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HomeMy WebLinkAbout2007-02-13 - AGENDA REPORTS - EDISON 500 KV LINE (2)NEW BUSINESS DATE: SUBJECT: DEPARTMENT: Agenda Item: q CITY OF SANTA CLARITA AGENDA REPORT City Manager Approval: Item to be presented by: February 13, 2007 SOUTHERN CALIFORNIA EDISON'S 500 KV TRANSMISSION LINE Community Development RECOMMENDED ACTION City Council direct staff to send the attached letters to the California Public Utilities Commission (CPUC) and the United States Forest Service (USFS). BACKGROUND Southern California Edison is proposing to construct a series of 500 Kv electric transmission lines from the Antelope Valley to the Pardee substation located in the Valencia Industrial Center inside City limits. These transmission facilities will transport electricity generated from future wind farms in the Antelope Valley to the Pardee substation, where it will then be distributed throughout the region. Beginning in the Antelope Valley, the transmission facilities will head south across the Angeles National Forest. The transmission lines will leave the Forest in the area of Haskell Canyon where they will then turn west then southwest to the substation. The facilities will follow existing Edison right-of-way through about 5 miles of existing neighborhoods located both inside and adjacent to the City. An aerial map of the proposed route is attached to the attached letter. The proposed project will remove a series of existing approximately 150 -foot tall lattice towers supporting three transmission lines and replace them with lattice towers up to 220 feet in height with six transmission lines. The project is subject to the California Environmental Quality Act (CEQA) and the National Environmental Policy Act (NEPA), for which the CPUC and USFS are the lead agencies, respectively. A Draft Environmental Impact Report (DEIR) and Draft Environmental Impact Statement (DEIS) were circulated for public comment in August/September of this year. The City provided comments. The Final EIR/EIS (FEIR/FEIS) is now available for public review. On January 30, CPUC staff issued a recommendation to the CPUC regarding the certification of the EIR and approval of the project. The recommendation includes the construction of tall towers and power lines through the City and residential neighborhoods. City staff believes this recommendation to be in error, as it is based on a flawed environmental document. There will be a 30 -day review period of the recommended action prior to certification. The USFS will be preparing a Record of Decision in the near future, which will also be subject to a public review period. On January 16, 2007, staff met with the Council's Development Subcommittee to discuss the issue. The Subcommittee agreed with staff's position that the EIR/EIS was in violation of CEQA/NEPA and suggested that staff should write a letter to each of the lead agencies citing the various violations and that the letter should be reviewed and authorized by the full Council. The letter is attached. ANALYSIS The DEIRMEIS and the FEIR/FEIS violate both CEQA and NEPA in many ways. These violations are outlined in detail in the attached letter. Therefore, only a summary of these violations is below. Both DEIR/DEIS and FEIR/FEIS: Fail to provide an accurate and complete Project Description and establish an accurate environmental baseline. Fail to provide a project alternative that will avoid and/or lessen the significant impacts that the proposed project and all of the proposed alternatives will have on the residential neighborhoods. These residential areas are provided with no project alternative that does not include the significant, unavoidable impacts associated with the construction of large towers with multiple transmission lines through their neighborhoods and adjacent to residences, parks, and schools. • Fail to adequately address the potential impacts of electro magnetic fields (EMF) on residents. • Fail to adequately address potential terrorist attacks. • Fail to adequately address the City's concerns and suggestions made during the DEIR/DEIS public comment period. Fails to cite, include, or reference in any way additional environmental analysis prepared by the CPUC and the comments regarding that analysis that were elicited from the City by the CPUC. The violations are extensive, as is outlined in the attached letter. The project will adversely impact both City and unincorporated County residents. The City Attorney's Office has reviewed the letter and concurs with its conclusion. The DEIR/DEIS and FEIR/FEIS are located in the City Clerk's Reading File. ALTERNATIVE ACTIONS Council may choose not to direct staff to send the attached letter to the California Public Utilities Commission and the United States Forest Service. Other direction as determined by the City Council. FISCAL IMPACT None. ATTACHMENTS Letter to the CPUC/USFS DEIR/DEIS and FEIR/FEIS available in the City Clerk's Reading File DRAFT' February 14, 2007 Angela K. Minkin Administrative Law Judge Room 5101 505 Van Ness Avenue San Francisco, CA 94102 Jody Noiron, Forest Supervisor Angeles National Forest Supervisor's Office 701 N. Santa Anita Ave. Arcadia, CA 91006 Subject: Antelope -Pardee 500 -kV Transmission Project California SCH #2005061161 Federal Docket No. 05-12734 Dear Judge Weissman: The City of Santa Clarita believes that the environmental review process for the above -referenced project has circumvented the California Environmental Quality Act (CEQA) and the National Environmental Policy Act (NEPA) and that analysis contained in the Final document is flawed. In addition, the City feels that its comments, concerns and input during the public review period for the Draft Environmental Impact Report/Statement (DEIR/DEIS) have not been fully considered or adequately addressed in the Final EIR/EIS (FEIR/FIES). As such, any recommendations or decisions based upon the EIR/EIS, such as the proposed decision of the Administration Law Judge Division of the CPUC, dated January 30, 2007, are in error. The proposed project will construct towers up to 220 feet in height that will support 500 -kV transmission lines in right-of-way through about 5 miles of existing residential neighborhoods located both within and abutting City limits. The City's concerns are mainly focused on this area (mile 20.3 to 25.6). Circumvention of CEOA and NEPA Project Description The project description is patently flawed. The maps utilized in the Executive Summary and the Project Description in Section B of the FEIR/FEIS, specifically February 14, 2007 Page 2 Figures ES -1 (updated) and B.2-1 (updated), which indicate the proposed project route, are incorrect and therefore misleading. The maps do not reflect the accurate City boundaries and, as a result, falsely indicate that the project is not impacting the City to the extent that it will. This is an inadequate project description and violates CEQA and NEPA. In the City's initial comment letter on the DEIR/DEIS dated September 29, 2006, the City indicated that the maps being used in the DEIR/DEIS were incorrect. In the response to this comment in the FEIR/FEIS (A.8-1) it states that the maps in the FEIRIFEIS have been updated and are accurate, specifically referring to Figures ES -1 and B.2-1, yet the City's boundaries are still significantly inaccurate in both Figures. The attached aerial map indicates the City's accurate boundary and the actual significant distance that project will travel through the City. These boundaries have been in place since March 2006 and have been available to the public since then, long before the FEIR/FEIS was prepared. Response to Comment A.8-1 continues with the statement that "The Land Use discussion has also been updated accordingly" based on these "updated" (though incorrect) maps. Because the Land Use discussion was based on incorrect maps, the discussion is flawed. In fact, because the maps used in the overall project description are incorrect, all discussion based on the project description is flawed. Also, the maps throughout the DEWDEIS and the FEIR/FEIS are incorrect and misleading, which was also discussed in the City's initial comment letter. For instance, Figure B.2 -2e (only one example of many), which is included in the Project Description, shows the proposed project route. The map is dated June 20, 2006. Looking at the map, it appears that the proposed route bi-passes just about all of the developed areas in and around the City, which are indicated by the dark shading and underlying streets. However, this is not the case. Though dated June 2006, the base map used is so old that it does not reflect the extensive development that has occurred throughout the area in the last 10-15 years. Extensive residential development now exists on both sides of the project route. The route cuts right through about 5 miles of this developed area, none of which is shown on the map. This is highly misleading. A resident of the area may look at this map, be mislead into thinking that the project avoids residential areas and be led to falsely conclude that the project will not impact him/her, when in fact, it may be located adjacent to his/her home. In response to the City's comments regarding these incorrect and misleading maps, Response A.8-8 states that the maps used "were the most current available at the time", the "time" being June 28, 2005, the date of the NOP. These residential areas were in existence several years before June 28, 2005. Maps showing these developments were widely available long before June 28, 2005 from the County of Los Angeles, the City of Santa Clarita, and even in the Thomas Guide for the last several years. To claim that they weren't is false. Also, one would assume that after the comments where made in the DEIR/DEIS some February 14, 2007 Page 3 attempt would have been made to update these maps for the FEIR/FEIS. This did not occur. These incorrect, inaccurate, and outdated maps violate the goal of CEQA and NEPA, which is to accurately inform the public and decision makers of the potential impacts of a project. The use of these maps renders the Project Description and the baseline faulty. Discussion based on a faulty Project Description and baseline is also faulty. Also, the acknowledgment in Response A.8-8 that these maps are inaccurate yet they remain uncorrected in the FEIR/FEIS may be perceived as an attempt to intentionally mislead the public. Project Alternatives None of the project alternatives evaluated in the EUVEIS (with the exception of the No Project Alternative) avoid constructing large towers and transmission lines through residential neighborhoods. The EIR/EIS demonstrates that the construction and on-going operation of these new transmission facilities will have significant permanent and temporary impacts to these residential communities in the areas of visual resources, air quality, and noise. There has been no attempt to develop or study a project alternative or alternative location that would eliminate or reduce these significant impacts. The only alternative that was evaluated for this project in these neighborhoods, Alternative 3, was itself determined to result in the same significant unavoidable impacts as the proposed project. This is a violation of both CEQA and NEPA. CEQA Section 15126.6 states: (a) An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. (b) Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have ... the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project... (c) The range of potential alternatives... shall include those that ... could avoid or substantially lessen one or more significant impacts. NEPA Regulations Section 1502.14 (a) states that the EIS shall: February 14, 2007 Page 4 (a) Rigorously explore and objectively evaluate all reasonable alternatives It is clear that all reasonable project alternatives are to be evaluated in the EIR/EIS. Further clarification of the alternatives that are to be included is provided in NEPA Regulations Section 1500.2, the various subsections of which state: (e) Use the NEPA process to identify and assess the reasonable alternatives to proposed actions that will avoid or minimize adverse effects of these actions upon the quality of the human environment. (f) Use all practicable means, consistent with the requirements of the Act and other essential considerations of national policy, to restore and enhance the quality of the human environment and avoid or minimize any possible adverse effects of their actions upon the quality of the human environment. Finally, NEPA Regulations Section 1502. 1, states of the very purpose of the EIS is that it: ...shall inform decisionmakers and the public of the reasonable alternatives which would avoid or minimize adverse impacts or enhance the quality of the human environment. It is clear that CEQA and NEPA require alternatives to the project or the project's location that reduce or eliminate potentially significant impacts. Both also require impacts to be mitigated to the extent feasible. There has been no alternative proposed that would reduce or eliminate significant impacts to these residential communities. Alternative 3 does not comply with CEQA or NEPA because this alternative itself will result in the same significant unavoidable impacts as the proposed project, as acknowledged in the FEIR/FEIS. Additionally, no adequate mitigation has been provided to alleviate the impacts of the project or Alternative 3. Though Alternative 1, the undergounding of the transmission facilities through a portion of the City, has been retained in the FEIR, this Alternative addresses the impacts to only a portion of the residential areas being discussed. Also, in a meeting with Southern California Edison, Edison staff indicated to City staff that they were opposed to this Alternative due to its unproven feasibility, high cost, the inaccessibility of the transmission facilities, the significant amount of right-of- way that would be occupied, and the need to construct surface facilities covering several acres. The FEMIFEIS seems to substantiate these and many more concerns. The City is not confident that this Alternative is feasible or desirable. Alternative 3 and Mitigation Measure V-1 a February 14, 2007 Page 5 Section C.15. of the FEIR/FIES acknowledges the significant unavoidable impacts the project will have on these neighborhoods. It also acknowledges that Mitigation Measure V -la, i.e. the use of tubular steal poles in lieu of the lattice towers, would not mitigate visual impacts from the proposed project, but would themselves be a "significant, unavoidable visual impact" as described under impacts V-10 through V-14. In an attempt to address these significant impacts, Alternative 3 is provided. However, Alternative 3, which is supposed to "avoid or substantially lessen" the significant unavoidable impacts under CEQA and "avoid or minimize adverse effects" of the proposed project under NEPA, does not do so. The DEIR/DEIS and FEIR/FEIS indicate that Alternative 3 itself will cause similar significant visual impacts as the project. The FEIRIFEIS continues that the significant visual impacts from Alternative 3 can be mitigated with the implementation of Mitigation Measure V -la (the use of tubular steel poles). This is contradictory, as the use of steel poles was already acknowledged to result in significant, unavoidable visual impacts. The use of tubular steal poles is not mitigation or a sufficient alternative when they will cause significant, unavoidable impacts in and of themselves. Additionally, the analysis of Mitigation Measure V -la as a mitigation is flawed. The FEIR/FEIS first compares the Mitigation Measure as it applies to the proposed project and, because of the proposed project's taller and wider towers, it concludes it will not mitigate the impacts of the proposed project, as the use of tubular steel pole towers will themselves be a significant unavoidable impact. The analysis then compares the use of tubular steel pole towers to mitigate the impacts of Alternative 3's lower more numerous towers and concludes that it does provide mitigation for these significant impacts because these significant impacts are somehow less severe than those of the proposed project, though it fails to explain how, a violation of CEQA section 15126.4. The comparison to determine the effectiveness of a mitigation measure should not be between the relative severity of the impacts of a project and an alternative, but between the existing conditions and the impacts that either of those projects will have on the existing conditions. Due to the lack of such an analysis, there is no basis to conclude that Mitigation Measure V -la will mitigate the impacts of Alternative 3. Also, Mitigation Measure V -la, as revised in the FEMIFEIS, contains provisions for future studies and documentation to determine exactly where, and if, the mitigation measure will be effective and technically feasible. Since this additional, but necessary, information has not yet been provided, its effectiveness as a mitigation measure is unknown. This is a deferral of mitigation, yet another violation of CEQA, and is not consistent with the definition of "mitigation" contained in NEPA Regulations Section 1508.20. No alternative has been proposed and no adequate mitigation has been provided that will reduce or alleviate the significant impacts that this project and its February 14, 2007 Page 6 alternatives will have on the environment and on residents of the Santa Clarita Valley. This project is in violation of CEQA and NEPA. EMF There has been a failure to comply with NEPA and CEQA with respect to the effects of electric and magnetic fields, commonly referred to as EMF. The Executive Summary, at page ES -5, § ES 1.5, 3rd bullet, leads the reader to believe that the effect of EMFs were considered, noting that areas of controversy considered in the process included "[p]otential health impacts due to the generation of new electric and magnetic fields (EMFs)." But when one goes to Table ES -3, which is described as summarizing the applicable mitigation measures, no mention of EMF can be found. Similarly, in § ES.4.3, CEQA Environmentally Superior Alternative, the second paragraph informs the reader, and the NEPA and CEQA decision makers, that "Consideration was also given to community concerns, such as air quality, EMF ...." Despite these reassuring passages, we find, buried in Section C.5, on p. C.6-27, in the second sentence in the first paragraph, the following: " Further, there are no federal or State standards limiting human exposure to EMFs or substation facilities in California. For those reasons, EMF is not considered in the EIR/EIS as a CEOA/NEPA issue and no impact sienificance criteria or impact statements are Presented. (Emphasis supplied. Thus, after having been led to believe that EMFs were to be considered, we learn that that 'BMF is not considered...." The stated reason for not considering EMF is that "there are no federal or State standards limiting human exposure to EMFs or substation facilities in California." This is a non sequitur, and violates NEPA and CEQA. NEPA and CEQA require consideration of effects on the human environment, and consideration under NEPA and CEQA is not dependent on the existence, or lack, of "federal or State standards limiting human exposure to EMFs or substation facilities in California." Moreover, the discussion of EMF, for what it is worth, is misleading. After discounting EMF concerns, (see C.6-1) the EIR/EIS concedes that there is a concept of "Prudent Avoidance." (See c.6-14.) Tellingly, the EIR/EIS, at p. C.6- 18 summarizes the conclusions of DHS scientists, who "believe that EMF can cause some decree of risk for certain health Problems...." (Last full paragraph on C.6-18, emphasis supplied.) That surely is sufficient evidence to bring EMF within the ambit of those factors which merit consideration under CEQA and NEPA, notwithstanding that "there are no federal or State standards limiting human exposure to EMFs or substation facilities in California." However, the EII2/EIS goes on to a misleading discussion of EMFs highlighted by the inclusion of two tables, C.6.-3 and C.6-4, which have to do with household appliances and EMFs. These appliance comparisons are frequently used by the electric power industry in attempts to fend off concerns over EMFs. The problem is that they are misleading, because typical appliances, such as garbage disposals, coffee pots and can openers are used only for short periods of time. Electric transmission lines are in constant use. February 14, 2007 Page 7 The City contends that the summary dismissal of EMF from consideration in this EIR/EIS, and the misleading nature of the analysis of EMFs, renders this EIR/EIS fatally deficient. Terrorist Threat The EIR/EIS is Deficient as a Matter of Law for Failure to Address the Environmental Effects of Terrorist Attack on the Antelope -Pardee 500 kV Transmission Line. In testimony before the Select Committee on Intelligence of the United States Senate on February 11, 2003, Robert S. Mueller, III, Director, FBI, had this to say about terrorist attacks on powerlines: "Terrorist planners probably perceive infrastructure such as dams and powerlines as having softer defenses than other facilities. Indeed, attacking them could cause major water and energy shortages, drive up transportation costs, and undermine public confidence in the government." This EIR/EIS has absolutely no discussion of the environmental effects of terrorist attack on the proposed Antelope -Pardee 500 kV Transmission Line. Indeed, the only mention of attack on any transmission line is the acknowledgement that "A transmission line could be lost (i.e., removed from service) due to a natural disaster, accident, or even intentional attack." (EIR/EIS at A. Introduction, p. A-8, 1st q, 3rd sentence.) (Emphasis added.) That this failure to address the environmental effects of terrorist attack renders the EIR/EIS fatally deficient is indisputable, especially in light of the recent decision the United States Court of Appeals for the Ninth Circuit in San Luis Obispo Mothers for Peace v. Nuclear Regulatory Commission, 449 F.3d 1016 (9th Cir., 2006), Cert. den., 2007 WL 91466 (Jan. 16, 2007). In that case, the Ninth Circuit held that the failure to consider environmental effects of terrorist attack was not reasonable. The court rejected the contention that the possibility of terrorist attack on a power plant could be dismissed as too remote and speculative, and that the environmental consequences of terrorist attack must be addressed. Id. at 1030. As this EIRJEIS concedes the possibility of attack on a transmission line (EIR/EIS at A. Introduction, p. A-8, 1st paragraph, 3rd sentence) the failure to have addressed the potential environmental impacts of terrorist attack must be the result of a fundamental misunderstanding of the requirements of NEPA (and its California correlative, CEQA) for environmental analysis. In San Luis Obispo Mothers, the court observed that "The Supreme Court has identified NEPA's 'twin aims' as 'plac[ing] upon an agency the obligation to consider every significant aspect of the environmental impact of a proposed action[, and] ensur[ing] that the agency will inform the public that it has indeed considered environmental concerns in its decisionmaking process. Baltimore Gas & Elec. Co. February 14, 2007 Page 8 v. Natural Res. Def. Council, Inc., 462 U.S. 87, ... (1983)."Id. at 1020. Here, the EIR/EIS did not even attempt to meet those standards with respect to the environmental consequence of terrorist attack, and must be found to be deficient. City's Proposed Alternative In the City's comment letter regarding the DEIR/DEIS (dated September 29, 2006), the City indicated that no alternatives had been considered that would avoid or lessen the impacts of the project and that this was a clear violation of environmental law. In this regard, the City and United States Congressman Howard "Buck" McKeon suggested a project alternative that would do so; however, this alternative was not included in the FEIR/FEIS. A map of the proposed project route and the City's suggested alternative is attached. As indicated in the City's previous letter, this alternative is feasible and addresses many on the potentially significant impacts that the proposed project and its alternatives would create. The City firmly believes that this, or a similar, alternative must be provided and adequately evaluated in the EIR/EIS. The responses to the City's comments contained in the FEIR/FEIS fail to adequately justify why this or a similar alternative was not included, as follows. • Response A-8.4 — This response attempts to divert CEQA's requirement for adequate alternatives by inferring that NEPA's less stringent requirements regarding alternatives applies and was met. Certainly, NEPA requirements apply for the FEIS, but CEQA's requirements cannot be ignored for the FEIR. The range of alternatives does not include one that attempts to adequately alleviate the impacts as discussed above, a violation of CEQA and NEPA. In addition, this response mischaracterizes NEPA's requirement for adequate alternatives. The response states that "...alternatives under NEPA are not required to avoid or lessen the significant effects of a project..." This is incorrect. NEPA Regulations Section 1502.14 (a), 1500.2 (e) and (f), and 1502.1 clearly require that all reasonable alternatives be evaluated and that these alternatives must avoid or minimize significant effects. Not only does the FEIR/FEIS not evaluate all reasonable alternatives, it does not include one that attempts to adequately alleviate the impacts as discussed above, a violation of NEPA. This also applies to the conclusory paragraph of Response A-8.6. • Response A-8.6 — Contrary to these comments, the City's alternative is not similar to the range of alternatives included in the FEIR/FEIS because none of those alternatives seeks to eliminate or reduce the impacts discussed above. The City's alternative does. Also, the City's alternative may very well be the environmentally superior alternative. February 14, 2007 Page 9 This response makes several conclusions that the City's alternative will result in greater and/or more impacts than the proposed project. However, all of these conclusions are not based on additional studies, surveys, or evidence. Extensive discussion was held by City and CPUC staff in late November and early December regarding the possible inclusion of the City's proposed alternative. The City assumed that since the document being prepared was a joint EIR/EIS between the CPUC and USFS, any decisions made by the CPUC were done with the consent of the Forest Service. On December 11, 2006 the CPUC provided the City with approximately 20 pages of analysis of the City's proposed alternative. The City was told by CPUC staff that this analysis was to be included in the FEIR/FIES in order to justify why the City's alternative was not to be included, as, according to CPUC staff, the analysis showed that the City's alternative was not going to be environmentally superior. However, after reviewing this analysis, on December 13, 2006 the City responded in writing that it had concluded its alternative may very well be the environmentally superior alternative and provided discussion supporting this conclusion. The City never received a response from CPUC staff regarding its conclusions and City staff assumed this analysis and the City's response were to be included in the FEIR/FEIS. It is notable that neither the CPUC's analysis nor the City's written response was included in the FEIR/FEIS. Both are attached to this letter. The fact that the City was told by the lead agency that these approximately 20 pages of analysis would be included in the FEIR/FEIS, the City properly assumed that its comments of December 13 regarding the analysis, would also be included along with a response to comments, which is required by CEQA Section 15088 (b), regardless of whether the comments were received after the close of the comment period, and by NEPA Regulations Section 1503.4.. This did not occur. The City was falsely led to believe that its concerns were going to be further addressed in the FEIR/FEIS. It is also notable that in the 20 -page analysis provided to the City by the CPUC, it concludes that some significant impacts of the proposed project would be eliminated or reduced with the City's alternative. It further concludes that just about every potential impact identified as a result of the City's alternative are not definitive impacts, only possibilities, as further studies would be needed to conclusively determine if any impacts exist (further studies may show these impacts do not exist). This was pointed out in the City's comments. However, in this response to comments from the FEIR/FEIS, the conclusions are now that significant impacts will occur with the City's Alternative, that they are now definitive though no further studies were conducted and even less analysis is provided. These contradictory conclusions violate CEQA Section 15088 (c) which states February 14, 2007 Page 10 that when responding to comments "Conclusory statements unsupported by factual information will not suffice." It appears that when faced with a reasonable argument that the City's suggested alternative may very well be environmentally superior and required under CEQA and NEPA, the analysis of the alternative provided by the lead agency, its conclusions, and the City's evaluation, all of which formed the basis of the reasonable argument, were all expunged from the public record and replaced with the cursory review and baseless conclusions contained in the Response to Comments in the FEIR/FEIS. This is certainly not the "good faith, reasoned analysis" of responses to comments required by CEQA Section 15088 (c) and is a violation NEPA Regulations Section 1503.4. It is also notable that, according to the Forest Service, the CPUC never informed them of the City's December 13 comments. The fact that the CPUC, with the apparent consent of the USFS, would go to such lengths as to prepare and provide approximately 20 pages of analysis to support its decision to not include the alternative appears to acknowledge that the CPUC may have erred in not including such an alternative in the first place. Also, this Response contains additional discussion about the City's alternative regarding Land Use Conflicts, concluding that there will be several. However, it does nothing to substantiate this. Below are the presumed Land Use conflicts, each followed by a brief discussion: • Traversing the edge of the Tesoro Del Valle development. How can skirting a residential development be a Land Use conflict when the FEIR MIS concludes that bisecting the communities along the proposed route is not a land use conflict? • Bisecting the proposed Tapia Ranch 405 home residential development site. This is a proposed, and, therefore non-existent development. There cannot be an impact on development that does not exist. The proposed project route impacts existing development. • Traversing Castaic Creek Trail. There is no discussion that this is a conflict. If this is a conflict, why is the proposed project route which crosses a public park (Mountain View Park) not a conflict? • Traversing known and potential oil and gas extraction areas. It is not established that there is conflict. • Traversing the Castaic Conduit water pipeline. This is not a conflict. Transmission lines frequently cross pipelines. In fact, several existing power lines cross the 96" Los Angeles Aqueduct pipeline in the City of Santa Clarita. • Traversing the Pitchess Detention Center. There is no defined conflict. The route does not affect the operation.of the detention February 14, 2007 Page 11 center. This area of the detention center is not used and far from detention facilities. It is unlikely that these transmission lines will aid a jail escapee. They certainly won't adversely impact inmate views, which are already obscured by bars. These claims of Land Use conflicts are unproven, blatantly false, and many actually contradict the evaluation of the land use conflicts of the proposed project. Thus, these supposed conflicts should not be used in determining the validity of the City's Alternative. Of further concern is CPUC staff's acknowledgement to City staff that a significant part of the decision to not include the City's alternative was based on the fact that it would delay the FEMIFEIS by about 6 months. This is not a justifiable reason to prepare an incomplete environmental document. Also, CPUC staff has argued to City staff that the City should have suggested its alternative during the scoping process, not the DEHUDEIS public review process. This is false. It is the lead agency's responsibility to identify project alternatives that comply with CEQA and NEPA, not the public's responsibility. The public should be able to rely on and assume that the lead agency will comply with CEQA and NEPA and provide alternatives that attempt to address all significant impacts without them having to do so for the lead agency. The City, like the public, assumed an alternative would be put forth that addresses the impacts discussed in this letter. This did not occur. For all of these reasons, the FEIR/FEIS is deficient and flawed. Also, the City's alternative, or one similar, must be fully considered and analyzed in the EHUEIS and MUMS then re -circulated for public comment. The failure to do so violates CEQA and NEPA. The City supports the overall goal of the project to provide the infrastructure necessary to harness renewable wind energy. The City does not support the circumvention of State and Federal Law in order to do so, especially when that circumvention will adversely impact the City, its residents, and the environment. The City only seeks that an additional project alternative be evaluated. The City is not advocating that its alternative be adopted at this time, only that it be included Pursuant to CEQA Section 15088(b), (c), and (d), the lead agency is required to provide a written proposed response to a public agency on comments made by that public agency at least 10 days prior to certifying an EIR. The response must address the comments fully and in detail. There is not mandate that the comments from a public agency for which a response is required must be provided during the public comment period. The City looks forward to a response to these comments. February 14, 2007 Page 12 Thank you for the opportunity to review this project. Please do not hesitate to contact me should you have any questions. Sincerely, Paul Brotzman Director of Community Development Enclosures PB:KL:ms SAMCURRENTCounty Monitoring\Edison tines\FEIIt FEIS eomments.doc cc: City Council, City of Santa Clarita Ken Pulskamp, City Manager , Ken Striplin, Assistant City Manager Kai Luoma, Senior Planner John Boccio/Marian Kadota, CPUC/USDA Forest Service Representative Howard P. "Buck" McKeon Senator George Runner Assemblymember Cameron Smyth Assemblymember Sharon Runner Assemblymember Audra Strickland Supervisor Michael Antonovich Jon Davidson, AICP, Aspen Environmental Group Page 1 of 2 Kai Luotna From: Kai Luoma Sent: Wednesday, December 13, 2006 11:48 AM To: Boccio, John Cc: Lukins, Chloe; Chaset, Laurence; Vlahos, Ourania M.; Paul Brotzman; Lisa Hardy Subject: RE: Santa Clarita alternative route for the Antelope -Pardee Transmission Line Project Hi John, Thanks for sending me the summary and comparison. After reviewing it I have concluded that the alternative suggested by the City may very well be the environmentally superior alternative. As such, I feel that it definitely should be evaluated and considered as a full project alternative in the. EIR. My conclusion is based on the fact that not a single one of the potential impacts of the Santa Clarita Alternative results in an impact that is of greater significance than those of the proposed project. In fact, the SC Alternative either eliminates entirely or decreases the significance of impacts in the areas of Land Use and Public Recreation, Noise, and Visual Resources. The only possible increase in the significance of an impact is under visual resources and is "assumed" to be an impact even though the table admits that it may not be. My conclusion is also based on the fact that Table A (Long Term Effects) indicates that there are nine impacts with the SC Alternative which may potentially be greater than those of the proposed project. It also indicates that there are eight impacts that will be reduced with the SC Alternative. It is important to point out that the eight impacts that would be reduced by the SC Alternative are definitive reductions, they will be reduced. However, the nine impacts that the SC Alternative would potentially increase are not definitive, but are only currently unverified possibilities. There is a potential greater impact to the gnatcatcher, but only if they are present, which is unknown; there is a potential to impact a wildlife corridor, but only if one exists, which is unknown; there is a potential to impact unknown cultural resources, but only of they exist, which is unknown; the same for potential impacts of landslides and fossils. Further studies may show that few or none of these potentially increased impacts exist. If some or all of these potential increased impacts are determined to not exist, then the SC Alternative appears to be environmentally superior to the proposed project. Additional analysis is needed to determine whether these potentially increased impacts do in fact exist. The impacts in Table B (Short Term Impacts) are much the same. The seven of the nine impacts that would potentially increase as a result of the SC Alternative are potential, not definitive, and may not occur. Whereas the six impacts that would decrease in intensity with the SC Alterriative are definitive. Additional analysis is needed. CEQA section 15126.6 requires that EIRs "consider a reasonable range of potentially feasible alternatives" which "...are capable of avoiding or substantially lessening any significant effects of the project'. Though the EIR contains a range of alternatives, these alternatives evaluate various options for the areas in the national forest and the uninhabited areas north of Santa Clarita. None of the current alternatives provides any options that avoid the residential neighborhoods in and north of Santa Clarita. Therefore, there are no current alternatives that would avoid, decrease, or lessen the significant impacts to these areas and to the thousands of residents in them. These residents currently have no choice but to either oppose the entire project or accept the significant impacts that would occur to them. The SC Alternative provides such an altemative both to these residents and that may very well lessen the 12/19/2006 Page 2 of 2 impacts to other natural respources. Again, thank you for allowing me to review the documents. I understand that the Final EIR is due out soon. I would greatly appreciate being informed of your decision about the inclusion of the SC Alternative as soon as possible. Please let me know if you have any questions (I'm available by e-mail today). From: Boccio, John [mailto:JBX@cpuc.ca.gov] Sent: Mon 12/11/2006 3:33 PM To: Kai Luoma Cc: Boccio, John; Lukins, Chloe; Chaset, Laurence; Vlahos, Ourania M. Subject: Santa Clarita alternative route for the Antelope -Pardee Transmission Line Project Kai: Attached is the promised Summary and a comparison discussion of the alternative route proposed by the City of Santa Clarita for the Antelope -Pardee Transmission Line Project. Please respond to us by Noon Thursday December 14th. Please call me if there are any questions. Sincerely, John Boccio CPUC Energy Division-- CEQA Unit Ph: 415-703-2641 jbx @ cpucca. eov 12/19/2006 Page i of 1 Kai Luoma From: Boccio, John [JBX*cpuc.ca.gov] Sent: Monday, December 11, 2006 3:34 PM To: Kai Luoma Cc: Boccio, John; Lukins, Chloe; Chaset, Laurence; Vlahos, Ourania M. Subject: Santa Clarita alternative route for the Antelope -Pardee Transmission Line Project Attachments: Santa Clarita Alernative .doc; Comparison of SC Alt to proposed Project.doc; 1—multipart/3—Comparison of SC Alt to proposed Project.doc/C58EA28C-18C0.4a97-9AF2- 036E93DDAFB3/Comparison of SC Alt to proposed Project.doc Kai: Attached is the promised Summary and a comparison discussion of the alternative route proposed by the City of Santa Clarita for the Antelope -Pardee Transmission Line Project. Please respond to us by Noon Thursday December 14th. Please call me if there are any questions. Sincerely, John Boccio CPUC Energy Division-- CEQA Unit Ph: 415-703-2641 jbx@cpuc,ca.gov 1/19/2007 Santa Clarita Alternative The Santa Clarita Alternative provides an alternate routing for the transmission line generally between the Angeles National Forest and the Pardee Substation. The Santa Clarita Alternative is identical to the proposed Project from the Antelope Substation to approximately Mile 18.6. From approximately Mile 18.6, the Santa Clarita Alternative would diverge from the proposed Project route by turning west rather than continuing in a southerly direction. The alternative route would continue west for approximately 1.9 miles in a new 180 -foot -wide ROW, crossing an existing Los Angeles Department of Water and Power (LADWP) transmission line corridor at approximately Mile 19.4. At approximately Mile 20.6, the alternative route would meet another existing LADWP transmission corridor and continue in a northwesterly direction adjacent to that LADWP corridor. The transmission line would leave Angeles National Forest and cross San Francisquito Canyon adjacent to the LADWP corridor, and continue in northwesterly direction for 1.6 miles. At Mile 22.1, the transmission line would tum southwest and depart from the adjacent LADWP corridor. The transmission line would proceed in a southwesterly direction for approximately 1.3 miles before turning south and continuing for approximately 1.6 miles. At Mile 25.0, the transmission line would meet an existing SCE transmission corridor consisting of two sets of single -circuit 220 -kV lines. This corridor would be widened to accommodate the additional 500 -kV transmission line. The new transmission line would run along the west of this corridor for approximately 1.1 miles. At Mile 26. 1, the transmission line would tum south for approximately 1.0 mile, remaining parallel and west of an existing SCE 66 -kV subtransmission line, entering the Pardee Substation at Mile 27.1. Features of the Santa Clarita Alternative compared to the proposed Project are presented in Table 1, below. Table 1. Features of the Santa Clarita Alternative Compared to the Proposed Project Feature Description Santa Clarita Alternative Proposed Pro ect Transmission Line Linear distance of transmission line 27.1 miles total 27.1 miles overhead 25.6 miles total 25.6 miles overhead Linear distance of existing ROW 17.5 miles (17.5 miles to be widened) 22.8 miles (17.5 miles to be widened) Linear distance of new ROW 9.65 miles 2.8 miles Linear distance on NFS lands 14.0 miles (1.4 miles of new ROW adiacent to LADWP corridor 12.6 miles (0 miles of new ROW) Estimated duration of construction 14 months 13 months Existing 66 -kV line To be removed from Mile 1.1 to 18.6 To be removed Mile 1.1 to 18.6 Environmental Setting and Impact Analysis Below is a description of the environmental setting and the environmental impacts associated with the Santa Clarita Alternative compared to the proposed Project for issue areas where a noticeable difference could be evaluated. Biological Resources Environmental Setting For the Santa Clarita Alternative, a new transmission line route would be constructed north of Pardee Substation in the foothills east of the Pitchess Detention Center. This area supports rolling foothills characterized by relatively undisturbed sections of contiguous coastal sage scrub habitat, riparian scrub, and oak woodlands. Near the southern border of the ANF, the alternative would cross Pettinger Canyon, Dry Creek, and San Francisquito Creek Habitat in this section of the ROW consists of a variety of coastal sage scrub, chaparral, oak riparian woodland, riparian woodland, disturbed areas, and non-native grasslands. At 1 San Francisquito Creek, the transmission line would cross areas supporting rural home sites, disturbed alluvial fan scrub, and riparian scrub. Dry Canyon reservoir appears to support mature cottonwood woodland. Impacts Implementation of this alternative would have greater impacts to biological resources than the proposed Project, which would be largely located within existing ROWS between Mile 18.6 and the Pardee Substation. For example, this alternative would be located almost entirely in relatively undisturbed native habitat when compared to the existing more urbanized ROW in the City of Santa Clarita, which is characterized by a narrow band of coastal sage scrub habitat bordered by residential development. As such, greater temporary and permanent loss of native vegetation communities would be anticipated for the Santa Clarita Alternative compared to the proposed Project (Impact B-1)1; although impacts would be reduced to a less -than -significant level with implementation of Mitigation Measures B -la (Provide Restoration/Compensation for Impacts to Native Vegetation Communities), B -lb (No Activities will occur in Riparian Conservation Areas), and R4 (Permanent Closure and Re -vegetation of Construction Roads). Large sections of contiguous open space, greater than one mile in width in many locations, would be crossed with this alternative. When compared to the existing ROW, plant communities in the re-routed portion of this alternative have a greater potential to support sensitive plants (Impact B-7)2 and wildlife (Impact B-3)3 based on the lack of disturbance, variety of structurally diverse habitat types, available prey base, and connectivity to open space. However, impacts to sensitive plants and wildlife would be minimized with implementation of Mitigation Measures B-7 (Conduct Surveys for Sensitive Plant Species) and B -la (Provide Restoration/Compensation for Impacts to Native Vegetation Communities), respectively (Class In. Construction activities and increased vehicular traffic through these undeveloped areas would also have greater potential to disturb wildlife species than the proposed Project by interfering with breeding or foraging activities, altering movement patterns, or causing animals to temporarily avoid areas adjacent to the construction zone (Impact B-5)°. Except where undeveloped wildlife habitats are known to support rare, threatened, or endangered species, or nesting birds, impacts on wildlife from construction would generate potentially adverse but less -than -significant impacts (Class III). The Santa Clarita Alternative also has greater potential to be utilized as a wildlife corridor. The area from Castaic Creek through Tapia Canyon to San Francisquito Creek and along NFS lands (Impact B-29)5 supports broad sections of open space and riparian corridors. Unlike the proposed Project where existing access roads have generally been established along the alignment, the Santa Clarita Alternative would require the development of new access and spur roads. Vehicle traffic associated with both construction and maintenance activities may impede wildlife movement along this corridor. Because these activities would be temporary or intermittent, the increase in traffic would not completely impede the movement of wildlife and would not affect the nocturnal movement of wildlife; therefore, this impact would be considered less than significant with no mitigation required (Class III). The Santa Clarita Alternative has the potential to result in greater impacts to sensitive species than the proposed Project, which is generally located in an existing ROW for the equivalent portion of the route. As discussed in the environmental setting above, this alternative would traverse relatively undisturbed sections of contiguous coastal sage scrub habitat, riparian scrub, and oak woodlands. Coastal California gnatcatchers have a limited potential to occur in coastal sage scrub habitat, and as such this alternative would have a Impact B-1: The Project would cause temporary or permanent loss of native vegetation communities. 2Impact B-7: The proposed Project would result in the loss of listed plant species. 3 Impact B-3: The Project would cause loss of foraging habitat for wildlife. Impact B-5: Construction activities and increased vehicular traffic on access roads would disturb wildlife species. 5 Impact B-29: The Project would affect linkages and wildlife movement corridors. greater potential to impact this species (Impact B-12)6 than the proposed Project. Gnatcatchers, if present in or adjacent to the ROW, could be directly impacted by construction activities through removal of nests and habitat. Construction noise, dust, and the presence of project personnel could also result in the disruption of breeding or nursery behavior such as incubating or attending the nest. Because of the potential for this species to be present in the proposed ROW, focused surveys for coastal California gnatcatchers would be required by Mitigation Measure B-12 (Conduct Protocol Surveys for California Gnatcatchers), in addition to APM BIO -1, which requires pre -construction surveys for all sensitive species with the potential to occur along the ROW. If gnatcatchers are determined to be present within or adjacent to the proposed ROW, then any impacts to coastal sage scrub would be considered significant. To reduce impacts to coastal sage scrub habitat, SCE would require the presence of a biological monitor during construction (APM BIO -5) and implementation of BMPs to minimize dust and runoff (APM BI04) in coastal sage scrub habitat. Impacts to coastal California gnatcatchers (Impact B-12) would be reduced to a less -than -significant level (Class In with the implementation of Mitigation Measure B-12 (Conduct Protocol Surveys for California Gnatcatchers), in addition to APMs BIO -1, BI04, and BIO -5 to ensure that coastal California gnatcatchers and their habitat are not significantly affected by the Santa Clarita Alternative. There is one potential benefit to biological resources that may occur from this alternative. Although not identified in the existing ROW, arroyo toads have the potential to occur in one portion of the existing ROW at San Francisquito Creek. Construction of the Santa Clarita Alternative would avoid this area and cross the creek approximately three miles upstream in an area currently subject to heavy use from vehicle crossings. While it is not known if this species occurs in the upstream portion of creek; crossing at this location could avoid impacts to this species if present (Impact B-8)'. However, it is important to note that until the Santa Clarita Alternative has been surveyed, the presence of arroyo toad cannot be ruled out for other sections of the route. Based on the disparity of existing biological conditions of the two routes, there would not be a reduction in impacts with the implementation of the Santa Clarita Alternative. In addition, until biological surveys of the proposed alternative route have been conducted it is not possible to fully evaluate potential impacts to biological resources at this time. Cultural Resources Environmental Setting An in-person records search for the re-routed portion of the Santa Clarita Alternative was completed at the South Central Coastal Information Center (SCCIC) at California State University, Fullerton, in November 2006. The records search provided information about previously recorded cultural resources and previous surveys within one-quarter mile of the alternative route. The City of Santa Clarita historical list was also reviewed. A total of nine surveys have been conducted within a quarter mile of the alternative route. Of these, seven surveys overlie or cross the 230 -foot wide proposed Area of Potential Effect (APE). The surveys covered only a small portion of the area along the alternative route. Impacts There are six previously recorded cultural resources and two isolated prehistoric artifacts in or within one- quarter mile of the alternative route APE (Table 2). Four of the six cultural resources are within the alternative route APE. All resources are from the historic period. One cultural resource (19-120077) near the Pardee Substation was previously identified during the survey for the proposed Project route. It was likely a 6Impact B-12: The Project would result in the loss of coastal California gnatcatchers. 7 Impact B-8: Construction activities would result in the loss of arroyo toads. historic period ranch or farmstead, but little other than a row of trees remains. It was assessed in the EIR/EIS as lacking integrity and as ineligible. Two transmission lines cross the re-routed portion of the Santa Clarita Alternative APE (P-19-186857 and CA -LAN -2132H). These transmission lines also cross or follow the proposed Project route. CA -LAN -2132H is the LADWP transmission line. It crosses the alternative route in the ANF, but would not be affected by construction of the alternative route transmission line. P19-186857 is the SCE PS 74 transmission line that would be demolished by construction of the Project. The east end of the alternative re-route connects with the P19-186857 route (Impact C-2)8. Mitigation Measure C-2 for P19- 186857 requires evaluation using NRHP eligibility criteria and, if eligible, documentation as mitigation. The other resources include a homestead site with foundations and artifacts (CA -LAN -1447H), a sparse historic artifact scatter (CA -LAN -207214), and a large mining site with mining excavations, structures, and artifacts (P19-003081). The mining site is in the ANF and crosses the entire half -mile wide records search area for the alternative route and might be difficult to avoid during construction. No cultural resources within the APE have been listed on the California State Historic Resources Inventory, the National Register of Historic Places, the California Register of Historical Resources, the California Historical Landmarks, or the California Points of Historical Interest. Historic maps were reviewed to determine whether historical structures may be present. The 1941 USGS Santa Susana 15 minute quad indicates one building (probably a house) on the east side of San Francisquito Canyon, where the Santa Clarita Alternative crosses into the ANF. This building is not shown on the current USGS Newhall quad, indicating it has been demolished. However, there could be an historical archaeological site at this location. The 1903 Santa Susana USGS 15 minute quad shows a building in Tapia Canyon along the alternative route near the location of CA -LAN -1447H. This may be the house (no longer extant) that was part of the homestead site recorded as CA -LAN -1447H. The City of Santa Clarita lists 33 historical resources in its General Plan (City of Santa Clarita, 1991). Of these, 29 are in Newhall, and therefore not near the Santa Clarita Alternative route APE. Of the remaining four resources, one is near the confluence of the Santa Clara River and Castaic Creek, one is in Placerita Canyon, one is in Soledad Canyon, and one is in San Francisquito Canyon. None of these are within one- quarter mile of the alternative route APE. Although the alternative route crosses San Francisquito Canyon, the historical resource in the canyon is the site of the St. Francis Dam disaster which is about four miles north of where the alternative route crosses San Francisquito Canyon. The County of Los Angeles does not have a register of historical resources. The records search results indicate that there is a low potential for prehistoric sites in the Santa Clarita alternative route APE and a moderate potential for historic sites. It should be noted, however, that this assessment is based on a very small previously surveyed sample. Table 2. Previously Recorded Cultural Resources Within One -Quarter Mile of the Santa Clarita Alternative APE. Trinomial or Primary rima Record k Historic/Prehistoric Description P In ANF In APE Recorded by PlHO3081 Historic Mining excavations, structures, Yes Yes Vance & Milburn (early 20th century) and artifacts DPR Record 2001 P19-186857 Historic SCE Antelope PS 74 Yes Yes Romani 1930s transmission line DPR Record 2002 CA -LAN -2132H Historic LADPW Transmission Line Yes Yes Macko 1917 DPR Record 1992 CA -LAN -1447H Historic Homestead structural remains I No Yes Parr (earl : ts I DPR Record 1988 8 Impact C-2: Destruction of P19-186857 would occur as a result of the Project. 4 Table 2. Previously Recorded Cultural Resources Within One -Quarter Mile of the Santa Clarita Alternative APE. Trinomial or Prima Record NIn Hi storidPrehistoric Description ANF In APE Recorded by 19.120077 Historic Tree lines possibly representing a No No Ahmet destroyed homestead site DPR Record (2005) CA -LAN -2072H Historic Sparse refuse scatter No No Rasson DPR Record (1992) P19-100480 Prehistoric Isolated Artifact: Yes Yes Vance & Milburn Quartz chopper --Yes DPR Record (2001) P19.100481 Prehistoric Isolated Artifact: Yes t Vance & Milburn Andesite core DPR Record (2001) The survey data for the proposed Project along the portion through Santa Clarita shows that it would affect two historical archaeological sites, CA -LAN -3131 and CA -LAN -3132. The records search data for the Santa Clarita Alternative shows that it would affect two historical archaeological sites, CA -LAN -1447H and P19-003081. Because only a small portion of the Santa Clarita Alternative has been field surveyed, it is likely that more sites would be identified along this route alternative once it is completely surveyed. Thus, the Santa Clarita Alternative will likely affect more cultural resources than the proposed Project route. Geology, Soils, and Paleontology Environmental Setting This alternative is located in the same geologic setting as the equivalent portion of the proposed Project. The same geologic units are exposed along this alternative, consisting of the Mint Canyon Formation, the Castaic Formation, the Saugus Formation, alluvium, and active stream channel deposits. Soil units encountered along this alignment have the same characteristics as those encountered along the equivalent section of the proposed Project alignment. Impacts Landslides hazards along this alignment are higher from approximately Mile 18.6 to Mile 22.5 where this alternative crosses hills and valleys with many mapped small and moderate sized landslides, primarily in the Saugus and Castaic Formations. The south -trending portion of this alignment, from approximately Mile 22.5 to the Pardee Substation, does not cross through any areas identified with existing landslides, although it is underlain primarily by the landslide prone Castaic Formation. As with the proposed Project, unmapped landslides and areas of localized slope instability may also be encountered in the hills traversed by the alignment. As such, the Santa Clarita Alternative is likely to have greater potential to cause slope instability during excavation and grading (Impact G-1)9 and greater potential for the transmission line to be damaged by landslides, earth flows, and debris slides (Impacts G-9)10. Similar to the proposed Project, implementation of Mitigation Measures G-1 (Protect Against Slope Instability) and G-9 (Geotechnical Surveys for Landslides) would reduced these impacts to a less -than -significant level (Class D). The seismic setting is the same as for the proposed Project, and is subject to similar impacts from fault rupture, seismic groundshaking and earthquake induced landslides, although landslide potential would be greater due to crossing a higher landslide prone area (see Impact G-1, above). As with the proposed Project this alternative crosses the San Gabriel fault, and although the section of the fault crossed by this alternative is not Alquist- Priolo zoned it is still considered active and the alignment could potentially be damaged by fault rupture 9Impact G-1: Excavation and grading during construction activities could cause slope instability. o Impact G-9: Transmission line structures could be damaged by landslides, earth flows, or debris slides. E (Impact G-4)". Implementation of Mitigation Measure G-4 (Minimize Project Structures within Active Fault Zones) would reduce this impact to a less -than -significant level (Class II). This alternative would also be subject to potential liquefaction related phenomena (Impact G-5)12; however, it crosses less liquefiable material (alluvial deposits) along its alignment, therefore slightly reducing the risk of damage to project structures from liquefaction. Mitigation Measure G-5 (Geotechnical Investigations for Liquefaction and Slope Stability) would reduce this impact to a less -than -significant level (Class II). More new access roads would be required for the Santa Clarita Alternative due to the more remote location and miles of new ROW to be established resulting in greater potential to permanently alter topography (Impact G-3)13. As only limited shallow grading for access roads and work areas is anticipated and excavations are limited to the tower footing areas, substantial alterations in topography are not anticipated and impacts would be less than significant (Class III). The potential for encountering significant fossils during excavation for this alternative would be the same as for the equivalent portion of the proposed Project, as it crosses the same geologic units with high paleontologic sensitivity, the Mint Canyon, the Saugus, and the Castaic formations, which all are known to contain significant fossils (Impact G-10)14. Mitigation Measure G-10 (Protection of Paleontological Resources) would reduce impacts to unique or significant fossils to a less -than -significant level (Class II). Hydrology and Water Quality Environmental Setting South of Mile 18.6, major overhead water body crossings for the proposed Project would include Pettinger Canyon, Haskell Canyon, and San Francisquito Canyon. The Santa Clarita Alternative south of Mile 18.6 would cross Pettinger Canyon, Dry Creek, San Francisquito Creek, Tapia Canyon, and Wayside Canyon. Impacts A total of five minor mountain stream or valley wash crossings would occur for the proposed Project within Santa Clarita, whereas the re-routed portion of the Santa Clarita Alternative would cross seven streams due to the additional hilly/mountainous terrain traversed by this alternative. These additional crossing would increase the potential for construction activities to degrade water quality, both resulting from soil erosion and sedimentation cause by construction activities (Impact H-1)13, which would also be potentially greater in steep terrain, and from accidental release of potentially harmful materials during construction activities (Impact H-2)16. Mitigation Measures H -la (Implementation of Erosion and Sediment Best Management Practices), H -lb (Maximum Road Gradient), H -lc (Road Surface Treatment), H-ld (Timing of Construction Activities), H -le (Dispersion of Subsurface Drainage from Slope Construction Areas), H-lf (Control of Side -cast material, Right -of Way Debris and Roadway Debris) would reduce water quality impacts soil erosion and sedimentation to a less -than -significant level (Class II). APMs HYD -4 through HYD -6 as well as Mitigation Measures PH -la (Environmental Training and Monitoring Program), PH -lb (Hazardous Substance Control and Emergency Response Plan), PH -lc (Proper Disposal of Construction Waste), and PH-ld (Emergency Spill Supplies and Equipment) would reduce the potential impact of accidentally spilled materials on water quality to a less -than -significant level (Class II). 11 Impact G-4: Transmission line damage by surface fault ruptures at crossings of active faults. 12 Impact G-5: Project structures could be damaged by landslides, liquefaction, settlement, lateral spreading, and/or surface cracking resulting from seismic events. 13 Impact G-3: Minor changes in topography due to excavation and grading. 14 Impact G-10: Excavation for transmission line structures could damage unique or significant fossils. 'Impact H-1: Soil erosion and sedimentation caused by construction activities would degrade water quality. l6 Impact H-2: Degradation of surface water or groundwater quality would occur from the accidental release of potentially harmful materials during construction activities. 0 Land Use and Public Recreation Environmental Setting The Santa Clarita Alternative would deviate from the proposed Project from Mile 18.6 on NFS lands in the ANF, until it terminates at Pardee Substation at Mile 27.1 within the City of Santa Clarita. Generally, this alternative would traverse NFS land and vacant private land along its route. The route would traverse private land designated by Los Angeles County and the City of Santa Clarita for the following types of uses: Single Family Residential and Agriculture as it crosses San Francisquito Creek; Open Space and Recreation where it traverses proposed residential developments, and Utility and Commercial Facilities and Extraction (facilities or operations) near the southern end of the route. The area traversed by the Santa Clarita Alternative consists mostly of uninhabited and steep terrain within the ANF and the unincorporated areas of Los Angeles County. Within the City of Santa Clarita, existing land uses are largely industrial in nature. Specifically within the ANF, the route would cross NFS lands designated as Backcountry Zone and private in -holdings (non-NFS lands), including LADWP property and a few vacant parcels. After exiting the ANF, the Santa Clarita Alternative would travel northwest adjacent to two single-family residences before entering and paralleling the northwest corner of the Tesoro del Valle development (TR 51644) with proposed 2,500 residential units. Although construction is currently ongoing in the southern end of the Tesoro del Valle development, portions to the north are currently undeveloped. Once exiting the Tesoro del Valle development, the transmission line would cross one vacant parcel before turning southwest at the ANF border. At this point the line would transverse approximately 5 vacant parcels, including the northernmost point of proposed Tract Map 53822, which is a proposed 405 -home residential development referred to as the Tapia Ranch project. The line would continue into the center of the TR 53822 before turning south, bisecting this proposed tract. The transmission line would exit TR 53822 and continue south through the western portion of Tesoro del Valle, crossing designated open space. Once exiting the residential development, the line would continue south across Los Angeles County -owned land before entering an existing SCE transmission line corridor, consisting of two sets of single -circuit 220 -kV lines. The corridor would need to be widened to accommodate the additional 500 -kV transmission line. The new transmission line would run parallel and west of this corridor for approximately 1.1 miles passing the Peter J. Pitchess Detention Center to the northwest, and the Rye Canyon Business Park and a former Lockheed R&D facility to the southeast. At this point, the transmission line would turn south for approximately 1.0 mile, parallel and west of an existing SCE 66 -kV subtransmission line, terminating at the Pardee Substation. The portion of the Santa Clarita Alternative south of Mile 18.6 would not traverse any known or proposed parks or bike routes. It would potentially traverse the Castaic Creek and the Cliffie Stone/San Francisquito Canyon Trails. The Castaic Creek Trail is a State trail running east -west in unincorporated Los Angeles County near the boundary with Angeles National Forest west of San Francisquito Canyon. The Castaic Creek Trail intersects with the northern portion of Los Angeles County's proposed Cliffie Stone/San Francisquito Canyon Trail that runs north -south along San Francisquito Creek. It is unknown whether the Cliffie Stone/San Francisquito Canyon Trail is a completed or proposed trail at this time. In addition, the route would likely traverse land designated as open space and recreation within the Tesoro Del Valle development, however at this time the purpose and status of these lands are unknown. The route would not affect any established recreational resources with the ANF. The Alternative would traverse land designated as Grazing Land on the east and west sides of San Francisquito Creek and in the southern portion of the route. The route may traverse a horse ranch or other agricultural area in the vicinity of San Fancisquito Creek; however, there are no parcels designated as Prime Farmland or with Williamson Act contracts along the route. 7 Other issues that characterize the area from a land use perspective include the existence of various mineral resources. The Pardee Substation is located within Mineral Resource Zone 2 (MRZ-2), which contains construction -grade aggregate. In addition, the route would traverse known and potential oil and natural gas extraction areas, as well as various producing, idle, and abandoned oil and natural gas wells just north of the City of Santa Clarita city limits south to Pardee Substation. Specifically, there is a natural gas or petroleum facility that would be located adjacent to the west of the route just north of Pardee Substation. There is also unknown liquid or solid waste disposal facility that may be associated with the Detention Center. The Castaic Conduct, a pipeline owned by the Castaic Lake Water Agency (CLWA) that is used to deliver water to purveyors, would cross the proposed route from northwest to southeast just as the route turns southwest through the SCE transmission corridor. Impacts South of Mile 18.6, where it diverges from the proposed Project route, the Santa Clarita Alternative would generally traverse undeveloped areas in the City of Santa Clarita, unincorporated Los Angeles County, and the ANF. As such, this alternative would result in fewer short-term construction -related impacts to existing residential and commercial land uses (Impact L-1)17 than the proposed Project, as it would be located adjacent to fewer of these land uses. Impacts would be reduced to a less -than -significant level with application of Mitigation Measures N -la (Nighttime Construction Noise Restriction in Santa Clarita), N -lb (Provide Advanced Notification of Construction), and N -lc (Provide Shields for Stationary Construction Equipment). This alternative would also result in fewer long-term impacts to existing residential land uses than the proposed Project (Impact L-3)18, as it would be located adjacent to fewer existing residences; however, impacts would continue to be significant and unavoidable (Class I). In addition, long-term impacts to fewer commercial land uses would occur (Impact L-4)19, as fewer commercial land uses are located along the route. More specifically, the re-route would avoid the Veluzat Motion Picture Ranch, which would reduce long-term impacts to commercial land uses to a less -than -significant (Class III) compared to the proposed Project. Similar to the proposed Project, the Santa Clarita Alternative would affect planned land uses, such as Tract 53822, but would avoid the proposed MacMillan Meadow Peak project near Haskell Canyon that would be affected by the proposed Project. The Santa Clarita Alternative would potentially traverse several Los Angeles County trails, including the Castaic Creek and the Cliffie Stone/San Francisquito Canyon Trails, as well as land designated as open space and recreation within the Tesoro Del Valle development; however, this alternative would avoid impacts to Chesebrough County Park, Mountainview Park, and a proposed bicycle trail associated with the proposed Project (and Alternative 4). Construction of the Santa Clarita Alternative would potentially preclude or interrupt the use of these trails and open space areas to ensure public safety during construction. Short-term preclusion of these facilities would negatively impact the adjacent residences and other community members who use these facilities (Impact R-1)20. To reduce significant construction impacts to recreational users, the following mitigation measures have been identified: Mitigation Measures R -la (Coordinate Construction Schedule with the Authorized Officer for the Recreation Area), R -lb (Identify Alternative Recreation Areas), R -1c (Temporary Closure of Off -Highway Vehicle Routes During Construction), and R-ld (Temporary Upgrades to Forest System Roads), as well as Mitigation Measure B - la (Provide Restoration/Compensation for Impacts to Native Vegetation Communities). These mitigation n Impact L-1: Construction of the Project would temporarily disrupt existing residential and commercial land uses. 's Impact L-3: Operation of the Project would cause long-term disruption of existing residential land uses. 19 Impact L-4: Operation of the Project would cause long-term disruption of existing commercial land uses. 20 Impact R-1: Construction of the Project would preclude the use of established recreation areas in the Angeles National Forest and in the City of Santa Clarita. 8 measures would minimize construction impacts to recreationists and recreational sites. The implementation of these mitigation measures would reduce construction impacts to less -than -significant levels (Class 11). Noise Environmental Setting Unlike the proposed Project, which would traverse through existing residential development in the City of Santa Clarita, including passing in proximity to Mountain View Elementary School (Mile 21.7), Chesebrough County Park (Mile 23.2), North Park Elementary School (Mile 23.2), Rio Norte Junior High School (Mile 24.0), traversing through Mountain View Park (Mile 22. 1), as well as passing by many homes located adjacent to the route, the Santa Clarita Alternative would place the new transmission line in an area of Santa Clarita with few existing sensitive receptors. For the portion of this alternative that deviates from the proposed Project, sensitive receptors would be limited to a few commercial buildings located north of the Pardee Substation, along Johnson Parkway, and residences located along San Francisquito Canyon Road. The alternative route would also avoid the Veluzat Motion Picture Ranch. Impacts For the portion of the Santa Clarita Alternative that deviates from the proposed Project, impacts would generally be the same as the proposed Project, except that fewer sensitive receptors within Santa Clarita would be impacted. However, overall construction noise impacts associated with mobile construction equipment would occur over a longer period of time as a result of this alternative being 1.5 miles longer than the proposed project and requiring more new ROW resulting in the need to build (and maintain) more access and spur roads. Unlike the proposed Project, the Santa Clarita Alternative would avoid the Veluzat Motion Picture Ranch (located between proposed Project Mile 19.5 to 20.3). As such, this alternative would not result in corona noise levels that would exceed the Los Angeles County standard for noise -sensitive areas (Impact N-2)21, or result in a permanent increase in ambient noise levels at the ranch (Impact N-5)22, or result in temporary increases in ambient noise levels that would severely disrupt operations at the ranch (Impact N-7)23. Alternatively, the proposed Project would result in a significant and unavoidable impact (Class I) to the ranch for all impacts associated with the Veluzat Motion Picture Ranch (Impacts N-2, N-5, and N-7). For noise -related impacts, the Santa Clarita Alternative is an improvement over the proposed Project. Public Health and Safety Environmental Setting Where this alternative deviates from the proposed Project, it crosses through primarily undeveloped hill and valley terrain and the eastern ends of both the active Honor Ranch gas field and the active Wayside Canyon oil field. The Honor Rancho field in the project vicinity is primarily used for gas storage by SoCal Gas and is dotted with many gas injection wells and a few idle and abandoned oil wells. The Wayside Canyon field is an old field that has been revitalized and is being pumped with new techniques in the project vicinity and is dotted with active oil and gas wells and a few old abandoned wells. A brief review of online environmental databases (DTSC EnviroStor - www.envirostor.dtsc.ca.gov and SWRCB Geotracker - 21 Impact N-2: Operational corona noise levels at Veluzat Motion Picture Ranch would violate Los Angeles County standards. 22 Impact N-5: The Project would result in a permanent increase in ambient noise levels at Veluzat Motion Picture Ranch. 23 Impact N-7: Temporary increases in ambient noise levels would severely disrupt operations at Veluzat Motion Picture Ranch. 2 www.geotracker.swrcb.ca.gov) indicates no known contaminated sites are present along this alternative alignment. Impacts Impacts along this alternative would generally be the same as for the proposed Project, except where the alignment crosses through active portions of the Hondo Rancho and Wayside Canyon oil and gas fields. This alignment crosses in close proximity to areas historically and currently used oil and gas extraction. Excavation for tower foundations and grading for access roads could potentially encounter petroleum contaminated soil due to preexisting soil or groundwater contamination (Impact PH -2)2" and/or previously unknown spills or improper disposal of drilling wastes (Impact PH -3)25. Additional hazards in the oil fields also include encountering unknown abandoned or improperly abandoned oil/gas wells during excavation. Based on these impacts, this alternative has a greater potential to encounter unknown hazardous materials and added hazards related to abandoned oil wells. Implementation of Mitigation Measures PH -2 (Conduct Phase 11 Investigations) and PH -3 (Observe Exposed Soil) would reduce the potential impacts to a less -than - significant level (Class 11). As discussed above for Hydrology and Water Quality, the Santa Clarita Alternative would cross a greater number of streams than the proposed Project. As a result, there would be greater potential for construction activities to result in groundwater contamination due to improper handling and/or storage of hazardous materials (Impact PH -1)26. Mitigation Measures PH -la (Environmental Training and Monitoring Program), PH -lb (Hazardous Substance Control and Emergency Response Plan), PH -lc (Proper Disposal of Construction Waste), and PH-ld (Emergency Spills Supplies and Equipment) would be implemented to adequately ensure that the potential impacts would be reduced to a less -than -significant level (Class 11). EMF impacts associated with the re-routed portion of the Santa Clarita Alternative would be less than the proposed Project, as fewer nearby existing sensitive receptors would be located along the alignment. Visual Resources Environmental Setting It is assumed for this analysis that the Santa Clarita Alternative would construct and operate a 500 -kV transmission line on single -circuit lattice steel towers from Mile 18.6 to 27.1, as compared to the proposed Project with its taller, wider, double -circuit lattice steel towers from Mile 18.6 to 25.6. Impacts The visual impacts of the Santa Clarita Alternative would be identical to those described for the proposed Project from Mile 0.0 to 18.6. However, from Mile 18.6 to the Pardee Substation at Mile 27.1, the Santa Clarita Alternative would result in no change in existing visual conditions as seen from the Veluzat Motion Picture Ranch (Impact V-9; KOP 9)27; North High Ridge Drive (Impact V-10; KOP 10)28; Mountain View ark (Impact V-11; KOP 11)29; Rio Norte Junior High School (Impact V-12; KOP 12)30; North Park 24 Impact PH -2: Project results in encountering known preexisting soil or groundwater contamination. " Impact PH -3: Project results in encountering unknown preexisting soil or groundwater contamination. 26 Impact PH -1: Soil or groundwater contamination results due to improper handling and/or storage of hazardous materials during construction activities. 2' Impact V-9: The Project would alter the visual quality of landscape views as seen from Veluzat Motion Picture Ranch (KOP 9). 28 Impact V-10: Project infrastructure would alter the visual quality of landscape views as seen from North High Ridge Drive (KOP 10). 29 Impact V-11: Project infrastructure would alter the visual quality of landscape views as seen from Mountain View Park (KOP 11). 10 Elementary School and Chesebrough Park (Impact V-13; KOP 13)31; and all other vantage points in between these KOPs. Under the Santa Clarita Alternative, a noticeable visual change would be seen from Copper Hill Road (Impact V-14; KOP 14)32, and it is predicted that this change would be less than significant, but adverse (Class III). From Mile 18.6 to approximately Mile 20.5, the Santa Clarita Alternative would be located in remote, generally inaccessible areas at the southern boundary of the Angeles National Forest, Santa Clara/Mojave Rivers Ranger District. According to Forest Service personnel at the District, there are no recreation trails or existing/planned developed sites in the vicinity of this alternative route. Locked gates at the ANF boundary prevent vehicular access to this portion of the ANF. At approximately Mile 20.75, the Santa Clarita Alternative would cross San Francisquito Canyon Road and the riverbed of San Francisquito Canyon. At this location, in addition to the travelers on this high use road (as described for the proposed Project), there are many large -acreage, equestrian, single-family residences developed along the road and river. It is expected that people living in these residences are sensitive receptors who would be concerned about visual resource impacts of the Project if the Santa Clarita Alternative were constructed (high sensitivity). The new transmission line would be visible and very noticeable for approximately one-half mile on either side of the road (for a total length of one -mile), making this a foreground viewing distance from approximately Mile 20.25 to 21.25. Because there are two existing high-voltage transmission lines that the Project would parallel, the addition of a third line would increase structural prominence and could create unnecessary visual complexity associated with asynchronous conductor spans. Implementation of a visual mitigation measure to reduce visual complexity as seen from sensitive receptor locations, by matching existing structure spacing and spans as closely as possible, would avoid this problem and reduce the visual impact. It is predicted that the resulting visual impacts would be similar to those described for Alternative 3 at KOP 10 — North High Ridge Drive (see discussion at Section C.15.8, Impact V-10). Implementation of Mitigation Measures V -la (Use Tubular Steel Poles), V -lb (Construct, Operate, and Maintain with Existing Access Roads), V -lc (Dispose of Cleared Vegetation), V -Id (Dispose of Excavated Materials), and V -le (Treat Surfaces with Appropriate Colors, Textures, and Finishes) would reduce visual impacts for the Santa Clarita Alternative. The resulting visual impact would be significant, but mitigable to a less -than -significant level (Class 11). From approximately Mile 21.25 to 24.9, the Santa Clarita Alternative would be completely screened by topography from all sensitive receptor locations. This alternative is not visible from single-family residential developments along the west side of San Francisquito Canyon and north of Copper Hill Drive (e.g., Casa Luna Place or Calle Lumina Drive). From approximately Mile 24.9 to 27. 1, this alternative would cross rolling foothills that would provide some topographic screening. Sensitive receptors are located on Copper Hill Drive (see Impact V-14; KOP 14), at the Mann Biomedical Park on Rye Canyon Loop, and at new commercial/professional developments along Alta Vista Avenue, Hercules Drive, Constellation, and Kelly Johnson Parkway. The Santa Clarita Alternative would also be visible from the Wa1Mart parking lot. This alternative would cross over the new extension of Newhall Ranch Road that is currently under construction. This alternative would be visible from the intersection of Avenue Crocker and Avenue Hall, but duration of view would be short. This alternative also would be visible from the Pitchess Detention Center. Because of partial topographic 30 Impact V-12: Project infrastructure would alter the visual quality of landscape views as seen from Rio Norte Junior High School (KOP 12). 31 Impact V-13: Project infrastructure would alter the visual quality of landscape views as seen from North Park Elementary School and Chesebrough Park (KOP 13). 32 Impact V-14: Project infrastructure would alter the visual quality of landscape views as seen from Copper Hill Road (KOP 14). 11 screening and existing transmission lines that are visible against the skyline in this vicinity, the visual effects of this alternative are predicted to be significant, but mitigable (Class 11). Therefore, considering the topographic screening and fewer encounters of sensitive receptors, for visual resources reasons, the Santa Clarita Alternative would provide a improvement over the proposed Project from Mile 18.6 to 27.1. Summary Table 2 provides a summary of the environmental advantages and disadvantages of the Santa Clarita Alternative compared to the proposed Project, specifically focusing on the portion of this alternative that deviates from the proposed Project. Table 2. Summary of Environmental Advantages and Disadvantages of the Santa Clarlta Alternative Issue Area Environmental Advantages/Disadvantages Compared to the Proposed Project Biological Advantages Resources May avoid impacts to arroyo toads if suitable habitat is absent at upstream crossing of San Francisquito Creek and areas of Peninger Canyon Disadvantages • Greater impact to undisturbed coastal sage scrub and potential to impact California gnatcatchers • Greater impact to native vegetation communities • Greater potential to impact sensitive plants and wildlife • Larger number of creeks and drainages crossed • Increase potential to impact wildlife movement corridors Cultural Resources Advantages . Avoids historical archaeological sites CA -LAN -3131 and CA -LAN -3132 Disadvantages • Potential to impact a greater number of cultural resources, beyond those identified only through record searches CA -LAN -1447H and P19.003081 Geology, Soils, and Advantages Paleontology . Decreased potential for liquefaction Disadvantages • Increased potential for slope instability related to construction, earthquake induced slope failures, and for slope failures to damage facilities during operation as a result of traversing greater mountainous/hilly terrain • Greater potential for landslides due to crossing a higher landslide prone area • Greater potential to permanently atter topography due to remote location and need for new access and spur roads to tower locations Hydrology and Advantages Water Duality . Avoids crossing Haskell Canyon Disadvantages • Crosses a larger number of creeks (5 versus 3) and drainages (7 versus 5) resulting in a greater potential to degrade water quality from soil erosion and sedimentation from construction activities on steep slopes, as well as from the accidental release of potentially harmful materials during construction 12 Table 2. Summary of Environmental Advantages and Disadvantages of the Santa Clarita Alternative Issue Area Environmental AdvantageslDisadvantages Compared to the Proposed Project Land Use and Advantages Public Recreation . Avoids temporary and long-term disruption to residential areas in the City of Santa Clarita • Avoids Veluzat Motion Picture Ranch • Avoids Chesebrough County Park, Mountainview Park, and proposed bicycle trail Disadvantages • May traverse two currently undeveloped, but proposed residential developments • May traverse active oil and natural gas extraction areas • Would potentially traverse several Los Angeles County trails as well as land designated as open space and recreation within the Tesora Del Valle development precluding use of these recreational resources during construction Noise Advantages • Fewer sensitive receptors with Santa Clarita would be impacted by noise from construction and operational activities • Veluzat Motion Picture Ranch avoided Disadvantages • Increases the duration of noise from construction activities within the ANF and in Santa Clarita as a result of requiring a longer route in these areas and more new ROW Public Health and Advantages Safety Less potential for EMF impacts as fewer nearby sensitive receptors would be located along the re- routed portion of the alignment Disadvantages • Increased potential to encounter known and unknown contamination in oil fields during excavation • Added potential to encounter unknown abandoned or improperly abandoned oil wells during excavation • Greater potential for construction activities to result in groundwater contamination due to the greater number of stream crossings Visual Resources Advantages • Fewer sensitive receptors in Santa Clarita and unincorporated Los Angeles County residential/commercial neighborhoods would be visually impacted by construction and operation of the transmission line • Visual impacts would be avoided at Veluzat Motion Picture Ranch, North High Ridge Drive, Mountain View Park, Rio Norte Junior High School, North Park Elementary School, Chesebrough Park, and all other vantage points in between Disadvantages • Sensitive receptors would see portions of this alternative from San Francisquito Canyon Road and nearby residences, Copper Hill Drive (KOP 14), the Mann Biomedical Park on Rye Canyon Loop, and from new commercial/professional developments along Alta Vista Avenue, Hercules Drive, Constellation, and Kelly Johnson Parkway. This alternative would also be visible from the WalMart parking lot and would cross over the new extension of Newhall Ranch Road under construction 13 Comparison of the Impacts of the Santa Clarita Alternative to SCE's Proposed Project The tables below compare the environmental impacts of the Santa Clarita Alternative to the impacts of Southern California Edison (SCE's) proposed Antelope -Pardee 500 -kV Transmission Project. Table A presents a comparison of long-term effects and Table B presents a comparison of short-term effects expected during construction. Long-term effects primarily include the permanent loss or degradation of biological and cultural resources, alteration of land, and visual changes associated with transmission infrastructure. Other long-term effects include operational noise (Le., corona noise), land use disruptions, and exposure to geologic hazards. Because the Santa Clarita Alternative traverses several more miles of natural habitat than the proposed Project (primarily coastal sage scrub), it would result in the long-term loss of more natural habitat and greater ongoing disturbance to wildlife than the proposed Project. This includes areas where a transmission corridor would need to be established as well as natural habitat areas adjacent to existing transmission corridors. The Santa Clarita Alternative would likely affect the same number of cultural resource sites as the proposed Project, but would have greater potential to affect previously unknown cultural resources sites due to the fact that it crosses a greater amount of undisturbed and unsurveyed land. More land disturbance for grading of access roads would occur with the Santa Clarita Alternative compared to the proposed Project because limited access currently exists southwest of Mile 18.6 where the Santa Clarita Alternative route diverges from the proposed Project route. The Santa Clarita Alternative also crosses more mapped landslide areas. However, the Santa Clarita Alternative does not cross the Alquist-Priolo zone for the San Gabriel Fault and traverses fewer liquefiable soils. An advantage of the Santa Clarita Alternative is that it is not located in close proximity to as many developed parcels as the proposed Project and, therefore, has less potential to cause land use disruptions than the proposed Project. From a visual impact standpoint, the Santa Clarita Alternative involves trade-offs. While effects on views at key observation points in Santa Clarita would be avoided or reduced by the Santa Clarita Alternative, this alternative would also introduce views of transmission infrastructure into areas where no such infrastructure currently exists. Specifically, the Santa Clarita Alternative would add transmission lines across 3.7 miles of open land where no transmission lines currently exist. In contrast, the proposed Project would primarily place the transmission lines in existing transmission corridors. Through most of Santa Clarita, the proposed Project would replace existing towers with new taller towers in a location adjacent to other existing transmission lines, rather than introducing new towers into areas where towers do not currently exist. Short-term effects include construction impacts related to air pollutant emissions, noise, erosion and water quality, hazardous material spills, and temporary land use disruptions. Air pollutant emissions would be slightly greater for the Santa Clarity Alternative than the proposed Project because the route would be slightly longer and would require more travel on unpaved roads. However, the Santa Clarita Alternative would be located adjacent to fewer sensitive receptors than the proposed Project. The greater amount of undisturbed natural area traversed by the Santa Clarita Alternative would result in greater short-term disturbances of habitat and wildlife, but this alternative would cross a less sensitive portion of San Francisquito Creek. The greater number of creeks and drainages crossed by the Santa Clarita Alternative would result in an increased potential for construction activities to adversely affect riparian habitat and water quality. Because less of the area traversed by the Santa Clarita Alternative is developed, there would be fewer sensitive land uses affected by construction noise than with the proposed Project and fewer construction -related disruptions to land uses in general. The fact that the Santa Clarita Alternative crosses active oil and gas fields means that construction would have a greater potential to disturb existing areas of contamination than the proposed Project. In summary, the Santa Clarita Alternative has greater potential for adverse effects on the natural environment than the proposed Project, primarily because It traverses a greater amount of relatively undisturbed natural habitat area, as well as streams and drainages. It would also have a greater impact on visual resources by introducing transmission Infrastructure Into natural areas where such infrastructure does not currently exist. Because the Santa Clarity traverses more natural areas and less developed area than the proposed Project, it would generally have fewer impacts on the human environment, including construction -related impacts on adjacent land uses. TABLE A. LONG-TERM EFFECTS Impact P Comparison of Santa Clarita Alternative to the Proposed Impact SI nificance Project (see the notes at the end of the table) SC Proposed Alternative Pro ect Biological Resources Loss of native vegetation Greater impact than the proposed Project because ofClass 11 Class II communities (Impact B•1) more work in natural habitat areas, including loss of coastal sae scrub habitat Loss of foraging habitat for wildlife Greater impact than the proposed Project because of > Class II Class II Im act B-3 more work in natural habitat areas. I Loss of listed plant species Greater impact than the proposed Project because plant > Class II Class II (Impact B-7) communities in the re-routed portion of this alternative have a greater potential to support sensitive plants when compared to the more urban route. Potential loss of California Greater potential impact than the proposed Project > Class II Class II gnatcatchers (Impact B-12) because of increased disturbance of contiguous stands of coastal sae scrub habitat. Affect linkages and wildlife Greater potential than the proposed Project because Class III Class III movement corridors (Impact B-29) this area has the potential to be utilized as a wildlife corridor from Castaic Creek through Tapia Canyon to San Francis uito Creekand NIS lands. Cultural Resources Effects on known cultural resource Similar number of recorded sites potentially affected. _ Class II Class II sites Potential to effect previously Greater impact than the proposed Projectbecause less > Class II Class II unknown cultural resource sites of the route has been previouslysurveyed. Geolo and Soils Grading of new access roads would Greater impact than the proposed Project because more > Class IIIClass III permanently alter topography new access roads would need to be constructed. (Impact G-3 Transmission line damaged by Slightly less impact than the proposed Project because < Class II Class 11 surface fault rupture at crossings of the route would not cross the Alquist-Priolo zone for the active faults (Impact G-4) San Gabriel fault (although the fault would still be crossed). Project structures could be damaged Less impact than the proposed Project because it Class II Class II by liquefaction from seismic events crosses less liquefiable materials. Im act G-5 Transmission line could be damaged Greater impact than the proposed Project because of Class II Class II by landslides, earth flows, and debris more mapped landslides. slides G Poteter significant Similar impacts to the proposed Project. The SC __ Class II Class II fossils during excavation Alternative would cross the same geologic units with (Impact G-10 high paleontolo is sensitivity. Land Use and Public Recreation Long-term disruption of existing Less impact than the proposed Project because it would < Class I Class I residential land uses (Impact L•3 be located adjacent to fewer existino residences. Long-term disruption of existing Less impact than the proposed Project because it would < Class III Class I commercial land uses (Impact L-4) be located adjacent to fewer businesses, and would avoid the Veluzat Movie Ranch. Noise Corona noise would adversely affect Less impact than the proposed Project because it would < Class III Class III residences (impact N-2 be located adiacent to fewer existin residences. Corona noise would adversely affect Less impact than the proposed Project because it would No Impact Class I the Veluzat Motion Picture Ranch avoid the Veluzat Motion Picture Ranch. (Impact N-5 TABLE A. LONG-TERM EFFECTS Impact Comparison of Santa Clarita Alternative to the Proposed Impact Significance nificance Project (see the notes at the end of the table) SC Proposed pltemative Prosed ect Visual Resources Adverse effects on views in Santa Substantially less impact than the proposed Project < No Impactor Class I Clarita (KOPs 9, 10, 11, 12, 13, & 14) because the transmission line would be largely Class III Im acts V-9, 10, 11, 12, 13, & 14 screened b to o ra h . Transmission lines would be added Greater Impact than the proposed Project, but the < Class I No Impact across 3.7 miles of open land where impact would occur in an area not readily visible to the (assumed) to this area no transmission lines currently exist. public. Criterion VISI Construction activities would disturb Increased vehicular traffic through undeveloped areas > Class III New transmission line added at a Similar impact to the proposed Project. The proposed__ would have greater potential to disturb wildlife species Class I Class I highly visible location crossing San Project also crosses San Francisquito Canyon in an than the proposed Project. (assumed) Francisquito Canyon (Criterion VISI) existing transmission corridor and also in a highly visible Less impact than the proposed Project because a less < Class II Class II location. suitable portion of San Francisquito Creek would be New transmission line across more Impacts wouldn't be substantially different than the crossed. However, it is unknown if this species occurs in miles of NFS lands (Criterion VISI) proposed Project. The new line would largely be located un -surveyed rtions of the ri ht of wa . in existing transmission corridors. The area is less Greater impact than the proposed Project because of > Class II Class 11 visible to most Forest users. more work in natural habitat areas likely to support Public Health and Safe Exposure to EMF (not treated as an Less impact than the proposed Project because of fewer impact in the EIRIEIS nearb existin sensitive receptors. Greater impact than the proposed Project because of >Class II i uiedlur mipaci man the proposed Project. < Less impact than the proposed Project. = Very similar or the same impact as the proposed Project. TABLE B. SHORT-TERM EFFECTS Impact p Comparison of Santa Clarita Alternative to the Proposed Im act SI nificance Project (see the notes at the end of the table) SC Proposed Alternative Project Air Quality Air pollutant emissions from Slightly greater impact than the proposed Project > Class I Class I construction (Impact A-1) because the route would be slightly longer and would require more travel on un aved roads. Exposure of sensitive receptors to air Less impact than the proposed Project because of fewer < Class II Class II pollutant emission during existing nearby sensitive receptors. construction(Imp act A-2 Biological Resources Construction activities would disturb Increased vehicular traffic through undeveloped areas > Class III Class III wildlife species (Impact B-5) would have greater potential to disturb wildlife species than the proposed Project. Adverse effects on arroyo toads Less impact than the proposed Project because a less < Class II Class II during construction (Impact B-8) suitable portion of San Francisquito Creek would be crossed. However, it is unknown if this species occurs in un -surveyed rtions of the ri ht of wa . Adverse effects on sensitive species Greater impact than the proposed Project because of > Class II Class 11 during construction (Criterion B1O2) more work in natural habitat areas likely to support sensitive plant and animal species. Geology and Soils Excavation and grading activates Greater impact than the proposed Project because of >Class II Class II could cause slope instability greater potential for unmapped landslides and areas of (Impact G-1) localized slope instability in the hills traversed by the SC Alterative. Hydrology and Water —Qualltv Degradation of surface water quality Slightly greater impact than the proposed Project > Class II Class II from soil erosion and sedimentation because the route would cross more creeks and during construction (Impact H -t drainages. TABLE B. SHORT-TERM EFFECTS Comparison of Santa Clarita Alternative to the Proposed Impact Si nificance Impact Project (see the notes at the and of the table) SC Alternative Proposed Project Degradation of water quality from Slightly greater impact than the proposed Project > Class II Class 11 accidental release of potentially because the route would cross more creeks and harmful materials during construction drainages. (impact H-2 Land Use and Public Recreation Temporary disruption of existing Less impact than the proposed Project because it would < Class II Class II residential and commercial land uses be located adjacent to fewer existing residences and construction Im act L-1 businesses, and would avoid the Veluzat Movie Ranch. tBurin onstruction would preclude the use Less impacts than the proposed Project because it < Class II Class II of established recreation areas would avoid impacts to Chesebrough County Park, (Impact R-1) Mountainview Park, and a proposed bicycle trail. The SC Alternative would potentially traverse several Los Angeles County trails and designated open space areas within the Tesoro DelValle development. No se Construction noise would violate Less impact than the proposed Project because it would < Class I Class I local standards (impact N-1 be located ad'acent to fewer sensitive receptors. Construction noise would severely Less impact than the proposed Project because the < No Impact Class I disrupt operations at Veluzat Motion Veluzat Motion Picture Ranch would be avoided. Picture Ranch (impact N-7 Public Health and Safe Potential to result in groundwater Great impact than the proposed Project because it > Class II Class 11 contamination due to improper would cross a greater number of creeks and drainages. handling and/or storage of hazardous materials (Impact PH -1 Potential to encounter known Greater impact than the proposed Project because it > Class II Class II hazardous materials (Impact PH -2) crosses active Honor Ranch gas field and Wayside Canyon oil field. Potential to encounter unknown Greater impact than the proposed Project because it > Class II Class II hazardous materials (Impact PH -3) crosses active Honor Ranch gas field and Wayside Canyon oil field. > Greater impact than the proposed Project. < Less impact than the proposed Project. = Very similar or the same impact as the proposed Project.