Exhibit D
R ESPONSE TO C OMMENTS DOCUMENT
S EPTEMBER 2025
F RESNO VMT REDUCTION PROGRAM
F RESNO , C ALIFORNIA
APPENDIX E
PUBLIC COMMENT LETTERS ON THE DRAFT EIR
F RESNO VMT REDUCTION PROGRAM
F RESNO , C ALIFORNIA
R ESPONSE TO C OMMENTS DOCUMENT
S EPTEMBER 2025
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“Provide a safe and reliable transportation network that serves all people and respects the environment.” DISTRICT 6 OFFICE
1352 WEST OLIVE AVENUE |P.O. BOX 12616 |FRESNO, CA 93778-2616 (559) 981-7284| FAX (559) 488-4195 | TTY 711
www.dot.ca.gov
July 21, 2025
City of Fresno
Draft Environmental Impact Report for
Vehicle Miles Traveled Reduction Program
GTS #: https://ld-igr-gts.dot.ca.gov/district/6/report/36990
SENT VIA EMAIL
Mx. Sophia Pagoulatos, Planning Manager
City of Fresno
2600 Fresno St. #3043
Fresno, CA 93721
[email protected]
Dear Mx. Pagoulatos:
Caltrans has completed the review of the Draft Environmental Impact Report for Vehicle Miles Traveled (VMT) Reduction Program proposing to implement a VMT Reduction Program to reduce VMT and associated greenhouse gas emissions, while streamlining the environmental compliance process for development projects that generate vehicle trips.
The project site is located in the City of Fresno including surrounding sphere of influence.
The mission of Caltrans is to provide a safe and reliable transportation network that serves all people and respects the environment. The Local Development Review (LDR) process reviews land use projects and plans through the lenses of our mission and state planning priorities of infill, conservation, and travel ‐efficient development. To ensure a safe and efficient transportation system, we encourage early consultation and coordination with local jurisdictions and project proponents on all development projects that utilize the multimodal transportation network.
Caltrans provides the following comments consistent with the State’s smart mobility goals that support a vibrant economy and sustainable communities:
1. Caltrans has completed its review of a Draft Environmental Impact Report (DEIR) to evaluate the potential environmental impacts resulting from implementation of the Fresno Vehicle Miles Travelled (VMT) Reduction Program for the City of Fresno. It should be noted in the DEIR Project Impacts (Index 4.16.3.2), that beyond or in Comment Letter A1
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Mx. Sophia Pagoulatos) – Draft Environmental Impact Report for VMT Reduction Program July 21, 2025
“Provide a safe and reliable transportation network that serves all people and respects the environment.” addition to the use of the VMT metric, determining how the State Highway System may otherwise be affected by a land use project may still be necessary at times, particularly as it relates to the safety of the traveling public. Road safety reviews, that are not based on VMT, may be required. The Caltrans Local Developmental Review (LDR) - Safety Review Practitioners Guidance provides guidelines for the review of land use projects and plans affecting the State Highway System (SHS) within the LDR process.
2. Alternative transportation policies should be applied to the development. An assessment of multi-modal facilities should be conducted to develop an integrated multi-modal transportation system to serve and help alleviate traffic congestion caused by the project and related development in this area of the city. The assessment should include the following:
a. Pedestrian walkways should link this Project to transit facilities, bicycle pathways and other walkways in the surrounding area.
b. Coordinating connections to local and regional bicycle pathways should be done to further encourage the use of bicycles for commuter and recreational purposes.
c. Transit service and bus stop accommodations should be extended to within ¼- mile of the Project site.
3. Caltrans recommends the Project implement “smart growth” principles regarding parking solutions, providing alternative transportation choices to residents and employees. Alternative transportation choices may include but are not limited to parking for carpools/vanpools, car-share and/or ride-share programs.
4. Based on Caltrans Vehicle Miles Traveled (VMT)-Focused Transportation Impact Study Guide, dated May 20, 2020, and effective as of July 1, 2020, Caltrans seeks to reduce single occupancy vehicle trips, provide a safe transportation system, reduce per capita VMT, increase accessibility to destinations via cycling, walking, carpooling, transit and reduce greenhouse gas (GHG) emissions. Caltrans recommends that the project proponent continue to work with the city to further implement improvements to reduce VMT and offer a variety of transportation modes.
5. The city should consider requiring the project to provide charging stations for electric vehicles and for freight trucking as part of the statewide efforts to reduce greenhouse gas emissions, reduce freight parking shortages and maintain the Federal Hours of Service regulations.
6. Due to severe truck parking shortages throughout the state and strict Federal Hours of Service regulations that limit the amount of time a truck driver can spend driving per day, many truck drivers cannot find safe and reliable truck parking spaces, and Letter A1
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Cont.
Mx. Sophia Pagoulatos) – Draft Environmental Impact Report for VMT Reduction Program July 21, 2025
“Provide a safe and reliable transportation network that serves all people and respects the environment.” therefore park in unauthorized and/or unsafe areas. Constructing adequate truck parking on-site can alleviate the unauthorized/unsafe truck parking demand on existing facilities. On-site parking for freight trucks will also strive to ensure a secure and reliable area for extended or overnight parking to help maintain adherence to the Federal Hours of Service regulations. On-site parking for freight trucks is adequate when on-site facilities include, at a minimum: restrooms, lighting, trash facilities, drinking water, showers, and food sellers (such as, but not limited to a food court, restaurant, food truck) or vending machines.
7. The city should consider requiring the Project to implement on-site parking for freight trucks within the Project boundaries, that truck drivers can utilize for extending parking periods before loading or after unloading.
8. The city should consider promoting the leveraging of strategic investments to maintain and modernize a multimodal freight transportation system with innovative approaches, including advanced technology to optimize integrated network efficiency, improve travel time reliability, and achieve sustainable congestion reduction.
9. To ensure that VMT-reducing projects do not unintentionally impact operations on the SHS, Caltrans requests early consultation during project-level environmental review and coordination on any improvements located adjacent to or affecting SHS facilities. Caltrans also recommends that the City provide clear reporting on the use of mitigation fees and the performance of funded projects, including metrics for trip reduction, mode share, and network connectivity. In addition, the City is encouraged to include freight-focused VMT reduction strategies, such as last-mile logistics improvements and off-peak delivery options, and to adopt equity-based project selection criteria that prioritize investments in disadvantaged communities and expand access to multi-modal transportation choices.
If you have any other questions, please call or email: Keyomi Jones, Associate Transportation Planner at (559) 981-7284 or [email protected].
Sincerely,
Mr. Dave Padilla, Branch Chief,
Local Development Review
Letter A1
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Cont.
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Comment Letter A2
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Comment Letter A2
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Cont.
Docusign Envelope ID: F8596550-DEFE-4D43-89AA-8118FED6864E Sophia Pagoulatos, Planning Manager
City of Fresno
August 20, 2025
PROGRAM DESCRIPTION SUMMARY
Proponent: City of Fresno
Objective: The proposed Program intends to create a VMT Reduction Program to establish mitigation for future projects that exceed the City's VMT thresholds in the form of a mitigation bank. The VMT Reduction Program includes two major components that can be applied, individually or in combination, to new development with VMT impacts:
an Urban Design Calculator, which estimates potential VMT reductions for development projects through incorporation of various design elements; and a mitigation fee program.
The mitigation impact fee would allow new development to mitigate VMT impacts by making "fair share" payments into a mitigation bank to cover the cost of the identified VMT-reducing projects in the proposed VMT Reduction Program. The VMT Reduction Program would identify relevant transportation demand management strategies and VMT-reducing projects within the City of Fresno to be funded by mitigation fees from developments that trigger potentially significant VMT impacts under CEQA Potential VMT-reducing measures may include active transportation improvements, multi-modal transportation programs, and improved street connectivity, including bicycle, pedestrian, and transit facilities. The Program intends to streamline the Senate Bill 7 43 compliance process for development projects while funding future VMT improvement projects.
Location: The proposed Program will apply to development within the city limits of Fresno. The City of Fresno is located in Fresno County and covers an area of approximately 113 square miles. To the north of Fresno is Madera County, to the northeast and adjacent to Fresno, is the City of Clovis. Unincorporated land is located to the east, south, and west of Fresno.
COMMENTS AND RECOMMENDATIONS
CDFW offers the following comments and recommendations to assist the City of Fresno in adequately identifying and/or mitigating the Program's significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources.
Editorial comments or other suggestions may also be included to improve the DEIR prepared for this Program.
CDFW previously commented on the Notice of Preparation for this Program on October 29, 2024, with recommendations related to species habitat assessments and surveys, cumulative impacts analyses, CEQA alternative analysis, federally listed species consultation, botanical surveys, nesting birds, and the potential need to notify for potential impacts to streams pursuant to Fish and Game Code section 1600 et seq.
Comment Letter A2
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Docusign Envelope ID: F8596550-DEFE-4D43-89AA..a118FED6864E Sophia Pagoulatos, Planning Manager
City of Fresno
August 20, 2025
Special-Status Species
Aerial imagery and species occurrence records from the California Natural Diversity Database (CNDDB) (CDFW 2025), CDFWs familiarity with biological resources in the Program area, and given that the Program encompasses the entirety of the city limits of Fresno, potential impacts to special-status species exists and should be analyzed during review of projects arising from the VMT Program. CDFW concurs with the content of Table 4.4.A and 4.4.B included in Section 4.4 of the DEIR for the Program which lists special-status plant and wildlife species within the Project vicinity. As noted in the analysis and repeated throughout the Project Impacts subsection, these biological resources would need to be evaluated and addressed as part of any project-specific reviews and approvals.
Additionally, CDFW agrees with the methodology that future potential projects should be analyzed on a project-specific basis for potential biological resources impacts with site specific information and implement measurable mitigation measures that would reduce impacts to less than significant levels as needed.
Biological mitigation measure 810-1 states that transportation improvement projects funded by the proposed Program subject to CEQA review and with the potential to reduce or eliminate habitat for native plant and wildlife species or sensitive habitats shall provide a Biological Resources Assessment (BRA). Biological mitigation measure 810-4 states that pre-construction nesting bird clearance surveys will be conducted no more than 14 days prior to the start of any vegetation removal or ground disturbing activities.
CDFW concurs with this methodology as appropriate for the majority of potential projects that are expected to occur within existing disturbed rights-of-way in developed areas; however, CDFW recommends strengthening the narrative in BIO-1 and BIO-4 by including species-specific protocol-level surveys as part of the BRA and pre- construction surveys, when appropriate. The additional site-specific evaluation will ensure that potential impacts from projects that occur outside of the existing rights-of way areas are eliminated or minimized.
California Endangered Species Act
Reasonably foreseeable future projects tiered from this Program may be subject to CDFWs regulatory authority pursuant to the California Endangered Species Act (CESA). In the event that species listed under CESA are detected during surveys, consultation with CDFW is warranted to discuss how to implement the project and avoid "take," or if avoidance is not feasible, to acquire a State ITP, pursuant to Fish and Game Code section 2081 subdivision (b), prior to any ground disturbing activities. In addition, CDFW recommends that mitigation measures for the CESA listed species be fully addressed in the CEQA document prepared for any future project tiered from this Program.
Comment Letter A2
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Docusign Envelope ID: F8596550-DEFE-4D43-89AA-8118FED6864E Sophia Pagoulatos, Planning Manager
City of Fresno
August 20, 2025
California Natural Diversity Database (CNDDB}
Please note that the CNDDB is populated by voluntary submissions of species detections. As a result, species may be present in locations not depicted in the CNDDB but where there is suitable habitat and features capable of supporting species. A lack of an occurrence record, or lack of recent occurrence records, in the CNDDB does not mean that a species is not present. All projects tiered from this Program should adequately assess any potential project-related impacts to biological resources by ensuring biological surveys are conducted by a qualified wildlife biologist during the appropriate survey period(s) and using the appropriate protocol survey methodology as warranted in order to determine whether or not any special-status species are present at or near the project area.
Federally Listed Species
CDFW recommends projects tiered from this Program consult with the USFWS on potential impacts to federally listed species. Take under the Federal Endangered Species Act (ESA) is more broadly defined than CESA; take under the ESA also includes significant habitat modification or degradation that could result in death or injury to a listed species by interfering with essential behavioral patterns such as breeding, foraging, or nesting. Consultation with the USFWS is advised well in advance of any ground disturbing activities.
Lake and Streambed Alteration
Reasonably foreseeable future projects tiered from this Program may be subject to CDFWs regulatory authority pursuant to Fish and Game Code section 1600 et seq.
Fish and Game Code section 1602 requires project proponents to notify CDFW prior to commencing any activity that may (a) substantially divert or obstruct the natural flow of any river, stream, or lake; (b) substantially change or use any material from the bed, bank, or channel of any river, stream, or lake; or (c) deposit debris, waste or other materials that could pass into any river, stream, or lake. "Any river, stream, or lake" includes those that are ephemeral or intermittent as well as those that are perennial in nature. For additional information on notification requirements, please contact our staff in the Lake and Stream Alteration Program at (559) 243-4593, or [email protected].
CDFW therefore recommends that the FEIR for this Program include information related to these requirements of Fish and Game code and advise that projects tiered from this Program retain a qualified biologist to determine if potential impacts to streams may require the need to notify pursuant to Fish and Game Code section 1602.
Comment Letter A2
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Comment Letter A2
A2-10
A2-11
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Docusign Envelope ID: F8596550-DEFE-4043-89AA-8118FED6864E Sophia Pagoulatos, Planning Manager
City of Fresno
August 20, 2025
REFERENCES
California Department of Fish and Wildlife. 2025. Biogeographic information and observation system (BIOS). https://www.wildlife.ca.gov/Data/BIOS. Accessed 5 August 2025.
Comment Letter A2
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August 6, 2025
Sophia Pagoulatos
City of Fresno
Planning and Development Department
2600 Fresno Street, Room 3043
Fresno, CA 93721
Project: Draft Environmental Impact Report for the Vehicle Miles Traveled Reduction Program
District CEQA Reference No: 20250761
Dear Ms. Pagoulatos:
The San Joaquin Valley Air Pollution Control District (District) has reviewed the Draft Environmental Impact report (DEIR) from the City of Fresno (City) for the Vehicle Miles Traveled (VMT) Reduction Program. Per the DEIR, the project consists of the establishment of a VMT Reduction Program intended to reduce Citywide VMT by establishing mitigation for future development projects in Fresno through developing an Urban Design Calculator that estimates potential VMT reductions for development projects through incorporation of various design elements and the use of a mitigation fee which would be used to fund VMT reducing projects throughout the City (Project).
The Project covers development projects in Fresno, California. The Project includes area within one of the communities in the state selected by the California Air Resources Board (CARB) for investment of additional air quality resources and attention under Assembly Bill (AB) 617 (Garcia) in an effort to reduce air pollution exposure in impacted disadvantaged communities. See Figure 1 below.
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Figure 1: Boundary of the South Central Fresno AB617 Community The District offers the following comments at this time regarding the Project:
Ongoing Commitment to Strengthen Working Relationship
The District appreciates the City’s ongoing commitment to strengthen the working relationship with the District, in identifying and mitigating impacts on air quality through the California Environmental Quality Act (CEQA) review process.
Consistent with this cooperative effort and in order to address air quality impacts and concerns prior to future development projects occurring, the District recommends that the City develop administrative mechanisms and policies that ensure consistency in providing the District with information about projects under consideration by the City, such as land use designation, project size, and proximity to sensitive receptors and existing emission sources. To aid the City in determining a project’s potential impacts, the District recommends the City provide an assessment evaluating potential project construction and operation related to air quality impacts to the District as early as possible. Additionally, the District is Letter B1
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San Joaquin Valley Air Pollution Control District Page 3 of 6 District Reference No: 20250761
August 6, 2025
available to work with the City and project applicants on future development projects to address air quality impacts and concerns. The District encourages the City to include guidance in relevant planning documents or development review procedures that advises project applicants to reach out and work with the District. The District’s goal is to assist with enhancing project designs in the early stages of the planning process for a better overall project with minimized impact on air quality and early identification of feasible mitigation measures.
Operational Funding Strategy
Nearly all development projects within the San Joaquin Valley Air Basin, from program-level to individual projects have the potential to generate air pollutants, making it more difficult to attain state and federal ambient air quality standards.
Land use decisions are critical to improving air quality within the San Joaquin Valley Air Basin because land use patterns greatly influence transportation needs, and motor vehicle emissions are the largest source of air pollution in the Valley. Land use decisions and project design elements such as preventing urban sprawl, encouraging mix-use development, and project design elements that reduce vehicle miles traveled (VMT) have proven to be beneficial for air quality. The District acknowledges that the Project will be incorporating strategies that reduce VMTs and the District recommends that the Project incorporate strategies that require the cleanest available heavy duty trucks, vehicles, and off-road equipment, including zero and near-zero technologies. VMTs can be reduced through encouragement of mix-use development, walkable communities, etc. Additional design element options can be found at:
https://ww2.valleyair.org/media/ob0pweru/clean-air-measures.pdf In addition, the District recommends that the Project incorporate strategies that will advance implementation of the best practices listed in Tables 5 and 6 of California Air Resource Board’s (CARB’s) Freight Handbook Concept Paper, to the extent feasible. This document compiles best practices designed to address air pollution impacts as “practices” which may apply to the siting, design, construction, and operation of freight facilities to minimize health impacts on nearby communities. The concept paper is available at:
https://ww2.arb.ca.gov/sites/default/files/2020-03/2019.12.12%20- %20Concept%20Paper%20for%20the%20Freight%20Handbook_1.pdf Project Siting
The Project is intended to supplement the blueprint for future growth and provides guidance for the community’s development. Without appropriate mitigation and associated policy, future development projects within the City may contribute to negative impacts on air quality due to increased traffic and ongoing operational emissions. Appropriate project siting helps ensure there is adequate distance between differing land uses, which can prevent or reduce localized and cumulative Letter B1
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Cont.
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San Joaquin Valley Air Pollution Control District Page 4 of 6 District Reference No: 20250761
August 6, 2025
air pollution impacts from business operations that are in close proximity to receptors (e.g., residences, schools, health care facilities, etc.). The Project’s siting-related goals, policies, and objectives should include measures and concepts outlined in the following resources:
• CARB’s Air Quality and Land Use Handbook: A Community Health Perspective. The document includes tables with recommended buffer distances associated with various types of common sources (e.g., distribution centers, chrome platers, gasoline dispensing facilities, etc.), and can be found at: https://ww2.arb.ca.gov/our-work/programs/resource-center/strategy- development/land-use-resources
• CARB’s Freight Handbook Concept Paper: This document compiles best practices designed to address air pollution impacts, which may apply to the siting, design, construction, and operation of freight facilities to minimize health impacts on nearby communities, and can be found at:
https://ww2.arb.ca.gov/sites/default/files/2020-03/2019.12.12%20- %20Concept%20Paper%20for%20the%20Freight%20Handbook_1.pdf Assembly Bill 617
AB 617 requires CARB and air districts to develop and implement Community Emission Reduction Programs (CERPs) in an effort to reduce air pollution exposure in impacted disadvantaged communities, like those in which the Project is located.
The South Central Fresno AB 617 community is one of the statewide communities selected by CARB for development and implementation of a CERP.
Following extensive community engagement and collaboration with the Community Steering Committee, the CERP for the South Central Fresno Community was adopted by the District’s Governing Board in September 2019 and by CARB in February 2020.
During the development of the CERP, the Community Steering Committee expressed concerns regarding the proximity of emission sources to nearby sensitive receptors like schools, homes, day care centers, and hospitals, and the potential future industrial development within the community that may exacerbate the cumulative exposure burden for community residents. The Community Steering Committee also expressed the desire for more meaningful avenues of engagement surrounding the land-use decisions in the area. As these issues can most effectively be addressed through strong partnerships between community members and local land-use agencies.
For more information regarding the CERP approved for South Central Fresno, please visit the District’s website at:
https://community.valleyair.org/selected-communities/south-central-fresno Letter B1
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Cont.
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San Joaquin Valley Air Pollution Control District Page 5 of 6 District Reference No: 20250761
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Truck Routing
Truck routing involves the assessment of which roads Heavy Heavy-Duty (HHD) trucks take to and from their destination, and the emissions impact that the HHD trucks may have on residential communities and sensitive receptors.
The District recommends the City evaluate HHD truck routing patterns for future development projects, with the aim of limiting exposure of residential communities and sensitive receptors to emissions. This evaluation would consider the current truck routes, the quantity and type of each truck (e.g., Medium Heavy-Duty, HHD, etc.), the destination and origin of each trip, traffic volume correlation with the time of day or the day of the week, overall Vehicle Miles Traveled (VMT), and associated exhaust emissions. The truck routing evaluation would also identify alternative truck routes and their impacts on VMT and air quality.
Electric Infrastructure
To support and accelerate the installation of electric vehicle charging equipment and development of required infrastructure, the District offers incentives to public agencies, businesses, and property owners of multi-unit dwellings to install electric charging infrastructure (Level 2 and 3 chargers). The purpose of the District’s Charge Up! Incentive program is to promote clean air alternative-fuel technologies and the use of low or zero-emission vehicles. The District recommends that the City and project proponents install electric vehicle chargers at project sites, and at strategic locations.
Please visit https://ww2.valleyair.org/grants/charge-up for more information.
District’s Bikeway Incentive Program
Incorporating design elements (e.g., installing bikeways) within the Project area that enhance walkability and connectivity can result in an overall reduction of VMT and improve air quality within the area. The Bikeway Incentive Program provides funding for eligible Class 1 (Bicycle Path Construction), Class II (Bicycle Lane Striping), or Class III (Bicycle Route) projects. These incentives are designed to support the construction of new bikeway projects to promote clean air through the development of a widespread, interconnected network of bike paths, lanes, or routes and improving the general safety conditions for commuter bicyclists. Only municipalities, government agencies, or public educational institutions are eligible to apply. More information on the grant program can be found at:
https://ww2.valleyair.org/grants/bike-paths/
Guidelines and Project Eligibility for the grant program can be found at:
https://ww2.valleyair.org/media/drpijuw1/bikeway-program-guidelines-62515.pdf Letter B1
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San Joaquin Valley Air Pollution Control District Page 6 of 6 District Reference No: 20250761
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Future Projects / Land Use Agency Referral Documents
The DEIR states that all future individual VMT reducing improvement projects within Fresno, including those implemented as part of development projects, would require separate environmental review under CEQA. The District recommends future project referral documents and environmental review documents provided to the District for review should include a project summary, the land use designation, project size, air emissions quantifications and impacts, and proximity to sensitive receptors and existing emission sources, and air emissions mitigation measures.
For reference and guidance, more information can be found in the District’s Guidance for Assessing and Mitigating Air Quality Impacts at:
https://ww2.valleyair.org/media/g4nl3p0g/gamaqi.pdf
If you have any questions or require further information, please contact Michael Corder by e-mail at [email protected] or by phone at (559) 230-5818.
Sincerely,
Mark Montelongo
Director of Policy and Government Affairs
Daniel Martinez
Program Manager
Letter B1
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Plan Review Team
Land Management
[email protected]
PG&E Gas and Electric Facilities Page 1
Internal
July 7, 2025
Sophia P
agoulatos
Planning Manager
2600 Fresno Street
Fresno, CA 93721
Ref: Ga
s and Electric Transmission and Distribution
Dear Sophi
a Pagoulatos,
Thank you
for submitting the VMT Reduction project plans for our review. PG&E will review the submitted plans in relationship to any existing Gas and Electric facilities within the project area.
If the proposed project is adjacent/or within PG&E owned property and/or easements, we will be working with you to ensure compatible uses and activities near our facilities.
Att
ached you will find information and requirements as it relates to Gas facilities (Attachment 1) and Electric facilities (Attachment 2). Please review these in detail, as it is critical to ensure your safety and to protect PG&E’s facilities and its existing rights.
Below
is additional information for your review:
1. This pl
an review process does not replace the application process for PG&E gas or electric service your project may require. For these requests, please continue to work with PG&E Service Planning: https://www.pge.com/en/account/service- requests/building-and-renovation.html.
2. If t
he project being submitted is part of a larger project, please include the entire scope of your project, and not just a portion of it. PG&E’s facilities are to be incorporated within any CEQA document. PG&E needs to verify that the CEQA document will identify any required future PG&E services.
3. An engineer
ing deposit may be required to review plans for a project depending on the size, scope, and location of the project and as it relates to any rearrangement or new installation of PG&E facilities.
Any propos
ed uses within the PG&E fee strip and/or easement, may include a California Public Utility Commission (CPUC) Section 851 filing. This requires the CPUC to render approval for a conveyance of rights for specific uses on PG&E’s fee strip or easement. PG&E will advise if the necessity to incorporate a CPUC Section 851filing is required.
This l
etter does not constitute PG&E’s consent to use any portion of its easement for any purpose not previously conveyed. PG&E will provide a project specific response as required.
Sinc
erely,
Plan R
eview Team
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Comment Letter C1
PG&E Gas and Electric Facilities Page 2
Internal
Land Management
Letter C1
PG&E Gas and Electric Facilities Page 3
Internal
Attachment 1 – Gas Facilities
The
re could be gas transmission pipelines in this area which would be considered critical facilities for PG&E and a high priority subsurface installation under California law. Care must be taken to ensure safety and accessibility. So, please ensure that if PG&E approves work near gas transmission pipelines it is done in adherence with the below stipulations. Additionally, the following link provides additional information regarding legal requirements under California excavation laws: https://www.usanorth811.org/images/pdfs/CA-LAW-2018.pdf
1. S
tandby Inspection: A PG&E Gas Transmission Standby Inspector must be present during any demolition or construction activity that comes within 10 feet of the gas pipeline. This includes all grading, trenching, substructure depth verifications (potholes), asphalt or concret e
dem
olition/removal, removal of trees, signs, light poles, etc. This inspection can be coordinated t
hrough the Underground Service Alert (USA) service at 811. A minimum notice of 48 hours is required. Ensure the USA markings and notifications are maintained throughout the duration of your work.
2. A
ccess: At any time, PG&E may need to access, excavate, and perform work on the gas pipeline. Any construction equipment, materials, or spoils may need to be removed upon notice.
Any temporary construction fencing installed within PG&E’s easement would also need to be capable of being removed at any time upon notice. Any plans to cut temporary slopes exceeding a 1:4 grade within 10 feet of a gas transmission pipeline need to be approved by PG&E Pipeline Services in writing PRIOR to performing the work.
3. W
heel Loads: To prevent damage to the buried gas pipeline, there are weight limits that must be enforced whenever any equipment gets within 10 feet of traversing the pipe.
E
nsure a list of the axle weights of all equipment being used is available for PG&E’s Standby Inspector. To confirm the depth of cover, the pipeline may need to be potholed by hand in a few areas.
D
ue to the complex variability of tracked equipment, vibratory compaction equipment, and cranes, PG&E must evaluate those items on a case-by-case basis prior to use over the gas pipeline (provide a list of any proposed equipment of this type noting model numbers and specific attachments).
N
o equipment may be set up over the gas pipeline while operating. Ensure crane outriggers are at least 10 feet from the centerline of the gas pipeline. Transport trucks must not be parked over the gas pipeline while being loaded or unloaded.
4. G
rading: PG&E requires a minimum of 36 inches of cover over gas pipelines (or existing gr
ade if less) and a maximum of 7 feet of cover at all locations. The graded surface cannot exceed a cross slope of 1:4.
5. E
xcavating: Any digging within 2 feet of a gas pipeline must be dug by hand. Note that while the minimum clearance is only 24 inches, any excavation work within 24 inches of the edge of a pipeline must be done with hand tools. So to avoid having to dig a trench entirely with hand t
ools, the edge of the trench must be over 24 inches away. (Doing the math for a 24 inch Letter C1
PG&E Gas and Electric Facilities Page 4
Internal
wide trench being dug along a 36 inch pipeline, the centerline of the trench would need to be at least 54 inches [24/2 + 24 + 36/2 = 54] away, or be entirely dug by hand.) W
ater jetting to assist vacuum excavating must be limited to 1000 psig and directed at a 40° angle to the pipe. All pile driving must be kept a minimum of 3 feet away.
A
ny plans to expose and support a PG&E gas transmission pipeline across an open excavation need to be approved by PG&E Pipeline Services in writing PRIOR to performing the work.
6. B
oring/Trenchless Installations: PG&E Pipeline Services must review and approve all plans to bore across or parallel to (within 10 feet) a gas transmission pipeline. There are s
tringent criteria to pothole the gas transmission facility at regular intervals for all parallel bore installations.
For
bore paths that cross gas transmission pipelines perpendicularly, the pipeline must be potholed a minimum of 2 feet in the horizontal direction of the bore path and a minimum of 24 inches in the vertical direction from the bottom of the pipe with minimum clearances measured from the edge of the pipe in both directions. Standby personnel must watch the locator trace (and every ream pass) the path of the bore as it approaches the pipeline and visually monitor the pothole (with the exposed transmission pipe) as the bore traverses the pipeline to ensure adequate clearance with the pipeline. The pothole width must account for the inaccuracy of the locating equipment.
7. S
ubstructures: All utility crossings of a gas pipeline should be made as close to perpendicular as feasible (90° +/- 15°). All utility lines crossing the gas pipeline must have a minimum of 24 inches of separation from the gas pipeline. Parallel utilities, pole bases, water line ‘kicker blocks’, storm drain inlets, water meters, valves, back pressure devices or other utility substructures are not allowed in the PG&E gas pipeline easement.
I
f previously retired PG&E facilities are in conflict with proposed substructures, PG&E must verify they are safe prior to removal. This includes verification testing of the contents of the facilities, as well as environmental testing of the coating and internal surfaces. Timelines for PG&E completion of this verification will vary depending on the type and location of facilities in conflict.
8. S
tructures: No structures are to be built within the PG&E gas pipeline easement. This includes buildings, retaining walls, fences, decks, patios, carports, septic tanks, storage sheds, tanks, loading ramps, or any structure that could limit PG&E’s ability to access its facilities.
9. Fenc
ing: Permanent fencing is not allowed within PG&E easements except for perpendicular crossings which must include a 16 foot wide gate for vehicular access. Gates will be secured with PG&E corporation locks.
10. Lands
caping: Landscaping must be designed to allow PG&E to access the pipeline for maintenance and not interfere with pipeline coatings or other cathodic protection systems. No t
rees, shrubs, brush, vines, and other vegetation may be planted within the easement area.
Only those plants, ground covers, grasses, flowers, and low-growing plants that grow unsupported to a maximum of four feet (4’) in height at maturity may be planted within the eas
ement area.
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11. Cathodic Protection: PG&E pipelines are protected from corrosion with an “Impressed Current” cathodic protection system. Any proposed facilities, such as metal conduit, pipes, service lines, ground rods, anodes, wires, etc. that might affect the pipeline cathodic protection system must be reviewed and approved by PG&E Corrosion Engineering.
12. Pi
peline Marker Signs: PG&E needs to maintain pipeline marker signs for gas transmission pipelines in order to ensure public awareness of the presence of the pipelines.
With prior written approval from PG&E Pipeline Services, an existing PG&E pipeline marker sign that is in direct conflict with proposed developments may be temporarily relocated to accommodate construction work. The pipeline marker must be moved back once construction is complete.
13. PG&E is also the provider of distribution facilities throughout many of the areas within the state of California. Therefore, any plans that impact PG&E’s facilities must be reviewed and approved by PG&E to ensure that no impact occurs which may endanger the safe operation of its facilities.
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A
ttachment 2 – Electric Facilities
It i
s PG&E’s policy to permit certain uses on a case by case basis within its electric transmission fee strip(s) and/or easement(s) provided such uses and manner in which they are exercised, will not interfere with PG&E’s rights or endanger its facilities. Some examples/restrictions are as follows:
1. B
uildings and Other Structures: No buildings or other structures including the foot print and eave of any buildings, swimming pools, wells or similar structures will be permitted within fee strip(s) and/or easement(s) areas. PG&E’s transmission easement shall be designated on s
ubdivision/parcel maps as “RESTRICTED USE AREA – NO BUILDING.”
2. G
rading: Cuts, trenches or excavations may not be made within 25 feet of our towers.
Developers must submit grading plans and site development plans (including geotechnical reports if applicable), signed and dated, for PG&E’s review. PG&E engineers must review grade changes in the vicinity of our towers. No fills will be allowed which would impair ground-to- conductor clearances. Towers shall not be left on mounds without adequate road access to bas
e of tower or structure.
3. Fenc
es: Walls, fences, and other structures must be installed at locations that do not affect the safe operation of PG&’s facilities. Heavy equipment access to our facilities must be maintained at all times. Metal fences are to be grounded to PG&E specifications. No wall, fence or other like structure is to be installed within 10 feet of tower footings and unrestricted access m
ust be maintained from a tower structure to the nearest street. Walls, fences and other structures proposed along or within the fee strip(s) and/or easement(s) will require PG&E review; submit plans to PG&E Centralized Review Team for review and comment.
4. Lands
caping: Vegetation may be allowed; subject to review of plans. On overhead electric transmission fee strip(s) and/or easement(s), plant only low-growing shrubs under the wire zone and onl
y grasses within the area directly below the tower. Along the border of the transmission l
ine right-of-way, plant only small trees no taller than 10 feet in height at maturity. PG&E must have access to its facilities at all times, including access by heavy equipment. No planting is to occur within the footprint of the tower legs. Greenbelts are encouraged.
5. R
eservoirs, Sumps, Drainage Basins, and Ponds: Prohibited within PG&E’s fee strip(s) and/or easement(s) for electric transmission lines.
6. A
utomobile Parking: Short term parking of movable passenger vehicles and light trucks (pickups, vans, etc.) is allowed. The lighting within these parking areas will need to be reviewed by
PG&E; approval will be on a case by case basis. Heavy equipment access to PG&E facilities is to be maintained at all times. Parking is to clear PG&E structures by at least 10 feet.
Protection of PG&E facilities from vehicular traffic is to be provided at developer’s expense AND t
o PG&E specifications. Blocked-up vehicles are not allowed. Carports, canopies, or awnings are not allowed.
7. S
torage of Flammable, Explosive or Corrosive Materials: There shall be no storage of fuel or combustibles and no fueling of vehicles within PG&E’s easement. No trash bins or incinerators are allowed.
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PG&E Gas and Electric Facilities Page 7
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8. St
reets and Roads: Access to facilities must be maintained at all times. Street lights may be allowed in the fee strip(s) and/or easement(s) but in all cases must be reviewed by PG&E for proper clearance. Roads and utilities should cross the transmission easement as nearly at right angles as possible. Road intersections will not be allowed within the transmission easement.
9. Pi
pelines: Pipelines may be allowed provided crossings are held to a minimum and to be as nearly perpendicular as possible. Pipelines within 25 feet of PG&E structures require review by PG&E. Sprinklers systems may be allowed; subject to review. Leach fields and septic tanks are not allowed. Construction plans must be submitted to PG&E for review and approval prior to the commencement of any construction.
10. Si
gns: Signs are not allowed except in rare cases subject to individual review by PG&E.
11. Rec
reation Areas: Playgrounds, parks, tennis courts, basketball courts, barbecue and light trucks (pickups, vans, etc.) may be allowed; subject to review of plans. Heavy equipment access to PG&E facilities is to be maintained at all times. Parking is to clear PG&E structures by at least 10 feet. Protection of PG&E facilities from vehicular traffic is to be provided at developer’s expense AND to PG&E specifications.
12. Cons
truction Activity: Since construction activity will take place near PG&E’s overhead electric lines, please be advised it is the contractor’s responsibility to be aware of, and observe the minimum clearances for both workers and equipment operating near high voltage electric lines set out in the High-Voltage Electrical Safety Orders of the California Division of Industrial Safety (https://www.dir.ca.gov/Title8/sb5g2.html), as well as any other safety regulations.
Contractors shall comply with California Public Utilities Commission General Order 95 (http://www.cpuc.ca.gov/gos/GO95/go_95_startup_page.html) and all other safety rules. No construction may occur within 25 feet of PG&E’s towers. All excavation activities may only commence after 811 protocols has been followed.
Cont
ractor shall ensure the protection of PG&E’s towers and poles from vehicular damage by (installing protective barriers) Plans for protection barriers must be approved by PG&E prior to construction.
13. PG
&E is also the owner of distribution facilities throughout many of the areas within the state of California. Therefore, any plans that impact PG&E’s facilities must be reviewed and approved by PG&E to ensure that no impact occurs that may endanger the safe and reliable operation of its facilities.
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