepared by The Watershed Company, Kirkland, WA.
February 9, 2018.
Appendix F:
Recreation-Related
Study Area Policies
F
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APPENDIX F RECREATION POLICIES MARCH 2018
APPENDIX F. RECREATION-RELATED STUDY
AREA POLICIES BY JURISDICTION
Policy Title Policy Text
City of Redmond
Utilities Policy UT-9 Promote the efficiency of utility placement both in cost and timing through
methods such as the following: Encourage joint use of utility corridors for
utilities, recreation and appropriate non-motorized connections.
City of Bellevue
Parks & Open Space
System Plan Goals
Define and enhance neighborhood character by using open space as visual
relief to separate and buffer between uses.
Parks and Open Space
Policy PA-30
Protect and retain, in a natural state, significant trees and vegetation in
publicly and privately-dedicated greenbelt areas.
Parks and Open Space
Policy PA-37
Require a public review process for the conversion to non-recreational use
of park lands and facilities.
Utilities Policy UT-68 Encourage the use of utility corridors as non-motorized trails. The city and
utility company should coordinate the acquisition, use, and enhancement
of utility corridors for pedestrian, bicycle and equestrian trails and for
wildlife corridors and habitat.
Utilities Policy UT-69 Avoid, when reasonably possible, locating overhead lines in greenbelt and
open spaces as identified in the Parks and Open Space System Plan.
Richards Valley Sub
Area Plan Policy S-RV-
11
Protect and preserve publicly owned land.
Discussion: This policy refers to land set aside for storm drainage and
detention, the right-of-way along the Lake Hills Connector, and potential
links in the trail and park system.
Bridle Trails Sub Area
Plan Policy S-BT-20
Work with utility companies to gain public non-motorized trail easements
along power line corridors to complete the equestrian trail facilities plan.
Newcastle Sub Area
Plan Policy S-NC-44
Encourage the use of utility and railroad easements and rights-of-way for
hiking, biking, and equestrian trails wherever appropriate in the Subarea.
City of Newcastle
Utilities Policy UT-P7 Where found to be safe, the City of Newcastle shall promote recreational
use of utility corridors such as trails, sport courts, and similar facilities.
City of Renton
Goal B Create a connected system of parks, corridors, trails and natural areas that
provides nearby and accessible opportunities for recreation and non-
motorized transportation.
King County
Objective 3.2 Invest in planning, design, and construction of new major trail corridors, the
Eastside Rail Corridor and the Lake to Sound Trail.
Source: City of Bellevue, 2015; City of Newcastle, 2016; City of Redmond, 2015; City of Renton, 2011; and King
County, 2016.
Appendix G:
Supplemental Information:
Historic Resources
G
FINAL EIS PAGE G‐1 APPENDIX G SUPPLEMENTAL INFORMATION: HISTORIC RESOURCES MARCH 2018 APPENDIX G. SUPPLEMENTAL INFORMATION: HISTORIC RESOURCES Table G‐1. Historic Register Resources along PSE’s Proposed Alignment Map # Property Name Address Year Built NRHP – Recom. Eligible NRHP – Determ. Eligible NRHP - Listed WHR - Listed WHB -Listed Desig. KC Landmark 1 Sammamish-Lakeside-Talbot Hill transmission lines #1 and #2 and the Eastside transmission corridor Redmond to Renton 1920s Yes No No No No No 2 Twin Valley Dairy 410 130th Place SE 1933 Yes Yes No No Yes No 3 Somerset Neighborhood Bellevue 1960s Yes No No No No No 4 Newcastle Cemetery SW of 69th Way off 129th Ave SE c.1870 Yes No No Yes No Yes 5 Mt. Olivet Cemetery 100 Blaine Ave NE, Renton c.1875 Yes No No No No No KC = King County; NRHP = National Register of Historic Places; WHBR = Washington Heritage Barn Register; WHR = Washington Heritage Register.
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APPENDIX G SUPPLEMENTAL INFORMATION: HISTORIC RESOURCES MARCH 2018
Consultation Record Summary
A copy of the June 21, 2017, consultation letter (one example attached) was sent to the following
recipients:
Rob Whitlam, State Archaeologist; Department of Archaeology & Historic Preservation;
Olympia, WA
Kim Dietz, Senior Planner/Historic Preservation Officer; City of Redmond, WA
Cecile Hansen, Chairwoman; Duwamish Tribe; Seattle, WA
Philippe D. LeTourneau; King County Historic Preservation Program; Seattle, WA
Laura Murphy, Archaeologist, Cultural Resources; Muckleshoot Indian Tribe; Auburn, WA
Steven Mullen-Moses, Director; Archaeology & Historic Preservation; Snoqualmie Tribe;
Snoqualmie, WA
Kerry Lyste, THPO; Stillaguamish Tribe; Arlington, WA
Dennis Lewarch, THPO; Suquamish Tribe; Suquamish, WA
Richard Young, Cultural Resources; Tulalip Tribes; Tulalip, WA
Each letter included two attachments: (1) Attachment A, GIS Model Topographic Mapbook; and (2)
Attachment B, GIS Model Aerial Mapbook. These attachments contained location-specific archaeological
site information that is exempt from public disclosure per RCW 42.56.300. Following this state
regulation, both attachments have been redacted from publication in the Final EIS.
Also attached is a letter (dated 8/18/2017) with a notification about planned field work in the study area.
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Appendix H:
Supplemental Information: EMF
H
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APPENDIX H SUPPLEMENTAL INFORMATION: EMF MARCH 2018
APPENDIX H. SUPPLEMENTAL INFORMATION:
ELECTRIC AND MAGNETIC FIELDS
Figure H-1. Unique Uses in the EMF Study Area
Appendix I:
Supplemental Information:
Pipeline Safety
I
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APPENDIX I SUPPLEMENTAL INFORMATION: PIPELINE SAFETY MARCH 2018
APPENDIX I. SUPPLEMENTAL INFORMATION:
PIPELINE SAFETY
APPENDIX I-1: PIPELINE INCIDENTS
The two pipeline incidents that led to the passage of the Pipeline Safety Improvement Act of 2002 and
the current pipeline integrity management rules are as follows:
Bellingham, Washington, June 10, 1999. According to the National Transportation
Safety Board (NTSB) accident report, “About 3:28 p.m., Pacific daylight time, on June 10,
1999, a 16-inch diameter steel pipeline owned by Olympic Pipe Line Company (Olympic)
ruptured and released about 237,000 gallons of gasoline into a creek that flowed through
Whatcom Falls Park in Bellingham, Washington. About one and one half hours after the
rupture, the gasoline ignited and burned approximately one and one half miles along the
creek. Two 10-year-old boys and an 18-year-old man died as a result of the accident.
Eight additional injuries were documented. A single-family residence and the City of
Bellingham’s water treatment plant were severely damaged. As of January 2002, Olympic
estimated that total property damages were at least $45 million.
The major safety issues identified during this investigation were excavations performed by
IMCO General Construction, Inc., in the vicinity of Olympic’s pipeline during a major
construction project and the adequacy of Olympic Pipe Line Company’s inspections
thereof; the adequacy of Olympic Pipe Line Company’s interpretation of the results of in-
line inspections of its pipeline and its evaluation of all pipeline data available to it to
effectively manage system integrity; the adequacy of Olympic Pipe Line Company’s
management of the construction and commissioning of the Bayview products terminal; the
performance and security of Olympic Pipe Line Company’s supervisory control and data
acquisition system; and the adequacy of Federal regulations regarding the testing of relief
valves used in the protection of pipeline systems.” (NTSB, 2002).
Carlsbad, New Mexico, August 19, 2000. Per the National Transportation Safety
Board accident report, “At 5:26 a.m., mountain daylight time, on Saturday, August 19,
2000, a 30-inch diameter natural gas transmission pipeline operated by El Paso Natural
Gas Company ruptured adjacent to the Pecos River near Carlsbad, New Mexico. The
released gas ignited and burned for 55 minutes. Twelve persons who were camping under
a concrete-decked steel bridge that supported the pipeline across the river were killed and
their three vehicles destroyed. Two nearby steel suspension bridges for gas pipelines
crossing the river were extensively damaged. According to El Paso Natural Gas Company,
property and other damages or losses totaled $998,296.
The major safety issues identified in this investigation were the design and construction of
the pipeline, the adequacy of El Paso Natural Gas Company’s internal corrosion control
program, the adequacy of Federal safety regulations for natural gas pipelines, and the
adequacy of Federal oversight of the pipeline operator.” (NTSB, 2003).
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APPENDIX I SUPPLEMENTAL INFORMATION: PIPELINE SAFETY MARCH 2018
References
NTSB (National Transportation Safety Board). 2002. Pipeline Rupture and Subsequent Fire in
Bellingham, Washington, June 10, 1999. Pipeline Accident Report NTSB/PAR-02/02.
Washington, D.C.
NTSB (National Transportation Safety Board). 2003. Pipeline Rupture and Subsequent Fire near
Carlsbad, New Mexico, August 19, 2000. Pipeline Accident Report NTSB/PAR-03/01.
Washington, D.C.
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APPENDIX I-2: BP PIPELINES CONSTRUCTION REQUIREMENTS
(2016 VERSION)
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APPENDIX I-3: OLYMPIC DATA REQUEST AND RESPONSES (FOR
ENERGIZE EASTSIDE EIS PIPELINE RISK ASSESSMENT)
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APPENDIX I-4: PSE ENERGIZE EASTSIDE CORRIDOR SAFETY
FAQ SHEET
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APPENDIX I-5: ENERGIZE EASTSIDE EIS PIPELINE SAFETY
TECHNICAL REPORT (PREPARED BY EDM SERVICES)
[note – no revisions have been made to the version as presented in the Phase 2 Draft EIS; therefore,
the full study is not reprinted here. See Appendix I-5 of the Phase 2 Draft EIS for the full study]
FINAL EIS PAGE I‐14
APPENDIX I SUPPLEMENTAL INFORMATION: PIPELINE SAFETY MARCH 2018
APPENDIX I-6: PIPELINE SAFETY REGULATIONS
Regulation Summary
Federal
Pipeline Safety Act of 1968
(49 United States Code [USC] Section
60101)
Granted authorization to the U.S. Department of
Transportation to develop minimum safety standards for
natural gas pipelines.
Hazardous Liquid Pipeline Safety Act
of 1979
(Public Law 96-129)
Granted authorization to the U.S. Department of
Transportation to develop minimum safety standards for oil
and hazardous liquid pipelines.
49 CFR, Parts 190 through 199 U.S. Code sections that cover pipeline safety.
49 CFR Part 195 Transportation of Hazardous Liquids by Pipeline (the
primary U.S. Code section addressing hazardous liquid
pipeline safety).
Pipeline Safety, Regulatory Certainty,
and Jobs Creation Act of 2011
(Public Law 112-90)
Increased the number of pipeline inspectors and mandated
a variety of new safety measures. Required studies of
pipeline safety.
Protecting Our Infrastructure of
Pipelines and Enhancing Safety Act of
2016
Reauthorized the Pipeline Safety, Regulatory Certainty, and
Jobs Creation Act of 2011; reaffirmed mandates of the
2011 act; and established new mandates.
Pipeline Safety Improvement Act of
2002
(CFR 192 Subpart O, Pipeline Integrity
Management)
Strengthened federal pipeline safety programs, state
oversight of pipeline operators, and public education
regarding gas pipeline safety. Required gas pipeline
operators to conduct a risk assessment and implement
integrity management programs for pipelines in high
consequence areas.
Oil Pollution Act of 1990
(49 CFR Part 194)
Expanded EPA’s oversight of oil storage facilities and
vessels. Required some oil storage facilities to prepare
Facility Response Plans.
2006 Pipeline Inspection, Protection,
Enforcement and Safety Act
(Public Law 109-468)
Created state grant system to improve damage prevention
programs, and established the national “Call Before You
Dig” program. Required a review of the adequacy of federal
pipeline safety regulations related to internal corrosion
control.
FINAL EIS PAGE I‐15
APPENDIX I SUPPLEMENTAL INFORMATION: PIPELINE SAFETY MARCH 2018
Regulation Summary
State
WAC, Title 480, Chapter 480-75,
Hazardous Liquid Pipelines
Adopted the federal hazardous liquids pipeline regulations.
Underground Utilities – Damage
Prevention Law
(RCW 19.122)
Established a comprehensive damage prevention program.
Required pipeline companies, underground facility owners,
and excavators to participate in protecting the public health
and safety when excavating.
WAC 173-182 – Oil Spill Contingency
Plan
Established covered vessel and facility oil spill contingency
plan requirements, drill and equipment verification
requirements, primary response contractor standards, and
recordkeeping and compliance information.
Local
Redmond Zoning Code (RZC)
21.26.040 Setback Requirements
Established minimum setback requirements from the
hazardous pipeline corridors. Purpose is to minimize risk to
public health, safety, and welfare due to hazardous liquid
pipelines. No construction or expansion of structures is
allowed in the pipeline corridor. No setback is required for
utilities for areas along the hazardous liquid corridor, but
the Director of Planning and Community Development (or
their designee) may require a setback based on site-
specific conditions.
Renton Municipal Code (RMC) 4-3-070
(Pipeline Notice)
Requires notice on title for development within 500 feet of
liquid or gas pipelines.
Appendix J:
Phase 1 Comments and Responses
J
FINAL EIS PAGE J1‐I
APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
APPENDIX J-1.
COMMENTS AND RESPONSES FOR THE PHASE 1 DRAFT EIS
Contents
Introduction ........................................................................................................................................... J1-1
EIS Process and Content (Topic EIS) ................................................................................................... J1-3
Key Theme EIS-1: Objectivity and overall adequacy of the Phase 1 Draft EIS ............................... J1-3
Key Theme EIS-2: SEPA process, including phased EIS and opportunities for meaningful
public input ....................................................................................................................................... J1-5
Key Theme EIS-3: Completeness of the Draft EIS scope ................................................................ J1-7
Key Theme EIS-4: Graphics and text ............................................................................................... J1-8
Project Objectives (Topic OBJ) ............................................................................................................ J1-9
Key Theme OBJ-1: Objectives of proposal (to address reliability issues or to increase capacity
for other purposes) ............................................................................................................................ J1-9
Key Theme OBJ-2: Disagreement with PSE’s planning data and assumptions and how they
define project need .......................................................................................................................... J1-12
Key Theme OBJ-3: Lauckhart/Schiffman Load Flow Study suggests project is not needed ......... J1-13
Key Theme OBJ-4: ColumbiaGrid ................................................................................................. J1-17
Key Theme OBJ-5: Clarifications and Errata ................................................................................. J1-17
Alternatives Evaluated in the Phase 1 Draft EIS (Topic ALT) ........................................................... J1-18
No Action Alternative ..................................................................................................................... J1-18
Alternative 1: New Substation and 230 kV Transmission Lines .................................................... J1-18
Alternative 2: Integrated Resource Approach ................................................................................. J1-20
Alternative 3: New 115 kV Lines and Transformers ...................................................................... J1-21
Key Theme ALT-1: Alternatives considered in the Draft EIS ....................................................... J1-21
Key Theme ALT-2: Comparative summary of impacts ................................................................. J1-25
Key Theme ALT-3: Minor clarifications ........................................................................................ J1-26
Earth (Topic EARTH) ......................................................................................................................... J1-28
Key Theme EARTH-1: Earthquake-related hazards ....................................................................... J1-28
Key Theme EARTH-2: Impacts from taller poles and pole installation ......................................... J1-29
Key Theme EARTH-3: Earthwork activities near Olympic Pipeline system ................................. J1-29
Key Theme EARTH-4: Regulatory thresholds and mitigation measures ....................................... J1-30
Key Theme EARTH-5: Request for more location-specific data ................................................... J1-30
Key Theme EARTH-6: Errata and minor clarifications ................................................................. J1-31
Greenhouse Gas Emissions (Topic GHG) .......................................................................................... J1-32
FINAL EIS PAGE J1‐II
APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
Key Theme GHG-1: Phase 1 Draft EIS scope, analysis, mitigation, and conclusions ................... J1-32
Key Theme GHG-2: Tree clearing analysis and GHG effects ........................................................ J1-33
Key Theme GHG-3: Sustainable utilities and climate change ........................................................ J1-33
Key Theme GHG-4: Need under SEPA for air quality analysis ..................................................... J1-34
Key Theme GHG-5: Clarifications and Errata ................................................................................ J1-34
Water Resources (Topic WTR) ........................................................................................................... J1-36
Key Theme WTR-1: Water resources not identified in the Phase 1 Draft (e.g., springs, streams,
lakes, Coal Creek basin resources, etc.) .......................................................................................... J1-36
Key Theme WTR-2: Stormwater management ............................................................................... J1-37
Key Theme WTR-3: Groundwater pollution and diversion ........................................................... J1-38
Key Theme WTR-4: Construction-related impacts ........................................................................ J1-39
Key Theme WTR-5: Water quality and permitting ........................................................................ J1-40
Key Theme WTR-6: Tribal treaty rights ......................................................................................... J1-41
Key Theme WTR-7: Clarifications ................................................................................................. J1-41
Plants and Animals (Topic P&A) ....................................................................................................... J1-43
Key Theme P&A-1: Habitat ........................................................................................................... J1-43
Key Theme P&A-2: Tree removal/vegetation clearing .................................................................. J1-44
Key Theme P&A-3: Fish and wildlife ............................................................................................ J1-45
Key Theme P&A-4: Impacts to birds ............................................................................................. J1-47
Key Theme P&A-5: Mitigation ...................................................................................................... J1-47
Key Theme P&A-6: Errata and minor clarifications ...................................................................... J1-48
Energy (Topic EGY) ........................................................................................................................... J1-49
Key Theme EGY-1: Energy use of peaker plants ........................................................................... J1-49
Key Theme EGY-2: Alternative 1 would result in increased demand for energy and would
therefore require more fossil fuel use.............................................................................................. J1-49
Key Theme EGY-3: The need for Utilities to adopt measures that reflect sustainability,
conservation, and efficiency ........................................................................................................... J1-50
Pipeline Safety (Topic PLS) ............................................................................................................... J1-51
Key Theme PLS-1: Risk of catastrophic explosions and leaks caused by construction ................. J1-51
Key Theme PLS-2: Risk of catastrophic explosions, fires, or leaks caused by natural forces,
such as earthquakes, windstorms, and lightning ............................................................................. J1-52
Key Theme PLS-3: Risk of pipeline corrosion caused by electrical interference from power
lines ................................................................................................................................................. J1-53
Key Theme PLS-4: Evaluation of worst-case scenario involving pipeline rupture and fire ........... J1-55
Key Theme PLS-5: Risk of non-compliance with safety regulations that apply to Olympic and
PSE .................................................................................................................................................. J1-56
Key Theme PLS-6: Engagement of Olympic in the EIS process ................................................... J1-57
FINAL EIS PAGE J1‐III
APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
Electric and Magnetic Fields and Corona Ions (Topic EMF) ............................................................. J1-58
Key Theme EMF-1: Potential health effects from electric and magnetic fields ............................. J1-58
Key Theme EMF-2: Potential health effects from corona ions ...................................................... J1-59
Key Theme EMF-3: Populations particularly susceptible to electric and magnetic fields ............. J1-59
Key Theme EMF-4: Potential for increase in magnetic fields ........................................................ J1-60
Noise (Topic NOI) .............................................................................................................................. J1-62
Key Theme NOI-1: Noise from corona discharge .......................................................................... J1-62
Key Theme NOI-2: Construction and operational noise ................................................................. J1-62
Key Theme NOI-3: Applicable noise regulations and significance thresholds .............................. J1-63
Key Theme NOI-4: Minor clarifications and Errata ....................................................................... J1-63
Land Use and Housing (Topic LU) ..................................................................................................... J1-65
Key Theme LU-1: Property condemnation ..................................................................................... J1-65
Key Theme LU-2: Easement width required for safety .................................................................. J1-66
Key Theme LU-3: Essential public facility .................................................................................... J1-67
Key Theme LU-4: Greater impacts in denser residential or natural areas ...................................... J1-67
Key Theme LU-5: Errata and minor clarifications ......................................................................... J1-68
Views and Visual Resources (Topic VR) ........................................................................................... J1-70
Key Theme VR-1: Study area and key viewpoints ......................................................................... J1-70
Key Theme VR-2: Methodology .................................................................................................... J1-71
Key Theme VR-3: Project clear zones would reduce visual quality .............................................. J1-73
Key Theme VR-4: Project would be inconsistent with comprehensive plan policies .................... J1-73
Key Theme VR-5: Condemning of homes and installation of a new transmission line would
change the visual character of Eastside neighborhoods .................................................................. J1-74
Key Theme VR-6: Light and glare ................................................................................................. J1-75
Key Theme VR-7: Mitigation ......................................................................................................... J1-76
Key Theme VR-8: Errata and minor clarifications ......................................................................... J1-76
Economics (Topic ECON) .................................................................................................................. J1-78
Key Theme ECON-1: Property value depreciation ........................................................................ J1-78
Key Theme ECON-2: Tax revenue impacts ................................................................................... J1-80
Key Theme ECON-3: Need for a full cost-benefit analysis ........................................................... J1-81
Key Theme ECON-4: Fairness of financial burden ........................................................................ J1-82
Recreation (Topic REC) ...................................................................................................................... J1-84
Key Theme REC-1: Trails in utility corridors ................................................................................ J1-84
Key Theme REC-2: Birding as a recreation activity ...................................................................... J1-85
Key Theme REC-3: Permanent loss of recreation sites .................................................................. J1-85
Key Theme REC-4: Cumulative impacts ........................................................................................ J1-86
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APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
Key Theme REC-5: Errata and minor clarifications ....................................................................... J1-87
Historic and Cultural Resources (Topic H&C) ................................................................................... J1-88
Key Theme H&C-1: Interpretation of impacts ............................................................................... J1-88
Key Theme H&C-2: Analytical process ......................................................................................... J1-89
Key Theme H&C-3: Existing and proposed cultural resources ...................................................... J1-89
Key Theme H&C-4: Errata and minor clarifications ...................................................................... J1-90
Transportation (Topic TRAN) ............................................................................................................ J1-91
Key Theme TRAN-1: General congestion/transportation impacts associated with construction ... J1-91
Key Theme TRAN-2: Potential need to truck contents of the pipelines ......................................... J1-92
Key Theme TRAN-3: Transporting project components ................................................................ J1-92
Key Theme TRAN-4: Mitigation of transportation impacts during construction ........................... J1-93
Public Services (Topic SVC) .............................................................................................................. J1-94
Key Theme SVC-1: Response to pipeline-related incident ............................................................ J1-94
Key Theme SVC-2: Interference with communication devices ..................................................... J1-97
Key Theme SVC-3: Safety measures and plans ............................................................................. J1-97
Key Theme SVC-4: Reliable energy is required for community services to operate ..................... J1-99
Key Theme SVC-5: Minor clarifications ........................................................................................ J1-99
Utilities (Topic UTL) ........................................................................................................................ J1-100
Key Theme UTL-1: Impacts to other utilities ............................................................................... J1-100
Key Theme UTL-2: Utility disruptions caused by terrorism or natural hazards .......................... J1-101
Key Theme UTL-3: Utility oversight ........................................................................................... J1-101
Key Theme UTL-4: Co-location with Olympic Pipeline system .................................................. J1-102
Key Theme UTL-5: Conclusions of the Phase 1 Draft EIS .......................................................... J1-103
Key Theme UTL-6: PSE clarifications and Errata ....................................................................... J1-104
References: ........................................................................................................................................ J1-106
FINAL EIS PAGE J1‐1
APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
Introduction
This appendix describes and responds to the comments received on the Phase 1 Draft EIS, which was
published in January 2016. This appendix was prepared to satisfy SEPA requirements as specified in
WAC 197-11-560. The following is a summary of public comments received on the Phase 1 Draft EIS
and responses to those comments. The comments received covered a range of topics or themes, and
reflect a variety of requests, perspectives, issues of concern, and ideas. The comment-response
summary is organized around the key themes that emerged from the comments and includes responses
to those key themes.
Many comments were statements of either support or opposition to the project or particular alternatives.
Most comments expressed concern about or opposition to PSE’s proposal, although some individuals
and organizations did express support. Other than expressing opposition or support for the proposal, the
comments generally fit into one or more of the following topics or themes:
EIS process and content
Project objectives
Alternatives evaluated in the EIS
Earth
Air quality and greenhouse gases
Water resources
Plants and animals (including tree canopy and vegetation clearing)
Energy
Environmental health and public safety (particular focus on issues related to Olympic
Pipeline system, as well as from electric and magnetic fields [EMF])
Noise
Land use
Views and visual resources
Economic issues (including property values and property taxes)
Recreation
Historic and cultural resources
Transportation
Public services
Utilities
In addition to these topics, some comments were received that were beyond the scope of the EIS
analysis, either because they were not related to potential impacts resulting from the project (such as
requests that the Partner Cities compel utilities like PSE to adopt new technologies to reduce fossil fuel
use), or because they relate to topics not addressed by SEPA (such as who owns PSE or profits from
PSE’s actions).
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APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
This summary and appendix were prepared in compliance with WAC 197-11-560, which states, in part:
“All substantive comments received on the draft statement shall be appended to the final statement or
summarized, where comments are repetitive or voluminous, and the summary appended. If a summary
of the comments is used, the names of the commenters shall be included (except for petitions).”
Given the programmatic nature of the Phase 1 Draft EIS, responses to comments are presented in this
appendix as a narrative summary (organized by topic), followed by reproductions of the comments
received. In the narrative summary, comments and responses are organized by topic, with similar
comments on a given topic grouped as “key themes.” Each key theme is given an alpha-numeric
designation (e.g., “ECON-1” for the first key theme associated with the economics topic). Following
the narrative summary of comments and responses, this appendix includes reproduced copies of all
comments received (including letters, emails, website forms, and testimony), with each individual
comment coded and cross-referenced to the summary response in the narrative, using the alpha-numeric
designation in the narrative summary. Although a separate response was not prepared for each
individual comment, the EIS Consultant Team made a significant effort to capture all substantive issues
raised in the comments and prepared the summary responses to address these concerns. As part of this
process, the EIS Consultant Team reviewed every comment received, employing a database and
separating the information received into over 1,400 individual comments. Recognizing that there is
overlap between topics, there is some degree of intentional repetition in the responses, for clarity; in
other instances, cross-references are provided. A similar process was used for responding to comments
on the Phase 2 Draft EIS; however, responses to Phase 2 comments are presented for each individual
comment received rather than using a narrative summary (see Appendix K).
In addition to the comment-response summary that follows, comments received on the Phase 1 Draft
EIS helped shape the analysis as presented in the Phase 2 Draft EIS and the Final EIS, as well as PSE’s
refined design of the proposed project.
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APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
EIS Process and Content (Topic EIS)
This section describes and responds to the comments related to the overall adequacy of the material
presented in the Phase 1 Draft EIS in the context of meeting requirements of the State Environmental
Policy Act (SEPA) (as opposed to addressing the adequacy of resource-specific technical analysis,
which are discussed in resource-topic summaries).
Key Theme EIS‐1: Objectivity and overall adequacy of the Phase 1 Draft EIS
Comment Summary:
The comments under this theme included general criticism or concern regarding the objectivity of the
Phase 1 Draft EIS based on technical material included within the Draft EIS, or based on the
assessment of impacts. This group of comments includes specific statements that the Phase 1 Draft EIS
did not include an independent evaluation of the need for the project and did not put forth viable
alternatives to PSE’s proposal, and therefore was not objective and/or displayed bias in favor of the
applicant or applicant’s proposal. Commenters also raised questions about the qualifications of the
individuals preparing and reviewing the Draft EIS, whether the consultants had worked for PSE and
therefore had conflicts of interest, and questioned whether the EIS Consultant Team and the Partner
Cities had the proper technical experts available to write and review the Draft EIS.
One commenter stated that the EIS does not adequately quantify the benefits and disadvantages of
delaying the proposal, but rather makes unsubstantiated qualitative generalizations.
Another theme among these comments was that the Phase 1 Draft EIS was inadequate in general,
including statements that the Draft EIS minimized the project’s environmental effects, included
inaccurate or incomplete information, or simply that the Draft EIS had many deficiencies, such as
unsupported opinions and summary conclusions.
Response:
The Phase 1 Draft EIS was prepared under the direction of Environmental Coordinator for the City of
Bellevue (the Lead Agency), in consultation with the co-lead agencies, the Partner Cities of Kirkland,
Newcastle, Redmond, and Renton. As the Lead Agency under SEPA, the City of Bellevue’s
responsibilities are to provide full disclosure of the expected environmental impacts of the Energize
Eastside project and to objectively analyze those impacts, so that decision-makers have adequate
environmental information for the permitting and decision-making process. The Partner Cities hired a
consultant team comprised of qualified firms with extensive experience conducting independent
analysis and preparing SEPA EISs. The EIS Consultant Team is comprised of subject matter experts
that are qualified to analyze the elements of the environment that are included in the EIS. For
specialized analysis related to electrical transmission and pipeline safety, the EIS Consultant Team has
involved engineers, scientists, and scholars in appropriate fields. The EIS Consultant Team is working
on the Partner Cities’ behalf to evaluate the proposal according to the adopted SEPA policies in each
Partner City’s jurisdiction. No member of the team is currently working for PSE or has a personal or
financial interest in the outcome of the project. For all firms working on the EIS Consultant Team,
disclosures were made to the Partner Cities about any past work for PSE. The Partner Cities determined
that this past work did not constitute a conflict of interest for reviewing this project. Other than these
disclosures, no specific conflict of interest was identified by commenters.
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APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
Outside of the EIS process, the City of Bellevue also hired a consultant to independently evaluate the
need for the project. As with the EIS Consultant Team, this consultant was not currently working for
PSE nor do they have a personal or financial interest in the outcome of the project. Because the system
is owned and operated by PSE, any such analysis requires cooperation from PSE, including the use of
reports prepared by PSE or for PSE by other consulting firms contracting directly with them. All
reports submitted by PSE were reviewed independently by experts in the respective fields of study.
As outlined in WAC 197-11-060 (3)(a), it is the responsibility of the Lead Agency to make certain that
a proposal that is the subject of environmental review is properly defined. The process of defining the
proposal includes a complete and impartial understanding of the proposal’s objectives and technical
requirements, in order to accurately identify feasible and reasonable project alternatives for
consideration in the EIS. As noted in WAC 197-11-060(3)(a)(iii), proposals should be described in
ways that encourage considering and comparing alternatives, and agencies are encouraged to describe
proposals in terms of objectives rather than preferred solutions. Specific responses to questions about
the need for the project are provided under the Project Objectives (Topic OBJ) section of this comment
response appendix.
This EIS will not be used to validate or reject the need for the proposal. Rather, the EIS is intended to
identify alternatives that could attain or approximate PSE’s objectives at a lower environmental cost
and disclose potential significant adverse environmental impacts associated with the alternatives
identified.
The opinions of commenters concerning the completeness and adequacy of the Phase 1 Draft EIS are
noted. The Partner Cities believe that the Draft EIS contains a reasonably thorough analysis of the
potential environmental impacts of the project, as required by SEPA. As discussed in the Phase 1 Draft
EIS, environmental information was compiled based primarily on literature reviews and
communications with knowledgeable resource agencies. Assumptions made in the analysis were
explained so that the reader could understand what was assumed and why, and any errors identified
during review are addressed in the Errata in this Final EIS.
The Phase 1 Draft EIS provides a high-level, programmatic assessment of potential impacts of the
project within the combined study area. The Phase 2 Draft EIS provides a more detailed, project-level
analysis. Every attempt was made to use the most current data and information reasonably available
prior to publication. In instances where updated data were released in time to be used for the Phase 2
Draft EIS analysis, the information was reviewed and incorporated into the Phase 2 documents.
The advantages and disadvantages of delaying the project are described qualitatively, in the context of
the detailed information provided elsewhere in the EIS. SEPA does not require a quantitative analysis
of these topics. Section 2.5 of the Phase 1 Draft EIS provides a high-level summary of the findings of
that analysis, indicating that there are both advantages and disadvantages associated with delay.
Specific issues with the adequacy of the Phase 1 Draft EIS analysis that were raised in comments
regarding bias, accuracy, or thoroughness are addressed below in the appropriate topic and key themes
sections. The Partner Cities found the analysis to be unbiased, accurate, and thorough for the level
appropriate for this stage of review. Where there were errors noted in comments or discovered after the
Phase 1 Draft EIS was published, these have been noted in the Errata in both the Phase 2 Draft EIS and
the Final EIS.
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APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
Key Theme EIS‐2: SEPA process, including phased EIS and opportunities for
meaningful public input
Comment Summary:
The comments under this theme addressed various aspects of the SEPA process for the project. Many
commenters expressed criticism of the phased environmental review process. This group of comments
includes specific statements that in order to conduct a true phased review, the Partner Cities would
prepare a Phase 1 Final EIS following the comment period on the Phase 1 Draft EIS, and would use the
analysis in the Phase 1 Final EIS to narrow the range of alternatives to be analyzed in Phase 2.
Commenters also requested that permits for the project be processed after completion of each phase of
the EIS.
Several commenters stated that the length of the document was overwhelming. One commenter noted
that the document exceeds 150 pages when WAC 197-11-425(4) states in part: “The EIS text shall not
exceed seventy-five pages; except for projects of unusual scope and complexity, where the EIS shall
not exceed one hundred fifty pages.” The commenter requested that future iterations of the EIS be
limited to no more than 150 pages, with detailed information in appendices. Several commenters
requested that the Partner Cities extend the Draft EIS comment period to allow people more time to
review the EIS and background documents before submitting comments.
Several commenters requested that the Partner Cities pause the EIS process and further review the need
for this project, with several commenters mentioning the desire to have a Hearing Examiner review the
project before the EIS process is finished. At least one commenter stated that the method of referencing
throughout the Phase 1 Draft EIS was cumbersome and inadequate, and requested an extension of the
comment period because of the difficulty of checking these references.
Some commenters stated that the Partner Cities should compel PSE to release requested information to
the public, as well as other requests for the process to be more transparent.
Several commenters said the length of the SEPA process is frustrating for landowners who feel they
cannot make major decisions about their properties until a final decision is made about the proposal.
Other commenters stated that the process lacked opportunities for meaningful public input, suggesting
that more direct coordination occur with property owners and others who would be affected, as well as
the need to incorporate the perspectives of affected citizens into the decision-making process (e.g., the
CAG).
Response:
The Partner Cities acknowledge the opinions of the commenters concerning the sufficiency of the
Phase 1 Draft EIS and SEPA process. As described in Section 1.5 of the Phase 1 Draft EIS, the Phase 1
Draft EIS is the first phase of a two-phase Draft EIS process to evaluate the potential for significant
environmental impacts. This approach is consistent with the requirements for Phased Review outlined
in WAC 197-11-060 (5)(c). The Phase 1 Draft EIS analysis is a voluntary expansion of the EIS process
to better inform decision-makers and the public about the environmental consequences of various
approaches that could be taken to address PSE’s objectives. No regulatory decision or approval was or
will be made, or is required, based on the Phase 1 Draft EIS other than the use of its conclusions to help
form the scope for the Phase 2 Draft EIS. No action, as defined under SEPA, was taken on the Phase 1
Draft EIS. As such, the Partner Cities believe that a Phase 1 Final EIS was not required. The
information presented in the Phase 1 Draft EIS did help narrow the scope of issues to be covered in the
FINAL EIS PAGE J1‐6
APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
Phase 2 Draft EIS, and to ensure that the decision-making process is transparent and consistent with the
commitment made by the Partner Cities to the public.
The Phase 1 Draft EIS contains a reasonably thorough discussion of the potential environmental
impacts of the range of programmatic options available to address PSE’s identified objectives for the
project. The Phase 1 Draft EIS, together with the Phase 2 Draft EIS, contribute to meaningful analysis
of the project, reasonable alternatives to PSE’s proposal, and its impacts, as required by SEPA.
The Partner Cities acknowledge that the Phase 1 Draft EIS exceeded 150 pages. This was due to the
complexity of the information considered, the number and variety of alternatives evaluated, and the
extent of the geographic area considered (in particular, the number of local jurisdictions that could
potentially be affected by the project, each with its own policy and regulatory framework). The Partner
Cities note that the length of the EIS is not uncommon when compared to other similarly complex EIS
documents. The wide range of information included is also due to the range of impacts that the public
requested be reviewed based on feedback during the scoping process. With the range of impacts being
assessed and the number of alternatives evaluated, in order to meet the SEPA rule for length of the
document, even greater portions of the analysis would have to be relegated to appendices, which also
frustrated readers. The summary information provided in Chapter 1 is intended to provide information
that can assist the public in its review. The Phase 2 Draft EIS considers a more focused project-level
scope, and every effort was made to limit the Draft EIS text, with more detailed technical information
provided in appendices.
The Partner Cities provided a 45-day public review and comment period for the Phase 1 Draft EIS,
which is 15 days longer than the minimum required and consistent with SEPA regulations for allowing
adequate time for Draft EIS review and comment. The Partner Cities provided timely and broad
distribution of the Phase 1 Draft EIS, with noticing, web postings, and periodic updates to encourage
public awareness of the Draft EIS and comment period. The Partner Cities also posted the Phase 1
Draft EIS on the agencies’ websites and held five public meetings on the Phase 1 Draft EIS.
Concerning the request to pause the EIS process to further review the project need, the Partner Cities
must evaluate PSE’s proposal to construct 230 kV overhead transmission lines in a timely way. The
Partner Cities do not have the authority under SEPA to make a determination that there is no need for a
proposal or to change the applicant’s objectives or proposal for purposes of review under SEPA (see
the responses under Project Objectives). Rather, their role is to understand the proponent’s objectives
and evaluate reasonable alternatives that meet the proposal’s objective at a lower environmental cost.
The project will follow all requisite permitting processes in the applicable jurisdictions. A “permitting
handout” (see Section 1.10) has been prepared that identifies the permit process associated with
required land use decisions, as well as future opportunities for the public to comment, which can be
viewed on the website maintained by the Partner Cities: www.Energize EastsideEIS.org.
The Partner Cities do not have the authority to compel PSE to release the modeling assumptions used in
its utility planning process. It is up to PSE to manage the release and disclosure of modeling data.
The Partner Cities acknowledge that the SEPA EIS process can be lengthy. The time needed to review
a proposal and prepare an EIS depends on the complexity of the project, the amount of information
already available, and the need to complete additional analysis or studies. SEPA rules also require
public comment periods, some of which have been extended with the applicant’s agreement beyond the
regulatory maximum, in order to ensure the public has time to provide input. As part of the process, the
Partner Cities and EIS Consultant Team must have sufficient time to develop alternatives, conduct
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analysis, and prepare the EIS. The Partner Cities will use the information in the EIS when making
decisions to approve, deny, or place conditions on any future application submitted by PSE. Agencies
can review permit applications concurrent with the SEPA process but cannot make permitting decisions
until after the Final EIS is issued. The Partner Cities conducted extensive outreach to solicit input
during scoping and Draft EIS comment periods for the Phase 1 Draft EIS, as described in the Summary
Phase 1 EIS Public Scoping Meetings and the Summary Phase 1 Draft EIS Public Hearings, available
on the project website at www.EnergizeEastsideEIS.com.
Key Theme EIS‐3: Completeness of the Draft EIS scope
Comment Summary:
The comments under this theme include a variety of issues related to the completeness of the Phase 1
Draft EIS scope. These comments included questions about the incorporation of scoping comments,
requests for additional information on economic impacts, and requests for a comparison of alternatives
through the lens of reliability vs. costs (both monetary and environmental impacts). Several
commenters requested that the analysis weigh potential environmental impacts against PSE’s
objectives.
Comments related to the incorporation of scoping comments stated that the Phase 1 Draft EIS does not
meaningfully consider all scoping comments. Commenters identified a number of scoping comments,
including comments stating positions on specific alternatives that they assert were either not addressed,
or addressed in a cursory fashion.
Some commenters stated that the Phase 1 Draft EIS needed more details related to design of the project,
including specifications on pole width, placement, and height, as well as mitigation that would be
pursued for the project to reduce site impacts.
Several commenters requested that the EIS include more cost information and more information on
reliability improvements that the project would provide, and asserted that the Partner Cities have a
“fiduciary duty” to do so.
Response:
Under SEPA, decision-makers in the permit process are not required to choose the alternative with the
least impacts identified in an EIS. The EIS is intended to be a disclosure document providing decision-
makers with information about potential impacts and options (within their jurisdiction and regulatory
authority) that could reduce or eliminate some or all of the impacts of the project.
An EIS is not intended to be a cost-benefit analysis for a project; rather, an EIS is intended to provide
environmental information to be considered alongside economic and other policy considerations in
reviewing projects that could significantly impact the environment. An EIS can include economic
information at the discretion of the Lead Agency, but economic information is not a required element
under SEPA (WAC 197-11-448). Additional discussion of economic issues can be found under Key
Theme ECON-1 through ECON-4. The Partner Cities’ duties under SEPA are regulatory not fiduciary.
The scoping comments received for the Phase 1 Draft EIS were considered in determining the
alternatives studied in the Phase 1 Draft EIS. The Partner Cities and EIS Consultant Team considered
what technically viable alternatives should be included and what issues are important for the range of
considerations in the Phase 1 Draft EIS. For example, Alternative 2 considered a number of
components that were requested to be considered together as a way to generate a viable alternative to
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the construction of new transmission lines. The Phase 1 Draft EIS follows the SEPA direction (WAC
197-11-402) that an EIS should analyze only probable, significant adverse impacts and that the
discussion of insignificant impacts is not required (and, if included, it should be brief). Accordingly, the
Phase 1 Draft EIS does not address or only briefly addresses impacts that are speculative and not
probable, or probable but insignificant.
Similarly, project-level specifics on pole design and siting are included in the Phase 2 Draft EIS
analysis, including detailed mitigation information throughout, with more detailed and updated
information presented in the Final EIS for PSE’s Proposed Alignment.
The Energize Eastside project is being undertaken to meet PSE’s objective to supply future electrical
capacity that meets regulatory requirements for operation of the Eastside’s electrical grid, as described
in Section 1.3 of the Phase 1 and Phase 2 Draft EISs. Because the majority of power outages on the
Eastside are related to the electrical distribution system and the Energize Eastside project will affect
only the reliability of the transmission system, the project would have limited impact on overall
electrical reliability. SEPA also does not require that an EIS discuss fiscal impacts or include a cost-
benefit analysis (WAC 197-11-450). Therefore, the EIS does not include an analysis of the reliability
versus costs that the project alternatives would have.
PSE’s pursuit of emerging alternative technologies to supply capacity to the Eastside is outside the
scope of the SEPA process insofar as it extends beyond the environmental analysis required for the EIS
process. An integrated resource approach is included as part of the Phase 1 Draft EIS analysis and is
summarized in Section 2.3.3 of the Phase 1 Draft EIS.
Key Theme EIS‐4: Graphics and text
Comment Summary:
Several commenters pointed out edits or changes they would like to see in the document. Most of these
commenters made requests to change the graphics in the document in some way, either because of an
error they perceived (e.g., liquefaction areas labeled as seismic hazard areas on Figure 2-3), or that they
were generally confusing. Some requested more or specific maps. PSE made two clarifications, stating
that the gray area on Figure 1-1 is meant to show the customers potentially affected by rotating outages,
and that the text in Chapter 1 should be updated to indicate that the SCL 230 kV line goes through the
center of the Eastside. One commenter noted difficulties in using the project website and its
commenting/emailing features, as well as inconsistent use of project terminology (such as the names of
the alternatives).
Response:
Numerous graphics were reworked for the Phase 2 Draft EIS. The EIS Consultant Team and the Partner
Cities worked to create graphics that would best represent what the EIS is intending to communicate.
The clarifications made by PSE and others are incorporated into the Errata for the Phase 1 Draft EIS
(see Chapter 3 of the Final EIS).
Multiple opportunities to comment on the Draft EIS were provided in addition to the project website,
including providing oral testimony at public hearings, sending letters by post to Bellevue City Hall, and
emailing info@energizeeastsideeis.org. Every effort is made to conduct editorial review of EIS-related
materials to ensure consistent use of terminology, including names of the alternatives.
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Project Objectives (Topic OBJ)
This topic includes comments related to the overall project objectives as presented in Chapter 2 of the
Phase 1 Draft EIS. Key themes include the objectives of the PSE proposal, disagreement with PSE’s
planning data and assumptions and how they define project need, and questions about ColumbiaGrid.
Key Theme OBJ‐1: Objectives of proposal (to address reliability issues or to increase
capacity for other purposes)
Comment Summary:
This group of comments includes questions about the overall objectives of PSE’s proposal. Comments
about specific planning data and assumptions are addressed below under Key Theme OBJ-2:
Disagreement with PSE’s planning data and assumptions and how they define project need.
Numerous commenters questioned the need for (and PSE’s motives for) the project. These included
specific comments requesting clarification of the need and whether it is related to growth and/or
reliability/peak demand, as well as the size of the need and timing of the need. Several commenters
expressed doubt that the demand is adequately justified by the studies examined by the EIS Consultant
Team, and requested that each of the issues noted above be supported with more detail. Numerous
commenters expressed doubt that the stated purpose was honest in depicting the intention of the project
and questioned the true likelihood of a power outage. Some commenters stated that PSE is incentivized
to build an expensive, oversized solution to the problem because it leads to higher returns on equity.
Commenters stated that PSE has provided inconsistent or confusing reasons to justify the project
objectives (or the need for the project), and that Stantec (the consultant hired to review the PSE needs
assessment to ensure it was conducted in accordance with industry standards) has a conflict of interest
because they have worked for PSE in the past. One commenter suggested that PSE conflated separate
issues related to transmission capacity deficiency (load growth) and peak demand assumptions. It was
further suggested that these two issues have separate solutions, and that conflating these issues has
limited the examination of viable alternatives in the Phase 1 Draft EIS. Commenters also questioned the
different numbers that PSE has presented for their deficiency estimate, pointing to the 2014 CAG
process, which forecast an overall need of 660 MW. The actual capacity used that year was 75 MW
lower than the predicted number. The 2015 Supplemental Needs Assessment study shows a need
deficiency of 74 MW by winter 2017-18 or summer of 2018. Commenters thought that the deficiency
of 133 MW stated in the Phase 1 Draft EIS (by the end of the study period, summer 2024) conflicted
with the actual need.
Several commenters made statements and raised questions about whether there is a direct relationship
between Bonneville Power Administration (BPA) and PSE facilities, whether BPA and PSE have made
arrangements to avoid cost allocation and NEPA requirements for the project, and whether PSE has
appropriately defined the project purpose and objectives. Commenters suggested that by not including
the Energize Eastside project in the regional transmission plan, PSE avoids FERC Order 1000
compliance and side-steps NEPA review.
Many comments focused on the economic motives for the project and other economic considerations
they felt should be considered by the Lead Agency in determining the project objectives and
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alternatives for the Phase 1 Draft EIS. The following summarizes the most frequently provided
comments relating to economic considerations.
Commenters asserted that PSE has an additional objective to transmit and sell electrical power
outside of PSE’s service area (to Canada and California, referred to as “wheeling” power) that
expands the project need and scope from PSE’s stated project intent.
Commenters questioned how much of the project’s need is based on the ability to participate in
additional power “wheeling” outside the region.
Commenters asserted that the Phase 1 Draft EIS does not adequately address appropriate cost
allocation for this project.
Commenters suggested the project is for the benefit of a foreign-based investment (or hedge)
fund in Australia and that PSE customers will pay and Eastside communities will suffer
impacts.
One commenter questioned who has the authority to review the project objectives and need and
whether it would be appropriate to move the Phase 1 Draft EIS to the Washington State Energy Facility
Site Evaluation Council (EFSEC).
Some commenters questioned whether or not building the project could discourage growth and
development on the Eastside, as stated in the Phase 1 Draft EIS, Section 2.5. Commenters who voiced
support for the Energize Eastside project stated that relying on 60-year-old utility facilities was poor
public policy and that the needs of the approximately 300,000 customers who would be served by the
transmission corridor should be considered.
Response:
As described in the Phase 1 Draft EIS, an EIS is intended to evaluate the probable significant
environmental impacts of a proposed project or program. The Phase 1 Draft EIS does not evaluate
whether or not a project is needed. The EIS does take into account PSE’s description of the need for the
project in establishing the project objectives and what alternatives should be included. Also, an EIS is
not a permit, although it is intended to be used by officials making decisions about whether to approve,
deny, or conditionally approve permits for a project.
SEPA requires that the Lead Agency evaluate the proposal as described by the applicant. Therefore, the
Phase 1 Draft EIS must evaluate PSE’s proposal to construct 230 kV overhead transmission lines. The
Lead Agency has limited authority to question an applicant’s motives and cannot use SEPA authority to
alter the objectives of an applicant for purposes of review under SEPA. The Lead Agency must ensure
that the project is properly defined, and that the alternatives are based on reasonable assumptions
developed using industry standard methods. The Partner Cities have done so by having qualified
electric engineering professionals review planning methods and assumptions. For all firms working on
the EIS Consultant Team, including Stantec, disclosures were made to the Partner Cities about any past
work for PSE. The Partner Cities determined that this past work did not constitute a conflict of interest
for reviewing this project, and furthermore, none of the EIS Consultant Team members are currently
under contract with PSE.
As described in the Phase 1 Draft EIS, transmission of electrical power outside of PSE’s service
territory is not an objective of the project. However, as with all of PSE’s transmission equipment, the
project would be part of the regional electric power grid. As such, it is virtually impossible to prevent
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flows of electricity from or to other regions over PSE’s transmission lines, and PSE has a regulatory
responsibility to keep power moving through the grid in accordance with ColumbiaGrid commitments
and federal guidelines. As such, PSE has included expected peak regional power flows in its planning
model as required, and has not increased them beyond those recommended by ColumbiaGrid to justify
the project.
In determining the capacity deficiency for 2024, PSE used best available data and industry-standard
utility planning modeling. Comments regarding the extent of the need seemed to confuse the near-term
need (2017-2018) with the long-term need (2024) and saw these as conflicting. As described in Chapter
1 of the Phase 1 Draft EIS, PSE expects the deficiency to grow over time. It is acknowledged that there
was a difference between what PSE modeled for 2014 and the actual capacity used. This is because, for
planning purposes, PSE is required to look at what its peak loads could be, if weather conditions and
customers’ projected demands materialize. Customer demand in particular is difficult to predict for the
near term because major customers may project faster growth than actually occurs. As a result,
differences between modeled predictions and the actual capacity used are to be expected in any
planning exercise. It is acknowledged that, over the long term, energy efficiency, economic conditions,
and other factors may reduce the actual loads, thus delaying the need for the project. Because of the
time required to plan and build transmission infrastructure, electrical utilities typically must plan years
in advance, making assumptions about consumer behavior that do not presume improvements in
efficiency that have not yet been adopted by consumers.
Comments and questions regarding FERC Order 1000 cost allocation requirements and related NEPA
review were previously raised in a complaint directed to FERC and were previously addressed by
FERC (see “Letter Clarifying Bonneville Power Administration’s role in Energize Eastside” and
“Letter Clarifying ColumbiaGrid’s role in Energize Eastside” within the documents section of the
Phase 1 Draft EIS project website: www.EnergizeEastsideEIS.org).
This EIS is being prepared by the City of Bellevue as the Lead Agency on behalf of the Partner Cities
because the project crosses all of the jurisdictions. The Partner Cities will use the Phase 1 Draft EIS to
inform their permitting process, and they, as the permitting agencies, have the authority to review the
documents produced for the EIS process. The City of Bellevue took on the role as the Lead Agency for
the Energize Eastside EIS because it is the largest and potentially most affected city. The project is not
required to be under EFSEC jurisdiction. The facilities subject to review by the EFSEC are found here:
http://www.efsec.wa.gov/cert.shtml#Certification2. Electrical transmission lines other than those in a
national interest transmission corridor (which Energize Eastside is not; USDOE, 2015) are only subject
to EFSEC review if:
a) the applicant chooses to receive EFSEC certification;
b) the transmission lines are at least 115 kV; and
c) the transmission lines are located in a new corridor or located in more than one jurisdiction that
has promulgated land use plans and zoning ordinances.
EFSEC review and certification would pre-empt all local SEPA and permit review. In this case, PSE
has not requested EFSEC certification.
The Washington Utilities and Transportation Commission (WUTC) also has authority to examine
whether the project is needed for purposes of establishing utility rates, but does not have a role in
determining need or purpose in the context of SEPA. If the WUTC determined that the project was not
needed, PSE would not be allowed to recover costs for the project in its utility rates.
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In regard to comments on the economic motives for the project, the Phase 1 Draft EIS is not required to
evaluate who would profit from a project. As discussed above, the EIS consultant team did review the
planning model and found that PSE had used standard planning practices and had not modified any
regional transmission planning assumptions beyond those recommended by ColumbiaGrid to justify the
project through wheeling of additional power. The EIS is also not required to evaluate cost allocation.
Regarding the discussion in Section 2.5 of the Phase 1 Draft EIS Benefits and Disadvantages of
Delaying the Proposal, electrical reliability has been an issue for Eastside cities for many years, as
reflected in policies in the comprehensive plans of the Partner Cities and other Eastside cities. In
comments received on the Phase 1 Draft EIS to date, businesses in the Eastside have indicated that
energy reliability is critical to their business growth.
Key Theme OBJ‐2: Disagreement with PSE’s planning data and assumptions and how
they define project need
Comment Summary:
One commenter asked how the City Council (Bellevue) established that the project is necessary.
Several commenters requested further data and independent analysis to ascertain the validity of the first
project objective, “Address PSE’s identified deficiency in transmission capacity.” These comments
assert that the PSE Eastside Needs Assessment is based on flawed assumptions and is limiting the
evaluation of viable alternatives. These comments further state that the independent studies cited in the
Phase 1 Draft EIS were cursory and are not sufficient because they either did not run their own load
flow studies, or they used load scenarios and assumptions provided by PSE, which commenters assert
are flawed or inaccurate. These commenters requested access to unredacted data and additional
independent studies to identify the base case scenario and assumptions used in the load flow analysis.
Commenters specifically took exception to the PSE assumption of simultaneous transformer failure
during a winter peak load event, which was seen as not only unlikely by commenters, but a scenario
that has not occurred in the past. Commenters also noted that there has been an overall drop in per-
capita energy consumption and stated that conservation upgrades were not adequately incorporated into
PSE’s needs assessment. Several commenters spoke on factors that would lead to reduced electricity
consumption for the demand models, such as a move toward natural gas for home and commercial
heating needs, and the inclusion of projected energy conservation from outside the Energize Eastside
area. Conversely, some commenters anticipate increased electric vehicle use as contributing to greater
reliance on electricity in the future. A commenter also stated that the proposed PSE reliability projects
listed in the 2014 Bellevue Reliability Overview should be implemented before a project like Energize
Eastside is pursued. The commenter requested that these reliability projects be addressed in the EIS.
One commenter asserted that the Seventh Power Plan from the Northwest Power and Conservation
Council found that the Energize Eastside project was not needed. Another commenter noted that PSE
reduced the projected growth in its 2015 Integrated Resource Plan (IRP) as evidence that the project
assumptions in 2014 were overstated. One commenter stated that PSE and ColumbiaGrid studies did
not reflect the Remedial Action Schemes (RAS) and Schedule Adjustment Schemes that have been put
in place for Northern Intertie schedules, and that any significant change (decrease) in electricity
generation capacity, like the retirement of Colstrip Power Plant, must be included in the overall EIS for
the Energize Eastside project.
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Response:
This project is proposed by PSE and is not a City-funded project. The Bellevue City Council is not
responsible for establishing whether the project is needed. In addition, the Lead Agency (in this case,
the City of Bellevue) has limited authority to question an applicant’s motives and cannot use SEPA
authority to alter the objectives of an applicant for purposes of review under SEPA. The Phase 1 Draft
EIS acknowledges that the project would provide more than adequate capacity to meet the projected
need in the 10-year planning horizon. However, as discussed in the Phase 1 Draft EIS, there is no
intermediate size of transmission facility between 115 kV and 230 kV capacity that would work within
the regional grid. See Section 2.2.1.15 for discussion of 115 and 230 kV transmission lines. The
Eastside Needs Assessment was reviewed by the EIS Consultant Team, which confirmed that it was
conducted in accordance with industry standards for utility planning. Please see the Stantec memo
referenced in the Phase 1 Draft EIS, which is available on the Energize Eastside EIS project website.
The Partner Cities cannot compel PSE to release its modeling assumptions.
The growth rate within the Eastside has been and is expected to continue to be greater than the growth
rate in PSE’s overall service area. The growth rate used for the IRP relates to PSE’s entire system, not
just the Eastside. The IRP also focuses on overall power sources, not on transmission capacity. The
Energize Eastside project is not in response to a shortage of electrical generation resources, although it
is acknowledged in the Phase 1 Draft EIS that adding generation capacity within the Eastside could
alleviate some of the transmission capacity deficiency. The Energize Eastside project has to do with a
projected deficiency in transmission capacity resulting from growth in electrical demand that, due to
federal regulatory requirements to protect the regional grid, could result in adverse effects on residents
and businesses on the Eastside, as described in Chapter 1 of the Phase 1 Draft EIS.
In response to comments about the RAS, electrical generation could help address the transmission
capacity deficiency if the generation facilities were constructed within the Eastside. Alternative 2 of the
Phase 1 Draft EIS evaluates the addition of generation facilities within the Eastside.
Conservation efforts were reviewed for the Phase 1 Draft EIS and are summarized in a memo contained
in Appendix A of the Phase 1 Draft EIS. The 119 MW number is an approximate level of conservation
that is included in the IRP. The example shown in Figure 2-13 of the Phase 1 Draft EIS is intended to
illustrate the approximate additional conservation that would be necessary within the Eastside to meet
the project’s objectives. Conservation outside of the Eastside area would contribute little toward
meeting this objective. Similarly, producing additional electricity outside of the Eastside area would do
little to affect the need for the project (Stantec, 2015). (Also see response to Lauckhart/Schiffman study
finding #2 in Key Theme OBJ-3, below).
The Seventh Northwest Conservation and Electric Power Plan does not make reference to this project
or say it is unnecessary.
Key Theme OBJ‐3: Lauckhart/Schiffman Load Flow Study suggests project is not
needed
Comment Summary:
Several commenters cited a load flow study completed by Richard Lauckhart and Roger Schiffman
(and submitted with their comments), which rejects PSE’s needs assessment for the project. Mr.
Lauckhart and Mr. Schiffman used the industry-standard simulation software, GE PSLF, for their study,
which is the same software that PSE used in the modeling to support its needs assessment. The
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Lauckhart/Schiffman study, however, acknowledges that it is based on a database provided by FERC,
because PSE declined to share its database and modeling assumptions. Commenters requested that the
Partner Cities pause the EIS process and review the need for this project by either accepting the
Lauckhart/Schiffman analysis or contracting for an independent study that includes an “honest,
transparent and verifiable” load flow study.
Commenters pointed to five main findings of the Lauckhart/Schiffman study. Each of these main
findings is listed in bold below, followed by a response intended to clarify the issue presented.
The responses were developed by the EIS Consultant Team after review of the Lauckhart/Schiffman
analysis by Stantec and requests for additional information from PSE regarding its planning
assumptions and results.
Lauckhart/Schiffman study finding #1: PSE modified data to increase transmission of electricity
to Canada from 500 megawatts (MW) to 1,500 MW, which during winter peak loads creates
instability in the regional grid. (The Lauckhart/Schiffman study authors assert this is an
unrealistic level of electricity transmitted to Canada.)
Response:
PSE did modify the Western Electricity Coordinating Council (WECC) model to reflect this amount of
peak energy flow to Canada. According to Stantec, modification of the WECC model is a commonly
accepted practice, where an individual utility provider uses the model to evaluate its specific system.
PSE confirmed that the value for the energy flow to Canada (over the Northern Intertie) that is in the
base case was set at 500 MW by WECC, as a starting place for planning studies. Planners are expected
to adjust that value to reflect firm transmission commitments, as required by North American Electric
Reliability Corporation (NERC) planning standard TPL-001-4 R1. PSE used the value set in its
agreements with the regional planning authorities, specifically from the ColumbiaGrid Biennial Plan.
Neither the 500 MW nor the 1,500 MW numbers reflect the maximum flows that actually occur over
the Northern Intertie during winter conditions. BPA data show that the maximum flow exceeds 2,000
MW at times. The 1,500 MW value is considered reasonable by ColumbiaGrid in its Biennial Plan for
planning for heavy winter conditions, which is PSE’s justification for making this modification in the
model. According to Stantec, this is the type of adjustment that utility providers are expected to make
when using the WECC model for system planning.
Furthermore, of the energy flowing over the Northern Intertie, only a small portion flows through the
Eastside. The EIS Consultant Team asked PSE to clarify how much of the Northern Intertie flow was
flowing through the substations on the Eastside where the capacity deficiency has been identified. PSE
clarified that between 1 and 2 percent (15 and 30 MW) of the 1,500 MW flowing north over the
Northern Intertie in the heavy winter model currently flows through the substations on the Eastside.
The lower value is the amount of flow that would be expected under normal conditions (with all
regional grid systems functioning). Stantec confirmed that this was consistent with their expectations,
given the presence of higher capacity lines in the region that would have lower resistance than PSE’s
existing 115 kV lines, and therefore would be more likely to carry the load flowing north over the
Intertie. If the Energize Eastside project were built, PSE indicated that according to the model, this flow
would increase to 45 MW under normal conditions. PSE also clarified that the direction and strength of
the flow of power can determine which substation would feed the Eastside (Sammamish or Talbot
Hill). Under conditions where other portions of the regional grid are not fully functioning, the flow on
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the proposed lines could rise to as much as 120 MW. Stantec again confirmed that this was a
reasonably expected outcome, because the new lines would have lower resistance than the existing
lines. While increased flow through the Eastside to the Northern Intertie is an expected result of the
upgraded capacity on the Eastside, the increase is not one of PSE’s objectives for the Energize Eastside
project, but simply a byproduct of the capacity increase.
Lauckhart/Schiffman study finding #2: PSE assumed that six local generation plants were out of
service, adding 1,400 MW of demand for transmission. This assumption also causes problems for
the regional grid. (The Lauckhart/Schiffman study authors questioned PSE’s rationale for this
assumption.)
Response:
It is acknowledged that failure of components of PSE's system simultaneously with a high demand
period due to high or low temperatures is not a common event. As noted in the Phase 1 Draft EIS,
however, having one component of its system down for planned maintenance is relatively common
throughout the year. While the exact probability of such an event is not of concern under SEPA, it is
acknowledged that it is possible that in any given year, it might not occur. NERC standards require PSE
models to “stress the system” to ensure that PSE’s system would operate without damaging other parts
of the grid when such stresses occur. PSE ran the model with a group of plants “out of service” for the
“low generation scenario” in testing its system. PSE also ran a “low-average generation” scenario with
1,000 MW of generation turned on, to determine if running generation would relieve the overloads seen
with the low generation scenario. PSE found that, while the transmission line overloads seen with the
low generation scenario were relieved by running generation, the transformer overloads were not
relieved for the full 10-year planning period. In the “winter scenarios,” adding 1,000 MW of Puget
Sound area generation resulted in 15 MW of change in loading at the Talbot Hill substation, which is
not enough to address the increased demand over the 10-year planning period.
Having these plants out of service was not the only stress that was modeled. PSE indicated that its
studies identified up to 40 different contingencies that violated the NERC standards over the 5- to 10-
year study period. In other words, while having the Puget Sound area generation plants out of service
was one scenario that contributes to the transmission capacity deficiency PSE has identified, there are
others that also could result in violations of the reliability standards, regardless of whether these
generators were considered to be “on” or not. Stantec reviewed the results showing there were cases in
which, even with these plants set as “on” in the model, there were still overloads in the Eastside,
indicating that those overloads are a problem local to the Eastside (Stantec, 2015).
Lauckhart/Schiffman study finding #3: The study authors assert that even if the regional grid
could sustain the level of demand under the condition set up by the first two findings, it is
unlikely that regional grid coordinators would continue to deliver 1,500 MW to Canada while
emergency conditions were occurring on the Eastside.
Response:
PSE indicates that it has a responsibility for planning its system according to NERC requirements.
Operation of the system as it relates to the flows on the Northern Intertie is up to BPA and not within
PSE’s control. PSE used the load levels that were in the WECC model because those are the conditions
that utility operators in the region agree that each utility’s system should be capable of accommodating.
Furthermore, less than 5 percent of the northward flow over the Intertie flows through the Eastside.
Therefore, to use curtailments over the Intertie as a means to address congestion on the Eastside as
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suggested in the comment, flows over the Intertie would have to be reduced by approximately 20 times
the amount of the deficit being experienced on the Eastside transmission system.
Lauckhart/Schiffman study finding #4: The WECC base case contains a default assumption that
PSE may not have corrected. The ratings for critical transformers are based on “summer
normal” conditions, but the simulation should use significantly higher “winter emergency”
ratings. The study authors suggest the default value could cause PSE to underestimate system
capacity and overstate urgency to build the project.
Response:
PSE used multiple WECC base cases for different study years and seasons, as confirmed by Stantec.
PSE has confirmed that they used all the correct ratings in the model, including adjusting for summer,
winter, and emergency conditions as required for each scenario evaluated. Stantec confirmed that
results are consistent with such adjustments being made, although they did not independently verify all
settings in PSE’s model. To do so would require extensive analysis, including verifying the capacity of
every piece of equipment that PSE operates, and evaluating past and expected trends in energy usage by
PSE customers, which was not considered necessary for purposes of SEPA review.
Lauckhart/Schiffman study finding #5: The base case shows a demand growth rate of 0.5 percent
per year for the Eastside. This is much lower than the 2.4 percent growth rate that PSE cites as
motivation for Energize Eastside.
Response:
WECC base cases are based on each utility’s latest load forecast for the specific years being modeled.
The WECC base case in 2012 did not have a specific growth rate from PSE for the Eastside because
PSE only performed a system-wide forecast for 2012. The 0.5 percent growth rate cited by the
Lauckhart/Schiffman report for the Eastside reflected average growth for PSE’s entire system. The
WECC base case did not include a specific rate for the Eastside. PSE subsequently determined that the
load for the Eastside area studied in the Phase 1 Draft EIS is expected to grow at a faster rate than the
rest of the PSE system. As described in the Phase 1 Draft EIS, PSE’s analysis of growth expected for
the Eastside was 2.4 percent. PSE used regional planning employment and population projections
provided by the Puget Sound Regional Council and accounted for known growth expectations of its
major customers.
PSE’s Eastside Needs Assessment Report prepared by PSE, the Supplemental Eastside Needs
Assessment Report prepared by Quanta Technology and PSE, and the Independent Technical Analysis
prepared by Utility System Efficiencies, Inc. for the City of Bellevue confirms the project need. Stantec
reviewed the analyses and found them to be in accord with standard industry practice for electrical
system planning.
PSE also provided specific comments on the Energize Eastside Phase 1 Draft EIS (March 14, 2016),
which are posted on the Partner Cities’ project website at www.EnergizeEastsideEIS.org, as well as in
this appendix (following the response to comment narrative).
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Key Theme OBJ‐4: ColumbiaGrid
Comment Summary:
Commenters voiced concern about the role of ColumbiaGrid in pursuing options that could accomplish
the objectives of the Energize Eastside project through construction of transmission capacity elsewhere
in the region.
Response:
ColumbiaGrid is made up of member organizations, each of which is responsible for delivering power
within its service area. PSE alone is responsible for delivering power within PSE's service area.
Therefore, other ColumbiaGrid members would not be responsible for building transmission capacity to
address the need that PSE has identified for the Energize Eastside project.
Key Theme OBJ‐5: Clarifications and Errata
The following errors are addressed in Chapter 3 of the Final EIS (Errata):
The reason for rolling blackouts is that NERC requires utilities to prevent overloads of
transmission components that could endanger the regional grid.
The legend for Figure 1-1 should read “customers potentially affected by rotating outages.”
The reference to Figure 1-1 should have noted that the SCL transmission line reaches the center
of the Eastside.
HPFF would not be used in underground lines.
SF6 is not used in transformers.
An incorrect description of Appendix A in Chapter 1 of the Phase 1 Draft EIS.
Table B-1 is updated with additional equipment.
See Chapter 3 of the Final EIS.
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Alternatives Evaluated in the Phase 1 Draft EIS (Topic ALT)
This section describes and responds to the comments related to questions, concerns, and opinions about
the alternatives evaluated in the Phase 1 Draft EIS. Alternative 1, Option A (new 230 kV transmission
lines and substation) generated the most “against” comments, many more than any other alternative.
Alternative 2 (integrated resource approach) generated a large number of “for” comments, more than
any other alternative, followed by the No Action Alternative. A smaller number of comments expressed
support for Alternative 1, Option A, followed by Option C (underground transmission lines). Few
comments expressed support for Alternative 1, Options B and D (existing SCL transmission lines and
underwater transmission lines, respectively), or Alternative 3 (new 115 kV transmission lines and
transformers).
The largest proportion of these comments expressed a preference for or against one or more of the
alternatives or options. The EIS is intended to be an impartial, factual document for use by the public
and decision-makers. Comments strictly expressing support or opposition are not considered factors in
the analysis of impacts presented in the EIS.
Comments expressing support or opposition to the various alternatives are first summarized below
(without responses), for context. These comments are acknowledged here to provide the complete
picture of comments received on the Phase 1 Draft EIS. To the extent that these comments also
provided information on the reasons for support or opposition to an alternative or option, the most
commonly cited reasons are summarized here.
No Action Alternative
Comments expressing opinions about the No Action Alternative were primarily in support of the
alternative. A smaller number of commenters expressed opposition to the No Action Alternative.
The following is a sample of comments expressing support for the No Action Alternative:
Best short-term solution; new technologies and innovations will be available in the future.
Most sensible solution; the need for the project has not been demonstrated.
Few negative impacts compared to the other alternatives.
Those opposed stated that delaying the project or taking “no action” would:
Result in undesirable impacts to communities, including cities outside of the Eastside and their
economies, should this alternative result in electrical fluctuations or blackouts.
Impact the Eastside’s niche as a technology center/technology leader.
Affect the future development of business parks.
Undermine the services provided by community colleges, universities, and medical centers.
Alternative 1: New Substation and 230 kV Transmission Lines
This alternative refers to PSE’s proposal to resolve the stated transmission capacity deficiency. The
types of lines considered for Alternative 1 were categorized into four options as follows: Option A –
new overhead transmission lines in existing PSE corridors, new corridors, or public right-of-way;
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Option B – use existing Seattle City Light (SCL) overhead transmission lines; Option C –
underground transmission lines; and Option D – underwater transmission lines.
Alternative 1 – General Comments on New Substation and 230 kV Transmission Lines
Many of the commenters indicated opposition to Alternative 1 but did not refer to a specific option. The
following is a sample of comments expressing opposition to any sort of transmission line solution:
Transmission line is a solution that is vastly bigger than we need – it will have a capacity
exceeding 1,000 MW when only 70 MW are required in the foreseeable future.
Puts “all eggs in one basket” – ratepayers would finance an upfront cost of more than a quarter
billion dollars to build a transmission line that has reliability and security risks.
High costs to the community, but no justification for the project.
Option A (New Overhead Transmission Lines)
Most of the comments indicated opposition to Alternative 1, Option A. The following is a sample of
comments expressing opposition:
Antiquated solution.
Places transmission lines too close to aging fuel pipelines.
Risky, unsightly (“industrial blight”), inflexible and overly expensive, in both environmental
and financial terms.
Vulnerable to extreme weather, fires, landslides, terrorism, solar flares, pipeline accidents, and
errors of human judgment.
If only one power pole falls, a big piece of electricity supply would be out of service.
Environmental impacts are unacceptable: loss of trees; loss of homes; community character
impacts; impacts to property values, soil stability, and animal habitat; spreads invasive species;
increased noise levels; view impacts; impacts to health from electric and magnetic field
exposure.
Unacceptable impacts; significant adverse impacts.
Lack of flexibility and opportunity for innovation; not a sustainable solution.
Does not meet goal to be “environmentally acceptable” to PSE and communities. Increasing
capacity encourages customers to increase their demand for more electricity.
The following is a sample of comments expressing support:
Reasonable use of land resources (use of existing PSE utility corridors).
Most predictable and cost-effective option.
Technically feasible.
Proven infrastructure; low-risk.
Solves the transmission capacity deficiency problem, meets mandatory federal standards, and
has the greatest longevity.
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Option B (Use Existing SCL Overhead Transmission Lines)
Several commenters expressed opposition, indicating that the option is not practical for financial or
political reasons. Some commenters indicated support for Alternative 1, Option B, indicating the option
is a reasonable use of land resources (use of existing SCL utility corridor). This included comments
asserting that FERC 1000 gives the authority to require SCL to allow use of its corridor by PSE.
Options C and D (Underground or Underwater Transmission Lines)
A small number of commenters indicated support for Alternative 1, Option C or Option D, but
generally did not give specific reasons for support other than these options avoid overhead transmission
lines, and would avoid impacts to public safety and the environment including habitat for birds and
wildlife. Commenters expressed opposition to Option C because they felt it would be too expensive and
that a rate increase to pay for it would harm lower and middle class residents, and such rate increases
may be deemed imprudent and rejected by state regulators. The Muckleshoot Indian Tribe expressed
opposition to Option D based on shoreline impacts to Lake Washington and its salmon resources.
Alternative 2: Integrated Resource Approach
The focus of Alternative 2 is on energy conservation and use of technologies other than transmission
lines to address the project objectives. Many commenters indicated support for Alternative 2, or
components of it. Many commenters suggested that Alternative 2 needs to be further developed and
reviewed by independent experts; these comments are summarized under Key Theme ALT-1,
Alternatives Considered in the Draft EIS. Below is a summary of comments indicating support for
Alternative 2:
The smart technology solution.
Safer and less costly alternative.
More scalable, more reliable, and more cost effective.
Promotes smart and sustainable growth, more energy-efficient, and less damaging to the
environment.
Lower vulnerability to damage from storms, fires, and terrorism.
Could be built incrementally as need develops over time.
Able to incorporate improved technology over time.
Solutions are available that are more economical than transmission lines.
Comments in opposition generally stated that the alternative relies on unproven technology, is
unreliable and risky, will jeopardize economic vitality on the Eastside and pose greater financial risk
than the cost associated with upgrades to PSE’s aging infrastructure, could potentially burden other
utilities, result in noise impacts to Lake Tradition Plateau, and impact student learning and achievement
should blackouts occur.
PSE commented that Alternative 2 includes elements that have limited feasibility and are not in their
direct control, and therefore could not be reliably implemented or approved by NERC.
The City of Sammamish stated that, while further design and review of Alternative 1 should be
pursued, they also requested that PSE continue its efforts in researching, designing, and utilizing
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emerging alternative technologies (such as those described in Alternative 2 of the Phase 1 Draft EIS) to
account for a growing portion of its system capacity. (Sammamish also noted that they are a member of
the King County Cities Climate Collaboration [K4C], and support the delivery of safe, reliable, and
clean energy to members of their community.)
Alternative 3: New 115 kV Lines and Transformers
Under Alternative 3, new 115 kV transmission lines would be constructed in existing or new rights-of-
way around a broad portion of the Eastside. Numerous commenters expressed opposition to this
alternative. The following is a sample of comments expressing opposition:
Would build three times as many transmission lines all over the Eastside; not a realistic option.
Highly inefficient; a line this far from the high-density source of the loads does not make sense.
Included only to make Alternative 1 look “less horrific.”
PSE commented that Alternative 3 would result in impacts significantly greater than impacts identified
for Alternative 1. PSE further commented that this alternative does not meet the longevity requirement
stated in the project objectives.
Key Theme ALT‐1: Alternatives considered in the Draft EIS
Comment Summary:
This theme incorporates comments relating to the definition or specification of alternatives evaluated in
the Phase 1 Draft EIS. These comments include statements suggesting that more work should be done
to refine or modify the alternatives. Several comments of this type requested further development and
refinement of Alternative 2. Some commenters questioned the viability or reasonableness of certain
alternatives or options.
Several commenters requested further definition of Alternative 1, Option A to understand potential
transmission line routes. Others requested additional information on which existing transmission poles
would be replaced, the timeline for replacement, potential pole heights, and construction equipment
necessary to build the project. Commenters also requested confirmation that new transmission poles
would be constructed at least 50 feet from the Olympic Pipeline system (citing BPA policy), while
others thought the existing PSE easement in Newcastle would not be wide enough to safely support a
new overhead line. Additional comments on pipeline safety or EMF issues related to Alternative 1 are
summarized in the Pipeline Safety and EMF comment response sections of this appendix. Commenters
questioned whether Alternative 1 would meet PSE’s own objectives for timing and reliability. One
commenter also questioned why the use of Corrective Action Plans (CAPs) can’t be seen as a
permanent solution.
Many of the commenters stated that Alternative 2 was developed and defined based on outdated data
and studies, and requested that the alternative be revisited using independent experts with experience
with modern electrical grid technologies, including demand-side management and distributed energy
resources. Several commenters referred to findings from a CENSE-sponsored third-party evaluation of
Alternative 2, the EQL study, stating that the analysis shows PSE and the EIS consultants made
significant errors in their evaluation of alternative technologies. (The EQL study was attached to
comments submitted, and was prepared in response to the Phase 1 Draft EIS. It disputes PSE’s
economic analysis in its Integrated Resource Plan [IRP], claiming that if the cost of transmission were
included, many more alternative “non-wire” technologies would be considered feasible means of
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supplying power. It also asserts that these technologies have matured sufficiently to be viable
alternatives to the proposed 230 kV transmission line.) Several commenters mentioned Northwest
Power and Conservation Council’s Seventh Power Plan, and suggested that a carefully developed plan
would be superior to Alternative 1, Option A in terms of cost, safety, and environmental protection.
In expressing support for Alternative 2, several commenters stated that this option would allow PSE to
implement better technologies over time, and stressed that more time should be taken before a
permanent option like Alternative 1 be pursued.
Among the comments were suggestions for the size and location of distributed generation facilities,
asserting that these facilities could be sized for rare peak loads and not for daily 230 kV transmission.
Similar comments suggested there are viable grid battery technologies that could address short-term
emergency peak loads. One suggestion was made to rely on incentivized conservation that would
provide financial benefits to the customer to ensure successful implementation of demand-side
reductions, while another commenter stated that Alternative 2 does not account for market drivers for
increased conservation and the impact of FERC Order 745 which addresses compensation for demand-
side reductions in wholesale energy markets.
Several commenters proposed the use of batteries, demand-side reductions, distributed generation, local
power generation facilities, and other new technologies, underground lines, underwater lines, and
upgrades to existing systems, but did not specify how these proposed solutions differ, or are the same
as, alternatives or options included in the Phase 1 Draft EIS. Other commenters expressed their support
for a Public Utility District and conservation over the listed alternatives, while another commenter
suggested the existing 115 kV transmission lines be converted from Alternating Current to Direct
Current to increase capacity and reliability.
Some commenters suggested that Alternative 3 and certain options under Alternative 1 were “red
herring” alternatives, put forward to make PSE’s proposal (Alternative 1, Option A) look favorable by
comparison. There were questions about how the transmission line under Alternative 3 would help ease
downtown Bellevue’s power needs, suggesting that a line far to the east of high-density loads does not
make sense and is inefficient. Commenters questioned why Alternative 1, Options B, C, and D were
included, asserting they would be either politically unacceptable or cost prohibitive due to state
regulations, and would not be implemented. Commenters from the City of Sammamish provided a list
of questions they wanted answered in Phase 2 if Alternative 3 is carried forward, including the miles of
lines to be retrofitted or newly constructed, required clearance zone, and diversion of electrical capacity
from existing substations and its effect on their performance.
One commenter suggested different transmission alternatives, including adding a new 230/115 kV
transformer at the Lakeside substation and looping the existing SCL double-circuit 230 kV line through
the Lakeside substation. The suggested route includes the line east along I-90 then north to the
substation along the existing PSE right-of-way, and west near the Lake Hills Connector until the SCL
lines are once again intercepted. The commenter suggested this alternative has significantly less
environmental impact than 18 miles of new transmission lines. It was further suggested that PSE
reevaluate the Lake Tradition Option and BPA’s best technical solution by building a second Monroe-
Echo Lake transmission line.
A different commenter asked whether the Phase 1 Draft EIS adequately explored the option of co-
locating within the SCL corridor; this commenter asked whether PSE had considered how to make the
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co-location more appealing to SCL, or whether there was legal precedent for making use of the existing
SCL corridor. They also asked if a change to city or state law would make this option more feasible.
Several commenters requested maps showing the specific locations where each alternative (or option)
would have construction impacts.
PSE commented that the complexity of rebuilding the SCL line under Alternative 1, Option B is
understated in the Phase 1 Draft EIS, emphasizing that taking the SCL line out of service and
rebuilding in place has not been studied or agreed to by SCL. The comments further stated that the
definition of Option B omits additional reconductoring that would be needed (outside the study area),
and additional miles of new 230 kV line corridor that would be needed to connect the SCL line to the
Sammamish substation and separately to the Lakeside substation. PSE commented that Option B would
potentially require clearing the entire SCL corridor and possibly require acquisition of additional
easement. Given these omitted elements, PSE commented that analysis of Option B either understates
or overstates impacts, depending on the resource.
A commenter asserted that attributing impacts to the No Action Alternative was not consistent with
SEPA. Instead, the No Action Alternative should be depicted as having no impacts on the environment
to properly compare to the Energize Eastside project. Other commenters thought the No Action
Alternative should include the Maple Valley-SnoKing reconductor project if deemed necessary by
ColumbiaGrid.
Response:
The Phase 1 Draft EIS includes a programmatic-level analysis that reflects the level of detail at which
alternatives were defined at the time the Phase 1 Draft EIS was prepared. The Phase 1 Draft EIS
evaluates the high-level aspects of the project (see Chapter 1 of the Draft EIS for more information).
While there were numerous comments regarding how the alternatives for this programmatic analysis
could be refined, the Partner Cities do not intend to revise the Phase 1 Draft EIS and republish it. The
Phase 1 Draft EIS served the purpose of building an understanding of the transmission capacity
deficiency PSE has identified, PSE’s objectives, and the environmental consequences associated with
different approaches to meeting those objectives.
The project-level Phase 2 Draft EIS includes a more specific and detailed review of alternatives based
on the analysis of Phase 1, and focuses on project design and construction. For example, as requested
by commenters, more detailed information on pole placement and design is provided in the Phase 2
Draft EIS. The Phase 2 Draft EIS addresses the need for setbacks from the Olympic Pipeline system, as
requested by commenters. Alternative 1, Options B, C, and D, and Alternatives 2 and 3 were not
carried forward into the Phase 2 analysis for the reasons described in Section 2.2 of the Phase 2 Draft
EIS. Therefore, the EIS acknowledges, but does not further address, concerns expressed by the
Muckleshoot Indian Tribe about the potential effects of Alternative 1, Option D, on tribal fishing areas.
In response to comments stating that PSE should hold off on building Alternative 1 because of a lack of
need for the project, all of these comments raise issues that were addressed in the discussion in the
Phase 1 Draft EIS Chapters 1 and 2. As noted there, the EIS does not evaluate whether or not a project
is needed, but takes need into account in considering the applicant’s objectives. PSE identified a
deficiency of 74 MW by the winter of 2017–2018 or summer of 2018. This finding is summarized in
the 2015 Needs Assessment, and is also described in Section 1.3 of both the Phase 1 and Phase 2 Draft
EISs. Additionally, see the discussion contained in the Project Objectives comment response section of
this appendix.
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The EIS acknowledges that the project would provide more than adequate capacity to meet the
projected need in the 10-year planning horizon. However, as discussed in the Phase 1 Draft EIS, there
is no intermediate size of transmission facility between 115 kV and 230 kV capacity that would work
within the regional grid. See Section 2.2.1.15 of the Phase 1 Draft EIS for discussion of 115 and 230
kV transmission lines. The mere fact that the project would create more than adequate capacity for the
next decade is not a reason for eliminating the alternative.
In selecting alternatives to be evaluated in an EIS, the Partner Cities are not obligated to consider every
conceivable scenario. The SEPA Rules note that use of the word “reasonable” is intended to limit
(emphasis added) the number and range of alternatives, as well as the amount of detailed analysis for
each alternative. For the Phase 1 Draft EIS, an objective of the Partner Cities was to identify a set of
alternatives (including the No Action Alternative) that would define the range of possible alternatives
to meet PSE’s objectives. According to the SEPA handbook (3.3.2.1), “SEPA requires the evaluation of
the no-action alternative, which at times may be more environmentally costly than the proposal, or may
not be considered "reasonable" by other criteria. Still, it provides a benchmark from which the other
alternatives can be compared.”
The EQL study cited in several letters was a critique of Alternative 2 in the Phase 1 Draft EIS. It is
acknowledged in Chapter 2 of the Phase 1 Draft EIS that the mix of technologies in Alternative 2 was
an example. The EQL study argued that both more conservation and more reliance on energy storage
were possible. However, Alternative 2 was not carried forward in the Phase 2 Draft EIS, for reasons
described in Section 2.2 of that document; therefore, variations on Alternative 2 were not analyzed.
The applicability of FERC Order 745 was not considered because the EIS is not required to take into
account how projects or programs are funded.
All of the technologies suggested in the comment letters, including those described in the EQL study,
were considered in the Phase 1 Draft EIS. In some cases, commenters suggested methods of addressing
the problem that were not capable of meeting PSE’s objectives. These include use of an existing BPA
transmission line, discounting flow of electricity to Canada through the Eastside grid, converting
existing 115 kV lines from alternating current (AC) to direct current (DC), and asking ColumbiaGrid to
build capacity outside of the Eastside area. As described in Chapter 2 of the Phase 1 Draft EIS, several
of these solutions were found to overload either transmission lines or transformers and would therefore
not meet PSE’s stated project objectives. These alternatives were not studied further in the Phase 1
Draft EIS.
As noted in Section 2.2 of the Phase 1 Draft EIS, converting the 115kV transmissions lines from AC to
DC would add complexity to the system that would reduce operational flexibility, which could have
adverse impacts to the reliability and the operating characteristics of PSE’s system. Comments
comparing the connection of the grid serving the Quebec region using DC power to the situation on the
Eastside ignore the fact that virtually the entire Quebec system is supplied by the DC connection, rather
than having a small segment within the system being converted to DC for a short distance and then
being converted back to AC.
Another solution that involved reconductoring the SCL Maple Valley – SnoKing 230 kV line with
high-temperature conductors was also considered and described in Chapter 2 of the Phase 1 Draft EIS
as not effective in addressing all relevant PSE equipment violations. Claims by commenters that
ColumbiaGrid has documented options that would solve the problem that do not require PSE
involvement are unsupported.
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With regard to whether the project would meet PSE’s standards for redundancy and reliability,
commenters may not have understood that Alternative 1 proposes two supplies of 230 kV power to the
proposed substation in the center of the Eastside—one from the north and one from the south. Either
would be capable of supplying the substation, so that if one line goes down the other would still be in
service. With regard to timing, it is acknowledged that the timing of the project has slipped, and that
completion of Alternative 1 would likely not occur by winter 2017–2018. PSE now estimates that the
earliest period when load shedding could be required is summer 2018. Timing of the construction of
PSE’s proposed alignment is discussed in Chapter 2 of the Final EIS. CAPs are not viewed by PSE as a
permanent solution because they place customers at risk of power outages. See the discussion of CAPs
in Chapter 1 of the Phase 1 Draft EIS.
With regard to Alternative 1 Option B, the Phase 1 Draft EIS was not a project-level analysis. It was
intended to identify the types of impacts associated with various ways to address the project need.
Because the SCL corridor was not carried forward, no additional analysis was conducted to determine
whether the statements from PSE were correct or not. However, it is correct that the Phase 1 Draft EIS
did not look in detail at how a connection would be made from the existing SCL line to the Talbot Hill
and Sammamish substations.
With regard to PSE’s statement that the Alternative 3 would have greater impacts than Alternative 1,
the Phase 1 Draft EIS did find this was true with regard to some elements of the environment, while for
other elements, impacts would be similar or less. The Phase 1 Draft EIS did not make an overall
judgment as to which alternative would have the least or most environmental impacts. With regard to
the statement that Alternative 3 would not meet the longevity objective, the longevity objective stated
by PSE in the Supplemental Eastside Solutions Study (2015) was to meet the performance criteria “for
10 or more years after construction with up to 100% of the emergency limit for lines and transformers.”
It was understood when this alternative was being developed in cooperation with PSE that Alternative 3
would meet or approximate this objective.
Key Theme ALT‐2: Comparative summary of impacts
Comment Summary:
This theme includes comments about the summary of impacts presented in the Phase 1 Draft EIS
(Chapter 1), such as specific concerns about the ability to compare alternatives based on their impacts, a
critique of the format used for summarizing impacts, and disagreement with specific conclusions in the
summary.
Several commenters identified inaccurate conclusions made for Recreation in Table 1-3 for Alternative
2 (Minor to Significant), noting that the conclusion is misleading based on findings in the EIS. Other
commenters requested clarification on the difference between conclusions of “significant” as presented
in Tables 1-2 and 1-3 and “significant unavoidable adverse impacts” as presented in the summary
sheets in Chapter 1 for key findings. Commenters requested that the environmental benefits of
Alternative 2 be presented in the EIS. One commenter found the definitions of minor, moderate, and
significant impacts to be so broad that they cannot be meaningfully used to evaluate alternatives and
thought the conclusions were skewed toward minor impacts, suggesting that the alternatives were not
analyzed at a sufficient level of detail or in a comparable manner.
Comments suggested that the comparison between Alternative 1 Option A and Alternative 1 Option C
were incorrect and that construction impacts on recreation resources from undergrounding the
transmission line could be much greater than an overhead line.
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Response:
The SEPA Rules require that the EIS summary “shall include a summary of the proposal, impacts,
alternatives, mitigation measures, and significant adverse impacts that cannot be mitigated” (WAC 197-
11-440 [4]) and that the EIS should present “a comparison of the environmental impacts of the
reasonable alternatives….” (WAC 197-11-440 [5] [vi]). Lead Agencies are granted leeway in how they
choose to present and format information on the comparative impacts of the alternatives. The
presentation of such information in the Phase 1 Draft EIS meets the requirements of the regulations,
and the Partner Cities believe the summary content is suitably clear and organized. The Partner Cities
note that Tables 1-2 and 1-3 in the Phase 1 Draft EIS are only a portion of the summary, and that
greater detail is included in the Chapter 1 narrative summaries for each element. The tables display
impacts in a way to facilitate side-by-side comparison of alternatives, but are not intended to be a stand-
alone summary.
There was an error in Table 1-3, in the presentation of impacts for Recreation under Alternative 2.
Impact conclusions should have been stated as Negligible to Minor, and a correction is issued in the
Errata in this Final EIS (see Chapter 3).
As clarification, a “significant impact” is defined by WAC 197-11-794 as “a reasonable likelihood of
more than a moderate adverse impact on environmental quality.” Some significant impacts can be
mitigated, while others cannot. Those that cannot be mitigated are considered “significant unavoidable
adverse impacts.” In each chapter, there is a discussion of what was considered a significant
unavoidable adverse impact for the respective element of the environment. In the evaluation of impacts,
including determinations regarding the significance of impacts, the EIS Consultant Team considered
impacts that have a low likelihood of occurrence but would be severe if they occurred.
The Phase 1 Draft EIS analysis was prepared without benefit of a project design. The development of
an overhead line is simpler than the design of an underground line. Furthermore, the discussion of
overhead lines extends to development of a new corridor, which would have a much greater extent of
construction impacts than use of the existing corridor. Because of the lack of design detail, some
assumptions about undergrounding may have understated impacts relative to those from overhead lines.
Had the underground line alternative been carried forward, additional design detail would have clarified
whether the impacts would indeed have been greater.
Key Theme ALT‐3: Minor clarifications
Comment Summary:
Several commenters stated concerns relating to pipeline safety, EMF, property acquisitions, home
devaluation, and land use and housing impacts as justification for preferring various alternatives. Other
commenters had concerns regarding project objectives. PSE provided a number of comments related to
the definition of alternatives evaluated in the Phase 1 Draft EIS.
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Response:
Pipeline safety, including discussion of the proposed shield wire, is addressed in Section 3.9 of the
Phase 2 Draft EIS and the Pipeline Safety comment response section of this appendix.
Impacts related to EMF are covered in Section 3.8 of the Phase 2 Draft EIS. Please also see the EMF
comment response section of this appendix.
No property acquisitions are anticipated for the project. Please refer to Section 3.1 of the Phase 2 Draft
EIS and Key Theme LU-1 of the comment response section of this appendix.
Please see Key Theme ECON-1 of the comment responses for topics related to impacts to property
value depreciation.
As described in the Phase 1 Draft EIS, an EIS is intended to evaluate the probable significant
environmental impacts of a proposed project or program. The EIS does not evaluate whether or not a
project is needed, although it does take into account the project objectives in establishing what
alternatives should be included. Please see response to Key Theme OBJ-1.
Comments regarding the definitions of Alternative 1, Option A and the No Action Alternative are
addressed through the more detailed definitions of these alternatives in Chapter 2 of the Phase 2 Draft
EIS and Chapter 2 of the Final EIS. Alternative 1, Options B, C, and D, and Alternatives 2 and 3 were
not carried forward into the Phase 2 analysis for the reasons described in Section 2.2 of the Phase 2
Draft EIS. The EIS acknowledges, but does not further address, clarifications on the definition of these
alternatives made by PSE.
Regarding PSE’s comment regarding the regulatory basis for vegetation clearing requirements, the
Final EIS Section 4.4.4.1 states that the vegetation clearing requirements are based on NERC
requirements.
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APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
Earth (Topic EARTH)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding earth
resources. Primary themes included earthquake-related hazards, impacts from pole installation, hazards
related to the Olympic Pipeline, mitigation measures, requests for more specific data, and project
specifics that should be included in the Errata.
Key Theme EARTH‐1: Earthquake‐related hazards
Comment Summary:
Commenters raised concerns regarding the Seattle Fault line which the existing aging Olympic
Pipelines and power lines cross in proximity to existing homes. Commenters stated that the Cascadia
Subduction Zone which ties to the Seattle Fault is capable of earthquakes in excess of 9 on the Richter
scale. Commenters pointed out that the Cascadia Subduction Zone occurs at intervals of 300 to 500
years, and the last major seismic event was 315 years ago. The Axial Seamount (underwater volcano)
began eruptions on April 30, 2015 which could add to the pressure along the Cascadia Subduction
Zone, and by extension, the Seattle Fault. Commenters requested an evaluation of how liquefaction that
could occur within the Eastside could affect the project.
Response:
The Phase 1 Draft EIS (Section 3.3.3.4) states: "A fault is considered active when it has shown
evidence of displacement within the last 11,000 years. An earthquake on the Seattle Fault poses the
greatest risk to the Seattle urban region.” The section states that there are three sources of earthquakes:
the Cascadia subduction zone, the deep intraslab subduction zone, or shallow crustal faults. The closest
active crustal source is the Seattle Fault Zone. Shallow quakes are the type expected on the Seattle
Fault Zone, which can create more damage than deep quakes because of the proximity of buildings and
infrastructure to the epicenter. The Phase 1 Draft EIS described the Seattle Fault, but did not
specifically state that the existing 115 kV transmission line and Olympic Pipelines cross the Seattle
Fault Zone. It is correct that a major earthquake of the magnitude expected on the Seattle Fault could
cause pipeline rupture in certain areas on the Eastside (Earthquake Engineering Institute and
Washington Military Department Emergency Management Division, 2005). See Errata, Chapter 3 of
the Final EIS that clarifies this omission further. Nonetheless, as stated in the Phase 1 Draft EIS, the
proposed project would not increase the probability of an earthquake to occur nor increase the amount
of damage that would occur to the pipeline in an earthquake.
The EIS Consultant Team found no incidents of steel poles built to modern standards, or transmission
lines falling as a result of earthquakes in the United States, including major quakes in California.
Damage to equipment on the poles, such as insulators and disconnect switches, has occurred. In major
California earthquakes, there have been instances of transformers and other substation equipment being
shaken from their foundations and other substation equipment damage.
Regarding the presence of seismic hazards, including the extent of the Seattle Fault Zone and areas
susceptible to liquefaction, the Final EIS includes an expanded discussion in Section 4.11, Earth
Resources. This section also addresses regulatory requirements in greater detail than the Phase 1 Draft
EIS. Just as the Phase 1 Draft EIS, the Final EIS concludes that compliance with existing regulations
would result in less-than- significant impacts.
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APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
Key Theme EARTH‐2: Impacts from taller poles and pole installation
Comment Summary:
Concerns were raised over the potential for taller poles to have a higher risk of destruction in a seismic
event, including at the Somerset Recreation Center, stating that the current lines would fall within
easement boundaries but the proposed lines would fall onto properties adjacent to the proposed routes.
Commenters asked how the “fall-zone” of 130-ft tall monopoles is accounted for in the Right of Way,
noting that many houses are closer than 130 feet to the monopole sites and earthquakes or high winds
could cause poles to topple. Concerns were also raised about vibration from vertical boring for the pole
placement, causing settlement damage to nearby house foundations.
Response:
As described in more detail under Key Theme Earth-1, transmission poles historically have not been
toppled by earthquakes, regardless of height. Although Alternative 1, Option A, would introduce taller
poles, design standards required for transmission poles are the same for any height pole, and would
make it extremely unlikely that poles would fall during a seismic event. Systemwide, PSE confirmed
that there have been no structure failures of steel transmission poles within their system due to geologic
hazards including seismic events and failures of wood poles have been rare, involving extenuating
circumstances like placement in a bog or being impacted by a landslide in a remote mountain setting
(see Section 3.4 of the Phase 1 Draft EIS). Section 4.11 of the Final EIS provides additional discussion
of seismic issues.
For a discussion of construction methods for removal of existing wooden poles and conductors and
installation of new steel poles, see Section 2.3.2 of the Phase 1 Draft EIS. Further, as discussed in
Section 3.6 of the Phase 1 Draft EIS, most construction processes do not generate enough vibration to
be considered damaging because ground vibrations dissipate quickly with distance. Further detail on
installation methods is included in the Final EIS.
Key Theme EARTH‐3: Earthwork activities near Olympic Pipeline system
Comment Summary:
Commenters, including representatives from the Somerset Recreation Club, expressed concern with
construction activities involving earthwork near the Olympic Pipeline Company pipelines and the
potential for damaging vibrations and erosion.
Response:
As discussed in the Phase 1 Draft EIS, a significant adverse impact could occur during construction
near petroleum pipelines; however, these potential hazards do not constitute a probable impact due to
existing regulations and practices in place for pipeline safety. The project would be required to comply
with all regulations regarding erosion-prone areas, such as steep slopes. The Olympic Pipeline
Company has stringent construction requirements in the area of its pipelines and would continue close
coordination with PSE and local jurisdictions for all construction activities located adjacent to these
pipelines. A risk assessment that took into account the risks in the corridor was conducted as part of the
Phase 2 Draft EIS. For further analysis of pipeline safety, see Sections 3.9 and 4.9 of the Phase 2 Draft
EIS, and Sections 4.9 and 5.9 of the Final EIS.
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APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
Key Theme EARTH‐4: Regulatory thresholds and mitigation measures
Comment Summary:
Commenters highlighted or questioned the level of regulatory thresholds required and Best
Management Practices (BMPs) applicable for different phases of the proposed project within different
jurisdictions; as well as pointed out that building codes are requirements not recommendations.
Commenters noted that mitigation for geology-related risks, including those at specific sites such as the
Somerset Recreation Club, should be more site-specific, more project-related, and that anticipating
mitigation without site-specific details is futile.
Mitigation measures were suggested by PSE for potential stormwater management impacts. PSE noted
that they would comply with local agency requirements for flow control mitigation (including
detention) to address stream bank erosion due to increased runoff from new impervious surfaces,
stream flow velocities, and flooding. PSE also noted that they would follow the appropriate NESC
design requirements; although seismic engineering would not be required for NESC compliance, it
could be required as mitigation for this project.
Response:
BMPs are developed on a project-specific basis and determined by the local regulatory agency (see
Section 3.6 of the Phase 1 Draft EIS). Building codes are indeed requirements (see Section 3.7.1.3 of
the Phase 1 Draft EIS). However, as a correction, Chapter 3, Errata, in the Final EIS notes that the
Washington State Building Code exempts electrical transmission equipment and structures in a utility
right-of-way from its requirements. Section 4.11 of the Final EIS provides an expanded discussion of
applicable standards.
The mitigation measures identified in Section 3.8 of the Phase 1 Draft EIS were prepared in the context
of a programmatic-level of analysis. These mitigation measures are not specific to certain facilities, but
would be applied where needed. These include measures that could be implemented during
construction or operation of the project to reduce or minimize the potential for erosion, slope failure,
unsuitable soils, or settling impacts for all alternatives that involve earthwork.
Stormwater runoff and associated erosion are evaluated in Chapter 5 of the Phase 1 Draft EIS and
further analyzed in the Phase 2 Draft EIS (see Chapter 4.3). Use of appropriate stormwater management
(detention) facilities to reduce stream flow velocities and flooding, as well as NESC seismic
engineering design requirements have been included as mitigation in Section 3.8.1 of the Phase 1 Draft
EIS, and carried forward into the Final EIS. Please see Section 4.11 of the Final EIS.
Key Theme EARTH‐5: Request for more location‐specific data
Comment Summary:
Commenters requested more information on specific pole placement locations. Additionally, more
information detailing site plans or building plans was suggested in order to accurately analyze soil
conditions.
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Response:
The Phase 1 Draft EIS provides a programmatic evaluation of the potential impacts to earth resources.
The Phase 2 Draft EIS provides a project-level assessment of elements of the environment where
significant adverse impacts could occur. Because it was determined during Phase 1 that impacts to earth
resources would be less than significant, it was not evaluated in the Phase 2 assessment. However, in
response to the number of comments on the Phase 2 Draft EIS asking for additional information on
seismic risks, the Final EIS includes an expanded discussion of the specific seismic risks in the study
area for PSE's Proposed Alignment (see Section 4.11 of the Final EIS). While seismic risks are present
in the study area and throughout the region, the project would not substantially affect those risks. Site-
specific geological and soil conditions will be evaluated as PSE moves forward with the project design
and moves into the permitting stage for the project. Revised pole location data are included in the Final
EIS analysis (see Appendix A), and accessible on the EIS project website
(www.energizeeastsideeis.org) for the public to review.
Additionally, Section 3.3.3 of the Phase 1 Draft EIS describes the potential to encounter geologic
hazards, including steep slopes, erosion, landslides, seismic hazards (e.g., liquefaction), and other
hazards such as soft soils. The Phase 1 Draft EIS evaluated the potential for adverse impacts in Sections
3.6 and 3.7. It determined that impacts under all alternatives would be minor with the implementation
of BMPs, geotechnical recommendations, regulatory requirements, and industry standards.
Key Theme EARTH‐6: Errata and minor clarifications
Comment Summary:
Following the release of the Phase 1 Draft EIS, PSE provided comments on coal mine hazards, role of
the geotechnical engineer, reference to seismic requirements of the Washington State Building Code
and local building code amendments, and description of the No Action Alternative.
Response:
Clarifications and errors were identified and rectified in the Errata regarding the presence and/or
absence of abandoned coal mines; that a geotechnical engineer would provide the foundation design of
the project facilities; and requirements of the Washington State Building Code and any local building
code amendments. The No Action Alternative would entail pole replacement activities, which was
mentioned in the Phase 1 Draft EIS and has been clarified in the Phase 2 Draft EIS and Final EIS.
Chapter 8 of the Phase 1 Draft EIS incorrectly states that: “state public utility commission has adopted
seismic standards that utilities must follow, with structural requirements for poles that would be
sufficient to resist anticipated earthquake ground motions.” PSE would meet the structural requirements
set by the IBC, ASCE, and ACI, and this has been rectified in Chapter 3 of the Final EIS.
PSE also provided other minor clarifications that have not been included in the Errata, primarily
because they relate to Phase 1 alternatives that are no longer being considered, they are minor
clarifications (as opposed to factual errors), and they do not influence the results or conclusions of the
analysis. The full letters are included at the end of Appendix J.
FINAL EIS PAGE J1‐32
APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
Greenhouse Gas Emissions (Topic GHG)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding air
quality and greenhouse gases (GHG). Primary themes included the EIS scope, analysis, mitigation and
conclusions regarding GHG, the tree clearing analysis and associated GHG effects, sustainable utilities
and climate change, and the need under SEPA for air quality analysis.
Key Theme GHG‐1: Phase 1 Draft EIS scope, analysis, mitigation, and conclusions
Comment Summary:
Several commenters stated that the EIS should fully assess, address, and mitigate carbon emission and
sequestration issues for all alternatives. Several comments related to the carbon sequestration provided
by trees and that these capabilities would not be replaced immediately by replanting young trees to
compensate for the removal of 8,000 trees (under Alternative 1, Option A). At least one commenter
stated that there should be no net reduction in carbon sequestration capacity as a result of the project,
and that the Partner Cities should require carbon offsets for all incremental fossil fuel-based power that
flows through the transmission line. Commenters were concerned over how mitigation was presented,
and uncertain how GHG emissions would be mitigated to a level of no significance.
Some commenters requested further analysis of air quality impacts and GHG emissions related to the
use of gas turbines under Alternative 2.
Commenters noted that the assertion that only the production of concrete, and not the production of
steel, aluminum, and other metals, produces GHGs in significant quantities is incorrect.
Response:
The Phase 1 Draft EIS analyzes the implementation of vegetation replacement to reduce sequestration
losses under Alternative 1, Option A, and Alternative 3 to a reasonable level for a programmatic
analysis and comparison of alternatives (see Section 4.7). Alternative 1, Options B and C, would also
involve vegetation clearing for alignments. Additionally, carbon credits could be purchased to offset
operational emissions. Additional, alternative-specific mitigation measures are listed in Section 3.5.8 of
the Phase 2 Draft EIS. These include measures such as replacing "trees removed for the project based
on tree protection ordinances and critical areas regulations in each jurisdiction; some of these trees
would likely be planted off-site or, in the case of the City of Newcastle, mitigated by paying into an in-
lieu fee program." It should be noted that mitigation is not limited to the measures listed in the EIS, and
additional mitigation could be required, including mitigation for carbon emissions from construction
and operation. However, none of the jurisdictions have policies specifically calling for such mitigation,
either for general development or specifically for electrical infrastructure.
The Phase 1 Draft EIS describes the potential GHG impacts associated with gas turbines in Sections
4.5.4.3.1, 4.6.4.2, 4.7, 4.8, and 4.9. The Phase 1 Draft EIS found that construction of gas turbines could
result in direct GHG emissions. However, Alternative 2 was not carried forward for further
consideration in the Phase 2 Draft EIS, because PSE determined that it did not meet the project
objectives, in particular that it would not meet PSE’s performance criterion for serving 10 years or
more of growth after construction (electrical criterion #1 - see Chapter 1 Phase 1 Draft EIS). The Phase
2 Draft EIS describes alternatives not carried forward for additional analysis in Section 2.2.
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APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
The Phase 1 Draft EIS states that the primary material resources for Alternative 1 would be concrete for
pier and transformer foundations, steel or laminated wood poles for towers, and conductors. Of these
materials, concrete is likely the “most GHG-intensive to produce,” accounting for cement production,
aggregate production, water, and transport. It is correct that other materials also generate GHGs in
production, transport, and installation, but for comparative purposes, the analysis used concrete only
because it was the largest component. This analysis showed the relative order of magnitude of the
potential impacts and allowed a determination regarding the potential significance of the impacts.
Given the relatively small level of emissions from a worst-case assumption regarding project emissions
for concrete foundations, it was concluded that the project would not result in significant emissions
from manufacturing construction materials.
The Phase 2 Draft EIS evaluated the potential for lifecycle emissions at the project level in a similar
manner to the Phase 1 Draft EIS, but with more accurate estimates of the number of poles. Potential
GHG emissions for concrete foundations for all poles were estimated at 109 metric tons of CO2, based
on an assumption that 180 poles would be constructed (see Section 4.5.2 of the Phase 2 Draft EIS).
Similar to the programmatic analysis, this was not intended to be a full life-cycle GHG inventory, but to
provide a relative comparison among alternatives. Similar to the Phase 1 Draft EIS analysis, it was
concluded that the alternatives evaluated in the Phase 2 Draft EIS would not result in significant
emissions from manufacturing construction materials.
Key Theme GHG‐2: Tree clearing analysis and GHG effects
Comment Summary:
A number of commenters were concerned with the tree clearing analysis and associated GHG effects.
Commenters also questioned the “worst-case scenario” analysis, which identified the potential need for
further tree removal and/or clearing.
Response:
The Phase 1 Draft EIS examined the worst-case scenario for new overhead transmission lines, which
assumed that the new corridor for a 230 kV line would be 120 to 150 feet wide (approximately 30 to 40
feet wider than a 115 kV line and the existing right-of-way corridor).
The Phase 1 Draft EIS analyzed tree removal and GHG effects as a worst-case scenario to provide a
conservatively high assumption at the programmatic level, without survey-based tree count numbers or
a defined route. It is true that use of the existing corridor would require less tree and vegetation removal
because the existing footprint is already largely cleared. An updated vegetation removal assessment,
including a more detailed discussion of clear zones and a tree inventory assessment, is provided in the
Phase 2 Draft EIS (see Section 3.4). This analysis incorporated information from site-specific tree
surveys and was used to provide an alternatives assessment for GHG emissions (see Section 3.5 of the
Phase 2 Draft EIS, and Section 4.5 of the Final EIS).
Key Theme GHG‐3: Sustainable utilities and climate change
Comment Summary:
Commenters expressed concern over GHG impacts when building energy infrastructure, noting that
sustainability, renewables, and energy efficiency should be supported and carbon offsets should
accompany projects to plan for climate change. Related to power that flows through the transmission
line, commenters requested that the air quality and greenhouse gas impacts of coal-based electric
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APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
generation be considered in the analysis. Other commenters suggested that utilities and utility
companies should wean themselves off of burning fossil fuels.
Response:
GHG impacts associated with the proposal are evaluated programmatically in the Phase 1 Draft EIS
(see Chapter 4) and at the project level in the Phase 2 Draft EIS (see Section 3.5). Both assessments
found that there would be less-than-significant impacts to GHG levels from construction and operation
of the project.
The project objectives are to address a deficiency in electrical transmission capacity during peak
periods, not to increase power production, or to transmit power from new or different sources, so such
impacts are not analyzed in the EIS. Whether or not a utility should be required to purchase or
implement carbon-offsets is a city-specific regulatory issue and beyond the scope of this EIS analysis.
Additionally, the willingness of utilities to adopt new technologies to reduce fossil fuel use is beyond
the scope of this EIS. The EIS analyzes the potential impacts of the proposal (new transmission line)
and alternatives, but it is not intended to analyze regional generation. Therefore, information and
analysis on impacts of coal-based generation are not included because they are outside the scope of the
EIS analysis.
Key Theme GHG‐4: Need under SEPA for air quality analysis
Comment Summary:
Commenters identified the need to include an air quality analysis in the SEPA document, and why
certain toxic pollutants such as mercury were exempted from analysis the Phase 1 Draft EIS analysis.
Response:
As stated in the SEPA Handbook, an EIS should focus on those elements of the environment that have
the potential to be significantly impacted. It is true that power plants produce harmful pollutants.
Existing regulations prohibit the release of pollutants such as mercury in levels that would be toxic, so
for a programmatic analysis, it could be assumed that regulations would prevent such releases for any
power plants that could be constructed, such as those described in Alternative 2. Construction of a new
power plant, such as a peak generation facility, was not carried forward as an alternative in the Phase 2
Draft EIS analysis, as described in Section 2.2. The new substation and 230 kV transmission lines that
would be constructed for the Energize Eastside project are proposed to address a deficiency in electrical
transmission capacity during peak periods and improve the reliability of the Eastside’s 230 kV
electrical grid (see Chapter 1 of the Phase 1 Draft EIS). The project is not being constructed to increase
power production; therefore, impacts associated with increased power production, such as mercury
emissions and other air pollutants from existing power sources, were not evaluated as part of this EIS
process.
Key Theme GHG‐5: Clarifications and Errata
Comment Summary:
PSE stated that SF6 is not a highly toxic gas and does not have adverse impacts to human health.
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APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
Response:
Text in Chapter 8 was incorrect and has been rectified in Chapter 3 of the Final EIS to state that SF6 is
not a highly toxic gas. However, SF6 is a contributor to GHG emissions and is further evaluated in that
respect in the Phase 2 and Final EIS documents.
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APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
Water Resources (Topic WTR)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding water
resources. Primary themes included water resources not identified in the Phase 1 Draft EIS, stormwater
management, groundwater pollution, construction-related impacts, water quality and permitting, tribal
treaty rights, and clarifications.
Key Theme WTR‐1: Water resources not identified in the Phase 1 Draft (e.g., springs,
streams, lakes, Coal Creek basin resources, etc.)
Comment Summary:
Commenters identified water resources they felt were not described in sufficient detail in the Phase 1
Draft EIS. One commenter noted the importance of the Water Resource Inventory Area (WRIA) 8,
stating that the Coal Creek Natural Area is an integral part of Bellevue's parks and recreation system,
and that the forest protects water quality and reduces erosion.
Commenters noted that Lake Boren was not included in the list of small lakes, natural springs along the
proposed routes were not described, underground streams that percolate down College Hill toward
Richard’s Creek were not identified, and the rainwater that accumulates in PSE’s easement between
135th Ave SE and Somerset Drive SE was not documented. Commenters stated that underground
streams produce large quantities of mud within the study area; there are above and below ground
catching ponds that retain water along PSE’s easement between 135th Ave SE and Somerset Drive SE;
and within the middle of the Olympus neighborhood (in Newcastle), the existing 115 kV transmission
corridor is swampy most of the year. Commenters noted that such conditions could make the use of
heavy equipment and siting power poles next to the pipelines difficult. Commenters also stated that
PSE soil tests were not done in the area south of SE 84th Street in the Olympus neighborhood.
Response:
The Phase 1 Draft EIS provides a high-level, programmatic assessment of potential impacts to water
resources within the combined study area, which encompasses portions of WRIA 8 (the Cedar-
Sammamish River watershed) and WRIA 9 (the Duwamish-Green River watershed). All of the impacts
described above were listed in the programmatic analysis. However, since a specific corridor was not
yet identified during the Phase 1 analysis, existing critical areas GIS datasets were used to identify
streams and wetlands, to generally understand the types of potential impacts that could occur. No field
surveys were performed because the specific location of project elements had not been determined. It is
acknowledged that those datasets may be incomplete.
The Phase 2 Draft EIS provides a more thorough, project-level assessment of the potential impacts of
PSE’s proposal. For example, the Phase 2 Draft EIS provides a detailed description of water resources
within approximately 300 feet of the project (the area where water quality and critical areas permits
would be required), making use of wetland and stream delineations performed for PSE by qualified
professionals (The Watershed Company, 2016). The list of project-specific water resources is provided
in Section 3.3.2 of the Phase 2 Draft EIS. This includes creeks and seasonal drainages that flow into
Lake Boren (see Table 3.3-1) and streams and wetlands connected to Richards Creek. Section 3.3.2.3 of
the Phase 2 Draft EIS notes that groundwater was found at or near the surface in the vicinity of the
Richards Creek substation site.
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The Phase 2 Draft EIS describes more specific methods to be used for construction, and how ground
clearing could expose soils and increase erosion, but low vegetation would be allowed to grow and
there would be no areas of exposed soil following construction. With the practices described, erosion
and sedimentation would not increase, and no long-term impacts to water quality from erosion would
occur (see Section 3.3.5.1 of the Phase 1 Draft EIS). The Phase 2 Draft EIS found that long-term
impacts to water resources would be less-than-significant.
The Phase 1 Draft EIS notes that site-specific geotechnical information would be required to determine
actual groundwater conditions (see Section 5.3.6). The Phase 2 Draft EIS reports the results of
geotechnical studies conducted along the existing corridor and notes that groundwater was found at or
near the surface on the Redmond Segment and in the vicinity of the Richards Creek substation site (see
Section 3.3.2.3). It also describes potential impacts to shallow groundwater during construction (see
Section 4.3.2.2) and notes that pump tests would be conducted prior to construction to determine
specific impacts to groundwater. In areas where groundwater is near the surface or surface water is
present, best management practices (BMPs) would be required to protect water quality (see Section
4.3.3, Mitigation Measures). Additionally, PSE must meet jurisdictional critical areas regulations.
Key Theme WTR‐2: Stormwater management
Comment Summary:
Multiple commenters expressed concerns regarding stormwater management both during and after
construction. Commenters stated that stormwater management is particularly important in steeper areas,
that stormwater would no longer be absorbed as a result of the project, and there should be a plan for
managing mosquitos in standing water. One commenter inquired why no maps or plans were provided
for stormwater management. Another stated that underground lakes and reservoirs may be formed as a
result of the project, leading to erosion and damage to buildings, pipelines, and transmission lines. Use
of existing utility or road corridors was suggested so there would be less clearing, and less potential for
impacts to water quality.
The Somerset Recreation Club noted that its facility has been impacted by stormwater runoff from the
hill and roadway along Somerset Blvd. The club noted that the existing transmission line and pipelines
could also have been impacted by stormwater runoff and suggested that an analysis be conducted
before new poles are constructed.
Response:
The Phase 1 Draft EIS provides a high-level, programmatic assessment of potential impacts to water
resources and therefore did not include the level of detail many commenters requested. A project-level
assessment of potential impacts to water quality is provided in the Phase 2 Draft EIS. Impervious
surface is the most common factor that reduces stormwater infiltration. However, the amount of new
impervious surface would be minimal. In addition, once installed, poles would not affect groundwater
infiltration or shallow groundwater flow (see Section 3.3.5.1 of the Phase 2 Draft EIS). During
construction, contractors would be required to comply with the stormwater regulations of the Partner
Cities, which are based on the standards set by Ecology's Stormwater Management Manual for Western
Washington (see Table 5-1 of the Phase 1 Draft EIS and Section 3.3.6 of the Phase 2 Draft EIS).
Compliance with these regulations would result in less-than-significant impacts on surface and
groundwater (Section 3.3.5 of the Phase 2 Draft EIS).
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The Phase 1 Draft EIS notes that tree canopy reduces stormwater runoff by intercepting and taking up
water (see Section 6.3.3), and that clearing vegetation could increase runoff and erosion. The Phase 1
Draft EIS examined a range of options that included transmission lines constructed through new utility
corridors that are currently vegetated. The Phase 2 Draft EIS examined specific corridors more closely
and compared the impacts among options in Sections 3.3 and 3.4. Although permanently cleared areas
would contribute to increased stormwater runoff, the Phase 2 Draft EIS found that impacts would be
less-than-significant because PSE would comply with state and local stormwater permit requirements
and would implement BMPs to control surface water runoff both during construction and over the long
term. In the Final EIS, PSE’s Proposed Alignment would be constructed within the existing corridor
only, using the option that requires the least amount of tree removal.
Approximate pole locations were provided by PSE for the Phase 2 Draft EIS and are included in
Appendix A of the Phase 2 Draft EIS. For the Phase 2 Draft EIS analysis, it was assumed that poles
could be placed up to 25 feet away in any direction from the locations shown in Appendix A. The new
steel poles will be designed and installed so that they would not be adversely impacted by stormwater
runoff, nor would they affect stormwater runoff once they are installed. As described in the Final EIS,
for the PSE’s proposed alignment, approximately 60% of the poles would be directly embedded and
would not require a concrete foundation. Directly embedded poles have a smaller impervious footprint
than poles with concrete foundations.
Key Theme WTR‐3: Groundwater pollution and diversion
Comment Summary:
One commenter asked why groundwater pollution from coal ash was not considered. Another stated
that properties along 129th St SE in the Olympus neighborhood drain groundwater (which is presumed
to mean that there are groundwater seeps where subsurface water emerges to the surface because of soil
saturation, a common feature in the Puget Sound region). They added that some homes were flooded
during their construction due to groundwater. The commenter was concerned that digging and placing
the foundations for the steel poles could change the flow of groundwater, and that construction
negligence could cause the groundwater to flood homes. In addition, commenters stated that there could
be significant adverse effects to water resources depending on the magnitude of a pipeline rupture,
citing Criteria for Pipelines Co-Existing with Electric Power Lines by Dr. Cheng.
Response:
Chapter 3 of the Phase 1 Draft EIS states that coal mines and other hazards are present throughout the
combined study area. As stated in Section 3.7.3.1, specific geotechnical investigations would be
required to define the underlying engineering properties and identify any geotechnical hazards (such as
coal mining areas) that may be present. Geotechnical engineering methods, such as the use of
engineered fill or foundation design, would ensure that the effects of any identified hazards are
minimized and impacts during operation would be minor. If coal ash were present in the soil, it is
unlikely it would contaminate the groundwater because of requirements for preventing pollution during
construction. The Phase 2 Draft EIS notes that construction for pole installation would also require
excavation for pole foundation or direct embedding that could encounter shallow groundwater. This
could require dewatering to remove groundwater that seeps into excavated areas. The uncontrolled
release of dewatering water could contaminate surface waters. Use of sediment tanks to settle soil
particles and filter or treat water pumped from the excavations would prevent groundwater
contamination. Because the area of excavation for each pole would be limited to approximately 8 feet
in diameter, any dewatering would be minimal and impacts would be less-than-significant (see Section
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4.3.2.2 of the Phase 2 Draft EIS). Once installed, poles would not affect groundwater infiltration or
shallow groundwater flow (see Section 3.3.5.1). Pump tests would be conducted prior to construction to
determine the potential for drawdown and settlement. Appropriate mitigation measures would be
developed to minimize impacts and comply with water quality protection regulations, as well as the
Cities’ critical aquifer recharge area and dewatering regulations.
The Phase 1 Draft EIS states that the Olympic Pipeline system could be damaged during construction
under Alternative 1, Option A, and could have significant adverse effects on groundwater quality and
other surrounding water resources depending on the location, size, and length of time of the rupture
(see Section 5.5.3.1.6). The Phase 1 Draft EIS explained that the likelihood of a pipeline rupture is still
considered low due to measures employed to prevent such accidents and is not measurably different
from risks associated with current pipeline operations. Potential impacts of pipeline damage on water
resources are evaluated in further detail in Section 3.9.6 of the Phase 2 Draft EIS.
Key Theme WTR‐4: Construction‐related impacts
Comment Summary:
Commenters had questions about the construction impacts section and requested that additional
analysis be conducted. One commenter stated that risk mitigation plans would need to be developed
because construction would cause rerouting of natural springs, flooding, and other water-related runoff
to structures. One commenter noted that trenching through wetlands has the potential to dewater/drain
wetlands without appropriate BMPs. Another commenter noted the potential impact on water resources
from heavy machinery and excavation during construction. Commenters also noted the finding that
Alternative 2 would have a lower potential for impact to water resources than Alternative 1, Option A.
Response:
It would not be necessary to reroute springs under any of the alternatives considered for this project.
Any temporary alterations to springs during construction would need to comply with applicable
regulations and accompanying mitigation requirements. Temporary periods of turbidity or disturbance
of contaminated sediments could occur during in-water work, potentially impacting the water quality of
streams. The implementation of BMPs, and compliance with local and state permit requirements, would
be required to reduce potential water quality impacts. This is covered in greater detail in Section 5.5.1.4
of the Phase 1 Draft EIS. Construction impacts to streams are further evaluated in Section 4.3 of the
Phase 2 Draft EIS.
The Phase 1 Draft EIS states that although some trenching could be required for the installation of
underground or underwater transmission lines, mitigation for impacts to wetlands, streams, or their
buffers would be required by existing regulations. Impacts to wetlands, streams, or their buffers would
be minor because it is expected that they could be avoided during project design and pole placement,
and any impacts could be fully mitigated (see Section 5.6.3.2). Under the alternatives carried forward
for the Phase 2 Draft EIS analysis, no trenching would be required.
The Phase 1 Draft EIS acknowledges that ground disturbance from heavy machinery and excavation for
the installation of poles for new or rebuilt overhead transmission lines have the potential for minor to
moderate impacts to wetlands, streams, and lakes (see Section 5.5.3.1.4). Equipment could be operated
in a manner to avoid wetlands, streams, and their buffers, and new poles would also be located to avoid
these areas, to the extent feasible. However, impacts to some wetlands, streams, and their buffers are
likely to be unavoidable. Mitigation would be required to comply with applicable regulations, and
impacts to water resources would less-than-significant due to requirements imposed by regulatory
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agencies. Table 4.3-1 of the Phase 2 Draft EIS states that heavy construction equipment could compact
soils and reduce the rate of surface water infiltration and groundwater recharge at the Richards Creek
substation site. It also notes that limiting the area of construction impact would minimize compaction.
Section 4.3.2 of the Phase 2 Draft EIS states that excavation could encounter shallow groundwater and
require dewatering. Pump tests would be conducted prior to construction to determine potential
drawdown and appropriate mitigation. Most of the other substation facilities would be placed on
concrete pads, requiring limited excavation.
It is true that Alternative 2 has a lower potential for construction impact to water resources than
Alternative 1 because construction would be smaller in scale (see Section 5.4.4). However, it was
determined that this alternative was not feasible. As a result, it was not evaluated further in the Phase 2
Draft EIS or the Final EIS. For more information, see Section 2.2.7 of the Phase 2 Draft EIS.
Key Theme WTR‐5: Water quality and permitting
Comment Summary:
A commenter requested that the EIS Consultant Team assess project compliance with the following:
Dredge and Fill Requirements (33 CFR Part 323) and Section 10 Permits for Work in Navigable
Waters (33 CFR Part 322). Another commenter stated that the reference to FEMA and local floodplain
management regulations in the Phase 1 Draft EIS does not address requirements resulting from the
2008 Biological Opinion on the National Flood Insurance Program (NFIP); the commenter noted that
not all of the referenced codes may have been amended to account for the BiOp, but each City is
responsible for demonstrating compliance under the BiOp. The commenter requested that the EIS be
revised to reflect the NFIP’s requirement to conserve/protect habitat conditions for threatened and
endangered salmonids and essential fish habitat.
Response:
Table 5-1 in the Phase 1 Draft EIS states that any project that proposes discharging dredged or fill
material into Waters of the United States must obtain a Section 404 permit. Case law and rule
amendments have specifically defined Waters of the United States (40 CFR 230.3). Case-by-case
analysis is required to confirm applicability of this law to surface waters such as rivers, streams,
ditches, lakes, ponds, territorial seas, and wetlands. Any work in, over, or under navigable Waters of
the United States requires a Section 10 permit. The purpose of Section 10 permitting is to prohibit the
obstruction or alteration of these navigable waters. Some of the streams and the Cedar River are within
FEMA-designated floodplains; however, any poles placed in the floodplain would not obstruct flood
flows or alter drainage. The Phase 1 Draft EIS and the Phase 2 Draft EIS state that the project would
comply with all applicable permits and regulations; this would include compliance with the Endangered
Species Act as well the NFIP BiOp, for example. During the permitting process, PSE would be required
to demonstrate that any proposed development activities in a floodplain do not result in an adverse
effect on listed species or habitat. For example, the City of Bellevue demonstrates compliance with the
BiOp on a permit-by-permit basis. In Redmond, subsequent land use permitting would need to submit a
FEMA Habitat Assessment and Floodplain/Floodway Report to the local jurisdiction for BiOp
compliance.
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Key Theme WTR‐6: Tribal treaty rights
Comment Summary:
The Muckleshoot Tribe commented that Table 5-1: (1) failed to note that the U.S. Army Corps of
Engineers must ensure tribal treaty rights are protected as part of their authorizations under Section 10
and 404; and (2) did not note that there are likely aquatic lands in the project area owned by the
Washington Department of Natural Resources (WDNR). The Muckleshoot Tribe stated that Alternative
1, Option D, has the potential to impact tribal fishing by limiting access to fishing sites within the entire
construction area, from the Renton area all along the eastern Lake Washington shoreline up to the
Kirkland area (Figure 2-1), and due to vessel movements and barge traffic. The Muckleshoot Tribe
stated the construction area would likely be larger than described in the EIS if construction materials
need to be transported via ships and barges coming from the Locks (page 2-31). The Tribe stated that
vessel traffic could potentially cause gear damage and obstruction of other fish sites if vessels and
barges need to be staged outside of the construction areas. In addition, the Tribe stated that lease
agreements and permission would be needed from WDNR to allow an underwater cable to be located
on State-owned Aquatic Lands.
The Tribe stated Alternative 1, Option D, would have to avoid WDNR owned aquatic lands in front of
the Barbee Mill Plat because it was capped as part of the clean-up efforts and should not be disturbed.
The Tribe stated that the impact assessment is incomplete because Option D would require a minimum
of three landing points that include six vaults for each landing point. Roads would also be required to
access these vaults. These facilities will result in permanent impacts to vegetation (at a minimum), and
where they occur on the shoreline there is the potential to permanently eliminate shoreline buffers,
potential filling of shoreline wetlands, or impacts to streams and their buffers that drain to Lake
Washington.
Response:
These comments relate specifically to Alternative 1, Option D (Underwater Transmission Line) as
presented in the Phase 1 Draft EIS, which provides a programmatic evaluation of the potential impacts
associated with Option D. The comments are correct regarding U.S. Army Corps of Engineers ensuring
protection of tribal treaty rights as part of their authorizations, and the need for WDNR leases. Further
analysis was not conducted because the alternative was not carried forward to the Phase 2 analysis (see
Section 2.2.3 of the Phase 2 Draft EIS).
Key Theme WTR‐7: Clarifications
Comment Summary:
PSE stated that maintenance under the No Action Alternative would not be limited to conductor
replacement, but would include regular pole replacement as well.
PSE also stated that Alternative 2 would require construction of facilities; therefore, as proposed, minor
to moderate impacts to water resources could occur. PSE stated that the necessary ancillary utilities that
are required for components of Alternative 2 have not been addressed, including natural gas, water, and
sewer pipelines.
Response:
For the Phase 1 Draft EIS, the No Action Alternative was generally defined as PSE managing its
system as it currently does. This includes maintenance programs that reduce the likelihood of
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equipment failure and stockpiling of additional equipment so repairs can be made as quickly as
possible. Impacts associated with routine maintenance of the existing transmission lines (e.g.,
occasional replacement or repair of poles, wires, and related equipment) are assessed in more detail as
part of Chapter 3, Long-Term (Operation) Impacts and Potential Mitigation of the Phase 2 Draft EIS.
Section 5.5.4 of the Phase 1 Draft EIS states that the types of impacts described for Alternative 1 would
be similar for some of the components of Alternative 2. The energy storage and peak generation plant
components of Alternative 2 could be similar to transformer/substation work since they would be
located at or adjacent to existing substations. Overall, Alternative 2 has a lower potential for impact to
water resources than Alternative 1 because construction, other than energy storage and peak generation
plant components, would be smaller in scale (small projects on individual homes and businesses) than
the transmission line construction. Groundwater, floodplains, and stormwater issues would be handled
in the same way as described above for Alternative 1. As a result, impacts on water resources are
anticipated to be minor. Section 16.6.4.5 of the Phase 1 Draft EIS states that for peak generation plant
components, utilities would need to be extended at the site, and upgrades or extensions of natural gas or
water distribution lines may be required to supply a generator at a particular location. However, such
utility extensions, after permitting requirements and implementation of BMPs, are unlikely to result in
anything above a minor impact to water resources.
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Plants and Animals (Topic P&A)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding
plants and animals. Primary themes included the types of habitat described and potential impacts, tree
removal/vegetation clearing, impacts to fish and wildlife, impacts specifically to birds, and appropriate
mitigation measures.
Key Theme P&A‐1: Habitat
Comment Summary:
Commenters listed habitats within the Eastside that they felt were not adequately described in the
Phase 1 Draft EIS. One commenter noted that landscaped areas of commercial properties can provide
habitat, lakes and ponds can be used by amphibians and some mammals, and forests can be utilized by
amphibians and reptiles. Another commenter noted that the Coal Creek Basin provides habitat for a
diverse assemblage of fish and wildlife, including Chinook (a Federal Endangered Species) and coho
(species of Local Importance: Bellevue Land Use Code 20.25H.150A), rainbow and cutthroat trout,
coho, sockeye, and steelhead.
One commenter stated that the creation of a new transmission line would change the type of habitat, but
would not completely remove habitat. It was noted that the use of existing corridors would reduce the
amount of habitat conversion as compared to other alternatives considered in the EIS; however, the
proposed route would include many environmentally sensitive areas. Some commenters asked how
impacts to specific types of vegetation, such as hedgerows, were addressed. Comments relating to
habitat also had to do with species displacement, with one commenter stating that animals avoid high
voltage lines and would be affected by habitat fragmentation.
Response:
The Phase 1 Draft EIS states that urban habitat includes areas where commercial, industrial, or dense
residential land uses dominate (see page 6-8 of the Phase 1 Draft EIS). Section 6.4.1 of the Phase 1
Draft EIS provides a programmatic overview of the general distribution of these habitat types within
the different jurisdictions in the combined study area, and a short description of each habitat and
species that typically use the habitat. The potential presence of amphibians and reptiles in the combined
study area has been added to the Errata (see Chapter 3 of the Final EIS). Although the Phase 1 Draft
EIS did not evaluate habitat and species on a basin level, it did note that Coal Creek Park Natural Area
provides diverse fish and wildlife habitat. The Phase 2 Draft EIS provides a project-level assessment of
impacts to habitat associated with Coal Creek Park Natural Area within 0.5 mile of the project
alignment, and notes that Coal Creek supports Chinook salmon and steelhead (see Section 3.4.2.2 of the
Phase 2 Draft EIS).
Altering habitat to the degree that species composition changes is characterized in the Phase 1 Draft
EIS as habitat loss (removal), not conversion. The Phase 1 Draft EIS supports the statement that using
existing corridors for the new transmission line would reduce the amount of habitat that would be
converted. PSE's existing corridor provides habitat and migration corridors for area wildlife, as well as
specific critical habitat areas (wetlands, streams, ponds, and their associated buffers) (see Section 3.4 of
the Phase 2 Draft EIS). A project-level assessment of impacts to vegetation is provided in Section 3.4
of the Phase 2 Draft EIS, which focused primarily on species with state or Federal listing status within
the project area. Specific impacts to hedgerows were not assessed; however, vegetation removal within
the right-of-way is covered. While hedgerows do accommodate a number of species common to the
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project area, they are not considered a critical habitat type. Because vegetation management restrictions
mainly affect trees, the only effect on hedgerows would be if they contained trees or if they were in
locations where a pole needed to be placed. The Phase 2 Draft EIS states that the existing corridor
provides important urban habitat, migration, and connectivity corridors for existing wildlife. There is
no evidence that animals avoid high voltage lines beyond what would occur as the result of increased
human presence (such as maintenance activities) and vegetation clearing. The use of the existing
transmission corridor would result in a loss of some habitat due to additional tree removal (also
discussed below), but would not measurably increase habitat fragmentation. However, alternatives or
routes that use new corridors would result in greater habitat loss and increased fragmentation because
they are in areas where a transmission corridor does not currently exist.
Key Theme P&A‐2: Tree removal/vegetation clearing
Comment Summary:
Commenters cited the findings of the Phase 1 Draft EIS, and said that the amount of tree removal
would be significant. One commenter suggested that no tree removal should be allowed. The
Muckleshoot Tribe stated (in reference to Alternative 1, Option D) that the Phase 1 Draft EIS failed to
adequately account for impacts associated with a permanent clear zone in the shoreline and would also
preclude restoration actions where they were identified as part of the Shoreline Master Programs
associated with each lakefront city. Another stated that vegetation removal would result in increased
noise because trees provide a degree of noise abatement. Multiple commenters noted that the amount of
tree removal would have cascading effects on views, water quality, and greenhouse gases.
PSE clarified that if the existing Sammamish-Lakeside-Talbot Hill 115 kV corridor is used, no
additional right-of-way width would be required. PSE also asserted that the existing 40 percent tree
canopy coverage noted in the Phase 1 Draft EIS is over-estimated.
Response:
The Phase 1 Draft EIS examined the worst-case scenario for new overhead transmission lines, which
assumed that a new corridor for a 230 kV line would be 120 to 150 feet wide (approximately 30 to 40
feet wider than the existing 115 kV transmission line corridor). However, the Phase 1 Draft EIS notes
that the severity of impacts would depend on the location of the project and adjacent habitat and species
that use it. During the development of the Phase 1 Draft EIS, the width of clear zones was unknown
because the height and form of the transmission poles had not been determined. The approximated
width was based on a literature review and information available from PSE at the time of the analysis.
The 40 percent existing tree canopy coverage cited in the Phase 1 Draft EIS was based on the average
tree coverage mapped in the project area jurisdictions. However, for the project-level, Phase 2 Draft
EIS it was assumed that the existing Sammamish-Lakeside-Talbot Hill corridor would not have to be
widened to accommodate the 230 kV line. Updated vegetation removal information, including a more
detailed discussion of clear zones, is provided in the Phase 2 Draft EIS (see Section 3.4.1.3, PSE
Vegetation Management Program) and in the Final EIS, Section 4.4.
It is correct that vegetation removal for a new corridor or substantial widening of an existing corridor
could result in reduced noise attenuation. However, noise impacts are not expected to be significant
because even dense forested vegetation must be greater than 20 meters (approximately 60 feet) in depth
to have a noticeable effect on noise levels. The option-specific estimates for tree removal are
incorporated into other resource analyses in the Phase 2 Draft EIS including scenic views and the
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aesthetic environment (Section 3.2), water (Section 3.3), and greenhouse gas (Section 3.5). The Phase 2
Draft EIS assessment did not estimate the amount of noise attenuation lost as a result of tree removal;
however, vegetation removal is not anticipated to result in a significant noise impact for any of the
alternatives evaluated in Phase 2, or for PSE’s proposed alignment in the Final EIS. Tree removal and
mitigation will be evaluated as part of the permitting process. PSE would be required to replace trees
removed for the project based on tree protection ordinances and critical areas regulations in each
affected city. Additional mitigation measures are proposed in Section 3.4.6 of the Phase 2 Draft EIS.
Key Theme P&A‐3: Fish and wildlife
Comment Summary:
Concerns were raised about potential impacts to fish and wildlife, and how such impacts were
evaluated. The Muckleshoot Tribe commented that the impacts to salmon and their prey in Lake
Washington [Alternative 1, Option D (Underwater Transmission Line)] were not fully evaluated, and
that fish exposure to contaminated sediments should have been considered. They also indicated that
construction would need to occur during the allowable “fish window” (as determined by WDFW). A
commenter stated that they were concerned about the pipeline failing during construction and impacting
spawning salmon in the Cedar River.
One commenter stated that because high voltage transmission lines are 50 percent thicker than typical
distribution lines and operate at much higher temperatures, they pose a threat to native and migratory
bird species, flying insects, and other plant and animal species sensitive to heat and nighttime light
emissions. They also stated that these high voltage lines produce ultra-violet (UV) flashes that affect
the vision of mammals. They added that corona emissions produce audible sounds that are disruptive to
animals. The commenter noted that EMF/corona have additional unknown impacts on plants and
wildlife. Another stated that the Phase 1 Draft EIS understated the potential noise impacts to wildlife
resulting from the operation of peaker plants, which the noise section described as exceeding noise
regulations in some areas.
One commenter asked if impacts to Bombus occidentalis (bumblebees) were evaluated. The commenter
also stated that there have been multiple reports of bobcats in the area, but noted that these sightings
may have been of young Canadian lynx. A few commenters noted that the Phase 1 Draft EIS’s list of
species of local importance does not match the one provided in the City of Bellevue municipal code.
Response
Alternative 1, Option D (Underwater Transmission Line) was evaluated at a programmatic level. The
alternative was not carried forward into the Phase 2 Draft EIS because the option was determined to not
be a reasonable alternative to using the existing corridor (as proposed by PSE), as described in more
detail in Section 2.2.3 of the Phase 2 Draft EIS. The Phase 1 Draft EIS, which was prepared as a
programmatic analysis, does not address impacts to plants and animals from pipeline spills. Impacts to
plants and animals as the result of a pipeline spill or fire are described in Section 3.9.6 of the Phase 2
Draft EIS, which was prepared as project-specific analysis.
Most of the project alignment occurs in areas that produce a variety of human-induced disturbances to
animal species. Larger wire sizes for the 230 kV lines would be more visible to flying species, resulting
in increased avoidance behavior, which is expected to reduce direct impacts from collision.
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The new power poles would also reduce the amount of structures that could be used by avian species
for roosting or nesting, include the latest technology to protect birds from electrocution, and increase
the separation between wires. All of these are expected to reduce collision and electrocution rates
compared to existing conditions.
EMF impacts to wildlife species are generally unknown or inconclusive, particularly for wild free-
ranging animals, because most research has been conducted in laboratory settings (Doherty and Grubb
Jr., 1998; Fernie and Reynolds, 2006; Tomás et al., 2012). In addition, most EMF impact studies have
focused on human subjects. Arun (2015) assessed over 900 EMF studies and observed that only 3%
focused on birds, and just 2% concerned other wildlife species. These studies also cover a wide range
of EMF conditions, including those produced by communication cell towers and higher voltage
transmission lines than those being evaluated for the proposed project. Laboratory studies have
identified EMF effects on embryonic development, but reproductive success of wild birds is dependent
on additional factors not present in a lab setting. Both positive and negative effects have been observed
on individual avian species, and effects also vary substantially between species, with some
experiencing negative effects on overall reproductive success and some having no apparent difference
in success (Fernie et al., 2000; Fernie and Reynolds, 2006; Vaitkuviene and Dagys, 2014; Tomàs et al.,
2012; Doherty and Grubb Jr., 1998). Although little or no direct information is available on potential
effects of species known to be present in the project corridor, the studies provide an indication of the
potential effects on wildlife species. Adverse impacts on wildlife species as a result of exposure to EMF
are not anticipated to increase as a result of the proposed project because magnetic field levels
associated with the proposed project are anticipated to be lower than field levels along the existing
transmission line corridor. See the discussion in Section 3.8.5.1 of the Phase 2 Draft EIS for the reasons
why the field levels are expected to be lower.
While powerlines are known to affect migration and behavioral activities of bees, transmission
corridors are also identified as important conservation areas for bee populations (Bartomeus and Hill,
2015). The 230 kV lines would be higher above the ground, which would minimize potential impacts to
low-flying insects and other ground-oriented species from increased light flashes or heat from the
wires. While avoidance by mammals and ground-nesting birds of habitat in the vicinity of high-voltage
power lines has been documented in remote areas, effects in urban areas are uncertain because of
influence of light pollution from other sources (Tyler et al., 2014). These researchers suggest that in
darkness birds and some other animals see power lines as lines of flickering UV corona light stretching
across the terrain, rather than dim, passive structures, which would enhance avoidance behavior and
reduce collision and electrocution rates. No evidence was found that air quality changes resulting from
the ionization of pollutant particles by the corona discharge would affect wildlife. To the extent wildlife
avoid power lines due to corona discharge, potential impacts suggested in the comments are unlikely
because the concentration of these pollutant particles would decrease with distance from the source.
The higher powerlines would also tend to minimize potential effects on ground-oriented species.
Noise impacts produced by corona discharge were found to be negligible (see Section 9.6.3.1.1 of the
Phase 1 Draft EIS). The noise levels from the proposed transmission lines would be similar to the noise
from existing lines.
Section 6.7.4 of the Phase 1 Draft EIS states that noise disturbance from peak generators located in or
adjacent to wildlife habitats could be moderate to significant. The finding of moderate to significant
impacts is not understated, given the findings in the noise section (see Section 9.6.4.1 of the Phase 1
Draft EIS).
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The analysis focused primarily on species with state or federal listing status, which did not include
Bombus occidentalis (bumblebee) and bobcats. As indicated above, the effects of powerlines on
wildlife species are highly variable, both within and between species, and there is limited information
to differentially identify specific impacts to many species that could occur in the project area. While
lynx have a threatened status, the project area does not provide suitable habitat, and any occurrence
would be infrequent and incidental. Therefore, detailed investigations were not conducted for this
species during the EIS process. While powerlines are known to interfere with normal migration and
behavioral activities of bees, transmission corridors are also identified as important conservation areas
for bee populations (Bartomeus and Hill, 2015). Western big-eared bat, Keen's myotis, long-legged
myotis, and long-eared myotis have been added to the Bellevue list (see Chapter 3 of the Final EIS), as
requested. Chinook and coho are listed as species of Local Importance under Bellevue Land Use Code
20.25H.150A; Chinook salmon are a federally listed threatened species and coho are a species of State
importance, both of which are listed in Appendix C, rather than in Section 6.4.2.
Key Theme P&A‐4: Impacts to birds
Comment Summary:
Commenters expressed concern over how impacts to birds caused by overhead transmission lines were
analyzed in the Phase 1 Draft EIS. One commenter said that birds would only be temporarily displaced.
Another cited a National Audubon study that concluded that 175 million bird deaths occur per year
from collision with or electrocutions from power lines. It was asserted that the Phase 1 Draft EIS
overstates the impact of a new overhead 230 kV transmission line on avian species and understates the
impact of constructing Alternative 3 (Distributed Generation). Specific locations of eagle nests were
provided by multiple commenters, and it was noted that eagle nest buffer zones and great blue heron
nest buffers would need to be considered and possibly avoided or monitored if construction is
scheduled to occur within active nest buffers during the nesting season.
Response:
At the programmatic level, if it was unclear whether a species would be temporarily or permanently
displaced, it was assumed they would be permanently displaced. Introduction of a new transmission
line in an area previously without one would increase the likelihood of bird collision and electrocution.
However, the alternatives evaluated in the Phase 2 Draft EIS would replace existing transmission lines
with higher voltage transmission lines in most locations. The Phase 2 Draft EIS states that the project
would reduce the electrocution and collision rates for avian species due to the increased separation
between conductors and larger, more visible conductors (see Section 3.4.5.1). Eagle nest locations were
considered during development of the Phase 2 Draft EIS, and potential impacts to birds are further
described in Sections 3.4.1.4 and 3.4.3. PSE would continue to implement the PSE Avian Protection
Program and mitigate for the direct loss of nesting and roosting habitat for protected species. For more
information about the Avian Protection Program, see Section 3.4.1.4 of the Phase 2 Draft EIS.
Key Theme P&A‐5: Mitigation
Comment Summary:
PSE stated that transmission lines can be configured and routed to minimize impacts to trees and
habitat. Other commenters stated that no amount of mitigation can counter the impact of PSE's
proposal.
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Response:
The Phase 1 Draft EIS states that impacts on vegetation and habitat would be mitigated through site and
facility design to minimize the need for vegetation and tree removal to the extent feasible. In addition,
one of the mitigation measures proposed in Section 3.4.6 of the Phase 2 Draft EIS is to increase pole
heights to allow greater separation between poles so that some poles can be moved outside of critical
areas or associated buffers.
Key Theme P&A‐6: Errata and minor clarifications
Following the release of the Phase 1 Draft EIS, PSE provided comments that clarified information or
rectified misstatements. Items that were found to be in error are provided in detail in Chapter 3, Errata,
of the Final EIS. Clarifications address the following topic: approximately 9 miles of additional 230 kV
line would need to be reconductored north of the Sammamish substation as part of Alternative 1,
Option C (SCL Corridor), which could include clearing associated with construction access. PSE (and
other commenters) also provided numerous other minor clarifications that we have not included in the
Errata because they relate to Phase 1 alternatives that are no longer being considered, they are minor
clarifications (as opposed to factual errors), or they do not influence the results or conclusions of the
analysis. The full letters are included as Appendix J-2 and therefore part of the record.
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Energy (Topic EGY)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding
energy. Primary themes included the energy use of peaker plants; the potential for Alternative 1 to
increase demand for electricity; and the need for utilities to adopt measures that reflect sustainability,
conservation, and efficiency. Please note that some of these comments and associated issues also relate
to the project objectives; see the additional description provided for Topic OBJ.
Key Theme EGY‐1: Energy use of peaker plants
Comment Summary:
PSE stated that if 20-MW peaker plants are used to solve the transmission deficiency problem, 20 such
peaker plants would be needed. A public commenter disagreed with the finding of the Phase 1 Draft
EIS that Alternative 2 would lead to generation of non-renewable power.
Response:
The Phase 1 Draft EIS notes that PSE suggested that twenty 20-MW generators would be necessary to
meet the project objectives (see Section 2.3.3.1). PSE determined that use of peaker plants should be
eliminated from consideration because they would produce noise that would be incompatible with the
predominately residential surroundings. As noted in the Phase 1 Draft EIS, noise would be an important
consideration in siting such facilities. However, the EIS Consultant Team determined that these proven
technologies could possibly be sited in some locations and be compatible with adjacent uses, addressing
a portion of the identified need. Therefore, use of three 20-MW peaker plants was considered for
Alternative 2. As stated in Section 2.3.3 of the Phase 1 Draft EIS, Alternative 2 was developed based
on the assumption that a mix of measures would be necessary to accomplish conservation savings.
The Phase 1 Draft EIS states that Alternative 2 would not substantially change the overall mix of
resources used by PSE to deliver power to its customers, but would lead to more local (Eastside) use of
resources for power generation, some of which would likely be fossil fuel-based and therefore not
renewable. The distributed generation component and peaker plants would rely on non-renewable
resources (fossil fuels such as diesel or natural gas) to operate. However, it was determined that since
those energy sources are currently in good supply and the project would require only brief periods of
operation, the components would have a negligible adverse impact on energy resources (see Sections
7.6.4.3 and 7.6.4.5 of the Phase 1 Draft EIS).
Key Theme EGY‐2: Alternative 1 would result in increased demand for energy and
would therefore require more fossil fuel use
Comment Summary:
Commenters stated that Alternative 1 would increase the demand for electricity and that more analysis
should have been conducted on the cascading impacts resulting from PSE’s Colstrip plant. One
commenter stated that Alternative 1 would enable the construction of up to 1000 MW of new
generation.
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Response:
The Phase 1 Draft EIS acknowledges that the project would provide more than adequate capacity to
meet the projected transmission need in the Eastside for the 10-year planning horizon. However, as
described in the Phase 1 Draft EIS, there is no intermediate size of transmission facility between 115
kV and 230 kV that would work within the regional grid and meet PSE’s stated objectives. See Section
2.2.1.15 of the Phase 1 Draft EIS for a more detailed discussion of 115 and 230 kV transmission lines
within the regional grid. The project is not being constructed to increase power production, and there is
no indication in its IRP that PSE plans to increase reliance on or transmission from the Colstrip plant.
Therefore, impacts associated with increased power production, such as increased operations at the
Colstrip plant, were not evaluated as part of this EIS process.
Key Theme EGY‐3: The need for Utilities to adopt measures that reflect
sustainability, conservation, and efficiency
Comment Summary:
Commenters stated that utilities are protecting their profits at the expense of progressive energy policy
reform and implementation of renewable energy sources. They asked if utilities are influencing energy
policy in a sustainable direction and are willing to adapt to new business models that are more inclusive
of renewable energy sources.
Response:
It is outside the scope of this EIS to speculate PSE’s motives. Consistency of the project with adopted
energy policies was conducted for the Phase 1 EIS analysis (see Chapter 7). For more information
about PSE’s conservation program, see Appendix A of the Phase 1 Draft EIS.
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Pipeline Safety (Topic PLS)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding
pipeline safety, specifically related to locating transmission lines adjacent to the fuel pipeline operated
by the Olympic Pipe Line Company (Olympic). Comments stressed the risks of catastrophic explosions
and leaks, both during and after construction. Primary themes included risk of explosions and leaks
caused by construction; explosions, fires, or leaks caused by natural forces; pipeline corrosion caused
by electrical interference from power lines; evaluation of worst-case scenario involving pipeline rupture
and fire; non-compliance with safety regulations; and engagement of Olympic in the EIS process.
The Partner Cities acknowledge that public safety is of paramount concern. The Partner Cities and the
EIS Consultant Team contacted Olympic during the development of the Phase 1 Draft EIS, and made
additional inquiries during the project-specific phase of the EIS. The EIS Consultant Team examined
the studies cited by commenters. The discussion, analysis, and characterization of public safety was
refined in the Phase 2 Draft EIS, with greater focus on project-level details, including the preparation of
a probabilistic pipeline risk assessment (risk assessment) that evaluated the probability of a pipeline
rupture occurring as a result of the construction and operation of overhead transmission lines. EDM
Services, a company specializing in pipeline safety risk assessments, conducted the assessment.
Key Theme PLS‐1: Risk of catastrophic explosions and leaks caused by construction
Comment Summary:
Commenters asserted that the Phase 1 Draft EIS did not adequately address construction-related risks.
Concern was expressed that there is a high risk of damaging the pipeline during excavation because the
pipeline is in a shared right-of-way that is narrow and, therefore, separation of the transmission line
from the pipeline is difficult, the pipeline is not buried deeply, and the pipeline is old (approximately 40
years old) and potentially vulnerable to breakage due to vibration or other construction-related effects.
To mitigate these potential impacts, commenters recommended that the liquid fuel lines be
depressurized during construction of tower foundations and erection of towers and cable.
Response:
When accidents do occur along pipelines, they often occur because of a failure to properly locate buried
utilities prior to construction, or failure to follow proper procedures during construction, as was the case
in the incidents in Texas (2010) and Bellingham (1999) often cited in comments. These risks are
acknowledged in the Phase 1 Draft EIS. In response to public comments such as these, the risks are
analyzed more closely in Sections 3.9 and 4.9 (Environmental Health –Pipeline Safety) of the Phase 2
Draft EIS.
In the case of PSE's and Olympic's shared corridor, PSE and Olympic have worked together in the
corridor for 40 years, and communicate regularly to coordinate activities related to pole replacement
and other maintenance work. In addition to State Damage Prevention Law (RCW 19.122) compliance,
Olympic has a list of requirements for all work proposed near the pipeline (see Appendix I of the Phase
2 Draft EIS). These include specific notification and monitoring requirements, requirements related to
excavation near the pipelines, and transport of construction materials or equipment over the pipelines.
As company practice, if a project is within 100 feet of the pipeline, Olympic's Damage Prevention
Team will meet with the construction crew on-site at the beginning of the project and weekly thereafter.
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If excavation has the potential to be within 10 feet of the pipeline, the Damage Prevention Team would
be continuously on-site to monitor excavation.
Section 4.9.3 of the Phase 2 Draft EIS describes potential pipeline safety risks related to construction
activities. As described above, with PSE's awareness of the pipelines within the corridor, Washington
State's Damage Prevention Law and "one-call" locator service, and Olympic's procedures to prevent
third party damage described in Section 4.9.4 of the Phase 2 Draft EIS, the increased risk posed to the
pipelines during construction is relatively low. Even with conservatively high assumptions of additional
risk factors resulting from the project, the results of the risk assessment completed for the Phase 2 Draft
EIS indicate that there would be a very small increase in total risk during construction. With the
implementation of measures to mitigate potential construction risks described in Section 4.9.4, these
risks would be even lower.
Vibration from construction equipment is also addressed in Section 4.9.3 of the Phase 2 Draft EIS. PSE
would work with Olympic to confirm that potential vibration associated with proposed excavation
methods for pole installation that include the use of vacuum trucks and auger drills would avoid
damaging the pipelines. For additional information on mitigation measures related to preventing
construction incidents, see Section 4.9.4 of the Phase 2 Draft EIS.
Regarding the mitigation suggestion of depressurizing the pipelines during construction of the project,
PSE has limited authority to influence specific mitigation measures undertaken by Olympic related to
pipeline operation or monitoring. PSE, as project applicant, has responsibilities (some of which may be
imposed by jurisdictions with permit authority) to coordinate and cooperate with Olympic. For more
information on PSE and Olympic’s roles and responsibilities in the corridor, see Section 3.9.7 of the
Phase 2 Draft EIS.
Key Theme PLS‐2: Risk of catastrophic explosions, fires, or leaks caused by natural
forces, such as earthquakes, windstorms, and lightning
Comment Summary:
Commenters asserted that the Phase 1 Draft EIS did not adequately address pipeline safety risks
associated with natural forces, such as earthquakes, windstorms and lightning. Commenters stated that
small punctures or weaknesses in the pipeline caused by arcing may result in leaks that are hard to
detect and could be catastrophic if they are ignited. The lack of detection of a leak that contributed to
the large pipeline fire in Bellingham in 1999 was often given as an example for this concern.
Commenters asserted the risk of a similar scenario occurring as a result of the Energize Eastside
project. Commenters cited several mechanisms that could lead to arcing from the power lines to the
pipeline that could cause a leak and/or a fire. These include seismic activity that could cause the
powerlines to break or fall at the same time that the pipeline would also be vulnerable to breaking; a
powerline knocked down during a windstorm causing an arc to the pipeline; or lightning striking on a
transmission line or pole and arcing to the pipeline. Commenters also voiced concern that galloping
lines could produce extensive power outages and an explosion.
Response:
The Phase 1 Draft EIS evaluated pipeline safety at a programmatic level and acknowledges the
potential for significant impacts related to proximity to the Olympic Pipeline system. Note that
operational risks related to natural forces were broadly analyzed as described in Sections 8.6.1.3,
8.6.2.3, 8.6.3.1.3, and 16.7 of the Phase 1 Draft EIS. Seismic risks are acknowledged in these sections.
Please also see the Earth comment summary for additional information on seismic risks.
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The Phase 1 Draft EIS and the Phase 2 Draft EIS both acknowledge that earthquakes and lightning
strikes or wires downed by extreme weather events present risks of fault conditions or arcing from the
transmission lines to the pipelines. As part of the risk assessment completed for Phase 2 Draft EIS,
natural forces (e.g., lightning strikes, seismicity, and extreme weather) were considered as potential
causes of pipeline damage (see Section 3.9.3.3). The risk assessment took into account historical
incident rates for natural force-caused pipeline incidents on similar systems nationwide, and current
risks in the corridor in consideration of fuel type/flammability, pipe parameters, safety features, and
other factors.
The project is not expected to increase risks of accidental releases due to seismic activity, or other
natural forces. Potential seismic risks exist under current conditions with the co-located transmission
lines and pipelines, which are not expected to increase with the project. PSE’s was asked about records
of downed transmission lines, and PSE indicated that their records show falling trees and cross-arm
failure were the causes. The project is not likely to increase trees falling on the lines, and the proposed
steel structures are expected to be stronger than the existing wooden ones and less prone to failure.
Section 3.9.7.1 of the Phase 2 Draft EIS describes the design and safety guidelines that PSE follows
when designing their transmission lines. The National Electrical Safety Code (NESC) contains the
provisions necessary for public safety under specific conditions, including electrical grounding,
protection from lightning strikes, extreme weather (including extreme wind), and seismic hazards. PSE
would use these in developing final design for the transmission line. PSE noted that Chapter 8 of the
Phase 1 Draft EIS incorrectly states that NESC guidelines direct PSE how to shield lines with lightning
protection. This has been rectified in the Errata; see Chapter 3 of the Final EIS. PSE also clarified that
for 230 kV substations, lightning protection is provided via a static mast with shield wires that are
connected to the substation ground grid. The comment from PSE that all substation transformers are
protected with surge arresters to limit damage done during a lightning strike is noted.
Additional information on seismic risks in the corridor and how these risks are accounted for is
provided in the Final EIS, Section 4.11. The potential for galloping conductors (i.e., galloping lines) is
calculated during design of transmission lines, and dampers are added to the line to dampen out
vibrations, preventing the conductors from galloping.
Key Theme PLS‐3: Risk of pipeline corrosion caused by electrical interference from
power lines
Comment Summary:
Several commenters asserted that locating transmission lines in the same area as fuel pipelines is much
riskier than described in the Phase 1 Draft EIS. Commenters cited a study by DNV GL, “Criteria for
Pipelines Co-Existing with Electric Power Lines” that considers several criteria to establish risk level
(e.g., separation distance, HVAC power line current, co-location length, and co-location angle). These
commenters asserted that, based on these four criteria, the Energize Eastside project would be
considered “high risk” per industry standards. Others referred to comments made by Dr. Frank Cheng,
“Safety of Co-location of Electric Power Lines and Pipelines” on corrosion risks associated with 230
kV lines. One commenter asked who is responsible for the upgrade of sacrificial metals that protect the
pipeline against corrosion caused by the electrical fields from the high voltage power line.
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Several commenters pointed to BPA’s policy of not locating transmission lines within a certain distance
(50 feet) of a buried pipeline running parallel to a transmission line. Other commenters pointed to other
separation distances recommended by companies, utilities, or by model code ordinances. These
commenters asserted that design and engineering alone are not enough, that physical separation is the
better way to mitigate the risk.
PSE comments on the Phase 1 Draft EIS indicated that if an existing utility corridor is used, PSE would
commission an appropriate engineering analysis of soil conditions as they relate to conductivity and
corrosiveness of underground utilities. Results would be used to determine appropriate grounding and
cathodic-protection needed. PSE also commented that the EIS should further acknowledge that PSE
and Olympic would evaluate the construction and operational parameters related to the replacement of
the two existing 115 kV lines with both a 230 kV and a 115 kV line. The evaluation would include
electrical interaction potential, cathodic protection, and proximity.
Response:
These comments were considered in the development of the Phase 2 Draft EIS (Sections 3.9 and 4.9),
which considers electrical interference risks related to corrosion, fault conditions, arcing, and
construction risks as part of the risk assessment. PSE did develop the analysis mentioned in its
comments. As described in Section 3.9.1.4, PSE retained DNV GL (the author of the report “Criteria
for Pipelines Co-Existing with Electric Power Lines”) to develop a detailed analysis of risks and
recommendations for the Energize Eastside project. This study (“A Detailed Approach to Assess AC
Interference Levels Between the Energize Eastside Transmission Line Project and the Existing
Olympic Pipelines, OLP16 & OPL20”), referred to in the EIS as the AC Interference Study, was used
in preparing the analysis for the Phase 2 Draft EIS. The study included recommendations related to
design of pole locations, layout, and configuration to mitigate potential electrical interference-related
impacts on the pipelines (see Section 3.9.7.2). As noted in the comments, several reference guidance
documents have presented general parameters for locating transmission lines and pipelines in shared
corridors. These limits used to determine when an engineering assessment, such as the one prepared by
DNV GL for the project, may be required, and do not themselves indicate that there will be a safety
issue. The DNV GL analysis provided PSE with a detailed assessment of the design available at the
time of their report, considering the many specific variables of this particular collocated
pipeline/transmission line segment. The results, conclusions, and recommendations of the report are
intended to be used as the basis for a more detailed engineering by PSE. The Phase 2 Draft EIS analysis
went a step further and developed additional recommendations for analysis of the potential for AC
interference once final pole locations are developed and again after the project is constructed and
operational (Stantec 2017).
Even with the conservatively high assumptions for risk factors associated with the project that were
used in the risk assessment completed for the Phase 2 Draft EIS, the results of the assessment indicated
there would be a small increase in total risk during operation. With the implementation of measures to
mitigate potential risks described in Sections 3.9.7, these risks would be even lower. Both the DNV GL
report and the analysis completed by Stantec for the Phase 2 Draft EIS concluded that the pipeline and
proposed transmission line could coexist safely with proper engineering and safety precautions by PSE
and Olympic. Per federal law, Olympic is responsible for the maintenance and safe operation of the
pipeline; therefore, beyond PSE employing reasonable measures in the design and construction of the
transmission line and providing information to Olympic, the responsibility for protecting the pipeline
from corrosion lies with Olympic.
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Key Theme PLS‐4: Evaluation of worst‐case scenario involving pipeline rupture and
fire
Comment Summary:
Several commenters requested that the EIS include a worst-case analysis involving a pipeline rupture
and ignition of fuel occurring in the most densely populated area of the proposed new transmission
lines. Among these comments was also the assertion that PSE cannot guarantee with certainty that there
would be no human error or equipment failure that could result in a severe rupture of the fuel lines and
potential ignition of flammable fuel. Because the impacts of a severe rupture and fuel ignition could be
catastrophic in the densely populated neighborhoods near the pipeline easement, commenters
maintained that impacts should be regarded as significant regardless of the likelihood of occurrence.
Response:
To address these concerns, Section 3.9 of the Phase 2 Draft EIS analyzed pipeline safety assuming a
“worst-case” scenario. The Phase 2 Draft EIS (Sections 3.9 and 4.9) also provided additional pipeline
safety analysis, which included a risk assessment that considers electrical interference risks related to
corrosion, fault conditions, arcing, and construction risks. The risk assessment took into account current
risks in the corridor in consideration of fuel type/flammability, pipe parameters, safety features, and
other factors. Using baseline data and modeling, the assessment estimated the probability of a potential
leak or fire resulting from the project.
In addition to characteristics of the pipeline and pipeline product, the presence of ignition sources and
the specific release setting (topography and nearby population density) are obvious factors affecting the
potential for major impacts to the public from a pipeline release. For a buried pipeline transporting
refined petroleum product, the greatest risk to the public is posed by pool fires, as described in the
Phase 2 Draft EIS. Depending on the local terrain, pipeline contents may flow for some distance away
from the location of the release. If an ignition source is present, the accumulated pool could catch fire.
EDM Services used data specific to the Olympic Pipeline system, including an estimated maximum
release volume based on pipe size, pressure, and other factors, to model a release and subsequent pool
fire size, as described in Section 3.9.4 and shown on Figure 3.9-7 of the Phase 2 Draft EIS. Section 4.9
of the Final EIS describes the variable conditions that could contribute to the severity and extent of a
pool fire resulting from a pipeline release, including a summary of conditions in each segment.
To estimate a “worst-case” or maximum release volume, the risk assessment used U.S. Hazardous
Liquid Pipeline Release data, filtered to include only refined petroleum product releases in order to be
as directly applicable to the Olympic Pipeline system as possible, and normalized the data to the pipe
diameter of the Olympic pipelines. The risk assessment used the average of the largest spill size range
(6,000 to 12,000 barrels) to arrive at an average "maximum" spill size of 8,861 barrels (or 372,162
gallons). Information on maximum release volume and probabilities of a potential leak and fire was
used in conjunction with a representative "maximum" population density along the corridor to estimate
risk to the public (in terms of potential fatalities) using different risk measures described in Section
3.9.5.1 of the Phase 2 Draft EIS. See also the Pipeline Safety Technical Report in Appendix I of the
Phase 2 Draft EIS for more information.
It is correct that some amount of risk is always inherent with transmission lines and pipeline systems
and that PSE cannot state with certainty that there would be no human error or equipment failure that
could result in a severe rupture of the fuel lines and potential ignition of flammable fuel. The Phase 2
Draft EIS addresses this by presenting an estimate of the probability of the worst-case scenario
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occurring, including before the project is built, while it is being constructed, and during operation. The
pipeline safety risk assessment considered national incident data on similar pipeline systems in order to
estimate the probability of pipeline failures, both under existing conditions (115 kV transmission lines)
and with new 230 kV transmission lines. In many cases, and in particular for pipeline damage caused
by construction activities, incidents in the national database occurred as a result of failure to follow
proper procedures. Even with the conservatively high risk assumptions used in the risk assessment, and
in consideration of rates of pipeline incidents from all causes of damage, the results indicated there
would be a very small increase in total risk with the project. With implementation of the mitigation
measures described in Section 3.9.7 of the Phase 2 Draft EIS, conditions related to potential for fault
damage on the pipeline due to coating stress and arc distances would likely improve over the existing
operational baseline risk (see Section 3.9.5.4). The Phase 2 Draft EIS does not dispute the fact that the
potential public safety impacts could be significant in the unlikely event a pipeline incident were to
occur as a result of electrical interference or construction damage.
Regarding the assertion that impacts should be considered significant regardless of the likelihood of
occurrence, the Phase 1 Draft EIS evaluated pipeline safety at a programmatic level and acknowledges
the potential for significant impacts related to proximity to the Olympic Pipeline system. As described
above, the focus of the risk assessment in the Phase 2 Draft EIS was estimating the change in risk that
would occur with PSE’s proposal (compared to existing conditions). In this context, project-related
risks were determined to be less-than-significant based on thresholds for significance described in
Sections 3.9.51 and 4.9.1.1 of the Phase 2 Draft EIS.
Key Theme PLS‐5: Risk of non‐compliance with safety regulations that apply to
Olympic and PSE
Comment Summary:
Several commenters stated that Olympic is currently under a Final Order by the Office of Pipeline
Safety to rectify deficiencies in its corrosion control program. The commenters pointed to an inspection
conducted in August 2014 that led to the Final Order, noting that the condition has gone uncorrected for
18 months, and the company has a further 18 months to complete corrective action (asserting that this
time period overlaps with PSE’s proposed construction). Several commenters stated that PSE has a
poor record of complying with regulations and safety standards and cannot be trusted to construct or
operate the transmission lines safely.
Response:
Further information on PSE’s responsibilities and requirements in relation to this project are included in
Section 3.9.7.1 of the Phase 2 Draft EIS. For PSE, national and state standards, codes, and regulations
and reference guidelines govern the design, installation, and operation of transmission lines and
associated equipment. In addition to these standards, codes, regulations, and guidelines, Section 3.9.7.2
lists additional measures that PSE has indicated it will use, and measures the EIS Consultant Team has
proposed as mitigation to provide additional safety assurances. The Partner Cities will use the Final EIS
to support any permit decisions required. The Partner Cities, in issuing permits, can decide that
additional conditions are required, such as reporting of compliance efforts by PSE.
Given that for portions of the corridor, construction of a 230 kV transmission line poses potential risks
of interaction with or disruption to the Olympic Pipeline system, particular attention to these risks is
necessary. Additional information on PSE's responsibilities within the shared corridor is included in the
Phase 2 Draft EIS. Extensive coordination with Olympic would be required during project design and
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construction to avoid disruption to the line. As described in Section 3.9.7.1 of the Phase 2 Draft EIS,
PSE and Olympic have coordinated regarding the project since 2012, and both have indicated they
would continue their coordination through final design, construction, and ongoing operation of both
utilities. Over the course of these ongoing discussions, the project plans have evolved to minimize the
potential for impacts. PSE plans to integrate, where applicable, the results and recommendation of
DNV GL's AC Interference Study (2016) to the design of pole locations, layout, and configuration in
order to mitigate potential electrical interference-related impacts on the pipelines. Because Olympic, as
pipeline operator, is responsible for the safety of their pipelines in compliance with federal safety
requirements, Olympic has a responsibility and interest in working closely with PSE on the project.
This includes reviewing and providing input on design, performing and evaluating field measurements
and modeling data in order to determine specific measures needed to minimize electrical interference
on the pipelines, and working with PSE on construction and access plans. Actions PSE can take, as
project proponent, to facilitate Olympic's design review, design input, and implementation of measures
that necessarily must be performed by the pipeline operator (e.g., cathodic protection) are the focus of
mitigation measures included in Sections 3.9.7 and 4.9.4 of the Phase 2 Draft EIS.
In response to comments on Olympic’s past violations, additional information available on the
Washington Utilities and Trade Commission (UTC) website was provided in the Phase 2 Draft EIS. In
the inspection reports summarized in Table 3.9-4, several violations and areas of concern were noted.
These inspections included a review by UTC of Olympic's records, operation and maintenance,
emergency response, and field inspection of pipeline facilities. Violations included late reporting and
defects at test sites. As described in Section 3.9.5.1 of the Phase 2 Draft EIS, to estimate the probability
of pipeline failures, historical data on pipeline incidents/spills that have occurred on similar systems are
most commonly used. However, this historical incident/spill data do not include information on these
similar systems' violations record. The EIS Consultant Team is, therefore, not able to state if Olympic
has less, the same, or more reported violations of safety rules compared to other pipeline companies in
any given reporting period for incidents/spills.
Key Theme PLS‐6: Engagement of Olympic in the EIS process
Comment Summary:
Several commenters requested that Olympic be extensively engaged and consulted as part of the EIS
process to ensure that accurate information is included and all relevant information is available for
decision-makers. Others requested specific information on Olympic’s pipelines in the corridor (e.g.,
valves). These comments also requested a full description of the “operating plan” for the pipelines to
understand how safety risks would be mitigated. Other commenters requested that the EIS include a
“truly independent assessment” of both PSE’s and Olympic’s findings, calculations, and
recommendations.
Response:
The Partner Cities and the EIS Consultant Team contacted Olympic during the development of the
Phase 1 Draft EIS, and made additional inquiries during the project-specific phase of the EIS. Certain
information (such as valve locations and operation) was not provided by Olympic for use in the Phase 2
Draft EIS. In the risk assessment field, it is not uncommon for certain pipeline information to be
unavailable from the pipeline operator due to proprietary or security reasons. As project applicant, PSE
does not have the ability to require Olympic to publicly release information.
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Electric and Magnetic Fields and Corona Ions (Topic EMF)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding the
potential environmental health effects of electric and magnetic fields (EMF) and corona ions produced
by PSE’s project. Primary themes included health effects from EMF, health effects from corona ions,
proximity of the project to potentially sensitive populations, and a potential increase in magnetic fields
within the existing PSE corridor.
Key Theme EMF‐1: Potential health effects from electric and magnetic fields
Comment Summary:
Commenters voiced concern that EMF could cause health effects, citing past research and published
studies, specifically concerning the potential for childhood leukemia, co-carcinogenesis,
neurodegenerative diseases, lymphatic and hematopoietic cancers, bone marrow cancer in children,
brain cancer in adults, impacts to mental health, damage to human DNA, miscarriages, interference
with electrocardiograms (EKGs),interference with cardiac pacemakers, sleep disturbance, low birth
weight, psychological effects, melatonin secretion disruption, and disruption to cortisol rhythms; as
well as individual health issues believed to be correlated to existing EMF exposure, such as Bell’s
Palsy.
Response:
Extensive health studies have not found a causal link between adverse health effects and EMF from
electrical transmission lines (see Section 8.6.1.4 of the Phase 1 Draft EIS). However, while it does not
appear that EMF from the project would pose an environmental health hazard, it was described in the
Phase 1 Draft EIS due to public concerns raised during EIS scoping. Citations of past research
identified by commenters were reviewed by Dr. Asher Sheppard, a consultant with the EIS Consultant
Team who has a scientific background in evaluating human health effects from electrical transmission
lines, to determine whether the findings presented by the cited studies would change the conclusion
provided in the Phase 1 Draft EIS. The additional study includes the Lewczuk et al. (2014) paper on
circadian rhythms. The potential health effects that were evaluated by the other studies cited by
commenters had already been part of Dr. Sheppard’s literature review per his November 25, 2015
memorandum to ESA, cited in the Phase 1 Draft EIS. Dr. Sheppard determined that the conclusion in
the Phase 1 Draft EIS is still accurate.]
The 2011 IARC and WHO citation provided by a commenter regarding low frequency magnetic field
generated by electrical devices as possibly being a carcinogenic to humans is not a study on EMF from
electrical transmission lines. It evaluates the possible association between the types of exposure from
radiofrequency electromagnetic fields from the use of wireless phones. Wireless phones are held very
close to a person, while transmission lines are designed to be great distances. Wireless phones also
generate EMF on different frequencies and power levels than transmission lines. In addition, the 2011
IARC and WHO citation addressing sleep disturbances and circadian rhythms provided by an
individual commenter is part of a larger publication that summarizes research on the hypothesis that the
disruption of melatonin secretion is a factor for carcinogenic effects of electric, magnetic, or
electromagnetic fields. The overall conclusion of this paper was that the hypothesis is not supported by
the epidemiological and experimental data.
The following health concerns linked to EMF are part of an ongoing area of research: childhood
leukemia, co-carcinogenesis, neurodegenerative diseases, and interference with implanted medical
devices (see further discussion in Section 8.3.5.1.4 of the Phase 1 Draft EIS). Other health concerns
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such as Parkinson’s disease, Alzheimer disease, motor neuron disease, and reproductive functions have
been specifically evaluated as part of past research studies and have informed the conclusion that there
are no causal links between adverse health effects and EMF from electrical transmission lines. An EIS
document can only evaluate known risks and provide an impartial evaluation of potential adverse
environmental impacts associated with a proposed project and project alternatives. Therefore, research
is ongoing in regard to EMF and health effects; existing research does not identify a direct relationship
between the EMF exposure that could be produced by PSE’s project and health effects.
Key Theme EMF‐2: Potential health effects from corona ions
Comment Summary:
Commenters, including representatives from Eastside Audubon, voiced concern that high voltage
transmission lines release corona discharge, and that such discharge is linked to an increase in air
pollution because the discharge attaches to pollutants that are known carcinogens, such as car exhaust,
which then increase the risk in lymphatic and hematopoietic cancers to recipients through inhalation.
Representatives of the Somerset Recreation Club (SRC) were concerned with corona ions adhering to
airborne pollutants near the SRC pool area and tennis courts, and then being inhaled by SRC members.
Commenters also cited specific studies that evaluated the potential for corona ions on human health.
Response:
Based on reviewed and available publications, there is no scientific consensus that corona ionization
poses a health risk; therefore, the Phase 1 Draft EIS concluded that there were no probable significant
impacts (see Section 8.6.1.4 of the Phase 1 Draft EIS). Available studies and research, including those
in Section 8.3.6 of the Phase 1 Draft EIS are considered inconclusive and do not suggest a probable
health impact associated with corona ionization, either during the construction or the operation of
PSE’s proposed project.
Citations of past and recent research identified by commenters that were specifically cited in the Phase
1 Draft EIS were reviewed by Dr. Asher Sheppard to determine whether the findings presented by the
cited studies would change the conclusion provided in the Phase 1 Draft EIS. These additional studies
cited by commenters include 12 reports, plus classification of EMF as a possible carcinogen by the
International Agency for Research on Cancer. Other studies cited by commenters had already been
reviewed by Dr. Sheppard per his November 25, 2015 memorandum to ESA, cited in the Phase 1 Draft
EIS. In most cases the studies were superseded by more recent studies. In some cases, the studies cited
do not support the commenters’ suggestions that the project would cause adverse health effects. Dr.
Sheppard determined that the conclusion in the Phase 1 Draft is still accurate (Sheppard 2017).
Key Theme EMF‐3: Populations particularly susceptible to electric and magnetic fields
Comment Summary:
Commenters voiced concern that children in homes and nearby schools, parks, and daycare facilities
(including Chestnut Hill Academy, Somerset Elementary School, Tyee Middle School, and Newport
High School) would be particularly susceptible to health effects from exposure to EMF. Others cited
concern along trails under the power lines. Additionally, commenters requested consideration of a
cumulative exposure: at school, home and work where children spend time.
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Response:
Exposure to magnetic fields in homes, schools, parks, and daycare facilities is acknowledged in the
Phase 2 Draft EIS (see Section 3.8.2), and such unique uses were identified within the study area of the
proposed project. As noted in the Phase 1 Draft EIS, there are no known health effects from EMF
expected as a result of the project. The calculated magnetic fields levels would be well below the lowest
reference guideline, even assuming 24-hour exposure, which is unlikely because the modeled electrical
loads would only occur during peak load periods, not all day. These exposure levels would apply to the
unique uses considered in the study area, which are also near the existing 115 kV corridor. See Section
3.8.5.1 of the Phase 2 Draft EIS for more detail.
Key Theme EMF‐4: Potential for increase in magnetic fields
Comment Summary:
Commenters voiced concern that the upgraded lines would generate higher levels of electric and
magnetic fields, and therefore the exposure by the public would increase. Commenters also questioned
whether there was a relationship between the distance from homes to electrical wires and whether that
distance would increase or decrease the strength of electric and magnetic fields. Commenters suggested
hiring experts to review the scientific evidence used to inform the Phase 1 Draft EIS discussion of
“electromagnetic” [sic] interference and the analysis of the proximity of lines to homes and people, and
the health effects and risks. Commenters also questioned whether underground transmission lines
would be a viable option in reducing potential EMF exposure. Commenters asked if an expansion of the
Lakeside Substation would increase EMF at Chestnut Hill Academy would have an impact on the
safety of children. One commenter asked whether harmonics were considered in the evaluation of EMF
from the project.
Response:
The Phase 2 Draft EIS analyzed the changes in magnetic fields that would occur as a result of PSE’s
proposal. PSE retained Power Engineers to measure and calculate existing magnetic fields at locations
along the transmission line corridor and calculate future magnetic field levels associated with the
proposed project. The EIS Consultant Team reviewed this analysis to confirm that the calculations were
correct (Enertech, 2016). The magnetic field levels associated with the proposed project are anticipated
to be lower than existing field levels along the existing transmission line corridor. See the discussion in
Section 3.8.5.1 of the Phase 2 Draft EIS for the reasons why the field levels are expected to be lower.
Statements that were cited in the Phase 1 Draft EIS regarding existing scientific research on adverse
health impacts from EMF exposure were statements made by Dr. Asher Sheppard’s research, per his
November 25, 2015 memorandum to ESA (Sheppard, 2015).
Magnetic field levels associated with underground transmission lines are generally higher directly over
the transmission line than under an overhead line. However, magnetic fields from underground
transmission lines drop in value in shorter distances than with aboveground transmission lines. See
pages 8-15 and 8-16 of the Phase 1 Draft EIS for a detailed description comparing magnetic fields
associated with aboveground and belowground transmission lines.
As stated in Section 3.8.3 of the Phase 2 Draft EIS, magnetic fields from electrical equipment at the
Richards Creek substation were not evaluated because they would be lower than the magnetic fields
associated with the overhead transmission lines entering or leaving the substation.
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Harmonic frequencies are more prevalent on lower-voltage distribution lines. Because this project
relates to 230 kV and 115 kV transmission lines, there should be little, if any, harmonics present.
Therefore, harmonics were not taken into account when calculating EMF for this analysis.
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Noise (Topic NOI)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding noise
impacts. Primary themes included noise associated with corona discharge, construction and operational
noise, and regulation of noise, as well as minor clarifications. Many commenters voiced concern over
alternatives that are no longer being considered because they would not meet PSE’s project objectives.
Key Theme NOI‐1: Noise from corona discharge
Comment Summary:
Commenters voiced concern that an increase in voltage would increase corona noise from the
transmission lines. They were concerned that corona noise would be constant and at a level that would
interfere with normal activities, particularly during wet weather conditions, and be considered a
nuisance, causing the stress levels to nearby residents to increase. A representative from the Somerset
Recreation Club (SRC) facility stated that SRC members often comment on the “noise issue.”
Commenters were concerned that corona noise would add to the existing noise in an urban
environment, specifically on top of the noise experienced from nearby interstates (I-405 and I-90).
Response:
Corona noise was analyzed as a part of the Phase 1 Draft EIS, Section 9.3. The potential impacts of
corona noise for the proposed 230 kV transmission lines were found to be relatively low for nearby
residential environments. Based on an analysis in the Pacific Northwest conducted by the Oregon
Department of Energy, the maximum corona noise of a 230 kV line outside at ground level is
approximately 29 dBA, which is approximately 10 dBA below the federal housing interior noise goal.
While corona noise from the project may be audible in very quiet areas, it is expected to be virtually the
same as existing corona noise levels. As stated on the Phase 1 Draft EIS, corona noise is generally a
concern for transmission lines operating at 345 kV or above. Corona noise from the transmission lines
is expected to remain well below the limits required by local noise regulations, and below levels that
would warrant mitigation.
Key Theme NOI‐2: Construction and operational noise
Comment Summary:
Commenters expressed concerns that noise from construction equipment had not been analyzed or the
significance of such noise had been understated. Commenters were also concerned about unchecked
noise during operation. Commenters questioned how noise would be regulated once the project is built
and whether or not there would be recourse for potential noise impacts after construction. A PSE
representative commented that ambient noise at the Westminster substation site from SR 520 would
likely exceed transformer noise, and that construction of peak generation plants would likely have off-
site construction impacts to extend utilities such as gas, water, and transmission lines to the plants.
Response:
The Phase 1 Draft EIS was analyzed at a programmatic level; impacts regarding construction
equipment were identified, but because of the short duration of construction, and the restrictions
imposed by noise regulations, construction impacts were not expected to be significant. Construction
noise is regulated at the local level, based on noise regulations of the respective local code requirements
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(see Table 9-3 of the Phase 1 Draft EIS). As such, the respective local jurisdictions would enforce
construction noise regulations based on their individual noise code requirements. Operational noise
would also be regulated at the local level, both through permit review and also through enforcement of
local codes after the project is operational. Comments from a PSE representative correctly pointed out
that substations are not exempt from local noise regulations, but are also not subject to the 10 dBA
reduction (WAC 197-60-040(2)(b).
It is likely that ambient noise at the Westminster substation site from SR 520 would exceed transformer
noise, although no site-specific studies were done for the Phase 1 Draft EIS. Noise was not further
analyzed in the Phase 2 Draft EIS because significant and unavoidable noise impacts were not
identified in the Phase 1 Draft EIS.
Key Theme NOI‐3: Applicable noise regulations and significance thresholds
Comment Summary:
Representatives from the Somerset Recreation Club (SRC) noted that “Noise” is an environmental
health issue and belongs under that category for the SEPA EIS.
A PSE representative was concerned with the regulatory noise thresholds, noting that a significance
threshold of a 5 dBA allowance is arbitrary and not based on regulation.
Response:
While noise is listed in SEPA as one of several possible environmental health issues, per WAC 197-11-
430, the format of a SEPA EIS is determined by the Lead Agency and can be modified if the
presentation of the environmental analysis can be made clearer by doing so. The Partner Cities
determined that a separate heading for Noise was appropriate in this instance.
Per WAC 197-11-794 significance involves context and intensity, magnitude and duration, and is
determined by the Lead Agency. For the Phase 1 Draft EIS, the City of Bellevue (along with the other
Partner Cities) determined that a project would have a significant impact if it would generate
operational noise that would conflict with local ordinances or would increase ambient noise levels by
5dBA or greater at a sensitive land use, because much of the study area has relatively low ambient
noise levels where a 5 dBA increase would represent a significant change in ambient noise.
The allowance of up to a 5 dBA ambient noise level increase is based on a perceivable difference:
where a change in the existing environment of at least 5 dBA would cause a human response (see
Section 9.1 of the Phase 1 Draft EIS for further discussion). This is based on established criteria (see
Caltrans 2013 study in the Chapter 17, References). Noise regulations are also based on the Washington
Administrative Code (WAC), which informs the noise regulations at the local level (see Section 9.2 of
the Phase 1 Draft EIS).
It is recognized that specific locations may have exceptionally low or high noise levels where such a
threshold may not apply. (see Section 9.3 of the Phase 1 Draft EIS).
Key Theme NOI‐4: Minor clarifications and Errata
Comment Summary:
PSE provided comments on the noise impact analysis in Phase 1 Draft EIS that clarified but did not
influence the result or conclusions of the noise analysis. They include a comment from a PSE
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representative stating that the Peak Generation Plant component (Section 9.6.4.1 of the Phase 1 Draft
EIS) meets the “significant” impact threshold, not the moderate threshold identified.
Response:
Clarifications and errors identified by commenters were reviewed and are included as appropriate in
Chapter 3, Errata, of the Final EIS. These include concurrence on the probable significance of noise
from peak generation plants, and on the applicability of noise regulations to substations. PSE and other
commenters also provided other minor clarifications that have not been included in the Errata, primarily
because they relate to Phase 1 alternatives that are no longer being considered, they are minor
clarifications (as opposed to factual errors), and they do not influence the results or conclusions of the
analysis. The full letters are included in Appendix J, following this narrative summary.
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Land Use and Housing (Topic LU)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding land
use and housing. Primary themes included concerns over property condemnation, PSE easement
widths, whether the project is an Essential Public Facility, site-specific impacts to neighborhoods, and
construction versus operation of the transmission lines.
Key Theme LU‐1: Property condemnation
Comment Summary:
Commenters voiced concern that the project would require the condemnation and demolition of
numerous houses, and stated that the removal of any houses should be considered a significant impact
and should preclude construction of the project. Commenters also expressed a desire to know how PSE
would determine the compensation for land owners if houses or land were acquired through eminent
domain. Commenters also urged that the project make use of existing corridors to the greatest extent
possible. The commenters expressed concern for how the neighborhood character would be impacted
by the removal of houses.
Commenters voiced concern that the Energize Eastside project would not be properly mitigated for,
specifically in terms of displacements. They asked how the City of Bellevue, as the Lead Agency for
the project, planned to assist in the relocation of any displaced residents or businesses from the Partner
Cities and how the residents would be compensated.
PSE provided clarification that they would not need to purchase land around the Lakeside substation (to
be known as the Richards Creek substation) as they already own the property south of the site, and this
property would be adequate for the expansion anticipated at this site. Additionally, PSE stated that if
the existing Sammamish-Lakeside-Talbot Hill 115 kV corridor is used, the replacement 230 kV and
115 kV lines could be constructed and operated within the existing easement and would not require
additional property acquisitions.
Response:
During the Phase 1 programmatic evaluation, project alignments were not definitively identified. As a
result, the EIS Consultant Team did not know if property acquisition would be required. The analysis
therefore identified this as a possible result of the project.
For the Phase 2 Draft EIS, locations of the various project segments and options have been identified,
and no houses or businesses would be condemned or demolished under any of the options, including
those where poles may be located outside the existing corridor (Bypass Options and Bellevue South
Options). Where the project would be located within the existing corridor, no new easements or
property acquisition would be needed (despite co-location with the Olympic Pipeline). In segments or
options where the project would diverge from the existing corridor, new easements would be required,
but this would only result in some accessory structures (e.g., garages and sheds) being moved or
demolished. Because there would be no property acquisitions for the project, neighborhood character
will not be impacted by the condemnation of land within existing neighborhoods. PSE’s Proposed
Alignment in the Final EIS would be located entirely within the existing corridor and can be developed
without need for displacement of houses or businesses. Please see the project description in Chapter 2
of the Final EIS.
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Mitigation measures are provided in the Phase 1 Draft EIS to address potential displacements. These
mitigation measures are broadly summarized because the Phase 1 Draft EIS is a programmatic-level
analysis and was prepared when the potential for property acquisition was considered a possibility. In
regards to compensation for any property acquired for the project (although no acquisitions are
proposed in the Phase 2 Draft EIS), any acquisitions by PSE would be governed by rules of eminent
domain, including notice and fair compensation requirements.
The clarifications from PSE were incorporated into the Phase 2 Draft EIS. Specifically, once the project
alternatives were established, land use and housing impacts were analyzed with the assumption that the
project would not require any condemnation of existing housing or land.
Key Theme LU‐2: Easement width required for safety
Comment Summary:
Commenters voiced concern that the right-of-way easement would need to be expanded because of the
need to provide safe distance from the Olympic Pipeline in areas where the transmission lines would be
co-located with the pipeline, and thus would require condemnation of property along the transmission
line corridor. The commenters also expressed worry over the adequacy of the proposed corridor width
for safety purposes, because the Olympic Pipeline system transports hazardous liquids, and commenters
thought that the transmission lines should be separated from the pipelines.
PSE provided clarification that if the existing Sammamish-Lakeside-Talbot Hill 115 kV corridor is
used (as with PSE’s Proposed Alignment presented in this Final EIS), the replacement 230 kV and 115
kV lines could be constructed and operated within the existing easement area and would not require
additional property acquisitions or easements. For concerns about co-location with the Olympic
Pipeline, PSE noted that there are already two 115 kV transmission lines within the corridor.
Response:
During the Phase 1 programmatic evaluation, project alignments were not definitively identified, nor
were the pole configurations. As a result, the EIS Consultant Team did not know if property acquisition
would be required. The analysis therefore identified this as a possible result of the project, and made
reasonable worst-case estimates of required width based on 115 kV and 230 kV corridors in other parts
of the country and without regard to setbacks from co-located pipelines. It is correct that if standard
corridor widths were added to the 50-foot separation that BPA generally advised for locating
transmission lines from any co-located pipeline, the corridor width would be greater than described in
the Phase 1 Draft EIS, and numerous homes would need to be removed. The separation required from
the pipelines and from adjacent structures is dependent on a number of factors, including soils, pole
heights and spacing, pole and circuit design, and other factors. The programmatic analysis provided by
the Phase 1 Draft EIS provides a reasonable assessment of the potential impacts given the lack of
design details.
As summarized in the response to comments in Key Theme LU-1: Property Condemnation, no houses
or businesses would be condemned or demolished under any of the segments or options analyzed in the
Phase 2 Draft EIS. The easement corridor would not need to be widened to accommodate the 230 kV
transmission lines.
For commenters concerned about the safety of co-locating the transmission lines within a corridor that
has hazardous liquid pipeline, see Section 3.9 of the Phase 2 Draft EIS for a discussion on pipeline
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safety which concluded that the likelihood of a pipeline rupture and fire would remain low if the project
is built, and there would be no substantial change in risk from existing conditions.
With regards to structures in the vicinity of high-capacity transmission lines, PSE would be required to
comply with NESC guidelines, which are summarized in Section 3.1.1.1 of the Phase 2 Draft EIS.
Key Theme LU‐3: Essential public facility
Comment Summary:
Commenters voiced concern that the project would be permitted as an Essential Public Facility (EPF) in
the jurisdictions through which it would be constructed. They felt that the Energize Eastside project did
not meet the definition of an EPF under the Growth Management Act, and should follow the standard
permitting procedures and requirements.
Response:
The proposed project will follow the conditional use, shoreline conditional use, shoreline substantial
development, and critical areas permit processes, depending on which alternative is selected, as
required by in the Cities of Bellevue, Newcastle, and Renton, and King County. The City of Redmond
previously indicated that an EPF permit would be required, but has subsequently determined that it is
not, and that a conditional use permit would be required instead. Other municipalities have permit
processes that define the project as an electric utility, and these permit processes would apply
regardless of whether or not the project is defined as an EPF. Municipalities determine the permit types
required for the project application submittal consistent with their procedural standards and applicable
land use processes. Applicable zoning regulations, policies, and shoreline regulations are contained in
Appendix B of the Phase 2 Draft EIS.
Key Theme LU‐4: Greater impacts in denser residential or natural areas
Comment Summary:
Commenters voiced concern that the project would have more pronounced land use impacts in specific
neighborhoods, like Somerset and Olympus, due to higher residential densities in these neighborhoods,
as well as in designated natural areas such as the Coal Creek Natural Area. Impacts cited include
displacement of residences, visual “blight” that could affect the quality and livability of these
communities, and “overburdening” natural areas with utility infrastructure. A commenter from CENSE
and a Somerset Recreation Club representative expressed concern that the project would adversely
impact a proposed renovation to the club facility, although no specifics about the impacts were
provided.
Response:
The Phase 1 Draft EIS addressed impacts to communities within the project area at a programmatic
level. It is acknowledged that where densities are higher, more people are likely to be impacted should
impacts occur. The potential impacts of condemnation and displacement are discussed in the Phase 1
Draft EIS and in the responses to comments above. Visual impacts described programmatically in the
Phase 1 Draft EIS included the effect on neighborhood character if a new or widened corridor was
needed and required the removal of homes. The Phase 1 Draft EIS did not address specific
neighborhood issues because it was not known which neighborhoods would be affected. Greater detail
was added for the Phase 2 Draft EIS, both to the design of the alternatives and to the analysis of
impacts.
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For the Phase 2 Draft EIS analysis, specific alignments were chosen for the alternatives, allowing an
examination of impacts to the specific neighborhoods that would be crossed by the 230 kV transmission
lines. As described in the responses above and in the Phase 2 Draft EIS, none of the alternatives
considered in Phase 2 would require the condemnation or removal of homes in any neighborhood,
including Somerset and Olympus. For all alternatives, the transmission lines would be placed
predominantly within a right-of-way that already includes 115 kV lines, and a hazardous liquids
pipeline in some portions of the corridor. Land uses within the corridor would be the same after the
project is built as they are today. For PSE’s proposed alignment in the Final EIS, the entire project
would be within the existing corridor.
Regarding conflicts with the potential impacts on the planned renovation of the Somerset Recreation
Club facilities, since no specific conflicts were mentioned, a response is not provided here. However,
the project-specific Phase 2 Draft EIS provides additional detail about PSE’s proposal and may have
addressed the concerns about the perceived conflicts.
Visual impacts would vary among the communities that the project would traverse. These are described
in the Phase 2 Draft EIS, Section 3.2. Design and siting factors that would decrease the visual impact to
specific communities (e.g., Somerset and Olympus) would be a part of the mitigation considered
through the permit process, including the decision whether to underground the transmission lines in
areas where the applicable plans discourage aerial facilities.
Key Theme LU‐5: Errata and minor clarifications
Comment Summary:
Commenters voiced concern that Alterative 1 Option A was determined to have negligible impacts on
Land Use and Housing. One commenter expressed confusion as to why the communities of Beaux Arts,
Hunts Point, and Yarrow Point were included in the analysis in Table 10-2 of the Phase 1 Draft EIS. A
few commenters were either concerned over the cumulative effects of the Energize Eastside project
combined with the nearby SCL transmissions lines, or expressed their desire to have the two projects
co-located in the same corridor.
PSE clarified that it avoids placing transmission lines over homes; however, it asserted that occupied
structures have been constructed under the existing transmission lines. PSE also stated that the
Newcastle Use Restriction information in Table 10-2 was incorrect. Utility facilities would be allowed
in mixed use, urban residential, and neighborhood business zoning districts.
In addition, commenters noted that Figure 10-5 mislabeled the Issaquah Highlands, the area
surrounding the Lake Tradition substation, and the parklands on Cougar Mountain and Squak Mountain
as vacant land.
PSE also stated that King County, Redmond, and Kirkland codes prohibit new high consequence land
uses within proximity to the existing corridor, but that transmission lines are an existing use within the
corridor and are not a new land use.
Response:
The "negligible" statement in the Phase 1 Draft EIS relates to short-term/construction. For long-term
(operation) impacts on land use, the Phase 1 Draft EIS states that impacts "could range from minor to
significant depending on specific location" (page 10-24). The Phase 1 Draft EIS found that construction
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impacts from the action alternatives to all communities in the study area were negligible because
appropriate access to properties from the public rights-of-way would be maintained.
Table 10-2 was included in the Phase 1 Draft EIS to show the zoning districts and shoreline
environment designations that would potentially prohibit all or portions of Alternative 1. Since the
communities of Beaux Arts Village, Hunts Point, and Yarrow Point are all within the study area for
Alternative 1, their policies prohibiting all or portions of the alternative were included in the table. The
Phase 2 Draft EIS identified alignments for the alternatives, which did not traverse these
neighborhoods. Therefore, the Phase 2 Draft EIS did not include these policies in the Land Use
analysis. Co-location with the existing SCL 230 kV transmission line corridor was analyzed in the
Phase 1 Draft EIS as Alternative 1, Option B in the resource sections. See Section 2.3.2.3 for a
description of this alternative in the Phase 1 Draft EIS document.
Chapter 3 of the Final EIS, Errata, includes a statement that up to three non-residential structures
appear to be constructed under the existing 115 kV transmission lines, and notes the errors in Figure
10-5 and Table 10-2. It also removes the following sentence “This option would have some of the same
zoning consistency issues as Option A (Table 10-2) including potential for co-location with a high
consequence land use, since it also crosses the OPL Company (OPLC) pipeline in places and is parallel
to it in other locations.”
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Views and Visual Resources (Topic VR)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding
views and visual resources. Primary themes included the extent of the study area, methodology used,
tree removal, inconsistency of the project with existing neighborhood character, and project specifics
that should be included in the Errata. Comments were also received on how the project might impact
private views, and as a result property values. These comments are addressed under Economics.
Key Theme VR‐1: Study area and key viewpoints
Comment Summary:
Commenters voiced concern that the 130-foot power poles would be seen for miles and would impact
viewers in locations not discussed in the Phase 1 Draft EIS. These include viewers in neighborhoods
and downtowns, drivers on I-405 and I-90, boaters on Lake Washington, visitors of the Newcastle Golf
Course, residents of East Mercer Island, and travelers on planes landing at SeaTac. It was also
suggested that the visual impacts would be greater than 100 lots per mile.
Representatives of CENSE and the Somerset Recreation Club asked why the Somerset community and
the Somerset Recreation Club were not included as key viewpoints. Commenters also disputed the area
identified as having scenic views on Figure 11-3 (showing King County Assessor’s data regarding
properties with views). One commenter stated that Newcastle has views of Mt. Rainier, and another
noted that there are many private views located in the Somerset area.
PSE requested to know which roadways were integrated into the visual study, and stated that
establishment or expansion of trails provided by new transmission lines would potentially result in new
viewpoints that should be evaluated as beneficial impacts associated with Alternatives 1 and 3.
Response:
A refined study area was not provided for the Phase 1 Draft EIS because project-specific information,
such as pole height and location, was unknown. Impacts to individual communities were not identified
at the programmatic level because, in general, the exact locations of the various alternatives were
unknown. A greater level of detail is provided in the Phase 2 Draft EIS (see Section 3.2).
For the Phase 2 Draft EIS, a GIS analysis was conducted to determine where the project would be
visible based on the height and location of the proposal, the surrounding topography, and the presence
of vegetation and buildings (see the Phase 2 Draft EIS, Appendix C). The Phase 2 study extends
roughly 0.25 mile from the edge of the proposed corridor, but excludes all areas west of Interstate 405,
which provides substantial visual separation from all alternatives. The project would be visible at
greater distances; however, significant visual impacts are not expected given the project’s scale relative
to its largely mixed urban context.
Visual impacts to boaters on Lake Washington, visitors of the Newcastle Golf Courses, residents of
East Mercer Island, and viewers from planes landing at SeaTac airport are not anticipated. Although I-
90 is within the refined study area, significant impacts are not anticipated because viewer focus on and
view duration of the project would be minimal (see Section 3.2.3.3 of the Phase 2 Draft EIS).
Section 11.6.3.5.3 of the Phase 1 Draft EIS states that an overhead transmission line would cross or
abut approximately 100 lots per mile in a typical single-family subdivision with 4 lots per acre. This
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would vary depending on the number of schools, parks, and commercial uses present along the
corridor, which tend to have larger lots, and on the residential density which could be higher in some
portions of the Eastside. This estimate was to provide a rough idea of the number of residential viewers
who would be the most impacted by the project, not to provide a refined study area.
Roadways are considered to be viewpoints programmatically in the Phase 1 Draft EIS (see Sections
11.3.3 and 11.6.3). Specific roadway corridors, such as the Mountains to Sound Greenway National
Scenic Byway and scenic roadways protected in city and subarea plans and policies, were evaluated in
the Phase 2 Draft EIS (see Section 3.2). Future use of the transmission line for any purpose beyond that
of a utility corridor was not considered. While some communities may support the use of a transmission
corridor as a trail, it would be speculative to assume that a new transmission line corridor would be
used as a trail. In addition, the focus of this assessment was to determine where existing scenic views
would be obscured.
The Phase 1 Draft EIS lists public viewpoints provided at parks, trails, and public open spaces (see
Section 11.3.3). However, because the Somerset Recreation Club is privately owned, it was not
included. For the Phase 2 Draft EIS, all recreation areas within the study area (parks, trails, outdoor
recreation facilities) were assessed regardless of their ownership, and impacts to the Somerset
Recreation Club were evaluated (see Section 3.2.5.8). Private views for the Somerset neighborhood
were identified in Figure 11-12 of the Phase 1 Draft EIS.
Figure 11-13 of the Phase 1 Draft EIS is a property view score map showing areas that the King County
Assessor identified as having better quality views. This map was not intended to be used to identify
impacts. The King County Assessor data do not provide a comprehensive analysis, but give a general
idea of what views can be had and from where. Often, assessors only conduct their assessment from the
street. Therefore, they do not see views from second-story windows, etc. For the Phase 2 Draft EIS, a
more refined analysis GIS analysis was used (see Section 3.2). The Phase 2 Draft EIS includes a map
that identifies scenic views impacts (see Appendix C, Figure C-6).
Key Theme VR‐2: Methodology
Comment Summary:
PSE asked why the Phase 1 Draft EIS analysis did not include an evaluation of vividness, intactness,
and unity. PSE also asked for clarification regarding how viewer sensitivity was assessed and whether
or not distance zones were factored into the analysis. In addition, PSE requested that more photos be
taken to show potential visual impacts. A member of the public asked why the Somerset view
covenants were not integrated into the Phase 1 analysis.
PSE asked for more information regarding how the significance criteria were applied. For example,
PSE requested clarification that significant impacts from Alternative 1 would be minimized if the route
were built in existing transmission line or road corridors, while members of the public stated that
significant impacts from Alternative 1 would be unavoidable regardless of design or mitigation
proposed. One commenter asked what would happen if PSE decided to construct a larger capacity line,
such as a 750 kV line, which was beyond the scope of the analysis for this assessment. Another
commenter suggested that the EIS summary (Chapter 1) should state that for unobstructed views that
would become obstructed with power poles and/or power lines, the contrast would be high and
obstruction permanent.
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Response:
Assessment of “vividness”, “intactness”, and “unity” was part of the FHWA guidance from 1981. The
Phase 1 and Phase 2 Draft EIS visual impact assessment methodologies were based in part on the 2015
FHWA guidance, adapted for use in the Energize Eastside analysis. Section 11.4 of the Phase 1 Draft
EIS describes how the FHWA methodology was applied for the programmatic assessment, and Section
3.2 and Appendix C of the Phase 2 Draft EIS describe how it was applied to the project-level
assessment.
Viewer sensitivity was assigned based on a viewer's proximity to the project and their level of
awareness. For the Phase 1 assessment, sensitive viewers were typically considered to be residential
viewers, and users of the public viewpoints identified in Section 11.3.3. A more refined methodology
for analyzing viewer sensitivity was used for the Phase 2 Draft EIS that took into account subarea
planning policies, residential density, and other considerations in addition to those evaluated in the
Phase 1 Draft EIS (see Section 3.2.3 of the Phase 2 Draft EIS).
Visual simulations are provided in the Phase 2 Draft EIS (see Appendix C, Attachment 2). They show
various types of natural and built environments, as well as different proposed pole heights and
configurations. In addition, the EIS Consultant Team made several site visits and took numerous photos
for reference.
Private covenants were not reviewed for the Phase 1 Draft EIS because the Partner Cities do not have
SEPA policies that provide authority to recognize private covenants. For the Phase 2 Draft EIS, private
covenants in Somerset were reviewed because they have affected the physical character of that
community, which broader City policies seek to preserve, and contribute to the prominence of the taller
poles in that location. Section 4.2 of the Final EIS describes how the Somerset covenants were applied
in further detail.
In the Phase 1 Draft EIS, potential impacts were described as minor, moderate, or significant based on
each one of the criteria being met (see Table 11-3 of the Phase 1 Draft EIS). For instance, if there is a
low number of viewers, only a minor impact was assigned because, in order for an impact to be
considered moderate or significant, there must be at least a medium number of viewers. Distance zones
are factored into the Phase 1 analysis as a component of viewer sensitivity. For the Phase 2 Draft EIS,
distance was factored into the analysis via the refined study area.
Section 11.6 of the Phase 1 Draft EIS describes how impacts would vary depending on where the
transmission line is placed. However, for the purposes of the Phase 1 Draft EIS, significance was
assigned based on the worst-case scenario. At the programmatic-level, it was determined that a new
transmission line corridor may result in significant unavoidable adverse impacts if a new corridor were
created (see Section 11.9). However, it was more difficult to ascertain if there would be significant
unavoidable adverse impacts where a transmission line and clear zone are already present due to the
lack of project-level information (such as exact pole heights). Potential significant adverse visual
impacts within an existing corridor were further evaluated in the project-level analysis (see Section 3.2
of the Phase 2 Draft EIS, and section 4.2 of the Final EIS). The Phase 2 Draft EIS and the Final EIS
describe areas where unobstructed views would be permanently affected by the taller poles, and
identify areas where the increase in contrast would be significant. Not all areas with currently
unobstructed views where a proposed pole would be visible would be significantly impacted.
At this time, there is no indication that a 750 kV line would be required on the Eastside. If such a line
were needed in the future, additional environmental assessment would be required.
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Key Theme VR‐3: Project clear zones would reduce visual quality
Comment Summary:
Commenters expressed concerns that a 120- to 150-foot clear zone required for Alternative 1, Option
A, would result in approximately 327 acres of vegetation removal, including approximately 8,000 trees.
Vegetation removal could reduce the visual quality of the surrounding area. It was stated that such clear
zone would be visible from large distances, replanting with low bushes would not effectively hide the
new transmission poles, and removal of landscaping and structures would be a negative aesthetic
impact. PSE stated that the National Electrical Safety Code (NESC) does not provide specific
vegetation clearances, but rather that NERC/FERC specify vegetation clearance requirements for high
voltage lines. PSE also commented that Alternative 1, Option B could have equal or greater clear zones
than Option A, based on its estimation that the new 230 kV line could be built and operated within the
existing Sammamish-Lakeside-Talbot Hill 115 kV 100-foot wide corridor; and therefore, the impacts
associated with the 50-foot widening would not be realized. Public commenters stated that they would
not want the clear zone to be reduced if it would mean lack of compliance with safety standards.
Response:
The Phase 1 Draft EIS examined the worst-case scenario for new overhead transmission lines, which
assumed that the new corridor for a 230 kV line would be 120 to 150 feet wide (approximately 30 to 40
feet wider than a 115 kV line and the existing right-of-way corridor). During the development of the
Phase 1 Draft EIS, the widths of clear zones were unknown because the height and form of the
transmission poles had not been determined. The estimated width was based on a literature review and
what information was available at the time of the assessment, including the Utility Vegetation
Management and Bulk Electric Reliability Report from the Federal Energy Regulatory Commission
(September 7, 2004). The NESC deals with electric safety rules, including transmission wire clearance
standards, while the applicable American National Standards Institute code deals with the practice of
pruning and removal of vegetation. However, these rules and guidelines are not specific with regard to
clearances between transmission lines and vegetation and are subject to interpretation. The 40 percent
tree canopy coverage used to programmatically identify vegetation impacts was based on the average
tree coverage experienced in the project area jurisdictions.
Project-specific clear zones are described and assessed in the Phase 2 Draft EIS, which includes use of
PSE’s existing 100-foot-wide Sammamish-Lakeside-Talbot Hill 115 kV corridor. Vegetation
Management and Clear Zones are described in more detail in Section 3.4.1.3 of the Phase 2 Draft EIS
and Section 4.4.1.1 of the Final EIS. Regulations for 230 kV lines call for the removal of trees with a
potential height of greater than 15 feet within the managed right-of-way, while 115 kV lines allow 25-
foot trees within the managed right-of-way zone. As described in the Phase 2 Draft EIS, PSE has
flexibility within these standards. (Note: the managed right-of-way is sometimes referred to as the clear
zone.) Whenever the management of a specific site varies from these standards, PSE would prepare a
vegetation management plan addressing the specific situation in consultation with the property owner.
Such plans ensure PSE’s compliance with safety standards.
Key Theme VR‐4: Project would be inconsistent with comprehensive plan policies
Comment Summary:
Commenters cited the City Bellevue Comprehensive Plan, which describes Bellevue as a “City in a
Park.” These commenters voiced concern that 100-foot poles in residential areas, as well as the removal
of acres of vegetation, would be inconsistent with this description and would result in adverse impacts
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to the aesthetic environment within the City of Bellevue. Commenters described the project as “a clear
zone with a 130-foot electric fence along 18 miles of the Eastside.” It was stated that such a project
would have a significant visual impact from the territorial view standpoint. One commenter noted that
the City of Bellevue already has the lowest percentage of tree canopy on the Eastside, and this project
could further the trend of tree canopy reduction due to the requirement for the clear zone to remain bare
of trees. Commenters noted that Bellevue’s “City in a Park” atmosphere provides attractive and
desirable living conditions that improve their quality of life and investments made in private property
and public spaces. It was stated that the project would introduce industrial blight. One commenter also
said that the project would be inconsistent with the Newcastle Comprehensive Plan.
Response:
The Phase 1 Draft EIS examined worst-case scenarios for a variety of options, at a programmatic level.
It also discusses applicable comprehensive plan policies. The analysis notes that overhead transmission
lines often contrast visually with their surroundings, especially in residential areas. While the project is
not considered “industrial” from a city policy perspective, it is acknowledged that the scale and
character of transmission line poles is very different from that of residential structures.
The potential extent of tree clearing is also discussed. Updated vegetation removal information is
provided in the Phase 2 Draft EIS (see Section 3.4) and the Final EIS (see Section 4.4), and the
resulting impacts to the aesthetic environment are also evaluated in greater detail (see Section 3.2 and
Section 4.2 of the Draft and Final EIS documents, respectively). There is no overarching policy that
states that vegetation removal is inconsistent with Eastside aesthetic values. In fact, a transmission line
clear zone is already present on the Eastside. However, there are policies that discourage tree removal
in certain areas (e.g., along Richards Road). These are listed in Table 3.2-4 in the Phase 2 Draft EIS.
As part of the Phase 2 Draft EIS analysis, the project-level alternatives were assessed based on their
consistency with study area codes and comprehensive plan and subarea plan policies, including those
that discourage vegetation removal. This includes additional review, beyond the analysis in the Phase 1
Draft EIS, of comprehensive plan policies for City of Bellevue and City of Newcastle, which are the
two comprehensive plans mentioned in the comments. In Bellevue, this was because specific subareas
were affected, while in Newcastle, new policies were adopted after the Phase 1 Draft EIS was
published.
Key Theme VR‐5: Condemning of homes and installation of a new transmission line
would change the visual character of Eastside neighborhoods
Comment Summary:
Commenters expressed concern that the removal of homes for the installation of a new transmission
line would change the visual character of Eastside neighborhoods. Commenters noted that the reason
they choose to live on the Eastside is for the neighborhood character, and stated that the proposed poles
would not be consistent with the existing neighborhood character, would blight the landscape, and
belong instead in an industrial setting. Some commenters noted that it would be more challenging to
hide the taller poles with landscaping.
Response:
During the Phase 1 programmatic evaluation, project alignments were not definitively identified. As a
result, the EIS Consultant Team did not know if the removal of homes would be required. The analysis
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therefore identified this as a possible result of the project. The Phase 1 Draft EIS discusses these
potential impacts, including the effect they could have on visual character of a neighborhood.
For the Phase 2 alternatives and for the PSE’s Proposed Alignment in the Final EIS, no houses or
businesses would be condemned or demolished. For segments where the project would be located
within the existing corridor, no new easements or property acquisition would be needed. In segments or
options where the project would diverge from the existing corridor, new easements would be required,
but this would only result in some accessory structures (e.g., garages and sheds) being moved or
demolished. For those residents whose accessory structures would need to be removed, the aesthetics of
their yards may be negatively impacted. However, because most of the locations where the project
would diverge from the existing corridor would occur along roadways, the likelihood of residential
yards being negatively impacted is low. Impacts to visual quality of the aesthetic environment
(including inconsistency with neighborhood character) are evaluated in the Phase 2 Draft EIS (see
Section 3.2). There are no policies that explicitly state that a transmission line would be inconsistent
with neighborhood character; in fact, a transmission line is already present in some Partner City
neighborhoods.
Key Theme VR‐6: Light and glare
Comment Summary:
One commenter inquired if the130-foot poles would require flashing beacons to alert low flying private
aircraft of tall aerial obstructions, especially in areas that cross I-90 or over Somerset. This commenter
also noted that tree removal could result in decreased light and glare reduction.
PSE stated that typically galvanized steel poles are more reflective than other finishes on steel poles,
especially when new. However, this typically diminishes with time. PSE requested that the EIS mention
different types of finishes that are not reflective in nature.
Response:
Aviation warning lights would not be required for this project because the proposed electrical
infrastructure, including transmission poles under any of the alternatives evaluated, would be less than
200 feet in height and would not exceed the obstruction standards contained in 14 CFR Part 77. The
EIS Consultant Team evaluated light and glare impacts associated with construction and operation of
the project, which considered potential impacts associated with construction site lighting, substation
security lighting, and reflectivity of steel pole conductors. Section 11.6.3.5.4 of the Phase 1 Draft EIS
states that if steel poles are used, a non-reflective coating would be applied.
It is correct that clearing could result in less screening of existing light sources, such as street lights or
lights from buildings. Glare from street lights can be reduced by requesting shielding be installed by the
public utility providing the lighting, and similar shielding can be provided in some cases for exterior
lights on buildings.
No significant impacts were identified regarding light and glare.
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Key Theme VR‐7: Mitigation
Comment Summary:
A commenter asked how changing the pole color would hide a 130-foot pole. Other commenters stated
that the only way to mitigate visual impacts for the project would be to place the transmission lines
underground or under water. Others requested that a full range of mitigation measures be provided,
including, but not limited to, undergrounding sections of the transmission lines, a range of pole heights,
pole colors, aesthetic treatments to poles, landscaping, and tree replacement. PSE noted that the project
design could be flexible to accommodate community concerns. For instance, poles could be made taller
or shorter, depending on the setting. In addition, PSE stated they would be willing to investigate the use
of combined static (shield wire)/communication line to reduce the total number of wires in the air.
Response:
Additional details on potential mitigation are presented in the Phase 2 Draft EIS. To see the proposed
pole heights for PSE’s proposed alignment, see Chapter 2 of the Final EIS. PSE proposes using a patina
covering to reduce the glare associated with galvanized steel poles. Patina causes the steel to rust,
changing the color of the poles to a more natural brown tone. Section 4.2.6 of the Final EIS describes
considerations for selecting pole finishes based on the background color, color of surrounding features,
and the surrounding land use. The poles would not be hidden, but they would be less noticeable. An
updated list of proposed mitigation measures to reduce impacts to scenic views and the aesthetic
environment is provided in Section 3.2.7 of the Phase 2 Draft EIS. For the Final EIS, PSE has also
committed to using a combined shield wire/communication line to reduce the total number of wires in
the air.
During Phase 1, it was determined that a submerged 230kV line in Lake Sammamish would not be
feasible (see Section 2.4.4 in the Phase 1 Draft EIS). The option of using a submerged or underwater
line in Lake Washington was included in the Phase 1 Draft EIS; however, it was not carried forward for
analysis due to shoreline regulations that would restrict where it could be placed and the potential for
higher environmental impacts than use of using existing corridors. For more information, see Section
2.2.3 in the Phase 2 Draft EIS. However, placing portions of the transmission line underground is still
proposed as a potential mitigation measure that could be considered by jurisdictions as part of the
permitting process (see Section 3.2.6 of the Phase 2 Draft EIS). Section 4.2.6 of the Final EIS discusses
the use of undergrounding as mitigation in greater detail.
Key Theme VR‐8: Errata and minor clarifications
Comment Summary:
Following the release of the Phase 1 Draft EIS, PSE provided comments on the project design and the
assessment of visual impacts. Another commenter asked if the project included the possibility of
“bundling” conductors as a means of controlling radio interference, as suggested in Section 15.6.2 of
the Phase 1 Draft EIS.
Response:
Clarifications and identified errors were provided and rectified in the Errata regarding pole height, a
statement that there was only one 230 kV transmission line in the Seattle City Light Corridor, and
wording that implied the Westminster substation already existed. See Chapter 3 of the Final EIS. PSE
(and other commenters) also provided numerous other minor clarifications that have not been included
in the Errata, primarily because they relate to Phase 1 alternatives that are no longer being considered,
they are minor clarifications (as opposed to factual errors), and they do not influence the results or
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conclusions of the analysis. The full letters are included in Appendix J, following this narrative
summary.
The reference to bundling was provided as an example of something that the IEEE manual suggests
where radio interference is a problem. However, PSE has not proposed bundling and uses other
methods for mitigating radio interference; therefore, this was not a good example. A profile of the
proposed conductors is included in the Phase 2 Draft EIS, Appendix C, Attachment 1.
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Economics (Topic ECON)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding
economic issues. Primary themes included property value depreciation, tax revenue impacts, the need
for a cost-benefit analysis, and fairness of financial burden.
Key Theme ECON‐1: Property value depreciation
Comment Summary:
Commenters voiced concern that the Energize Eastside project would negatively impact their property
values. The commenters were concerned about new transmission lines in areas that previously had
none, as well as taller transmission lines in areas where transmission lines already exist. They
questioned whether the Phase 1 Draft EIS adequately addressed how much the property values could
decrease due to view impacts, impacts to neighborhood character, concern regarding the health effects
of EMF, and tree loss.
Multiple commenters cited a potential for a 20 percent depreciation in property values, and pointed out
that the effect would be more pronounced on the Eastside because the properties are higher-end.
Commenters expressed concern about the EPRI report that the Phase 1 Draft EIS relied on, stating that
they believed it could be biased, that the findings were inconclusive, and that it was not an Eastside-
specific study and was therefore not applicable. Similarly, commenters requested that the EIS team
consult with real estate brokers for local data on how real estate prices could be impacted by
transmission lines. Commenters stated that local brokers or realtors indicated a 10–30 percent decrease
in value for homes along transmission lines. Additionally, commenters pointed to data from the King
County Assessor’s Office documented in a report prepared by FCS Group, a consultant on the EIS
team, which noted that construction of a view-obstructing transmission line could negatively affect
property values. Multiple commenters asked for an assessment of property value impacts as a result of
obstructed views from residences along the corridor. Representatives for the Somerset Recreation Club
stated that the project could reduce property values by blocking views, hindering access, and being co-
located with a pipeline.
Several commenters requested information on how a reduction in property values would be mitigated,
including a suggestion that PSE compensate owners whose views are affected.
Response:
The Phase 1 Draft EIS provided a review of the impacts at a programmatic level; therefore, no site-
specific data were analyzed. Also, SEPA does not require that an economic analysis be included. It
allows the Lead Agency to include economic information it believes would be helpful to decision
makers. The EIS Consultant Team included a section on impacts to property values because it was
highlighted as a concern during the scoping process, and the Lead Agency determined it could be
helpful. The scope of the analysis is limited, and is not intended to be a full cost-benefit analysis of the
project. The focus of the property value analysis is on using economic studies regarding the siting of
transmission lines as one gauge of community acceptance of transmission lines as a land use and as a
visual element. Site-specific data (including information gathered from local brokers and real estate
agents) were not used in the analysis in the Phase 1 Draft EIS.
For the Phase 2 Draft EIS the EIS Consultant Team performed further economic analysis regarding
impacts to property values from transmission lines; this analysis is included in Section 3.10.1. A 2016
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study was reviewed that reinforced the conclusion of the Phase 1 Draft EIS that a negative effect on
property values is expected from the presence of transmission lines (Tatos et al., 2016, Property Value
Impacts from Transmission Lines, Subtransmission Lines, and Substations). The findings of this study,
however, do not suggest that the replacement of lower voltage with higher voltage lines would result in
a greater negative effect than the existing lines have at present.
The Phase 1 Draft EIS identified the results of several studies that gave a range of a 1–20 percent
reduction in property value for properties with a view of transmission lines, with the average of these
studies being a 6 percent reduction. An EPRI-sponsored study found that the voltage and size of
transmission lines and easements were not determining factors regarding changes in property values.
The EPRI-sponsored study was chosen as the source of information for the Phase 1 Draft EIS because it
synthesizes and summarizes the findings of over 50 surveys and studies. EPRI is an independent
nonprofit whose members are made up of electric utilities, businesses, government agencies, regulators,
and other entities involved in the generation, delivery, or use of electricity. While most of these entities
have an interest in building and operating transmission lines, the study was found to have been
conducted without bias, and summarizes a range of independent studies that found various levels of
effects on property values.
The Phase 1 Draft EIS analysis found no studies specifically on the subject of increasing the pole height
or voltage on an existing corridor. Also, none of the studies looked separately at the effect on property
values of scenic view blockage by transmission lines. All focused on the general effect of having the
transmission lines in view of the homes, regardless of the presences of a scenic view. The studies
reviewed had inconclusive or inconsistent findings on how property values could be impacted by
changes in views due to the increased pole heights (see Section 11.6.1.4 of the Phase 1 Draft EIS). Site-
specific data (including information gathered from local brokers and real estate agents) were not used in
the analysis contained in the Phase 1 Draft EIS.
Chapter 10 of the Phase 1 Draft EIS acknowledges that the sale prices of higher priced homes are more
affected by proximity to high power transmission lines than are lower priced homes. The study cited in
the comment, however, does not address whether the replacement of lower voltage with higher voltage
lines has resulted in a greater negative effect than the existing lines have at present. Based on the
studies cited in the EIS and the study cited in this comment, it is reasonable to assume that the existing
transmission lines have affected property sale prices and would continue to do so under the No Action
Alternative. Although the EIS acknowledges that some reduction of property values is likely, it would
be speculative to assume, based on these studies, that replacement of the transmission lines would cause
an additional reduction in sales price of the same amount as was observed for homes in the vicinity of
the existing lines. Because impacts to property values are not an element of the environment that must
be analyzed under SEPA, specific impacts to property values that could be caused by the project were
not included in the Phase 2 analysis or the Final EIS.
Because the Phase 1 Draft EIS was a programmatic-level review, it did not look at visual impacts from
specific alternative routes. The Phase 2 Draft EIS does include a detailed analysis of the visual impacts
(see Section 3.2) and found that there would be no significant unavoidable impacts to scenic views (as
defined in the EIS) due to the Energize Eastside project. The project would result in significant impacts
to the aesthetic environment under the Bypass 1, Bypass 2, and Willow 1 Options, and the Newcastle
Segment as evaluated in the Phase 2 Draft EIS due to high viewer sensitivity and contrast with the
aesthetic environment. (For definitions of “scenic views” and the “aesthetic environment” see Section
3.2 of the Phase 2 Draft EIS.) For the Final EIS, significant adverse impacts to the aesthetic
environment would occur under the Bellevue South Segment and both Newcastle Options. Because
impacts to property values are not an element of the environment that must be analyzed under SEPA,
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specific impacts to property values that could be caused by the project were not included in the Phase 2
analysis.
As described in the response to Key Theme LU-1, it was not known whether the project would require
land acquisition during the Phase 1 Draft EIS process. After the alignments for the alternatives were
identified for the Phase 2 Draft EIS analysis, it was determined that the proposed alignment and options
evaluated in the Phase 2 Draft EIS would not involve any condemnation of homes or other properties.
Access to residential and commercial properties would be maintained (see Chapter 14 of the Phase 1
Draft EIS). Therefore, two factors that commenters suggested would affect property values - removal of
homes and addition of a new transmission line through a residential area – would not occur. PSE’s
proposed alignment evaluated in the Final EIS would be operated entirely in an existing utility corridor.
The EIS does not investigate whether co-location of a transmission line with a pipeline would result in
reduced property values independent of having one or the other next to a property. Because the
properties along much of the existing PSE corridor already abut a transmission line that is co-located
with a pipeline, it is assumed that existing property values reflect the effects of such co-location. It is
acknowledged that heightened awareness of the pipeline may be affecting property values more at
present than before the Energize Eastside project was proposed. It would be speculative to estimate
changes in specific property values that could result from replacing the existing lines with a 230 kV
transmission line.
It is not common practice to require monetary reimbursement for property devaluation associated with
views of a transmission line or private view obstruction, and there is no city policy in place in any of
the jurisdictions suggesting that such compensation be required. However, mitigation measures, such as
requiring that the transmission line be placed underground or pole heights be minimized, could be
required by the Partner Cities, and are identified as a potential mitigation measure in the Phase 2 Draft
EIS, Section 3.2.6. While Bellevue has policies regarding the general preservation of scenic views, no
regulations in any of the Partner Cities guarantee the protection of private views. The policies of each
jurisdiction regarding the preservation of general visual quality are described in both the Phase 1 Draft
EIS and the Phase 2 Draft EIS.
Key Theme ECON‐2: Tax revenue impacts
Comment Summary:
Commenters voiced concern that the project would result in decreased property values, which would
then decrease the tax revenue for the Partner Cities. This impact, according to commenters, could lead
to a decrease in services provided by the communities because of the acquisition of land and conversion
to utility use, combined with the potential decrease in property value because of the presence of the
transmission lines. One commenter noted that the impact of the project on smaller towns like Newcastle
would likely be proportionally higher because larger cities, such as Bellevue, have a more diverse tax
base. Several commenters requested information on how the loss of property tax revenue would be
mitigated.
Response:
The Phase 1 Draft EIS examined the question of whether a reduction in property value would
significantly affect the ability to maintain public services. Because the change in value that can be
expected was dependent on the specific location, the Phase 1 analysis looked at hypothetical property
value reductions so that decision makers would have a sense of the potential order of magnitude, and
could see how that compared to the most affected city, the City of Bellevue. The Phase 2 Draft EIS
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analyzed the potential loss of property tax revenue, with results presented in Section 3.10. The analysis
conducted for Phase 2 used the City of Newcastle as a proxy for impacts to tax revenue because it is the
smallest of the Partner Cities jurisdictions in both population and property tax base, and thus is the most
sensitive to property tax fluctuations. See Section 3.10.4.1 of the Phase 2 Draft EIS for the results of the
analysis.
During the preparation of the Phase 1 Draft EIS, it was not known whether the installation of new 230
kV overhead transmission lines would result in the acquisition of land, and potential condemnation of
homes and other improvements. The proposed alignment and options evaluated in the Phase 2 Draft
EIS would not involve any condemnation of homes or other properties but may result in the demolition
of accessory structures (e.g., sheds). Easements along road rights-of-way would be required. Therefore,
the impact on property values from the conversion of land to a utility use is not evaluated in the Phase 2
Draft EIS.
Key Theme ECON‐3: Need for a full cost‐benefit analysis
Comment Summary:
Many commenters stated that economics are an element of the environment for many SEPA EISs, and
suggested that this project warranted a more thorough economic assessment. For instance, the Somerset
Recreation Club stated that having 85- to 100-foot poles on their property could result in reduced
membership to the point that they might have to close their facility. Commenters stated that a cost
comparison of the various alternatives should be conducted and considered during the selection of a
preferred alternative.
One commenter said that there should be a preliminary quantitative assessment of the impact on PSE's
tariff(s) and rate schedules and a preliminary lifecycle cost estimate for acquisition and ownership for
each alternative/option considered based on the same economic/financial basis and expressed in the
same-year dollars. Others added that mitigation measures (such as replacing trees, constructing
stormwater improvements, property acquisition, and placing portions of the project underground)
should be included in the cost estimate, as well as environmental externalities (such as GHG emissions,
etc.). Commenters said that the EIS does not adequately address reliability versus cost, and that the
Draft EIS should include a numerical analysis of the expected increase in reliability versus the relative
cost of each alternative. Some commenters speculated that Alternative 2 would likely cost more while
others say Alternative 3 would be expensive due to property acquisition. One commenter said that
using newer technologies helps to spread the risk and investment, stating that investment has the
potential to go further as technology improves and costs drop.
Some commenters stated that high electricity prices might suppress regional economic activity,
business growth, and business development on the Eastside and greater Puget Sound area. Commenters
stated that high electricity rates are a careful consideration when a business chooses to start or relocate
to the Eastside and noted that Gross State Product is very sensitive to changes in electric prices over
time, and there is a correlation between high electric prices and lower or negative economic growth.
Commenters were also concerned that the project could use up funds needed for maintenance of other
infrastructure.
Response:
Economic analysis is not a required element for a SEPA EIS; however, SEPA provides discretion to
agencies to include economic information in an EIS that could be beneficial to decision makers, such as
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information related to environmental concerns that may not be readily available elsewhere. The analysis
in the Phase 1 Draft EIS of property tax effects on the City of Bellevue was prepared to give a sense of
how sensitive the budget of the largest city was to changes in property values if the project adversely
affected property values. In the Phase 2 Draft EIS, a similar analysis for the City of Newcastle and an
analysis of the value of lost ecosystem services due to reduced tree cover were conducted, in response
to comments received during the public comment periods for the Phase 1 Draft EIS and the scoping
period for the Phase 2 Draft EIS.
The analysis of the costs of undergrounding a portion of the transmission line was developed because it
was recognized in Phase 1 that the cost of undergrounding the entire line would be prohibitively high,
but that undergrounding might be viable as mitigation in site-specific areas. The analysis is intended to
assist decision makers considering whether to require undergrounding as a mitigation measure to offset
environmental impacts. Per PSE’s interpretation of state-approved tariff rules, the requesting party
(such as the local jurisdiction, or an affected party or group) may be responsible for paying the
difference between overhead and underground costs, including design, construction, and maintenance.
A full cost comparison of the various alternatives was not assessed because it is not required under
SEPA. As the electric utility provider for the Eastside, PSE is responsible for determining the most
cost-effective method for delivering reliable electric power. PSE has concluded that the most cost-
effective solution to meet its objectives is to site a new 230 kV transformer in the center of the Eastside
(Stantec, 2015) (see Section 1.3 of the Phase 1 and 2 Draft EISs).
Commenters are correct that energy prices can be determining factors for businesses locating in the
region. Based on the estimates of cost per customer provided by PSE, this project is not expected to
significantly affect the price of electricity for existing or prospective businesses. PSE has indicated that
customers would not see an increase in their monthly bill directly as a result of the project because PSE
funds electric infrastructure upgrades and additions through its annual capital budget, which is already
covered in current customer rates. Utility rates are regulated by the Washington Utilities and
Transportation Commission, and PSE would need the commission’s approval to include this project in
its rate basis. Furthermore, SEPA does not require an analysis of how a project will be funded. As such,
a cost analysis is not necessary in order to evaluate environmental impacts.
Key Theme ECON‐4: Fairness of financial burden
Comment Summary:
Commenters noted that the cost of the project would be borne by rate payers. Some calculated the cost
to be over $1 billion over the lifetime of the project and cited the Energize Eastside Economic Analysis
on the CENSE website. Many stated that the project is over-scaled and overpriced. Some stated that
increased utility bills could impact low-income populations. Some suggested that PSE use the proceeds
from selling the Schuffleton Peaker Plant to upgrade the grid. Some commenters asked why PSE
customers are being asked to solely pay for electricity grid enhancements and stated that the project
should have been included in the regional transmission plan, which would have resulted in the project
receiving funding from BPA, SCL, and others. Others stated that all PSE customers should not have to
pay for improvements that would only benefit 3 percent of PSE’s customers. A handful of commenters
stated that rate increases to pay for the project combined with loss of property values would place a
double financial burden on adjacent property owners.
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Many stated that the project would result in ratepayers paying for PSE shareholders to profit. Some
stated that State regulations allow PSE to collect a 10 percent return on infrastructure investments;
others commenters stated opposition for investing in old technology and noted that policies should be
put into place to support investing in newer technology. Comments were also received about how PSE
budgets and plans for its improvement projects.
Another asked who pays for the acquisition and ownership of possible resources required (gas turbines,
microturbines, fuel cells, etc.), and how such payments would be made for Alternative 2, as well as
how electrical output from distributed generation would be priced.
Response:
The Partner Cities do not regulate PSE’s rates. It is the responsibility of the Washington Utilities and
Transportation Commission (WUTC) to determine if the cost of electrical upgrades is appropriate.
PSE has stated that because this project meets local needs, it is a local project and the cost should be
borne by PSE customers. It is the responsibility of ColumbiaGrid to determine if the project is needed
for regional transmission or is primarily a local transmission solution.
Although the exact cost of the project is unknown, PSE’s estimates for its proposed alignment are
between $150 million and $300 million. Regular upgrades or additions to the electric infrastructure are
shared by all of PSE’s customers and are paid for over time. PSE has indicated that customers would
not see an increase in their monthly bill directly as a result of the project because PSE funds electric
infrastructure upgrades and additions through customer rates based on its annual capital budget. At any
given time, the PSE rates cover numerous capital investments made in past years; thus, the Energize
Eastside project would be one of many being funded in this way. The Energize Eastside project would
be paid for like most transmission and distribution projects, with PSE including the cost of the project
in future annual capital budgets. Once the project is built and added to the annual capital budget, PSE
expects that $1 to $2 of the average monthly bill for residential customers will go toward paying for the
project. While theoretically PSE rates could be lowered if the Energize Eastside project were not built,
in practice, PSE would likely fund other capital projects and the rates would not change appreciably.
PSE has determined that Alternative 2 was not feasible because PSE does not have the ability to require
its customers to install energy efficiency measures or peak period generation facilities. PSE does not
believe it is feasible to expect voluntary measures to be adopted quickly enough to address the capacity
deficiency it has identified. Further analysis of Alternative 2 was not conducted. For more information,
see Section 2.2.7 of the Phase 2 Draft EIS.
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Recreation (Topic REC)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding
recreation. Primary themes include trails in utility corridors, temporary trail closures, impacts to the
Somerset Recreation Club (SRC), birding as a recreational activity, and loss of recreation sites/access
from right-of-way widening, and the need for new trail corridors.
Key Theme REC‐1: Trails in utility corridors
Comment Summary:
PSE noted that trails and utility corridors can co-exist, and often only exist because of the presence of a
utility corridor, listing examples such as Bridle Trails State Park Equestrian Trail on the SCL corridor
which was established as a utility corridor prior to the area becoming a park; Interurban Trail in south
King County, which is situated on PSE's 230 kV/115 kV corridor and co-located with the Olympic
Pipeline; and the Puget Power Trail in Redmond along PSE's 230 kV line.
PSE also noted the potential for wider or improved trails where two H-frame pole types are replaced
with a single monopole, as is proposed along portions of the corridor as part of PSE’s Proposed
Alignment. New trails or improvements to existing trails systems can be incorporated into siting of
utility projects so that there is a positive impact to recreation. One commenter requested that the
currently fenced green space, particularly between NE 24th Street and the 520 bicycle path, should be
made accessible and include a path or trail so that people can use the space, particularly to provide
access to the 520 bicycle path from NE 24th Street.
Trail users expressed concern regarding the potential for trails to be closed for months due to vegetation
clearing activities associated with the construction of the project. One commenter noted that the trail
along the Olympus Trail in Newcastle is a significant part of the Newcastle trail system, and trail users
will be negatively impacted by any restrictions in access. PSE noted that there would be temporary
closure of trails for maintenance of the transmission line.
Response:
Trails on existing transmission line rights-of-way were described in the Phase 1 Draft EIS as “informal
trails,” that are “ancillary to the primary use of the property” (see Section 12.6.3.1.3 of the Phase 1
Draft EIS). Improvements to recreational resources, including trails, can be identified as permit
conditions by the appropriate municipality, and comments suggesting such improvements will be taken
into consideration by the Partner Cities.
There is the potential for permanent impacts to recreation within existing transmission corridors if
vegetation removal results in a permanent conversion of vegetation type (e.g., from forested to low-
growing vegetation). This could substantively change or negatively impact the scenic nature of a
recreation site or could result in a loss of habitat for animals that may use these areas, reducing user
enjoyment. In addition, if benches, playground equipment, gazebos, or other structures are removed
underneath the transmission lines, visitors may avoid a recreation site if it no longer offers the
amenities they previously used at that site (see Section 12.6.3.1.1). However, the Phase 2 Draft EIS
found that within the existing corridor, impacts to recreation would be less-than-significant because
vegetation clearing and changes to poles and wires would not affect the use of recreation sites (see
Section 3.6.5 of the Phase 2 Draft EIS).
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The Phase 1 Draft EIS described construction of the transmission line along existing trails as occurring
in three stages, each 1 to 3 days long, over a period of 2 months. The length of time for vegetation
clearing would depend on the location, but, it would not be closed for months (see Section 4.6.2.2 of
the Phase 2 Draft EIS for discussion).
Impacts to trails, including Olympus Trail in Newcastle, were evaluated in Section 3.6 of the Phase 2
Draft EIS.
Key Theme REC‐2: Birding as a recreation activity
Comment Summary:
A representative from the Eastside Audubon noted that birding is a recreation activity, enjoyed in the
study area’s 235 recreation sites, and should be considered different from other uses listed in the
Phase 1 Draft EIS. The commenter asserted that project impacts on birding could be much more
negative in the vicinity of the transmission lines and towers than impacts on other users because of the
direct impact the overhead transmission lines could have on birds. The commenter suggested adding
two sites to Table 12-2 on page 12-6 of the Phase 1 Draft EIS, the Cross Kirkland Trail and the
proposed Eastside Rail Corridor that King County is now planning. These linear open space corridors
are bordered by high quality woodlands and wetlands, so any habitat fragmentation caused by
transmission facilities could significantly affect birding.
Response:
The Phase 1 Draft EIS did consider birding as a subset of nature viewing in keeping with a
programmatic evaluation. It is correct that habitat degradation or fragmentation would adversely affect
enjoyment of birders as it would other nature viewing. Potential impacts to wildlife, including birds, are
discussed in Chapter 6, Plants and Animals in the Phase 1 Draft EIS, as well as in Section 3.4, Plants
and Animals, in the Phase 2 Draft EIS. The Phase 2 Draft EIS did not evaluate the Cross Kirkland Trail
because the alignment route and options did not extend into the City of Kirkland where the trail is
located. Potential impacts to the Eastside Rail Corridor were evaluated in the Phase 2 Draft EIS,
Section 3.6.
Key Theme REC‐3: Permanent loss of recreation sites
Comment Summary:
A number of commenters expressed concern that recreational sites would be permanently impacted, in
some cases eliminated, as a result of corridor widening to make room for the overhead transmission
lines and to ensure an adequately safe distance from the existing Olympic Pipeline. Commenters
expressed concern over the following recreational sites as a result of Alternative 1, Option A: Coal
Creek Natural Area (which a commenter pointed out was recently improved), Bridle Trails State Park,
Viewpoint Park, Kelsey Creek Park, May Creek Park, Forest Hill Neighborhood Park, Sierra Heights
Park, Eastside Rail Corridor (ERC). Other commenters were concerned about impacts to recreational
resources associated with the placement of new 230 kV corridors to connect the SCL corridor with the
Sammamish substation and Lakeside substation. Additionally, commenters expressed concerns over the
possibility of community programs being shut down for safety reasons, such as the farm at Kelsey
Creek Park, elimination of certain recreation activities, such as kite-flying, because of safety concerns,
and exposure to children and other park users to unsafe conditions. The cost of replacing lost park lands
should be considered. Commenters felt that Alternative 2 would have the flexibility to locate new
transmission infrastructure so as to avoid park lands and related environmental destruction.
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Commenters expressed concern that recreational users would be affected by the permanent loss of
vegetation because it would negatively impact the scenic nature of a recreation site and increase
exposure to noise.
Representatives from SRC and others identified potential impacts concerning the SRC facilities,
including permanent displacement of SRC facilities as a result of the project and any associated
corridor widening, the inability of mitigation measures to provide solutions, and the potential for
construction during the club’s peak season to affect club membership which would impact the financial
viability of the club.
Response:
At the time the Phase 1 Draft EIS was prepared, the alternatives considered included the potential for
new corridor routes or widening the existing 115 kV transmission line corridor, which could have
affected adjacent recreational resources. For the Final EIS, PSE’s proposed alignment would occur
within their existing right-of-way and will not require new easements or properties. Therefore, there
will be no impacts to the trails along the SCL right-of-way or the recreational resources along new 230
kV corridors that would have been required to be built to connect the SCL corridor with the
Sammamish and Lakeside substations. There would also be no impacts to the Eastside Rail Corridor or
the Coal Creek Natural Area.
The existing transmission line corridor crosses or abuts Viewpoint, Kelsey Creek, May Creek, Forest
Hill, and Sierra Heights Parks, and the SRC. None of these parks or community centers would be
eliminated. Programs such as the farm at Kelsey Creek Park would continue unchanged. For further
discussion, see the Phase 2 alternatives analysis, which describes impacts to the SRC in more detail
(see Sections 3.6.5.9 through 3.6.5.12 of the Phase 2 Draft EIS). The Phase 2 Draft EIS found that no
significant adverse impacts to the SRC would occur. More information about the proposed easement,
pipeline safety, and recreation impacts are described in Section 3.4, 3.9, and 3.6 of the Phase 2 Draft
EIS, respectively. Safety issues, as they relate to recreation resources, are described in Section 3.9.6 of
the Phase 2 Draft EIS.
Additionally, mitigation measures in the Phase 1 Draft EIS were in keeping with the programmatic
nature of the document, and mitigations measures proposed were high-level in nature. The Phase 2
Draft EIS provides more specific mitigation strategies (see Section 3.6.6 of the Phase 2 Draft EIS).
Key Theme REC‐4: Cumulative impacts
Comment Summary:
In combination with the East Link project and other projects planned in the project area, the Energize
Eastside project could cause cumulative impacts on recreation if the same recreation sites are affected
or if construction periods overlap.
Response:
Cumulative impacts to recreational resources from overlapping construction projects such as the Sound
Transit East Link project are described in Section 5.6 of the Phase 2 Draft EIS.
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Key Theme REC‐5: Errata and minor clarifications
Comment Summary:
Following the release of the Phase 1 Draft EIS, PSE provided comments on the project design and the
assessment of recreational impacts.
Response:
Clarifications and errors were identified and rectified in the Errata, specifically regarding transmission
line placement in Lake Washington and the summary of recreation impacts in Table 1-3 in the Phase 1
Draft EIS.
PSE also provided other minor clarifications that have not been included in the Errata, primarily
because they relate to Phase 1 alternatives that are no longer being considered, they are minor
clarifications (as opposed to factual errors), and they do not influence the results or conclusions of the
analysis. The full letters are included in Appendix J of the Final EIS, following this narrative summary.
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APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
Historic and Cultural Resources (Topic H&C)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding
historic and cultural resources. Primary themes included the interpretation of impacts, the analytical
process, impacts to site-specific resources, and information that should be included in the Errata as well
as minor clarifications.
Key Theme H&C‐1: Interpretation of impacts
Comment Summary:
PSE noted that past project construction within or adjacent to documented resources has not been
considered significant—even if the resources are removed—when the resources are properly identified,
evaluated, and documented. Other commenters expressed concern over impacts to historic and cultural
resources as a result of ground disturbance as a part of routine pole replacement, and whether noise and
vibration from the transmission lines should be considered impacts in the context of historic and
cultural resources. Commenters requested clarification on why the No Action Alternative would have a
minor to moderate impact, noting that nothing would be constructed under this alternative.
Response:
Significance has two meanings with regard to historic and cultural resources. The historic or cultural
significance of a site and the potential eligibility of archaeological resources are determined by the
Washington State Department of Archaeology and Historic Preservation (DAHP), affected Tribes, and
any additional consulting parties, as defined in 36 CFR Part 800.2. Under SEPA, the significance of an
impact refers to the intensity of the impact, taking into account any proposed mitigation to reduce that
impact.
The potential for ground disturbance and associated impacts under the No Action Alternative is
addressed in the Phase 2 Draft EIS (see Section 3.7.4). Pole replacement would be a ground-disturbing
activity and could impact archaeological resources, if present. The Eastside Transmission System has
been recommended eligible for listing on the National Register of Historic Places, and the existing H-
frame wood poles have been recommended as a contributing element to the system's historical
significance. Replacement of existing poles has the potential to impact the system's ability to convey its
historical significance. This is considered to be a less-than-significant impact under SEPA as it is likely
that impacts could be mitigated. PSE is conducting further evaluation of the resource and is consulting
with DAHP to obtain an eligibility determination for the system as part of a historic property inventory
field assessment. If the Eastside Transmission System is determined eligible by DAHP for listing in the
NRHP, pole replacement could be a significant impact, but it is possible that the impacts could be
mitigated, such as through conducting an historic property inventory, providing documentation and/or
interpretation of the line as it is currently configured or was when it was built, or by other means
developed in consultation with DAHP.
Noise and vibration are addressed in the Historic and Cultural Resources chapter of the Phase 1 Draft
EIS to identify whether or not noise and/or vibration could cause an impact to a historic and/or cultural
resource and its setting. These impacts were characterized as a minor impact in the Phase 1 Draft EIS
when considering the noise and/or vibration that would occur as a result of construction of components
and larger facilities associated with the transmission lines and maintenance work.
As stated in Section 13.5.2 of the Phase 1 Draft EIS, implementation of the No Action Alternative
could have minor to moderate impacts to aboveground historic properties, primarily from the
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installation of components associated with energy conservation measures (such as solar panels, wind
turbines, or rooftop generators). Such components could alter a resource’s architectural elements or
diminish the ability of the property to convey its historical significance.
Key Theme H&C‐2: Analytical process
Comment Summary:
A PSE representative recommended that in order to perform the appropriate level of analysis of
identified properties, the analysis should state that prior to construction, PSE will commission the
appropriate historic and cultural resources field surveys along the proposed route.
Response:
The Phase 2 Draft EIS addresses the analysis of individual properties (see Section 3.7). PSE has begun
conducting historic property and archaeological studies for the resources identified in the EIS, and has
committed to completing the analysis prior to construction. PSE will comply with applicable analysis
and survey requirements as determined in consultation with DAHP, affected Tribes, and any additional
consulting parties, as defined in 36 CFR Part 800.2.
Key Theme H&C‐3: Existing and proposed cultural resources
Comment Summary:
Commenters expressed concern over potential impacts to properties in the study area that contain or
could contain historical significance, such as the Newcastle Cemetery and the Somerset Recreation
Club (SRC). Commenters were also concerned about what mitigation measures could be put in place
for specific sites.
Response:
The Phase 1 Draft EIS is a programmatic-level analysis, as specific alternative routes were not
identified at the time of the analysis. The Phase 2 Draft EIS is a project-specific analysis and includes
information on the routes of specific segments and options. The Phase 2 Draft EIS (see Section 3.7.2.6)
describes the Newcastle Cemetery, noting its historic significance. Section 3.7.6.1 of the Phase 2 Draft
EIS states that PSE will request an eligibility determination from DAHP regarding the cemetery's
eligibility for inclusion on the National Register of Historic Places, and notes that cemeteries and
graves will be avoided per state laws. The Phase 2 Draft EIS, Section 3.7.6.2, describes potential
mitigation measures, including the preparation of an Inadvertent Discovery Plan (IDP) and conducting
ground-penetrating radar survey in areas adjacent to Newcastle Cemetery.
The SRC is addressed in the Phase 2 Draft EIS (see Section 3.7.2.5), which describes the Somerset
Neighborhood. PSE is conducting further evaluation of this potential historic district (including the
Somerset Recreation Club) as part of the historic property inventory field assessment and is consulting
with DAHP to obtain an eligibility determination.
Analysis of components associated with peak generation plants and energy efficiency (as presented in
the Phase 1 Draft EIS) was not included in the Phase 2 Draft EIS because these project elements are no
longer under consideration.
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Key Theme H&C‐4: Errata and minor clarifications
Comment Summary:
Following the release of the Phase 1 Draft EIS, PSE provided comments on the assessment of historical
and cultural impacts, stating that all alternatives should have the same construction significance
conclusions. PSE also noted a number of clarifications, including the following: the definition of
properties should also include an object; the Smithsonian numbering system is used for historic
resources as well as archaeological sites; and the absence of identification of multicomponent sites in
the Phase 1 Draft EIS.
Response:
Identified errors were rectified in the Errata (see Chapter 3 of the Final EIS) regarding the
inconsistencies in the Construction Impact Comparison Table and the impacts specific to the Energy
Storage and Peak in Alternative 1.
Clarifications were addressed in the Phase 2 Draft EIS analysis; Section 3.7, paragraph 1 includes
"object" in the definition of historic and cultural resources. Objects were included in the evaluation of
historic and cultural resources. The Phase 2 Draft EIS, Section 3.7.2.9, acknowledges the Smithsonian
numbering system includes resources other than archaeological sites. At the time of publication, there
are no recorded multicomponent sites, neither within the Phase 1 Draft EIS Alternative 1 study area,
nor the Phase 2 Draft EIS Alternative 1 study area.
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Transportation (Topic TRAN)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding
transportation. Primary themes included congestion and access during construction, the potential need
to truck petroleum products if the pipeline is damaged as a result of the project, transportation
associated with large utility infrastructure, and mitigation.
Key Theme TRAN‐1: General congestion/transportation impacts associated with
construction
Comment Summary:
Some commenters disagreed with the significance determination made for the installation of new 230
kV transmission lines, citing activities that involve large equipment, such as the following: removal of
houses, digging holes for pole footings, large trucks hauling power poles, large cranes installing the
poles, stringing wires, and a general public exclusion radius for all of these activities. Additionally,
commenters stated that the EIS should anticipate disruptions and set-backs for this type of work.
Representatives of the Somerset Recreation Club (SRC) voiced concerns over access to the facility and
the parking lot(s) during construction and operation of the project, especially during peak times in the
summer season when the swim team meets. Additionally, individuals expressed concerns over
vehicular traffic being closed to the Coal Creek Parkway exit in the Olympus neighborhood while the
transmission line wire is pulled and strung between poles in the Olympus area.
Individuals expressed concern over the project blocking access to homes, particularly driveways and
garages.
Response:
Use of construction vehicles and other construction activities, and the potential for impacts to
transportation, are evaluated in Section 14.5 of the Phase 1 Draft EIS. This section evaluates
transportation impacts from construction-related restrictions on roadway use, sidewalk use, access to
intersecting alleys and driveways, transit, and parking. Impacts from truck trips and employee commute
trips generated by construction work, and pavement degradation from heavy trucks are also evaluated.
Construction would be spread out over the 18-mile corridor and completed in segments so that
disruption of a specific area would be brief in duration.
As noted in the project-level analysis in the Phase 2 Draft EIS, houses would not be removed for the
project. A project-level description of construction activities and equipment is provided in Section 2.1.3
of the Phase 2 Draft EIS. The methods used to install new steel poles will depend on the type of pole
used and both its physical and functional location. Some poles can be directly embedded in the ground
(similar to a wood pole). Such poles do not require a foundation and are installed using a vacuum truck
to excavate the hole, which typically results in less surface area disturbance than other equipment (such
as a backhoe or drill) and fewer transportation-related impacts. See Chapter 2 of the Final EIS for
discussion of the pole types expected for PSE’s Proposed Alignment. Regarding the size of trucks
needed to deliver poles, it should be noted that steel poles are delivered in sections and assembled on-
site. While the trucks delivering poles would be long, they would not need to be long enough to carry
fully assembled poles.
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It is noted in Section 12.5.1.1 of the Phase 1 Draft EIS that "construction trucks around a recreation site
may also disrupt traffic or make parking difficult.” However, PSE would work with the SRC to ensure
that access is maintained during construction activities, consistent with the mitigation measures
identified in Section 14.7 of the Phase 1 Draft EIS. Access to other properties would be maintained
during construction, including driveways to homes and garages.
Driveways along the transmission line route would be passable during construction unless there is an
alternative driveway serving a property that can accommodate vehicles if one driveway is closed. See
Sections 14.5.3.2.2 and 14.5.3.4.2 of the Phase 1 Draft EIS.
With regard to road closures for pulling wires, brief closures could be needed, including on the Coal
Creek Parkway exit. Any road closure would be less than a full day, and closures would be minimized
and could be scheduled to avoid peak traffic periods. Any road closure would require approval of the
responsible agency or agencies. In addition, PSE will need traffic control plans and will work closely
with City construction division staff regarding road closures, traffic plans, etc.
Key Theme TRAN‐2: Potential need to truck contents of the pipelines
Comment Summary:
Commenters expressed concern over the feasibility of trucks being used as an alternative to the pipeline
system in the event of a disruption such as a leak or fire (as part of Alternative 1, Option A); that trucks
transporting petroleum products would generate more trips (approximately six times more) on nearby
highways than reflected in the Phase 1 Draft EIS. Concerns were also expressed over the temporary
nature of a short-term disruption associated with a pipeline shut down possibly being many days to
weeks.
Response:
It is difficult to estimate the number of truck trips because a pipeline breach could simply delay
delivery of some products, some products could be shifted to trains, some could be transported in
undamaged portions of the pipeline north and south of the breach, and some orders could be cancelled.
However, it is correct that if a major disruption occurred that shut down the entire pipeline system and
lasted more than few days, and if all material normally transported through the entire Olympic Pipeline
system were delivered by truck, it would take on the order of 4,000 trucks per day, which is more than
was listed in the Phase 1 Draft EIS. The estimate included in the Phase 1 Draft EIS was provided by
Olympic, and would result in a substantial reduction in the amount of fuel being transported through the
region, or a substantial amount being transported by means other than truck, such as by rail, barge, or
ship. This higher estimate of truck trips is considered a worst-case estimate because it assumes no
reduction in volume of products being shipped through the region, and all of the products being shipped
by truck. This has been noted in the Errata for Phase 1 and in the Final EIS. Not all of these trips would
be on nearby highways because the sources and destinations are mostly outside of the project area and
dispersed through the region.
Key Theme TRAN‐3: Transporting project components
Comment Summary:
Comments expressed concern over the timing and the logistics of transporting larger project
components, such as the new poles and substation equipment, and how construction along the 18-mile
corridor will be phased.
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A PSE representative clarified that large equipment such as 230/115 kV transformers and breakers can
remain operational for decades.
Response:
The Phase 1 Draft EIS discusses the fact that project construction would involve oversize loads, and
that the timing would follow rules for such loads. Construction timing/scheduling was not known at the
time of the Phase 1 Draft EIS or the Phase 2 Draft EIS, but is described in the Final EIS. Steel poles
would be delivered to the site in 30- to 50-foot sections, and assembled in the field. The delivery would
require one or two vehicle trips per pole. For more information, see Section 2.1.3.2 of the Phase 2 Draft
EIS.
During operations, as noted by the PSE comment, the replacement of large equipment happens very
infrequently. Section 14.6.3.1.2 of the Phase 1 Draft EIS states that: "a new substation would require
infrequent (less than once a year) replacement of very large equipment such as transformers, resulting
in oversized loads being carried on surface streets from regional freeways to the substation site. The
same route and time of day restrictions could be imposed by a City and/or WSDOT for such loads, as
described previously in construction impacts. Operational transportation impacts would be minor."
Because this statement remains correct, changes have not been made to the text.
No significant unavoidable adverse impacts to transportation were identified (see Section 14.9 of the
Phase 1 Draft EIS). Mitigation measures are provided in Section 14.7; however, their implementation
would be included as part of the maintenance of traffic plans.
Key Theme TRAN‐4: Mitigation of transportation impacts during construction
Comment Summary:
Commenters suggested restricting the most disruptive construction to night time hours and temporarily
relocating residential customers to hotels because of the risk of pipeline accidents during construction.
Response:
Two project-related construction elements could occur at night: (1) stringing across SR 520/I-90, and
(2) transformer delivery to the substations. There are no plans to relocate residential customers to
hotels. However, this is a potential mitigation measure that could be employed, if warranted. For
information about pipeline safety, see Section 4.9 of the Phase 2 Draft EIS.
Section 14.7 of the Phase 1 Draft EIS presents general mitigation measures identified to avoid or reduce
the potential transportation impacts expected to occur during construction of Alternatives 1 or 3, and
battery storage and peak generation plant facilities for Alternative 2.
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Public Services (Topic SVC)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding
public services. Primary themes included interference with communication devices, emergency
response to pipeline-related incidents, safety measures currently in place, increased demand for
emergency response personnel, and additional information provided by PSE.
Key Theme SVC‐1: Response to pipeline‐related incident
Comment Summary:
Commenters suggested that additional police and other emergency response personnel would be needed
during or after construction of the project because of the risk of a pipeline fire caused by the Energize
Eastside project, and that the EIS should identify the costs of such services. Commenters also suggested
that emergency personnel would be at increased risk, and asked how such risk is being analyzed and
minimized, and whether the involved Cities’ insurance would increase. One commenter asked why
“6,000 rescue workers recently rehearsed for an earthquake if such an event is not a real possibility.”
Commenters cited the Bellevue Fire Department Standards of Response Coverage Report, which states
that the Olympic Pipeline system presents a significant consequence risk that approaches the
“catastrophic” level. Commenters also said there could be a huge explosion similar to the gas leaks in
Greenwood, Lynnwood, and Tukwila, and that such an event would result in impacts to first
responders.
Commenters requested a copy of the Olympic Pipeline Break Disaster Plan. One commenter noted that
there would be insufficient Aqueous Film Forming Foam (AFFF)-equipped fire trucks and that the ones
deployed to the Eastside area by SeaTac International Airport would be too late to respond to an
emergency.
Another commenter asked how the elderly and disabled would be assisted in the event of a pipeline
incident.
Response:
Potential effects on public services are described in Section 15.4 of the Phase 1 Draft EIS. The analysis
found that existing local service providers are expected to be adequate to address the demand for fire
and other emergency response for most incidents that could occur during construction and operation of
the transmission lines. The demand for emergency services during operation would be similar to the
existing demand under current conditions (No Action Alternative).
The Phase 1 Draft EIS does not claim that earthquakes are not a real possibility in this region, or that
emergency responders would not be needed for such an event. Section 15.6.3 of the Phase 1 Draft EIS
states that there would be a need for emergency response if an earthquake, storm, or accident were to
result in a fire, explosion, or spill along the existing transmission lines or at a substation. However, the
need for such emergency services would be the same under the No Action Alternative and Alternative
1. An expanded description of seismic hazards is provided in Section 4.11 of the Final EIS.
For the Phase 1 Draft EIS, potential effects on public services were determined by reviewing
comprehensive plans and policies of each jurisdiction, conducting phone interviews with the major
police and fire departments. The Bellevue Fire Department Standards of Response Coverage Report
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was not identified as a source by the Bellevue Fire Department at the time and was not reviewed by the
EIS Consultant Team during the development of the Phase 1 Draft EIS. Based on policy and code
review, it was determined that no unavoidable significant adverse impacts to public services would
occur from either construction or operation of the project alternatives, so long as appropriate mitigation
measures are implemented. Review of the Bellevue Fire Department Standards of Response Coverage
Report suggests that potential impacts in the Phase 1 Draft EIS were generally consistent with that
report, but the Phase 1 Draft EIS and Phase 2 Draft EIS did not mention under mitigation measures that
additional resources from other jurisdictions could likely be required if there were a major incident on
the pipeline system. In the Bellevue Fire Department Standards of Response Coverage Report,
petroleum pipeline fires are classified as having a special risk (that is unlikely to occur) and a
potentially significant community impact. These findings are consistent with the findings in the Phase 1
and Phase 2 Draft EISs. The report also states that "response and recovery from a significant pipeline
event would deplete the response and mitigation abilities of the jurisdiction." Bellevue Fire Department
notes that it has agreements with other fire districts and emergency response providers that would
provide additional support in such a scenario, and that the rest of the community would remain
protected.
The Bellevue Fire Department was interviewed in October 2015. When asked if they had the staff,
training, and equipment to respond to an Olympic Pipeline system explosion and fire and a natural gas
line explosion and fire, they stated that they do, but staff, training, and equipment could be more
extensive. The City of Bellevue, like other jurisdictions, analyzes risks and makes a determination as to
the ‘reasonable’ needs of the City while contemplating the cost of these services. High impact events
such as a pipeline fire are similar to other special risks such as earthquakes, high-rise fires, or a volcanic
eruption triggering a lahar, where even with extensive training, back-up is likely to be needed
(Adolfson, 2017). If an event exceeds the City of Bellevue Fire Department capabilities, then
surrounding fire and emergency medical service agencies would provide back-up in accordance with
existing agreements.
Gasoline, jet fuel, and diesel fuel generally do not explode unless under pressure, which would not be
the case for fuel in an accidental release; therefore, it is unlikely that an explosion such as those that
occurred in Greenwood, Lynnwood, and Tukwila (which occurred because of a natural gas release)
would occur along the Olympic Pipeline system. Natural gas can spread vertically and permeate
surrounding areas more easily and have a higher potential for a large-scale impact. For a buried pipeline
transporting refined petroleum product, the greatest risk to the public is posed by pool fires, which are
restricted to ground level flow limiting the area of potential impact to the location immediately
surrounding the area of release (see additional discussion in the Final EIS on potential variation in pool
fire size based on site-specific conditions along the project corridor). Although an explosion is not
likely, a pipeline rupture would be extremely hazardous for emergency personnel as well as civilians.
For more information, see Section 3.9.4 and Appendix I of the Phase 2 Draft EIS.
According to the Bellevue Fire Department Standards of Response Coverage, flow and pressure are
controlled by computers in Olympics’ Control Center in Renton. Check valves, hand-operated valves,
and remotely-operated valves are utilized throughout the system. Check valves prevent backflow, hand-
operated valves are shut by Olympic personnel in the field (this can take over an hour depending on
traffic), and remotely-operated valves are controlled by Olympics’ Control Center in Renton (which
can take approximately 45 to 90 seconds to completely close using a computer-enhanced system)
(Bellevue Fire, Undated). The maximum release volume for the Olympic Pipeline system was
evaluated in greater detail in the Phase 2 Draft EIS, and it was estimated that approximately 370,000
gallons could be released (see Section 3.9.4). Validating Olympic’s system operation is outside of the
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scope of the EIS for the Energize Eastside project. Olympic, as the pipeline operator, is responsible for
operating and maintaining their pipelines in accordance with federal standards.
Olympic’s Facility Response Plan is not made available to the public. Rather, it is shared with federal,
state, and local officials, including emergency planning agencies and first responders, to strengthen and
coordinate planning and prevention activities, with certain key information redacted due to potential
security risk. The plan provides guidelines to prepare for and respond to a spill from the Olympic
Pipeline system. The Facility Response Plan, which received final 5-year approval by Ecology in 2016,
serves as Olympic’s oil spill contingency plan under WAC 173-182. The Facility Response Plan is
based on the Northwest Area Contingency Plan (Regional Response Team 10 and Northwest Area
Committee, 2016), as approved by Ecology and the federal Pipeline Hazardous Materials Safety
Administration. Section 15.3.1.3 of the Phase 1 Draft EIS states that the local fire department and
Olympic technical staff would be contacted simultaneously, but fire departments within other
jurisdictions could be dispatched as backup, as could Olympic, Port of Seattle Fire Department, and
Boeing for backup equipment and fire suppression supplies.
The comment on insufficient AFFF trucks is correct. In such an event, City of Bellevue Fire
Department fire responders would likely allow the petroleum release to burn off while Olympic shut
down the flow. This would be safer than trying to extinguish the fire and thereby risk a larger
subsequent fire or continued seeping in to the environment.
The Phase 1 Draft EIS found there would be no unavoidable significant adverse impacts to public
services due to construction or operation of the Energize Eastside project. Mitigation measures can
limit but cannot eliminate the risk of a catastrophic release and fire on the pipelines, which is possible
under both the No Action Alternative and any of the action alternatives. Some of the risk of pipeline
release is attributable to proximity to transmission lines and the pipelines, both existing and proposed,
as noted in Section 3.9 of the Phase 2 Draft EIS. This low probability/high consequence risk is
considered a potential significant impact because it could exceed the capacity of available resources
should such an event occur in any of the affected communities. With the mitigation measures noted in
Section 3.9 of the Phase 2 Draft EIS, the Energize Eastside project would not likely increase the risk,
and could decrease the probability of some aspects of the risk of an accidental release from the
pipelines. Incremental change to risks to human health, safety, and the environment as a result of the
Energize Eastside project are discussed in Section 3.9 of the Phase 2 Draft EIS.
Mitigation measures for impacts to public services are included in Section 15.7.2 of the Phase 1 Draft
EIS to minimize impacts on response times, including requiring the contractor to prepare “maintenance
of traffic” plans for any work within the public right-of-way. The Cities will require right-of-way use
permits that address traffic, safety, etc. wherever the project crosses or is within a public right-of-way.
Emergency response personnel are trained in proper response protocol and procedures to protect their
safety and the public's safety when responding to incidents. The Phase 2 Draft EIS provides additional
information on protections in place to prepare for and respond to an incident (see Section 3.9.2.2) as
well as measures to minimize the potential for pipeline incidents that could occur as a result of
construction or operation of the project. In terms of the financial impact of the provision of services, the
contractor would be responsible for providing (and paying) for traffic control presence.
Because the risks associated with the transmission lines and pipelines are not expected to increase
substantially as a result of the Energize Eastside project, insurance rates for police and other emergency
responders are not expected to increase; therefore, no specific measures are proposed as mitigation.
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The emergency responders would address the elderly or disabled during or after a pipeline incident by
evacuating those in immediate danger and evaluating who they could “protect in place,” with frequent
evaluations of their safety level as the incident evolves. This is the same approach to what emergency
responders would do for other similar high impact incidents.
Key Theme SVC‐2: Interference with communication devices
Comment Summary:
Commenters stated that if the project interfered with radio or television reception it would negatively
impact nearby residents. Another commenter stated that the Phase 1 Draft EIS fails to address radio
frequency interference that the proposed 230 KV transmission lines will likely cause to Personal Radio
Service (PRS) licensees along the proposed transmission line route. The commenter noted that PRS
must operate at lower frequencies, at lower transmitter power, and over longer transmitter-to-receiver
distances and with different modulation types; therefore, PRS is more susceptible to power line
interference than those that have been addressed in the Phase 1 Draft EIS.
Commenters also stated that corona produced by the project would interfere with emergency 911 back-
up communication within 2,000 feet of the project, impacting radio broadcasting capabilities during
natural disasters. Commenters asked for clarification regarding the statement in the Phase 1 Draft EIS
that: “electrical engineers will usually design overhead transmission lines to comply with recommended
maximum conductor surface gradient values set forth in the Institute of Electrical and Electronics
Engineers.”
Response:
Section 15.6.2 of the Phase 1 Draft EIS states that overhead transmission lines do not generally
interfere with radio or television reception. Whenever corona is a problem, it is usually for amplitude
modulation (AM) radio and not the higher frequencies associated with frequency modulation (FM)
radio or TV/satellite signals. Therefore, it is possible that some residents near the transmission lines
would notice interference with AM stations. Section 15.6.4.1.3 of the Phase 1 Draft EIS states that
corona interference is not considered a problem for transmission lines rated at 230 kV and below. No
corona-generated interference with police and emergency personnel communication/emergency devices
is anticipated, and to comply with FCC regulations, PSE would work with owners and operators of
communications facilities along the transmission lines to identify and implement mitigation measures if
interference should occur. See Section 15.6.2 for additional information.
The Institute of Electrical and Electronics Engineers study cited is a design guide that electric
transmission line designers use in designing overhead lines. PSE would design the new 230 kV lines in
consideration of these reference guidelines.
Key Theme SVC‐3: Safety measures and plans
Comment Summary:
Commenters asked about the operational safety requirements for new or upgraded transmission lines
and if the City of Bellevue or Eastside Fire and Rescue need to invest in any specific equipment or
update emergency response plans to account for the proposed transmission lines.
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Commenters inquired if construction activities would hinder emergency access to their property or
would result in increased response time for emergency responders, such as when wires are pulled
during construction.
Commenters asked for clarification regarding the statement in the Phase 1 Draft EIS that: “Stronger
laws are in place that require monitoring for digging that occurs near the pipeline.” PSE stated that
because Olympic conducts aerial reconnaissance of the corridor weekly, unauthorized work near the
pipelines and transmission lines is monitored on a regular basis.
One commenter asserted that the transmission line towers would pose a safety risk for small aircraft.
Response:
Section 15.6 of the Phase 1 Draft EIS describes the operational impacts on public services at a
programmatic level. Section 15.6.1 states that operation of new transmission lines, expanded
substations, distributed generation, generators, and energy storage facilities associated with the
alternatives could increase demand for emergency services in the study areas. However, with the
appropriate mitigation measures in place, no unavoidable significant adverse impacts to public services
are anticipated from either construction or operation of the Energize Eastside project. The need for new
equipment or updated emergency response plans was not identified, but it would be at the discretion of
emergency service providers to determine if additional equipment or planning would be needed to
conform with industry standards and regulatory requirements. First responders were interviewed for the
Phase 1 assessment. Current safety measures, including emergency service providers, levels of service,
and response times, are detailed in Section 15.3 of the Phase 1 Draft EIS.
Access to residential and commercial properties would be maintained at all times (see Section 14.7 of
the Phase 1 Draft EIS). The wire-stringing operation requires the use of temporary pulling or tensioning
sites that are typically 2 to 3 miles apart; at a given location, stringing the wires across the pole occurs
within 1 or 2 days (see Section 2.1.3 of the Phase 2 Draft EIS).
The Phase 1 Draft EIS broadly evaluates pipeline safety and applicable requirements for work near the
pipelines, including laws that have been strengthened in recent years, such as Washington State’s
Damage Prevention Law and the “one-call” locator service law. For the Phase 2 Draft EIS, a more
detailed pipeline safety risk assessment was conducted to further evaluate pipeline safety risks,
including construction risks. In addition to Washington State’s Damage Prevention Law and “one-call”
locator service law, Olympic has a list of requirements for all work proposed near their pipelines. This
includes specific requirements related to work within 100 feet of the pipelines. Regarding the driving of
vehicles over the pipelines (surcharge loads), these risks are described in Section 4.9.3 of the Phase 2
Draft EIS. As part of Olympic’s construction requirements, PSE will provide all necessary information
for Olympic to perform pipe stress calculations of equipment crossings and surface loads. Based on
pipe stress calculations, and in coordination with Olympic, PSE will provide additional cover that may
include installing timber mats, steel plating, or bridging, or avoid crossing in certain identified areas.
This, and other mitigation measures related to surcharge loads, are included in Section 4.9.4.1 of the
Phase 2 Draft EIS. Section 15.3.1.3 of the Phase 1 Draft EIS states that Olympic flies the pipeline
corridor once per week to check for discoloration of the grass or other anomalies and to ensure
unauthorized digging is not occurring within the easement.
As noted in Section 11.6.3.4 of the Phase 1 Draft EIS, the Federal Aviation Administration (FAA) has
standards and guidelines that determine when structures need to be marked and lighted for aircraft
safety. Aviation warning lights would not be required for this project because the proposed electrical
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infrastructure (including transmission poles) would be less than 200 feet in height and would not
exceed the FAA’s obstruction standards in 14 CFR Part 77.
Key Theme SVC‐4: Reliable energy is required for community services to operate
Comment Summary:
The Bellevue Medical District requested that the project ensure PSE can supply reliable electricity to
serve the expanding Eastside region. The Medical District noted that if PSE's infrastructure is not
equipped to serve projected customer energy demands in Bellevue and throughout the Eastside, there
would be a “crippling effect on their ability to accommodate the health and safety needs of the local
community.” They noted that it would become a major public safety issue if their hospitals and medical
facilities are not powered in a consistent and reliable way.
Response:
Since publication of the Phase 1 Draft EIS, PSE has clarified how the project relates to reliability. PSE
is proposing the project to meet regulatory requirements that relate to protection of the regional
transmission grid that could result if PSE were to have an equipment failure in its transmission system.
Many commenters have conflated distribution reliability concerns, which are far more common, with
transmission system reliability. The transmission system improvement that PSE is proposing is
designed to avoid a potential future reliability issue that they expect to develop as a result of growth in
demand for electricity at peak times. PSE has determined that, without the project, under certain
circumstances the Eastside communities would need to be placed at risk of load shedding (deliberate
power outages) in order to protect the regional grid. The degree of additional system reliability
provided by the Energize Eastside project is nearly impossible to predict or quantify because of the
complexity of the system and the variety of factors that can cause equipment failure. The likelihood of
the need for load shedding is different from reliability problems with the electrical distribution system
in Bellevue and other areas of the Eastside. Please see the response to Key Theme OBJ-1.
Key Theme SVC‐5: Minor clarifications
Comment Summary:
In the context of emergency access, PSE stated that a Consent Agreement between PSE and property
owners allows for a shared lock system for fences, gates, and structures within PSE’s easement. PSE
also stated that 230 kV systems are typically constructed using steel poles rather than wood; therefore,
operationally, pole replacement frequency would be reduced as compared with the existing 115 kV
system. Also, steel poles are stronger and less susceptible to weather impacts.
Response:
No changes have been made to the EIS in response to this comment. The description in Section
15.6.4.1.2 of the Phase 1 Draft EIS provides the appropriate level of detail for this high-level
assessment, and these comments do not affect any of the conclusions of the EIS. As stated in Section
15.6.4.1.1 of the Phase 1 Draft EIS: "The same types of hazards and potential need for emergency
services related to operation of new 230 kV transmission lines in proximity to the Olympic Pipeline are
already present with the existing 115 kV lines and would remain similar with a 230 kV line…”
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Utilities (Topic UTL)
This section describes and responds to the comments received on the Phase 1 Draft EIS regarding
utilities. Primary themes included impacts to other utilities, utility disruptions caused by terrorism or
natural hazards, utility oversight, co-location with the Olympic Pipeline system, conclusions of the
Phase 1 Draft EIS assessment, and clarification and errors identified by PSE. There were also
comments about Chapter 16, Utilities, regarding PSE’s statement of need for increased reliability; these
comments are addressed in Topic OBJ.
Key Theme UTL‐1: Impacts to other utilities
Comment Summary:
One commenter asked about interference with home electronics and appliances. The commenter also
inquired how the project might interfere with cell phone towers attached to the water tower on 12th Ave
North (sic). (Because there is no 12th Ave North in the area referred to in the comment, presumably this
refers to a water tower near 12th Ave NE.) The Somerset Recreation Club (SRC) stated that there is a T-
Mobile cell tower on one of the existing 115 kV H-frames on SRC’s property; they requested that it be
protected because it provides cell coverage in the area and the rental income is “essential to SRC
operations.” Commenters stated that the natural gas, other telecommunications systems, water, and
wastewater utilities in the area have not been identified and will potentially be impacted.
The King County Wastewater Treatment Division (WTD) reviewed the Phase 1 Draft EIS and
determined that, due to the programmatic nature of the document, it did not have enough information to
comment on the physical impacts to specific facilities, access to facilities for maintenance, or
permanent easements associated with these facilities. WTD requested that design drawings be
submitted as the design of specific alternatives continues.
Response:
Section 15.6.2 of the Phase 1 Draft EIS describes the potential for interference with other electronic
communications equipment. It does not address any specific locations, but indicates that interference is
unlikely due to frequency differences and distance. Specifically for cellphone transmission, it is not
uncommon for cellphone transmission sites to have objects that are taller than them, including trees,
hills, and buildings. Cellphone providers determine how much interference such objects cause for their
service and add sites if necessary. None of the cellphone providers in the region has indicated that any
interference with their service is expected from the Energize Eastside project.
If the project is constructed, PSE will work with telecom companies to reinstall cellular equipment onto
the new 230 kV poles, subject to the requirements of Chapter 80.54 RCW, Chapter 480-54 WAC, and
local jurisdiction regulations.
Utilities present within the combined study area are described programmatically in Section 16.3 of the
Phase 1 Draft EIS.
PSE will continue to coordinate with WTD as the project design is refined. WTD was provided a copy
of the Phase 2 Draft EIS and this Final EIS.
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Key Theme UTL‐2: Utility disruptions caused by terrorism or natural hazards
Comment Summary:
A commenter noted that the Phase 1 Draft EIS does not mention the possibility of the project being a
target for physical or cyber terrorism. The commenter referenced Ted Koppel’s book Lights Out, and
stated that an attack on such infrastructure could cause “months of hardship.” The commenter stated
that PSE may have increased the likelihood of such an incident as a result of the public involvement
effort for this project. Commenters also stated there should be more information about the potential
security threats. Another commenter stated that building one single line without redundancy makes the
system more vulnerable to disruptions caused by construction accidents, natural causes (storms, floods
and earthquakes), or malicious intent (terrorism).
Response:
Public safety risks associated with terrorist attacks are discussed in the Phase 1 Draft EIS as an
unlikely, but possible worst-case scenario. However, the project is not expected to increase the risk of
terrorist or other malicious attacks. While public awareness of this transmission line has increased
because of the EIS process, there is no reason that the project would become a more likely target of
such action because of the Energize Eastside project. Impacts associated with natural hazards are
described in Chapter 3 of the Phase 1 Draft EIS.
Redundancy is considered by PSE as part of its long-range planning efforts. The proposed Energize
Eastside project includes two 230 kV lines feeding the new substation in the center of the Eastside, one
from the north and one from the south. This allows the substation to be powered from either direction,
in the event one of the lines is damaged or out of service.
Key Theme UTL‐3: Utility oversight
Comment Summary:
One commenter stated that they hoped Newcastle would adopt policies that encourage use of new or
innovative technologies to increase the quality and efficiency of utility service. A commenter stated that
PSE needs oversight and noted that the Washington Utilities and Transportation Commission (WUTC)
did not approve of PSE’s Integrated Resource Plan (IRP). They added that the WUTC would not grant
PSE the ability to charge ratepayers for the Energize Eastside project. One commenter stated that the
WUTC should stop the project from being built over the Olympic Pipeline system, stating that the
Olympic Pipe Line Company was put on notice to make corrosion repairs in 2014, which it still has not
completed.
Response:
Although the City of Newcastle is one of the Partner Cities in preparing this EIS, the EIS does not
address whether or not Newcastle should consider changes to their policies regarding innovative
technologies.
The WUTC regulates private, investor-owned electric and natural gas utilities in Washington. It is the
commission's responsibility to ensure that regulated companies provide safe and reliable service to
customers at reasonable rates, while allowing them the opportunity to earn a fair profit. The WUTC has
authority to allow or disallow PSE to recover costs for the project once it is built. The WUTC does not
regulate the siting or construction of transmission lines.
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The IRP process is a separate regulatory process from the setting of rates and relates to the sources of
power that PSE plans to use to provide electricity to its customers. The IRP is not related to
transmission line planning, except to the degree that, if a potential source of power were inaccessible
because of transmission capacity, the IRP could include plans to improve transmission capacity. That is
not the case with Energize Eastside.
The WUTC also regulates the Olympic Pipeline system, including oversight of safety planning,
inspection, and reporting. WUTC regulation of the Olympic pipeline system is independent from PSE’s
project.
Key Theme UTL‐4: Co‐location with Olympic Pipeline system
Comment Summary:
Regarding the co-located Olympic Pipeline system, a commenter asked the following: when the last
inspection date was, if any anomalies exist and if they have been repaired, how often block valves are
tested and if the test results are available to the public, how a leak is detected for a pipeline located
under a street, the percentage of pressure drop in the pipeline required to set off an alarm, and what the
minimum acceptable thickness of the pipeline wall is to meet applicable regulations. A commenter
asked if Olympic has the legal authority to deny PSE’s project; the same commenter asked if liability is
assigned to Olympic, PSE, or another party if there were a pipeline explosion.
A commenter asked if upgrading the line from 115 kV to 230 kV would require changes in the cathodic
protection system for the Olympic Pipeline system and, if so, how and when the changes would be
implemented. The commenter also asked for clarification regarding the statement in the Phase 1 Draft
EIS that there would be potential disruption to existing natural gas lines or the Olympic Pipeline system
during construction of the project.
Response:
The Energize Eastside project is proposed by PSE and not by Olympic. Questions about pipeline
inspections and test results should be directed to Olympic or the WUTC (website address:
https://www.utc.wa.gov/Pages/Default.aspx). In response to questions about pipeline safety, the Phase
2 Draft EIS included a probabilistic risk assessment that took into account some of the information
requested by the commenters.
Olympic is responsible for operating its pipeline system safely. This includes protecting it from
corrosion caused by overhead transmission lines, as well as other potential damage, such as
construction, or corrosion caused by groundwater or soil.
For the proposed Energize Eastside project, the annual test post cathodic protection survey data should
be reviewed prior to construction. During operation, the necessary information should be provided to
Olympic so that it can record AC and DC pipe-to-soil potentials during the annual cathodic protection
survey. This will assist Olympic in detecting any changes in corrosion potential resulting from the
transmission lines (see Section 3.9.7 of the Phase 2 Draft EIS). If the cathodic protection needs to be
changed to address the effects of the project, it is the responsibility of the pipeline operator to make
those changes.
Olympic does not have legal authority to deny PSE’s project. If there were a pipeline explosion (or leak
or fire), the liability would depend on the cause. Olympic is responsible for protecting its pipelines
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from corrosion such as that caused by AC interference, but if the pipelines were damaged by an activity
like excavation, the responsibility could also fall on other parties.
Key Theme UTL‐5: Conclusions of the Phase 1 Draft EIS
Comment Summary:
Commenters asked why the Phase 1 Draft EIS states that the No Action Alternative would result in
moderate to significant impacts on utilities. Commenters asserted that ColumbiaGrid has resources to
mitigate the stated impacts if PSE did not build the Energize Eastside project; therefore, the impact on
utilities for the No Action Alternative should be "negligible." Commenters also stated that the assertion
in the EIS that there would be a reliability risk under Alternative 2 is false due to ColumbiaGrid
resources.
Commenters asked for information supporting the claim that the No Action Alternative would
experience minor effects from hazards due to conformance with industry standards and regulatory
requirements, with the Greenwood explosion provided as an example. Commenters also inquired why
the risks due to maintenance activities would be the same for 230 kV and the 115 kV transmission
lines, given that their structures are very different. Commenters also stated that 115 kV poles do not
have foundations and asked why the Phase 1 Draft EIS implies that they do.
Response:
PSE has stated that this project is needed in part to protect the regional grid from harm that could result
from overloading of PSE’s system due to growing demand within the Eastside. Consistent with NERC
requirements, PSE cannot pass that responsibility off to its regional partners in ColumbiaGrid. Also,
ColumbiaGrid does not have a project that proposes to address the transmission capacity issue within
the Eastside. Therefore, the EIS does not assume that ColumbiaGrid will address the issue if PSE does
not. Similarly, for Alternative 2 of the Phase 1 Draft EIS, it cannot be assumed that ColumbiaGrid will
take action if Alternative 2 failed to address the capacity deficiency identified by PSE. For more
information, see Chapter 1 of the Phase 1 and Phase 2 Draft EISs.
Conformance with industry standards and regulatory requirements would ensure that potential hazards
are identified and design plans developed to minimize adverse effects from these hazards to minor
levels. The Partner Cities are aware that PSE was found to have not complied with regulatory
requirements in the case of the Greenwood natural gas pipeline explosion. For SEPA purposes, the
Partner Cities need to take this into account in making their permit decisions, including possibly
placing conditions on PSE for additional reporting to ensure compliance with all safety regulations.
Maintenance activities required for 115 kV transmission lines are similar to those for 230 kV lines,
despite their differences in height and form. One difference is that most 115 kV lines are on wood
poles, while most 230 kV lines are on metal poles. Thus, periodic pole replacement could be different.
It is true that typically no foundations are used for wooden poles. In many cases, metal poles are also
directly embedded in the ground and have no foundation. In some cases, 115 kV lines are placed on
metal poles, and in a few places, those poles require foundations due to soil conditions or other
structural factors, such as whether the pole is a terminal pole or turning point in the line. While both
115 kV lines would be likely to have fewer poles with foundations than 230 kV lines, the overall
maintenance activities would be similar for both types, except for those few locations where a 230 kV
line would need a foundation and a 115 kV line would not.
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Key Theme UTL‐6: PSE clarifications and Errata
Comment Summary:
PSE stated that if an existing utility corridor is used, they will commission an engineering analysis to
evaluate soil conditions as they relate to conductivity and corrosiveness of existing underground
utilities. PSE noted that such a study is used to help them determine the appropriate grounding and
cathodic protection. PSE added that all steel pipelines are required to have cathodic protection
regardless of their proximity to a power line. In areas where transmission lines and pipelines are co-
located, PSE said it works with the pipeline operator to ensure that appropriate engineering analysis is
performed so that if any modifications to the pipeline's cathodic protection are necessary, they can be
made. PSE stated that they would work with Olympic to evaluate the construction and operational
parameters related to the replacement of the two existing 115 kV lines with both a 230 kV and a 115
kV line, including electrical interaction potential, cathodic protection, and proximity.
PSE clarified that the proposed project would replace the existing 115 kV lines with one 230 kV line
and one high capacity 115 kV line. PSE stated that oftentimes road rights-of-way have more co-located
utilities in them, thereby leading to a higher risk of disruption.
For information purposes, PSE stated that the 230 kV substations will have several dead-end towers
with a height of 65 feet. If new 115 kV line were sited with an existing 115 kV line, the circuits could
be on both sides of the pole or on taller poles with the circuits on the same side of the pole.
Regarding Alternative 2 in the Phase 1 Draft EIS, PSE estimated that more than 15 miles of high
pressure natural gas pipeline would need to be installed, and also said other utilities may need to be
upgraded if peaker plants are necessary. PSE also stated that for alternatives that utilize a battery
facility, a new substation would be required at the facility. An existing substation could be expanded to
support the battery facility, but no existing substations in the Bellevue area have enough room for
expansion.
PSE said that regulations regarding colocation of high consequence land uses with hazardous materials
pipelines only prohibit new uses within proximity to the existing corridor, and that there are no policies
that discourage co-location. They noted that Kirkland and Redmond have policies regarding new uses,
which are designed to minimize risk.
PSE stated that the reference to the Bothell-SnoKing double-circuit 230 kV line should have been the
Maple Valley-SnoKing double-circuit 230 kV line, and that the BPA Maple Valley substation is next to
PSE Talbot Hill substation with two connections to Talbot Hill. PSE noted that Olympic has a franchise
agreement with the City of Bellevue, which was passed in early 2016. PSE stated that the claim that
“two new substations may be needed” is incorrect, and that only two new transformers are required.
PSE stated that it is considering expanding the Lakeside and Westminster substation sites, not the
Vernell substation. It also noted that Vernell is not an existing substation; therefore, it could not be
expanded. In addition, PSE noted that there are many foundations associated with the proposed project,
including dead-end towers, the control house, etc. PSE clarified that it would completely remove the
old lines and rebuild the existing SCL 230 kV lines under Alternative 1, Option B.
PSE stated that the SR 520 Improvement Project should not be included in the cumulative impacts for
the project because SR 520 was completed on the Eastside from Medina to I-405, and the floating
bridge portion opened in April 2016.
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Response:
Clarifications and identified errors were provided and rectified in the Errata regarding BPA facilities,
Olympic franchise agreements, foundations, substations, and improvements to the SCL corridor. See
Chapter 3 of the Final EIS. PSE also provided numerous other minor clarifications that have not been
included in the Errata, primarily because they relate to Phase 1 alternatives that are no longer being
considered, they are minor clarifications (as opposed to factual errors), and they do not influence the
results or conclusions of the analysis. The full letters are included in this Appendix J, following the
narrative summary. Regulations and policies that prohibit colocation of high consequence land uses
with hazardous material pipelines are further evaluated in Section 3.1 of the Phase 2 Draft EIS. The SR
520 Improvement Project was not included in the cumulative impacts in Phase 2 of the EIS.
FINAL EIS PAGE J1‐106
APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
References:
Adolfson, A. 2017. E-mail from Andy Adolfson, Deputy Chief of Operations, City of Bellevue Fire
Department. Subject title “E2 Fire Dept Review AA2,” dated September 6, 2017. Sent to Heidi
Bedwell, City of Seattle. With attachment.
Arun, P.R. 2015. Environmental impacts of electro-magnetic fields; A review report submitted to the MoEF
expert committee on communication towers on birds & bees. Research. June 2015. Available at:
https://www.researchgate.net/publication/277813116_Environmental_Impacts_of_Electro-
magnetic_fields_A_Review_Report_Submitted_to_the_MoEF_Expert_committee_on_communicati
on_towers_on_birds_bees.
Bartomeus, I., and B. Hill. 2015. Maintained electrical transmission corridors can provide valuable
bumblebee habitat for conservation and ecosystem service provision. Cold Spring Harbor
Laboratory, bioRxiv. Available at: https://doi.org/10.1101/027078.
Doherty, P.F., and T.C. Grubb Jr. 1998. Reproductive Success of Cavity-nesting Birds Breeding under
High-voltage Powerlines. The American Midland Naturalist, Vol 140 (1) 122-128.
Earthquake Engineering Institute and Washington Military Department Emergency Management
Division. 2005. Scenario for a Magnitude 6.7 Earthquake on the Seattle Fault. June 2005.
Enertech Consulting. 2016. Technical Memo on Power-Frequency Electric and Magnetic Fields
Related to the Puget Sound Energy Energize Eastside Project.
Fernie, K.J., and S.J. Reynolds. 2006. The Effects of Electromagnetic Fields from Power Lines on Avian
Reproductive Biology and Physiology: A Review. Journal of Toxicology and Environmental
Health, Part B Vol. 8 (2).
Fernie, K.J., D.M. Bird, R.D. Dawson, and P.C. Laguë. 2000. Effects of Electromagnetic Fields on the
Reproductive Success of American Kestrels. Physiological and Biochemical Zoology 73, no. 1
(January/February 2000): 60-65.
Regional Response Team 10 and Northwest Area Committee. 2016. Northwest Area Contingency Plan.
Available: http://www.rrt10nwac.com/nwacp/. January 1, 2016. Accessed: September 13, 2016.
Sheppard, A.R. 2015. Memorandum to ESA from Dr. Asher Sheppard, PhD concerning updating prior
reports on powerline health effects issues. November 25, 2015.
Sheppard, A.R. 2017. Memorandum to ESA from DR. Asher Sheppard, PhD concerning public
comments on EMF and corona health impacts. December 23, 2017.
Stantec. 2015. Energize Eastside Project Memorandum from Keith DeClerck to Mark Johnson, dated
July 31, 2015. Available at http://www.energizeeastsideeis.org/library.html.
Tatos, T., M. Glick, and T.A. Lunt. 2016. Property Value Impacts from Transmission Lines,
Subtransmission Lines, and Substations. The Appraisal Journal. Available:
https://www.appraisalinstitute.org/assets/1/7/TAJ_Preview_Front_Page.pdf. Accessed:
November 2016.
FINAL EIS PAGE J1‐107
APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
The Watershed Company. 2016. Tree Inventory: Energize Eastside Project. Includes the following
separate reports: City of Bellevue Tree Inventory Report; King County Tree Inventory Report;
City of Newcastle Tree Inventory Report; City of Redmond Tree Inventory Report; City of
Renton Tree Inventory Report; Richards Creek Parcel Tree Inventory Report; Segment O Tree
Inventory Report; Segment P Tree Inventory Report; and Bypass Routes 1 and 2 Tree Inventory
and Analysis Report. Prepared for Puget Sound Energy, Bellevue, WA. Prepared by The
Watershed Company, Kirkland, WA. May and July 2016.
Tomás, G., E. Barbab, S. Merinoa, and J. Martínezc. 2012. Clutch size and egg volume in great tits (Parus
major) increase under low intensity electromagnetic fields: A long-term field study. Environmental
Research, Vol 118.
Tyler, N., K. Stokkan, C. Hogg, C. Nellemann, A. Vistnes, and G. Jeffery. 2014. Ultraviolet Vision and
Avoidance of Power Lines in Birds and Mammals. Conservation Biology. Vol 28(3) 630-631.
USDOE (U.S. Department of Energy). 2015. National Electric Transmission Congestion Study.
Washington, DC. September 2015.
Vaitkuvienė, D., and M. Dagys. 2014. Possible effects of electromagnetic field on White Storks Ciconia
breeding on low-voltage electricity line poles. Journal of Zoology and Ecology, Vol 24 (4) 2014.
FINAL EIS
APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
APPENDIX J-2.
REPRODUCED COMMENT LETTERS AND CROSS-
REFERENCES TO KEY THEME RESPONSES
Note: Because of its length, Appendix J‐2 is included as Volume 3, as a separate PDF.
Appendix K:
Phase 2 Comments and Responses
K
FINAL EIS
APPENDIX J PHASE 1 COMMENTS & RESPONSES MARCH 2018
APPENDIX K.
PHASE 2 COMMENTS AND REPONSES
Note: Because of its length, Appendix K is included as Volume 4, as a separate PDF.
Appendix L:
Comparison of Data Sources
L
FINAL EIS PAGE L‐1
APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018
APPENDIX L. COMPARISON OF EIS DATA
SOURCES
PSE continued to refine the design of the proposed project from when the Phase 2 Draft EIS was
published (in May 2017) and as the analysis was being conducted for the Final EIS. In particular, PSE
submitted two permit applications to the Cities of Bellevue and Newcastle for the initial phase of project
construction; the permit applications included more detailed, site-specific information for portions of the
project alignment (namely, the Bellevue South Segment, the Richards Creek substation site, that portion
of the Bellevue Central Segment that contains the Lakeside substation, and the Newcastle Segment). The
permit applications include refined, site-specific information for project components such as proposed
pole types and locations, as well as vegetation survey and clearing data. The Partner Cities decided that
the analysis in the Final EIS should reflect the most up-to-date data and information, which because of the
permit applications differs in level of detail from segment to segment.
Appendix L was prepared to assist the reader and reviewer understand the relationship between the data
sources used in the Phase 2 Draft EIS and the Final EIS documents. It summarizes and compares the
source material and results, organized by element of the environment and project segment. Because the
data sources used for the Redmond, Bellevue North, Bellevue Central (excluding the Lakeside
substation), and Renton Segments are substantively the same as those used for the Phase 2 Draft EIS, the
material in Appendix L focuses on the segments associated with the permit applications. It focuses on the
following project components and analyses: pole location data, critical areas data, construction access
data, and tree clearing data.
FINAL EIS PAGE L‐2 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Scenic Views & Aesthetic Environment Phase 2 Draft EIS Final EIS (Permit Application) Richards Creek Substation Data Source(s) Data Source(s) The Watershed Company, 2016 and accompanying GIS data. The Watershed Company, 2017 and accompanying GIS data. Energize Eastside Vegetation Management Plan, August 30, 2017. Pole Data Tree Data Pole Data Tree Data N/A No trees were inventoried or identified for removal adjacent to the Lakeside substation. N/A Near the Lakeside substation, approximately 43 trees would be removed. Notes: Tree removal next to the Lakeside substation results in the Richards Creek substation being more noticeable from the northeast than was evident in the Phase 2 Draft EIS.
FINAL EIS PAGE L‐3 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Scenic Views & the Aesthetic Environment Phase 2 Draft EIS Final EIS (Permit Application) Bellevue Central Segment Data Source(s) Data Source(s) Strauch, B. 2016. Email (with attachment) from Bradley Strauch, Sr. Land Planner/Environmental Scientist, PSE, to Claire Hoffman and Reema Shakra, ESA, regarding information and data for the Energize Eastside Project. August 16, 2016. The Watershed Company, 2016 and accompanying GIS data. PSE. 2017. Emails from Bradley Strauch, Energize Eastside Project Manager, PSE, to Reema Shakra and Mark Johnson, ESA. August 23, 2017, and December 1, 2017. The Watershed Company, 2017 and accompanying GIS data. Energize Eastside Vegetation Management Plan, August 30, 2017. Pole Data Tree Data Pole Data Tree Data 95’-115’ tall double-circuit steel monopoles No trees were inventoried or identified for removal adjacent to the Lakeside substation. 94’-113’ tall double-circuit steel monopoles. Near the Lakeside substation, approximately 43 trees would be removed, including trees near Chestnut Hill Academy. Notes: The Bellevue Central Segment is not in the permit application, except for the area near the Lakeside substation. Pole types have not changed substantively. An additional 43 trees would be removed adjacent to the Lakeside substation.
FINAL EIS PAGE L‐4 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Scenic Views and the Aesthetic Environment Phase 2 Draft EIS Final EIS (Permit Application) Bellevue South Segment Data Source(s) Data Source(s) Strauch, B. 2016. Email (with attachment) from Bradley Strauch, Sr. Land Planner/Environmental Scientist, PSE, to Claire Hoffman and Reema Shakra, ESA, regarding information and data for the Energize Eastside Project. August 16, 2016. The Watershed Company, 2016 and accompanying GIS data. PSE. 2017. Emails from Bradley Strauch, Energize Eastside Project Manager, PSE, to Reema Shakra and Mark Johnson, ESA. December 1, 2017. The Watershed Company, 2017 and accompanying GIS data. Energize Eastside Vegetation Management Plan, August 30, 2017. Pole Data Tree Data Pole Data Tree Data Remove 2 existing 60-foot H-Frame poles. Replace with 1-2 85-100’ tall monopoles at each location (total 2-4). Typical pole height 65’ to 100’. Approximately 20 trees would be removed near the Coal Creek to SE 60th Street segment of the Lower Coal Creek Trail. Pole types, heights, and sizes are more detailed than in the Phase 2 Draft EIS but generally the same as described for Phase 2. General pole types, heights, and locations in permit application are the same as the information provided by PSE in August 2017. Approximately 20 trees would be removed north of where the Lower Coal Creek Trail crosses the transmission corridor.
FINAL EIS PAGE L‐5 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Scenic Views and the Aesthetic Environment Phase 2 Draft EIS Final EIS (Permit Application) Newcastle Segment (No Code Variance) Data Source(s) Data Source(s) Strauch, B. 2016. Email (with attachment) from Bradley Strauch, Sr. Land Planner/Environmental Scientist, PSE, to Claire Hoffman and Reema Shakra, ESA, regarding information and data for the Energize Eastside Project. August 16, 2016. The Watershed Company, 2016 and accompanying GIS data. The Watershed Company, 2017 and accompanying GIS data. PSE. 2017. Emails from Bradley Strauch, Energize Eastside Project Manager, PSE, to Reema Shakra and Mark Johnson, ESA. December 1, 2017. Pole Data Tree Data Pole Data Tree Data 100’ tall single circuit steel monopoles. 301 trees removed. General pole types, heights, and locations were the same based on updated information provided by PSE in August 2017. 244 trees removed. Notes: Discussion of tree removal is qualitative in the Phase 2 Draft EIS and Final EIS and is based on a spatial analysis of tree removal within the corridor. Reduction in tree removal did not result in new findings for the Final EIS.
FINAL EIS PAGE L‐6 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Water Resources Phase 2 Draft EIS Final EIS (Permit Application) Richards Creek Substation Data Source(s) Data Source(s) The Watershed Company. 2016. City of Bellevue Critical Areas Delineation Report. Prepared for Puget Sound Energy – Energize Eastside Project. May 2016. The Watershed Company. May 2016. City of Bellevue. Critical Areas Delineation Report: Puget Sound Energy –Energize Eastside Project. Prepared for PSE. The Watershed Company. 2017. Richards Creek Substation Property, Wetland and Stream Delineation Report. The Watershed Company Reference Number: 111103.6. Submitted to Molly Reed, PSE. June 22, 2017. The Watershed Company. August 2017. City of Bellevue Critical Areas Report: Puget Sound Energy – Energize Eastside Project South Bellevue Segment. Prepared for PSE. PSE. 2017. Emails from Bradley Strauch, Energize Eastside Project Manager, PSE, to Reema Shakra and Mark Johnson, ESA. December 1, 2017. Pole Data Wetlands and Streams Data Construction Access Data Pole Data Wetlands and Streams Data Construction Access Data Two poles would be in wetland JB01 or its buffer. Streams--East Creek, Stream C, Stream JB01, unnamed tribs. of Richards Creek. Wetlands—BC, FG, JB01. Used general assumptions since preliminary access road data provided did not indicate whether wetlands would be filled or not. Assumed all new roads in wetlands, streams, and buffers were temporary, and would be restored per Bellevue Code requirements. Ten poles would be in Wetland A or its buffer, and approx. six poles would be in Wetland H or its buffer. More specific information on stream and wetland impacts. Streams A & C. Wetlands: New wetland naming system. Wetland A (named BC in Draft EIS), Wetland B, Wetland C, Wetland D (named FG in Draft EIS), Wetland H (named JB01 in Draft EIS). Temporary access roads would be constructed in Wetlands A and H, and stringing sites would be constructed in Wetland A. Notes: Information in the Richards Creek delineation report and in the permit application identified two wetlands not shown in the Phase 2 Draft EIS, provides greater detail on wetland locations and impacts, and renames some wetlands. Information in the Richards Creek delineation report and permit application also provides greater detail on stream classifications and impacts.
FINAL EIS PAGE L‐7 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Water Resources Phase 2 Draft EIS Final EIS (Permit Application) Bellevue Central Segment Data Source(s) Data Source(s) The Watershed Company. 2016. City of Bellevue Critical Areas Delineation Report. Prepared for Puget Sound Energy – Energize Eastside Project. May 2016. The Watershed Company. 2016. City of Bellevue Critical Areas Delineation Report. Prepared for Puget Sound Energy – Energize Eastside Project. May 2016. (No new information was provided for this segment.) PSE. 2017. Emails from Bradley Strauch, Energize Eastside Project Manager, PSE, to Reema Shakra and Mark Johnson, ESA. December 1, 2017. Pole Data Wetlands and Streams Data Construction Access Data Pole Data Wetlands and Streams Data Construction Access Data Poles in wetlands reduced from 3 to 2. Poles in buffers reduced from 14 to 6. Kelsey Creek, East Creek and various tribs to Kelsey, East, and Richards creeks.23 Category II and IV wetlands. Used general assumptions based on narrative; preliminary access road data provided did not indicate whether wetlands would be filled or not. Poles in wetlands would be reduced to 0; no poles in streams or stream buffers. No change to wetlands or streams. Used general assumptions since no data provided, except as noted for Richards Creek above. Notes: Bellevue Central Segment is not in the permit application, except for the area near the Lakeside substation. The permit application did not show any change in wetland and stream impacts in that area.
FINAL EIS PAGE L‐8 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Water Resources Phase 2 Draft EIS Final EIS (Permit Application) Bellevue South Segment Data Source(s) Data Source(s) The Watershed Company. 2016. City of Bellevue Critical Areas Delineation Report. Prepared for Puget Sound Energy – Energize Eastside Project. May 2016. The Watershed Company. 2016. City of Bellevue Critical Areas Delineation Report: Puget Sound Energy Energize Eastside Project. May 2016. The Watershed Company. 2017. City of Bellevue Critical Areas Report: Puget Sound Energy – Energize Eastside Project South Bellevue Segment. August 2017. PSE. 2017. Emails from Bradley Strauch, Energize Eastside Project Manager, PSE, to Reema Shakra and Mark Johnson, ESA. December 1, 2017. Pole Data Wetlands and Streams Data Construction Access Data Pole Data Wetlands and Streams Data Construction Access Data Poles in wetland buffers would decrease from 7 to 3. 3 unnamed tributaries of East Creek, Sunset, and Coal creeks. 14 Category II and IV wetlands. Used general assumptions based on narrative; preliminary access road data provided did not indicate whether wetlands would be filled or not. Poles in wetland buffers would decrease from 7 to 1. 7 tributaries, different naming system in permit data. 13 Category III and IV wetlands. No access roads in wetlands, streams, or buffers. Notes: Stream and wetland information was revised for the Final EIS based on additional detail in the permit application. Information in the permit application was used for access road locations.
FINAL EIS PAGE L‐9 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Water Resources Phase 2 Draft EIS Final EIS (Permit Application) Newcastle Segment (No Code Variance) Data Source(s) Data Source(s) The Watershed Company. 2016. City of Newcastle Critical Areas Delineation Report. Prepared for Puget Sound Energy – Energize Eastside Project. May 2016. The Watershed Company. 2016. City of Newcastle Critical Areas Delineation Report. Prepared for Puget Sound Energy – Energize Eastside Project. May 2016. PSE. 2017. Emails from Bradley Strauch, Energize Eastside Project Manager, PSE, to Reema Shakra and Mark Johnson, ESA. December 1, 2017. Pole Data Wetlands and Streams Data Construction Access Data Pole Data Wetlands and Streams Data Construction Access Data No poles in critical areas or buffers. 2 unnamed streams and May Creek. One Category IV and one Category III wetland. Used general assumptions based on narrative; preliminary access road data provided did not indicate whether wetlands would be filled or not. No poles would be placed in streams or stream buffers. Number of poles in wetland buffers would be reduced. 3 unnamed streams (one with headwaters in Bellevue was added), May Creek. Two Category III wetlands. No access roads in wetlands, streams, or buffers. Notes: In the Newcastle permit application, the wetlands were reclassified using revised Newcastle Critical Areas regulations. Information in the permit application was used for access road locations.
FINAL EIS PAGE L‐10 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Plants and Animals Phase 2 Draft EIS Final EIS (Permit Application) Richards Creek Substation Data Source(s) Data Source(s) The Watershed Company. 2016a. Tree Inventory: Energize Eastside Project. Includes the following separate reports: City of Bellevue Tree Inventory Report; King County Tree Inventory Report; City of Newcastle Tree Inventory Report; City of Redmond Tree Inventory Report; Segment O Tree Inventory Report; Segment P Tree Inventory Report; and Bypass Routes 1 and 2 Tree Inventory and Analysis Report. Prepared for Puget Sound Energy, Bellevue, WA. Prepared by the Watershed Company, Kirkland, WA. May and July 2016. The Watershed Company. 2016b. Tree Inventory: Energize Eastside Project. Includes the following separate reports: City of Bellevue Critical Areas Delineation Report; King County Critical Areas Delineation Report; City of Newcastle Critical Areas Delineation Report; City of Redmond Critical Areas Delineation Report; City of Renton Critical Areas Delineation Report. Prepared for Puget Sound Energy, Bellevue, WA. Prepared by the Watershed Company, Kirkland, WA. May and July 2016. The Watershed Company. 2016c. GIS Dataset labeled as twc_ee_veg_impact_results_20160914. September 14, 2016. The Watershed Company, 2017 and accompanying GIS data. The Watershed Company. 2017. City of Bellevue Critical Areas Report: Puget Sound Energy – Energize Eastside Project South Bellevue Segment. August 2017. Tree Data Construction Access Wetland/Stream Habitat Tree Data Construction Access Wetland/Stream Habitat 173 removed (109 significant, 0 CA, 29 CA buffers). Used general assumptions since preliminary access road data provided did not indicate whether existing habitat would be impacted. Assumed all new roads were temporary, and would be restored per Bellevue Code requirements. 2.8 acres of habitat would be removed. 178 removed (108 significant, 23 trees in critical areas, 76 tress in critical area buffers) No additional information added. 2.8 acres of habitat would be removed. More specific information on impacts from realigning Stream C. (see Water section) Notes: Tree removal numbers in the Phase 2 Draft EIS column reflect corrected numbers (see Chapter 3, Errata, of the Final EIS). Therefore, they are slightly different than what was presented in the Phase 2 Draft EIS.
FINAL EIS PAGE L‐11 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Plants and Animals Phase 2 Draft EIS Final EIS (Permit Application) Bellevue Central Segment Data Source(s) Data Source(s) The Watershed Company. 2016a. Tree Inventory: Energize Eastside Project. Includes the following separate reports: City of Bellevue Tree Inventory Report; King County Tree Inventory Report; City of Newcastle Tree Inventory Report; City of Redmond Tree Inventory Report; Segment O Tree Inventory Report; Segment P Tree Inventory Report; and Bypass Routes 1 and 2 Tree Inventory and Analysis Report. Prepared for Puget Sound Energy, Bellevue, WA. Prepared by the Watershed Company, Kirkland, WA. May and July 2016. The Watershed Company. 2016b. Tree Inventory: Energize Eastside Project. Includes the following separate reports: City of Bellevue Critical Areas Delineation Report; King County Critical Areas Delineation Report; City of Newcastle Critical Areas Delineation Report; City of Redmond Critical Areas Delineation Report; City of Renton Critical Areas Delineation Report. Prepared for Puget Sound Energy, Bellevue, WA. Prepared by the Watershed Company, Kirkland, WA. May and July 2016. The Watershed Company. 2016c. GIS Dataset labeled as twc_ee_veg_impact_results_20160914. September 14, 2016. The Watershed Company, 2017 and accompanying GIS data. Tree Data Construction Access Wetland/Stream Habitat Tree Data Construction Access Wetland/Stream Habitat 599 removed (232 significant, 50 CA, 152 CA buffer). Used general assumptions based on narrative; preliminary access road data provided did not indicate whether wetland habitat would be filled or not. No impacts to terrestrial species are expected and stream habitat would not be substantially affected. 642 removed (234 significant, 68 CA, 172 CA buffer). No additional information added. No additional information added. Notes: Tree removal numbers changed primarily due to an increase in tree removal near the Lakeside substation. Additional trees would be removed from critical areas and critical area buffers. Tree removal numbers in the Phase 2 Draft EIS column reflect corrected numbers (see Chapter 3, Errata, of the Final EIS). Therefore, they are slightly different than what was presented in the Phase 2 Draft EIS.
FINAL EIS PAGE L‐12 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Plants and Animals Phase 2 Draft EIS Final EIS (Permit Application) Bellevue South Segment Data Source(s) Data Source(s) The Watershed Company. 2016a. Tree Inventory: Energize Eastside Project. Includes the following separate reports: City of Bellevue Tree Inventory Report; King County Tree Inventory Report; City of Newcastle Tree Inventory Report; City of Redmond Tree Inventory Report; Segment O Tree Inventory Report; Segment P Tree Inventory Report; and Bypass Routes 1 and 2 Tree Inventory and Analysis Report. Prepared for Puget Sound Energy, Bellevue, WA. Prepared by the Watershed Company, Kirkland, WA. May and July 2016. The Watershed Company. 2016b. Tree Inventory: Energize Eastside Project. Includes the following separate reports: City of Bellevue Critical Areas Delineation Report; King County Critical Areas Delineation Report; City of Newcastle Critical Areas Delineation Report; City of Redmond Critical Areas Delineation Report; City of Renton Critical Areas Delineation Report. Prepared for Puget Sound Energy, Bellevue, WA. Prepared by the Watershed Company, Kirkland, WA. May and July 2016. The Watershed Company. 2016c. GIS Dataset labeled as twc_ee_veg_impact_results_20160914. September 14, 2016. Energize Eastside Vegetation Management Plan, August 30, 2017. Tree Data Construction Access Wetland/Stream Habitat Tree Data Construction Access Wetland/Stream Habitat 1,032 removed (449 significant, 4 in CA, 76 in CA buffers). Used general assumptions based on narrative; preliminary access road data provided did not indicate whether wetlands would be filled or not. No impacts to terrestrial species are expected and stream habitat would not be substantially affected. 1,030 trees removed (442 significant, 3 in CA, 69 in CA buffers) No changes. No changes in this chapter. Notes: Tree removal numbers in the Phase 2 Draft EIS column reflect corrected numbers (see Chapter 3, Errata, of the Final EIS). Therefore, they are slightly different than what was presented in the Phase 2 Draft EIS.
FINAL EIS PAGE L‐13 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Plants and Animals Phase 2 Draft EIS Final EIS (Permit Application) Newcastle Segment (No Code Variance) Data Source(s) Data Source(s) The Watershed Company. 2016a. Tree Inventory: Energize Eastside Project. Includes the following separate reports: City of Bellevue Tree Inventory Report; King County Tree Inventory Report; City of Newcastle Tree Inventory Report; City of Redmond Tree Inventory Report; Segment O Tree Inventory Report; Segment P Tree Inventory Report; and Bypass Routes 1 and 2 Tree Inventory and Analysis Report. Prepared for Puget Sound Energy, Bellevue, WA. Prepared by the Watershed Company, Kirkland, WA. May and July 2016. The Watershed Company. 2016b. Tree Inventory: Energize Eastside Project. Includes the following separate reports: City of Bellevue Critical Areas Delineation Report; King County Critical Areas Delineation Report; City of Newcastle Critical Areas Delineation Report; City of Redmond Critical Areas Delineation Report; City of Renton Critical Areas Delineation Report. Prepared for Puget Sound Energy, Bellevue, WA. Prepared by the Watershed Company, Kirkland, WA. May and July 2016. The Watershed Company. 2016c. GIS Dataset labeled as twc_ee_veg_impact_results_20160914. September 14, 2016. The Watershed Company, 2017 and accompanying GIS data. Newcastle CUP No Variance (C-2), Significant Tree Inventory. The Watershed Company. 2017. City of Newcastle Critical Areas Report: Puget Sound Energy – Energize Eastside Project South Bellevue Segment. November 2017. The Watershed Company. November 8, 2017. Addendum to the Newcastle Critical Areas Report for the Puget Sound Energy Energize Eastside Project. Tree Data Construction Access Wetland/Stream Habitat Tree Data Construction Access Wetland/Stream Habitat 301 removed (33 significant, two in CA, 57 in CA buffer). Used general assumptions based on narrative; preliminary access road data provided did not indicate whether wetlands would be filled or not. No impacts to terrestrial species are expected and stream habitat would not be substantially affected. 244 removed (30 significant, 0 in CA, 21 in CA buffer) No changes No changes. Notes: Tree removal numbers in the Phase 2 Draft EIS column reflect corrected numbers (see Chapter 3, Errata, of the Final EIS). Therefore, they are slightly different than what was presented in the Phase 2 Draft EIS.
FINAL EIS PAGE L‐14 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Greenhouse Gases Phase 2 Draft EIS Final EIS (Permit Application) Richards Creek Substation Data Source(s) Data Source(s) The Watershed Company, 2016. GIS Dataset labeled as twc_ee_veg_impact_results_20160914. September 14, 2016. Energize Eastside Vegetation Management Plan, August 30, 2017. The Watershed Company, 2017 and accompanying GIS data. GHG Emissions GHG Emissions 173 trees for removal. 178 trees for removal. Notes: Tree removal numbers only increased slightly. Bellevue Central Segment Data Source(s) Data Source(s) The Watershed Company, 2016. GIS Dataset labeled as twc_ee_veg_impact_results_20160914. September 14, 2016. Energize Eastside Vegetation Management Plan, August 30, 2017. The Watershed Company, 2017 and accompanying GIS data. GHG Emissions GHG Emissions 599 trees for removal 642 trees for removal Notes: Tree removal numbers increased somewhat.
FINAL EIS PAGE L‐15 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Greenhouse Gases Phase 2 Draft EIS Final EIS (Permit Application) Bellevue South Segment Data Source(s) Data Source(s) The Watershed Company. 2016. Tree Inventory Excel Database titled Willow, Oak, Richards, Bypass_EIS Segments w VIA Result. Dated September 9, 2016. Energize Eastside Vegetation Management Plan, August 30, 2017. The Watershed Company, 2017 and accompanying GIS data. GHG Emissions GHG Emissions 1,032 trees for removal. 1,030 trees for removal. Notes: Tree removal numbers only decreased slightly. Newcastle Segment (No Code Variance) Data Source(s) Data Source(s) The Watershed Company, 2016. GIS Dataset labeled as twc_ee_veg_impact_results_20160914. September 14, 2016. Energize Eastside Vegetation Management Plan, August 30, 2017. The Watershed Company, 2017 and accompanying GIS data. GHG Emissions GHG Emissions 301 trees for removal. 244 trees for removal. Notes: Tree removal numbers decreased somewhat.
FINAL EIS PAGE L‐16 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Recreation Phase 2 Draft EIS Final EIS (Permit Application) Richards Creek Substation Data Source(s) Data Source(s) The Watershed Company. 2016c. GIS Dataset labeled as twc_ee_veg_impact_results_20160914. September 14, 2016. Energize Eastside Vegetation Management Plan, August 30, 2017. The Watershed Company, 2017 and accompanying GIS data. Pole Data Tree Data Pole Data Tree Data Chestnut Hill Academy: No poles existing or proposed on the school site. Trees would be removed on the adjacent substation site, but they would not be visible from the school. Chestnut Hill Academy: No poles existing or proposed on the school site. Trees would be removed on the adjacent Lakeside and Richards Creek substations that may be visible from the school.
FINAL EIS PAGE L‐17 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Recreation Phase 2 Draft EIS Final EIS (Permit Application) Bellevue South Segment Data Source(s) Data Source(s) The Watershed Company. 2016c. GIS Dataset labeled as twc_ee_veg_impact_results_20160914. September 14, 2016. Energize Eastside Vegetation Management Plan, August 30, 2017. The Watershed Company, 2017 and accompanying GIS data. Pole Data Tree Data Pole Data Tree Data Summary: 32 poles would be removed and replaced with 17 poles in recreation areas (number in Coal Creek Natural Area not specified). Tyee Middle School: 2 60-foot H-frames replaced with a 100-monopole. Somerset North Slope Open Space: No existing poles, one 85-foot pole placed within park and 1 to the adjacent parcel (2 total). Somerset Recreation Club: 2 new taller poles in place of existing 2. Forest Hill Neighborhood Park & Open Space: 2 60-foot H-frame poles replaced with 2 85-foot tall monopoles. Coal Creek Natural Area: existing pairs of 60-foot H-frames would be replaced with 100-foot monopoles or 2 85-foot tall poles (number not specified). Newport Hills Mini Park: 2 sets of 3 poles would be replaced with 2 85-foot tall poles. Summary: 77-87 trees removed in specific recreation areas. Tyee Middle School: 17 removed. Somerset North Slope Open Space: One tree removed. Somerset Recreation Club: 5-10 removed. Forest Hill Neighborhood Park & Open Space: 14 trees removed. Coal Creek Natural Area: 35 trees removed. Newport Hills Mini Park: 5-10 trees removed. Summary: 32 poles would be removed and replaced with 16 poles in recreation areas. Tyee Middle School: The more northern 60-foot H-frame replaced with a 100-foot monopole, the other replaced with 2 110-foot monopoles. Somerset North Slope Open Space: No poles existing, and none would be placed within or adjacent to. Somerset Recreation Club: 2 90-foot poles in place of existing 2. Forest Hill Neighborhood Park & Open Space: 2 60-foot H-frame poles replaced with 2 90-foot tall monopoles. Coal Creek Natural Area: Ten e pairs of 60-foot H-frames would be replaced with 100-foot monopoles or 2 110-foot tall poles (20 poles would be replaced with 7 poles total). Newport Hills Mini Park: 2 sets of 3 poles would be replaced with 2 110-foot tall poles. Summary: 60-75 trees for removal in specific recreation areas. Tyee Middle School: 12 trees for removal. Somerset North Slope Open Space: One tree for removal. Somerset Recreation Club: 4-8 trees for removal. Forest Hill Neighborhood Park & Open Space: 13 trees for removal. Coal Creek Natural Area: 25 – 30 trees for removal. Newport Hills Mini Park: 5-10 trees for removal. Notes: Limited changes to pole numbers, pole heights, and tree removal numbers.
FINAL EIS PAGE L‐18 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Recreation Phase 2 Draft EIS Final EIS (Permit Application) Newcastle Segment (No Code Variance) Data Source(s) Data Source(s) The Watershed Company. 2016c. GIS Dataset labeled as twc_ee_veg_impact_results_20160914. September 14, 2016. Energize Eastside Vegetation Management Plan, August 30, 2017. The Watershed Company, 2017 and accompanying GIS data. Pole Data Tree Data Pole Data Tree Data Summary: There would be approximately half the number of poles. Waterline, Cross Town, China Creek (proposed), and Olympus Trails: Existing pairs of 60-foot H-frames would be replaced with 2 85-foot monopoles (number not specified). May Creek Natural Area: Two pairs of 60-foot H-frames replaced with 2 85-foot monopoles. Summary: Approximately 280 trees for removal. Waterline, Cross Town, China Creek (proposed), and Olympus Trails: Approximately 185 trees for removal. May Creek Natural Area: 94 trees for removal. Summary: There would be approximately half the number of poles. Waterline, Cross Town, China Creek (proposed), and Olympus Trails: Existing pairs of 60-foot H-frames would be replaced with 2 95-foot monopoles (number not specified). May Creek Natural Area: The two pairs of 60-foot H-frames would be replaced with 2 95-foot monopoles. Summary: Approximately 215 trees for removal. Waterline, Cross Town, China Creek (proposed), and Olympus Trails: Approximately 170 trees for removal. May Creek Natural Area: Approximately 45 trees for removal. Notes: Fewer trees would be removed in the May Creek Natural Area.
FINAL EIS PAGE L‐19 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Ecosystem Services Phase 2 Draft EIS Final EIS (Permit Application) Richards Creek Substation Data Source(s) Data Source(s) The Watershed Company. 2016c. GIS Dataset labeled as twc_ee_veg_impact_results_20160914. September 14, 2016. Energize Eastside Vegetation Management Plan, August 30, 2017. The Watershed Company, 2017 and accompanying GIS data. Trees Removed Trees Removed 173 178 Bellevue Central Segment Data Source(s) Data Source(s) The Watershed Company. 2016c. GIS Dataset labeled as twc_ee_veg_impact_results_20160914. September 14, 2016. Energize Eastside Vegetation Management Plan, August 30, 2017. The Watershed Company, 2017 and accompanying GIS data. Trees Removed Trees Removed 599 642
FINAL EIS PAGE L‐20 APPENDIX L COMPARISON OF EIS DATA SOURCES MARCH 2018 Ecosystem Services Phase 2 Draft EIS Final EIS (Permit Application) Bellevue South Segment Data Source(s) Data Source(s) The Watershed Company. 2016c. GIS Dataset labeled as twc_ee_veg_impact_results_20160914. September 14, 2016. Energize Eastside Vegetation Management Plan, August 30, 2017. The Watershed Company, 2017 and accompanying GIS data. Trees Removed Trees Removed 1,032 1,030 Newcastle Segment (No Code Variance) Data Source(s) Data Source(s) The Watershed Company. 2016c. GIS Dataset labeled as twc_ee_veg_impact_results_20160914. September 14, 2016. Energize Eastside Vegetation Management Plan, August 30, 2017. The Watershed Company, 2017 and accompanying GIS data. Trees Removed Trees Removed 301 244
Appendix M:
Mitigation Measures
M
FINAL EIS PAGE M‐1 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 APPENDIX M. SUMMARY OF MITIGATION MEASURES Potential mitigation measures as identified in the Phase 1 Draft EIS, Phase 2 Draft EIS, and Final EIS are listed below, organized by element of the environment. Table M‐1 identifies potential mitigation measures during construction. Table M‐2 identifies potential measures during operations. Individual cities may require additional mitigation measures during the land use entitlement process consists with their city policies and regulations. Table M‐1. Construction Mitigation Measures Mitigation Measures (Construction) Related Resources Phase/ Source Land Use Prior to Construction None During Construction In locations where access is difficult, a helicopter or large crane could be used to lift foundation rebar and/or poles over adjacent properties and into place. Helicopters could also be used to facilitate stringing the new transmission line into place, reducing the need to enter property to feed the initial lead line (called a “sock line”) that is used to pull the actual conductors into place. The decision to use a large crane or helicopter is usually determined by the construction contractor to address access concerns and minimize site disturbance. Use of a helicopter for this purpose is regulated by the Federal Aviation Administration (FAA). A “congested air” permit and advance notification are required. Because of the potential impacts of this type of construction, local regulators may also want to limit where this type of construction would be allowed. Appendix A includes a series of questions and answers about helicopter use. Following is a brief summary of considerations regarding this type of construction. o Helicopter use for stringing the sock line takes only a few minutes per pole, for each conductor. It involves flying directly over the poles and would not likely involve suspending anything over occupied buildings or homes. o If a crane or helicopter were used to install poles, it would require occupants of buildings or homes in the path of the poles being transported to vacate the premises for up to 2 hours at a time during daylight working hours. o Helicopters generate substantial noise that is not regulated by local codes. Appendix A includes a table that shows expected noise levels. o Helicopter use would not eliminate the need for construction access by vehicles for excavation and pouring concrete. Plants and Animals Final
FINAL EIS PAGE M‐2 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source During Operations None Visual Resources Prior to Construction Choosing routes that are already developed with power lines and where minimal vegetation clearing is necessary. Plants and Animals, GHG, Economics Phase I During Construction None Final During Operations None Final Water Resources Prior to Construction Apply for all necessary permits (BMPs specific to the site and project would be specified in the construction contract documents that the construction contractor would be required to implement). (Regulatory Requirements) Plants and Animals Final, Phase II Comply with applicable requirements from local, state, and federal regulatory agencies for all construction affecting water resources directly or indirectly. Plants and Animals Phase I All of the segments and options would need to comply with applicable federal, state, and local permit requirements for stormwater, streams, wetlands, and critical areas, and Shorelines of the State. Compliance with these requirements would mitigate the potential for short‐term adverse impacts to water resources. Mitigation measures required to comply with such regulations are not discretionary. (Regulatory Requirements) Plants and Animals Phase II During Construction Comply with code provisions for the protection of water resources from clearing and grading activities. (Regulatory Requirements) Plants and Animals Final, Phase II
FINAL EIS PAGE M‐3 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source Comply with all necessary permits (Regulatory Requirements): o National Pollutant Discharge Elimination System general permit for construction (issued by Ecology). o Hydraulic Project Approval (issued by WDFW). o Construction Stormwater General Permit. Plants and Animals Final, Phase II Implement the Stormwater Pollution Prevention Plan and Temporary Erosion and Sediment Control Plan to mitigate potential increased sedimentation and turbidity from stormwater runoff. These plans will include BMPs to ensure that sediment originating from disturbed soils would be retained, with the limits of disturbance such as the following (Regulatory Requirements): o Temporary covering of exposed soils and stockpiled materials. o Silt fencing, catch basin filters, interceptor swales, or hay bales. o Temporary sedimentation ponds or sediment traps. o Installation of a rock construction entrance and street sweeping. Final, Phase II Implement a Spill Prevention, Control, and Countermeasures Plan to minimize the potential for spills or leaks of hazardous materials. BMPs in the Spill Prevention, Control, and Countermeasures Plan would include the following (Regulatory Requirements): o Operating procedures to prevent spills. o Control measures such as secondary containment to prevent spills from entering nearby surface waters. o Countermeasures to contain, clean up, and mitigate the effects of a spill. o Construction vehicle storage and maintenance and fueling of construction equipment will be located away from streams and wetlands. Final, Phase II Comply with a dewatering plan to monitor groundwater withdrawal during excavations and to avoid groundwater contamination. This would likely include collecting dewatering water from excavations and treating it before discharge to surface water or stormwater systems. (Regulatory Requirements) Final, Phase II Comply with construction standards applicable to Wellhead Protection Zone 4 (RZC 21.64.050D.4.b) in the City of Redmond. (Regulatory Requirements) Final, Phase II
FINAL EIS PAGE M‐4 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source Comply with construction standards applicable to Wellhead Protection Area Zone 2 (RMC 4‐4‐030.C8) in the City of Renton. These standards include requirements for the following (Regulatory Requirements): o Secondary containment for hazardous materials. o Securing hazardous materials. o Removal of leaking vehicles and equipment. o Cleanup equipment and supplies. Final, Phase II Monitor soils from construction‐related excavation/grading for contamination; if contaminated soils are encountered, mitigate in accordance with federal, state, and local regulations. (Regulatory Requirements) Final, Phase II Comply with applicable requirements from local, state, and federal regulatory agencies for all construction affecting water resources directly or indirectly. Phase I Avoid and minimize impacts to Waters of the U.S. (lakes, wetlands, streams, and buffers), or provide compensatory mitigation for losses that are approved. Phase I Control construction within floodplains so that flood risk is not increased and floodway capacity is not reduced. Phase I Require trenchless construction for underground and underwater power line segments (Only applicable if undergrounding is used for mitigation). Phase I Bore underneath water resources to avoid temporary and permanent impacts to those areas when feasible. Phase I Manage stormwater to ensure it is properly detained and treated prior to release. Phase I During Operations None Final
FINAL EIS PAGE M‐5 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source Plants and Animals Prior to Construction None Final During Construction Implementation of the mitigation measures described in Section 5.3.3 of the Final EIS to minimize impacts to water resources would minimize impacts to plants and animals. In addition, PSE would comply with applicable construction windows for in‐water work. (Regulatory Requirements) Water Final PSE would also comply with all requirements of their Joint Aquatic Resources Permit Application (JARPA) imposed by natural resource agencies to protect fish and wildlife species and their habitat, such as: (Regulatory Requirements) o Limit work to allowable “fish window” time periods. o Limit work during sensitive nesting and breeding seasons for protected wildlife species occurring in the area. o Implement PSE’s established bird protection programs and procedures. o Provide fish exclusion if required to prevent harm to protected species. o Replant and stabilize disturbed construction and staging areas with native trees, shrubs, and grasses. o Implementation of temporary erosion control measures. o Utilize a Spill Prevention and Control Plan. Final, Phase II Minimize impacts to critical areas and buffers, including Fish and Wildlife Conservation Areas, to the extent practicable. (Regulatory Requirements) Water Phase II Mitigate impacts to critical areas to the levels established by the appropriate jurisdictions and environmental permit requirements. (Regulatory Requirements) Water Phase II Flag the limits of construction, trees to be retained, and critical habitat areas and associated buffers to be avoided. Final, Phase II PSE would continue to implement an ecologically based, integrated weed management program to control the spread of invasive and noxious weeds at these disturbed areas by planting native plants. Final, Phase II At sites where access is difficult, a helicopter or large crane may be used to limit the extent of disturbance necessary for construction access. See the discussion of helicopter use in Section 5.1.3. Land Use Final Avoid removal of mature trees in all construction areas, where possible. Phase I
FINAL EIS PAGE M‐6 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source Facilities, access roads, and staging areas should be located in areas of disturbed vegetation cover if possible. Visual Resources Phase I If vegetation is removed for construction, where possible, replace with appropriate native plant species. Visual Resources Phase I Utilize PSE vegetation management permits for their right‐of‐way in Bellevue that minimize tree removal in transmission line clear zones that are located in critical areas in favor of tree pruning where feasible. Visual Resources, GHG, Economics Phase I Measures to reduce noise and human activity should be implemented for construction activities located near undisturbed or functional wildlife habitat areas such as forests and wetlands, riparian zones, and Lake Washington. Noise Phase I During construction, best management practices would be used to minimize potential impacts from noise, dust, and turbidity, and established water quality standards and in‐water work permit conditions would be met. Noise, Water Phase I Timing of construction work would occur outside of critical time periods for listed species such as nesting and spawning seasons. Phase I During Operations None GHG Prior to Construction None Final During Construction Use renewable diesel for diesel‐powered construction equipment. The fuel can achieve a 40–80 percent reduction in GHG emissions compared to fossil diesel and is a recommended component of GHG reduction efforts in other jurisdictions such as the Drive Clean Seattle program (Seattle OSE, 2012). Final, Phase II Use non‐petroleum lubricants for construction equipment. Final, Phase II Replant disturbed construction and staging areas with native trees, shrubs, and grasses. Visual Resources Final, Phase II During Operations None Final
FINAL EIS PAGE M‐7 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source Recreation Prior to Construction Coordinate with potentially affected park districts/departments. Final, Phase II Provide alternative access points to recreation sites and trail detours. Final, Phase II Avoid construction during months when recreation sites are busier, when possible. Final, Phase II Avoid vegetation clearing for construction activities where possible. Visual Resources, Plants and Animals, GHG, Economics Final, Phase II Avoid replacing poles at Rose Hill Middle School and Tyee Middle School while school is in session. Final, Phase II Notify local jurisdictions, schools, or private owners (including the Somerset Recreation Club), 60 days in advance of work within recreation sites. Final, Phase II Notify the public of any temporary closure of trails or recreations sites 2 weeks in advance. Final, Phase II Provide signage along trails or park entrances at least 1 week prior to closures. Final, Phase II Alternative access points to recreation sites and trail detours would be provided and months in which recreation sites are busier would be avoided as much as reasonably possible. Phase I During Construction Use BMPs to minimize noise, dust, and other disturbances to visitors to recreation sites during construction, as well as in areas used for informal recreation (e.g., along roads). (Regulatory Requirements) Noise Final, Phase II, Phase 1 Recreation facilities and access to recreation activities (e.g., water access points) would be avoided to the extent practicable. Phase I Post Construction Restore recreation sites or trails after construction. Final, Phase II, Phase I
FINAL EIS PAGE M‐8 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source Cultural Resources Prior to Construction None Final, Phase II, Phase I During Construction Follow outlined procedures in the Inadvertent Discovery Plan in the event archaeological resources are identified during construction activities. Under state law (RCW 27.44), archaeological resources identified during construction would need to be evaluated. If the resources are considered significant, any impacts on archaeological resources would require mitigation, which would likely entail archaeological investigation such as scientific excavation and analysis. For archaeological resources found during construction, an emergency archaeological excavation permit may be issued by DAHP and is typically received within three business days. It is possible that archaeological monitoring would be recommended for portions of the project; this work would be conducted under an Archaeological Resources Monitoring Plan. Phase I Best management practices would be implemented during construction to minimize impacts from dust, noise, and vibration. Noise Phase I Vibration monitoring may be conducted at historic buildings to document that vibration does not exceed acceptable levels. Phase I During Operations None Final, Phase II EMF Prior to Construction No adverse impacts from magnetic fields are expected; therefore, no mitigation is proposed. Final, Phase II, Phase I During Construction No adverse impacts from magnetic fields are expected; therefore, no mitigation is proposed. Final, Phase II, Phase I During Operations No adverse impacts from magnetic fields are expected; therefore, no mitigation is proposed. Final, Phase II, Phase I
FINAL EIS PAGE M‐9 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source Pipeline Safety Prior to Construction Develop construction and access plans in coordination with Olympic’s Damage Prevention Team and mutually agreed upon by both parties. These plans will outline the specific actions that PSE will take to protect the pipelines from vehicle and equipment surcharge loads, excavation, and other activities in consideration of Olympic’s general construction requirements and in consultation with Olympic on the Energize Eastside project design specifically. The following general measures, at a minimum, would be included in the construction and access plans (Regulatory Requirements): o Notify “one‐call” 811 utility locater service at least 48 hours prior to PSE or PSE designated contractors conducting excavation work. (Olympic’s line marking personnel would then mark the location of the pipelines near the construction areas. These procedures are designed to ensure that excavation would not damage any underground utilities and to decrease potential safety hazards.) o Field verify the distance between the pipelines and transmission line pole grounds. o Add the pipeline location and depth to project plans and drawings and submit to Olympic for evaluation. o Arrange for Olympic representatives to be on‐site to monitor construction activities near the pipelines. o Install temporary fencing or other markers around the pipeline area. o Provide all necessary information for Olympic to perform pipe stress calculations for equipment crossings and surface loads (surcharge loads). Based on pipe stress calculations, and in coordination with Olympic, provide additional cover that may include installing timber mats, steel plating, or temporary air bridging; utilize a combination of these; or avoid crossing in certain identified areas in order to avoid impacts on Olympic pipelines. Ensure that mitigation to address potential surcharge load impacts is implemented in accordance with applicable requirements and recommended practices, including the following: 49 CFR 195, Transportation of Hazardous Liquid by Pipeline. American Petroleum Institute Recommended Practice 1102, Steel Pipelines Crossing Railroads and Highways. American Lifelines Alliance, Guidelines for the Design of Buried Steel Pipe. o Comply with additional measures related to minimizing surcharge loads included in Olympic’s general construction requirements (Appendix I‐2). Final, Phase II
FINAL EIS PAGE M‐10 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source Prior to permit issuance of the Energize Eastside project, prepare a preliminary plan detailing measures PSE will required of its contractor to protect the pipeline during construction. Final, Phase II Prior to construction of the Energize Eastside project, file a mitigation and monitoring report with the Partner Cities documenting consultations with Olympic and mitigation measures to address safety‐related issues. The report should include a monitoring plan that identifies how mitigation measures will be monitored to ensure that mitigation related to construction activities is followed. Final, Phase II Require that a geotechnical engineer review final plans and indicate in their report measures necessary to ensure that construction activity will not increase the risk of landslides that could damage the Olympic Pipeline system. Earth Final Coordinate with Olympic and include safeguards in the project construction and access plans to protect nearby pipelines from excavation activities and surcharge loads. Final, Phase II Develop an adjacent use protection plan near sensitive land uses to identify appropriately sized construction zones to protect the general public, construction timing limits, and other mitigation measures that would effectively limit the exposure of the general public to potential pipeline incidents. Final, Phase II Coordinate with school districts to identify the most appropriate time for construction to occur near schools that would minimize exposure to students or others in the school facility. Public Services Final During Construction As part of Olympic’s general construction requirements for all work proposed near the pipelines (see Appendix I of the Phase 2 Draft EIS), comply with other applicable requirements, including the following (Regulatory Requirements): o No excavation or construction activity will be permitted in the vicinity of a pipeline until appropriate communications have been made with Olympic’s field operations and its Right‐of‐Way Department. A formal engineering assessment (conducted by Olympic) may be required. o No excavation or backfilling within the pipeline right‐of‐way will be permitted for any reason without a representative of Olympic on‐site giving permission. o In some instances, excavation and other construction activities around certain pipelines can be conducted safely only when the pipeline operating pressure has been reduced. PSE must inform its designated contractors that Final, Phase II
FINAL EIS PAGE M‐11 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source excavation that exposes or significantly reduces the cover over a pipeline may have to be delayed until the reduced operating pressures are achieved. o For a project within 100 feet of the pipelines, Olympic’s Damage Prevention Team will meet the construction crew on‐site at the beginning of the project and weekly thereafter. If excavation has the potential to be within 10 feet of the pipelines, the Damage Prevention Team would be on‐site at all times to monitor excavation. To address the potential to encounter boulders, use vacuum truck/equipment (or hand digging in difficult to access areas) to dig past the depth of the pipelines before auguring type equipment is utilized. Final, Phase II Coordinate with Olympic to ensure that line marking personnel mark the entire length of any pipeline within 50 feet of any excavation or ground disturbance below original grade, and not only the location of angle points (points of intersection). Final, Phase II Use soft dig methods (e.g., hand excavation, vacuum excavation, etc.) whenever the pipeline(s) are within 25 feet of any proposed excavation or ground disturbance below original grade. Final, Phase II Coordinate with Olympic to ensure that an Olympic employee, trained in the observation of excavations and pipeline locating, is on‐site at all times during excavation and other ground‐disturbing activities that occur within 100 feet of the pipelines where the pipelines are co‐located with the proposed transmission lines. Final, Phase II Arrange for a special monitor (third‐party monitor) on‐site at all times during excavation and other ground‐disturbing activities that occur within 100 feet of the pipelines where the pipelines are co‐located with the proposed transmission lines. Final, Phase II Where excavations will be within 10 to 20 feet of the Olympic Pipeline system, temporary casing in the upper 10 to 15 feet should be considered to reduce the risk of sloughing under the pipeline. Final, Phase II Steel plates or mats should be placed over the pipelines to distribute vehicle loads where construction equipment needs to cross over the pipelines. Final, Phase II
FINAL EIS PAGE M‐12 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source Utility settlement monitoring points, similar to that described below, should be established on the Olympic Pipeline system where drilled shafts will be within 15 feet, if requested by Olympic, to monitor settlement during installation of the drilled shafts. Settlement monitoring points should be installed so that base‐line readings of the settlement monitoring points may be completed prior to the contractor mobilizing to the site. Monitoring should continue during construction on a daily basis and twice a week in the 3 weeks following construction. The monitoring readings should be reviewed by the Engineer on a daily basis. If measured settlement exceeds 1 inch, or the amount specified by the utility owner, the integrity of the utility should be tested and the contractor should be required to repair any damage to the utilities as a result of construction. Final, Phase II During Operations None Economics Prior to Construction The economic aspects of the project that are evaluated in this Final EIS do not relate to construction impacts. Final, Phase II During Construction The economic aspects of the project that are evaluated in this Final EIS do not relate to construction impacts Final, Phase II During Operations The economic aspects of the project that are evaluated in this Final EIS do not relate to construction impacts Final, Phase II Earth Resources Prior to Construction Implementation of construction BMPs as required by local codes would ensure that impacts are minor and not significant. This includes having a geotechnical engineer review plans and make recommendations to avoid increasing the risk of destabilizing landslide prone slopes or increasing soil erosion, and implementing those recommendations during construction. Final Avoid construction on steep slopes, known and potential landslide zones, and areas with organic or liquefiable soils, where feasible. Phase I
FINAL EIS PAGE M‐13 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source Coordinate with other utility providers, as appropriate, to determine how best to avoid or minimize any impacts. PSE would work with other utility service providers during design of the project to coordinate the placement of new facilities and ensure protection of other utilities. Utilities Phase I During Construction Implementation of construction BMPs as required by local codes would ensure that impacts are minor and not significant. Final Use appropriate shoring during construction. Phase I Use erosion and runoff control measures, including retention of vegetation, replanting, ground cover, etc. Phase I Comply with relevant state and local critical areas codes and other applicable requirements. Phase I Dispose of soils at approved disposal sites. Phase I Conduct settlement and vibration monitoring, as applicable, during construction to identify potential adverse conditions to critical structures and local facilities. Phase I During Operations Implementation of construction BMPs as required by local codes would ensure that impacts are minor and not significant. Final Energy and Natural Resources (Phase I Only) Prior to Construction None Phase I During Construction None Phase I During Operations None Phase I
FINAL EIS PAGE M‐14 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source Noise (Phase I Only) Prior to Construction None Phase I During Construction Nighttime Construction Noise. For project elements that would require prolonged nighttime construction activities, portable acoustical barriers may be used to reduce noise. Moveable sound barrier curtains can provide 15 dBA of sound attenuation (INC, 2014). Static sound barrier curtains can provide sound transmission loss of 16 to 40 dBA, depending on the frequency of the noise source (ENC, 2014). Phase I During Operations None Phase I Transportation (Phase I Only) Prior to Construction Education and Outreach: A public involvement program should be implemented prior to project construction. It would provide information about the purpose and importance of the project, and detailed information about the types and locations of expected construction impacts and the measures that would be implemented to minimize those impacts. A Construction Outreach Team may be desired, which would work closely with affected residents and business owners to minimize construction‐related impacts throughout the duration of project construction. A contact person should be identified whom community members can contact to address specific concerns both prior to and during project construction. Phase I Coordination with Other Projects: PSE must coordinate all construction needs and impacts of this project with the other infrastructure and development projects in the combined study area. This would typically be done as part of the permitting process with each community affected by potential construction. Phase I Maintenance of Traffic Plans: The contractor would be required to prepare “maintenance of traffic” plans for any work within the public right‐of‐way that affects vehicular, transit, bicycle, or pedestrian traffic. These plans must show the location of traffic cones, traffic control personnel, and signs; note if bus stops are to be closed or relocated; and indicate special treatments for pedestrian and bicycle access. Phase I
FINAL EIS PAGE M‐15 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source Haul Routes: The contractor would need to coordinate with municipalities to determine appropriate times of travel and haul routes for construction‐generated truck traffic. Haul routes generally would be on arterial streets through commercial areas and use the most direct path to and from the state highway system. Phase I Signal Detection Disruption: Some intersections have in‐pavement induction loops that control traffic signal operations. Prior to trenching through these intersections, alternative detection equipment (e.g., camera detectors) might need to be installed to maintain proper signal function. Loops or permanent cameras would need to be installed as part of restoration. (Only applies to undergrounding for mitigation). Phase I During Construction Construction through an Intersection: Manual traffic control would be needed when construction occurs through an intersection. Work in a signalized intersection may require police officer control; work in an unsignalized intersection can typically be performed with certified flaggers. Public Services Phase I Construction across Driveways: Access to residential and commercial properties would need to be maintained at all times. When trenching across a driveway, the work can usually be done in two parts: trench across one‐half of the driveway and then plate it for driving before trenching the other half of the driveway. At major driveways, flagger control may be needed to facilitate alternating enter and exit traffic. Special treatment would be needed for developments that have split driveways (with one driveway serving entering traffic and one serving exiting traffic) if traffic cannot easily be shifted to the other driveway for two‐way operation. The contractor would be required to coordinate with property owners when driveways or alleys are affected by construction. Land Use Phase I Bus Stop Closure or Relocation: For bus stops that would need to be closed or relocated during construction, the contractor would be required to coordinate with King County Metro Transit, Sound Transit, or Community Transit. Phase I Pavement Restoration: Any pavement degradation that results from increased construction truck traffic or excavation would need to be fully restored upon completion of construction activities. This includes restoration of streets, curbs, gutters, sidewalks, parking lots, driveways, and traffic signal induction loops where appropriate. Phase I During Operations None Phase I
FINAL EIS PAGE M‐16 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source Public Services (Phase I Only) Prior to Construction Emergency Response Service As required by law, contact appropriate Underground Service Alert organization to identify the location of underground utilities and pipelines prior to any excavation work. Pipeline Safety, Utilities Phase I Response Times Preparation of “Maintenance of Traffic” plan by contractor for any work within the public right‐of‐way, as described in Chapter 14 (Phase I), to minimize effects on emergency response and other public services. Transportation Phase I Substation Fire Risk Notify service providers and neighborhood residents of construction schedules, street closures, and utility interruptions as far in advance as possible. Phase I Notify and coordinate with fire departments for water line relocations that could affect water supply for fire suppression, and establish alternative supply lines prior to any service interruptions. Phase I Where feasible, schedule construction outside of hours of peak traffic congestion and times when service providers such as school buses and waste collectors are in the area. Transportation Phase I Coordinate with law enforcement agencies to implement crime prevention plans for construction sites and staging areas. Phase I During Construction Emergency Response Service An OPLC representative is to be present to observe excavation activities around buried pipelines during construction. Pipeline Safety Phase I During Operations None
FINAL EIS PAGE M‐17 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Construction) Related Resources Phase/ Source Utilities (Phase I only) Prior to Construction Coordination with Other Utility Providers. PSE would site new transmission lines according to industry best practices, which includes proper positioning and design (separation and grounding) relative to other utilities. For all alternatives, coordination with the individual utility providers would be required to determine whether or not existing and future utilities could be affected and how best to avoid or minimize those impacts. PSE would work with other utility service providers during design and construction of the project to coordinate the placement of new facilities and ensure protection of other utilities. In some instances, vibration and settlement monitoring may be required where construction would occur near existing utilities. Phase I Utility Location: PSE would follow regulatory requirements to correctly locate and plan for other utility locations such as gas lines or the OPLC pipelines prior to start of construction, including showing pipeline locations on plans and requiring contractors to field locate utilities. Prior to the start of construction, existing utilities would be located and field‐verified where feasible to avoid conflicts with the proposed facilities. Pipeline Safety Phase I Utility Relocations. PSE and its contractors would be required to develop construction sequence plans and coordinate schedules for utility work to minimize service disruptions and provide ample advance notice when service disruptions are unavoidable, consistent with utility owner policies. Relocation plans and service disruptions would be reviewed and approved by the affected utility providers before construction begins. PSE would develop a plan for public outreach to inform customers of potential service outages and construction schedules. The public outreach effort would be coordinated with other utility service providers. Phase I During Construction None Phase I During Operations None Phase I
FINAL EIS PAGE M‐18 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Table M‐2. Operations Mitigation Measures Mitigation Measures (Operations) Related Resources Phase/ Source Land Use Prior to Construction Design and operate regional utility facilities to minimize impacts on the surrounding uses, the environment, and the city (NMC 18.44.052.C.1). (Regulatory Requirements) Visual Resources Final Work with the City of Newcastle to adopt any conditions imposed relating to the location, development, design, use, or operation of a utility facility to mitigate environmental, public safety, or other identifiable impacts. Mitigation measures may include, but are not limited to, natural features that may serve as buffers, or other site design elements such as fencing and site landscaping (NMC 18.44.052.D). (Regulatory Requirements) Visual Resources Final Consolidate utility facilities and co‐locate multiple utilities (City of Newcastle Plan Policy UT‐P3). Visual Resources Final Implement new and expanded transmission and substation facilities in such a manner that they are compatible and consistent with the local context and the land use pattern established in the Comprehensive Plan (City of Bellevue Plan Policy UT‐95). Visual Resources Final Design, construct, and maintain facilities to minimize their impact on surrounding neighborhoods (City of Bellevue Plan Policy UT‐8). Visual Resources Final Conduct a siting analysis for new facilities and expanded facilities at sensitive sites (areas in close proximity to residentially‐zoned districts) (City of Bellevue Plan Policy UT‐96). Visual Resources Final Underground sections of the transmission lines where inconsistencies with the comprehensive plan policies regarding aerial facilities would otherwise occur. Visual Resources Final, Phase II Select the route that requires the least number of properties where easements would restrict future development in areas with policies encouraging building up to or close to the street edge. (Applies only to Bypass 1, Bypass 2, Bellevue Central Easement, Oak 1, Oak 2, Willow 1, and Willow 2 Options). Phase II Construct taller transmission lines so that wires would clear the tops of buildings sufficiently to meet NESC standards if such development were to occur in the future. Phase II Design transmission lines to extend as far as possible over the street right‐of‐way to minimize the amount of easement and clearance needed adjacent to the right‐of‐way. (Applies only to Bypass 1, Bypass 2, Oak 1, Oak 2, and Willow 2 Options). Phase II
FINAL EIS PAGE M‐19 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Use existing utility corridors or properties already in PSE‐ownership to the extent feasible. Visual Resources Phase I Provide relocation assistance for any residents displaced or businesses purchased. Phase I During Construction None Final, Phase II During Operations Limit the number of telecommunication facilities that could be installed on the 230 kV poles to the number currently installed in the corridor and proposed to be reinstalled as part of the EIS (seven locations). Visual Resources Final Require the reinstalled telecommunications facilities to be in the same approximate locations as they were previously and to comply with the requirements of Chapter 80.54 RCW, Chapter 480‐54 WAC, and local jurisdiction regulations. Visual Resources Final Visual Resources Prior to Construction Ensure siting and location of transmission facilities is accomplished in a manner that minimizes adverse impacts on the environment and adjacent land uses (City of Renton Plan Policy U‐72). Land Use Final Consolidate utility facilities and co‐locate multiple utilities (City of Newcastle Plan Policy UT‐P3). Land Use Final, Phase II Implement new and expanded transmission and substation facilities in such a manner that they are compatible and consistent with the local context and the land use pattern established in the Comprehensive Plan (City of Bellevue Plan Policy UT‐95). Land Use Final, Phase II Design, construct, and maintain facilities to minimize their impact on surrounding neighborhoods (City of Bellevue Plan Policy UT‐8). Land Use Final, Phase II Conduct a siting analysis for new facilities and expanded facilities at sensitive sites (areas in close proximity to residentially‐zoned districts) (City of Bellevue Plan Policy UT‐96). Land Use Final, Phase II New development should install a dense visual vegetative screen along Richards Road (City of Bellevue Plan Policy S‐RV‐31). Final, Phase II Consider neighborhood character in planting appropriate varieties and trimming tree limbs around overhead lines (City of Newcastle Plan Policy UT‐P9). Final, Phase II
FINAL EIS PAGE M‐20 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Design overhead transmission lines in a manner that is aesthetically compatible with surrounding land uses (City of Newcastle Plan Policy UT‐P10). This could include design measures such as changes to pole height, spacing, location, or color. Final, Phase II Minimize visual and other impacts of transmission towers and overhead transmission lines on adjacent land uses through careful siting and design (City of Newcastle Plan Policy UT‐P14). Final, Phase II Design transmission structures to minimize aesthetic impacts appropriate to the immediate surrounding area whenever practical (City of Newcastle Plan Policy UT‐P16). Final, Phase II Underground sections of the transmission lines where unavoidable significant impacts to scenic views or the aesthetic environment would otherwise occur. Final, Phase II Position poles and adjust pole height to minimize impacts to the greatest extent possible. In Newcastle, a variance from the setback requirements would allow the poles to be positioned farther away from the houses. This would also allow for shorter poles. Final, Phase II Specify poles with an aesthetic treatment (such as paint or a self‐weathering finish) to reduce contrast with the surrounding environment (see Section 4.2.6.3 below). Final, Phase II Choosing routes that are already developed with power lines and where minimal vegetation clearing is necessary. Phase I Consulting with Cities and affected residents when locating structures, rights‐of‐way, and other disturbed areas to minimize visual impacts. Phase I Complying with applicable plans and policies within potentially affected jurisdictions. Land Use Phase I Placing and designing structures to minimize impacts on specific visual resources and popular public viewpoints. Phase I Using aesthetically pleasing materials and landscaping to shield electrical equipment from public view. Phase I For steel poles, using paint colors that reduce the contrast of the poles with the surrounding environment. Phase I Placing portions of the transmission line underground (as in Alternative 1, Option C) or underwater (as in Alternative 1, Option D) in areas where significant impacts would occur from overhead lines. Phase I For 115 kV lines proposed in corridors with existing distribution lines, placing both transmission and distribution lines on the same poles (referred to as “underbuild”) to limit additional visual clutter. Phase I
FINAL EIS PAGE M‐21 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source During Construction Retain or replace trees to the greatest extent possible. Plants and Animals, GHG, Economics Final, Phase II During Operations Limit disturbance to vegetation within major utility transmission corridors to what is necessary for the safety and maintenance of transmission facilities (City of Newcastle Plan Policy UT‐P8). In areas where vegetation disturbance is unavoidable, replant with vegetation that would be compatible with vegetation clearance requirements, preventing future vegetation removal or maintenance in the future. Plants and Animals, GHG, Economics Final, Phase II Use landscape screening of above‐ground utility facilities to diminish visual impacts (City of Newcastle Plan Policy UT‐P20). Final, Phase II Water Resources Prior to Construction Before any direct wetland impacts occur, PSE would obtain the necessary state and federal authorizations. To obtain state and federal authorization, PSE must provide: A jurisdictional determination from the U.S. Army Corps of Engineers stating whether the delineated wetlands are under federal jurisdiction. Final An application and report presenting impacts to jurisdictional wetlands. Final A mitigation plan for unavoidable wetland impacts following the standards in Wetland Mitigation in Washington State – Part 1: Agency Policies and Guidance (Ecology, 2006). Plants and Animals Final The project would also need to comply with the following regulations of the Partner Cities: Stormwater regulations of the Partner Cities, which are based on the standards set by Ecology’s Stormwater Management Manual for Western Washington (Ecology, 2014). Final, Phase II Requirements of Shoreline Master Programs for Renton in crossing the Cedar River (see Appendix B‐3). Land Use Final
FINAL EIS PAGE M‐22 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Requirements of each applicable Partner City’s critical areas ordinance (see Appendix D). Typical mitigation measures suggested in the ordinances include: o Replacement of wetland acreage based on replacement ratios in critical areas ordinances. o Replacement of lost buffer area. o Enhancement or restoration of buffers. Plants and Animals Final, Phase II Avoid locating poles in wetlands and wetland buffers to the extent possible. It should be possible to avoid most wetlands by raising the height of poles, allowing for a longer stretch of transmission line over the wetland. Plants and Animals Final, Phase II Comply with the requirements of Shoreline Master Programs for Bellevue and Renton in crossing Kelsey Creek and the Cedar River (see Appendix B‐3). (Applies only to Bypass Options). Land Use Phase II During Construction Avoid and minimize impacts to Waters of the U.S. (lakes, wetlands, streams, and buffers), or provide compensatory mitigation for losses that are approved. Phase I Manage stormwater to ensure it is properly detained and treated prior to release. Phase I During Operations Implement Spill Prevention Control and Countermeasures Plans during maintenance activities (for poles, the transmission corridor, and access roads) to prevent spills or leaks of hazardous materials, paving materials, or chemicals from contaminating surface or groundwater. Final, Phase II Plants and Animals Prior to Construction Increasing pole heights to allow greater separation between poles, allowing for some poles to be moved outside of critical areas or buffer. Water Final, Phase II Partner with local, state, and federal agencies to identify potential off‐site mitigation areas that are currently degraded. Water Final, Phase II Develop enhancement plans to convert off‐site mitigation areas into thriving ecosystems, with an emphasis on enhancing critical habitat areas and buffers through planting of native trees and shrubs to provide shade to streams and habitat for birds, woody debris for fish and amphibians, foraging habitat for mammals, and nesting habitat for avian species. Water Final, Phase II
FINAL EIS PAGE M‐23 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Pay an in‐lieu fee to the City of Bellevue for trees removed in the City’s right‐of‐way to offset loss of public amenity. Final, Phase II Pay an in‐lieu fee to the City of Renton if tree replacement ratios cannot be met within the corridor. Final, Phase II Short‐term impacts on vegetation and habitat caused by development of facilities and infrastructure would be mitigated through site and facility design to minimize the need for vegetation and tree removal to the extent feasible. Phase I If intact vegetation or habitat is present, the footprint of the facility should be minimized and situated to result in the least amount of disturbance. Phase I The impacts on animals, including listed species, caused by the development of facilities and infrastructure would be mitigated through site and facility design to minimize the need for habitat removal and construction activity. Phase I Specific measures and pile driving restrictions will be provided in the project‐specific permits from WDFW, Corps of Engineers, U.S. Fish and Wildlife Service, and National Marine Fisheries Service. Phase I The PSE Avian Protection Program would also be implemented to address avian issues and concerns with electrical systems, including methods and equipment to reduce avian collisions, electrocution, and problem nests. Phase I During Construction Replace trees removed for the project based on tree protection ordinances and critical areas regulations in each jurisdiction; some of these trees would likely be planted off‐site or, in the case of the City of Newcastle, mitigated by paying into an in‐lieu fee program. Replacement may be based on cross‐sectional diameter of trees removed, or on habitat functions lost due to tree removal, depending on applicable regulations. (Regulatory Requirements) Final, Phase II In the Bridle Trails Subarea in the City of Bellevue, plant replacement trees as required under the City’s Tree Retention and Replacement Code. (Regulatory Requirements) Visual Final, Phase II Replant disturbed areas using native vegetation that would meet transmission line clearance requirements and would not need to be removed or require maintenance (i.e., trimming) in the future. Visual Final, Phase II Critical area and buffer trees would be trimmed and not removed if possible, and trimmed branches and trunks at least 4‐inches in diameter would be left in place to provide a greater amount of available woody debris for the area streams, compared to the long‐term natural recruitment process. Water Final Avoid removal of mature trees in all construction areas, where possible. Phase I
FINAL EIS PAGE M‐24 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Facilities, access roads, and staging areas should be located in areas of disturbed vegetation cover if possible. Visual Phase I If vegetation is removed for construction, where possible, replace with appropriate native plant species. Phase I Utilize PSE vegetation management permits for their right‐of‐way in Bellevue that minimize tree removal in transmission line clear zones that are located in critical areas in favor of tree pruning where feasible. Phase I Measures to reduce noise and human activity should be implemented for construction activities located near undisturbed or functional wildlife habitat areas such as forests and wetlands, riparian zones, and Lake Washington. Noise Phase I During construction, best management practices would be used to minimize potential impacts from noise, dust, and turbidity, and established water quality standards and in‐water work permit conditions would be met. Noise, Water Phase I Habitat that is determined to be of significant importance (e.g., presence of listed species, priority habitats) will be avoided to the greatest extent possible. Phase I Timing of construction work would occur outside of critical time periods for listed species such as nesting and spawning seasons. Phase I During Operations Trees removed from critical areas in Bellevue and Renton may require mitigation monitoring. (Regulatory Requirements) Final, Phase II Continue to implement an ecologically based, integrated weed management program, to control the spread of invasive and noxious weeds along the corridor, and at PSE substation facilities, including the removal of existing infestations of invasive species. Final, Phase II Continue to implement PSE’s Avian Protection Program (PSE, 2016b), and mitigate for the direct loss of nesting and roosting habitat for protected species (i.e., eagles, osprey, and other raptors). This mitigation typically occurs by providing nesting platforms in isolated areas away from power lines when nests of species protected under the Migratory Bird Treaty Act and the Bald and Golden Eagle Protection Act need to be removed from the power structures. Any such removal/replacement would occur outside of the nesting season to minimize the disturbance of the birds. In addition, PSE will continue to proactively discourage and minimize the use of the power structures by all avian species by retrofitting existing structures with wire guards, flight diverter devices, and bird guards. Final, Phase II
FINAL EIS PAGE M‐25 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source During tree maintenance activities, critical area and buffer trees would be trimmed and not removed if possible, and trimmed branches and trunks at least 4 inches in diameter would be left in place to provide a greater amount of woody debris for the area streams, compared to the long‐term natural recruitment process. Final Revegetated areas would be monitored to ensure success and invasive species would be controlled. Phase I GHG Prior to Construction Install SF6‐filled equipment with manufactured guaranteed leakage rate of 0.1 percent at the Richards Creek, Sammamish, and Talbot Hill substations. Installation of such equipment could reduce fugitive SF6 emissions by up to 80 percent over older equipment types. Final, Phase II During Construction Replace trees removed for the project based on tree protection ordinances and critical areas regulations in each jurisdiction; some of these trees would likely be planted off‐site or, in the case of the City of Newcastle, mitigated by paying into an in‐lieu fee program. Replacement may be based on the cross‐sectional diameter of trees removed, or on habitat functions lost due to trees removal, depending on applicable regulations. (Regulatory Requirements) Plants and Animals, Economics Final, Phase II Install fuel flow meter to restrict the use of fuel and associated GHG emissions over a given time period, if gas turbines or reciprocating engines are selected as distributed energy components and if required by air quality permits. Phase I Implement vegetation replacement program to reduce sequestration losses under Alternative 1, Option A, and Alternative 3 to a moderate level. Alternative 1, Options B and C would also involve vegetation clearing for alignments, although to a lesser extent. Phase I During Operations Carbon credits may be purchased to offset operational emissions generated by permitted sources. Phase I
FINAL EIS PAGE M‐26 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Recreation Prior to Construction Avoid placement of infrastructure within or adjacent to recreation sites where there is none currently to the extent possible. (Regulatory Requirements) Final, Phase II Meet site‐specific agency requirements regarding acquisition of easements that require conversion of recreation land to a non‐recreation use. (Regulatory Requirements). (Applies only to Bypass 1, Bypass 2, Oak 1, Oak 2, and Willow 2 Options). Phase II Use vegetation outside of any area required to be cleared to screen poles and wires where transmission infrastructure is placed within a recreation site. Visual Resources Final, Phase II Work with each Partner City to determine mitigation for tree removal within recreation sites in its jurisdiction. Final, Phase II Undergo a public review process for the conversion to non‐recreational use of public park lands and facilities (City of Bellevue Plan Policy PA‐37). (Applies only to Bypass 1, Bypass 2, Oak 1, Oak 2, and Willow 2 Options). Phase II Design the project so that poles would be placed farther into the road right‐of‐way and supports would extend farther over the road so that new easements would not be required for the pole placement or the associated vegetation clear zone (i.e., the managed right‐of‐way). (Applies only to Bypass 1, Bypass 2, Oak 1, Oak 2, and Willow 2 Options). Phase II Work with the City of Bellevue to relocate the trailhead at Woodridge Open Space, if needed under Bypass Option 2. (Applies only to Bypass 2 Option). Phase II Work with Newport High School (Bellevue School District) to relocate lighting structures for the track, if needed under the Oak 2 Option. (Applies only to Oak 2 Option). Phase II To minimize potential operational impacts to recreation sites, placement of infrastructure within or adjacent to recreation sites would be avoided to the extent possible. Phase I All impacts to recreational sites would comply with applicable requirements, such as restrictions that protect recreation land from conversion to other uses (for example, state or federal grant funded sites). Phase I If it is not possible to avoid a recreation site, vegetation screening could be used outside of any required clear zone. Phase I
FINAL EIS PAGE M‐27 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source If recreation sites are affected and cannot be restored, they would be relocated and replaced as required; for example property could be purchased and a new recreation facility created. Phase I During Construction None Final, Phase II During Operations None Final, Phase II Cultural Resources Prior to Construction Develop resource‐specific mitigation measures during consultation with DAHP, affected Tribes, KCHPP, and other appropriate stakeholders if a protected archaeological resource is identified during pre‐construction archaeological survey or historic property inventory. (Regulatory Requirements) Final, Phase II Apply for an archaeological excavation permit from DAHP (WAC 25‐48‐060) if impacts to a protected archaeological resource cannot be avoided. (Regulatory Requirements) Final, Phase II Request an eligibility determination from DAHP for resources listed as eligible for listing in the NRHP (Eastside Transmission System, Somerset Neighborhood, Newcastle Cemetery, Mt. Olivet Cemetery, and the Columbia & Puget Sound Railroad). If any are determined eligible, mitigation measures specific to those resources will be developed during consultation with DAHP, affected Tribes, and any other appropriate stakeholders. (Regulatory Requirements) Final, Phase II Obtain a Certificate of Appropriateness (COA) from KCHPP (KCC 20.62) if there are potential impacts to a designated KC Landmark. (Regulatory Requirements) Final, Phase II Avoid cemeteries in accordance with state law (Chapters 68.60 RCW and 68.50 RCW). (Regulatory Requirements) Final, Phase II Avoid graves outside of the dedicated boundaries of a cemetery in accordance with state law (Chapters 27.44 RCW and 68.60.050). (Regulatory Requirements) Final, Phase II Conduct a historic property inventory (field work is complete; resulting forms and associated report are being submitted to DAHP for review). Final, Phase II
FINAL EIS PAGE M‐28 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Conduct archaeological resource surveys for the selected route that include subsurface testing (pedestrian and subsurface survey of the 16‐mile alignment and specific proposed pole locations began in August 2017 and is still ongoing as of the writing of this [December 2017]; PSE will conduct a second pedestrian and subsurface survey to assess staging areas, laydown areas, stringing sites, and access roads once more information on these locations is available; as of this writing this has not started). Final, Phase II Prepare an Inadvertent Discovery Plan (IDP) for the project and discuss the IDP during pre‐construction meeting(s). Final, Phase II, Phase I Conduct subsurface testing. Final, Phase II Consult with DAHP and any other appropriate stakeholders to develop resource‐specific mitigation measures for impacts to significant cultural resources. Final, Phase II Preserve or add screening at proposed pole sites to minimize potential impacts to the viewsheds of historic cemeteries. Final, Phase II Adjust the proposed pole locations to reduce potential direct impacts to historic cemeteries. Final, Phase II Conduct ground penetrating radar analysis in areas adjacent to Newcastle Cemetery, if conditions are determined appropriate. Final, Phase II If the selected alternative presents potential operational impacts to eligible or listed historic properties, mitigation measures would depend upon the nature of the property and the characteristics contributing to its significance. If impacts to a designated King County Landmark are proposed, the project will be subject to the COA process with the King County Landmarks. Phase I Operational impacts to aboveground resources may include noise, vibration, and views. The impacts to each identified historic resource will need to be assessed individually to determine mitigation measures, which may include redesign options or measures to minimize noise and vibration impacts. Phase I
FINAL EIS PAGE M‐29 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source During Construction Develop mitigation measures during consultation with DAHP, affected Tribes, and any other appropriate stakeholders if a protected archaeological resource is identified during construction. In accordance with RWC 27.53, an archaeological resource identified during construction is protected until DAHP determines whether it is eligible for listing in the NRHP.1(Regulatory Requirements) Final, Phase II Follow procedures dictated by state law (RCW 27.44) if human skeletal remains are discovered. (Regulatory Requirements) Final, Phase II Obtain an excavation permit from DAHP if unmarked graves would be disturbed. (Regulatory Requirements) Final, Phase II Follow the procedures identified in the IDP if any cultural resources are encountered during construction. Final, Phase II During Operations None Final, Phase II EMF Prior to Construction No adverse impacts from magnetic fields are expected; therefore, no mitigation is proposed. Final, Phase II During Construction No adverse impacts from magnetic fields are expected; therefore, no mitigation is proposed. Final, Phase II During Operations No adverse impacts from magnetic fields are expected. If radio frequency interference is found, PSE would de‐tune pole structures by installing hardware (such as arresters). Mitigation for potential corrosion of the pipeline is discussed in Section 4.9.7, Mitigation Measures (for Pipeline Safety). Mitigation for potential corrosion of the pipeline could include optimizing the geometry of the phase conductors in a triangular pattern, which results in higher cancellation of magnetic fields, as discussed in the Phase 2 Draft EIS (Section 3.8.5.1) (DNV GL, 2016). If that mitigation is incorporated into the project, it would further reduce magnetic field levels at the ground level from the proposed transmission lines. Final, Phase II 1 Isolated (single) artifacts, either precontact or historic, are not protected because they do not meet the definition of a “site” under state law (WAC 25‐48‐020(9)).
FINAL EIS PAGE M‐30 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Pipeline Safety Prior to Construction Continue to coordinate with Olympic and include safeguards in the project design to protect nearby pipelines from interaction with the new transmission lines due to AC current density, faults caused by lightning strikes, mechanical/equipment failure, or other causes. Final, Phase II Perform an AC interference study incorporating the final powerline route, configuration, and operating parameters to confirm that current densities would remain within acceptable levels, and inform Olympic of any locations where additional measures may be needed to protect the pipelines. Final, Phase II Obtain and incorporate all of the pipeline parameters required for detailed modeling and study (i.e., locations and details of above‐grade pipeline appurtenances/stations, bonds, anodes, mitigation, etc.). This should include a review of the annual test post cathodic protection survey data. Final, Phase II Fully assess the safety and coating stress risks for phase‐to‐ground faults at powerline structures along the entire area of co‐location, including both inductive and resistive coupling. Final, Phase II Fully assess the safety and AC corrosion risks under steady state operating conditions on the powerline. Final, Phase II Reassess the safe separation distance at each pole location to minimize arcing risk based on NACE SP0177‐2014 and considering the findings in CEA 239T817 (Stantec, 2017). Final, Phase II Ensure that the separation distance between the pipelines and the powerline structures exceeds the safe distance required to avoid electrical arcing by installing pole grounds at appropriate distance from the pipeline based on engineering analysis. Final, Phase II In areas where the pipelines are within the modeled arcing distance of transmission line pole grounding rods, incorporate mitigation measures into the project design to prevent ground fault arcing to the pipelines (see Section 4.9.5.5 for information on arcing distances). Recommended measures to incorporate into the project design may include installing arc shielding protection, consisting of zinc ribbon, copper wire, or other acceptable means extending a minimum of 25 feet past the transmission line pole grounding rods in both directions. The arc shielding protection should be designed so that it is connected to the pipelines through a single direct‐current decoupler. Phase II
FINAL EIS PAGE M‐31 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source File a mitigation and monitoring report with the Partner Cities demonstrating that sufficient safety factors have been incorporated into design, and documenting all consultations with Olympic, including the sharing of modeling and engineering information with Olympic to assist Olympic in its monitoring and mitigation responsibilities. The report should include a plan that identifies the process for conducting additional field surveys and data collection for identifying mitigation measures following project start‐up, and proposed monitoring to ensure that mitigation related to operational issues is followed. Final, Phase II Install Optical Ground Wire (OPGW) shield wire on the transmission line poles. Final Apply the results and recommendations of the AC Interference Study (DNV GL, 2016) to the design of pole locations, layout, and configuration. Phase II Optimize conductor geometry, where a true delta configuration provides the greatest level of field cancellation. Phase II During project design, field verify the distances between the pipelines and transmission line poles grounding rods. Phase II Design AC mitigation (as required) to ensure that all safety and integrity risks have been fully mitigated along the collocated pipelines. Phase II Design monitoring systems to monitor the AC corrosion risks along the pipelines. Phase II At Project Startup Work with Olympic to evaluate and implement appropriate mitigation measures to reduce electrical interference on the Olympic Pipeline system to safe levels. (Olympic has informed PSE that, after the system is energized, it plans to collect field data to assess the necessity for the installation of AC grounding or similar systems to address steady‐state conditions. Olympic has informed PSE that it plans to implement appropriate mitigation measures to the extent needed based on its analysis of field data collected following system energization. AC grounding systems are commonly installed in connection with power transmission poles to dissipate any energy to ground.) Final, Phase II Verify arc distances once poles are installed and, where necessary, install ground wires or other grounding systems to ensure that pole grounds are all adequately separated from the pipelines. Final Mitigation that Olympic could provide based on the results of the analysis may include the installation of additional protective measures such as grounding mats, horizontal surface ribbon, and/or deep anode wells based on a detailed mitigation study, as appropriate. Final
FINAL EIS PAGE M‐32 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Install and commission the AC mitigation and monitoring systems prior to energization of the 230 kV powerline. Phase II Install Optical Ground Wire (OPGW) shield wire on the transmission line poles. Phase II After energization, perform a site survey to ensure that all AC interference risks have been fully mitigated under stead‐state operation of the powerline. Phase II Install additional grounding based on the results of the detailed engineering/mitigation analysis conducted by Olympic. Final mitigation measures and design would be based on field data collected after the system is energized. Mitigation may include the installation of additional protective measures such as grounding mats, horizontal surface ribbon, and/or deep anode wells based on a detailed mitigation study. Phase II During Operations If indicated by the AC interference study conducted for final design, inform Olympic when the electrical system is expected to operate at or near winter peak loading so as to provide Olympic a reasonable opportunity to take appropriate steps to measure actual AC current densities. Final To detect any unexpected changes between the pipeline and transmission line, provide information to Olympic as necessary for Olympic to record AC pipe‐to‐soil potentials and DC pipe‐to‐soil potentials during their annual cathodic protection survey. Final, Phase II Provide Olympic with as much advance notice as practical of when outages are planned on the individual circuits, as the AC induction effects on the pipelines may be magnified when only one circuit (of the double‐circuit transmission lines) is energized. Final, Phase II Provide the Partner Cities with PSE monitoring data on maximum currents under peak winter operating conditions. Final Operate both circuits at 230 kV to address the AC current load imbalance between the two circuits (see Section 3.9.5.5 for information on AC current load imbalance). Although the other proposed measures listed in this section are anticipated to fully address potential external corrosion issues related to the current imbalance, this measure is recommended, where feasible, to reduce or eliminate the potential for electrical interference with the pipeline. Phase II Inform Olympic when the electrical system is operating at, or near, winter peak loading so that Olympic can conduct testing to ensure that AC current densities do not exceed 20 amps per square meter in areas where AC current density has been predicted by the AC Interference Study (DNV GL, 2016) to exceed 20 amps per square meter. PSE would inform the Partner Cities upon completion of Olympic monitoring and/or mitigation. Phase II
FINAL EIS PAGE M‐33 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Inform Olympic when loading scenarios are expected to be at their greatest to ensure that Olympic conducts field monitoring and/or mitigation for AC potential greater than 15 volts and AC current density greater than 20 amps per square meter throughout the project corridor. PSE would inform the Partner Cities upon completion of Olympic monitoring and/or mitigation. Phase II Economics Prior to Construction None Final During Construction Replace trees removed for the project based on tree protection ordinances and critical areas regulations in each jurisdiction; some of these trees would likely be planted off‐site or, in the case of the City of Newcastle, mitigated by paying into an in‐lieu fee program. Replacement may be based on cross‐sectional diameter of trees removed, or on habitat functions lost due to tree removal, depending on applicable regulations. Plants and Animals, Water Final During Operations Mitigation for economic impacts from a project is not required under SEPA; however, potential impacts to City revenues due to decreased assessed value for property could be mitigated by an adjustment to the mil rate for all taxpayers or a reduction in expenditures to match the reduced revenues. Phase II Earth Resources Prior to Construction Confirm that a Washington State licensed geotechnical engineer has conducted geotechnical hazard evaluations for all proposed elements addressing groundshaking, fault rupture, liquefaction, and landslides, and that all geotechnical recommendations have be incorporated into project design. Final Design Richards Creek substation project in accordance with the design recommendations presented in the project geotechnical report GeoEngineers 2016). This will ensure that substation structures will be designed to IBC seismic standards even though the IBC exempts this project from its requirements. Final
FINAL EIS PAGE M‐34 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Use the 2012 International Building Code (IBC) parameters for short period spectral response acceleration (SS), 1‐second period spectral response acceleration (S1), and Seismic Coefficients FA and FV presented in Table 2 of the geotechnical report (GeoEngineers 2016). Final Use site‐specific soil input parameters for lateral load design that consider the effects of liquefaction through the application of p‐multipliers for LPILE parameters. Final For the area north of the proposed Richards Creek substation, reevaluate the lateral spreading risk to the proposed poles in this area once their final location has been determined, to determine appropriate foundation dimensions. Final Where liquefiable deposits are present, extend foundations below the loose to medium density liquefiable deposits into underlying dense, non‐liquefiable soils. Final Reevaluate the axial capacity of the pole foundations and potential downdrag loads for poles in liquefiable deposits once final locations are selected, and consider these in the structural design. Final For the one location where soil test results indicated a moderate to high potential for corrosion consider engaging a corrosion engineer. Final Where bedrock is near the surface, additional options such as rock anchors or micropiles might be appropriate as an alternative to drilled shafts. If micropiles are used, the contractor should submit a detailed micropile plan describing methods and demonstrating consistency with specifications. Final The contractor should submit a detailed drilled shaft installation plan describing casing and drilled shaft construction methods for review and comment by the engineer before construction. The submittal should include a narrative describing the contractor’s understanding of the anticipated subsurface conditions, the overall construction sequence, access to the pole locations, and the proposed pole foundation installation equipment. Final The contractor should submit a detailed direct embedment pole installation plan describing both uncased and temporary casing methods. Final During Construction If drilled shafts are used where groundwater is present, the concrete for drilled shafts should be placed using the “tremie” method (described in geotechnical report). Final
FINAL EIS PAGE M‐35 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Monitor the installation of the drilled shafts to confirm that soil conditions are as anticipated and that the shafts are installed in accordance with project plans and specifications, document variations in the field if necessary, and provide consultation as required should conditions vary from those anticipated. Final Where sensitive structures may be present within about 100 feet of the work area, vibration should be monitored. Final During Operations Develop a monitoring and maintenance program that includes inspection and reporting on structural stability. Final As part of PSE’s regular inspection of the transmission line, monitor all improvements for changes in conditions such as cracking foundations or slumping slopes that could reduce the ability of structures to resist seismic disturbances. This could include regular reporting to permitting agencies to ensure compliance. Final If changes are identified during inspection and monitoring of conditions, implement additional measures to reduce or minimize those impacts. Final Monitor all improvements for changes in conditions such as cracking foundations, slumping slopes, or loss of vegetative cover. Phase I Implement inspection and maintenance programs for all improvements to ensure consistent performance and stability. Phase I Comply with relevant state and local critical areas codes. Phase I Energy and Natural Resources (Phase I Only) Prior to Construction None Phase I During Construction None Phase I During Operations None Phase I
FINAL EIS PAGE M‐36 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Noise (Phase I Only) Prior to Construction Substation/Transformer Operational Noise. Although electrical substations are exempt from the maximum permissible noise levels established in Chapter 173‐60 of the Washington Administrative Code, the transformers could result in a noticeable increase in local ambient noise levels and therefore elicit an adverse community reaction. If new transformers are proposed for installation in a new substation facility, siting of that facility should consider the proximity of sensitive land uses. Site plans should include noise attenuation measures as necessary to maintain noise levels at the nearest receptors within 5 dBA of existing ambient noise levels. Static sound barrier curtains can provide sound transmission loss of 16 to 40 dBA, depending on the frequency of the noise source (ENC, 2014). Phase I During Construction Nighttime Construction Noise. For project elements that would require prolonged nighttime construction activities, portable acoustical barriers may be used to reduce noise. Moveable sound barrier curtains can provide 15 dBA of sound attenuation (INC, 2014). Static sound barrier curtains can provide sound transmission loss of 16 to 40 dBA, depending on the frequency of the noise source (ENC, 2014). Phase I During Operations Distributed Energy Operation Noise. The following distributed generation sources have the potential to result in minor to moderate operational noise impacts: wind turbines, gas turbines, anaerobic digesters, reciprocating engines, and microturbines. Siting of facilities that would operate these types of equipment should consider the proximity of sensitive land uses. Site plans should include noise attenuation measures as necessary to maintain noise levels at the nearest receptors within 5 dBA of existing ambient noise levels. Static sound barrier curtains can provide sound transmission loss of 16 to 40 dBA, depending on the frequency of the noise source (ENC, 2014). The efficacy of such barriers would depend on the surrounding elevations of the plant and receptors, and air flow requirements of the plant that might prohibit ceiling barriers. Exhaust stack silencers are also widely available for electrical generator engine applications. Phase I
FINAL EIS PAGE M‐37 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Public Services (Phase I Only) During Operations Substation Fire Risk. In order to reduce the risk of substation fire, PSE would routinely do the following: Install relays and circuit breakers to shut down equipment experiencing a fault or malfunction. Install systems to conduct lightning to the ground rather than through lines or equipment. Use sulfur hexafluoride (SF6) gas for closely spaced equipment. SF6 is a nonflammable gas and an excellent insulator. Phase I Monitor oil insulation for evidence of arcing and gassing. Monitor substations for evidence of overloading, overheating, or malfunctions. Phase I Utilities (Phase I only) Prior to Construction Coordination with Other Utility Providers. PSE would site new transmission lines according to industry best practices, which includes proper positioning and design (separation and grounding) relative to other utilities. For all alternatives, coordination with the individual utility providers would be required to determine whether or not existing and future utilities could be affected and how best to avoid or minimize those impacts. PSE would work with other utility service providers during design and construction of the project to coordinate the placement of new facilities and ensure protection of other utilities. In some instances, vibration and settlement monitoring may be required where construction would occur near existing utilities. Pipeline Safety Phase I Coordination with Other Projects: PSE would coordinate all construction needs and impacts of this project with the other infrastructure and development projects in the combined study area. This would typically be done as part of the permitting process with each community affected by potential construction. Phase I Utility Location: PSE would follow regulatory requirements to correctly locate and plan for other utility locations such as gas lines or the OPLC pipelines prior to start of construction, including showing pipeline locations on plans and requiring contractors to field locate utilities. Prior to the start of construction, existing utilities would be located and field‐verified where feasible to avoid conflicts with the proposed facilities. Pipeline Safety Phase I
FINAL EIS PAGE M‐38 APPENDIX M SUMMARY OF MITIGATION MEASURES MARCH 2018 Mitigation Measures (Operations) Related Resources Phase/ Source Utility Relocations. PSE and its contractors would be required to develop construction sequence plans and coordinate schedules for utility work to minimize service disruptions and provide ample advance notice when service disruptions are unavoidable, consistent with utility owner policies. Relocation plans and service disruptions would be reviewed and approved by the affected utility providers before construction begins. PSE would develop a plan for public outreach to inform customers of potential service outages and construction schedules. The public outreach effort would be coordinated with other utility service providers. Phase I During Construction None Phase I During Operations None Phase I