White Paper #7: Sunrise Powerlink Project Project Sponsor: Gas & Electric Company Project Status: Construction Started April 2010 Location: Southern California

Project Location The Sunrise Powerlink Project is located in southern California, in western Imperial County and in San Diego County. See illustration (inset map above). A route map is presented on the last page of this report as Figure 1. The 117-mile transmission line would run from SDG&E’s Substation near El Centro, Imperial County, to SDG&E’s Peñasquitos Substation near Interstate 805, in coastal San Diego. The project is now under construction and will be energized in 2012/2013.

Project Schedule Table 1 presents the schedule for the Sunrise Powerlink Project. The NEPA and CEQA documents published for this project included the following:  Draft EIR/EIS (addressed the proposed project and numerous alternatives)  Recirculated Draft EIR/Supplemental Draft EIS (addressed addition connected actions :wind generation in Mexico proposed by SDG&E’s parent company, Sempra, and cross-border transmission that would interconnect with the Sunrise Powerlink)  Final EIR/EIS, presenting responses to comments on both draft documents

Table 1. Schedule as Proposed vs. Actual Process Steps Original Schedule Actual Date Pre-filing consultation or meetings with state and federal Fill in lead permitting agencies Submittal of Plan of Development (POD)/Application to Nov. 2, 2005 to BLM BLM or other federal lead agency Submittal of Application to state or local permitting Aug. 4, 2006 to CPUC agency/agencies of general jurisdiction Determinations that POD/Applications are complete Fill in Issuance of Notice of Intent to prepare an Environmental Aug. 31, 2006 (BLM) Impact Statement and of Notice of Preparation (NOP) to prepare EIR NOP Sept. 15, 2006 (CPUC) Scoping 1: Oct 2006 Scoping Meetings and Publication of Scoping Report Scoping 2 (Alts): Dec. 2006 Scoping 3 (Mod Route D Alt) May 2007 Publication of Draft EIS and of any state-level Jan. 2008 Draft EIR/EIS: Jan. 2008 environmental review document/s Project #7 WGA Transmission Siting – Task 1 Sunrise Powerlink Project

Table 1. Schedule as Proposed vs. Actual Process Steps Original Schedule Actual Date Draft EIR/EIS: April 2008 End of public comment period on Draft EIS/EIR Apr. 11, 2008 Recirculated Draft EIR/Suppl EIS: Aug. 25, 2008 Publication of Final EIS/EIR Oct. 2008 Publication of Record of Decision and all public agency CPUC approval in Dec. 2008, BLM approval approvals in Jan. 2009, USFS approval in Jul. 2010 Mar. 2009 (three BLM appeals filed with Appeals or legal challenges IBLA, 2 dismissed), Aug. 2009 (CPUC appeals in CA supreme court) Start of construction Sept. 2010 Energizing transmission line Est. Jun. 2012

Project Purpose and Need The Sunrise Powerlink was proposed to serve two main purposes: 1. Improved Reliability. As population and industry grow in the San Diego region, increased energy is required (SDG&E 2010). The Sunrise Powerlink project is designed to serve this growth in energy demand in several ways. The line will maintain reliability through interconnection and additional energy supply. This will allow the San Diego transmission system to satisfy the reliability requirements of the California Independent System Operator (“CAISO”). Additionally, the line will reduce energy costs by allowing for access to lower cost sources of power in the desert southwest and reduced reliance on older, less-efficient in- area generation (CPUC & BLM 2008). 2. Reduced Cost of Electricity. [expand] 3. Access to Renewable Generation in the Imperial Valley. The Sunrise Powerlink Project will also improve access to and promote the development of renewable energy. The Project will provide California consumers more economical access to the renewable resources in Imperial Valley, encourage the development of these resources, and provide access for wind resource development in southeastern San Diego County (CPUC & BLM 2008).

Rationale for Sponsor’s Selection of its Proposed Route The purpose of the project was to connect urban San Diego with the transmission and generation resources of the Imperial Valley. The Imperial Valley Substation is where SDG&E’s system connects with the Imperial Irrigation District transmission system. SDG&E identified the specific proposed route for two primary reasons.  First, much of the route through ABDSP followed an existing transmission line. However, the existing line was only 91 kV [verify], and was in a much narrower ROW than would be required for the proposed 500 kV line. In addition, portions of the route west of ABDSP would have created new 230 kV ROW through San Diego County.

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 Second, the proposed route avoided the creation of a ROW through the CNF and the associated permitting requirements.

NEPA and State Processes Table 2 lists the permits that were required to be obtained by SDG&E.

Table 2. Permits or Other Actions Required Prior to Construction of the SRPL Agency Jurisdiction Permit or Regulatory Requirement FEDERAL U.S. Fish and Endangered Species Act 16 USC  Biological Assessment, Section 7 Consultation, Wildlife Service 1531-1544 Biological Opinion Migratory Bird Treaty Act and Eagle Protection Act Fish and Wildlife Coordination Act Bureau of Land FLPMA, 43 USC 1701 et seq.  ROW Grant Management 43 USC 1701 et seq.  Temporary Use Permit  Antiquities and Cultural Resources Use Permit  Plan of Development  Notice to Proceed  California Desert Conservation Area Plan Amendment  Clean Air Act Conformity  Fire Prevention Control Plan USDA Forest FLPMA, 43 USC 1701 et seq.  [add details] Service, Cleveland 43 USC 1701 et seq. National Forest Army Corps of Clean Water Act, 33 USC 1341  Individual/Nationwide Section 404 Permit Engineers Section 10, Rivers and Harbors Act Permit U.S. Department of  Encroachment Permits Transportation,  Review of obstruction and objects affecting airspace Federal Highway Administration U.S. Department of the Where blasting may be required  Explosive User’s Permit Treasury, Bureau of Alcohol, Tobacco and Firearms Federal Aviation  Helicopter Lift Plan Administration  Form 7460-1 MCAS Miramar On MCAS Miramar land  FAR Part 77 Request (via FAA)  SECNAVINST 11011.47A (access road outside of easement)

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Table 2. Permits or Other Actions Required Prior to Construction of the SRPL Agency Jurisdiction Permit or Regulatory Requirement CALIFORNIA California Public Transmission, substation,  Certificate of Public Convenience and Necessity Utilities Commission generation projects 50 kV and  Certification of EIR above California Department State Park Lands (Anza-Borrego  Easement of Parks and Desert State Park) Recreation California Park and State Park Lands (Anza-Borrego  Plan Amendment Recreation Desert State Park)  Change in Wilderness Designation Commission California Independent Purpose and Need for new  Interconnection approval System Operator transmission, substation and generation projects California State Lands State lands  Right-of-Way Easement Commission California Department Manage fish, wildlife, plant  Streambed Alteration 1601 Permit of Fish and Game resources and habitats; California  Section 2061 Incidental Take Permit ESA, California Native Plant  Mitigation agreement/plan Protection Act, California Fish and  Certification of EIR Game Code Section 1601  Easement California Department CA streets and highways Code  Encroachment Permits of Transportation 660-711.21 Cal. Code of Regs.  Traffic Control Plans 1411.1-1411.6 California Department Hazardous Waste Control Act of  EPA Hazardous Waste Generator ID of Toxic Substations 1972  90 days TSD Permit Control  Hazardous Material Business Plan  EPA Hazardous Waste Generator ID California State Any archaeological or  Cultural Resources Use Permit, Field Use Authorization, Historic Preservation paleontological work or an Archaeological Resources Protection Act Office (ARPA) Permit (if required)  Consultation for Section 106 of the National Historic Preservation Act State Water Quality Clean Water Act, Section 401  401 Certification Control Board  Storm Water Construction General Permit 99-08-DWQ  NPDES Permit  WDRs California Air State-wide  Portable Engine Registration for specified non-mobile Resources Board portable engines. California Reclamation Waterways that possess designated  Encroachment Permit Board floodways

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Table 2. Permits or Other Actions Required Prior to Construction of the SRPL Agency Jurisdiction Permit or Regulatory Requirement LOCAL AND REGIONAL Imperial County County roads and highways, flood  Road/Highway Encroachment/Crossing Permit control/drainage channels  Grading Permit  Flood Control/Drainage Channel Encroachment/Crossing Permit  Explosives Permit San Diego County County roads and highways, flood  Road/Highway Encroachment/Crossing Permit control/drainage channels  Grading and Wall Permits  Traffic Control Plans  Explosives Permit  New or expanded ROW Grant  Flood Control/Drainage Channel Encroachment/Crossing Permit  Excavation Permit Regional Water Quality Clean Water Act, Section 401  401 Certification Control Board, Region  Storm Water Construction General Permit 99-08-DWQ 7 (Colorado River  National Pollutant Discharge and Elimination System Basin) (NPDES) Permit  Waste Discharge Requirements (WDRs) Imperial Irrigation District irrigation/drainage channels  Encroachment/Crossing Permit District  Easements and ROW Grant Imperial County APCD Health and Safety Code 42300 et  Permit to Operate San Diego County seq.  Fugitive Dust Permit APCD San Diego and Health and Safety Code Chapter  Hazardous Materials Business Plan Imperial County 6.95  Hazardous Materials Inventory Environmental Health Services City of San Diego Coastal zone (Local Coastal  Coastal Development Permit Program) Cities of San Diego City roads and highways, flood  Road/Highway Encroachment/Crossing Permit and Poway control/drainage channels, lands  Flood Control Channel  Encroachment/Crossing Permit  Temporary Use/Occupancy Permit – Material and Storage Yards Source: CPUC & BLM 2008

Alternatives Evaluated The EIR/EIS presented detailed analysis of 27 alternatives to the Proposed Project, including:  18 alternative route segments along the Proposed Project route;

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 4 routes in southern Imperial and San Diego Counties that avoided the ABDSP and followed portions of the existing 500 kV Southwest Powerlink (SWPL);  Two non-wires (generation) alternatives;  Two alternatives including components of the Lake Elsinore Advanced Pumped Storage (LEAPS) Project; and  The No Project/No Action alternative. An additional 70 alternatives were considered in a screening process and eliminated from further review (CPUC and BLM 2008). Figure 2 illustrates the alternatives evaluated. The CPUC, BLM, and USFS ultimately selected the Southern Route Alternative, even though the EIR defined the non-wires renewable generation alternatives as the one with least environmental impacts.

Major Issues of Concern to Stakeholders This section presents a summary of comments from the NEPA and CEQA scoping process. Private citizens provided the majority of the scoping comments. In addition to private individuals and groups, comments were received from organizations and government agencies. The issues raised during the public scoping process are described in detail in two Scoping Reports (CPUC and BLM 2006, CPUC and BLM 2007), and are summarized below (CPUC and BLM 2008).

Purpose and Need. Commenters questioned the Proposed Project’s ability to provide transmission capability for delivering Imperial Valley renewable resources, because this renewable energy source had not yet developed. Imperial County Planning and Development Services commented that no application had been submitted or approved for any of these potential renewable energy sources relied upon by the project. Agencies, organizations, and private citizens expressed concern about the project’s potential to be used to import power from Mexico. Many commenters felt that the need for the project had not been established and that the focus should be on generation of power within the area (in-area generation) rather than importing energy from other regions. Commenters provided information on the workability of in-area generation. One company’s representative explained that during the energy crisis, it was the independent energy producers and SDG&E that supplied energy for the region. Commenters suggested that in-area generation was the preferred and only feasible option. Safety Issues and Fire Risk. The Forest Service and property owners near existing, proposed, and potential transmission line corridors were concerned with the potential for the proposed transmission line to start wildfires and to inhibit firefighting capabilities near the transmission line. Commenters requested a thorough analysis of how the SRPL project could contribute to fire risk.

Impacts to Property Values and Business Revenues. A number of residents expressed concern that the placement of towers near their homes and in their communities would be detrimental to the value of their property. Some homeowner groups requested that transmission lines be

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placed underground in their neighborhoods. Concern was expressed over the impact of the project on dairy businesses in Imperial County. The Imperial Irrigation District expressed concern over possible economic impacts of the project on agriculture.

Effects on Public and Park Lands. Comments both in the public meeting and through letters expressed concerns about the use of public lands for the Proposed Project and alternative routes. Concerns centered on the use of Anza Borrego Desert State Park (ABDSP) and the Cleveland National Forest (CNF) land for project ROW. California State Parks, environmental organizations, and community groups were strongly opposed to any use of ABDSP for the project. They requested the identification of alternatives that avoided the Park. San Diego County staff was concerned about the large number of parks and preserves affected by the project.

De-designation of Wilderness. A major concern was the Proposed Project’s location within State Wilderness and the required precedent-setting de-designation of wilderness land that would need to occur to allow for a wider transmission corridor and the relocation of the existing corridor within ABDSP to avoid a cultural site. There were major concerns from community and environmental groups that the project would have significant impacts to biological resources within ABDSP. Commenters asked that a thorough evaluation of recreation and biological resources be conducted in order to effectively mitigate potential impacts to these resources. Conflicts with Existing or Planned Land Uses. Concerns were raised by several developers and land owners that the Proposed Project and alternative routes could adversely affect future developments that are being planned. Among these were the Proposed Project’s impact on the Imperial Gateway Development project and other development projects along the Alternative in San Diego County. Human Environment Issues and Concerns. Some public comments focused on the potential effect of the project on the human environment, especially in neighborhoods where new towers and lines would be placed within an existing corridor with existing towers and lines. Concerns were with regard to the health and safety impacts of electric and magnetic fields (EMFs), health risks associated with prolonged exposure to high voltage electric fields, impacts to property values, safety and fire risk issues, noise (including corona noise), construction impacts, and conflicts with planned uses. EMF and Dairy Operations. Commenters believed that the transmission lines would be detrimental to the dairy industry, and would have significant impacts on operations at an existing dairy. Construction Impacts. The City of San Diego requested that construction be planned to avoid impacts to wildlife and that workers be trained to avoid impacts to wildlife. Alternatives. A substantial number of alternative routes were suggested by citizens, organizations, and agencies. Comments from California State Parks and others expressed interest in alternatives that avoided the ABDSP. Comments from Cleveland National Forest expressed interest in alternatives that avoided the CNF. Preference for the I-8 Alternative route

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with a particular reroute was expressed by the Campo Band of Kumeyaay Indians and the Ewiiaapaayp Band of Kumeyaay Indians. Modified Route D Alternative. After the Modified Route D Alternative was suggested by Cleveland National Forest, a third public comment period was held (May-June 2007) for this new alternative. Due to subsequent adjustments to the route, another comment period was held in September and October 2007, and commenters noted concerns about this alternative’s proximity to residences and its effect on the rural setting of the area. Concerns were also expressed about effects on the biological, cultural, and geological resources at “The Narrows,” and the risk of fire caused by power lines in this fire-prone area. In addition, planned development in this area was noted. Environmental Review and Decision-Making Process: Public Involvement. Concerns were expressed about the number and timing of scoping meetings. Because of the large distance spanned by the project, some commenters stated that the meetings were too far apart and not convenient. The CNF submitted requests for additional time to respond to the NOP. The Sierra Club and the Center for Biological Diversity filed a motion requesting the scoping period be extended and that additional scoping meetings be held to address impacts as well as alternatives. In response, CPUC Administrative Law Judge Weissman ruled that there be a second 30-day scoping period at the earliest practical time that focused on preliminary alternative identification. Cumulative Impacts. Concerns were expressed that the project would result in cumulatively significant harm by permitting completion of the “full loop” transmission alternative, because SRPL and “full loop” were closely related. Commenters suggested that the EIR/EIS consider cumulative harm of the “full loop” alternative on people and nature. Biological Resources Issues. Many comments addressed potential impacts to wildlife, habitats, and the pristine and undeveloped condition of the landscape. There were significant concerns expressed by resource agencies and environmental groups that the project would have major impacts on biological resources within ABDSP and in areas covered under the San Diego Multiple-Species Conservation Program Plan. It was noted that the project has the potential to impact native plants and bighorn sheep, raptors, gnatcatcher, least Bell’s vireo, and southwestern willow flycatcher and their habitats. Commenters asked that a thorough evaluation of biological resources be conducted in order to effectively mitigate potential impacts to such resources. The U.S. Fish and Wildlife Service requested that protocol surveys for sensitive species be completed prior to release of the Draft EIR/EIS to ensure that biological resource issues are effectively addressed and mitigated in the draft document. The U.S. Fish and Wildlife Service and California Department of Fish and Game requested mitigation measures be evaluated based on the implementation of measures for other projects. Cultural Resources Issues. Four comment letters were received from tribal governments and one from the Native American Heritage Commission (NAHC). The NAHC expressed concern on behalf of tribes in San Diego and Imperial Counties about the lack of information and inadequate

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consultation and urged the BLM to be proactive in providing tribes adequate opportunity for consultation on the Proposed Project. Visual Resources Issues. The County of San Diego expressed concerns with the visual impacts of the project, and suggested alternatives to the far north, outside San Diego County, or to the far south within San Diego County. Many individuals and community groups expressed concerns over the visual impacts to their residences, communities, and the San Diego County backcountry, including a decrease in tourism revenue as a result of visual impacts. The California Department of Transportation (Caltrans) expressed concerns about visual impacts to scenic highways and impacts to cultural resources within Caltrans rights-of-way. It requested that the EIR/EIS identify scenic highway design and eligibility, and develop visual simulations of views from State highways.

Water Resources Issues. The State Water Resources Control Board expressed concern regarding riparian corridors and other waters, and requested that all waters of the State affected by the project be identified, and that the board be consulted on mitigation measures concerning State water.

Air Quality Issues. The Imperial County Air Pollution Control Board of Directors expressed opposition to the construction of transmission lines between Imperial Valley Substation and San Diego. It expressed concern that the project would allow further fossil-fuel burning facilities to be built in the Mexicali Valley, where air quality standards are not as stringent as those in California, and could further degrade air quality in Imperial Valley and thereby negatively impact the health of residents. Regulatory Compliance. Caltrans commented that work performed in Caltrans ROWs will require an Encroachment Permit. It also requested that all areas where impacts occur on State ROWs be clearly delineated in the report and in maps.

Particular Permitting Challenges Evaluation and Selection of Alternatives. The originally proposed route would have passed through the Anza-Borrego Desert State Park, California’s largest State Park. As a result, there was pressure on the EIR/EIS team to identify a large range of alternatives that would avoid the Park or minimize the impacts in the park. The Assigned CPUC Commissioner (Dian Grueneich) specifically required that a route be considered that would avoid Anza-Borrego. The very large number of alternatives considered during the aggressive EIR/EIS schedule required a number of analytical methods to be developed. Biological and cultural resources surveys had been completed along 100% of the proposed route, but there was inadequate time to obtain landowner permission to survey all of the lands that would be affected. Accordingly, the EIR/EIS team and the CPUC and BLM developed sampling protocols, used in combination with assessment of air photos to define habitat types. Another alternative component of the EIR/EIS was the development of “non-wires alternatives” that were generation scenarios that could take the place if the transmission line were not

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constructed. The EIR/EIS team developed both a traditional (gas-fired) generation scenario and a completely renewable scenario with solar, wind, and geothermal power projects providing the power required for San Diego and for California’s RPS. Permitting through the Cleveland National Forest (CNF). SDG&E’s originally proposed route that passed through Anza-Borrego Desert State Park avoided the CNF, but the selected alternative (the Southern Route) required compliance with numerous specific CNF requirements. These requirements included limits on construction of access roads, resulting in most towers built via helicopter and reducing project impacts on the ground. Environmental Analysis of Connected Actions. The Sunrise Powerlink Project was proposed to import renewable generation from the Imperial Valley. The CPUC’s attorneys determined that the renewable generation projects were essentially part of the transmission project, since they could not be constructed in the absence of the transmission line. Therefore, the EIR/EIS included impact analysis of several solar, wind, and geothermal projects that were covered by Power Purchase Agreements with SDG&E. This additional analysis resulted in an extraordinarily lengthy and detailed EIR/EIS (the Final EIR/EIS was about 11,000 pages long). Environmental Analysis of Future Transmission Expansion Corridors. Because the SRPL was creating a new transmission corridor and new substations, the legal team supporting the CPUC determined that future new transmission lines connecting with the SRPL were foreseeable actions that should be analyzed in the EIR/EIS. This required the development of maps identifying likely future corridors, and the analysis of impacts created by these future corridors.

Schedule Deviations Even with the addition of the second (focused) Draft EIR/EIS, the timeframe required for the NEPA/CEQA process was relatively short. From the issuance of the NOI/NOP (August 2006) to the publication of the Final EIR/EIS (October 2008), 26 months elapsed. There was substantial pressure on the EIR/EIS team to maintain the project schedule due to both the reliability and RPS components of the project, so the EIR/EIS consultant added field personnel, technical staff, and specialty subcontractors (e.g., in areas related to wildfire, real estate and access acquisition, civil engineering). The aggressive schedule was partially responsible for the high cost of the EIR/EIS ($16 million before the start of construction monitoring).

Appeals or Legal Challenges The EIR/EIS was challenged in all possible legal and administrative venues, as summarized below. Despite these challenges, SDG&E moved forward aggressively with construction planning and acquisition of materials, so the challenges have not yet resulted in any project delays. Request for Rehearing at CPUC. After the CPUC approved the Southern Alternative in late 2008, several parties filed requests for rehearing (the CPUC appeals process). In 2009, the

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CPUC reaffirmed its December 2008 vote to approve the line by voting 4-1 to deny requests for a rehearing of the case. This decision stated that no legal errors were found in the four-year- long case, so a rehearing was rejected (SDG&E 2010). Federal Appeal to the Interior Board of Land Appeals (IBLA). The IBLA evaluated an appeal filed by several parties that was filed in [date]. After xx months of deliberation, the IBLA denied a motion to halt all planning, preconstruction and construction activities related to the transmission line. The IBLA rejected in its entirety the opponents’ request, stating they failed to show any likelihood of “immediate and irreparable harm” if Sunrise activities were allowed to move forward. (SDG&E 2010) CEQA Challenge to California Supreme Court. The adequacy of the EIR was challenged in a filing to the California Supreme Court, alleging that the EIR was not in compliance with CEQA. On [date] the Supreme Court declined to consider the filing, affirming the adequacy of the EIR. NEPA Challenge to Federal Court. The NEPA adequacy of the BLM and Forest Service decisions was challenged in Federal Court. In addition to the NEPA adequacy challenge, the complaint alleges violations of FLPMA, NFMA, and ESA. These challenges have not yet been resolved. Motions for a stay have been denied by the District Court, and are pending on appeal to the 9th Circuit. At this time, NEPA adequacy has still not been resolved. The BLM case was decided on other grounds and both the FS and BLM cases are pending appeals.

Discussion and Observations: Methods to Mitigate Permitting Delays While the Sunrise Powerlink Project did not experience significant permitting delays, there were numerous process challenges that present opportunities for learning about process improvements. 1. Preparation of a joint state (CEQA) and federal (NEPA) document is efficient and effective. In the case of the SRPL EIR/EIS, close coordination between the CPUC, BLM, USFS, and several cooperating agencies resulted in development of an EIR/EIS that served nearly all agencies’ permitting requirements. 2. Applicant needs to listen to serious route objections voiced early in the process and make revisions to the route as soon as possible. The CPUC Assigned Commissioner, Project Manager, representatives of the NRDC and many other NGOs told SDG&E that the route through Anza-Borrego would be difficult or impossible to permit. SDG&E decided to retain the proposed route through ABDSP for evaluation in the EIR/EIS. This required the EIR/EIS team, at the direction of the Assigned CPUC Commissioner, to develop and analyze numerous alternatives including one that completely avoided the park. 3. Utilities need to make effective use of the “pre-filing processes” offered by CEQA and NEPA lead agencies. a. Utilities should enter the pre-filing process with lead agencies early enough that changes can be incorporated. Ideally, the pre-filing consultation should occur before the utility has finalized its proposed route so useful input can be

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provided by the agencies. The length of time required to complete biological and cultural resources surveys presents challenges to utility schedules for permitting proposed projects. Thus, effective consultation may prevent the need for surveys to occur along a route that is unlikely to be permitted (like the SRPL Anza-Borrego route). b. Pre-filing consultation can ensure utility compliance with land management agency requirements related to resource management plans. Examples of challenges to be accommodated in siting transmission projects include USFS Riparian Conservation Areas and Forest Plan Consistency, and BLM Areas of Critical Environmental Concern. c. Utilities should enter the pre-filing process in good faith. In the Sunrise process, the CPUC and its consultant team were given the opportunity to review draft application files prepared by SDG&E, and numerous comments were given to SDG&E. However, the aggressive schedule that SDG&E was following did not allow time for the utility to incorporate many CPUC comments into the application. 4. NEPA and CEQA lead agencies should define the specific components of a “legally adequate” EIS or EIR, so each project document is not pushed to provide more and more comprehensive and detailed analysis in order to create a “legally bulletproof” document. In the case of the Sunrise EIR/EIS, the required analysis of “connected actions” and “future transmission corridor expansion” described above were required. These additional efforts, which were only mandated well after the project application was deemed complete, added hundreds of pages of analysis and many thousands of dollars of cost to the EIR/EIS. 5. Utility and agency staff should plan for workable construction schedules, while protecting sensitive biological resources. In the case of SRPL, construction has been severely limited where the route passes through areas of bighorn sheep habitat and in proximity to a number of golden eagle nests. Other serious restrictions are imposed by migratory bird nesting seasons. Early consideration of all such seasonal concerns, and the development of effective and creative mitigation measures to address them during the regulatory review of the project, could reduce construction delays. Other “Lessons Learned” from the project relate to working relationships among agencies (USFS, 2012):  There should have been a Memorandum of Understanding the FS and BLM for the cooperating agency status.  There was lack of interagency coordination and meetings during the NEPA/CEQA process. The FS/BLM deciding officials never met until after the CPUC issued its decision. Interagency working relationships are essential where multiple alternatives are being seriously considered.

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 There was a problem getting appropriate permitting agency review coordinated with lead agency reviews. For example, delays in obtaining 401 and 404 permits are an issue and should be addressed as part of the lead federal agency review. Also, coordination with the SHPO and FWS needs to happen early in the process. For a recent LADWP project (Barren Ridge Transmission), the draft BA and draft PA were released with the draft EIS. On the Sunrise project, the BLM didn't even file a BA or develop the PA until after the Final EIS was released.  It would have been helpful for BLM to identify an agency preferred alternative at the Draft EIS stage. That would have provided more focus for commenters, and it would have helped with the early consultation with FWS, the ACOE, the SHPO, and the State Water Board. It would have given the FS more clarity as well.  It is also important to evaluate the total time it takes to get from application to construction. It took almost two years for SDG&E to start construction after the CPUC decision because there were so many details to work out related to permits and mitigation. Doing some of that work prior to the adoption of the FEIS would have avoided construction delays.

Key Project Contacts In developing the information presented in this report, the consultant team consulted with the people listed in Table 1 below. [note: finalizing the list of contacts is still in progress as of 1/31/12] Table 1. Project Contacts Agency / Name Telephone Email Company SDG&E Kevin O’Beirne (858) 654-1765 KO'[email protected] CPUC Billie Blanchard (415) 703-2068 [email protected] BLM Thomas Zale, El Centro Field Office USFS Bob Hawkins

References BLM (Bureau of Land Management). 2010. BLM Strategies for Environmental Review of Renewable Transmission Line and Generator Interconnect Projects. Presentation at SCE sponsored symposium: Challenges and Solutions: Siting, Licensing and Construction of Renewables Power Transmission in California, LAX Renaissance, January 14, 2010 CEC (California Energy Commission). 2010. Planning and Siting for Renewable Energy Transmission and Generation Facilities in California. Presentation at SCE sponsored

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symposium: Challenges and Solutions: Siting, Licensing and Construction of Renewables Power Transmission in California, LAX Renaissance, January 14, 2010. CPUC. 2010. California Public Utilities Commission: A Regulator’s Perspective on Siting, Licensing, and Construction of Renewable Power Transmission, presentation at SCE sponsored symposium: Challenges and Solutions: Siting, Licensing and Construction of Renewables Power Transmission in California, LAX Renaissance, January 14, 2010 CPUC and BLM (California Public Utilities Commission and Bureau of Land Management). 2008. Final Environmental Impact Report/Environmental Impact Statement and Proposed Land Use Amendment for the Sunrise Powerlink Project. CPUC and BLM. 2006. Sunrise Powerlink Project Scoping Report part 1. Online: http://www.cpuc.ca.gov/environment/info/aspen/sunrise/scoping/scoping_report_part 1.pdf. Accessed on Jan. 16, 2012. CPUC and BLM. 2007. Sunrise Powerlink Project Scoping Report Part 2. Online: http://www.cpuc.ca.gov/environment/info/aspen/sunrise/scoping2/scoping_report_pa rt2.pdf. Accessed on Jan. 16, 2012. SCE (Southern California Edison). 2010. Transmission to Connect Renewables: Challenges & Solutions Symposium. January 14. SDG&E 2010. “The Powerlink Story.” Sunrise Powerlink. Online: http://regarchive.sdge.com/sunrisepowerlink/powerlink_story.html. Accessed on Jan. 16, 2012. USFS. 2012. Comments and personal communication between Susan Lee and Bob Hawkins. January 31.

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