UNDERGROUND ARIZONA - For a detailed analysis-
https://undergroundarizona.org/tep-midtown-reliability-project
https://undergroundarizona.org/tep-midtown-reliability-project
January 2, 2024 Upddate from Underground AZ
Dear Neighborhood Undergrounding Coalition Members,
As TEP’s Midtown Reliability Project plan enters its fifth year, the Steering Committee of the Neighborhood Undergrounding Coalition wants to share information with you about upcoming public meetings that will be important and background to them. As many of you know, rather than placing this project underground, TEP proposes to erect pylons that are 75–85-foot tall and taller, up to 110-foot tall, from Kino and 36th street north straight through the heart of the city to Grant and Park on its way to Demoss-Petrie on the city’s west side.In order to accomplish its goal, TEP cannot proceed unless it obtains exceptions to the City’s zoning regulations. Right now, TEP is submitting applications to City Planning and Zoning for exceptions to the gateway and scenic routes ordinance regarding the project in order to permit them to construct overhead lines across three intersections, including Broadway and Euclid. The ordinance requires undergrounding the lines unless TEP can meet certain exceptions without offending other requirements in the ordinance. The public hearing will occur online before the City’s Zoning Examiner. It will be preceded by a review of the Design Review Board. The hearing is likely to be scheduled for some time in early 2025.
Soon thereafter TEP plans to apply for a second zoning exception to enable them to construct a new substation at Vine. The University Area Plan calls for the undergrounding of new utilities everywhere within the plan’s jurisdiction (Country Club to Stone and Broadway to Grant). This TEP application, too, will need to go before the Design Review Board and the Zoning Examiner.
The Zoning Examiner will hold public hearings on each exception before making his decision, and his decision is appealable to the Mayor and Council. We will keep you apprised as to when these hearings will take place, how to link into them, and effective ways to participate.
TEP should not construct the project above ground. Structures that are 75-85 feet high or taller will dominate the entire landscape all across the center of town. Its repellant effects cannot be overstated, and the effects will last a half century or more. We believe that TEP should be denied both of the exceptions based on the City’s own ordinances and plans as well as other compelling reasons.
The project is perfectly affordable. TEP is easily able to finance it. Using TEP’s own likely greatly exaggerated estimates of the cost, financing the entire project spread out over the project’s lifetime would cost less than 20 cents per $100 of TEP’s revenues (or less than 20 cents on a typical $100 ratepayer bill if TEP were to reverse its position).
In addition to opposing the City’s gateway and scenic ordinance and area plans, the project also conflicts with zoning requirements for numerous residential and historic neighborhoods. The proposed route goes straight though several Historic Register Districts, both national and local, and Neighborhood Preservation Zones, which require new construction to adhere to height and compatibility requirements.
There has been activity at the state level as well. Underground Arizona (UAZ), a separate non-profit group that represents neighborhoods and collaborates with the Neighborhood Undergrounding Coalition, appeared at state hearings held by the Arizona Corporation Commission (ACC) late last summer to determine the project’s route. With the leadership of Dan Dempsey, UAZ has raised compelling reasons opposing the legality of the ACC’s decisions affecting the project’s financing. The ACC issued a guideline (over their own attorney’s legal objections) that constructing underground projects should not be chargeable to ratepayers. The ACC also decided that obeying the City’s ordinance makes TEP’s project financially unfeasible, which is clearly false and so goes beyond the ACC’s powers.
The whole issue will reach a crucial stage in February with the city Zoning Examiner’s public process to decide on granting or denying zoning exceptions for the project. We will keep you in close touch. We feel that our case is very strong at both the local and the state levels. With your continued support and involvement in this project, we believe that we will prevail.
Very appreciatively,
John Schwarz, Colleen Nichols, and Bill Craig,
Steering Committee, Neighborhood Undergrounding Coalition
As TEP’s Midtown Reliability Project plan enters its fifth year, the Steering Committee of the Neighborhood Undergrounding Coalition wants to share information with you about upcoming public meetings that will be important and background to them. As many of you know, rather than placing this project underground, TEP proposes to erect pylons that are 75–85-foot tall and taller, up to 110-foot tall, from Kino and 36th street north straight through the heart of the city to Grant and Park on its way to Demoss-Petrie on the city’s west side.In order to accomplish its goal, TEP cannot proceed unless it obtains exceptions to the City’s zoning regulations. Right now, TEP is submitting applications to City Planning and Zoning for exceptions to the gateway and scenic routes ordinance regarding the project in order to permit them to construct overhead lines across three intersections, including Broadway and Euclid. The ordinance requires undergrounding the lines unless TEP can meet certain exceptions without offending other requirements in the ordinance. The public hearing will occur online before the City’s Zoning Examiner. It will be preceded by a review of the Design Review Board. The hearing is likely to be scheduled for some time in early 2025.
Soon thereafter TEP plans to apply for a second zoning exception to enable them to construct a new substation at Vine. The University Area Plan calls for the undergrounding of new utilities everywhere within the plan’s jurisdiction (Country Club to Stone and Broadway to Grant). This TEP application, too, will need to go before the Design Review Board and the Zoning Examiner.
The Zoning Examiner will hold public hearings on each exception before making his decision, and his decision is appealable to the Mayor and Council. We will keep you apprised as to when these hearings will take place, how to link into them, and effective ways to participate.
TEP should not construct the project above ground. Structures that are 75-85 feet high or taller will dominate the entire landscape all across the center of town. Its repellant effects cannot be overstated, and the effects will last a half century or more. We believe that TEP should be denied both of the exceptions based on the City’s own ordinances and plans as well as other compelling reasons.
The project is perfectly affordable. TEP is easily able to finance it. Using TEP’s own likely greatly exaggerated estimates of the cost, financing the entire project spread out over the project’s lifetime would cost less than 20 cents per $100 of TEP’s revenues (or less than 20 cents on a typical $100 ratepayer bill if TEP were to reverse its position).
In addition to opposing the City’s gateway and scenic ordinance and area plans, the project also conflicts with zoning requirements for numerous residential and historic neighborhoods. The proposed route goes straight though several Historic Register Districts, both national and local, and Neighborhood Preservation Zones, which require new construction to adhere to height and compatibility requirements.
There has been activity at the state level as well. Underground Arizona (UAZ), a separate non-profit group that represents neighborhoods and collaborates with the Neighborhood Undergrounding Coalition, appeared at state hearings held by the Arizona Corporation Commission (ACC) late last summer to determine the project’s route. With the leadership of Dan Dempsey, UAZ has raised compelling reasons opposing the legality of the ACC’s decisions affecting the project’s financing. The ACC issued a guideline (over their own attorney’s legal objections) that constructing underground projects should not be chargeable to ratepayers. The ACC also decided that obeying the City’s ordinance makes TEP’s project financially unfeasible, which is clearly false and so goes beyond the ACC’s powers.
The whole issue will reach a crucial stage in February with the city Zoning Examiner’s public process to decide on granting or denying zoning exceptions for the project. We will keep you in close touch. We feel that our case is very strong at both the local and the state levels. With your continued support and involvement in this project, we believe that we will prevail.
Very appreciatively,
John Schwarz, Colleen Nichols, and Bill Craig,
Steering Committee, Neighborhood Undergrounding Coalition
ARIZONA CORPORATION COMMISSION supported TEP (Sept 5, 2024) to overhead lines on map below
SAMPLE LETTER for TEP –
YOU MAY COPY AND PASTE FROM THIS DOC
*** CHOOSE A FEW POINTS FROM LIST BELOW OR ADD YOUR OWN ***
(The points below are meant only as individual suggestions; please feel free to use only one or two of them, or to offer your own ideas, or to insert your ideas along with some of the above suggestions. Also, please feel free to rewrite any of our suggestions in your own words.)
Date, 2024
Docket Control Center
Arizona Corporation Commission
1200 West Washington
Phoenix, AZ 85007
Docket # L-00000C-24-0118-00232
RE: Tucson Electric Power, Midtown Reliability Project
My name is _____________ and I am a resident of and/or homeowner in the _____________ neighborhood, situated along the route of the proposed TEP overhead transmission lines project. I live at____address, Tucson, AZ ____. (Might consider adding a personal note such as, I am a board member, etc., or how long you’ve lived in the neighborhood. If you support undergrounding, but do not live along the route, please change to suit your needs).
Let me state right up front that I am in no way against the utility fulfilling its responsibility to supply power to its customers. However, I strongly object to the Arizona Corporation Commission approving the proposed overhead lines along the line-siting routes selected by TEP as part of the Midtown Reliability Transmission Line Project, for the following reasons:
For Tucson Electric Power to continue to insist on routes and overhead lines that clearly have long-term injurious effects on many citizens and, ultimately, on the entire city, is intolerable.
It is critical that the very real concerns of the literally tens of thousands of residents who will be affected by this project, indeed the policies of the entire city, be taken into consideration. Thank you for your attention to this matter.
Very truly yours,
(The points below are meant only as individual suggestions; please feel free to use only one or two of them, or to offer your own ideas, or to insert your ideas along with some of the above suggestions. Also, please feel free to rewrite any of our suggestions in your own words.)
Date, 2024
Docket Control Center
Arizona Corporation Commission
1200 West Washington
Phoenix, AZ 85007
Docket # L-00000C-24-0118-00232
RE: Tucson Electric Power, Midtown Reliability Project
My name is _____________ and I am a resident of and/or homeowner in the _____________ neighborhood, situated along the route of the proposed TEP overhead transmission lines project. I live at____address, Tucson, AZ ____. (Might consider adding a personal note such as, I am a board member, etc., or how long you’ve lived in the neighborhood. If you support undergrounding, but do not live along the route, please change to suit your needs).
Let me state right up front that I am in no way against the utility fulfilling its responsibility to supply power to its customers. However, I strongly object to the Arizona Corporation Commission approving the proposed overhead lines along the line-siting routes selected by TEP as part of the Midtown Reliability Transmission Line Project, for the following reasons:
- According to state statutes and court decisions, the Arizona Corporation Commission does not have jurisdiction to determine whether transmission lines should be constructed above ground or underground. The request TEP is making to construct the project overhead instead of underground asks the ACC to make a decision that goes beyond its jurisdiction.
- An area where the ACC could have jurisdiction (determining whether a project is technologically feasible) does not apply to this project. TEP’s own studies and dozens of projects around the state make clear that undergrounding the Midtown Reliability Project is technologically feasible.
- Overheading the Midtown Reliability Project conflicts with the University Area Plan (UAP) and Plan Tucson, both adopted plans governing the development and growth of the Tucson region. TEP is obligated by state law as well as its own franchise agreement with the City of Tucson to underground where required to by local laws, which include ordinances (like the gateway and scenic corridor ordinance and other zoning ordinances) and specific plans (like the UAP).
- Quite a few of the affected neighborhoods are designated as National or City Historic Districts or are Neighborhood Preservation Zones (NPZ’s) or Historic Preservation Zones (HPZ’s). Citizens worked for years to actuate these safeguards to protect unique historic Tucson neighborhoods.
- The presence of residential neighborhoods and small business owners adjacent to or directly within the proposed route will lead to loss of property value. TEP itself cites studies that show the devaluation of private property from overhead lines can reach 10% when within 500-1,000ft of the proposed right-of-way, reducing property values by as much as $70 million along the proposed TEP route.
- The suggestion that affected residents form an Underground Utility Assessment District is unacceptable. Individuals should not have to pay special higher rates in order to avoid TEP damaging their property values.
- The up-front costs of undergrounding where the city requires it, even in the worst-case scenario, are affordable and not outrageously expensive or unaffordable. Because the cost is divided over the actuarial life of the project (more than 50 years) and among all customers, the bill of an individual customer for the Midtown Reliability Project, would rise no more than a few cents per month. Programs are available to completely offset the cost (and more) for all low-income customers. The reality is that undergrounding is extremely common in Arizona and becoming more common as technology improves and density increases. The cost is also offset to some degree by eliminating reduced property values that overhead transmission lines often cause.
- With the growing problems of climate change, it becomes more important every year to place electric infrastructure underground rather than above ground. Recent studies show that the total cost of ownership of an underground asset to electrical utility companies (in this case, TEP), including savings from storm-related damages, significantly reduces the difference between above ground and underground cost, perhaps even making above ground lines cost more than underground. Over the long term, ratepayers will reap the benefit of reduced costs.
- There has been a long-standing, strong, and very vocal disapproval from many neighborhoods of the selected routes since the initial proposal. A coalition of eleven neighborhoods and three other interest groups, representing some 25,000+ residents and business owners, formed an alliance to protest the overhead lines and supports the new non-profit called Underground Arizona.
- The placement of the substation (whose permit was denied by the Zoning Examiner in 2021, which TEP did not appeal) guarantees that the overhead lines will pass through areas with numerous “sensitive receptors," such as schools, churches, a nursing home and rehab center, and right through the middle of residential neighborhoods, if the project is allowed to move forward with overhead lines.
For Tucson Electric Power to continue to insist on routes and overhead lines that clearly have long-term injurious effects on many citizens and, ultimately, on the entire city, is intolerable.
It is critical that the very real concerns of the literally tens of thousands of residents who will be affected by this project, indeed the policies of the entire city, be taken into consideration. Thank you for your attention to this matter.
Very truly yours,
May 7, 2024 TEP's responsibility to economic development - Opinion piece by Dan Dempsey
Current TEP Proposal March 1, 2024
Underground Coalition Proposal "Half-way Solution" 2024.2
Location of the TEP substation on Jefferson Park Border (Vine near Lester) should be moved and no lines should go through this historic district.
OP-Ed by D. Dempsey published in Jan 2024 E-news:
"I have prepared this to help combat some of the confusion that TEP is attempting to generate at neighborhood meetings and elsewhere.
A. TEP’s Red Herrings (in no particular order and not a comprehensive list):
1.The ACC won’t allow undergrounding for aesthetic reasons.
OP-Ed by D. Dempsey published in Jan 2024 E-news:
"I have prepared this to help combat some of the confusion that TEP is attempting to generate at neighborhood meetings and elsewhere.
A. TEP’s Red Herrings (in no particular order and not a comprehensive list):
1.The ACC won’t allow undergrounding for aesthetic reasons.
- False. The issue in Tucson is laws not aesthetics. Laws, no matter for what reason they’re enacted, are enforceable by the City and the ACC does not have the power to override the ones TEP would prefer to ignore. See the case law below.
2.The ACC won’t allow TEP to recover its costs.
False. Prop 412 may have given new taxpayer money to TEP for some undergrounding but its failure or even its passage would not have changed any of the facts contained herein.
B. The City’s undergrounding requirements include but are not limited to:
1.The Gateway and Scenic Ordinances
August 2021 Zoning Administrators Determination
2.The City’s General and Specific plans
May 2021 Zoning Examiners Decision
At least some neighborhood and area plans require the undergrounding of new electrical infrastructure. If yours does not, I recommend amending it.
3.Historic Preservation Zoning
*UDC 1.4.2.G says, “... The Zoning Administrator may allow, within the right-of-way, only those uses or structures that are permitted on the property immediately abutting the right-of-way.”
*UDC 9-02.3.0 says, among other things: “... Although new construction does not require a specific architectural style, it must be compatible with the overall design context of the neighborhood and streetscapes.”
*While undergrounding may not be explicitly required in an HPZ, 120ft poles are not compatible with at least the height restrictions of an HPZ leaving undergrounding as the only HPZ-compatible option.
3.TEP’s 2000 Franchise Agreement
5.The Arizona Supreme Court said utilities must comply with local undergrounding laws.
TEP has left many with the impression that its only obstacle within local law is the gateway ordinance. This is false. The City has already enforced much more than that and, so long as we do not let it relent, should continue to do so. TEP cannot be allowed to make local laws optional, whether you agree with those laws or not. This is a much bigger issue than simply the gateway ordinance.
Undergrounding through the gateway and a few neighborhoods remains TEP's only economical option to comply with our laws. The cost difference spread out over the life of the asset is not significant and the laws would remain enforceable even if the cost was significant."
(Op Ed, by Dan Dempsy, member of the Undergrounding Coalition) published in January 2024 e-newletter
- False. TEP can recover the cost of complying with local laws. And, even if it could not, that does not give it nor the ACC the power to override local laws.
- False. TEP is already required to use its normal funding process to underground where the law requires. If the law does not require it but undergrounding is still desired, then the City can opt to force TEP to underground if it pays the difference. See the Franchise Agreement below.
False. Prop 412 may have given new taxpayer money to TEP for some undergrounding but its failure or even its passage would not have changed any of the facts contained herein.
B. The City’s undergrounding requirements include but are not limited to:
1.The Gateway and Scenic Ordinances
August 2021 Zoning Administrators Determination
2.The City’s General and Specific plans
May 2021 Zoning Examiners Decision
At least some neighborhood and area plans require the undergrounding of new electrical infrastructure. If yours does not, I recommend amending it.
3.Historic Preservation Zoning
*UDC 1.4.2.G says, “... The Zoning Administrator may allow, within the right-of-way, only those uses or structures that are permitted on the property immediately abutting the right-of-way.”
*UDC 9-02.3.0 says, among other things: “... Although new construction does not require a specific architectural style, it must be compatible with the overall design context of the neighborhood and streetscapes.”
*While undergrounding may not be explicitly required in an HPZ, 120ft poles are not compatible with at least the height restrictions of an HPZ leaving undergrounding as the only HPZ-compatible option.
3.TEP’s 2000 Franchise Agreement
- TEP voluntarily agreed to underground where required by local laws.
5.The Arizona Supreme Court said utilities must comply with local undergrounding laws.
TEP has left many with the impression that its only obstacle within local law is the gateway ordinance. This is false. The City has already enforced much more than that and, so long as we do not let it relent, should continue to do so. TEP cannot be allowed to make local laws optional, whether you agree with those laws or not. This is a much bigger issue than simply the gateway ordinance.
Undergrounding through the gateway and a few neighborhoods remains TEP's only economical option to comply with our laws. The cost difference spread out over the life of the asset is not significant and the laws would remain enforceable even if the cost was significant."
(Op Ed, by Dan Dempsy, member of the Undergrounding Coalition) published in January 2024 e-newletter
The Undergrounding Coalition makes these points:
1. An overhead project is in direct conflict with the UA Area Plan (UAP) and Major Streets and Routes Plan (MS&R Plan).
"[U]tilities in the right of way or visible from the street should be placed underground, wherever possible" MS&R Plan at Policy 5 & 6 Guideline 4.
2.To allow an unprecedented invasion of the massive overhead lines runs completely against these longstanding values - the city's distinctive character, vibrant neighborhoods and thoughtful growth - as reflected in numerous development codes, ordinances, area and neighborhood plans, and scenic and gateway routes, such as Kino/Campbell.
3. The presence of residential neighborhoods adjacent to or directly within the proposed route will lead to a loss of property value. TEP cites studies that show the devaluation of private property from overhead lines reaches a minimum of 10% when within 500–1,000 feet of the proposed right-of-way.
4. Quite a few affected neighborhoods within the study area are designated as National Historic Districts, and two neighborhoods are Neighborhood Preservation Zones (NPZs). Jefferson Park is both!
5. The cost to TEP to go underground is negligible, estimated to be 2/100th of the most current 11.5% rate increase, or about .20 per month per customer. The ACC could very possibly allow a zero rate increase for such a project, so TEP might have to absorb the expenditure as an ordinary cost to TEP and its shareholders of doing business in Tucson and complying with Tucson ordinances and plans. The city, U of A, and Banner should help as well. They are huge energy users, and this is to their advantage as much, if not more, than anyone else.
6. Coalitions, neighborhood groups and associations, and individual citizens have invested an immense amount of effort.To dismiss the need to go underground is not acceptable. A collaborative group of stakeholders willing to discuss the issue should be formed.
7. The proposed Vine substation will be located in a densely populated area, with the hospital nearby, residential neighborhoods on two sides, and U of A buildings and their residences on the other. TEP stated the Vine location as most appropriate due to the need to remain in the "Load Center". The substation could and should be moved to a more industrial area.
8. The issue of undergrounding affects the entire community—residences, businesses, and scenic areas. Undergrounding will safeguard the city’s extraordinary views. Pre-pandemic, in 2018–19, tourists spent $2.4 billion for the year in the Tucson market. That comes to more than $5,000 per household.
"[U]tilities in the right of way or visible from the street should be placed underground, wherever possible" MS&R Plan at Policy 5 & 6 Guideline 4.
2.To allow an unprecedented invasion of the massive overhead lines runs completely against these longstanding values - the city's distinctive character, vibrant neighborhoods and thoughtful growth - as reflected in numerous development codes, ordinances, area and neighborhood plans, and scenic and gateway routes, such as Kino/Campbell.
3. The presence of residential neighborhoods adjacent to or directly within the proposed route will lead to a loss of property value. TEP cites studies that show the devaluation of private property from overhead lines reaches a minimum of 10% when within 500–1,000 feet of the proposed right-of-way.
4. Quite a few affected neighborhoods within the study area are designated as National Historic Districts, and two neighborhoods are Neighborhood Preservation Zones (NPZs). Jefferson Park is both!
5. The cost to TEP to go underground is negligible, estimated to be 2/100th of the most current 11.5% rate increase, or about .20 per month per customer. The ACC could very possibly allow a zero rate increase for such a project, so TEP might have to absorb the expenditure as an ordinary cost to TEP and its shareholders of doing business in Tucson and complying with Tucson ordinances and plans. The city, U of A, and Banner should help as well. They are huge energy users, and this is to their advantage as much, if not more, than anyone else.
6. Coalitions, neighborhood groups and associations, and individual citizens have invested an immense amount of effort.To dismiss the need to go underground is not acceptable. A collaborative group of stakeholders willing to discuss the issue should be formed.
7. The proposed Vine substation will be located in a densely populated area, with the hospital nearby, residential neighborhoods on two sides, and U of A buildings and their residences on the other. TEP stated the Vine location as most appropriate due to the need to remain in the "Load Center". The substation could and should be moved to a more industrial area.
8. The issue of undergrounding affects the entire community—residences, businesses, and scenic areas. Undergrounding will safeguard the city’s extraordinary views. Pre-pandemic, in 2018–19, tourists spent $2.4 billion for the year in the Tucson market. That comes to more than $5,000 per household.
wHat is THE uNDERGROUNDING cOALITION?
The Underground Coalition is a group of several neighborhoods and entities who became aware of the plans of TEP to place 100ft 138kV poles through Tucson by way of Campbell Avenue, a designated scenic by-way. This group brought to the attention of the city the seemingly forgotten ordinance requiring all utilities on such by-ways to be undergrounded. Thus began examination of options, the writing of a white paper, hiring of attorneys, and hours of meetings. The city was clearly going to consider "exceptions" to this ordinance and TEP was going to lobby for as many as possible. How to minimize the impact, and keep open the public's ability to challenge any exceptions became the goals of the coalition. Below are listed papers of the Underground Coalition and newspaper articles that chronical the efforts to date.
May 16 Special Election-Franchise Agreement:
The franchise agreement:
https://docs.tep.com/wp-content/uploads/Proposed-City-of-Tucson-TEP-Franchise-Agreement-1-17-2023.pdf
More on Prop 412 (approving the TEP Franchise Agreement)
https://yeson412.com/supporters
The franchise agreement:
https://docs.tep.com/wp-content/uploads/Proposed-City-of-Tucson-TEP-Franchise-Agreement-1-17-2023.pdf
More on Prop 412 (approving the TEP Franchise Agreement)
https://yeson412.com/supporters
UPDATE November 29, 2022
From the Undergrounding Coalition In early November, the Steering Committee initiated informal discussions with TEP about the Kino to DeMoss-Petri Transmission Line Project. We want you to know those conversations continue with the representative from TEP. To date, we have discussed possible alternative methods for funding for the undergrounding portion of the project and optimizing the number of miles that TEP will construct underground within the guidelines that the City Council has set forth.
What follows is our present understanding of the process to come. There will be considerable opportunity for public participation.
In a study session of the Mayor and Council that will take place in late December, TEP will present a draft proposal regarding a means to secure financing for undergrounding. After a public meeting (or series of public meetings) that will probably take place early next year, the Mayor and Council will make a decision. Should Mayor and Council approve, they would then call for a special election with a vote of the public that will likely occur in May, preceded by open public meetings.
Our current understanding is that if the public gives approval in the special election, making funding available, TEP will then draw up and make their specific proposal for the project (the exact route, where construction will be underground or overhead, the cost of the project, etc.). That proposal will go through the phases of the special public process for gateway and scenic routes that the Mayor and Council recently adopted. If approved, TEP would like the project to be able to go to the Arizona Corporation Commission (ACC) in early 2024 and then the Zoning Examiner for the special exception permit for the substation. Barring difficulties and delays, the earliest construction would begin is in 2025 and, if so, the lines would be in use by early 2027.
We will continue trying to make certain that optimizing undergrounding and securing significant funding are top of mind with TEP in the process, and we will remain in touch with you.
Thank you once again for your activism and support.
(Steering Committee Member and JP Rep: Colleen Nichols, [email protected]
From the Undergrounding Coalition In early November, the Steering Committee initiated informal discussions with TEP about the Kino to DeMoss-Petri Transmission Line Project. We want you to know those conversations continue with the representative from TEP. To date, we have discussed possible alternative methods for funding for the undergrounding portion of the project and optimizing the number of miles that TEP will construct underground within the guidelines that the City Council has set forth.
What follows is our present understanding of the process to come. There will be considerable opportunity for public participation.
In a study session of the Mayor and Council that will take place in late December, TEP will present a draft proposal regarding a means to secure financing for undergrounding. After a public meeting (or series of public meetings) that will probably take place early next year, the Mayor and Council will make a decision. Should Mayor and Council approve, they would then call for a special election with a vote of the public that will likely occur in May, preceded by open public meetings.
Our current understanding is that if the public gives approval in the special election, making funding available, TEP will then draw up and make their specific proposal for the project (the exact route, where construction will be underground or overhead, the cost of the project, etc.). That proposal will go through the phases of the special public process for gateway and scenic routes that the Mayor and Council recently adopted. If approved, TEP would like the project to be able to go to the Arizona Corporation Commission (ACC) in early 2024 and then the Zoning Examiner for the special exception permit for the substation. Barring difficulties and delays, the earliest construction would begin is in 2025 and, if so, the lines would be in use by early 2027.
We will continue trying to make certain that optimizing undergrounding and securing significant funding are top of mind with TEP in the process, and we will remain in touch with you.
Thank you once again for your activism and support.
(Steering Committee Member and JP Rep: Colleen Nichols, [email protected]
July 12, 2022 - AZ STAR ARTICle OF m&C Meeting
July 2, 2022 - revisions to exceptions
recommendations of the Underground coalition
April 6, 2022
Recommendations of the Undergrounding Coalition
april 6, 2022 -virtual meeting to consider exceptions
This meeting of PDSD and the public ended when the commission lost its quorum - a commissioner left the meeting. How much of the testimony was lost depends upon the timing--i.e. when the meeting lost its quorum. Who may have to retestify is uncertain at this time. This meeting will have to be rescheduled.
TEP is seeking to amend the Gateway and Scenic Routes code of the City of Tucson so as to allow the construction of tall overhead transmission lines in places along those routes, which are now prohibited. Toward this end, TEP has proposed criteria to permit exceptions to the current code.
Next Wednesday, April 6, at 6:00 PM, the City of Tucson's Planning Commission will hold an important virtual public meeting. The purpose of the meeting is to present the proposed exceptions to the public, and to gather public feedback. This hearing is crucial and we hope as many neighbors as possible will attend and voice their concerns at the hearing.
Details about meeting access and procedures to submit written comments or speak at the meeting are as follows: To join the meeting: Go to https://www.tucsonaz.gov/pdsd/planning-commission. Click "Join Meeting" at the top of the page.
To comment:
For the history of the project and latest updates on the efforts to keep 138kV poles out of historic and residential neighborhoods, and off the Gateway and Scenic routes in Tucson, see below.
What to Consider:
After much research, thought, and consideration to develop a strategy that could most likely result in the most favorable outcome for all members of the Undergrounding Coalition, the Steering Committee has concluded that we, the citizens of Tucson, can optimize our impact by focusing on outright opposition to four of TEP’s proposed criteria.
Furthermore, the Steering Committee advocates for the addition of four new criteria along with amending TEP's proposed preface, the combination of which will place checks on the effects of all of TEP’s other criteria.
(Note: TEP's language is in red, the Steering Committee's responses are in blue).
Criteria to OPPOSE
The four criteria to outright oppose are the following:
Utility shall gain relief from the Gateway/Scenic ordinances if the following are allowed without mitigation…
12-d. Existing high-voltage transmission lines, vertical structures, or buildings in area that already compromise the viewshed. No (See the awful visual impact of the current doubling up of poles on Grant from Alvernon to Swan).
12-h. Proposed transmission lines provide electrical service to critical customers where overhead lines are strongly recommended for specialized operations; examples include but are not limited to: provision of electricity to Davis Monthan AFB or other installations necessary to the national defense, hospitals, research facilities, etc. No. We object categorically that hospitals and research facilities would be considered in the same manner as military facilities. We also oppose overhead lines at hospitals and research facilities and remain neutral about Davis Monthan and military facilities.
12-i. Proposed overhead transmission lines, rather than undergrounded transmission lines on a particular route, would avoid undesirable aesthetic, viewshed, or other adverse impacts that would result from facilities being located on an alternative route. No (This criterion, if implemented as written, would convert gateway and scenic routes from being special routes the Code intends them to be, to being subsidiary to other routes instead).
12-k. A Special Exception request to relieve the requirement to underground transmission lines that meets the findings established by UDC section 3.4.5, Findings and which also meets criteria a, e, and g of this subsection is deemed to presumptively meet the required findings for approval. No (There should always be full public review without prejudice of any proposed exception).
New Criteria to SUPPORT
The amended preface and four new criteria are as follows:
12. Transmission lines may be relieved of their requirement to be underground per UDC section 5.3, Scenic Corridor Zone (SCZ) or section 5.5, Gateway Corridor Zone (GCZ) in accordance with UDC section 3.4.3 Zoning Examiner Special Exception Procedure. In addition to the required findings of UDC section 3.4.5, the criteria for Special Exception consideration includes the following, with the understanding that an exception will be permitted only as long as none of the other following criteria are violated where the criteria are relevant.
12-l. The effects that can be expected from permitting any of the exceptions listed herein or any combination of those exceptions when added together must remain consistent with the overall purpose and integrity of the gateway/scenic route, unless it is technologically impossible and/or clearly financially cost prohibitive.
12-m. Notwithstanding any of the above criteria, above ground transmission lines are not allowed in or alongside historic areas (as defined by or listed in the National Register of Historic Places, properties or districts, City of Tucson Historic Preservation Zones, City of Tucson Historic Landmarks, or Neighborhood Preservation Zones).
12-n. Utility cannot obtain relief from Gateway/Scenic ordinances by routing through adjacent residential neighborhoods.
12-o. Any new above-ground utility that is permitted must be designed, constructed, and also maintained to be as unobtrusive as possible.
A public meeting to review the exception criteria, and for you to provide comments and input is scheduled for Wednesday, April 6 at 6:00PM. It is virtual meeting.
TEP's Entire Proposed Exceptions for your information :
12. Transmission lines may be relieved of their requirement to be underground per UDC section 5.3, Scenic Corridor Zone (SCZ) or section 5.5, Gateway Corridor Zone (GCZ) in accordance with UDC section 3.4.3 Zoning Examiner Special Exception Procedure. In addition to the required findings of UDC section 3.4.5, the criteria for Special Exception consideration includes the following:
a. Proposed overhead transmission lines are contextually sensitive to adjacent and surrounding zoning and land uses. Examples of this may include a proposed location that is industrially zoned or a proposal that results in a less adverse aesthetic impact or less adverse impact on viewsheds for surrounding properties.
b. Underground construction causes significant increase in ground disturbance when compared to overhead construction in sensitive areas such as Environmental Resource Zone (ERZ) or Watercourse Amenities, Safety and Habitat (WASH) wash crossings or environmentally and archeologically sensitive areas,
c. Minimal impact on residential areas with adequate setback,
d. Existing high-voltage transmission lines, vertical structures, or buildings in area that already compromise the viewshed,
e. Overhead lines located on non-Gateway or non-Scenic corridor route that perpendicularly crosses a Gateway Corridor Zone or Scenic Corridor Zone,
f. Repair or upgrade of existing facilities where proposed facilities are similar in size and scale to the existing facilities being repaired or replaced,
g. Transmission lines are proposed in an area where there is an existing presence of railroad, highway and/or bridge crossings, or in an area where underground installation would interfere with other existing undergrounded utilities,
h. Proposed transmission lines provide electrical service to critical customers where overhead lines are strongly recommended for specialized operations; examples include but are not limited to: provision of electricity to Davis Monthan AFB or other installations necessary to the national defense, hospitals, research facilities, etc.,
i. Proposed overhead transmission lines, rather than undergrounded transmission lines on a particular route, would avoid undesirable aesthetic, viewshed, or other adverse impacts that would result from facilities being located on an alternative route,
j. Proposed project in an area where costs to install underground would have a disparate impact on low-income residents. Satisfaction of this criteria alone is not sufficient as a finding for approval and must be found in conjunction with at least one other criterion.
k. A Special Exception request to relieve the requirement to underground transmission lines that meets the findings established by UDC section 3.4.5, Findings and which also meets criteria a, e, and g of this subsection is deemed to presumptively meet the required findings for approval.
Next Wednesday, April 6, at 6:00 PM, the City of Tucson's Planning Commission will hold an important virtual public meeting. The purpose of the meeting is to present the proposed exceptions to the public, and to gather public feedback. This hearing is crucial and we hope as many neighbors as possible will attend and voice their concerns at the hearing.
Details about meeting access and procedures to submit written comments or speak at the meeting are as follows: To join the meeting: Go to https://www.tucsonaz.gov/pdsd/planning-commission. Click "Join Meeting" at the top of the page.
To comment:
- No in-person attendance; by computer or phone only.
- Submit written comments by e-mail to [email protected]. Include the public hearing date, the title: UDC Amendments-Underground Transmission Line Relief C8-22-04, Special Exceptions, and your name. Written comments must be received no later than 5pm Tuesday, April 5.
- Submit written comments by mail to Dept of Planning and Development Svcs, 201 N Stone Ave, 3rd Floor, T/A 85701, Include the public hearing date, the title: UDC Amendments-Underground Transmission Line Relief C8-22-04, Special Exceptions, and your name. Written comments must be received no later than 5pm Tuesday, April 5.
- To speak at the hearing - Send a written request to Planning [email protected] by Tuesday, April 5, 5pm. Include the hearing date, your name, and phone number you will use.
For the history of the project and latest updates on the efforts to keep 138kV poles out of historic and residential neighborhoods, and off the Gateway and Scenic routes in Tucson, see below.
What to Consider:
After much research, thought, and consideration to develop a strategy that could most likely result in the most favorable outcome for all members of the Undergrounding Coalition, the Steering Committee has concluded that we, the citizens of Tucson, can optimize our impact by focusing on outright opposition to four of TEP’s proposed criteria.
Furthermore, the Steering Committee advocates for the addition of four new criteria along with amending TEP's proposed preface, the combination of which will place checks on the effects of all of TEP’s other criteria.
(Note: TEP's language is in red, the Steering Committee's responses are in blue).
Criteria to OPPOSE
The four criteria to outright oppose are the following:
Utility shall gain relief from the Gateway/Scenic ordinances if the following are allowed without mitigation…
12-d. Existing high-voltage transmission lines, vertical structures, or buildings in area that already compromise the viewshed. No (See the awful visual impact of the current doubling up of poles on Grant from Alvernon to Swan).
12-h. Proposed transmission lines provide electrical service to critical customers where overhead lines are strongly recommended for specialized operations; examples include but are not limited to: provision of electricity to Davis Monthan AFB or other installations necessary to the national defense, hospitals, research facilities, etc. No. We object categorically that hospitals and research facilities would be considered in the same manner as military facilities. We also oppose overhead lines at hospitals and research facilities and remain neutral about Davis Monthan and military facilities.
12-i. Proposed overhead transmission lines, rather than undergrounded transmission lines on a particular route, would avoid undesirable aesthetic, viewshed, or other adverse impacts that would result from facilities being located on an alternative route. No (This criterion, if implemented as written, would convert gateway and scenic routes from being special routes the Code intends them to be, to being subsidiary to other routes instead).
12-k. A Special Exception request to relieve the requirement to underground transmission lines that meets the findings established by UDC section 3.4.5, Findings and which also meets criteria a, e, and g of this subsection is deemed to presumptively meet the required findings for approval. No (There should always be full public review without prejudice of any proposed exception).
New Criteria to SUPPORT
The amended preface and four new criteria are as follows:
12. Transmission lines may be relieved of their requirement to be underground per UDC section 5.3, Scenic Corridor Zone (SCZ) or section 5.5, Gateway Corridor Zone (GCZ) in accordance with UDC section 3.4.3 Zoning Examiner Special Exception Procedure. In addition to the required findings of UDC section 3.4.5, the criteria for Special Exception consideration includes the following, with the understanding that an exception will be permitted only as long as none of the other following criteria are violated where the criteria are relevant.
12-l. The effects that can be expected from permitting any of the exceptions listed herein or any combination of those exceptions when added together must remain consistent with the overall purpose and integrity of the gateway/scenic route, unless it is technologically impossible and/or clearly financially cost prohibitive.
12-m. Notwithstanding any of the above criteria, above ground transmission lines are not allowed in or alongside historic areas (as defined by or listed in the National Register of Historic Places, properties or districts, City of Tucson Historic Preservation Zones, City of Tucson Historic Landmarks, or Neighborhood Preservation Zones).
12-n. Utility cannot obtain relief from Gateway/Scenic ordinances by routing through adjacent residential neighborhoods.
12-o. Any new above-ground utility that is permitted must be designed, constructed, and also maintained to be as unobtrusive as possible.
A public meeting to review the exception criteria, and for you to provide comments and input is scheduled for Wednesday, April 6 at 6:00PM. It is virtual meeting.
TEP's Entire Proposed Exceptions for your information :
12. Transmission lines may be relieved of their requirement to be underground per UDC section 5.3, Scenic Corridor Zone (SCZ) or section 5.5, Gateway Corridor Zone (GCZ) in accordance with UDC section 3.4.3 Zoning Examiner Special Exception Procedure. In addition to the required findings of UDC section 3.4.5, the criteria for Special Exception consideration includes the following:
a. Proposed overhead transmission lines are contextually sensitive to adjacent and surrounding zoning and land uses. Examples of this may include a proposed location that is industrially zoned or a proposal that results in a less adverse aesthetic impact or less adverse impact on viewsheds for surrounding properties.
b. Underground construction causes significant increase in ground disturbance when compared to overhead construction in sensitive areas such as Environmental Resource Zone (ERZ) or Watercourse Amenities, Safety and Habitat (WASH) wash crossings or environmentally and archeologically sensitive areas,
c. Minimal impact on residential areas with adequate setback,
d. Existing high-voltage transmission lines, vertical structures, or buildings in area that already compromise the viewshed,
e. Overhead lines located on non-Gateway or non-Scenic corridor route that perpendicularly crosses a Gateway Corridor Zone or Scenic Corridor Zone,
f. Repair or upgrade of existing facilities where proposed facilities are similar in size and scale to the existing facilities being repaired or replaced,
g. Transmission lines are proposed in an area where there is an existing presence of railroad, highway and/or bridge crossings, or in an area where underground installation would interfere with other existing undergrounded utilities,
h. Proposed transmission lines provide electrical service to critical customers where overhead lines are strongly recommended for specialized operations; examples include but are not limited to: provision of electricity to Davis Monthan AFB or other installations necessary to the national defense, hospitals, research facilities, etc.,
i. Proposed overhead transmission lines, rather than undergrounded transmission lines on a particular route, would avoid undesirable aesthetic, viewshed, or other adverse impacts that would result from facilities being located on an alternative route,
j. Proposed project in an area where costs to install underground would have a disparate impact on low-income residents. Satisfaction of this criteria alone is not sufficient as a finding for approval and must be found in conjunction with at least one other criterion.
k. A Special Exception request to relieve the requirement to underground transmission lines that meets the findings established by UDC section 3.4.5, Findings and which also meets criteria a, e, and g of this subsection is deemed to presumptively meet the required findings for approval.
Tucson Underground Coalition white paper
MARCH 15, 2022
December 2021
UNDERGROUNDING THE 138 Kv POLES - UPDATE by the uderground coalition
(December 2021 update)
The Steering Committee of the Undergrounding Coalition (UC) wants to update you about TEP’s proposal to construct 100-foot industrial scale power lines across the city, north to south, from 36 Street and Kino Boulevard to Demoss-Petrie on the far northwest side of Tucson.
Over the past seven months, the Underground Coalition won a series of victories in the effort to keep the overhead transmission lines out of residential neighborhoods. 1) The Zoning Examiner denied TEP’s application for a new electrical substation on the north perimeter of the UMC Banner campus required for the project. The Examiner cited TEP’s failure to address the University Area Plan, which forbids new overhead power line construction in favor of underground lines.
2) Members of the UC Steering Committee then found existing city ordinances prohibiting overhead placement of new transmission lines along Gateway and Scenic routes, which include the full length of Kino/Campbell in TEP’s proposed Kino-DeMoss- Petrie project.
3) The Tucson Mayor and Council in September voted unanimously, 7-0, to oppose placing the power lines along TEP’s alternative Euclid route.
4) Mayor and Council also decided to enforce its ordinances prohibiting overhead transmission lines along the Kino-Campbell Gateway.
5) Following this series of adverse rulings, TEP requested and was granted a four-month continuance of the ACC (Az Corporation Commission) hearings, until February 2022 to allow time for good-faith negotiations with parties to the action.
Currently, negotiations between the City and TEP have been underway, and the process will soon expand to include all parties to this action.
The successes thus far are in no small part due to the efforts of the coalition members and the many activists who have contributed tens of thousands of dollars and hundreds of hours of time to fight TEP’s overheading plan.
Our current understanding of the public process to come is that TEP will approach the City to request specific individual exemptions it wants to the ordinances. There will then follow a full open public meetings then the City will decide to accept or deny any or all of the individual requests.
Meanwhile, TEP will ask for another delay for the ACC hearings, until June. When the details for the public process on the City’s side have become known, we will schedule a meeting by zoom for representatives of all neighborhoods in the coalition to determine appropriate future action. Meanwhile it's "wait and see".
(JP contact: Colleen Nichols -[email protected])
The Steering Committee of the Undergrounding Coalition (UC) wants to update you about TEP’s proposal to construct 100-foot industrial scale power lines across the city, north to south, from 36 Street and Kino Boulevard to Demoss-Petrie on the far northwest side of Tucson.
Over the past seven months, the Underground Coalition won a series of victories in the effort to keep the overhead transmission lines out of residential neighborhoods. 1) The Zoning Examiner denied TEP’s application for a new electrical substation on the north perimeter of the UMC Banner campus required for the project. The Examiner cited TEP’s failure to address the University Area Plan, which forbids new overhead power line construction in favor of underground lines.
2) Members of the UC Steering Committee then found existing city ordinances prohibiting overhead placement of new transmission lines along Gateway and Scenic routes, which include the full length of Kino/Campbell in TEP’s proposed Kino-DeMoss- Petrie project.
3) The Tucson Mayor and Council in September voted unanimously, 7-0, to oppose placing the power lines along TEP’s alternative Euclid route.
4) Mayor and Council also decided to enforce its ordinances prohibiting overhead transmission lines along the Kino-Campbell Gateway.
5) Following this series of adverse rulings, TEP requested and was granted a four-month continuance of the ACC (Az Corporation Commission) hearings, until February 2022 to allow time for good-faith negotiations with parties to the action.
Currently, negotiations between the City and TEP have been underway, and the process will soon expand to include all parties to this action.
The successes thus far are in no small part due to the efforts of the coalition members and the many activists who have contributed tens of thousands of dollars and hundreds of hours of time to fight TEP’s overheading plan.
Our current understanding of the public process to come is that TEP will approach the City to request specific individual exemptions it wants to the ordinances. There will then follow a full open public meetings then the City will decide to accept or deny any or all of the individual requests.
Meanwhile, TEP will ask for another delay for the ACC hearings, until June. When the details for the public process on the City’s side have become known, we will schedule a meeting by zoom for representatives of all neighborhoods in the coalition to determine appropriate future action. Meanwhile it's "wait and see".
(JP contact: Colleen Nichols -[email protected])
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For Line-siting Committee comments you file on line:
Use this the link https://efiling.azcc.gov/online-services/utilities-public-comment-external A form comes up, * fill in all of your pertinent info, *name of Company - Tucson Electric Power, * Docket number L-00000C-21-0288-00192, * and if you are for, against, or neutral, * then you fill in the comments section, which could actually be selected from parts of the letter below. Every comment that supports undergrounding is important. |
LINE SITING SAMPLE LETTER WITH OPINION/ISSUE POINTS
YOU MAY COPY AND PASTE FROM THIS DOC
Date:
Docket Control Center
Arizona Corporation Commission
1200 West Washington
Phoenix, AZ 85007
Docket number: L-00000C-21-0288-00192
RE: Tucson Electric Power, TEP Kino to DeMoss-Petrie Transmission Line Project
My name is ________and I am a resident of and/or homeowner in the ________ neighborhood, situated along the route of the proposed TEP overhead transmission lines project. I live at____address, Tucson, AZ ____. (Might add another personal note such as, I am a board member, etc., or how long you’ve lived in the neighborhood.)
First, let me state that I am not against the utility fulfilling its responsibility to supply power to its customers. However, I profoundly object to the line siting routes and the proposed overhead lines selected by TEP as part of the Kino to DeMoss-Petrie Transmission Line Project for the following reasons:
For Tucson Electric Power to continue to insist on routes and overhead lines that clearly have long-term injurious effects on many citizens and, ultimately, to the entire city, is intolerable.
It is critical that the very real concerns of the literally thousands of residents who will be affected by this project be taken into consideration. Thank you for your attention to this matter.
Very Truly Yours,
YOU MAY COPY AND PASTE FROM THIS DOC
Date:
Docket Control Center
Arizona Corporation Commission
1200 West Washington
Phoenix, AZ 85007
Docket number: L-00000C-21-0288-00192
RE: Tucson Electric Power, TEP Kino to DeMoss-Petrie Transmission Line Project
My name is ________and I am a resident of and/or homeowner in the ________ neighborhood, situated along the route of the proposed TEP overhead transmission lines project. I live at____address, Tucson, AZ ____. (Might add another personal note such as, I am a board member, etc., or how long you’ve lived in the neighborhood.)
First, let me state that I am not against the utility fulfilling its responsibility to supply power to its customers. However, I profoundly object to the line siting routes and the proposed overhead lines selected by TEP as part of the Kino to DeMoss-Petrie Transmission Line Project for the following reasons:
- An overhead project along a gateway corridor, namely Kino and Campbell Avenue, is expressly forbidden by Tucson city ordinances.
- An overhead project conflicts with the UA Area Plan (UAP) and Plan Tucson, both adopted plans governing the development and growth of the Tucson region.
- Some affected neighborhoods are designated as a National Historic Districts and two neighborhoods are Neighborhood Preservation Zones (NPZ’s). Citizens worked for years to actuate these safeguards to protect the unique historic Tucson neighborhoods.
- The presence of residential neighborhoods adjacent to or directly within the proposed route will lead to loss of property value. TEP cites studies that show the devaluation of private property from overhead lines can reach 10% when within 500-1,000ft of the proposed right-of-way.
- Tucson values its unique character, vibrant city neighborhoods, and thoughtful growth, as reflected in numerous development codes, ordinances, and area and neighborhood plans and by scenic gateway routes such as Kino/Campbell. To allow an unprecedented invasion of the massive overhead lines runs completely against these longstanding values.
- The suggestion that affected residents form an Underground Utility Assessment District is unacceptable. Individuals should not have to pay special higher rates in order to avoid TEP damaging their property values, reducing property values by $70 million.
- The cost to TEP to underground is negligible, estimated to be 2/100th of the most current 6.8 % rate increase, about 14cents/month per customer.
- There has been strong and very vocal disapproval from many neighborhoods of the selected route since its initial proposal. A coalition comprised of nine neighborhoods and two other interest groups, representing some 20,000+ residents, have formed an alliance to protest the overhead lines.
- The placement of the substation, (whose permit is currently denied by the Zoning Examiner) guarantees that the overhead lines will pass through numerous “sensitive receptors”, and through neighborhoods, if the project is allowed to move forward with overhead lines.
- One of the current “selected routes”, 1B, exiting the substation, is next to a hospital, near churches, and a school, directly bisects a historic district - the heart of a residential neighborhood, and runs right next to a long-term care facility, all “sensitive receptors” as defined by TEP.
- No neighborhood should bear the brunt of providing an upgraded electrical system to the urban core, nor be expected to shoulder the enormous needs of large entities, such as The University of Arizona, Banner Health, and other buildings which continue to be erected in the surrounding areas.
- The latest, eleventh hour added “alternate route”-5A, was long ago rejected due to the number of “sensitive receptors” and neighborhoods it would damage. The exit route, A, proceeds right down a neighborhood street between homes. The eleventh-hour community input meetings in August will be fraught with controversy. TEP has not been consistent with its process.
For Tucson Electric Power to continue to insist on routes and overhead lines that clearly have long-term injurious effects on many citizens and, ultimately, to the entire city, is intolerable.
It is critical that the very real concerns of the literally thousands of residents who will be affected by this project be taken into consideration. Thank you for your attention to this matter.
Very Truly Yours,
Beliefs and Goals of the underground coalition
Beliefs of the Underground Coalition The following is to clarify the position of the members of the Coalition as it relates to the proposed TEP 138kV poles line siting from Kino to DeMoss-Petrie project.
1. Tucsonans have the right to expect consistent access to electricity.
2. Overhead power lines have significant negative effects on our community.
3. No residential areas, including their borders, are suitable for high voltage power lines of the type proposed in the Kino to DMP project.
4. Property value reduction caused by overhead lines amount to approximately $5-to-$10 million per mile, a conservative amount based on estimates in TEP-cited studies. Property owners should not be placed in a position of having to pay higher rates in order to avoid damage a TEP project does to the value of their property.
5. The City of Tucson invested $100M+ to build Kino Parkway as a scenic gateway to our city, promoting economic growth and investment. The city needs to protect its investment.
6. The reduction in property taxes due to the loss of property values for Pima County would be conservatively $500k per year.
7. Undergrounding the lines is technically feasible, affordable, and can be done as demonstrated in municipalities/cities across the country. TEP absorbs costs of this magnitude routinely for community benefit.
8. The issue of over heading large 138kV lines, if approved, could eventually affect any neighborhood in Tucson, now and in the future, thus neighborhoods must now cooperatively work together on this issue.
Goals of the Underground Coalition
Members/Supporters of the Underground Coalition: Catalina Vista, Feldman’s, Iron Horse, Jefferson Park, Mountain/1st, Pie Allen, Rincon Heights, Sam Hughes, Samos, Sugar Hill, and West University, the Historic Fourth Avenue Coalition, and the Tucson Historic Preservation Foundation.
1. Tucsonans have the right to expect consistent access to electricity.
2. Overhead power lines have significant negative effects on our community.
3. No residential areas, including their borders, are suitable for high voltage power lines of the type proposed in the Kino to DMP project.
4. Property value reduction caused by overhead lines amount to approximately $5-to-$10 million per mile, a conservative amount based on estimates in TEP-cited studies. Property owners should not be placed in a position of having to pay higher rates in order to avoid damage a TEP project does to the value of their property.
5. The City of Tucson invested $100M+ to build Kino Parkway as a scenic gateway to our city, promoting economic growth and investment. The city needs to protect its investment.
6. The reduction in property taxes due to the loss of property values for Pima County would be conservatively $500k per year.
7. Undergrounding the lines is technically feasible, affordable, and can be done as demonstrated in municipalities/cities across the country. TEP absorbs costs of this magnitude routinely for community benefit.
8. The issue of over heading large 138kV lines, if approved, could eventually affect any neighborhood in Tucson, now and in the future, thus neighborhoods must now cooperatively work together on this issue.
Goals of the Underground Coalition
- The lines should be constructed underground.
- Undergrounding the lines will protect property values of homes and businesses in the proposed area as well as protect the scenic gateway to Tucson, the Kino Parkway.
- TEP should either absorb the cost or seek a rate increase with the ACC. If it seeks a rate increase, then the cost of lines would be shared by all, not just by nearby property owners.
- Should TEP seek a rate increase, TEP’s assistance for low-income ratepayers should be raised to cover cost increase (possibly 50 cents per month, likely less).
- Collaborate with neighborhoods city-wide to ensure the undergrounding of power lines in residential areas, now and in the future.
Members/Supporters of the Underground Coalition: Catalina Vista, Feldman’s, Iron Horse, Jefferson Park, Mountain/1st, Pie Allen, Rincon Heights, Sam Hughes, Samos, Sugar Hill, and West University, the Historic Fourth Avenue Coalition, and the Tucson Historic Preservation Foundation.
Meetings & Minutes
Underground Coalition Meeting #3
TimeThursday: Jul 1, 2021 06:30 PM
TimeThursday: Jul 1, 2021 06:30 PM
6/9/2021 Underground Coalition Meeting #2
Underground Coalition Mtg 2
Wednesday, June 9 ⋅ 6:30 – 8:30pm
Underground Coalition Mtg 2
Wednesday, June 9 ⋅ 6:30 – 8:30pm
6/9/2021 Minutes - Underground Coalition #2 Meeting Minutes
5/10/2021 Minutes - Underground Coalition #1 Meeting Minutes
5/13/2021 Zoning Examiner Denies TEP request for Substation
138Kv Vine Avenue Substation, A.K.a. UA Substation
Association Letter: Sent April 13, 2021. Printed here to inform our neighbors and community.
Sample letter for individual neighbors
Copy, paste, and edit to your specifications. You too can make your opinions known.
Association Letter: Sent March 22, 2021 Initial letter sent to the zoning examiner. Printed here to inform our neighbors and community.
UNDERGROUNDING PROPOSAL
The Underground Coalition is comprised of 11 Tucson neighborhoods, Historic Preservation Society, and 4th Avenue Historic District. The proposal below was researched by the listed authors and presented to TEP as an alternative to overhead 138Kv poles. As of January 2021, TEP has not responded and continues with the three options, two of which bisect Jefferson Park. No other neighborhood has been projected for poles through the neighborhood.
WHY TEP SHOULD NOT IMPACT ANY HISTORIC NEIGHBORHOOD
1 – TEP has other options along major thorough-fares (or underground?)
• Neighborhood streets are generally narrower and designed to accommodate slow car, pedestrian and bike flow within the neighborhood.
• Right -of -ways are not large enough. Poles would be too close to residences.
• Visual blight – non-conforming with the intent of historic districts.
2 – TEP itself has designates Historic Neighborhoods as “sensitive receptors”
“sensitive receptors,” are factors which would have impact on placement, and would be taken into consideration. They include aspects, such as historic status, impact on the affected area, such as schools, nursing homes, hospitals and the like.
WHY JEFFERSON PARK IS ESPECIALLY IMPACTED
1– Jefferson Park already bears the burden of an ENLARGED substation at its southern border-complete with SF-6 gas, a greenhouse gas, which has been discontinued in CA and Europe.
2- JP is not only an Historic District but also a Neighborhood Preservations Zone, one of two in the city. It has special provisions to protect the integrity of the Historic District.
3 – Vine or Park BISECT the neighborhood
JP includes three churches, a long term care nursing home and rehab facility, The International School of Tucson, which serves students from preschool through eighth grades, and Banner Hospital, which is located on our southern border.
These kinds of poles should not be sited through any residential neighborhood. Jefferson Park happens to meet several of the "sensitive receptor" criteria which makes the Vine or Park options especially controversial. On an additional note, several neighbors believe that the EMFs from the larger Kv Poles are dangerous and they are not convinced otherwise by the current arguments.
1 – TEP has other options along major thorough-fares (or underground?)
• Neighborhood streets are generally narrower and designed to accommodate slow car, pedestrian and bike flow within the neighborhood.
• Right -of -ways are not large enough. Poles would be too close to residences.
• Visual blight – non-conforming with the intent of historic districts.
2 – TEP itself has designates Historic Neighborhoods as “sensitive receptors”
“sensitive receptors,” are factors which would have impact on placement, and would be taken into consideration. They include aspects, such as historic status, impact on the affected area, such as schools, nursing homes, hospitals and the like.
WHY JEFFERSON PARK IS ESPECIALLY IMPACTED
1– Jefferson Park already bears the burden of an ENLARGED substation at its southern border-complete with SF-6 gas, a greenhouse gas, which has been discontinued in CA and Europe.
2- JP is not only an Historic District but also a Neighborhood Preservations Zone, one of two in the city. It has special provisions to protect the integrity of the Historic District.
3 – Vine or Park BISECT the neighborhood
- and are narrow residential streets heavily traveled by bikers to and
- and have especially narrow right of ways placing poles too close to residences
- and Vine is a watershed management area for neighborhood with stormwater basins along right-of-ways to address flooding issues.
JP includes three churches, a long term care nursing home and rehab facility, The International School of Tucson, which serves students from preschool through eighth grades, and Banner Hospital, which is located on our southern border.
These kinds of poles should not be sited through any residential neighborhood. Jefferson Park happens to meet several of the "sensitive receptor" criteria which makes the Vine or Park options especially controversial. On an additional note, several neighbors believe that the EMFs from the larger Kv Poles are dangerous and they are not convinced otherwise by the current arguments.
TUCSON ELECTRIC PROJECT AND JEFFERSON PARK
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Jefferson Park Neighborhood Association has consistently, with other historic neighborhoods , rejected the placement of 75-100 ft 138Kv electric poles in historic neighborhoods.
TEP lists historic neighborhoods, school, hospitals as sensitive areas, yet continues to suggest the possibility of using Park or Vine south to north from the Banner northwest corner. Read the newsletters below. |
Jefferson Park Neighborhood continues to advocate regarding the pathway of the proposed 138Kv poles and the creation of a 138Kv substation on the southern border of the neighborhood on Vine Avenue. We ask for no poles through this Historic neighborhood---2 of the 3 pathways proposed by TEP bisect the neighborhood. We raise concerns about the SF6 gas used in the substation and its siting next to residential areas and Banner hospital. Further we support the Underground Coalition which asks for undergrounding of the poles.