Scoping Comments for Power Santa Clara Valley

Joint letter logos

Valisa Nez
Project Manager
ESA Associates
Via email to: vnez@esassoc.com

October 7, 2024

Re: Scoping Comments for Power Santa Clara Valley (SCH Number 2024090200)

The Sierra Club Loma Prieta Chapter and the Santa Clara Valley Bird Alliance submit the following Scoping Comments to the California Public Utilities Commission (CPUC) regarding the Notice of Preparation for the Power Santa Clara Valley (Project) in the City of San Jose.

The Project consists of two new high-voltage direct current (HVDC) terminals and associated new transmission lines. The new transmission lines include an approximately 13-mile underground transmission line connecting the southern terminal (the Grove terminal), to the northern terminal (the Skyline terminal), an approximately 100-foot overhead line connecting the new Skyline terminal to the existing Pacific Gas and Electric Company (PG&E) San Jose B substation, and an approximately 1.2 mile underground transmission line connecting the new Grove terminal to the existing PG&E Metcalf substation.

  1. Underground transmission lines
    • Please describe the construction process for underground transmission lines. Does construction require trenching and/or boring? Does underground infrastructure cross waterways? What processes are involved for dewatering?
    • Were all residents along the underground transmission lines notified of this project?
       
  2. Please analyze and discuss Environmental Justice (EJ) Impacts
    The EIR should evaluate whether communities, particularly disadvantaged or historically underserved populations, may be disproportionately affected by air pollution, noise and vibrations, traffic disruption, or other impacts of the project.
     
  3. Please analyze and discuss Cumulative Impacts
    While cumulative impacts are mentioned, the specifics of other large infrastructure projects San Jose and the Coyote Valley need to be detailed. These include overlapping impacts with the proposed Heritage Oaks cemetery and various transportation, industrial projects, and urban development along all project segments, especially in terms of air quality, water resources, and biological resources. Please provide a detailed analysis of how this project, combined with others, may exacerbate environmental stress on the region.
     
  4. Biological impacts
    • Migratory birds and Golden Eagles: Please analyze all above ground infrastructure for the potential to pose bird collision and/or electrocution hazards and provide adequate mitigation strategies.
    • Nesting Birds: Please provide biologically relevant mitigations for nesting birds for any ground disturbance, removal of structures and/or the removal or trimming of vegetation during the nesting season (February 1st through August 31st). For this linear project, nesting bird surveys should be performed no more than a week prior to any new section of the project commencing work. A pause of a week or more should require a new survey.
    • Light pollution: Please describe the lighting during construction and for any new above ground infrastructure, and evaluate potential impacts on wildlife in adjacent and nearby habitats, especially in riparian corridors and in Coyote Valley (Please find attached report1).
    • Wetlands and riparian habitats: Please provide detailed hydrological studies on the potential effects of construction near these sensitive habitats. Restoration or offset measures should be evaluated and included in the mitigation measures. Regarding the Skyline Terminal Site, please consider San Jose General Plan Policy ER-2.2 to “Ensure that a 100-foot setback from riparian habitat is the standard to be achieved in all but a limited number of instances, only where no significant environmental impacts would occur.” Since there is space to accommodate the Project with this setback, we request the project be designed to protect and enhance the riparian corridor within this setback area through planting of native vegetation.
    • Habitat connectivity: We believe that this project could fragment critical habitat connections or block potential alignments that are currently being studied for the restoration of habitat connectivity. Please provide a substantive discussion of impacts to wildlife connectivity, especially in Coyote Valley and along riparian linkages.
       
  5. Agricultural Resources
    The conversion of Prime Farmland is identified, but mitigation strategies to reduce or offset this loss are not well-defined. Please provide a detailed evaluation of farmland conversion impacts, with a focus on mitigation strategies such as land preservation or a land use offset policy.
     
  6. Air Quality
    • Sensitive receptors: Analysis should address the potential for air quality impacts on nearby residential and school zones, considering not only direct pollutant emissions but also cumulative traffic-related air quality issues during construction and operation.
    • Construction-related dust and emissions should be addressed thoroughly, including mitigation measures to control particulate matter (PM2.5 and PM10).
       
  7. Hazards, Hazardous Materials, and Public Safety
    • Given that contaminated soil and groundwater are identified near the project area, please provide a comprehensive contamination risk assessment, particularly how construction activities could mobilize these contaminants.
    • A robust analysis of the potential risks related to hazardous material transport and use should be conducted, particularly for accidental releases and impacts to nearby communities and to waterways.
       
  8. Hydrology and Water Quality
    Given the proximity to Coyote and Fisher Creeks, a thorough hydrological study is needed to assess flood risks, the potential for sedimentation during construction, and the long-term impacts of altered drainage patterns on water quality.
     
  9. Noise
    Potential nighttime noise impacts from construction and operation should be included, particularly for nearby residential areas.
     
  10. Recreation
    Please provide in-depth evaluation of how construction closures, noise, and visual impacts will temporarily or permanently affect the user experience and accessibility of trails and recreational resources.
     
  11. Growth inducing impacts
    Please analyze growth inducing impacts.
     
  12. Alternatives and Mitigation
    No Project Alternative: The EIR should thoroughly evaluate the No Project Alternative, not just in terms of the feasibility of meeting energy demands but also in terms of avoiding environmental damage. This should include exploring alternative location options that may lessen environmental impacts.

Conclusion

In conclusion, the EIR must address the issues outlined above with a more thorough and transparent analysis of impacts and feasible mitigation measures. Specific attention should be paid to cumulative impacts, environmental justice, the protection of sensitive biological and hydrological resources, and wildlife movement through the landscape.


We thank you for the opportunity to provide scoping comments,

Julianne Wang
Environmental Advocacy Assistant
Santa Clara Valley Bird Alliance

Katja Irvin
Guadalupe Group Conservation Chair
Sierra Club Loma Prieta Chapter

1 Light, Noise, and Development Impacts on Wildlife - Literature Review and Recommendations. 2024. Project #4842-01 Prepared for: Peninsula Open Space Trust by: H. T. Harvey & Associates https://drive.google.com/file/d/1wpXmDEcTmEzdLgn7F5t-7WWdq_4msI-4/view