READER’S EDITORIAL: WHAT YOU SHOULD KNOW ABOUT SDG&E’S PROPOSAL FOR CLEVELAND NATIONAL FOREST

By Cindy Buxton, Chair, Forest Committee of the San Diego Sierra Club

“This is the general “neck of the woods” of the famous Cedar Creek Falls and Three Sisters Waterfall… We are hoping for universal outcry to insist that all parties, SDG&E, the CPUC, and the USFS will embrace this as the golden opportunity to evolve community safety and environmental integrity forward.” – Cindy Buxton

October 21, 2013 (San Diego’s East County) -- The U.S. Forest Service (USFS) sent out its request for scoping on SDG&E’s Master Permit renewal.  The comment period is through November 7th.   Document links are provided at the end of this editorial.

The Forest Service, in an attempt to consistently and effectively manage wilderness and wilderness-like portions of their Forest, recommends moving the 626 69kV line that runs up Boulder Creek Road out of these fragile areas and makes this suggestion along with a mile or so wide corridor for study where portions of the line could be moved. But there more to this proposal than meets the eye.

The terrain

This is the general “neck of the woods” of the famous Cedar Creek Falls and Three Sisters Waterfall, getting as many as a thousand visitors in a weekend and more if the USFS for safety reasons didn’t limit the crowds. Given that deer season begins this week it bears mention that it is also one of the most popular hunting areas around.  All deer tags were sold this year!

The lines cross the streams flowing into these two popular hiking destinations upstream of them  in extraordinarily scenic, wild , rugged, and remote canyons.  The consequential over grading has resulted in serious silting issue and access road beds over six feet below grade and grades in excess of 40 %, chronically in excess of 30 % making runoff inappropriately ineffective and difficult to mitigate.

These two streams are a significant component of the Greater San Diego River Watershed.  For these reasons and a host of others,  I do not dispute the given reasons by the USFS for wanting to move the lines away from the gorges. In fact I would applaud at long last a courageous stand taken. -With some caveats. Namely, we need to assure a fair and significantly improved alternative. 

Why your voice matters for a project scoping

The purpose of a Federal “Scoping” request on a project as dictated by the National Environmental Policy Act or NEPA, (not to be confused with its California distant cousin, CEQA) , is to establish some alternatives that would be worthy for an already massively overburdened and thinly stretched local Forest Service  (all snickers about some of their recent early Christmas “vacation” aside- many of these guys were up and working)  to narrow down for more time, money, and effectively used resources to study in detail. Once this is accomplished, these alternatives will receive a more thorough environmental review also out for public comment, called a Draft environmental impact statement or DEIS, before yet another period to publish a final.

 But that’s not all… If you comment, and provide “substantive “ (loosely determined depending on the opinion of your attorney, we hope only in jest) you are then a commenter of record meaning you have “standing” and can challenge that final EIS or FEIS if you can. Wow the forces that be with a really good argument for doing so. 

Generally the USA has made it this far because at the end of the day,  our government works seriously and this is without questions its finest hour- your ability to weigh in to agency “stuff”.  With all of this public participation, democracy is a great thing.  This is likely the biggest area of government where the average guy can make monumental impact.  It’s not just on the forest.  If you want entertainment on a rainy Friday night, explore the comments to other agency projects, from the IRS to the SEC and sub agencies as well (if you consider the Forest Service is under the Dept of Agriculture) and you’ll see many times where one knowledgeable, or even less than knowledgeable  but impassioned  person weighing in on a government management decision made a difference

We are in a scoping period and looking for alternatives to explore further. Get in now, during scoping,  to have the most say so  upstreamThis insures the most significant building blocks of a plan make their way into consideration.  It can also matter who is doing the considering.  In the case of the Cleveland National Forest, I’m very optimistic that Forest Service officials will do their best to consider the public’s concerns.  With some of the mysterious state players that have wormed their way into land decisions way down here in San Diego it is much more difficult to tell.  

The larger of the two docs I posted have some detailed suggestion for effectively approaching your comments.  However even if you just  like or don’t like the plan, making that known is a positive.  The beauty of the little corner of our democracy is that it really is for once, about us. Just do it.

The plan at hand—my observations

I’m attending the open houses for more clarity.  This is a very convoluted project interfacing all kinds of junky history and other projects and other addenda.  Maybe they will completely change my mind tomorrow.  Could happen but don’t count on it!  The better outcome of course is that we all team up and find a community win-win no matter what a politician light years from here thinks.  Since the Sunrise Powerlink we’ve used this took to turn the tide several times and made interesting collaborations along the way where we surprised others, thinking it was not possible.

Here are my observations so far.

1) First and foremost, we do not support using private lands for this mitigation.  Not a nanometer. The intention is honorable but it does not call for this drastic measure. Nor would it really help for most of the stated issue.   We are appalled at any suggestion, from the given and rather general map provided that the line would be moved onto private or reservation lands as a means of improving this line.  There are other viable alternatives but this one is most unacceptable. We have seen too much of fixing a problem only by moving it.

2) Given already so far a very thorough review of the geography, foot to the ground as it were, I see no above ground alternative that is an improvement.  The stated study corridor may result in brining power where it doesn’t currently exist but even though this would be the time to make that change to route for a particular coverage it should be stated as being for that purpose.  Such is the case in the suggestion of taking this through the Inaja Reservation. If they have requested that alignment for energy purposes, who could blame them?   I do know the geography of Cedar Gorge passing through the Inaja Reservation.  It is every bit as breathtaking and remote wilderness-like character, sensitive and critical habitat as in the forest.   It is their sovereign nation; they decide if it is their goal.  I know of no reason for an above ground alignment there of an urgency that would warrant forcing this there.  There is the underground one however I’m getting to.

2) The threat of fire could be reviewed at that qualifying urgency. The time has come to put an end to the fire and environmental issues created by locating these lines in close association to extreme fire hazards in our back country.   The issues with maintaining corridors and vegetation management are as problematic as the lines themselves.  It is time to put them underground in total and this is the best opportunity to make that investment as a community once and for all.  

One caveat-that would be under or directly beside a road where the access is viable-NOT going cross country.  Cross country undergrounding has serious environmental issues of its own.   This means getting them under or next to public county roads.   What does this mean for forest management?  A lot as it still affects the easement and impact to the forest.  It is not a sure in but should be seen as an alternative that warrants much more consideration than the current scoping request gives it.  The original plan came from SDG&E and much influence by the state upon them-not from us here locally who live with this deal.   In 2004 SDG&E made an offer to combine a 69kV and a 128 kv and UNDERGROUND it near Jamul for less money per mile than they are suggesting that this will cost above ground.  I think that accounting needs more study as well!   They seem to mention with spunk and enthusiasm the undergrounding possibility when it is to their benefit.  Well natch, ok? But we need to insist that we have spunk and enthusiasm too!  It IS our forest, ok? Remember how much they wanted the Northern route of the Sunrise Powerlink?  Remember one of their alternatives was to underground for many miles out in the desert.  So if they can there with ease, and in Jamul even easier, why all of a sudden is it so impossible and remove the threat of fire and a host of annoying and controversial environmental issues once and for all for this master permit. 

That would have to be the predominating and central appeal for a community uprising.  Get’er done and be done. -because we are sooo done….   

 The inevitable threat by fire, the impedance to fire response, the constant erosion into our watershed , the blight upon scenic integrity, and maybe the worst of all the constant controversy among our people in having to keep one eye on these projects needs to come to an end.  Undergrounding – more precisely undergrounding under county roads, not cross country is THE way to end this nightmare once and for all.   We are hoping for universal outcry to insist that all parties, SDG&E, the CPUC, and the USFS will embrace this as the golden opportunity to evolve community safety and environmental integrity forward.

3) Some of the lines are lightly used and should receive as an alternative conscientious study to be removed completely.  The 69kV that runs the face of Cuyamaca, -only the most visible force of nature on our skyline from down town, has one local distribution line running to one local user all the way from Descanso to Santa Ysabel.  In the meantime there have been numerous upgrades to the local grid on both sides of this remote, unique, and very sensitive, while highly and growing popular Forest corridor.  For our number one suggested alternative for the 626 line specifically up Boulder Creek road is that rather than ANY new study of yet another cut and impact where the  whole idea is to preserve  a particularly wild and scenic and rather small corner of the Cleveland Forest, why add more if you don’t have to.  What we have paid for maintenance in rugged areas would pay for undergrounding many of the other areas.   

A clarification, there should be no one left without power.  Anyone who has it now should have it when they are done.  Not everyone is on the grid.  The 69kv line runs the top of the current power lines.  Under it is a simple 12kv line.  This is a distribution line that severs local users.   I’m suggesting that they remove the 626 69kV line.  I’m also suggesting that they put the remaining 12 kv distribution line underground. Done.

There are two or three ranches north of the areas of sensitive impact.  These should without question be provided a solar alternative for reasonable perpetuity.  Much cheaper than what we are doing now. One is the oldest ranch in San Diego ; let’s give ‘em a break, they are the living voice of our history and the should be honored for their place in it and the value the give to our forest by still having that voice  and living presence and not over sanitizing the colorful character of the past.  

4) Did you know that the 12 kv is the only line turned off in high winds?  Apparently the 69 kV above is still on.  These HAVE broken in the past and they HAVE started fires in the past.  The most inexpensive thing is to remove the ones we don’t really need.  This brings me to the final point about this process for now.

5) These lines are being replaced with lines that have as much as five fold capacity as the ones they replace.  The stated purpose is fire hardening.  But if they go underground this is no longer the case.  Huh?  However if there is another purpose that requires more capacity—five-fold more in fact—it must also be stated according to the NEPA rules of disclosure (which state you don’t have to make  a smart decision but you do have to provide enough information for an informed one).  I must clarify as such, if there is an additional reason for beefing up the amperage and wattage, IT MUST BE DISCLOSED or removed from the issue for good.

No more double talk! We need this done once and for all. Anything else is pushing the boundary of abusive actions for the years we’ve endured this string of energy projects.

My concern is with an increase in amperage. Voltage remaining the same, the wattage must be increasing five fold. What are the ramifications of this? Aren’t they supposed to be explaining in dtail? This also creates a much higher capacity for this line. They have not disclosed this, to the contrary they maintain they don’t need to because of the static voltage. If this is going up because they anticipate ANYTHING more making use of that added wattage, how is that not information I would need to make an informed decision? Or more precisely, the Forest Supervisor to make an informed decision?

I would beg to differ. I’ll elaborate:

They are replacing a ½ inch wire with a whole inch wire. The cross sectional area of a wire is directly proportional to the increase in amperage.  Voltage x Amperage = Wattage

Doing the math (by all means correct me if necessary)    ½ in for the pi r2 rules = .785, 1 inch = 3.14  and 3.14 divided by .785 is 4.  THEN the engineer for SDG&E also with the right questions disclosed that the temperature of the line goes from 190 to 270 or an additional increase of 42%  on top of 4 is 5.86.  So if we have a constant 69 kv (volts) but the amperage is now 5.68 times as great than the wattage is now 5.68 times as great.  That is WITHOUT changing the voltage which SDG&E has stated in their notice of intent that they are ardently insisting will not change.  Ok 69 it is.  But then please explain how in the laws of science this could imply anything less than the potential fivefold increase in wattage capacity.   If the voltage were to change 5.68 times instead of the amperage the wattage would still be increasing by 5.68 times as much.  That is to say that the new lines will be getting the bump in electricity that would be the EQUIVALENT of increasing the voltage to 391 kV.  The two lines that came off of the Sunrise Power link and taken underground into Alpine were both 230.  The one going from the desert, through the “south route” and up to Bell Bluff was 500kv.  This is in-between just with higher amperage and lower voltage.  Is it as efficient as using higher voltage.  I’m inclined to doubt it.  But we should ask! That is what we do in a scoping.  I seem to recall there is significant drop in power with the length of the wire.  The type of wire being used is more commonly used for 230kv.  They have suggested using it for 12 kv as well.  If this is underground that may not be necessary. 

But wait that is not all!   The new permit calls for more of these lines on one larger pole between three more on single circuit PLUS several more 12 kv’s also one inch.  And the new permit says that some lines will be double circuit.  So they will have 6 of these 5 fold wattage busters for 69 kV and 6 with a 5 fold wattage buster for the 12 kv.  There is a lessor used line , a 340 kV. If we suggest they may be going to that which they are required to disclose this would then be 6 times 340 PLUS 6 time 5 times the 12 in added capacity of a double circuit. A whopping increase in the equivalent of a 2400 kV line!!   Someone with some physics of these things need to step in and explain!  Obviously this opens a can of worms of technical issues that I’m sure could not be right.

That one I can give a temporary answer to: I asked the project manager who asked them.  Recall in December of 2012, Miriam interviewed the Forest  Supervisor who said they would not be expanding up Boulder Creek Road and hence the miracle new Land Management Plan (LMP)would reflect the protection of our backcountry in this areas from this potential expansion.  Clearly the January 2012 MOU between SDG&E and the USFS does not indicate any disclosure to our Forest Supervisor that they were planning to sneak in a 15 to 31 fold increase in capacity. Hence I , me the writer, MUST be spreading rumors.  He’s lucky I like ‘em for that miracle LMP… well apparently they took another look at the numbers.  “Cindy”, you were right. (yea , I love it when that happens! ) but SDG&E doesn’t believe they should have to disclose because the current substation cannot handle an increase in voltage. Well somewhere in there I did mention that this was increasing amperage and SDG&E insisted that the voltage would be the same.

Time for action

Ok so if you get something from this, find an open house and go ask A LOT of Questions!         

While you are at it, please ask, if this is a catch all , all sizes fit all project plan which included the state authority and CEQA as well does this now mean that  if they have a current single circuit such as the 626 it can “turn into “ a double circuit without further public disclosure and commenting process?   That would be seriously pivotal and something that HAS TO be made clear now in order to make that informed decision.

What is the ultimate difference in the experience of wattage by amperage vs wattage by voltage.  I don’t know. Without question SDG&E must be explaining this much more. Lower voltage sounds a tad safer but it doesn’t sound efficient.

That brings up one other point. Aren’t we supposed to be developing our energy infrastructure on the roof, in town, not slipping in as much as 15 to 30 times the capacity across the backcountry?  Gee where is all of that going when the county is not letting us subdivide –likely a very good thing, too! ?

Thank you for reading and caring about our backcountry!

Document links: 

I could not find a direct link to this announcement so I uploaded mine to a Hotmail public SkyDrive where you can access this announcement and some other relevant materials including a more lengthy opinion so far.  Maybe we will see it appear on their site soon!  (Editor’s note: The USFS has added a link on its site for documents here.)

The bulk of the official information is also on the CPUC web site here though not as user friendly.. My SkyDrive public folder: ON the sky drive are the two announcements (1) (2), some photos of the new study areas and some maps, one of which is my first draft and a USGS topo map that actually shows the relationship of this project to the private inholdings.

Additionally, here are two very recent videos of the lower half of the study area suggested for the 626 transmission line. http://www.youtube.com/watch?v=2bQnCMrIGd4 and http://www.youtube.com/watch?v=5MYAQzpDBcU

The opinions in this editorial reflect the views of the author and do not necessarily reflect the views of East County Magazine. To submit an editorial for consideration, contact editor@eastcountymagazine.org.