Cities Index.
Agenda packet

City Council and Authorities Concurrent
October 8, 2024

Document
Agenda packet
Meeting
October 8, 2024
Body
City Council and Authorities Concurrent
Pages
174
Original file
47.2 MB
Text extracted from the city's file for reading and search. Open the original on santaclara.legistar.com. That file is the official record.

discussions with several real estate agents in the region, I have unanimously found all to agree that the real estate values of residences in close proximity to power lines goes down. Its hard to find potential buyers and most folks refrain from buying a house too close to high power transmission lines. There are 1000 plus residences in the area affected by this project. Even if we were to make very rough assumptions, and assume minimal cost reduction in property values and take an average loss of H-353
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
$100,000 per property in the current year, that goes to $100,000,000 of loss of equity to the public. This is not even accounting the businesses affected by this project. This long explanation was to raise a point that if the selection of route A was saving money to the city, this is costing a huge financial loss to the public, which is not acceptable. This decrease in property values will also directly impact the tax collection by the Santa Clara Assessor and result in lower tax revenue coming into the city of Santa Clara.

Reference #5 : Page 49 of report- Figure 5.1-2. Wall separating residences and Lafayette Street.

Personal observation#5: The picture is taken conveniently from the other side of the railway line which is actually Kingsbury street, inside a private community and not Lafayette street. This is further away from the proposed SVP lines. This is very misleading; see snapshots taken from Google maps below

H-354
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
And this is what is included on the report:

The Mission Garden Townhome community has no walls as such and the main entry to residences face the road directly and are the most impacted. There are several other single family homes on Lafayette street with the same impact, having an entryway directly on the street. This and including other citations of reusing sections of older reports, is all in all absolutely unacceptable and instills distrust. This further shows incompetency of the agency/ agencies preparing this report.

Conclusion: This project's initial study needs to expand beyond CEQA for approval from the public. The limited scope of CEQA has failed to address the following concerns we have:
• Health hazards due to EMF levels.- This is by far the gravest concern and CEQA is clearly not qualified to study that.
• Reduced property values- several references provided below. • Loss of Aesthetic appeal for potential real estate buyers/ new and current businesses. • Increase in audible noise levels during and post construction, which is already high in the area with presence of railway line and air traffic route. • Increased fire hazard/ risk of other accidents.
• Induced current on railway lines with close proximity/ corona effect- CEQA report did not clearly address this for a 115KV line.
• Economic effect on the community from small to larger scale based on all of the above.

We demand further investigation and revisit other routes or proposals to resolve the power needs of the city. We have to ensure our and our kids’ health is not at stake in the name of development and infrastructure and are not in agreement for this project to move forward. We cannot approve this to move forward as of now given the lack of study and absence of a satisfactory solution/ mitigation provided in favor/ assurance to public health.

Additional References:

H-355

5.1. Alm.TIG
Figure S.1-2. Wall Separating Residences and Lafayette Street W I S.parot,ng RHldtOUI ond ufayotll Si,-
Juu202• S.1-S ~TM:Dwl MND/IS
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Research on effects of EMF on humans:

1. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6025786/ This research reinforces the concerns of EMF exposure effect on human health.

2. https://www.epa.gov/radtown/electric-and-magnetic-fields-power-lines This resource suggests taking precautions and keeping distance or limiting exposure. Residents would no longer have either of these two options per the current proposals if they are living there 24-7.

3. https://www.fastexpert.com/blog/should-i-buy-a-house-near-power-lines/ These are points of view from a real estate expert who clearly states that property value declines proportionately to the distance of the property from high tension lines. People have apprehensions whether or not research clearly defines the risk. Potential buyers might have low priority for a property too close to a high tension power line.

4. https://orchard.com/blog/posts/power-lines-and-property-value Another research on real estate values lowered due to high tension power lines proximity.

Thank you,
Venkat Patchigolla
2102 Payne Pl, Santa Clara, CA-95054

H-356
at You Can Do
If you are concerned abo ut possible health risks from electric and magnet ic fields, you can:
• Increase the distance between yourself and the source. The greater the distance between you and the source of EMF, the lower your exposure.
• Limit the time spent around the source. The less t ime you spend near EMF, th e lower your NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: Aparna Raman <[email protected]>
Sent: Thursday, August 29, 2024 7:31 PM
To: NRS-KRS Project; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community for the upcoming SVP project connecting the Northern Receiving Station NRS to Kifer receiving station (KRS)- NRS-KRS 115kV Transmission Line Project

To Whomsoever it may concern,
We are residents of Santa Clara that will be negatively impacted by the “NRS-KRS 115kV Transmission Line Project”. We have collectively reviewed the draft Initial Study/ Mitigated Negative declaration for “NRS-KRS 115kV Transmission Line Project” from July 2024. After reviewing this report and also attending the virtual and in person meetings, here are some references to emphasize our various concerns.

Reference #1 : CEQA’s reporting includes these State reviewing agencies: California Air Resources Board (ARB), California Department of Fish and Wildlife, Bay Delta Region 3 (CDFW), California Department of Forestry and Fire Protection (CAL FIRE), California Department of Parks and Recreation, California Department of Toxic Substances Control (DTSC), California Department of Transportation, District 4 (DOT), California Department of Transportation, Division of Aeronautics (DOT), California Department of Transportation, Division of Transportation Planning (DOT), California Department of Water Resources (DWR), California Energy Commission, California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Public Utilities Commission (CPUC), California Regional Water Quality Control Board, San Francisco Bay Region 2 (RWQCB), Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water.

Personal observation#1 : None of these agencies has any association with human health. CEQA reporting is not qualified enough to force the public to compromise on health concerns. Other agencies need to be involved to review this proposal, that are qualified to study the effect on “ humans”, not just wildlife and vegetation, or “ environment. The checklist is completely devoid of our gravest humanitarian concerns. It is quite shocking that the project has not included any study to understand the potential impact of EMF waves on human lives, given that the transmission lines are potentially less than 60 feet from the closest dwellings. The city of Santa Clara needs to step in and have third party/ independent studies completed in favor of human health.

Reference #2: Page 41 of report- Section 4.15. Electric and Magnetic Fields summary.

Personal observation#2 : This consideration was completely absent earlier. Only after the residents raised their voices, this section was added. To our greatest disappointment, this section is copied over from an older report on the “South Loop Reconfiguration Project” from 2020. One would have expected that a new study would have been conducted for a project this size. The lack of due diligence and ignorance towards the specifics of this project are apparent and not acceptable. In fact we have found several sections of this older report as being reused across the entire report.

The EMP map shared during the in person meeting had several flaws and we would like to question the viability of the study that was completed. What time of the day was the study completed and on what models were the values based on since these were done on assumption for the EMF values that would H-357
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
be there once the project is complete. Since we have seen the several sections of the report redundantly copied over from other reports, we would like a more detailed analysis of this report.

Regarding EMF concerns for human health, there are plenty of scientific studies that do indicate the grave concern on human health with EMF exposures and we cannot ignore this aspect. Here is a reference to an article and there are plenty of articles listed here under references:
https://psc.wi.gov/Documents/Brochures/EMF.pdf

There are not enough references listed in the draft report provided to us, and the explanation provided seems to be conveniently using studies that prove otherwise. This needs more investigation and references. The solution provided as raising the height of the poles and increasing the distance is non- existent. It was confirmed during the in person meeting that the design will not be altered and the height was already designed as required according to the SVP team present there. It seems that the preparers of this report did not even read the report after copying pasting from the old report as evident in the list of proposed solutions is not applicable here.

The live presentation on August 22nd showed the comparison of EMF values of household objects as a means to show that everyday household items carry a similar range of mG( milli Gauss) units. This comparison was inherently flawed since it mentioned that the household devices were producing those level at 1 feet while those indicated for 115KVf lines were at 60 feet. further these household devices do not operate 24X7 similar to the transmission lines.

There were a lot of citations of reports showcasing that no clear proof of EMF to human health exists but we would like to also point out certain states like Connecticut Department of Public Health have cited reports that have shown an increased incidence of childhood leukemia( Blood cancer) at avg exposure of only 3 mG. Also they have called out that some utility workers exposed to high levels of emf have increase risks of Lur Gehrig's disease.

They also call out that most impacts of EMF from high voltage lines dissipate at ~300 feet.

These are available on Page 2 & Page 3 of this report: https://portal.ct.gov/-/media/departments- and-agencies/dph/dph/environmental_health/eoha/pdf/emffactsheet2008pdf.pdf This report has citations from WHO , National Institute of Environmental Health Sciences and California Department of Health Services.
https://www.niehs.nih.gov/sites/default/files/health/materials/electric_and_magnetic_fields_associ ated_with_the_use_of_electric_power_questions_and_answers_english_508.pdf

Reference #3

Page 174 ends

Personal observation#3
The railway line's proximity to the proposed high transmission lines is very concerning. The centerline distance from proposed lines to railway line is aproximately 50 feet per google maps with some margin for error. As per the report there are no Corona rings proposed for the 115KV lines. There seems to be negligence in design in consideration of the hazards posed by these high voltage lines as Corona effect can transfer current to railway lines. All the residents are at a high risk of accidental hazards given the proximity of the railway line, this project is adding on to the hazards. This section is only stating information about what Corona effect is, as may be required by law, which by the way is again a copy paste from an old report. The only concern discussed in more depth is the audible noise level. The concerns are presented to imply that this is not significant by stating that 115KV lines pose less than significant risk.

H-358
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

Reference #4: Post meeting material from March 19th 2024 @https://santaclara.legistar.com/LegislationDetail.aspx?ID=6582415&GUID=E6E14646-3CF7-4D15- BB98-F18580696012&Options=&Search=
Personal observation#4: At surface level, it looks like Option #A was selected only based on Cost perspective, without any consideration to human health, young children, property values, Corona effect, long term sustainability perspective or any other factors. While its important to understand the results of CEQA study, its extremely critical to understand the negative impact of EMF on the many young children living around the proposed transmission lines. Without extensive research and study on the impact to young children and adult heath, we should not be approving such an incomplete proposal.

Page 6 ends

discussions with several real estate agents in the region, I have unanimously found all to agree that the real estate values of residences in close proximity to power lines goes down. Its hard to find potential buyers and most folks refrain from buying a house too close to high power transmission lines. There are 1000 plus residences in the area affected by this project. Even if we were to make very rough assumptions, and assume minimal cost reduction in property values and take an average loss of $100,000 per property in the current year, that goes to $100,000,000 of loss of equity to the public. This is not even accounting the businesses affected by this project. This long explanation was to raise a point that if the selection of route A was saving money to the city, this is costing a huge financial loss to the public, which is not acceptable. This decrease in property values will also directly impact the tax collection by the Santa Clara Assessor and result in lower tax revenue coming into the city of Santa Clara.

Reference #5 : Page 49 of report- Figure 5.1-2. Wall separating residences and Lafayette Street.

Personal observation#5: The picture is taken conveniently from the other side of the railway line which is actually Kingsbury street, inside a private community and not Lafayette street. This is further away from the proposed SVP lines. This is very misleading; see snapshots taken from Google maps below

And this is what is included on the report:

The Mission Garden Townhome community has no walls as such and the main entry to residences face the road directly and are the most impacted. There are several other single family homes on Lafayette street with the same impact, having an entryway directly on the street. This and including other citations of reusing sections of older reports, is all in all absolutely unacceptable and instills distrust. This further shows incompetency of the agency/ agencies preparing this report.

Conclusion: This project's initial study needs to expand beyond CEQA for approval from the public. The limited scope of CEQA has failed to address the following concerns we have:
• Health hazards due to EMF levels.- This is by far the gravest concern and CEQA is clearly not qualified to study that.
• Reduced property values- several references provided below. • Loss of Aesthetic appeal for potential real estate buyers/ new and current businesses. • Increase in audible noise levels during and post construction, which is already high in the area with presence of railway line and air traffic route. • Increased fire hazard/ risk of other accidents.
• Induced current on railway lines with close proximity/ corona effect- CEQA report did not clearly address this for a 115KV line.
• Economic effect on the community from small to larger scale based on all of the above.

H-359
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
We demand further investigation and revisit other routes or proposals to resolve the power needs of the city. We have to ensure our and our kids’ health is not at stake in the name of development and infrastructure and are not in agreement for this project to move forward. We cannot approve this to move forward as of now given the lack of study and absence of a satisfactory solution/ mitigation provided in favor/ assurance to public health.

Thank you for your time.

Best regards,
Aparna Raman
4126086258

Aparna

H-360
at You Can Do
If you are concerned about possible health risks from electric and magnetic fields, you can:
• Increase the distance between yourself and the sou rce. The greater t he distance between you and the source of EMF, the lower your exposure.
• Limit the time spent around the source. The less time you spend near EMF, the lowe r your NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: Gayathiri Lakshmanan <[email protected]> Sent: Thursday, August 29, 2024 7:04 PM
To: NRS-KRS Project; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community for the upcoming SVP project connecting the Northern Receiving Station NRS to Kifer receiving station (KRS)- NRS-KRS 115kV Transmission Line Project

To Whomsoever it may concern,
We are residents of Santa Clara that will be negatively impacted by the “NRS-KRS 115kV Transmission Line Project”. We have collectively reviewed the draft Initial Study/ Mitigated Negative declaration for “NRS-KRS 115kV Transmission Line Project” from July 2024. After reviewing this report and also attending the virtual and in person meetings, here are some references to emphasize our various concerns.

Reference #1 : CEQA’s reporting includes these State reviewing agencies: California Air Resources Board (ARB), California Department of Fish and Wildlife, Bay Delta Region 3 (CDFW), California Department of Forestry and Fire Protection (CAL FIRE), California Department of Parks and Recreation, California Department of Toxic Substances Control (DTSC), California Department of Transportation, District 4 (DOT), California Department of Transportation, Division of Aeronautics (DOT), California Department of Transportation, Division of Transportation Planning (DOT), California Department of Water Resources (DWR), California Energy Commission, California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Public Utilities Commission (CPUC), California Regional Water Quality Control Board, San Francisco Bay Region 2 (RWQCB), Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water.

Personal observation#1 : None of these agencies has any association with human health. CEQA reporting is not qualified enough to force the public to compromise on health concerns. Other agencies need to be involved to review this proposal, that are qualified to study the effect on “ humans”, not just wildlife and vegetation, or “ environment. The checklist is completely devoid of our gravest humanitarian concerns. It is quite shocking that the project has not included any study to understand the potential impact of EMF waves on human lives, given that the transmission lines are potentially less than 60 feet from the closest dwellings. The city of Santa Clara needs to step in and have third party/ independent studies completed in favor of human health.

Reference #2: Page 41 of report- Section 4.15. Electric and Magnetic Fields summary.

Personal observation#2 : This consideration was completely absent earlier. Only after the residents raised their voices, this section was added. To our greatest disappointment, this section is copied over from an older report on the “South Loop Reconfiguration Project” from 2020. One would have expected that a new study would have been conducted for a project this size. The lack of due diligence and ignorance towards the specifics of this project are apparent and not acceptable. In fact we have found several sections of this older report as being reused across the entire report.

The EMP map shared during the in person meeting had several flaws and we would like to question the viability of the study that was completed. What time of the day was the study completed and on what models were the values based on since these were done on assumption for the EMF values that would be there once the project is complete. Since we have seen the several sections of the report redundantly copied over from other reports, we would like a more detailed analysis of this report.

Regarding EMF concerns for human health, there are plenty of scientific studies that do indicate the grave concern on human health with EMF exposures and we cannot ignore this aspect. Here is a reference to an article and there are plenty of articles listed here under references:
https://psc.wi.gov/Documents/Brochures/EMF.pdf
H-361
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

There are not enough references listed in the draft report provided to us, and the explanation provided seems to be conveniently using studies that prove otherwise. This needs more investigation and references. The solution provided as raising the height of the poles and increasing the distance is non- existent. It was confirmed during the in person meeting that the design will not be altered and the height was already designed as required according to the SVP team present there. It seems that the preparers of this report did not even read the report after copying pasting from the old report as evident in the list of proposed solutions is not applicable here.

The live presentation on August 22nd showed the comparison of EMF values of household objects as a means to show that everyday household items carry a similar range of mG( milli Gauss) units. This comparison was inherently flawed since it mentioned that the household devices were producing those level at 1 feet while those indicated for 115KVf lines were at 60 feet. further these household devices do not operate 24X7 similar to the transmission lines.

There were a lot of citations of reports showcasing that no clear proof of EMF to human health exists but we would like to also point out certain states like Connecticut Department of Public Health have cited reports that have shown an increased incidence of childhood leukemia( Blood cancer) at avg exposure of only 3 mG. Also they have called out that some utility workers exposed to high levels of emf have increase risks of Lur Gehrig's disease.

They also call out that most impacts of EMF from high voltage lines dissipate at ~300 feet.

These are available on Page 2 & Page 3 of this report: https://portal.ct.gov/-/media/departments-and- agencies/dph/dph/environmental_health/eoha/pdf/emffactsheet2008pdf.pdf This report has citations from WHO , National Institute of Environmental Health Sciences and California Department of Health Services.
https://www.niehs.nih.gov/sites/default/files/health/materials/electric_and_magnetic_fields_associated_wit h_the_use_of_electric_power_questions_and_answers_english_508.pdf

Reference #3

Page 174 ends

Personal observation#3
The railway line's proximity to the proposed high transmission lines is very concerning. The centerline distance from proposed lines to railway line is aproximately 50 feet per google maps with some margin for error. As per the report there are no Corona rings proposed for the 115KV lines. There seems to be negligence in design in consideration of the hazards posed by these high voltage lines as Corona effect can transfer current to railway lines. All the residents are at a high risk of accidental hazards given the proximity of the railway line, this project is adding on to the hazards. This section is only stating information about what Corona effect is, as may be required by law, which by the way is again a copy paste from an old report. The only concern discussed in more depth is the audible noise level. The concerns are presented to imply that this is not significant by stating that 115KV lines pose less than significant risk.

Reference #4: Post meeting material from March 19th 2024 @https://santaclara.legistar.com/LegislationDetail.aspx?ID=6582415&GUID=E6E14646-3CF7-4D15- BB98-F18580696012&Options=&Search=
Personal observation#4: At surface level, it looks like Option #A was selected only based on Cost perspective, without any consideration to human health, young children, property values, Corona effect, long term sustainability perspective or any other factors. While its important to understand the results of CEQA study, its extremely critical to understand the negative impact of EMF on the many young children living around the proposed transmission lines. Without extensive research and study on the impact to young children and adult heath, we should not be approving such an incomplete proposal.

Page 6 ends

discussions with several real estate agents in the region, I have unanimously found all to agree that the real estate values of residences in close proximity to power lines goes down. Its hard to find potential buyers and most folks refrain from buying a house too close to high power transmission lines. There are H-362
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
1000 plus residences in the area affected by this project. Even if we were to make very rough assumptions, and assume minimal cost reduction in property values and take an average loss of $100,000 per property in the current year, that goes to $100,000,000 of loss of equity to the public. This is not even accounting the businesses affected by this project. This long explanation was to raise a point that if the selection of route A was saving money to the city, this is costing a huge financial loss to the public, which is not acceptable. This decrease in property values will also directly impact the tax collection by the Santa Clara Assessor and result in lower tax revenue coming into the city of Santa Clara.

Reference #5 : Page 49 of report- Figure 5.1-2. Wall separating residences and Lafayette Street.

Personal observation#5: The picture is taken conveniently from the other side of the railway line which is actually Kingsbury street, inside a private community and not Lafayette street. This is further away from the proposed SVP lines. This is very misleading; see snapshots taken from Google maps below

And this is what is included on the report:

The Mission Garden Townhome community has no walls as such and the main entry to residences face the road directly and are the most impacted. There are several other single family homes on Lafayette street with the same impact, having an entryway directly on the street. This and including other citations of reusing sections of older reports, is all in all absolutely unacceptable and instills distrust. This further shows incompetency of the agency/ agencies preparing this report.

Conclusion: This project's initial study needs to expand beyond CEQA for approval from the public. The limited scope of CEQA has failed to address the following concerns we have:

Health hazards due to EMF levels.- This is by far the gravest concern and CEQA is clearly not qualified to study that.

Reduced property values- several references provided below.

Loss of Aesthetic appeal for potential real estate buyers/ new and current businesses.

Increase in audible noise levels during and post construction, which is already high in the area with presence of railway line and air traffic route.

Increased fire hazard/ risk of other accidents.

Induced current on railway lines with close proximity/ corona effect- CEQA report did not clearly address this for a 115KV line.

Economic effect on the community from small to larger scale based on all of the above.

We demand further investigation and revisit other routes or proposals to resolve the power needs of the city. We have to ensure our and our kids’ health is not at stake in the name of development and infrastructure and are not in agreement for this project to move forward. We cannot approve this to move forward as of now given the lack of study and absence of a satisfactory solution/ mitigation provided in favor/ assurance to public health.

Additional References:

Research on effects of EMF on humans:
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6025786/
This research reinforces the concerns of EMF exposure effect on human health. https://www.epa.gov/radtown/electric-and-magnetic-fields-power-lines This resource suggests taking precautions and keeping distance or limiting exposure. Residents would no longer have either of these two options per the current proposals if they are living there 24-7.

https://www.fastexpert.com/blog/should-i-buy-a-house-near-power-lines/ These are points of view from a real estate expert who clearly states that property value declines proportionately to the distance of the property from high tension lines. People have apprehensions whether or not research clearly defines the risk. Potential buyers might have low priority for a property too close to a high tension power line.
https://orchard.com/blog/posts/power-lines-and-property-value Another research on real estate values lowered due to high tension power lines proximity.

H-363
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: Prashant Tiwari <[email protected]>
Sent: Thursday, August 29, 2024 7:03 PM
To: NRS-KRS Project; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community for the upcoming SVP project connecting the Northern Receiving Station NRS to Kifer receiving station (KRS)- NRS-KRS 115kV Transmission Line Project

To Whomsoever it may concern,
We are residents of Santa Clara that will be negatively impacted by the “NRS-KRS 115kV Transmission Line Project”. We have collectively reviewed the draft Initial Study/ Mitigated Negative declaration for “NRS-KRS 115kV Transmission Line Project” from July 2024. After reviewing this report and also attending the virtual and in person meetings, here are some references to emphasize our various concerns.

Reference #1 : CEQA’s reporting includes these State reviewing agencies: California Air Resources Board (ARB), California Department of Fish and Wildlife, Bay Delta Region 3 (CDFW), California Department of Forestry and Fire Protection (CAL FIRE), California Department of Parks and Recreation, California Department of Toxic Substances Control (DTSC), California Department of Transportation, District 4 (DOT), California Department of Transportation, Division of Aeronautics (DOT), California Department of Transportation, Division of Transportation Planning (DOT), California Department of Water Resources (DWR), California Energy Commission, California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Public Utilities Commission (CPUC), California Regional Water Quality Control Board, San Francisco Bay Region 2 (RWQCB), Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water.

Personal observation#1 : None of these agencies has any association with human health. CEQA reporting is not qualified enough to force the public to compromise on health concerns. Other agencies need to be involved to review this proposal, that are qualified to study the effect on “ humans”, not just wildlife and vegetation, or “ environment. The checklist is completely devoid of our gravest humanitarian concerns. It is quite shocking that the project has not included any study to understand the potential impact of EMF waves on human lives, given that the transmission lines are potentially less than 60 feet from the closest dwellings. The city of Santa Clara needs to step in and have third party/ independent studies completed in favor of human health.

Reference #2: Page 41 of report- Section 4.15. Electric and Magnetic Fields summary.

Personal observation#2 : This consideration was completely absent earlier. Only after the residents raised their voices, this section was added. To our greatest disappointment, this section is copied over from an older report on the “South Loop Reconfiguration Project” from 2020. One would have expected that a new study would have been conducted for a project this size. The lack of due diligence and ignorance towards the specifics of this project are apparent and not acceptable. In fact we have found several sections of this older report as being reused across the entire report.

The EMP map shared during the in person meeting had several flaws and we would like to question the viability of the study that was completed. What time of the day was the study completed and on what models were the values based on since these were done on assumption for the EMF values that would be there once the project is complete. Since we have seen the several sections of the report redundantly copied over from other reports, we would like a more detailed analysis of this report.

H-364
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Regarding EMF concerns for human health, there are plenty of scientific studies that do indicate the grave concern on human health with EMF exposures and we cannot ignore this aspect. Here is a reference to an article and there are plenty of articles listed here under references:
https://psc.wi.gov/Documents/Brochures/EMF.pdf

There are not enough references listed in the draft report provided to us, and the explanation provided seems to be conveniently using studies that prove otherwise. This needs more investigation and references. The solution provided as raising the height of the poles and increasing the distance is non- existent. It was confirmed during the in person meeting that the design will not be altered and the height was already designed as required according to the SVP team present there. It seems that the preparers of this report did not even read the report after copying pasting from the old report as evident in the list of proposed solutions is not applicable here.

The live presentation on August 22nd showed the comparison of EMF values of household objects as a means to show that everyday household items carry a similar range of mG( milli Gauss) units. This comparison was inherently flawed since it mentioned that the household devices were producing those level at 1 feet while those indicated for 115KVf lines were at 60 feet. further these household devices do not operate 24X7 similar to the transmission lines.

There were a lot of citations of reports showcasing that no clear proof of EMF to human health exists but we would like to also point out certain states like Connecticut Department of Public Health have cited reports that have shown an increased incidence of childhood leukemia( Blood cancer) at avg exposure of only 3 mG. Also they have called out that some utility workers exposed to high levels of emf have increase risks of Lur Gehrig's disease.

They also call out that most impacts of EMF from high voltage lines dissipate at ~300 feet.

These are available on Page 2 & Page 3 of this report: https://portal.ct.gov/-/media/departments- and-agencies/dph/dph/environmental_health/eoha/pdf/emffactsheet2008pdf.pdf This report has citations from WHO , National Institute of Environmental Health Sciences and California Department of Health Services.
https://www.niehs.nih.gov/sites/default/files/health/materials/electric_and_magnetic_fields_associ ated_with_the_use_of_electric_power_questions_and_answers_english_508.pdf

Reference #3

Page 174 ends

Personal observation#3
The railway line's proximity to the proposed high transmission lines is very concerning. The centerline distance from proposed lines to railway line is aproximately 50 feet per google maps with some margin for error. As per the report there are no Corona rings proposed for the 115KV lines. There seems to be negligence in design in consideration of the hazards posed by these high voltage lines as Corona effect can transfer current to railway lines. All the residents are at a high risk of accidental hazards given the proximity of the railway line, this project is adding on to the hazards. This section is only stating information about what Corona effect is, as may be required by law, which by the way is again a copy paste from an old report. The only concern discussed in more depth is the audible noise level. The concerns are presented to imply that this is not significant by stating that 115KV lines pose less than significant risk.

H-365
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Reference #4: Post meeting material from March 19th 2024 @https://santaclara.legistar.com/LegislationDetail.aspx?ID=6582415&GUID=E6E14646-3CF7-4D15- BB98-F18580696012&Options=&Search=
Personal observation#4: At surface level, it looks like Option #A was selected only based on Cost perspective, without any consideration to human health, young children, property values, Corona effect, long term sustainability perspective or any other factors. While its important to understand the results of CEQA study, its extremely critical to understand the negative impact of EMF on the many young children living around the proposed transmission lines. Without extensive research and study on the impact to young children and adult heath, we should not be approving such an incomplete proposal.

Page 6 ends

discussions with several real estate agents in the region, I have unanimously found all to agree that the real estate values of residences in close proximity to power lines goes down. Its hard to find potential buyers and most folks refrain from buying a house too close to high power transmission lines. There are 1000 plus residences in the area affected by this project. Even if we were to make very rough assumptions, and assume minimal cost reduction in property values and take an average loss of $100,000 per property in the current year, that goes to $100,000,000 of loss of equity to the public. This is not even accounting the businesses affected by this project. This long explanation was to raise a point that if the selection of route A was saving money to the city, this is costing a huge financial loss to the public, which is not acceptable. This decrease in property values will also directly impact the tax collection by the Santa Clara Assessor and result in lower tax revenue coming into the city of Santa Clara.

Reference #5 : Page 49 of report- Figure 5.1-2. Wall separating residences and Lafayette Street.

Personal observation#5: The picture is taken conveniently from the other side of the railway line which is actually Kingsbury street, inside a private community and not Lafayette street. This is further away from the proposed SVP lines. This is very misleading; see snapshots taken from Google maps below

H-366
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

And this is what is included on the report:

The Mission Garden Townhome community has no walls as such and the main entry to residences face the road directly and are the most impacted. There are several other single family homes on Lafayette H-367

5.1. AU'll«TIG
Figure 5,14 2, Wall Separatln1 Residences and Lafayette Street W II S.paroting Rnldtncn and Ulayotlt St-
Juu202•
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
street with the same impact, having an entryway directly on the street. This and including other citations of reusing sections of older reports, is all in all absolutely unacceptable and instills distrust. This further shows incompetency of the agency/ agencies preparing this report.

Conclusion: This project's initial study needs to expand beyond CEQA for approval from the public. The limited scope of CEQA has failed to address the following concerns we have:
• Health hazards due to EMF levels.- This is by far the gravest concern and CEQA is clearly not qualified to study that.
• Reduced property values- several references provided below. • Loss of Aesthetic appeal for potential real estate buyers/ new and current businesses. • Increase in audible noise levels during and post construction, which is already high in the area with presence of railway line and air traffic route. • Increased fire hazard/ risk of other accidents.
• Induced current on railway lines with close proximity/ corona effect- CEQA report did not clearly address this for a 115KV line.
• Economic effect on the community from small to larger scale based on all of the above.

We demand further investigation and revisit other routes or proposals to resolve the power needs of the city. We have to ensure our and our kids’ health is not at stake in the name of development and infrastructure and are not in agreement for this project to move forward. We cannot approve this to move forward as of now given the lack of study and absence of a satisfactory solution/ mitigation provided in favor/ assurance to public health.

Additional References:

Research on effects of EMF on humans:

1. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6025786/ This research reinforces the concerns of EMF exposure effect on human health.

2. https://www.epa.gov/radtown/electric-and-magnetic-fields-power-lines This resource suggests taking precautions and keeping distance or limiting exposure. Residents would no longer have either of these two options per the current proposals if they are living there 24-7.

3. https://www.fastexpert.com/blog/should-i-buy-a-house-near-power-lines/ These are points of view from a real estate expert who clearly states that property value declines proportionately to the distance of the property from high tension lines. People have apprehensions whether or not research clearly defines the risk. Potential buyers might have low priority for a property too close to a high tension power line.

H-368
at You Can Do
If you are concerned about possible health risks from electric and magnetic fields, you can:
• Increase the distance between yourself and the source. The greater the distance between you and the source of EMF, the lower your exposure.
• Limit the time spent around the source. The less time you spend near EM F, th e lower your NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

4. How Much Do Power Lines Decrease My Property Value?

How Much Do Power Lines Decrease My Property
Value?
Breaking down the pros and cons of living in, and selling, a home near power lines. How close is too close, for ...

Another research on real estate values lowered due to high tension power lines proximity.

Thanks & regards,
Prashant

H-369
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: Srinivas Reddy <[email protected]>
Sent: Thursday, August 29, 2024 6:32 PM
To: NRS-KRS Project; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community for the upcoming SVP project connecting the Northern Receiving Station NRS to Kifer receiving station (KRS)- NRS-KRS 115kV Transmission Line Project
Attachments:

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Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community for the upcoming SVP project connecting the Northern Receiving Station NRS to Kifer receiving station (KRS)- NRS-KRS 115kV Transmission Line Project

To Whomsoever it may concern,
We are residents of Santa Clara that will be negatively impacted by the “NRS-KRS 115kV Transmission Line Project”. We have collectively reviewed the draft Initial Study/ Mitigated Negative declaration for “NRS-KRS 115kV Transmission Line Project” from July 2024. After reviewing this report and also attending the virtual and in person meetings, here are some references to emphasize our various concerns.

Reference #1 : CEQA’s reporting includes these State reviewing agencies: California Air Resources Board (ARB), California Department of Fish and Wildlife, Bay Delta Region 3 (CDFW), California Department of Forestry and Fire Protection (CAL FIRE), California Department of Parks and Recreation, California Department of Toxic Substances Control (DTSC), California Department of Transportation, District 4 (DOT), California Department of Transportation, Division of Aeronautics (DOT), California Department of Transportation, Division of Transportation Planning (DOT), California Department of Water Resources (DWR), California Energy Commission, California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Public Utilities Commission (CPUC), California Regional Water Quality Control Board, San Francisco Bay Region 2 (RWQCB), Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water.

Personal observation#1 : None of these agencies has any association with human health. CEQA reporting is not qualified enough to force the public to compromise on health concerns. Other agencies need to be involved to review this proposal, that are qualified to study the effect on “ humans”, not just wildlife and vegetation, or “ environment. The checklist is completely devoid of our gravest humanitarian concerns. It is quite shocking that the project has not included any study to understand the potential impact of EMF waves on human lives, given that the transmission lines are potentially less than 60 feet H-370
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
from the closest dwellings. The city of Santa Clara needs to step in and have third party/ independent studies completed in favor of human health.

Reference #2: Page 41 of report- Section 4.15. Electric and Magnetic Fields summary.

Personal observation#2 : This consideration was completely absent earlier. Only after the residents raised their voices, this section was added. To our greatest disappointment, this section is copied over from an older report on the “South Loop Reconfiguration Project” from 2020. One would have expected that a new study would have been conducted for a project this size. The lack of due diligence and ignorance towards the specifics of this project are apparent and not acceptable. In fact we have found several sections of this older report as being reused across the entire report.

The EMP map shared during the in person meeting had several flaws and we would like to question the viability of the study that was completed. What time of the day was the study completed and on what models were the values based on since these were done on assumption for the EMF values that would be there once the project is complete. Since we have seen the several sections of the report redundantly copied over from other reports, we would like a more detailed analysis of this report.

Regarding EMF concerns for human health, there are plenty of scientific studies that do indicate the grave concern on human health with EMF exposures and we cannot ignore this aspect. Here is a reference to an article and there are plenty of articles listed here under references:
https://psc.wi.gov/Documents/Brochures/EMF.pdf

There are not enough references listed in the draft report provided to us, and the explanation provided seems to be conveniently using studies that prove otherwise. This needs more investigation and references. The solution provided as raising the height of the poles and increasing the distance is non- existent. It was confirmed during the in person meeting that the design will not be altered and the height was already designed as required according to the SVP team present there. It seems that the preparers of this report did not even read the report after copying pasting from the old report as evident in the list of proposed solutions is not applicable here.

The live presentation on August 22nd showed the comparison of EMF values of household objects as a means to show that everyday household items carry a similar range of mG( milli Gauss) units. This comparison was inherently flawed since it mentioned that the household devices were producing those level at 1 feet while those indicated for 115KVf lines were at 60 feet. further these household devices do not operate 24X7 similar to the transmission lines.

There were a lot of citations of reports showcasing that no clear proof of EMF to human health exists but we would like to also point out certain states like Connecticut Department of Public Health have cited reports that have shown an increased incidence of childhood leukemia( Blood cancer) at avg exposure of only 3 mG. Also they have called out that some utility workers exposed to high levels of emf have increase risks of Lur Gehrig's disease.

They also call out that most impacts of EMF from high voltage lines dissipate at ~300 feet.

These are available on Page 2 & Page 3 of this report: https://portal.ct.gov/-/media/departments- and-agencies/dph/dph/environmental_health/eoha/pdf/emffactsheet2008pdf.pdf This report has citations from WHO , National Institute of Environmental Health Sciences and California Department of Health Services.
https://www.niehs.nih.gov/sites/default/files/health/materials/electric_and_magnetic_fields_associ ated_with_the_use_of_electric_power_questions_and_answers_english_508.pdf

H-371
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Reference #3

Page 174 ends

Personal observation#3
The railway line's proximity to the proposed high transmission lines is very concerning. The centerline distance from proposed lines to railway line is aproximately 50 feet per google maps with some margin for error. As per the report there are no Corona rings proposed for the 115KV lines. There seems to be negligence in design in consideration of the hazards posed by these high voltage lines as Corona effect can transfer current to railway lines. All the residents are at a high risk of accidental hazards given the proximity of the railway line, this project is adding on to the hazards. This section is only stating information about what Corona effect is, as may be required by law, which by the way is again a copy paste from an old report. The only concern discussed in more depth is the audible noise level. The concerns are presented to imply that this is not significant by stating that 115KV lines pose less than significant risk.

Reference #4: Post meeting material from March 19th
2024 @https://santaclara.legistar.com/LegislationDetail.aspx?ID=6582415&GUID=E6E14646-3CF7- 4D15-BB98-F18580696012&Options=&Search=
Personal observation#4: At surface level, it looks like Option #A was selected only based on Cost perspective, without any consideration to human health, young children, property values, Corona effect, long term sustainability perspective or any other factors. While its important to understand the results of CEQA study, its extremely critical to understand the negative impact of EMF on the many young children living around the proposed transmission lines. Without extensive research and study on the impact to young children and adult heath, we should not be approving such an incomplete proposal.

Page 6 ends

discussions with several real estate agents in the region, I have unanimously found all to agree that the real estate values of residences in close proximity to power lines goes down. Its hard to find potential buyers and most folks refrain from buying a house too close to high power transmission lines. There are 1000 plus residences in the area affected by this project. Even if we were to make very rough assumptions, and assume minimal cost reduction in property values and take an average loss of $100,000 per property in the current year, that goes to $100,000,000 of loss of equity to the public. This is not even accounting the businesses affected by this project. This long explanation was to raise a point that if the selection of route A was saving money to the city, this is costing a huge financial loss to the public, which is not acceptable. This decrease in property values will also directly impact the tax collection by the Santa Clara Assessor and result in lower tax revenue coming into the city of Santa Clara.

Reference #5 : Page 49 of report- Figure 5.1-2. Wall separating residences and Lafayette Street.

Personal observation#5: The picture is taken conveniently from the other side of the railway line which is actually Kingsbury street, inside a private community and not Lafayette street. This is further away from the proposed SVP lines. This is very misleading; see snapshots taken from Google maps below

And this is what is included on the report:

The Mission Garden Townhome community has no walls as such and the main entry to residences face the road directly and are the most impacted. There are several other single family homes on Lafayette H-372
□□
□
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
street with the same impact, having an entryway directly on the street. This and including other citations of reusing sections of older reports, is all in all absolutely unacceptable and instills distrust. This further shows incompetency of the agency/ agencies preparing this report.

Conclusion: This project's initial study needs to expand beyond CEQA for approval from the public. The limited scope of CEQA has failed to address the following concerns we have:
• Health hazards due to EMF levels.- This is by far the gravest concern and CEQA is clearly not qualified to study that.
• Reduced property values- several references provided below. • Loss of Aesthetic appeal for potential real estate buyers/ new and current businesses. • Increase in audible noise levels during and post construction, which is already high in the area with presence of railway line and air traffic route. • Increased fire hazard/ risk of other accidents.
• Induced current on railway lines with close proximity/ corona effect- CEQA report did not clearly address this for a 115KV line.
• Economic effect on the community from small to larger scale based on all of the above.

We demand further investigation and revisit other routes or proposals to resolve the power needs of the city. We have to ensure our and our kids’ health is not at stake in the name of development and infrastructure and are not in agreement for this project to move forward. We cannot approve this to move forward as of now given the lack of study and absence of a satisfactory solution/ mitigation provided in favor/ assurance to public health.

Additional References:

Research on effects of EMF on humans:

1. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6025786/ This research reinforces the concerns of EMF exposure effect on human health.

2. https://www.epa.gov/radtown/electric-and-magnetic-fields-power-lines This resource suggests taking precautions and keeping distance or limiting exposure. Residents would no longer have either of these two options per the current proposals if they are living there 24-7.

3. https://www.fastexpert.com/blog/should-i-buy-a-house-near-power-lines/ These are points of view from a real estate expert who clearly states that property value declines proportionately to the distance of the property from high tension lines. People have apprehensions whether or not research clearly defines the risk. Potential buyers might have low priority for a property too close to a high tension power line.

4. https://orchard.com/blog/posts/power-lines-and-property-value Another research on real estate values lowered due to high tension power lines proximity.

Thank you,
Srinivas

H-373
□
r r r r 1
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: Gane Sugali <[email protected]>
Sent: Thursday, August 29, 2024 4:45 PM
To: NRS-KRS Project
Cc: [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community for the upcoming SVP project connecting the Northern Receiving Station NRS to Kifer receiving station (KRS)- NRS-KRS 115kV Transmission Line Project

To Whomsoever it may concern,
We are residents of Santa Clara that will be negatively impacted by the “NRS-KRS 115kV Transmission Line Project”. We have collectively reviewed the draft Initial Study/ Mitigated Negative declaration for “NRS-KRS 115kV Transmission Line Project” from July 2024. After reviewing this report and also attending the virtual and in person meetings, here are some references to emphasize our various concerns.

Reference #1 : CEQA’s reporting includes these State reviewing agencies: California Air Resources Board (ARB), California Department of Fish and Wildlife, Bay Delta Region 3 (CDFW), California Department of Forestry and Fire Protection (CAL FIRE), California Department of Parks and Recreation, California Department of Toxic Substances Control (DTSC), California Department of Transportation, District 4 (DOT), California Department of Transportation, Division of Aeronautics (DOT), California Department of Transportation, Division of Transportation Planning (DOT), California Department of Water Resources (DWR), California Energy Commission, California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Public Utilities Commission (CPUC), California Regional Water Quality Control Board, San Francisco Bay Region 2 (RWQCB), Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water.

Personal observation#1 : None of these agencies has any association with human health. CEQA reporting is not qualified enough to force the public to compromise on health concerns. Other agencies need to be involved to review this proposal, that are qualified to study the effect on “ humans”, not just wildlife and vegetation, or “ environment. The checklist is completely devoid of our gravest humanitarian concerns. It is quite shocking that the project has not included any study to understand the potential impact of EMF waves on human lives, given that the transmission lines are potentially less than 60 feet from the closest dwellings. The city of Santa Clara needs to step in and have third party/ independent studies completed in favor of human health.

Reference #2: Page 41 of report- Section 4.15. Electric and Magnetic Fields summary.

Personal observation#2 : This consideration was completely absent earlier. Only after the residents raised their voices, this section was added. To our greatest disappointment, this section is copied over from an older report on the “South Loop Reconfiguration Project” from 2020. One would have expected that a new study would have been conducted for a project this size. The lack of due diligence and ignorance towards the specifics of this project are apparent and not acceptable. In fact we have found several sections of this older report as being reused across the entire report.

The EMP map shared during the in person meeting had several flaws and we would like to question the viability of the study that was completed. What time of the day was the study completed and on what models were the values based on since these were done on assumption for the EMF values that would H-374
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
be there once the project is complete. Since we have seen the several sections of the report redundantly copied over from other reports, we would like a more detailed analysis of this report.

Regarding EMF concerns for human health, there are plenty of scientific studies that do indicate the grave concern on human health with EMF exposures and we cannot ignore this aspect. Here is a reference to an article and there are plenty of articles listed here under references:
https://psc.wi.gov/Documents/Brochures/EMF.pdf

There are not enough references listed in the draft report provided to us, and the explanation provided seems to be conveniently using studies that prove otherwise. This needs more investigation and references. The solution provided as raising the height of the poles and increasing the distance is non- existent. It was confirmed during the in person meeting that the design will not be altered and the height was already designed as required according to the SVP team present there. It seems that the preparers of this report did not even read the report after copying pasting from the old report as evident in the list of proposed solutions is not applicable here.

The live presentation on August 22nd showed the comparison of EMF values of household objects as a means to show that everyday household items carry a similar range of mG( milli Gauss) units. This comparison was inherently flawed since it mentioned that the household devices were producing those level at 1 feet while those indicated for 115KVf lines were at 60 feet. further these household devices do not operate 24X7 similar to the transmission lines.

There were a lot of citations of reports showcasing that no clear proof of EMF to human health exists but we would like to also point out certain states like Connecticut Department of Public Health have cited reports that have shown an increased incidence of childhood leukemia( Blood cancer) at avg exposure of only 3 mG. Also they have called out that some utility workers exposed to high levels of emf have increase risks of Lur Gehrig's disease.

They also call out that most impacts of EMF from high voltage lines dissipate at ~300 feet.

These are available on Page 2 & Page 3 of this report: https://portal.ct.gov/-/media/departments- and-agencies/dph/dph/environmental_health/eoha/pdf/emffactsheet2008pdf.pdf This report has citations from WHO , National Institute of Environmental Health Sciences and California Department of Health Services.
https://www.niehs.nih.gov/sites/default/files/health/materials/electric_and_magnetic_fields_associ ated_with_the_use_of_electric_power_questions_and_answers_english_508.pdf

Reference #3

Page 174 ends

Personal observation#3
The railway line's proximity to the proposed high transmission lines is very concerning. The centerline distance from proposed lines to railway line is aproximately 50 feet per google maps with some margin for error. As per the report there are no Corona rings proposed for the 115KV lines. There seems to be negligence in design in consideration of the hazards posed by these high voltage lines as Corona effect can transfer current to railway lines. All the residents are at a high risk of accidental hazards given the proximity of the railway line, this project is adding on to the hazards. This section is only stating information about what Corona effect is, as may be required by law, which by the way is again a copy paste from an old report. The only concern discussed in more depth is the audible noise level. The concerns are presented to imply that this is not significant by stating that 115KV lines pose less than significant risk.

H-375
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

Reference #4: Post meeting material from March 19th 2024 @https://santaclara.legistar.com/LegislationDetail.aspx?ID=6582415&GUID=E6E14646-3CF7-4D15- BB98-F18580696012&Options=&Search=
Personal observation#4: At surface level, it looks like Option #A was selected only based on Cost perspective, without any consideration to human health, young children, property values, Corona effect, long term sustainability perspective or any other factors. While its important to understand the results of CEQA study, its extremely critical to understand the negative impact of EMF on the many young children living around the proposed transmission lines. Without extensive research and study on the impact to young children and adult heath, we should not be approving such an incomplete proposal.

Page 6 ends

discussions with several real estate agents in the region, I have unanimously found all to agree that the real estate values of residences in close proximity to power lines goes down. Its hard to find potential buyers and most folks refrain from buying a house too close to high power transmission lines. There are 1000 plus residences in the area affected by this project. Even if we were to make very rough assumptions, and assume minimal cost reduction in property values and take an average loss of $100,000 per property in the current year, that goes to $100,000,000 of loss of equity to the public. This is not even accounting the businesses affected by this project. This long explanation was to raise a point that if the selection of route A was saving money to the city, this is costing a huge financial loss to the public, which is not acceptable. This decrease in property values will also directly impact the tax collection by the Santa Clara Assessor and result in lower tax revenue coming into the city of Santa Clara.

Reference #5 : Page 49 of report- Figure 5.1-2. Wall separating residences and Lafayette Street.

Personal observation#5: The picture is taken conveniently from the other side of the railway line which is actually Kingsbury street, inside a private community and not Lafayette street. This is further away from the proposed SVP lines. This is very misleading; see snapshots taken from Google maps below

H-376
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

And this is what is included on the report:

The Mission Garden Townhome community has no walls as such and the main entry to residences face the road directly and are the most impacted. There are several other single family homes on Lafayette H-377

5.1. AU'll«TIG
Figure 5,14 2, Wall Separatln1 Residences and Lafayette Street W II S.paroting Rnldtncn and Ulayotlt St-
Juu202•
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
street with the same impact, having an entryway directly on the street. This and including other citations of reusing sections of older reports, is all in all absolutely unacceptable and instills distrust. This further shows incompetency of the agency/ agencies preparing this report.

Conclusion: This project's initial study needs to expand beyond CEQA for approval from the public. The limited scope of CEQA has failed to address the following concerns we have:
• Health hazards due to EMF levels.- This is by far the gravest concern and CEQA is clearly not qualified to study that.
• Reduced property values- several references provided below. • Loss of Aesthetic appeal for potential real estate buyers/ new and current businesses. • Increase in audible noise levels during and post construction, which is already high in the area with presence of railway line and air traffic route. • Increased fire hazard/ risk of other accidents.
• Induced current on railway lines with close proximity/ corona effect- CEQA report did not clearly address this for a 115KV line.
• Economic effect on the community from small to larger scale based on all of the above.

We demand further investigation and revisit other routes or proposals to resolve the power needs of the city. We have to ensure our and our kids’ health is not at stake in the name of development and infrastructure and are not in agreement for this project to move forward. We cannot approve this to move forward as of now given the lack of study and absence of a satisfactory solution/ mitigation provided in favor/ assurance to public health.

Additional References:

Research on effects of EMF on humans:

1. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6025786/ This research reinforces the concerns of EMF exposure effect on human health.

2. https://www.epa.gov/radtown/electric-and-magnetic-fields-power-lines This resource suggests taking precautions and keeping distance or limiting exposure. Residents would no longer have either of these two options per the current proposals if they are living there 24-7.

3. https://www.fastexpert.com/blog/should-i-buy-a-house-near-power-lines/ These are points of view from a real estate expert who clearly states that property value declines proportionately to the distance of the property from high tension lines. People have apprehensions whether or not research clearly defines the risk. Potential buyers might have low priority for a property too close to a high tension power line.

H-378
at You Can Do
If you are concerned about possibl e health risks from electric and magneti c fields, you can:
• Increase the distance between yourself and the source . The greater the distance between you and the source of EMF, the lower your exposure.
• Limit the time spent around the source . The less time you spend near EMF, th e lower your NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

4. https://orchard.com/blog/posts/power-lines-and-property-value Another research on real estate values lowered due to high tension power lines proximity.

Thanks
Gane Sugali
1921 Silva place
Santa Clara CA

H-379
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: Adnan Hemani <[email protected]>
Sent: Thursday, August 29, 2024 4:32 PM
To: NRS-KRS Project; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community for the upcoming SVP project connecting the Northern Receiving Station NRS to Kifer receiving station (KRS)- NRS-KRS 115kV Transmission Line Project

To Whomsoever it may concern,
We are residents of Santa Clara that will be negatively impacted by the “NRS-KRS 115kV Transmission Line Project”. We have collectively reviewed the draft Initial Study/ Mitigated Negative declaration for “NRS-KRS 115kV Transmission Line Project” from July 2024. After reviewing this report and also attending the virtual and in person meetings, here are some references to emphasize our various concerns.

Reference #1 : CEQA’s reporting includes these State reviewing agencies: California Air Resources Board (ARB), California Department of Fish and Wildlife, Bay Delta Region 3 (CDFW), California Department of Forestry and Fire Protection (CAL FIRE), California Department of Parks and Recreation, California Department of Toxic Substances Control (DTSC), California Department of Transportation, District 4 (DOT), California Department of Transportation, Division of Aeronautics (DOT), California Department of Transportation, Division of Transportation Planning (DOT), California Department of Water Resources (DWR), California Energy Commission, California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Public Utilities Commission (CPUC), California Regional Water Quality Control Board, San Francisco Bay Region 2 (RWQCB), Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water.

Personal observation#1 : None of these agencies has any association with human health. CEQA reporting is not qualified enough to force the public to compromise on health concerns. Other agencies need to be involved to review this proposal, that are qualified to study the effect on “ humans”, not just wildlife and vegetation, or “ environment. The checklist is completely devoid of our gravest humanitarian concerns. It is quite shocking that the project has not included any study to understand the potential impact of EMF waves on human lives, given that the transmission lines are potentially less than 60 feet from the closest dwellings. The city of Santa Clara needs to step in and have third party/ independent studies completed in favor of human health.

Reference #2: Page 41 of report- Section 4.15. Electric and Magnetic Fields summary.

Personal observation#2 : This consideration was completely absent earlier. Only after the residents raised their voices, this section was added. To our greatest disappointment, this section is copied over from an older report on the “South Loop Reconfiguration Project” from 2020. One would have expected that a new study would have been conducted for a project this size. The lack of due diligence and ignorance towards the specifics of this project are apparent and not acceptable. In fact we have found several sections of this older report as being reused across the entire report.

The EMP map shared during the in person meeting had several flaws and we would like to question the viability of the study that was completed. What time of the day was the study completed and on what models were the values based on since these were done on assumption for the EMF values that would be there once the project is complete. Since we have seen the several sections of the report redundantly copied over from other reports, we would like a more detailed analysis of this report.

H-380
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Regarding EMF concerns for human health, there are plenty of scientific studies that do indicate the grave concern on human health with EMF exposures and we cannot ignore this aspect. Here is a reference to an article and there are plenty of articles listed here under references:
https://psc.wi.gov/Documents/Brochures/EMF.pdf

There are not enough references listed in the draft report provided to us, and the explanation provided seems to be conveniently using studies that prove otherwise. This needs more investigation and references. The solution provided as raising the height of the poles and increasing the distance is non- existent. It was confirmed during the in person meeting that the design will not be altered and the height was already designed as required according to the SVP team present there. It seems that the preparers of this report did not even read the report after copying pasting from the old report as evident in the list of proposed solutions is not applicable here.

The live presentation on August 22nd showed the comparison of EMF values of household objects as a means to show that everyday household items carry a similar range of mG( milli Gauss) units. This comparison was inherently flawed since it mentioned that the household devices were producing those level at 1 feet while those indicated for 115KVf lines were at 60 feet. further these household devices do not operate 24X7 similar to the transmission lines.

There were a lot of citations of reports showcasing that no clear proof of EMF to human health exists but we would like to also point out certain states like Connecticut Department of Public Health have cited reports that have shown an increased incidence of childhood leukemia( Blood cancer) at avg exposure of only 3 mG. Also they have called out that some utility workers exposed to high levels of emf have increased risks of Lou Gehrig's disease.

They also call out that most impacts of EMF from high voltage lines dissipate at ~300 feet.

These are available on Page 2 & Page 3 of this report: https://portal.ct.gov/-/media/departments- and-agencies/dph/dph/environmental_health/eoha/pdf/emffactsheet2008pdf.pdf This report has citations from WHO , National Institute of Environmental Health Sciences and California Department of Health Services.
https://www.niehs.nih.gov/sites/default/files/health/materials/electric_and_magnetic_fields_associ ated_with_the_use_of_electric_power_questions_and_answers_english_508.pdf

Reference #3

Page 174 ends

Personal observation#3
The railway line's proximity to the proposed high transmission lines is very concerning. The centerline distance from proposed lines to railway line is aproximately 50 feet per google maps with some margin for error. As per the report there are no Corona rings proposed for the 115KV lines. There seems to be negligence in design in consideration of the hazards posed by these high voltage lines as Corona effect can transfer current to railway lines. All the residents are at a high risk of accidental hazards given the proximity of the railway line, this project is adding on to the hazards. This section is only stating information about what Corona effect is, as may be required by law, which by the way is again a copy paste from an old report. The only concern discussed in more depth is the audible noise level. The concerns are presented to imply that this is not significant by stating that 115KV lines pose less than significant risk.

H-381
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Reference #4: Post meeting material from March 19th 2024 @https://santaclara.legistar.com/LegislationDetail.aspx?ID=6582415&GUID=E6E14646-3CF7-4D15- BB98-F18580696012&Options=&Search=
Personal observation#4: At surface level, it looks like Option #A was selected only based on Cost perspective, without any consideration to human health, young children, property values, Corona effect, long term sustainability perspective or any other factors. While its important to understand the results of CEQA study, its extremely critical to understand the negative impact of EMF on the many young children living around the proposed transmission lines. Without extensive research and study on the impact to young children and adult heath, we should not be approving such an incomplete proposal.

Page 6 ends

discussions with several real estate agents in the region, I have unanimously found all to agree that the real estate values of residences in close proximity to power lines goes down. Its hard to find potential buyers and most folks refrain from buying a house too close to high power transmission lines. There are 1000 plus residences in the area affected by this project. Even if we were to make very rough assumptions, and assume minimal cost reduction in property values and take an average loss of $100,000 per property in the current year, that goes to $100,000,000 of loss of equity to the public. This is not even accounting the businesses affected by this project. This long explanation was to raise a point that if the selection of route A was saving money to the city, this is costing a huge financial loss to the public, which is not acceptable. This decrease in property values will also directly impact the tax collection by the Santa Clara Assessor and result in lower tax revenue coming into the city of Santa Clara.

Reference #5 : Page 49 of report- Figure 5.1-2. Wall separating residences and Lafayette Street.

Personal observation#5: The picture is taken conveniently from the other side of the railway line which is actually Kingsbury street, inside a private community and not Lafayette street. This is further away from the proposed SVP lines. This is very misleading; see snapshots taken from Google maps below

H-382
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

And this is what is included on the report:

The Mission Garden Townhome community has no walls as such and the main entry to residences face the road directly and are the most impacted. There are several other single family homes on Lafayette street with the same impact, having an entryway directly on the street. This and including other citations of reusing sections of older reports, is all in all absolutely unacceptable and instills distrust. This further shows incompetency of the agency/ agencies preparing this report.

Conclusion: This project's initial study needs to expand beyond CEQA for approval from the public. The limited scope of CEQA has failed to address the following concerns we have:
• Health hazards due to EMF levels.- This is by far the gravest concern and CEQA is clearly not qualified to study that.
• Reduced property values- several references provided below. • Loss of Aesthetic appeal for potential real estate buyers/ new and current businesses.

H-383
Flaure s.1-2. wall Separatinc Residencu and Lafayette Street Wall~RHlcMncnandLlfayrt11: SlrNt

5.1·5
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
• Increase in audible noise levels during and post construction, which is already high in the area with presence of railway line and air traffic route. • Increased fire hazard/ risk of other accidents.
• Induced current on railway lines with close proximity/ corona effect- CEQA report did not clearly address this for a 115KV line.
• Economic effect on the community from small to larger scale based on all of the above.

We demand further investigation and revisit other routes or proposals to resolve the power needs of the city. We have to ensure our and our kids’ health is not at stake in the name of development and infrastructure and are not in agreement for this project to move forward. We cannot approve this to move forward as of now given the lack of study and absence of a satisfactory solution/ mitigation provided in favor/ assurance to public health.

Additional References:

Research on effects of EMF on humans:

1. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6025786/ This research reinforces the concerns of EMF exposure effect on human health.

2. https://www.epa.gov/radtown/electric-and-magnetic-fields-power-lines This resource suggests taking precautions and keeping distance or limiting exposure. Residents would no longer have either of these two options per the current proposals if they are living there 24-7.

3. https://www.fastexpert.com/blog/should-i-buy-a-house-near-power-lines/ These are points of view from a real estate expert who clearly states that property value declines proportionately to the distance of the property from high tension lines. People have apprehensions whether or not research clearly defines the risk. Potential buyers might have low priority for a property too close to a high tension power line.

4. https://orchard.com/blog/posts/power-lines-and-property-value Another research on real estate values lowered due to high tension power lines proximity.

--
Thanks,
Adnan Hemani

H-384
at You Can Do
If you are concerned abo ut possible health risks from electric and magnetic fields, you can:
• Increase the distance between yourself and the source. The greater t he distance between you and th e source of EMF, th e lowe r your exposure.
• Limit the time spent around the source. The less time you spend near EMF, th e lower your NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: Darshna Siva <[email protected]>
Sent: Thursday, August 29, 2024 4:19 PM
To: NRS-KRS Project; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community for the upcoming SVP project connecting the Northern Receiving Station NRS to Kifer receiving station (KRS)- NRS-KRS 115kV Transmission Line Project

To Whomsoever it may concern,
We are residents of Santa Clara that will be negatively impacted by the “NRS-KRS 115kV Transmission Line Project”. We have collectively reviewed the draft Initial Study/ Mitigated Negative declaration for “NRS-KRS 115kV Transmission Line Project” from July 2024. After reviewing this report and also attending the virtual and in person meetings, here are some references to emphasize our various concerns.

Reference #1 : CEQA’s reporting includes these State reviewing agencies: California Air Resources Board (ARB), California Department of Fish and Wildlife, Bay Delta Region 3 (CDFW), California Department of Forestry and Fire Protection (CAL FIRE), California Department of Parks and Recreation, California Department of Toxic Substances Control (DTSC), California Department of Transportation, District 4 (DOT), California Department of Transportation, Division of Aeronautics (DOT), California Department of Transportation, Division of Transportation Planning (DOT), California Department of Water Resources (DWR), California Energy Commission, California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Public Utilities Commission (CPUC), California Regional Water Quality Control Board, San Francisco Bay Region 2 (RWQCB), Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water.

Personal observation#1 : None of these agencies has any association with human health. CEQA reporting is not qualified enough to force the public to compromise on health concerns. Other agencies need to be involved to review this proposal, that are qualified to study the effect on “ humans”, not just wildlife and vegetation, or “ environment. The checklist is completely devoid of our gravest humanitarian concerns. It is quite shocking that the project has not included any study to understand the potential impact of EMF waves on human lives, given that the transmission lines are potentially less than 60 feet from the closest dwellings. The city of Santa Clara needs to step in and have third party/ independent studies completed in favor of human health.

Reference #2: Page 41 of report- Section 4.15. Electric and Magnetic Fields summary.

Personal observation#2 : This consideration was completely absent earlier. Only after the residents raised their voices, this section was added. To our greatest disappointment, this section is copied over from an older report on the “South Loop Reconfiguration Project” from 2020. One would have expected that a new study would have been conducted for a project this size. The lack of due diligence and ignorance towards the specifics of this project are apparent and not acceptable. In fact we have found several sections of this older report as being reused across the entire report.

The EMP map shared during the in person meeting had several flaws and we would like to question the viability of the study that was completed. What time of the day was the study completed and on what models were the values based on since these were done on assumption for the EMF values that would be there once the project is complete. Since we have seen the several sections of the report redundantly copied over from other reports, we would like a more detailed analysis of this report.

H-385
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Regarding EMF concerns for human health, there are plenty of scientific studies that do indicate the grave concern on human health with EMF exposures and we cannot ignore this aspect. Here is a reference to an article and there are plenty of articles listed here under references:
https://psc.wi.gov/Documents/Brochures/EMF.pdf

There are not enough references listed in the draft report provided to us, and the explanation provided seems to be conveniently using studies that prove otherwise. This needs more investigation and references. The solution provided as raising the height of the poles and increasing the distance is non- existent. It was confirmed during the in person meeting that the design will not be altered and the height was already designed as required according to the SVP team present there. It seems that the preparers of this report did not even read the report after copying pasting from the old report as evident in the list of proposed solutions is not applicable here.

The live presentation on August 22nd showed the comparison of EMF values of household objects as a means to show that everyday household items carry a similar range of mG( milli Gauss) units. This comparison was inherently flawed since it mentioned that the household devices were producing those level at 1 feet while those indicated for 115KVf lines were at 60 feet. further these household devices do not operate 24X7 similar to the transmission lines.

There were a lot of citations of reports showcasing that no clear proof of EMF to human health exists but we would like to also point out certain states like Connecticut Department of Public Health have cited reports that have shown an increased incidence of childhood leukemia( Blood cancer) at avg exposure of only 3 mG. Also they have called out that some utility workers exposed to high levels of emf have increase risks of Lur Gehrig's disease.

They also call out that most impacts of EMF from high voltage lines dissipate at ~300 feet.

These are available on Page 2 & Page 3 of this report: https://portal.ct.gov/-/media/departments- and-agencies/dph/dph/environmental_health/eoha/pdf/emffactsheet2008pdf.pdf This report has citations from WHO , National Institute of Environmental Health Sciences and California Department of Health Services.
https://www.niehs.nih.gov/sites/default/files/health/materials/electric_and_magnetic_fields_associ ated_with_the_use_of_electric_power_questions_and_answers_english_508.pdf

Reference #3

Page 174 ends

Personal observation#3
The railway line's proximity to the proposed high transmission lines is very concerning. The centerline distance from proposed lines to railway line is aproximately 50 feet per google maps with some margin for error. As per the report there are no Corona rings proposed for the 115KV lines. There seems to be negligence in design in consideration of the hazards posed by these high voltage lines as Corona effect can transfer current to railway lines. All the residents are at a high risk of accidental hazards given the proximity of the railway line, this project is adding on to the hazards. This section is only stating information about what Corona effect is, as may be required by law, which by the way is again a copy paste from an old report. The only concern discussed in more depth is the audible noise level. The concerns are presented to imply that this is not significant by stating that 115KV lines pose less than significant risk.

H-386
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Reference #4: Post meeting material from March 19th 2024 @https://santaclara.legistar.com/LegislationDetail.aspx?ID=6582415&GUID=E6E14646-3CF7-4D15- BB98-F18580696012&Options=&Search=
Personal observation#4: At surface level, it looks like Option #A was selected only based on Cost perspective, without any consideration to human health, young children, property values, Corona effect, long term sustainability perspective or any other factors. While its important to understand the results of CEQA study, its extremely critical to understand the negative impact of EMF on the many young children living around the proposed transmission lines. Without extensive research and study on the impact to young children and adult heath, we should not be approving such an incomplete proposal.

Page 6 ends

discussions with several real estate agents in the region, I have unanimously found all to agree that the real estate values of residences in close proximity to power lines goes down. Its hard to find potential buyers and most folks refrain from buying a house too close to high power transmission lines. There are 1000 plus residences in the area affected by this project. Even if we were to make very rough assumptions, and assume minimal cost reduction in property values and take an average loss of $100,000 per property in the current year, that goes to $100,000,000 of loss of equity to the public. This is not even accounting the businesses affected by this project. This long explanation was to raise a point that if the selection of route A was saving money to the city, this is costing a huge financial loss to the public, which is not acceptable. This decrease in property values will also directly impact the tax collection by the Santa Clara Assessor and result in lower tax revenue coming into the city of Santa Clara.

Reference #5 : Page 49 of report- Figure 5.1-2. Wall separating residences and Lafayette Street.

Personal observation#5: The picture is taken conveniently from the other side of the railway line which is actually Kingsbury street, inside a private community and not Lafayette street. This is further away from the proposed SVP lines. This is very misleading; see snapshots taken from Google maps below

H-387
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

And this is what is included on the report:

The Mission Garden Townhome community has no walls as such and the main entry to residences face the road directly and are the most impacted. There are several other single family homes on Lafayette street with the same impact, having an entryway directly on the street. This and including other citations of reusing sections of older reports, is all in all absolutely unacceptable and instills distrust. This further shows incompetency of the agency/ agencies preparing this report.

Conclusion: This project's initial study needs to expand beyond CEQA for approval from the public. The limited scope of CEQA has failed to address the following concerns we have:
• Health hazards due to EMF levels.- This is by far the gravest concern and CEQA is clearly not qualified to study that.

H-388
NAS-KR51ls.NTMN-UICPIIOl(C1
Figure S.1-2. Wall Separat ing Residences and Lafayette Street Wall ~g Rt11dtncn and LAfayette Stf'Nt
S.1-5 ~nu,JMDunMNO/IS
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
• Reduced property values- several references provided below. • Loss of Aesthetic appeal for potential real estate buyers/ new and current businesses. • Increase in audible noise levels during and post construction, which is already high in the area with presence of railway line and air traffic route. • Increased fire hazard/ risk of other accidents.
• Induced current on railway lines with close proximity/ corona effect- CEQA report did not clearly address this for a 115KV line.
• Economic effect on the community from small to larger scale based on all of the above.

We demand further investigation and revisit other routes or proposals to resolve the power needs of the city. We have to ensure our and our kids’ health is not at stake in the name of development and infrastructure and are not in agreement for this project to move forward. We cannot approve this to move forward as of now given the lack of study and absence of a satisfactory solution/ mitigation provided in favor/ assurance to public health.

Additional References:

Research on effects of EMF on humans:

1. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6025786/ This research reinforces the concerns of EMF exposure effect on human health.

2. https://www.epa.gov/radtown/electric-and-magnetic-fields-power-lines This resource suggests taking precautions and keeping distance or limiting exposure. Residents would no longer have either of these two options per the current proposals if they are living there 24-7.

3. https://www.fastexpert.com/blog/should-i-buy-a-house-near-power-lines/ These are points of view from a real estate expert who clearly states that property value declines proportionately to the distance of the property from high tension lines. People have apprehensions whether or not research clearly defines the risk. Potential buyers might have low priority for a property too close to a high tension power line.

4. https://orchard.com/blog/posts/power-lines-and-property-value Another research on real estate values lowered due to high tension power lines proximity.

H-389
at You Can Do
If you are concerned about possible healt h risks from electric and magnet ic fields, you can:
• Increase the distance between yourself and the source. The greater t he distance betwee n you and th e source of EMF, th e lowe r your exposure.
• Limit the time spent around the source. The less time you spend near EMF, the lower you r NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: vinay iyer <[email protected]>
Sent: Thursday, August 29, 2024 4:17 PM
To: NRS-KRS Project; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community for the upcoming SVP project connecting the Northern Receiving Station NRS to Kifer receiving station (KRS)- NRS-KRS 115kV Transmission Line Project

To Whomsoever it may concern,
We are residents of Santa Clara that will be negatively impacted by the “NRS-KRS 115kV Transmission Line Project”. We have collectively reviewed the draft Initial Study/ Mitigated Negative declaration for “NRS-KRS 115kV Transmission Line Project” from July 2024. After reviewing this report and also attending the virtual and in person meetings, here are some references to emphasize our various concerns.

Reference #1 : CEQA’s reporting includes these State reviewing agencies: California Air Resources Board (ARB), California Department of Fish and Wildlife, Bay Delta Region 3 (CDFW), California Department of Forestry and Fire Protection (CAL FIRE), California Department of Parks and Recreation, California Department of Toxic Substances Control (DTSC), California Department of Transportation, District 4 (DOT), California Department of Transportation, Division of Aeronautics (DOT), California Department of Transportation, Division of Transportation Planning (DOT), California Department of Water Resources (DWR), California Energy Commission, California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Public Utilities Commission (CPUC), California Regional Water Quality Control Board, San Francisco Bay Region 2 (RWQCB), Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water.

Personal observation#1 : None of these agencies has any association with human health. CEQA reporting is not qualified enough to force the public to compromise on health concerns. Other agencies need to be involved to review this proposal, that are qualified to study the effect on “ humans”, not just wildlife and vegetation, or “ environment. The checklist is completely devoid of our gravest humanitarian concerns. It is quite shocking that the project has not included any study to understand the potential impact of EMF waves on human lives, given that the transmission lines are potentially less than 60 feet from the closest dwellings. The city of Santa Clara needs to step in and have third party/ independent studies completed in favor of human health.

Reference #2: Page 41 of report- Section 4.15. Electric and Magnetic Fields summary.

Personal observation#2 : This consideration was completely absent earlier. Only after the residents raised their voices, this section was added. To our greatest disappointment, this section is copied over from an older report on the “South Loop Reconfiguration Project” from 2020. One would have expected that a new study would have been conducted for a project this size. The lack of due diligence and ignorance towards the specifics of this project are apparent and not acceptable. In fact we have found several sections of this older report as being reused across the entire report.

The EMP map shared during the in person meeting had several flaws and we would like to question the viability of the study that was completed. What time of the day was the study completed and on what models were the values based on since these were done on assumption for the EMF values that would be there once the project is complete. Since we have seen the several sections of the report redundantly copied over from other reports, we would like a more detailed analysis of this report.

H-390
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Regarding EMF concerns for human health, there are plenty of scientific studies that do indicate the grave concern on human health with EMF exposures and we cannot ignore this aspect. Here is a reference to an article and there are plenty of articles listed here under references:
https://psc.wi.gov/Documents/Brochures/EMF.pdf

There are not enough references listed in the draft report provided to us, and the explanation provided seems to be conveniently using studies that prove otherwise. This needs more investigation and references. The solution provided as raising the height of the poles and increasing the distance is non- existent. It was confirmed during the in person meeting that the design will not be altered and the height was already designed as required according to the SVP team present there. It seems that the preparers of this report did not even read the report after copying pasting from the old report as evident in the list of proposed solutions is not applicable here.

The live presentation on August 22nd showed the comparison of EMF values of household objects as a means to show that everyday household items carry a similar range of mG( milli Gauss) units. This comparison was inherently flawed since it mentioned that the household devices were producing those level at 1 feet while those indicated for 115KVf lines were at 60 feet. further these household devices do not operate 24X7 similar to the transmission lines.

There were a lot of citations of reports showcasing that no clear proof of EMF to human health exists but we would like to also point out certain states like Connecticut Department of Public Health have cited reports that have shown an increased incidence of childhood leukemia( Blood cancer) at avg exposure of only 3 mG. Also they have called out that some utility workers exposed to high levels of emf have increase risks of Lur Gehrig's disease.

They also call out that most impacts of EMF from high voltage lines dissipate at ~300 feet.

These are available on Page 2 & Page 3 of this report: https://portal.ct.gov/-/media/departments- and-agencies/dph/dph/environmental_health/eoha/pdf/emffactsheet2008pdf.pdf This report has citations from WHO , National Institute of Environmental Health Sciences and California Department of Health Services.
https://www.niehs.nih.gov/sites/default/files/health/materials/electric_and_magnetic_fields_associ ated_with_the_use_of_electric_power_questions_and_answers_english_508.pdf

Reference #3

Page 174 ends

Personal observation#3
The railway line's proximity to the proposed high transmission lines is very concerning. The centerline distance from proposed lines to railway line is aproximately 50 feet per google maps with some margin for error. As per the report there are no Corona rings proposed for the 115KV lines. There seems to be negligence in design in consideration of the hazards posed by these high voltage lines as Corona effect can transfer current to railway lines. All the residents are at a high risk of accidental hazards given the proximity of the railway line, this project is adding on to the hazards. This section is only stating information about what Corona effect is, as may be required by law, which by the way is again a copy paste from an old report. The only concern discussed in more depth is the audible noise level. The concerns are presented to imply that this is not significant by stating that 115KV lines pose less than significant risk.

H-391
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Reference #4: Post meeting material from March 19th 2024 @https://santaclara.legistar.com/LegislationDetail.aspx?ID=6582415&GUID=E6E14646-3CF7-4D15- BB98-F18580696012&Options=&Search=
Personal observation#4: At surface level, it looks like Option #A was selected only based on Cost perspective, without any consideration to human health, young children, property values, Corona effect, long term sustainability perspective or any other factors. While its important to understand the results of CEQA study, its extremely critical to understand the negative impact of EMF on the many young children living around the proposed transmission lines. Without extensive research and study on the impact to young children and adult heath, we should not be approving such an incomplete proposal.

Page 6 ends

discussions with several real estate agents in the region, I have unanimously found all to agree that the real estate values of residences in close proximity to power lines goes down. Its hard to find potential buyers and most folks refrain from buying a house too close to high power transmission lines. There are 1000 plus residences in the area affected by this project. Even if we were to make very rough assumptions, and assume minimal cost reduction in property values and take an average loss of $100,000 per property in the current year, that goes to $100,000,000 of loss of equity to the public. This is not even accounting the businesses affected by this project. This long explanation was to raise a point that if the selection of route A was saving money to the city, this is costing a huge financial loss to the public, which is not acceptable. This decrease in property values will also directly impact the tax collection by the Santa Clara Assessor and result in lower tax revenue coming into the city of Santa Clara.

Reference #5 : Page 49 of report- Figure 5.1-2. Wall separating residences and Lafayette Street.

Personal observation#5: The picture is taken conveniently from the other side of the railway line which is actually Kingsbury street, inside a private community and not Lafayette street. This is further away from the proposed SVP lines. This is very misleading; see snapshots taken from Google maps below

H-392
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

And this is what is included on the report:

The Mission Garden Townhome community has no walls as such and the main entry to residences face the road directly and are the most impacted. There are several other single family homes on Lafayette street with the same impact, having an entryway directly on the street. This and including other citations of reusing sections of older reports, is all in all absolutely unacceptable and instills distrust. This further shows incompetency of the agency/ agencies preparing this report.

Conclusion: This project's initial study needs to expand beyond CEQA for approval from the public. The limited scope of CEQA has failed to address the following concerns we have:
• Health hazards due to EMF levels.- This is by far the gravest concern and CEQA is clearly not qualified to study that.
• Reduced property values- several references provided below.

H-393
NIIS-IOt$1l5cVT,.,,,.__LMlP11011K'T S,LAcmtfTIQ
Figure S.l -2. Wall Sepa~tlng Residences and Lafayette Strut NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
• Loss of Aesthetic appeal for potential real estate buyers/ new and current businesses. • Increase in audible noise levels during and post construction, which is already high in the area with presence of railway line and air traffic route. • Increased fire hazard/ risk of other accidents.
• Induced current on railway lines with close proximity/ corona effect- CEQA report did not clearly address this for a 115KV line.
• Economic effect on the community from small to larger scale based on all of the above.

We demand further investigation and revisit other routes or proposals to resolve the power needs of the city. We have to ensure our and our kids’ health is not at stake in the name of development and infrastructure and are not in agreement for this project to move forward. We cannot approve this to move forward as of now given the lack of study and absence of a satisfactory solution/ mitigation provided in favor/ assurance to public health.

Additional References:

Research on effects of EMF on humans:

1. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6025786/ This research reinforces the concerns of EMF exposure effect on human health.

2. https://www.epa.gov/radtown/electric-and-magnetic-fields-power-lines This resource suggests taking precautions and keeping distance or limiting exposure. Residents would no longer have either of these two options per the current proposals if they are living there 24-7.

3. https://www.fastexpert.com/blog/should-i-buy-a-house-near-power-lines/ These are points of view from a real estate expert who clearly states that property value declines proportionately to the distance of the property from high tension lines. People have apprehensions whether or not research clearly defines the risk. Potential buyers might have low priority for a property too close to a high tension power line.

4. https://orchard.com/blog/posts/power-lines-and-property-value Another research on real estate values lowered due to high tension power lines proximity.

--
Regards,
Vinay Iyer

H-394
at You Can Do
If you are concerned about possible health risks from elect ric and magnet ic fields, you can:
• Increase the distance between yourself and the source . The greater the distance betwee n you and th e source of EMF, the lowe r your exposure.
• Limit the time spent around the source . The less time you spend near EMF, the lowe r your NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: Preetika <[email protected]>
Sent: Wednesday, August 28, 2024 11:37 AM
To: Allie Jackman <[email protected]>
Cc: [email protected]; Mayor and Council <[email protected]>; DL SVP Info Group <[email protected]>; PlanningCommission
<[email protected]>; Manager <[email protected]> Subject: NRS-KRS 115kV Transmission Line Project- Comments

Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community for the upcoming SVP project connecting the Northern Receiving Station NRS to Kifer receiving station (KRS)- NRS-KRS 115kV Transmission Line Project

To Whomsoever it may concern,
We are residents of Santa Clara that will be negatively impacted by the “NRS-KRS 115kV Transmission Line Project”. We have collectively reviewed the draft Initial Study/ Mitigated Negative declaration for “NRS-KRS 115kV Transmission Line Project” from July 2024. After reviewing this report and also attending the virtual and in person meetings, here are some references to emphasize our various concerns.

Reference #1 : CEQA’s reporting includes these State reviewing agencies: California Air Resources Board (ARB), California Department of Fish and Wildlife, Bay Delta Region 3 (CDFW), California Department of Forestry and Fire Protection (CAL FIRE), California Department of Parks and Recreation, California Department of Toxic Substances Control (DTSC), California Department of Transportation, District 4 (DOT), California Department of Transportation, Division of Aeronautics (DOT), California Department of Transportation, Division of Transportation Planning (DOT), California Department of Water Resources (DWR), California Energy Commission, California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Public Utilities Commission (CPUC), California Regional Water Quality Control Board, San Francisco Bay Region 2 (RWQCB), Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water.

Personal observation#1 : None of these agencies has any association with human health. CEQA reporting is not qualified enough to force the public to compromise on health concerns. Other agencies need to be involved to review this proposal, that are qualified to study the effect on “ humans”, not just wildlife and vegetation, or “ environment. The checklist is completely devoid of our gravest humanitarian concerns. It is quite shocking that the project has not included any study to understand the potential impact of EMF waves on human lives, given that the transmission lines are potentially less than 60 feet from the closest dwellings. The city of Santa Clara needs to step in and have third party/ independent studies completed in favor of human health.

Reference #2: Page 41 of report- Section 4.15. Electric and Magnetic Fields summary.

Personal observation#2 : This consideration was completely absent earlier. Only after the residents raised their voices, this section was added. To our greatest disappointment, this section is copied over from an older report on the “South Loop Reconfiguration Project” from 2020. One would have expected that a new study would have been conducted for a project this size. The lack of due diligence and You don't often get email from [email protected]. Learn why this is important H-395
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
ignorance towards the specifics of this project are apparent and not acceptable. In fact we have found several sections of this older report as being reused across the entire report.

The EMP map shared during the in person meeting had several flaws and we would like to question the viability of the study that was completed. What time of the day was the study completed and on what models were the values based on since these were done on assumption for the EMF values that would be there once the project is complete. Since we have seen the several sections of the report redundantly copied over from other reports, we would like a more detailed analysis of this report.

Regarding EMF concerns for human health, there are plenty of scientific studies that do indicate the grave concern on human health with EMF exposures and we cannot ignore this aspect. Here is a reference to an article and there are plenty of articles listed here under references:
https://psc.wi.gov/Documents/Brochures/EMF.pdf
There are not enough references listed in the draft report provided to us, and the explanation provided seems to be conveniently using studies that prove otherwise. This needs more investigation and references. The solution provided as raising the height of the poles and increasing the distance is non- existent. It was confirmed during the in person meeting that the design will not be altered and the height was already designed as required according to the SVP team present there. It seems that the preparers of this report did not even read the report after copying pasting from the old report as evident in the list of proposed solutions is not applicable here.

The live presentation on August 22nd showed the comparison of EMF values of household objects as a means to show that everyday household items carry a similar range of mG( milli Gauss) units. This comparison was inherently flawed since it mentioned that the household devices were producing those level at 1 feet while those indicated for 115KVf lines were at 60 feet. further these household devices do not operate 24X7 similar to the transmission lines.

There were a lot of citations of reports showcasing that no clear proof of EMF to human health exists but we would like to also point out certain states like Connecticut Department of Public Health have cited reports that have shown an increased incidence of childhood leukemia( Blood cancer) at avg exposure of only 3 mG. Also they have called out that some utility workers exposed to high levels of emf have increase risks of Lur Gehrig's disease.

They also call out that most impacts of EMF from high voltage lines dissipate at ~300 feet.

These are available on Page 2 & Page 3 of this report: https://portal.ct.gov/-/media/departments- and-agencies/dph/dph/environmental_health/eoha/pdf/emffactsheet2008pdf.pdf This report has citations from WHO , National Institute of Environmental Health Sciences and California Department of Health Services.
https://www.niehs.nih.gov/sites/default/files/health/materials/electric_and_magnetic_fields_associ ated_with_the_use_of_electric_power_questions_and_answers_english_508.pdf

Reference #3

Page 174 ends

H-396
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Personal observation#3
The railway line's proximity to the proposed high transmission lines is very concerning. The centerline distance from proposed lines to railway line is aproximately 50 feet per google maps with some margin for error. As per the report there are no Corona rings proposed for the 115KV lines. There seems to be negligence in design in consideration of the hazards posed by these high voltage lines as Corona effect can transfer current to railway lines. All the residents are at a high risk of accidental hazards given the proximity of the railway line, this project is adding on to the hazards. This section is only stating information about what Corona effect is, as may be required by law, which by the way is again a copy paste from an old report. The only concern discussed in more depth is the audible noise level. The concerns are presented to imply that this is not significant by stating that 115KV lines pose less than significant risk.

Reference #4: Post meeting material from March 19th 2024 @https://santaclara.legistar.com/LegislationDetail.aspx?ID=6582415&GUID=E6E14646-3CF7-4D15- BB98-F18580696012&Options=&Search=
Personal observation#4: At surface level, it looks like Option #A was selected only based on Cost perspective, without any consideration to human health, young children, property values, Corona effect, long term sustainability perspective or any other factors. While its important to understand the results of CEQA study, its extremely critical to understand the negative impact of EMF on the many young children living around the proposed transmission lines. Without extensive research and study on the impact to young children and adult heath, we should not be approving such an incomplete proposal.

Page 6 ends

discussions with several real estate agents in the region, I have unanimously found all to agree that the real estate values of residences in close proximity to power lines goes down. Its hard to find potential buyers and most folks refrain from buying a house too close to high power transmission lines. There are 1000 plus residences in the area affected by this project. Even if we were to make very rough assumptions, and assume minimal cost reduction in property values and take an average loss of $100,000 per property in the current year, that goes to $100,000,000 of loss of equity to the public. This is not even accounting the businesses affected by this project. This long explanation was to raise a point that if the selection of route A was saving money to the city, this is costing a huge financial loss to the public, which is not acceptable. This decrease in property values will also directly impact the tax collection by the Santa Clara Assessor and result in lower tax revenue coming into the city of Santa Clara.

Reference #5 : Page 49 of report- Figure 5.1-2. Wall separating residences and Lafayette Street.

Personal observation#5: The picture is taken conveniently from the other side of the railway line which is actually Kingsbury street, inside a private community and not Lafayette street. This is further away from the proposed SVP lines. This is very misleading; see snapshots taken from Google maps below H-397
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

And this is what is included on the report:

H-398
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

The Mission Garden Townhome community has no walls as such and the main entry to residences face the road directly and are the most impacted. There are several other single family homes on Lafayette street with the same impact, having an entryway directly on the street. This and including other citations of reusing sections of older reports, is all in all absolutely unacceptable and instills distrust. This further shows incompetency of the agency/ agencies preparing this report.

Conclusion: This project's initial study needs to expand beyond CEQA for approval from the public. The limited scope of CEQA has failed to address the following concerns we have:
• Health hazards due to EMF levels.- This is by far the gravest concern and CEQA is clearly not qualified to study that.
• Reduced property values- several references provided below. • Loss of Aesthetic appeal for potential real estate buyers/ new and current businesses.
• Increase in audible noise levels during and post construction, which is already high in the area with presence of railway line and air traffic route. • Increased fire hazard/ risk of other accidents.
• Induced current on railway lines with close proximity/ corona effect- CEQA report did not clearly address this for a 115KV line.
• Economic effect on the community from small to larger scale based on all of the above.

We demand further investigation and revisit other routes or proposals to resolve the power needs of the city. We have to ensure our and our kids’ health is not at stake in the name of development and infrastructure and are not in agreement for this project to move forward. We cannot approve this to move forward as of now given the lack of study and absence of a satisfactory solution/ mitigation provided in favor/ assurance to public health.

H-399
HRS-HS 115cYT~UM PIOIIC1
Fl1Urt s.1.2. W•II S.p•r•tlns Ruklences and Laf•veue Street I Stpvot 119 Raidtncts a,d Llflytllt St1911
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Additional References:

Research on effects of EMF on humans:

1. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6025786/ This research reinforces the concerns of EMF exposure effect on human health.

2. https://www.epa.gov/radtown/electric-and-magnetic-fields-power-lines This resource suggests taking precautions and keeping distance or limiting exposure. Residents would no longer have either of these two options per the current proposals if they are living there 24-7.

3. https://www.fastexpert.com/blog/should-i-buy-a-house-near-power-lines/ These are points of view from a real estate expert who clearly states that property value declines proportionately to the distance of the property from high tension lines. People have apprehensions whether or not research clearly defines the risk. Potential buyers might have low priority for a property too close to a high tension power line.

4. https://orchard.com/blog/posts/power-lines-and-property-value Another research on real estate values lowered due to high tension power lines proximity.

Thanks for your time and urgent attention on the matter Preetika Tiwari
Resident of 4489 Lafayette st, Santa Clara

H-400
at You Can Do
If you are concerned about possible health risks from electric and magnetic fields, you can:
• Increase the distance between yourself and the source. The greater t he distance between you and th e source of EMF, th e lowe r your exposure.
• Limit the time spent around the source. The less tim e you spend near EMF, th e lower your NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: kanupriya kabra <[email protected]>
Sent: Wednesday, August 28, 2024 11:48 AM
To: NRS-KRS Project; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community for the upcoming SVP project connecting the Northern Receiving Station NRS to Kifer receiving station (KRS)- NRS-KRS 115kV Transmission Line Project

To Whomsoever it may concern,
We are residents of Santa Clara that will be negatively impacted by the “NRS-KRS 115kV Transmission Line Project”. We have collectively reviewed the draft Initial Study/ Mitigated Negative declaration for “NRS-KRS 115kV Transmission Line Project” from July 2024. After reviewing this report and also attending the virtual and in person meetings, here are some references to emphasize our various concerns.

Reference #1 : CEQA’s reporting includes these State reviewing agencies: California Air Resources Board (ARB), California Department of Fish and Wildlife, Bay Delta Region 3 (CDFW), California Department of Forestry and Fire Protection (CAL FIRE), California Department of Parks and Recreation, California Department of Toxic Substances Control (DTSC), California Department of Transportation, District 4 (DOT), California Department of Transportation, Division of Aeronautics (DOT), California Department of Transportation, Division of Transportation Planning (DOT), California Department of Water Resources (DWR), California Energy Commission, California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Public Utilities Commission (CPUC), California Regional Water Quality Control Board, San Francisco Bay Region 2 (RWQCB), Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water.

Personal observation#1 : None of these agencies has any association with human health. CEQA reporting is not qualified enough to force the public to compromise on health concerns. Other agencies need to be involved to review this proposal, that are qualified to study the effect on “ humans”, not just wildlife and vegetation, or “ environment. The checklist is completely devoid of our gravest humanitarian concerns. It is quite shocking that the project has not included any study to understand the potential impact of EMF waves on human lives, given that the transmission lines are potentially less than 60 feet from the closest dwellings. The city of Santa Clara needs to step in and have third party/ independent studies completed in favor of human health.

Reference #2: Page 41 of report- Section 4.15. Electric and Magnetic Fields summary.

Personal observation#2 : This consideration was completely absent earlier. Only after the residents raised their voices, this section was added. To our greatest disappointment, this section is copied over from an older report on the “South Loop Reconfiguration Project” from 2020. One would have expected that a new study would have been conducted for a project this size. The lack of due diligence and ignorance towards the specifics of this project are apparent and not acceptable. In fact we have found several sections of this older report as being reused across the entire report.

The EMP map shared during the in person meeting had several flaws and we would like to question the viability of the study that was completed. What time of the day was the study completed and on what models were the values based on since these were done on assumption for the EMF values that would be there once the project is complete. Since we have seen the several sections of the report redundantly copied over from other reports, we would like a more detailed analysis of this report.

H-401
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Regarding EMF concerns for human health, there are plenty of scientific studies that do indicate the grave concern on human health with EMF exposures and we cannot ignore this aspect. Here is a reference to an article and there are plenty of articles listed here under references:
https://psc.wi.gov/Documents/Brochures/EMF.pdf

There are not enough references listed in the draft report provided to us, and the explanation provided seems to be conveniently using studies that prove otherwise. This needs more investigation and references. The solution provided as raising the height of the poles and increasing the distance is non- existent. It was confirmed during the in person meeting that the design will not be altered and the height was already designed as required according to the SVP team present there. It seems that the preparers of this report did not even read the report after copying pasting from the old report as evident in the list of proposed solutions is not applicable here.

The live presentation on August 22nd showed the comparison of EMF values of household objects as a means to show that everyday household items carry a similar range of mG( milli Gauss) units. This comparison was inherently flawed since it mentioned that the household devices were producing those level at 1 feet while those indicated for 115KVf lines were at 60 feet. further these household devices do not operate 24X7 similar to the transmission lines.

There were a lot of citations of reports showcasing that no clear proof of EMF to human health exists but we would like to also point out certain states like Connecticut Department of Public Health have cited reports that have shown an increased incidence of childhood leukemia( Blood cancer) at avg exposure of only 3 mG. Also they have called out that some utility workers exposed to high levels of emf have increase risks of Lur Gehrig's disease.

They also call out that most impacts of EMF from high voltage lines dissipate at ~300 feet.

These are available on Page 2 & Page 3 of this report: https://portal.ct.gov/-/media/departments- and-agencies/dph/dph/environmental_health/eoha/pdf/emffactsheet2008pdf.pdf This report has citations from WHO , National Institute of Environmental Health Sciences and California Department of Health Services.
https://www.niehs.nih.gov/sites/default/files/health/materials/electric_and_magnetic_fields_associ ated_with_the_use_of_electric_power_questions_and_answers_english_508.pdf

Reference #3

Page 174 ends

Personal observation#3
The railway line's proximity to the proposed high transmission lines is very concerning. The centerline distance from proposed lines to railway line is aproximately 50 feet per google maps with some margin for error. As per the report there are no Corona rings proposed for the 115KV lines. There seems to be negligence in design in consideration of the hazards posed by these high voltage lines as Corona effect can transfer current to railway lines. All the residents are at a high risk of accidental hazards given the proximity of the railway line, this project is adding on to the hazards. This section is only stating information about what Corona effect is, as may be required by law, which by the way is again a copy paste from an old report. The only concern discussed in more depth is the audible noise level. The concerns are presented to imply that this is not significant by stating that 115KV lines pose less than significant risk.

H-402
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Reference #4: Post meeting material from March 19th 2024 @https://santaclara.legistar.com/LegislationDetail.aspx?ID=6582415&GUID=E6E14646-3CF7-4D15- BB98-F18580696012&Options=&Search=
Personal observation#4: At surface level, it looks like Option #A was selected only based on Cost perspective, without any consideration to human health, young children, property values, Corona effect, long term sustainability perspective or any other factors. While its important to understand the results of CEQA study, its extremely critical to understand the negative impact of EMF on the many young children living around the proposed transmission lines. Without extensive research and study on the impact to young children and adult heath, we should not be approving such an incomplete proposal.

Page 6 ends

discussions with several real estate agents in the region, I have unanimously found all to agree that the real estate values of residences in close proximity to power lines goes down. Its hard to find potential buyers and most folks refrain from buying a house too close to high power transmission lines. There are 1000 plus residences in the area affected by this project. Even if we were to make very rough assumptions, and assume minimal cost reduction in property values and take an average loss of $100,000 per property in the current year, that goes to $100,000,000 of loss of equity to the public. This is not even accounting the businesses affected by this project. This long explanation was to raise a point that if the selection of route A was saving money to the city, this is costing a huge financial loss to the public, which is not acceptable. This decrease in property values will also directly impact the tax collection by the Santa Clara Assessor and result in lower tax revenue coming into the city of Santa Clara.

Reference #5 : Page 49 of report- Figure 5.1-2. Wall separating residences and Lafayette Street.

Personal observation#5: The picture is taken conveniently from the other side of the railway line which is actually Kingsbury street, inside a private community and not Lafayette street. This is further away from the proposed SVP lines. This is very misleading; see snapshots taken from Google maps below

H-403
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

And this is what is included on the report:

The Mission Garden Townhome community has no walls as such and the main entry to residences face the road directly and are the most impacted. There are several other single family homes on Lafayette street with the same impact, having an entryway directly on the street. This and including other citations of reusing sections of older reports, is all in all absolutely unacceptable and instills distrust. This further shows incompetency of the agency/ agencies preparing this report.

Conclusion: This project's initial study needs to expand beyond CEQA for approval from the public. The limited scope of CEQA has failed to address the following concerns we have:

H-404
Figure S.1·2- Wall Separating Residences and Lafayette: Street Juu2024

5.l. A6Tl-tftlCS
Flgun5 .1-2
w,n S•p1rat1ng R11idfflc:n and Laf1)'fltl: StrNt
AoMltflSTU.TllltOlwl MN0/15
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
• Health hazards due to EMF levels.- This is by far the gravest concern and CEQA is clearly not qualified to study that.
• Reduced property values- several references provided below. • Loss of Aesthetic appeal for potential real estate buyers/ new and current businesses. • Increase in audible noise levels during and post construction, which is already high in the area with presence of railway line and air traffic route. • Increased fire hazard/ risk of other accidents.
• Induced current on railway lines with close proximity/ corona effect- CEQA report did not clearly address this for a 115KV line.
• Economic effect on the community from small to larger scale based on all of the above.

We demand further investigation and revisit other routes or proposals to resolve the power needs of the city. We have to ensure our and our kids’ health is not at stake in the name of development and infrastructure and are not in agreement for this project to move forward. We cannot approve this to move forward as of now given the lack of study and absence of a satisfactory solution/ mitigation provided in favor/ assurance to public health.

Thanks & Regards,
Kanupriya

Additional References:

Research on effects of EMF on humans:

1. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6025786/ This research reinforces the concerns of EMF exposure effect on human health.

2. https://www.epa.gov/radtown/electric-and-magnetic-fields-power-lines This resource suggests taking precautions and keeping distance or limiting exposure. Residents would no longer have either of these two options per the current proposals if they are living there 24-7.

3. https://www.fastexpert.com/blog/should-i-buy-a-house-near-power-lines/ These are points of view from a real estate expert who clearly states that property value declines proportionately to the distance of the property from high tension lines. People have apprehensions whether or not research clearly defines the risk. Potential buyers might have low priority for a property too close to a high tension power line.

4. https://orchard.com/blog/posts/power-lines-and-property-value Another research on real estate values lowered due to high tension power lines proximity.

H-405
at You Can Do
If you are concerned about possible health risks from elect ric and magnetic fields, you can:
• Increase the distance between yourself and the source. The greater the distance between you and th e source of EMF, the lowe r your exposure.
• Limit the time spent around the source. The less tim e you spend near EMF, the lowe r your NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: Ruchika Sarna <[email protected]>
Sent: Tuesday, August 27, 2024 10:31 PM
To: NRS-KRS Project; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community for the upcoming SVP project connecting the Northern Receiving Station NRS to Kifer receiving station (KRS)- NRS-KRS 115kV Transmission Line Project

To Whomsoever it may concern,
We are residents of Santa Clara that will be negatively impacted by the “NRS-KRS 115kV Transmission Line Project”. We have collectively reviewed the draft Initial Study/ Mitigated Negative declaration for “NRS-KRS 115kV Transmission Line Project” from July 2024. After reviewing this report and also attending the virtual and in person meetings, here are some references to emphasize our various concerns.

Reference #1 : CEQA’s reporting includes these State reviewing agencies: California Air Resources Board (ARB), California Department of Fish and Wildlife, Bay Delta Region 3 (CDFW), California Department of Forestry and Fire Protection (CAL FIRE), California Department of Parks and Recreation, California Department of Toxic Substances Control (DTSC), California Department of Transportation, District 4 (DOT), California Department of Transportation, Division of Aeronautics (DOT), California Department of Transportation, Division of Transportation Planning (DOT), California Department of Water Resources (DWR), California Energy Commission, California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Public Utilities Commission (CPUC), California Regional Water Quality Control Board, San Francisco Bay Region 2 (RWQCB), Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water.

Personal observation#1 : None of these agencies has any association with human health. CEQA reporting is not qualified enough to force the public to compromise on health concerns. Other agencies need to be involved to review this proposal, that are qualified to study the effect on “ humans”, not just wildlife and vegetation, or “ environment. The checklist is completely devoid of our gravest humanitarian concerns. It is quite shocking that the project has not included any study to understand the potential impact of EMF waves on human lives, given that the transmission lines are potentially less than 60 feet from the closest dwellings. The city of Santa Clara needs to step in and have third party/ independent studies completed in favor of human health.

Reference #2: Page 41 of report- Section 4.15. Electric and Magnetic Fields summary.

Personal observation#2 : This consideration was completely absent earlier. Only after the residents raised their voices, this section was added. To our greatest disappointment, this section is copied over from an older report on the “South Loop Reconfiguration Project” from 2020. One would have expected that a new study would have been conducted for a project this size. The lack of due diligence and ignorance towards the specifics of this project are apparent and not acceptable. In fact we have found several sections of this older report as being reused across the entire report.

The EMP map shared during the in person meeting had several flaws and we would like to question the viability of the study that was completed. What time of the day was the study completed and on what models were the values based on since these were done on assumption for the EMF values that would be there once the project is complete. Since we have seen the several sections of the report redundantly copied over from other reports, we would like a more detailed analysis of this report.

H-406
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Regarding EMF concerns for human health, there are plenty of scientific studies that do indicate the grave concern on human health with EMF exposures and we cannot ignore this aspect. Here is a reference to an article and there are plenty of articles listed here under references:
https://psc.wi.gov/Documents/Brochures/EMF.pdf

There are not enough references listed in the draft report provided to us, and the explanation provided seems to be conveniently using studies that prove otherwise. This needs more investigation and references. The solution provided as raising the height of the poles and increasing the distance is non- existent. It was confirmed during the in person meeting that the design will not be altered and the height was already designed as required according to the SVP team present there. It seems that the preparers of this report did not even read the report after copying pasting from the old report as evident in the list of proposed solutions is not applicable here.

The live presentation on August 22nd showed the comparison of EMF values of household objects as a means to show that everyday household items carry a similar range of mG( milli Gauss) units. This comparison was inherently flawed since it mentioned that the household devices were producing those level at 1 feet while those indicated for 115KVf lines were at 60 feet. further these household devices do not operate 24X7 similar to the transmission lines.

There were a lot of citations of reports showcasing that no clear proof of EMF to human health exists but we would like to also point out certain states like Connecticut Department of Public Health have cited reports that have shown an increased incidence of childhood leukemia( Blood cancer) at avg exposure of only 3 mG. Also they have called out that some utility workers exposed to high levels of emf have increase risks of Lur Gehrig's disease.

They also call out that most impacts of EMF from high voltage lines dissipate at ~300 feet.

These are available on Page 2 & Page 3 of this report: https://portal.ct.gov/-/media/departments- and-agencies/dph/dph/environmental_health/eoha/pdf/emffactsheet2008pdf.pdf This report has citations from WHO , National Institute of Environmental Health Sciences and California Department of Health Services.
https://www.niehs.nih.gov/sites/default/files/health/materials/electric_and_magnetic_fields_associ ated_with_the_use_of_electric_power_questions_and_answers_english_508.pdf

Reference #3

Page 174 ends

Personal observation#3
The railway line's proximity to the proposed high transmission lines is very concerning. The centerline distance from proposed lines to railway line is aproximately 50 feet per google maps with some margin for error. As per the report there are no Corona rings proposed for the 115KV lines. There seems to be negligence in design in consideration of the hazards posed by these high voltage lines as Corona effect can transfer current to railway lines. All the residents are at a high risk of accidental hazards given the proximity of the railway line, this project is adding on to the hazards. This section is only stating information about what Corona effect is, as may be required by law, which by the way is again a copy paste from an old report. The only concern discussed in more depth is the audible noise level. The concerns are presented to imply that this is not significant by stating that 115KV lines pose less than significant risk.

H-407
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Reference #4: Post meeting material from March 19th 2024 @https://santaclara.legistar.com/LegislationDetail.aspx?ID=6582415&GUID=E6E14646-3CF7-4D15- BB98-F18580696012&Options=&Search=
Personal observation#4: At surface level, it looks like Option #A was selected only based on Cost perspective, without any consideration to human health, young children, property values, Corona effect, long term sustainability perspective or any other factors. While its important to understand the results of CEQA study, its extremely critical to understand the negative impact of EMF on the many young children living around the proposed transmission lines. Without extensive research and study on the impact to young children and adult heath, we should not be approving such an incomplete proposal.

Page 6 ends

discussions with several real estate agents in the region, I have unanimously found all to agree that the real estate values of residences in close proximity to power lines goes down. Its hard to find potential buyers and most folks refrain from buying a house too close to high power transmission lines. There are 1000 plus residences in the area affected by this project. Even if we were to make very rough assumptions, and assume minimal cost reduction in property values and take an average loss of $100,000 per property in the current year, that goes to $100,000,000 of loss of equity to the public. This is not even accounting the businesses affected by this project. This long explanation was to raise a point that if the selection of route A was saving money to the city, this is costing a huge financial loss to the public, which is not acceptable. This decrease in property values will also directly impact the tax collection by the Santa Clara Assessor and result in lower tax revenue coming into the city of Santa Clara.

Reference #5 : Page 49 of report- Figure 5.1-2. Wall separating residences and Lafayette Street.

Personal observation#5: The picture is taken conveniently from the other side of the railway line which is actually Kingsbury street, inside a private community and not Lafayette street. This is further away from the proposed SVP lines. This is very misleading; see snapshots taken from Google maps below

H-408
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

And this is what is included on the report:

The Mission Garden Townhome community has no walls as such and the main entry to residences face the road directly and are the most impacted. There are several other single family homes on Lafayette street with the same impact, having an entryway directly on the street. This and including other citations of reusing sections of older reports, is all in all absolutely unacceptable and instills distrust. This further shows incompetency of the agency/ agencies preparing this report.

H-409
NftS..KRS l l SKVTMHSMISSION IJN£h0l(CT S.l . AlSTHlTICS Figure 5.1-Z. Wall Separating Residences and Lafayette Street Wall Stp&rlbng R11ldtncn and ufayettt Slrfft
Jt.u2024 5.1-5 AOMINISlltATMOIIAFtMNO/IS
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Conclusion: This project's initial study needs to expand beyond CEQA for approval from the public. The limited scope of CEQA has failed to address the following concerns we have:
• Health hazards due to EMF levels.- This is by far the gravest concern and CEQA is clearly not qualified to study that.
• Reduced property values- several references provided below. • Loss of Aesthetic appeal for potential real estate buyers/ new and current businesses. • Increase in audible noise levels during and post construction, which is already high in the area with presence of railway line and air traffic route. • Increased fire hazard/ risk of other accidents.
• Induced current on railway lines with close proximity/ corona effect- CEQA report did not clearly address this for a 115KV line.
• Economic effect on the community from small to larger scale based on all of the above.

We demand further investigation and revisit other routes or proposals to resolve the power needs of the city. We have to ensure our and our kids’ health is not at stake in the name of development and infrastructure and are not in agreement for this project to move forward. We cannot approve this to move forward as of now given the lack of study and absence of a satisfactory solution/ mitigation provided in favor/ assurance to public health.

Additional References:

Research on effects of EMF on humans:

1. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6025786/ This research reinforces the concerns of EMF exposure effect on human health.

2. https://www.epa.gov/radtown/electric-and-magnetic-fields-power-lines This resource suggests taking precautions and keeping distance or limiting exposure. Residents would no longer have either of these two options per the current proposals if they are living there 24-7.

3. https://www.fastexpert.com/blog/should-i-buy-a-house-near-power-lines/ These are points of view from a real estate expert who clearly states that property value declines proportionately to the distance of the property from high tension lines. People have apprehensions whether or not research clearly defines the risk. Potential buyers might have low priority for a property too close to a high tension power line.

4. https://orchard.com/blog/posts/power-lines-and-property-value Another research on real estate values lowered due to high tension power lines proximity.

H-410
at You Can Do
If you are concerned about possible health risks from electric and magnetic fields, you can:
• Increase the distance between yourself and the source. The greater the distance between you and the source of EMF, the lower your exposure.
• Limit the time spent around the source. The less time you spend near EMF, th e lower your NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: Ruchika Sarna <[email protected]>
Sent: Wednesday, August 28, 2024 12:32 AM
To: NRS-KRS Project <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>
Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community for the upcoming SVP project connecting the Northern Receiving Station NRS to Kifer receiving station (KRS)- NRS-KRS 115kV Transmission Line Project

To Whomsoever it may concern,
We are residents of Santa Clara that will be negatively impacted by the “NRS-KRS 115kV Transmission Line Project”. We have collectively reviewed the draft Initial Study/ Mitigated Negative declaration for “NRS-KRS 115kV Transmission Line Project” from July 2024. After reviewing this report and also attending the virtual and in person meetings, here are some references to emphasize our various concerns.

Reference #1 : CEQA’s reporting includes these State reviewing agencies: California Air Resources Board (ARB), California Department of Fish and Wildlife, Bay Delta Region 3 (CDFW), California Department of Forestry and Fire Protection (CAL FIRE), California Department of Parks and Recreation, California Department of Toxic Substances Control (DTSC), California Department of Transportation, District 4 (DOT), California Department of Transportation, Division of Aeronautics (DOT), California Department of Transportation, Division of Transportation Planning (DOT), California Department of Water Resources (DWR), California Energy Commission, California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Public Utilities Commission (CPUC), California Regional Water Quality Control Board, San Francisco Bay Region 2 (RWQCB), Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water.

Personal observation#1 : None of these agencies has any association with human health. CEQA reporting is not qualified enough to force the public to compromise on health concerns. Other agencies need to be involved to review this proposal, that are qualified to study the effect on “ humans”, not just wildlife and vegetation, or “ environment. The checklist is completely devoid of our gravest humanitarian concerns. It is quite shocking that the project has not included any study to understand the potential impact of EMF waves on human lives, given that the transmission lines are potentially less than 60 feet from the closest dwellings. The city of Santa Clara needs to step in and have third party/ independent studies completed in favor of human health.

Reference #2: Page 41 of report- Section 4.15. Electric and Magnetic Fields summary.

Personal observation#2 : This consideration was completely absent earlier. Only after the residents raised their voices, this section was added. To our greatest disappointment, this section is copied over from an older report on the “South Loop Reconfiguration Project” from 2020. One would have expected that a new study would have been conducted for a project this size. The lack of due diligence and ignorance towards the specifics of this project are apparent and not acceptable. In fact we have found several sections of this older report as being reused across the entire report.

The EMP map shared during the in person meeting had several flaws and we would like to question the viability of the study that was completed. What time of the day was the study completed and on what H-411
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
models were the values based on since these were done on assumption for the EMF values that would be there once the project is complete. Since we have seen the several sections of the report redundantly copied over from other reports, we would like a more detailed analysis of this report.

Regarding EMF concerns for human health, there are plenty of scientific studies that do indicate the grave concern on human health with EMF exposures and we cannot ignore this aspect. Here is a reference to an article and there are plenty of articles listed here under references:
https://psc.wi.gov/Documents/Brochures/EMF.pdf

There are not enough references listed in the draft report provided to us, and the explanation provided seems to be conveniently using studies that prove otherwise. This needs more investigation and references. The solution provided as raising the height of the poles and increasing the distance is non- existent. It was confirmed during the in person meeting that the design will not be altered and the height was already designed as required according to the SVP team present there. It seems that the preparers of this report did not even read the report after copying pasting from the old report as evident in the list of proposed solutions is not applicable here.

The live presentation on August 22nd showed the comparison of EMF values of household objects as a means to show that everyday household items carry a similar range of mG( milli Gauss) units. This comparison was inherently flawed since it mentioned that the household devices were producing those level at 1 feet while those indicated for 115KVf lines were at 60 feet. further these household devices do not operate 24X7 similar to the transmission lines.

There were a lot of citations of reports showcasing that no clear proof of EMF to human health exists but we would like to also point out certain states like Connecticut Department of Public Health have cited reports that have shown an increased incidence of childhood leukemia( Blood cancer) at avg exposure of only 3 mG. Also they have called out that some utility workers exposed to high levels of emf have increase risks of Lur Gehrig's disease.

They also call out that most impacts of EMF from high voltage lines dissipate at ~300 feet.

These are available on Page 2 & Page 3 of this report: https://portal.ct.gov/-/media/departments- and-agencies/dph/dph/environmental_health/eoha/pdf/emffactsheet2008pdf.pdf This report has citations from WHO , National Institute of Environmental Health Sciences and California Department of Health Services.
https://www.niehs.nih.gov/sites/default/files/health/materials/electric_and_magnetic_fields_associ ated_with_the_use_of_electric_power_questions_and_answers_english_508.pdf

Reference #3

Page 174 ends

Personal observation#3
The railway line's proximity to the proposed high transmission lines is very concerning. The centerline distance from proposed lines to railway line is aproximately 50 feet per google maps with some margin for error. As per the report there are no Corona rings proposed for the 115KV lines. There seems to be negligence in design in consideration of the hazards posed by these high voltage lines as Corona effect can transfer current to railway lines. All the residents are at a high risk of accidental hazards given the proximity of the railway line, this project is adding on to the hazards. This section is only stating information about what Corona effect is, as may be required by law, which by the way is again a copy paste from an old report. The only concern discussed in more depth is the audible noise level. The H-412
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
concerns are presented to imply that this is not significant by stating that 115KV lines pose less than significant risk.

Reference #4: Post meeting material from March 19th 2024 @https://santaclara.legistar.com/LegislationDetail.aspx?ID=6582415&GUID=E6E14646-3CF7-4D15- BB98-F18580696012&Options=&Search=
Personal observation#4: At surface level, it looks like Option #A was selected only based on Cost perspective, without any consideration to human health, young children, property values, Corona effect, long term sustainability perspective or any other factors. While its important to understand the results of CEQA study, its extremely critical to understand the negative impact of EMF on the many young children living around the proposed transmission lines. Without extensive research and study on the impact to young children and adult heath, we should not be approving such an incomplete proposal.

Page 6 ends

discussions with several real estate agents in the region, I have unanimously found all to agree that the real estate values of residences in close proximity to power lines goes down. Its hard to find potential buyers and most folks refrain from buying a house too close to high power transmission lines. There are 1000 plus residences in the area affected by this project. Even if we were to make very rough assumptions, and assume minimal cost reduction in property values and take an average loss of $100,000 per property in the current year, that goes to $100,000,000 of loss of equity to the public. This is not even accounting the businesses affected by this project. This long explanation was to raise a point that if the selection of route A was saving money to the city, this is costing a huge financial loss to the public, which is not acceptable. This decrease in property values will also directly impact the tax collection by the Santa Clara Assessor and result in lower tax revenue coming into the city of Santa Clara.

Reference #5 : Page 49 of report- Figure 5.1-2. Wall separating residences and Lafayette Street.

Personal observation#5: The picture is taken conveniently from the other side of the railway line which is actually Kingsbury street, inside a private community and not Lafayette street. This is further away from the proposed SVP lines. This is very misleading; see snapshots taken from Google maps below

H-413
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

And this is what is included on the report:

The Mission Garden Townhome community has no walls as such and the main entry to residences face the road directly and are the most impacted. There are several other single family homes on Lafayette street with the same impact, having an entryway directly on the street. This and including other citations of reusing sections of older reports, is all in all absolutely unacceptable and instills distrust. This further shows incompetency of the agency/ agencies preparing this report.

H-414
NRS-KRS llS.CVTI\MSMISSK)fl'I..IHEPN>JECT 5.1. AlSTit£TICS Figure 5.1· 2, Wall Separating Residences and Lafayett e Street Wall Separating Ruldtncn and ufayettt StrNt
JULY202 4 5.1·5 Al>MINl5JU.T'IV{ o...r, MN0/15
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Conclusion: This project's initial study needs to expand beyond CEQA for approval from the public. The limited scope of CEQA has failed to address the following concerns we have:
• Health hazards due to EMF levels.- This is by far the gravest concern and CEQA is clearly not qualified to study that.
• Reduced property values- several references provided below. • Loss of Aesthetic appeal for potential real estate buyers/ new and current businesses. • Increase in audible noise levels during and post construction, which is already high in the area with presence of railway line and air traffic route. • Increased fire hazard/ risk of other accidents.
• Induced current on railway lines with close proximity/ corona effect- CEQA report did not clearly address this for a 115KV line.
• Economic effect on the community from small to larger scale based on all of the above.

We demand further investigation and revisit other routes or proposals to resolve the power needs of the city. We have to ensure our and our kids’ health is not at stake in the name of development and infrastructure and are not in agreement for this project to move forward. We cannot approve this to move forward as of now given the lack of study and absence of a satisfactory solution/ mitigation provided in favor/ assurance to public health.

Additional References:

Research on effects of EMF on humans:

1. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6025786/ This research reinforces the concerns of EMF exposure effect on human health.

2. https://www.epa.gov/radtown/electric-and-magnetic-fields-power-lines This resource suggests taking precautions and keeping distance or limiting exposure. Residents would no longer have either of these two options per the current proposals if they are living there 24-7.

3. https://www.fastexpert.com/blog/should-i-buy-a-house-near-power-lines/ These are points of view from a real estate expert who clearly states that property value declines proportionately to the distance of the property from high tension lines. People have apprehensions whether or not research clearly defines the risk. Potential buyers might have low priority for a property too close to a high tension power line.

4. https://orchard.com/blog/posts/power-lines-and-property-value Another research on real estate values lowered due to high tension power lines proximity.

H-415
at You Can Do
If you are concerned about possible health risks from electric and magnetic fields, you can:
• Increase the distance between yourself and the source. The greater the distance between you and the source of EMF, the lower your exposure.
• Limit the time spent around the source. The less time you spend near EMF, th e lower your NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: Yuri Kleban π <[email protected]>
Sent: Tuesday, August 27, 2024 8:20 PM
To: NRS-KRS Project; [email protected]; [email protected]; [email protected]; [email protected]; Allie Jackman Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community for the upcoming SVP project connecting the Northern Receiving Station NRS to Kifer receiving station (KRS)- NRS-KRS 115kV Transmission Line Project

To Whomsoever it may concern,
We are residents of Santa Clara that will be negatively impacted by the “NRS-KRS 115kV Transmission Line Project”. We have collectively reviewed the draft Initial Study/ Mitigated Negative declaration for “NRS-KRS 115kV Transmission Line Project” from July 2024. After reviewing this report and also attending the virtual and in person meetings, here are some references to emphasize our various concerns.

Reference #1 : CEQA’s reporting includes these State reviewing agencies: California Air Resources Board (ARB), California Department of Fish and Wildlife, Bay Delta Region 3 (CDFW), California Department of Forestry and Fire Protection (CAL FIRE), California Department of Parks and Recreation, California Department of Toxic Substances Control (DTSC), California Department of Transportation, District 4 (DOT), California Department of Transportation, Division of Aeronautics (DOT), California Department of Transportation, Division of Transportation Planning (DOT), California Department of Water Resources (DWR), California Energy Commission, California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Public Utilities Commission (CPUC), California Regional Water Quality Control Board, San Francisco Bay Region 2 (RWQCB), Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water.

Personal observation#1 : None of these agencies has any association with human health. CEQA reporting is not qualified enough to force the public to compromise on health concerns. Other agencies need to be involved to review this proposal, that are qualified to study the effect on “ humans”, not just wildlife and vegetation, or “ environment. The checklist is completely devoid of our gravest humanitarian concerns. It is quite shocking that the project has not included any study to understand the potential impact of EMF waves on human lives, given that the transmission lines are potentially less than 60 feet from the closest dwellings. The city of Santa Clara needs to step in and have third party/ independent studies completed in favor of human health.

Reference #2: Page 41 of report- Section 4.15. Electric and Magnetic Fields summary.

Personal observation#2 : This consideration was completely absent earlier. Only after the residents raised their voices, this section was added. To our greatest disappointment, this section is copied over from an older report on the “South Loop Reconfiguration Project” from 2020. One would have expected that a new study would have been conducted for a project this size. The lack of due diligence and ignorance towards the specifics of this project are apparent and not acceptable. In fact we have found several sections of this older report as being reused across the entire report.

The EMP map shared during the in person meeting had several flaws and we would like to question the viability of the study that was completed. What time of the day was the study completed and on what models were the values based on since these were done on assumption for the EMF values that would be there once the project is complete. Since we have seen the several sections of the report redundantly copied over from other reports, we would like a more detailed analysis of this report.

H-416
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Regarding EMF concerns for human health, there are plenty of scientific studies that do indicate the grave concern on human health with EMF exposures and we cannot ignore this aspect. Here is a reference to an article and there are plenty of articles listed here under references:
https://psc.wi.gov/Documents/Brochures/EMF.pdf

There are not enough references listed in the draft report provided to us, and the explanation provided seems to be conveniently using studies that prove otherwise. This needs more investigation and references. The solution provided as raising the height of the poles and increasing the distance is non- existent. It was confirmed during the in person meeting that the design will not be altered and the height was already designed as required according to the SVP team present there. It seems that the preparers of this report did not even read the report after copying pasting from the old report as evident in the list of proposed solutions is not applicable here.

The live presentation on August 22nd showed the comparison of EMF values of household objects as a means to show that everyday household items carry a similar range of mG( milli Gauss) units. This comparison was inherently flawed since it mentioned that the household devices were producing those level at 1 feet while those indicated for 115KVf lines were at 60 feet. further these household devices do not operate 24X7 similar to the transmission lines.

There were a lot of citations of reports showcasing that no clear proof of EMF to human health exists but we would like to also point out certain states like Connecticut Department of Public Health have cited reports that have shown an increased incidence of childhood leukemia( Blood cancer) at avg exposure of only 3 mG. Also they have called out that some utility workers exposed to high levels of emf have increase risks of Lur Gehrig's disease.

They also call out that most impacts of EMF from high voltage lines dissipate at ~300 feet.

These are available on Page 2 & Page 3 of this report: https://portal.ct.gov/-/media/departments- and-agencies/dph/dph/environmental_health/eoha/pdf/emffactsheet2008pdf.pdf This report has citations from WHO , National Institute of Environmental Health Sciences and California Department of Health Services.
https://www.niehs.nih.gov/sites/default/files/health/materials/electric_and_magnetic_fields_associ ated_with_the_use_of_electric_power_questions_and_answers_english_508.pdf

Reference #3

Page 174 ends

Personal observation#3
The railway line's proximity to the proposed high transmission lines is very concerning. The centerline distance from proposed lines to railway line is aproximately 50 feet per google maps with some margin for error. As per the report there are no Corona rings proposed for the 115KV lines. There seems to be negligence in design in consideration of the hazards posed by these high voltage lines as Corona effect can transfer current to railway lines. All the residents are at a high risk of accidental hazards given the proximity of the railway line, this project is adding on to the hazards. This section is only stating information about what Corona effect is, as may be required by law, which by the way is again a copy paste from an old report. The only concern discussed in more depth is the audible noise level. The concerns are presented to imply that this is not significant by stating that 115KV lines pose less than significant risk.

H-417
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Reference #4: Post meeting material from March 19th 2024 @https://santaclara.legistar.com/LegislationDetail.aspx?ID=6582415&GUID=E6E14646-3CF7-4D15- BB98-F18580696012&Options=&Search=
Personal observation#4: At surface level, it looks like Option #A was selected only based on Cost perspective, without any consideration to human health, young children, property values, Corona effect, long term sustainability perspective or any other factors. While its important to understand the results of CEQA study, its extremely critical to understand the negative impact of EMF on the many young children living around the proposed transmission lines. Without extensive research and study on the impact to young children and adult heath, we should not be approving such an incomplete proposal.

Page 6 ends

discussions with several real estate agents in the region, I have unanimously found all to agree that the real estate values of residences in close proximity to power lines goes down. Its hard to find potential buyers and most folks refrain from buying a house too close to high power transmission lines. There are 1000 plus residences in the area affected by this project. Even if we were to make very rough assumptions, and assume minimal cost reduction in property values and take an average loss of $100,000 per property in the current year, that goes to $100,000,000 of loss of equity to the public. This is not even accounting the businesses affected by this project. This long explanation was to raise a point that if the selection of route A was saving money to the city, this is costing a huge financial loss to the public, which is not acceptable. This decrease in property values will also directly impact the tax collection by the Santa Clara Assessor and result in lower tax revenue coming into the city of Santa Clara.

Reference #5 : Page 49 of report- Figure 5.1-2. Wall separating residences and Lafayette Street.

Personal observation#5: The picture is taken conveniently from the other side of the railway line which is actually Kingsbury street, inside a private community and not Lafayette street. This is further away from the proposed SVP lines. This is very misleading; see snapshots taken from Google maps below

H-418
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND

And this is what is included on the report:

The Mission Garden Townhome community has no walls as such and the main entry to residences face the road directly and are the most impacted. There are several other single family homes on Lafayette street with the same impact, having an entryway directly on the street. This and including other citations H-419
NJlS.,lCRSll5kVTUH$MISSl0N~PIIIOIICl
Figure 5.1-2. Wall Separatin1 RHldencH and Lafayette Strut W I StparaMg RHldtncn and Ufayello SlrHl
J1.u202• 5.1-5 A~tMOUnMND/IS
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
of reusing sections of older reports, is all in all absolutely unacceptable and instills distrust. This further shows incompetency of the agency/ agencies preparing this report.

Conclusion: This project's initial study needs to expand beyond CEQA for approval from the public. The limited scope of CEQA has failed to address the following concerns we have:
• Health hazards due to EMF levels.- This is by far the gravest concern and CEQA is clearly not qualified to study that.
• Reduced property values- several references provided below. • Loss of Aesthetic appeal for potential real estate buyers/ new and current businesses. • Increase in audible noise levels during and post construction, which is already high in the area with presence of railway line and air traffic route. • Increased fire hazard/ risk of other accidents.
• Induced current on railway lines with close proximity/ corona effect- CEQA report did not clearly address this for a 115KV line.
• Economic effect on the community from small to larger scale based on all of the above.

We demand further investigation and revisit other routes or proposals to resolve the power needs of the city. We have to ensure our and our kids’ health is not at stake in the name of development and infrastructure and are not in agreement for this project to move forward. We cannot approve this to move forward as of now given the lack of study and absence of a satisfactory solution/ mitigation provided in favor/ assurance to public health.

Additional References:

Research on effects of EMF on humans:

1. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6025786/ This research reinforces the concerns of EMF exposure effect on human health.

2. https://www.epa.gov/radtown/electric-and-magnetic-fields-power-lines This resource suggests taking precautions and keeping distance or limiting exposure. Residents would no longer have either of these two options per the current proposals if they are living there 24-7.

3. https://www.fastexpert.com/blog/should-i-buy-a-house-near-power-lines/ These are points of view from a real estate expert who clearly states that property value declines proportionately to the distance of the property from high tension lines. People have apprehensions whether or not research clearly defines the risk. Potential buyers might have low priority for a property too close to a high tension power line.

4. https://orchard.com/blog/posts/power-lines-and-property-value H-420
at You Can Do
If you are concerned about possible health risks fro m electri c and magnetic fields, you can:
• Increase the distance between yourself and the source. The greater th e distance between you and the source of EMF, th e lowe r your exposure.
• Limit the time spent around the source. The less t ime you spend near EMF, the lowe r your NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Another research on real estate values lowered due to high tension power lines proximity.

---
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H-421
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: *Sir*Yuri <[email protected]>
Sent: Tuesday, August 27, 2024 8:22 PM
To: NRS-KRS Project; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Concerns Regarding Upcoming High Power Electric Wire Poles in Our Community - NRS-KRS 115kV Transmission Line Project

Hi there,

As residents of Santa Clara, we are deeply concerned about the potential negative impacts of the "NRS- KRS 115kV Transmission Line Project." After thoroughly reviewing the draft Initial Study/Mitigated Negative Declaration (July 2024) and participating in related meetings, we have identified several critical issues that require attention.

Health Concerns: The California Environmental Quality Act (CEQA) review lacks focus on human health impacts, particularly concerning electromagnetic fields (EMF). Despite proximity to residences (less than 60 feet), there has been no comprehensive study on the potential health effects of EMF exposure. We urge the City of Santa Clara to commission independent studies that prioritize public health.

Inadequate Reporting: The inclusion of an Electric and Magnetic Fields (EMF) section in the report seems to have been an afterthought, prompted by resident concerns. This section largely replicates content from a 2020 report, lacking specific analysis relevant to this project. Additionally, the EMF study presented is flawed and does not provide a realistic assessment of potential risks.

Corona Effect and Railway Line Proximity: The report neglects the risks associated with the Corona effect and its potential impact on nearby railway lines. With the proposed transmission lines only 50 feet from the railway, this oversight poses a significant safety hazard.

Economic and Property Value Implications: The selection of Route A appears driven by cost-saving measures, with little regard for the potential $100 million loss in property value for residents in the affected area. This decision could also reduce tax revenues for the city.

Misleading Information: Certain report sections, such as the representation of residential impact, are misleading. The report’s reliance on outdated data further erodes trust in its findings.

In conclusion, the scope of the CEQA review is insufficient to address our concerns. We demand further investigation, particularly into the health and economic impacts, before this project proceeds. The well- being of our community should not be compromised in the name of development.

-Y & A, residents

H-422
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: derek fong <[email protected]>
Sent: Tuesday, August 27, 2024 4:28 PM
To: NRS-KRS Project
Subject: feedback on slides from feedback meeting

hi Allie,

i wasn't able to attend the meeting, but i did review the slides (without Appendix G being available) and quite frankly, i don't find the analysis and comparison of household appliances vs the expected load of the segments very convincing as rational to construct the project as proposed. in fact, i find the analysis/arguments misleading for several reasons:
• some residents are roughly ~60 ft from the centerline of the Lafayette stretch • the normal and peak loads greatly exceed the median value of many of the household appliances listed (who uses Electric can openers anyway?) • and most importantly, most of those appliances listed are not emitted EMF constantly to the homeowner. they only emit when operated (in short bursts) which is nothing like the 24/7 operated e transmission lines.
i hope, even if costly, Silicon Valley Power will reconsider the more costly and inconvenient option of undergrounding the line. white there are no regulations or agreement on "safe" EMF levels, as a scientist, i well know there is enough evidence in the peer reviewed literature which suggests any added EMF fields are harmful and increase the risk of cancer.

as a SVP customer, i would gladly have slightly higher electricity rates than have the added risk of the calculated EMF fields which to me are significant and should be avoided.

thanks for taking time time to hear my concerns. i hope the powers that be will take the concerns and voices of nearby residences seriously. don't hesitate to contact me if you have any questions about what i've written above.

Sincerely,
Derek Fong

H-423
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
Email: NRS-KRS 115 kV T-Line

From: jeff.holmbeck <[email protected]>
Sent: Saturday, August 24, 2024 3:11 AM
To: NRS-KRS Project; Silicon Valley Power
Cc: Allie Jackman
Subject: Re: Join Us for a Community Meeting to Discuss SVP's New Transmission Line Project

Thank you Grace and I appreciate the response.

Regards,
Jeff

Sent from my Verizon, Samsung Galaxy smartphone

-------- Original message --------
From: NRS-KRS Project <[email protected]>
Date: 8/23/24 8:05 PM (GMT+01:00)
To: "jeff.holmbeck" <[email protected]>, Silicon Valley Power <[email protected]> Cc: Allie Jackman <[email protected]>
Subject: Re: Join Us for a Community Meeting to Discuss SVP's New Transmission Line Project

Hi Jeff,

Thanks for reaching out and expressing your preference on the Project. On Monday, we will upload the Public Engagement Meeting PowerPoint and FAQ to the SVP website (link below).

Projects | Silicon Valley Power

I am looking into the cost and will get back to you.

Thanks, and have a great weekend!
Grace

From: jeff.holmbeck <[email protected]>
Sent: Monday, August 12, 2024 8:39 PM
To: Silicon Valley Power <[email protected]>
Cc: NRS-KRS Project <[email protected]>
Subject: RE: Join Us for a Community Meeting to Discuss SVP's New Transmission Line Project

I can't attend the meeting, bur would like to know how much Santa Clara taxpayer $'s was spent on the environmental study?

My vote would be to put it underground.

Jeff

Sent from my Verizon, Samsung Galaxy smartphone

H-424
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
-------- Original message --------
From: Silicon Valley Power <[email protected]>
Date: 8/12/24 5:42 PM (GMT+01:00)
To: [email protected]
Subject: Join Us for a Community Meeting to Discuss SVP's New Transmission Line Project

View as a webpage / Share

Join Us for a Community Meeting to Discuss SVP's New Transmission Line Project Silicon Valley Power (SVP) is proposing to construct 2.24 miles of new 115 kV transmission line connecting the Northern Receiving Station (NRS) and Kifer Receiving Station (KRS).

This project aims to balance and redistribute energy and support load growth.

An Initial Study was completed by Aspen Environmental Group on behalf of SVP, in accordance with the California Environmental Quality Act (CEQA), and is available for review in the Planning Division office in City Hall at 1500 Warburton Avenue, the Northside Branch Library at 695 Moreland Way, and online at: SiliconValleyPower.com/115kv. Based on the Initial Study, since the project involves constructing a new 2.24-mile-long overhead

H-425
NRS-KRS 115KV TRANSMISSION LINE PROJECT
SEPTEMBER 2024 FINAL IS/MND
and/or underground 115 kV transmission line between the Northern Receiving Station (NRS) and Kifer Receiving Station (KRS) to enhance SVP’s system capacity and reliability, the project is not expected to have a significant environmental impact. This is due to the incorporation of mitigation measures through conditions of approval, which will reduce potential impacts to a less-than-significant level.

To help the affected community understand the Initial Study and to explain how the public can participate in SVP’s decision-making process, SVP will hold an in-person community meeting.

Meeting Details
Date: Thursday, August 22, 2024
Time: 5:00 pm - 6:30 pm
Location: Northside Community Room, 695 Moreland Way, Santa Clara, CA 95054 Public Engagement
A Draft Initial Study/Mitigated Negative Declaration (IS/MND) was published on July 31, 2024. The 30-day public review period ends at 5:00 PM on August 30, 2024. We encourage residents to attend the community meeting in person. However, comments can also be submitted via US Mail or email to Allie Jackman (contact info below) by the deadline.

Contact Information
Allie Jackman, Silicon Valley Power
c/o Aspen Environmental Group
235 Montgomery Street, Suite 967
San Francisco, CA 94104-3002
Email: [email protected]
Project website: SiliconValleyPower.com/115kv
We look forward to your participation.

STAY CONNECTED

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H-426
am am II m
gOVDELIVERY,.

Resolution/ 115kV Tline Northern Receiving Station and Kifer Receiving Station – MND & MMRP Page 1 of 3 Rev. 7/31/24
RESOLUTION NO. __________

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

SANTA CLARA , CALIFORNIA TO ADOPT THE MITIGATED

NEGATIVE DECLARATION AND THE MITIGATION
MONITORING AND REPORTING PROGRAM FOR THE 115kV

TRANSMISSION LINE PROJECT BETWEEN NORTHERN

RECEIVING STATION AND KIFER RECEIVING STATION

WHEREAS, the City of Santa Clara ("City") proposes the construction of a 115 kilo-volt (kV) transmission line between Northern Receiving Station (NRS) and Kifer Receiving station (KRS) ("Project") on a path as more fully described in the mitigated negative declaration referenced below;
WHEREAS, the City is the lead agency for the preparation and consideration of environmental documents for the Project, as defined in the California Environmental Quality Act and the State of California Guidelines for the Implementation of the California Environmental Quality Act (collectively, "CEQA");
WHEREAS, pursuant to CEQA, specifically section 15070 of Title 14 of the California Code of Regulations, the City prepared an initial study which identified potentially significant effects on the environment which will be avoided or mitigated through the implementation of the Mitigated Negative Declaration (“MND”) and Mitigation Monitoring and Reporting Program (“MMRP”); WHEREAS, the City prepared the MND and MMRP and circulated these documents for a 30 - day public review period between July 31,2024 and August 30, 2024 , in compliance with the requirements of CEQA;
WHEREAS, during the public review period, the City received comments from the San Jose International Airport;
WHEREAS, the City prepared a “Responses to Comments” document is included in Section 7 of the MND and addresses all comments raised;
WHEREAS, the City conducted its own independent analysis of the MND and MMRP prior to releasing it for public review and determined that the MND and MMRP were appropriate as Resolution/ 115kV Tline Northern Receiving Station and Kifer Receiving Station – MND & MMRP Page 2 of 3 Rev. 7/31/24
there is substantial evidence the Project would not result in any significant environmental impacts;
WHEREAS, the Santa Clara City Council has reviewed and considered the MND, MMRP, the comments received to date and the responses prepared , and the City Council, in reviewing the Project as proposed, intends to take actions on the Project in compliance with CEQA; and WHEREAS, the MND and the M MRP have been attached to the sta ff report for this environmental approval and the approval of the Project and, by this reference, are incorporated into this Resolution as if fully set forth herein.

NOW THEREFORE, BE IT FURTHER RESOLVED BY THE CITY COUNCIL OF THE CITY OF SANTA CLARA AS FOLLOWS:

1. That the City Council hereby finds that the above Recitals are true and correct and by this reference makes them a part hereof.

2. That based on the whole record before it, the City Council hereby finds that all potentially significant environmental impacts that may directly or indirectly result from the Project would be reduced to a less than significant level by the mitigation measures specified in the MND and MMRP and that there is no substantial evidence that the project will have a significan t effect on the environment.

3. That the City Council hereby finds that the MND and MMRP is complete, prepared in compliance with CEQA, and represents the independent judgment of the City Council.

4. That the City Council further finds that the MND and MMR P are adequate to serve as the required CEQA environmental documentation for the Project, and hereby adopts the MND and MMRP for the Project.

5. That the City Council hereby designates the Chief Electric Utility Officer of the City of Santa Clara, Silicon Valley Power as the Custodian of Records for the Project, and the Planning Division at City Hall, 881 Martin Avenue , Santa Clara, California, is the location of the Resolution/ 115kV Tline Northern Receiving Station and Kifer Receiving Station – MND & MMRP Page 3 of 3 Rev. 7/31/24
documents and other material that constitute the record of proceedings upon which this decision is based.

6. The City Council directs the City Manager or designee to file a notice of determination with the County of Santa Clara and State Clearinghouse.

7. Effective Date. This Resolution shall become effective immediately.

I HEREBY CERTIFY THE F OREGOING TO BE A TRUE COPY OF A RESOLUTION PASSED

AND ADOPTED BY THE CITY COUNCIL OF THE CITY OF SANTA CLARA, CALIFORNIA, AT A REGULAR MEETING THEREOF HELD ON THE _____________ DAY OF _____________, BY THE FOLLOWING VOTE:

AYES: COUNCILORS:

NOES: COUNCILORS:

ABSENT: COUNCILORS:

ABSTAINED: COUNCILORS:

ATTEST: ______________________________

NORA PIMENTEL, MMC

ASSISTANT CITY CLERK

CITY OF SANTA CLARA

Attachments incorporated by reference:

1. Mitigated Negative Declaration

2. Mitigation Monitoring and Reporting Program
City of Santa Clara
Agenda Report
1500 Warburton Avenue
Santa Clara, CA 95050
santaclaraca.gov
@SantaClaraCity
24-892 Agenda Date: 10/8/2024

REPORT TO COUNCIL

SUBJECT
Action on City Position on Proposed League of California Cities’ 2024 Resolutionon Fair and Equal Treatment of All Governmental Officials at All Levels

COUNCIL PILLAR
Enhance Community Engagement and Transparency

BACKGROUND
The League of California Cities (Cal Cities) will hold its Annual Conference and Expo in Long Beach, California on October 16-18, 2024. As part of the Annual Conference and Expo, Cal Cities will convene its General Assembly where the member cities’ voting delegates will debate and consider general and petitioned resolutions. If a resolution is approved at the General Assembly, it becomes official Cal Cities policy.

City councils must appoint a voting delegate to vote during the General Assembly. As part of the September 24, 2024 Council Meeting, the City Council designated Councilmember Park as the City’s voting delegate.

This report transmits the Cal Cities 2024 Resolutions Packet (Attachment 1), which contains the proposed resolution that will be considered at the Cal Cities’ General Assembly on October 18, 2024, supporting letters from city officials, and an analysis by Cal Cities. Cal Cities encourages each city council to consider the resolution and determine a city position so that cities’ voting delegates can represent their respective city’s position on the resolution.

Staff recommends Council discussion and action on a City position on the proposed Cal Cities 2024 Resolution on Fair and Equal Treatment of All Governmental Officials at All Levels submitted by the City of Glendora (Cal Cities 2024 Resolution). Additionally, the voting delegate should be authorized to cast a vote consistent with the City Council’s position during the Cal Cities 2024 General Assembly.

DISCUSSION
Below is a description of the proposed Cal Cities 2024 Resolution followed by background and an analysis prepared by staff and the City’s legislative consultant, Townsend Public Affairs.

Resolution of the General Assembly of the League of California Cities Calling for the California Legislature to Enact Laws That Ensure That “What Applies to One, Applies to All” in the Fair and Equal Treatment of All Government Officials at All Levels in the State of California City of Santa Clara Printed on 10/4/2024Page 1 of 4
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24-892 Agenda Date: 10/8/2024
The City of Glendora has submitted a resolution for consideration related to equitable treatment of local and state elected officials. The resolution would ask the Cal Cities to call on the Governor and Legislature to adopt a policy that states:

The California State Legislature shall not enact, and the Governor shall not sign into law, any law or regulation that applies solely to elected officials of California cities and counties, unless such law or regulation also applies equally to members of the California State Assembly and Senate. This prohibition shall not apply to laws or regulations affecting the inherent powers of the legislative branch under the California Constitution.

Concurrence
Any resolution submitted to the General Assembly must be concurred by five cities or by city officials from at least five or more cities. The proposed Cal Cities 2024 Resolution received concurrence from the following officials:
· April A. Verlato, Mayor, City of Arcadia
· Robert Gonzales, Mayor, City of Azusa
· Tim Hepburn, Mayor, City of La Verne
· Bill Uphoff, Mayor, City of Lomita
· John M. Cruikshank, Mayor, City of Rancho Palos Verdes Background
Each year the California State Legislature introduces between 2,000 to 3,000 bills, many of which proposed to enact, or amend, laws pertaining to the roles, responsibilities, and laws that govern the conduct of elected officials. These proposed laws often apply solely to local elected officials, and not to state or federal representatives, nor to state-level constitutional officers. In addition, many legislative proposals will impact the actions that local elected officials are permitted to take, while not applying to elected officials at the state level.

Over time, there have been numerous laws enacted that apply to locally elected officials, but not to other elected officials. Some of the more high-profile laws include the Ralph M. Brown Act relating to the public meetings and transparency, the Public Records Act, portions of the Political Reform Act of 1974, and recent laws limiting the ability of locally elected officials to take certain actions related to local planning and zoning, particularly as it relates to housing. Additionally, the Legislature has adopted many laws which apply solely to elected officials within certain jurisdictions, such as streamlining of the California Environmental Quality Act (CEQA) to facilitate the expedited review of certain projects.

In each of these cases, the Legislature has found that there is a compelling need for these laws to apply at the local level, but have not maintained consistency by applying the same laws to their own members. In some situations, such as legislation related to local planning and zoning, as well as to CEQA approvals, the underlying governmental actions are taken at the local level, not the state level, so it wouldn’t necessarily make sense to have those laws apply to state officials; however, laws such as the Brown Act and the Public Records Act specifically exempt members of the Legislature from their provisions, and instead the Legislature has approved laws that are less stringent on state officials than on their local counterparts.

City of Santa Clara Printed on 10/4/2024Page 2 of 4
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24-892 Agenda Date: 10/8/2024
Analysis
There may be constitutional constraints related to the proposed resolution as discussed below.

The proposed resolution contains the provision, “This prohibition shall not apply to laws or regulations affecting the inherent powers of the legislative branch under the California Constitution.”As this sentence notes, the California State Constitution provides broad latitude for the State Legislature to enact laws to govern affairs within the state. While the Legislature does have constraints on types of legislation that can be considered due to specific provisions within sections of the State Constitution, for the most part the Legislature has broad latitude to approve laws as they see fit. If necessary, courts have the ability to review laws to ensure that they are not in conflict with provisions of the US Constitution or State Constitution; additionally, voters have the ability to reject or modify approved laws through the use of the referendum and initiative process.

Additionally, the proposed resolution provides direction to Cal Cities to “call upon the Governor of the State of California and the elected members of the California Legislature, including all members of the Senate and Assembly to adopt the following policy:”; however, the Legislature does not adopt policies. The closest thing to adopting a policy that the Legislature can do is to approve something as part of the Rules of the House; however, these do not carry the weight of law and can be easily suspended by a majority vote at any time. In order to carry out the policy that is being advanced within the proposed resolution, the Legislature would need to approve a bill, which would then need to be signed into law by the Governor. However, many of the examples cited as need for the bill are contained within the California Constitution and have been approved by voters, in addition to, or in place of, the State Legislature. Any of the provisions that are currently within the State Constitution, or are added at a later date, would supersede statutory provisions, or House Rules, approved by the Legislature, therefore it would make the most sense for the proposed resolution to be pursued as an amendment to the State Constitution.

Relevant City Policy
On December 12, 2023, the City Council adopted eleven (11) 2024 Legislative Advocacy Positions (LAPs). While these LAPs cover a range of issues and provide direction on a diverse number of issues, there is no position statement within the LAPs that applies directly to the proposed resolution.

However, there are several position statements within the LAPs that are aimed at maintaining local decision-making authority and opposing the state mandating local agencies carry out certain activities without providing adequate funding and resources and the City’s LAP Policy outlines similar legislative guiding principles.

Recommended Position
The proposed Cal Cities 2024 Resolution requires Council consideration because there is no City policy or Legislative Advocacy Position relative to the issue and the proposed resolution does not directly impact City operations. As such, the City Council should consider taking one of the following positions with regard to the proposed Cal Cities 2024 Resolution: “Approve”, “Disapprove”, or “ Abstain”.

It is important to note that the proposed Resolution may be amended during the deliberation process at the Cal Cities 2024 General Assembly and, should a resolution be adopted, further analysis will be conducted by Cal Cities staff and adjustments/compromises to the proposed actions may occur through the Cal Cities legislative advocacy process.

City of Santa Clara Printed on 10/4/2024Page 3 of 4
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24-892 Agenda Date: 10/8/2024
Should the Council take a position on the proposed Cal Cities 2024 Resolution, it is recommended that the Council authorize its voting delegate, Councilmember Kevin Park, to cast a vote consistent with the City Council’s position during the Cal Cities 2024 General Assembly.

ENVIRONMENTAL REVIEW
The action being considered does not constitute a “project” within the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines section 15378(b)(5) in that it is a governmental organizational or administrative activity that will not result in direct or indirect changes in the environment.

FISCAL IMPACT
There are no costs associated with this report or action aside from administrative time to prepare and review this report.

The City has an existing agreement with Townsend Public Affairs for state and federal legislative advocacy services, which includes developing and implementing a legislative strategy. These services are included at no additional cost as part of the consultant’s monthly service fee.

COORDINATION
This report was coordinated with the City’s legislative consultant, Townsend Public Affairs and the City Attorney’s Office.

PUBLIC CONTACT
Public contact was made by posting the Council agenda on the City’s official-notice bulletin board outside City Hall Council Chambers. A complete agenda packet is available on the City’s website and in the City Clerk’s Office at least 72 hours prior to a Regular Meeting and 24 hours prior to a Special Meeting. A hard copy of any agenda report may be requested by contacting the City Clerk’s Office at (408) 615-2220, email [email protected] <mailto:[email protected]>.

RECOMMENDATION

1. Council discussion and action on the proposed Cal Cities 2024 Resolution, which aims to ensure fair and equal treatment of all governmental officials at all levels; and

2. Authorize the City’s voting delegate, Councilmember Park, to cast a vote consistent with the City Council’s position during the Cal Cities 2024 General Assembly.

Prepared by: Christine Jung, Assistant to the City Manager Approved by: Jovan D. Grogan, City Manager

ATTACHMENTS

1. League of California Cities 2024 Resolutions Packet
City of Santa Clara Printed on 10/4/2024Page 4 of 4
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2023-2024

CAL CITIES OFFICERS
President
Daniel T. Parra
Mayor
Fowler
First Vice President
Lynne Kennedy
Mayor Pro Tem,
Rancho Cucamonga
Second Vice President
Gabe Quinto
Council Member,
El Cerrito
Immediate Past President
Ali Sajjad Taj
Mayor Pro Tem,
Artesia
Executive Director
and CEO
Carolyn M. Coleman
1400 K Street, Suite 400, Sacramento, CA 95814 • 916.658.8200 • calcities.org August 28, 2024
TO: Mayors, Council Members, City Managers, and City Clerks RE: Cal Cities 2024 Resolution Packet
Sixty days before the Cal Cities Annual Conference and Expo, Cal Cities members may submit resolutions on issues of importance to cities. This year, Cal Cities received one resolution by the Aug. 17 deadline.

The attached packet contains the proposed resolution, supporting letters from city officials, and an analysis of the resolution by Cal Cities. The packet includes detailed information on the resolution process.

We encourage each city council to consider the resolution and determine a city position so your voting delegate can represent your city’s position on the resolution.

Voting Delegates: City councils must appoint a voting delegate to vote during the General Assembly. Each city may also appoint up to two alternate delegates. If your city has not already done so, please appoint your voting delegate by Sept. 25. The voting delegate packet contains more information.

The Cal Cities 2024 General Assembly will be held Oct. 18 at 8:30 a.m. in the Long Beach Convention Center during the Annual Conference and Expo.

For
questions about resolutions, voting delegates, or the General Assembly, please contact Zach Seals.

LEAGUE OF

CALIFORNIA
CITIES

2024
Resolutions
Packet

LEAGUE OF

CALIFORNIA
CITIES
2024 Resolutions Packet
Information on 2024 Resolutions Process
Consideration by Policy Committee (pre-conference)
Per the Cal Cities bylaws, the Cal Cities President has referred the submitted resolution to the Governance, Transparency, and Labor Relations Policy Committee. The committee will meet on Oct. 3 at 10 a.m. via Zoom to review the resolution and make a recommendation that will be sent to the Resolutions Committee. A public comment period will be held during the meeting. Register for the meeting here.

A list of recommendations the policy committee may make during its meeting are on page three of this packet.

Consideration by Resolutions Committee (during conference) On Oct. 17 at 1:30 p.m. the Resolutions Committee will meet to review the resolution and the recommendation of the policy committee.

The Resolutions Committee consists of one representative from each of Cal Cities caucuses, departments, divisions, and policy committees, as well as up to ten additional appointments made by the Cal Cities President. A public comment period will be held during the meeting. Refer to the onsite conference program for the location.

A list of recommendations the Resolutions Committee may make during its meeting are on page three of this packet.

Consideration by the General Assembly (during conference) The General Assembly will convene on Oct. 18 at 8:30 a.m. to consider any qualified resolutions. To vote during the General Assembly, voting delegates must have checked-in at the voting delegate booth.

Conference attendees will receive materials for the General Assembly on the evening of Oct. 17. For more information on voting and discussion procedures during the General Assembly, see page four of this packet.

Petitioned Resolutions (during conference)
The petitioned resolution is an alternate method to introduce policy proposals during the annual conference. To initiate a petitioned resolution, voting delegates from 10% of member cities must sign the petition. The resolution and signatures are due at least 24 hours before the beginning of the General Assembly. Voting delegates who have checked-in at the voting delegate booth can receive more information on petitioned resolutions at the booth onsite. 1 Sixty days before the
Annual Conference
and Expo, Cal Cities
members may submit
policy proposals on
issues of importance
to cities. The resolution must
have the concurrence of at least
five additional member cities or
individual members.

How it works: Cal Cities
Resolutions and the General Assembly
General Assembly
General Resolutions Policy Committees
Developing League of California Cities policy is a dynamic process that engages a wide range of members to ensure Cal Cities represents cities with one voice. These policies directly guide Cal Cities’ advocacy to promote local decision-making, and lobby against statewide policies that erode local control.

The resolutions process and General Assembly is one way that city officials can directly participate in the development of Cal Cities policy. If a resolution is approved at the General Assembly, it becomes official Cal Cities policy. Here’s how resolutions and the General Assembly work.

The petitioned
resolution is an
alternate method
to introduce policy
proposals during
the annual conference. The
petition must be signed by
voting delegates from 10% of
member cities, and submitted to
the Cal Cities President at least
24 hours before the beginning
of the General Assembly.

Petitioned Resolutions
The Cal Cities
President assigns
general resolutions
to policy committees
where members
review, debate, and recommend
positions for each policy proposal.

Recommendations are forwarded
to the Resolutions Committee.

Who’s who
The Resolutions Committee
includes representatives
from each Cal Cities
diversity caucus, regional
division, municipal
department, and policy
committee, as well as
individuals appointed by
the Cal Cities president.

Voting delegates
are appointed by each
member city; every city
has one voting delegate.

The General Assembly is a
meeting of the collective
body of all voting
delegates —one from
every member city.

Seven policy committees
meet throughout the year
to review and recommend
positions to take on bills
and regulatory proposals.

Policy committees include
members from each Cal
Cities diversity caucus,
regional division, and
municipal department,
as well as individuals
appointed by the Cal
Cities president.

During the General Assembly, voting delegates
debate and consider general and petitioned
resolutions forwarded by the Resolutions
Committee. Potential Cal Cities bylaws
amendments are also considered at this meeting.

Cal Cities policy
development is a member-
informed process,
grounded in the voices and
experiences of city officials
throughout the state.

For more information visit www.calcities.org/general-assembly Prior to the Annual Conference and Expo
Resolutions Committee
The Resolutions
Committee considers
all resolutions. General
Resolutions approved
1 by
either a policy committee
or the Resolutions Committee are next
considered by the General Assembly.

General resolutions not approved, or
referred for further study by both a
policy committee and the Resolutions
Committee do not go to the General
Assembly. All Petitioned Resolutions
are considered by the General
Assembly, unless disqualified.
2 During the Annual Conference and Expo
1 The Resolution Committee can amend a general resolution prior to sending it to the General Assembly. 2 Petitioned Resolutions may be disqualified by the Resolutions Committee according to Cal Cities Bylaws Article VI. Sec. 5(f). 2 •••
_. G
•••
G
--+

2024 Resolutions Packet

Policy Committee and Resolutions Committee Actions

The submitted resolution will be heard by the policy committee to which it was assigned, and the Resolutions Committee. The below table shows what recommendations these bodies may make on the resolution.

Policy Committee Actions Resolutions Committee Actions
Approve Approve
Disapprove* Disapprove*
No Action No Action
Amend and approve

Amend and approve

Refer to appropriate policy committee
for further study*
Approve as amended
Refer as amended to appropriate
policy committee for further study*
Refer to appropriate policy committee
for further study*
Refer as amended to appropriate
policy committee for further study*
Approve with additional
amendment(s)

Additional amendments and refer to
appropriate policy committee for
further study*

*If a resolution is disapproved or referred for further study by all policy committees to which it is assigned and the Resolutions Committee, it will not proceed to the General Assembly.

3 2024 Resolutions Packet

General Assembly Voting and Discussion Procedures
Discussion Procedures:

Discussion procedures during the General Assembly are guided by two calendars:
the Consent Calendar and the Regular Calendar. As seen below, resolutions are calendared by the recommendations they receive from policy committees and the Resolutions Committee.

For General Resolutions:

Policy Committee
Recommendation
Resolutions Committee
Recommendation Calendar
Approve Approve Consent Calendar
Approve Disapprove or refer Regular Calendar
Disapprove or refer Approve Regular Calendar
Disapprove or refer Disapprove or refer Does not proceed to General Assembly

For Petitioned Resolutions:

Policy Committee
Recommendation Resolutions Committee Action Calendar
N/A
Approve Regular Calendar
Disapprove or Refer Regular Calendar
Disqualified Does not proceed to General
Assembly

Items on the Consent Calendar will be presented as one motion during the General Assembly from the Resolutions Committee chair. Unless an item on the Consent Calendar is set aside by the majority of the General Assembly, a vote will be taken on the whole calendar. It an item is set aside, it will be opened for discussion, followed by a vote.

Items on the Regular Calendar will be presented individually by the Resolutions Committee chair. After a recommendation is presented by the Resolutions Committee chair, the resolution will be opened for discussion by the General Assembly. A vote will take place following discussion.

Voting Procedures:

Per Cal Cities Bylaws Article XII, Sec. 2, all votes will be conducted by voice vote first. If the presiding official cannot determine the outcome a vote will be taken by an alternative method, typically a raise of voting cards by voting delegates. A roll call vote may be called for by delegates of ten percent or more of the General Assembly.

4 2024 Resolutions Packet

2024 Resolution

1. R esolution on Fair and Equal Treatment of All Governmental Officials at All Levels submitted by City of Glendora
• Letters of concurrence submitted by:
i. April A. Verlato, Mayor, City of Arcadia
ii. Robert Gonzales, Mayor, City of Azusa
iii. Tim Hepburn, Mayor, City of La Verne
iv. Bill Uphoff, Mayor, City of Lomita
v. John M. Cruikshank, Mayor, City of Rancho Palos Verdes • Referred to Governance, Transparency, and Labor Relations Policy Committee
• Policy Committee Recommendation:
• Resolutions Committee Recommendation:

5 2024 Resolutions Packet

Resolution N o. 1: Fair and Equal
Treatment of All Governmental
Officials at All Levels submitted by
City of Glendora

6 2024 Resolutions Packet

1. A RESOLUTION OF THE GENERAL ASSEMBLY OF THE LEAGUE OF

CALIFORNIA CITIES CALLING FOR THE CALIFORNIA LEGISLATURE TO ENACT LAWS THAT ENSURE THAT “WHAT APPLIES TO ONE, APPLIES TO ALL” IN THE

FAIR AND EQUAL TREATMENT OF ALL GOVERNMENTAL OFFICIALS AT ALL

LEVELS IN THE STATE OF CALIFORNIA

Source: C
ity of Glendora
Concurrence of five or more cities/city officials
City Officials: April A. Verlato, Mayor, City of Arcadia; Robert Gonzales, Mayor, City of Azusa; Tim Hepburn, Mayor, City of La Verne; Bill Uphoff, Mayor, City of Lomita; John M. Cruikshank, Mayor, City of Rancho Palos Verdes
Referred to: Go
vernance, Transparency and Labor Relations Policy
Committee

WH
EREAS, the General Assembly of the League of California Cities objects to the practice of the California Legislature of imposing rules limiting authority or regulating the conduct of local municipal officials that do not also apply to elected officials of the State of California; and

WHEREAS, examples of such rules or regulations that apply to local city elected officials that do not otherwise apply to the elected officials of the State of California include, but are not limited to:

California’s open meeting rules, codified in the Ralph M. Brown Act, Government Code, Chapter 9, §§ 54950 et seq., which purport to “declare[] that the public commissions, boards and councils and the other public agencies in this State exist to aid in the conduct of the people’s business. It is the intent of the law that their actions be taken openly and that their deliberations be conducted openly,” but which limits its application to “local agencies,” but not including elected officials of the State of California;

Creating “one-off” exemptions, in the form of Senate Bill No. 174, from the California Environmental Quality Act (“CEQA”) which purportedly requires all government agencies to consider the environmental consequences of their actions before approving plans and policies or committing to a course of action on a project in order to demolish and then rebuild State offices for the Governor and other State officials;

7 2024 Resolutions Packet

Adopting rules, in the form of Senate Bill No. 1439, amending the Political Reform Act (the “Act”), by removing the exception for local elected officers from contribution limits requiring disqualification on development project decisions,” but not including elected officials of the State of California;

Adopting rules, in the form of Assembly Bill No. 571, that apply to city and county candidates for local elected office, but not to candidates for state-wide office, including, but not limited to: prohibiting the making a contribution over the AB 571 limit to another candidate in jurisdictions subject to the AB 571; requiring a candidate that has qualified as a committee to establish a separate controlled committee and campaign bank account for each specific office; prohibiting a candidate from redesignating a committee for one election for another election.

WHEREAS, the General Assembly of the League of California Cities now calls upon the Governor and the California Legislature to adopt a policy, practice, and procedure requiring, in their legislative activities, that “what applies to one applies to all.”

NOW, THEREFORE, BE IT RESOLVED at the League General Assembly, assembled at the League Annual Conference on October 18, 2024 in Long Beach, California, that the League calls upon the Governor of the State of California and the elected members of the California Legislature, including all members of the Senate and Assembly to adopt the following policy:

“The California State Legislature shall not enact, and the Governor shall not sign into law, any law or regulation that applies solely to elected officials of California cities and counties, unless such law or regulation also applies equally to members of the California State Assembly and Senate . This prohibition shall not apply to laws or regulations affecting the inherent powers of the legislative branch under the California Constitution.”

8 2024 Resolutions Packet

Resolution No. 1: Letters of
Concurrence

9 July 10, 2024
The City Council of Glendora
is proposing the following resolution for consideration at the California League of Cities annual conference
on
October 18, 2024
Proposed Resolution: (“To ensure fairness and equal treatment for all government officials in California”)
“The California State Legislature shall not enact, and the Governor shall not approve, any law or regulation that applies solely to elected officials of California cities and counties, unless such law or regulation also applies equally to members of the California State Assembly and Senate. This prohibition shall not apply to laws or regulations affecting the inherent powers of the legislative branch under the California Constitution.”
The following five city council members are in concurrence with their letters of support (attached):
✓ Mayor John Cruikshank, City of Rancho Palos Verdes
✓ Mayor Bill Uphoff, City of Lomita
✓ Mayor Robert Gonzales, City of Azusa
✓ Mayor April Verlato, City of Arcadia
✓ Mayor Tim Hepburn, City of La Verne
Please confirm receipt of this request.

Sincerely,
Michael Allawos
Council Member
City of Glendora
10 CITY OF GLENDORA CITY HALL (626) 914-8201
116 East Foothill Blvd. , Glendora, California 91741
FAX (626) 914-8221
www .ci.glendora.ca. us

PRIDE OF THE FOOTHILLS

11 ARCADIA
April A. Verl:uo
Ata,w
l40 \\~ Huntington DtM:

P<llliC Offioc Box 60021
~\..A 9 1066-6021
(626) 574-5403 City Hall
1\'Cl'b1n@A~::ld.ii1C\.p
www.kodia CA.gov
July 9, 2024
Honorary Mike Allawos
Glendora City Councilmember
116 E. Foothill Blvd.

Glendora, CA 91741
RE: Support for "Glendora CalCitles Resolution "
Dear Councilmember Allawos:

I would like to be a voice of support for Glendora's timely and needed resolution below for the upcoming CalCitles annual conference this coming October 18, 2024. "The California State Legislature shall not enact , and the Governor shall not approve, any law or regulation that applies solely to elected officia ls of California cities and counties , unless such law or regulation also applies equally to members of the California State Assembly and Senate . This prohibition shall · not apply to laws or regulations affecting the inherent powers of the legislative branch under the California Constitution ." I am an elected representative for our respective city, county, and state govemance to do the people's work and be their collective voices. We should all have the same rules to be governed by.

Sincerely,
April A. Verlato
City of Arcadia Mayor

12 July 8, 2024
Hon. Michae\ AUawos
Glendora City Council member
116 E. Foothill Blvd.

Glendora, CA 91741
Councilmember Alla.,JOS:
1would likt to support Glendora's timely and needed resolution below· for the upcomh1g CalCil;es annual conference this coming October 18, 2024:
"The (alifornia State Legislature shall not enact, and the Governor shall not approve, any law or re-gulation 1hat appl~s solely to elected officials of California cities and counties, unless such taw or reeulation also applies equally to members of the California Stat~ .i\$$embly and Senate. This prohibition sh.lll not apply to laws or regularions affecting the inherent powers of the ~glslatlve branch under the California co,.stltu~on •
I am an elected representati\•e for the City of Azusa . We should all have tbe same rules to be governed by.

Sincerely,
Mayor Robert Gonzales
"The views or opinions expre~d in this letttr are intended to be interpreted as the individu.al work product of the a.rthor They do not necessar;ly reflect dn official position of the City Council, sta1 or other entities
13 CITY OF LA VERNE

CITY HALL
July 8, 2024
Ms. Kathleen Sessman
Glendora City Clerk
116 E. Foothill Blvd.

Glendora, California 917 41
3660 ·o· Sneet. La Verne. California 91751).3599
www.cityoflaverne.org
Re: Item 14 - Gal CrtiesAnnual Conferen:e Resolution
Dear Ms. Sessman:

As the Mayor of the City of La Verne, I v.ould like to voice support for Glendora's timely and needed resolution, within agenda rtem #14, for the upcoming League of California Cities (Cal Cities) annual conference this coming October 18, 2024.

In its simplistic fom1, the proposed Resolution states what we all believe should be true for each and every elected official: We should a ll have the same rules to be governed by. No matter what level of government an official is elected to, we are here to do the people's work and be their collective voices. The Resolution simply states:
"The California Srare Legislawreshall /JO! ellacr, a/Jd rhe Governor shall /JO! approve, ally law or regulariOll r/Jar applies solely 10 elecred officials of California cicies alld coumies, u/Jless such law or regulacioll also applies equally 10 members of che California Scace Assembly alld Se/lace.

This prohib icioll shall /JO! apply co laws or regulaciolls affecrillg che illherem powers of che legislauve brallch Ullder che California Consrirulion."
Whether the State Legislature or Governor heed our collective voices, we at the local level, through our Cal Cities membership, will have demonstrated our resolve that the basic leadership characteristic of leadership by example is the best approach to holding elective office.

Sincerely,
Tim Hepburn
Mayor
Genetal AdminiStration 909/596-8726 • Wa·er Customer Servir>! 008/5$-8744 • Community Servir>!s 909/596-8700 P\lbl~ Works 909/596-8741 • Finance 909/596-8716 • Ccmmunity Oe11elopmen1 909/596-8706 • 8u,lding 909/596-8713 Police Department 909/596·1913 • Fire Depanment 009/596-5991 • Goneral Fax 909/596-8737

14 July 8, 2024
Hon. Mike Allawos
Glendora City Councilmember
116 E. Foothill Blvd.

Glendora, CA 91741
Bill Uphoff
Lomita, CA
Re: Support for "Glendora's CalCities Resolution "
Dear Councilmember Allawos :

I would like to be a voice of support for Glendora's timely and needed resolution below for the upcoming CalCities annual conference this coming October 18, 2024. "The California State Legislature shall not enact, and the Governor shall not approve, any law or regulation that applies solely to elected officials of California cities and counties, unless such law or regulation also applies equally to members of the California State Assembly and Senate. This prohibition shall not apply to laws or regulations affecting the inherent powers of the legislative branch under the California Constitution."
I am an elected representative for our respective city, county, and state governance to do the people's work and be their collective voices. We should all have the same rules to be governed by.
~
Bill Uphoff, Mayor
City of Lomita
The views or opinions expressed In this letter are Intended to be Interpreted as rhe Individual wnrlc product of the author. Jney do not necessarily reflect an official position of the Oty Council, staff or other entities.

15 July 6, 2024
Hon. Mike Allawos
Glendora City Councilmember
116 E. Foothill Blvd.

Glendora , CA 91 741
John M. Cruikshank
Rancho Palos Verdes, CA
Re: Support for "Glendora's CalCities Resolution"
Dear Councilmember Allawos:

I would like to be a voice of support for Glendora's timely and needed resolution below for the upcoming CalCities annual conference this coming October 18, 2024. "The California State Legislature shall not enact, and the Governor shall not approve , any law or regulation that applies solely to elected officials of California cities and counties, unless such law or regulation also applies equally to members of the California State Assembly and Senate. This prohibition shall not apply to laws or regulations affecting the inherent powers of the legislative branch under the California Constitution."
I am an elected representative for our respective city, county, and state governance to do the people's work and be their collective voices. We should all have the same rules to be governed by.

Sincerely,
The views or opinions expressed in this letter ore intended to be interpreted os the individual work product of the author. They do not necessarily reflect on officio/ position of the City Council, stoff or other entities .

2024 Resolutions Packet

Resolution No. 1: Staff Analysis

16 League of California Cities Staff Analysis on Resolution No. 1 Sta
ff: Johnnie Pina, Legislative Affairs, Lobbyist
Committee: Governance, Transparency, and Labor Relations Summary:

This Resolution states that the League of California Cities shall call upon the Governor of the State of California and the elected members of the California Legislature, including all members of the Senate and Assembly to adopt the following policy:
“The California State Legislature shall not enact, and the Governor shall not sign into law, any law or regulation that applies solely to elected officials of California cities and counties, unless such law or regulation also applies equally to members of the California State Assembly and Senate. This prohibition shall not apply to laws or regulations affecting the inherent powers of the legislative branch under the California Constitution.”
Background:

This resolution states that examples of the California Legislature imposing rules limiting authority or regulating the conduct of local municipal officials that do not also apply to elected officials of the State of California include, but are not limited to:
• California’s open meeting rules, codified in the Ralph M. Brown Act, Government Code, Chapter 9, §§ 54950 et seq.;
• “One-off” exemptions, in the form of Senate Bill No. 174, from the California Environmental Quality Act (“CEQA”);
• Rules, in the form of Senate Bill No. 1439, amending the Political Reform Act (the “Act”); and
• Rules, in the form of Assembly Bill No. 571, that apply to city and county candidates for local elected office, but not to candidates for state-wide office.

Ralph M. Brown Act
T
he Ca
lifornia Attorney General’s (AG) Office defines The Ralph M. Brown Act (Brown Act) as what governs meetings conducted by local legislative bodies, such as boards of supervisors, city councils and school boards. The AG’s office states the Act represents the Legislature’s determination of how the balance should be struck between public access to meetings of multi-member public bodies on the one hand and the need for confidential candor, debate, and information gathering on the other.

The Ra
lph M. Brown Act governs local agencies, the Bagley-Keene Open Meeting Act covers all state boards and commissions, and Government code 17 9027 governs t he state Legislature. The California Constitution also mandates open meetings for state agencies, boards, and commissions. Specifically, the Constitution requires that each local agency comply with the Brown Act (Article I, section 3(b)(7)): and that the proceedings of each house of the Legislature be open and public (with exceptions for employment matters; matters affecting security; confer with legal counsel; and to meet as a caucus (Article IV, section 7).

Alt
hough fairly detailed requirements apply to state agencies and other state bodies, they do not apply to the Legislature. The Legislature has Constitutional authority to adopt rules for its proceedings that are consistent with the requirement that the proceedings of each house and the committees be open and public.

Another notable difference between the Legislature and a city council is the ability for Legislators to have a caucus to discuss a bill, express how they will vote, and to count votes. This is not allowed under the Brown Act. One other difference is that the laws governing teleconferencing for members of the state Legislature is far less flexible than it is for local bodies. However, state agencies have more flexibility than locals in that regard.

California Environmental Quality Act (“CEQA”)
The Resolution cites the Legislature's action in exempting from CEQA the reconstruction of the State Capitol Annex building. The State Legislature enacted the California Environmental Quality Act (CEQA) in 1 970, establishing it as a public disclosure law for the environmental review of discretionary projects and a process for mitigating or avoiding potential environmental impacts.

S
B 174 (Committee on Budget and Fiscal Review) C haptered by Secretary of State. Chapter 74, Statutes of 2024 was signed into law July 2, 2024. This bill exempts the work performed under the State Capitol Building Annex Act of 2016 from the California Environmental Quality Act (CEQA). In this example the Legislature exempted themselves as not being considered a “public agency,” “state agency,” or “lead agency” under CEQA. A lead agency under CEQA is the public agency that has the principal responsibility for carrying out or approving a project that is subject to CEQA.

Ov
er the years, the Legislature has also created many CEQA exceptions and exemptions for local projects involving local agencies as well.

The Political Reform Act (PRA) - Senate Bill No. 1439
SB 1439 (Glazer) C
haptered by Secretary of State. Chapter 848, Statutes of 2022 amends section 84308 and is aimed at preventing "pay-to-play" practices, in part by prohibiting parties, participants, and their respective agents in a 18 proceeding involving a license, permit, or other entitlement for use from contributing more than $250 to an officer of an agency during a 12 month period. When the Levine Act was first enacted in 1982, Section 84308 applied to appointed members of boards and commissions who were running for elective office. SB 1439 expended this law to now apply to local elected officials. Since it is focused on permits and licenses, it now applies to State agencies and local agencies that approve permits and licenses. Section 84308 does not apply to the Legislature or the Courts. It is important to note that unlike local governments, neither issue permits and licenses.

The Political Reform Act (PRA) - Assembly Bill No. 571
AB 571 (Mullin) C
haptered by Secretary of State. Chapter 556, Statutes of 2019 established default campaign contribution limits for county and city office at the same level as the limit on contributions from individuals to candidates for Senate and Assembly, effective January 1, 2021. This bill permitted a county or city to establish its own contribution limits, which would prevail over these default limits.

T
he Resolution cites AB 571 as an example of treating cities differently than the State. The Fair Political Practices Commission clarifies in their AB 571 fact sheet that under AB 571 a city may elect to have "no" contribution limit in which case the state contribution limit will not apply as a default for that jurisdiction. A city or county can set contribution limits higher than the default state limit, AB 571 sets a default in line with contributions Assembly Members and Senators if a city or county is silent on contribution limits.

Fiscal Impact:

Unknown.

Existing Cal Cities Policy:

Mission Statement
To expand and protect local control for cities through education and advocacy to enhance the quality of life for all Californians.

We Believe:
• Local self-governance is the cornerstone of democracy. • In the involvement of all stakeholders in establishing goals and in solving problems.
• In conducting the business of government with transparency, openness, respect, and civility. The spirit of honest public service is what builds communities.
• Open decision-making that is of the highest ethical standards honors the public trust.
• The vitality of cities is dependent upon their fiscal stability and local autonomy. The active participation of all city officials increases Cal Cities’ effectiveness.
19 • Partnerships and collaborations are essential elements of focused advocacy and lobbying.
• Ethical and well-informed city officials are essential for responsive, visionary leadership and effective and efficient city operations.

Comments:

Additional Examples
The Legislature has passed and the Governor has signed many laws that apply to local governments and do not apply to the state or the state Legislature. This year AB 2561(McKinnor) wa
s introduced , which requires local governments to
present in a public meeting a detailed report about their vacancy rates and detailed information about their hiring practices. This is an attempt to address public sector vacancy rates. This bill does not apply to the state in a time when they are also dealing with high vacancy rates.

Ad
ditionally, there were several bills that aim to amend the Levine Act, which now applies to local elected officials, to make changes to SB 1439, referenced previously in the analysis. None of the bills would amend the law to be applicable to Assembly Members or Senators.

AB 817 (Pacheco), co-s
ponsored by Cal Cities tried to bring parity to the Brown Act by making the teleconference rules for state advisory bodies the same for local advisory bodies but the Legislature struck the bill down.

Applying to elected officials or to the legislative body? Legislature or the State? T
he resolution also states, “… applies solely to elected officials of California cities and counties, unless such law or regulation also applies equally to members of the California State Assembly and Senate.”

This portion of the resolve clause is specifically speaking to local elected officials and State Assembly Members and Senators. However, many of the “where as” clauses are in reference to laws that apply to cities, the state and the Legislature as government agencies and not specifically to the elected officials on the governing bodies. For example, the Brown Act applies rules to the Legislative body and not the individual council member. Additionally, the city council as a whole is the lead agency under CEQA and not the individual council members.

Inherent Powers of the Legislative Branch
The resolution also states, “This prohibition shall not apply to laws or regulations affecting the inherent powers of the legislative branch under the California Constitution.”

It is unclear what inherent powers of the legislate branch under the California Constitution means in this context. The legislative branch does have the power 20 of preemption over cities and can state that a change in law is a matter of state wide concern. This allows the legislative branch to apply new laws or amend existing laws to apply to general law and charter cities. It seems like the last sentence of the resolve clause could negate the rest of the resolve clause if not clarified.

Support:

The following letters of concurrence were received:

April A. Verlato, Mayor, City of Arcadia
Robert Gonzales, Mayor, City of Azusa
Tim Hepburn, Mayor, City of La Verne
Bill Uphoff, Mayor, City of Lomita
John M. Cruikshank, Mayor, City of Rancho Palos Verdes

21

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