Reasons for Exemption
Under CEQA Guidelines §15062, a lead agency must identify the rationale for making the determination that a project is exempt under CEQA. SMUD has determined that the Bradshaw Road 69kV Extension Project is exempt under CEQA Guidelines §15301, Existing Facilities, which reads, “Class 1 consists of the…minor alteration of existing public or private structures, facilities, mechanical equipment, or topographical features, involving negligible or no expansion of existing or former use. The key consideration is whether the project involves negligible or no expansion of use,” and (b) “Existing facilities of both investor and publicly-owned utilities used to provide electric power, natural gas, sewerage, or other public utility services,” and §15302, Replacement or reconstruction, which reads, “Class 2 consists of replacement or reconstruction of existing structures and facilities where the new structure will be located on the same site as the structure replaced and will have substantially the same purpose and capacity as the structure replaced …” and “(c) Replacement or reconstruction of existing utility systems and/or facilities involving negligible or no expansion of capacity”, and (d) Conversion of overhead electric utility distribution system facilities to underground including connection to existing overhead electric utility distribution lines where the surface is restored to the condition existing prior to the undergrounding, and §15303, New Construction or Conversion of Small Structures, which reads, “Class 3 consists of construction and location of limited numbers of new, small facilities or structures; installation of small new equipment and facilities in small structures; and the conversion of existing small structures from one use to another where only minor modifications are made in the exterior of the structure...” Lastly, the common sense exemption which states that “CEQA applies only to projects which have the potential for causing a significant effect on the environment. Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA.” The Bradshaw Road 69kV Extension project involves the replacement of existing utility poles within the project limits and extending a 69kV line above an existing 12kV line in the project area to better utilize existing capacity and provide redundancy. A section of the 12kV line would be installed underground and the surface would be restored to the condition existing prior to the undergrounding. The purpose of the project is to increase reliability in the area during planned or unplanned outages and to better utilize existing capacity and therefore is considered exempt in accordance with CEQA Guidelines §15301, §15302, §15303, and §15061(b)(3).