10-13

Comment noted. The offshore completion of the HDD cable installation would be contained so that sediment could not enter the water column. Please see Response to 10-10 for more information.

No nearshore construction activities would occur associated with the submarine cable installation since the cable would be installed via horizontal directional drilling (in conduit to preclude frac-out and contain cuttings for onshore retrieval, testing, and appropriate disposal) from shore to a distance of approximately 800 feet offshore regardless of which alternative was selected. No potentially significant Project impacts are anticipated and no additional mitigation is warranted.

10-14

The proposed Project no longer includes dredging in the Bay or connecting waterways (i.e., New York Slough near Pittsburg) associated with the Standard Oil site, including ancillary facilities, as that site has been withdrawn from consideration and it was the only Project component analyzed in the Draft EIR that had a related dredging component. Therefore, the Project no longer has a dredging or dredged material disposal component in New York Slough and no associated water quality or biological impacts would occur. Two small excavations (each less than 50 cubic yards) are planned in association with HDD activities (see Response to Comment 10-10).

10-15

As discussed in Sections 1.0 and 3.0 of this Final EIR, the Standard Oil site including ancillary facilities has been withdrawn from consideration, thus the potential wetland impacts analyzed in the Draft EIR for this site would not occur. As noted in Draft EIR Table 2-1, the proposed installation of the submarine cable in the bottom of the Bay would require an individual permit or general permits from the USACE pursuant to the USACE Regulatory Program for authorizing actions under Section 10 of the Rivers and Harbors Act and Section 404 of the Clean Water Act. The Project proponent has coordinated with the USACE regarding the proposed Project and plans to submit permit applications to the USACE in the near future. It is anticipated that the USACE permitting process, including consultations with other federal agencies (e.g., National Oceanic and Atmospheric Administration [NOAA] Fisheries and U.S. Fish and Wildlife Service [USFWS]), will take 4 to 6 months.

10-16

As discussed in previous comment responses, the Standard Oil site including ancillary facilities has been withdrawn from consideration, thus the potential impacts and relevance of sensitive habitats and species occurrences are no longer applicable. As discussed in Draft EIR Sections 4.5 and 5.2 through 5.6, and also in the new Section 4.A of the Final EIR, the other converter station sites under consideration occur on Disturbed/Developed properties and would not be expected to impact terrestrial biological resources.

10-17

As discussed in previous comment responses, the Standard Oil site including ancillary facilities has been withdrawn from consideration, thus the potential impacts, mitigation, and relevance of sensitive vernal pool, saltmarsh, other wetland habitats and/or rare plant and species occurrences are no longer applicable to the Project.

10-18

Neither of the proposed converter station sites or associated ancillary facilities under consideration in the Final EIR would result in potentially significant impacts to terrestrial biological resources due to the pre-disturbed/developed nature of the sites. Therefore, the additional plans mentioned in this comment have no applicability to the TBC Project.

10-19

Please refer to Response 10-17.

10-20

Please refer to Response 10-17.

10-21

Please refer to Response 10-17.

10-22

Please refer to Response 10-15.

10-23

Please refer to Response 10-17.

10-24

Refer to Response 10-17.

10-25

Comments noted. The alternative to which this comment applies, the Pittsburg West Tenth Street Alternative 2 converter station site and ancillary facilities, has two identified unavoidable adverse significant impacts (construction noise and visual resources) as summarized in Draft EIR Sections 1.3.5, 5.5.5, and 6.3. Therefore, the City of Pittsburg and the Project proponent currently do not expect to utilize this alternative. Were this alternative to be selected, the minor wetland area north of the site (estimated at approximately 30 feet in width) would be crossed by the AC and DC cables associated with this alternative using jack-and-bore auger technique. This technique would preclude the potential for frac-out and associated impacts.

10-26

Comment noted. As discussed previously, the formerly proposed Pittsburg Standard Oil Converter Station site, including ancillary facilities such as onshore cable routes, has been deleted from further consideration. The remaining converter station sites in Pittsburg including the now proposed West Tenth Street Alternative 1 site and ancillary facilities, do not have suitable habitat for the Suisin song sparrow and no Project-related impacts would be expected to occur to this specie.

10-27

Comment noted. Please refer to new Section 13.0 of the Final EIR for revisions to Appendix F (List of Potentially Affected Species, page 15) related to the CNPS status of the bearded popcorn-flower.

10-28

Comments noted. As shown on Figure 4.6-2 of the Draft EIR, the proposed submarine cable route does not cross any intertidal mudflats; it is located in deeper water. No Project-related impacts to intertidal mudflats are anticipated and no additional mitigation is warranted.

10-29

Information on life history and habitat requirements of special status species are described in Section 4.6.1.3 of the Draft EIR. As discussed in Section 4.4 (Water Quality) of the Draft EIR, the cable-laying operation would result in a very localized sediment plume that is not expected to significantly impact water quality. Installation of the cable could potentially suspend approximately 6,220 to 12,440 cubic yards of sediment over the entire 53-mile Project area. This would amount to about 117 to 235 cubic yards of suspend material per mile. This amount of suspended material is small compared with the volume of sediment naturally resuspended on a regular basis in the Bay by the tides or wind. Listed fish species were not addressed separately in the impacts section of the Draft EIR, however, all fish species inhabiting the Bay including listed species such as delta smelt are well adapted to the natural condition of relatively high turbidity. It is expected that adult and juvenile delta smelt would react to the temporary disturbance of the cable laying operation similarly to other mobile organisms as described in Section 4.6.3.2.4 in the Draft EIR, that is, they would tend to exhibit temporary behavioral avoidance of the immediate area of increased turbidity and activity during the cable laying operation. Impacts to fish, including listed species, are not expected to be significant.

In addition, as discussed in the Draft EIR, installation would be conducted within Environmental Work Windows outlined in the Long Term Management Strategy (LTMS) for bay dredging and disposal, recognized by agencies such as NOAA Fisheries. The work windows would provide for protection of listed salmonids and a number of other species such as Pacific herring and Dungeness crab.

10-30

Comments noted. As shown on Draft EIR Figure 4.6-1, the range of Pacific herring spawning grounds includes the nearshore area off of Potrero Point in San Francisco. As shown on Figure 4.6-2 of the Draft EIR, the proposed submarine cable route avoids eelgrass bed areas in the Bay by a wide margin. Construction of onshore Project facilities in San Francisco would have no potential to impact this locally important commercial fishery. In addition, no nearshore construction activities would occur associated with the submarine cable installation since the cable would be installed via horizontal directional drilling (in conduit to preclude frac-out and contain cuttings for onshore retrieval, testing, and appropriate disposal) from shore to a distance of approximately 800 feet offshore regardless of which alternative was selected. No potentially significant Project impacts to Pacific herring are anticipated and no additional mitigation is warranted.

10-31

Cable installation is not expected to have a significant impact on marine birds, including listed species, thus no mitigation measures are required. Listed bird species which may forage on the open Bay include the California brown pelican and the California least tern. The brown pelican forages over large areas of the Bay. Typically, least terns forage within 2 miles of their nesting colony, allowing them to alternate between feeding and protecting their nests. The largest least tern nesting colony in the Bay is at the former Alameda Naval Air Station, more than 2 miles from the southern end of the cable-laying operation.

Installation of the cable would involve movement of a cargo size ship or work barges over the cable route. Most of the cable route is in open water near the main channel of the Bay (see Figure 1-1 of the EIR). The installation activity would be temporary in any given area of the Bay and would not be substantially different than regular shipping activity that occurs throughout north San Francisco Bay on a daily basis. While foraging by these species could not occur at the specific location of the cable-laying ship, adjacent open water would always be available. No foraging habitat would be permanently lost.

10-32

Comments noted. Draft EIR Figure 4.6-2 accurately reflects the location of eelgrass beds which occur in the San Francisco Bay and San Pablo Bay portions of the general Project area. This figure is based on data from the most recent source: The Baywide Eelgrass Inventory and Habitat Management Research Program (Merkel and Associates, 2004), a joint effort of the California Department of Transportation (Caltrans) and National Marine Fisheries Service (NOAA Fisheries). As shown, the proposed submarine cable route, including 500-meter-wide study corridor, does not traverse near any of the mapped eelgrass bed locations. Accordingly, no impacts to eelgrass beds are expected and no mitigation is warranted. There are no eelgrass beds located east of Point Pinole, thus Figure 4.6-2 of the Draft EIR is limited to the applicable portion of the cable route where eelgrass beds are actually present. The text in Final EIR Section 4.6.1.2.5 has been revised in response to this comment to clarify the geographical extent of eelgrass beds in the Project area. Please refer to new Section 13.0 of the Final EIR for the applicable text revision.

Reference: Merkel and Associates. 2004. Baywide Eelgrass Inventory and Habitat Management Research Program. Prepared in cooperation with NOAA Fisheries and Caltrans. October.

10-33

Information on life history and habitat requirements of the delta smelt are described in Section 4.6.1.3 of the Draft EIR. Delta smelt (and other listed fish species) were not addressed separately in the impacts section of the Draft EIR. As discussed in Draft EIR Section 4.4 (Water Quality), the cable-laying operation would result in a very localized sediment plume that is not expected to significantly impact water quality. Installation of the cable could potentially suspend approximately 6,220 to 12,440 cubic yards of sediment over the entire 53-mile project area. This would amount to about 117 to 235 cubic yards of suspend material per mile. This amount of suspended material is small compared with the volume of sediment resuspended in the Bay by the tides or wind. Fish species inhabiting the Bay and estuarine species such as delta smelt are well adapted to the natural condition of relatively high turbidity. It is expected that adult and juvenile delta smelt would react to the temporary disturbance of the cable-laying operation similarly to other mobile organisms as described in Section 4.6.3.2.4 in the Draft EIR, that is, they would tend to exhibit behavioral avoidance of the immediate area of increased turbidity and activity during the cable-laying operation.

As described in the Draft EIR, during spawning, the delta smelt prefers freshwater habitats. Delta smelt begin a diffuse, gradual migration to upstream spawning areas in September or October. Delta smelt spawn from February to July in side channels and sloughs in the upper delta and in the Sacramento River north of Rio Vista. Spawning is not likely to occur in the open water areas traversed by the Trans Bay Cable, thus no impacts to spawning habitat are expected.

10-34

All of the regulations described in Section 4.6.2 of the Draft EIR apply to San Francisco Bay biological resources and the Project proponent and agencies involved would need to comply with the requirements of each. The Project will require a number of permits and consultations with various agencies. For example, the Project will require a permit from the USACE under Section 404 of the Clean Water Act. During this process, the USACE will need to consult with other Federal agencies, including NOAA Fisheries (consultation on listed species and Essential Fish Habitat) and the U.S. Fish and Wildlife Service (consultation on listed species). The Marine Mammal Protection Act is described in Section 4.6.2 of the Draft EIR and would apply to the Project with regard to disturbance to marine mammals, generally from underwater sound. It is possible that the Project may require an Incidental Harassment Authorization from NOAA Fisheries. During processing of the environmental permits for the Project any additional avoidance or mitigation measures or restrictions stipulated by the agencies would be made conditions of the environmental permits and would be required to be carried out.

10-35

Prior to preparation of the Draft EIR, representatives of the City of Pittsburg, the Project proponent, and the EIR consultant (URS Corporation) met with numerous regulatory agencies including: USACE, NOAA Fisheries, U.S. Coast Guard, SLC, the Bay Conservation and Development Commission (BCDC), Regional Water Quality Control Board, CCSF, Port of San Francisco, and the Bay Area Air Quality Management District (BAAQMD). The aforementioned agencies indicated they might comment on the Draft EIR and that they may stipulate conditions in their respective permits for the Project based in part on the findings in the Draft EIR. In general, all of the agencies explained their potential jurisdiction, any potential concerns or issues they might have had regarding the Project, etc. The results of these informal agency meetings are considered in the scope of the Draft EIR, as appropriate. Refer to Section 10.3 of the Draft EIR for a list of agencies, organizations, and other entities that were consulted during preparation of the Draft EIR. In summary, no mitigation measures beyond those specified in the Draft EIR were recommended by agencies with regulatory authority over this Project prior to issuance of the Draft EIR on May 10, 2006.

10-36

As discussed in Section 4.4 (Water Quality) of the Draft EIR, the cable-laying operation would result in a very localized sediment plume that is not expected to significantly impact water quality. Installation of the cable could potentially suspend approximately 6,220 to 12,440 cubic yards of sediment over the entire 53-mile Project area. This would amount to about 117 to 235 cubic yards of suspend material per mile. This amount of suspended material is small compared with the volume of sediment resuspended in the Bay by the tides or wind. Fish species and filter feeding invertebrates inhabiting the Bay and estuarine species such as delta smelt are well adapted to the natural conditions of relatively high turbidity in the Bay. As described in the Draft EIR, it is expected that adult and juvenile fish would react to the temporary disturbance of the cable-laying operation by exhibiting behavioral avoidance of the immediate area of increased turbidity and activity during the cable-laying operation. As described in Section 4.6.2.5 of the Draft EIR, there would be some loss of benthic organisms in the immediate vicinity of the disturbance, followed by re colonization of the disturbed areas. These impacts were considered adverse, but not significant and as such, no mitigation measures are warranted.

10-37

Please refer to Response 10-14.

10-38

Please refer to Responses 10-10, 10-12, and 10-29.

10-39

Please refer to Response 10-9.

10-40

Comment noted. The potential splice locations are shown on Map A.2-1, Sheets 5 of 10 (approximate milepost [MP] 22.1), 6 of 10 (MP 26.5), and 7 of 10 (MP 38.5). The actual need for, and specific locations of, cable splices will be determined during final engineering following completion of the forthcoming geophysical survey. It is currently anticipated that up to three cable splices may be required, two in the relatively shallow water where the cable route crosses Pinole Shoals, and another in the Carquinez Strait area where it is anticipated there would be a transition from utilization of a cable-laying ship (to west) to a cable-laying barge (east to Pittsburg). The splice operation involves precise welding of the individual cable strands and must be performed on the ship and/or barge, as applicable, and would not involve a splice box on the Bay floor. The splice would be approximately the same diameter as the balance of the cable bundle (i.e., approximately 10 to 12 inches in diameter). No potential impacts to marine organisms associated with the splice operation or the splice itself would be expected to occur. Since there are no anticipated splice-specific impacts to marine organisms, additional discussion in Section 4.6 is not warranted.

10-41

The executive summary has been revised to reflect the requirement for a USACE 404 permit and the nexus with 36 CFR 800.The text in Sections 1.2.3 and 1.2.6 of the Final EIR has been revised in response to this comment.

10-42

Please refer to Response 10-40.

10-43

The geophysical survey (Mitigation Measure CUL-3a) will be completed prior to final engineering, however, the Project proponent has indicated that it is not feasible to complete the survey prior to issuance of the Final EIR. Mitigation Measure CUL-3b provides for avoidance of any submerged archaeological resources found during the geophysical survey. The cable route study corridor is 500 meters wide and provides ample room to make minor adjustments to the cable route prior to construction to avoid any archaeological resources found during the forthcoming survey.

10-44

As discussed in Response 3-7, the Draft EIR recognizes the unavoidable adverse impacts that could occur to contributing elements of the potential historic districts associated with implementation of the Project at the HWC site in San Francisco. The Draft EIR presents mitigation measures to address these impacts. Furthermore, partly in response to comments received regarding potential historic resources impacts associated with development of the Project on the HWC site, the Project proponent has negotiated with the landowner at the HWC site and now proposes to shift the San Francisco converter station to the west on the overall HWC property (HWC [Mitigated] site). The HWC (Mitigated) site completely avoids direct impacts to the two historic buildings on the eastern portion of the HWC property. This action would not directly or indirectly impact the potential historic district(s) or contributing elements of potential historic district(s) located north of the HWC site. Refer to Section 4.A.7 of the Final EIR for more information.

10-45

Comments noted. As discussed in previous comment responses, the Standard Oil site, including ancillary facilities, has been withdrawn from consideration, thus the potential impacts and relevance of the cultural resources/historic attributes of the adjacent rail facilities are no longer applicable.

10-46

Refer to Response 10-45.

10-47

Text from Section 4.7.2.1 of the Draft EIR has been revised in response to this comment. Please refer to new Section 13.0 of the Final EIR for applicable text revision.

10-48

At this point in time, the Project proponent does not have site control of the parcel in question (i.e., Mirant Potrero). Furthermore, the parcel contains structural development that would need to be removed in order to access proposed construction areas. As such, it is infeasible to implement Mitigation Measure CUL-1a (Archaeological Resource Testing) prior to completion of the environmental document.

10-49

If archaeological testing and possible data recovery are required, the Project proponent will coordinate with the City of Pittsburg and the CCSF to ensure appropriate steps are taken to satisfy these mitigation measures. This coordination could also involve the USACE and the State Historic Preservation Office should the USACE conclude the subject area identified for testing or data recovery is within the jurisdictional footprint of the USACE's 404 permit, thus creating a nexus with Section 106 of the National Historic Preservation Act.

10-50

Comments noted. As stated in the prelude (Historical Architectural Resources) to Mitigation Measure(s) CUL-2 (Disturbance of Historical Architectural Resources), these measures apply to construction of the San Francisco HWC Converter Station which would involve demolition of historical resources. It should be noted that, partly in response to comments received regarding potential historic resources impacts associated with development of the Project on the HWC site, the Project proponent has negotiated with the landowner at the HWC site and now proposes to shift the San Francisco converter station to the west on the overall HWC property (HWC [Mitigated] site) , thereby completely avoiding direct impacts to the two historic buildings on the eastern portion of the HWC property. Another advantage of the HWC (Mitigated) site is that it allows the proposed 115 kV interconnection to the PG&E Potrero substation to be installed without impacting the Station A Complex on the adjacent Mirant Potrero property. This action would not directly or indirectly impact the potential historic district(s) located north of the HWC site. Refer to Section 4.A.7 of the Final EIR for more information. The mitigation measures presented in the Draft EIR that would be undertaken to address the San Francisco Mirant alternative to the proposed Project have been expanded and clarified. The Draft EIR presents three mitigation measures (i.e., Mitigation Measure CUL-2a, Recording Architectural Resources; CUL-2b, Architectural Resource Interpretive Display and/or Interpretive Material; and CUL-2c, Architectural Resource Salvage Opportunities). Mitigation Measure CUL-2d (Central Waterfront Historic Preservation) has been added to the Final EIR. Please refer to Section 13.0 of the Final EIR for the applicable text revision.

10-51

Comments noted. Maintenance activities associated with the converter stations and ancillary facilities are not anticipated to involve ground disturbance and, if ground disturbance was required, it is anticipated that it would only occur in areas that had been previously disturbed and/or cleared from a cultural resource perspective.

10-52

Comments noted. As discussed in previous comment responses, the Standard Oil site including ancillary facilities has been removed from further consideration, thus the potential historic significance of railroad facilities in this area is no longer germane to the proposed TBC Project.

10-53

Please refer to Response 10-43.

10-54

If unavoidable marine archaeological resources were encountered, the Project proponent would coordinate with the City of Pittsburg, the CCSF (if the resources were on submarine lands under its authority), and the SLC to ensure appropriate steps were taken to satisfy these mitigation measures. California Public Resources Code 6313 also requires the SLC to coordinate with the State Historic Preservation Office. Additionally, it is likely the USACE (and the State Historic Preservation Office) would be involved should the USACE include the subject area identified for testing or data recovery as within its jurisdictional footprint of the USACE's 404 permit, thus creating a nexus with Section 106 of the National Historic Preservation Act.

10-55

Comments noted. No planned maintenance activities are associated with the proposed submarine cable. If maintenance activities required ground disturbance (e.g., to repair a cable break), it is anticipated that it would only occur in areas that had been previously disturbed and/or cleared from a cultural resource (e.g., shipwreck) perspective.

10-56

Comments noted. The Standard Oil site in Pittsburg has been removed from further consideration. Further, partly in response to comments received regarding potential historic resources impacts associated with development of the Project on the HWC site, the Project proponent has negotiated with the landowner at the HWC site and now proposes to shift the San Francisco converter station to the west on the overall HWC property (HWC [Mitigated] site). The potential impacts to historic resources associated with the Project are no longer applicable. Because the proposed project would cause no significant adverse change to historical resources, there would be no significant cumulative adverse change to these resources. Additionally, the potential for cumulative impacts with other projects such as the Carquinez Bridge Replacement Project (I-80) are not applicable.

10-57

The text in Section 9.2 of the Draft EIR has been clarified with respect to potential Project impacts to the larger historic context of the Potrero area in San Francisco. Please refer to new Section 13.0 of the Final EIR for the applicable text revision. Please refer also to Responses 10-44 and 10-50.

10-58

Comments noted. The proposed and alternative San Francisco converter station sites are located within the M-2 zoning district, and the converter station is consistent with uses permitted within that zoning district. Section 4.8.1.1.4 of the Draft EIR acknowledges that the housing deficit in the City of San Francisco has led to increased development pressure in traditionally industrial sectors, including the Central Waterfront District. As discussed in Sections 4.8.2.3.4 and 7.2.3.4 of the Draft EIR, the City and County of San Francisco has released the Draft Central Waterfront Neighborhood Plan, which acknowledges this increased development pressure and sets several goals to maintain the established mixed-use character of the District. The Draft Plan proposes to rezone large areas of the Central Waterfront District as production, distribution and repair (PDR). The PDR district would be designed to protect existing activities and encourage new PDR activities. The proposed and alternative San Francisco converter station sites are all located on areas proposed to be re-zoned PDR. The converter station would be consistent with uses allowed within the PDR district. The PDR district would not allow the wide range of activities in the current M-2 district and would prohibit new housing. Thus, while it is acknowledged that residential and mixed uses are increasing in the area, including the Mission Bay and Hunters Point redevelopment projects, rezoning proposed in the Draft Plan establishes the protection of PDR activities and specifically prohibits residential uses to limit further encroachment on PDR uses. Please refer to Section 4.A.8 of the Final EIR for more information.

10-59

Comments noted. As noted in Response 4-1, the Project proponent has negotiated with the landowner at the HWC site and now proposes as a mitigating alternative to construct the San Francisco Converter Station on the western portion of the overall HWC property ("HWC [Mitigated] site"), thereby completely avoiding this potential impact to public access to the Bay. Therefore, no mitigation is warranted.

10-60

This comment is in error. Potential Impact PS-4, Water Service, and the associated Mitigation Measure PS-4, is included in Table 1-1 of the Draft EIR on p. 1-49. It should be noted that this potential impact applies to the Pittsburg Standard Oil and Pittsburg Mirant sites. The Standard Oil site has been removed from further consideration. This potential impact does not apply to the either of the Pittsburg West Tenth Street sites, or to any San Francisco sites.

10-61

Comments noted. The Draft EIR is correct as written. The proposed Project does not include specific planting or architectural design plans for the sites under consideration in San Francisco. However, the City of Pittsburg as CEQA Lead Agency and the Project proponent fully understand that landscaping and architectural design for converter station facilities in San Francisco (and Pittsburg) will be required, thus Mitigation Measures VIS-1, VIS-2, and VIS-3 shall be required of the Project proponent as clearly presented in the Draft EIR. The plan requirements for building materials and colors, lighting, and landscaping for the selected site in San Francisco will be prepared and approved in coordination with the City and County of San Francisco as stated in the mitigation measures.

10-62

Comments noted. As discussed in Section 4.4.3.4.1 of the Draft EIR, material that would be dredged in New York Slough associated with the Standard Oil site was expected to be acceptable for replacement in the dredged area following cable installation. This preliminary conclusion was based on site-specific sediment sampling that was performed (refer to Section 4.4 and Appendix E of the Draft EIR). However, the Standard Oil site has been withdrawn from further consideration and since dredging was only associated with the submarine cable installation for this site, dredging issues in New York Slough are no longer applicable to the Project.

10-63

Comments noted. The results of the Phase I and II investigations for the now-proposed HWC (Mitigated) site are presented in Section 4.A.14 of the Final EIR. Section 4.A.14 also addresses remediation and associated issues for the HWC (Mitigated) site.

10-64

TBC is no longer considering the Standard Oil site as either the primary or an alternative site for the Pittsburg converter station. Therefore, no Phase II investigation is needed for this site. The now-preferred Pittsburg converter station site is the West Tenth Street Alternative 1 (East/West configuration) site. A Phase II Soil and Groundwater Investigation has been conducted for this site, and the results are discussed in the Draft EIR.

11-1

The City of Pittsburg as CEQA Lead Agency appreciates the California Public Utilities Commission review of the Draft EIR for the proposed TBC Project, including the concern expressed regarding potential Project-related effects on the BART tube where the proposed submarine cable would cross. Please refer to Responses 5-1 through 5-5 that address BART's comments on the Draft EIR.

11-2

The alternatives analysis presented in Draft EIR Section A.8 does consider the possibility of laying a submarine cable between Oakland and San Francisco under the Moraga-Potrero 230 kV AC/HVDC alternative (refer to Section A.8.3.5.5 of the Draft EIR), and the Moraga-Embarcadero 230 kV AC alternative (Section A.8.3.5.6 of the Draft EIR). Both of these alternatives, and variations thereof, would require use of a combination of utility, BART, and/or highway corridors, including the possibility of crossing the Bay from Oakland to San Francisco by laying a submarine cable. None of the alternatives considered, with the exception of the proposed TBC Project, is considered capable of meeting all of the screening criteria presented in Draft EIR Section A.8.3.

12-1

Comments noted. Section 4.4 of the Draft EIR addresses potential water quality impacts associated with sediment disturbance in the Bay and surface runoff associated with construction activities. In summary, no unavoidable adverse significant water quality effects have been identified associated with implementation of the proposed Project.

12-2

Comment noted. Dioxin has been measured in effluent and treatment plant discharges to the Bay. The TBC Project does not include discharge of effluent or treated water to the Bay. Section CWA 303(d) of the federal Clean Water Act requires states to identify waters that do not meet applicable water quality standards. The California 303(d) list identifies impaired water bodies and pollutants for which the State water board is in the process of developing allowable total maximum daily loads. San Francisco Bay is listed for a number of pollutants including mercury and PCBs. The sediment survey presented in Appendix E of the Draft EIR did not encounter any sediment contamination along the cable alignment and the shore-term construction activities are not expected to contribute to the daily load of identified pollutants.

12-3

Comment noted. The sediment survey presented in Appendix E of the Draft EIR did not encounter any contamination, including mercury, along the cable alignment at concentrations greater than ambient Bay concentrations or generally accepted benchmarks. Methyl mercury would be identified as a potential concern if shallow sediments exhibiting elevated total mercury concentrations above the NOAA effects range medium benchmark of 710 µg/kg were encountered. These concentration levels were not detected. The majority of the cable alignment is in deep water near the center of the Bay that has lower mercury levels than concentrations measured in shallow water in the south Bay and San Pablo Bay.

12-4

Comments noted. Please note that the Standard Oil site and ancillary facilities has been withdrawn from further consideration as noted in the Final EIR and previous comment responses. Therefore, the Project no longer has the potential to impact Kirker Creek. Regarding the Project's potential to result in exceedance of water quality standards, NOAA sediment benchmarks and RWQCB ambient sediment concentrations are accepted criteria used in human health and sediment ecological risk analyses for characterization of sediments in San Francisco Bay.

12-5

Comment noted. The volume of dispersed sediment along the cable alignment is between 117 and 235 cubic yards per mile assuming the full 6-ft burial depth. The total volume of dispersed sediment along the 53-mile alignment is between 6,220 and 12,440 cubic yards. The Dredged Material Management Office (DMMO) guidelines for implementing the USACE Inland Testing Manual indicate that for dredged volumes of between 5,000 and 20,000 cubic yards, 1 composite sample from 4 sample locations is required for testing. Therefore, 27 samples tested for the project from 27 locations far exceeds the requirements of the regulatory dredging agencies.

12-6

Comment noted. The use of HDD at the shoreline crossing near the Potrero substation would allow the cable to enter the Bay at a depth of approximately 30-35 feet below MLLW offshore of known shoreline contamination. The HDD technique consisting of bore-and-core combined with containment at the offshore end of the boring has been proposed to contain drilling mud and cuttings, as well as the introduction of any shoreline contaminants into the Bay. Please see Response to 12-5.

13-1

Comments noted. This letter dates from late 2004 and, as such, is not specific to the accuracy or content of the Draft EIR for the Trans Bay Cable Project which was issued on May 10, 2006. None the less, the City of Pittsburg as CEQA Lead Agency appreciates the San Francisco Baykeeper's interest in the Project and has responded to the issues raised in the December 16, 2004 letter.

13-2

Comment noted. Please see Responses10-9 and 10-12. Sediment toxic hot spots are typically associated with historic manufacturing and town gas operations located along the Bay shoreline. It is true that at some toxic hot spots, contamination increases with depth. However, in deep, open water there is no evidence of contamination from toxic hot spots or evidence that contamination increases with depth. The majority of the cable alignment is in deep water near the center of the Bay. The use of HDD at the shoreline crossing near the Potrero Power Plant would allow the cable to enter the Bay at a depth of approximately 25 feet below MLLW offshore of known shoreline contamination. The HDD technique being proposed consisting of bore-and-core combined with containment at the offshore end of the boring has been proposed to ensure that drilling mud and any shoreline contaminants are not introduced to the Bay.

13-3

Comment noted. Please refer to Responses 10-9 and 10-12.

13-4

Comment noted. Please refer to Responses 10-9 and 10-12.

13-5

Comment noted. Please refer to Responses 10-10 and 10-12.

13-6

Comment noted. Please refer to Response 10-10.

13-7

Comment noted. Please refer to Responses 10-9, 10-12, and 12-5.

13-8

Comment noted. Please refer to Responses 10-10 and 10-12.

13-9

Comment noted. Please refer to Responses 10-9 and 10-12.

13-10

Comment noted. Please see Responses 10-9 and 10-12. There is no evidence of contamination in sediments along the cable alignment and, therefore, there is no reason to expect that fish could become contaminated by exposure to dispersed sediments. Long-term exposure to contamination is required before fish show elevated tissue concentrations. As indicated in Response 10-12, the volume of sediment being dispersed is extremely small particularly compared to typical dredging projects and the sediment would be dispersed at a very slow rate. It is not credible to hypothesize a fish would preferentially remain in the disturbed area of the sediment plume over the course of the cable installation.

13-11

Comment noted. Please see Response 12-5.

13-12

Comment noted. Please see Response 12-5.

13-13

Comment noted. Please see Response 12-5.

13-14

Comment noted. Please see Responses 10-12 and 12-5.

13-15

Comment noted. Please see Responses 10-12 and 12-5

13-16

Please refer to Section A.8.3 of the Draft EIR which analyzes numerous alternatives to the proposed Trans Bay Cable Project, including its proposed submarine cable component. None of the alternatives is considered to be feasible and capable of meeting the stated Project objectives.

13-17

Comment noted. Please see Responses 10-9 and 10-12.

13-18

Comment noted. Various sections of the Draft EIR describe the benthic communities and potential impacts to these communities. For example, Draft EIR Sections 4.6.3.2.5 and 4.6.3.2.6 address potential impacts to the benthos with regard to cable installation. Sections 4.6.3.3.1 and 4.6.3.3.2 include discussions of potential impacts to the benthos from operation of the cable and provide references to studies of impacts to benthic communities conducted on similar cable undersea projects.

Comment Number

Response

14-1

Comments noted. The City of Pittsburg as CEQA Lead Agency appreciates the City of Antioch's review of the Draft EIR for the proposed TBC Project and concurs with the City of Antioch's comment. The Project proponent has made a decision to withdraw the previously-proposed Standard Oil site, including ancillary facilities, from further consideration thus the City of Antioch's concerns have been addressed. Refer to Sections 1.0 and 3.0 of the Final EIR for further information.

14-2

Please refer to Response 14-1.

14-3

Comments noted. Please refer to Response 14-1.

15-1

The City of Pittsburg as CEQA Lead Agency appreciates your review on behalf of the Dogpatch Neighborhood Association of the Draft EIR for the TBC Project, including the assessment of potential cultural resource impacts related to historic resources in San Francisco. The previous testimony before the CEC was reviewed and cited in the Draft EIR (Section 4.7.1.2.1) and in the technical report for historical resources (Draft EIR Appendix G). Furthermore, the Project proponent has negotiated with the landowner at the HWC site and now proposes to shift the San Francisco converter station to the west on the overall HWC property (HWC [Mitigated] site). HWC (Mitigated) avoids all direct and indirect impacts to the historic buildings on the HWC site, the adjacent Mirant property (i.e., Station A Complex), and to potential historic districts. Please refer to Responses 3-7 and 10-44 for more information.

15-2

Please refer to Response 15-1.

15-3

Comment noted. As stated in the prelude (Historical Architectural Resources) to Mitigation Measure(s) CUL-2 (Disturbance of Historical Architectural Resources) of the Draft EIR, these measures apply to construction of the previously proposed San Francisco HWC Converter Station which would involve demolition of historical resources. It should be noted that, partly in response to comments received regarding potential historic resources impacts associated with development of the Project on the HWC site, the Project proponent has negotiated with the landowner at the HWC site and now proposes to shift the San Francisco converter station to the west on the overall HWC property (HWC [Mitigated] site), thereby completely avoiding direct impacts to the two historic buildings on the eastern portion of the HWC property. Another advantage of the HWC (Mitigated) site is that it allows the proposed 115 kV interconnection to the PG&E Potrero substation to be installed without impacting the Station A Complex on the adjacent Mirant Potrero property. This action would not directly or indirectly impact the potential historic district(s) located north of the HWC site. Refer to Section 4.A.7 of the Final EIR for more information. The mitigation measures presented in the Final EIR that would be undertaken to address this shift of the proposed project have been expanded and clarified. The Draft EIR presents four mitigation measures (i.e., Mitigation Measure CUL-2a, Recording Architectural Resources; CUL-2b, Architectural Resource Interpretive Display and/or Interpretive Material; and CUL-2c, and Architectural Resource Salvage Opportunities. The Final EIR presents an additional mitigation measure, CUL-2d, Central Waterfront Historic Preservation. Refer to Final EIR Section 13.0 for more information.

15-4

Comments noted. Please refer to Draft EIR Section 4.8.2.3.4 (Central Waterfront Neighborhood Plan [Draft] and Final EIR Section 4.A.8) for information regarding the pending zoning and planning code controls that encompass the Project area in San Francisco.

16-1

Comments noted. The City of Pittsburg as CEQA lead Agency appreciates Mirant's review of the Draft EIR for the proposed TBC Project.

16-2

Comments noted. An exhaustive underground survey was conducted to locate existing underground utilities in the area. All utilities in the area of concern have been mapped. Installation of the cable in these areas will be performed based on this information, using a combination of equipment and hand excavation to locate and protect existing utilities during construction.

16-3

Comments noted. The proposed 115 kV AC cable would be placed underground between the converter station site and the PG&E Potrero Substation. The proposed cable route does not interfere with either the San Francisco Mirant 115 kV overhead transmission line or transmission towers.

16-4

Comment noted. The Project proponent is aware that Mirant Alternative 1 would require removal and relocation of a water tank on Mirant's property at the Project proponent's expense.

16-5

Comment noted. In the event the alternative Mirant 3 layout was selected for implementation, the Project proponent would coordinate with Mirant to relocate the affected portion of Humboldt Street at TBC's expense.

16-6

Comments noted. The Project proponent has withdrawn the Standard Oil site and ancillary facilities from further consideration and, thus, the Project no longer includes a dredging component near Mirant's once through cooling water intake facilities in Pittsburg. No adverse Project-related impacts on Mirant's cooling water intake facilities are anticipated.

16-7

Comment noted. None of the proposed or alternative Project components would directly impact Willow Creek on Mirant's Pittsburg property. The proposed AC and DC cable routes (refer to Figure A.8-20 in the Draft EIR and Figure 3-11 in this Final EIR) stay at least 200 feet or more to the east of Willow Creek. The proposed cables would be installed in underground conduit via trenching in the gravel shoulder of the existing Mirant Pittsburg facility access road which is paved. Mitigation Measures WATER-1 (Erosion Control and Contaminant Source Control) and WATER-2 (Spill Prevention and Control Plan for HDD) would minimize or avoid any potential for construction-related impacts to Willow Creek.

16-8

Comments noted. In response to this comment, Mr. Ronald Kino (Mirant Environmental Specialist) was contacted by the EIR preparers on August 23 and 24, 2006. Mr. Kino concurred with URS Biologist Bill Martin's assessment from the site reconnaissance meeting at Mirant's Pittsburg facility in April of 2004 that the site is composed of heavily disturbed industrial landscape lacking native plant communities/habitats. The offshore cable route comes onshore via HDD under rock rip-rap and continues in unvegetated, heavily disturbed landscapes. Additionally, the proposed temporary construction laydown areas and the alternative converter station sites on the Mirant Pittsburg property are also located on unvegetated, heavily disturbed landscapes. Based on the California Natural Diversity Database (CNDDB) mapped occurrences, Bill Martin's field assessment, and the input from Mr. Kino, the potential for impact to sensitive terrestrial biological resources from the proposed onshore cable routes, laydown areas, and or the alternative converter station areas on Mirant's Pittsburg property is low to non-existent since no sensitive resources are present in the potentially affected Project areas.

16-9

Comments noted. The Standard Oil site, including laydown areas has been removed from further consideration, thus potential impacts to salt marsh harvest mouse are no longer applicable for the Standard Oil site laydown areas referenced in this comment. As discussed in Response 16-8, the EIR preparers contacted Mirant Environmental Specialist Ronald Kino on August 23 and 24, 2006. Mr. Kino confirmed that there is "no pickleweed on the Mirant property". Pickleweed marsh habitats occur considerably further west of the Mirant property. Based on the lack of habitat known to support the species on the Mirant Pittsburg property, including the portion where proposed or alternative Trans Bay Cable Project facilities would be located (i.e., saltmarsh or pickleweed marsh, sometimes with adjacent upland vegetated grasslands), it is unlikely this species occurs on the Mirant Pittsburg property. Therefore, no Project-related impacts to salt marsh harvest mouse would be likely to occur.

16-10

See Response 10-33 related to delta smelt. As described in the Draft EIR, work is planned to be conducted during the environmental work windows for a number of listed (e.g., Chinook salmon, steelhead) or commercially important species (e.g., Pacific herring). NOAA Fisheries issued a Final Rule to list the southern distinct population segment (DPS) of green sturgeon as threatened on April 7, 2006, after the biology section of the Draft EIR was prepared and the document was in production. This final rule became effective on June 6, 2006, after the Draft EIR was published. The Final EIR text has been updated to include Section 4.6.1.3.4 describing green sturgeon. Please refer to the new Section 13.0 of the Final EIR for the applicable text revision.

16-11

See Response 16-10 regarding the listing status of green sturgeon. The Final EIR text has been updated to include Section 4.6.1.3.4 describing this species. Please refer to the new Section 13.0 of the Final EIR for applicable text revision. Green sturgeon (and other listed fish species) were not addressed separately in the impacts section of the Draft EIR. As discussed in Draft EIR Section 4.4 (Water Quality), the cable-laying operation would result in a very localized sediment plume that is not expected to significantly impact water quality. Installation of the cable could potentially suspend approximately 6,220 to 12,440 cubic yards of sediment over the entire 53-mile project area. This would amount to about 117 to 235 cubic yards of suspended material per mile. This amount of suspended material is small compared with the volume of sediment resuspended in the Bay by the tides or wind. Fish species inhabiting the Bay and estuarine species such as delta smelt are well adapted to the natural condition of relatively high turbidity. It is expected that green sturgeon would react to the temporary disturbance of the cable-laying operation similarly to other mobile fish species as described in Section 4.6.3.2.4 in the Draft EIR, that is, they would tend to exhibit behavioral avoidance of the immediate area of temporarily increased turbidity and activity during the cable-laying operation.

Comment Number

Response

17-1

The City of Pittsburg as CEQA Lead Agency appreciates Miller, Starr & Regalia's review of the Draft EIR for the proposed Project. Based on the impact assessments presented in the Draft EIR and the comments received on the Draft EIR, the City of Pittsburg and the Project proponent agree with the commentor's preference for the Pittsburg West Tenth Street Alternative 1 as the environmentally preferred converter station location in Pittsburg. As noted in the Final EIR and previous responses to comments on the Draft EIR, the previously-proposed Standard Oil site and ancillary facilities has been withdrawn from further consideration.

17-2

Comments noted. Please refer to Response 17-1.

18-1

The City of Pittsburg as CEQA Lead Agency appreciates Chevron Shipping Co. LLC's review of the Draft EIR for the proposed Project. Before and during installation of the submarine cable, the precise location of the vessels engaged in cable-laying operations would be reported to the U.S. Coast Guard for dissemination via the local Notices to Mariners. The as-built location of the cable would be documented and reported to the USACE and NOAA for addition to navigation charts for San Francisco Bay. As requested, Mitigation Measure MTRANS-1d has been added to Section 4.9.3.2.1. Please refer to the Table 1-1 and Section 13.0 of the Final EIR for appropriate text revision.

18-2

Comments noted. The Project proponent/construction contractor would fulfill its statutory obligation to inform other vessel traffic of short-term submarine cable laying activities associated with the proposed TBC Project before and during installation of the cable. The Project proponent/construction contractor would maintain contact with the U.S. Coast Guard Vessel Traffic Service (VTS) San Francisco Bay, and would provide accurate information to the Commandant, Coast Guard District 11, Waterways Management Branch for inclusion in local Notices to Mariners regarding the location and potential hazards posed by construction vessel traffic. It should be noted that the proposed submarine cable route avoids potential conflicts with established U.S. Coast Guard navigation channels to the maximum extent possible, and that the proposed limited crossings of the established navigation channels are not in areas that would be expected to affect Chevron Shipping Company's operations. The Project proponent would coordinate with the U.S. Coast Guard and other interested parties, including Chevron Shipping Co., LLC, prior to the initiation of submarine construction activities and during the submarine installation activities to coordinate activities and avoid potential conflicts with marine vessel traffic.

19-1

Comments noted. The City of Pittsburg as CEQA Lead Agency appreciates BCDC's review of the Draft EIR for the proposed Trans Bay Cable Project and recognizes BCDC's role in protecting the Bay.

19-2

Comments noted. Based on the physical location of the proposed and alternative Trans Bay Cable Project components, the City of Pittsburg understands that the converter station and ancillary facilities in Pittsburg/Contra Costa County are all located east of BCDC's jurisdiction. In addition, the Project proponent has negotiated with the landowner at the HWC site and now proposes to shift the San Francisco converter station to the west on the overall HWC property (HWC site [mitigated]) (refer to Section 4.A of the Final EIR). Accordingly, all of the converter station sites in San Francisco and associated 115 kV AC interconnections to the existing PG&E Potrero substation are outside of BCDC's jurisdiction since their easternmost boundaries are more than 100 feet inland from the western shore of the Bay as it existed on September 17, 1965. The proposed submarine cable (approximately mileposts 0.0 – 49.5; refer to Map A.2-1 in Section 3.0 of the Final EIR), including onshore portions in San Francisco within 100 feet of the Bay shoreline as well as portions of the temporary construction laydown areas in San Francisco are within BCDC's jurisdiction.

19-3

Comments noted. Please refer to Response 19-2.

19-4

Comments noted. Based on the distance of proposed submarine cable within BCDC's jurisdiction (i.e., approximately 49.5 miles) and the approximate diameter of the cable (i.e., 10 inches), an estimated 5,277 cubic yards of buried submarine cable would be installed in BCDC's jurisdiction or about 107 cubic yards per mile. In addition, a currently unquantified amount of protective mattresses would be required (e.g., at shallow utility crossings and possible need to install insulation at BART tube crossing, etc.). The results of the forthcoming geophysical survey will help clarify the actual amount of fill that would be associated with the Project.

19-5

Comments noted. As discussed in Section A.8.3 in Appendix A of the Draft EIR, multiple land-based alternatives for meeting the Project need and objectives were examined. These include alternatives previously considered by the SFSSG, the CAISO, the CEC, and PG&E. In addition to apparent insurmountable obstacles in getting a land-based transmission line from Contra Costa County to San Francisco, including the portion up to the East Bay shoreline, there are no identified feasible ways to get across the Bay to San Francisco without installing a submarine cable in the Bay. Caltrans does not allow longitudinal encroachments in their rights of way and has specifically stated that the cable can not be installed on its bridges. Similarly, it is not feasible to install the cable in BART's trans Bay tube due to space limitations, structural design limitations, construction window constraints, and safety concerns. The CAISO and CEC recognize the need for the proposed Trans Bay Cable Project as demonstrated by the CAISO's approval of the Project on September 8, 2005 and the CEC's analysis of alternatives and selection and support for the Project in their 2005 Strategic Transmission Investment Plan. Please refer to Responses 3‑1 and 3-6, Section 13.0, and Appendix C of the Final EIR for documentation of these facts.

19-6

The SLC and the Port of San Francisco own the Bay property where the DC cable would be installed. TBC is in the process of negotiating a long-term lease agreement, with both parties, to acquire the legal rights to install the cable. Upon execution of both lease agreements, a copy will be made available upon request.

19-7

Comments noted. A text revision has been be made to include Section 4.6.2.2.2 San Francisco Bay Plan. Please refer to the new Section 13.0 of the Final EIR for the applicable text revision. Also refer to Draft EIR Section 4.8.2.3.6 (San Francisco Bay Plan) for information regarding the San Francisco Bay Plan and BCDC's jurisdiction and responsibilities, including those related to protection of resources. In general, the proposed Trans Bay Cable submarine route is located in deeper water and avoids tidal flats, mudflats, and intertidal areas. In addition, the proposed cable installation method using a Hydroplow is minimally invasive and designed to limit disturbance of Bay floor habitat and limit sediment disturbance/suspension. In addition to minimal construction impacts, no adverse long-term impacts during the operational phase of the Project would be expected to occur.

19-8

Comment noted. Please see Responses 6-6, 10-12, and 10-32.

19-9

Comments noted. The locations and extent of hard bottom, rocky locations, if any, along the proposed Trans Bay Cable submarine route are currently not known but are expected to be minimal or non-existent based on available data. Protective mattresses may be required to be placed over the cable in rocky areas, as applicable, and in areas of shallow utility crossings, as applicable. The forthcoming geophysical survey will identify any such areas/needs. Although the geophysical survey has not yet been conducted, a Project-specific environmental sediment quality sampling survey was conducted in 2005 along portions of the proposed submarine cable route (refer to Figure 4.4-2, Sediment Sample Locations, of the Draft EIR). No rocky bottom areas were encountered during this survey (refer to the boring logs in Appendix E, Sediment Characterization Report of the Draft EIR for more information). It is not expected that much, if any, of the proposed cable route will encounter rocky substrate, with the possible exception of the area east of Angel Island and the Tiburon Peninsula (refer to Map A.2-1, Sheets 2 of 10 and 3 of 10 in Section 3.0 of the Final EIR; approximate DC cable mileposts 7.0 to 11.5). The sediment sampling program performed for the Trans Bay Cable Project included a sample (identified as SFB-3 on Draft EIR Figure 4.4-2 and the boring logs in Draft EIR Appendix E) along the proposed cable route at approximately milepost 11 east of the Tiburon Peninsula. No rocky substrate was encountered to a depth of 6 feet at this location. It is expected that little, if any, rocky substrate is present along the proposed cable route and that the potential need for, and use of, protective mattresses relative to this condition would be minimal or non-existent. The forthcoming geophysical survey will clarify this issue. Once the geophysical survey results are available, the Project proponent will evaluate the need for protective mattresses, evaluate the associated volume of fill, and include this estimate in the permit application to be submitted to BCDC for the Project. The volume of concrete mattresses is currently expected to be minimal and the long-term impacts to marine organisms associated with replacement of limited, if any, natural hard bottom with artificial (i.e., concrete) hard bottom would be expected to be minimal since the substrates are both conducive to organisms with an affinity for hard bottom substrate.

19-10

Comments noted. The currently proposed directional drilling locations (i.e., bore pits) are shown on Figures 3-15 and 3-8 in the Final EIR for Pittsburg and San Francisco, respectively. The noise levels from horizontal directional drilling are much lower than pile driving and, as shown on the referenced figures, the directional drilling locations for the HVDC cable are further away from potentially sensitive receptors (i.e., residences) than the pile driving that would occur at the converter stations. Because the general construction and pile driving (with the exception of the West Tenth Street Alternative 2) noise levels were determined in the Draft EIR to be less than significant, the noise and vibration impacts from directional drilling would also be less than significant.

The HDD drilling operation would be performed from both the landside and from a barge on the waterside. A diesel engine would be used to power the drill. This engine would be similar to the engines used in trucks that are in the area every day carrying freight.

19-11

As discussed in the Draft EIR (Section 4.6.3.2), installation would be conducted within Environmental Work Windows outlined in the Long Term Management Strategy (LTMS) for bay dredging and disposal, recognized by agencies such as NOAA Fisheries. The work windows would provide for protection of listed salmonids and a number of other species such as Pacific herring and Dungeness crab. Other listed species include delta smelt and the green sturgeon. These are year-round residents and no work windows exist. For these species, consultation with USFWS (delta smelt) and NOAA Fisheries (green sturgeon) will be required. As discussed in the EIR and in response to other public comments (for example, see Responses 10-33 and 16-11), it is expected that the cable installation would not significantly affect these species, if present.

19-12

Comments noted. The proposed Trans Bay Cable would be heavily armored and expected to be buried at a typical target depth of 3 to 6 feet. In the unlikely event of damage to the cable, the electrical current would be automatically shutoff within milliseconds with no anticipated environmental impacts with the exception of a temporary loss of a portion of the power supply in the San Francisco area. There are no planned, regular maintenance activities associated with the proposed submarine cable, and thus, no associated potential environmental impacts. In the unlikely event that the cable was damaged at some location, it would be necessary to excavate the damaged portion and repair the damaged portion via a splice which would occur on a surface vessel. Once the splice was completed, the cable would be reburied and/or covered with protective mattresses on the Bay floor at approximately the same location as the original installation. The potentially affected area would be minimal and disturbance to habitat would be temporary and similar to the original installation. No significant impacts would be expected to occur.

19-13

The anticipated cable life is at least 40 years based on the Project proponent's experience on similar projects. If future conditions warranted extending the life of the Project beyond 40 years, refurbishment of the converter stations in Pittsburg and San Francisco would be more likely than a need to refurbish and/or replace the submarine cable. In the event that the cable needed to be replaced, the Project owner would likely need to reapply to applicable regulatory authorities at that time to install a new cable in the Bay (i.e., not likely possible to refurbish a 40-year-old cable if in fact it had deteriorated or had been severely damaged over time). Since the cable is proposed to be buried at a typical depth of 3 to 6 feet, the Project proponent proposes to not remove the cable in the Bay upon decommissioning of the Project in order to avoid additional disturbance to the Bay floor and associated biological communities, and potentially affected adjacent buried utilities.

19-14

Comments noted. As assessed and discussed in the Draft EIR, the proposed Trans Bay Cable Project has been designed to have minimal impacts on the Bay and is not expected to result in any potentially significant impacts to the Bay.

19-15

Comments noted. The Project proponent has withdrawn the previously proposed Standard Oil site, including ancillary facilities, from further consideration. The need for dredging at two locations in New York Slough was only associated with the Standard Oil site, Therefore, potential impacts associated with dredging and dredge spoil disposal in New York Slough are no longer applicable to the proposed Trans Bay Cable Project.

19-16

Comment noted. While the BCDC is in fact a state agency, in relation to the TBC Project, BCDC addresses the Bay Area "region" and, therefore, is discussed in terms of the Project's local area.

19-17

Comment noted. The text in Section 4.4.3.4.1 of the Draft EIR has been revised in response to this comment. Please refer to new Section 13.0 of the Final EIR for applicable text revisions.

19-18

Comment noted. The Project proponent consulted with the SLC (among others such as Hanson Permanente Cement Company) during the cable routing process and made sure that the proposed cable route avoids all sand mining areas/leases (refer to EIR Map A.2-1). The proposed Project is not expected to have any impact on designated sand mining operations in Suisun Bay or elsewhere.

19-19

Comments noted. The Project proponent has consulted with the Regional Water Quality Control Board (RWQCB) to discuss the Project details and the RWQCB's potential concerns regarding the Project. The RWQCB has commented on the Draft EIR as well. Please refer to the responses to the comments in the RWQCB comment letter (Comment Letter 25).

19-20

Comments noted. The Suisun Marsh Protection Plan is discussed in Draft EIR Sections 4.8.2.3.7 and 4.8.3.4.2. As discussed in Draft EIR Section 4.6 (Marine Biological Resources), installation of the proposed submarine cable in the Bay and connecting waterways such as Suisun Bay using the minimally invasive Hydroplow would not result in any identified potentially significant impacts.

19-21

Comments noted. The proposed submarine cable route is shown on Map A.2-1 and the portion within Suisun Bay is shown on Sheets 8 of 10 and 9 of 10. The mapped location of the proposed cable route may be modified slightly based on the results of the forthcoming geophysical survey. Any proposed future deviations from the currently mapped location would be developed in consultation with pertinent regulatory agencies, including BCDC. Installation of the submarine cable in Suisun Bay using the minimally invasive Hydroplow is not expected to result in any potentially significant impacts to wetlands or marsh habitat. The trench width associated with the Hydroplow operation is expected to be only slightly wider (e.g., 4 to 6 inches on average) than the cable bundle width of approximately 10 inches. Cable installation in Suisun Bay is planned to occur during a portion of the NOAA recommended fish window of June 1 through November 30 for anadramous fish. The proposed Project no longer includes dredging of or spoil disposal from New York Slough east of Suisun Bay.

19-22

Comments noted. Please refer to Response 19-2 regarding the relationship of the proposed Project components, including those in San Francisco, to BCDC's jurisdiction. Since the HWC site as analyzed in the Draft EIR has been withdrawn from further consideration and shifted to the west, potential Project conflicts with public access along the Bay in San Francisco are no longer applicable.

19-23

Comments noted. As discussed in previous comment responses, the Project proponent has negotiated with the landowner at the HWC site and now proposes to shift the San Francisco converter station to the west (HWC [Mitigated] site) on the overall HWC property in San Francisco. The closest roads to the HWC (Mitigated) site that are accessible to the public are Illinois Street to the west, 23^rd Street to the north, and 24^th Street to the south. Please refer to Section 4.A.13 (Visual Resources) of the Final EIR for the visual impact assessment for the HWC (Mitigated) site. The new location of the HWC (Mitigated) site will remove the visual mass of the Converter Station on the north side of Warm Water Cove Park and places the DC Hall further from the water, where it will have less visual impact than the former location. In summary, no unavoidable adverse significant visual impacts, including those to views of the Bay or from Warm Water Cove Park, are associated with the HWC (Mitigated) site.

19-24

Comments noted. The Project proponent has negotiated with the landowner at the HWC property and now proposes to shift the San Francisco converter station site to the west on the overall HWC property (HWC [Mitigated] site). This shift locates the converter station site further away from the Bay shoreline. As discussed in Draft EIR Section 4.4.3.2.1, surface runoff from the HWC site (applies to entire property) is currently directed to the San Francisco combined stormwater and sanitary sewer system; i.e., site runoff does not flow to the Bay. The HWC site is currently completely covered with buildings and/or pavement, thus it is already impervious. Development of the San Francisco converter station at the HWC (Mitigated) site would not increase surface runoff relative to the currently existing condition. As discussed in Draft EIR Section 4.4.3.2.1, Mitigation Measure WATER-1 (Erosion Control and Contaminant Source Control), including development and implementation of a Stormwater Pollution Prevention Plan in accordance with NPDES requirements, would reduce potential impacts to a less-than-significant level. No further mitigation is warranted.

19-25

Comments noted. The HWC (Mitigated) site is not within BCDC's jurisdiction. Demolition activities and potential site remediation activities for the HWC (Mitigated) site are discussed in Section 4.A.14 of the Final EIR. In summary, no unavoidable site remediation related impacts, including those related to Bay water quality, would be expected to occur.

Comment Number

Response

20-1

The City of Pittsburg as CEQA Lead Agency appreciates the Association of Bay Area Governments' (ABAG's) review of the Draft EIR for the proposed Trans Bay Cable Project. The Project proponent has successfully negotiated with the landowner at the HWC site in San Francisco and shifted the HWC converter station site to the west (HWC [Mitigated] site) as a mitigating action. The HWC (Mitigated) site avoids any impacts on potential future implementation of the San Francisco Bay Trail Plan along the Bay waterfront. Please refer to Section 4.A of the Final EIR for more information.

Comment Number

Response

21-1

See Responses 10-12, 12-6, 13-2, and 13-10.

Installation of the proposed submarine cable would not be expected to result in contamination of fish or other marine organisms, thus no associated human health effects associated with eating organisms from the Bay would occur due to the Trans Bay Cable Project.

22-1

The City of Pittsburg as CEQA Lead Agency appreciates the CCSF review of the Draft EIR for the Trans Bay Cable Project. The City of Pittsburg looks forward to further, ongoing coordination with CCSF representatives regarding this important Project and its objective of helping secure the long-term electrical system reliability in the CCSF.

22-2

Comments noted. The City of Pittsburg respects and acknowledges the CCSF's expertise regarding environmental protection in San Francisco, and its important role in the CEQA review process and subsequent permitting approvals for this Project, as applicable. The San Francisco Stakeholder's Study Group, California Independent System Operator, and California Energy Commission's assessments of the formidable energy supply and reliability issues facing the CCSF area in the future strongly indicate and support the timely implementation of the Trans Bay Cable Project as an integral part of the solution to the issues facing the CCSF area. Please refer to Appendix C of the Draft and Final EIRs for key pertinent CAISO and CEC documents supporting the need and expressing support for the Trans Bay Cable Project. The City of Pittsburg appreciates that based on early City of Pittsburg consultation with the CCSF regarding CEQA compliance and possible CCSF involvement in the Draft EIR preparation process, the CCSF declined to be involved and deferred full responsibility for preparation of the Draft EIR to the City of Pittsburg. The City of Pittsburg appreciates the informal input provided by the CCSF Planning Department to the City of Pittsburg in 2004 following issuance of the Notice of Preparation and the associated scoping phase for the Trans Bay Cable EIR regarding the issues and desired scope of the EIR.

22-3

The City of Pittsburg consulted with the San Francisco Planning Department to confirm land use consistency and the Draft EIR Section 4.8 as well as Final EIR Section 4.A.8 evaluate the Project's consistency with the General Plan. In addition, the City of Pittsburg agrees that an Application for General Plan Referral will be submitted concurrently with other Project applications.

22-4

Comments noted. All of the graphics presented in the Draft EIR are available via the web-based version on the City of Pittsburg's website by going to the applicable table of contents of the Draft EIR on the website and double clicking on the applicable figure number/name. Many of the figures are very large in terms of file size, thus they are only accessible individually versus as a group on the website. In the published hard copy of the Draft EIR, the figures are placed at the end of the individual applicable sections (e.g., Appendix A). This convention also facilitates efficient downloading of text and figures from the web-based version by individuals/computers with various memory and download capabilities, as available to the wide range of potential EIR reviewers. The City of Pittsburg as CEQA Lead Agency ensured that the Draft EIR information on the City's website is as accurate and up to-date as possible; any discrepancies with the Project proponent's website are beyond the City's control and are likely related to the frequency with which the Project proponent updates its website information. Please refer to the City of Pittsburg's website and/or a hard copy or CD version of the Draft EIR for accurate representations of the proposed and alternative project component locations as germane to the assessment in the Draft EIR.

22-5

Comments noted. The City of Pittsburg recognizes that the Draft Central Waterfront Neighborhood Plan proposes to re-zone the area west of Illinois Street from current M-2 to mixed use residential. Draft EIR Sections 4.8.2.3.3 (Central Waterfront Area Plan), 4.8.2.3.4 (Central Waterfront Neighborhood Plan [Draft]), and 4.8.3.2.2 indicate and conclude that the proposed Project is consistent with both existing and proposed land use plans and zoning in San Francisco, including the production, distribution, and repair (PDR) district and mixed use residential shown on the Draft Plan.

Upon adoption of this Draft Plan, possible future residences could be located 445 feet west of the Mirant sites (Alternatives 1 and 2) and directly across Illinois Street (approximately 80 feet) from the HWC (Mitigated) site. Given the status of the proposed land use changes in the area, construction of the proposed Project would likely occur prior to the residential development in this area. Thus, the construction phase of the proposed Project would not impact the future residences directly across Illinois Street.

Calculations were performed using linear octave band sound power levels as inputs from each noise source for the proposed and converter stations using the same equipment as the once-proposed HWC Converter Station. As discussed in the Draft and Final EIRs, calculated sound levels for the Mirant L-configuration at the west property line would be 63 A-weighted sound level (dBA) equivalent sound level (Leq), 71 dBA Leq for the Mirant rectangular configuration, and 63 dBA Leq for the HWC (Mitigated) site. Based on direct line-of-sight distance, the estimated sound levels from the converter stations at the future residences would be approximately 51 dBA Leq from the Mirant L-configuration, 58 dBA Leq from the Mirant rectangular configuration, and 61 dBA Leq from the HWC (Mitigated) site.

Based on the San Francisco Noise Ordinance, the noise limits for fixed sources (such as the converter stations) at the property lines of residential/commercial land uses depend on the zoning of the property, as shown in Table 4.11-4 in Section 4.11.2.3.1 of the Draft EIR. Because the potential future development would be mixed use, it is assumed that the property would not be zoned R-1 or R-2; thus, the nighttime limits at the possible future development would be 55 or 60 dBA. In addition, the Noise Ordinance requires that interior noise levels in the sleeping/living rooms not exceed 45 dBA in the nighttime hours. Therefore, the estimated direct line-of-sight calculated sound levels would exceed the nighttime limits at the future development for the Mirant rectangular site and the HWC (Mitigated) site. However, based on the San Francisco Transportation Element of the General Plan and the California Code of Regulations, Title 24: Noise Insulation Standards, future residential structures require an acoustical analysis for multifamily dwellings in an area exceeding 60 dBA CNEL. As stated in Policy 10.2 of the San Francisco Transportation Element, "builders should be encouraged to take into account prevailing noise levels and to include noise insulation materials as needed to provide adequate installation." The Element also recommends using building setbacks, buildings sited with their narrower dimensions facing the noise sources, and to design the interior layout so that rooms that require quiet (i.e., bedrooms) are away from the noise source. Therefore, future development would need to take into account the existing noise sources, including the converter station, in their design to be submitted to the City's Building Inspection Department to be in compliance with both local and state regulations regarding new residential developments.

22-6

Comments noted. Please refer to Response 22-5, as well as Sections 4.A.8, 4.A.11, and 4.A.13 of this Final EIR.

Please refer to Response 22-5 for noise-related impacts to future mixed use residential. The Draft Central Waterfront Neighborhood Plan proposes to change land uses to mixed use residential at the northwest and southwest corners of the 23^rd Street and Illinois Street intersection. In the current Draft Plan, residences would be permitted on all stories of buildings. Neighborhood retail, housing compatible with production, distribution and repair uses, and small office uses would be principally permitted uses on the ground floor. Residences are the only uses allowed on the third floor and above.

Landscaping and architectural design features would be added to ensure that the converter station site is more consistent with proposed future mixed uses in the area. However, given the height of future residences (third floors and above), it is likely that residences on the third floor and above would still have views of the converter station site despite installation of visual barriers. However, this impact is not expected to be significant based on the existing industrial land uses that surround the site, including the PG&E substation.

22-7

The City of Pittsburg and the Project proponent fully expect that the CCSF would require building permits from the CCSF, rather than the State Architect.

22-8

Comments noted. CEQA does not include a requirement to address environmental justice issues (i.e., this is typically a National Environmental Policy Act requirement for federal projects). Regardless, the proposed Trans Bay Cable Project would not be expected to result in any significant, unmitigable disproportionate impacts on minority or low income populations in either San Francisco or Pittsburg. It should be noted that based on early consultation in 2004 with senior San Francisco Planning Department officials regarding the scope of the EIR for the Project, City of Pittsburg representatives were told by CCSF that CCSF as a matter of policy does not address environmental justice issues in their EIRs.

22-9

Comments noted. Since this comment provides no specific examples, it is difficult for the City of Pittsburg as CEQA Lead Agency to respond. The mitigation and monitoring measures presented in the Draft and Final EIRs are presented as appropriate to the specific site/project component and relevant potentially significant impact regardless of geographic location or jurisdiction. Without more specific examples, it is not possible to respond further to this comment. The City of Pittsburg as CEQA Lead Agency has the overall responsibility for ensuring that the stated mitigation and monitoring measures are adequate, implemented, and monitored properly. The City of Pittsburg will work together with the CCSF and other responsible agencies to make sure that the appropriate mitigation measures are implemented properly by the appropriate, qualified entity and that the documentation of the mitigation measures effectiveness and/or remedial action needed is properly recorded, reported, and/or implemented. To the extent that the CCSF or its designee needs to be involved for Project components in San Francisco, the details will need to be worked out, in part, based on final permit negotiations and/or forthcoming agreements, as applicable and appropriate.

22-10

The proposed Trans Bay Cable Project will not require a permit from the Federal Energy Regulatory Commission (FERC). FERC's role on the Project includes approval of the financing for construction and setting of the appropriate tariff rate for the Project. The primary federal permitting action for the Project is associated with the USACE permitting (e.g., related to Section 10 of the Rivers and Harbors Act and Section 404 of the Clean Water Act) for the proposed submarine cable installation in the Bay. As discussed in Table 2-1, Section 4.4.2, 4.7.2, and Appendix G of the Draft EIR, the USACE permitting process for the Project will likely include Section 7 (of the Endangered Species Act) consultation with other federal agencies such as the U.S. Fish and Wildlife Service and NOAA Fisheries as well as the State Historic Preservation Office relative to Section 106 (of the National Historic Preservation Act) compliance. Based on City of Pittsburg and Project proponent informal consultation with USACE representatives in 2004, the USACE does not plan to prepare an EIS for this Project, but will instead prepare an Environmental Assessment (EA) based in part on the Final EIR for the Trans Bay Cable Project.

22-11

Comments noted. Section K.1 of Appendix K of the Draft EIR accurately states that there are currently no federal or State CEQA standards for defining health risk from electromagnetic frequencies (EMF) or for limiting human exposure to EMFs from transmission lines or substation facilities in California. Moreover, the California Public Utilities Commission's (CPUC's) EMF policies do not apply to the proposed Trans Bay Cable Project. As discussed in Draft EIR Section A.3.6, preliminary modeling estimates of EMF levels have been performed and the estimated electric and magnetic fields from the submarine DC cable and at the converter station fence lines would be negligible. DC electric and magnetic fields have never been associated with health effects. Also, as discussed in Draft EIR Section A.3.6, the preliminary modeling estimates of AC electric and magnetic field levels at the converter station fence line would also be negligible. Finally, as presented in Section A.3.6 of the Draft EIR, the estimated AC electric and magnetic field EMF levels above the proposed buried DC and AC cables in San Francisco and Pittsburg would also be minimal at the ground surface above the buried cables. The California Public Utility Commission's EMF policies do not apply to the proposed Trans Bay Cable Project. However, the proposed Project design already incorporates EMF mitigating factors since much of the converter station electrical facilities are enclosed within a steel building that provides shielding, and the onshore transmission system employs underground cables as opposed to overhead lines. Cables are proposed to be buried in conduit or duct banks which include concrete casings. In addition, it is expected that the converter station in San Francisco will be surrounded by a masonry wall which will help mitigate noise impacts, EMF, and visual impacts. No further EMF modeling is necessary and no further mitigation is warranted beyond that already included in the Project design.

22-12

Comment noted. As discussed in the Draft EIR, the CAISO selected the proposed Trans Bay Cable 400 MW HVDC Project along with the Jefferson-Martin Transmission Line and the San Francisco Electric Reliability Project as the trio of projects needed to solve San Francisco's short-term and long-term electrical supply and reliability needs. The CAISO assessed the Moraga-Potrero alternative and determined that the proposed Trans Bay Cable Project was preferable. As discussed in Draft EIR Section A.8.3.5.5, the Moraga-Potrero alternative was determined to likely be infeasible due to the significant constraints that exist for getting the line to the East Bay shoreline and the difficulty in getting the line across the Bay to San Francisco/Potrero (i.e., would likely require a submarine cable since it could not be placed on the bridge or within BART tube). CEQA does not require detailed analysis of alternatives that are deemed to be infeasible. In addition, the environmental impacts of the Moraga-Potrero alternative are expected to likely be greater than the proposed TBC Project since it would involve construction through the East Bay hills and through highly populated urban areas as well as installation of a submarine cable component similar to the proposed Project. Please refer to Responses 11-2 and 19-5 for more information.

22-13

Comments noted. Please refer to Responses 3-1 through 3-6.

22-14

Comments noted. Section A.8.3 of the Draft EIR considers multiple transmission and non-transmission alternatives for meeting current and projected electrical supply and reliability needs in San Francisco. None of the various alternatives considered were deemed to be capable of meeting all of the Project objectives and the related screening criteria for feasibility and environmental impacts avoidance. CEQA does not require detailed analysis of alternatives that are infeasible, incapable of meeting the Project's objectives, or that are speculative. The alternatives analysis presented in Draft EIR Section A.8.3 is adequate and reasonable.

22-15

Comments noted. Potential cumulative impacts with the BART earthquake safety program are addressed in Draft EIR Section 7.2.2.12.2. The primary potential concern from a cumulative impact standpoint given the geographical locations of the BART retrofit project components and the proposed Trans Bay Cable Project is the area where the proposed Trans Bay Cable route crosses the BART trans bay tube in the Bay (refer to Map A.2-1, Sheet 1 of 10, milepost 3.5).The proposed onshore TBC Project components are located several miles south of the BART seismic retrofit project's western terminus at the Montgomery station in San Francisco (source: Environmental Assessment/Finding of No Significant Impact , BART Seismic Retrofit Project, Berkeley Hills Tunnel to the Montgomery Street Station; USDOT, Federal Highway Administration et al., August 2005) components in San Francisco, thus, the potential for cumulative impacts to occur during the construction phases is minimal. BART's schedule for performing the retrofits to the trans Bay tube in the Bay indicates that BART's in-bay work would be completed prior to the initiation of the submarine cable installation component of the proposed Trans Bay Cable Project which would not begin until at least the summer of 2008. Therefore, the potential for significant cumulative construction phase environmental impacts between the two projects is negligible. However, the cumulative impact assessment presented in Section 7.2.2.12.2 of the Draft EIR recognizes the potential for system and maintenance conflicts between the two systems and the Project proponent for the Trans Bay Cable has, and will continue to, coordinate with BART engineers to resolve applicable issues prior to final design and construction of the proposed Project. Please refer to Responses 5-1 through 5-5 for more information.

22-17

Comments noted. Please refer to Response 9-1.

22-18

Comments noted. Please refer to Response 2-1A. As noted in Comment Response 2-1A, the electrical sources that would feed the proposed Trans Bay Cable Project via the existing PG&E Pittsburg Substation include a variety of previously permitted ad mitigated sources that varies over time. It is not known what specific sources would supply the PG&E Pittsburg Substation in the future nor what impact, if any, the proposed Project would have on the operation of these sources as these factors involve decisions to be made by the CAISO based on future conditions such as supply and demand. To try and make assumptions about how the grid would be supplied and operated in the future (i.e., in order to form the basis for any air quality impact modeling) would be speculative which is discouraged under CEQA. Given that the proposed Project is a transmission project, not a generation project, speculative indirect operational phase air quality impact modeling is not appropriate. As also noted in Comment Response 2‑1A, there is sufficient generation in the electrical grid to provide the energy that would be transmitted by the Project. The TBC Project is not expected to encourage or facilitate any new generation projects. The Project is actually expected to reduce demand for generation because of an estimated 20 MW savings in transmission line losses as a result of the proposed Project.

22-19

Comments noted. Please note that the proposed TBC Project is a transmission project not an electrical generation project. There are no operational phase "generation" related emissions associated with the proposed Project. Please refer to Responses 2-1A and 22-18.

22-20

Comments noted. Neither CEQA nor the BAAQMD require air quality modeling for mobile sources such as the submarine cable-laying vessel which would install approximately 52 miles of submarine cable in the Bay over a 3- to 4-month period. Therefore, modeling of mobile marine vessel construction emissions is not necessary. The comment regarding the Project's emissions relative to the BAAQMD's definition of a "major new source" is not pertinent since this regulation pertains to qualifying stationary sources that typically emit specific criteria pollutants over the long term not a brief construction period. The Draft EIR includes mitigation measures for temporary marine vessel emissions as discussed in Section 4.2.3.4 under Mitigation Measure AIR-3, Marine Vessel Emission Controls. With implementation of the stated mitigation measure, no significant air quality impacts are expected to occur associated with short-term marine vessel emissions. As discussed in Section 4.2.3.2.2 of the Draft EIR (see Table 4.2-12), a long term air quality-related benefit of the proposed TBC Project would be the expected savings of 20 megawatts of electricity that is currently lost due to line losses/transmission grid congestion.

The term "regional air quality" in this context is assumed to mean large scale (i.e., district-wide) modeling of ozone precursors (i.e., nitrogen oxides NO_x] and volatile organic compounds [VOCs]) that undergo reactions in the atmosphere and contribute to the formation of ozone. The potential effect to regional air quality from marine vessel emissions was addressed in the Draft EIR. [It was correctly pointed out that the Project's contribution to regional emissions from the marine cable installation phase would likely be too small to be discernible to the results of regional ozone modeling (see Draft EIR, page 4.2-26). This is not only the applicant's position, it is the BAAQMD's position as well. As stated in an email received by URS following a meeting held with BAAQMD on the TBC Project wherein the estimated NOx emissions of the cable-laying ship were stated to be over 1,000 pounds per day, "Modeling would not show increased ozone levels resulting from 1000 lb/day - that's way too small to show up in photochemical models" (Henry Hilken, BAAQMD Director of Planning, 01/24/06).

The term "localized air quality" in this context is assumed to mean small scale (i.e., within about 10 km) modeling of pollutants in a non-reactive mode (again including NO_x) to determine those emissions' contributions to existing ambient air quality levels and compare the total to established ambient air quality standards (AAQS). The potential effect on localized air quality of a ship allegedly being in the proximity of a given point for 20 days as suggested in the comment is nebulous because there are no federal or state AAQS having a 20-day averaging time, or even close to a 20-day averaging time. Therefore, there are no criteria for the results of the localized air dispersion modeling requested in the comment to be compared with.

NO₂ has an AAQS for both a 1-hr and an annual averaging time. It is quite possible that the vessel could remain in the same position for periods of one hour or longer but the annual standard is clearly not applicable to this project due to the temporary nature of the construction phase. Air dispersion modeling was conducted using the USEPA SCREEN3 computer model for the NO_x emissions from the cable ship Giulio Verne. The SCREEN3 model looks at emissions from a single stack and evaluates downwind impacts over a full array of all possible meteorological conditions. Several highly conservative and in some cases impractical assumptions were used which would tend to make the modeled results higher than what would actually occur. First, each of the four engines in service on the vessel was assumed to be operating at maximum rated output of 2,268 brake horsepower per engine @ 0.0109 pound of NO_x per brake horsepower hour unit emission rate, an emission rate from the vessel equal to 99 pounds per hour of NO_x. Second, the ship was assumed to be stationary for one full hour even at this maximum engine output. Third, it was assumed that all NO_x is emitted as NO₂ - a highly conservative assumption in that it is likely that only about 10 percent of the emissions would be NO₂.

The maximum-modeled impact occurred at about 875 meters downwind from the vessel and was 53 micrograms per cubic meter. Concentrations at other locations and during other operating conditions all would be lower. The 1-hr California AAQS for NO₂ is 470 micrograms per cubic meter. The highest measured background was 141 micrograms per cubic meter (see Draft EIR Table 4.2-3, Arkansas Street, San Francisco, Nitrogen Dioxide Maximum1-hr Average for year 2002 = 0.075 parts per million (ppm), which is equivalent to 141 micrograms per cubic meter). Therefore, the sum of the worst-case modeled project impact plus background is 53 + 141 = 194, which does not exceed the California AAQS of 470 micrograms per cubic meter. The estimated worst-case project impact plus existing background is only about 40 percent of the applicable standard. Therefore, operation of the Giulio Verne would not cause the California 1-hour NO₂ Ambient Air Quality Standard to be exceeded.

22-21

Please see Response 22-20 regarding ozone modeling.

22-22

Comments noted.

22-23

Please see Response 10-4. The concerns related to emissions from construction equipment operating on land are addressed in the expanded list of mitigation measures added to AQ-2.

Please see Response 10-5. The concerns related to emissions from marine operations are partially addressed in the mitigation measure added to AQ-3. It is very feasible to equip the vessel with the infrastructure necessary to allow hook up to shore side power and have this modification completed in time for this project. Shore side power infrastructure currently exists in at least two locations within the SF Bay Area capable of docking this vessel.

22-24

Comments noted. The comment is not clear what "site" the comment is in reference to, but since the comment is provided by the CCSF, it is assumed that the comment is in reference to the proposed San Francisco converter station site as assessed in the Draft EIR. As noted in previous responses to comments received on the Draft EIR, the Project proponent has negotiated with the landowner at the HWC site and now proposes to shift the San Francisco converter station to the west on the overall HWC property (HWC [Mitigated] site). Please refer to Section 4.A.3 of the Final EIR for the Geologic Resources and Soils assessment of the now-proposed HWC (Mitigated) site. It should be noted that the geologic resources and soil conditions at the HWC (Mitigated) site are essentially the same as the conditions for the HWC site assessed in the Draft EIR as they are located on the same property. The comments stating that specific geologic conditions and hazards as well as hazardous material contamination conditions need to be clearly stated for the site are currently clearly stated in Sections 4.3 and 4.14 of the Draft EIR as well as the corresponding sections of the Final EIR. See new Sections 4.A.3 and 4.A.14 for information regarding the HWC (Mitigated) site in the Final EIR.

22-25

Comment noted. This comment is non-specific to the portion of the Draft EIR to which the comment is intended to apply and it is difficult to interpret as to its potential validity. This comment response assumes that this comment applies to geologic conditions and potential impacts at the San Francisco converter station site (i.e., Sections 4.3.1.4.1 and 4.3.3.2.1, respectively, of the Draft EIR) and the appropriate building design measures to address the site-specific geologic conditions and hazards. The Draft EIR mitigation measures for geologic hazards are clear with respect to the sites in San Francisco and Pittsburg, that site-specific geotechnical investigation results would be required prior to construction, and that the results would be considered as appropriate in the final converter station designs for the various hazards that potentially exist at each site. The final design process would include adherence to applicable regulations including portions of the Uniform and California Building Codes, and review by the City of Pittsburg and CCSF as part of the building permit review and approval process.

22-26

Comments noted. Section 4.3.3.2 of the Draft EIR addresses potential construction-related impacts and appropriate mitigation measures associated with geologic resources and soils, including potential impacts associated with excavation of naturally occurring serpentinite (asbestos bearing rock)(please refer to Impact GEO-2 and Mitigation Measure GEO-2 in Section 4.3.3.2.1 of the Draft EIR). Draft EIR Section 4.3.1.4.1 clearly states that the San Francisco converter station site is underlain by fill. The potential presence of contaminants in the fill are irrelevant to the assessment of geologic conditions at the site. Please refer to Draft EIR Section 4.14 (Hazardous Materials and Waste Management) and Final EIR Section 4.A.14, which addresses the results of the Phase II hazardous material investigation results for the now-proposed HWC (Mitigated) site and the associated potentially significant environmental impacts related to subsurface contamination and associated mitigation measures to protect the environment, public health, and worker safety. The mitigation measures include consideration of Article 22A (Maher Ordinance) requirements.

22-27

Comments noted. Previous studies of sediments in the vicinity of the Mirant Potrero power plant have detected the highest sediment contamination at the northeast corner of the Potrero site and in surface sediments near the Unit 3 outfall (URS, 2001: Final Offshore Sediment Characterization Report, Potrero Power Plant). Contamination in water deeper than 14 feet below MLLW was not detected. The proposed Trans Bay Cable Potrero shoreline crossing would emerge south, and in 25 feet of water offshore, of these locations. The HDD approach has been adopted to ensure that shoreline contaminants are not encountered and are not introduced to the Bay.

22-28

Comments noted. Please see Responses 10-9 and 10-12. In addition, please note that the total sediment dispersed per mile is a very small volume, between 117 and 234 cubic yards per mile, and will be dispersed at a very slow rate of 1 cubic foot per 16 seconds. The total sediment dispersed within the 10 miles of cable alignment in City and County of San Francisco jurisdiction is between 1,170 and 2,340 cubic yards. This volume is below the 5,000 cubic yard DMMO trigger for sediment sampling.

22-29

Comments noted. Please refer to Response 22-28.

22-30

Comments noted. Please refer to Response 10-10.

22-31

Comments noted. Please refer to Response 19-24.

22-32

Comments noted Please refer to Responses 10-11 and 10-12. In addition, please see Response 22-27 regarding contamination at Potrero and Response 12-6 regarding the use of HDD to avoid known near shore contamination at Potrero.

22-33

Comments noted. As noted in Response 22-27, contamination in offshore sediment near the Potrero power plant is in shoreline and near shore sediments. The Project has been designed to avoid known contamination at Potrero. Specifically, the HDD has been proposed to pass under shoreline contamination and to surface offshore and in deep water (30-35 feet) in order to avoid known near shore contamination. Therefore, the presence of the cable would not conflict with remediation of near shore sediments if it is required in the future.

22-34

Comments noted. As discussed in Draft EIR Section 4.5.1.4.1, the onshore portion of the Project area in San Francisco consists of previously developed and industrialized landscapes characterized as "Disturbed/Developed" habitats. As discussed in Draft EIR Section 4.5.3.2.1, no potentially significant impacts to onshore natural communities, wildlife habitat, wetlands, or special-status species are expected to occur from construction or operations related activities associated with the proposed Project in San Francisco. No further analysis is needed or appropriate.

22-35

Comments noted. No potentially significant impacts to marine biological resources are identified in the Section 4.6 of the Draft EIR for any portions of the Project either in Pittsburg, San Francisco, or elsewhere. Accordingly, no mitigation measures beyond those incorporated into the proposed Project design (e.g., careful routing of cable to avoid potentially sensitive marine biological resources and use of minimally invasive Hydroplow for submarine cable installation) are deemed necessary or proposed. The marine biological resources impact assessment presented in the Draft EIR is comprehensive and not preferential to the Pittsburg portion of the Project.

22-36

Comments noted. As described in Draft EIR Sections 4.12.3.2.2, operation of the converter stations would only require nominal quantities of water for landscaping, drinking, restrooms and maintenance activities. The proposed converter stations would not consume water for cooling (i.e., no cooling water intake or discharges). No impacts to marine biological resources associated with cooling would occur.

22-37

The Dungeness crab fishery within San Francisco Bay is recreational only; no commercial fishing vessel traffic (either crabbers or sport fishing [party] vessels) engage in taking Dungeness crab within San Francisco Bay. Crabbers in transit to other grounds (if any) are considered vessels in transit in Section 4.9.1.3 of the Draft EIR.

22-38

Comment noted. The Draft EIR authors have consulted Caltrans documents (e.g., Baywide Eelgrass report) in preparing the Draft EIR section. Many of the Caltrans documents related to the East Span Replacement Project have very different issues associated with them with respect to topics such as marine mammals and underwater noise, but to the extent that these documents and survey data are applicable, they have been considered.

22-39

Comments noted. See Responses 16-10, 16-11, and 19-11.

22-40

Comments noted. Potential construction-related noise impacts to marine organisms associated with submarine cable installation would be associated primarily with the cable-laying vessels as described in the Noise and Vibration section of the Draft EIR (Section 4.11.3.4.1). Please refer to Draft EIR Section 4.11.3.4.1 for more information, including the anticipated Project noise levels in the marine environment, presentation of NOAA Fisheries' noise guidance for impacts to marine organisms, and the impact finding of less than significant with respect to this issue. Please note that the proposed Project no longer includes dredging activities in New York Slough.

22-41

Comments noted. Section 4.7.1.2.1 and Appendix G of the Draft EIR address the historic architectural resources at the HWC site and the Station A Complex on the adjacent Mirant property. In addition, Section 4.7.1.2.1 and Appendix G of the Draft EIR also discuss the CEC evidentiary hearings associated with the Application for Certification for the once-proposed Potrero Power Plant Unit 7 project, including recognition of the larger potential historic district. It should be noted that as a mitigating action and partly in response to comments received regarding potential historic resources impacts associated with development of the Project on the HWC site, the Project proponent has negotiated with the landowner at the HWC site and now proposes to shift the San Francisco converter station to the west on the overall HWC property (HWC [Mitigated] site). The HWC (Mitigated) site avoids direct and indirect impacts to the historic buildings on the HWC property, the San Francisco Mirant property (Station A Complex), and to potential historic districts. Please refer to Response 3-7 for more information.

22-42

Comment noted. Partly in response to comments received regarding potential historic resources impacts associated with development of the Project on the HWC site, the City of Pittsburg as CEQA Lead Agency and the Project proponent have considered the potential project impacts on historic resources in San Francisco and incorporated a mitigating action into the Project to avoid impacts to the historic buildings on the HWC site and the adjacent Mirant property. Please refer to Response 22-41.

22-43

Comments noted. The mitigation measures presented in the Draft EIR are commensurate with the level of impacts because, partly in response to comments received regarding potential historic resources impacts associated with development of the Project on the HWC site, the Project proponent has negotiated with the landowner at the HWC site and now proposes to shift the San Francisco converter station to the west on the overall HWC property (HWC [Mitigated] site). HWC (Mitigated) will completely avoid direct impacts to the two historic buildings on the eastern portion of the HWC property. This action would not directly or indirectly impact the potential historic district(s) or contributing elements of potential historic district(s) located north of the HWC (Mitigated) site. Refer to Section 4.A.7 of the Final EIR for more information.

22-44

Comments noted. The Project proponent has consulted with the San Francisco Planning Department Historic Preservation Coordinator, and through this coordination, has consulted with the Landmarks Preservation Advisory Board.

22-45

Comments noted. The mitigation measures presented in the Draft EIR are commensurate with the level of impacts because, partly in response to comments received regarding potential historic resources impacts associated with development of the Project on the HWC site, the Project proponent has negotiated with the landowner at the HWC site and now proposes to shift the San Francisco converter station to the west on the overall HWC property (HWC [Mitigated] site). Shifting the site location west will completely avoid direct impacts to the two historic buildings on the eastern portion of the HWC property. This action would not directly or indirectly impact the potential historic district(s) or contributing elements of potential historic district(s) located north of the HWC (Mitigated) site. Refer to Section 4.A.7 of the Final EIR for more information.

22-46

Comments noted. Please refer to Responses 22-41 and 22-42.

22-47

Comments noted. Section 4.8.2.3 of the Draft EIR discusses local plans, including the San Francisco General Plan, Central Waterfront Area Plan, and Draft Central Waterfront Neighborhood Plan. Table 4.8-6 of the Draft EIR lists specific policies outlined in these plans that are applicable to the Project, including policies 2.3, 9.1.1, and 7.1 referenced in the comment letter. Sections 4.8.3.2.2, 5.2.8.2, and 5.3.8.2 of the Draft EIR discuss the applicability of the Project with these policies. In addition, an Application for General Plan Referral will be submitted concurrently with other Project applications, whereby a more detailed analysis of consistency with specific objectives and policies of the General Plan and related documents will be conducted.

22-48

Comments noted. Section 4.13 of the Draft EIR, including Figure 4.13-7 which presents a baseline photo and a visual simulation showing the appearance of the converter station site from a viewing point at Warm Water Cove Park looking in a northerly direction, addresses the visual impacts of the proposed San Francisco converter station at the time the Draft EIR was prepared. As discussed in previous comment responses and as assessed in the Final EIR, the Project proponent has negotiated with the landowner at the HWC property and now proposes to shift the San Francisco converter station to the west on the overall HWC property (HWC [Mitigated] site). As shown in Section 4.A.13 of the Final EIR, the visual impacts on Warm Water Cove Park of the now-proposed HWC (Mitigated) converter station site are even lower than those predicted for the previously-proposed HWC site since the converter station is now further to the west, away from the park and the Bay. In addition, the retention of the existing historic warehouse buildings on the eastern portion of the overall HWC property would screen the vast majority of the converter station facilities on the HWC (Mitigated) site as seen from Warm Water Cove Park and as shown on Figure 4.A.13-3 of the Final EIR. As discussed in Draft EIR Section 4.13 and Final EIR Section 4.A.13, none of the proposed or alternative converter station sites under consideration in San Francisco would result in unmitigable significant visual impacts as viewed from Warm Water Cove Park or elsewhere.

22-49

Comments noted. The proposed and alternative converter station sites and ancillary facilities are consistent with the existing (M-2) and proposed (PDR) zoning of the Project area in San Francisco. Section 4.10.3.2 of the Draft EIR identifies that temporary impacts to the Bay Trail may occur during construction of the proposed Project, which could also apply to the HWC (Mitigated) site. Implementation of Mitigation Measure TRAFFIC-3 would ensure that trail closures be coordinated with the San Francisco Department of Parking and Traffic and, as appropriate, signage would be erected for temporary re-routing. No significant impacts to the Bay Trail or access to the Bay shoreline from Project operations were identified in either Section 4.8 (Land Use) or Section 4.10 (Traffic and Transportation) of the Draft EIR. No unmitigable potentially significant impacts to the Bay Trail or recreational opportunities on the Bay are associated with the Trans Bay Cable Project as proposed in the Final EIR, including ancillary facilities and alternatives. Further, the Project would not interfere with access or linkages to other shoreline areas or recreational areas located north or south of the site.

22-50

Comments noted. Draft EIR Sections 4.8.2.3 and 4.8.3.2.4 discuss the applicable general plan policies, including the Draft Central Waterfront Neighborhood Plan. The section discusses that the Draft Plan proposes to change the land uses in the area, including re-zoning of the San Francisco converter station sites from M-2 (Heavy Industrial) to PDR (Production, Distribution, and Repair). Sections 4.8.3.2.2, 5.2.8.2, 5.3.8.2 of the Draft EIR discuss the consistency of the Project with both the existing and proposed land uses.

22-51

Comments noted. The site is currently zoned Heavy Industrial and the HWC Converter Station is consistent with permitted uses within this district. Section 4.8.3.2.2 of the Draft EIR discusses CCSF's policies related to expanding Warm Water Cove Park to the north. Impact LU-1 is identified as a potential conflict between the proposed Project and CCSF/BCDC policies which stress the importance of public access to the Bay. Implementation of Mitigation Measure LU-1 would ensure that requisite conditions of permits from applicable agencies be met, including any conditions to provide Bay access in the vicinity of the Project site. However, the proposed Project has now been shifted in a westerly direction on the overall HWC property (HWC [Mitigated] site), and would not impact the potential implementation of the CCSF General Plan policies regarding improvements to Warm Water Cove Park. Thus, Impact LU-1 is no longer applicable to the HWC (Mitigated) site and Mitigation Measure LU-1 is no longer warranted.

22-52

Comments noted. The proposed submarine cable route, including the portion of the route in San Francisco Bay, was developed in consultation with the USACE and the San Francisco Bar Pilots, among others. In general, the proposed route in San Francisco waters avoids shipping channels and is located in waters that are at least 30 feet deep since this is the approximate minimum depth at which the cable-laying vessel can operate. The proposed submarine cable route avoids portions of ship channels that are routinely dredged or planned to be dredged to maintain adequate vessel draft. The proposed cable would be installed at a typical target burial depth of 3 to 6 feet below the bottom of the Bay and, once installed and buried, would not impact vessel movements in the Bay regardless of water depth. Please refer to Response 18-1 regarding the addition of the cable route (as built) to NOAA charts.

22-53

Comments noted. The proposed submarine cable route was sited to avoid established shipping channels as well as dredge areas, dredge material disposal areas, and sand mining areas. The cable location has been defined in conference with the USACE, U.S. Coast Guard, NOAA, and other authorities knowledgeable about planned future dredged channel depths. It is expected that any future implementation and maintenance of 50-foot-deep shipping channels would occur in existing shipping channels which are avoided by the proposed submarine cable route. No potential conflicts between the proposed submarine cable route and potential future 50-foot navigation channels are anticipated. In the unlikely event that future dredge plans conflicted with the cable route, the cable could be shut down, cut, spliced, and reburied at a lower depth in the applicable location.

22-54

Comments noted. As discussed in Draft EIR Section 4.10.3.2, the transport of oversize loads to the San Francisco converter station site and/or temporary construction laydown areas constitutes a potentially significant impact (Impact TRAFFIC-2, Oversized Loads). With implementation of Mitigation Measure TRAFFIC-2, Coordination of Oversized Loads, this potentially significant impact would be reduced to a less-than-significant level as clearly stated in the Draft EIR. The Project proponent evaluated the potential shipment of oversized equipment to the Port of San Francisco (versus the Port of Oakland) and determined that the Port of Oakland is more appropriate due to its more central location to both Pittsburg and San Francisco and due to the capacity of its facilities for handling oversized loads.

22-55

Comments noted. Please refer to Response 20-1.

22-56

Comments noted. The City of Pittsburg as CEQA Lead Agency and the Project proponent recognize the potential conflicts with San Francisco's planned uses of the Western Pacific site in the future and, accordingly, the proposed Trans Bay Cable Project now anticipates the use of the alternate laydown area at Pier 94/96 as assessed in the Draft EIR. An area of up to approximately 7 acres would be required for the temporary construction laydown area as indicated in Table A.4-5 of the Draft EIR. The Project proponent has not entered into any agreements with the CCSF or the Port of San Francisco at this time regarding the use of Pier 94/96 or other site for temporary construction laydown, but recognizes that agreements for temporary use of such sites would need to be negotiated prior to the initiation of construction.

22-57

Comments noted. As discussed in Response 22-56, the previously-proposed use of the Western Pacific site for temporary construction laydown has been determined to be problematic and the alternate Pier 94/96 laydown site is now considered to be preferable. As discussed in Draft EIR Section 4.10.3.2, use of the Pier 94/96 alternate laydown site would avoid the majority of potential Project-related construction traffic impacts with the Metro Rail operations. The text in Section 4.10.3.2 of the Draft EIR has been revised in response to this comment. Please refer to the new Section 13.0 of the Final EIR for applicable text revision.

22-58

Comments noted. The text in Section 4.10 of the Draft EIR has been revised in response to this comment. Please refer to the new Section 13.0 of the Final EIR for applicable text revision.

22-59

Comments noted. Section 4.10.3.2.1 of the Draft EIR has been revised to further discuss potential parking impacts as follows. In the San Francisco study area, most streets have curb parking on both sides of the street. However, parking is often pre-empted by construction projects that temporarily restrict parking on the surrounding streets. By 9 a.m. on weekdays, most available curb parking in the area is taken. Although the City of San Francisco does not consider limited parking availability to be a significant impact, the Project sponsor will consider providing employee parking at the Pier 94/96 laydown area and to shuttle workers to and from the construction site. Please refer to new Section 13.0 of the Final EIR for more information.

22-60

Comments noted. The noise assessments performed for the San Francisco and Pittsburg components of the Project were performed appropriately and in conformance with the applicable noise ordinances and regulations, including applicable noise measurement criteria, that apply in each jurisdiction. To apply City of Pittsburg noise regulations to the analysis for San Francisco would be neither appropriate nor legally defensible. Based on post-Draft EIR consultation with CCSF staff, Section 4.A.11, including Table 4.A.11-2 of the Final EIR, present L_dn as well as L_eq sound levels for the HWC Mitigated site in San Francisco.

22-61

Comments noted. Please refer to Response 22-60. The noise analysis presented in the Draft EIR is specific to the proposed and alternative facilities in San Francisco and Pittsburg, including consideration of the applicable noise regulations in each jurisdiction. In summary, the only unavoidable adverse significant noise impact identified in the Draft EIR is for construction-related pile driving for the Pittsburg West Tenth Street, Alternative 2 site. Please refer to Draft EIR Sections 4.11 and 5.0 as well as Section 4.A.11 of the Final EIR for more information.

22-62

Comments noted. The noise analysis presented in the Draft EIR considers cumulative noise impacts by definition. As discussed and analyzed in Draft EIR Sections 4.11 and 5.0, the noise assessment considers background noise levels obtained via noise measurements and modeled noise levels with consideration of Project-related construction and operations-phase noise levels. Any potential future projects in the Project vicinity in San Francisco with the potential to generate substantial noise would be expected to be subject to environmental review and permitting (e.g., CEQA compliance) with commensurate mitigation and adherence to applicable noise regulations in San Francisco. Therefore, no significant cumulative noise impacts are anticipated.

22-63

Comments noted. An EIR is required to describe and evaluate a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR does not need to consider every conceivable alternative to a project. The intent of the alternatives analysis in an EIR is to provide a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation. The range of alternatives required in an EIR is governed by a "rule of reason" that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. An EIR is not required to consider alternatives which are infeasible.

The proposed and alternative converter station sites under consideration in San Francisco are all in proximity to the PG&E Potrero Substation, to limit the length of the required 115 kV AC interconnection. No other potential alternative sites have been identified and no unavoidable adverse significant visual impacts have been identified for the proposed or alternative converter station sites in San Francisco from any viewing points. The Draft EIR considers multiple alternatives and the alternatives analysis is deemed adequate.

22-64

Comments noted. As stated in Draft EIR Section A.3.6.1.3, the proposed 115 kV AC interconnection in San Francisco is underground and is consistent with San Francisco General Plan Urban Design Element policy regarding undergrounding of new utilities for new projects. The Project description in the Draft EIR does discuss the possible alternative of an overhead 115 kV line as a contingency in the event that there were some insurmountable obstacle to installing an underground line between the San Francisco converter station and the PG&E Potrero substation. Based on further analysis by the Project proponent, it has been determined that the proposed underground option is feasible and the overhead option has been dropped from further consideration.

22-65

Comments noted. The design of the converter station includes an automatic fire protection system. Systems will be designed to automatically respond to the detection of both smoke and fire, should a fire occur. The Project proponent will coordinate with the Fire Marshall during design review in San Francisco and automated emergency/fire notification facilities, as appropriate, will be included in the design.

22-66

The facility will be hardened against vandalism with sound walls or chain-link fencing, which will surround the facility except for the access gates. The gates will be kept locked at all times except when authorized personnel need to access the site. Signs with the words "Danger: High Voltage" will be posted near the high-voltage lines and equipment in the facility.

Other options that the Project proponent and the City of Pittsburg are considering to enhance security at the HWC (Mitigated) site are as follows:

Regarding the need to reduce the storage and use of hazardous materials; transformer oil will be the only hazardous material used in large volume at the HWC (Mitigated) site. The use and storage of other hazardous materials, such as paint and lubricants, will be kept to a minimum. Only minimal amounts of hazardous wastes will be generated at the site, as no chemical processes will be performed onsite.

Placards and Signage

Warning about the Presence of Hazardous Materials; placards and signage will be used to comply with the Fire Code and other laws and ordinances related to the use, storage, and disposal of hazardous materials. The various applicable laws, regulations, and ordinances are discussed in more detail in the Draft EIR Appendix I (Volume 2).

Public Open Space Uses at the Converter Station Sites; both the San Francisco and the Pittsburg converter stations sites will be isolated from adjacent public open spaces, such as 23rd Street and Illinois Streets in San Francisco and West Tenth Street in Pittsburg, by sound walls or fences with locked gates. Neither converter station will have any public open space, and neither converter station will allow the public on the site.

22-67

Comment noted. Storm water runoff and capacity are addressed in Draft EIR Sections 4.4.1.5.1 and 4.4.1.6.1 and Final EIR Section 4.A.4. See also Response to Comment 19-24.

22-68

Comments noted. The Final EIR considers the results of the Phase II investigation that was performed for the HWC (Mitigated) site in Section 4.A.14. Appropriate remediation and mitigation measures are proposed to protect human health, and the environment, including Bay water quality. Please refer to new Section 4.A.14 of the Final EIR.

22-69

Comments noted.

22-70

At the time of Final EIR issuance, the field investigation as part of a Phase II soil and groundwater investigation at the HWC (Mitigated) site and the associated report have been completed. It is clear that the site soils and groundwater are impacted from earlier site activities. Site contaminants include heavy metals, polynuclear aromatic hydrocarbons, and heavy petroleum hydrocarbons. The Maher Ordinance analytical criteria were a part of the Phase II analytical program and will be reported in the Phase II soil and groundwater investigation report for the HWC (Mitigated) site. The TBC Project will comply with the provisions of the Maher Ordinance during the redevelopment of the HWC (Mitigated) site.

The Project proponent is not responsible for the existing soil and groundwater contamination at the HWC (Mitigated) site. The Project proponent has never had any ownership interest in the property or the former operations at the site that caused the soil and groundwater contamination that currently exists at the site. The Project proponent has entered into an option agreement with the property owner so that should the TBC Project move forward, the Project proponent would enter into a 99-year lease with the property owner.

Site-specific waste management plans will be required for the redevelopment of the site to provide the details of the contaminated soil and groundwater collection, storage, transportation, and management. The Project proponent plans to enter into a Brownfield redevelopment agreement with the State of California Environmental Protection Agency (CalEPA) for the redevelopment of the HWC (Mitigated) site. The Project proponent would also be responsible for any contamination caused by the operation of the converter station in the future. As a matter of public policy, Brownfield agreements limit the environmental liability of the developer to the environmental issues resulting directly from the redevelopment to encourage the redevelopment of contaminated properties. At the HWC (Mitigated) site, the Project proponent would be responsible for the management and disposal of the contaminated soil excavated to construct the building foundations and secondary containment structures and for the management and disposal of the contaminated groundwater collected during construction dewatering, if any. The management of the previously existing contaminated soils and groundwater at the site would remain the responsibility of the landowner and/or the other responsible parties that caused the contamination during earlier operations.

The implementation oversight of these plans for the redevelopment of the HWC (Mitigated) site would be provided by the State of California (CalEPA). Coordination between the CalEPA agency providing the Brownfield oversight and the San Francisco Department of Health as the Local Oversight Program on the management of contaminated soils and groundwater is expected to be a part of the Brownfield agreement. The City of Pittsburg and the Project proponent also agree that the redevelopment construction involving the excavation of contaminated soils and the collection and management of groundwater will require that the construction contractor prepare a site-specific and contaminant-specific Health and Safety Plan.

The Occupational Health and Safety regulations are discussed in more detail in the Draft EIR Appendix I (Volume 2).

22-71

The City of Pittsburg and the Project proponent agree that the redevelopment construction at each converter station site will require a Project-specific and site-specific Storm Water Pollution Prevention Plan (SWPPP). These site-specific plans would address the measures that the construction contractor will take to prevent storm water pollution. These measures, which would be designed to reduce the potential impact of the construction to stormwater, would include, but are not limited to, the following:

The construction contractor for each converter station site would develop a site-specific SWPPP and present it to the regulatory oversight agency for each converter station site for review and approval. The City of Pittsburg, as the lead CEQA agency, together with the environmental regulatory agencies for the redevelopment, would provide implementation oversight of the SWPPP.

22-72

The City of Pittsburg agrees that the San Francisco Department of Public Health (SFDPH) is the local oversight agency that administers Hazardous Materials Business Plans (HMBPs) in the CCSF. Similarly, the Contra Costa County Department of Health is the local oversight agency for HMBPs in Contra Costa County. The construction contractor would provide a construction HMBP to meet federal, state, and local requirements for the Project sites in San Francisco and Pittsburg to the City and County of SFDPH and the Contra Costa County Department of Health, respectively. Before the startup of the converter stations, the Project proponent would also provide an operations-phase HMBP plan to the City and County of SFDPH and to the Contra Costa County Department of Health.

22-73

Comments noted. Please refer to Responses 3-1 through 3-6.

22-74

Comments noted. The City of Pittsburg as CEQA Lead Agency and the Project proponent are supportive of renewable energy sources such as solar. The Project proponent has evaluated the potential for placing solar panels on the roofs of the converter stations. The Project proponent plans to coordinate further with CCSF representatives on this issue and solar panels may be incorporated into the final design, if appropriate.

22-75

Comments noted. Please refer to Response 22-56. In accordance with the CCSF's request, the Western Pacific site is no longer proposed for temporary construction laydown due to the conflicts stated in Comment 22-75. The text in the Final EIR has been revised to reflect the deletion of the Western Pacific site from further consideration. Please refer to Section 3.0 of the Final EIR.

22-76

Comments noted. Although several different cable capacities were assessed by the Project proponent and the CAISO during the conceptual project development phase, the CAISO selected and approved the proposed TBC Project with a specific capacity of 400 megawatts (MW) (please refer to Appendix C of the Draft EIR for pertinent CAISO documents). The Project proponent has sized the Proposed project to be consistent with the CAISO's specification of a 400 MW project.

22-77

Comments noted. The Project proponent considered the possibility of installing two cables instead of one. The Project size under a two-cable scenario would be 600 MW, or 300 MW for each cable. CAISO's analysis concluded that 400 MW would accommodate the projected demand in San Francisco. The Board approved CAISO specification of a 400 MW project concluding that the alternative of installing two cables was infeasible due to economic considerations.

22-78

Comments noted. The CAISO evaluated multiple alternatives for meeting San Francisco's long-term electric supply and reliability needs and selected the TBC Project along with the Jefferson-Martin transmission line and the San Francisco Electric Reliability Project. One of the primary benefits of the TBC Project is that it would provide an alternate transmission pathway to serve San Francisco and northern San Mateo County; i.e., would not involve use of existing transmission facilities that come up the Peninsula to San Francisco. Neither the No Project Alternative or possible reconductoring of PG&E's transmission lines would provide an alternate transmission pathway, thus they would not provide the same level of reliability provided by the TBC Project.

22-79

Comments noted. Please refer to Response 22-78. Both CAISO and PG&E routinely perform long-term grid transmission planning. The San Francisco Stakeholders Study Group analyzed the greater Bay area for 2 years, during which they evaluated many alternatives including the "No Project" alternative and reconductoring (see Appendices A.8.4 and A.8.3.5.4 of the Draft EIR). They determined that to increase electrical transmission reliability to San Francisco, an alternate pathway was required. Reconductoring would not provide the alternate pathway for added reliability to serve the San Francisco load.

22-80

Comments noted. The CAISO analysis determined that the Jefferson – Martin transmission line would shut down Hunters Point. The Jefferson – Martin transmission line is operational and Hunters Point is shut down. Upon commercial operation of the San Francisco Electric Reliability Project (SFERP), the shut down of the Mirant Potrero Power Plant would seem likely. Mirant solely has the authority to shut the Potrero Power Plant and the CCSF solely has the authority to cause the SFERP to be constructed and placed into operation.

22-81

Comments noted. Sections 1.3.5 and 6.3 of the Draft EIR have been revised to reflect the environmentally superior alternative(s) as being the HWC (Mitigated) site in San Francisco and the temporary construction laydown area on the Port of San Francisco's property at Pier 94/96 as evaluated in the Draft EIR. Please refer to Sections 1.3.5, 4.A,and 6.3 of the Final EIR for the rationale supporting identification of these facility locations as the environmentally superior sites.

22-82

Comments noted. The Babcock & Brown website is not current with respect to the locations of the currently proposed and alternative converter station sites under consideration in San Francisco. The City of Pittsburg's website includes a copy of the Draft and Final EIRs which delineate the accurate locations of proposed and alternative facilities in San Francisco at the time the subject documents were prepared. The site of the Muni Metro East Maintenance Facility is no longer proposed for a converter station site or a temporary construction laydown area and no conflicts between the two projects are expected to occur.

22-83

The City of Pittsburg as CEQA Lead Agency appreciates the reference documents provided by the CCSF relative to the CEC's hearings and prepared testimony for the Mirant Potrero Unit 7 Application for Certification in 2002. The Final EIR for the TBC Project, including responses to pertinent comments (e.g., regarding historical resources) considers these reference documents, as appropriate. Please refer to Responses 15-1 and 22-41, which explain that the proposed HWC (Mitigated) site will avoid any impacts to historic resources.

22-84

The City of Pittsburg as CEQA Lead Agency appreciates the reference letter from the Port of San Francisco dated May 21, 2001 provided by the CCSF relative to the California Energy Commission's consideration of the Mirant Potrero Unit 7 Application for Certification. The Final EIR for the TBC Project, including responses to pertinent comments (e.g., regarding historical resources and mitigation costs) considers this reference document, as appropriate. Please refer to Responses 15-1 and 22-41.

22-85A

Comments noted. The City of Pittsburg as CEQA Lead Agency appreciates the San Francisco Power Plant Task Force's (SFPPTF) review of the Draft EIR for the Trans Bay Cable Project. The City of Pittsburg disagrees with the SFPPTF's assertion that the Draft EIR is inadequate and that it was not properly noticed. The Draft EIR was issued, including the Notice of Availability, on May 10, 2006. As noted in the Office of the Administrator's cover letter to the SFPPTF's written comments, the public comment period for the Draft EIR was extended by two weeks (i.e., 59 days total) to accommodate the SFPPTF's request for an extension. The availability of the Draft EIR and the public meetings schedule was posted in the San Francisco Chronicle on May 29, 2006 and in the Contra Costa Times on June 2, 2006, and multiple hard copies and CDs of the Draft EIR were provided directly to applicable regulatory agencies, including CCSF and members of the SFPPTF, as well as to various environmental groups. The Draft EIR is also posted on the City of Pittsburg's website. In addition, public meetings to describe the Project, summarize the Draft EIR findings, and receive oral comments were held in San Francisco (June 8, 2006) and Pittsburg (June 14, 2006). Members of the SFPPTF were present and provided oral comments at the June 8, 2006 public meeting in San Francisco at the Potrero Hill Neighborhood House. Responses to the oral comments received are presented in subsequent responses based on the Public Meeting transcripts.

22-85B

Comments noted. The Association of Bay Area Governments (ABAG) commented on the Draft EIR; please refer Response 20-1.

22-85C

Comment noted. Section 4.13 of the Draft EIR (and Section 4.A.13 in the Final EIR) includes a context photo from the western edge of the Bay at Warm Water Cove Park (key observation point "SF-3"). This location and view represent the worst case view from the Bay towards the applicable San Francisco converter station sites under consideration. The water area of the Bay east of the HWC (Mitigated) site is primarily utilized for heavy shipping given the Port of San Francisco facility nearby to the south. The quality of views from the shipping lane is not a significant visual issue. Recreation sailing further to the east in the central portion of the Bay is relatively distant; the Warm Water Cove Area will blend into the overall industrial character of the shoreline that is prevalent for this area both north and south.

22-85D

Comments noted. Draft EIR Section 4.8 (Land Use and Recreation) has been revised in response to this comment. Please refer to the new Section 13.0 of the Final EIR for applicable text revision.

22-85E

Please refer to Response 10-44 and Response 22-41, which explain that the HWC site has been shifted to the west, and that the now-proposed HWC (Mitigated) site avoids historic resource impacts.

22-85F

The construction of these concrete sugar warehouses was an "improvement" in the storage of refined sugar, but neither the buildings themselves nor the way they are constructed was considered a "technological advancement." Neither building is eligible for its architectural or engineering merit under National Register Criterion C, or California Register Criterion 3. [Source: Corbett, URS Corporation, "Historic Architecture Report for 435 23rd Street, CCSF, California" (2001)].

22-85G

Comment noted.

22-85H

The evaluation of the significance of the Station A Complex does not identify the office building facing Humboldt Street as a separate contributing element of the complex. The building is described as part of the main Station A structure because it was attached to the main building. The evaluation was prepared by an architectural historian who meets the Secretary of the Interior's Standards. The discussion of Station A in the Draft EIR is based on this professional evaluation and adequately describes the contributing elements of the Station A complex for the purposes of identification and impact analysis.

22-85I

Comments noted. The text in Draft EIR Section 4.7.1.2.1 and Appendix G presents the conclusions of the testimony of experts for the CEC, the CCSF, and for Mirant regarding the historical status of the Station A Complex as discussed during the CEC licensing process and hearings for the once proposed Mirant Potrero Unit 7 AFC project. As stated in Draft EIR Section 4.7.1.2.1 and Appendix G, the Station A Complex, whether as a separate resource complex or as a contributor to a potential historic district, is considered to be a historical resource for the purposes of CEQA. The evaluation of Station A was prepared by an architectural historian who meets the Secretary of the Interior's Standards for architectural historian.

22-85J

The Draft EIR correctly states that "Status 7" listing in the State Historic Preservation Office's Historic Property Data File indicates that information has been submitted to SHPO, but there has been no determination of eligibility.

22-85K

The technical reports in Draft EIR Appendix G list the relevant local historic preservation ordinances and Draft EIR Section 4.7.2.2. refers the reader to Appendix G.

22-85L

As stated in the prelude (Historical Architectural Resources) to Mitigation Measure(s) CUL-2 (Disturbance of Historical Architectural Resources), these measures apply to construction of the San Francisco HWC Converter Station as originally proposed which would have involved demolition of historical resources. It should be noted that, partly in response to comments received regarding potential historic resources impacts associated with development of the Project on the once-proposed HWC site, the Project proponent has negotiated with the landowner at the HWC property and now proposes to shift the San Francisco converter station to the west on the overall HWC property (HWC [Mitigated] site). The HWC (Mitigated) site completely avoids direct impacts to the two historic buildings on the eastern portion of the HWC property. Another advantage of the HWC (Mitigated) site is that it allows the proposed 115 kV interconnection to the PG&E Potrero substation to be installed without impacting the Station A Complex on the adjacent Mirant Potrero property. This action would not directly or indirectly impact the potential historic district(s) located north of the HWC (Mitigated) site. Refer to Section 4.A.7 of the Final EIR for more information. The mitigation measures presented in the Draft EIR that would be undertaken to address alternatives to the proposed Project have been expanded and clarified. The Draft EIR presented three mitigation measures (i.e., Mitigation Measure CUL-2a, Recording Architectural Resources; CUL-2b, Architectural Resource Interpretive Display and/or Interpretive Material; and CUL-2c, Architectural Resource Salvage Opportunities). Mitigation Measure CUL-2d Central Waterfront Historic Preservation has been added to Section 5.2.7 of the Draft EIR for the San Francisco Mirant alternative. Refer to Section 13.0 of this Final EIR for the applicable text revision.

22-85M

Comments noted. Mitigation Measures CUL-2a through -2c in the Draft EIR were intended to apply to the Mirant Station A Complex as well as the HWC buildings, as applicable. Please refer to Final EIR Section 4.A.7 which addresses potentially significant cultural resource impacts and associated mitigation for the three Mirant Potrero alternative converter station layouts under consideration. As noted in responses to previous comments, the HWC site as analyzed in the Draft EIR has been shifted to the west on the HWC property (HWC [Mitigated] site) as a mitigating action. The HWC (Mitigated) site is assessed in the Final EIR, partly in response to comments received regarding potential historic resources impacts associated with development of the Project on the HWC site as defined by the Draft EIR. The HWC (Mitigated) site which is located on the western portion of the overall HWC site would avoid direct impacts to the historic HWC buildings as well as the Station A Complex on the adjacent Mirant property. HWC (Mitigated) will completely avoid direct impacts to the two historic buildings on the eastern portion of the HWC property. This action would not directly or indirectly impact the potential historic district(s) or contributing elements of potential historic district(s) located north of the HWC (Mitigated) site. Refer to Final EIR Section 4.A.7 for more information.

22-85N

Comments noted. Please refer to Response 3-3.

22-85O

Comments noted. Please refer to Response 3-4.

22-85P

Comments noted. Please refer to Response 3-5.

22-85Q

Comments noted. Please refer to Response 3-6.

22-85R

Comments noted. Please refer to Responses 3-1 through 3-6 and text revisions to Section 4.8 regarding CCSF's energy-related policies. Refer to the new Section 13.0 of the Final EIR for the applicable text revision. In 2004 the CAISO, working closely with the CCSF, PG&E, and interested stakeholders, established a plan describing the transmission and generation requirements necessary to reliably serve the San Francisco Peninsula Area load while allowing for the release of all existing generation at Hunters Point and Potrero Power Plants from their Reliability Must-Run (RMR) Agreements. This plan, called the "Revised Action Plan for San Francisco" (Action Plan), was adopted by the CAISO Board of Governors in November 2004 and is currently being implemented by PG&E, the CCSF, and the CAISO. Full implementation of the Action Plan is expected by the end of 2007.

The CAISO continued to utilize the stakeholder group to establish a long-term (10-year) transmission plan beyond the implementation of the Action Plan. This effort, called the Long Term Phase 2 Study, was initiated by the CAISO in February 2004. Ultimately the CAISO chose the proposed Trans Bay Cable Project as the best long-term transmission solution for San Francisco and the region.

The Trans Bay Cable Project is a part of this larger strategy to meet energy demand and decrease pollution in San Francisco while still bringing additional safe, clean, reliable energy to the City's residents and businesses.

The Project does not involve any new energy generation. This Project supports San Francisco's goals by finding an innovative way to deliver energy to San Francisco and the peninsula without requiring the development of new power plants in San Francisco or the City of Pittsburg, or elsewhere in the Bay Area. The electricity conveyed for the Project would be taken from the Pittsburg substation and transmitted under the Bay to San Francisco. The Pittsburg substation receives power directly from several local power plants, as well as through transmission lines from many other power plants in California and the Western U.S. Because of the diversity of that substation's energy sources, the source of power to the Project cannot be specified; however, renewable energy sources such as hydropower, geothermal, wind, and solar are included in the mix of resources supplied to the Pittsburg substation from the transmission system.

22-85S

Comments noted. Please refer to Responses 3-1 through 3-6.

22-85T

Comments noted. As discussed in the Draft EIR (Section 2.0 and Appendix C) and previous comment responses, the CAISO selected and approved the proposed Trans Bay Cable Project on September 8, 2005. The CAISO studied various alternatives as part of the San Francisco Stakeholders Study Group process of which the San Francisco Power Plant Task Force was a participant. The CAISO considered the cost of the TBC Project in its evaluation process. In addition, the Federal Energy Regulatory Commission (FERC) will set the rate tariff structure for the Project.

22-85U

Comments noted. Please refer to Response 21-1.

Comment Number

Response

23-1

Comments noted. Please refer to Response 20-1.

Comment Number

Response

24-1

Comments noted. Please refer to Response 20-1.

Comment Number

Response

25-1

Comments noted. The City of Pittsburg as CEQA Lead Agency appreciates the SFRWQCB's review of the Draft EIR and understands that the Board may exercise conditions on the Project relative to its permitting jurisdiction.

25-2

Comments noted. The text in Section 4.4 of the Draft EIR regarding the responsibility for 401 Water Quality Certification has been revised in response to this comment. Please refer to the new Section 13.0 of the Final EIR for the applicable text revision.

25-3

Comment noted. Table 4.14-8 in Draft EIR Section 4.14 has been revised in response to this comment to specify the listed telephone number of 510-622-2300. Please refer to the new Section 13.0 of the Final EIR for the applicable text revision.

26-1

Comments noted. The City of Pittsburg as CEQA Lead Agency appreciates Valero's review of the Draft EIR for the TBC Project. The City of Pittsburg understands that Project proponent representatives met with Valero representatives on July 25, 2006 and September 26, 2006 and that Valero has provided preliminary pipeline design details that will facilitate design of the proposed Project to plan for and avoid potential impacts on Valero's pipeline facilities. The Project proponent has provided proposed cable-laying sketches and explained the electrical cable design to Valero representatives. The City of Pittsburg understands that the Project proponent and Valero representatives are in the process of negotiating a crossing agreement which would include, among other issues, potential specific crossing methods and measures. The crossing agreement will include provisions for further cooperation and coordination between the representatives in conjunction with the geotechnical study and final design. The crossing agreement is expected to require written procedures for installation of the DC cable in relationship to the Valero pipelines, and Valero's possible future maintenance requirements for Valero's pipelines. Please refer to subsequent comment responses which address the points raised in Valero's comment letter.

26-2

Comments noted. Based on final engineering design/installation drawings provided by Valero to the Project proponent, the Project Proponent understands that Valero's pipelines are buried at a depth of approximately 10 to 15 feet below the bottom of Suisun Bay in the general area of the proposed Trans Bay Cable crossing area. The Project proponent has provided three cable burial options to Valero: 1) typical crossing with pipeline greater than 10 feet below the bottom of the Bay floor; 2) typical crossing with pipeline between the Bay floor but no greater than 10 feet below the bottom of the Bay floor; and 3) typical crossing with the pipeline just below the bottom of the Bay floor or resting on the bottom of the Bay floor. A proposed conceptual mattress design is provided in the options. The Project proponent will determine the specific crossing method and measures to be taken to protect Valero's pipelines and the HVDC cable based on the results of the forthcoming geophysical survey and further consultation with Valero representatives pursuant to the crossing agreement currently under development. Typical mattress installation using an overhead crane is shown on Figure A.4-6 of the Draft EIR and typical mattress deployment for pipeline crossings is shown on Figure A.4-7. General information regarding use of protective mattresses is provided in Section A.4.4.1.4 of the Draft EIR. The Kinder Morgan pipelines were not in the SLC database at the time the SLC's files were reviewed by Project proponent representatives in 2005 during preparation of the Draft EIR. The Project proponent is now aware of the presence of the Kinder Morgan pipelines. Draft Table A.2-1, Known Utility Crossings, and Map A.2-1 have been revised to acknowledge the presence of the Kinder Morgan pipelines in response to this comment. Please refer to the new Section 13.0 of the Final EIR for the applicable text revision. The Kinder Morgan pipelines have been added to Map A.2-1 (Sheet 7 of 10) in Section 3.0 of the Final EIR.

26-3

Comments noted. The proposed Project will be designed so as to not interfere with Valero's operation, maintenance, and repair procedures for its pipelines. Valero representatives indicated that if repairs are required to the exterior of the pipe, then Valero will coordinate with the Project proponent to make the repairs. The Project proponent will coordinate further with Valero representatives prior to final design and submarine cable installation to ensure that adequate measures are in place to protect Valero's pipelines from possible damage associated with HVDC cable installation and operation. The Project proponent recognizes that Valero is required to comply with regulations relative to submerged pipeline operation and maintenance.

26-4

Comments noted. Please refer to Response 26-3. Following review of the results of the forthcoming geophysical survey, the Project proponent will perform the final engineering design for the submarine cable system, including the site-specific crossing plans for submerged utilities, including Valero's pipelines.

26-5

Comments noted. The fact that the proposed submarine HVDC cable system route crosses several pipelines is identified in Table A.2-1, Known Utility Crossings. The final engineering design, including coordination and consultation with owners of other submerged utilities that are crossed, will ensure that significant direct and/or cumulative impacts are avoided.

26-6

Comments noted. The City of Pittsburg as CEQA Lead Agency believes that the Draft and Final EIRs fully address all environmental impacts of the Project and contain sufficient information to inform decision-makers of the potential environmental impacts of the Project. The City of Pittsburg has instructed the Project proponent to coordinate further with Valero to make sure all legitimate issues are satisfactorily addressed prior to the completion of final design and construction.

26-7

Comments noted. Please refer to Responses 26-2 through 26-6.

26-8

Comments noted. Please refer to Responses 26-2 through 26-6.

26-9

Comments noted. Please refer to Response 26-2.

26-10

Comments noted. The fact that the proposed submarine HVDC cable system route crosses several pipelines is identified in Table A.2-1, Known Utility Crossings. The proposed cable crossing locations of Valero's pipelines are shown on Map A.2-1, Sheet 7 of 10 of the Draft and Final EIRs. The information presented in the Draft EIR is adequate for the purposes of environmental assessment in accordance with CEQA requirements. The information presented in the Final EIR will be supplemented with results of the forthcoming geophysical survey which will be considered in the final design, including the specific crossing methods for the Valero pipelines (and other submerged utilities traversed by the cable route).

26-11

Comments noted. Please refer to Response 26-3.

26-12

Comments noted. Please refer to Response 26-10.

26-13

Comments noted. The City of Pittsburg as CEQA Lead Agency believes the Draft EIR does adequately address the potentially significant environmental impacts of the proposed Trans Bay Cable Project. Please refer to subsequent comment responses that address the specific points raised by Valero.

26-14

Comments noted.

26-15

Comments noted. Following review of the results of the forthcoming geophysical survey, the Project proponent will perform the final engineering design for the submarine cable system, including the site specific crossing plans for submerged utilities, including Valero's pipelines. Mattress installation in the vicinity of the proposed Valero pipeline crossings, as applicable, will be designed to avoid the potential for damage to the submerged pipelines. Accordingly, no potential biological impacts associated with pipeline damage would occur.

26-16

Comments noted. Please refer to Response 26-3 regarding potential impacts on Valero's pipeline operation and maintenance activities. Operation of the submarine Trans Bay Cable would not involve any routine maintenance activities, thus no impacts on Valero's pipelines would be expected to occur. Project proponent representatives will incorporate measures in the final design to avoid any impacts on Valero's pipeline cathodic protection system (e.g., maintain adequate distance between cable and anodes and/or install an insulation buffer between the cable and the pipelines).

26-17

Comment noted. Section 4.2 of the Draft EIR presents the estimated construction emissions (onshore and offshore) associated with the Project as well as the thresholds that were used to assess the potential significance of construction emissions. In addition, Section 4.2 of the Draft EIR also quantifies estimated emissions during the operational phase from intermittent testing of emergency equipment. In summary, with implementation of mitigation measures, all air quality related impacts would be reduced to less-than-significant levels. Please refer to Response 22-20 for more information that supports the less-than-significant impact conclusions for air quality.

26-18

Comment noted. Please refer to Responses 26-17 and 22-20.

26-19

Comment noted. Based on the information provided in the Draft EIR and discussions with Valero, Valero informed the Project proponent that they were in the process of consulting with an engineer who was preparing a cathodic protection study of the Valero system in conjunction with the DC cable. The Project proponent has not received the results of that study. After receipt and review of the study, the Project proponent will work with Valero to address any issues identified.

26-20

Comments noted. Please refer to Responses 26-3, 26-15, 26-16, and 26-19. The final design of the proposed Trans Bay Cable Project and additional Project proponent consultation with Valero representatives will ensure that Valero's pipelines (and other submerged utilities that are crossed) are not damaged during cable installation and operation and, therefore, water quality impacts associated with a Project-related pipeline break would not occur.

26-21

Comments noted. Please refer to Response 26-20. No impacts on Valero's pipelines or product deliveries would occur associated with the proposed Project.

26-22

Comments noted. Valero's concerns regarding the Draft EIR adequacy relative to biology, water quality, and public services and utilities are based on the premise that installation and/or operation of the proposed submarine cable would damage Valero's pipelines. As discussed in responses to previous comments, the Project will avoid impacts to Valero's pipeline facilities as well as other submerged utility crossings. Please refer to Responses 26-15, 26-16, 26-19, 26-20, and 26-21.

26-23

Comments noted. Please refer to Response 26-22. The final Project design relative to utility crossing plans will ensure that no significant Project specific or cumulative impacts on submerged utilities would occur.

26-24

Comments noted. Please refer to Response 26-6.

PM1:1-1

Comments noted. The TBC Project proponent filed the proposed rate structure with the Federal Energy Regulatory Commission (FERC). The FERC approved the proposed rate structure in July, 2005. Prior to commercial operation of the Project, the costs to engineer, procure, and construct the Project will be filed with the FERC. The FERC has the discretion to either approve the costs as presented or deny costs that are deemed not to be relevant to the Project. The approved costs will be applied to the rate base and passed on to the rate payers in a fashion similar to other projects, e.g., the Path 15 project. The CAISO evaluated five projects during the two-year San Francisco Stakeholder process. CAISO evaluated alternative technical options as well as their associated costs. The CAISO selected the TBC Project as the alternative that would best support the San Francisco reliability issues.

PM1:1-2

Comments noted. Refer to Response PM1:1-1.

PM1:1-3

Comments noted. Please refer to Responses 3-1, 10-1, and 10-2.

PM1:1-4

Comments noted. Please refer to Responses 3-1 through 3-6.

PM1:2-1

Comments noted.

PM1:3-1

Comments noted. The Draft EIR assesses potential Project-related impacts to visual resources in Sections 4.13 and Section 5.0. The San Francisco HWC (Mitigated) site is evaluated in Section 4.A-13 of the Final EIR. With the exception of the Pittsburg West Tenth Street Alternative 2 converter station site in Pittsburg, no unmitigable visual impacts have been identified for the proposed or alternative sites. As discussed in the Final EIR, the Pittsburg West Tenth Street Alternative 2 site is no longer under consideration due to its unavoidable adverse significant visual and noise impacts and, thus, has been withdrawn from further consideration.

PM1:3-2

Comments noted. Please refer to Response PM1:1-1

PM1:3-3

Comment noted. Please refer to Response 10-58.

PM1:3-4

Comment noted. UCSF was not specifically consulted; however, the Mission Bay redevelopment project, which includes the Mission Bay Campus, was considered in the Draft EIR. The Mission Bay redevelopment project is located north of the Potrero Power Plant as shown on Figure 4.8-2 of the Draft EIR. Please refer to Response 10‑58.

PM1:3-5

Comment noted. With respect to the potential future inundation of Bay shoreline areas due to a rise in the Bay surface due to global warming, this contention is highly speculative and unlikely to occur to the extent that the San Francisco converter station sites under consideration would be impacted during the life of the Project. Were the Bay to rise to I-280 by 2050 as contended, the impacts would not be limited to the TBC Project, but would be a Bay Area/worldwide problem in coastal areas.

PM1:4-1

Comments noted. Please refer to Responses 3-1 through 3-6.

PM1:4-2

Comments noted. Please refer to Responses 3-1, 10-1, and 10-2.

PM1:4-3

Comments noted; Please refer to Response PM1:1-1.

PM1:4-4

Comments noted. Please refer to Response 2-1A.

PM1:5-1

Comments noted. Please refer to Response 15-1.

Comment Number

Response

PM2:1-1

Comment noted.

PM2:1-2

Comment noted.

PM2:1-3

Comments noted.

PM2:2-1

Comments noted. Please refer to Responses 3-1 through 3-6, 10-1, and 10-2.

PM2:2-2

Comments noted. Please refer to Response 3-7.

PM2:2-3

Comment noted. Please refer to Response PM1:1-1.

PM2:3-1

Comments noted. Please refer to Response 2-1A.

PM2:3-2

Comments noted. The TBC Project is being evaluated on its own merits. The only air quality issues involve the emergency generator and firewater pump that are required by regulations and used only on an emergency basis. TBC is in the process of obtaining air permits for both the Pittsburg and San Francisco converter station sites.

PM2:4-1

The City of Pittsburg as CEQA Lead Agency appreciates Miller, Starr and Regalia's review of the Draft EIR for the proposed Trans Bay Cable Project. The City of Pittsburg concurs with the commentor's comments regarding the environmental superiority of the Pittsburg West Tenth Street Alternative 1 converter station site as discussed in the Draft and Final EIRs. Please refer to Sections 1.0 and 3.0 of the Final EIR for a description of the currently-proposed Project, which includes Pittsburg West Tenth Street Alternative 1 (East-West) as the now-preferred Pittsburg site.