The following emails were exchanged between Frank Creede, an RSFA resident, and Joseph Gabaldon, an SDG&E representative. We have redacted private information.
From: Frank Creede
Sent: Wednesday, February 21, 2018 2:55 PM
To: Gabaldon, Joseph M
Subject: [EXTERNAL] Steel utility poles in the Rancho Santa Fe Covenant
Dear Mr. Gabaldon,
My wife and I have lived at [redacted] for 18 years. The recent news that SDG&E plan to replace wooden utility poles with steel poles in our community with no notice is unconscionable.
We prefer undergrounding of utilities to preserve the rural character of this historic area. The Rancho Santa Fe Association and residents are happy to discuss undergrounding costs. The steel pole expenditures could be used wisely towards undergrounding vs. towards creating a 20+ year eyesore. Even with steel poles, the utility lines will be subject to falling trees. It is a partial solution with huge negative affects to our community.
Replacing wooden utility poles with steel coupled with zero community notice and involvement is absurd. We request that the replacement effort immediately cease and that SDG&E schedule a community meeting to discuss plans and options.
From: "Gabaldon, Joseph M"
Date: March 10, 2018 at 4:41:06 PM PST
To: Frank Creede
Subject: RE: Steel utility poles in the Rancho Santa Fe Covenant
Dear Mr. Creede,
Thank you for your correspondence related to the San Diego Gas and Electric (SDG&E) electric distribution project in a portion of Rancho Santa Fe. As you may be aware, we have been meeting with the Association Board members and staff to discuss various aspects of the project. I am responding on behalf of Caroline Winn to your letter about your desire to see the distributions lines put underground.
We have advised Association Board members of our willingness to work with them to explore ways to secure funding to see portions of the system placed underground. These discussions have centered around asking the County of San Diego for a loan from their 20A funds (specifically earmarked for undergrounding projects) or potentially asking residents of the Covenant to approve a per household assessment that could be used to fund the undergrounding projects.
The conversations about funding and other projects aspects will continue and the SDG&E team is committed to helping the Association board and residents find the best option to pursue. I have attached a Frequently Asked Questions (FAQ) sheet with this response and hope you will find this information useful. Thank you for your correspondence and please do not hesitate to contact me if you have further questions.
SDG&E | Public Affairs Manager
SDG&E RSF Project
Frequently Asked Questions
Question: Why is this project needed? How does it benefit our community?
Answer: To increase reliability of the electric distribution system serving portions of Rancho Santa Fe neighborhood, SDG&E is replacing outdated equipment and infrastructure. Additionally, we are converting our system from 4KV to 12 KV along with equipment upgrades to the existing substation, to serve increasing demand in the region.
Question: Why can’t the lines be converted to underground?
Answer: Customers within SDG&E service territory do have options to convert SDG&E’s equipment from overhead to underground. The Rancho Santa Fe Association is exploring its options for undergrounding power lines. These options may include the use of County of San Diego CPUC 20A Conversion Funds, but this approach may be insufficient for a project of this size. . Additional options are to have citizens fund undergrounding through the CPUC 20B and 20C programs or a special assessment district. Note: Undergrounding within RSF cannot be socialized by other customers across our service territory. Typically, undergrounding is several multiples more expensive than traditional overhead infrastructure.
Question: How much would it cost to underground the entire Covenant to underground?
Answer: SDG&E estimates the cost of undergrounding all overhead facilities (1,499 poles) in the Covenant to be in excess of $300 Million.
Question: What will the height of the new poles will be and is it true that they will be 50% higher?
Answer: The current pole heights for Rancho Santa Fe range from 30 feet to 56 feet tall. Of the ~120 poles in the project, ~70 of them will be on average 5 feet taller to meet current technical standards. The height of the 50 remaining poles will not change.
Question: When will the Project be completed?
Answer: There are three components to this project - enhancements and upgrades to an existing substation and system improvements to two electric circuits.
Circuit 2 will be completed on or near the end of August 2018.
Bounded by Linea del Cielo, La Gracia, Callejon Sur, Via de Santa Fe, Via de la Valle and Calzada del Bosque
Circuit 3 is still in the design phase.
Roughly bounded by Via de la Valle, La Valle Plateada, El Mirador, El Vuelo, La Colinas and El Zorro Vista.
Substation activities will be completed on or near June 2019.
Please keep in mind, construction schedules are subject to change, without notice, due to inclement weather or other unforeseen circumstances.
Question: What purpose do the planned outages serve?
Answer: Safety. We turn off power for the safety of our employees who are working around energized wires and transformers. Our team schedules outages to facilitate timely completion of the project and we notify impacted customers with as much lead time as possible.
Question. What if I don’t want to let SDG&E employees or contractors on my property?
Answer: Per State law and for your safety, SDG&E requires access to its equipment at all times. Restricting access is not only dangerous – it can drive up costs for all customers.
Question: I am concerned about electro-magnetic fields (EMF’s). What is SDG&E position on such matters?
Answer: There is no conclusive evidence that EMFs are harmful to human health at long-term, low-level exposure. Major reviews of scientific studies on EMF and possible health effects have reported that the body of study data, as large as it is, does not demonstrate that exposure to power-frequency magnetic fields causes cancer or other health risks, although the possibility cannot be dismissed.
Numerous internationally recognized scientific organizations and independent regulatory advisory groups have conducted scientific reviews, bringing together experts from a variety of disciplines to review the full body of research on EMFs. The weakness of the reported associations, lack of consistency and severe limitations in exposure assessment in the epidemiology studies together with the lack of support from laboratory studies were key considerations in the findings of the scientific reviews. Most reviews recommend further research, and, appropriately, research is ongoing worldwide.
SDG&E is committed to providing clean, safe and reliable electric service for its customers. We share the concerns of our customers over the possibility that electric and/or magnetic fields (EMF) might adversely affect health. Until research and the scientific community can provide greater direction, SDG&E will continue its efforts to inform the public and support on-going research.
For information, please visit http://www.sdge.com/safety/electric-and-magnetic-fields/emf-issue.
Question: Is SDG&E complying with CEQA? If SDG&E is exempt from CEQA, what is the statute stating they are exempt?
Answer: General Order 131D issued by the California Public Utilities Commission (CPUC) provides the rules relating to the planning and construction of electric generation, transmission/power/distribution line facilities and substations located in California. Section III(C) covers the construction of electric distribution line facilities, and states that such construction “does not require the issuance of a CPCN [Certificate of Public Convenience and Necessity] or permit by this Commission nor discretionary permits or approvals by local governments.” This provision means that SDG&E is not required to obtain a discretionary approval from the CPUC for distribution line facilities such as those at issue here, and similarly SDG&E is not required to obtain any discretionary approvals from the local government. CEQA applies to “discretionary projects proposed to be carried out or approved by public agencies” (Public Resources Code section 21080(a), 14 California Code of Regulations sections 15002(i) and 15357. Therefore, because SDG&E is not required to obtain any discretionary approvals for the distribution line work, CEQA does not apply.
Question: The Community of Rancho Santa Fe and Osuna Ranch both have a historic designation that protects the community and ranch. Is SDG&E abiding by the rules of these designations?
Answer: SDG&E’s distribution facilities are exempt from discretionary review pursuant to General Order 131D.
Question Did SDG&E receive an encroachment permit from the County for poles to be replaced in the County right of way?
Answer: The project will not include trenching and does not require encroachment permits from the County. Traffic control permits will be secured, if needed.
Question. What are the noticing requirements that SDG&E is required to follow prior to and during a project?
Answer: General Order 131D provides noticing requirements for projects subject to a CPCN or Permit to Construct. Distribution line facilities are not required to obtain a CPCN or Permit to Construct, so there are no official noticing requirements. However, as a courtesy SDG&E will continue to provide ongoing communications to affected residents.
Question: What Federal laws does SDG&E need to comply with environmental services?
Answer: The distribution line work does not require any federal authorizations or approvals.
Question. Is SDG&E exempt from the Covenant Height restrictions?
Answer: Pursuant to General Order 131D Section III(C), a “utility must first communicate with, and obtain the input of, local authorities regarding land use matters and obtain any non-discretionary local permits required for the construction and operation of these projects.” Section XIV of General Order 131(D) further “clarifies that local jurisdictions acting pursuant to local authority are preempted from regulating electric … distribution lines … or electric facilities constructed by public utilities subject to the Commission’s jurisdiction.” Therefore, SDG&E is not required to comply with Covenant Height restrictions.
Question. This project is a complete surprise. Why didn’t SDG&E notify the Association or residents previously?
Answer: On December 6, 2016, SDG&E’s project team met with RSF Association staff to discuss the project, scope of work, timelines and project areas. The SDG&E project team and Association staff had numerous meetings during the past year and a half (between August 3, 2016 and February 1, 2018). In addition, SDG&E has provided six notices to residents within the project area. Finally, SDG&E staff has made two presentations to the Board of Directors: June 1, 2017 and February 1, 2018.
Question. Will SDG&E host a public open house for the benefit of community residents?
Answer: SDG&E is currently available to meet with any concerned resident at their convenience and we welcome the opportunity to provide additional project information and gather feedback on the project from residents and the Board, upon invitation.
Question: Where can I go for periodic updates on the project?
A website is currently under development and will be launched no later than March 15th. We expect the URL will be www.sdge.com/RSFproject