HomeMy WebLinkAboutC_Public_Comment_08_180327.email_attch2of2Jeanne DeMund
2811 Mountain View Ave. N.
Renton, WA 98056
March 27, 2018
Jill Ding
Senior Planner
Planning Division
Community & Economic Development
1055 S. Grady Way 6th Floor
Renton, WA 98057
RE: LUA18-000055 Energize Eastside
Dear Ms. Ding,
In addition to my previous comment, I would like to provide these additional comments
regarding the Land Use Application for Energize Eastside.
The Land Use Application for Energize Eastside should be denied for the following reasons:
1. The Energize Eastside project will not benefit Renton.
In Renton’s Comprehensive Plan, Utilities Element, Electricity p. 68 the only GOAL stated
is as follows:
“Promote the availability of safe, adequate, and efficient electrical service within
the City and its planning area, consistent with the regulatory obligation of the
utility to serve customers.”
Energize Eastside’s goal is to provide electricity for needs occurring in downtown
Bellevue. It is not needed for growth in usage or peak demand shortfalls in Renton.
2. The Energize Eastside capacity increase is not needed.
At the beginning of the-now $50 million and counting planning process PSE maintained
that electricity consumption was growing at 2.4%/year and rolling blackouts were a risk
beginning in winter of 2017-2018. A graph to that effect was prominently featured on
the Energize Eastside website. That graph has been removed from the website , and
growth is no longer touted as a justification for the project. The attached graph from
the City of Bellevue’s website shows overall electricity consumption is flat or falling
2011-2016.
This trend is not unique to Bellevue. It is a trend that all electric utilities are facing, as
conservation measures, green building codes, increased use of LED lighting, smart
appliances, etc. decrease need even in the face of building booms and population
growth.
Even the WUTC agreed that there were flaws in the Energize Eastside needs analysis:
“As stated above, the IRP must include a needs assessment of the transmission and
distribution system. During the course of the IRP process, PSE provided a number of
studies in support of the reliability need it identified and potential alternative solutions
to the Energize Eastside project.
“However, the time allocated by PSE to discuss these and other studies during the IRP
advisory group meetings was not sufficient to examine the studies in detail. This left
some basic questions unresolved. For example Staff concerns include a lack of narrative
in the IRP regarding:
The effect of the power flows due to entitlement returns on the need for
the Energize Eastside project.
The reason for, and effect on the need for Energize Eastside, of modeling
zero output from five of PSE’s Westside thermal generation facilities.
PSE’s choice not to provide modeling date to stakeholders with Critical
Energy Infrastructure Information clearance from FERC.”
(2017 PSE IRP WUTC Staff Comments, 2/6/2-18 page 16 of 22)
This last point highlights PSE’s unwillingness to engage in an open, honest and
transparent public process, respecting citizen engagement and input, which certainly is
incongruent with Renton’s Comprehensive Plan Mission dedication to, “building an
inclusive, informed city with opportunities for all”.
3. PSE did not adequately evaluate alternatives to Energize Eastside to handle any peak
demand shortfalls that may occur.
The chart above shows consumption. PSE argues that consumption isn’t the issue, peak
demand is. Alternatives to PSE’s preferred pole and wire solution for meeting peak
demand were given short shrift, analyses were flawed, and the public was not once
permitted to question this aspect of the project. Furthermore, t echnology development
has not stood still since 2014 when PSE began the public process promoting Energize
Eastside. Battery, smart grid and other technologies have increased in efficiency and
decreased in cost to such an extent that an array of safer, cleaner and, very importantly,
cheaper alternatives must be re-evaluated.
4. Energize Eastside will cause Renton to suffer environmental degradation, visual
degradation, and impacts to adjacent land as a result of Energize Eastside.
Renton will suffer environmental degradation in the form of lost tree canopy. Mature
trees will be cut down, to be replaced with smaller trees (less biomass) and perhaps
trees in other locations that will not provide local the environmental benefits of the
trees that are removed. PSE has attempted to assuage concerns in the LUA and FEIS by
pages and pages of verbiage describing potential mitigation. However, they clearly state
on page 7 within the Conditional Use Permit Justification, “Although not required to
replace those trees that are removed…”. If the LUA is approved, it appears that
replacement will be at PSE’s discretion, not under Renton’s control.
Another form of environmental degradation will be the large volume of solid waste
generated by the removal of several hundred still-serviceable creosote-treated wooden
poles. This is in contradiction of the Renton Comprehensive Plan Policy U-55 p. 64
recommending overall reduction of residential and commercial solid waste streams.
Visual degradation will come in the form of poles that are significantly taller and thicker
than the current poles. These poles will loom over homes, schools, churches, daycares,
businesses, parks and streets.
Impacts to adjacent land will occur as Energize Eastside turns a swath of Renton’s
residential, business and commercial areas inappropriately into an industrial corridor.
Thank you for including these comments in the record for evaluating Energize Eastside. I
hope that City of Renton staff will make a recommendation to the Hearing Examiner
that LUA18-000055 should be denied.
Sincerely,
Jeanne DeMund