Reponse to PG&E's Letter

Go to Project History and CHA Concerns
Go to the Media Alert/Resolution to Board of Supervisors
Go to Flyer to Cow Hollow Neighbors - Dec. 19, 2003
Go to How to Get Involved

View EMF Fact Sheet
View Route Options

Our informational comments and responses to the December 12, 2003 PG&E letter follow in red italics.

12.12.03 LETTER FROM PG&E
Gary Tognozzi
Superintendent General Construction
2180 Harrison Street
San Francisco, CA 94110

As you may know, Pacific Gas and Electric Company is working to supply power by July 2004 to the Letterman Digital Arts Center under construction at the Presidio. To do so, it is necessary to trench along Filbert Street between Lyon and Fillmore.

It is not necessary to trench along Filbert Street, since the Fillmore-Filbert-Lyon Street route is not the only possible route. A more thorough and public review needs to be conducted discussing the alternatives, including the uninhabited open space adjacent to Marina Boulevard and into the Presidio, and power generation from within the Presidio itself.

This power line will be underground and the disruption will be temporary. The work will be done in accordance with all permit restrictions.
In recent months we have attended a number of community meetings, responded to letters and fielded numerous phone calls from neighbors concerned about the project.

We are writing because there appears to be an enormous amount of misinformation circulating about the project’s impact and we wanted to clear up any misunderstanding you may have.

PG&E’s Obligation To Serve: PG&E is currently working to construct a 12,000-volt (12 kV) distribution circuit to the Letterman project.

A 12,000 volt (12 kV) distribution line to Letterman, yes, but a second conduit will be placed in the open trench to receive another 12,000 volt (12 kV) distribution circuit for future development, as acknowledged by Mr. Tognozzi on 11.19.03, which will most probably be in the Presidio with new housing units planned.

Once Letterman applied for new power service in October of 2001, PG&E became obligated to supply the power pursuant to our California Public Utilities Commission mandated duty to provide electric service. In this case, Letterman requested power by July 1, 2004. We are treating this customer just as we do any customers requesting new service, be it a residence, hospital, school or high rise - they are entitled to power and we are required to provide it.

The Route: Pursuant to our duty to provide service, PG&E selected the trench route -- as it does for every project -- based on engineering criteria, such as adequacy and reliability of electric supply and efficiency of construction, as well as approval from appropriate permitting agencies.

Mr. Tognozzi stated at the 10.23.03 Community Meeting that the reasons the Greenwich now Filbert route was selected are to:
1. Tie circuits together for reliability of service - PG&E chose to tie into a circuit at Chestnut and Fillmore en route to Greenwich, and now Filbert

Response - PG&E could have made it a destination line

2. House a capacitor(s) - 1 capacitor for each powerline, 2 possible powerlines, thus 2 possible capacitors. PG&E elected to mount the capacitor for Lucasfilm Ltd. on an existing utility pole; the only poles left near the east wall of the Presidio are located at Lyon/Lombard, the Greenwich corridor, and Filbert at Baker and Broderick; capacitor could have been pad mounted and placed on the ground in the Presidio; PG&E stated they did not want the capacitor on federal property because PG&E did not want the Federal Government taking over and running the equipment in a time of emergency; now. PG&E has backed off that statement and states that the Presidio Trust did not want the capacitor on Presidio property from the onset

Response - capacitor should have always been planned to be located in the Presidio; negotiations are now taking place to locate the capacitor in the Presidio, which of course changes the need to run the powerline where utility poles currently exist - Filbert, Greenwich, Lyon

3. Cross Highway 101 (Lombard) at Fillmore - PG&E stated it was safer to cross Lombard at Fillmore than Richardson (Hwy 101) at Francisco (straight-line route) due to the speed of traffic

Response - Taking the Marina Blvd. Route entirely avoids crossing Hwy 101; if the Francisco route were selected, vehicles would be slowed down "in the cone zone" on Richardson as with any highway project

4. Alhambra/Francisco is the straight-line route, but 3 blocks of Francisco had been recently repaved and a 5-year moratorium keeps most construction projects from occurring.

Response - in the distribution of power, if it saves the ratepayers money, trenching a recently repaved street can be considered; to travel 8 blocks off the straight-line route to Filbert is costing PG&E, therefore the ratepayers, $1.2 million ($150,000 per block)

The route for this project satisfies the above criteria because it made the most sense from an engineering perspective and was the one route for which we could secure necessary permits.

We have no information on the feasibility of any other route. The request to Mr. Tognozzi to receive PG&E's cost analysis to trench on Fillmore-Filbert-Lyon vs. Alhambra/ Francisco has been repeatedly denied. If PG&E had considered the Marina Boulevard route adjacent to the Marina Green, they would not have needed to apply and pay for a permit from CalTrans to cross Hwy 101

Again, while we understand the neighbors’ concerns, the only possible result of re-routing the project, even if it were feasible, would be to shift the project to another street in the area.

Re-routing would not necessarily shift the project to another street if it could travel adjacent to the Marina Green. PG&E stated that that route was never considered yet could be the most efficient and economical. Moreover, a direct route would minimize the number of residents affected by the "project"

Health and Safety: A few Cow Hollow residents have misstated that this project would bring dangerous levels of power and risk the health of local residents by exposing them to high levels of electric and magnetic fields (EMF). We want to be absolutely clear on this point: PG&E is complying with all environmental regulations.

WE DON'T AGREE: CNFFL 11.26.03 LETTER TO CPUC
There has been no Environmental Impact Report (EIR) or Negative Declaration that are the minimum requirements of the California Environmental Quality Act (CEQA), Pub. Res. Code §§ 21000 et seq., or evidence of any environmental clearance of any kind, formal or informal. DPW has ignored the Project's potentially significant and undesirable environmental impacts. As a matter of common practice, such impacts must be brought to the public's attention so that alternatives may be sought and mitigation of adverse impacts may be planned. PG&E now asserts, by its letter of November 12, that the small portion of the project that is under CalTrans's jurisdiction is exempt from CEQA per "the General Orders of the CPUC," but cites no specific authority for this proposition; nor does it even mention the CEQA responsibilities of the City of San Francisco, which has jurisdiction over the lion's share of the Project.

There has been no consideration of the "Precautionary Principle" that is a new City policy applicable to all agencies and all businesses operating here effective this past summer. Ch. 1 § 101 SF Environment Code. Key elements of this new policy include adequate notice to the community, a considered analysis of the human health risks of various alternatives, and a transparent and participatory decision-making process. DPW failed to consider reasonable alternatives to the current location of the Project, which passes through densely populated residential and neighborhood commercial areas, along the side and front of Marina Middle School and in close proximity to underground petroleum tanks.

This is not a high-voltage transmission line, as some have incorrectly alleged, but a 12,000-volt (12 kV) distribution line. This is standard voltage for distribution lines throughout PG&E’s service territory, including San Francisco. In other words, the power PG&E intends to supply to Letterman is neither excessive nor atypical. In fact, there are more than 250 circuits of underground and overhead electric lines throughout San Francisco. Most of the power lines in residential neighborhoods are 12,000 volts (12 kV), but range from 4,000 volts (4kV) up to 230,000 volts (230kV).

Again, PG&E has not even discussed watts, only volts. We understand that Filbert Street has an existing 12,000 volt (12 kV) distribution line, which carries a load of approximately 2,000,000 watts (2 mW); Lucasfilm needs 8,000,000 watts (8 mW) of supplied power, but had initially requested 12,000,000 watts (12mW), which the line can carry; the 2nd conduit has the same capacity - 12,000,000 watts (12mW); in the future, with the projected development in the Presidio and when both lines carry power, the street could have thirteen (13) times the amount of wattage that it currently has (26mW vs. 2mW), on three 12 kV lines (vs. the current one 12 kV line). Is this typical for a residential neighborhood to carry up to 26 mW on three 12 kV powerlines?

As to concerns about EMF, EMF is present where electricity is used. This includes distribution lines, but also the building wiring in homes, offices, and schools, and in the appliances and machinery used in these locations. The California Public Utilities Commission (CPUC) and California Department of Health Services have not concluded that exposure to magnetic fields from utility electric facilities is a health hazard. For more information about the California Public Utilities Commission’s EMF policies, please visit the CPUC’s website at: www.cpuc.ca.gov/static/industry/environment/electromagnetic+fields/index.htm.

PG&E is only telling half the story: The CPUC and the California Department of Health Services (DHS) have not reached a conclusion either way on EMFs -- safe or not safe. Given the uncertainty, they have begun instructing the utilities to take reasonable measures to minimize the potential risks. What PG&E didn't direct us to is the California Department of Health Services EMF Long Fact Sheet as referenced earlier in the beginning of this letter. Again, the amount of wattage determines the strength of the magnetic fields, which don't reach low background levels until 60 - 200 feet from distribution lines, such as the Lucas Powerline.

PG&E is installing all underground facilities in strict accordance with the safety rules of the California Public Utilities Commission, including meeting proper depth for underground electric facilities and shielding of power lines.

Notice: On August 19, 2003, PG&E sent 30-day construction notices to all 1,240 residents and property owners directly along the construction route in accordance with notice procedures required by the City and County of San Francisco. We have subsequently verified this advance notice was properly completed.

DPW (Public Works Code 2.4.50) requires "…the permittee shall provide written notice…to each property owner on the block(s) affected by the excavation and each affected neighborhood and merchant organization that is listed in the City Planning Department's Directory of Neighborhood Organizations and Service Agencies. The latest City-wide assessor's roll for names and addresses of owners shall be used for the mailed notice. . ."
No neighborhood organizations received the notice, only individuals associated with the organizations, and no names were used in addressing the letters. The Public Works Code, thus the notice was not properly completed.

Capacitor: Per the request of Cow Hollow neighbors, PG&E is working with the Presidio Trust to evaluate the relocation of a capacitor on Trust property and, therefore, out of view of local residents. We will notify neighbors as soon as we know more.

It is interesting that we could have an influence on the location of the capacitor, but not on the location of the route. PG&E received the 10/10/03 letter from the Cow Hollow Association, which represents 1100 housing units, to oppose the selected PG&E Power Line Route for the Letterman Digital Arts Center through the Cow Hollow neighborhood, and to request that no work commence on the Filbert Street corridor. This was days before the trenching turned the corner at Bay and Fillmore, yet there was no response from PG&E. When a few concerned neighbors were invited to walk the neighborhood with representatives from PG&E and DPW on 11.19.03, no criteria were used for selecting the location for the capacitor. Mr. Tognozzi concluded that residents may not like to look at the 8 ft wide x 2.5 ft x 2.5 ft capacitor approximately 35 feet up a pole at Filbert and Broderick, so he moved the capacitor to Filbert and Baker, and then thought about moving it to Lyon and Lombard. Before DPW could review that location, PG&E that day had replaced the 35 ft pole next to Liverpool Lil's with a 50 ft pole in order to house the capacitor at that location. Then Mr. Tognozzi suggested, after EMF concerns affecting the nearby apartment building were raised by DPW's Cynthia Chono, that the better location would be across the street on Lyon next to the stone wall at the Lombard entrance to the Presidio. Looking up the hill and noting all the homes that would be impacted by the pole-mounted capacitor, discussion involved pad mounting it next to the wall, which would leave approximately 7 feet of sidewalk for pedestrians. We all concluded in the end that the capacitor should be in the Presidio. In addition, the capacitor location is not only a view issue, but also a planning (why not in the Presidio?), health (unknowns around EMFs), and safety (8 ft (wide) x 2.5 ft x 2.5 ft box approximately 35 feet up a utility pole) issue.

Again, we appreciate your concerns and hope we have provided some useful information. We expect to complete the substructure portion of this project, weather permitting, in January 2004, working around the holiday moratorium. Thank you for your understanding.

Should you have any additional concerns please feel free to contact PG&E at (415) 695-3451.

Sincerely,

Gary Tognozzi