City Council and Authorities Concurrent
November 12, 2024

The EOP does not identify specific emergency shelters or evacuation routes in Santa Clara, though schools are identified as preferred facilities for lodging large numbers of people, with churches, hotels, and motels NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.9. HAZARDS AND HAZARDOUS MATERIALS SEPTEMBER 2024 5.9-14 ADMINISTRATIVE DRAFT MND/IS
also likely to function as mass care facilities during large-scale disasters. The proposed Project would not interfere with operation of any emergency shelters and would not permanently close off or otherwise alter any existing streets, and therefore would not create any obstructions to potential evacuation routes that might be used in the event of an emergency.

During construction, any temporary lane closures would be coordinated with local agencies as specified in Transportation and Traffic Mitigation Measure T-1 (Construction Traffic Control Plan) (see Section 5.16, Traffic and Transportation). Additionally, any temporary road closures would follow applicable regulations and would not impede emergency response. Adherence to the City’s EOP, coupled with implementation of mitigation measure MM T-1 during construction would ensure that the Project would not impair the implementation of, or physically interfere with, an adopted emergency response or evacuation plan; therefore, the impact that would occur related to emergency response during construction would be less than significant.

Mitigation Measure for Interference with an Adopted Emergency Response Plan or Emergency Evacuation Plan
MM T-1 Construction Traffic Control Plan [See Section 5.17.2 (Transportation) for complete text of the mitigation measure.]
(g) Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
NO IMPACT – CONSTRUCTION. The proposed Project is in an urban setting with no risk of wildland fire owing to the lack of extensive vegetation in the area. The Project route and surrounding areas are located in an LRA area and are not in mapped VHFHSZ as designated on CAL FIRE wildland fire hazard maps (OSFM, 2024).

LESS THAN SIGNIFICANT– OPERATION AND MAINTENANCE. Operation and maintenance activities would be incorporated into SVP’s existing O&M schedule for the existing transmission lines. As with current operation and maintenance, SVP would comply with all current federal and State laws related to vegetation clearance and fire prevention.

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5.10. Hydrology and Water Quality

HYDROLOGY AND WATER QUALITY
Would the project:

Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
(a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? ☐ ☒ ☐ ☐
(b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
☐ ☐ ☒ ☐
(c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i) result in substantial erosion or siltation on- or off-site; ☐ ☐ ☒ ☐ ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite;
☐ ☐ ☒ ☐
iii) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or ☐ ☐ ☒ ☐
iv) impede or redirect flood flows? ☐ ☐ ☒ ☐
(d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
☐ ☐ ☒ ☐
(e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
☐ ☐ ☒ ☐
Significance criteria established by CEQA Guidelines, Appendix G.

5.10.1. Setting

5.10.1.1. Surface Waters and Drainage
Surface water drainage in the City of Santa Clara is primarily to the Guadalupe River (east of the Project); San Tomas Aquino Creek, also sometimes mapped as the southern extension of Saratoga Creek; (west of the Project); Saratoga Creek (southwest of the Project), and Calabazas Creek (west of the Project) (City of Santa Clara, 2014). The proposed Project route is located approximately equidistantly between San Tomas Aquino Creek to the west and Guadalupe River to the east. The Project site drains to the San Tomas Aquino Creek within the San Jose International Airport-Frontal San Francisco Bay Estuaries Watershed.

Saratoga Creek (and San Tomas Aquino Creek) is listed as an impaired water body by the State Water Resource Control Board (SWRCB) 303 (d) list for diazinon (a pesticide) and trash; the diazinon TMDL listing is from 2007 and is being addressed by the USEPA approved San Francisco Bay Urban Creeks Diazinon TMDL and the trash is being addressed by implementing the trash control provisions of the Water Quality Control Plan for Inland Surface Waters, Enclosed Bays, and Estuaries of California (SWRCB, 2018).

All of the streams and rivers crossing the City originate in the Santa Cruz Mountains, which are largely undeveloped. These streams drain northward across Santa Clara Valley to discharge into San Francisco Bay. Within the City, these regionally important streams have been substantially channelized and modified to reduce flood hazards. The City has a storm drainage system that consists of curb inlets that collect and channel surface water, such as rainwater, into a series of storm sewers beneath City’s roadways. The stormwater is transported through the underground pipe to the 4 streams within the City. These streams then directly flow into the San Francisco Bay (City of Santa Clara, 2014).

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5.10.1.2. Groundwater Resources
The Santa Clara Valley is primarily underlain by the Santa Clara Valley groundwater basin, which is divided into three subbasins: the San Mateo Plain, the Niles Cone, and the Santa Clara subbasins. The proposed Project is within the Santa Clara Subbasin (DWR, 2024). The Santa Clara Subbasin is approximately 240 square miles, covering the middle and southern end of the Santa Clara Basin. The water bearing formations of the Santa Clara subbasin include Plio-Pleistocene age Santa Clara Formation of and Pleistocene to Holocene younger alluvium (DWR, 2003). Water production well depths in the Santa Clara Valley average about 278 feet below the ground surface and yield an average of 425 gallons per minute (City of Santa Clara, 2014).

In contrast to other areas adjacent to San Francisco Bay, where saltwater intrusion has been an issue, total dissolved solids in the groundwater have not been a concern for the City. Nitrates have also not been a problem and are below one‐half of allowable levels in water extracted from the City’s wells. However, manganese, a naturally occurring metal in groundwater, has been detected at one well, resulting in the City installing a manganese removal system for that well before putting it into production (City of Santa Clara, 2014). Water quality in the major producing aquifers in the subbasin is generally of a bicarbonate type, with sodium and calcium bicarbonate the principal cations. Although hard, is of good to excellent quality and suitable for most uses (DWR, 2003).

5.10.1.3. Flood Hazard Areas
On Federal Emergency Management Agency (FEMA) flood maps (FEMA, 2009), the Project site is primarily mapped as Zone X - Area with Reduced Flood Risk due to Levee, however, there are some portions of the proposed Project that intersect with areas mapped as Zone X – 0.2% Annual Chance Flood Hazard. The proposed Project would be adjacent to areas that are mapped as Zone AO with a depth of 1 foot, and AH with a base flood elevation of 23 to 32 feet. Special Flood Hazard Zone AO are areas that are river or stream flood hazard areas or areas with a 1% or greater chance of shallow flooding each year, usually in the form of a sheet flow, with an average depth ranging from 1 to 3 feet. Zone AH are areas with a 1% annual chance of shallow flooding usually in the form of a pond, with an average depth ranging from 1 to 3 feet (FEMA, 2009).

According to the City’s General Plan from 2014, Figure 5.10-2, the proposed Project is wholly within the Lexington Dam inundation area and is partially within the Anderson Dam inundation area. Some portions of the proposed Project are immediately adjacent to a small Special Flood Hazard Area, as identified above as Zone AH, however the Project site is not vulnerable to sea level rise. The General Plan also states that the City has adopted the Flood Damage Prevention Code, 1987, ed., to address requirements for flood protection (City of Santa Clara 2014).

5.10.1.4. Water Supply
Potable water for the City comes from a combination of sources: City of San Francisco’s Hetch Hetchy aqueduct system, Santa Clara Valley Water District, and groundwater from City‐owned wells. Groundwater comprises almost 70 percent of the City’s water supply. Recycled wastewater is also used in the City for certain landscape irrigation, industrial, and construction purposes (City of Santa Clara, 2014).

Regulatory Background
Federal
Clean Water Act. The Clean Water Act (CWA; 33 U.S.C. Section 1251 et seq.), formerly the Federal Water Pollution Control Act of 1972, was enacted with the intent of restoring and maintaining the chemical, physical, and biological integrity of the waters of the United States. The CWA requires states to set standards to protect, maintain, and restore water quality through the regulation of point source and NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.10. HYDROLOGY AND WATER QUALITY SEPTEMBER 2024 5.10-3 ADMINISTRATIVE DRAFT MND/IS
certain non-point source discharges to surface water. Those discharges are regulated by the National Pollutant Discharge Elimination System (NPDES) permit process (CWA Section 402). NPDES permitting authority is delegated to, and administered by, California’s nine Regional Water Quality Control Boards (RWQCB). In addition, the State Water Resources Control Board (SWRCB) regulates the NPDES stormwater program. The Proposed Project is under the jurisdiction of the San Francisco Bay Regional Water Quality Control Board (Region 2) and the SWRCB.

Projects that disturb one or more acres are required to obtain NPDES coverage under the California General Permit for Discharges of Storm Water Associated with Construction Activity. The Construction General Permit requires the development and implementation of a Storm Water Pollution Prevention Plan (SWPPP). The SWPPP describes Best Management Practices (BMPs) the discharger will use to protect stormwater runoff. The SWPPP must contain a visual monitoring program and a chemical monitoring program for “non-visible” pollutants to be implemented if there is a failure of BMPs.

Section 401 of the CWA requires that any activity, including river or stream crossing during road, pipeline, or transmission line construction, which may result in discharges into a State waterbody, must be certified by the RWQCB through the issuance of a Waste Discharge Requirement. This certification ensures that the proposed activity does not violate State or federal water quality standards. The limits of nontidal waters extend to the Ordinary High Water Mark (OHWM), defined as the line on the shore established by the fluctuation of water and indicated by physical characteristics, such as natural line impressed on the bank, changes in the character of the soil, and presence of debris.

Section 404 of the CWA requires a permit for construction activities involving placement of any kind of fill material into waters of the U.S. or wetlands. The U.S. Army Corps of Engineers (USACE) may issue either individual, site-specific permits or general, nationwide permits for discharge into U.S. waters. A Water Quality Certification pursuant to Section 401 of the CWA is required for Section 404 permit actions. If applicable, construction would also require a request for Water Quality Certification (or waiver thereof) from the Central Valley RWQCB and/or the Lahontan RWQCB.

Section 303(d) of the CWA (CWA, 33 USC 1250, et seq., at 1313(d)) requires states to identify impaired waterbodies as those which do not meet water quality standards. States are required to compile this information in a list and submit the list to the USEPA for review and approval. This list is known as the Section 303(d) list of impaired waters. As part of this listing process, states are required to prioritize waters and watersheds for future development of Total Maximum Daily Load (TMDL) requirements. A TMDL is the maximum amount of a pollutant that a particular waterbody can receive while still meeting water quality standards, or an allocation of that water pollutant deemed acceptable to receiving waters. The SWRCB and RWQCBs have ongoing efforts to monitor and assess water quality, to prepare the Section 303(d) list, and to develop TMDL requirements.

State
Porter-Cologne Water Quality Control Act. The Porter Cologne Water Quality Control Act of 1967, Water Code Section 13000 et seq., requires the SWRCB and the nine RWQCBs to adopt water quality criteria to protect State waters. These criteria include the identification of beneficial uses, narrative and numerical water quality standards, and implementation procedures. The criteria for the Project area are contained in the Water Quality Control Plan (also referred to as a Basin Plan) for the San Francisco RWQCB.

Constraints in the water quality control plans relative to the proposed Project relate primarily to the avoidance of altering the sediment discharge rate of surface waters, and the avoidance of introducing toxic pollutants to the water resource. A primary focus of water quality control plans is to protect designated beneficial uses of waters. In addition, anyone proposing to discharge waste that could affect the quality of the waters of the state must make a report of the waste discharge to the Regional Water Board or State Water Board as appropriate, in compliance with Porter-Cologne.

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California Water Code Section 13260. California Water Code Section 13260 requires that any person discharging waste, or proposing to discharge waste, within any region that could affect the quality of the waters of the State, other than into a community sewer system, must submit a report of waste discharge to the applicable RWQCB. Any actions related to the proposed Project that would be applicable to Section 13260 would be reported to the San Francisco RWQCB, as applicable.

Local
Safety Policies. The purpose of the City’s safety policies is to identify potential hazards and measures that can lessen risks for the City’s population and property. The following policies in the General Plan generally relate to the proposed Project (City of Santa Clara, 2014):
 Policy 5.10.5‐P11. Require that new development meet stormwater and water management requirements in conformance with State and regional regulations.  Policy 5.10.5‐P13. Require that development complies with the Flood Damage Protection Code.  Policy 5.10.5‐P14. Coordinate with the Federal Emergency Management Agency to ensure appropriate designation and mapping of floodplains.
 Policy 5.10.5‐P16. Require new development to implement erosion and sedimentation control measures to maintain an operational drainage system, preserve drainage capacity and protect water quality.  Policy 5.10.5‐P21. Require that storm drain infrastructure is adequate to serve all new development and is in place prior to occupancy.
 Policy 5.10.5‐P22. Regulate development on sites with known or suspected contamination of soil and/or groundwater to ensure that construction workers, the public, future occupants and the environment are adequately protected.

5.10.2. Environmental Impacts and Mitigation Measures
(a) Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? LESS THAN SIGNIFICANT WITH MITIGATION. Disturbance of soil during construction could result in soil erosion and lowered water quality through increased turbidity and sediment transport into the storm drain system. There are no watercourses or other water bodies within or adjacent to the Project. Drainage from the Project is directed to the municipal storm drain system which eventually flows into San Francisco Bay.

The City participates in the regional program for the Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP). Santa Clara is committed to improving water quality in the Bay and streams, reducing urban runoff pollution through the implementation of the City’s Urban Runoff Management Plan (URMP). The City’s URMP, along with other local Urban Runoff Management Plans, collectively constitute the regional plan that conforms to the federal requirements of the National Pollution Discharge Elimination System (City of Santa Clara, 2014).

During construction, there is also the potential for violations of water quality standards or waste discharge requirements to occur from accidental leaks, spills, or releases of hazardous or potentially hazardous materials. There also is a potential for violations if existing contamination is encountered during construction.

The proposed Project’s transmission line is approximately 2.24 miles long. Work would also occur at the existing NRS, KRS, and Palm Substation. Laydown or staging areas would also be required for Project material and equipment. While Option 1 (overhead line) would create less ground disturbance than Option 2 (partial underground line) it is assumed that over 1 acre of disturbance would be required for construction of the line under either option, triggering the need for a SWPPP. Implementation of mitigation measure MM HYD-1 is recommended to ensure that erosion control best management practices (BMPs) would be NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.10. HYDROLOGY AND WATER QUALITY SEPTEMBER 2024 5.10-5 ADMINISTRATIVE DRAFT MND/IS
in place to reduce potential water quality impacts to a less than significant level whether or not a SWPPP is triggered by State law. In addition to mitigation measure MM HYD-1, complying with applicable water quality standards, including obtaining and adhering to any required water quality permits, would offer sufficient protection to avoid significant adverse impacts to water quality from erosion and sedimentation. Applicable water quality standards and regulations are described above, in Section 5.10.1.

In the event of an accidental spill, adherence to regulatory standards and regulations, as well as implementation of mitigation measure MM HM-1 (Hazardous Substance Control and Emergency Response) (see Section 5.9), would collectively ensure that a suite of BMPs would be applied to minimize the potential for an accidental release of hazardous materials to occur, to quickly and effectively address any such leak, and to quickly and effectively respond to any existing contamination produced or encountered during construction. The intent of regulatory standards is to prevent degradation of water quality to the point where beneficial uses would be impaired. Therefore, potential impacts to water quality standards or waste discharge requirements or other substantial degradation of surface or groundwater quality during construction would be less than significant with implementation of mitigation measures HYD-1 and HM-1 and compliance with regulatory standards. With these mitigation measures, no violations would be expected from operation of the proposed Project.

Mitigation Measures for Water Quality
MM HYD-1 SWPPP or Erosion Control Plan Development and Implementation. Following Project approval, SVP will prepare and implement a SWPPP, if required by State law, or erosion control plan to minimize construction impacts on surface water and groundwater quality.

Implementation of the SWPPP or erosion control plan will help stabilize graded or disturbed areas and reduce erosion and sedimentation. The plan will designate BMPs that will be adhered to during construction activities. Erosion and sediment control measures, such as straw wattles, covers, and silt fences, may be installed before the onset of winter rains or any anticipated storm events if soils are not stabilized. Suitable stabilization measures will be used to protect exposed areas during construction activities, as necessary.

During construction activities measures will be in place to prevent contaminant discharge.

The Project SWPPP or erosion control plan will include erosion control and sediment transport BMPs to be used during construction. BMPs, where applicable, will be designed by using specific criteria from recognized BMP design guidance manuals. Erosion-minimizing efforts may include measures such as properly containing stockpiled soils.

Erosion control measures identified will be installed in an area before construction begins during the wet season and before the onset of winter rains or any anticipated storm events.

Temporary measures such as silt fences or wattles, intended to minimize sediment transport from temporarily disturbed areas, will remain in place until disturbed areas have stabilized. The plan will be updated during construction as required by the SWRCB.

A worker education program shall be established for all field personnel prior to initiating fieldwork to provide training in the appropriate application and construction of erosion and sediment control measures contained in the SWPPP. This education program will also discuss appropriate hazardous materials management and spill response. Compliance with these requirements will be ensured by the on-site construction contractor.

MM H-1 Hazardous Substance Control and Emergency Response (see full text in Section 5.9, Hazards and Hazardous Materials)
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(b) Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
LESS THAN SIGNIFICANT. Groundwater supplies could be adversely affected through direct consumption of groundwater resources or indirect depletion of groundwater supplies such as through conducting dewatering activities where the water is not returned to the subsurface. In the case of the proposed Project there would be minimal demand for water.

A water truck may be to support dust suppression during ground disturbing work and for foundation slurry preparation during construction of the drilled concrete pier foundations for the tubular steel poles. These uses would not result in a significant demand for water resources from the City, where groundwater makes up 70 percent of the City’s water supply. The existing supply is adequate for use during construction activities. Dewatering may be necessary if groundwater is encountered, but given the depth to the groundwater table, water encountered during project excavation would be shallow and local. The small amount of dewatering would therefore not result in a substantial decrease of the groundwater supply or interfere substantially with groundwater recharge or sustainable groundwater management. Overall, any impacts to groundwater would be less than significant.
(c) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i. result in substantial erosion or siltation on- or off-site; LESS THAN SIGNIFICANT. The proposed Project will be built entirely overhead under Option 1, with a possibility of a portion of transmission line being underground under Option 2. The overhead transmission line has no potential to alter the course of a stream or river, nor to substantially alter the existing drainage pattern of the site or area. The proposed Project is in an urban area, which has extensive impervious surfaces, therefore increases in impervious areas and soil compaction would be slight compared to the impervious area of the surrounding urban landscape. The proposed Project would therefore have a less than significant impact on drainage patterns or runoff generation. ii. substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?
LESS THAN SIGNIFICANT. As described under Item (c)(i) above, the Project area has extensive impervious surfaces except landscaping. The proposed Project would occur in and adjacent to paved areas and, if underground construction is required, the disturbed area would be restored. This would have a less than significant impact on drainage patterns or runoff generation. The site would drain to the existing stormwater drainage system, similar to existing condition. Impacts on flooding would therefore be less than significant.
iii. create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or LESS THAN SIGNIFICANT. As discussed above, the Project will not substantially increase the rate or amount of runoff. Existing or planned stormwater drainage systems would therefore not be adversely affected.

Except as described under Item (a) above, the Project has no features that would generate substantial polluted runoff. This impact would be less than significant. iv. impede or redirect flood flows?
LESS THAN SIGNIFICANT. The majority of the proposed Project route is within FEMA Zone X Area with Reduced Flood Risk due to Levee. A small portion of the route intersects Zone X – 0.2% Annual Chance Flood Hazard.

Additionally, the proposed Project is adjacent to a FEMA-designated Special Flood Hazard Areas(Zone AO, NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.10. HYDROLOGY AND WATER QUALITY SEPTEMBER 2024 5.10-7 ADMINISTRATIVE DRAFT MND/IS
and Zone AH). However, the proposed Project would be installing transmission line poles, which have a very small footprint compared to the width of the floodplain. The proposed Project would not pose a substantial obstruction to flood flows such that flood flows would be impeded or redirected in any substantial way; therefore, the impact would be less than significant. (d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation? LESS THAN SIGNIFICANT. The proposed Project site is not subject to the effects of a tsunami and is not near a waterbody that would create seiche effects. The majority of the proposed Project route is within FEMA Zone X Area with Reduced Flood Risk due to Levee. A small portion of the route intersects Zone X – 0.2% Annual Chance Flood Hazard. However, the proposed overhead lines would be well above the level of flooding with no opportunity to release pollutants as a result of flooding. NRS, which are not in the floodplain, would require minor improvements to accommodate the new circuit. The Project is not in a tsunami or seiche zone. This impact is therefore less than significant. (e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? LESS THAN SIGNIFICANT. As described in Item (a) above, the Project’s effect on water quality will be less than significant with mitigation. Although the nearby San Tomas Aquino/Saratoga Creek is listed as an impaired water body, there are no features of the Project that would adversely impact the diazinon or trash load of the creek. There are no features of the Project that would otherwise generate water quality impairments, nor are there any components of the Project construction or use that could otherwise conflict with the implementation of a water quality control plan. The Project will have minimal water use, mainly during construction, which will be obtained from local water purveyors. There are no features of the Project that would otherwise have any effect on groundwater management. This impact is therefore less than significant.

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5.11. Land Use and Planning

LAND USE PLANNING
Would the project:

Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
(a) Physically divide an established community? ☐ ☐ ☒ ☐ (b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
☐ ☐ ☐ ☒
Significance criteria established by CEQA Guidelines, Appendix G.

5.11.1. Setting
The proposed Project would be in an urban, heavily developed area in the City of Santa Clara within Santa Clara County, CA. The northern end of the proposed Project is at the North Receiving Station (NRS) located west of Lafayette Street and south of Bill Wash Way and immediately south of the Levi’s Stadium complex.

The southern end of the proposed Project is at Kifer Receiving Station (KRS) located northwest of the intersection of Lafayette Street and Central Expressway.

Various zoning designations apply to land along the Project alignment, including Heavy Industrial (MH), Light Industrial (ML), Medium Density Multiple Dwelling (R3-25D), Neighborhood Commercial (CN), Planned Development (PD), Single Family (R1-6L), and Planned Development – Master Community (PD-MC). The NRS and KRS sites are zoned as Public or Quasi Public (B) (City of Santa Clara 2023a). “MH” designations permit primary manufacturing, refining and similar activities, warehousing and distribution, and data centers. “ML” designations permit a range of light industrial uses, including general service, warehousing, storage, distribution, and manufacturing. “R3-25D” designations permit residential developments with 25 units per gross acre, with a variety of housing types such as low-rise apartments or townhouses. This designation is primarily intended for areas with access to collector streets or in close proximity to neighborhood centers. “CN” designations are intended for local-serving retail, personal service, and office uses that meet neighborhood needs, such as supermarkets, stores, medical facilities, restaurants, hair salons, and banks. “R1-6L” designations are designated for single family homes, or very low-density residential uses with detached dwelling units. “B” designations allow a variety of public and quasi-public uses, including government offices, fire and police facilities, transit stations, commercial adult care and childcare centers, religious institutions, schools, cemeteries, hospitals and convalescent care facilities, places of assembly, and other facilities that have a unique public character as their primary use. (City of Santa Clara, 2014) “PD” designations and “PD-MC” designations permit property with a minimum project size of 25 acres, or a master community, and are intended to allow modification of requirements established by other ordinances and diversification in the relationship of different uses, while ensuring compliance with the General Plan (City of Santa Clara 2023b).

Regulatory Background
This section includes a description of the land use and planning regulatory framework. There are no federal regulations or policies related to land use and planning applicable to the Project.

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Local
City of Santa Clara General Plan. The City’s land use policies consider the effects of development on public facilities and infrastructure. The following policy in the General Plan generally relates to the proposed Project (City of Santa Clara, 2014):
 Policy 5.3.1‐ P1. Preserve the unique character and identity of neighborhoods through community‐ initiated neighborhood planning and design elements incorporated in new development.  Policy 5.3.1‐ P2. Encourage advance notification and neighborhood meetings to provide an opportunity for early community review of new development proposals.  Policy 5.3.1‐P10. Provide opportunities for increased landscaping and trees in the community, including requirements for new development to provide street trees and a minimum 2:1 on‐ or off‐site replacement for trees removed as part of the proposal to help increase the urban forest and minimize the heat island effect.
 Policy 5.3.1-P11. Allow new public/quasi-public uses under any General Plan Land Use classification, provided that the use is compatible with planned uses on neighboring properties, consistent with other applicable General Plan policies, and has primary access from a Collector or larger roadway. Such uses not associated with government operations are prohibited in areas designated as Light Industrial or Heavy Industrial, and in areas designated High or Low Intensity Office/Research and Development outside the Exception Area.  Policy 5.3.1‐P15. Require new developments and major public infrastructure projects to include adequate rights-of‐way to accommodate all modes of transportation.  Policy 5.3.1‐P17. Promote economic vitality by maintaining the City’s level of service for public facilities and infrastructure, including affordable utilities and high-quality telecommunications.  Policy 5.3.1‐P28. Encourage undergrounding of new utility lines and utility equipment throughout the City.

5.11.2. Environmental Impacts and Mitigation Measures
(a) Would the project physically divide an established community? LESS THAN SIGNIFICANT - CONSTRUCTION. The new 115 kV transmission pole structures would primarily follow the edge of roadways, or would be within the median of the road, which includes landscaped planter areas, the perimeters of parking lots, or in sidewalks, where many of the existing power lines in the project vicinity are located. There are residential communities to the east and west of the proposed Project alignment. However, these communities are already physically divided by a main arterial road, Lafayette Street, and the railroad line, which is parallel to the road. The railroad is fenced or walled along part of the alignment to restrict access. The proposed Project would be constructed along Lafayette Street and parallel to the railroad line and would not be a physical barrier.

During construction work areas for pole installation would typically be within or edge of the road ROW and/or within SVP easements. The work areas would extend approximately 50 feet along the alignment for each individual pole location. The width of the Project encroachment into the public ROW and/or SVPs easement during pole installation and construction stringing will depend on the location of the pole in relation to the curb and private property lines, among other factors.

Construction of both Option 1 (all overhead) and Option 2 (partial underground) would require periodic, temporary lane closures along various public and private roads within the project area to create a safe workspace. Under Option 2, construction would occur over 14 months. Option 2 includes underground construction, which would require a longer construction period for the overall Project and more extensive NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.11. LAND USE AND PLANNING SEPTEMBER 2024 5.11-3 ADMINISTRATIVE DRAFT MND/IS
and longer duration temporary lane closures. The temporary lane closures would be coordinated with local agencies and SVP would obtain encroachment permits to conduct work in public ROWs in accordance with applicable City requirements.

Given the relatively short construction period and SVP’s coordination with local agencies, there would be a less-than-significant impact to the local established community during construction of the proposed Project.

NO IMPACT – OPERATIONS AND MAINTENANCE. During operations and maintenance, most of the proposed Project, except for the poles, would be overhead or underground, and would not divide an established community, therefore, there would be no impact.
(b) Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? NO IMPACT. The proposed Project would be consistent with the policies of the City General Plan, as listed above in Section 5.11.1, Setting. As discussed in Sections 5.1, Aesthetics, and 5.13, Noise, the project would have less than significant visual and noise impacts. SVP shall obtain all applicable ministerial permits prior to commencing project activities. The proposed Project does not cause an environmental impact due to a conflict with any applicable land use plans, policy, or regulation.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.12. MINERAL RESOURCES SEPTEMBER 2024 5.12-1 ADMINISTRATIVE DRAFT MND/IS

5.12. Mineral Resources

MINERAL RESOURCES
Would the project:

Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
(a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State? ☐ ☐ ☐ ☒
(b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan?
☐ ☐ ☐ ☒
Significance criteria established by CEQA Guidelines, Appendix G.

5.12.1. Setting
Mineral resources of significance found and extracted in Santa Clara County include construction aggregate deposits and salts derived from evaporation ponds at the edge of San Francisco Bay (City of Santa Clara, 2014). A review of California Department of Conservation (CDOC) and U.S. Geological Survey (USGS) data indicate that the proposed Project is in an area identified as MRZ-1, which is an area where there are no known significant mineral resources, and no active mining operations are located in the immediate vicinity of the proposed Project (CDOC, 1996 and 2024a; USGS, 2024). The USGS Mineral Resources Data System identifies one past gravel producer just to the west of the proposed Project (USGS, 2024). The site is currently identified as the CEMEX Concrete Plant located south of Montague Expressway (Google Earth, 2024).

Regulatory Background
This section includes a description of the regulatory framework for mineral resources. There are no federal or local regulations associated with mineral resources that are relevant to the proposed Project.

State
California Surface Mining and Reclamation Act of 1975 (SMARA). SMARA requires that the State Geologist classify land into Mineral Resource Zones (MRZs) according to the known or inferred mineral potential of the land. The California Department of Conservation’s Office of Mine Reclamation (OMR) and the State Mining and Geology Board (SMGB) are jointly charged with administration of the Act’s requirements. The OMR provides technical assistance to lead agencies and operators, maintains a statewide database of mine locations and operational information, and is responsible for matters involving SMARA compliance.

The SMGB promulgates regulations to clarify and interpret SMARA requirements in addition to serving as a policy and appeals board (CDOC, 2024b). The SMGB has the authority to further regulate the authority of the local agencies if it finds that the agencies are not in compliance with the provisions of SMARA.

Mineral resources have been mapped using the California Mineral Land Classification System, which include the following four MRZs:
 MRZ-1: Areas where adequate information indicates that no significant mineral deposits are present, or where it is judged that little likelihood exists for their presence;  MRZ-2: Areas where adequate information indicates that significant mineral deposits are present, or where it is judged that a high likelihood exists for their presence;  MRZ-3: Areas containing mineral deposits, the significance of which cannot be evaluated; and  MRZ-4: Areas where available information is inadequate for assignment to any other zone.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.12. MINERAL RESOURCES SEPTEMBER 2024 5.12-2 ADMINISTRATIVE DRAFT MND/IS

5.12.2. Environmental Impacts and Mitigation Measures
(a) Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State?
NO IMPACT. The proposed Project and the surrounding vicinity are not located within a classified Mineral Resource Zone and there are no known important mineral resources that would be impacted by the Project. Therefore, the Project would not result in the loss of availability of a known mineral resource of value to the region or State.
(b) Would the project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? NO IMPACT. As stated above, there are no designated Mineral Resource Zones in the proposed Project vicinity and there are no known important mineral resources that would be impacted by the Project.

Therefore, the Project would have no impact on any locally important mineral resource recovery sites.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.13. NOISE
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5.13. Noise
NOISE
Would the project result in:

Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
(a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
☐ ☐ ☒ ☐
(b) Generation of excessive groundborne vibration or groundborne noise levels?
☐ ☐ ☒ ☐
(c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
☐ ☐ ☐ ☒
Significance criteria established by CEQA Guidelines, Appendix G.

5.13.1. Setting
Existing Conditions
Community Noise. A measurement scale (A-weighted scale) that simulates human perception is used to describe environmental noise and to assess a project’s impacts on areas that are sensitive to community noise. The A-weighted scale of frequency sensitivity accounts for the sensitivity of the human ear, which is less sensitive to low frequencies, and correlates well with human perceptions of the annoying aspects of noise. The A-weighted decibel scale (dBA) is cited in most noise criteria. Decibels are logarithmic units that can be used to conveniently compare wide ranges of sound intensities.

Community noise levels can be highly variable from day to day as well as between day and night. For simplicity, sound levels are usually best represented by an equivalent level over a given time period (Leq) or by an average level occurring over a 24-hour day-night period (Ldn). The Leq, or equivalent sound level, is a single value (in dBA) for any desired duration, which includes all of the time-varying sound energy in the measurement period, usually one hour. The L50, is the median noise level that is exceeded fifty per cent of the time during any measuring interval. The Ldn, or day-night average sound level, is equal to the 24 hour A-weighted equivalent sound level with a 10 decibel penalty applied to nighttime sounds occurring between 10:00 p.m. and 7:00 a.m. Community Noise Equivalent Level (CNEL) is another metric that is the average equivalent A-weighted sound level during a 24 hour day, obtained after addition of five decibels to sound levels in the evening from 7:00 p.m. to 10:00 p.m. and after addition of 10 decibels to sound levels in the night from 10:00 p.m. to 7:00 a.m. To easily estimate the day-night level caused by any noise source emitting steadily and continuously over 24 hours, the Ldn is 6.4 dBA higher than the source’s Leq. For example, if the expected continuous noise level from equipment is 50.0 dBA Leq for every hour, the day-night noise level would be 56.4 dBA Ldn.

Community noise levels are usually closely related to the intensity of human activity. Noise levels are generally considered low when below 45 dBA, moderate in the 45 to 60 dBA range, and high above 60 dBA. In wilderness areas, the Ldn noise levels can be below 35 dBA. In small towns or wooded and lightly used residential areas, the Ldn is more likely to be around 50 or 60 dBA. Levels around 75 dBA are more common in busy urban areas, and levels up to 85 dBA occur near major freeways and airports.

Although people often accept the higher levels associated with very noisy urban residential and residential-commercial zones, they nevertheless are considered to be adverse to public health.

Surrounding land uses dictate what noise levels would be considered acceptable or unacceptable. Lower levels are expected in rural or suburban areas than what would be expected for commercial or industrial NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.13. NOISE
SEPTEMBER 2024 5.13-2 ADMINISTRATIVE DRAFT MND/IS
zones. Nighttime ambient levels in urban environments are about seven decibels lower than the corresponding daytime levels. In rural areas away from roads and other human activity, the day-to-night difference can be considerably less. Areas with full-time human occupation and residency are often considered incompatible with substantial nighttime noise because of the likelihood of disrupting sleep. Noise levels above 45 dBA at night can result in the onset of sleep interference. At 70 dBA, sleep interference effects become considerable (U.S. EPA, 1974).

Noise Environment in the Project Area. The Project area includes land uses that are residential, commercial, and industrial. The major arteries, such as Central Expressway and U.S. 101 near the Project, cause traffic noise levels that exceed 75 dBA CNEL along the edges of the roads, and noise levels that exceed 70 dBA CNEL at the Project alignment (City of Santa Clara, 2014; General Plan Figure 5.10 4). The Project is also within a 65 dB CNEL airport noise contour (City of Santa Clara, 2014; General Plan Figure 5.10 5).

Noise Sensitive Areas. Within 0.5 miles of the Project are a diverse range of general plan designations, including areas with medium density residential, low density residential, and community-serving parks/ open space. The only residences in the project vicinity are both east and west of Lafayette Street, primarily in the northern portion of the alignment, and just over 100 feet from the proposed transmission line route at their nearest. Project-related staging areas and work areas would be at least 100 feet from land uses containing sensitive receptors.

5.13.2. Regulatory Background
Regulating environmental noise is generally the responsibility of local governments. The U.S. EPA once published guidelines on recommended maximum noise levels to protect public health and welfare (U.S.

EPA, 1974), and the State of California maintains recommendations for local jurisdictions in the General Plan Guidelines published by the Governor’s Office of Planning and Research (OPR, 2017). The following summarizes the local requirements.

The City of Santa Clara City Code
The City Code generally prohibits “loud and unreasonable noise” as a nuisance if it may disturb the peace “between the hours of 10:00 P.M. and 7:00 A.M.” including specifically noise that is “made within two hundred fifty (250) feet of any building or place regularly used for sleeping purposes” (Section 9.05.010).

The City’s Noise Ordinance (Chapter 9.10) includes exterior noise limits that must not be exceeded at receiving land uses, for noise generated by any fixed source of noise. Construction activities that occur during allowed hours and noise from City-owned electric facilities are exempt from the noise and vibration standards of the Noise Ordinance (Section 9.10.070). For construction that is “off-street,” which would include project staging areas and substations, and within 300 feet of a residentially zoned property, construction activities shall be limited to occur within the hours of 7:00 A.M. to 6:00 P.M. on weekdays that are not holidays or within the hours of 9:00 A.M. to 6:00 P.M. on Saturdays that are not holidays (Section 9.10.230).

City of Santa Clara General Plan
The Environmental Quality chapter of the General Plan (2014) includes policies to encourage land uses that are compatible with areas of higher noise levels and to protect noise sensitive land uses in areas where existing ambient noise levels are high, as follows:
 Policy 5.10.6‐P6, Discourage noise sensitive uses, such as residences, hospitals, schools, libraries and rest homes, from areas with high noise levels, and discourage high noise generating uses from areas adjacent to sensitive uses.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.13. NOISE
SEPTEMBER 2024 5.13-3 ADMINISTRATIVE DRAFT MND/IS
 Policy 5.10.6‐P7, Implement measures to reduce interior noise levels and restrict outdoor activities in areas subject to aircraft noise in order to make Office/Research and Development uses compatible with the Norman Y. Mineta International Airport land use restrictions.  Policy 5.10.6‐P8, Continue to encourage safe and compatible land uses within the Norman Y. Mineta International Airport Noise Restriction Area.

5.13.3. Environmental Impacts and Mitigation Measures
(a) Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? LESS THAN SIGNIFICANT – CONSTRUCTION. The proposed Project would require 14 -months of construction (for Option 1) that includes mobilizing construction equipment, crews, and materials, excavating holes for poles, installing concrete pier foundations, installing poles, and wire stringing. The construction activities would require use of vehicles and heavy-duty equipment capable of generating noise along the proposed transmission line, at the proposed staging and work areas, within the modified substation sites, and along the roadways used to access these locations. The types of construction equipment used at work sites would include trucks for linework, lifts, delivery, concrete, water and work crews, backhoes, loaders, drill rigs, cranes, and small welders, pumps and generators. Outside of work sites, increased traffic noise would be caused by vehicles transporting equipment and supplies to the sites, trucks removing debris, and workers commuting to and from work sites.

Construction would temporarily increase the noise levels within the project area. Noise would vary, as work would occur intermittently at various sites. The surrounding land uses are primarily residential and heavy and light industrial, as well as transportation (arterial and connector roads, railroad). The locations of the proposed transmission line would not be immediately adjacent to any sensitive receptors. However, the area includes a diverse range of general plan designations within 0.5 miles of the project, including areas with medium density residential, low density residential, and community-serving parks/open space.

The closest residences in the project vicinity are east of Lafayette Street and approximately 100 feet from the proposed transmission line route. Most residences to the west are behind a high block wall. Projectrelated staging areas and work areas would be at least 100 feet from land uses containing sensitive receptors.

Construction activities along the project segments and at staging areas would create both intermittent and continuous noises. Intermittent noise would be caused by periodic, short-term equipment operation.

For example, a drill rig would need to be used with a backhoe or loader to create foundations, and this would require one or two days of work at each pole site. Continuous noise would emanate from equipment operation over longer periods, such as steady generator or excavator use. The maximum intermittent noise levels from a construction work spread would typically range from 84 to 90 dBA at 50 feet. These would be the highest levels expected for foundation development or excavation activities. At 50 feet, continuous noise levels could range up to about 83 dBA. Because sound fades over distance, these levels would diminish over additional distance and could be reduced further by intervening structures. At 100 feet from a work spread, continuous noise levels could range up to 77 dBA and at 200 feet, up to 71 dBA.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.13. NOISE
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Table 5.13-1 summarizes the typical noise levels
for individual pieces of construction equipment.

Construction would also cause noise away from
work areas, primarily from commuting workers and
from trucks needed to bring materials to the sites.

This would be similar to vehicle and truck traffic
already present in the area. Haul trucks would make
trips to bring poles, conductor line, and other
materials to the construction sites and remove
excavated soil and debris. The noise levels associated with passing trucks and commuting worker vehicles would be approximately 71 to 76 dBA at 50
feet, and would be concentrated along the major
arterial streets and smaller streets and access roads
leading to individual work areas.

Construction noise would affect the locations
closest to the work and staging areas and along site access routes used by haul trucks and other construction traffic. The surrounding land uses would experience a temporary increase in noise above the conditions that exist without the Project. Construction noise would occur in a setting of industrial land uses and moderate ambient noise levels without the Project. However, the intermittent and variable nature of construction noise limits the potential for adverse effects such as annoyance to be experienced by off-site receptors, and sleep interference would not be a concern because residences in the project area are set back from the alignment and most construction activities would occur during daylight hours.

Incremental noise from construction vehicles and traffic noise would not represent a substantial increase in the context of the project surroundings of industrial land uses and the existing noise levels.

SVP would take routine precautions to avoid creating unnecessary noise, especially near residential or other sensitive land uses. Construction traffic would be routed away from residential areas, when possible. The construction noise levels would be compatible with existing land uses and ambient noise levels and would pose no conflict with City policies regarding compatibility of land uses with noise levels. Project construction noise during daytime hours would be exempt from the standards established in City Noise Ordinance. The construction noise impact under this criterion would be less than significant.

LESS THAN SIGNIFICANT – OPERATIONS AND MAINTENANCE. City-owned electric facilities are exempt from the noise and vibration standards of the Noise Ordinance (Chapter 9.10.070). Upon completing construction, occasional maintenance of the Project would not result noise levels in excess of standards established in the local general plan or noise ordinance. Permanent increases in ambient noise levels in the project vicinity would not occur, and the transmission and distribution system improvements would not generate a new or different source of permanent noise. Operation and maintenance activities would be comparable to O&M of the SVP’s existing facilities. Corona and audible noise from the corona effect typically becomes a design concern for transmission lines at 230 kV and higher and is less noticeable or inaudible on lines operated at lower voltages such as the proposed 115 kV transmission line. This impact would be less than significant.
(b) Would the project result in generation of excessive groundborne vibration or groundborne noise levels generation of excessive groundborne vibration or groundborne noise levels? LESS THAN SIGNIFICANT. Groundborne vibration from construction equipment and activities might be perceptible to receptors in the immediate vicinity of work or staging areas. The activity that would be most likely to cause groundborne vibration would be the passing of heavy trucks on uneven surfaces. The impact from construction‐related groundborne vibration would be short‐term and confined to only the Table 5.13-1. Typical Noise Levels for Individual
Construction Equipment
Equipment
Typical Lmax
(dBA, at 50 ft)
Typical Leq
(dBA, at 50 ft)
Drill rig, auger 84 77
Crane 81 73
Backhoe 78 74
Excavator 81 77
Compactor 83 76
Dump truck, haul truck,
concrete mixer truck
76-79 73-76
Pickup truck, crew truck 75 62-71
Source: FHWA, 2006.

Lmax: Maximum noise level from Actual Measured in Roadway Construction Noise Model.

Leq: Equivalent noise level for one hour incorporating the Acoustical Usage Factor.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.13. NOISE
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immediate area around such activities (within about 25 feet). Pole locations and work sites, including the work within the existing substations, would be more than 25 feet from residences, so no homes would be exposed to excessive vibration, and the impact during construction would be less than significant.

Equipment associated with operation and maintenance of the Project would not produce any groundborne noise or vibration; therefore, operation and maintenance of the project would result in no impact under this criterion.
(c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? NO IMPACT. The proposed Project would be located adjacent to Levi Stadium and Lafayette Street and would cross Highway 101 and the Montague Expressway. The proposed Project would be unstaffed and would not create inhabited structures or workspaces. Therefore, the Project would not expose people to noise from the airport. Similarly, no excessive noise would result from Project operations that could impact people residing or working near the airport. There are no private airstrips located within two miles of the project, therefore the project would have no impact under this criterion. As such, the proposed Project would not expose people to excessive noise from aircraft, and there would be no impact.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.14. POPULATION AND HOUSING SEPTEMBER 2024 5.14-1 ADMINISTRATIVE DRAFT MND/IS

5.14. Population and Housing

POPULATION AND HOUSING
Would the project:

Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
(a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
☐ ☐ ☒ ☐
(b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? ☐ ☐ ☐ ☒
Significance criteria established by CEQA Guidelines, Appendix G.

5.14.1. Setting
The northern approximately 0.74 mile of the proposed Project is adjacent to areas zoned for residential uses of varying densities. The remainder of the proposed Project is adjacent to areas zoned for offices, businesses, and industrial uses (City of Santa Clara 2023).

Overall, this area of the City is substantially built out. Substantial increases in population can be achieved only by development of higher density housing, either on vacant land or through redevelopment of existing land uses.

Table 5.14-1 provides existing conditions for population housing, and employment for the City and the County of Santa Clara.

Table 5.14-1. Year 2017 Existing Conditions – Population, Housing, and Employment: City of Santa Clara and County of Santa Clara
Housing Units Employment
Location Population
Total
Units
Vacancy
Rate
Total
Employed*
Unemployment
Rate
City of Santa Clara 132,476 53,370 6.4% 70,400 3.3%
County Santa Clara 1,886,079 701,539 5.0% 1,002,600 3.5% *Accounts for population greater than 16 years of age and in Labor Force.

Source: CA DOF, 2023; CA EDD, 2023
Regulatory Background
This section includes a description of the population and housing regulatory framework. There are no federal or state regulations, plans, and standards for population and housing that apply to the proposed project.

City of Santa Clara General Plan
The purpose of the City’s housing policies is to plan for an adequate variety of safe, appropriate, and wellbuilt housing for all residents of Santa Clara (City of Santa Clara, 2014b). The following policies from the City General Plan and the Housing Element of the General Plan, respectively, generally relate to the proposed project (City of Santa Clara, 2014a; City of Santa Clara, 2014b):
 Policy 5.3.1‐P5. Implement a range of development densities and intensities within General Plan land use classification requirements to provide diversity, use land efficiently and meet population and employment growth.
 Policy D-4: Encourage early participation from residents and other stakeholders in development of long-range plans and review of new development proposals.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.14. POPULATION AND HOUSING SEPTEMBER 2024 5.14-2 ADMINISTRATIVE DRAFT MND/IS

5.14.2. Environmental Impacts and Mitigation Measures
(a) Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
LESS THAN SIGNIFICANT. The proposed project is in a substantially developed urban area. There would be no direct population growth induced by the Project, as it would not provide new housing and would not require an expansion of the SVP workforce to service and maintain the new transmission facilities. During the 14-month construction period (for Option 1), the proposed Project would provide short-term jobs for a small workforce. Construction needs are not anticipated to result in workers relocating to the area. The proposed Project would therefore generate neither a permanent increase in population levels nor a decrease in available housing.

The construction and operation of the new 115 kV transmission line and reconfiguring of the electric load would facilitate future planned growth by ensuring reliable electricity to the area and would therefore result in an indirect effect of facilitating the development of the surrounding area of the City of Santa Clara. Greater electrical reliability would provide developmental and employment opportunities to the regional workforce. While the further development of this area of the City may induce some population growth, this has already been accounted for through the City’s General Plan. Therefore, there would be a less than significant effect as a result of the proposed Project. (b) Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
NO IMPACT. The proposed Project would not be expected to result in an increase in population within the area. Construction of the new 115 kV transmission line would occur over approximately 14-months (for Option 1) and would not require the relocation of workers to the proposed Project area in the City. The proposed Project would not displace any housing or people, and therefore would not necessitate the construction of replacement housing. Therefore, no impacts would occur.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.15. PUBLIC SERVICES SEPTEMBER 2024 5.15-1 ADMINISTRATIVE DRAFT MND/IS

5.15. Public Services

PUBLIC SERVICES
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:

Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
(a) Fire protection? ☐ ☐ ☒ ☐
(b) Police protection? ☐ ☐ ☒ ☐
(c) Schools? ☐ ☐ ☐ ☒
(d) Parks? ☐ ☐ ☐ ☒
(e) Other public facilities? ☐ ☐ ☐ ☒
Significance criteria established by CEQA Guidelines, Appendix G.

5.15.1. Setting
For the area where the proposed Project would be located, public services, including fire and police services, as well as schools, parks and recreational areas, and other public services, are provided by the City of Santa Clara, special districts, and private entities.

5.15.1.1. Fire Protection
The Santa Clara Fire Department (SCFD) serves the City and provides fire protection and emergency services to the project site and the surrounding area (City of Santa Clara, 2014a). There are 10 fire stations throughout the City and each fire station has at least one 3‐person engine or ladder-truck company (City of Santa Clara, 2014a). The nearest fire stations to the proposed Project route are Fire Station 8 at 2400 Agnew Road, about 0.6 miles west of Lafayette Street, Fire Station 6 at 888 Agnew Road, about 0.5 miles west of Lafayette Street, and Fire Station 2 at 1900 Walsh Avenue about 0.8 mile from Kifer Receiving Station (KRS), which is the southernmost part of the proposed Project route (City of Santa Clara, 2024c).

The average response time is 3 minutes for all areas of the City (City of Santa Clara, 2014a).

5.15.1.2. Police Protection
The Santa Clara Police Department (SCPD) serves the City and provides police protection to the project site and the surrounding area (City of Santa Clara, 2014a). The police station at 3992 Rivermark Parkway is approximately 0.7 miles east of Lafayette Street. SCPD headquarters is located at 601 El Camino Real, about 1.7 miles from Kifer Receiving Station, which is the southernmost part of the proposed Project route. SCPD has 232 full-time employees, including 153 sworn officers and 79 civilians. The average response time from dispatch to first officer arrival is 2 minutes and 35 seconds (City of Santa Clara, 2024d).

5.15.1.3. Schools and Daycare
Six school districts serve the City: Santa Clara Unified School District, San José Unified School District, Cupertino Union School District, Fremont Union High School District, Campbell Union School District, and Campbell Union High School District. The Santa Clara Unified School District is the only school district that operates schools within the City (City of Santa Clara, 2014a). Numerous daycare facilities operate in the NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.15. PUBLIC SERVICES SEPTEMBER 2024 5.15-2 ADMINISTRATIVE DRAFT MND/IS
City, often in private homes. Educational institutions and known daycare facilities within 0.25-miles of the proposed Project include:
 Kathryn Hughes Elementary School, 4949 Calle De Escuela  North Valley Baptist Schools; 941 Clyde Ave
 Montague District Preschool, 750 Laurie Ave
 Anna’s Daycare, 4639 Snead Dr
 Care A Lot Family Daycare, 2056 Fairway Glen Dr
 Marvelous Kids Daycare, 4646 Armour Dr
 Hackett Daycare, 4493 Cheeney St
 Patty’s Loving Care, 2347 Remo Ct
 iGurukul Learning Center, 2067 Agnew Rd
 Little Dolphin Family Daycare, 2376 Silveria Ct
 Matangi Family Daycare, 901 Clyde Ave
 Santa Clara Joy Family Day Care, 849 Leith Ave
 Agape Playskool, 3700 Thomas Rd
 Little Glitters Daycare, 1038 Leith Ave
 Kool School Daycare, 983 Laurie Ave
 Martinson Child Development, 1350 Hope Dr
 Hughes Preschool, 4949 Calle De Escuela
 Mater Ecclesiae Academy, 968 Leith Ave

5.15.1.4. Parks
There are 40 parks in the City (City of Santa Clara 2024a). The parks nearest to the proposed Project are Lick Mill Park, a small part of which fronts on Lafayette Street near the Northern Receiving Station, and the Agnews Historic Park, located directly adjacent to the proposed Project at 4030 Lafayette Street (City of Santa Clara, 2024b). See Section 5.16, Recreation for a list of parks in the vicinity of the proposed Project.

5.15.1.5. Hospitals
The hospitals closest to the proposed Project are:
 O’Connor Hospital, 2105 Forest Avenue, San Jose, 3.4 miles south of KRS  Valley Health Center Sunnyvale, 660 S Fair Oaks Avenue, Sunnyvale, 4 miles west of KRS  Kaiser Permanente Santa Clara Medical Center, 700 Lawrence Expressway, 3.8 miles southwest of KRS The City’s 2010-2035 General Plan Integrated Final EIR identified seven roads as key routes in the City for emergency vehicles. Out of the seven routes only one, Montague Expressway, would be crossed by the proposed Project (City of Santa Clara 2011).

Regulatory Background
This section includes a description of the public services regulatory framework. There are no federal regulations associated with public services that are relevant to the proposed project.

State
2010 Strategic Fire Plan for California. The 2010 Strategic Fire Plan for California was developed in coordination with the State Board of Forestry and Fire Protection and CAL FIRE to reduce and prevent the impacts of fire in California. Goal 6 of the Plan sets objectives to determine the level of suppression resources (staffing and equipment) needed to protect private and public state resources. Specific objectives include, but are not limited to, maintaining an initial attack policy which prioritizes life, property, and natural NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.15. PUBLIC SERVICES SEPTEMBER 2024 5.15-3 ADMINISTRATIVE DRAFT MND/IS
resources; determining suppression resources allocation criteria; analyzing appropriate staffing levels and equipment needs in relation to the current and future conditions; increasing the number of CAL FIRE crews for fighting wildfires and other emergency response activities; maintaining cooperative agreements with local, state, and federal partners; and implementing new technologies to improve firefighter safety, where available (State Board of Forestry and Fire Protection). The standards outlined are applicable to the fire protection agency serving the City.

Local
City of Santa Clara General Plan. The purpose of the City’s public services policies is to maintain the safety and security that is essential and integral to the quality of life in the City’s community. The following policy in the General Plan generally relate to the proposed project (City of Santa Clara, 2014):
 Policy 5.9.3‐P1. Encourage design techniques that promote public and property safety in new development and public spaces.

5.15.2. Environmental Impacts and Mitigation Measures
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
(a) Fire protection?
LESS THAN SIGNIFICANT. The construction of the new 115 kV transmission line would result in fire risk that would be comparable to that of the transmission line that is being replaced and other existing electrical infrastructure in the area. The proposed Project area would continue to be adequately supported by the existing fire protection services since the construction and operation of the proposed Project would not induce growth in the project area and the fire risk from the proposed Project would not create the need for new or physically altered fire protection facilities. In addition, operation and maintenance would not affect the ability of fire personnel to respond to fires. Only one emergency access route, Montague Expressway, would be crossed by the proposed Project. No construction-related activities would be located on streets identified as major emergency access routes. Therefore, the proposed Project is not expected to significantly interfere with emergency response. Impacts on local or regional fire protection would be less than significant.
(b) Police Protection?
LESS THAN SIGNIFICANT. The proposed Project would not require police services during construction or operation and maintenance beyond routine patrols and response. As with fire services discussed in Item (a) above, the construction and operation of the proposed project would not induce growth in the project area, would not result in a need for additional police facilities or affect response times or other service performance. Only one emergency access route, Montague Expressway, would be crossed by the proposed Project. No construction-related activities would be located on streets identified as major emergency access routes. Therefore, the proposed Project is not expected to significantly interfere with emergency response. The result would be a less than significant impact. (c) Schools?
NO IMPACT. The proposed Project would not be expected to result in an increase in population within the area. Construction of the new 115 kV transmission line would occur over approximately 14 months and would not require the relocation of workers’ families to the City of Santa Clara. There would not be an expected increase in families or in school-age children as a result of the temporary construction activities and any workers who might temporarily migrate to the area. After construction, SVP’s existing maintenance NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.15. PUBLIC SERVICES SEPTEMBER 2024 5.15-4 ADMINISTRATIVE DRAFT MND/IS
and operations group would assume inspection, patrol, and maintenance duties as needed; therefore, no additional staff would be required after project construction work is completed. The proposed Project would result in no impact related to requiring expanded schools. (d) Parks?
NO IMPACT. The proposed Project would not increase the region’s population. Construction of the new 115 kV transmission line would take place over 14 months (for Option 1) and would require only a small workforce of construction personnel working on any given day. While it is possible that workers traveling to the area may use existing public services or amenities such as parks, the potential increase in use and demand would be minimal and temporary and would not contribute substantially to the physical deterioration of existing facilities. Consequently, the Project would not increase any long-term demands on existing parks in the project area, and no new or expanded park facilities would be required because of the proposed Project.
(e) Other Public Facilities?
NO IMPACT. The proposed Project would not increase population and would not affect other governmental services or public facilities that would lead to the requirement of new or expanded facilities to be developed. Therefore, no impact on other public facilities is expected.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.16. RECREATION SEPTEMBER 2024 5.16-1 ADMINISTRATIVE DRAFT MND/IS

5.16. Recreation

RECREATION
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
(a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? ☐ ☐ ☐ ☒
(b) Does the project include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment?
☐ ☐ ☐ ☒
Significance criteria established by CEQA Guidelines, Appendix G.

5.16.1. Setting
There are 40 parks in the City of Santa Clara (City of Santa Clara, 2024a). In general, each 1‐square mile of residential area in the City contains a neighborhood or community park located close to the center to ensure that almost all residents live within a 10-minute walk of a park (City of Santa Clara, 2014a).

The two parks nearest to the proposed Project are Lick Mill Park, a small part of which fronts on Lafayette Street near the Northern Receiving Station, and the Agnews Historic Park, located at 4030 Lafayette Street (City of Santa Clara, 2024a). The portion of Lick Mill Park at Lafayette Street is a 75-foot-wide greenway that extends east 0.3 miles along Fairway Glen Drive to the main park facilities. The Agnews Historic Park is 14.5 acres and is located on a Historic Easement on the Oracle Santa Clara campus property, which was the site of the former Agnews State Hospital. The park includes four historic buildings which are preserved as part of the historic easement (City of Santa Clara, 2024b).

There are several parks within 0.5 miles of the proposed Project, including: Agnew Park (approximately

0.22 mile west); Fuller Street Park (approximately 0.2 mile west); Santa Clara Youth Soccer Park (approximately 0.2 mile northwest); Fairway Glen Park (approximately 0.18 mile northeast); Lick Mill Park (approximately 0.3 mile east); and Montague Park (approximately 0.38 mile east). The Ulistac Natural Area is located approximately 0.5 mile east of the proposed Project and consists of 40 acres of open space with no facilities. All these parks, except the greenway strip from Lick Mill Park and Agnews Historic Park, fronting on Lafayette Street, are separated from the proposed Project development. Other recreational facilities in the City include sports fields, a skate park, swimming pools/centers, senior center and youth center (City of Santa Clara, 2024a), but none of these area in the vicinity of the proposed project.

Regulatory Background
This section includes a description of the recreation regulatory framework. There are no federal or State regulations associated with recreation that are relevant to the proposed project.

City of Santa Clara General Plan. The objective of the City’s public facilities and services policies is to maintain a high quality of life and livability in the City. The following policies in the General Plan generally relate to the proposed project (City of Santa Clara, 2014a):
 Policy 5.3.5‐P3. Encourage industrial development to participate in the identification and funding of 25 acres for park and recreational facilities to serve employment centers north of the Caltrain railroad tracks.
 Policy 5.9.1‐P16. Encourage non‐residential development to contribute toward new park facilities to serve the needs of their employees.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.16. RECREATION SEPTEMBER 2024 5.16-2 ADMINISTRATIVE DRAFT MND/IS

5.16.2. Environmental Impacts and Mitigation Measures
(a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
NO IMPACT. The Project does not include development of new residential areas or commercial facilities that would increase population and, therefore, would not increase the demand for parks in the Project area. Construction of the new 115 kV transmission line would take place over approximately 14 months (for Option 1) and would require only a small workforce working on any given day. While some workers may use nearby park facilities during Project construction, increased use would be minimal and temporary and would not contribute substantially to the physical deterioration of existing facilities. Therefore, there would be no impact.
(b) Does the project include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment? NO IMPACT. The proposed Project does not include recreational facilities, nor does it require the construction of new or expanded parks or recreational facilities that could create an adverse physical effect on the environment. There would be no impact.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.17. TRANSPORTATION SEPTEMBER 2024 5.17-1 ADMINISTRATIVE DRAFT MND/IS

5.17. Transportation

TRANSPORTATION
Would the project:

Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
(a) Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? ☐ ☒ ☐ ☐
(b) Conflict or be inconsistent with CEQA Guidelines §15064.3, subdivision (b)?
☐ ☐ ☒ ☐
(c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
☐ ☒ ☐ ☐
(d) Result in inadequate emergency access? ☐ ☒ ☐ ☐
Significance criteria established by CEQA Guidelines, Appendix G.

5.17.1. Setting
The proposed Project would use local roadways for accessing work areas during construction. Roadways along the proposed Project route may be temporarily disrupted during installation of the new transmission line. Baseline conditions of regional and local roadways likely used to access the proposed Project area and work locations and those temporarily affected by proposed Project construction activities are discussed below.

5.17.1.1. Highways
The following highways provide regional access to the proposed Project area and staging areas in the City (City of Santa Clara, 2014):
 U.S. Highway (U.S.) 101, specifically the section of U.S. 101 known as Bayshore Freeway, is an 8-lane divided (4 lanes per direction) south-north highway that travels the length of the West Coast. The San Tomas Expressway exit or the De La Cruz Boulevard/Trimble Road exit from U.S 101 would likely be used to access the Project area. At the San Tomas Expressway exit, the year 2016 average daily traffic (ADT) volumes on U.S. 101 were 193,000 vehicles per day. At the De La Cruz Boulevard/Trimble Road exit, the year 2016 ADT volumes on U.S. 101 were 183,000 vehicles per day (Caltrans, 2020). Year 2016 ADT volumes represent the most recently published data.  State Route (SR) 237, or Southbay Freeway, is a 6-lane- divided west-east highway that connects Interstate (I)-880 and I680 with U.S. 101 and SR 85 and extends northeast through the city. The Great America Parkway exit would likely be- used to access the Project area. At this exit, year 2016 ADT volumes on SR 237 were 124,000 vehicles per day (Caltrans, 2020).  Interstate 280, or Junipero Serra Freeway, is a 10-lane south-north regional highway that connects I880 and SR1 and extends through the City. The exit at the junction of I280 with SR 17 and I880 would likely be the used to access the Project area. At this exit, year 2016 ADT volumes on I280 were 205,000 vehicles per day (Caltrans, 2020).

5.17.1.2. Local Roads
CEQA now analyzes project impacts in terms of vehicle miles traveled (VMT) to better understand such parameters as air quality impacts, fuel consumption, and commute times. The VMT approach is reasonable for projects that will generate traffic to and from the project site over time, such as offices, apartments, factories, and shopping centers. However, for projects that have a temporary traffic impact related to construction, after which traffic generation is minimal or non-existent, the primary concern is with the NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.17. TRANSPORTATION SEPTEMBER 2024 5.17-2 ADMINISTRATIVE DRAFT MND/IS
project’s impact on congestion during construction. To understand congestion and traffic delays, roadway and intersection operating conditions and the adequacy of existing roadway systems to accommodate traffic can be described in terms of level of service (LOS) ratings. LOS is expressed as A through F, with LOS A as the best operating conditions (characterized by free-flow traffic, low volumes, and little or no restrictions on maneuverability) and LOS F being the worst operating conditions (stop-and-go traffic flow with high traffic densities and slow travel speeds). The analysis in this section considers LOS impacts.

Access Routes
Table 5.17-1 provides information on some primarily local travel routes that would likely be used by project-related vehicles to access the construction staging yards and the proposed Project alignment.

Details on access routes that would also be disrupted by project construction are discussed below under “Roadways Disrupted by Project Construction” and are not repeated in Table 5.17-1. While the average daily traffic provided in Table 5.17-1 are from 2011, it remains the most currently available ADT volume data for these roadways.

Table 5.17-1. Existing Local Roadway Conditions
Street Lanes ADT Volume LOS
Montague Expressway (between De La Cruz Boulevard and Lafayette Street) 8 60,570 D Montague Expressway (between Lafayette Street and Mission College Boulevard) 8 58,070 D Central Expressway (Lafayette Street and De La Cruz Boulevard) 8 59,700 D Central Expressway (between Scott Boulevard and Lafayette Street) 8 47,550 D Agnew Road (between Lafayette Street and Montague Expressway) 4 14,820 D Lafayette Street (between Tasman Drive and Montague Expressway) 4 18,370 D Lafayette Street (between Montague Expressway and US 101) 4 11,600 C Lafayette Street (between US 101 and Central Expressway) 4 18,190 D LOS = level of service
Source: City of Santa Clara, 2011.

Roadways Disrupted by Project Construction
Construction of the proposed Project could result in a temporary disruption to local roadways during delivery of large equipment or materials and during installation of poles and conductors along the transmission line alignment on Lafayette Street. The main roads that may require temporary lane closures and/or escort vehicles to facilitate material and equipment deliveries include Lafayette Street, Agnew Road, Montague Expressway, and Central Expressway, a combination of which could be used to access the smaller local roads which may be used to access the transmission route and the substations.

5.17.1.3. Mass Transit
Bus
Existing public transit service within the City is primarily provided by Santa Clara Valley Transportation Authority (VTA) and consists of bus, light rail transit, and paratransit services. VTA bus route 20 crosses the proposed Project at Agnew Road (VTA, 2021). Route 10 travels along Agnew Road in the central part of the proposed transmission line route (VTA, 2021).

Passenger Rail
Existing commuter rail lines include Caltrain, operated by the Peninsula Joint Powers Board (JPB), and Altamont Commuter Express (ACE), operated by the San Joaquin Regional Rail Commission. Both stop at the Santa Clara Transit Center, approximately 2 milessouth of Kifer Receiving Station. The Capitol Corridor NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.17. TRANSPORTATION SEPTEMBER 2024 5.17-3 ADMINISTRATIVE DRAFT MND/IS
commuter rail line, operated by the Capitol Corridor Joint Powers Authority (CCJPA), stops at the Great America Station approximately 0.4 miles northwest of the Northern Receiving Station and provides transit services between Sacramento and San Jose. Planned transit developments in the City include a possible extension of Bay Area Rapid Transit (BART) to the Santa Clara Transit Center, High Speed Rail along the Caltrain corridor, and the Agnew Siding Project along the Capital Corridor. (City of Santa Clara, 2011 and 2014)

5.17.1.4. Rail (Freight)
Outside peak commuter rail periods, the Union Pacific Railroad (UPRR) provides freight operations within the Caltrain right‐of‐way (ROW). The Caltrain ROW traverses through the middle and downtown areas of the City. The rail network includes grade‐separated and at‐grade railroad crossings. The network includes the potential for additional crossings to accommodate a future high-speed rail. (City of Santa Clara, 2014)

5.17.1.5. Bicycle
Existing bicycle facilities are part of City Bicycle and Trail Network, providing connections between residential neighborhoods, employment, recreation, education, and transit centers within the City (City of Santa Clara, 2014). Bikeways are typically classified as Class I, II, or III facilities. Bike paths or trails (also known as Class I bikeways) operate within a right-of-way separated from vehicular traffic. Bike lanes (also known as Class II bikeways) are located within roadways but are delineated by warning symbols and striping. Bike routes (also known as Class III bikeways) operate in the shoulder lane of roadways but are not delineated by striping. One Class II bikeway is located along De La Cruz Boulevard on the section of the Boulevard north of the proposed Project route (City of Santa Clara, 2013).

5.17.1.6. Air Transportation
The Norman Y. Mineta San Jose International Airport (Airport) is southeast of the Kifer Receiving Station in San Jose, adjacent to the City.

Regulatory Background
Federal
14 CFR Part 77 – Safe, Efficient Use, and Preservation of the Navigable Airspace. Construction of a project could potentially impact aviation activities if a structure or equipment were positioned such that it would be a hazard to navigable airspace. The Federal Aviation Administration (FAA) has established reporting requirements if any construction includes equipment or structures more than 200 feet above ground level or results in an object penetrating an imaginary surface extending outward and upward at a ratio of 100 to 1 from a public or military airport runway out to a horizontal distance of 20,000 feet (approximately

3.78 miles) (FAA, 2016). For areas around heliports, this same requirement applies to any construction that is more than 200 feet above ground level or would penetrate an imaginary surface extending outward and upward at a ratio 25 to 1 from a public or military heliport out to a horizontal distance of 5,000 feet.

State
California Vehicle Code (CVC). The CVC includes regulations pertaining to licensing, size, weight, and load of vehicles operated on highways; safe operation of vehicles; and the transportation of hazardous materials.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.17. TRANSPORTATION SEPTEMBER 2024 5.17-4 ADMINISTRATIVE DRAFT MND/IS
Local
City of Santa Clara General Plan. The objectives of the City’s mobility and transportation policies are to a safe, efficient, convenient, and integrated system to move people and goods and promote a reduction in the use of personal vehicles and vehicle miles traveled. The following policies in the General Plan generally relate to the proposed Project (City of Santa Clara, 2014):
 Policy 5.8.2‐P3. Encourage undergrounding of utilities and utility equipment within the public right‐of‐ way and site these facilities to provide opportunities for street trees and adequate sidewalks.  Policy 5.8.5‐P1. Require new development and City employees to implement transportation demand management programs that can include site‐design measures, including preferred carpool and vanpool parking, enhanced pedestrian access, bicycle storage and recreational facilities.  Policy 5.8.5‐P4. Encourage new development to participate in shuttle programs to access local transit services within the City, including buses, light rail, Bay Area Rapid Transit, Caltrain, Altamont Commuter Express Yellow Shuttle, and Lawrence Caltrain Bowers/Walsh Shuttle services.

5.17.2. Environmental Impacts and Mitigation Measures
(a) Would the project conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities? LESS THAN SIGNIFICANT WITH MITIGATION – CONSTRUCTION. Project construction would occur in a highly urbanized setting and would therefore create impacts to public, private, and pedestrian transit in the project area. Some road closures and/or one-way traffic controls would be required to allow for certain construction activities and to maintain public safety. These closures and controls would decrease traffic flow and parking availability in the project area, particularly on Lafayette Street. The ROW width that would be required for the transmission line would vary depending on the location, but in general, is approximately 50 feet. SVP would obtain encroachment permits to conduct work in public and railroad ROWs in accordance with applicable City and UPRR requirements. Many of the existing power lines in the Project vicinity are located along the edges of the roadway, such as in landscaped planter areas, the perimeters of parking lots, or along sidewalks. From NRS to Palm Substation at Agnew Road, the new transmission line would be either underground or on poles in the median of Lafayette Street. South of Palm Substation, the lines would be overhead on poles along the east side of Lafayette Street to Montague Expressway, where the line would cross to the west side of Bassett Street. The lines would be mainly located at the west edge of the roadway and continue to Kifer Receiving Station (See Figure 4-1) and be installed in the same general locations as the existing power lines.

While construction would create impacts, these impacts would be localized, temporary in nature, and would not change long-term traffic loads or patterns. Mitigation Measure T1 is proposed to provide specificity regarding the requirements of a construction Traffic Control Plan. The purpose of this plan would be to reduce potential impacts to the circulation system from the closure/disruption to roadways and travel lanes. With the incorporation of this mitigation, construction would not conflict with programs, policies, plans, or ordinances regarding public roadway, transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities.

NO IMPACT – OPERATIONS AND MAINTENANCE. SVP’s existing maintenance and operations group would assume inspection, patrol, and maintenance duties as needed. Typical maintenance activities involve both routine inspections and preventive maintenance to ensure service reliability, as well as emergency work to maintain or restore service continuity. No additional staff would be required after Project construction work is completed. No substantial increase in traffic or traffic-related impacts would occur due to operation and maintenance activities.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.17. TRANSPORTATION SEPTEMBER 2024 5.17-5 ADMINISTRATIVE DRAFT MND/IS
Mitigation Measures for Transportation Impacts
MM T-1 Construction Traffic Control Plan. Prior to the start of construction, SVP or its designee shall prepare and submit an Encroachment Permit which will include the construction Traffic Control Plan for review and approval to the City’s Department of Public Works for public roads and transportation facilities that would be directly affected by the construction activities and/or would require permits and approvals. SVP shall submit the construction Traffic Control Plan to the City prior to conducting activities covered in the traffic control permits. The Construction Traffic Control Plan shall include, but not be limited to:
 The locations and use of flaggers, warning signs, lights, barricades, delineators, cones, arrow boards, etc., according to standard guidelines outlined in the Manual on Uniform Traffic Control Devices, the Standard Specifications for Public Works Construction, and/or the California Joint Utility Traffic Control Manual.  Additional methods to reduce temporary traffic delays and trips during peak travel hours to the extent feasible.
 Typical access routes between all staging areas and the proposed work areas.  Defining methods to coordinate with the City throughout construction to minimize cumulative lane disruption impacts should simultaneous construction projects affect shared segments/portions of the circulation system.
 Prior to the start of construction, provide (or identify the timing to provide) the City with methods to comply with all specified requirements.  Plans to coordinate in advance with emergency service providers to avoid restricting the movements of emergency vehicles. Police departments and fire departments shall be notified in advance by SVP of the proposed locations, nature, timing, and duration of any roadway disruptions, and shall be advised of any access restrictions that could impact their effectiveness. At locations where roads will be blocked, provisions shall be ready at all times to accommodate emergency vehicles, such as immediately stopping work for emergency vehicle passage, providing short detours, and developing alternate routes in conjunction with the public agencies. Documentation of the coordination with police and fire departments shall be gathered prior to the start of construction.  Plans to coordinate in advance with property owners, if any, that may have limited access to properties due to temporary lane closures. Provisions for ensuring secondary access should be provided.
 Plans to coordinate with Valley Transportation Authority in advance of construction to minimize disruption to mass transit.
(b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)? LESS THAN SIGNIFICANT – CONSTRUCTION. CEQA Guidelines section 15064.3(b) concerns vehicle miles travelled (VMT) as the measure of transportation impacts. Prior to July 1, 2020, use of the provisions of section 15064.3(b) was at the discretion of the CEQA lead agency but are now mandatory statewide. As discussed in CEQA Guidelines Section 15064.3(b)(3), a qualitative analysis of construction traffic vehicle miles travelled (VMT) may be appropriate.

Construction of the proposed Project would occur over approximately 14 months (for Option 1) and proposed Project–related traffic would be limited to worker commutes and the transport of supplies and equipment to and from construction areas and material supply sources. Once the Project is completed, the vehicle trips associated with construction would end. The total peak number of vehicle trips is NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.17. TRANSPORTATION SEPTEMBER 2024 5.17-6 ADMINISTRATIVE DRAFT MND/IS
estimated to be up to 30 roundtrips daily. Construction personnel would commute to the staging yards and work sites at the beginning of the day and leave at the end of the day, and few people would travel to and from work areas throughout the middle of the day.

Vehicle miles traveled by personal vehicle trips and truck trips during construction would vary in their origins and destinations, but they are assumed to come primarily from the local or Bay Area and they would be periodic and temporary. At this time, no known applicable VMT thresholds of significance for temporary construction trips that may indicate a significant impact is known. Therefore, while the proposed Project would include temporary construction trips with some that may include higher VMT to deliver specialized materials and equipment, they would be short-term and the Project would not affect existing transit uses or corridors and is presumed to cause a less than significant transportation impact under State CEQA Guidelines section 15064.3(b).

LESS THAN SIGNIFICANT – OPERATIONS AND MAINTENANCE. Maintenance of the proposed Project would require routine inspection and periodic maintenance visits by existing SVP personnel. These activities would generate a negligible number of new vehicle trips with no notable growth in VMT. The transportation impact under State CEQA Guidelines section 15064.3(b) would be less than significant. (c) Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? LESS THAN SIGNIFICANT WITH MITIGATION – CONSTRUCTION. Heavy equipment operating adjacent to or within a road right-of-way could increase the risk of accidents. Construction of the proposed Project would involve activities within and adjacent to public roadways, requiring temporary lane narrowing and, in some instances, temporary lane or roadway closures. Construction-generated truck traffic on the affected city streets would interact with other vehicles, and potentially create hazards. Potential conflicts also could occur between construction traffic and bicyclists and pedestrians, and potential short-term hazards could be associated with temporary lane closures during construction. Construction traffic–related impacts would be reduced with implementation of Mitigation Measure T-1 (Construction Traffic Control Plan) to ensure temporary lane closures and construction activities do not result in increased hazards to the traffic circulation system.

Mitigation Measure T1 requires the Project applicant to obtain and adhere to all requirements of an Encroachment Permit from the City, and to prepare a Traffic Control Plan that provides for the safe and efficient movement of emergency vehicles, bicycles, pedestrians, and transit vehicles through or around construction zones while protecting the workers, equipment, and construction areas. While there may be a limited increase in hazards due to construction activities proximate to public roadways, construction would be temporary and with the incorporation of Mitigation Measure T1, temporary impacts during construction would be less than significant.

LESS THAN SIGNIFICANT – OPERATIONS AND MAINTENANCE. The height and form of the proposed Project structures would be similar to the existing 115 kV transmission structures located adjacent to roadways throughout the City and they are not expected to increase transportation hazards or be an incompatible use. Maintenance of the proposed Project would require routine inspection and periodic maintenance visits. While temporary lane closures are not anticipated, occasionally maintenance vehicles or equipment may be temporarily present alongside the roadways depending on structure locations; however, at least one lane of travel would remain open at all times. Therefore, the Project would not cause hazards or incompatible uses due to maintenance activities proximate to public roadways; no mitigation is required.

Mitigation Measures for Transportation Hazards
MM T-1 Construction Traffic Control Plan. [see full text under Item (a) above] NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.17. TRANSPORTATION SEPTEMBER 2024 5.17-7 ADMINISTRATIVE DRAFT MND/IS
(d) Would the project result in inadequate emergency access? LESS THAN SIGNIFICANT WITH MITIGATION – CONSTRUCTION. Construction of the proposed Project would cause a minor short-term increase in the local traffic and congestion in the immediate vicinity of the section of the proposed route if there would be a temporary lane closure. The proposed Project would not increase traffic substantially as compared to the existing traffic volume and the capacity of the street system in the area. At least one lane of travel through each construction area would remain open throughout the construction period to accommodate roadway users (including emergency vehicles). To ensure temporary lane closures do not result in inadequate emergency vehicle movements or impede access to property, Mitigation Measure T-1 (Construction Traffic Control Plan) is proposed and would require review and approval of a project-specific Construction Traffic Control Plan, which would include specific measures to address temporary closures/disruptions to travel lanes and plans to coordinate in advance with emergency service providers. With the incorporation of Mitigation Measure T-1, temporary impacts during construction would be less than significant.

LESS THAN SIGNIFICANT – OPERATION AND MAINTENANCE. Once operational, the proposed Project would have minimal impact on access or movement to emergency service providers. Occasional maintenance activities would be short-term in duration throughout the project area. While temporary lane closures are not anticipated, occasionally maintenance vehicles or equipment may be temporarily present alongside the roadways depending on structure locations; however, at least one lane of travel would remain open at all times. Therefore, maintenance of the proposed Project would have a less than significant impact on emergency vehicle access and movements.

Mitigation Measures for Emergency Access
MM T-1 Construction Traffic Control Plan. [see full text under Item (a) above] NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.18. TRIBAL CULTURAL RESOURCES SEPTEMBER 2024 5.18-1 ADMINISTRATIVE DRAFT MND/IS

5.18. Tribal Cultural Resources

TRIBAL CULTURAL RESOURCES
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
(a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code §21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i) listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code §5020.1(k), or
☐ ☒ ☐ ☐
ii) a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code §5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.
☐ ☒ ☐ ☐
Significance criteria established by CEQA Guidelines, Appendix G.

5.18.1. Setting
Tribal Cultural Resources (TCRs) are defined under Assembly Bill 52 (AB 52) as resources that include sites, features, places, cultural landscapes, and sacred places or objects that have cultural value or significance to a California Native American tribe. Tribal representatives are considered experts appropriate for providing substantial evidence regarding the locations, types, and significance of TCRs within their traditional and cultural affiliated geographic areas, and therefore the identification and analysis of TCRs should involve government-to-government tribal consultation between the CEQA lead agency and interested tribal groups and/or tribal persons (Public Resources Code [PRC] §21080.3.1(a)).

Additionally, best practices show that a lead agency should make a good faith effort to identify TCRs that may be impacted by a Project even if a Native American tribe does not identify any during consultation.

This includes requesting a search of the Native American Heritage Commission’s (NAHC) Sacred Lands file, conducting ethnographic research, and using information that has been previously provided during tribal consultation for other projects in the area.

5.18.1.1. Record Search
As documented in Section 5.5 (Cultural Resources), the records search indicates that no prehistoric cultural resources have been previously identified in the Project area.

5.18.1.2. Ethnographic Setting
The Project area is located within the tribal territory of the “Costanoan,” a term derived from the Spanish word Costanos, meaning “coast people” or “coastal dwellers.” At the time of European ethnic groups’ arrival, the Costanoan occupied the central California coast from the northern end of the San Francisco Peninsula south to Big Sur and as far east as the Diablo Range. An estimated 1,400 or more persons of partial Costanoan descent currently reside in the greater San Francisco Bay Area. These individuals now generally prefer the term Ohlone to identify themselves (Margolin, 1978).

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.18. TRIBAL CULTURAL RESOURCES SEPTEMBER 2024 5.18-2 ADMINISTRATIVE DRAFT MND/IS
The Costanoan language is part of the Penutian language family spoken by other California Indian groups known as the Wintun, Maidu, Miwok, and Yokuts. The Costanoan (Ohlone) language family consists of six dialect clusters, of which three were recorded during the ethnohistoric period, including the San Francisco Bay Costanoan, Mutsun along the Pajaro River, and Rumsen near Monterey and Carmel (Golla, 2011:162 163). Linguistic analysis suggests that the Costanoans moved into the Bay Area from the San Joaquin and Sacramento River regions around 1,500 years Before Present (BP) and replaced the original Hokan speaking population of the Bay Area. This appears to coincide with the appearance of Late Horizon artifact assemblages. Using Spanish mission records and archaeological data, researchers have estimated a Costanoan population of 1,000 to 1,200 individuals for the Santa Clara Valley in 1770 (Levy, 1978:485; King, 1977:54).

The Costanoan practiced a hunting and collecting economy focusing on the collection of seasonal plant and animal resources, including tidal and marine resources from San Francisco Bay. They traded with neighboring groups and exported shells, salt, and cinnabar among other items. At the time of contact with Europeans, the Costanoan people were living in approximately 50 separate and politically autonomous tribelets, with each group having one or more permanent villages surrounded by a number of temporary camps used to exploit seasonally available floral and faunal resources (Levy, 1978:485, 487).

Mission Santa Clara and Mission San José were established in the South Bay in the late 1770s. The aboriginal lifeway disappeared by 1810 due to diseases, a declining birth rate, and the impact of the mission system. Missionization not only decimated local populations but also relocated native peoples from throughout north-central California to the San José area. The Costanoan/Ohlone were transformed from hunters and gatherers into agricultural laborers (and in some cases, craft artisans) who lived at the missions and worked with former neighboring Native American groups such as the Esselen, Yokuts, and Miwok (Levy, 1978:486).

With secularization of the missions by Mexico in 1834, most of the aboriginal population gradually moved to ranchos to work as manual laborers (Levy, 1978:486). During the Mexican Period several ranchos were granted to Native Americans. Rancho Ulistac, located on the west bank of the Guadalupe River in the City of Santa Clara, was granted to “emancipated” Mission Indians Marcello, Pio, and Cristobal in 1845 (Hendry and Bowman, 1940:872 873). Rancho Posolmi, located along the Guadalupe River at the northeastern boundary of the City of Mountain View, was granted to Lopez Indigo (or Yndigo) in 1881 (City of San Jose, 2011).

Contemporary descendants of the Costanoan (Ohlone) Native Americans are not members of federally recognized tribes. Ohlone recognition and assertion began to move to the forefront during the early twentieth century, enforced by legal suits brought against the United States government by Indians of California (1928–1964) for reparations due them for the loss of traditional lands. The Ohlone/Costanoan Muwekma Tribe, consisting of surviving Native American lineages who trace their ancestry through Missions Dolores, Santa Clara and San José. The State of California has recognized the validity of unrecognized tribal groups of local Native Americans and has afforded both the groups and Native American individuals status in regard to consultation for planning and CEQA compliance.

5.18.1.3. Regulatory Setting
State
California Environmental Quality Act. CEQA requires that impacts to TCRs be identified and, if impacts would be significant, that mitigation measures be implemented to reduce those impacts to the extent feasible (PRC §21081). In the protection and management of the cultural environment, both the statute and the CEQA Guidelines (14 California Code of Regulations §15000 et seq.) provide definitions and standards for management of TCRs.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.18. TRIBAL CULTURAL RESOURCES SEPTEMBER 2024 5.18-3 ADMINISTRATIVE DRAFT MND/IS
PRC Section 21074 defines a TCR as “a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe.” TCRs also include “non-unique archaeological resources” that may not be scientifically significant, but still hold sacred or cultural value to a consulting tribe.

A resource shall be considered significant if it is: (1) listed or eligible for listing in the California Register of Historical Resources (CRHR), or in a local register of historical resources as defined in PRC Section 5020.1(k); or “(2) a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1. In applying these criteria, the lead agency must consider the significance of the resource to a California Native American tribe.”
Therefore, a project may have substantial adverse change in the significance of a TCR if a project may cause a substantial adverse change in the significance of a tribal cultural resource (PRC §21084.2) or the resource is listed, or eligible for listing, in the CRHR or in a local register of historical resources, and it is demolished (CEQA Guidelines §15064.5(b)(2)).

The fact that a TCR is not listed in the CRHR, determined to be ineligible for listing in the CRHR, not included in a local register of historical resources, or is not identified in a historical resources survey does not preclude a lead agency from determining that the resource may be a historical resource.

CEQA Guidelines Section 15064.5(b)(1) explains that effects on historical resources (or TCRs, if so determined by the lead agency) would be considered adverse if it involves physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of the resource would be materially impaired. Adverse effects on historical resources may result in a project having a significant effect on the environment. CEQA Guidelines Section 15064.5(c)(3) requires that TCRs receive treatment under PRC Section 21083.2, which requires that these resources be preserved in place or left in an undisturbed state. If these treatments are not possible, then mitigation for significant effects is required, as outlined in PRC Section 21082.2(c).

5.18.1.4. Assembly Bill 52 Tribal Consultation
The proposed Project’s effects on potentially buried and therefore presently unidentified TCRs were evaluated using the significance criteria set forth in Appendix G of the CEQA Guidelines and with consideration to AB 52 and the Governor’s Office of Planning and Research’s “Technical Advisory: AB 52 and Tribal Cultural Resources in CEQA” (OPR, 2017).

Representatives of the Tamien Nation had previously requested to be contacted regarding projects within the City of Santa Clara. Two representatives of the Tamien Nation requesting to be contacted under AB 52 for possible tribal consultation were notified of the proposed Project and invited to engage in consultation.

The invitation was extended to each representative by registered mail (April 11, 2024). No responses were received to the emails or letters during the 30-day response period. This concluded AB 52 compliance under CEQA.

5.18.1.5. NAHC Sacred Lands File Search
Aspen requested a search of the NAHC’s Sacred Lands file to determine the presence or likelihood of encountering TCRs within the Project area. On March 27, 2024, the NAHC responded that the search was completed with negative results (i.e., no sacred sites are located within the Project area or surrounding vicinity).

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5.18.2. Environmental Impacts and Mitigation Measures
(a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? LESS THAN SIGNIFICANT WITH MITIGATION. There are no TCRs listed in, or are known to be eligible for listing in, the CRHR or local register of historical resources within the proposed Project area. Although there is no evidence that TCRs exist within the proposed Project site or immediate vicinity, it is possible that previously unidentified TCRs that may be eligible for inclusion in the NRHP, CRHR, or local registers could be discovered and damaged, or destroyed, during project-related ground disturbance, as both Project options involve ground disturbance. This would constitute a significant impact absent mitigation. Implementation of mitigation measure MM TCR-1 would evaluate and protect unanticipated TCR discoveries, thereby reducing this impact to a less than significant level after mitigation.

MM TCR-1 Management of Unanticipated Tribal Cultural Resources. During project construction, should subsurface tribal cultural resources be discovered, all activity in the vicinity of the find shall stop and a qualified archaeologist and an authorized tribal representative shall be contacted to assess the significance of the find according to CEQA Guidelines Section 15064.5 and Section 21074. If any find is determined to be significant, the archaeologist shall determine, in consultation with the implementing agency and any local Native American groups expressing interest, appropriate avoidance measures or other appropriate mitigation. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred means to avoid impacts to tribal cultural resources. Methods of avoidance may include, but shall not be limited to, Project reroute or redesign, , or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, such as data recovery or other appropriate measures, in consultation with the implementing agency and any local Native American representatives expressing interest in the tribal cultural resource. ii. a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe?
LESS THAN SIGNIFICANT WITH MITIGATION. No known TCRs were identified during a search of the NAHC’s Sacred Lands File, record search, or during ethnographic research. Nevertheless, it is possible that previously unidentified TCRs that may qualify as a significant resource according to lead agency determination could be discovered and damaged or destroyed during ground disturbance, as both Project options involve ground disturbance. Such a discovery or inadvertent damage/destruction to a previously unknown TCR would constitute a significant impact absent mitigation. Implementation of mitigation measure MM TCR-1, which is discussed under Item (a), would evaluate and protect unanticipated TCR discoveries, thereby reducing this impact to a less than significant level.

MM TCR-1 Management of Unanticipated Tribal Cultural Resources [see full text under Item (a) above]
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5.19. Utilities and Service Systems

UTILITIES AND SERVICE SYSTEMS
Would the project:

Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
(a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? ☐ ☐ ☒ ☐
(b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
☐ ☐ ☒ ☐
(c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
☐ ☐ ☒ ☐
(d) Generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
☐ ☐ ☒ ☐
(e) Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
☐ ☐ ☐ ☒
Significance criteria established by CEQA Guidelines, Appendix G.

5.19.1. Setting
Utility and services system facilities associated with electricity, domestic (potable) water, stormwater, solid waste, communications, and natural gas are provided and maintained by a variety of local purveyors, including cities, counties, special districts, water agencies, and private companies. Table 5.19-1 lists utility providers in the area.

Table 5.19-1. Utility Providers
Natural gas: Pacific Gas & Electric Company
Electricity: Silicon Valley Power
Water: City of San Francisco’s Hetch Hetchy aqueduct, Santa Clara Valley Water District, Santa Clara City-owned wells
Wastewater: San José‐Santa Clara Water Pollution Control Plant Telephone: AT&T, Comcast
Solid Waste: Mission Trail Waste Systems, Allied Waste, Green Waste Recovery, and Los Gatos Garbage Company
Source: City of Santa Clara, 2014

5.19.1.1. Utilities
Water Supply
Potable water for the City comes from a combination of sources: the City of San Francisco’s Hetch Hetchy aqueduct system, the Santa Clara Valley Water District, and groundwater from City‐owned wells.

Groundwater comprises almost 70 percent of the City’s water supply. Recycled wastewater is also used in the City for certain landscape irrigation, industrial, and construction purposes (City of Santa Clara, 2014).

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.19. UTILITIES AND SERVICE SYSTEMS SEPTEMBER 2024 5.19-2 ADMINISTRATIVE DRAFT MND/IS
Electricity and Natural Gas
Silicon Valley Power (SVP) is owned and operated by the City as a municipal electric utility and as a department of the City. SVP maintains approximately 383 miles of underground distribution lines, nearly 200 miles of overhead distribution lines and over 60 miles of transmission lines. Electricity for the City is provided from natural gas, wind, solar, geothermal, and hydroelectric generation resources in California and other western states (Silicon Valley Power, 2023).

The City’s natural gas is provided by Pacific Gas & Electric Company. Transmission mains deliver gas from basins in California, Canada, and the Western United States (City of Santa Clara, 2014).

5.19.1.2. Service Systems
Sewage/Wastewater
Sewer systems collect wastewater in the City and transport it via pipelines to the San Jose–Santa Clara Regional Wastewater Facility (RWF) in San Jose, CA. The RWF treats approximately 110 million gallons per day (mgd) of wastewater from cities in Santa Clara County and is able to treat up to 167 mgd. (City of San Jose, 2024).

About 10 percent of the total treated wastewater from the RWF is directed into the South Bay Water Recycling system. The treated wastewater is used for landscaping irrigation, dual plumbing, industrial uses, and other approved uses around the southern Bay Area. Recycled water distribution pipelines are located throughout the City. Treated wastewater that is not directed into the recycled water pipelines is discharged into San Francisco Bay (City of Santa Clara, 2014).

Solid Waste Disposal
Solid waste and recycling collection services in the City is primarily provided by four companies: Mission Trail Waste Systems, Allied Waste, Green Waste Recovery, and Los Gatos Garbage Company. Newby Island Sanitary Landfill is the main landfill that serves the City, although solid wastes are also sent to landfills outside of Santa Clara County (City of Santa Clara, 2014). Newby Island Sanitary Landfill is located at 1601 Dixon Landing Road, Milpitas, CA, approximately 5.5 miles north of the proposed Project. Guadalupe Sanitary Landfill is located in San Jose, and Corinda Los Trancos Landfill is located in Half Moon Bay, approximately 12 miles south and 27 miles northwest from the proposed Project, respectively.

Table 5.19-2 lists the capacities of landfills in or near the City of Santa Clara.

Table 5.19-2 Landfill Capacities
Landfill Name
Total Capacity
(cu.yd.)
Remaining
Capacity
(cu.yd.)
Remaining
Capacity
(percent)
Maximum
Throughput
(tons/day)
Newby Island Sanitary Landfill
(Cease operation estimated 2041)
57,500,000 16,400,000 28.5 4,000
Guadalupe Sanitary Landfill
(Cease operation estimated 2043)
28,238,855 7,518,220 26.6 3,650
Corinda Los Trancos Landfill
(Cease operation estimated 2034)
60,500,000 22,180,000 36.7 3,598
Sources: CalRecycle, 2024a; CalRecycle, 2024b; CalRecycle, 2024c NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.19. UTILITIES AND SERVICE SYSTEMS SEPTEMBER 2024 5.19-3 ADMINISTRATIVE DRAFT MND/IS
Regulatory Background
This section includes a description of the utilities and public service systems regulatory framework.

Federal
Clean Water Act Section 402: National Pollutant Discharge Elimination System. Section 202 of the Clean Water Act (CWA) establishes the National Pollutant Discharge Elimination System (NPDES) permit program to regulate point source discharges of pollutants to Waters of the United States. Discharges or construction activities that disturb one or more acres, which includes the proposed Project, are regulated under the NPDES stormwater program and are required to obtain coverage permit under a NPDES Construction General Permit. The Construction General Permit establishes limits and other requirements such as the implementation of a Stormwater Pollution Prevention Plan, which would further specify best management practices to avoid or eliminate pollution discharge into the nation’s waters. The State Water Resources Control Board (SWRCB) issues both general and individual permits under this program. The SWRCB delegates much of its NPDES authority to nine regional water quality control boards. The proposed Project’s NPDES permits would be under jurisdiction of Region 2, the San Francisco Regional Water Quality Control Board.

State
California Government Code – Protection of Underground Infrastructure. The responsibilities of California utility operators working in the vicinity of utilities are detailed in Section 1, Chapter 3.1, “Protection of Underground Infrastructure” (Article 2 of California Government Code §§4216-4216.9). This law requires that an excavator must contact a regional notification center at least two days prior to excavation of any subsurface installation. Any utility provider seeking to begin a project that may damage underground infrastructure can call Underground Service Alert, the regional notification center. Underground Service Alert will notify the utilities that may have buried lines within 1,000 feet of the project. Representatives of the utilities are required to mark the specific location of their facilities within the work area prior to the start of project activities in the area. The code also requires excavators to probe and expose underground facilities by hand prior to using power equipment.

California Integrated Waste Management Act of 1989. Assembly Bill 939 codified the California Integrated Waste Management Act of 1989 in the Public Resources Code and established a hierarchy to help the California Integrated Waste Management Board (CIWMB) and local agencies implement three major priorities under the Integrated Waste Management Act: source reductions; recycling and composting; and environmentally safe transformation and land disposal. Waste diversion mandates are included under these priorities. The duties and responsibilities of the CIWMB have since been transferred to the California Department of Resources Recycling and Recovery (CalRecycle) after the abolishment of the CIWMB in 2010, but all other aspects of the Act remain unchanged.

The Act requires all local and county governments to adopt a waste reduction measure designed to manage and reduce the amount of solid waste sent to landfills. This Act established reduction goals of 25 percent by the year 1995 and 50 percent by the year 2000. Senate Bill 1016 (2007) streamlines the process of goal measurement related to Assembly Bill 939 by using a disposal-based indicator: the per capita disposal rate. The per capita disposal rate uses two factors: the jurisdiction’s population (employment can be considered in place of population in certain circumstances) and the jurisdiction’s disposal as reported by disposal facilities. CalRecycle encourages reduction measures through the continued implementation of reduction measures, legislation, infrastructure, and support of local requirements for new developments to include areas for waste disposal and recycling on-site.

California Code of Regulations (Title 27). Title 27 (Environmental Protection) of the California Code of Regulations defines regulations and minimum standards for the treatment, storage, processing, and NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.19. UTILITIES AND SERVICE SYSTEMS SEPTEMBER 2024 5.19-4 ADMINISTRATIVE DRAFT MND/IS
disposal of solid waste at disposal sites. The State Water Resources Control Board maintains and regulates compliance with Title 27 (Environmental Protection) of the California Code of Regulations by establishing waste and site classifications and waste management requirements for solid waste treatment, storage, or disposal in landfills, surface impoundments, waste piles, and land treatment units. The compliance of the proposed Project would be enforced by the San Francisco RWQCB Region 2 and the California Department of Resources Recycling and Recovery (CalRecycle) (formerly the California Integrated Waste Management Board). Compost facilities are regulated under CCR Title 14, Division 7, Chapter 3.1 Section 17850 through 17895, by CalRecycle. Permit requests, Reports of Waste Discharge, and Reports and Disposal Site Information are submitted to the RWQCB and CalRecycle, and are used by the two agencies to review, permit, and monitor these facilities.

Local
Energy Policies. The purpose of the City’s energy policies is to encourage reduced energy use. The following policies in the General Plan generally relate to the proposed Project (City of Santa Clara, 2014):
 Policy 5.10.3‐P10. Maintain the City’s level of service for high quality utilities and telecommunications infrastructure.
 Policy 5.10.3‐P12. Work with SVP to implement adequate energy distribution facilities to meet the demand generated by new development.

Water Policies. The purpose of the City’s water policies is to off-set increased demand associated with the implementation of the City General Plan. The following policies in the General Plan generally relate to the proposed Project (City of Santa Clara, 2014):
 Policy 5.10.4‐P10. Work with Santa Clara Valley Water District to minimize undesirable compaction of aquifers and subsidence of soils.

5.19.2. Environmental Impacts and Mitigation Measures
(a) Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
LESS THAN SIGNIFICANT. Under Option 1, the entire proposed Project would be built Overhead. Under Option 2, the northern 0.74 miles of the proposed Project would be placed underground. For both Options, the proposed Project would involve construction of a new 115 kV transmission line that will be built to 230 kV standards, and underbuilding existing transmission/distribution lines on the new transmission structures for the southern segment of the Project.

Water, Wastewater Treatment or Storm Water Facilities. Construction of the proposed Project would generate minimal demand for water or wastewater treatment. A water truck or hose may be on-site to support dust suppression during ground disturbing work. Any water used for dust control would be dispersed onsite and would either evaporate or be absorbed into the ground; therefore, no wastewater generation is anticipated from this use.

Concrete would be required for pole foundations and any vaults and underground conduits for lines underground. Excess concrete from construction as well as removed concrete foundations of poles no longer needed would be disposed of at an approved site away from the work area. Dewatering may be necessary if groundwater is encountered. Portable toilets would be provided for construction work crews and would be removed after construction is completed. These toilets will be maintained by a licensed sanitation contractor.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.19. UTILITIES AND SERVICE SYSTEMS SEPTEMBER 2024 5.19-5 ADMINISTRATIVE DRAFT MND/IS
The proposed Project would not result in any increased stormwater flow entering stormwater drainage systems and therefore would not require, or result in the construction of, new stormwater drainage facilities or the expansion of existing facilities.

Upon completion of construction, the proposed Project would not generate any demand for water or wastewater treatment. There would be no sanitary sewer hookup as part of the Project. Existing wastewater and water treatment facilities are adequate to accommodate the demand generated by the proposed Project during construction. Thus, the Project would have less than significant impact that would not cause the need for the construction or expansion of water or wastewater treatment facilities or storm water drainage.

Electric Power, Natural Gas, or Telecommunications Facilities. No new natural gas or telecommunications facilities would be required in support of the Project. Construction of the proposed Project would have the potential to disrupt existing underground utility systems or cause a collocation accident.

Coordination with other utility system owners and compliance with California Government Code §§4216– 4216.9 would reduce the likelihood of accidental disruptions from a collocation accident. Prior to initiating underground construction, including drilling for structure footings, SVP or its contractor would contact Underground Service Alert to identify any existing underground utilities in the construction zone.

Option 1 would not require the expansion or development of new utility systems. However, it would require minor modifications to some existing electric power and distribution lines and substations. Portions of the 115 kV line would have existing 60 kV circuits underbuilt on the new transmission line. Construction for Option 1 would include minimal utility relocation work at three locations. During routine operation and maintenance of the proposed Project, SVP’s new transmission line would be unstaffed and would not create any need for new or expanded utilities or service systems.

Option 2 would require underground construction and would need to cross existing utilities owned by PG&E, SVP, and the City, numerous times. These utilities range from communication, electric, natural gas, and water lines, as well as sanitary sewers and a storm drain. Due to these conflicts, the transmission line would need to be buried approximately 20 feet deep in some areas.

There are 25 existing underground utilities in the corridor where the line would be underground. These include gas, sewer, storm, water, and electric lines. Option 2 would require the relocation of approximately 300 feet of two existing transmission natural gas lines, owned by SVP and PG&E, to facilitate the installation of two underground vaults for the Project. The SVP-owned transmission natural gas line is a high-pressure gas line for the Donald Von Raesfeld Power Plant (DVR). The relocation of this line would require a full shutdown of DVR and would need to be coordinated to occur during off-peak times of the year, November through March. It is unknown when the PG&E transmission natural gas line could be relocated. SVP would coordinate with PG&E to schedule the relocation work.

During routine operation and maintenance of the proposed Project, under either option, SVP’s new transmission line would be unstaffed and would not create any need for new or expanded utilities or service systems. While the relocation of some utilities would create impacts, these would be similar to routine installation of utilities and be of limited extent. Any relocation work would be required to comply with applicable ordinances, standards, and best practice requirements. Therefore, impacts would be less than significant.
(b) Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? LESS THAN SIGNIFICANT. Water would be used for the proposed Project primarily for the concrete pier foundations for the tubular steel poles. For an approximate foundation size of 8 feet in diameter and 35 feet deep, about 1,785 cubic feet of water would be required at each foundation. For Option 1, it is estimated that there would be approximately 40 poles. Option 2 would require approximately 32 poles but would NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.19. UTILITIES AND SERVICE SYSTEMS SEPTEMBER 2024 5.19-6 ADMINISTRATIVE DRAFT MND/IS
also require concrete for underground duct banks and vaults. This water demand would be a one-time need.

Water may also be used for dust suppression, if necessary, during the 14-month construction timeframe (for Option 1 only), although this would be a limited need. The volume of water required for dust control is not known. However, the amount of water for dust suppression during construction is considered to be nominal in comparison to available municipal water supply, and water use for construction would be periodic and temporary during the construction period.

Water trucks or hydrants would provide water for these activities as needed. Upon completion, the proposed Project would not generate any demand for water. Therefore, the proposed Project would have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years.
(c) Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
LESS THAN SIGNIFICANT. The proposed Project would generate minimal wastewater during construction.

Foundation drilling slurry for the installation of the tubular steel poles would be disposed of at an approved site away from the work area. The proposed Project would also require portable toilets for construction workers and the waste would be disposed of at appropriately licensed official facilities with adequate capacity. As discussed in Item (b) above, existing wastewater facilities would adequately accommodate the minor demand caused by Project construction while serving existing commitments. Therefore, this impact would be less than significant.
(d) Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? LESS THAN SIGNIFICANT. Construction debris and waste generated during construction of the Project would be transported to staging areas for temporary storage or directly to a facility for recycling or disposal.

Existing wood poles removed as part of the Project would be moved to an area service center or staging area collection bin for transport with other materials for disposal at a licensed Class I or Class II landfill or a composite lined portion of a solid waste landfill. Total solid waste generated by construction of the proposed Project is anticipated to be minor compared to the capacity of local existing landfills, as identified in Table 5.19-2, Landfill Capacities. The landfills identified in Table 5.19-2 are not expected to close for about another 20 years. During operation, the proposed Project would not be staffed and would not generate notable quantities of solid waste. Therefore, the impact of solid waste disposal on local infrastructure and landfill capacity would be less than significant. (e) Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
NO IMPACT. The California Integrated Waste Management Act of 1989, which emphasizes resource conservation through the reduction, recycling, and reuse of solid waste guide solid waste management requires that localities conduct a Solid Waste Generation Study (SWGS) and develop a Source Reduction Recycling Element (SRRE). The proposed Project would operate in accordance with these applicable Solid Waste Management Policy Plans by recycling materials where feasible. As identified in Table 5.19-2, Landfill Capacities, the landfills serving the site would have sufficient capacity to accommodate Project construction solid waste disposal needs, and Project solid waste disposal would not result in the need for new or expanded landfill facilities. Therefore, the proposed Project would comply with federal, State, and local management and reduction statutes and regulations related to solid waste disposal limits and landfill capacities. No impact would occur.

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5.20. Wildfire

WILDFIRE
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:

Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
(a) Substantially impair an adopted emergency response plan or emergency evacuation plan? ☐ ☒ ☐ ☐
(b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? ☐ ☐ ☒ ☐
(c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
☐ ☐ ☒ ☐
(d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
☐ ☐ ☒ ☐
Significance criteria established by CEQA Guidelines, Appendix G.

5.20.1. Setting
Wildland fire protection in California is the responsibility of the State, local, or federal government, depending on the location. The California Department of Forestry and Fire Protection (CAL FIRE) is required by law to map areas of significant fire hazards based on fuels, terrain, weather, and other relevant factors.

These zones, which are referred to as Fire Hazard Severity Zones (FHSZ), influence how people construct buildings and protect property to reduce risk associated with wildland fires. FHSZ maps identify the likelihood that an area will burn over a 30 to 50-year period without considering that modifications may occur, such as fuel reduction efforts. Risk is not indicated by the maps. Risk is the potential damage that can be done by a fire, based on existing conditions. Risk can be reduced by various strategies, such as creation of defensible space, fuel load reduction, and, in the case of structures, the use of sprinklers and ignition-resistant building materials and construction. The City of Santa Clara is not located in a FHSZ in the CAL FIRE wildland fire hazard maps, primarily due to its urban conditions, flat terrain, and low fuel load (CAL FIRE, 2007). Fire protection within the City is discussed in Section 5.15 (Public Services).

Regulatory Background
Federal
A variety of transmission line and tower clearance standards are used throughout the electric transmission industry. Nationally, most transmission line owners follow the National Electric Safety Code (NESC) rules or ANSI guidelines, or both, when managing vegetation around transmission system equipment. The NESC deals with electric safety rules, including transmission wire clearance standards, whereas the applicable ANSI code deals with the practice of pruning and removing vegetation.

State and Local
California Public Utilities Commission (CPUC) General Order (GO) 95. CPUC’s GO 95 is the key standard governing the design, construction, operation, and maintenance of overhead electric lines in the State.

The CPUC has promulgated various Rules to implement the fire safety requirements of GO 95, including:
 GO 95 Rule 31.2 requires that lines be inspected frequently and thoroughly to ensure that they are in good condition, and that lines temporarily out of service be inspected and maintained in such condition so as not to create a hazard.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.20. WILDFIRE SEPTEMBER 2024 5.20-2 ADMINISTRATIVE DRAFT MND/IS
 GO 95 Rule 35 governs requirements that vegetation management activities be performed in order to establish necessary and reasonable clearances.
 GO 95 Rule 38 establishes minimum vertical, horizontal, and radial clearances of wires from other wires.

California Public Resources Code Sections 4294 and 4293. The California Public Resources Code (CPRC) Sections 4292 and 4293 specify requirements related to fire protection and prevention in transmission line corridors. CPRC Section 4292 states that any person that owns, controls, operates, or maintains any electrical transmission or distribution line has primary responsibility for fire protection of such areas, and shall maintain around and adjacent to any pole or tower which supports a switch, fuse, transformer, lightning arrester, line junction, or dead end or corner pole, a firebreak which consists of a clearing of not less than 10 feet in each direction from the outer circumference of such a pole or tower (CPRC 4292).

Power Line Fire Prevention Field Guide 2008 Edition. CAL FIRE, the state’s three investor-owned utilities (Pacific Gas and Electric [PG&E] Company, Southern California Edison Company, and San Diego Gas and Electric), and other California electric utilities have mutually developed a comprehensive field guide for their personnel. Its purpose is “to provide information and guidance to the personnel of the fire service agencies and electrical operators for minimum uniform application within the areas of their respective jurisdiction and franchise responsibilities.” In addition to safety of the public, the guide details fire hazard reduction maintenance procedures for the safety of conductors and certain hardware.

PG&E's Public Safety Power Shutoff Program. The Public Safety Power Shutoff program was developed in cooperation with state utility regulators at the CPUC. A utility shuts off electricity on transmission and distribution lines in fire-prone areas during high fire-risk periods, including:
 Red flag warning declared by the National Weather Service;  Low humidity levels – generally 20% and below; and/or  Forecasted sustained winds generally above 25 mph and wind gusts in excess of approximately 45 mph.

SVP operates and maintains the distribution and transmission grid inside the City, yet the larger transmission grid that brings most of SVP’s energy into the City is integrated throughout the State. Therefore, if large transmission lines are de-energized or constrained, then SVP may need to reduce load quickly to help the greater transmission grid. Depending on the severity of the event, it may mean power shutoffs or rolling outages in the City.

5.20.2. Environmental Impacts and Mitigation Measures
(a) Would the project substantially impair an adopted emergency response plan or emergency evacuation plan? LESS THAN SIGNIFICANT WITH MITIGATION- CONSTRUCTION. The City of Santa Clara does not have an adopted emergency response plan or an emergency evacuation plan. The Project does not cross over or is not near any roads in a very high FHSZ nor would it require complete road closures. As stated in Section 5.17, Transportation, the Project may require brief temporary lane closures/disruptions, however, at least one lane of travel through each construction area would remain open throughout the construction period to accommodate roadway users (including emergency vehicles). During temporary lane closures, SVP would implement traffic control protocols and a project-specific traffic plan under Mitigation Measure T-1 (Construction Traffic Control Plan) to accommodate traffic flow. There is no other aspect of the Proposed Project, aside from traffic flow, that could impair an emergency response effort. Therefore, with incorporation of mitigation, impacts from Project construction would not substantially impact emergency response or evacuation plans.

NO IMPACT – OPERATIONS AND MAINTENANCE. Once operational, the proposed Project would have minimal impact on emergency response or evacuation. Occasional maintenance activities would be of short duration throughout the project area. While temporary lane closures are not anticipated, maintenance NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.20. WILDFIRE SEPTEMBER 2024 5.20-3 ADMINISTRATIVE DRAFT MND/IS
vehicles or equipment may be temporarily present alongside the roadways depending on structure locations and maintenance activities. However, at least one lane of travel would remain open at all times and any closure or disruption would be of limited duration (likely less than one day).

Option 1 would have a shorter duration of maintenance compared to Option 2, because overhead lines are easier to access. Additionally, Option 1 would have a shorter downtime in the event of a power outage or emergency, due to the visibility and accessibility of the line. However, the maintenance for both options would be of short duration and would be temporary. Therefore, maintenance of the proposed Project would not substantially impair an emergency response plan or emergency evacuation plan.

Mitigation Measures for Emergency Response
MM T-1 Construction Traffic Control Plan. [see full text in Section 5.17, Transportation] (b) Would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
LESS THAN SIGNIFICANT - CONSTRUCTION. The project would not result in any occupied facilities and the City area is not located in a FHSZ as shown on CAL FIRE wildland fire hazard maps (CAL FIRE, 2007). However, there are residences in the Project vicinity located on Lafayette Street near the proposed transmission line route. Therefore, the following analysis focuses on the potential for Project construction and operation to increase the exposure of residences to wildfire risks.

During construction, Project-related activities have the potential to be a fire ignition source. Examples of ignition sources include improperly discarded smoking materials or sparks from welding or from metal striking metal or stone, igniting surrounding vegetation or other flammable materials. To reduce fire risk, SVP would implement standard fire prevention protocols. In addition, the proposed Project is located in a flat, urban environment without extensive easily ignited vegetation, and construction activities would occur over a limited duration (14 months for Option 1). Impacts from wildfire risk during construction would be less than significant and no mitigation is required.

LESS THAN SIGNIFICANT – OPERATIONS AND MAINTENANCE. Electrical lines can start a fire if an object such as a tree limb, kite, or mylar balloon simultaneously contacts the power line conductors and a second object, such as the ground or a portion of the supporting pole or tower. System component failures and accidents during maintenance activities can also cause line faults that result in arcing on power lines. Power lines are also subject to conductor-to-conductor contact, which can occur when extremely high winds force two conductors to oscillate so excessively that they contact one another. This contact can result in arcing (sparks) that could ignite nearby vegetation. Aging, failing equipment increases the risk of system failures and faults.

The Project would update and install new electrical line equipment, reducing the risk of a system failure or line fault due to aging equipment. While the proposed Project would result in additional overhead electrical lines, the increase in risk of ignition associated with the additional line would be minimal relative to baseline conditions and the Project is not located in an area of high wildfire risk. Operation and maintenance activities would be incorporated into SVP’s existing O&M schedule for its existing transmission lines, substations, and associated facilities. As with current operations and maintenance, SVP would comply with all current federal and State laws related to vegetation clearance and fire prevention, reducing wildfire risks. Impacts from wildfire risk during operations and maintenance would be less than significant and no mitigation is required.

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(c) Would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? LESS THAN SIGNIFICANT. The proposed Project includes construction of a new transmission line. Most activities associated with the proposed Project would occur along existing transmission line ROWs in an urban area and would rely primarily on existing paved roads for access. No fuel breaks or emergency water sources would be required. None of the new transmission lines would be within a wildfire risk area.

Operation and maintenance activities would be incorporated into SVP’s existing O&M schedule for its existing transmission lines, substations, and associated facilities. As with current operations and maintenance, SVP would comply with all current federal and State laws related to vegetation clearance and fire prevention. No additional infrastructure that has not been considered would be installed, and no additional fire risk impacts would occur because of operating and maintaining the Project. (d) Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? LESS THAN SIGNIFICANT. The Project would not create occupied structures and thus could not expose residents to increased fire risk. The proposed Project is situated in an urban area with flat topography and low fuel load. During construction, there would be ground disturbance at the pole structure locations and, if sections of the line are buried, along the trench. The proposed Project would use up to two staging areas, each approximately one acre, in areas that are already disturbed. As with current operations and maintenance, SVP would comply with all current regulations related to vegetation clearance and fire prevention. Given the low fire risk in a flat area with no known historic landslides or slope instability and the limited amount of surface disturbance proposed, the exposure of people or structures to risks as a result of runoff, post fire slope instability, or drainage changes would be less than significant.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.21. CORONA AND INDUCED CURRENT EFFECTS SEPTEMBER 2024 5.21-1 ADMINISTRATIVE DRAFT MND/IS

5.21. Corona and Induced Current Effects

5.21.1. Environmental Setting

5.21.1.1. Corona
Corona is one of the phenomena associated with all energized electrical devices, including high voltage transmission lines. The localized electric field near a conductor can be sufficiently concentrated to ionize air close to the conductors. This can result in a partial discharge of electrical energy called a corona discharge, or corona. The corona effect is the physical manifestation of discharged electrical energy into very small amounts of sound, radio noise, heat, and chemical reactions with air components. It is a phenomenon associated with all energized electrical devices but is especially common with high-voltage power lines.

The amount of corona produced by a power line is a function of several factors, including line voltage, conductor diameter, conductor locations in relation to each other, condition of conductors and hardware, and local weather conditions including power line elevation above sea level. Corona typically becomes a design concern for 230 kV and higher power lines that are overhead (i.e., transmission lines on poles or towers). It is less noticeable for lines that are operated at lower voltages (i.e., subtransmission and distributionsized lines). The electric field gradient is greatest at the conductor surface. Larger-diameter conductors have lower electric field gradients at the conductor surface and, therefore, lower corona noise than smallerdiameter conductors. The corona effect would not be a design concern for underground portions of power lines, regardless of voltage level, because the energized conductors are fully enclosed in a semi-conducting layer within insulated cables that serve to equalize the electrical gradient at the surface of the components.

5.21.1.2. Induced Currents
Electric currents can be induced in metallic objects located within the electric fields created by power lines. An electric current can flow when an object has an induced charge and a path to ground is present.

The amount of induced current that can flow is important to evaluate from a safety perspective because of the potential for electrical shocks to people and the possibility of electric arcs that could form across small gaps between conductive surfaces. These arcs can have the secondary effect of igniting flammable materials in the vicinity of the arc. In addition, induced currents are evaluated for their potential to lead to corrosion of metallic objects from the discharge of the induced current to ground.

From a safety perspective, the National Electrical Safety Code (NESC) specifies that transmission lines be designed to limit short circuit current from vehicles or large objects near the line to no more than 5 milliampere (mA). The NESC also addresses shock hazards to the public by providing guidelines on minimum clearances to be maintained for practical safeguarding of persons during the installation, operation, or maintenance of overhead transmission lines and their associated equipment.

5.21.2. Environmental Impacts and Assessment
Concerns about project interference with existing businesses and future development in the area were raised during scoping. The CEQA Guidelines do not provide significance criteria for evaluating impacts from corona or induced current effects. Corona and induced current from high voltage power lines can cause environmental impacts through:
 Audible noise
 Radio and television interference
 Computer interference
 Disturbance of cardiac pacemakers
 Ignition of flammable materials
 Corrosion of buried metallic objects
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The proposed Project involves construction of a new 115 kV transmission line, relocation of existing distribution power lines and/or telecommunication lines along some segments of the new 115 kV transmission line, and minor modifications at two existing substations affected by the Project. The audible corona noise level caused by the 115 kV power line was not quantified. However, circuits operating at 115 kV typically cause noise at levels comparable to the ambient baseline noise levelsin the vicinity of the line. Although the Proposed Project would be constructed to accommodate a 230 kV line, it would be operated at 115 kV.

If, in the future, the line was to be upgraded to 230 kV, corona may become a concern. The applicant has proposed to install corona rings on all insulators to prevent future corona impacts. Therefore, the impact of audible noise from the corona effect would be less than significant.

Although corona can generate high frequency energy that may interfere with broadcast signals or electronic equipment, this is generally not a problem for transmission or lower voltage power lines. The Institute of Electrical and Electronic Engineers (IEEE) has published a design guide (IEEE, 1971) that is used to limit conductor surface gradients so as to avoid corona levels that would cause electronic interference. Corona or gap discharges related to high frequency radio and television interference impacts are dependent upon several factors, including the strength of broadcast signals, and are anticipated to be very localized if they occur. Individual sources of adverse radio/television interference impacts can be located and corrected on the power lines. Conversely, magnetic field interference with electronic equipment such as computer monitors can be corrected through the use of software, shielding or changes at the monitor location. As a result, impactsfrom corona, radio/television interference, and magnetic field interference would be less than significant.

Induced currents and voltages on conducting objects near the proposed power lines would not pose a threat in the environment if the conducting objects are properly grounded. Project construction and operation would be done in accordance with SVP’s existing inspection and maintenance program and safety practices. Likewise, induced currents would not increase the risk of fuel ignition in the area.

The electric fields associated with high voltage transmission lines may be of sufficient magnitude to impact operation of a few older model pacemakers resulting in them reverting to an asynchronous pacing (IEEE, 1979). Substantial adverse effects would not occur with prolonged asynchronous pacing; periods of operation in this mode are commonly induced by cardiologists to check pacemaker performance. Therefore, while the transmission line’s electric field may impact operation of some older model pacemakers, the result of the interference would be of short duration and is not considered significant or harmful. No mitigation measures would be required or recommended.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.22. MANDATORY FINDINGS OF SIGNIFICANCE SEPTEMBER 2024 5.22-1 ADMINISTRATIVE DRAFT MND/IS

5.22. Mandatory Findings of Significance

MANDATORY FINDINGS OF SIGNIFICANCE
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
(a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?
☐ ☒ ☐ ☐
(b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.)
☐ ☒ ☐ ☐
(c) Does the project have environmental effects that would cause substantial adverse effects on human beings, either directly or indirectly?
☐ ☒ ☐ ☐
Significance criteria established by CEQA Guidelines, Appendix G. (a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory? LESS THAN SIGNIFICANT WITH MITIGATION. The proposed Project would be in a highly urbanized area of the City. Project components would be within existing substations in existing roads, or within or adjacent to the public right-of-way. Little vegetation would be affected. Some trees may be removed to accommodate poles and conductors, and other trees would be trimmed. Adjacent properties along the Project include maintained landscaping consisting of trees, shrubs, and grass. As described in Section 5.4, Biological Resources, there are no special-status plants or animals in the Project area due to the lack of habitat in such a highly urbanized environment. The Project is not expected to result in impacts to habitats that support sensitive species. However, some special-status birds may use the Project vicinity for foraging, although the habitat is marginal and the potential for occurrence of these species is very low. - Implementation of mitigation measures MM BIO-1 through MM BIO-5 would reduce these potential impacts to less than significant levels.

Similarly, Section 5.5 (Cultural Resources) and Section 5.18 (Tribal Cultural Resources) show that the Project would have a less than significant impact to important examples of the major periods of California history or prehistory. The records search indicates that no prehistoric cultural resources have been previously identified in the project area. However, as described in Section 5.5 (Cultural Resources) and Section 5.18 (Tribal Cultural Resources), the proposed Project could have an adverse effect on previously undiscovered cultural or tribal cultural resources. With implementation of mitigation measures MM CR1, MM CR-2, and MM TCR-1 for unanticipated discoveries of archaeological and historical resources or human remains- and mitigation measures MM G-2 for paleontological resources, impacts would be less than significant, and the Project would not eliminate important examples of major periods of California history or prehistory.

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(b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, effects of other current projects, and the effects of probable future projects.)
LESS THAN SIGNIFICANT WITH MITIGATION. CEQA defines a cumulative impact as an effect that is created as a result of the combination of the proposed Project together with other projects (past, present, or future) causing related impacts. Cumulative impacts of a project need to be evaluated when the project’s incremental effect is cumulatively considerable and, therefore, potentially significant. The proposed Project is planned for construction from November 2026 through March 2028. Once constructed, the Project would have little to no environmental impacts except for maintenance.

Two projects identified from the Planning Department’s current project list are within 0.25 miles of the proposed Project. The projects are in the application stage and were reviewed to identify whether the NRS-KRS project could contribute to cumulatively significant impacts when evaluated in combination with these projects. The projects are:
 4220 Network Circle – Involving demolition of existing structures and redevelopment of a 38-acre site near Lafayette Street and Montague Expressway with 584 housing units, open space, and parking.

Status as of May 2024: Pending Review.
 960 Central Expressway – Involving demolition of existing warehousing and loading docks and construction of three buildings for warehousing and/or datacenter uses. Status as of May 2024: Pending Review.

As discussed in Sections 5.1 through 5.21 potential impacts of the proposed Project would occur during construction, with few, if any, operational effects. Because the construction-related impacts of the Project would be temporary and localized, they would have the potential to combine with similar impacts of other projects only if they occur at the same time and in close proximity. The cumulative temporary and localized impacts of the construction of the proposed Project are considered by issue area below. The potential construction period for the two identified projects is unknown, as they have not yet undergone review and approval. Also, actual construction initiation and duration often varies from what is initially anticipated as a result of unforeseen circumstances including market conditions and availability of financing among others. In the future, applications may be submitted for other unknown projects in the vicinity of the Project and may overlap with the Project construction period. Because the area is built out, any projects would be reconstruction or construction of replacement land uses on already occupied sites.

Given the built-out nature of the Project vicinity and the capacity of existing thoroughfares, there would be no post-construction impacts from the proposed Project that would have the potential to combine with impacts from the projects listed.

The 4220 Network Circle application was filed in March 2024. To date, no hearings have been scheduled and CEQA review has not begun. If construction of the Network Circle proposed project were to coincide with that of the proposed NRS-KRS Project, both projects would use 4-lane Layette Street and 6-lane Montague Expressway for access to work areas. The Network Circle project site is close to Montague Expressway and construction related traffic using the Expressway to Lafayette Street would be on Lafayette Street for 500 feet from the west bound Expressway exit and 1,000 feet from the east bound exit. Thereafter, traffic would be within the project site on the former Agnew State Hospital property.

Construction traffic could also access the work site using Lafayette Street from the north. Construction of the NRS-KRS transmission line Project would be on Lafayette Street in the vicinity of the Network Circle project, and would be relatively short term – requiring installation of pole foundations approximately 350 feet apart, installation of tubular steel transmission poles, and stringing of conductor.

For the 960 Central Expressway project, the Notice of Preparation of an EIR and of a scoping meeting was published in December 2021. To date, the EIR has not been prepared. The Central Expressway proposed NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.22. MANDATORY FINDINGS OF SIGNIFICANCE SEPTEMBER 2024 5.22-3 ADMINISTRATIVE DRAFT MND/IS
project is proposed at the southwest corner of the intersection of Central Expressway and Lafayette Street, south of KRS. It is expected that construction related traffic for the Central Expressway project would be primarily on Central Expressway with some traffic on Lafayette Street. The NRS-KRS Project would enter KRS north of the Expressway with most of the Project south of Highway 101 within SVP property. It is unknown if the projects would overlap during construction.

Aesthetics. Potential views of the proposed Project are limited by the existing structures, walls, and vegetation along the alignment. NRS and KRS are behind screening walls and set back from nearby roads.

These facilities are already visual elements of the local urban setting and viewscape, and the continued urbanization of the area is the likely trend for the foreseeable future with little change in its overall visual character. The impacts from the construction of the Project would be minimal because the work would be temporary in nature. The proposed Project represents only a relatively minor incremental change in cumulative conditions given the urban nature of the location and the presence of existing features similar to the proposed Project. Therefore, the Project’s visual effects are less than significant and are not considerable enough to represent a significant cumulative impact.

Agriculture and Forestry Resources. There is no agricultural activity at the site or any of the cumulative project sites. The Project would not contribute to cumulative impacts to agriculture and forestry resources.

Air Quality. Air emissions would occur during construction of the proposed Project. Emissions would include criteria air pollutants that could contribute to existing or projected violations of the ambient air quality standards for ozone and PM10. Other pollutants resulting from construction activities are accounted for in emissions inventories for regional air quality maintenance plans and would not impede attainment or maintenance of ambient air quality standards. Foundation excavation and other construction-related activities could potentially expose sensitive receptors to construction-related emissions, including emissions of fugitive dust and DPM, which could expose the receptors to increased health risk and hazards. These would occur only during construction and would be less than significant with implementation of mitigation measure MM AQ-1 (Implement Basic Construction Air Quality Mitigation). Any potential adverse cumulative air quality impacts would be short-term (lasting for the duration of construction) and would not be cumulatively considerable; therefore, the cumulative impact would be less than significant. The operation and maintenance emissions (e.g., limited vehicle use) would be less than the emissions during construction activities and also less than the significance thresholds.

Concurrent construction of other projects in close proximity to the proposed Project would result in increased local air quality impacts for the duration of simultaneous construction activities. However, simultaneous construction projects would also need to comply with BAAQMD rules and regulations regarding criteria pollutants. Any potential adverse cumulative air quality impacts would be short-term (lasting for the duration of construction) and would not be cumulatively considerable; therefore, the cumulative impact would be less than significant.

Biological Resources. The proposed Project and the cumulative projects are located within an urbanized area and near busy roadways. The proposed Project area contains no habitat for special-status plant species and limited habitat suitable for most special-status wildlife species unless they are adapted to urban environments. However, if present within or adjacent to the proposed Project area, the proposed Project could result in direct or indirect impacts to special-status wildlife species. These impacts would be avoided or minimized with the implementation of Mitigation Measures (MMs) BIO-1 through BIO-5.

As described in Section 4 Project Description and in Appendix D, some vegetation and tree removal or tree trimming may be required for pole installation and vehicle access and to minimize the risk of fire by providing clearance between conductors and trees. Implementation of MM BIO-6 will ensure the proposed Project complies with the local policies and ordinances by following the tree protection requirements and recommendations of the City arborist.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.22. MANDATORY FINDINGS OF SIGNIFICANCE SEPTEMBER 2024 5.22-4 ADMINISTRATIVE DRAFT MND/IS
The Project would not represent a significant contribution to cumulative impacts. Given the built-up nature of the City, other cumulative projects in the vicinity have limited biological resources. Impacts to biological resources during operation and maintenance of the NRS-KRS Project would be less than significant, therefore, no contribution to cumulative impacts would occur.

Cultural Resources. There are no known historical or unique archaeological resources identified within the proposed Project area; however, previously unknown buried historical resources or human remains could be discovered and damaged, or destroyed, during ground disturbing work. Short-term construction activities and operation and maintenance activities would not significantly affect any unknown cultural or paleontological resources or human remains with the implementation of mitigation measures MM CR-1 (Worker Training and Management of Unanticipated Discoveries of Historical Resources, Unique Archaeological Resources) and MM CR-2 (Treatment of Human Remains), as discussed in Section 5.5, Cultural Resources. No cultural resources would be affected during Project construction or during operation of the Project, and no contribution to cumulative impacts would occur.

Energy. Construction activities would consume nonrenewable energy resources to power construction equipment and vehicles. The short-term use of fuels by equipment and motor vehicle trips during construction would be necessary to install the transmission line. The energy used by the Project during construction and operation would not be wasteful, inefficient, or unnecessary considering the new facilities that would increase system reliability and power deliverability. The proposed Project would not conflict with any state or local plan for prioritizing renewable energy or energy efficiency, and there would be no considerable contribution to a cumulative impact associated with energy.

Geology and Soils. As discussed in Section 5.7, the proposed Project would be located in an area mapped as likely to experience strong ground shaking, including ground shaking that could result in liquefactionrelated phenomena. Projects in the vicinity of the NRS-KRS Project would also be located in areas mapped as likely to experience strong ground shaking potentially combining to expose people or structures to potential significant cumulative impacts. All construction would be required to comply with building code standards that take into account effects of seismic events. For the proposed Project, implementation of mitigation measure MM G-1 (Conduct Geotechnical Investigations), which would ensure that Project design would reduce the potential for geologic and seismic hazards, such as liquefaction and expansive soils. The Project would not increase potential risks associated with seismic events or other geologic hazards. Shortterm construction impacts to soils, including unstable soils, have the potential to occur; however, final geotechnical recommendations would reduce the impacts to a less than significant level and the proposed Project impacts are not considerable enough to represent a significant cumulative impact. Adherence to similar design and engineering standards, which are applicable to the identified cumulative projects, ensure that their cumulative impacts to geology and soils would also be less than significant.

There is a limited potential for paleontological resources to occur on the site. Mitigation measure MM G-2 (Work Training and Management of Unanticipated Discoveries of Paleontological Resources) would ensure any potential impacts are less than significant and would not contribute to a cumulatively considerable impact.

Greenhouse Gas Emissions. Because the direct environmental effect of GHG emissions is to influence global climate change, GHG emissions are by their nature inherently a cumulative concern with a cumulatively global scope. Project-specific GHG emissions would occur from the burning of fuels required by construction equipment and vehicles during construction activities. Primary GHG emissions during construction are associated with CO2 from the combustion of gasoline and diesel fuel in equipment and vehicles. CH4 and N2O are also emitted from fuel combustion but at rates of less than 1 percent of the mass of CO2 combustion emissions. Construction-related emissions would be distributed over 14 months (for Option 1). These estimated levels would not exceed the threshold level of 25,000 metric tons per year for annual mandatory reporting of GHGs.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.22. MANDATORY FINDINGS OF SIGNIFICANCE SEPTEMBER 2024 5.22-5 ADMINISTRATIVE DRAFT MND/IS
GHG emissions from operation and maintenance would be minimal, as the transmission line would require only infrequent maintenance. The minor quantity of GHG emissions created during construction and for operation and maintenance would not be a cumulatively considerable impact.

Hazards and Hazardous Materials. The use of hazardous materials for the Project would be minimal during construction and operation. Hazardous materials would be stored and used in compliance with applicable regulations. Minor spills or releases of hazardous materials could occur due to upset or improper handling and/or storage practices during construction activities. Impacts from routine use, transportation, disposal, and accidental spillage of hazardous materials would be reduced to a less than significant level with implementation of mitigation measure MM HM-1 (Hazardous Substance Control and Emergency Response) discussed in Section 5.9, Hazards and Hazardous Materials; no contribution to cumulative impacts would occur.

Hydrology and Water Quality. The Project would not change existing drainage patterns along the route, which is covered primarily with impervious surfaces. The proposed Project would require minimal water for dust control and concrete during construction. Dewatering during foundation excavation for poles is possible, but not anticipated. In the event that dewatering is necessary, the water would be pumped out and treated and encountered groundwater would be tested to meet requirements set by the Regional Water Quality Control Board (RWQCB). Implementation of Mitigation measures MM HYD-1 (SWPPP or Erosion Control Plan Development and Implementation) and MM HM-1 (Hazardous Substance Control and Emergency Response) would ensure that erosion, sedimentation, or an accidental spill would not significantly affect water quality. With implementation of this mitigation, the Project’s hydrology and water quality impacts are less than significant and are not considerable enough to represent a significant cumulative impact.

Land Use. The proposed Project would be consistent with the policies of the City General Plan. In addition, the proposed Project, as well as the cumulative projects, are required to minimize any impacts to state and federally listed species and/or habitats through compliance with CEQA, the federal ESA, the CESA, and/or applicable local habitat conservation plans. The Project would, therefore, not conflict with applicable land use policies and regulations and would not contribute to cumulative impacts to land use.

Mineral Resources. No commercial mineral resources are known to exist within the proposed Project site or vicinity. Therefore, the proposed Project would not result in the loss of availability of a known mineral resource. The Project would not contribute to potential cumulative impacts that may result in the loss of mineral resources.

Noise. The proposed Project is not expected to contribute to a long-term cumulative impact on ambient noise levels in the area. Noise from construction activities would be audible to nearby residents and businesses, but construction would be limited to daytime hours and would be short-term. The nearest sensitive receptors, residents, are located just over 100 feet from the proposed transmission line route at their nearest. It is assumed that the cumulative projects would also be constructed during daytime. There would be a limited potential for the projects to have overlapping construction schedules for an extended duration that could result in substantial levels of combined construction noise. These projects are not likely to combine with noise generated from the construction of the Project to create significant adverse effects since noise reduces rapidly with distance.

Population and Housing. The proposed Project would not result in impacts to population and housing.

During its construction, the Project would provide short-term jobs for a small workforce. Construction workers would be contracted workers from the region. These jobs are not anticipated to result in workers relocating to the area. The Project would not displace any existing housing or people. The proposed Project, combined with the cumulative projects will have the potential to increase the population in the area due to increased job or housing opportunities. The proposed Project itself can facilitate future planned growth by ensuring a reliable and flexible electricity grid in the area. While the development of these NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.22. MANDATORY FINDINGS OF SIGNIFICANCE SEPTEMBER 2024 5.22-6 ADMINISTRATIVE DRAFT MND/IS
properties may induce some population growth, this has already been accounted for through the General Plan for the City. The NRS-KRS Project is proposed to increase system reliability and to serve planned growth in the area. The Project’s population and housing impacts would be less than significant and are not considerable enough to represent a significant cumulative impact.

Public Services. The proposed Project would not interrupt fire or police protection services, schools, access to public parks, or other public facilities nor would it require the construction of new public service facilities. The completion of the projects in the vicinity may have the potential to also increase the demand for public services and public facilities, including schools, parks, and fire and police protection. However, impacts from the proposed Project on public services would be incremental and would not contribute to a cumulatively significant impact.

Recreation. Although some workers may use nearby park facilities during Project construction; increased use would be minimal and temporary and would not contribute substantially to the physical deterioration of existing facilities. The cumulative projects also have the potential to increase use of park facilities, but the increased use would also be minimal. The projects would have less than significant effects on recreation and would not contribute to cumulative effects associated with other projects.

Transportation. Construction would occur in a highly urbanized setting and would therefore create temporary impacts to traffic volumes, road hazards, and emergency access in the project area. Some road closures and/or one-way traffic controls would be required to allow for certain construction activities and to maintain public safety. While construction would create impacts, these impacts would be localized, temporary in nature, and would not change long-term traffic loads or patterns. Impacts due to traffic and temporary lane closures as a result of the construction of the proposed Project would be reduced to a less than significant level with implementation of mitigation measure MM T1 (Construction Traffic Control Plan) discussed in Section 5.17, Transportation and Traffic.

Impacts from the proposed Project, combined with construction of the cumulative projects would have the potential to cumulatively impact transportation and traffic in the surrounding area; however, the construction schedules of the Projects and that of the proposed Project would be variable. The potential for the planned and current projects in the vicinity to require lane closures simultaneously would be a remote possibility and would be limited in duration and location. Adherence to mitigation measure MM T-1 (Construction Traffic Control Plan) would ensure that the proposed Project’s cumulative impacts to traffic and transportation would be incremental, short-term, and less than significant.

Tribal Cultural Resources. There are no known Tribal Cultural Resources (TCRs) listed in, or are known to be eligible for listing in, the California Register of Historical Resources (CRHR) or local register of historical resources within the proposed Project site or surrounding area. However, it is possible that previously unidentified TCRs that may be eligible for inclusion in the CRHR or local registers could be discovered and damaged, or destroyed, during ground disturbance, which would constitute a significant impact absent mitigation. Implementation of mitigation measure MM TCR-1 (Management of Unanticipated Tribal Cultural Resources), discussed in Section 5.18 (Tribal Cultural Resources), would ensure evaluation and protection of unanticipated TCR discoveries. Adherence to this mitigation measure would ensure that no tribal cultural resources would be affected during Project construction or during operation of the Project, and no contribution to cumulative impacts would occur.

Utilities and Service Systems. The construction of the proposed Project would generate minimal demand for water or wastewater treatment. Construction would require the disposal of a less than significant amount of all types of waste. No expanded utility facilities or services would be needed for the Project and use and disposal of all water and waste products would comply with all applicable laws and regulations. Operation and maintenance of the proposed Project would not require any demand for water or wastewater treatment. Therefore, a less than significant contribution to cumulative impacts to utilities and service systems would occur.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 5.22. MANDATORY FINDINGS OF SIGNIFICANCE SEPTEMBER 2024 5.22-7 ADMINISTRATIVE DRAFT MND/IS
Wildfire. The construction of the Proposed Project would require temporary lane closures. The potential for the planned and current projects in the vicinity to require lane closures simultaneously would be a remote possibility and would be limited in duration and location. Implementation of MM T-1 (Construction Traffic Control Plan) would ensure that at least one lane of travel would remain open. Since the Proposed Project is not located in or near a very high fire hazard severity zone and is in an urban area with flat topography and low fuel load, the risk of wildfire is low. Furthermore, the Proposed Project would be unstaffed and would require only occasional maintenance with a small crew. The Proposed Project would be installing new electrical line equipment, which would reduce the risk of system failure due to aging equipment, which would reduce the cumulative fire risk for the area. Therefore, a less than significant contribution to cumulative impacts to wildfire would occur.

Corona and Induced Current Effects. None of the planned or current projects in the vicinity of the proposed Project would be sensitive to corona or induced current effects. The proposed Project will not contribute to a cumulative impact to corona and induced current effects. (c) Does the project have environmental effects, which would cause substantial adverse effects on human beings, either directly or indirectly?
LESS THAN SIGNIFICANT WITH MITIGATION. The proposed Project would not substantially adversely affect human beings directly or indirectly. The Initial Study identified no environmental effects that would cause substantial adverse effects on human beings. Adverse effects would be mitigated by implementation of mitigation measures and, in most instances, would be short-term construction period impacts. Each type of impact with the potential to cause substantial adverse effects on human beings has been evaluated, and this Initial Study concludes that all of these potential impacts are either less than significant or can be mitigated to a less than significant level with the implementation of measures presented herein. (See Section 6, Mitigation Monitoring and Reporting Program, for a complete listing of the mitigation measures.) Therefore, the proposed Project does not involve any activities, either during construction or operation, which would cause significant adverse effects on human beings that cannot be readily mitigated to a less than significant level. The proposed operation and maintenance activities would be the same as current operation and maintenance practices for the existing substations and existing SVP transmission lines, which have minimal impacts on human beings. The potential beneficial effects of the project include improving the reliability and capacity of the existing transmission system in the City.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 6. MITIGATION MONITORING PLAN SEPTEMBER 2024 6-1 ADMINISTRATIVE DRAFT MND/IS

6. MITIGATION MONITORING PLAN
This Mitigation Monitoring and Reporting Program (MMRP) will be used by the City of Santa Clara and SVP to ensure that the mitigation measures adopted as a condition of project approval are implemented.

The MMRP is consistent with CEQA Guidelines (Sections 15074(d), 15091(d), and 15097) for the implementation of mitigation.

SVP will be responsible for monitoring the implementation of the mitigation measures presented in Table 6-1. SVP will designate specific personnel to implement and document all aspects of the MMRP. SVP will ensure that the designated personnel have authority to enforce mitigation requirements and will be capable of terminating Project construction activities found to be inconsistent with mitigation objectives.

Additionally, SVP will be responsible for ensuring that construction personnel understand their responsibility to adhere to the MMRP requirements and other contractual requirements related to the implementation of mitigation.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 6. MITIGATION MONITORING PLAN SEPTEMBER 2024 6-2 ADMINISTRATIVE DRAFT MND/IS
Table 6-1. Mitigation Monitoring Plan
Impact Mitigation Measure
Monitoring
Requirement
Timing of
Action
Air Quality
ConstructionPhase Air
Quality
MM AQ-1. Implement Basic Construction Air Quality Mitigation. The Project shall ensure that basic construction emissions control measures are implemented as “Best Management Practices,” as follows:
 All exposed soil surfaces (e.g., parking areas, staging areas, soil piles, and graded areas) shall be watered two times per day.
 All haul trucks transporting soil, sand, or other loose material off-site shall be covered.  All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.  All areas to be paved shall be completed as soon as possible. Foundation pads shall be laid as soon as possible after grading.
 Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage regarding idling shall be provided for construction workers at all access points.  All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.
 Post a publicly visible sign with the telephone number and person to contact at SVP regarding dust complaints. This person shall respond and take corrective action within 48 hours. The BAAQMD’s phone number shall also be visible to ensure compliance with applicable regulations.

Emissions from
construction equipment exhaust are
reduced
During
construction
Biological Resources
Special Status
Wildlife Species
MM BIO-1. Implement Worker Environmental Awareness Program. Prior to and for the duration of any vegetation removal and trimming and any ground disturbing activities, SVP or its designee shall provide Worker Environmental Awareness Program (WEAP) training to all new personnel prior to beginning work on the Project. The training may be presented in the form of a video. The training program shall be developed by a qualified biologist to educate Project personnel about the Project’s sensitive biological resources. The name and credentials of the qualified biologist shall be submitted to the City no less than 14 days prior to the surveys for review and approval. A draft of the training program (i.e., video and written materials) shall be submitted to the City no less than 14 days prior for approval prior to implementation. The WEAP shall include, at a minimum:

Monitor
implementation of
specified biological
monitor activities
Prior to and
during
construction
Special Status
Wildlife Species
MM BIO-2. Biological Monitoring. SVP or its designee shall retain a qualified biologist as biological monitor on the Project, to be approved by the City. If sensitive biological resources are identified during preconstruction surveys or incidentally, the qualified biologist will monitor Project work locations in proximity to sensitive biological resources weekly until biological resources are not found for one consecutive month, at which point weekly monitoring will cease. The qualified biologist shall be notified immediately if any nesting birds or other biological resources are discovered once construction begins. The qualified Monitor sensitive
biological resources
if identified during
preconstruction
survey
Prior to and
during
construction
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Impact Mitigation Measure
Monitoring
Requirement
Timing of
Action
biologist will be the point of contact for any employee or contractor who might inadvertently kill or injure a special-status species or anyone who finds a dead, injured, or entrapped animal. The qualified biologist or biological monitor shall have the authority and responsibility to halt any Project activities that are not in compliance with applicable mitigation measures, permit conditions, or other Project requirements, or will have an unauthorized adverse effect on biological resources.

Special Status
Wildlife Species
MM BIO-3. Conduct Preconstruction Surveys for Special-Status Wildlife and Implement Avoidance Measures. A qualified biologist shall conduct a preconstruction survey for each of the species identified below. These surveys can be combined if they meet the requirements outlined in this measure. The name and credentials of the qualified biologist shall be submitted to the City no less than 14 days prior to the surveys for review and approval. Within 14 days of completion of the surveys, the City shall be provided with a report describing the findings, including the date, time, and duration of the surveys; identity of the surveyor(s); a list of all common and special-status species observed; locations of any special-status species identified, including any established avoidance buffers; and any actions taken at the direction of the City in coordination with CDFW, and/or USFWS.

Bumble Bee: A preconstruction survey for Crotch’s bumble bee and western bumble bee shall be conducted during the colony active period for each species (April through August) prior to project vegetation management and ground disturbing activities. The survey shall be conducted by a qualified entomologist or biologist familiar with the life history and ecology of special-status bumble bee species. The preconstruction survey for special-status bumble bees shall focus on the ruderal habitat within the utility rightof-way adjacent to the Northern Receiving Station and landscaped and ruderal land at the Montague Expressway interchange. The survey shall identify any potential foraging, nesting, and/or overwintering resources present within the Project work areas and a 50-foot buffer where legal access is available. If a potential active special-status bumble bee nest site is identified, a 50-foot avoidance buffer shall be clearly delineated with staking, flagging, and/or signage and Project activities will be prohibited from the area until it is determined that the nest is no longer potentially active. The qualified biologist shall notify the City for coordination with CDFW within 24 hours as further coordination may be required to avoid or mitigate impacts.

Burrowing Owl. No later than seven days prior to start of project vegetation management and ground disturbing activities, a qualified biologist shall conduct a preconstruction survey for burrowing owl. The survey shall include the focus areas (described below) plus a 250-foot buffer where legal access is available. The survey for burrowing owl shall focus on the ruderal habitat described for bumble bees above. If burrows or other structures are identified that contain signs of use by burrowing owl, or if burrowing owl(s) is observed, an avoidance buffer area shall be clearly delineated with staking, flagging, and/or signage. If during the nesting season (February 1 to August 31), a 250-foot avoidance buffer shall be established, and Project activities will be prohibited from the area until a qualified biologist determines it is occupied either by a non-mated pair or the young have fledged. If outside the nesting season, a 160-foot avoidance buffer shall be established. The prescribed buffers may be adjusted by the qualified avian biologist in coordination with the City and CDFW based on existing conditions around the burrow, planned construction activities, tolerance of the species at a given location, and other pertinent factors.

If avoidance of burrowing owls is not feasible and work will be conducted outside the nesting season, a Burrowing Owl Passive Relocation Plan shall be developed to provide detailed methods and guidance for passive relocation of burrowing owls. The Burrowing Owl Passive Relocation Plan shall be submitted to Monitor
implementation of
specified biological
monitor activities
and implement
avoidance measures
Prior to and
during
construction
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Impact Mitigation Measure
Monitoring
Requirement
Timing of
Action
the City for approval in coordination with CDFW prior to conducting passive relocation. An occupied burrow may not be disturbed during the nesting season, unless a qualified biologist determines, by noninvasive methods, that it is not occupied by a mated pair. Passive relocation would include installation of one-way doors on burrow entrances that would let owls out of the burrow but would not let them back in. Once owls have been passively relocated, burrows will be carefully excavated by hand and collapsed by, or under the direct supervision, of a qualified biologist.

Within 14 days of completion of the surveys, the City shall be provided with a report describing the findings, including the date, time, and duration of the surveys; identity of the surveyor(s); any established avoidance buffers in the event burrowing owls are documented to be present; and any actions taken at the direction of the City and/or CDFW.

Western Pond Turtle: No later than seven days prior to start of project vegetation management and ground disturbing activities, a qualified biologist shall conduct a preconstruction survey for western pond turtle. The survey for western pond turtle shall focus on the ruderal habitat within the utility right-of-way southeast adjacent to the Northern Receiving Station.

Western pond turtle or other special-status wildlife found within the Project site during the surveys shall be allowed to leave on its own volition prior to the onset of construction. If species of special concern are found within the Project site during surveys and will not leave on its own volition, the species will be relocated to the nearest suitable habitat outside of the Project site. Species of special concern will only be handled by qualified personnel as authorized by CDFW and/or USFWS under an issued state scientific collecting permit (SCP), memorandum of understanding (MOU), or federal recovery permit. Impacts to federally or state-listed species or state-listing candidate species are not authorized. If any State or federally listed, candidate, or proposed species are detected work will be stopped and the applicant shall notify the City for coordination with CDFW and or USFWS, within 24-hours for further direction.

Special Status
Wildlife Species
MM BIO-4. Preconstruction Nesting Bird Surveys and Nest Protection. During the nesting season (February 1 to August 31) If Project-related work is scheduled during the nesting season (typically February 15 to August 30 for small bird species such as passerines; January 15 to September 15 for owls; and February 15 to September 15 for other raptors), preconstruction nesting bird surveys shall be conducted on the site and vicinity by a qualified biologist no more than 7 days before any work activities, including any vegetation removal or trimming, are performed at a given Project location. The surveys shall be conducted following the sequential schedule of the linear Project in a manner that minimizes potential for the surveys to expire before the construction crews proceed to a new Project work location. The survey radii surrounding the work area shall be 250 feet for passerines and 500 feet for raptors. Surveyors will search for all potential nest types (e.g., ground, cavity, shrub/tree, structural, etc.) and determine whether the nest is active. A nest will be determined to be active if eggs or young are present in the nest. Upon discovery of active nests, the biological monitor will determine if there is need for a buffer or shield to minimize disturbance of the nest. Upon this determination and execution of any required minimization action, work may proceed. The extent of the determination will be based upon: acclimation of the species or individual to disturbance, nest type (cavity, tree, ground, etc.), and level and duration of construction activity. If there is a break in construction at a work location for a period of 14 or more days during nesting season, a new nesting bird survey shall be undertaken before construction is allowed to commence at that location to determine if any nests have been established. Bird surveys are not required outside of the nesting season.

Monitor
implementation of
measures to protect
nesting bids
During nesting
season; prior
to and during
construction
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Impact Mitigation Measure
Monitoring
Requirement
Timing of
Action
In the unlikely event a special-status or listed species is found nesting nearby, CDFW and USFWS will be notified, and the City will be provided with nest survey results, if requested. When active nests are identified, monitoring for significant disturbance to the birds will be implemented. Construction will not be allowed to continue unless the qualified biologist determines that no disturbance is occurring.

Special Status
Wildlife Species
MM BIO-5. Preconstruction Bat Survey and Implement Avoidance Measures. A qualified biologist shall conduct surveys for special-status bats during the appropriate time of day to maximize detectability to determine if bat species are roosting in trees or other vegetation requiring removal or clearance pruning for the Project. The name and credentials of the qualified biologist shall be submitted to the City no less than 14 days prior to the surveys for review and approval. The survey shall occur no less than 7 days and no more than 14 days prior to beginning tree or other vegetation removal or trimming activities. Survey methodology may include visual surveys for bats (e.g., observation of bats emerging from roosts to forage), inspection for suitable roost habitat, bat sign (e.g, guano), or use of ultrasonic detectors (e.g., Anabat, etc). Visual surveys shall include all trees or other vegetation requiring removal or clearance pruning for the Project.

If evidence of bat use is observed, the approximate number and species of bats using the roost shall be determined. Bat detectors may be used to supplement survey efforts.

If roosts or a maternity colony are determined to be present, then a Bat Mitigation and Monitoring Plan (Plan) shall be prepared and implemented to mitigate for the loss of roosting habitat. The Plan shall include information pertaining to the species of bat and location of the roost, exclusion methods and roost removal procedures, compensatory mitigation for permanent impacts (including specific mitigation ratios and location of proposed mitigation) and monitoring to assess bat use of mitigation areas. This Plan shall be submitted to the City and CDFW for review and approval prior to project activities that could disturb roosting bats.

Monitor
implementation of
bat survey and
avoidance measures
Prior to and
during
construction
Compliance with
Local Tree Policies
and Ordinances
MM BIO-6. Tree Protection Measures for Retained Trees. To minimize the potential damage and ensure the long-term health, stability, and survival of retained trees, measures outlined in the Tree Protection Plan below shall be implemented:

Tree Protection Zone
 A Tree Protection Zone (TPZ) shall be defined by the City Arborist or City designated ISA Certified Arborist for all trees within 50 feet of any excavations that could be affected by project activities and are intended for preservation. A TPZ will not be established for trees within the Project area that are not within this excavation zone. TPZ will be taken down once excavation work is completed within 50 feet. A TPZ will typically include all area within the dripline of trees to be retained.  The TPZ will be protected by a fenced enclosure to prevent unauthorized access during project activities. Fencing shall be constructed of sturdy but open material (i.e., orange webbed construction fencing, chain-link) with a minimum height of 4 feet and secured in place. Warning signs (e.g. WARNING – Tree Protection Zone – This fence shall not be moved without approval by the City Arborist or a City designated arborist) shall be prominently displayed and visible from all sides of the TPZ fencing.  TPZ fencing shall be installed prior to any demolition, grading, staging, stockpiling, or any other construction activities, and shall remain in place until all construction activities are complete.

Monitor
implementation of
tree protection
measures
Prior to and
during
construction
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Impact Mitigation Measure
Monitoring
Requirement
Timing of
Action
 No construction, staging, or storage of materials, equipment or vehicles shall occur within the TPZ without advanced approval and oversight by the City Arborist or a City designated ISA Certified Arborist.  No excess soil, excess concrete or concrete wash, chemicals, refuse or other waste shall be placed within the TPZ.
 The primary contractor shall be responsible for maintaining TPZ fencing and enforcing all TPZ guidelines outlined above throughout the course of the Project.

Site Grading, Excavation, and Trenching
 Soil disturbance or grade changes within a TPZ are not permitted unless approved by the City Arborist or a City designated arborist. Any approved grading, excavation or trench work within a TPZ will be field staked and inspected by the City Arborist or a City designated ISA Certified Arborist prior to implementation.
 All grading, excavation and trenching work within a TPZ shall be performed under the observation of a City Arborist or City designated ISA Certified Arborist.  All grading shall be designed to provide positive drainage away from the base of trees to be preserved and shall not create ponding within a TPZ.
 Grade changes in the vicinity of trees to be preserved should remain as close to natural grade as possible.

Canopy Pruning
 To the extent possible, any necessary canopy pruning shall be completed prior to the commencement of construction activities.
 Pruning shall be performed by a qualified tree service worker under the direction of a ISA Certified Arborist following International Society of Arboriculture tree pruning best management practices.

Pruning shall not be performed by construction personnel.

Root Pruning
 Any roots one inch and larger requiring removal shall be cut cleanly in sound tissue. No pruning seals or paint shall be used on wounds.
 Roots two inches and greater shall remain in place and undamaged to the extent practicable. If removal is required, cuts shall be made with the approval and under the direction of an ISA Certified Arborist.

Communication for Tree Protection Compliance
 A preconstruction meeting shall be arranged for the City Arborist or City designated ISA Certified Arborist to meet with the Project Planner, Project Contractors, Onsite Project Supervisors, Tree Pruning and Removal Contractor, and/or other appropriate Project Leads to review and secure a commitment to comply with all tree protection measures.

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Impact Mitigation Measure
Monitoring
Requirement
Timing of
Action
Cultural Resources
Unanticipated
Discoveries of
Historical
Resources or
Unique
Archaeological
Resources
MM CR-1. Worker Training and Management of Unanticipated Discoveries of Historical Resources, Unique Archaeological Resources. SVP shall conduct a worker environmental awareness program (WEAP) for Project personnel who, during the course of Project work, might encounter or alter historical resources or important/unique archaeological materials. This program may be combined with any similar required program, such as for biological resources. The WEAP may include a kickoff tailgate session that describes how to identify cultural resources and what to do if an unanticipated discovery is made during construction, presents site avoidance requirements and procedures to be followed if unanticipated cultural resources are discovered during Project construction, and includes a discussion of disciplinary and other actions that could be taken against persons violating historic preservation laws and SVP policies.

If previously unidentified cultural resources are identified during construction, construction work within 100 feet of the find shall be halted and directed away from the discovery until a Secretary of the Interior qualified archaeologist assesses the significance of the resource. The archaeologist, in consultation with the City of Santa Clara, State Historic Preservation Officer, any interested Tribes, and any other responsible public agency, shall make the necessary plans for treatment of the find(s) and for the evaluation and mitigation of impacts if the finds are found to be eligible to the National or California Registers, qualify as a unique archaeological resource under California Environmental Quality Act Section 21083.2, or are determined to be tribal cultural resource as defined in Section 21074.

Review and attend
worker
environmental
awareness program;
Monitor implementation of
unanticipated
discovery protocols
Prior to
construction
and during
construction
Unanticipated
Discoveries of
Human Remains
MM CR-2. Treatment of Human Remains. Any human remains discovered are to be treated with respect and dignity. Upon discovery of human remains, all work within 50 feet of the discovery area must cease immediately, nothing is to be disturbed, and the area must be secured. The Santa Clara County Coroner’s Office must be called. The Coroner has two working days to examine the remains after notification. The appropriate land manager/owner of the site is to be called and informed of the discovery. If the remains are located on federal lands, federal land managers, federal law enforcement, and the federal archaeologist must be informed as well, due to complementary jurisdiction issues. It is very important that the suspected remains, and the area around them, are undisturbed and the proper authorities called to the scene as soon as possible, as it could be a crime scene. The Coroner will determine if the remains are archaeological/ historic or of modern origin and if there are any criminal or jurisdictional questions.

After the Coroner has determined the remains are archaeological/historic-era, the Coroner will make recommendations concerning the treatment and disposition of the remains to the person responsible for the excavation, or to his or her authorized representative. If the Coroner believes the remains to be those of a Native American, he/she shall contact the Native American Heritage Commission (NAHC) by telephone within 24 hours.

The NAHC will immediately notify the person it believes to be the most likely descendant (MLD) of the remains. The MLD has 48 hours to make recommendations to the landowner for treatment or disposition of the human remains. If the descendant does not make recommendations within 48 hours, the landowner shall reinter the remains in an area of the property secure from further disturbance. If the landowner does not accept the descendant’s recommendations, the owner or the descendant may request mediation by NAHC.

According to the California Health and Safety Code, six (6) or more human burials at one (1) location constitute a cemetery (Section 8100), and willful disturbance of human remains is a felony (Section 7052).

Monitor
implementation of
human remain
discovery protocols
During
construction
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Impact Mitigation Measure
Monitoring
Requirement
Timing of
Action
Geology and Soils
Geologic and
Seismic Hazards
MM G-1. Conduct Geotechnical Investigations. Because seismically induced liquefaction-related ground failure has the potential to damage or destroy Project components, SVP shall cause design-level geotechnical investigation for the Project to be performed that shall include investigations designed to assess the potential for geologic and seismic hazards, and specifically include evaluation of the potential for liquefaction and expansive soils to affect the 115 kV line structures. Where liquefaction or expansive soils hazards are found to exist/verified, appropriate engineering design and construction measures shall be incorporated into the Project design as deemed appropriate by the Project engineer. Finalized Project design incorporating geotechnical recommendations shall be submitted to the City 60 days prior to Project construction.

Ensure a design-level
geotechnical
investigation is
performed
At least 60
days before
final Project
design
Unanticipated
Discoveries of
Paleontological
Resources
MM G-2. Worker Training and Management of Paleontological Resources. A paleontologist must be retained who meets the professional paleontologist qualifications (Society of Vertebrate Paleontology’s Standard Procedures, 2010) and has demonstrated experience in carrying paleontological projects to completion. The qualified professional paleontologist shall prepare a Worker Environmental Awareness Program (WEAP) for potentially encountered paleontological resources, and training shall be provided for all staff who will be onsite during excavations. The WEAP shall show what local Pleistocene fossils look like in general, where they may appear in the Project, and how to proceed should material suspected to be a fossil is encountered.

The WEAP shall include procedures to follow if paleontological resources are encountered, including:
 A monitoring plan for soils generated from tubular pole foundation excavations that may encounter Pleistocene sediments. Workers may temporarily halt operations to allow for identification and collection of paleontological resources from soil spoil piles. If a potential significant paleontological resource is noted, a qualified paleontologist or paleontological monitor shall be called to the site identify and collect the fossil.
 A plan for treatment of significant fossils that provides for the treatment of specimens to the point of identification and permanent preservation, including washing of sediments to recover small invertebrates and vertebrates.  A specimen identification, analysis, and curation plan that includes identification to the lowest taxonomic level possible; taxonomic, taphonomic, and biostratigraphic analysis; and curation to the standards of the repository where they will be curated.
 Paleontological resource collection treatment, and identification shall meet standards set forth in the Society of Vertebrate Paleontology (2010).

Review
Paleontological
Resource Monitoring
Program; Monitor
implementation of
Program
Prior to
construction
and during
construction
Hazards and Hazardous Materials
Hazardous
Substances
Control
MM H-1 Hazardous Substance Control and Emergency Response. SVP shall implement its hazardous substance control and emergency response. procedures as needed. These procedures identify methods and techniques to minimize the exposure of the public and site workers to potentially hazardous materials during all phases of Project construction through operation. They address worker training appropriate to the site worker’s role in hazardous substance control and emergency response. The procedures also require implementing appropriate control methods and approved containment and spill-control practices for construction and materials stored on site. If it is necessary to store chemicals on site, they shall be Collect and analyze
soil samples and, if
contamination is
discovered, ensure
that construction
activities are conducted according to
Prior to
construction
and during
construction
NRS-KRS 115 KV TRANSMISSION LINE PROJECT 6. MITIGATION MONITORING PLAN SEPTEMBER 2024 6-9 ADMINISTRATIVE DRAFT MND/IS
Impact Mitigation Measure
Monitoring
Requirement
Timing of
Action
managed in accordance with all applicable regulations. Material safety data sheets shall be maintained and kept available on site, as applicable.

All hazardous materials and hazardous wastes shall be handled, stored, and disposed of in accordance with all applicable regulations, by personnel qualified to handle hazardous materials. The hazardous substance control and emergency response procedures include, but are not limited to, the following:
 Proper disposal of potentially contaminated soils resulting from leaks or spills.  Establishing site-specific buffers for construction vehicles and equipment located near sensitive resources.
 Emergency response and reporting procedures to address hazardous material spills.  Stopping work at that location and contacting the City Fire Department Hazardous Materials Division immediately if visual contamination or chemical odors are detected. Work will be resumed at this location after any necessary consultation and approval by the Hazardous Materials Division.  SVP shall complete its Emergency Action Plan Form as part of Project tailboard meetings. The purpose of the form is to gather emergency contact numbers, identify first aid locations and provide other tailboard safety information.

SVP’s hazardous
substance control
and emergency
response procedures
Contaminated
Soil and
Groundwater
MM H-2 Soil and Groundwater Management. Prior to Project construction and ground disturbing activities, SVP shall implement an evaluation of potential soil and groundwater contamination at locations along the Project route where excavation, drilling, auguring, or other significant ground disturbance will occur to prevent mobilization of contaminants and exposure of workers and the public.

The evaluation shall be completed at least 60 days prior to the start of Project construction. The evaluation of soil and groundwater shall include, but not be limited to, the following:
 If contaminants below regulatory screening levels are identified, SVP shall coordinate with SCCDEH regarding soil reuse guidelines;
 If contaminants exceeding applicable regulatory screening levels for construction workers and residential users published by the RWQCB, DTSC, or the Environmental Protection Agency (EPA) (except for arsenic which is naturally occurring in the area), are encountered during the Soil and Groundwater Characterization Study SVP shall obtain regulatory oversight from SCCDEH and shall prepare a Soil and Groundwater Management Plan (SGMP); and
 Soils found in concentrations above established thresholds (except for arsenic) shall be removed and disposed of according to California Hazardous Waste Regulations.

If a SGMP is needed, the SGMP shall be prepared to guide activities during excavation and other ground disturbing activities to ensure that identified contaminated soils or groundwater are handled, removed, and disposed of properly. The SGMP shall be prepared by a licensed qualified professional and submitted to SCCDEH at least 30 days prior to Project construction and shall include, but not be limited to, the following elements:
 Procedures and protocols for the safe handling, storage, stockpiling, and disposal of contaminated soils;  Contaminated soil excavated from the site shall be hauled off-site and disposed of at a licensed hazardous materials disposal site;
Evaluate potential
soil and
groundwater
contamination, if
present, prepare and
implement a Soil and
Groundwater
Management Plan
Prior to and
during
construction
NRS-KRS 115 KV TRANSMISSION LINE PROJECT 6. MITIGATION MONITORING PLAN SEPTEMBER 2024 6-10 ADMINISTRATIVE DRAFT MND/IS
Impact Mitigation Measure
Monitoring
Requirement
Timing of
Action
 Protocols to manage and dispose of contaminated groundwater that may be encountered during trenching or subsurface excavation activities, and if dewatering is required; and  Procedures and protocols to follow in the event soils or groundwater not previously identified as contaminated and suspected of being contaminated (on the basis of visual, olfactory, or other evidence) are identified during site grading or excavation activities or dewatering activities to allow for proper identification and characterization, and subsequent proper handling, removal, and disposal.

Hydrology and Water Quality
Water Quality MM HYD-1. SWPPP or Erosion Control Plan Development and Implementation. Following Project approval, SVP will prepare and implement a SWPPP, if required by State law, or erosion control plan to minimize construction impacts on surface water and groundwater quality. Implementation of the SWPPP or erosion control plan will help stabilize graded or disturbed areas and reduce erosion and sedimentation. The plan will designate BMPs that will be adhered to during construction activities. Erosion and sediment control measures, such as straw wattles, covers, and silt fences, may be installed before the onset of winter rains or any anticipated storm events if soils are not stabilized. Suitable stabilization measures will be used to protect exposed areas during construction activities, as necessary. During construction activities measures will be in place to prevent contaminant discharge.

The Project SWPPP or erosion control plan will include erosion control and sediment trans-port BMPs to be used during construction. BMPs, where applicable, will be designed by using specific criteria from recognized BMP design guidance manuals. Erosion-minimizing efforts may include measures such as properly containing stockpiled soils.

Erosion control measures identified will be installed in an area before construction begins during the wet season and before the onset of winter rains or any anticipated storm events. Temporary measures such as silt fences or wattles, intended to minimize sediment transport from temporarily disturbed areas, will remain in place until disturbed areas have stabilized. The plan will be updated during construction as required by the SWRCB.

A worker education program shall be established for all field personnel prior to initiating fieldwork to provide training in the appropriate application and construction of erosion and sediment control measures contained in the SWPPP. This education program will also discuss appropriate hazardous materials management and spill response. Compliance with these requirements will be ensured by the on-site construction contractor.

Ensure a SWPPP is
prepared and implemented, or if a
SWPPP is not
required, ensure
that an erosion
control plan is
developed and
implemented to
minimize construction impacts on
surface water and
groundwater quality
Prior to and
during
construction
Transportation
Construction
Traffic Control
MM T-1. Construction Traffic Control Plan. Prior to the start of construction, SVP or its designee shall prepare and submit an Encroachment Permit which will include the construction Traffic Control Plan for review and approval to the City’s Department of Public Works for public roads and transportation facilities that would be directly affected by the construction activities and/or would require permits and approvals.

SVP shall submit the construction Traffic Control Plan to the City prior to conducting activities covered in the traffic control permits. The construction Traffic Control Plan shall include, but not be limited to:
 The locations and use of flaggers, warning signs, lights, barricades, delineators, cones, arrow boards, etc., according to standard guidelines outlined in the Manual on Uniform Traffic Control Devices, the Ensure that a
Construction Traffic
Control Plan is submitted by SVP and
approved by the City
of Santa Clara
Prior to
construction
NRS-KRS 115 KV TRANSMISSION LINE PROJECT 6. MITIGATION MONITORING PLAN SEPTEMBER 2024 6-11 ADMINISTRATIVE DRAFT MND/IS
Impact Mitigation Measure
Monitoring
Requirement
Timing of
Action
Standard Specifications for Public Works Construction, and/or the California Joint Utility Traffic Control Manual.
 Additional methods to reduce temporary traffic delays and trips during peak travel hours to the extent feasible.
 Typical access routes between all staging areas and the proposed work areas.  Defining methods to coordinate with the City throughout construction to minimize cumulative lane disruption impacts should simultaneous construction projects affect shared segments/portions of the circulation system.
 Prior to the start of construction, provide (or identify the timing to provide) the City with methods to comply with all specified requirements.
 Plans to coordinate in advance with emergency service providers to avoid restricting the movements of emergency vehicles. Police departments and fire departments shall be notified in advance by SVP of the proposed locations, nature, timing, and duration of any roadway disruptions, and shall be advised of any access restrictions that could impact their effectiveness. At locations where roads will be blocked, provisions shall be ready at all times to accommodate emergency vehicles, such as immediately stopping work for emergency vehicle passage, providing short detours, and developing alternate routes in conjunction with the public agencies. Documentation of the coordination with police and fire departments shall be gathered prior to the start of construction.  Plans to coordinate in advance with property owners, if any, that may have limited access to properties due to temporary lane closures. Provisions for ensuring secondary access should be provided.  Plans to coordinate with Valley Transportation Authority in advance of construction to minimize disruption to mass transit.

Tribal Cultural Resources
Unanticipated
Tribal Cultural
Resources
MM TCR-1. Management of Unanticipated Tribal Cultural Resources. During project construction, should subsurface tribal cultural resources be discovered, all activity in the vicinity of the find shall stop and a qualified archaeologist and an authorized tribal representative shall be contacted to assess the significance of the find according to CEQA Guidelines Section 15064.5 and Section 21074. If any find is determined to be significant, the archaeologist shall determine, in consultation with the implementing agency and any local Native American groups expressing interest, appropriate avoidance measures or other appropriate mitigation. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred means to avoid impacts to tribal cultural resources. Methods of avoidance may include, but shall not be limited to, Project reroute or redesign, or identification of protection measures such as capping or fencing.

Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, such as data recovery or other appropriate measures, in consultation with the implementing agency and any local Native American representatives expressing interest in the tribal cultural resource.

Confirm that all
activity in the vicinity
of a found
subsurface tribal
cultural resource is
ceased and that an
authorized tribal
representative is
contacted
During
construction
NRS-KRS 115 KV TRANSMISSION LINE PROJECT 7. RESPONSE TO COMMENTS SEPTEMBER 2024 7-1 ADMINISTRATIVE DRAFT MND/IS

7. RESPONSE TO COMMENTS

7.1. Introduction to Comments and Responses Section
The Final IS/MND includes the NRS-KRS 115 kV Transmission Line Project (Project) Draft IS/MND as revised, comments received on the Draft IS/MND, and responses to those comments.

This document has been prepared in accordance with California Environmental Quality Act (CEQA) as amended (Public Resources Code Section 21000 et seq.) and the Guidelines for Implementation of the California Environmental Quality Act (State CEQA Guidelines) (Cal. Code Regs., tit. 14, § 15000 et seq.) Although State CEQA Guidelines Section 15088 does not require a Lead Agency to prepare written responses to comments received on a Draft IS/MND, the City and SVP have elected to prepare the following written responses with the intent of providing a comprehensive and meaningful evaluation of the proposed Project.

This section summarizes and responds to the comments received during the public review period, which occurred from July 31 to August 30, 2024. This section also provides general responses to common comments.

7.2. Summary of Comments Received
Table 7-1 lists the Public Agencies, Groups, Organizations, and Individuals that submitted comments on the Draft IS/MND. The individual comments were numbered and are included in Appendix H, Public Comments on Draft IS/MND. This section summarizes the concerns in each comment and responds to them. It is important to note that only the substantive comments raised on the merits of the environmental analysis are identified, numbered, and responded to, while comments such as those related to the commenter’s interest in or opinions about the project, or a summary of the project itself were noted but not included.

If revisions were made to the IS/MND based on the comments, the revisions are summarized with the response to the specific comment and are indicated in the text of this Final IS/MND with strikeout for deletions of text, and in underline for new text.

Table 7-1. Comments Received on the Draft IS/MND
Commenter Date of Comment Comment #
A: Public Agencies, Groups, and Organizations
California Department of Fish and Wildlife (CDFW) 8/29/24 A1 SFPUC Water Enterprise 8/26/24 A2
San Jose International Airport 7/24/24 A3
California Department of Transportation (Caltrans) 8/29/24 A4 B: Individuals
Kanupriya Kabra 8/29/24 B1
Harsha Priya 8/29/24 B2
Aadya Shrotriya 8/29/24 B3
Jigisha Shukla 8/29/24 B4
Jigisha Shukla #2 8/29/24 B5
Praveen Vutukuru and Vijaya Chaganti 8/29/24 B6
Sudhir Kulkarni 8/29/24 B7
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Commenter Date of Comment Comment #
Rajesh Upalekar 8/29/24 B8
Amit Chandak 8/30/24 B9
Neelam z.dabholkar 8/30/24 B10
Aman Sharma 8/30/24 B11
Aruna Pothukuchi 8/31/24 B12
Fang Gong 8/3/24 B13
Sriharish Pisipati 8/30/24 B14
Saurabh Sharma 8/30/24 B15
Saurabh Sharma #2 8/30/24 B16
Prithvi Arun 8/30/24 B17
Vishnu Hari 8/30/24 B18
Sathiya Narayanan 8/30/24 B19
Unnikrishnan Udinoor 8/30/24 B20
Sweety h 8/30/24 B21
Simple Yadav 8/30/24 B22
Niaz Khan 8/30/24 B23
Kuldeep Singh 8/30/24 B24
Paddy Subbian 8/30/24 B25
Anjana Batchu 8/30/24 B26
Anjana Batchu #2 8/30/24 B27
Amit Chandak #2 8/30/24 B28
Amit Chandak #3 8/30/24 B29
Candida Bayross 8/30/24 B30
Johny Rufus 8/30/24 B31
Mehul Suresh Jain 8/30/24 B32
Priyadarshini Vijayakumar 8/30/24 B33
Manojkumar Mohanram 8/30/24 B34
Anupama Lolage-Baheti 8/30/24 B35
Vijay Srinivasan 8/30/24 B36
Lini Kuriyan 8/30/24 B37
Olivier Madec 8/29/24 B38
Suneet Bisht 8/30/24 B39
Manjunath Jagannatharao 8/30/24 B40
Phani Shankar Pandravada 8/30/24 B41
Harini Tadinada 8/30/24 B42
Shankar Pandravada #2 8/30/24 B43
Vishaka Sutrave 8/30/24 B44
Jerin 8/30/24 B45
Punnya Ann Joy 8/30/24 B46
Manali Desai 8/30/24 B47
SriVidya Chavali 8/30/24 B48
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Commenter Date of Comment Comment #
Hima Sree MC 8/30/24 B49
Lakshmikanth Chowdary Pothula 8/30/24 B50
Sith Thuon 8/29/24 B51
Cipson Jose 8/29/24 B52
Om Shankar 8/29/24 B53
Om Shankar #2 8/29/24 B54
Amit Thakkar 8/29/24 B55
Lenny Le 8/29/24 B56
Srinivas Dangeti 8/29/24 B57
Venkat Patchigolla 8/29/24 B58
Aparna Raman 8/29/24 B59
Gayathiri Lakshmanan 8/29/24 B60
Prashant Tiwari 8/29/24 B61
Srinivas Reddy 8/29/24 B62
Gane Sugali 8/29/24 B63
Adnan Hemani 8/29/24 B64
Darshna Siva 8/29/24 B65
Vinay Iyer 8/29/24 B66
Preetika Tiwari 8/28/24 B67
Kanupriya Kabra #2 8/28/24 B68
Ruchika Sarna 8/27/24 B69
Ruchika Sarna #2 8/28/24 B70
Yuri Kleban 8/27/24 B71
Sir Yuri 8/27/24 B72
Derek Fong 8/27/24 B73
Jeff Holmbeck 8/12/24 B74

7.3. General Responses to Common Comments
This section presents detailed responses to comments that were made by multiple commenters. General Responses (GR) address the following topics:
 GR #1 – Human Health and Scope of CEQA
 GR #2 – Electromagnetic Fields (EMF)
 GR #3 – Corona and Induced Currents
 GR #4 – Property Values and Cost
 GR #5 – Aesthetics
 GR #6 – Noise
 GR #7 – Hazards

7.3.1. General Response #1 – Human Health and Scope of CEQA During the Public Comment Period, SVP hosted a Public Engagement Meeting on August 22. This meeting was attended by approximately one dozen community members, who expressed their concerns about the Project’s potential impact on human health. The commentors cited a list of State reviewing agencies and NRS-KRS 115 KV TRANSMISSION LINE PROJECT 7. RESPONSE TO COMMENTS SEPTEMBER 2024 7-4 ADMINISTRATIVE DRAFT MND/IS
stated that none of the agencies listed have an association with human health. Commentors stated that CEQA reporting is not qualified enough regarding human health concerns, and recommended that other agencies, who are qualified to study “humans” should be involved in reviewing the proposal. Commentors stated that a third party or independent study should be completed in favor of human health.

CEQA analyses are guided by the CEQA Guidelines, which are defined as:

The CEQA Guidelines (Title 14, Division 6, Chapter 3 of the California Code of Regulations) are administrative regulations governing implementation of the California Environmental Quality Act. The CEQA Guidelines reflect the requirements set forth in the Public Resources Code, as well as court decisions interpreting the statute and practical planning considerations. Among other things, the CEQA Guidelines explain how to determine whether an activity is subject to environmental review, what steps are involved in the environmental review process, and the required content of environmental documents. The CEQA Guidelines apply to public agencies throughout the state, including local governments, special districts, and State agencies (OPR, 2024).

The IS/MND was prepared pursuant to the CEQA Guidelines, including all required content, and following the CEQA Appendix G checklist. Further, SVP conducted Public Scoping, which identified additional concerns to be addressed in the Draft IS/MND, expanding the scope of the CEQA document to include an EMF study which is not required as part of the CEQA Guidelines.

CEQA’s Appendix G checklist does not include specific questions related to human health, per se, but it does include questions that address the physical condition of the environment that would be affected by the Project and the nature of the environment with project implementation. Human health is impacted by the physical condition of the environment.

CEQA defines “environment” to mean “the physical conditions which exist within the area which will be affected by a proposed project, including land, air, water, minerals, flora, fauna, noise, objects of historic or aesthetic significance.” (Pub. Resources Code § 21060.5) For example, the Air Quality section discusses impacts related to toxic air contaminants, with which the thresholds of significance are set at a level that is agreed upon, by experts, to protect human health.

Not all impact analyses have quantitative thresholds due to their nature (Aesthetics, Energy, Public Services), and some concerns are not included in the CEQA checklist, because there is not a scientific consensus on a threshold of significance (See GR #2, EMF, as an example of this).

7.3.2. General Response #2 – EMF
Several commentors stated that consideration of EMF was absent prior to input during the scoping process.

The scoping process is designed to do exactly this; shape the environmental analysis. Commentors also stated that the lack of specifics included in the EMF section is not acceptable.

A project-specific EMF report was conducted by qualified engineers and was published along with the Draft IS/MND.

Commentors stated that because some of the information had been previously published in an SVP report, they would like a more detailed analysis. While it is true that language from a 2020 report was used, this information is still considered up-to-date, and is fully applicable to the NRS-KRS Project. The EMF report expands on the information presented, uses up-to-date modeling software, and provides detailed engineering drawings and graphs.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 7. RESPONSE TO COMMENTS SEPTEMBER 2024 7-5 ADMINISTRATIVE DRAFT MND/IS
Commentors included references to studies that further support SVP’s conclusion – that there is no scientific consensus on EMF impacts to human health. One reference provided by commentors states the following:
“In order to have confidence that an exposure agent is actually linked to human disease, scientists look for strong and consistent associations from epidemiological research. In the cases of electric and magnetic fields, the studies have found only weak association, or no association, between exposure and the incidence of some cancers. In addition, study outcomes are not consistent… There is a general consensus within the scientific community that exposure to EMF is not responsible for human disease” (PSCW, 2017).

It is not within the scope of this IS/MND to speculate on the impact of EMF on human health. The IS/MND has conducted a project-specific study on EMF and presented the results to be reviewed by the public and decision-making bodies.

Several comment letters included questions related to EMF. These are included below.

1. Have you conducted an existing EMF study to identify the current value of the community? (a) The EMF study included a simulation of current magnetic field strength values that exist in the area.

2. Are your EMF study values based on the cumulative, or interference of existing EMF and potential EMF.
(a) The EMF study was set up to assume constructive interference between the potential sources of magnetic fields. This study would not capture potential destructive interference between sources of EMF. Destructive interference between sources of EMF would have the effect of reducing EMF.

3. EMF value was calculated based on existing studies. What was the delta between mathematical modeling and actual values (from existing structures).
(a) No field study to take measurements of EMF was completed. The EMF study accounts for mathematical modeling as outlined in EPRI’s (Electric Power Research Institute) Transmission Line Reference Book, an industry standard reference book addressing electrical aspects of transmission line design.

4. What is the delta between underground and overhead structures’ EMF values? (a) The main change in reported magnetic field strength between overhead and underground placement of magnetic field sources would be due to proximity to the magnetic field source.

For example, an underground cable producing magnetic fields 10 feet below the ground surface would result in a higher magnetic field at the typical reporting and measuring height of 1 meter above ground compared to an overhead conductor installed 20 feet above ground.

5. Can you provide the same for Route options B and C?
(a) The EMF study was completed for the preferred alignment only. The EMF study is dependent on the proposed design of the transmission line and nearby adjacent sources of magnetic fields such as other power lines. The proposed loading for the proposed transmission line would remain the same so the only changing variables that would affect the reported magnetic field strengths would be the height of the poles, conductor phasing, and adjacent power lines. An EMF study will not be prepared for routes that are not analyzed in detail in the CEQA document.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 7. RESPONSE TO COMMENTS SEPTEMBER 2024 7-6 ADMINISTRATIVE DRAFT MND/IS

6. What happens when electrification of rail lines happens- as this is already planned for the future? Have you potentially considered the cumulative EMF effect in coexistence of the high power lines and with railway lines’ electrification? Will the EMF values not be much higher then? (a) The future electrification of the rail lines was not considered. Without having specific information for the future electrification of the rail line, it is difficult to speculate whether or not EMF levels will increase, stay the same, or decrease.

7. Can you share the mathematical modeling maps of EMF for 115kV, 230kV and the next two higher values of the power line?
(a) The EMF report includes the modeling for the 115 kV transmission line. Magnetic fields are created by the current flow through the line. The current EMF report uses the forecasted current load (measured in amps) of the transmission line which is mostly independent of the operating voltage. Although the Project is being designed for future growth, there are currently no plans to energize this line to 230 kV or beyond.

8. Can you share EMF maps from existing structures of 115kV, 230kV and the next 2 higher values of the power line?
(a) The existing power facilities identified running parallel to the proposed transmission line were included in the EMF report using existing load data from SVP. The existing power facilities along the alignment are 12 kV and 60 kV. Although the Project is being designed for future growth, there are currently no plans to energize this line to 230 kV or beyond.

9. Please share any EMF related information that you have especially if it contains assumptions for any calculations so we can understand the effects of current project and future projects. (a) All the data considered in the modeling of the magnetic field strength in the EMF report are detailed in the EMF report, which has been publicly available on the State Clearinghouse website since July 31, 2024.

10. Why does the electric pole structure proposed have wider diameter at the top? Can you share the design of the top of the pole? Can it be extended by adding another section by bolting, welding or any other method? If so, what extra voltage can be added to the line? (a) The structures themselves and their final geometries are still being finalized, but the proposed poles do not have a wider diameter at the top and are not expected to have a wider diameter at the top in the final design. While modifications to existing structures are possible and there is industry precedent for it, generally structures are replaced when significant upgrades become necessary. Although the Project is being designed for future growth, there are currently no plans to energize this line to 230 kV or beyond.

11. What is the proposed power consumption of 95054 zip code for the next 5, 10 and 15 years in the master plan?
(a) Based on SVP’s load growth plan, power consumption over the next 5, 10, and 15 years is estimated to be 450 MW, 538 MW, and 593 MW, respectively for the 95054 zip code. Please note that the 95054 zip code only includes a portion of the City.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 7. RESPONSE TO COMMENTS SEPTEMBER 2024 7-7 ADMINISTRATIVE DRAFT MND/IS

7.3.3. General Response #3 – Corona and Induced Currents Commentors expressed concerns about the Project’s proximity to the railway line, and the potential risks associated with corona and induced current effects.

As described in Section 5.21, the corona effect for transmission lines describes the localized electrical discharge caused by ionization of the air surrounding the energized portions of the transmission line. The corona produced by a transmission line is dependent on multiple factors beyond operating voltage such as the diameter of the conductors, the location of conductors relative to each other, the elevation above sea level, weather, and more. Some possible byproducts of corona discharge on transmission lines include a faint glow, buzzing noise, and AM radio interference. Corona rings and specifically designed hardware designed for use on high voltage systems help mitigate corona by attenuating the electric field to reduce the electric field gradient that causes the ionization of the air adjacent to the energized surfaces. The corona effect is localized to the immediate vicinity of the energized portions of the transmission line.

To prevent any interference between the transmission line and the railroad, minimum safety clearances defined by the National Electrical Safety Code and CPUC’s GO-95 would be met or exceeded by the Project.

Additionally, the Applicant will work with UPRR as needed during the permitting process, to ensure that there are no adverse impacts due to corona or induced currents.

7.3.4. General Response #4 – Property Values and Cost
Commentors expressed concerns about the reason the proposed Project route was chosen, specifically citing costs of construction. Commentors also expressed concerns that the Project may decrease property values.

The proposed Project route was chosen due to several reasons. It is inaccurate to say that the route was chosen based on costs alone. In the initial design process, several routes were considered. Prior to initiation of the IS/MND, an Alternatives Analysis was done, which analyzed three routes, and identified the Proposed Project as the most feasible. The reasons for this were explained in Section 4.16.

Property values are not within the scope of a CEQA review. CEQA focuses on the potential physical impacts of a project. The economic effects of a project need only be considered if those effects themselves would cause a significant physical impact on the environment. Decreases in property values are not physical impacts, are speculative, and are difficult to predict. The IS/MND does not speculate about potential effects on property value. Therefore, given the CEQA guidance regarding social and economic impacts, this is not considered as part of CEQA environmental review.

7.3.5. General Response #5 – Aesthetics
Commentors expressed concerns about the aesthetic impact of the Project, citing that there were no photos from the east side of Lafayette Street presented in the IS/MND.

Revisions to Section 5.1 Aesthetics, were made to add additional information about the visual setting of the residents on the east side of Lafayette Street. The CEQA Appendix G questions focus on scenic resources and public views. The Project is located in a highly urbanized area. Public views of the Project would be from motorists and people on Lafayette Street, but private residences are not considered public viewpoints, and are therefore not specifically analyzed. However, public views from Lafayette Street, directly adjacent to these residents are analyzed.

Additionally, aesthetic impacts are analyzed based on the visual change from baseline conditions. The current visual setting includes transmission lines, telephone lines, street lighting, and traffic signals, as well as buildings, fences, landscaping, roads, and a railroad. For viewers looking at Lafayette Street from the sidewalk, the poles within the median of Lafayette Street would be widely spaced and would not NRS-KRS 115 KV TRANSMISSION LINE PROJECT 7. RESPONSE TO COMMENTS SEPTEMBER 2024 7-8 ADMINISTRATIVE DRAFT MND/IS
represent a substantial change in the existing visual context. Motorists on Lafayette Street would view the new poles in the context of a developed visually complex built urban environment, and views would be fleeting as they drive. The poles that would be installed in the median of Lafayette Street would be visually consistent with the existing visually complex and built urban environment.

Attached here are three images from Google Earth that show the existing visual setting of locations along Lafayette Street, and explanations for the reasons why the Project would not be considered a significant visual change to the existing setting.

The existing urbanized setting, illustrated in Figure 7-1, includes several industrial-type visual features, including power poles on both sides of Lafayette Street. Across Lafayette Street, several more power poles, a fenced railroad` right of way, NRS, and Levi’s Stadium are visible. The Project’s industrial elements would be consistent with the developed complex urban environment and would not result in a significant visual change.

Figure 7-1. View of Lafayette Street from the east side of the intersection of Lafayette Street and Fairway Glen Drive, looking west
Figure 7-2 illustrates the existing setting just north of the Mission Gardens community. This figure shows several industrial visual elements, such as power poles with several lines on them, light poles, a fenced railroad right of way, and traffic signals. The power poles shown in this image are older, shorter, and are spaced closer together than the proposed Project. Residents who would view the Project from the east side of Lafayette Street would have views of the poles from their windows, however, the poles would be spaced further apart than existing power poles on Lafayette Street, approximately 300 feet apart.

Additionally, the poles would be much taller than existing infrastructure, increasing the conductor heights, and limiting the number of views from residences. The Project poles and lines would be viewed in the existing complex urban environment and are similar to the existing industrial elements present in the area. Therefore, there would be a low level of visual change.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 7. RESPONSE TO COMMENTS SEPTEMBER 2024 7-9 ADMINISTRATIVE DRAFT MND/IS
Figure 7-2. View of Lafayette Street from the east side of the intersection of Lafayette Street and Hope Drive, looking south
This image illustrates the public view experienced by motorists travelling north on Lafayette Street. The existing visual setting includes industrial elements such as power poles, light poles, a fenced railroad right of way, and Levi’s stadium in the background. Motorists on Lafayette Street would view the poles and lines in the median from this perspective, but their experience would be fleeting as they drive. The Project would introduce additional visual elements into the landscaped median but would not result in a significant visual change to the existing setting, given the existing complex visual environment of built and landscaped features. New poles would be widely spaced and existing landscaping between the street and buildings would often screen the views.

Figure 7-3. View of Lafayette Street from a motorist’s perspective, adjacent to the Mission Gardens community, looking north
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7.3.6. General Response #6 – Noise
Commentors expressed concerns related to noise produced by the Project during construction and after the new 115 kV transmission line becomes operational.

While construction of the project would create noise, this construction would occur within the times allowed under the City’s noise ordinance and would be temporary and intermittent. It is estimated that construction will take 14 months for the overhead alignment, however, due to the linear nature of the Project, construction will be moving along the route during this 14-month construction period. After construction, ambient noise levels in the Project area are not anticipated to increase and would be similar to current noise levels.

There would be no noise produced by the Project after construction, aside from during maintenance activities or corona noise. The analysis anticipates no permanent increases in ambient noise levels in the project vicinity once the Project commences operation (Section 5.13.3) One source of audible noise would be due to the corona effect, which is caused by the electric field near the surface of the conductors (see Section 5.21.1.1, Corona).

Commentors specifically stated that they are concerned about noise levels, which are already high in the area due to the proximity of Lafayette Street, the railway line, and the air traffic route. Given that noise levels are elevated in the Project area, due to traffic noise and airport noise (Section 5.15.1), low levels of corona noise from Project components would not be noticeably audible and would not meaningfully contribute to an increase in noise levels relative to the existing conditions.

7.3.7. General Response #7 – Hazards
Commentors expressed concerns related to hazards, fire, and risk of accidents due to the proposed Project.

As stated in Section 5.7, Geology and Soils, the transmission line structures would be designed to meet or exceed all applicable local and State seismic design criteria.

As stated in Section 5.9, Hazards and Hazardous Materials, the Project would implement Mitigation Measure H-1 (Hazardous Substance Control and Emergency Response) and H-2 (Soil and Groundwater Management), to prevent and reduce potential impacts associated with hazardous material use and the potential for encountering soil or groundwater contamination.

As discussed in Section 5.15, Public Services, the Project area is adequately served by the City of Santa Clara’s fire department. There are three fire stations located less than one mile from the proposed Project route, and the average response time is 3 minutes for all areas of the City.

As discussed in Sections 5.17, Transportation, and 5.20, Wildfire, the Project would not interfere with emergency response. These sections include a discussion of Mitigation Measure T-1 (Construction Traffic Control Plan), which ensures that access is maintained in the event of an emergency due to fire or other hazards. Fire risk associated with energized transmission lines is of concern in vegetated areas where the vegetation is a fuel source. In an urban setting, with lines located along streets, the risk of fire, such as from a downed line, is minimal.

Hazards due to induced current and the proximity to the railroad is discussed in General Response #3.

7.4. Responses to Comment Set A1 - California Department of Fish and Wildlife (CDFW)
Due to the specifics included in the CDFW comment letter, each concern was independently responded to. The alphanumeric codes correspond with the codes in the CDFW letter, presented in Appendix H, Public Comments on Draft IS/MND.

NRS-KRS 115 KV TRANSMISSION LINE PROJECT 7. RESPONSE TO COMMENTS SEPTEMBER 2024 7-11 ADMINISTRATIVE DRAFT MND/IS
A1-1 Thank you for your comment. The CDFW reviewer indicated that a CESA Incidental Take Permit would be required should the Project result in impacts to any CESA listed species.

As described in Section 5.4.1 (Setting) of the IS/MND the Project is located within a fully developed urban area between the San Jose International Airport and Levi Stadium in the City dominated by urban hardscape and land cover. As described in the analysis, CESA listed species are not expected to occur in or near the Project area and the Project is not expected to result in the take of any species listed under CESA. Therefore, a CESA Incidental Take Permit is not required for this project.

A1-2 The CDFW reviewer indicated that a notification pursuant to Section 1600 et seq. of the California Fish and Game Code would be required should the Project substantially divert or obstruct the natural flow; change or use material from the bed, channel, or bank (including associated riparian or wetland resources); or deposit or dispose of material where it may pass into a river, lake, or stream.

As described in response to Comment A1-1, the project is located in an urbanized setting and there are no potentially jurisdictional waters or wetlands within the Project area. A supplemental site visit was conducted to verify site conditions and confirmed the analysis presented in Section

5.4 (Biological Resources). The Project will not affect any river, lake, or stream. No infrastructure will be installed beneath aquatic features. A Lake and Streambed Alteration Agreement is not required for the Project.

A1-3 Thank you for your comment. The CDFW reviewer notes that Fish and Games Codes provide protection to nesting birds and their eggs. Please see the response to Comment A1-9.

A1-4 The CDFW recommends the IS/MND analyze potential adverse impacts to fully protected species due to habitat modification, loss of foraging habitat, and/or interruption of migratory and breeding behaviors.

Due to a production error, Appendix E containing the table of known and potential occurrences of special-status species, including State fully protected species, that have the potential to occur in or near the Project area was inadvertently left out of the draft IS/MND. Appendix E is included in the Final IS/MND. The fully protected species identified in the assessment that do not also have a state and/or federal listing status include golden eagle and white-tailed kite. As described in Section 5.4.1 (Setting), the Project is located within a fully developed urban area dominated by urban hardscape and land cover. The Project area and surrounding land lack suitable habitat to support foraging or nesting for the golden eagle (Appendix E).

As described in Section 5.4.2(a)(Environmental Impacts and Mitigation Measures, Criterion ‘a’), limited suitable nesting trees are present within or near the proposed Project area that could support the white-tailed kite during nesting season. Marginal foraging habitat is present adjacent to the Northern Receiving Station, the landscaped interchange for Montague Expressway, and ruderal road shoulders along the west side of the Montague Expressway overpass. The limited marginal foraging habitat consists of ruderal land cover containing primarily grasses and other herbaceous vegetation. Current and historic Google Earth aerial and street view imagery identify these areas are periodically managed for weeds and fire abatement. To verify these conditions a supplemental site visit was conducted. No raptor nests were identified in suitable trees along the Project alignment and no white-tailed kites were observed. Due to the high level of human disturbance along the Project alignment and adjacent areas, the potential for white-tailed kite to nest or forage within or adjacent to the proposed Project area is low.

The Project would not result in habitat modification or the loss of foraging habitat, or the interruption of migratory behaviors. To ensure the Project does not impact breeding behavior or the viability of nests, should they occur, the IS/MND includes MM BIO-4 (Preconstruction Nesting NRS-KRS 115 KV TRANSMISSION LINE PROJECT 7. RESPONSE TO COMMENTS SEPTEMBER 2024 7-12 ADMINISTRATIVE DRAFT MND/IS
Bird Surveys and Nest Protection). This measure requires preconstruction nesting bird surveys and nest protection measures in the event an active bird or raptor nest is identified. MM BIO-2 (Biological Monitoring) requires a biological monitor who will conduct weekly monitoring checks of any sensitive resources that may be identified during the preconstruction surveys or incidentally found during construction. In addition, MM BIO-1 (Implement Worker Environmental Awareness Program) requires that all personnel working on the Project are trained on the applicable environmental regulations, BMPs, and other protective measures to ensure impacts to wildlife are reduced or avoided, as well as how to notify the biological monitor if an active nest or other wildlife are discovered in the Project work areas. The implementation of MM BIO-1 through MM BIO-3 will ensure impacts to fully protected species do not occur.

A1-5 The CDFW recommends that a full list or table is included in the updated Biological Resources Section of the IS/MND that notes species common name, scientific name, state and federal listing status (as applicable), habitat type preference and determination on presence, for all specialstatus species with the potential to occur within the Project area.

Due to a production error, Appendix E containing the table of known and potential occurrences of special-status species within the Project area was inadvertently left out of the draft IS/MND.

However, the conclusions presented in the Draft IS/MND were based on the evaluation of all potential species that have the potential to occur. Species that were considered to have a very limited or unlikely potential to occur were not carried forward for analysis. Appendix E contains a list of those species and the table is included in the Final IS/MND. The table includes a full list of special-status plant and wildlife species identified during the literature review that have a potential to occur within the Project area and 5-mile query buffer. The common name, scientific name, listing status, habitat type preference, and determination on presence are included in the table for each species.

A1-6 The CDFW recommends the IS/MND provide baseline habitat assessments for special-status plant, fish and wildlife species located and potentially located within the Project area and surrounding lands, including all rare, threatened, and endangered species (CEQA Guidelines, §15380).

As stated in Section 5.4.1 (Setting), the IS/MND did include an assessment consistent with CEQA guidelines. The Project is located in an urbanized location and a review of the CDFW VegCAMP BIOS data was not initially conducted. A supplemental review of the Santa Cruz and Santa Clara Fine Scale Vegetation Map (TG & AIS 2023) shows the Project area and adjacent lands largely containing Urban (Developed) cover. Additionally, patches of Californian Annual & Perennial Grassland are mapped where the analysis identified ruderal land cover. Urban – Nonnative Forest cover were included urban landscape trees, particularly at the Oracle Santa Clara Campus/Agnews Historic Park. There are no sensitive vegetation communities in the Project area or adjacent areas.

The IS/MND adequately represented the vegetation communities within the Project area. As described in the Existing Habitat portion of Section 5.4.1 (Setting), “Urban/developed areas occur throughout the proposed Project area and adjacent lands, and include paved roads, bare ground associated with disturbance or development, buildings, paved parking lots, road medians and roadsides, railroad tracks and right-of-way, and landscaped areas. Land uses within the Study Area include residential, parks/open space, commercial, and industrial. Areas not containing hardscape are limited to residential, commercial, and roadside landscaped areas, landscaped parks/open space, and managed (e.g., mowing) ruderal areas of road shoulders and utility rights-of-way. Figure

5.4-1 identifies isolated ruderal communities, park/open space, and landscaped interchange areas meaningful to the analysis as they can provide marginal habitat for special-status species in some locations. The Study Area does not contain natural vegetation community alliances as described in A Manual of California Vegetation (Sawyer et al., 2009).” NRS-KRS 115 KV TRANSMISSION LINE PROJECT 7. RESPONSE TO COMMENTS SEPTEMBER 2024 7-13 ADMINISTRATIVE DRAFT MND/IS
As described in the Jurisdictional Waters portion of Section 5.4.1 (Setting), “There are no potentially jurisdictional waters or wetlands within the proposed Project area based upon a review of the USFWS NWI Wetlands Mapper (USFWS, 2024b), USGS Milpitas and San Jose West 7.5-minute quadrangle map, and Google Earth aerial and street view imagery. A formal aquatic resources delineation was not completed for the proposed Project.” A supplemental site visit was conducted to re-verify site conditions and confirmed the assessment of vegetation/land cover and habitat described in Section 5.4 (Biological Resources).

A1-7 The CDFW recommends that the California Natural Diversity Database (CNDDB), as well as previous studies performed in the area, be consulted to assess the potential presence of sensitive species and habitats. CDFW recommended a nine-quadrangle search to determine what may occur in the region.

The IS/MND adequately describes the potential of the proposed Project to impact sensitive plants and wildlife. A 5-mile buffer around the Project area was chosen for the CNDDB query conducted due to the heavily urbanized characteristic of the Project area and surrounding region. No Significant Natural Areas were identified within the Project area or 5-mile buffer.

Additional sources of information were utilized in this analysis, as listed in Section 5.4.1 (Setting), including the following:
• USFWS Information for Planning and Consultation federal resource list for the proposed Project area;
• CNPS Rare Plant Inventory species list within the 7.5-minute quadrangles overlapping the Project area, Milpitas and San Jose West;
• Jepson eFlora with access to the Consortium of California Herbaria record locations for special-status plants;
• California Academy of Sciences and National Geographic Society – iNaturalist observations within a 5-mile buffer around the Project area;
• Cornell Lab of Ornithology eBird sensitive species observations within a 5-mile buffer around the Project area;
• NRCS Web Soil Survey and National Hydric Soils List; and • USFWS National Wetlands Inventory Wetlands Mapper.

A1-8 CDFW noted that according to Biogeographic Information and Observation System (BIOS) records, the Project site contains positive detections of several special-status species and has the potential to support numerous special-status species and their associated habitat.

The IS/MND adequately describes the potential for sensitive plants and wildlife to occur in or near the proposed Project area. We acknowledge the presence of special-status species occurrence records and the potential for the Project site to support several special-status species and their habitat in Section 5.4.1 (Setting – Special-Status Plants and Animals) and Section 5.4.2(a) (Environmental Impacts and Mitigation Measures – Criterion ‘a’). However, the Project is located in an urban environment with limited habitat for sensitive species. Please also see the response to Comment A1-5.

A1-9 The CDFW notes that sensitive birds are known from the region and that trees would be removed during construction and recommends the project be constructed in compliance with APLIC guidelines.

Please see Comment A1-4 for the potential of sensitive birds to nest in any of the trees located in the Project area. In regard to APLIC guidelines, the IS/MND clearly defines the requirements to remain in compliance with APLIC guidelines. Section 4.11 (Project Components) states that the NRS-KRS 115 KV TRANSMISSION LINE PROJECT 7. RESPONSE TO COMMENTS SEPTEMBER 2024 7-14 ADMINISTRATIVE DRAFT MND/IS
Project is being designed in compliance with current APLIC guidelines and will have sufficient distance in between conductor wires as to prevent electrocution. The Project area does not contain wetlands or other aquatic features, large expanses of natural land cover, or agricultural fields that are attractive to birds and raptors (APLIC 1994). The ruderal land cover, landscaped interchange, and the Oracle Santa Clara Campus/Agnews Historic Park have the potential to attract birds; however, each of those areas has existing overhead electrical lines immediately adjacent to them.

The Project would not substantially change the baseline conditions at those locations.

The Project does not propose new electrical distribution lines, generator-tie lines, or fences.

Approximately half of the Project alignment involves existing utility poles supporting existing electrical transmission lines, electrical distribution lines, and/or communication lines, including along Lafayette Street between Agnew Road and Norman Avenue and between Laurelwood Road and the Kifer Receiving Station in the southern end of the Project. The Project would replace some of the existing utility poles along this portion of the alignment and be constructed with the existing lines as an underbuild to the proposed transmission lines; therefore, baseline conditions will not substantially change. The Project is being designed with enough distance between the conductor wires, to comply with current APLIC guidelines to prevent electrocution. SVP investigated the feasibility of placing the entire Project underground and concluded that it was infeasible due to the number of existing utilities underground that would necessitate relocations and require that the NRS-KRS line be buried very deep. An entirely underground option was determined to have more impacts due to the intensity required for construction and increase in ground disturbance when compared to an overhead line. Lastly, schedule and cost were considered, and an entirely underground option would cost more, take longer to construct, and would limit the capacity of the line, which would not meet the objectives of the Project.

A1-10 The CDFW recommends that MM BIO-4 be amended to include different nesting seasons for small bird species, owls, and other raptors, in addition to different survey radii for passerines, small raptors, and large raptors.

To respond to the request, MM BIO-4 (Preconstruction Nesting Bird Surveys and Nest Protection) has been modified to include the different nesting seasons for small bird species, owls, and other raptors as recommended. This measure has also been modified to incorporate the recommended survey radii of 250 feet for passerines and 500 feet for raptors.

MM BIO-4 requires that a preconstruction nesting bird survey shall be conducted no more than 7 days before any work activities occur at a given Project location. Further, if there is a break in construction at a work location for a period of 14 or more days during the nesting season, a new survey shall be completed before work resumes at that location. Additionally, MM BIO-2 requires weekly biological monitoring of any Project work locations in proximity to sensitive biological resources identified during preconstruction surveys, and any resources identified by the crew incidentally.

Given the highly urbanized nature of the Project area and surrounding region and limited line-ofsight due to residential and urban structures, the recommendation for conducting three surveys prior and including a 1,000-ft radii survey area for larger raptors would be excessive and would not contribute to the protection of these birds.

A1-11 The CDFW recommends the IS/MND should propose measures to conduct a bat habitat assessment of suitable bat roosting habitat, provide a survey methodology plan, and tree removal plan.

The IS/MND adequately characterized the potential for bats to roost and forage in the Project area and included measures to avoid or minimize impacts to local bats. Due to the heavily urbanized setting and the level of disturbance in proximity to the limited roosting and foraging NRS-KRS 115 KV TRANSMISSION LINE PROJECT 7. RESPONSE TO COMMENTS SEPTEMBER 2024 7-15 ADMINISTRATIVE DRAFT MND/IS
habitat, there is a very low potential for bats to be present in available roost habitat along the Project alignment. To verify the conclusions presented in the IS/MND, a supplemental site visit was performed to inspect the three trees proposed for removal. This survey confirmed the absence of structural features that provide day roost habitat for crevice and cavity/hollow roosting bats. In addition, MM BIO-5 (Preconstruction Bat Survey and Implement Avoidance Measures) requires a preconstruction survey for bats to determine if roost habitat is present and if bats are roosting in trees or other vegetation requiring removal for the Project. In the unlikely event that the trees proposed for removal develop features that provide suitable roost habitat, MM BIO-5 will ensure that impacts to roosting bats will not occur by requiring the development of a Bat Mitigation and Monitoring Plan which requires coordination with the City and CDFW. The Plan shall include information pertaining to the species of bat and location of the roost, the recommended two-step tree removal process, compensatory mitigation for permanent impacts (including specific mitigation ratios and location of proposed mitigation), and monitoring to assess bat use of mitigation areas.

A1-12 The CDFW notes that Crotch’s bumble bee, a state candidate for listing, has been detected in the region and recommends a habitat assessment be conducted by a qualified entomologist knowledgeable with the life history and ecological requirements of Crotch’s bumble bee.

The IS/MND adequately characterized the potential for Crotch’s bumble bee to occur in the Project area. Due to the heavily urbanized setting and the existing level of disturbance, there is a very low/minimal potential for Crotch’s bumble bee to be present along the Project alignment and adjacent land. To verify conditions, a supplemental site visit was conducted of the Project area which confirmed the presence of suitable nest habitat, California ground squirrel and other small mammal burrows, in the ruderal roadside land cover along Bassett Street and the landscaped interchange area south of the Montague Expressway overpass. However, the interchange area south of the overpass is outside of the Project work area and 50-ft avoidance buffer recommended for avoiding impacts to bumble bee nests, if present. Further, the ruderal roadside areas are extremely narrow and land use within and adjacent to the Project alignment contains few flowering plants that would provide high quality forage for Crotch’s bumble bee. However, in the unlikely event this species occurs in the Project area during construction, the IS/MND included MM BIO-3 (Conduct Preconstruction Surveys for Special-Status Wildlife and Implement Avoidance Measures) which was modeled on the CDFW survey considerations for CESA candidate bumble bee species and requires a preconstruction survey for Crotch’s bumble bee and the establishment of a 50-foot avoidance buffer around a nest, if present. MM BIO-3 states that the survey shall focus on the ruderal habitat within the utility right-of-way adjacent to the Northern Receiving Station and landscaped and ruderal land at the Montague Expressway interchange, but does not state that the survey shall be limited to these locations. Because of the low likelihood of this species occurring in the Project Area, SVP will not be seeking incidental take authorization for Crotch’s bumble bee.

SVP has confirmed that the use of herbicides and mowing activities will not occur during construction and are not activities they apply for operations or maintenance of facilities in the Project area.

A1-13 The CDFW indicated that burrowing owl is known from the region and recommends the IS/MND should include a thorough habitat assessment of potential burrowing owl habitat within and adjacent to the Project area.

As discussed in Section 5.4.2(a)(Environmental Impacts and Mitigation Measures, Criterion ‘a’), there are numerous CNDDB records for burrowing owl in the region of the Project area including a 2014 occurrence record overlapping the Northern Receiving Station, adjacent ruderal utility NRS-KRS 115 KV TRANSMISSION LINE PROJECT 7. RESPONSE TO COMMENTS SEPTEMBER 2024 7-16 ADMINISTRATIVE DRAFT MND/IS
right-of-way, and Levi’s Stadium. To verify site conditions, a supplemental site visit was conducted of the Project area which included the most likely areas that could support burrowing owls. This included the northeastern end of the ruderal utility right-of-way adjacent to the Project. Habitat in this area appeared graded and contained a layer of erosion control material possibly from hydroseeding. No burrows or owls were observed from the fence line using binoculars. In other areas of the right-of-way, the vegetation was approximately 1 to 3 feet tall. In addition, the ruderal utility right-of-way does not provide suitable habitat for burrowing owl. Suitable burrowing owl habitat was not observed in the ruderal roadside areas or the landscaped interchange north of Montague Expressway. The narrow roadside area between Bassett Street and Lafayette Street was observed to lack suitable burrow habitat and contained a high degree of human presence.

The narrow roadside areas adjacent to Montague Expressway on the west side of the overpass contained dense herbaceous vegetation approximately 3 to 5 feet tall. The landscaped interchange north of Montague Expressway was heavily disturbed by staging activities for an unrelated and unknown construction project. The landscaped interchange south of Montague Expressway contains suitable burrowing owl habitat (i.e., California ground squirrels and burrows, short vegetation); however, no owls or their sign were observed.

To ensure that owls are protected in the event that habitat and land cover/use changes over time, the IS/MND included MM BIO-3 (Conduct Preconstruction Surveys for Special-Status Wildlife and Implement Avoidance Measures) which includes prescriptive survey recommendations and mitigation guidelines for burrowing owls. If active burrows or potentially active burrows are identified, a 250-ft avoidance buffer will be established during the nesting season, and a 160-ft avoidance buffer outside the nesting season. Given the highly urbanized characterization of the Project area and surrounding region in addition to the small Project footprint, these avoidance buffer sizes would be adequate. Please note that MM BIO-3 also states “The prescribed buffers may be adjusted by the qualified avian biologist in coordination with the City and CDFW based on existing conditions around the burrow, planned construction activities, tolerance of the species at a given location, and other pertinent factors.” This would include increasing buffers should an owl show signs of disturbance.

7.5. Responses to Comment Set A2 - SFPUC Water Enterprise Representatives from the San Francisco Public Utilities Commission (SFPUC) submitted a comment identifying SFPUC parcels that may be within the proposed Project site. They requested that SVP work with SFPUCs Real Estate Services regarding land rights. SFPUC requested to be listed as a responsible agency in the CEQA document.

The proposed NRS-KRS 115 kV Transmission Line crosses the SFPUC ROW on Lafayette Street contained within the public road ROW. There are no proposed project activities that would encroach on SFPUC ROW.

SVP will coordinate with SFPUC as needed to ensure that the Project follows the required SFPUC processes, and that the Project would not interfere with, endanger, or damage existing or future SFPUC operations, security, or facilities.

7.6. Responses to Comment Set A3 - San Jose International Airport Representatives from the San Jose International Airport (SJC) submitted a comment which expressed concerns about some transmission structures in the southern portion of the Project, due to their height and location near the airport.

SVP and SJC held a meeting to discuss concerns that SJC had regarding the Project based on the filed 7460 form on the FAA’s Obstruction Evaluation website. In the meeting, SJC shared their airport-specific requirements for One-Engine Inoperative elevation restrictions in the vicinity of the departure and NRS-KRS 115 KV TRANSMISSION LINE PROJECT 7. RESPONSE TO COMMENTS SEPTEMBER 2024 7-17 ADMINISTRATIVE DRAFT MND/IS
approach angles to the airport’s runways. The structure location and height limits were discussed in relation to the specific needs of the airport in order to maintain a safe airspace around the airport. As a result of the meeting, structures on the proposed transmission line on Bassett Street south of the Laurie Avenue and Lafayette Street intersection are being designed so that each structure remains below the elevation limit defined by SJC’s One-Engine Inoperative Surfaces map that was provided to SVP. No changes to the IS/MND are required due to this change.

7.7. Responses to Comment Set A4 - California Department of Transportation (Caltrans)
Representatives from the California Department of Transportation (Caltrans) submitted a comment letter which identified several regulations, restrictions, or permits, that may be required by the Project.

The letter identifies the Project as being within the Airport Land Use Compatibility Plan for Santa Clara County and recommends that the City consider the safety zone and noise compatibility policies stipulated in the ALUCP. Section 5.9, Hazards and Hazardous Materials, of the IS/MND explains that the Project will comply with FAA Part 77 regulations, ensuring impacts related to aviation hazards are less than significant.

The applicant will coordinate with Caltrans as needed prior to or during the construction process to ensure that any permits, such as Encroachment permits, are acquired.

7.8. Responses to Comment Set B1 through B74
Concerns raised in comments B1 through B74 are addressed in General Responses numbers 1 through 7, above.

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Appendix A

LIST OF PREPARERS
NRS-KRS 115KV TRANSMISSION LINE PROJECT
JULY 2024 A-1 ADMINISTRATIVE DRAFT MND/IS

LIST OF PREPARERS
A consultant team headed by Aspen Environmental Group prepared this document under the direction of Silicon Valley Power. The preparers and technical reviewers of this document are presented below.

Lead Agency
Silicon Valley Power, City of Santa Clara
Allie Jackman, Principal Electric Utility Engineer......................... Project Manager & Lead Agency Contact Project Management and Document Production
Aspen Environmental Group – Prime Contractor
Hedy Koczwara, Vice President, Sr. Environmental Scientist ...... Program Manager Grace Weeks, Environmental Scientists ...................................... Project Manager, Agriculture and Forestry, Hydrology and Water Quality, Public
Services, Utilities, and Service Systems,
Population and Housing, Recreation
Fritts Golden, Senior Associate .................................................... Project Oversight, Aesthetics, Land Use and Planning, Corona and Induced
Effects, Cumulative
Rachael Dal Porto, Environmental Engineer................................ Air Quality, Greenhouse Gas, Energy Lauren DeOliveira, Cultural Resources Group Manager.............. Cultural Resources, Tribal Cultural Resources
Krystal Pulsipher, Senior Biologist ............................................... Biological Resources Aurie Patterson, Environmental Scientist & Geologist................ Geology and Soils, Hazards and Hazardous Materials, Mineral Resources
Jeffrey Linn................................................................................... Noise, Transportation, Wildfire Sharon Heesh............................................................................... Document Production Kati Simpson................................................................................. Graphic Design Chris Notto................................................................................... GIS/Graphics Kramer Botanical – Subcontractor for Arborist Report
Neal Kramer, Botanist/Ecologist, Certified Arborist.................... Arborist Report NRS-KRS 115KV TRANSMISSION LINE PROJECT
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Appendix B

REFERENCES
NRS-KRS 115KV TRANSMISSION LINE PROJECT
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REFERENCES

4. Project Description
City of Santa Clara. 2023. MapSantaClara Parcel Identification. https://www.santaclaraca.gov/our-city/ departments-a-f/community-development/planning-division/map-santa-clara. Accessed February 2024.

DHS (California Department of Health Services). 2002. An Evaluation of the Possible Risks from Electric and Magnetic Fields (EMFs) from Power Lines, Internal Wiring, Electrical Occupations, and Appliances. California EMF Program. June 2002. [Online]: https://ia.cpuc.ca.gov/Environment/ info/esa/lakeview/resources/01_introduction.pdf. Accessed May 2024.

WHO (World Health Organization). 2001. International EMF Project. May 2001. [Online]: https://www. who.int/publications/m/item/international-advisory-committee-meeting-minutes-2001.

Accessed May 2024.
_____. 2007. Environmental Health Criteria Monograph No. 238. Extremely Low Frequency Fields. March 13, 2007. [Online]: https://www.who.int/publications/i/item/9789241572385. Accessed May 2007.

5.1 Aesthetics
None

5.2 Agriculture and Forestry Resources
City of Santa Clara. 2014. City of Santa Clara Zoning Map. Updated January 2014. http://santaclaraca.gov/ home/showdocument?id=756. Accessed April 1, 2024.

DOC (California Department of Conservation). 2022. California Important Farmland Finder. https://maps. conservation.ca.gov/DLRP/CIFF/. Accessed April 1, 2024.

DOC 2017. State of California Williamson Act Contract Land Map. https://planning.lacity.org/eir/Holly woodCenter/Deir/ELDP/(E)%20Initial%20Study/Initial%20Study/Attachment%20B%20Refer ences/California%20Department%20of%20Conservation%20Williamson%20Map%202016.pdf.

Accessed April 1, 2024.
_____. 2016. Important Farmland in California, 2014. ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/ statewide/2014/fmmp2014_08_11.pdf. Accessed April 1, 2024.

5.3 Air Quality
BAAQMD. 2022. CEQA Air Quality Guidelines. https://www.baaqmd.gov/plans-and-climate/californiaenvironmental-quality-act-ceqa/updated-ceqa-guidelines. Accessed May 5, 2024. _____. 2023. Air Quality Standards and Attainment Status. https://www.baaqmd.gov/about-air-quality/ research-and-data/air-quality-standards-and-attainment-status. Accessed May 5, 2024.

CARB (California Air Resources Board). 2016. Ambient Air Quality Standards Chart. https://ww2.arb.ca. gov/sites/default/files/2020-07/aaqs2.pdf. Accessed May 5, 2024.

City of Santa Clara. 2014. City of Santa Clara 2010 2035 General Plan. City Council adopted on November 16, 2010. Updated December 9, 2014. https://www.santaclaraca.gov/our-city/departments-a-f/ community-development/planning-division/general-plan. Accessed May 5, 2024.

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5.4 Biological Resources
ABB (All About Birds), 2024. All About Birds: The Cornell Lab of Ornithology. [Online]: https://allabout birds.org. Accessed April 2024.

APLIC (Avian Power Line Interaction Committee). Mitigating Bird Collisions With Power Lines: The State of the Art in 1994. Edison Electric Institute and APLIC. Washington, D.C. ______. 2006. Suggested Practices for Avian Protection on Power Lines: The State of the Art in 2006.

Edison Electric Institute, APLIC, and the California Energy Commission. Washington, D.C. and Sacramento, CA. http://www.aplic.org/uploads/files/2643/SuggestedPractices2006(LR 2).pdf. ______. 2012. Reducing Avian Collisions with Power Lines: The State of the Art in 2012. Edison Electric Institute and APLIC. Washington, D.C. http://www.aplic.org/uploads/files/11218/Reducing_ Avian_Collisions_2012watermarkLR.pdf.

Baldwin et al., 2012 (Baldwin, B.G., D.H., Goldman, D.J. Keil, R. Patterson, and T.J. Rosatti). The Jepson Manual: Higher Plants of California. 2nd edition. University of California Press, Berkeley, California.

Bumble Bee Watch 2024 – Bumble Bee Watch, a collaborative effort to track and conserve North America’s bumble bees. Partners: Wildlife Preservation Canada, The Xerces Society for Invertebrate Conservation, York University Faculty of Environmental Studies, University of Ottawa, Montreal Insectarium, London Natural History Museum, BeeSpotter. [Online]: https:// www.bumblebeewatch.org/about/. Accessed April 2024.

CalTrans and CDFW (California Department of Fish and Wildlife). 2010. California Essential Habitat Connectivity Project: A Strategy for Conserving a Connected California. Available online at:
https://wildlife.ca.gov/Science-Institute/Habitat-Connectivity. Accessed April 2024.

CDFW (California Department of Fish and Wildlife). 2013. Report to the Fish and Game Commission:

Evaluation of the Petition from the Center for Biological Diversity to List Townsend’s Big-eared Bat (Corynorhinus townsendii) as Threatened or Endangered Under the California Endangered Species Act. Prepared by California Department of Fish and Wildlife, March 2013. ______. 2016. Status Review: Swainson’s Hawk (Buteo swainsoni) in California. California Department of Fish and Wildlife, Wildlife and Fisheries Division Nongame Wildlife Program, Sacramento, CA. April 11, 2016.
______. 2019. California Department of Fish and Wildlife (CDFW). Report to the Fish and Game Commission: Evaluation of the Petition from the Xerces Society, Defenders of Wildlife, and the Center for Food Safety to List Four Species of Bumble Bees as Endangered Under the California Endangered Species Act. Prepared by California Department of Fish and Wildlife, April 4, 2019. _____. 2023. Survey Considerations for California Endangered Species Act (CESA) Candidate Bumble Bee Species. California Department of Fish and Wildlife, Sacramento, CA. Available online at: https:// wildlife.ca.gov/Conservation/Survey-Protocols#377281281-invertebrates. Accessed April 2024. ______. 2024. California Natural Diversity Database (CNDDB), Rarefind, Version 6. Heritage Section, CDFW, Sacramento.

CNPS (California Native Plant Society). 2024. Rare Plant Inventory. California Native Plant Society, Sacramento. [Online]: https://rareplants.cnps.org/Home/. Accessed April 2024.

CWHR. 2021. California Wildlife Habitat Relationships (CWHR) System. Various species accounts. Updated versions of California’s Wildlife, edited by Zeiner, D.C. et all 1998-1990. CDFW, Sacramento, CA. [Online]: https://wildlife.ca.gov/Data/CWHR/Life-History-and-Range. Accessed: April 2024.

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eBird.org. 2024. eBird: An online database of bird distribution and abundance [web application]. eBird, Ithaca, New York. [Online]: https://ebird.org/home. Accessed April 2024.

Hatfield, R., S. Jepson, R. Thorp, L. Richardson, S. Colla, 2008. Bombus caliginosus. The IUCN Red List of Threatened Species 2014: e.T44937726A69000748. [Online]: http://dx.doi.org/10.2305/IUCN.UK. 2014-3.RLTS.T44937726A69000748.en. Accessed April 2024.

ICF International 2012. Final Santa Clara Valley Habitat Plan. Prepared for City of Gilroy, City of Morgan Hill, City of San Jose, County of Santa Clara, Santa Clara Valley Transportation Authority, and Santa Clara Valley Water District. August 2012. [Online]: https://www.scv-habitatagency.org/178/ Santa-Clara-Valley-Habitat-Plan. Accessed April 2024.
iNaturalist. 2024. iNaturalist Online Database. [Online]: https://www.inaturalist.org/home. Accessed April 2024.

Jepson eFlora. 2024. Jepson eFlora. The Jepson Herbarium, University of California, Berkeley. Revision 12 (2023) [Online]: https://ucjeps.berkeley.edu/eflora/. Accessed April 2024.

Jepson, S., D.F. Schweitzer, B. Young, N. Sears, M. Ormes, S.H. Black, 2015. Conservation Status and Ecology of Monarchs in the United States. 36 pp. NatureServe, Arlington, Virginia, and the Xerces Society for Invertebrate Conservation, Portland, Oregon.

NAS 2023 – National Audubon Society (NAS). 2023. Important Bird Areas. [Online]: https://ca.audubon. org/important-bird-areas-9. Accessed April 2024.

NatureServe. 2024. NatureServe Explorer [web application]. NatureServe, Arlington, Virginia. [online]:
https://explorer.natureserve.org/. Accessed April 2024.

Sawyer et al. (Sawyer, J., T. Keeler-Wolf, and J. Evans). 2009. A Manual of California Vegetation: Second Edition, 2009.

Shuford, W. D., and T. Gardali (editors). 2008. California Bird Species of Special Concern: A ranked assessment of species, subspecies, and distinct populations of birds of immediate conservation concern in California. Studies of Western Birds 1. Western Field Ornithologists, Camarillo, California, and California Department of Fish and Game, Sacramento.

USDA NRCS (U.S. Department of Agriculture, Natural Resources Conservation Service). 2024a. Web Soil Survey 3.4.0. [Online]: https://websoilsurvey.nrcs.usda.gov/app/. Accessed April 2024. ______. 2024b. National Hydric Soil List by State. [Online]: https://www.nrcs.usda.gov/publications/ query-by-state.html. Accessed April 2024.

USFWS (U.S. Fish and Wildlife Service). 2020. Monarch (Danaus plexippus) Species Status Assessment Report, version 2.1. Prepared by U.S. Fish and Wildlife Service. 96 pp + appendices. ______. 2023. Species status assessment report for the northwestern pond turtle (Actinemys marmorata) and southwestern pond turtle (Actinemys pallida), Version 1.1, April 2023. U.S. Fish and Wildlife Service, Ventura Fish and Wildlife Office, Ventura, California. ______. 2024a. IPaC: Information for Planning and Consultation. [Online]: https://ipac.ecosphere.fws. gov/. Accessed April 2024.
______. 2024b. National Wetlands Inventory Wetlands Mapper. [Online]: https://fwsprimary.wim.usgs. gov/wetlands/apps/wetlands-mapper/
WBWG 2017 – Western Bat Working Group (WBWG). Western Bat Species. [Online]: http://wbwg.org/ western-bat-species/. Accessed April 2024.

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Xerces Society. 2018. Petition to the State of California, Fish and Game Commission, to list the Crotch bumble bee (Bombus crotchii), Franklin’s bumble bee (Bombus franklini), Suckley cuckoo bumble bee (Bombus suckleyi), and western bumble bee (Bombus occidentalis occidentalis) as endangered under the California Endangered Species Act. Prepared by The Xerces Society for Invertebrate Conservation, Defenders of Wildlife, and Center for Food Safety. October 2018.

5.5 Cultural Resources
Broek, J.O.M. 1932. The Santa Clara Valley, California: A Study in Landscape Changes. N.v.A. Oosthoek’s Utig. Maadtij, Utrecht.

Cutter, D.C. 1978. Plans for the Occupation of Upper California: A New Look at the “Dark Age” from 1602 to 1769. Journal of San Diego History 24(1):78-90.

Findlay, J.M. and D.M. Garaventa. 1983. Archaeological Resources of Downtown San Jose: A Preliminary Planning Summary of Prehistoric and Historic Sites in the Central Business District. MS on file, S 5905, CHRIS/NWIC, CSU Sonoma, Rohnert Park.

Fitzgerald, R.T. and J. Porcasi. 2003. The Metcalf Site (CA-SCL-178) and Its Place in Early Holocene California Prehistory. Society for California Archaeology Newsletter 37(4):27-31.

Fitzgerald, R.T. 1991. Archaic Milling Cultures of the Southern San Francisco Bay Region. Archives of California Prehistory 35. Coyote Press, Salinas.

Fredrickson, David A. 1973. Spatial and Cultural Units in Central California Archaeology. University of California, Berkley.

Hart, J.D. 1987. A Companion to California (revised and expanded). Oxford University Press, New York.

Heizer, R.F., and S.F. Cook. 1953. “Capay Man,” An Ancient Central California Indian Burial. In Papers on California Archaeology: 21-26, edited by Richard F. Heizer. Reports of the University of California Archaeological Survey 22:24-26, University of California, Berkeley, Department of Anthropology.

Heizer, R.F. 1949. The Archaeology of Central California, L· The Early Horizon. University of California Anthropological Records. University of California Press, Berkeley. 12(1):1-84. _____. 1952. A Review of Problems in the Antiquity of Man in California. In Symposium of the Antiquity of Man in California, pp. 1-10. Reports of the University of California Archaeological Survey No. 16:3 17.
_____. 1950. Observations on Early Man in California. In Papers on California Archaeology: 1-5, pp. 5-10.

Reports of the University of California Archaeological Survey No.7, Berkeley.

Hendry, G.W. and J.N. Bowman. 1940. The Spanish and Mexican Adobe and Other Buildings in the Nine San Francisco Bay Counties, 1776 to about 1850 (and associated maps). MS on file, Bancroft Library, University of California, Berkeley.

Hildebrandt, W.R. 1983. Archaeological Research of the Southern Santa Clara Valley Project: Based on a Data Recovery Program from Sites CA-SCl-54, CA-SCl-163, CA-SCl-178, CA-SCl-237, and CA-SCl-241 Located in the Route 101 Corridor, Santa Clara County, California. Submitted to California Department of Transportation, District 4, San Francisco. Report S 6369. On file at the Northwest Information Center, Sonoma State University, Rohnert Park, CA.

Levy, R. 1978. Costanoan. In California, edited by R.F. Heizer, Volume 8. Handbook of North American Indians, W.G. Sturtevant, general editor, pp. 485-497. Smithsonian Institution, Washington, D.C.

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Lillard, J.B., R.F. Heizer, and F. Fenenga. 1939. An Introduction to the Archaeology of Central California.

Sacramento Junior College Department of Anthropology Bulletin 2. Board of Education of the Sacramento City Unified School District, Sacramento, California.

Meighan, C.W. 1965. Pacific Coast Archaeology. The Quaternary of the United States, edited by H.E.

Wright and D.G. Frey.

Winther, J.C. 1935. Archaeological Investigations at CA-SCl-128, The Holiday Inn Site. For the Ohlone People and the Redevelopment Agency of the City of San Jose, California. MS on file, S-5281, CHRIS/NWIC, CSU Sonoma, Rohnert Park.

5.6 Energy
CEC (California Energy Commission). 2022. Final 2021 Integrated Energy Policy Report (IEPR), Volume II - Ensuring Reliability in a Changing Climate. https://efiling.energy.ca.gov/GetDocument.aspx?tn= 241583. Accessed April 26, 2024.
_____. 2023a. 2021 Power Content Label for City of Santa Clara/Silicon Valley Power. https://www. energy.ca.gov/filebrowser/download/4673. Accessed April 26, 2024. _____. 2023b. Refinery Inputs and Production, Weekly Fuels Watch Dashboard. Data last updated:

September 27, 2023. https://www.energy.ca.gov/data-reports/reports/weekly-fuels-watch/ refinery-inputs-and-production. Retrieved April 15, 2024. _____. 2024. Electricity Consumption by Entity. http://www.ecdms.energy.ca.gov/elecbyutil.aspx.

Accessed May 3, 2024.

CPUC (California Public Utilities Commission). 2008. Energy Action Plan, 2008 Update. February. http:// www.cpuc.ca.gov/eaps/. Accessed April 26, 2024.

City of Santa Clara. 2024. Utility Fact Sheet. Electric Utility: City of Santa Clara. January–December 2023. http://www.siliconvalleypower.com/svp-and-community/about-svp/utility-fact-sheet. Accessed April 26, 2024.

SVP (Silicon Valley Power). 2023. Final 2023 Integrated Resource Plan for Silicon Valley Power. Adopted by the Santa Clara City Council, December 5, 2023. https://www.siliconvalleypower.com/home/ showpublisheddocument/82481/638367924630670000. Accessed May 3, 2024.

5.7 Geology and Soils
CGS (California Geological Survey). 2001. Seismic Hazard Zone Report for the Milpitas 7.5-Minute Quadrangle, Alameda and Santa Clara Counties, California. https://maps.conservation.ca.gov/ cgs/EQZApp/app/.
_____. 2016. Earthquake Shaking Potential for California. https://www.conservation.ca.gov/cgs/docu ments/publications/map-sheets/MS_048.pdf. Site specific data viewed at: https://usgs.maps. arcgis.com/apps/webappviewer/index.html?id=5a6038b3a1684561a9b0aadf88412fcf. Accessed April 2024.
_____. 2018. Earthquake Fault Zones, CGS Special Publication #42. https://www.conservation.ca.gov/cgs/ Documents/Publications/Special-Publications/SP_042.pdf. Accessed April 2024. _____. 2024a. Earthquake Zones of Required Investigation. https://maps.conservation.ca.gov/cgs/EQZ App/app/. Accessed April 2024.

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_____. 2024b. Big California Earthquakes. https://www.conservation.ca.gov/cgs/earthquakes/significant.

Accessed April 2024.

City of Santa Clara. 2011. City of Santa Clara Draft 2010-2035 General Plan: Integrated Final Environmental Impact Report. January 2011. http://santaclaraca.gov/home/showdocument?id=12900.

Accessed April 2024.
_____. 2014. City of Santa Clara 2010-2035 General Plan. City Council adopted on November 16, 2010.

Updated December 9, 2014. https://www.santaclaraca.gov/our-city/departments-a-f/commu nity-development/planning-division/general-plan. Accessed April 2024.

County of Santa Clara. 2012. “Santa Clara County Geologic Hazard Zones.” https://stgenpln.blob.core. windows.net/document/GEO_GeohazardATLAS.pdf. Accessed April 2024.

DWR (Department of Water Resources). 2024. Water Data Library Groundwater Levels. https://wdl.water. ca.gov/WaterDataLibrary/Map.aspx. Accessed April 2024.

Dibblee, T.W., and Minch, J.A. 2005. Geologic map of the Milpitas Quadrangle, Alameda and Santa Clara and Counties, California: Dibblee Geological Foundation, Dibblee Foundation Map DF-1531, scale 1:24,000. Viewed at: https://ngmdb.usgs.gov/Prodesc/proddesc_71767.htm. Accessed April 2024.

Helley, E.J., 1990, Preliminary contour map showing elevation of surface of Pleistocene alluvium under Santa Clara Valley, California: U.S. Geological Survey Open-File Report 90-633, scale 1:24,000. https://pubs.er.usgs.gov/publication/ofr90633. Accessed April 2024.

NRCS (Natural Resources Conservation Service). 2024. Web Soil Survey, Project Area Map and Data. https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx. Accessed April 2024.

SCCVWD (Santa Clara County Valley Water District). 2024. Your Water – Subsidence. https://www. valleywater.org/your-water/groundwater/subsidence. Accessed April 2024.

Society of Vertebrate Paleontology. 2010. Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. https://vertpaleo.org/wp-content/uploads/2021/ 01/SVP_Impact_Mitigation_Guidelines-1.pdf. Accessed April 2024.

USGS (United States Geological Survey). 2024a. Land Subsidence in the Santa Clara Valley. https://www. usgs.gov/centers/land-subsidence-in-california/science/land-subsidence-santa-clara-valley .

Accessed April 2024.
_____. 2024b. Earthquake Hazards Program, 2008 National Seismic Hazard Maps - Source Parameters. https://earthquake.usgs.gov/cfusion/hazfaults_2008_search/query_main.cfm. Accessed April 2024.
_____. 2024c. Earthquakes Hazard Program, Earthquake Catalog Search. https://earthquake.usgs.gov/ earthquakes/search/. Accessed April 2024.

USGS and CGS (United States Geological Survey and California Geological Survey). 2024. Quaternary Fault and Fold Database of the United States KML files. https://www.usgs.gov/programs/earthquakehazards/faults. Downloaded April 2024.

Youd, T.L. and D.M. Perkins. 1978. Mapping Liquefaction Induced Ground Failure Potential, in the Proceedings of the American Society of Civil Engineers, Journal of the Geotechnical Engineering Division.

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5.8 Greenhouse Gas Emissions
CARB (Air Resources Board). 2023. California Greenhouse Gas Emissions for 2000-2021: Tends of Emissions and Other Indicators. December 14, 2023. https://ww2.arb.ca.gov/ghg-inventory-data.

Accessed April 25, 2024.
_____. 2022. California’s Scoping Plan for Achieving Carbon Neutrality. November 16, 2022. https://ww2. arb.ca.gov/sites/default/files/2022-12/2022-sp.pdf. Accessed April 25, 2024.

BAAQMD. 2022. CEQA Air Quality Guidelines. https://www.baaqmd.gov/plans-and-climate/californiaenvironmental-quality-act-ceqa/updated-ceqa-guidelines. Accessed May 5, 2024.

IPCC (Intergovernmental Panel on Climate Change). 2022. Chapter 2: Emissions trends and drivers.

Contribution of Working Group III to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change. Cambridge University Press, Cambridge, UK and New York, NY, USA. https:// www.ipcc.ch/report/ar6/wg3/chapter/chapter-2/. Accessed April 25, 2024.

OEHHA (Office of Environmental Health Hazard Assessment, California Environmental Protection Agency). 2018. Indicators of Climate Change in California. May. https://oehha.ca.gov/media/downloads/ climate-change/report/2018caindicatorsreportmay 2018.pdf. Accessed April 25, 2024.

5.9 Hazards and Hazardous Materials
City of Santa Clara. 2014. City of Santa Clara General Plan – Chapter 5: Goals and Policies. https://www. santaclaraca.gov/home/showpublisheddocument/13934/635729106120730000. Accessed April 2024.

OEM (Office of Emergency Management). 2022. County of Santa Clara Emergency Operations Plan.

January 2022. https://emergencymanagement.sccgov.org/sites/g/files/exjcpb261/files/docu ment/2022%20EOP_County%20of%20Santa%20Clara_01.20.2022%20Accessibility%20Check. pdf. Accessed June 2024.

DTSC (California Department of Toxic Substances Control). 2024a. EnviroStor Database. https://www. envirostor.dtsc.ca.gov/public/map/?myaddress=santa+clara. Accessed April 2024. _____. 2024b. EnviroStor database. “Cortese List Data Resources.” https://www.envirostor.dtsc.ca.gov/ public/search?cmd=search&reporttype=CORTESE&site_type=CSITES,FUDS&status=ACT,BKLG, COM&reporttitle=HAZARDOUS+WASTE+AND+SUBSTANCES+SITE+LIST+%28CORTESE%29.

Accessed April 2024.

OSFM (Office of the State Fire Marshal). 2024. Frequently Asked Questions About: 2023 Fire Hazard Severity Zones., Updated March 11, 2024. https://34c031f8-c9fd-4018-8c5a-4159cdff6b0d-cdnendpoint.azureedge.net/-/media/osfm-website/what-we-do/community-wildfire-preparednessand-mitigation/fire-hazard-severity-zones/fire-hazard-severity-zones-map/2023-fhsz-faqsmarch-11-2024.pdf?rev=4652b9617dec4dceac0e6443b19cfe8f&hash= 9C503ABC051104ECE7CC0E7ECCB5FDE0. Accessed April 2024.
_____. 2024b. Santa Clara County, Fire Hazard Severity Zone Viewer. https://experience.arcgis.com/ experience/03beab8511814e79a0e4eabf0d3e7247/. Accessed April 2024.

SCCALUC (Santa Clara County Airport Land Use Commission). 2024. Airport Land Use Compatibility Plan, Santa Clara County, San Jose Mineta International Airport. https://stgenpln.blob.core.windows. net/document/ALUC_SJC_CLUP.pdf. Accessed April 2024.

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SWRCB (State Water Resources Control Board). 2024. State Water Resources Control Board GeoTracker, https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=santa+clara.

Accessed April 2024.

5.10 Hydrology and Water Quality
City of Santa Clara. 2014. City of Santa Clara General Plan – Chapter 5: Goals and Policies. http://santa claraca.gov/home/showdocument?id=13934. Accessed March 2024.

DWR (California Department of Water Resources). 2003. Bulletin 118 Update 2003 – Basin Report 2_009_

02. https://data.cnra.ca.gov/dataset/bulletin-118-update-2003-basin-reports/resource/20296ca 3-a155-4285-8786-b775b89b9033. Accessed March 2024.
_____. 2024. Bulletin 118 Groundwater Basin Boundaries Dataset. https://data.cnra.ca.gov/dataset/i08- b118-ca-groundwaterbasins. Accessed March 2024.

FEMA (Federal Emergency Management Agency). 2009. Online flood map 06085C0064H, effective 05/18/2009. https://msc.fema.gov/portal/search?AddressQuery=santa%20clara. Accessed March 2024.

SWRCB (State Water Resources Control Board). 2018. Final California 2018 Integrated Report (303(d) List/305(b) Report), Supporting Information Regional Board 2 – San Francisco Bay Region, Water Body Name: Saratoga Creek. https://www.waterboards.ca.gov/water_issues/programs/water_ quality_assessment/2018_integrated_report.html. Accessed March 2024.

5.11 Land Use and Planning
City of Santa Clara. 2014. City of Santa Clara General Plan – Chapter 5: Goals and Policies. http://santa claraca.gov/home/showdocument?id=13934. Accessed March 2024. _____. 2023a. MAP Santa Clara, Zoning Map. Updated January 1, 2023. https://www.santaclaraca.gov/ our-city/departments-a-f/community-development/planning-division/map-santa-clara.

Accessed March 2024.
_____. 2023b. Title 18 - Zoning Code. December 2023. [Online]: https://www.santaclaraca.gov/home/ showpublisheddocument/82067/638386835249500000

5.12 Mineral Resources
CDOC (California Department of Conservation). 1996. Update of Mineral Land Classification: Aggregate Materials in the South San Francisco Bay Production-Consumption Region. DMG Open-File Report 96-03. Downloaded from: https://maps.conservation.ca.gov/cgs/informationwarehouse/index. html?map=mlc. Accessed April 2024.
_____. 2024a. CGS Information Warehouse: Mineral Land Classification. https://maps.conservation.ca. gov/cgs/informationwarehouse/index.html?map=mlc. Accessed April 2024. _____. 2024b. SMARA Statutes and Regulations. https://www.conservation.ca.gov/dmr/lawsandregu lations. Accessed April 2024.

Google Earth. 2024. Identification of CEMEX Concrete Plant south of Montague Expressway. https://earth. google.com/web/search/CEMEX+Santa+Clara+Concrete+Plant,+Russell+Avenue,+Santa+Clara,+ CA/@37.38681316,-121.95740583,6.58677683a,1891.91957173d,35y,359.99980199h,0t,0r/ data=Cq0BGoIBEnwKJTB4ODA4ZmM5OWFlYWU0MzJiZDoweGQxZmJiZGZjMWQ3NjU4NGMZY npnWZyxQkAhsyodBzl9XsAqQUNFTUVYIFNhbnRhIENsYXJhIENvbmNyZXRlIFBsYW50LCBSdXNzZ NRS-KRS 115KV TRANSMISSION LINE PROJECT
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WxsIEF2ZW51ZSwgU2FudGEgQ2xhcmEsIENBGAIgASImCiQJ-NQjAbUCQ0AR-1fmKccBQ0AZS7- 1SBxAXsAhyiI8v61AXsA6AwoBMA. Accessed June 2024.

USGS (United States Geological Survey). 2024. Mineral Resources Data System. https://mrdata.usgs.gov/ mrds/. Accessed April 2024

5.13 Noise
City of Santa Clara. 2014. City of Santa Clara 2010 2035 General Plan. City Council adopted on November 16, 2010. Updated December 9, 2014. https://www.santaclaraca.gov/our-city/departments-a-f/ community-development/planning-division/general-plan. Accessed April 3, 2024.

FHWA (Federal Highway Administration). 2006. Roadway Construction Noise Model, User’s Guide. January. http://www.fhwa.dot.gov/environment/noise/construction_noise/rcnm/rcnm.pdf. Accessed April 3, 2024.

OPR (Governor’s Office of Planning and Research). 2017. General Plan Guidelines: 2017 Update. Updated September 2017. http://www.opr.ca.gov/planning/general-plan/guidelines.html. Accessed April 3, 2024.

U.S. EPA (U.S. Environmental Protection Agency). 1974. Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety. No. 550/ 9 74 004, Washington, D.C.

5.14 Population and Housing
City of Santa Clara. 2014a. City of Santa Clara General Plan – Chapter 5: Goals and Policies. http:// santaclaraca.gov/home/showdocument?id=13934. Accessed March 2024. _____. 2014b. City of Santa Clara General Plan – Appendix 8.12 Housing Element. https://www.santaclara ca.gov/home/showpublisheddocument/13932/635713044859030000. Accessed March 2024. _____. 2023. MAP Santa Clara, Zoning Map. Updated January 1, 2023. https://www.santaclaraca.gov/ourcity/departments-a-f/community-development/planning-division/map-santa-clara. Accessed March 2024.

California Department of Finance (CA DOF). 2023. E-5 Population and Housing Estimates for Cities, Counties, and the State, January 2021-2023, with 2020 Benchmark. Updated May 2023. https:// dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates-forcities-counties-and-the-state-2020-2023/. Accessed March 2024.

California Employment Development Department (CA EDD). 2023. Labor Force and Unemployment Rate for Cities and Census Designated Places – 2023 Annual Average. https://labormarketinfo.edd.ca. gov/data/labor-force-and-unemployment-for-cities-and-census-areas.html. Accessed March 2024.

5.15 Public Services
City of Santa Clara. 2011. City of Santa Clara Draft 2010-2035 General Plan – Integrated Final Environmental Impact Report, Volume I EIR Text. https://www.santaclaraca.gov/our-city/departmentsa-f/community-development/planning-division/general-plan. Accessed March 2024. _____. 2014a. City of Santa Clara General Plan – Chapter 5: Goals and Policies. http://santaclaraca.gov/ home/showdocument?id=13934. Accessed March 2024.

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_____. 2024a. Parks. https://www.santaclaraca.gov/our-city/departments-g-z/parks-recreation/parkspools/parks. Accessed March 2024. _____. 2024b. Agnews Historic Park. https://www.santaclaraca.gov/Home/Components/ServiceDirect ory/ServiceDirectory/321/2654. Accessed March 2024.
_____. 2024c. City of Santa Clara: Public Safety; Fire Stations and Police Stations within Santa Clara. https://missioncity.maps.arcgis.com/apps/MapTour/index.html?appid=15779cefd9bc463d8bc 6229b61d921d5. Accessed March 2024.
_____. 2024d. Santa Clara Police Department – Fact Sheet. Updated February 15, 2024. https://www.santa claraca.gov/our-city/departments-g-z/police-department/about-us/fact-sheet. Accessed March 2024.

5.16 Recreation
City of Santa Clara. 2014a. City of Santa Clara General Plan – Chapter 5: Goals and Policies. http://santa claraca.gov/home/showdocument?id=13934. Accessed March 2024. _____. 2024a. Parks. https://www.santaclaraca.gov/our-city/departments-g-z/parks-recreation/parkspools/parks. Accessed March 2024. _____. 2024b. Agnews Historic Park. https://www.santaclaraca.gov/Home/Components/ServiceDirect ory/ServiceDirectory/321/2654Accessed March 2024.

5.17 Transportation
Caltrans (California Department of Transportation). 2020. 2020 Traffic Volumes on California State Highways.” https://dot.ca.gov/programs/traffic-operations/census. Accessed April 3, 2024.

City of Santa Clara. 2011. City of Santa Clara Draft 2010-2035 General Plan: Integrated Final Environmental Impact Report. January 2011. http://santaclaraca.gov/home/showdocument?id=12900. _____. 2013. “2013 City of Santa Clara Bicycle Map”. http://santaclaraca.gov/home/showdocument?id= 1326. Accessed April 3, 2024.
_____. 2014. City of Santa Clara General Plan – Chapter 5: Goals and Policies. https://www.santaclaraca. gov/our-city/departments-a-f/community-development/planning-division/general-plan.

Accessed April 3, 2024.

VTA (Valley Transit Authority). 2021. Valley Transit Authority Transit Map. October 11, 2021. https://www. vta.org/sites/default/files/2021-10/VTA_MainMap_101121.pdf. Accessed April 3, 2024.

5.18 Tribal Cultural Resources
City of San Jose. 2011. Envision San Jose 2040 General Plan. Adopted November 1, 2011.

Golla, V. 2011. California Indian Languages. University of California Press, Berkeley.

King, C.D. 1977. Matalan Ethnohistory. In Final Report of Archaeological Test Excavations of Freeway 04 SCl-101, Post Mile 17.2/29.4, Cochrane Road to Ford Road, edited by S.A. Dietz. MS on file, S 4395, CHRIS/NWIC, CSU Sonoma, Rohnert Park.

Levy, R. 1978. Costanoan. In California, edited by R.F. Heizer, Volume 8. Handbook of North American Indians, W.G. Sturtevant, general editor, pp. 485-497. Smithsonian Institution, Washington, D.C.

NRS-KRS 115KV TRANSMISSION LINE PROJECT
JULY 2024 B-11 ADMINISTRATIVE DRAFT MND/IS
Margolin, M. 1978. The Ohlone Way: Indian Life in the San Francisco–Monterey Bay Area. Heyday Books, Berkeley.

OPR (Office of Planning and Research). 2017.Technical Advisory: AB 52 and Tribal Cultural Resources in CEQA. https://www.opr.ca.gov/docs/20200224-AB_52_Technical_Advisory_Feb_2020.pdf.

5.19 Utilities and Service Systems
CalRecycle 2024a. Facility/Site Summary Details: Newby Island Sanitary Landfill (43 AN 0003). https://www2. calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1362?siteID=3388. Accessed March 2024. _____. 2024b. Facility/Site Summary Details: Guadalupe Sanitary Landfill (43-AN-0015). https://www2. calrecycle.ca.gov/SolidWaste/Site/Summary/3399. Accessed March 2024. _____. 2024c. Facility/Site Summary Details: Corinda Los Trancos Landfill (Ox Mtn) (41 AA 0002). https:// www2.calrecycle.ca.gov/SolidWaste/Site/Summary/3223. Accessed March 2024.

City of Santa Clara. 2014. City of Santa Clara 2010 2035 General Plan. City Council adopted on November 16, 2010. Updated December 9, 2014. https://www.santaclaraca.gov/our-city/departments-a-f/ community-development/planning-division/general-plan. Accessed March 2024.

City of San Jose. 2024. San Jose–Santa Clara Regional Wastewater Facility. https://www.sanjoseca.gov/ your-government/departments-offices/environmental-services/water-utilities/regional-waste water-facility. Accessed March 2024.

Silicon Valley Power. 2023. Utility Fact Sheet. Electric Utility: City of Santa Clara. January-December 2023. https://www.siliconvalleypower.com/svp-and-community/about-svp/utility-fact-sheet.

Accessed March 2024.

5.20 Wildfire
CAL FIRE (California Department of Forestry and Fire Protection). 2007. Santa Clara County Fire Hazard Severity Zones in SRA. Adopted November 7, 2007. http://frap.fire.ca.gov/webdata/maps/santa_ clara/fhszs_map.43.pdf. Accessed April 1, 2024.

5.21 Corona and Induced Current Effects
IEEE (Institute of Electrical and Electronic Engineers). 1971. Radio Noise Subcommittee Report – Working Group No. 3. Radio Noise Design Guide For High Voltage Transmission Lines. IEEE Transactions on Power Apparatus and Systems, Volume PAS 90, Number 2, p. 833. _____. 1979. J.E. Bridges and M.J Frazier. The Effect of 60 Hertz Fields and Currents on Cardiac Pacemakers.