Also troubling is the fact that the SPL allows SDG&E to avoid using or supporting in-county energy sources that are already available from its competition. Our understanding is that SDGE can recognize 10-15% profit on any infrastructure the CPUC authorizes it to construct.  However, the company gets no mark-up for buying power from third parties, such as those that own the existing Encina or South Bay power plants or even Sterling Solar.  Therefore, SDGE has a large monetary incentive to squeeze out other power suppliers, which is probably one of the main reasons why they won’t sign long-term contracts to modernize the coastal power plants even though in-county generation is recognized as a preferred energy solution. This is also why the contract terms with Sterling Solar will most likely assure the failure of that contract.  However, the fact that ratebasing policy is still not aligned to reward the state’s preferred loading order as outlined in the Energy Action Plan does not mean we should ignore the EAP and approve this project.

It’s clear that this project is not aligned with state policy priorities and it’s claim toward securing renewables is a shoddy attempt to dress up an inferior strategy. Note the Imperial Valley Board of Supervisors voted 4-0 against this project for this very reason.  Renewable energy sources in the Imperial Valley can already be accessed with the SWPL transmission line, provided the line isn’t congested with SEMPRA’s fossil fueled energy traveling from Mexico through San Diego to points north or the independently proposed Green Path transmission line already in the works.  The $1.3 billion dollars of ratepayer money that would be spent on the SPL could then be better spent toward developing local distributed generation and renewable resources like roof top solar to more efficiently add power in the San Diego region and make us less dependent upon power imported from outside the region, thereby alleviating the congestion problem on current transmission lines.

I believe there are more efficient, local alternatives that will better add reliablility and renewables to our energy mix and that have fewer harmful impacts on our parks, preserves and communities and that approving this project will squelch the momentum and incentive to pursue these superior alternatives.

Our other point of opposition to this project involves the route chosen.  In addition to the habitat destruction this will cause in Anza Borrego State Park, there is the risk to our own community, Carmel Valley, which borders the edge of the Los Penasquitos Preserve.  This community has already accepted more than it’s fair share of the power infrastructure.  SDG&E proposes to add massive steel and concrete pilons holding 230Kv in addition to the ugly erector set style structures that already tower over people’s homes and scar the Los Penasquitos Preserve. The rationale for not needing to mitigate this impact is that we are already impacted by some transmission lines now.

We would like to point out that the existing overhead lines in this community were put in before the expansion of community development and they are no longer appropriate given the additional voltage proposed and number of homes now in close proximity.  If EMF exposure is not a real enough concern for SDG&E or the CPUC to consider, there is also the increased wildfire risk in an area that already has a significant fire load (due to the dense vegetation of the Preserve) and that suffers from inadequate fire and rescue response times (due to the lack of a nearby fire station). There are the collision risks posed by birds from the preserve and low flying military helicopters from MCAS Miramar, and, finally, there are the visual impacts of the taller, more intrusive metal and concrete pilons that are proposed to be added along the with additional 230Kv of power.

The implication that our fire, health, safety and aesthetic concerns somehow count less because we are already impacted by some transmission lines is unacceptable and I would argue quite the opposite.  Undergrounding options were not seriously evaluated for this part of the Preserve as far as I know and the lack of the examination by SDG&E of any less invasive implementation in this neighborhood and the Preserve shows a complete lack of concern for local ratepayers, their home values and their treasured, shrinking open space.

We are acutely aware of the corporate and governmental pressures at play here and the risk of the so called “federal hammer”.  We urge you, however, to be unbiased in your evaluation of this project.  Assume state sovereignty and follow state energy policy and examine if this is truly the best solution for our future energy needs or simply the only solution SDG&E and SEMPRA are willing to offer.