SMUD Franklin Electric Transmission Project. Initial Study and Mitigated Negative Declaration Addendum July 2017

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1 SMUD Franklin Electric Transmission Project Initial Study and Mitigated Negative Declaration Addendum July 2017

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3 Sacramento Municipal Utility District Franklin Electric Transmission Project Initial Study Mitigated Negative Declaration Addendum July 2017 Lead Agency: Sacramento Municipal Utility District 6201 S Street, MS H201 Sacramento, CA or P.O. Box MS H201 Sacramento, CA Attn: Kim Crawford (916) or kim.crawford@smud.org

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5 Franklin Electric Transmission Project Addendum July 2017 Executive Summary The Sacramento Municipal Utility District (SMUD) adopted an Initial Study/Mitigated Negative Declaration (IS/MND) (State Clearinghouse [SCH] No ) for the Franklin Electric Transmission Project in October The project includes constructing and operating a new bulk transmission substation (Franklin Bulk substation), constructing and operating a new distribution substation (Franklin Distribution substation), modifying existing and constructing new overhead 69 kilovolt (kv) and 230kV power lines to link the substations to the electrical grid, and dismantling a nearby distribution substation. Since adoption of the 2016 IS/MND and approval of the project, SMUD has refined the substation design to address flood risks, thus requiring further environmental analysis. Flood protection is an important site design criterion to maintain SMUD s electric system reliability. During final design of the Franklin Bulk and Franklin Distribution Substation, SMUD determined that the planned Franklin Substation site should be raised above the previously proposed base elevation to provide adequate flood protection. SMUD will raise the grade of the substation to provide adequate head room based upon historical water level data for the Franklin area from the Sacramento County Department of Water Resources. The minimum surface elevation of the substation site will be increased from elevation 19.0 to 23.0 feet. The purpose of this Addendum is to evaluate the environmental effects of this design modification and determine whether the project, as modified, will result in any new or substantially greater significant effects or require any new mitigation measures not identified in the previously circulated 2016 IS/MND. Based on the information provided in this Addendum, the modification will not result in new significant environmental impacts compared to those previously analyzed in the 2016 IS/MND. No changes have occurred with respect to project circumstances that will cause significant environmental impacts, and no new information has become available that shows that the project will cause new significant environmental impacts. No new significant impacts have been identified, nor is the severity of previously identified impacts substantially greater than those presented in the 2016 IS/MND. Therefore, the analyses conducted and the conclusions reached in the IS/MND adopted in October 2016 remain valid and no supplemental environmental review is required beyond this Addendum.

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7 Table of Contents Executive Summary Franklin Electric Transmission Project Addendum July Introduction Background Purpose of the Addendum to the IS/MND Project Description Project Location Project Modifications Since IS/MND Adoption Environmental Impact Analysis Aesthetics Air Quality Biological Resources Cultural Resources Geology and Soils Greenhouse Gas Emissions Hazards and Hazardous Materials Hydrology and Water Quality Noise Transportation and Circulation Other Environmental Topics Conclusions References Report Preparers List of Appendices Appendix A Air Emissions Modeling CalEEMod Output

8 Acronyms and Abbreviations Franklin Electric Transmission Project Addendum July 2017 BMPs CEQA dba EIR EMF GHG IS IS/MND kv LOS MND MTCO 2 e ND NO x Project SMAQMD SMUD SWPPP UPRR best management practices California Environmental Quality Act A-weighted decibels Environmental Impact Report Electric and Magnetic Fields Greenhouse gas Initial Study Initial Study/Mitigated Negative Declaration kilovolt level of service Mitigated Negative Declaration metric tons of carbon dioxide equivalents Negative Declaration oxides of nitrogen Franklin Electric Transmission Project Sacramento Metropolitan Air Quality Management District Sacramento Municipal Utility District Storm Water Pollution Prevention Plan Union Pacific Railroad

9 Franklin Electric Transmission Project Addendum July Introduction The Sacramento Municipal Utility District (SMUD) adopted an Initial Study/Mitigated Negative Declaration (IS/MND) (State Clearinghouse [SCH] No ) for the Franklin Electric Transmission Project in October The project includes constructing and operating a new bulk transmission substation (Franklin Bulk substation), constructing and operating a new distribution substation (Franklin Distribution substation), modifying existing and constructing new overhead 69 kilovolt (kv) and 230kV power lines to link the substations to the electrical grid, and dismantling a nearby distribution substation. Since adoption of the 2016 IS/MND, SMUD has refined the substation design to address flood risks, thus requiring further environmental analysis. The potential environmental impacts resulting from project changes are addressed in this Addendum. As demonstrated in this Addendum, the IS/MND continues to serve as the appropriate document addressing the environmental impacts of the project pursuant to the California Environmental Quality Act (CEQA). The 2016 Draft and Final IS/MND (SCH No ) are hereby incorporated by reference; the 2016 Draft and Final IS/MND are available for review on SMUD s CEQA Reports web page: Background SMUD published a Draft IS/MND on April 19, 2016, followed by a 30-day public review period and a public meeting. A Notice of Intent to adopt the MND was distributed to property owners and occupants of record within at least 500 feet of the project boundary. The Draft IS/MND was distributed to the Governor s Office of Planning and Research, the State Clearinghouse (SCH); local libraries; the County of Sacramento; the City of Elk Grove; and relevant resource agencies. SMUD then published a Final IS/MND containing responses to comments and a Mitigation Monitoring and Reporting Program (MMRP) with mitigation measures to address the project s potential environmental impacts. SMUD s Board of Directors certified the Final IS/MND and approved the project on October 20, A Notice of Determination was filed with the SCH on October 25, The 2016 IS/MND assessed the environmental impacts that may result from the construction and operation of the project. It identified potentially significant impacts associated with air quality, biological resources, cultural resources, geology/soils, greenhouse gas, hazards/hazardous materials, and hydrology/water quality. SMUD determined that those impacts will be less than significant with implementation of mitigation measures, which were adopted in the MMRP. Page 1 of 23

10 Franklin Electric Transmission Project Addendum July 2017 During final design of the Franklin Bulk and Franklin Distribution Substation, SMUD determined that the elevation of the approximately 17-acre substation site 1 should be raised to approximately 3 feet higher than originally planned to alleviate risk of flooding. 1.2 Purpose of the Addendum to the IS/MND This addendum describes the project modification and documents SMUD s determination that the modification does not require preparation of a subsequent or supplemental IS/MND. This determination is necessary because after an IS/MND has been approved, CEQA requires an agency, as part of any further discretionary approvals, to evaluate any project modifications that necessitate changes or additions to the IS/MND. If the project modifications are substantial and require major changes to the previous IS/MND because of new significant environmental effects or a substantial increase in the severity of previously identified effects, then the agency must prepare a subsequent or supplemental IS/MND. For project modifications that do not rise to this level but necessitate some revisions to the IS/MND, the agency may prepare an addendum to describe the project modifications and explain why a subsequent or supplemental MND is not required. Accordingly, a technical analysis of the incremental environmental effects posed by the modification was completed, using the project as described in the IS/MND as the baseline. This addendum describes that analysis, which concludes that the modifications will not cause new significant environmental effects or a substantial increase in the severity of previously identified effects (CEQA Guidelines Section 15164). There are also no changes in circumstances or new information that should have been known with reasonable diligence materialize that will substantially affect the project. 1 The proposed Franklin Bulk and Franklin Distribution substations would be co-located within the Project s substation footprint. This area is referred to as the substation site in the IS/MND. Page 2 of 23

11 Franklin Electric Transmission Project Addendum July Project Description The objective of the project is to maintain SMUD s electric system reliability and to increase the electric system capacity to meet expected customer demand as a result of planned land development in the southwest area of Sacramento County. In response, SMUD is planning to construct and operate a new bulk transmission substation (Franklin Bulk substation), construct and operate a new distribution substation (Franklin Distribution substation), modify existing and construct new overhead 69kV and 230kV power lines that will link the substations to the electrical grid, and dismantle a nearby distribution substation. The project elements and construction methods are described in detail in the 2016 Draft and Final IS/MND, which are incorporated by reference. This section describes the project changes analyzed in this IS/MND Addendum. 2.1 Project Location The project is located in southwestern Sacramento County, California (Figures 1 and 2). The planned substation is located in unincorporated Sacramento County and the subtransmission pole modifications extend into the City of Elk Grove, California. As described in the 2016 IS/MND, the Franklin Distribution substation will be co-located within the footprint of the Franklin Bulk substation. This area is referred to as the Franklin Substation site or substation site in the 2016 IS/MND and will occupy an approximately 17-acre site located southeast of the intersection of Franklin Boulevard and Hood Franklin Road and adjacent to an existing 230kV SMUD electrical transmission corridor and UPRR tracks to the east (Figure 2). 2.2 Project Modifications Since IS/MND Adoption SMUD has determined that the planned Franklin Substation site elevation should be increased for flood protection. Flood protection is an important site design criterion to maintain SMUD s electric system reliability. The site is located just north of and outside of the existing Federal Emergency Management Agency (FEMA) 100-year flood plain boundary (Figure 3). After the recent winter and associated flooding in the southern portion of the County, SMUD requested historical hydrologic information from the County Department of Water Resources. From those data, SMUD has determined that the highest previously recorded water elevation in the substation area was 21.0 feet above mean sea level, which is higher than the previously planned minimum elevation of 19.0 feet. Therefore, to adequately protect the substation and electric system reliability, SMUD will raise the substation site elevation to provide adequate flood protection. Page 3 of 23

12 Franklin Electric Transmission Project Addendum July 2017 Figure 1. Regional Location Page 4 of 23

13 Franklin Electric Transmission Project Addendum July 2017 Figure 2. Project Overview Page 5 of 23

14 Franklin Electric Transmission Project Addendum July 2017 Figure 3. FEMA 100-Year Floodplain Page 6 of 23

15 Franklin Electric Transmission Project Addendum July 2017 The minimum elevation within the substation site will be increased from 19.0 to 23.0 feet. The substation perimeter along Franklin Boulevard, which was originally planned to have an approximately 2 foot elevation difference between Franklin Boulevard and the substation, will instead have an elevation difference of approximately 5 feet, as shown in Figure 4 below. Thus the project change results in an incremental elevation change that raises the substation by 3 additional feet. The transition between Franklin Boulevard and the substation will be accomplished with a 3 to 1 slope (i.e., for every 3 feet of horizontal distance, the ground elevation increases by 1 foot). The area between Franklin Boulevard and the perimeter block wall will be landscaped. The drainage and grading plan, including design of the onsite detention basin and storm water collection facilities, has been refined (Figure 5). Figure 4. Elevations at Substation Site Raising the substation elevation does not change the project footprint or substantially alter the construction methods or the schedule described in the 2016 IS/MND. The 2016 IS/MND states that the substation site will be graded to accommodate substation equipment, drainage, and access roads, and that approximately 82,000 cubic yards of engineered fill will be imported. It states that grading, installing drainage facilities, and improving the access road will require approximately 16 weeks. With the elevation change, the estimated volume of imported material will increase to approximately 110,850 cubic yards and the duration of grading work will extend by three days. The 2016 IS/MND reported that construction of the Franklin Bulk substation was planned to begin in early 2017 and be completed in However, the project start date has been adjusted to September 2017; therefore, construction of the Franklin Bulk substation will be completed by the end of 2019 and other project components will extend until Page 7 of 23

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17 Franklin Electric Transmission Project Addendum July 2017 Figure 5. Preliminary Substation Drainage and Grading Plan Page 9 of 23

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19 Franklin Electric Transmission Project Addendum July Environmental Impact Analysis This comparative analysis has been undertaken pursuant to the provisions of CEQA Guidelines Section and to provide SMUD with the factual basis for determining whether changes in the project, changes in circumstances, or new information since the 2016 IS/MND was certified may require additional environmental review. The 2016 IS/MND found that the project will result in impacts that were either less than significant or less than significant with mitigation. The project has been modified to raise the elevation of the substation site to reduce flood risk. The environmental evaluation focuses on resource areas for which the project change warrants additional consideration. This section does not re-evaluate resources that are unaffected by the project modification. 3.1 Aesthetics As described in the 2016 Draft and Final IS/MND, the substations will be visible to nearby residents and will alter the view along Franklin Boulevard and Hood Franklin Road. SMUD has sited the substation in a location that will minimize the visual effect on residents. The 2016 IS/MND concluded that the project will not change the visual character of the area or result in a significant impact on aesthetics. The project has been modified to raise the elevation of the substation site by approximately 5 feet. The substation perimeter along Franklin Boulevard was originally planned to have an approximately 2 foot elevation difference between Franklin Boulevard and the substation. This elevation difference will now be raised by an additional 3 feet for a total of 5 feet elevation difference between Franklin Boulevard and the substation. This additional raise of the substation will make tall electrical equipment within the substation visible at greater distances than previously analyzed. The tall equipment includes two transformers (approximately 35 feet tall), up to thirteen 230kV power circuit breakers (approximately 25 feet tall), a network of steel structures to support the equipment (varying in height from approximately 16 to 80 feet tall), overhead conductors entering the substation from the interconnecting subtransmission and transmission overhead lines, and a two-story control building. Raising the substation site elevation and consequently the height of the electrical facilities will make these features visible at a greater distance. More of the substation s tall vertical elements will be visible from the Rancho Verde neighborhood east of the substation site. However, the original plan was to raise the site elevation by 2 feet, thus the incremental elevation change above the original plan is only 3 feet. In addition, most of the substation site still will be obscured by an existing sound barrier wall and vegetation. As noted in the 2016 IS/MND, the substation will be visible to residents and visitors to the Franklin community north of the Hood-Franklin/Franklin Boulevard intersection. Raising the substation site by approximately 5 feet will make these elements visible at a slightly greater distance; however, this change will not appreciably increase the project s effects on the overall visual character. The impact of the project on views and the visual character of the area remain the same as described in the 2016 IS/MND. Therefore, no changes to the conclusions of Page 11 of 23

20 Franklin Electric Transmission Project Addendum July 2017 the aesthetics analysis presented in the 2016 IS/MND are required. No new or substantially more severe significant effects will occur. 3.2 Air Quality The 2016 IS/MND identified potential impacts and mitigation measures for short-term construction impacts on air quality. It concluded that construction-generated emissions attributable to the project will exceed the Sacramento Metropolitan Air Quality Management District (SMAQMD) recommended significance threshold for oxides of nitrogen (NO x ). It also determined that emissions of particulate matter (PM), both PM 10 and PM 2.5, which are primarily associated with ground-disturbing activities (e.g., site preparation, grading, trenching), will not exceed the SMAQMD s daily or annual emissions thresholds. The SMAQMD updated their thresholds of significance in May 2017 (SMAQMD 2017); however, the update did not affect the construction thresholds used in the 2016 IS/MND analysis and therefore does not affect the impact conclusions. The project change will require additional earthwork and truck trips during the grading phase of construction. The 2016 IS/MND reported that approximately 82,000 cubic yards of engineered fill will be imported and that grading, drainage facilities, and access road improvements will require approximately 16 weeks of construction. With the additional fill, the volume of imported material will increase to approximately 110,850 cubic yards and the duration of grading work will extend by 3 days (totaling 16.5 weeks). To evaluate the potential impacts of the change on air quality, this addendum contains updated emissions calculations. Updated emissions estimates were calculated using the California Emissions Estimator Model (CalEEMod) Version The revised calculations accounted for the import of 110,843 cubic yards of fill and export of 14,991 cubic yards, resulting in a total of 13,287 haul trips. This represents a 4.5% increase in haul trips compared to the 2016 IS/MND, which evaluated 12,712 haul trips. The revised emissions estimates do not change the impact conclusions presented in the 2016 IS/MND. As shown in Table 1, PM emissions are well below the emission limits; however, NO x exceeds the adopted emission threshold during the first 2 years of construction (see Appendix A for additional details). Page 12 of 23

21 Franklin Electric Transmission Project Addendum July 2017 Table 1. Unmitigated Daily Construction Emissions (lbs/day) Year ROG NO x PM 10 1 PM Maximum Daily Emissions (lbs/day) SMAQMD Threshold Exceeds Threshold -- Yes No No Maximum Daily Emissions (lbs/day) reported in 2016 IS/MND Notes: Exceeds Threshold -- Yes No No 1 PM 10 emissions shown include the sum of particulate matter with aerodynamic diameter 0 to 2.5 microns and particulate matter with aerodynamic diameter 2.5 to 10 microns. ROG = reactive organic gases; NO x = oxides of nitrogen; PM 10 = suspended particulate matter; PM 2.5 = fine particulate matter; lbs/day = pounds per day Source: AECOM 2017, AMBIENT Air Quality and Noise Consulting 2015 The mitigation measures identified in the 2016 IS/MND include implementation of a Fugitive Dust Control Plan (AIR-1) and SMAQMD-recommended NO x reduction measures (AIR-2). Mitigation Measure AIR-2 includes a combination of construction equipment emission reductions and enhanced measures to reduce NO x emissions. To maintain NO x emissions below the SMAQMD emission threshold, SMUD will revise the technical specifications contained in Mitigation Measure AIR-2 to require use of Tier 4 Final equipment instead of Tier 3 equipment. With Tier 4 equipment, which is more effective in reducing NOx emissions, maximum mitigated daily emissions will be below SMAQMD thresholds (see Appendix A). Changes to Mitigation Measure AIR-2 are shown below; deletions are shown as strikeout text and additions are shown as double underline text. These changes are incorporated into the MMRP. Mitigation Measure AIR-2: NOx Reduction Measures The following SMAQMD-recommended basic and enhanced measures shall be implemented during substation construction and during the decommissioning of the Franklin-Bilby substation to reduce mobile source emissions of NO x : Page 13 of 23

22 Franklin Electric Transmission Project Addendum July 2017 Basic Measures: a. Minimize idling time of diesel-powered equipment either by shutting equipment off when not in use or reducing the time of idling to 5 minutes [required by California Code of Regulations, Title 13, sections 2449(d)(3) and 2485]. Provide clear signage that posts this requirement for workers at the entrances to the site. b. Maintain all construction equipment in proper working condition according to manufacturer s specifications. The equipment must be checked by a certified mechanic and determine to be running in proper condition before initial use in the Project Area. Documentation verifying compliance with this measure shall be retained on site and provided to SMAQMD upon request. c. When leasing equipment, the contractor shall use alternatively fueled equipment (e.g., electric, propane, etc.), in lieu of diesel- or gasoline-fueled equipment, whenever possible and to the extent available. Enhanced Measures: d. A comprehensive inventory of all off-road construction equipment, equal to or greater than 50 horsepower, that would be used in aggregate of 40 or more hours during substation construction and during the decommissioning of the Franklin-Bilby substation shall be submitted to the SMAQMD. The inventory shall include the horsepower rating, engine model year, and projected hours of use for each piece of equipment. The contractor shall provide the anticipated construction timeline including start date, and name and phone number of the project manager and on-site foreman. This information shall be submitted at least four business days prior to the use of subject heavy-duty off-road equipment. The inventory shall be updated and submitted monthly throughout the duration of the Project, except that an inventory shall not be required for any 30-day period in which no construction activity occurs. e. A plan shall be submitted to the SMAQMD demonstrating that combined emissions from heavy-duty off-road equipment (50 horsepower or more), construction vehicles, and haul truck to be used during substation construction and during the decommissioning of the Franklin-Bilby substation, including owned, leased, and subcontractor vehicles, will achieve NO X reductions sufficient to demonstrate compliance with the SMAQMD s maximum allowable mass emissions threshold of 85 pounds per day (lbs/day) of NOx. The use of newer heavy-duty off-road equipment will be sufficient to reduce construction-generated emissions to below SMAQMD s maximum allowable mass emissions threshold of 85 lbs/day of NO x. The construction contractor shall use offroad construction diesel engines that meet, at a minimum, the Tier 4 Final California Emissions Standards, unless such an engine is not available for a particular item of equipment. Lesser tier engines will be allowed on a case-by-case basis when the contractor has documented that no Tier 4 Final equipment or emissions equivalent retrofit equipment is available for a particular equipment type Page 14 of 23

23 Franklin Electric Transmission Project Addendum July 2017 that must be used to complete construction. SMAQMD s Construction Mitigation Tool spreadsheet (last updated January 1, 2017) shall be employed to confirm consistency with the plan. The plan shall include an inventory of all off-road equipment and haul trucks to be used during construction. Acceptable options for reducing emissions may include use of late model engines, low-emission diesel products, alternative fuels, engine retrofit technology, aftertreatment products, limitations on the use of off-road equipment and/or haul trucks, changes in construction schedules, the payment of mitigation fees to the SMAQMD, and/or other options as they become available. The SMAQMD s Construction Mitigation Calculator can be used to identify an equipment fleet that achieves this reduction. f. SMUD shall ensure that emissions from all off-road diesel powered equipment used in substation construction and during the decommissioning of the Franklin-Bilby substation do not exceed 40% opacity for more than three minutes in any one hour. Any equipment found to exceed 40 percent opacity (or Ringelmann 2.0) shall be repaired immediately. Non-compliant equipment shall be documented and a summary provided to SMAQMD monthly. A visual survey of all in-operation equipment shall be made at least weekly. A monthly summary of the visual survey results shall be submitted throughout the duration of the Project, except that the monthly summary shall not be required for any 30-day period in which no construction activity occurs. The monthly summary shall include the quantity and type of vehicles surveyed as well as the dates of each survey. g. In lieu of implementing all or a portion of the above Enhanced Measures, a refined emissions modeling analysis can be performed, once more detailed construction information becomes available. The refined analysis shall be conducted in accordance with applicable SMAQMD-recommended methodologies and guidance. Emissionsreduction measures shall be included sufficient to demonstrate compliance with SMAQMD s maximum allowable mass emissions threshold of 85 lbs/day of NO x. The refined analysis shall be reviewed and endorsed by the SMAQMD prior to initiating construction. Based on a preliminary analysis of the proposed Project, the The use of newer heavy-duty off-road equipment (i.e., Tier 3 4 or newer [EPA 2015]) would will be sufficient to reduce construction-generated emissions to below SMAQMD s maximum allowable mass emissions threshold of 85 lbs/day of NO x. Page 15 of 23

24 Franklin Electric Transmission Project Addendum July Biological Resources The project modification will not change the impact conclusions for biological resources. The substation remains within the previously evaluated 17-acre site. Raising the elevation of the substation will not result in new or substantially more severe significant effects on biological resources. Impacts on biological resources will be less-than-significant with mitigation incorporated. No changes have been made to the conclusions of the biological resources analysis presented in the 2016 IS/MND. 3.4 Cultural Resources As described in the 2016 IS/MND, impacts on cultural resources will be less-than-significant with mitigation incorporated. The project modification will not change the impact conclusions for cultural resources. The substation remains within the previously evaluated 17-acre site and raising the elevation of the substation will not result in new or substantially more severe significant effects on cultural resources. No changes have been made to the conclusions of the cultural resources analysis presented in the 2016 IS/MND. 3.5 Geology and Soils The 2016 IS/MND describes impacts to soil erosion as less-than-significant with mitigation incorporated. The 2016 IS/MND states that the grading and ground-disturbing activities will expose soils and could result in accelerated erosion. Preparation and implementation of a Storm Water Pollution Prevention Plan (SWPPP) is included as a mitigation measure to reduce this potential impact to a less-than-significant level. Through the SWPPP, SMUD will implement erosion control measures and best management practices (BMPs) to stabilize soils during and following construction. Raising the elevation of the substation site elevation does not change the project footprint or substantially alter the construction methods described in the 2016 Draft IS/MND. However, with the elevation change, the estimated volume of imported material will increase and the duration of grading work will extend by less than one week. These changes will not result in new or substantially more severe significant effects on soil erosion than those described in the 2016 IS/MND, and no changes are needed to the adopted mitigation measure. 3.6 Greenhouse Gas Emissions As described in the 2016 IS/MND, construction will result in the temporary generation of greenhouse gas (GHG) emissions. The 2016 IS/MND reported that annual GHG emissions during the initial year of construction could potentially exceed SMAQMD s significance threshold of 1,100 metric tons of carbon dioxide equivalents (MTCO 2 e) per year. The 2016 IS/MND included Mitigation Measure GHG-1. With this mitigation, the impact was determined to be less than significant. To evaluate the effect of adding fill and truck trips, updated GHG emissions calculations were completed (see Appendix A). The revised analysis shows that the estimated GHG emissions will be higher than originally planned but will not exceed the SMAQMD s annual threshold. Although Page 16 of 23

25 Franklin Electric Transmission Project Addendum July 2017 the number of haul truck trips has increased, the revised construction start date and schedule spreads these emissions over more years, with the initial construction stages (including import of fill and grading) spread more evenly between the first 2 years. In the 2016 IS/MND, GHG emissions in the first 2 years of construction were estimated at 1,230 and 476 MTCO2e/year. With the project change, the estimates for the first two years of construction are 969 and 720 MTCO2e/year (Appendix A). Therefore, the modified project s GHG emissions impacts will be less than significant. Mitigation Measure GHG-1, adopted by SMUD, includes the following provision: In lieu of implementing the above measure, a refined emissions modeling analysis can be performed, once more detailed construction information becomes available. The refined analysis shall be conducted in accordance with applicable SMAQMDrecommended methodologies and guidance. Emissions-reduction measures shall be included sufficient to demonstrate compliance with SMAQMD s mass emissions threshold of 1,100 MTCO2e/year. The refined analysis shall be reviewed and endorsed by the SMAQMD prior to initiating construction. The revised GHG analysis presented in Appendix A constitutes a refined emissions modeling analysis, which SMUD will transmit to SMAQMD as proof of completion of mitigation measure GHG Hazards and Hazardous Materials As described in the 2016 Draft and Final IS/MND, impacts on hazards and hazardous materials are considered less-than-significant with mitigation incorporated. The 2016 IS/MND includes mitigation measures to minimize the potential for accidental releases of hazardous materials into the environment during construction and operation. These measures include preparation and implementation of a worker training program; a SWPPP; a Spill Prevention, Control, and Countermeasures Plan; and a Hazardous Materials Business Plan. Raising the elevation of the substation site elevation does not change the project footprint or alter the construction methods and materials to be used at the site. Therefore, no changes are needed to the impact conclusions for hazards and hazardous materials. The 2016 Final IS/MND presented results of pre- and post-project electric and magnetic fields (EMF) modeling and determined that 1) the project will not result in an appreciable increase in EMF exposure to nearby residents over existing conditions, and 2) exposure levels will be far below published EMF guidelines (see 2016 Final IS/MND pages 65 to 77). As noted in the analysis, EMF strength is affected by distance, conductor spacing, load, and phase configuration. Raising the substation site elevation by approximately 5 feet will not change these factors. The project footprint and electrical equipment design has not been modified substantially, thus no changes in the factors that influence EMF strength, including distance from electric facilities to surrounding residents, will occur. The modeling and conclusions presented in the 2016 Final IS/MND for EMF are valid. The project will not have a significant effect on public health related to EMF emissions and no mitigation is required. Page 17 of 23

26 Franklin Electric Transmission Project Addendum July Hydrology and Water Quality The 2016 IS/MND describes impacts on hydrology as less than significant and impacts on water quality as less than significant with mitigation incorporated. As shown in Figure 3, the substation site is located immediately north of the FEMA 100-year floodplain boundary. The 2016 IS/MND determined that: the onsite drainage management system and detention basin will not alter downstream flows, the project would not impede or redirect flood flows, and the substation minimum site elevation will be at least 1.5 feet above the 100-year floodplain per County of Sacramento requirements. After the recent winter and associated flooding in the southern portion of the County, SMUD decided to change the final design by adjusting the substation elevation to adequately protect the substation and electric system reliability during high flood events. The design of the onsite detention basin and storm water collection facilities has been refined to match the new higher elevation (Figure 5). Therefore, the project modifications do not change the hydrology conclusions presented in the 2016 IS/MND. No new or substantially more severe significant effects on water quality or hydrology would occur, and no changes are needed to the adopted mitigation measures to address potential water quality impacts. 3.9 Noise The 2016 IS/MND evaluated short-term (construction) and operational noise impacts of the substation on nearby sensitive noise receptors, including residences and schools. The 2016 IS/MND noted that the highest noise levels would be associated with earth-moving equipment used during site preparation, grading and trenching activities. Noise resulting from constructiongenerated vehicle traffic on primarily affected roadway segments was also calculated. The results of the 2016 IS/MND analysis found that the increase in ambient noise levels during construction and operation would result in less-than-significant impacts on nearby sensitive receptors. The project has been modified to raise the elevation of the substation site, which will require additional earthwork and truck trips to import engineered fill during the grading phase of construction. The construction vehicle-generated noise analysis in the 2016 IS/MND was based on an estimate of 12,712 truck trips during this phase. With the project modification, an estimated 13,287 truck trips would be required; this results in approximately 575 additional truck trips during the grading phase of construction. In addition, as described above, the duration of construction will increase by 3 days for the additional grading and related work. However, the increase in haul truck traffic will not increase construction noise because the additional (approximately 575) haul trips would be distributed over the duration of the longer (83 days) filling and grading phase, resulting in an additional approximately 7 trips per day (less than more 1 trip per hour). Because Page 18 of 23

27 Franklin Electric Transmission Project Addendum July 2017 the construction phase would be longer, the number of trucks per day would not increase substantially. Therefore, the impact conclusions in the 2016 ISMND would remain the same. With respect to operational noise, the analysis in 2016 IS/MND shows that the operational noise levels at the property lines of the nearest residential land uses (not accounting for noise reduction from the substation perimeter wall along Franklin Boulevard) would be approximately 43 dba L eq /L 50 2 or less, under normal daytime operational conditions including the simultaneous operation of all onsite transformers and cooling fans from both the bulk and distribution substations. Elevating the substation would slightly increase the noise levels at the property lines. However, because this change would not move the noise source closer to the residences and the planned substation perimeter wall along Franklin Boulevard will provide noise protection to the nearest residents, the increase in noise levels would not exceed applicable thresholds at nearby noisesensitive uses. Therefore, the noise impact conclusions related to operation noise levels would remain the same Transportation and Circulation As described in the 2016 IS/MND, the project would have less-than-significant impacts on traffic and circulation. The potential impacts of the project on intersections and roadways were assessed by evaluating the estimated construction trips under worst case assumptions and assessing associated potential impacts on intersection and roadway level of service (LOS), and potential safety impacts at the substation site access points. Construction material loads will be highest during the initial site preparation and grading phase. Trip generation estimates for the worse-case scenario are presented in Table TRA-1 of the 2016 Draft IS/MND. The worst case analysis shows 370 truck trips required for materials import and export occurring on a typical construction grading workday. This activity represents an average of 46 truck trips on an hourly basis over an 8-hour haul day. As material receiving hours will be 7:00 a.m. to 3:00 p.m., the project will add truck traffic during the a.m. peak hour, but the contribution during the p.m. peak hour would be limited. Using a worse-case assumption, project construction could generate approximately 430 daily truck trips under the 2016 IS/MND analysis, with most of that activity concentrated at the beginning and end of the work day when worker commutes occur. The 2016 IS/MND analysis found that the increase in traffic during construction would result in less-thansignificant impacts on nearby interchange and roadway LOS. The project change will require additional earthwork and add approximately 575 additional truck trips during the grading phase. Using a worse-case assumption analysis for the updated construction scenario (all additional truck trips occur over the three additional grading days) would result in approximately 192 trips per day. Therefore, the additional truck trips will not result in an increase in the daily trip generation estimate because the additional trips would be distributed over the extended construction period rather than compressed into the three 2 A-weighted decibels (dba) = the decibel level which has been weighted to approximate the frequency response of the average human ear. Energy-Equivalent Noise Level (L eq ) = an average of the sound energy occurring over a specified period. In effect, L eq is the steady-state sound level containing the same acoustical energy as the time-varying sound that actually occurs during the same period. Page 19 of 23

28 Franklin Electric Transmission Project Addendum July 2017 additional days of grading work. No change to the impact conclusions in the 2016 IS/MND is needed Other Environmental Topics The environmental analysis provided in the 2016 IS/MND remains current and applicable to the project in areas unaffected by the design refinement. Substation construction would be completed within the previously evaluated 17-acre site and the project modifications would not change the impact conclusions related to the following resources: Agricultural resources; Land use and planning, Mineral resources, Population and housing, Public services, Recreation, and Utilities and service systems. The project would neither increase the severity of these impacts nor result in new or substantially different environmental effects than those described in the 2016 IS/MND. These topics do not warrant further discussion in this Addendum. Page 20 of 23

29 Franklin Electric Transmission Project Addendum July Conclusions Based on the information provided above, SMUD has determined that the project modifications would not have a significant effect on the environment and that changing the specifications in Mitigation Measure AIR-2 to require Tier 4 equipment will address increases in NOx emissions. No new significant impacts have been identified, nor is the severity of previously identified impacts substantially greater than those presented in the 2016 IS/MND. No new mitigation measures would be necessary to reduce significant impacts. Furthermore, no changes have occurred with respect to circumstances surrounding the project that would cause significant environmental impacts and no new information has become available that shows that the project would cause new significant environmental impacts. Therefore, this addendum, which considers increasing the substation elevation, is consistent with the MND adopted by the SMUD Board of Directors in Kim Crawford Date Environmental Management Specialist Page 21 of 23

30 Franklin Electric Transmission Project Addendum July References AECOM Air Quality and Greenhouse Gas Technical Memorandum for the Revised Franklin Electric Transmission Project. June 2017 Ambient Air Quality and Noise Consulting Air Quality and Greenhouse Gas Impact Assessment Report for the Franklin Electric Transmission Project. September Sacramento Metropolitan Air Quality Management District (SMAQMD). May Guide to Air Quality Assessment in Sacramento County. Available at: Guidance-Tools. Accessed June Page 22 of 23

31 Franklin Electric Transmission Project Addendum July Report Preparers SMUD Kim Crawford, Environmental Specialist Area West Environmental, Inc. Aimee Dour-Smith, Senior Planner Becky Rozumowicz, Principal AECOM, Inc. Susan Sanders, Project Manager Peter Boucher, CEQA/NEPA Specialist Petra Unger, CEQA/NEPA Specialist Caitlin Miller, Air Quality Specialist Mohammad Issa Mahmodi, Traffic and Noise Analyst Page 23 of 23

32 Appendix A. Air Emissions Modeling CalEEMod Output

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