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Informed Opinion Comment Guide

CENSE thanks you for commenting.

The Hearing Examiner advised that the most efficient way to comment on Energize Eastside is to state why you disagree with a statement in the City Staff Report and cite the page number.

  1. Address your comments to the Hearing Examiner at hearingexaminer@bellevuewa.gov
    CENSE would appreciate it if you bcc us at hearing@cense.org
  2. Alternatively, you may send your printed comments via U.S. mail to:
    Hearing Examiner’s Office, 450 110th Av NE, Bellevue, WA 98004
  3. Include your full name and address
  4. Limit each letter to one topic. You can make multiple submissions.

Click on your topic(s) of concern below for ideas on how to comment.

Ideas for writing about how the project will impact your property

LUC 20.30B.140.D states that the project should not be materially detrimental to uses or property. Refer to this Land Use Code if you want to comment on how larger transmission lines and poles would affect your property and neighborhood. Include photos, if possible. For example, you could describe the aesthetic changes that would result from removing trees, wires obstructing your views, or potential safety issues posed by steep slopes or proximity to Olympic pipeline. If you have talked with a realtor you might want to share their comments about how the project might affect the sale of your home. Or you might want to share any mitigation agreements you have made with PSE, listing what is to be removed and what will be provided for mitigation.

Ideas for commenting on City Staff Report

City Staff Report claims: The City Staff Report concludes that PSE’s proposal complies with the following Land Use Codes:

  • Where feasible, the preferred site is located within the land use district requiring additional service and residential land use districts are avoided when the proposed new or expanded electrical utility facility serves a nonresidential land use district. LUC 20.20.255.E.5.b (See City Staff Report pages 98, 112)
  • The proposal shall provide mitigation sufficient to eliminate or minimize long-term impacts to properties located near an electrical utility facility.
    LUC 20.20.255.E.6 (See City Staff Report pages 54-85 96-99, 103-106, 113-119, 128-139, 143-145)
  • The design is to be compatible and responds to the existing OR intended character, appearance, quality of development and physical characteristics of the subject property and the immediate vicinity. LUC 20.30B.140.B (City Staff Report pages 82, 98, 116, 119-122)
  • The conditional use will not be materially detrimental to uses or property in the immediate vicinity of the subject property LUC 20.30B.140.D (City Staff Report pages 82, 121-122)

CENSE counterclaim: LUC 20.20.255.E.5.b Larger poles and higher voltage lines do not belong in residential neighborhoods. PSE claims non-wired alternatives are not feasible. For this reason, the city will allow PSE to construct 80% of the larger power line in residential areas, (page 33) even though, “Most of the population and employment growth in Bellevue to be served by the Project is expected to occur in non-residential zones and mixed-use zones.” (page 112). Only 19% of the line would pass through commercial or industrially zoned land use districts. (page 33). The city’s rationale is that since poles and wires are already in the corridor, that makes it the best place to put larger poles and wires.

CENSE counterclaim: LUC 20.20.255.E.6 Project should be mitigated to eliminate or avoid long-term impacts. Page 117, staff claims, “There would be no long-term impacts to land use and housing from the proposal, and the visual impacts in the Somerset area identified by the FEIS, while potentially unwelcome changes to views of the neighborhood and more distant scenic resources, are not anticipated to cause the health and vitality of this residential area to deteriorate.” These conclusions are not substantiated by data or quantitative analysis. CENSE believes that significantly taller poles and more visible wires will adversely affect property values adjacent to the corridor and other properties where views are degraded. There has been a long-running debate about the effect of electromagnetic fields on human health. Although science has not established a definitive health risk, the public remains concerned. The industrial nature of this infrastructure will increase these concerns, depressing home values nearby. Loss of trees and foliage along the corridor will also impact home values.

CENSE counterclaim: LUC 20.30B.140.B Project should be compatible with neighborhood character. Neighborhood character will be impacted by tree removal on properties, limitations to owners landscaping plans, and lower landscaping profiles that will be unable to camouflage taller poles. Taller poles with a vertical configuration of wires will hinder a greater number of views. Larger pole bases and foundations up to 5 feet in diameter are not in character with the existing neighborhoods.

Ideas for writing about how the project will impact your property

LUC 20.30B.140.D states that the project should not be materially detrimental to uses or property. If trees will be removed from your property, you might want to share details (height, evergreen or deciduous, genus/species, if possible) and/or describe the number and types of trees offered for mitigation. If possible, please include photos of trees to be removed.

Ideas for writing about how the project will impact the community

Page 76 of the City Staff Report notes a total of 580 trees will be removed:

  • 377 trees from the 3.3 mile of private property along the corridor
  • 108 from Richards Creek substation site
  • 66 trees from City-owned right of way
  • 29 trees from city-owned parks or utilities

Ideas for commenting on City Staff Report

City Staff Report Claim: Page 115 states: The land use pattern established in the Comprehensive Plan along the existing corridor is a geographic area within the City where the electrical utility facilities have become a fixture of the landscape. The proposal will not be located in any new parks and open spaces and will be limited to the existing corridor. Where feasible, the proposal is designed to avoid and minimize impacts to the character of existing neighborhoods by retaining and replacing trees within neighborhoods and parks, by limiting tree removal to the amount necessary to ensure safe operation of the proposed lines, and by avoiding or minimizing impacts to visual character.

CENSE counterclaim: At a recent Neighborhood Leadership Gathering on trees, the city discussed a commitment to achieve a 40% tree canopy. This would require an additional 670 acres of tree canopy. Residential property contains 65% of existing tree canopy and continues to be the most reasonable location for planting new trees. In contrast, PSE will be removing 580 significant trees, of which 377 are located on residential property where PSE has easements for its transmission corridor. City Staff Report notes PSE would remove between 380 valuable urban trees(1), while the FEIS indicates 442(2).
1. chapter_4.4_plants_and_animals.pdf : p 76
2. chapter_4.4_plants_and_animals.pdf : page 4.4-20

 

City Staff Report Claim: Appendix E, Vegetation Management includes 52 aerial photos of trees that will be removed or retained, 12 pages of tables that lists all the trees that have been tagged including their tag number, parcel number and whether they will be removed or retained, a 4-page letter from PSE describing the plant replacement policy, (see excerpt below), an example planting plan, 18 pages of aerial photos of trees that will be removed from public property, and a 7-page brochure showing sample replacement plants.

“PSE’s approach is to encourage property owners to incorporate additional trees into their landscape and tree replacement plans; however, PSE cannot require property owners to do so. While some property owners take this as an opportunity to add additional trees to their properties, others decline the offer of any replacement trees. As of the end of September 2018, PSE has met with approximately 45% of the property owners who are expected to have vegetation changes along the route in Bellevue – south segment.

PSE anticipates that a number of trees cannot be replaced onsite due to property owners’ preferences. In those cases replacement trees will need to be planted outside the corridor. One benefit of offsite planting is the option to plant larger trees, which contribute to habitat quality, tree canopy, and area aesthetics. Offsite options that PSE has considered include city parks, neighborhood groups/HOAs, and other developments within the City.”

CENSE counterclaim: If retaining trees is your passion, we strongly recommend that you look at Appendix E. It provides very specific information on which trees will be removed and where they are located. The four-page letter from PSE is buried in the middle of the document, but well worth reading.

Replacement trees are generally 3-6 feet tall. Just the sheer reduction in photosynthetic leaf/needle surface will greatly diminish the level of carbon sequestration. In addition, replacing evergreen species with deciduous species will also reduce the amount of time, in months, that sequestration would occur. Why plant unneeded poles and remove needed trees?

Ideas for writing about how the project will impact your property

You might want to comment on the number and/or duration of power outages you have experienced in the past year, and if you know, the cause of any outages.

Ideas for commenting on City Staff Report

Refer to City Staff report Reliability pages

City Staff Report claim: The City Staff Report concludes that PSE’s proposal complies with the following Land Use Codes:

  • The applicant shall demonstrate that the proposed electrical utility facility improves reliability to the customers served and reliability of the system as a whole, as certified by the applicant’s licensed engineer. 20.20.255.E.4
  • Describe how the proposed electrical utility facility provides reliability to customers served. 20.20.255.D.3.b

CENSE counterclaim: Electrical reliability is measured by two standard metrics, SAIDI (measures duration of outages) and SAIFI, (measures frequency of outages). Energize Eastside is extravagantly over-designed for any electrical stresses the Eastside would realistically experience. PSE admits the project will not improve either the duration or frequency of outages for “any Bellevue neighborhood or the system as a whole.” To improve reliability, PSE must improve the smaller power lines that serve our neighborhoods. These cause most of our power outages when they are damaged by trees during wind and ice storms.

City Staff Report claim: Page 48 states “The objective of PSE’s proposal is to increase the capacity of the Eastside electric grid to keep pace with projected increases in electricity demands during peak periods…”

CENSE counterclaim: Five years ago, PSE expected demand for electricity to grow at a rate of 2.4% per year, more than twice the expected rate of population growth. As the years have passed, it is obvious that this forecast was too high. Consumption of electricity is not growing due to technological advances like LED lights. You can see this on Bellevue’s website that tracks electricity consumption in our city: Community Energy Usage (look at the second graph). One of PSE’s fundamental assumptions is obviously wrong.

Ideas for writing about how the project will impact your property

If the pipeline is near your property, and especially if a pole will be placed near your home, consider commenting on your concerns about digging a deeper and wider hole for the pole. It would be helpful to note if the pole is located on a slope. If possible, include photos.

Ideas for commenting on City Staff Report

Refer to City Staff Report – Pipeline Safety pages 78-80, 93

City Staff Report claim: “PSE and Olympic have worked together in the corridor for 40 years, and communicate regularly to coordinate activities related to pole replacement and other maintenance work”. (Source: City Staff Report page 93, Section1)

CENSE counterclaim: The proposed project cannot be compared to previous pole replacement and maintenance work. The new poles will require deeper and wider holes. The energy capacity of the lines will be quadrupled.

City Staff Report Claim: “The risk assessment completed for the EIS indicates that there will be a very small increase in total risk during construction.” (Source: City Staff Report page 93, Section1)

CENSE counterclaim: According to a review by Accufacts of EDM’s “Technical Report, Pipeline Safety and Risk of Upset,” Accufacts states, EDM’s “attempts to characterize the impact area in the Technical Report are unrealistic small. … pipeline elevation profile is neither discussed nor proved.”

Accufacts also notes that “Risk probabilities derived from industry-wide databases do not represent the risks that may exist o a specific pipeline operation as management safety cultures can vary widely.” (Source: Accufacts Review of Puget Sound Energy’s Energize Eastside Transmission project. For city of Newcastle, page 7-9, review the EDM study)

City Staff Report claim: “… the Project is not expected to increase the risks of accidental release due to seismic activities or other natural forces, and that overall the operations risks would decrease.” (Source: City Staff Report page 93, Section 2)

CENSE counterclaim: Another example of PSE’s misdirection: The significant question is NOT about the project increasing the risk of accidental release of petroleum products after an earthquake, but the increased risk of released petroleum exploding if it comes into contact with a downed wire with twice the voltage.

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