To: Karen Miller, Public Advisor at CPUC
Moorpark-Newbury 66 kV subtransmission Project -10/18/13 Notice of Appllication for PTC Number A1...
We protest Edison's proposed Moorpark-Newbury 66 Kv Subtransmission Project based on the public/environmental impact it will cause, such as: EMF exposure, brush fire hazard, earthquake hazard, habitat threats, greenhouse gas emissions, and more. We request an Environmental Impact Report with a public hearing and ask the CPUC to propose an alternative route for this power line.
Why is this important?
SCE seeks to construct a new Moorpark-Newbury 66 kV sub-transmission line in a right-of-way (ROW) that has served for decades exclusively as a 220 kV transmission corridor (providing power from Ormond Beach to the Moorpark substation). An existing Moorpark-Newbury 66 kV sub-transmission line runs parallel to it through a 2-mile wide green belt, approximately 1800 feet to the west.
We are writing to protest this plan and request that any enhancement of the Moorpark-Newbury line be contained within the existing sub-transmission corridor. This may entail some additional expense to enhance the east-west run from the substation. However, it is reasonable and prudent in order to keep the potential hazards and burden of the new sub-transmission lines from compounding the burden already born by homeowners adjacent the existing 220 kV facilities. SCE admits it has studied no alternative site.
Background:
The ROW in question abuts the residentially zoned communities of Santa Rosa Valley and Moorpark (to its east). It also forms the eastern boundary of a 2-mile wide swath of Open Space (O-S) and Agricultural (A-E) zoning. (The existing 66 kV ROW lies entirely within this swath.)
Discussion:
The proposed project addresses no immediate need, but rather an anticipated possible future overload of the existing 66 kV line. According to SCE, the existing line has never lost power. Even in the “worst case” scenario projected by SCE (i.e., heat storm peak loading), “de-energized distribution” is admittedly a mere possibility. Further, this “need” assessment was made in 2005, based on the 2003-04 housing boom and prior to our dire economic crisis. It also predated the explosion of private solar electrical systems. Reassessment may reveal that projected growth and “need” have not occurred. Thus, at best, this is a preventative, possibly unnecessary, “rainy day” measure.
The project is not entitled to Exemption G status. Constructing a sub-transmission power line facility in the shadow of a 220 kV transmission line creates hazards (see below) not contemplated in the granting of exemption under Section III.B.1. Rather, for public and environmental protection, this proposal should undergo the scrutiny required for permits under General Order 131-D, Section III.B.
Several environmental concerns mitigate in favor of relocating the project to the existing 66 kV easement approximately 1800 feet west of the proposed site:
1. Brush Fire Hazard
The easement traverses an extremely fire sensitive rural residential region. As evidence by last week’s wind-driven Porter Ranch fire, it is long past time to get serious about this hazard and its proximity to populated areas.
Each year, our annual “red flag” wind season downs power lines, some of which ignite brush fires. Last year, the season began in September and did not relent until late-Spring 2008, with winds sometimes gusting at near-hurricane force. As reported in the LA Times, 10/18/08, Section A, page 20, electrical lines ignited four
of the State’s 20 worst fires. The loss of life and property attributable to electrically ignited brush fires is staggering.
The proposed project moves this ignition point 40 feet nearer to populated residential areas; whereas enhancing the existing Moorpark-Newbury-Pharmacy would bury it deep within the buffer of the 2-mile wide green belt.
2. Earthquake Hazard
SCE has explained that, because earthquakes are considered “unpredictable,” it has no earthquake structural fortification requirements. SCE proposes to erect new TSPs in Section 2 of the project right on top of the Simi-Santa Rosa fault line. It is a very active fault line. The 220 kV towers have withstood numerous earthquakes. On one occasion, the force caused the 220 kV lines to slap together, creating sparks. Given their proposed proximity, the new TSPs could topple into the 220 kV wires, or perhaps worse, onto our homes and properties.
3. Compound EMF Exposure
Another potential hazard is EMF exposure. While acknowledging its inability to verify a relationship between EMFs and negative health consequences, the CPUC affirmed its cautious policy of prudent avoidance of EMF exposure (D.06-01-042). In doing so, it implicitly acknowledged the existence of scientific evidence correlating illness with EMF exposure.
Prudence mitigates in favor of locating the new 66 kV lines in the existing sub-transmission line deep within the green belt. This would avoid compounding EMF exposure at the 220 kV line, which flanks so many residential properties.
4. Other Environmental Concerns
The ancient native chaparral that blankets our hilltop to the east of the 150’ tower is sensitive habitat for several endangered species of birds as well as native plants. By locating the new TSP within the 100’ buffer that currently separates the towers from our property lines, SCE will create a brush clearing burden over our hillside, jeopardizing this important habitat. (This is probably true of any number of neighboring properties along the easement.)
Additionally, the new TSP at the dead-end of Presilla Road will require the removal of a “Heritage Tree” (protected by the Ventura County Tree Protection Ordinance). This tree has a 12-½ foot trunk girth and is approximately 80 feet tall. This tree also visually softens the “industrial” impact of the existing transmission facilities. While
it does not hide the towers, its position in the foreground serves as visual mitigation for all who travel Presilla Road. There may be a number of such protected trees doomed by this proposal.
Pubic Hearing:
A public hearing may not be necessary if the CPUC honors this request for relocation of the project to the existing 66 kV easement within the green belt.
In the event this request is denied, we hereby lodge our protest to the project, request an evidentiary hearing and an Environmental Impact Report, as well as compliance with the permit process of General Order 131-D, Section III.B.
We are writing to protest this plan and request that any enhancement of the Moorpark-Newbury line be contained within the existing sub-transmission corridor. This may entail some additional expense to enhance the east-west run from the substation. However, it is reasonable and prudent in order to keep the potential hazards and burden of the new sub-transmission lines from compounding the burden already born by homeowners adjacent the existing 220 kV facilities. SCE admits it has studied no alternative site.
Background:
The ROW in question abuts the residentially zoned communities of Santa Rosa Valley and Moorpark (to its east). It also forms the eastern boundary of a 2-mile wide swath of Open Space (O-S) and Agricultural (A-E) zoning. (The existing 66 kV ROW lies entirely within this swath.)
Discussion:
The proposed project addresses no immediate need, but rather an anticipated possible future overload of the existing 66 kV line. According to SCE, the existing line has never lost power. Even in the “worst case” scenario projected by SCE (i.e., heat storm peak loading), “de-energized distribution” is admittedly a mere possibility. Further, this “need” assessment was made in 2005, based on the 2003-04 housing boom and prior to our dire economic crisis. It also predated the explosion of private solar electrical systems. Reassessment may reveal that projected growth and “need” have not occurred. Thus, at best, this is a preventative, possibly unnecessary, “rainy day” measure.
The project is not entitled to Exemption G status. Constructing a sub-transmission power line facility in the shadow of a 220 kV transmission line creates hazards (see below) not contemplated in the granting of exemption under Section III.B.1. Rather, for public and environmental protection, this proposal should undergo the scrutiny required for permits under General Order 131-D, Section III.B.
Several environmental concerns mitigate in favor of relocating the project to the existing 66 kV easement approximately 1800 feet west of the proposed site:
1. Brush Fire Hazard
The easement traverses an extremely fire sensitive rural residential region. As evidence by last week’s wind-driven Porter Ranch fire, it is long past time to get serious about this hazard and its proximity to populated areas.
Each year, our annual “red flag” wind season downs power lines, some of which ignite brush fires. Last year, the season began in September and did not relent until late-Spring 2008, with winds sometimes gusting at near-hurricane force. As reported in the LA Times, 10/18/08, Section A, page 20, electrical lines ignited four
of the State’s 20 worst fires. The loss of life and property attributable to electrically ignited brush fires is staggering.
The proposed project moves this ignition point 40 feet nearer to populated residential areas; whereas enhancing the existing Moorpark-Newbury-Pharmacy would bury it deep within the buffer of the 2-mile wide green belt.
2. Earthquake Hazard
SCE has explained that, because earthquakes are considered “unpredictable,” it has no earthquake structural fortification requirements. SCE proposes to erect new TSPs in Section 2 of the project right on top of the Simi-Santa Rosa fault line. It is a very active fault line. The 220 kV towers have withstood numerous earthquakes. On one occasion, the force caused the 220 kV lines to slap together, creating sparks. Given their proposed proximity, the new TSPs could topple into the 220 kV wires, or perhaps worse, onto our homes and properties.
3. Compound EMF Exposure
Another potential hazard is EMF exposure. While acknowledging its inability to verify a relationship between EMFs and negative health consequences, the CPUC affirmed its cautious policy of prudent avoidance of EMF exposure (D.06-01-042). In doing so, it implicitly acknowledged the existence of scientific evidence correlating illness with EMF exposure.
Prudence mitigates in favor of locating the new 66 kV lines in the existing sub-transmission line deep within the green belt. This would avoid compounding EMF exposure at the 220 kV line, which flanks so many residential properties.
4. Other Environmental Concerns
The ancient native chaparral that blankets our hilltop to the east of the 150’ tower is sensitive habitat for several endangered species of birds as well as native plants. By locating the new TSP within the 100’ buffer that currently separates the towers from our property lines, SCE will create a brush clearing burden over our hillside, jeopardizing this important habitat. (This is probably true of any number of neighboring properties along the easement.)
Additionally, the new TSP at the dead-end of Presilla Road will require the removal of a “Heritage Tree” (protected by the Ventura County Tree Protection Ordinance). This tree has a 12-½ foot trunk girth and is approximately 80 feet tall. This tree also visually softens the “industrial” impact of the existing transmission facilities. While
it does not hide the towers, its position in the foreground serves as visual mitigation for all who travel Presilla Road. There may be a number of such protected trees doomed by this proposal.
Pubic Hearing:
A public hearing may not be necessary if the CPUC honors this request for relocation of the project to the existing 66 kV easement within the green belt.
In the event this request is denied, we hereby lodge our protest to the project, request an evidentiary hearing and an Environmental Impact Report, as well as compliance with the permit process of General Order 131-D, Section III.B.