APPENDIX A DETAILED PROJECT DESCRIPTION

A.8   ALTERNATIVES CONSIDERED

A.8.1   Introduction

As required by the California Environmental Quality Act (CEQA), a "range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the project objectives but would avoid or substantially lessen any of the significant effects of the project" (14 CCR. 15126.6[a]) has been considered. CAISO management and Board of Governors have determined the Trans Bay Cable Project is required to ensure reliable operation of the transmission system serving the San Francisco Bay area, and is preferred in comparison with alternate transmission projects (ISO Board of Governors Meeting, September 8, 2005).

The proposed Project includes installation of approximately 56 miles of HVDC submarine cable in the bottom of San Francisco Bay and Carquinez Straits from a converter station to be constructed in the City and County of San Francisco near Potrero Point to a converter station to be constructed in the City of Pittsburg in Contra Costa County.

The primary goal of the Project is to deliver electricity to San Francisco to meet demand projected for the period 2012 and beyond. The proposed Project is anticipated to meet the CAISO planning and reliability standards while creating economic benefit compared to Project costs. The Project would decrease transmission grid congestion in the East Bay, reduce transmission losses, increase the overall security and reliability of the electrical system, and provide potential savings to ratepayers.

The proposed submarine HVDC cable route was selected in coordination with applicable regulatory agencies and organizations (e.g., SF Bar Pilots) and avoids sensitive biological resources, known areas of contamination, anchorage areas, dredge areas, and sand mining areas, etc. No alternatives to the proposed submarine HVDC cable route are considered in this EIR.

This section summarizes the alternatives to the proposed Trans Bay Cable Project including:

The balance of this section is organized as follows:

A.8.2   Alternative Converter Station Sites

A.8.2.1   Introduction

Given that the primary objective of the Project is the delivery of electricity to San Francisco, a primary consideration in converter station site selection is to focus on parcels in proximity to major electrical substations. The proposed converter station site in Pittsburg (Standard Oil site) is presently under option to Trans Bay Cable LLC from the City of Pittsburg and would interconnect with the PG&E Pittsburg Substation via a single-circuit 230 kV AC transmission line. The proposed converter station site in San Francisco (HWC site) is presently under option to Trans Bay Cable LLC, and would interconnect via a double-circuit 115 kV transmission line with the PG&E Potrero Substation.

The Project Proponent has identified several alternative sites for the proposed converter stations. The suitability of the sites was evaluated considering:

The proposed 5.4-acre converter station site in the City of Pittsburg (known as the Standard Oil Site) is located within a developed industrial area with a mix of industrial and former industrial uses. The site is zoned General Industrial.

The proposed 5.6-acre converter station site in San Francisco (the HWC Site) is located on 23rd Street south of the existing Mirant Power Plant and adjacent to San Francisco Bay. The site is zoned Major Industrial.

A summary discussion of the alternative converter station sites considered, including onshore AC/DC cable routes and construction laydown areas, follows.

A.8.2.2   San Francisco Converter Station Site Alternatives

The alternative converter station sites in southeastern San Francisco that are evaluated in detail in this EIR are the Mirant Potrero and Sheedy sites. The converter station facilities that would be constructed and operated at these alternative sites are the same as those described in Sections A.2, A.3, and A.4 of this Appendix.

A.8.2.2.1   Mirant Potrero. The San Francisco Mirant Converter Station site is within the Mirant Potrero Power Plant property that is east of Illinois Street and north of 23rd Street. The site is immediately adjacent to the PG&E Potrero Substation and north of the proposed HWC site. Three different converter station layouts are under consideration on the Mirant Potrero site as shown on Figures A.8-1 through A.8-15. In addition, the onshore AC/DC cable routes associated with the three Mirant Potrero layouts are also shown on the previously referenced figures. This site includes several old structures, however, Mirant is seeking a demolition permit and plans to remove them. A brief description of each of the three Mirant Potrero converter station alternative layouts follows.

San Francisco Mirant Converter Station Alternative 1. This alternative site and layout are shown on Figures A.8-1 and A.8-2, respectively. This alternative layout is rectangular and is oriented east-west on the north side of 23rd Street and east of the PG&E Potrero Substation. This alternative would require removal of Station A on the Mirant Potrero property. This alternative layout avoids the existing Mirant units 4, 5, and 6 (peakers/jets). An elevation view of this alternative is shown on Figure A.8-3 and photosimulations are shown on figures A.8-4 and A.8-5.

San Francisco Mirant Converter Station Alternative 2. This alternative site and layout are shown on Figures A.8-6 and A.8-7, respectively. This alternative layout is "L" shaped and is oriented east-west on the north side of 23rd Street and east of the PG&E Potrero Substation. This alternative would require removal of Station A on the Mirant Potrero property. This alternative layout avoids the existing Mirant units 4, 5, and 6 (peakers/jets), and extends further to the east than alternatives 1 and 3. An elevation view of this alternative is shown on Figure A.8-8 and photosimulations are shown on figures A.8-9 and A.8-10.

San Francisco Mirant Converter Station Alternative 3. This alternative site and layout are shown on Figures A.8-11 and A.8-12, respectively. This alternative layout is rectangular and is oriented north-south on the north side of 23rd Street and east of the PG&E Potrero Substation. This alternative would also require removal of Station A on the Mirant Potrero property. This alternative layout also avoids the existing Mirant units 4, 5, and 6 (peakers/jets). The Alternative 3 layout minimizes encroachment on the eastern portion of the Mirant Potrero property. An elevation view of this alternative is shown on Figure A.8-13 and photosimulations are shown on Figures A.8-14 and A.8-15.

A.8.2.2.2   Sheedy. The San Francisco Sheedy site is bounded by 24th and 25th streets to the north and south, respectively, with Michigan Street to the west and the Western Pacific site and then San Francisco Bay to the east (refer to Figures A.8-16 through A.8-19). The site is in an industrial area immediately south of the proposed HWC site. Several existing structures on the site would require demolition. One potential disadvantage of this site is the difficulty in routing the 115 kV transmission line from the Sheedy site to the PG&E Potrero Substation given the presence of buried utilities in Illinois Street. Another disadvantage of the San Francisco Sheedy site is that the Project proponent does not have site control.

A.8.2.3   Pittsburg Converter Station Site Alternatives

The alternative converter station sites in Pittsburg that are evaluated in detail in this EIR are a location in an industrial area in the vicinity of West Tenth Street, near PG&E's Pittsburg substation, as well as a location on the Mirant Pittsburg Power Plant site adjacent to the PG&E Pittsburg Substation. The converter station facilities that would be constructed and operated at these alternative sites are the same as those described in Sections A.2, A.3, and A.4 of this Appendix.

A.8.2.3.1   West Tenth Street. The alternative Pittsburg West Tenth Street sites (Alternative 1, E/W and Alternative 2, N/S) are located in an industrial area of Pittsburg, south of the existing PG&E Pittsburg Substation and Mirant Pittsburg Power Plant. The sites are in close proximity to the PG&E 230 kV substation. Use of these sites would require leasing or procuring and sub-dividing several parcels. These sites are in proximity to a new residential community on the south side of West Tenth Street. The City of Pittsburg is in the process of amending the existing CS-O (1171) zoning district [Service Commercial with Limited Overlay (Ordinance No. 00-1171)] for a group of parcels. The affected zoning district includes 085-270-016, 085-270-018, 085-270-019, 085-270-020, 085-270-022, 085-270-025, 085-270-026, 085-270-029, 085-270-032, 085-270-035, 085-270-036, 085-270-038, 085-270-039, and 085-270-040) and encompass an area larger than that required for either of the 2 alternative converter station layouts under consideration for the West Tenth Street sites. The details of the proposed Overlay Zoning Amendment would be as follows with respect to allowable uses, setbacks, and height limitation:

"Utility, Major – L39" with the additional land use regulations: "L39 Limited, as a permitted use, to electrical substations of 50 megawatts or less, or AC/DC power converter stations with electrical transformers. Any structures must be located a minimum of 35 feet from the right-of-way of West Tenth Street and a minimum of 600 feet from the right-of-way of Beacon Street, and with the maximum height of any building not to exceed 65 feet and/or any ancillary structure/tower not to exceed 80 feet in height. The site perimeter must be planted with a substantial screen of evergreen trees and other landscaping in order to minimize the impact of the size, height and bulk of the structures."

This revised text to the City of Pittsburg General Plan is based on a Zoning Amendment proposed by the City in order to satisfy the needs of the Project Proponent. The language above does not apply to land use on West Tenth Street as it exists today.

The West Tenth Street sites, layouts under consideration, elevation views, and a photosimulation are presented on Figures A.8-20 through A.8-27.

A.8.2.3.2   Pittsburg Mirant. The Pittsburg Mirant site is located in unincorporated Contra Costa County within the Mirant Pittsburg Power Plant property, immediately adjacent to the PG&E Pittsburg Substation (Figures A.8-28 through A.8-31). The site is industrial and currently has an oil tank and several wooden and metal frame buildings, which would need to be demolished. The Project Proponent does not currently have a lease option agreement with the owner of this site (Mirant).

A.8.3   Alternatives Considered but Eliminated from Further Consideration

A.8.3.1   Introduction

The purpose of this Alternatives Analysis is to examine the different possibilities for meeting the Project's need and objectives (refer to Section 2.3 for more information). The analysis is needed to determine whether or not the Project objectives can be met by different means that avoid, minimize, or mitigate potential significant environmental effects of the proposed Project. Refer to Section A.8.2 (Alternative Converter Station Sites) and Section 5.0 for Project component alternatives that have been retained for further consideration in the environmental analysis. A comparative analysis of alternatives retained for further consideration, including the No Project Alternative, is presented in Section 6.0.

This Alternatives Analysis section supports the environmental review process required for the proposed Project. It is also intended to support agency review for the environmental permits and related approvals that would be required to construct and operate the proposed Project. For example, the Bay Conservation and Development Commission (BCDC) requires an analysis of alternatives prior to issuing a permit to allow construction activities that involve placement of fill within the Bay.

In accordance with the requirements of CEQA, this EIR must address Section 15126(a) of the CEQA Guidelines that states that a reasonable range of alternatives to the proposed project must be described and analyzed in the environmental review process to allow for a comparison by decision-makers. The Guidelines establish that the analysis should focus on alternatives capable of eliminating or reducing significant adverse environmental effects of a proposed project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly. However, the Guidelines establish that alternatives whose effects cannot be reasonably ascertained and whose implementation is remote or speculative need not be analyzed.

A.8.3.2   Project Objectives 

The purpose and need for the Trans Bay Cable Project is discussed in Section 2.3 and is summarized as follows with respect to transmission system reliability objectives. Refer to Section 2.3.2.1 for a discussion of Project objectives relative to converter station and cable route locations (Objectives 5 and 6).

On September 8, 2005, the CAISO staff recommended and the Board of Governors approved the Trans Bay Cable Project as the preferred long term transmission alternative to address the identified reliability concerns in northern San Mateo County and San Francisco beginning in 2012. The CAISO staff and Board of Governors support the early implementation of the Project for operation in 2009. Refer to Appendix C of this EIR for a copy of the CAISO Decision.

Trans Bay Cable LLC identified the following Project objectives. These objectives are used to guide and evaluate the selection of the most feasible alternative in this EIR and to meet the CAISO's San Francisco Stakeholders Study Group (SFSSG) plan reliability project requirements dated September 2, 2005. The following web address provides the San Francisco Peninsula, Phase 2, Long-Term Electric Transmission Planning Technical Study, Final Report, November 14, 2005: http://www.caiso.com/14cd/14cd7bd415cb0ex.html (CAISO, 2005a).

The overall objective of the proposed Project is to assist in meeting the current and projected electricity needs in San Francisco. The overall objective is based on achieving the following four specific project objectives.

A.8.3.2.1   Transmission System Reliability Objectives.

Objective 1: Create a More Diverse Transmission System in the Area. The objective is to increase transmission system reliability in the greater San Francisco Peninsula by providing a second independent major transmission route into the northerly end of the San Francisco Peninsula. This provides a long-term reliable access to a load-serving source of energy, provides access to more economically available energy in the East Bay, and decreases the San Francisco Peninsula's vulnerability and dependence over the single existing south-to-north transmission path.

Objective 2: Comply with Planning Criteria. The objective is to ensure that the transmission system serving the City of San Francisco will continue to provide both the capacity and flexibility necessary to meet the planning standards and criteria established by the CAISO and the North American Electric Reliability Council (NERC). In addition, compliance with the San Francisco Peninsula Long Term Transmission Planning Study Phase 2 prepared by the SFSSG will result in an integrated transmission system capable of supplying the City of San Francisco with the energy necessary to meet load demands in 2012 and beyond. See Appendix C of this EIR for relevant CAISO documents related to this study.

Objective 3: New Generation and/or Transmission Facilities. With no new generation anticipated to be built north of the Martin substation except the San Francisco Electrical Reliability Project, the CAISO plan to reliably serve the San Francisco load from 2012 and beyond requires a new transmission system to be installed. The singular and heavily loaded existing south-to-north transmission path serving San Francisco should be supported with the addition of new major transmission capacity. In addition, the installation of new transmission lines and pathways should be complementary to and compatible with allowing the San Francisco Peninsula access to available local generation as well as provide the CAISO the robust operating system necessary to effectively manage the area's transmission and generating systems.

Objective 4: Current Electric Supply and Demand. The objective is to supply northern San Mateo County and San Francisco County with a reliable, efficient, economic, and environmentally compatible source of energy from the East Bay. CAISO transmission studies estimate that the Project would allow the same load to be served with approximately 20 MW less generation because: 1) the Project would create a new, shorter transmission path into the northern San Francisco Peninsula; 2) the DC transmission line losses are less than a typical AC transmission line; and 3) congestion would be relieved in the transmission grid. The current transmission infrastructure within the San Francisco Peninsula area is insufficient to accommodate the CAISO-anticipated area load projections.

A.8.3.3   Alternatives Development and Screening Process

The alternative development and screening process applied to this Project involved the following steps:

In order to screen alternatives by their ability to avoid or reduce potential adverse impacts, judgments of potential Project effects were made. As such, the screening process is based on the anticipated significant adverse project impacts of the proposed Project and other alternatives that were considered to be potentially capable of meeting the Project goals and objectives.

Most of the anticipated potentially significant impacts for the proposed Project and alternatives would pertain to short-term construction activities associated with different facilities sites and transmission routes.

A.8.3.4   Screening Process Criteria

The process used to screen alternatives to the Trans Bay Cable Project includes application of the following criteria:

A.8.3.5   Alternatives Analysis Presentation

As discussed previously, the CAISO Board of Governors approved the Trans Bay Cable Project on September 8, 2005 as the preferred long-term transmission alternative to address the reliability concerns in northern San Mateo County and San Francisco. The CAISO through the SFSSG evaluated four transmission alternatives that were considered potentially capable of meeting the reliability concerns in northern San Mateo County and San Francisco by 2012 (and beyond), as follows:

The CAISO determined that the Trans Bay Cable Project is the only alternative capable of meeting the objective of establishing long-term reliable load serving capability by adding 400 MW of load serving capability upon its initial operation. Additionally, the CAISO identified the following three reinforcements, including the Trans Bay Cable Project, to meet the CAISO objectives:

Although the CAISO/SFSSG alternatives analysis focused on a much smaller list of potential alternatives, this alternatives assessment assesses a wider range of potential alternatives in order to comply with the requirements of CEQA. The sections below provide an analysis of potential alternatives to the Trans Bay Cable Project, including the proposed Project. The presentation for the alternatives analysis is as follows:

Discussions of each alternative considered and the screening analysis results follow.

The following potential alternatives are assessed in this section, some of which were considered by the CAISO as non-transmission alternatives:

A.8.3.5.1   Proposed Trans Bay Cable Project (Pittsburg-Potrero 400 MW DC).

Alternative Description. The proposed Project is the only alternative that is considered to be capable of meeting all of the screening criteria presented previously.

Screening Process Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria. This alternative meets the four specific project objectives for Criteria #1 - Project Objectives. It has been assessed by way of this EIR to meet the legal, regulatory, and technical feasibility categories for Criteria #2 – Alternative Feasibility. The assessment pertaining to Criteria #3 - Environmental Impacts Avoidance and Minimization is a finding that the proposed Project would have a different set of impacts relative to the other alternatives under consideration but the overall level of significance would be equal or less.

Alternative Conclusion. The proposed Trans Bay Cable Project meets the three Screening Process Criteria and is retained for further consideration.

A.8.3.5.2   Pittsburg to SF 400 MW DC Land-based Route – New Transmission Corridor.

Alternative Description. A land-based approach for transmitting the electricity from Pittsburg to San Francisco could involve development of a new transmission corridor that would run over Willow Pass and then through Contra Costa County and Alameda County to the edge of the Bay. This overhead or underground route would probably require avoiding the U. S. Naval Magazine – Port Chicago, the U.S. Naval Weapons Station – Concord, the U.S. Naval Magazine – Concord, and the Avon Refinery. The new routing would also need to avoid Briones Regional Park, Wildcat Regional Park, Tilden Regional Park, and other open space areas. In addition, it would be necessary to minimize impacts to existing linear features, such as roadways and other transportation systems in Contra Costa and Alameda counties. Further, it would be desirable to avoid siting the corridor where sensitive receptors (e.g., residences, parks, schools, hospitals, etc.) are located. In addition, a new transmission corridor would still have to cross the Bay and address the constraints associated with the Moraga substation to Potrero substation alignment (see Section A.8.3.5.5 below) or the Sobrante substation to Potrero substation alignment (see Section A.8.3.5.7, below).

Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria. This alternative does meet the four specific project objectives for Criteria #1 - Project Objectives. It has been assessed to not meet the legal, regulatory, and technical feasibility categories for Criteria #2 – Alternative Feasibility for the following two reasons: 1) while siting and developing a new transmission corridor is not impossible, it would be difficult to obtain all of the necessary permits and approvals in a timely manner, particularly given the potential for disruption to the public and to sensitive resources; and 2) it could be difficult, and possibly infeasible, to secure the required transmission ROW because of the varied land ownership and attendant constraints along a land-based route. Caltrans does not allow longitudinal encroachments within their ROWs thereby likely rendering this alternative infeasible. It is considered to be highly unlikely that this alternative could be sited, permitted, approved, and constructed in a timely manner. The assessment for Criteria #3 – Environmental Impacts Avoidance and Minimization, is a finding that the proposed Project would have a different set of impacts relative to this alternative but that the overall level of significance would be equal or less.

Alternative Conclusion. Development of a new land-based transmission route alternative was eliminated from further evaluation because: 1) it is considered that this alternative could not be sited, approved, permitted, built, and in operation in a timely manner (e.g., by 2009-2012) for Criteria #1; and 2) it does not meet the legal, regulatory, and technical feasibility categories for Criteria #2.

A.8.3.5.3   Pittsburg to SF 400 MW DC- Land-based Route – Within Existing Utilities and Transportation Corridors.

Alternative Description. The other potential land-based approach for the transmission of electricity from Pittsburg to San Francisco is use of portions or all of existing corridors established for such utilities as gas, water, and transit. There are eight primary categories of existing public and private utility corridors between Pittsburg and San Francisco that could potentially be used for the transmission system as described below.

Aboveground Routing. Aboveground routing requires power line infrastructure on which the cables are installed, except in specific cases (see discussion of BART, below) where the cable could potentially be attached onto other infrastructure for short and transitional intervals.

Bay Bridge Crossing. A critical piece of all routing options is a means of crossing the Bay into San Francisco. The logical means of avoiding potential marine effects would be to cross the bay by routing the cable over the Bay. Caltrans, however, does not allow longitudinal encroachments in their ROWs, and has other issues that would likely preclude installation (e.g., lack of available space and concerns regarding public safety and homeland security). In addition, construction of the eastern span of the new Bay Bridge is currently underway and is not expected to be completed in time to meet the Project objectives.

Electricity Corridors. Electricity corridors include primarily the PG&E routes that run through the East Bay. There is the possibility that the corridors of the East Bay Municipal Utility District or the San Francisco Public Utility District's Hetch Hetchy System could be used. However, these systems would require bringing the power across the Bay and, therefore, would not avoid Bay-related effects. The only existing electricity towers and lines that cross the Bay are south of San Francisco and using them would still require routing the electricity up the peninsula through San Mateo County. This would require using the existing San Mateo – Martin system or the Jefferson-Martin Project system corridor once it has been constructed.

Gas Pipeline Corridors. Gas pipeline corridors in the East Bay are discontinuous and could only provide a corridor for a portion of the transmission line route. In addition, there could be ROW constraints with co-locating the two types of systems. If the transmission line could be routed to the Emeryville-Oakland area, there would still remain the need for bringing it across the Bay.

Telecommunications Corridors. These corridors provide another alternative, with the same constraints as the previous two corridor options including the need for a Bay crossing.

Roadway Corridors. The Federal Highway Administration (FHWA) has provisions for crossing highways and freeways, but prohibits the placement of utility lines in the Interstate Highway System ROW. In California, Caltrans handles encroachment permitting for both federal and state highways. FHWA and Caltrans policies would prohibit using the I-680 and I-80 corridors. The use of the State Highway System would require Caltrans approval, including granting of an exception to their longitudinal encroachment policy. Roadways such as San Pablo Avenue are permissible, although these do not provide a relatively direct route and would therefore lengthen the route and compound roadway and traffic disturbance.

Private Rail Corridors. The UPRR and BNSF Railroad have ROW close to potential sites for the proposed Project Pittsburg Converter Station and/or the PG&E Pittsburg substation. The UPRR ROW runs all the way to the Emeryville-Oakland area, while the BNSF ROW terminates in Point Richmond. The railroad ROW has been used in the past for linear projects, such as telecommunication cables and industrial pipelines, but the rail companies are trying to retain the integrity of their ROW so that they can expand their trackage to support increased passenger rail service in addition to maintaining their freight service. Caltrans has been funding numerous projects to double or triple track the existing alignments to support enhanced passenger service by the Capitol Corridor Joint Powers Authority and both Caltrans and the railroads are reluctant to release ROW for other uses. In 2004, Project representatives presented UPRR with a proposal to install the transmission line in the UP ROW. The UPRR reviewed and rejected this Project (Love, 2004) based on the following: 1) the UPRR corridor from Pittsburg to Oakland is a "core network" route; and 2) current and expected freight rail growth combined with current and future obligations to provide capacity for commuter trains make it not possible for the UPRR to accommodate additional encroachments in an already crowded corridor.

Routing Within the BART System. The BART system provides a land-based route that appears more continuous than other corridors. Under this alternative, the location of the two converter stations would be unchanged from the Project, but the transmission route between the two converter stations in Pittsburg and San Francisco would go overland along the existing rail network of the BART system, from the Pittsburg Bay Point Station to the San Francisco Embarcadero Station. The route from the Pittsburg converter station to the Bay Point Station would require the underground installation of approximately 4.5 miles of cable in local surface streets. The route connecting the Embarcadero Station to the converter station in the vicinity of the Potrero substation would require the underground installation of approximately 4 miles of cable in local surface streets. Once in the BART system, the cables would be routed to accommodate all existing utilities, the varying ROW widths, and the constraints that would be encountered at the intermediate stations and differing trackage configurations. Between the Bay Point Station and Embarcadero Station, cable would be installed within five different trackage configurations, each requiring its own installation approach for each rail at grade, elevated rail, underground, Caldecott Tunnel, and the Trans Bay Tube. Other considerations and constraints identified for this alternative include:

In concert with the extreme difficulty of defining and planning the route, installing the cables within the BART ROW would place severe limits on the available construction window, thereby requiring a substantial amount of additional work to be performed. In addition, construction in the BART ROW would require continuous coordination and development of specially tailored construction procedures and methods. Safety of train operations is paramount, access to work areas is limited, and the available construction workday is expected to be a maximum of 3 to 5 hours for weekdays and weekends, respectively.

Unlike installation for an undersea cable, which can be accomplished with as few as zero to three splices, the number of splices for a land-based installation is determined by the capacity of "baskets" on the construction equipment that bring and lay-out the cable onsite. The maximum segment length on land is approximately 2/3 of a mile to 1 mile, thus requiring splicing at these intervals (and/or as defined by the work windows, as noted above). Each splice requires approximately 8 to 10 days to complete. This fact, combined with the 3 to 5 hour work windows, results in a construction schedule that is completely incompatible with the planned and safe BART operations. To make a comparison with fiber projects, the weight of the HVDC cable is approximately 50 pounds per foot and is approximately 10 inches in diameter. This means the HVDC cable can not be bent at a 90 degree angle and trying to hang the cable on the side of a wall means the structure would need to be able to support the weight of the cable. In comparison, fiber cable weighs approximately 5 pounds per foot and can be bent at a 90 degree angle. In the BART tunnel, the fiber optic cable is hung from the side wall; the cable diameter is about 2 inches and can be easily removed if it becomes necessary. In summary, while fiber optic cable can be readily installed in the BART tunnel, installation of a HVDC cable would be much more problematic.

Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria used in this assessment. The eight options for land-based transmission routing within existing corridors includes Aboveground Routing, Bay Bridge Crossing, Electricity Corridors, Gas Pipeline Corridors, Telecommunications Corridors, Roadway Corridors, Private Rail Corridors, and DC Routing Within the BART System. All eight options are considered potentially capable of meeting the four specific project reliability objectives for Criteria #1 - Project Objectives. However, it is considered unlikely that any of these alternatives could be sited, approved, and built in a timely manner. With respect to the legal, regulatory, and technical feasibility categories for Criteria #2 – Alternative Feasibility, four of these eight options have been differentially assessed to not meet at least one of the three categories, whereas, the remaining four options have been assessed to likely meet all three categories of feasibility although the actual implementation would be regarded as difficult, as summarized below.

Aboveground Routing. Public opposition to power lines installed onto other infrastructure for short and transitional intervals has been intensive, as demonstrated in public comments received on the Jefferson-Martin DEIR. As such, this option would likely meet substantial opposition and be very difficult to permit in a timely manner.

Bay Bridge Crossing. According to Caltrans, the new eastern section of the bridge is designed to have all conduit (except water) internal to the bridge, and available space has already been allocated. Therefore, this option is considered technically infeasible.

Electricity Corridors. This option likely meets the legal, regulatory, and technical categories of feasibility although the actual implementation would be regarded as extremely difficult.

Gas Pipeline Corridors. For segments of the corridors, this option likely meets the legal, regulatory, and technical categories of feasibility although the actual implementation would be regarded as difficult with respect to co-locating the two different types of systems, including consideration of safety issues.

Telecommunications Corridors. This option likely meets the legal, regulatory, and technical categories of feasibility although the actual implementation would be regarded as difficult.

Roadway Corridors. The ability to secure a continuous ROW for the entire project length along roadway corridors is not considered likely related to the legal and regulatory categories of feasibility. Although technically feasible, construction and schedule impacts upon traffic circulation would likely render actual implementation difficult.

Private Rail Corridors. Requests were placed by the Project Proponent with both BNSF and UPRR to evaluate the feasibility of routing the DC cables in the respective ROWs. BNSF was unwilling to consider a ROW based on several factors, including lack of space in the ROW, soil stability and wetland concerns, and declined to allow routing of cables in their tunnels (which would entail detours from the main rail route). BNSF responded that they were "respectfully denying" TBC's request to use a portion of the railroad ROW. UPRR similarly considered the conceptual ROW request and determined that there is insufficient space for the cable, given present and planned alignments and expansions, as noted above. The UPRR also rejected TBC's request to use a portion of their ROW due to expected growth in freight and commuter trains (Love, 2004). These alternatives are considered infeasible for legal and regulatory reasons (i.e., the Project Proponent cannot compel UPRR or BNSF to provide ROW). In addition, although potentially feasible from a technical standpoint, construction and schedule impacts pertaining to railroad company operations would likely render actual implementation of these alternatives difficult.

Routing Within the BART System. This option likely meets the legal and regulatory categories of feasibility, but does not meet the technical feasibility criteria. Significant legal feasibility property challenges exist for a route that uses the BART system, even excluding property and land use issues in the surface streets connecting the converter stations to BART in Pittsburg and San Francisco. One challenge would be to successfully obtain property interests along the proposed route sufficient to obtain both financing for construction and operation of the transmission line and title insurance. The preferred property interest for the transmission line is an easement, which is both a financeable and insurable interest. Licenses and franchises, although they may be financeable, are not insurable real property interests.

A second challenge associated with regulatory feasibility is the likelihood that the developer of the transmission line would need to deal with a multitude of other parties in addition to BART, including, without limitation, state agencies, counties, municipalities, local agencies and private parties, to negotiate, document and pay for easements, franchises, permits and consents. There would be significant time and costs associated with this process. Negotiation and documentation would extend not only to obtaining the easements and/or licenses and franchises for the transmission line, but also to obtaining permits, franchises and consents from third parties who may have other interests in the route (e.g., other easement holders and/or licensees), all with no assurance of success.

The title and survey work for a transmission line route under this alternative would also be problematic. Regardless of what type of interest was obtained and regardless that a significant portion of the transmission line route would be within the BART ROW, title for the route would need to be analyzed to ascertain what interests may be obtained, from whom to obtain those interests, and what other parties may have an interest in the transmission line route.

Given unlimited time, the BART easement and physical/engineering constraints might be able to be resolved. It could take additional months of route verification to determine whether a route is in fact technically feasible. However, in a meeting on March 23 of 2004, BART clearly explained that their responsibility and mission is for safe public transit and that safety and transit scheduling issues would override the electrical transmission project objectives and milestones (BART, 2004). In addition, the construction schedule necessary to safely support BART operations is not feasible for installation of the proposed cable including consideration of the time needed to perform cable spices that would be needed every 2/3 of a mile to 1 mile as discussed previously.

For all eight options, the assessment for Criteria #3 - Environmental Impacts Avoidance and Minimization, is a finding that the proposed Project would have a different set of impacts from these alternatives but that the overall level of significance would be equal or less.

Alternative Conclusion. Development of a land-based transmission route alternative within existing corridors was eliminated from further evaluation because: 1) it is considered highly unlikely that any of them could be sited, permitted/approved, and built in a timely manner; 2) all eight options fail one or more of the feasibility categories under Criteria #2; and 3) their relative impact significance would be expected to be equal to or greater than the proposed Project.

A.8.3.5.4   Reconductor Option.

Alternative Description. Instead of building a new line to San Francisco, this alternative would involve reconductoring, and the development of operating solutions to eliminate overloads and increase the load serving capability of facilities serving the overall San Francisco Bay Area. The alternative assumes that the existing generating units at the Potrero and Hunters Point power plants are retired, the City/County of San Francisco (CCSF) Electric Reliability Project consisting of four 48.7 MW combustion turbine generating units are operational, and that no new major transmission line is built to San Francisco from year 2011 to year 2018. Three of the combustion turbine generating units would be located at a shared site with SF MUNI and one unit would be located near San Francisco International Airport. In addition to the four projects identified in the CAISO Revised Action Plan, this alternative would require eight other projects to increase Greater Bay Area transmission load serving capacity through 2018 (as specified in Attachment 1 in the document titled: San Francisco Peninsula Long Term Transmission Planning Study, Phase 2, Draft Preliminary Results, Thermal Analysis Study, Reconductoring Alternative, 4 CCSF Generating Units Operational, Revised March 7, 2005)(CAISO, 2005b).

Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria. This alternative does not meet the four specific project reliability objectives for Criteria #1 - Project Objectives. It has been assessed as likely to meet the legal, regulatory, and technical feasibility categories for Criteria #2 – Alternative Feasibility. Since the alternative would involve reconductoring and operational solutions to existing infrastructure, it is assessed as likely to avoid and/or reduce environmental impacts relative to the proposed Project and would, therefore, meet Criteria #3 – Environmental Impacts Avoidance and Minimization.

Alternative Conclusion. This alternative was eliminated from further consideration because it does not meet all of the four specific project reliability objectives for Criteria #1 - Project Objectives. This alternative would not create a more diverse transmission system (Objective 1); it would not comply with the planning standards and criteria established by the CAISO and NERC (Objective 2); and this alternative would constitute a relatively short-term fix (through 2018), not a long-term solution as provided in part by the proposed Project.

A.8.3.5.5   Moraga-Potrero 230 kV AC/ HVDC.

The Moraga-Potrero alternative could involve installation of either a 230 kV AC line or a HVDC line, as discussed below.

Moraga-Potrero 230 kV AC.

      Alternative Description. The Moraga substation to Potrero substation alignment would involve a minimum of 20 miles of transmission of 230 kV AC electricity from the Moraga substation in the City of Orinda in Contra Costa County, through Alameda County, and into San Francisco. The route would utilize an existing transmission corridor from the Moraga substation to the Claremont substation in Alameda County and would then largely follow a common corridor to the east side of the Bay. There would be four options for bringing the power across the Bay. It could involve running a cable through the BART service tunnel, running the cable on the Bay Bridge, laying a new submarine cable, or a combination of using the bridge and a submarine cable. The potential impacts associated with the Bay crossing are similar to those described previously in Section A.8.3.5.3 for the Land-based Route – Within Existing Utilities and Transportation Corridors. Since the Embarcadero Substation is an indoor substation with limited room to expand, it may not feasible to add another 230 kV line. This constraint leaves using the PG&E Potrero Substation site as the most feasible option for interconnection to the electrical grid.

      Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria. This alternative does meet some of the four specific project reliability objectives for Criteria #1 – Project Objectives, such as increasing transmission system reliability in San Francisco by providing an alternative transmission pathway into the area. An assessment regarding this alternative's ability to meet the legal, regulatory, and technical feasibility categories for Criteria #2 – Alternative Feasibility is problematical, but regarded as likely not feasible at this time because of a range of potential issues associated with the Bay crossing and/or use of transportation and utilities ROWs similar to the discussion presented under Section A.8.3.5.3, above. The assessment for Criteria #3 – Environmental Impacts Avoidance and Minimization, is a finding that this alternative would likely result in equal or greater impacts than the proposed Project.

      Alternative Conclusion. This alternative was eliminated from further evaluation because: 1) implementation of this alternative is remote or speculative and may not be completed by the 2012 need date specified by the CAISO; and 2) it does not meet most of the screening criteria under Criteria #2.

Moraga-Potrero HVDC.

      Alternative Description. The Moraga substation to Potrero substation would be similar if not identical to the alignment for the Moraga-Potrero 230 kV AC option and would involve a minimum of 20 miles of transmission of HVDC electricity from the Moraga substation in the City of Orinda in Contra Costa County, through Alameda County, and into San Francisco. The route would utilize an existing transmission corridor from the Moraga substation to the Claremont substation in Alameda County and would then largely follow a common corridor to the east side of the Bay. Alternatively, the alignment could be along the BART or highway ROW. There would be four options for bringing the power across the Bay. It could involve running a cable through the BART service tunnel, running the cable on the Bay Bridge, laying a new submarine cable, or a combination of using the bridge and a submarine cable. The potential impacts associated with the Bay crossing are similar to those described previously in Section A.8.3.5.3 for the Land-based Route – Within Existing Utilities and Transportation Corridors. Additionally, a converter station would be required near the PG&E Potrero Substation and another near the PG&E Moraga Substation. The potential impacts associated with the Potrero converter station would be similar as that for the proposed TBC Project. The potential impacts associated with the Moraga converter station were not evaluated.

      Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria. This alternative does meet some of the four specific project reliability objectives for Criteria #1 – Project Objectives, such as increasing transmission system reliability in San Francisco by providing an alternative transmission pathway into the area. An assessment regarding this alternative's ability to meet the legal, regulatory, and technical feasibility categories for Criteria #2 – Alternative Feasibility is problematical, but regarded as likely not feasible at this time because of a range of potential issues associated with the Bay crossing and/or use of transportation and utilities ROWs similar to the discussion presented under Section A.8.3.5.3, above. The assessment for Criteria #3 – Environmental Impacts Avoidance and Minimization, is a finding that this alternative would likely result in equal or greater impacts than the proposed Project.

      Alternative Conclusion. This alternative was eliminated from further evaluation because: 1) implementation of this alternative is remote or speculative and may not be timely completed by the 2012 need date specified by the CAISO; and 2) it does not meet most of the screening criteria #2.

A.8.3.5.6   Moraga-Embarcadero 230 kV AC.

Alternative Description. The Moraga substation to the Embarcadero substation alignment would involve a minimum of 20 miles of transmission of 230 kV electricity from the Moraga substation in the City of Orinda in Contra Costa County, through Alameda County, and into San Francisco. The route would utilize an existing transmission corridor from the Moraga substation to the Claremont substation in Alameda County and would then largely follow a common corridor to the east side of the Bay. Under this alternative, the same four options as set forth in Section A.8.3.5, would bring the power across the Bay. It could involve running a cable through the BART service tunnel, running the cable on the Bay Bridge, laying a new submarine cable, or a combination of using the bridge and a submarine cable. Addition of a 230 kV line at the Embarcadero Substation from a new source would require converting the existing bus to a transmission bus configuration with all facilities electrically connected on the 230 kV side. Several 230 kV breakers and switches would be needed. Space at the site is extremely limited and not available for the amount of equipment needed for such a conversion. As such, since the Embarcadero substation is an indoor substation with limited room to expand, it is technically not feasible to add another 230 kV line. This constraint leaves using the Potrero site as the only feasible option (see Section A.8.3.5.5, above).

Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria. This alternative does meet some of the four specific project reliability objectives for Criteria #1 - Project Objectives, such as increasing transmission system reliability in San Francisco by providing an alternative transmission pathway into the area (Objective 1). An assessment regarding this alternative's ability to meet the legal, regulatory, and technical feasibility categories for Criteria #2 – Alternative Feasibility is problematical, but regarded as likely not feasible at this time because of a range of potential issues associated with the Bay crossing and/or use of transportation and utilities ROWs similar to the discussion presented under Section A.8.3.5.5, above. The assessment for Criteria #3 - Environmental Impacts Avoidance and Minimization, is a finding that this alternative would likely result in equal or greater impacts than the proposed Project.

Alternative Conclusion. This alternative was eliminated from further evaluation because: 1) implementation of this alternative is remote or speculative; and 2) it does not meet most of the screening criteria under Criteria #2 with respect to legal, regulatory, and technical feasibility.

A.8.3.5.7   Sobrante to Potrero 230 kV AC.

Alternative Description. The Sobrante substation to Potrero substation alignment would be very similar to the Moraga substation to Potrero substation alignment as described under Section A.8.3.5.6, above. It would require an additional 3.3 miles of cable between the Sobrante substation and the Moraga substation and would have the same limitations with respect to crossing the Bay and the need to get to the Potrero substation for interconnection to the electrical grid.

Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria. This alternative does meet some of the four specific project reliability objectives for Criteria #1 – Project Objectives, such as increasing transmission system reliability in San Francisco by providing an alternative transmission pathway into the area. An assessment regarding this alternative's ability to meet the legal, regulatory, and technical feasibility categories for Criteria #2 – Alternative Feasibility is problematical, but regarded as likely not feasible at this time because of a range of potential issues associated with the Bay crossing and/or use of transportation and utilities ROWs similar to the discussion presented under Section A.8.3.5.6, above. The assessment for Criteria #3 - Environmental Impacts Avoidance and Minimization, is a finding that this alternative would likely result in equal or greater impacts than the proposed Project.

Alternative Conclusion. This alternative was eliminated from further evaluation because: 1) implementation of this alternative is remote or speculative and may not be completed by the 2012 need date specified by the CAISO; and 2) it does not meet most of the screening criteria under Criteria #2 with respect to legal, regulatory, and technical feasibility.

A.8.3.5.8   Tesla-Potrero 230 kV AC.

Alternative Description. This alternative would involve installing about 21 miles of new 230 kV circuit from the Tesla substation to the San Ramon substation, reconnecting lines so that there are two 230 kV circuits connecting the San Ramon and the East Shore substations, reconductoring the two 230 kV lines connecting San Ramon to East Shore substations in the vicinity of Hayward (about 14 miles), and installing a new 230 kV overhead and underground line (about 31 miles for the overland route) from the East Shore substation to the Potrero substation. The alternative assumes that the existing generating units at the Potrero and Hunters Point power plants are retired, and that the four CCSF 48.7 MW combustion turbine generating units are operational. Three of the combustion turbine generating units would be located at the SF MUNI site and one unit located near San Francisco International Airport. This alternative would require four other projects to increase greater Bay Area transmission load serving capacity through 2018, as identified in the CAISO Revised Action Plan (see San Francisco Peninsula Long Term Transmission Planning Study, Phase 2, Draft Preliminary Results, Thermal Analysis Study, New 230 kV AC Line Alternative 2, Tesla-Potrero 230 kV Alternative, 4 CCSF Generating Units Operational, February 14, 2005)(CAISO, 2005c). This alternative would construct a new transmission line in parallel with the Jefferson-Martin Project.

Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria. This alternative does meet some of the four specific project reliability objectives for Criteria #1 - Project Objectives, such as increasing transmission system reliability in San Francisco. However, this alternative would still bring transmission into San Francisco via the peninsula and would not create a completely new transmission pathway as would the proposed Project. An assessment regarding this alternative's ability to meet the legal, regulatory, and technical feasibility categories for Criteria #2 – Alternative Feasibility is problematical, but regarded as likely not feasible at this time because of a range of potential issues associated with the amount of new transmission line ROW required through developed areas (e.g., residential), including the anticipated need to use transportation and utilities ROWs similar to the discussions presented previously. It is also considered unlikely that this alternative could be sited, permitted/approved, and built in a timely manner. The assessment for Criteria #3 - Environmental Impacts Avoidance and Minimization, is a finding that this alternative would likely result in greater impacts than the proposed Project.

Alternative Conclusion. This alternative was eliminated from further evaluation because:1) implementation of this alternative is remote or speculative and may not be completed by the 2012 need date specified by the CAISO; and 2) it does not meet many of the screening criteria under Criteria #1 and #2.

A.8.3.5.9   San Mateo to Martin 230 kV AC.

Alternative Description. The San Mateo substation to Martin substation project would involve the development of a 14.3-mile underground cable through northern San Mateo County. It would use the same route as the existing 230 kV underground transmission line between the two substations. The San Mateo substation is currently the only source of externally generated power to northern San Mateo County and San Francisco.

Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria. This alternative does not meet some of the four specific project reliability objectives for Criteria #1 – Project Objectives such as increasing transmission system reliability in San Francisco because this alternative would still involve bringing power up the peninsula to San Francisco. Additionally, with this alternative, if there were to be a loss of power to the San Mateo substation, San Francisco would lose nearly all of its ability to import electricity. It has been assessed as likely to meet the legal, regulatory, and technical feasibility categories for Criteria #2 – Alternative Feasibility. However this option would likely meet substantial public opposition (as demonstrated in public comments on the Jefferson-Martin EIR) and be difficult to permit in a timely manner. Since the alternative would involve installation within an existing 230 kV underground transmission line ROW, it is assessed as likely to avoid and/or reduce environmental impacts relative to the proposed Project and would, therefore, meet Criteria #3 – Environmental Impacts Avoidance and Minimization.

Alternative Conclusion. This alternative was eliminated from further evaluation primarily because it does not provide contingency for a San Mateo substation failure by providing an alternative transmission route into the San Francisco Peninsula area. In addition, it is considered unlikely that this alternative could be permitted, approved, and built in a timely manner.

A.8.3.5.10 Jefferson to Various SF Substations (230 kV AC).

Alternative Description. The Jefferson substation to various San Francisco substations alignments would connect the Jefferson substation to either the Potrero substation, Hunters Point substation, Embarcadero substation, Bayshore substation, or Mission substation, but would not connect the Jefferson substation to the Martin substation. However, supplying power from the Jefferson substation to the Embarcadero, Bayshore, and Mission substations is regarded as infeasible because of upgrade and space constraint limitations at these substations. This leaves only Potrero and Hunters Point as feasible options because both are outdoor 115 kV transmission substations that have property available for substation facilities expansions.

Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria. This alternative does meet some of the four specific project reliability objectives for Criteria #1 – Project Objectives such as increasing transmission system reliability in San Francisco. However, this alternative would still bring transmission into San Francisco via the peninsula and would not create a completely new transmission pathway as would the proposed Project. It has been assessed potentially capable of meeting the legal, regulatory, and technical feasibility categories for Criteria #2 – Alternative Feasibility, although the level of potential difficulty and time required to permit, approve, and build this alternative is considered to be very high as evidenced by PG&E's Jefferson-Martin Project. The assessment for Criteria #3 – Environmental Impacts Avoidance and Minimization, is a finding that this alternative would likely result in greater impacts than the proposed Project.

Alternative Conclusion. This alternative was eliminated from further evaluation because: 1) implementation of this alternative is remote or speculative and may not be completed by the 2012 need date specified by the CAISO; and 2) it does not meet many of the screening criteria under Criteria #1 (i.e., Objective 1).

A.8.3.5.11 New Generation – Mirant Potrero LLC Potrero Power Plant Unit 7.

Alternative Description. New generation capacity in San Francisco would be aimed at meeting electricity demand without the need to import capacity from outside the City and County. A new generation alternative in San Francisco that has been considered includes the Mirant Potrero LLC proposed Potrero Power Plant Unit 7. An application for the Potrero Unit 7 Project was filed in 2000 to develop a 540 MW natural gas-fired combined cycle power generating facility as an expansion of the existing Potrero Power Plant. The latest information available from the California Energy Commission (CEC), the agency responsible for approving the proposed project, is that on November 5, 2003 the applicant requested an indefinite suspension of the review proceedings. The CEC issued an Order terminating the Proceedings and the Docket closed on March 1, 2006.

Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria. This alternative does meet some of the four specific project reliability objectives for Criteria #1 – Project Objectives, such as providing increased system reliability and added capacity. While the Potrero Unit 7 Project is regarded as technically feasible, it has been assessed as potentially unlikely to meet the legal and regulatory technical feasibility categories for Criteria #2 – Alternative Feasibility. For example, siting and licensing of power plants has been problematic in San Francisco because of space constraints and community opposition (see Jefferson-Martin EIR, page Ap.1-194 and page AP.1‑196)(CPUC, 2003). The assessment for Criteria #3 – Environmental Impacts Avoidance and Minimization, is a finding that this alternative would likely result in significantly greater impacts (especially in San Francisco) than the proposed Project. For example, this alternative would likely impact the bay if the cooling water source was bay water as is the case for the existing Potrero Power Plant operation, and this alternative would result in long-term air emissions in San Francisco.

Alternative Conclusion. This alternative has been eliminated from further evaluation because: 1) implementation of this alternative is remote or speculative and may not be completed by the 2012 need date specified by the CAISO; 2) it is considered highly unlikely that this alternative could meet Criteria #2 relative to regulatory feasibility, including obtaining necessary approvals from applicable local jurisdictions; and 3) would result in greater environmental impacts in San Francisco than the proposed Project.

A.8.3.5.12 New Generation - Peaker Power Project.

Alternative Description. New generation capacity in San Francisco would be aimed at meeting electricity demand without the need to import capacity from outside the City and County. A new generation alternative in San Francisco that is under consideration is the San Francisco Electric Reliability Project (SFERP) proposed by the City and County of San Francisco (CCSF). The SFERP would consist of a 145 MW simple cycle power plant utilizing three natural-gas fired LM 6000 turbines and associated infrastructure. The currently proposed SFERP site is located south of 25th Street and east of Illinois Street about 0.25 mile south of the Mirant Potrero Power Plant. This project is currently being reviewed by the California Energy Commission.

Alternative Conclusion. The SFERP has been identified by the CAISO as one of three needed reinforcements to the electrical supply/distribution system in San Francisco (along with the Jefferson-Martin and Trans Bay Cable projects). As such, the SFERP is not considered to be an alternative to the Trans Bay Cable Project, but instead a potential complementary project to help meet the CAISO's objectives related to creation of a long-term, reliable energy solution in San Francisco.

A.8.3.5.13 Renewable Energy Sources – Wind, Solar, and Tidal Technologies.

Alternative Description. For the purposes of this Alternatives Analysis, the renewable energy sources considered were limited to those that could be applied within the City and County of San Francisco, thereby eliminating the need for transmission capacity. Potential renewable energy source alternatives to meet San Francisco's needs include wind, solar, and tidal technologies. There are two other renewable sources: geothermal and biomass. There are no proximate geothermal sources that could meet the identified needs and biomass is not feasible because there are no proximate fuel sources.

San Francisco has an approved Electricity Resource Plan that was developed as a result of the "Human Health and Environmental Protections for New Electric Generation" ordinance. The plan encourages the use of wind, solar, and tidal sources and identifies local project opportunities.

Wind Generation. Wind generation generally requires 40 to 50 acres per MW of power to be generated. Most of the best wind sources to meet the needs of San Francisco and the surrounding area have already been developed, primarily in the Altamont Pass area in Alameda County and in Solano County.

Solar Power Generation. San Francisco has proposed the use of solar power generated from sites such as the Moscone Center and the Southeast Water Pollution Control Plant. However, these sites have limited potential to meet the identified needs. The generation of power from a solar thermal power generation facility requires approximately 5 acres to produce 1 MW. Generation from a photovoltaic facility requires approximately 4 acres to produce 1 MW. Solar power generation is limited only to daylight hours and by the relatively high cost of solar panels and the large amount of surface area required for the panels.

Tidal Electricity Generation. Potential generating technologies for deriving electrical power from San Francisco Bay and the ocean include tidal power, wave power, ocean thermal energy conversion, ocean currents, ocean winds and salinity gradients. Of these, the three most currently well-developed technologies are tidal power, wave power and ocean thermal energy conversion. San Francisco has authorized analysis of tidal sources to help meet the identified needs. However, the technologies are new and it is not clear whether they would be feasible for the greater Bay Area and nearby ocean. For example, a possible tidal technologies application would include placement of underwater power generation (tidal) turbine units at the mouth of the Bay outside of the navigation zone.

Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria under this Alternatives Analysis. The three options for renewable energy sources include wind, solar, and tidal energy generation technologies. None of these three options are considered capable of meeting all of the four specific project reliability objectives for Criteria #1 – Project Objectives. For example, it is considered unlikely that any of these three options could meet Objective #2 (Comply with Planning Criteria). With respect to the legal, regulatory, and technical feasibility categories for Criteria #2 – Alternative Feasibility, these three options have been differentially assessed to not meet at least one of the three categories as summarized below.

Wind Generation. The large land requirement for generating wind power means that it technically is not a feasible option within the City and County of San Francisco. In addition, any electricity generated by wind power would need to be interconnected to the electrical grid in San Francisco via overhead and/or underground transmission lines.

Solar Power Generation. This option is regarded as not technically feasible for two main reasons: 1) while solar projects contemplated by San Francisco would reduce the City's future reliance on fossil fuels, it is unlikely that enough power would be generated to meet the identified needs or that it would be available to meet the identified schedule; and 2) similar to the wind energy discussion, above, there is a large land requirement (i.e., 4-5 acres of facilities for 1 MW of generation, and the need for overhead or underground transmission interconnection to the electrical grid in San Francisco).

Tidal Electricity Generation. The regulatory feasibility of this alternative is questionable because placing a system in the Bay and/or offshore would require obtaining permits from a number of agencies, including the USACE and the BCDC or the California Coastal Commission (depending on where a tidal generation facility would be located). The technical feasibility of developing a project for the greater Bay Area has not been fully evaluated. As such, the range and magnitude of potential environmental effects has not been assessed. However, it is considered likely that a tidal generation facility would have greater impacts to the marine and coastal environments relative to the proposed Project due to the required placement and operation of substantial equipment and facilities in the Bay or Pacific Ocean.

A detailed assessment for Criteria #3 Environmental Impacts Avoidance and Minimization, is not rendered at this time due to the different issues and unknown magnitude of potential impacts associated with these potential renewable energy resources. For example, while wind, solar, and tidal generation technologies may avoid some of the environmental effects associated with the proposed Project, construction and operation of these renewable energy options would likely have other types of environmental effects that may exceed those of the proposed Project.

Alternative Conclusion. Although renewable energy resources should be developed to the maximum extent feasible, development of a renewable energy resources option as an alternative to the project was eliminated from further evaluation because: 1) implementation of this alternative is remote or speculative; and 2) it does not meet most of the screening criteria under Criteria #1 and #2.

A.8.3.5.14 System Enhancement – Demand Management Option (DMO).

Alternative Description. The system enhancement alternative, Demand Management Option (DMO), involves techniques to reduce the overall use of electricity, as compared with techniques to increase supply. DMO programs consist of the planning, implementing, and monitoring activities of electric utilities that are designed to encourage consumers to modify their level and pattern of electricity usage. Techniques include end-user energy efficiency and conservation measures, load shifting and curtailment. In the past, the primary objective of most DMO programs was to provide cost-effective energy and capacity resources to help defer the need for new sources of power, including generating facilities, power purchases, and transmission and distribution capacity additions. However, due to changes occurring within the industry, electric utilities are also using DMO to enhance customer service.

Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria. This alternative does not meet the four specific project objectives for Criteria #1 – Project Objectives such as increasing transmission system reliability in San Francisco by providing an alternative transmission pathway into the area. It has been assessed to meet the regulatory feasibility category for Criteria #2 – Alternative Feasibility primarily because operational changes would occur to existing infrastructure. However, the development of this system enhancement alternative is beyond the capability and control of the proponents of the proposed Project. In addition, this alternative is likely not a feasible alternative to the Project because available energy savings from DMO programs are insufficient to supply necessary long-term needs. The alternative is assessed to potentially avoid and/or reduce environmental impacts relative to the proposed Project per Criteria #3 – Environmental Impacts Avoidance and Minimization.

Alternative Conclusion. This alternative was eliminated from further evaluation because: 1) implementation of this alternative is remote or speculative; and 2) it does not meet many of the screening criteria including Criteria #1 (Project Objectives).

A.8.3.5.15 System Enhancement – Distributed Generation Option (DGO).

Alternative Description. The system enhancement alternative, Distributed Generation Option (DGO), involves the use of generation, storage, and demand-side management devices, measures, and/or technologies connected to the distribution level of the transportation and distribution grid, usually located at or near the intended place of use. These act to either reduce the load on the system or are applied as additional system generation.

Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria. This alternative does not meet the four specific project objectives for Criteria #1 - Project Objectives, including increasing transmission system reliability in San Francisco by providing an alternative transmission pathway into the area. It has been assessed to meet the legal and regulatory feasibility categories for Criteria #2 – Alternative Feasibility primarily because it would involve operational and systems upgrade changes to existing infrastructure and through implementation of end-user strategies. However, it is likely not yet technically feasible to construct and operate in sufficient quantity to meet projected demand. The alternative is assessed to avoid and/or reduce environmental impacts relative to the proposed Project per Criteria #3 - Environmental Impacts Avoidance and Minimization.

Alternative Conclusion. This alternative was eliminated from further evaluation because: 1) implementation of this alternative is remote or speculative; and 2) it does not meet many of the screening criteria including Criteria #1 (Project Objectives).

A.8.3.5.16 Integrated Resource Alternatives.

Alternative Description. Integrated resource alternatives involve use of several components, rather than consideration of a single component, to meet needs. The components could include a combination of the following:

Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three Screening Process Criteria. This alternative does not meet all of the four specific project objectives for Criteria #1 - Project Objectives including increasing transmission system reliability in San Francisco by providing an alternative transmission pathway into the area. It has been assessed as unlikely to meet several aspects of the legal, regulatory, and technical feasibility categories for Criteria #2 – Alternative Feasibility as summarized by category below.

Legal Feasibility. If there were a system-wide proposal, it would likely legally require a programmatic EIR. The proposed project would then tier off of the programmatic EIR. In the absence of a system-wide plan and corresponding programmatic EIR, it is only appropriate under CEQA that projects be analyzed on a project-by-project basis. Furthermore, the development of a system-wide solution is beyond the capability and control of the proponents of the proposed Project.

Regulatory Feasibility. While it is important to address power needs with an integrated, coordinated solution, it is difficult to overcome regulatory obstacles if there is not a proposed system-wide solution.

Technical Feasibility. The technical feasibility of designing and implementing the integrated resource alternatives components specified above is uncertain due to lack of a clear understanding of the feasibility of the individual components. The strategic use of an integrated planning system is important, but it does not substitute for the need for tactical technological solutions such as the proposed Project.

The findings for Criteria #3 - Environmental Impacts Avoidance and Minimization, is problematic and speculative (i.e., unknown) due to the high degree of uncertainties associated with different scenarios for implementing an integrated resource alternative (i.e., selection of components).

Alternative Conclusion. This alternative was eliminated from further evaluation because: 1) implementation of this alternative is remote or speculative; and 2) it does not meet many of the screening criteria under Criteria #1 and #2.

A.8.3.5.17 Oregon-California Transmission: HVDC Underwater Cable from Oregon to San Francisco Bay Area.

Alternative Description. This alternative includes a 1,600 MW, HVDC, primarily underwater, transmission line which would stretch approximately 650 miles from a substation near Portland, Oregon to the San Francisco Bay Area (Sea Breeze Power, 2005). If completed, it would be the world's longest undersea HVDC cable.

Screening Criteria Suitability. Refer to Section A.8.3.4 for descriptions of the three screening criteria. This potential project is under consideration by Sea Breeze Power Corporation and PG&E and would tap hydroelectric power and wind energy resources in Pacific Northwest and Western Canada. Due to the preliminary nature of this proposal, the expected long lead time required for permitting, approvals and construction, and unknown environmental effects, it is problematic to assess this potential alternative at this time. It is considered highly unlikely that this potential alternative could be approved and built in a timely manner (i.e., does not meet Criteria #1-Project Objectives). In addition, this line would be the longest such line in the world, and would consume major portions of the world-wide manufacturing capacity for such lines. Due to size of the project, it is unlikely that either the required converter station(s) could be sited in San Francisco or that the line could be interconnected with existing San Francisco substations.

Alternative Conclusion. This potential alternative was eliminated from further consideration in this EIR due to: 1) implementation of this alternative is remote or speculative; and 2) it does not meet many of the screening criteria under Criteria #1 and #2.

A.8.3.6   Summary and Conclusion

This Alternative Analysis considered various potential alternatives to the proposed Project that were considered to be potentially capable of meeting the Project objectives. Based on the alternative screening analysis performed and presented herein, none of the various alternatives are considered to be capable of meeting all of the Project objectives and the related screening criteria for "feasibility" and "environmental impacts avoidance and minimization." Therefore, none of the aforementioned potential alternatives to the proposed Project were retained for further consideration in this EIR. Refer to Sections 5.0 and 6.0 of this EIR for an assessment of Project Alternatives that were retained for further consideration and full CEQA-level analysis in the EIR.

A.8.4   No Project Alternative

The No Project Alternative represents the status quo and under this alternative the proposed Trans Bay Cable Project would not be built. Under this alternative, the adverse and beneficial impacts associated with the Trans Bay Cable Project would not occur. Under this alternative, it is assumed that the transmission facilities planned to exist once the CAISO Revised Action Plan for San Francisco (Action Plan) is fully implemented by the end of 2007 would be utilized and relied on by San Francisco. Full implementation of the Action Plan is expected to provide adequate load serving capability to the San Francisco Peninsula area until the summer of 2011 when additional load serving capability will be needed to meet the anticipated power needs for the area. This alternative fails to meet San Francisco Bay Area long-term reliable load serving capability. The No Project Alternative also fails to meet the reliability planning standards. The No Project Alternative would be expected to have adverse effects on San Francisco's energy needs and supply beginning in 2012.


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