Where the Case Stands

Five protests. One consistent record.

SDG&E asked the California Public Utilities Commission to approve the Suncrest 230 kV Loop-In Project without evidentiary hearings. Between June 30 and August 19, 2026, five protests were filed in Proceeding A.26-05-005: from ECAPS, from the conservation nonprofit Friends of Loveland Reservoir, and from three sets of Alpine property owners, one of them a licensed civil engineer whose 37-page filing is built entirely from SDG&E's own documents. All five asked the Commission for public evidentiary hearings.

None of the protests asks the Commission to leave the reliability problem unaddressed. What they contest is the design SDG&E chose to solve it, the age of the record supporting that choice, and the request to be approved with no hearing at all.

The wildfire analysis is inadequate. Roughly eleven miles of new overhead conductor on 67 steel poles would run through the state's Tier 3 High Fire-Threat District, across ground that burned in the Cedar and Witch Creek fires. The record contains no meaningful ignition-risk analysis, no consultation with CAL FIRE or the local fire agencies, and no analysis of aerial firefighting or evacuation. The terms "aerial firefighting," "air tanker" and "fire suppression aircraft" appear nowhere in either volume of the environmental report.

The fire model used the winds that blow most often, not the winds that cause fires. Fire behavior was modeled at 8 and 13 miles per hour, which are ten-year average values. SDG&E's own Red Flag standard is 25 mph sustained and 35 mph in gusts, and its own December 2024 outage reporting documents gusts to 95 mph with twelve weather stations breaking all-time records. Even at 8 mph the model shows fire spreading more than 100 feet per minute with 25-foot flames, and still concludes the impact is less than significant.

Undergrounding was never seriously evaluated, and SDG&E's own filings undercut the omission. SDG&E calls undergrounding the most effective method of reducing wildfire risk, and roughly 99 percent effective. It already proposes 3.6 miles of underground 230 kV on this route, including in Tier 3. It nonetheless buried the lower-risk segment and left the extreme-risk segment overhead, with no stated engineering or fire-related reason.

The alternatives screening rests on a deadline that no longer exists. Eleven of fourteen candidate routes were eliminated for failing a CAISO-specified in-service date of 2032. CAISO's current Board-approved plan lists that date as not applicable. Nine were dropped on an untested assumption about federal easement delays, with no record of any contact with the Bureau of Indian Affairs or any tribal government. No reconductoring, conductor-upgrade or non-wires alternative was studied at all.

The project does not match what CAISO approved, and the cost has nearly doubled. CAISO approved a 16-mile line with two 500/230 kV transformer banks; SDG&E proposes 14.5 miles and one. CAISO approved a range of $275 to $375 million; SDG&E now estimates $500 to $600 million, with no cost breakdown. The application also asks the Commission to commit San Diego retail ratepayers to any costs federal regulators later refuse to allow.

Easements are drawn as though they already exist. Route sheets label the corridor "Overhead Easement (200 feet)" without qualification across roughly 266 acres of proposed new permanent easement. On at least one parcel the only high-voltage easement SDG&E actually holds authorizes underground facilities. Structures are proposed inside a County-held open space easement while the land use analysis reports no impact.

It has been done before. In 2008 the Commission required 6.2 miles of undergrounding through Alpine (D.08-12-058). In 2013 it ordered Southern California Edison to underground 3.5 miles in Chino Hills at a cost of up to $224 million (D.13-07-018). This is not a long shot. It is a case that has to be argued properly, with counsel and independent experts.

What happens next. Responses to the protests were due August 31, 2026. After responses, the assigned Commissioner and Administrative Law Judge Marcelo Poirier convene a Prehearing Conference, which the Commission notices shortly after the response deadline.

The prehearing conference is procedural rather than evidentiary, but it is where the shape of the case is decided: the category of the proceeding, whether evidentiary hearings are held, which issues fall within the scope, the schedule, and party status. Issues left outside the scope generally cannot be litigated later. Following the conference, the assigned Commissioner issues a Scoping Memo and Ruling that governs the rest of the proceeding.

The environmental review runs on a separate track. Its scoping period opened with the Notice of Preparation on August 21, 2026 and closed on October 5. The CPUC's Scoping Report is the next milestone there, and no date has been announced. What follows sets out what the Notice of Preparation covers, what residents asked the study to address, and every step still to come. See Suncrest Project 101 for how the two tracks fit together.

What the Notice of Preparation is for

The CPUC issued a Notice of Preparation on August 21, 2026, and revised it on September 16 only to extend the comment deadline. A Notice of Preparation is the formal start of environmental review under the California Environmental Quality Act. It does three things.

Announces an Environmental Impact Report. The CPUC, as lead agency, will prepare an EIR on SDG&E's application for a Permit to Construct.

Describes the project. About 14.5 miles of new double-circuit 230 kV transmission line, part overhead and part underground, connecting existing Transmission Line 23021 into the Suncrest Substation, plus a new 500/230 kV transformer bank and a 230 kV bay at the substation. The route crosses unincorporated communities including Crest and Harbison Canyon.

Asks what the EIR should study. This is scoping: agencies and the public tell the CPUC which environmental effects, alternatives and mitigation measures the study has to cover.

Four points in the notice matter for what comes next. The EIR will address every topic in Appendix G of the CEQA Guidelines. SDG&E's own draft found no significant and unavoidable impacts, and the CPUC says it will evaluate impacts independently and may add to or replace SDG&E's proposed measures. The objectives listed in the notice are SDG&E's; the CPUC has not yet set its own, and those objectives shape which alternatives get considered. The alternatives identified so far are No Project and Routes 4, 4B and 5, and the notice says others may be added based on scoping input.

What residents told the CPUC

Residents wrote their own letters and shared them with ECAPS. Wildfire, evacuation and aerial firefighting were the dominant theme, and ran through the letters regardless of where the writer lives along the route. Views from homes and direct effects on private property followed. Most letters closed by asking the CPUC to study undergrounding or upgrading the existing lines. What follows is grouped by topic and is not attributed to anyone.

Wildfire. The corridor has burned repeatedly: the 2003 Cedar Fire, the 2007 Witch Fire, the 2020 Valley Fire and the Dehesa 7 Fire of August 19, 2026. Residents asked that fire behavior be modeled at the Santa Ana winds they actually record, gusts of 80 mph and more, rather than the 8 and 13 mph averages used in SDG&E's draft, with all inputs disclosed. They asked the CPUC to quantify the ignition risk from about eleven miles of new overhead line in the Tier 3 High Fire-Threat District, and to reconcile SDG&E's repeated Public Safety Power Shutoffs in this area with building a new overhead line here.

Aerial firefighting. Energized 230 kV lines may limit where air tankers and helicopters can fly and drop, including water pickups at Loveland Reservoir. Commenters asked for a written CAL FIRE assessment, a comparison of overhead and underground, and the Dehesa 7 response used as a test case.

Evacuation and emergency access. Single-exit neighborhoods along Dehesa Road and Alpine Boulevard. Underground construction on La Cresta Road, one of only two ways out of Crest, steep and curving with blind curves and little shoulder. Driveways too narrow for a fire engine. Residents asked for an analysis of clearance time in a wind-driven fire that assumes roads may be blocked, and that accounts for people who cannot leave quickly.

Views from homes. Steel poles of roughly 100 to 160 feet standing in the foreground of views that are open and unobstructed today. Requests included photo simulations from affected homes and yards at true height and location, for the proposed route and for each alternative including underground, and that rural views be given the same weight as urban ones.

Land, parcels and easements. The alignment would cross or split private parcels in places where residents say SDG&E holds no transmission easement today. Residents asked the EIR to disclose, parcel by parcel, which easements SDG&E already holds and which it would have to acquire, the lasting limits on building and landscaping, and whether the route is consistent with recorded open-space easements and deed restrictions.

Habitat and wildlife. The route crosses County Multiple Species Conservation Program land and a regional wildlife linkage used by mountain lions. Species named include the Hermes copper and Quino checkerspot butterflies, Harbison's dun skipper, golden eagle, least Bell's vireo and the coastal California gnatcatcher, with bird collision and electrocution risk near Loveland Reservoir.

Fire protection, aviation and noise. Direct consultation with CAL FIRE, the local fire districts, County Fire and the Sheriff's Department, with their written responses placed in the record. FAA consultation on whether the structures would obstruct the general aviation traffic already crossing the area. Ambient noise measured before construction, including aircraft, and helicopter noise evaluated against it.

Alternatives. Underground the eleven-mile overhead segment, noting that SDG&E already proposes undergrounding at both ends of this route. Upgrade or reconductor the existing lines inside existing rights-of-way. Study an underground route running north from the Suncrest Substation to the Interstate 8 corridor, and routes that avoid steep high-fire terrain, new private easements and La Cresta Road. Evaluate every alternative on the same footing as the proposed route.

Notice and participation. Many residents reported little or no notice, some first learning of the project from a neighbor or from a request to enter their land for surveys. They asked that Draft EIR notice be mailed to every owner on or next to the route and each alternative, well beyond the 300-foot standard, that SDG&E bill inserts be used, and that an in-person meeting be held in the affected communities with a call-in option.

Also raised: loss of conventional fire insurance and reliance on the California FAIR Plan, property values, building plans put on hold, and survey crews marking private property before any approval. Residents noted that EMF exposure, property value and the burden on fixed-income rural seniors are decided in the application proceeding rather than in the EIR.

What happens next in the environmental review

The CPUC has published only two future milestones: the Scoping Report, with no date, and the Draft EIR in the third quarter of 2027. The steps below follow the standard CEQA sequence.

Scoping Report. The CPUC's consultant summarizes every comment received during scoping. The report becomes an appendix to the EIR and will be posted on the project web page. This is the next milestone, and no date has been announced.

Objectives and alternatives. The CPUC sets its own CEQA objectives, which the notice says it has not yet done, and decides which alternatives get full analysis. Scoping comments feed directly into this step.

Draft EIR. The CPUC publishes its independent analysis of impacts, mitigation and alternatives, with a public comment period that is normally at least 45 days. Third quarter of 2027 on the current schedule. This is the main chance to comment on the actual analysis.

Final EIR. The CPUC responds in writing to the comments received on the Draft EIR and makes any revisions.

Certification and decision. The Commission must certify the EIR before it decides on the Permit to Construct. If significant impacts remain, it has to adopt findings and explain why it would approve anyway. The vote happens in the application proceeding, A.26-05-005.

Notice of Determination. Filed if the project or an alternative is approved. It opens a 30-day window for court challenges.

The permit itself is decided in a separate CPUC proceeding under the same application number, where an Administrative Law Judge prepares a proposed decision for the Commissioners' vote. Cost, need and EMF are argued there. The two tracks meet at certification.

What you can do now. Get on the CPUC notification list by emailing CEQA@suncrestloop-in.com. Check the Scoping Report when it posts, and tell the CPUC project manager if your comment is not reflected. Keep building the record: photos, wind readings, evacuation experiences and insurance notices will all be useful when the Draft EIR is released. Plan to comment on the Draft EIR, because the CPUC must respond to those comments in writing, and issues generally have to be raised before the decision in order to be argued later.

Full CPUC NOP