1.1
Project background
Level
(3) Communications, LLC (“Level (3)”), a U.S.
telecommunications company, is building the first international
fiber optic network optimized for internet technology. The company is currently connecting
various city pairs in the United States by constructing a national
Long-Haul Network mainly in utility ROW for the transmission of voice and
data services. Approximately
2,000 miles of this network will be located in California (Figure 1).
In
Decision No. 98-03-066 issued
March 26,1998 (“Decision”), the California Public Utilities Commission
("CPUC" or "Commission") granted Level (3) a
Certificate of Public Convenience and Necessity ("CPCN") to
provide services to the public as a facilities-based competitive local
exchange carrier. The
Commission’s Decision allows Level (3) to construct underground
innerduct and cable installation and support facilities (e.g., emergency
power supply) within existing utility ROW, subject to certain conditions
and the “Environmental Mitigation Measures” specified in the
Commission’s Negative Declaration IX (Appendix D of the subject
decision). The
Commission concluded that implementation of these measures would ensure
that impacts associated with the project would be less than significant.
According to the measures specified under “All Environmental
Factors,” a Petition to Modify (or “Application for Modification
of”) the CPCN must be filed to obtain approval for off-ROW work.
As part of this Application for Modification, Level (3) must
perform a site-specific assessment of the potential impacts associated
with off-ROW design, construction, and operation activities. These off-ROW
elements of the California Network are herein referred to as “project
elements.”
To
address the Commission’s requirements for off-ROW work, Level (3)
prepared and submitted its Proponent’s Environmental Assessment
(“PEA”) on May 21, 1999 as part of its filing of an Application for
Modification of its CPCN. This
assessment was responsive to the specifications of Rule 17.1 of the Commission’s Rules of
Practice and Procedures (the Special Procedure for Implementation of the
California Environmental Quality Act of 1970) and the Commission’s
Information and Criteria List.
The
May 21st submittal included CEQA checklists for 31 vacant (and
largely undeveloped) land sites where construction of ILAs, 3Rs, and
D-Nodes were proposed, as well as 3 Workarounds.
On June 15th Level (3) submitted an addendum to the PEA
which included checklists for two additional vacant land sites.
The
CPUC provided review comments on these submittals on June 18th and
June 28th, prompting Level (3) to reevaluate its
off-ROW system needs. As a
result, Level (3) substantially reduced both the number of (off-ROW)
project elements and the potential for environmental impacts associated
with those selected for inclusion in the California Network.
This transition from what were largely
undeveloped sites to ROW sites and off-ROW developed or disturbed sites
imposed a substantial cost burden on Level (3), but was determined to be
the environmentally superior system design as mandated by CEQA.
The revised PEA, which included CEQA checklists for 25 off-ROW
project elements (22 facilities and 3 Workarounds), was submitted to CPUC
on October 1.
CPUC
conducted a preliminary review of Level (3)’s October 1 submittal and,
on October 14th, provided 12 “threshold comments” to which
responses were needed before the October 1 submittal could be fully
evaluated. On November 11, as
part of Level (3)’s response to these threshold comments, 5 additional
CEQA checklists (4 facilities and 1 Workaround) were submitted to CPUC,
and CPUC was notified that 5 of the October 1 off-ROW project elements had
been dropped. Since the
November 11th submittal, one additional facility (Escondido ILA)
has been relocated to ROW, and the CEQA checklist for the October 1 site
has been dropped. This change
reduced the suite of off-ROW project elements for which CEQA checklists
were required to 24 (20 facilities and 4 Workarounds).
These 24 project elements were the subject of Level (3)’s January
4th Draft Final PEA.
Subsequent
to the Jan 4th submittal, Level (3) dropped the Irvine D-Node
site from the California Network. . Therefore,
this Final PEA addresses 23 project elements, which fall into the
following categories:
- Facilities
within existing structures on developed sites (9 project elements);
- Facilities
on the existing foundations of demolished or removed structures on
developed sites (5 project elements);
- Facilities
on vacant developed sites (2 project elements);
- Facilities
on disturbed undeveloped sites (3 project elements); and
- Workarounds
(4 project elements)
1.2
PURPOSE AND
SCOPE OF THE PEA
Pursuant to
the Environmental Mitigation Measures of
CPUC’s Negative Declaration IX, and specifically the measures included
under “All Environmental Factors,” Level (3) has prepared this
PEA to accompany the Application for Modification of its CPCN.
As specified in CPUC Rule 17.1, the PEA is designed to enable the
Commission to quickly focus on project impacts which may be of concern.
The PEA may also be used as an aid in
preparing the Commission’s Initial Study.
The information provided is intended to support the Commission's
responsibilities as lead agency under the California Environmental Quality
Act of 1970 ("CEQA," PRC § 21000 et
seq. and the CEQA
Guidelines, CCR Title 14 § 15000 et seq.), to assist other reviews or evaluations by CEQA responsible
or trustee agencies, and to facilitate agency actions in accordance with
the Permit Streamlining Act (CGC § 65920 et seq.).
This
PEA has been developed to be consistent with, and responsive to, Section V
Environmental Information Requirements, of the CPUC’s Information and
Criteria List (adopted pursuant to Chapter 1200 of the Statutes of 1977,
Government Code Sections 65940 through 65942), which applies to all
projects subject to CEQA for which Commission approval is required by law.
To
meet these requirements, the PEA presents Level (3)’s detailed
environmental assessment of proposed (off-ROW) project elements. The assessment:
·
Identifies probable direct or
reasonably foreseeable indirect physical changes in the environment that
would result from construction or operation of these project elements;
·
Analyzes the potential impacts of these
physical changes to each of 16 potentially affected environmental issue
areas; and
·
Recommends measures to ensure that
potential impacts are kept at less-than-significant levels.
Summary
information is also provided on Level (3)’s proposed on-ROW ILA sites
(Appendix G). More detailed
treatment of these on-ROW ILA sites is provided in the individual Facility
Construction Workbooks.
1.3
LEVEL (3) ENVIRONMENTAL COMMITMENTS
Level (3) is committed to avoiding or reducing to
less-than-significant levels any potentially significant environmental
impacts resulting from off-ROW work activities.
Level (3) has conducted a rigorous evaluation of the potential for
off-ROW impacts. Level
(3)’s decision to re-configure the California Network with emphasis on
placement of project elements within utility ROW, on developed parcels,
and on disturbed sites represents a strong commitment by the company to
maintaining the quality of California’s environment and being fully
responsive to CEQA.
This PEA identifies those actions that Level (3) will undertake to
ensure that any potential environmental impacts are less than significant.
These actions include integration into project planning, design,
and technical specifications all “Environmental Mitigation Measures”
stipulated in Appendix D of the Commission’s Negative Declaration IX
(see Appendix B of this PEA) as well as other appropriate measures.
In so doing, these mitigation measures become Level (3)
Site-Specific Environmental Commitments and potentially significant
impacts addressed by them are now considered to be less than significant.
1.4
Major Conclusions
Due
substantially to an alternatives evaluation process that favored selection
of developed and disturbed sites with minimal environmental attributes,
Level (3)’s detailed impact assessment found that the potential
environmental impacts for all (off-ROW) project elements are less than
significant for all impact assessment issues.
Technical analyses that support this conclusion are reported in the
site-specific CEQA checklists in Appendix A.
The need for mitigation measures, per
se, has been avoided by integrating into the planning and design of
the California network Site-Specific Environmental Commitments that ensure
that any and all potential impacts do not exceed less-than-significant
levels. This approach was especially beneficial with respect to
cultural resources, biological resources, and land use issues.
As
a result of the rigorous alternatives evaluation criteria designed to
avoid impacts along with Level (3)’s Environmental Commitments, no
impacts or areas of concern result from the proposed actions.
Level (3) concludes that there are no issues remaining that would
change the conclusions of this impact assessment.
2.0
PROJECT PURPOSE AND NEED
Level (3) is
authorized to build a state-of-the-art underground fiber optic system that
relies on internet technology and protocols and sets new standards for the
telecommunications industry to serve the burgeoning communication needs of
California. The California
Network (Figure 1) is part of the 15,000-mile national network that will
change the way people across the U.S., and ultimately the world,
communicate.
2.1
Purpose
of the project
The purpose
of the California Network project is to offer businesses and communities
in California competitive choices in the provisioning of innovative and
efficient telecommunications services and equipment.
Such choices offer significant benefits to end users in our State,
including lower prices, faster and more reliable data transmission, and
increased diversification. Level
(3) will offer a variety of services to enhance user’s Internet access,
phone calls, faxes, and other telecommunication needs.
The design of
this network integrates the latest technology with sufficient capacity,
bandwidth, and speed to meet rapidly expanding consumer demand with
minimal environmental impacts. The
Level (3) network is the first to provide Gigabit Ethernet as a standard
option for directly connecting customer server and network equipment.
Interconnection of the California network with Level (3)’s
international network will build upon a combination of facilities-based
and resold switches, interexchange points of presence, central offices,
and gateways. The Level (3)
international network is the first such network optimized end-to-end for
IP technology.
2.2
PROJECT NEED
The project
will provide the benefits of competition to the consumers of the State of
California, which is one of two areas in the U.S. that have been given
priority in Level (3)’s schedule for network implementation. Construction of the world’s most sophisticated and
technologically advanced telecommunications network will keep California
at the forefront of internet technology and availability, and ensure
services second to none well into the future.
By implementing state-of-the-art technology, Level (3) can provide
competitive service with minimal environmental impacts.
Level (3) firmly believes this project will have a positive impact
on the communities served by the network by providing a range of
cost-effective telecommunications services, new infrastructure, and local
jobs.
The need for
the 23 off-ROW project elements is addressed in more detail in Section 3.0
Project Description.
3.0
PROJECT DESCRIPTION
This section
provides a broad overview and regional perspective of the California
Network and its elements. The
23 off-ROW project elements that are subject to CEQA analysis are
described in detail in the Appendix A checklists.
On-ROW network elements are briefly described in Appendix G, and
described in greater detail in the Facility Construction Workbooks.
3.1
INTRODUCTION
Level (3) is
developing the first international fiber optic voice and data transmission
network optimized for internet technology.
Level (3)’s network will make possible a major and highly
beneficial shift in communications. Information
is typically transferred worldwide over the Internet via high-bandwidth
fiber optic cables. Information
that moves over the Internet is broken into pieces called
"packets.” These packets are coded with address information for
delivery and reassembled into their original form upon reaching their
proper destination. Two important communication tools make this process work.
One divides and reassembles the packets while the other ensures
packets reach their correct destination.
Together, these tools allow for a single, unbroken connection
between sender and receiver, and make data transmission much quicker and
more efficient than transmission through traditional circuit-switched
networks designed almost a century ago.
The Level (3) network embraces the “packet-switched” design
using an Internet-based technology. Unlike
other planned major fiber optic networks, Level (3)’s system will
combine both local and long distance connections, linking customers
end-to-end across the United States.
As part of
this ambitious effort, the company is building a 15,000-mile Long-Haul
Network across North America. The
vast majority of this network will be located within utility ROW. Level (3) has targeted proposed routes in California and in
the Boston-to-Washington D.C. corridor
as first priorities in its nationwide network because of their ability to
link major U.S. population centers. In
California, Level (3) is building two main routes covering approximately
2,000 miles. Level (3)’s
California Network project includes the design and construction of a
city-to-city fiber optic network with multiple fiber ducts. The California
Network will serve the entire state and will link California with the rest
of the U.S. and the world
(Figure 1).
Level (3) was
granted a CPCN in Decision 98-03-066 by the CPUC to provide switched and
dedicated, resale, and facilities-based, inter-exchange and local exchange
telecommunications services in California.
The original CPCN Decision did not address construction of project
elements outside utility ROW. Such
construction is required in some locations for Long-Haul cable placement
or support facility development. Collectively,
these off-ROW activities constitute a “project” as defined by CEQA.
The checklists in Appendix A provide a detailed description and
impact assessment of each project element.
The types of
off-ROW support facilities addressed in this PEA that are required to make
the network operational are:
·
In-Line
Amplification Units (ILAs) – The technology used in
Level (3)’s fiber optic network requires amplification of the
light signal being transmitted through the fiber approximately every
60-miles along the Long-Haul network.
The proposed ILA units occupy approximately 3,000 square feet, with
a total of approximately 5,000 square feet of total development at the
site;
·
Regeneration Units
(3Rs) - A regeneration station is an integral
part of the operation of a fiber network.
Regeneration is the process of re-shaping, re-timing, and
re-modulating the optical signal. The
resulting signal is filtered of noise and directed to the end destination
along the fiber. The optical
signal is converted to an electrical signal and then back to an optical
signal through the 3R processing. Current
technology limits the distance an optical signal can travel to about 300
miles without going through a regeneration process.
The 3R station, which requires about 6,000 square feet of space,
would be assembled at the site and would contain equipment to regenerate
the signals carried on the fiber optic network;
·
Distribution Nodes
(D-Nodes) – The Long-Haul fiber optic network is
connected to local telecommunication systems through distribution nodes.
A D-node facility size is about 20,000 square feet, subject to
local building and zoning codes. The
larger size of a node (compared to an ILA or 3R) allows the installation
of additional hardware needed to connect the fiber optic network to local
telecommunication systems. A
particular D-Node will perform the ILA or 3R function, depending on its
location along the network; and
·
Terminals - A terminal, which typically marks the
point where two segments of the running line come together, is designed to
direct traffic (signals) to major distribution centers and elsewhere on
the Level (3) network. These
facilities are also designed to allow other telecommunication customers to
co-locate within the facility.
Depending on its location along the network, a terminal will also
perform ILA, 3R, or D-Node functions.
The
project elements described herein are necessary and sufficient to operate
the system and meet existing and expected demand.
Any further construction or expansion of the network and associated
support facilities is speculative because of the rapidly changing
technology in this industry and is not proposed herein.
The ultimate configuration of the project elements may vary because
of site configuration, engineering constraints, or the presence of
drainage constraints, natural resource concerns, wetlands, or cultural or
historical resources. Because
of their modular construction, huts can be added to ILA sites as service
load increases and additional fiber optic cables are installed in unused
ducts.
For
the project herein proposed, each ILA, 3R, D-node, and Terminal will have
signal amplification and emergency generator capabilities needed to
service a maximum of four fiber optic cables.
Each 3R will have regeneration capabilities required to service up
to four cables, as will those D-Nodes, and terminals that must also serve
a 3R function based on their location along the California network.
Four fiber optic cables are sufficient to meet the identified needs
of Level (3) and its lessees.
While Level
(3)'s Long-Haul Project will include laying 12 fiber ducts that could
potentially carry fiber optic lines in the future, it is unknown at this
time whether this capacity will ever be put into use.
Level (3) has made a business decision to include additional fiber
optic cable capacity in this manner so that future “installation” of
such cables will not require ground disturbance along the conduit
right-of-way with the attendant environmental impacts.
Level (3) may utilize this capacity in the future or may lease the
capacity to other carriers, thereby minimizing future ground disturbance
by the industry as a whole. Additionally,
the incremental cost of laying empty conduit now, as compared to having to
go back at some time in the future and lay more conduit, is relatively
small. At this time, however,
Level (3) has no definite plans to use any capacity beyond the four ducts
herein addressed, and the possibility of such use is highly speculative. Rapid technological development has already significantly
increased the information capacity of a single line and may render the
additional capacity unnecessary. Moreover,
it is anticipated that technological advances in fiber optic technology
will minimize both the need for and size of ancillary equipment such as
ILA, 3R, D-Node, and Terminal facilities, such that it would be
speculative to plan for such facilities at this time.
Finally, the number and capacity of fiber optic cable systems being
installed by other carriers makes the future market for additional fiber
optic cables uncertain and speculative.
According to CEQA Guidelines, the possible future expansion of a
project, which is speculative, need not be considered in determining the
significance of the environmental effects caused by a project.
3.2
Project Location
As
herein defined, a “location” is the general area or vicinity in which
a network element is situated. Locations
of all 40 elements supporting the California Network are provided in
Figure 2 and Table 1.
Of
the 40 network elements shown in Figure 2 and Table 1, 23 are located
outside of ROW and not within existing telecommunications facilities.
These 23 project elements include 19 support facilities and four
Workarounds. Each is
addressed in detail in the site-specific CEQA checklists (see Appendix A).
Thirteen (13) additional ILAs will be located on existing utility
ROW. Each is briefly
described in Appendix G and more fully addressed in the site-specific
Facility Construction Workbooks. The
four Gateways will be co-located in existing telecommunications facilities
and are outside the scope of this PEA.
The
“Map ID” numbers in Table 1 correspond to the identification numbers
on Figure 2. The 23
project elements are assigned MAP ID numbers 1-23, the 13 on-ROW ILA sites
are assigned MAP ID numbers 24-36, and the 4 Gateways are assigned MAP ID
numbers 37-40. The right-hand
column in Table 1 (“PEA Status”) identifies the 23 project elements as
“Included,” the 13 on-ROW ILA sites as “Line Book,” and the four
Gateways as “Not Applicable.” In Appendix A, the tab number for each
project element corresponds the MAP ID number in Table 2 and
identification number on Figure 1.
The
five types of network support facilities (i.e., ILAs, 3Rs, D-Nodes,
Terminals, and Gateways) are positioned along the network to perform
functions necessary to provide integrated telecommunications services
throughout the State of California, and to link California users with
users across the nation and much of the world.
Workarounds are located adjacent to the running line ROW in areas
where engineering or environmental concerns required the running line to
diverge from the ROW.
After
travelling approximately 60 miles along the Long-Haul network, signals
require amplification, a function performed by an ILA station.
However, as the amplified signal travels
along the fiber, it also becomes increasingly distorted because of
splicing and imperfections in the fiber.
After the fifth ILA in a series, the signal can no longer just be
amplified to maintain system standards.
It must be re-generated, re-shaped, and re-timed at approximately
300-mile intervals, a function of a 3R station.
A typical 3R facility also provides the signal amplification
function of an ILA station. D-Nodes are required to distribute
signal to customers. A D-Node
and Terminal may also perform the ILA or 3R function depending on its
relative location along the network.
Similarly, Terminals may also incorporate D-Node capabilities as
their position along the network may require.
Thus, while an ILA per se may not exist at every 60-mile interval along the Long-Haul
running line and a 3R per se may
not exist at every 300-mile interval, their functions are accomplished at
these intervals by other support facilities.
Table
2 provides a summary of characteristics of each of the 19 (non-Workaround)
support facilities that are key to assessment of impacts from the proposed
action(s). Information
particularly important to assessing construction-related impacts include
the presence and usability of on-site buildings, the size of the area of
grading, and size of the primary structure.
The most important factor for assessing operational impacts is the
capacity of the emergency generator.
A detailed analysis of the impacts of each of these 19 support
facilities and the four Workarounds with regard to each of the 16 impact
assessment areas is provided in the Appendix A checklists.
3.3
CONSTRUCTION AND OPERATION
OVERVIEW
Section
8, Description of Facility, of each Appendix A checklist provides a
summary description of the construction and operation activities
associated with the project element.
Impacts at Workarounds are restricted to the construction-phase
since operations-phase activities are negligible (i.e., Workarounds are
functionally identical to the running line).
For the other 19 project elements, impacts associated with both
facility construction and operation must be assessed.
Construction
Activities
Development
of ILA, 3R, D-Node, and Terminal facilities may include some or all of the
following, depending on the functions and characteristics of the
particular site:
·
Pre-construction surveys as required to
mark environmentally sensitive resources for avoidance;
·
Site brush clearance and grubbing;
·
Building demolition and debris removal;
·
Minimal grading;
·
Pouring of a foundation slab and
driveway improvements;
·
Delivery of prefabricated building
components;
·
Assembly of prefabricated structures or
buildings;
·
Connection of the facility to the
Long-Haul network (cable installation and hookup,
see Workaround construction, below).
·
Connection of utilities (electrical
power, telephone, sewer and potable water);
·
Installation of fencing; and
·
Site finishing (e.g., landscape
vegetation, architectural treatments).
Figures
3 is an artist’s representation of a 4-hut ILA installation with
generator shelter (sufficient to service four fiber optic cable fibers),
while Figure 4 is an artist’s representation of delivery of a single ILA
hut to the construction site.
Off-site
staging and parking will not be required at any of these facilities during
either construction or operation phases.
Construction
at Workarounds will involve the following:
·
Pre-construction surveys to mark
environmentally sensitive resources for avoidance;
·
Site brush clearance and grubbing;
·
Disturbing a section of earth,
approximately 1 foot wide by 5 feet deep, by means of plowing, trenching,
or boring (maximum width of ground disturbance by vehicles is 20 feet);
·
Inserting PVC innerducts within the
trench while simultaneously backfilling the trench after the innerduct is
installed; and
·
Burying handhole structures to connect
innerduct sections.
Table
3 of each checklist in Appendix A provides detailed quantitative and
descriptive information on the construction and operation activities at
each site, including the following:
·
Equipment
(e.g., graders, excavators, and water trucks) that will be used at the
construction site. Included
are the size (in gross horsepower (hp)) and number of units of each type
of equipment, and the numbers of hours per day and days that each piece of
equipment will operate;
·
Numbers of trips and one-way commuting distance (miles) that members of
the construction crew will travel to the construction site;
·
Number of trips per day, total number of trips, and number of one-way
miles traveled by material delivery vehicles (e.g., cement and gravel
trucks); and
·
The amount of material
(soil) that will be disturbed during cable placement operations at the
proposed site.
Methods and
specifications for construction of several categories of project elements
are described in detail in Appendices C and D.
These construction techniques and standards have been designed to
avoid or minimize damage to the environment.
Level (3) has introduced state-of-the-art and “environmentally
friendly” equipment for construction.
Technologically advanced equipment like the “spider” plow,
equipment with large, low-pressure tires, and directional boring will be
used whenever possible to minimize impacts to sensitive natural or
cultural resources and to avoid encroachment on public roads.
Appendix E describes the measures Level (3) will implement to avoid
and minimize water quality impacts during construction.
Responsiveness
of Level (3)’s construction practices to environmental concerns is
ensured by adoption of the issue-specific Environmental Mitigation
Measures identified in the Negative Declaration IX and other relevant and
appropriate measures in project planning and design.
For example, procedures and practices to control fugitive dust
during site grading and cable placement will be followed as specified by
local or air quality maintenance permits.
Noise will be controlled through observance of allowable work
periods, generator shelter insulation and placement, and construction
equipment mufflers. Use of
equipment that meets BACT will help reduce the potential for air quality
impacts. These measures,
which have been incorporated into Level (3)’s standard operating
procedures, are termed “Environmental Commitments” in the checklists.
The
construction duration for an ILA site is 30 to 45 working days, depending
on the characteristics of the particular site and associated logistic
considerations. The
construction duration for a 3R facility is approximately 24 weeks, while
that for a D-Node or Terminal is approximately 28 weeks.
Workaround construction will vary from
several days to several weeks, depending on the length of the Workaround.
Construction activities within an air
basin will be sequenced, as necessary, to avoid significant air quality
impacts, based on comparison of estimates of district-total emissions to
conservative thresholds (see Section III of the Appendix A checklists).
Level (3)
does not currently know when approval for construction of off-ROW project
elements will be granted and station construction can be initiated;
therefore, the precise construction schedule has not been established. However, Level (3)’s commitment to sequence construction
where necessary to achieve environmental compliance is unambiguous.
Construction schedules will be detailed in Level (3)’s Quarterly
Reports to CPUC as well as in the segment Line Books.
The
company's timetable for the Long-Haul network calls for the completion of
both the Easterly and Westerly Sacramento to Los Angeles routes before the
end of year 2000.
Operation
Activities
The ILA, 3R, and D-node sites that
perform ILA functions (i.e., ILA D-Nodes) will not be permanently staffed.
Operational impacts will be associated with the approximately
weekly site visits for data logging and maintenance and the weekly
automated testing of the emergency generators (which does not require a
site visit). The 3R D-nodes
(i.e., those D-Nodes that also perform the 3R function) and Terminals will
be permanently staffed (3 individuals each).
Operational impacts at these sites will be associated with daily
commutes and use of the facility , and automatic emergency generator
testing.
Table
3 of each Appendix A checklist provides detailed quantitative and
descriptive information on the operation activities at each site,
including the following:
·
Size/gross horsepower of the standby
generator and its duration of activity; and
·
Number and distances of vehicular trips
to the site associated with site operation, maintenance, and data logging.
Except
for the occasional inspection visit, there are no operation activities
associated with the Workarounds.
3.4
Required Permits and Approvals
Consistent
with the Environmental Mitigation Measures identified in Negative
Declaration IX, all necessary local, state, or federal permits, and
approvals will be obtained for each ILA, 3R, D-node, Terminal, and
Workaround. These
permits and approvals are discussed in detail in each Appendix A checklist
under Item 10 (Other Agencies Whose Approval Is Required) of the
“Environmental Checklist” section and under the relevant impact
assessment areas of the “Environmental Impacts” section.
3.5
Level (3) Environmental Commitments
Level
(3) is committed to avoiding or reducing to less-than-significant levels
any potentially significant environmental impacts resulting from off-ROW
work activities. This
goal will be met through implementation of Level (3)’s Environmental
Commitments (based on the Mitigation Measures in the Negative Declaration
IX and other appropriate environmental concerns), Level (3)’s corporate
policies on environmental protection and safety, and any additional
requirements that CPUC may impose based on its Initial Study.
These commitments and corporate policies are addressed below.
Level (3) continues to file its Quarterly Reports as required by
the CPCN, and will integrate the project elements into this reporting
process once the CPCN is modified.
Environmental
Mitigation Measures
Level
(3) has incorporated all of the mitigation measures specified in Negative
Declaration IX, as well as additional appropriate measures, into the
planning, design, construction, and operation of the project elements
addressed in this PEA. Therefore,
all actions previously identified as mitigation measures for ROW network
construction and operation are now part of Level (3)’s Environmental
Commitments for off-ROW activities. These
Environmental Commitments include:
·
Measures to avoid or minimize potential
impacts to various resources;
·
Commitment to obtain all approvals and
permits required for construction and operation of the project;
·
Coordination and/or consultation with
local and resource management agencies;
·
Notifications to adjacent property
owners;
·
Coordination with other utility
projects in the area; and
·
Documentation and reporting of
compliance measures.
Level
(3)’s decision to reconfigure the network with emphasis on placement of
project elements within ROW, on developed parcels, and on disturbed sites
is a strong commitment to maintaining the quality of California’s
environment and being responsive to CEQA.
Level
(3) Corporate Policies and Approach to Environmental Quality
Above and
beyond Level (3)’s Environmental Commitments, this project incorporates
Level (3)'s corporate policies and procedures on environmental quality as
standard measures in project design, construction, and operation.
Level (3) has
issued an "Environmental/Cultural Resources Philosophy"
statement that defines what Level (3) expects from its employees and
contractors. The statement
promotes employee and contractor awareness of the company's goal to comply
with the conditions of its CPCN and permits and thus protect the long-term
quality of the environment wherever it constructs.
Native American, archaeologists, endangered species specialists,
and environmental inspectors currently provide oversight during Long-Haul
construction, and are expected to do the same for off-ROW reviews.
Level (3)’s
multidisciplinary team of in-house environmental specialists communicates
the company’s commitment to compliance with the conditions of its CPCN
and various permits, and ensures that all contractors are aware of the
adverse impact that non-compliance could have on both the environment and
the construction schedule.
Level (3)’s
commitment to protecting the quality of the environment includes, but is
not limited to:
·
Utilizing a highly reputable contractor
with experience with California's environmental policies, laws, and
regulations, as its construction contractor.
The construction contractor then hired a national engineering firm
with a strong presence in California to manage the acquisition of the
needed permits by subcontractors;
·
Training the construction managers and
crews and providing guidance to construction managers and crews via permit
workbooks;
·
Employing a site selection process that
emphasized environmental protection over cost, and was successful in
siting all facilities on developed and/or disturbed properties;
·
Implementing state-of-the-art and
costly “environmentally-friendly” construction methods to avoid or
minimize impacts to sensitive or regulated areas.
Such methods include, but are not limited to:
·
Boring under streams and sensitive
resource areas instead of plowing through them;
·
Employing "spider" plows that
leave a smaller "footprint" in sensitive areas; and
·
Putting larger tires on vehicles to
reduce soil disturbance and compaction;
·
Requiring construction contractors and
subcontractors to define and implement very aggressive safety and
environmental protection programs;
·
Actively seeking opportunities to
participate in "joint-build" opportunities in order to reduce
costs and minimize environmental impacts.
4.0
ENVIRONMENTAL SETTING
Item
9, Surrounding Land Uses and Environmental Setting, of the
“Environmental Checklist” section of each Appendix A checklist
includes a discussion of the setting of the particular (on-ROW) project
element. These discussions are supported by Figure 5 that shows the
surrounding land use and by a set of photos that visually display the site
characteristics as well as those of the surrounding landscape.
Figure 6, the photo key map, identifies the vantage points from
which each photo was taken. Figure 7, the conceptual plot plan, schematically shows
actual or proposed development appurtenances in the immediate vicinity of
each non-Workaround element, while Figure 8 (Figure 7 for the Workarounds)
depicts the locations of public and sensitive receptors relevant to air
and noise analysis. As
appropriate and relevant, the checklists also include figures depicting
the presence of wetlands and floodplains within the vicinity of the
project element.
In
addition to the Item 9 setting description, many issue-specific sections
under the “Environmental Impacts” section of these checklists include
a “setting” discussion that describes those aspects of the local
environment of particular concern to that specific issue area.
Table 2
provides a summary of the salient features for each non-Workaround project
element. Information provided
in Table 2 includes:
·
Proposed location;
·
Zoning designation;
·
Parcel size;
·
Project element space requirement;
·
Size of existing building (if present)
and demolition status;
·
Type and status of existing fencing;
·
Size of new buildings (main facility
and generator structure) ;
·
Generator and fuel tank capacities;
·
Area of grading or otherwise disturbed
surfaces;
·
Facility staffing requirement; and
·
Estimate of solid waste volume to be
generated during construction.
In addition,
The Appendix A checklist for each of the 23 off-ROW project elements
includes detailed maps showing the locations and boundaries of each site.
The 13 on-ROW
ILA sites are briefly described in Appendix G that includes generic
designs for the 3000- and 5000-square foot ILA facilities.
Construction Workbooks are being developed to provide all CPUC-required
information for these off-ROW ILAs to the construction crews.
The Construction Action Lists (CALs) in the segment Line Books are
also being updated to: (1) denote the locations of proposed on- and
off-ROW facilities as construction exclusion areas; (2) specify the
permitting, monitoring, and mitigation requirements; and, (3) identify the
need for CPUC approval prior to construction (e.g., the CAL inserts will
be “gray” until approval is granted).
5.0
Environmental Impact
Assessment Summary
A
detailed assessment of impacts for each project element was conducted by
addressing each of the 86 questions contained in the CEQA Checklist.
The results are presented in the 23 element-specific Appendix A
checklists. This
assessment incorporated Level (3)’s Environmental Commitments, which
include the mitigation measures required by the Level (3) CPCN Decision
(Appendix B) and other appropriate actions.
The detailed assessment process was used to identify potential
environmental impacts for which implementation of these Environmental
Commitments will be required. In
this way, the Environmental Commitments became integral components of
Level (3)’s project design and planning.
Assessment
of potential impact requires that thresholds of significance be defined.
The thresholds defined in the 1998 CEQA Revisions and Checklist
were employed in this PEA. Each of the 86 detailed questions in the CEQA Checklist
provides a description of how significance is to be judged.
5.1
IMPACT
ASSESSMENT METHODOLOGY
Assessment
of project-related impacts proceeded as a four-step process, as follows:
1.
Preparation of field questionnaires;
2.
Implementation of site visits;
3.
Discipline-specific impact analyses;
and
4.
Cumulative impact assessment.
Each of these
four steps in the assessment process are discussed in the following
paragraphs.
Preparation
of Field Questionnaires
To ensure
that all information needed for impact assessment was acquired in an
expeditious manner, field questionnaires were developed.
Five such forms were developed, as follows: (1) General Agency
Questionnaire, (2) General Field Questionnaire, (3) Cultural
Questionnaire, (4) Biological Questionnaire, and (5) Hazards
Questionnaire.
The general
field and general agency questionnaires includes information required to
address all land use-related areas as well as air quality, noise, water
quality, and geology issues.
To ensure the
thoroughness of these questionnaires and their responsiveness to CPUC
needs, Level (3) conducted a detailed reevaluation of existing checklists
subsequent to receipt of CPUC comments on the May 21st and June
18th submittals. With
Team members from all disciplines assembled, each existing checklist was
compared to CPUC comments and amended, as appropriate, for completeness.
Site Visits
Once the
questionnaires were complete, a multidisciplinary team visited each site.
In general, each field team included a biologist, a land use
planner, and a cultural resources specialist.
These individuals evaluated the site, filled out the
questionnaires, and in cases where the need was identified, specified
additional types of expertise for which a follow-on site visit would be
appropriate. For example, the
cultural resources specialist made an initial evaluation of the historical
significance of any structures on the site and, as appropriate, identified
the need for an Historical Architect to visit the site and evaluate its
historic significance. The
Team took numerous photographs, particularly of site attributes whose
evaluation might require a site visit by team members with other
expertise. The photos and field questionnaires were then evaluated in
detail for final determination regarding the need for additional site
visits. The land use planner
also took the opportunity to visit local agency offices and acquire land
use plans, parcel maps, and other pertinent background information.
Once the
field work was over, the field checklists were completed and distributed
to team members involved in the detailed evaluation of impacts.
Discipline-Specific
Evaluation Methodologies
While the
information from the site visits was essential to the impact evaluation,
it was not all that was required. While
these field efforts were underway, Level (3) engineers were conducting
preliminary design of the project elements and providing key information
on design, construction, and operation parameters needed for impact
assessment. Once this information was developed, the basis for detailed,
discipline-specific impact assessment was established.
In the following paragraphs, the methodologies utilized in each
impact assessment area is summarized.
Land Use, Aesthetics, Agricultural Resources,
Mineral Resources, Population and Housing, Public Services, Recreation,
Transportation/Traffic, Utilities and Service Systems
Following the
field visits, information in the field checklists, acquired documents, and
follow-up telephone interviews with personnel from appropriate agencies
was collected and analyzed to determine the overall environmental impacts
of each project element and to address the specific questions in the CEQA
checklist. Some of the most
important information included the assessor’s map and parcel number of
the site, information on surrounding properties, and the general
atmosphere of the surrounding area. Photographs
taken during the site visit were particularly helpful in addressing
aesthetic issues. Primary
documents reviewed included city and county general plans and zoning
ordinances. Information
available on websites, such as city and county population trends and
distributions and names of designated scenic highways, also proved useful.
Considerable information and confirmation of information in
documents was obtained through telephone conversations with agency and
other personnel (e.g., planners and engineers).
Additional information, such as location and capacity of solid
waste landfills from cities and counties, was independently gathered to
fill gaps in the data base.
Each analyst
determined the significance of project impacts using her/his judgement and
experience with similar projects. Unofficial
opinions of city and county staff members were also weighed into the
determination. Quantitative
estimates of project contributions and limiting values that could be used
to assess impacts were only available for a few issues (e.g., solid waste
generation and landfill capacities).
For example, the requirement to obtain a conditional use permit
when the project conformed with land use and zoning (but the zoning
ordinance did not specifically list the project or a similar type of
project) was usually not considered by itself to be a significant impact
on land use. Conditions that
may be attached to the use permit usually have to do with site plot plan
layout, fencing, egress/ingress, and similar conditions.
These types of conditions do not result in significant impacts to
the environment.
Air Quality/Noise
The air
quality and noise impact assessments were based on detailed identification
and quantification of construction and operation activities and equipment.
These data are summarized in tabular form in each checklist.
The key information derived from the field visits included
distances to public and sensitive receptors and environmental setting
information relevant to identifying ambient noise levels.
To the maximum extent possible, air quality and noise assessments
were integrated to assure consistency.
Construction and operation impacts were assessed separately because
activities were substantially different and typically subject to different
regulations.
For construction and operation phases,
the analytical sequence proceeded as follows:
·
Review and summarize federal, state,
and air district regulations, local noise regulations and ordinances, and
the noise element of the county or city general plan;
·
Identify and describe relevant source
activities and parameters;
·
Assemble emission factors and compute
emissions;
·
Describe noise levels produced by
source activities;
·
Describe project features that are
designed to keep air quality and noise impacts below a level of
significance; and
·
Determine the resulting level of
significance.
Proposed project design features that
keep air quality and noise impacts below a level of significance at
individual project elements include the following:
·
Fugitive dust control measures;
·
Construction and operation emissions
and noise would comply with local, state, and federal emission standards;
·
Construction scheduling would be
coordinated with other petitioners in locales where activities could
potentially cause considerably cumulative impacts; and
·
If significant construction noise were
expected, Level (3) would inform, at least two weeks in advance,
surrounding property owners and occupants, particularly school districts,
hospitals and residential neighborhoods, of the days when the most noise
would occur.
Compliance with these actions would be
documented in Level (3)’s quarterly report to the CPUC.
Biological Resources
Prior to
conducting a site visit, the California Natural Diversity Database was
searched for occurrence records of special status biological resources on
the 7.5 minute USGS quadrangle map(s) where the site is located. Potential habitat for each of these species was evaluated
during a site visit and their potential to occur is described in Table 5
of each checklist.
During the
site visit, a biologist walked over the property for one to two hours.
Notes and photographs were taken to document biological resources
located on and adjacent to the site.
Special attention was given to species identified during the CNDDB
search and protected or sensitive habitats.
In addition to evaluating species and habitats on the site,
consideration was given to the impact of the project on wildlife movement
corridors. All biological
features and photographic points were mapped onto a parcel map.
Cultural Resources
The
protocols contained in Level (3)’s
Long Haul Fiber Optics Project Cultural Resources Procedures (Parsons
Brinckerhoff Network Services, 1999), requiring records searches and field
survey, where appropriate, were followed for each facility site, as
summarized below. A technical
report, providing more information on the results of the records search
and field survey has been prepared for each of the facility sites.
For
Cultural Resources questions, record searches were obtained from the
appropriate information center of the California Historical Resources
Inventory System. These
searches had two objectives: (1) to determine whether previous
archaeological investigations have been conducted in the project area, and
(2) to provide information on known historic sites or culturally sensitive
areas on and in the vicinity of the proposed facility.
The Information Center staff checked maps on file and provided maps
showing locations of cultural resources within one mile of the parcel, and
provided site records. The
information centers sent a bibliography of survey reports and reports of
other investigations for the one mile radius.
The Information Centers also checked the Inventory of Historic
Resources from the Office of Historic Preservation, which includes State
Historic Landmarks and properties, listed or eligible for the National
Register of Historic Places, as well as properties evaluated, but not
determined eligible. Other
sources checked by each information center are listed in each checklist.
In addition,
the Level (3) Team sent letters dated June 3, September 3, and October 22,
1999 to the Native American Heritage Commission (NAHC) requesting a search
of the NAHC Sacred Lands file and identification of contact persons for
follow-on contact/consultation for each of the facility sites (Mason,
1999a, 1999b; White, 1999). The
responses, dated July 9, September 17, and November 9, 1999, indicated
that the NAHC searches revealed no available site-specific information on
Sacred Lands (McNulty, 1999a, 1999b, 1999c).
The response letters cautioned that absence of information did not
necessarily indicate the absence of cultural resources.
A list of Native American contacts that might serve as sources of
additional information was also provided.
For each project element, Level
(3) has sent letters to all NAHC-identified Native American contacts for
the particular county, notifying them of the Level (3) project activities
and requesting information they might have on sacred lands.
Any response indicating the possible presence of Sacred Lands will
be followed up with a detailed, site-specific evaluation utilizing the
expertise of the relevant Native American contacts.
For Cultural
Resources Question c), regarding paleontologic resources, a consulting
paleontologist, Dr. E.
Bruce Lander, obtained information on previously recorded fossil
localities and the potential for specific formations underlying the
project element parcels to yield fossils from the Invertebrate and
Vertebrate Paleontology Sections of the Natural History Museum of Los
Angeles County; the San Bernardino County Museum; the University of
California, Riverside, Campus Museum; and the University of California,
Berkeley, Museum of Paleontology. He
also consulted the California Division of Mines and Geology Geologic Map
Series and the Society of Vertebrate Paleontology Bulletin, as well as
other sources specific to individual parcels cited in the checklists.
Photographs
of parcels were taken by environmental planning staff and were reviewed by
the Consulting Archaeologist, Dr. Roger
D. Mason, to determine if
structures that appeared to be more than 50 years old were present and to
determine whether open ground (not paved or covered by gravel) was
present. If structures that
appeared to be more than 50 years old were present, they were evaluated
for the California Register by architectural historians Richard Starzak,
Gail Miller, and John Snyder. The
results of the evaluations are provided in the checklists as part of the
response to cultural resources Question a).
Appropriate DPR 523 forms were filled out for evaluated structures.
If open ground was present, a field survey was performed by
qualified archaeologists. The
results of the surveys are provided in the checklists as part of the
response to cultural resources Question b).
The
determination of the level of impact was based on whether significant
resources were known to be present on the proposed parcel or whether there
was only a potential to encounter such resources.
If a known significant cultural resource was identified on the
parcel, the level of impact would normally be assessed as “Less Than
Significant With Mitigation Incorporation.” However, if project design
would result in avoidance or no significant effect on the known
significant resource, the level of impact was assessed as “No Impact.”
If there were prehistoric or historic sites or isolated artifacts recorded
near the parcel, or if historic structures were known near the parcel,
there would be a potential for encountering subsurface prehistoric or
historic resources during construction.
In this case, the level of impact was assessed as “Less Than
Significant” because Level (3) has made an environmental commitment to
provide archaeological monitoring during construction in these situations.
For paleontology, the presence of fossils found elsewhere in
formations identified as being under the parcel would suggest the
potential for encountering similar fossils on the parcel.
All potential paleontologic impacts were assessed as “Less Than
Significant” because Level (3) made an environmental commitment to
provide paleontological monitoring during construction wherever necessary.
Geological Resources
The
geological resources assessment focused on examination of specific
geologic hazards to people and/or structures associated with each of the
proposed sites. The geologic
hazards evaluated include: (1) Alquist-Priolo Earthquake Zones; (2)
recently active faults; (3) potential ground failure; (4) landslide
potential; (5) subsidence; (6) erosion; and (7) expansive soils.
This evaluation was based on current available literature, proposed
facility structural design parameters and intended use, and Level (3)’s
prior environmental commitments to this project.
Hydrology and Water Quality
The factors
considered to evaluate the significance of an impact included site
habitation, proximity to specifically designated recharge areas, potential
for flooding from storm events or from a dam failure, amount of
topographic relief, and potential for inundation by tsunami or seiche.
The primary
references used to address each potential impact included County and City
General Plans, floodplain maps from Vista Information Solutions, and
inundation maps from the California Office of Emergency Services.
If a site was located within a groundwater recharge area or within
the area subject to inundation by a 100-year flood, dam failure, tsunami,
seiche, or mudflow, the impact was determined to be less than significant
because the facilities will be placed within an existing building and will
not be permanently occupied. A
“no impact” designation was assigned to those sites that were not
located within a groundwater recharge area or within an area subject to
inundation by a 100-year flood, dam failure, tsunami, seiche, or mudflow.
Hazards and Hazardous Materials
For
questions relating to hazards and hazardous materials, a reconnaissance of
the site was conducted and a record search was requested from Vista
Information Solutions, Inc. During
the site reconnaissance, a field questionnaire was completed and
photographs of the project sites were taken by environmental planning
staff. The field
questionnaire and photographs were used to document factual information
about the site and surrounding properties including conditions that might
expose people or structures in the area to a significant risk of loss,
injury, or death from safety hazards or hazardous materials.
The
VISTA records search consisted of a “Site Assessment Plus Report” and
a “NEPA Checklist” report. The
“Site Assessment Plus Report” covered 18 federal and state government
databases containing environmental information about properties in the
vicinity of the project site including properties that transport, use, or
dispose of hazardous materials, emit hazardous emissions, and handle
acutely hazardous materials. The
“NEPA Checklist” report covered 11 information sources that identified
nearby properties containing historic landmarks, parks, wild and scenic
rivers, wildlife preserves, areas of Native American significance,
floodplains, wetlands, and endangered species.
The field
questionnaires, photographs and record searches were compiled and reviewed
to determine if the project site or the proposed activities would create a
hazard to the public or the environment, including safety hazards for
people residing or working in the project area.
5.2
CUMULATIVE IMPACT ASSESSMENT
METHODOLOGY
In the
context of CEQA, cumulative impacts are two or more environmental effects
which, when considered together, are considerable or which compound or
increase other environmental impacts.
Additionally, the scope of the cumulative impact analysis in this
PEA includes the requirements of the Negative Declaration for the Level
(3) network regarding construction within existing utility ROW.
Thus, Level (3) must coordinate with other carriers and consult
with affected local agencies so that any cumulative impacts are minimized.
In addition, Level (3) has submitted reports to CPUC prior to the
beginning of each quarter that summarize construction projects anticipated
in the next three months. The
scope of the cumulative impact assessment in this PEA is limited to those
attributable to current and reasonably foreseeable future projects located
in the vicinity of the proposed project elements.
The results
of the cumulative impact assessment are addressed in the checklist for
each site.
6.0
Detailed Discussion of Significant Impacts
As a result
of rigorous siting criteria designed to avoid potential impacts along with
general and site-specific Environmental Commitments, the proposed project
will not result in any significant impacts.
7.0
alternatives to the proposed action
7.1
EVALUATION OF SITE ALTERNATIVES
Level (3)’s alternatives evaluation process was implemented
within the constraints imposed by the selected “ground zero” locations
along the Long-Haul network, as described in Section 3.2. At each location, the process focused on identifying
the site or sites that minimized the potential for environmental impacts while
satisfying network design requirements and constraints.
Typically, sites had to be within two miles of the “ground
zero” location. Lateral
siting options were largely restricted by this distance constraint.
When
initially configured (i.e., the May 21st and June 18th
submittals), the suite of proposed sites for California network support
facilities consisted largely of undeveloped sites. To minimize the potential for impacts, Level (3) subsequently
reconfigured the network by establishing as its primary evaluation
criterion that undeveloped sites would be considered only where suitable
developed or disturbed parcels could not be found.
As a result, the suite of facility sites herein proposed includes
no sites that are both undisturbed and undeveloped. In general, the alternative developed or disturbed sites at a
particular location that were subject to detailed evaluation all posed
comparably low potential environmental impacts.
Within the domain of developed and disturbed sites that were
identified by Level (3) land agents as meeting project requirements, the
following criteria were used to evaluate alternatives and select the site
with minimal environmental impacts:
Criterion
1: Highest alternatives ranking was given to sites on ROW.
These sites typically posed the lowest potential for impacts to the
environment. All were highly
disturbed and required no off-ROW connector routes.
Several segments of the Long-Haul running
line were relocated to take advantage of available ROW acreage.
Criterion
2: Off-ROW alternative sites were ranked in the following order of
preference:
1.
Sites with buildings that could be retrofitted;
2.
Developed (i.e., graded and otherwise enhanced) sites without
buildings;
3.
Sites with buildings that were of
sufficient size but could not be retrofitted (building demolition/removal
and use of existing foundations); and,
4.
Disturbed, undeveloped vacant land
sites.
Sites with
rankings 1-3 typically had access and parking facilities and were often
fenced.
Other generic
considerations in the alternatives evaluation process included: (1) the
presence of utility corridors to and from the ROW; (2) proximity to the
running line; (3) industrial, commercial, or mixed-use zoning; and, (4)
presence/absence of hazardous materials contamination on and adjacent to
the site.
The
alternatives evaluation process resulted in selection of 13 on-ROW sites
for ILA construction and 19 off-ROW sites for construction of ILAs, 3Rs,
D-Nodes, and Terminals. These
19 off-ROW sites included 9 with useable buildings, 2 developed, vacant
lots, 5 with buildings that
could not be retrofitted (requiring demolition or removal), and 3
disturbed, undeveloped properties (Table 1).
In a few cases, the owner of the alternative with highest ranking
was unwilling to sell at a reasonable price, requiring selection of
another alternative.
Potential
Workaround alignments were evaluated with the primary criterion being
avoidance of areas of potential environmental concern.
This typically involved staying as close as possible to the ROW
from which the Workaround diverged. Where
alignments lacking potential environmental issues did not exist,
environmental concerns were avoided using innovative engineering
techniques (i.e., directional boring).
7.2 EVALUATION OF THE NO PROJECT ALTERNATIVE
The
“no project” alternative assumes that no project elements will be
constructed outside of utility corridors.
Because it was not possible to locate all project elements
(including portions of the running line) within utility corridors, these
elements of the Level (3) project would not be built under this scenario.
As a result, the proposed fiber optic system in California would be
inoperable and would probably not be completed. Because Level (3)’s proposed project will have no
significant negative impacts on the environment, selection of the “no
project” alternative would not benefit the environment, and the
substantial environmental benefits of fiber optic cable communications as
compared to more conventional means of communication (e.g., reducing
travel by providing video conferencing and electronic transmission of
information, and reducing the requirements for raw materials such as
copper) would not be realized.
Under
the no project alternative, the ever-increasing demand for communication
services would have to be addressed through means other than Level (3)’s
fiber optic cable network. Given
Level (3)’s outstanding effort to design a system with minimal impacts,
construction and operation of other fiber optic-based systems would be
expected to have, at minimum, comparable and probably greater impacts. Therefore, these fiber optic-based systems would also
not be approved by CPUC. Wireless
communications systems might be built to fulfill demand, but these too
would be expected to have greater long-term impacts compared to fiber
optic cable systems. Alternatively,
the demand for communications would have to be handled by more
conventional technologies with substantially greater operational impacts
than the proposed project (e.g., resource use, aesthetics, air quality,
and transportation). In
addition, signals transmitted along conventional wire-based electric lines
are subject to interference, a problem not faced with fiber optic cable
systems. Table 3 summarizes
the potential impacts of the no project alternative by impact category.
8.0 GROWTH-INDUCING IMPACT OF THE PROPOSED ACTION
The
proposed project will not foster population growth, either directly or
indirectly, in the surrounding environment.
However, as part of the overall transition to a technology-based
society, the Level (3) network has the potential to contribute
substantially to the economic growth of California.
If Level (3)’s network or a similar fiber optic-based
telecommunications system is not developed, California would be at a
serious competitive disadvantage with other states and countries for
high-technology industry. The
situation could have disastrous consequences for the economy of
California.
The Level (3)
network will serve existing demand and provide for service expansion in
response to continually increasing signal transmission.
Population growth in California is not dependent on the
availability of fiber optic capacity. While
Level (3)’s network will address telecommunications needs associated
with population growth, business and residential use of telecommunications
services continue to increase independently of increases in population. This reflects the overall societal transition to
telecommunications-based commerce. The
substantial and on-going growth in telecommunications-based services
creates the need for additional capacity and new technologies apart from
those associated with increasing population.
Level (3)’s network will also increase the quality of
telecommunications service and contribute to the competitive choices
available to existing and future users.
9.0
AFFECTED
PROPERTY OWNERS
Appendix F
includes a tabular listing of affected property owners.
The entries in the Appendix F table are organized by City Pair
segment and project element. For
each adjacent property, tract type, parcel number, property owner, and
address are provided.
10.0
sources
Mason,
R.D., Chambers Group. Written
communication to Gail McNulty, Native American Heritage Commission, June
3, 1999a.
Mason,
R.D., Chambers Group. Written
communication to Gail McNulty, Native American Heritage Commission,
September 3, 1999b.
McNulty, G. Native American Heritage Commission. Written communication to Roger Mason, Chambers Group, July 9,
1999a.
McNulty,
G., Native American Heritage Commission.
Written communication to David White, Level (3) Long Haul Project,
September 17, 1999b.
McNulty,
G., Native American Heritage Commission.
Written communication to David White, Level (3) Long Haul Project
Team, November 9, 1999c.
Parsons
Brinckerhoff Network Services (PBNS).
Level (3) Long Haul Fiber
Optics Project: Cultural Resources Procedures, July 1999.
White, D., Level (3) Network Communications.
Written communication to Gail McNulty, California Native American
Heritage Commission, October 22, 1999 |
