VERDE TRANSMISSION PROJECT - Hunt Power proposed Verde Transmission Project (Verde Project or...

RIGHT-OF-WAY

PLAN OF DEVELOPMENT

VERDE TRANSMISSION PROJECT

ROW APPLICATION NM-114507

Prepared for:

BUREAU OF LAND MANAGEMENT Taos Field Office

226 Cruz Alta Road Taos, NM 87571-5983

May 2016

P a g e | i Verde Transmission POD

1.0 Overview and Purpose and Need ........................................................................................... 1-1

1.1 Overview.......................................................................................................................... 1-2 1.2 Project Organization and Contacts .................................................................................. 1-3 1.3 Major Land Uses .............................................................................................................. 1-3 1.4 Purpose and Need ........................................................................................................... 1-3

1.4.1 Applicant’s Purpose for the Proposed Action ............................................................. 1-4 1.4.2 Agencies’ Need for the Proposed Action..................................................................... 1-5

2.0 Right-of-Way Location ............................................................................................................ 2-1 2.1 ROW Description ............................................................................................................. 2-2 2.2 Legal Descriptions............................................................................................................ 2-2 2.3 Site-Specific Engineering Surveys .................................................................................... 2-2 2.4 Routing Options ............................................................................................................... 2-3

3.0 Facility Design Factors ............................................................................................................ 3-1 3.1 Transmission Facilities ..................................................................................................... 3-3

3.1.1 Structures And Foundations ................................................................................. 3-3 3.1.2 Structure Sites ...................................................................................................... 3-4 3.1.3 Wire Pull Sites and Wire Splicing Sites ................................................................. 3-4 3.1.4 Staging Areas/Equipment Storage Areas ............................................................. 3-4 3.1.5 Access (Permanent and Temporary) .................................................................... 3-4 3.1.6 Induced Current Mitigation .................................................................................. 3-5

3.2 Substation Facilities ......................................................................................................... 3-6 3.3 Labor and Equipment ...................................................................................................... 3-6 3.4 Removal of Facilities and Waste Disposal ....................................................................... 3-8 3.5 Cleanup and Reclamation ................................................................................................ 3-9 3.6 Hazardous Materials within Corridor .............................................................................. 3-9 3.7 Use of Public Lands ........................................................................................................ 3-10 3.8 Use of Construction Camps ........................................................................................... 3-10

4.0 Additional Components .......................................................................................................... 4-1 4.1 Existing Components On and Off Public Land ................................................................. 4-2 4.2 Possible Future Components On and Off Public Land ..................................................... 4-2 4.3 Location of Substations ................................................................................................... 4-2 4.4 Permanent and Temporary Access ................................................................................. 4-2 4.5 Communication Facilities Needed to Operate the Facility .............................................. 4-3 4.6 Location of Equipment Storage Areas ............................................................................. 4-3

5.0 Government Agencies Involved ............................................................................................. 5-1 6.0 Construction Methods ............................................................................................................ 6-1

6.1 Pre-Construction Environmental Resource Surveys ....................................................... 6-2 6.2 Construction Crew Training ............................................................................................. 6-3 6.3 Transmission Line Surveying ........................................................................................... 6-3 6.4 Staging Area Construction ............................................................................................... 6-3 6.5 Access Road Construction ............................................................................................... 6-3

Table of Contents

P a g e | ii Verde Transmission POD

6.6 Structure Sites ................................................................................................................. 6-5 6.7 Flagging/Staking .............................................................................................................. 6-6 6.8 Fences, Gates, Cattle-guards ........................................................................................... 6-6 6.9 Blasting ............................................................................................................................ 6-6 6.10 Structure Site Clearing, Foundation Excavation, and Foundation Installation............. 6-7 6.11 Structure Assembly and Erection ................................................................................. 6-8 6.12 Conductor Installation .................................................................................................. 6-9 6.13 Cleanup ....................................................................................................................... 6-10 6.14 Landscape Rehabilitation ........................................................................................... 6-10

7.0 Resource Values and Environmental Concerns ...................................................................... 7-1 7.1 Standard Operating Procedures and Mitigation Measures ............................................ 7-2

7.1.1 Air Quality Impacts and Mitigation .................................................................... 7-10 7.1.2 Paleontological Impacts and Mitigation Measures ............................................ 7-11 7.1.3 Soils Impacts and Mitigation Measures.............................................................. 7-11 7.1.4 Water Resources Impacts and Mitigation Measures ......................................... 7-12 7.1.5 Vegetation Impacts and Mitigation Measures ................................................... 7-12 7.1.6 Wildlife Impacts and Mitigation Measures ........................................................ 7-13 7.1.7 Threatened and Endangered Species Impacts and Mitigation Measures .......... 7-13 7.1.8 Cultural Resources Impacts and Mitigation Measures ....................................... 7-13 7.1.9 Visual Resources Impacts and Mitigation Measures .......................................... 7-14

7.2 Pre-Construction Environmental Resource Surveys ..................................................... 7-14 7.3 Methods and Principles for Construction ..................................................................... 7-15

8.0 Stabilization and Rehabilitation.............................................................................................. 8-1 8.1 Transmission Line Reclamation ....................................................................................... 8-2 8.2 Noxious Weed Species .................................................................................................... 8-3

8.2.1 Noxious Weed Monitoring Plan ........................................................................... 8-4 8.3 Restoration Success Criteria and Post-Construction Monitoring .................................... 8-4 8.4 Restoration of Temporary Disturbance Areas ................................................................. 8-5 8.5 Erosion Control ................................................................................................................ 8-5

9.0 Operation and Maintenance .................................................................................................. 9-1 9.1 Safety ............................................................................................................................... 9-2 9.2 Emergency Response ...................................................................................................... 9-2 9.3 Inspection and Maintenance Schedule and Level of Use ................................................ 9-3 9.4 Transmission Line Maintenance ...................................................................................... 9-3

9.4.1 Inspection Patrols ................................................................................................. 9-3 9.4.2 Hardware Maintenance and Repairs .................................................................... 9-4 9.4.3 Insulator Washing ................................................................................................. 9-4

9.5 Right-of-Way Repair ........................................................................................................ 9-4 9.6 Vegetation Management ................................................................................................ 9-4 9.7 Fire Control ...................................................................................................................... 9-5 9.8 Noxious Weed Control .................................................................................................... 9-5

10.0 Termination and Restoration ............................................................................................. 10-1

Table of Contents

P a g e | iii Verde Transmission POD

FIGURES Figure 1 – Project Location Figure 2 – Proposed Route Overview Figure 3 – Portions of Proposed Route on BLM Land Figure 4 – Route Location on BLM Land in Rio Arriba County Figure 5 - Route Location on BLM Land in Santa Fe County Figure 6 – Potential Route Options on BLM Land Figure 7 - Proposed Transmission Structures Figure 8 – Relative Size of Proposed 345 kV Structures vs Existing 115 kV Structures

APPENDICES Appendix A – Legal Description of Portions of Proposed Route on BLM Lands

1.0 Overview and Purpose and Need


P a g e | 1-2 Verde Transmission POD

1.1 Overview Verde Transmission LLC (Verde or Applicant) proposes to construct a new approximately 33-mile single-circuit 345 kV transmission line that will interconnect the existing Public Service Company of New Mexico (PNM) Ojo station in southern Rio Arriba County to the existing Norton station in Santa Fe County, New Mexico. The general location of the proposed Verde Transmission Project (Verde Project or Project) is shown on Figure 1. This Plan of Development (POD) identifies the proposed location, construction activities, access, and other features of the portion of the Verde Transmission Project located on BLM administered lands. The Verde Project would increase transmission capacity in Northern New Mexico. That capacity would contribute to the reliability of the transmission system, help accommodate anticipated demand growth, and facilitate the development of renewable energy. The Verde Project would cross lands administered by several jurisdictions. It would cross tribal lands within three separate Pueblos (Ohkay Owingeh, Santa Clara, and Pojoaque). The Applicant has worked closely with each of the three Pueblos to determine the preferred location of the line on tribal lands. The location of the portions of the line on Tribal land has been determined by each Pueblo and is shown on Figure 2. The Project would also cross Federal lands administered by the Department of Interior, Bureau of Land Management (BLM), private lands in both Rio Arriba and Santa Fe Counties, and possibly State lands administered by the New Mexico State Land Office. The portions of the line that would be located on BLM-administered land occur in two locations as shown on Figure 3. One segment on BLM land is located in the northern portion of the Project area in Rio Arriba County (Figure 4). In this area, the Verde Project is proposed to be located parallel and adjacent to an existing PNM 115 kV line between the Ojo and Norton Substations. The other segment of the line that would be located on BLM-administered lands occurs in Santa Fe County between the point where the Verde Project would exit the southern boundary of the Pojoaque Pueblo and the Norton Substation (Figure 5). In this area, the Project would be located along the preferred route option as determined by the BLM through the NEPA environmental analysis process. Approximately one-third of the line (about 10 to 11 miles) would be located on BLM administered lands. Appendix A provides the legal descriptions of those BLM lands that would be crossed by the Project. Where the line parallels the existing Ojo-Norton line, the new structures would be located adjacent to the existing line. The Project would be built on steel H-frame structures similar to those used on the existing Ojo-Norton line. On Tribal lands where



there are siting constraints, the Verde Project line would be built on single steel poles, as needed. 1.2 Project Organization and Contacts The Project is being developed by Verde Transmission LLC. The primary project contact is as follows:

Ms. Gabriela Canales Verde Transmission LLC 1900 North Akard Street Dallas, TX 75201 Phone: (214) 978-8977 Cell: (972) 843-0661 Email: [email protected]

1.3 Major Land Uses The land along the Verde Project is primarily undeveloped with uses that include recreation, grazing, other agricultural use and linear energy infrastructure. There are two areas along the route where residences are located. In selecting a route, Verde Transmission considered, among other things, existing linear energy infrastructure, existing linear features and corridors, and the locations on tribal lands preferred by the Tribes. Of the approximate 33-mile total length of the Verde Project line, approximately 17 miles would be located in Rio Arriba County and the remaining 16 miles would be located in Santa Fe County. Approximately 1.6 miles of line in Rio Arriba County and up to 9 miles in Santa Fe County would be located on BLM administered lands. The remaining portion would be predominately tribally-owned or privately-owned land. 1.4 Purpose and Need Demand for new sources of electric energy, and the transmission infrastructure to transmit that energy to load centers, is projected to increase significantly in the coming decades. In particular, the demand for renewable electric energy will continue to grow. Firstly, total electricity demand continues to grow (as a result of population growth, economic growth and new technologies) and would be offset only in part by energy efficiency programs. The 2015 US Energy Information Administration (EIA) Annual Energy Outlook (“reference case”) forecast is for a 25% increase in raw demand, between the years 2013 and 2040. Secondly, new generation facilities are required to not only meet this demand, but to replace the output of aging existing generation



facilities, which are to be retired in this period. Thirdly, driven by federal incentives, regional and national greenhouse gas reduction targets, state renewable energy portfolio standards (RPS) requirements and potential legislation, an increasingly greater portion of new generation will need to be supplied in the form of renewable energy. As the fastest growing region in the United States, this national trend is particularly evident in the West. Ten of the 12 western states have adopted renewable energy standards and green-house gas (GHG) reduction goals. 1.4.1 Applicant’s Purpose for the Proposed Action The Project is intended to complete a critical transmission loop in the Northern New Mexico transmission system. The Project will strengthen import and export capabilities system-wide, help relieve congestion, strengthen the reliability of the existing electrical system, and improve transmission access for local renewable and other energy sources. Specifically, the Project would:

• Improve current capacity constraints, particularly in the Northern New Mexico transmission system, will improve system reliability and decrease reliability risks.

• Relieve congestion since available electrical transmission capacity in the region is limited. Additional capacity will help relieve congestion and help local utilities access the most cost-efficient energy sources.

• Encourage and sustain growth. New Mexico, and the Southwest Region, are expected to experience long-term growth, creating an increased demand for power and therefore a greater need for transmission capacity to provide that power.

• Facilitate renewable energy. New Mexico is a renewable resource rich state. A major challenge facing renewable energy development is insufficient transmission access. Increasing transmission capacity enables New Mexico to foster renewable energy development.

The estimated cost of the Project is between $60MM and $90MM. Public benefits from the Project include:

• Contributing to the reliability of the electric system and providing greater flexibility to conduct preventative system maintenance activities.



• Providing the opportunity to develop new generation facilities in areas currently unavailable due to lack of transmission capacity. This could potentially provide access to more cost-competitive generation.

• Creating temporary construction and supply chain jobs, while creating a more robust electric grid necessary for business growth in the region.

• Providing enhancements to the transmission system necessary to develop new renewable energy generation facilities and meet renewable energy requirements. New renewable energy generation will be able to reach nearby markets utilizing the additional capacity provided by the Project.

• Minimizing land use conflicts by work with federal, tribal, state and local energy and land use planning efforts and by developing a route along existing corridors where possible.

• Coordinated approach through close collaboration with federal, tribal, state and local entities to ensure the Project meets local needs and improves the regions’ electric system.

• Providing a source of revenue to each of the three Pueblos through the ROW payments made by the Applicant to each for the portion of the line located on their land.

The proposed project has been designed to meet these principal needs and to achieve the following project---specific objectives:

a) Create a link that completes a high-voltage 345 kV path providing reliability benefits by adding needed redundancy to the system.

b) Provide a solution that fits with broader regional utility planning and needs for

the efficient, cost---effective, and transmission of up to 600 MW of initial rated capacity.

c) Meet North American Electric Reliability Corporation, Western Electricity

Coordinating Council, and National Electric Safety Code standards and guidelines.

d) Provide an electric transmission path supportive of renewable resource

development efforts. 1.4.2 Agencies’ Need for the Proposed Action 1.4.2.1 BLM’S PURPOSE AND NEED In 2015, the Applicant submitted to the BLM an SF---299 Application for Transportation and Utility Systems and Facilities on Federal Lands that requested the BLM to grant ROW on public lands necessary to construct the Verde Project. The BLM is authorized



to grant ROW for electrical transmission lines under the Federal Land Policy and Management Act (FLPMA) Title V (43 USC 1761 – 1771), and pursuant to 43 CFR 2800 has authority to “grant, issue, or review rights---of---way for . . . transmission, and distribution of electric energy.” Additionally, as part of its review of Verde’s ROW application, the BLM must conduct an environmental analysis of the Project in compliance with the National Environmental Policy Act (NEPA) that also requires evaluation of a range of reasonable alternative routes. It is expected that the NEPA analysis will be conducted as an Environmental Impact Statement (EIS). 1.4.2.1 BIA’S PURPOSE AND NEED As stated earlier, the Applicant has worked closely with each of the three Pueblos to determine the preferred location of the line on tribal lands. After final agreements between the Applicant and each Pueblo were finalized, each of the three Pueblos submitted to the BIA the required information for the ROWs for the portions of the line located on each of their lands. Each Pueblo identified the Proposed Project as a viable opportunity to meet their economic development goals, because the ROWs would provide revenue to each Pueblo via the ROW payments while occupying only a very small portion of their land. Also, construction of the Project could afford employment opportunity to Pueblo members. The BIA must meet its responsibility to approve actions on tribal lands and on lands held in trust for the benefit of the Pueblos (as defined in 42 U.S.C. §§ 4321 et seq). For this Project, the BIA must review and respond to ROW agreements between the Tribe and the Applicant. The BIA purpose, pursuant to 25 United States Code (U.S.C.) §415, is to review the ROW agreements between the Pueblos and Applicant for the portions of the transmission line located on each Pueblo. Because of their jurisdictional trust responsibility, BIA must also comply with the National Environmental Policy Act (NEPA) and will use the EIS prepared for the Project to satisfy those requirements.

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Figure 1Project Location

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Figure 3Portions of Proposed Route on BLM Land

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2.0 Right-of-Way Location



2.1 ROW Description Figure 1 shows the location of the Verde Project. On BLM lands, the permanent and temporary ROW for the transmission line will be up to 150 feet wide. The term of the ROW for all Project features would be for 50 years and the Project will operate year-round. All areas needed during construction on BLM lands for equipment storage and material lay-down would be located on Tribal or private lands to the extent possible. The proposed ROW for the Verde Transmission line on BLM lands would be approximately 9.65 miles long or 50,952 feet. The Project is proposing a 150-foot wide ROW that will allow flexibility in areas for turning structures, etc. At a ROW width of 150 feet, the Project would require approximately 147 acres for the transmission ROW on BLM land. A small expansion of PNM’s Norton Substation (less than 3 acres) will also be located on BLM land in Section 29 of T18N, R8E. Therefore, total permanent ROW on BLM lands for the Verde transmission Project would be up to approximately 150 acres. Off-ROW access roads could possibly need to be added as determined by final design. 2.2 Legal Descriptions The legal description of the portions of the Verde Transmission Project located on BLM-administered land is included in Appendix A. 2.3 Site-Specific Engineering Surveys The Project has conducted preliminary routing / engineering for the transmission line. During final design, detailed drawings of the route will be developed that will include the following:

• Aerial Base Map • Land Ownership • County Boundaries • Proposed ROW • Proposed Centerline • Existing Substations • Existing Transmission Lines

The site-specific engineering surveys will be conducted just prior to construction as part of final design and engineering. Verde Transmission will continue to refine the design of the Project during the BLM approval process, the BIA process, County processes, and



negotiations with private landowners. Final engineering surveys will determine the precise locations of individual structures, access roads, etc., prior to the start of construction and will be included in the POD. Therefore these Project alignment sheets will be updated with the Final POD and the Final Engineering Design. 2.4 Routing Options A number of route options were identified between the point where the proposed route would leave the southern boundary of the Pojoaque Pueblo and the Norton Substation (the southern terminus of the Project). Through collaboration with the BLM, these routes were screened for potential feasibility and the route options below were determined to be potentially viable for considering as alternatives in the NEPA process. In addition, other routes considered in this area but that would not be carried forward in the environmental analysis were also identified and are also described below along with the reasons for their exclusion. Current Route Options The following sections describe the current route options for the southern portion of the Verde Transmission Project along with their primary characteristics and features. These route options are shown on Figure 6. Proposed Route – The proposed route originally included in the SF299 application (discussed in the section on route options dropped) was modified between the point where it enters BLM-administered land south of Pojoaque Pueblo to a point where it would rejoin the originally proposed route where it parallels the existing 115 kV line. This route option was developed to:

• Avoid paralleling the southern boundary of the San Ildefonso Pueblo where the route would travel cross-country

• Take advantage of existing topography by paralleling the ridges in the area • Shorten this segment of the line - with the current proposal totaling about 3.8

miles versus about 4.6 miles for the original proposal • Avoid the need to cross State lands • Follow two-track roads for over half of the distance between the Pojoaque

Pueblo and where it joins with the existing 115 kV line (total distance of 3.5 miles)

This route option would parallel the existing 115 kV line for the remaining distance (about 4.8 miles) to the Norton Substation. Here it would utilize the existing road associated with the 115 line for access. In addition, locating the line in this area could



possibly minimize visual impact by placing the new line adjacent to the existing line to consolidate visual impacts in the same corridor. This option parallels the existing line for the greatest length. Route Option A – This route option would be located on either side of the BLM/private land boundary that runs north-south just west of the point where the line exits the Pojoaque Pueblo. This route option straddles the land boundary and could be located on either side – on private land (owned by the Jacona Land Grant) or on BLM-administered land. This route option was developed to:

• Follow a well-established road for access – could be used if the line were located on the private lands and possibly also if the line were located on BLM-administered lands

• Provide a route option on the eastern side of the routing area farther away from National trails

• If feasible, provide a private land option that would reduce impacts to federal lands

Route Option B – This route option would connect the southern end of the Route Option A to the existing 115 kV line/road followed by the proposed route. This route was developed to:

• Provide a more direct route across BLM-administered land between the Route Option A and the existing 115 line

o This NE to SW diagonal route is about 3.1 miles on BLM versus about 4.5 miles on BLM for an E-W route between the same points

Route Option C – This route option would be a continuation of Route Option A further south on private land. It was developed to:

• To continue to follow a well-established road for access • Provide a longer route option on the eastern side of the routing area farther

away from National trails • If feasible, provide a longer private land option that would reduce impacts to

federal lands Route Option D – This route option would connect Route Option C to the Norton Substation. This route was developed to:

• Follow the well-established Silver Meadow Road on BLM-administered land for about 2.1 miles for access

• Follow a boundary road for about 0.6 miles to utilize for access • Provide a route furthest from National trails



Route Option E – This route option provides a variation to a portion of Route Option D. It was developed to:

• Leave Route Option C about 0.6 miles farther north to provide a greater buffer to private residences in the area

• Parallel existing topographic features • On BLM, follow a well-defined road for about 0.4 miles and two-track roads for

about 1.9 miles where it would meet with BLM Route Option D (which it would follow for about 3.2 miles to the Norton Substation).

Route Option F – This route option provides a short variation of the proposed route along the existing 115 kV line. It was developed to:

• Stay on BLM instead of private land • On BLM, follow an existing boundary road for about 0.7 miles and then about

0.4 miles cross-country – starting and ending at the existing road along the 115 line.

Route Options Considered But Dropped A number of route options were considered in this area between the Pojoaque Pueblo and the Norton Substation that were dropped from further consideration after being evaluated. These route options are described below along with the reasons for being eliminated for further analysis. Originally Proposed Route – This route option was the route included in the original right-of-way (ROW) application to BLM. It would leave the Pojoaque Pueblo and continue due west on BLM-administered land along the southern boundary of the San Ildefonso Pueblo until it intersects with the existing 115 kV line which it would parallel south to the Norton Substation. This route was modified to create the currently Proposed Route and dropped from further consideration for the following reasons:

• This route would not follow existing roads • This route would be longer than the currently Proposed Route (about 4.6 miles

versus about 3.8 miles) • This route would require crossing one mile of State lands

East-West Route Connectors – Two east-west route connectors that would follow section lines between Route Option A on the east and the existing 115 kV line on the west were considered. These route options were dropped from further consideration for the following reasons:



• Neither would follow existing roads that would provide access for the new line • Neither would follow existing topography • Each would result in longer connections between the same two points than the

options selected

°


0 0.25 0.5 0.75 1

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NORTONSUBSTATION

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025026027028

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Figure 6Route Options

Author: rnc


Date: 05-03-16


Map Extent

NEW MEXICO

Tribal Land

Pueblo Boundary



State Land

Legend


Proposed Route


Substation")

Route Option B

Route Option D

Route Option C

Route Option F

Route Option A

Route Option E

Section Lines

County Boundary

3.0 Facility Design Factors

4.0 Additional Components


The major components of the Verde Project include transmission line facilities, substation facilities, and communications facilities. The following information describes these facilities in greater detail. Typical design characteristics are listed in Table 3-1. More detail on project design is contained in the following sections. Final design characteristics will be determined in the detailed design phase of the Project.

TABLE 3-1 TYPICAL DESIGN CHARACTERISTICS

Transmission Line Facilities Line length Approximately 33 miles (up to 10 miles on BLM) Type of Structure Single-circuit steel H-frame on BLM and most

other lands with single-circuit single steel pole on physically constrained private lands (or where otherwise needed)

Typical structure height 100 to 120 feet (poles); 90 to 110 feet (H-frames) Typical span lengths 800 to 1400 feet Number of structures per mile Approximately 5 – 7 Right-of-way width 150 feet on BLM land Access roads Where the new line would be adjacent to existing

transmission lines or roads, access to the new line will be provided via short spur roads from the existing access road. In other areas along the line, an access road will be located within ROW for the new line or as determined by the BLM and private land owners

Voltage 345,000 volts or 345 kilovolts (kV) Circuit configuration Single-circuit (three phase per circuit) 345kV Conductor size Two or three 1.1 to 1.4-inch diameter ACSR

conductors per phase Ground Wires 0.3 to 0.6 inches diameter wires Design ground clearance of conductor The design will meet or exceed requirements of

the National Electric Safety Code in all operating conditions. Minimum clearance is anticipated to be 30 to 35 feet at expected operating temperature.

Pole foundation depth/diameter

15 to 50 feet / 6 to 12 feet

H-Frame foundation depth/diameter 15 to 30 feet / 5 to 8 feet Substation Facilities Ojo Substation Will expand existing ring bus to a breaker and a

half scheme within the existing substation footprint

Norton Substation Will expand the existing 345 kV portion of the substation from a line bay into a 3-position ring bus configuration



TABLE 3-1 TYPICAL DESIGN CHARACTERISTICS

Communications Facilities Systems Microwave and Fiber Optic Ground Wire (OPGW) Functions Communications for fault detection, line

protection, SCADA, and two-way voice communication.

3.1 Transmission Facilities The transmission line would be designed as a single 345kV circuit with two conductors per phase in a bundle configuration. Each conductor would be 1.1 to 1.4 inch diameter ACSR conductor. The transmission line would also have two shield wires. One of the shield wires will be composed of extra high strength (EHS) steel wire. The second shield wire will be an OPGW (Optical Ground Wire) constructed of aluminum and steel core which will carry glass fibers within its core. Steel H-frame and single steel pole structures are proposed for the Project. The span lengths between structures will typically be 800-1200 feet. The assemblies of insulators in the shape of a “V” or “I” would be used to position and support each of the conductor bundles while maintaining electrical design clearances between the conductors and the structures. The “V” or “I” form insulators will be used for typical tangent structures and the “I” form insulators will be used for dead-end structures. 3.1.1 Structures and Foundations The Proposed Project would be built using primarily self-supporting steel H-frame structures on BLM lands and primarily self-supporting single steel poles on private lands or where otherwise needed due to space or other constraints. All structures would be single-circuit structures. All structures would be designed to withstand extreme wind speeds based on local meteorological data. Meteorological studies would be referenced and/or updated to evaluate and confirm maximum wind loading criteria to be used for the final design of the structures. The self-supporting H-frame structures would be made of steel. The self-supporting single pole structure would be made of self–weathering or galvanized steel. Illustrations of 345kV H-frame and steel pole structures that would be used for this Project are provided in Figures 7A and 7B. Structure heights would be approximately 100 to 120 feet for single poles and 90 to 110 feet for H-frames, varying with terrain and associated span lengths. Span lengths would typically be between 800 - 1200 feet, resulting in about 5 to 7 structures per mile of line. Each H-frame pole would be



installed by direct embedding the poles or mounting on drilled concrete piers would be typically 15 to 30 feet deep and 5 to 8 feet in diameter with anchor bolts. The single steel poles would be mounted on drilled concrete piers with anchor bolts. The foundation depths and diameters would depend on prevailing soil properties. A geotechnical study would be conducted prior to foundation designs. Figure 8 shows the relative size of the 345 kV structures proposed for the new line versus the 115 kV structures used on the existing line. 3.1.2 Structure Sites Structure Sites are areas that would be cleared of vegetation and used for construction. A portion of the area around each structure would remain available for future line maintenance. Each structure site will be approximately 200 feet by 150 feet. The locations of structure sites would be shown on the final engineering design and POD. Final structure locations will be determined by topography, best engineering practice, and any environmental or social considerations. 3.1.3 Wire Pull Sites and Wire Splicing Sites The pull sites are the locations where equipment is set up for pulling the conductors and shield wires. Construction equipment will be set up at both sides of a pull site at approximately a 3:1 ratio from the structure. Since structures will be approximately 90 to 120 feet in height, equipment will normally be about 300 to 400 feet from the structure. Pull sites will typically be 150 feet by 550 feet (1.9 acres), with one located approximately every 16,000 feet along the line. In addition to the pull sites, there will be wire splicing sites staggered approximately 8,000 feet from pulling sites. Splice sites will typically be 150 feet by 400 feet (1.4 acres), one every 16,000 feet staggered from the pull sites. 3.1.4 Staging Areas/Equipment Storage Areas Staging areas and equipment storage areas would be needed for storing materials, construction equipment, and vehicles. Any staging areas/construction material storage areas needed for the Project would be located on tribal land to the extent practical. 3.1.5 Access (Permanent and Temporary) Access to the portions of the Verde Project line on BLM land will be provided both temporarily and permanently by new access roads where the new line does not parallel an existing line. Where the new line would parallel the existing line, access would be



provided by short spur roads from the access road within the existing ROW to the Verde Project structures that would be located adjacent. In areas where the Verde Project line will not parallel an existing line, a new access road would be constructed within the ROW or as specified by the BLM. On BLM lands, the roads would be constructed in accordance with BLM standards. The final locations of these roads will be determined during final design. New access roads that would be constructed would be approximately 16-feet wide in straight sections (12-foot wide roadwaysurface plus 2 feet each side for berms/ditches) and up to 20-feet wide in sections at curves. These roads would be typically unsurfaced though gravel may be added in certain areas as conditions warrant. 3.1.6 Induced Current Mitigation Buried water and gas pipelines collocated with overhead electrical transmission lines are subject to the influence of electromagnetic fields that may result in safety concerns for people or mobile equipment making contact with the pipeline, including pipeline personnel, as well as long-term corrosion damage to the pipeline and to any existing corrosion protection equipment. Determining proper mitigation for placing electrical transmission lines over pipelines requires a detailed site specific analysis involving measuring the background inductive electrical currents found within the pipeline, the effect of any existing pipeline corrosion protection, and any potential voltages transferred through the earth in location of the electrical conductor and structures. Factors such as soil resistivity, soil layering, length and proximity of pipeline to the transmission line, fault current levels, transmission line static wire type, transmission line structure as well as the effectiveness of pipeline grounding and coating need to be fully analyzed in order to determine proper mitigation requirements. Coordination with each utility that may be crossed will be conducted to ensure that the proposed mitigation is sufficient. Crossing permits will be obtained from these entities as needed. In addition, all existing fences, metal gates, pipelines, etc. that cross or are within the transmission line right-of-way will be grounded to prevent electrical shock.



3.2 Substation Facilities This Project includes the interconnecting into the existing PNM Ojo and Norton substations. The locations of these substations are depicted on Figure 2. While there may be additional area required at Ojo, it is currently planned for any additional facilities to be located within the existing footprint. A small addition (less than 3 acres) could be required at Norton. 3.3 Labor and Equipment The Project would be constructed primarily by contract personnel with Verde Transmission responsible for project administration and construction review. It is likely that multiple contractors could be working concurrently on separate segments of project. Tables below show the estimated number of workers and types of equipment required to construct the proposed transmission lines and substations. Regular field meetings would be held with the construction contractors and environmental monitors to review progress and ensure implementation of and compliance with all specified requirements and mitigation measures.

TABLE 3-2 ESTIMATED PERSONNEL AND EQUIPMENT FOR TRANSMISSION LINE

Activity Equipment Type Quantity of Equipment # of People

Material/Yard/ Receiving/ Distribution

3/4-ton Pickup 2

8

10,000# R/T Forklift 2 50t Crane 2 Tractor Trailer (flatbed) 4 20t Boom Truck 1 100t Crane 0

Survey (Construction Staking) 1/2-ton Pickup 2 4 ATVs 2

Soil Borings 3/4-ton Pickup 1 4 Drill Rig 1

Right-of-Way Clearing 3/4-ton Pickup 1

3 Chainsaw 1 Hydro Axe 1

Roads and Access

1-ton Pickup 2

6 Cat D-6 1 Grader 1 Semi w/Dump Trailer 1 Water Truck 2

Foundations (2 crews)

1/2-ton Pickup 2

24

1-ton Pickup 1 Drill Rig 2 Loader/Backhoe 2 Boom Truck 2 Concrete Truck 4



TABLE 3-2 ESTIMATED PERSONNEL AND EQUIPMENT FOR TRANSMISSION LINE


Generator 2 Cat D-6 2

Structure Assembly Tubular (1 crew)

1/2-ton Pickup 1

6 1-ton Flatbed Trk 1 Air Compressor 1 30-ton R/T Crane 1

Structure Erection (Tubular -1 crew)

1/2-ton Pickup 1

10 1-ton Flatbed Trk 1 200-ton Crane 1 20-ton Boom Trk 1 Air Compressor 2

Wire Pulling (Conductor, OHGW, OPGW)

1-ton Line Truck 2

20

200t Crane 2 20t Boom Truck 2 Air Compressor 0 Cat D-8 3 Puller 2 Tensioner 2

Conductor Clipping and Deadending (3 clip, 1 deadend)

1/2-ton Pickup 4

32 1-ton Line Truck 6 Bucket Truck/ Boom w/Basket 4

Restoration

1/2-ton Pickup 2

4 Tractor with Disc 1 Cat D-4 1 Hydro Seed Truck 1

Contractor Management /Compliance Monitors

1/2-ton Pickup 20 20 ATV (Inspection) 2

Total # of People* 181 ∗ Maximum total personnel required during the XX-month construction period, considering all tasks (actual personnel at any one time would be less). Depending on schedule requirements, multiple crews may be required.

TABLE 3-3 ESTIMATED PERSONNEL AND EQUIPMENT FOR SUBSTATIONS


Material Yard /Receiving /Distribution

3/4-ton Pickup 2

3 5-ton R/T Forklift 2 50t Crane 1 Tractor & Trailer 1 30t Boom Truck 1

Construction Staking 1/2-ton Pickup 1 2

Soil Borings 3/4-ton Pickup 1 2 Drill Rig 1



TABLE 3-3 ESTIMATED PERSONNEL AND EQUIPMENT FOR SUBSTATIONS


Site Clearing and Grading

3/4-ton Pickup 2

8

F-350 Pickup 2 Cat D-6 2 Grader 2 Semi & Dump Truck 4 Water Truck 1 Scrapers 1 Roller Compactors 2

Foundations & Raceway & Grounding

1/2-ton Pickup 3

10

3/4-ton Pickup 4 Drill Rig 1 Loader/Backhoe 2 Boom Truck 1 Concrete Truck 1 Excavator 1 Dump Truck 2 5-ton R/T Forklift 1 Mini Excavator 2 Air Compressor 2 Trencher 2 Roller Compactor 2 Hand Compactor 3

Structure & Equipment Installation

1/2-ton Pickup 4

10

1-ton Line Truck 2 200t Crane 1 30t Boom Truck 4 Air Compressor 3 Man Lifts 4 50t Crane 2 Generator 2 5-ton R/T Forklift 4

Wiring

1/2-ton Pickup 1

12 1-ton Line Truck 1 Generator 2 5-ton R/T Forklift 1

Testing & Cleanup 1/2-ton Pickup 2

5 Bucket Truck /Boom w/Basket 2

Contractor Mgmt 1/2-ton Pickup 3 3 Total number of people 55

3.4 Removal of Facilities and Waste Disposal In any instances when construction materials or waste needs to be removed from the Project area, removal and disposal would be conducted in accordance with all applicable regulations. Solid wastes will be hauled away for reuse, recycle, or disposal. Excavated materials along the ROW will generally be used as fill but some of the excavated material could be removed for reuse or disposal if needed. Excavated material that is clean and dry would likely be spread along the ROW.



3.5 Cleanup and Reclamation Construction sites and access roads will be kept in an orderly condition throughout the construction period by using approved enclosed refuse containers. Refuse and trash will be removed from the sites and disposed of in an approved manner. No open burning of construction trash will occur without agency approval. At the conclusion of construction, where affected by project construction, Verde Transmission would:

• Repave or repair all removed or damaged paved surfaces, unless appropriate approvals are obtained to do otherwise

• Restore removed or damaged vegetation in areas to be reclaimed • Remove all construction materials from project site and associated staging areas

and disposed of or recycled at an off-site location, as appropriate. Littering will not be allowed. Project personnel would not deposit or leave any food or waste in the Project area, and no non-biodegradable debris would remain in the right-of-way following completion of construction. All refuse would be placed in appropriate wildlife-proof containers and removed from job sites regularly. In areas of temporary disturbance, all practical means would be made to reclaim the land to its approximate original contours, natural drainage patterns, and vegetation (i.e. use of native plants and seeds mix) along the ROW, as required by the BLM. 3.6 Hazardous Materials within Corridor Petroleum products such as gasoline, diesel fuel, crankcase oil, lubricants, and cleaning solvents will be present within the Project ROW and temporary work areas during construction. These products will be used to fuel, lubricate, and clean vehicles and equipment, and will be transported in containerized trucks or in other approved containers. When not in use, hazardous materials will be properly stored to prevent drainage or accidents. These materials will not be drained onto the ground or into drainage areas. Totally enclosed containment will be provided for all hazardous waste. All hazardous construction waste, used petroleum products, and other potentially hazardous wastes, will be removed to a treatment/disposal facility authorized to accept such materials. A health and safety plan will be developed by the construction contractor. In the event of a hazardous materials spill, notification and clean-up will be undertaken by



construction contractors’ trained personnel in an expeditious manner and consistent with all applicable regulations. 3.7 Use of Public Lands The Verde Project would cross public lands administered by the BLM. Up to 10 miles of the proposed transmission line would be located on BLM administered lands. Of those miles, approximately 1.6 would be located in Rio Arriba County and 10 miles would be located in Santa Fe County. Much of the line on BLM lands may be located adjacent to an existing utility line. 3.8 Use of Construction Camps The Project will not be required to use construction camps. Construction workers will come primarily from Rio Arriba, Santa Fe, and Taos Counties and would mostly commute to the job site daily. Worker parking areas will be located at the staging areas on private lands.

Randy Schroeder

Typewritten Text

FIGURE 7A

Randy Schroeder

Typewritten Text

FIGURE 7B

Figure 8 Proposed 345 kV Structures Compared to Existing 115 kV Structures

PROPOSED 345kV STRUCTURE Approximately 90 to 110 feet

EXISTING 115kV STRUCTURE Approximately 55 feet




4.1 Existing Components On and Off Public Land The Verde Project would be a new 345 kV transmission line and would not use any existing transmission structures. The line would, however, interconnect at two existing substations (Ojo and Norton). Of these, only the Norton Substation is located on federal lands administered by the BLM. The Verde Project would parallel an existing PNM 115 kV transmission line for a portion of its length, both on and off public (BLM) land. Where it parallels this existing line, the new line route will be selected to the degree feasible to maximize use of the existing access road adjacent to the existing line in order to minimize the need for new access routes and to minimize the associated impacts. 4.2 Possible Future Components On and Off Public Land Other than the new transmission structures, transmission line, and associated access on and off public (BLM) land, no new future components are planned. 4.3 Location of Substations The locations of the two existing substations that are the end-points of this project are shown on Figure 2:

• Ojo Substation • Norton Substation

4.4 Permanent and Temporary Access As discussed in Section 3.1.5, access to the portions of the Verde Project on BLM land will be provided both temporarily and permanently by new access roads where the new line does not parallel an existing line. Where the new line would parallel the existing line, access would be provided by short spur roads from the access road within the existing ROW to the adjacent Verde Project structures. In areas where the Verde Project will not parallel an existing line, a new access road would be constructed within the ROW or as specified by BLM. On BLM lands, the roads will be constructed in accordance with BLM standards. The final locations of these roads will be determined during final design.



4.5 Communication Facilities Needed to Operate the Facility The proposed project would include a communications system consisting of a fiber optic network necessary for control and protection of the transmission system (referred to as supervisory control and data acquisition, or SCADA). Primary communications for relaying and control would be provided via fibers within the optical ground wire that would be installed in the shield wire position on the transmission line. For redundancy purposes, a secondary communications path would be provided via a power line carrier system or a microwave system. The location and typical design / layout of microwave sites would be determined during final engineering. A typical microwave station consists of a microwave equipment building that houses telecommunication and network equipment, backup batteries, and chargers. The station also has a microwave antenna, typically installed on a self-standing tower. Antennae may be added to existing towers where practical. 4.6 Location of Equipment Storage Areas Staging areas and equipment storage areas would be needed for storing materials, construction equipment, and vehicles for the duration of project construction. Any staging areas/construction material storage areas needed for the Project would be located on tribal land to the extent possible.

5.0 Government Agencies Involved

5.0 Government Agencies Involved


The Verde Project will be on public land administered by the BLM, tribal lands, private land, and possibly State land. Federal, state, and local agencies will be consulted during preparation of the Environmental Impact Statement (EIS) for the Project. In addition to the BLM, those agencies with potential jurisdiction over this Project will be contacted to obtain necessary permits and approvals. These agencies are identified in Table 5-1.

Table 5-1 GOVERNMENT AGENCIES INVOLVED

Agency/Department Permit/Approval Action Associated With or Required For

Federal Agencies

Bureau of Indian Affairs Approval of Rights-of-Way (ROWs) on tribal land

Approval of ROWs on trust lands

U.S. Fish and Wildlife Service

Biological Assessment, Section 7 Consultation, Biological Opinion (Endangered Species Act [ESA] 16 USC 1531-1544)

Activity where there may be an effect on federally-listed endangered/threatened/proposed species (applies to projects with federal U.S. Fish and Wildlife Service involvement).

Fish and Wildlife Coordination Act

Provide comments to prevent loss of and damage to wildlife resources.

Department of Defense Consultation Confirmation of no effect on military training airspace.

Army Corps of Engineers

Nationwide Section 404 Permit No. 12 (CWA, 33 USC 1341)

Discharge of dredge/fill into Waters of the United States, including wetlands. Preconstruction notification will be made with the US Army Corps of Engineers.

Advisory Council on Historic Preservation

Section 106 Consultation, National Historic Preservation Act (NHPA)

Opportunity to comment if project may affect cultural resources listed or eligible for listing on National Register of Historic Places.

US Environmental Protection Agency (EPA)

General Construction Activity Stormwater Permit

Stormwater discharges associated with construction activity.

Tribes Tribal Historic Preservation Officer (THPO)

Section 106 Consultation Oversight of activities potentially affecting cultural resources.

State Agencies New Mexico Department of Game and Fish

Consultation Wildlife impacts

New Mexico Historic Preservation Division

Section 106 Consultation, NHPA, NM Cultural Property Act on state lands

Consult with BLM, BIA, project applicant, appropriate land management agencies, and others regarding activities potentially affecting cultural resources.

New Mexico Public Regulation Commission

Location Permit Approve siting of line

Local Agencies Rio Arriba and Santa Fe Counties

Use Permit Land use approval for private lands within county.

6.0 Construction Methods



This section describes the construction process that will be employed to develop the Project. Installation of the transmission line will generally be performed using the proposed construction techniques identified below and discussed in the following subsections. Any significant modifications to the proposed construction techniques described in this section that arise during construction on BLM lands will be approved by the BLM prior to implementation to determine potential impacts and appropriate mitigation measures. The primary construction activities and areas of potential impact will be confined to access roads, spur roads, structure locations, and pull and splicing sites. The final locations of these project components will be confirmed during final design of the Project. 6.1 Pre-Construction Environmental Resource Surveys The final mitigation commitments for the Project would be identified in the Final EIS and Record(s) of Decision (RODs). Clearance surveys for biological and cultural resources would be conducted prior to the start of construction. Class III pedestrian surveys for cultural resources will be completed for the portions of the segments located on BLM land in consultation with the BLM. Field surveys would be conducted prior to construction to determine the presence of cultural resources and special-status species within potentially affected areas. Prior to the initiation of any preconstruction surveys, the necessary survey permits for federal and state land and rights-of-entry to privately owned land would be obtained. Consultation is on-going and a management plan is being developed and implemented in consultation, as appropriate, with the BLM, New Mexico Historic Preservation Division (HPD), the involved tribes, other interested tribes and the public. Recommended measures will include avoidance, spanning, and site testing and excavation; other possible mitigation techniques include adjusting structure site spacing or pull site location. Pre-construction surveys will be conducted for the protected biological species identified in the Final EIS as having a potential to occur in the area and to be impacted by the project. The details of these surveys would be coordinated with the BLM, BIA, and USFWS. Qualified biologists will conduct these site surveys. If special status species are encountered during the pre-construction surveys or during construction, appropriate mitigation measures will be implemented at that time to minimize any anticipated impact.



6.2 Construction Crew Training All sensitive resources that are identified will be flagged in the field to ensure awareness and appropriate treatment during construction. Prior to beginning work in the project area, all contractors, subcontractors and project personnel would receive training, as applicable to their activities, regarding the appropriate work practices necessary to effectively implement the biological mitigation measures and to comply with the applicable environmental laws and regulations including appropriate wildlife avoidance, and impact minimization procedures, the importance of these resources and the purpose and necessity of protecting them. 6.3 Transmission Line Surveying Prior to construction, preconstruction survey work would be conducted locating the centerline, structure locations, right-of-way boundaries, and structure access roads. No permanent discoloring agents will be applied to rocks or non-deciduous vegetation to indicate survey or construction limits. In addition, sensitive areas will be flagged so they can be avoided or appropriately dealt with during construction as described below. 6.4 Staging Area Construction Construction of the transmission lines would begin with the establishment of staging areas, which would be required for storing materials, construction equipment, vehicles, and in some cases as a show-up yard for the construction crews. There would be a number of staging areas over the length of the alignment. It is anticipated that vegetation will be cleared in such staging areas. In some areas, the staging area may need to be scraped by a bulldozer and a temporary layer of rock laid to provide an all-weather surface. Portions of staging areas may be fenced for security. Unless otherwise directed by the land-owner, the rock would be removed from the staging area upon completion of construction and the area would be restored as required. Staging areas would have temporary impacts to native vegetation because each would be restored and re-vegetated with native vegetation. 6.5 Access Road Construction Access to the ROW and structure sites will be required for both construction and long term maintenance of the transmission line. To limit the amount of new road construction for the Project, existing paved and unpaved access roads would be used, to



the extent practical, for the transportation of material and equipment from the storage yard to the areas where they would be needed along the transmission line ROW. Because access roads must be sufficient to bear the weight and endure heavy construction vehicle use, existing access roads may need to be upgraded to meet construction requirements. Private landowners and affected agencies would be consulted before road upgrades or construction begins. New access would be constructed using a bulldozer or grader, followed by a roller to compact and smooth the ground. Front-end loaders would be used to move the soil locally or offsite. Typically for transmission access roads, laydown areas and fly yards, 16-foot-wide straight sections of road (12-foot travel surface plus 2 feet either side for berms/ditches) and 16- to 20-foot-wide sections at curves would be required to facilitate safe movement of equipment and vehicles. Wherever possible, new access would be constructed within the transmission line ROW, or existing streets and access roads would be used. Existing access roads may be improved for project use, as required. In all cases, best engineering controls would be applied to minimize runoff and erosion. After project construction, existing and new permanent access roads would be used by maintenance crews and vehicles for inspection and maintenance activities. Temporary construction roads not required for future maintenance access would be removed and restored after project construction in the area is complete unless agreed otherwise with the landowner and/or appropriate regulatory authority. Where the Verde Project parallels an existing line, access will be provided via short spur roads from the existing access roads and structure locations associated with the existing line. Where the Verde Project deviates from the existing line, access will be provided by a new access road that will be developed along the line. New access roads will be required to access structure sites and pull sites. In cases where new access roads or improvements are proposed, the final construction drawings will identify the length of road improvement, fences, gates, and drainage improvements. Road standards will also be addressed specifically in the final engineering design. All roads would be constructed in accordance with Project requirements for transmission line access roads. Wherever possible, new spur roads would be built at right angles to existing maintenance roads. All existing roads would be left in a condition equal to or better than their condition prior to the construction of the transmission line. Culverts or other drainage structures would be installed only as necessary to allow passage of heavy equipment across drainages. In addition, road construction would include dust and erosion control measures. Water application or other dust suppression methods will be utilized in areas where the application of road surface sealants would be considered unsuitable for the local wildlife habitat.



The construction contractor selected to build this Project will be required to develop a specific Access Road Use Plan. The plan would address use of the existing road network to transport workers, materials, and heavy equipment to the staging areas, structure locations, concrete batch plant sites, and material storage locations. The planned use of existing roads would be evaluated to determine the best approach to mitigate potential impacts to the roads and adjacent construction areas. The installation of culverts and other road improvement amenities would be reviewed and addressed on a site-by-site basis.

TABLE 6-1 ROADS CROSSED BY THE PROPOSED PROJECT

Rio Arriba County County Road (CR) 136A, CR 136B, CR 456, BIA Road 514, 31 Mile Road, Industrial Park Road, Canyon Road, Indian Service Route (ISR) 617, ISR 611, Puye Road, ISR 612, State Highway 30, Southern Fields Road, O Toh Nah Po

Santa Fe County Owenge Road (84), Dry Creek Road (101B), State Highway 502, Horseshoe Bend

6.6 Structure Sites The structure sites on BLM lands will have a temporary 200-foot by 150-foot workspace (all within the proposed 150 foot ROW) cleared and graded for construction. These temporary work areas would be minimized to the maximum extent. At each structure location, an area approximately 100 feet by 100 feet would be cleared and graded within the above-described 200-feet by 150-feet area using equipment such as bulldozers, backhoes, etc. Additionally, a 35-foot by 75-foot flat graded pad will be cleared and graded immediately adjacent to the 100-foot by 100-foot area. Additional equipment may be required if solid rock is encountered at a structure location. Rock-hauling, hammering, or blasting may be required to remove the rock. Following construction, these 200-foot by 150 -foot areas will be re-contoured to blend in to original grade. Dead end and angle structures areas will have a 150-foot by 400-foot (mostly within the proposed 150 foot ROW) area cleared and graded for construction and future line maintenance. Grading for the construction and maintenance pads may not be required at all structure locations. Bulldozers or backhoes will be used for grading. This area would be minimized to the maximum amount possible and other minimization measures would be used. Where solid rock is encountered, blasting, rock-hauling, and/or the use of a rock anchoring or micro pile system may be required. The rock anchoring or micro-pile system would be used in areas where site access is limited or adjacent structures could



be damaged as a result of blasting or rock-hauling activities. In environmentally sensitive areas, a HydroVac, which uses water pressure and a vacuum, may be used to excavate material into a storage tank. In areas where it is not possible to operate large drilling equipment due to access or environmental constraints, hand digging or auguring may be required. Reinforcing steel anchor bolt cages, embedded pole sections, and concrete would be installed after excavation and prior to structure installation. As mentioned above, it is anticipated that a flat 100-foot by 100-foot area would be cleared of vegetation for construction and would be available for future line maintenance. These locations can move to some degree during final engineering if needed to avoid or minimize impacts to identified resources. For initial impact acreage calculations, the total number of structures will be multiplied by 10,000 square feet. Their individual size may vary somewhat from structure to structure but the average will be approximately 10,000 square feet. 6.7 Flagging/Staking Verde will ensure the ROW edges and the centerline are staked prior to construction. During construction all environmentally sensitive areas will be staked and clearly marked that they are sensitive. Flag colors will denote the type and restriction on an area. 6.8 Fences, Gates, Cattle-guards Fences and gates will be placed or replaced as required. If cattle-guards, fences, and gates are damaged, they will be repaired or replaced to their original condition as required by the BLM. Temporary gates will be installed only with the permission of the BLM. 6.9 Blasting As described above, transmission line structure foundations would normally be either direct-embedded or installed using drilled shafts or piers. If hard rock is encountered within the planned drilling depth, blasting may be required to loosen or fracture the rock in order to reach the required depth to install the structure foundation. Prior to blasting, a detailed blasting plan will be submitted by the construction contractor for each blast site that includes blasting methods, survey of existing structures and facilities, and scaled distance calculations that estimate the projection distance and speed of particles from blasting activities. Blasting would be very brief in



duration (milliseconds), and the noise would dissipate with distance. Blasting produces similar noise and vibration as comparable non-blasting methods to remove hard rock. Non-blasting methods include track rig drills, rock breakers, jack hammers, rotary percussion drills, core barrels, and rotary rock drills with rock bits, which would require a longer time duration to excavate approximately the same amount of rock as blasting. A work practice being considered for area’s where terrain or environmental constraints will prohibit access roads or sites unsuitable for wire pulling and tensioning sites is IMPLO explosive sleeves. These sleeves could be utilized when the above constraints are present, the process involved includes preparing all the subconductors, fitting with the explosive sleeves and detonating all charges simultaneously. 6.10 Structure Site Clearing, Foundation Excavation, and Foundation Installation Vegetation clearing and ground disturbance will be required at each structure site for excavation of holes and pouring of concrete foundations. Temporary disturbance will be approximately 200 feet by 150 feet at each structure. Vegetation in this temporary work area will be trampled, but not cleared if not necessary to do so. Foundation excavations will be made using mechanized equipment, with poles requiring one 6 to 12 foot diameter hole and H-frames requiring two 5 to 8 foot diameter holes. Structure foundation excavations will be made with power drilling equipment. A vehicle-mounted power auger or backhoe will be used to excavate the structure foundations. In rocky areas, the foundation holes would be excavated by drilling. Although not expected, in some instances blasting could be necessary because of the specific geologic conditions. In the unlikely event that blasting is necessary, conventional or plastic explosives would be used. Safeguards (e.g., blasting mats) would be employed when adjacent areas require protection. Foundation holes left open or unguarded would be covered to protect the public and wild life. If practical, fencing may be used. Foundations would be installed by placing reinforced steel and transmission structure steel components into each foundation hole, positioning the steel components, and encasing them in concrete. Direct embedded poles may be backfilled with native soil instead of concrete. Excess spoil material would be used for fill where suitable. The foundation excavation and installation activities would require access to the site by a power auger or drill, a crane, material trucks, and ready-mix trucks. Soil removed from foundation holes will be stockpiled in the work area. If warranted, the first six inches of topsoil will be stockpiled separately to ensure that the best possible topsoil for reseeding is used during site rehabilitation. Remaining soil would be spread on the access road or used as fill where needed at appropriate locations within the ROW.



Water will be used for soil compaction and dust abatement at each structure site and along access roads. Water for footer compaction and dust abatement will be obtained from available approved sources, such as agricultural or municipal water sources and trucked to the construction area. 6.11 Structure Assembly and Erection Structural components and associated hardware would be transported to each structure site by truck. Steel structure sections may be delivered to structure locations where they would be fastened together to form a complete structure and hoisted into place by a large crane. At each structure site, leveled areas would be needed to facilitate the safe operation of equipment, such as construction cranes. The leveled area required for the location and safe operation of large cranes would be approximately 5 by 70 feet. At each structure site, a work area of approximately 200 feet by 150 feet would be required for the structure foundation construction, structure assembly, and the necessary crane maneuvers. The work area would be cleared of vegetation only to the extent necessary. Concrete for use in constructing foundations would be dispensed from concrete mixer trucks and best management practices would be employed to minimize impacts from spilled concrete. After line construction, all pads would be restored to natural contours to the greatest extent possible and revegetated where required.



6.12 Conductor Installation Prior to stringing, any vegetative clearance or trimming within the ROW to maintain required clearances and electrical safety requirements would be conducted where needed. At the same time, insulators, hardware, and stringing sheaves would be delivered to each structure site. The structures would be rigged with insulator strings and stringing sheaves at each ground wire and conductor position. For public protection during wire installation, guard structures could be erected adjacent to roads, existing power-lines, and other obstacles. Guard structures typically consist of H-framed wood poles placed on either side of an obstacle. These structures would prevent ground wire, conductor, or equipment from falling on an obstacle, and would be removed following the completion of conductor installation. Equipment for erecting guard structures would include augers, line trucks, pole trailers, and small cranes. Guard structures may not be required for small roads or other areas where suitable safety measures such as barriers, flagmen, or other traffic controls could be used. Pilot lines would be pulled (strung) from structure to structure and threaded through the stringing sheaves at each structure. Following pilot lines, a larger diameter, stronger line would be attached to conductors to pull them onto structures. This process would be repeated until the ground wire or conductor is pulled through all sheaves. The shield wire (and/or OPGW) and conductors would be strung using powered pulling equipment at one end and powered braking or equipment tensioning at the other end



of each conductor stringing segment. Sites for tensioning equipment and pulling equipment would be approximately 8,000 feet apart. This distance could be essentially doubled on straight sections where it is prudent to do so by pulling in two sets of conductors back to back. Each tensioning site would be approximately 150 feet by 550 feet. Tensioners, line trucks, wire trailers, and tractors needed for stringing and anchoring the ground wire or conductor would be necessary at each tensioning site. The tensioner, in concert with the puller, would maintain tension on the shield wires or conductors while they are pulled through the structures. Each pulling site would require less area than the tension site. A puller, line trucks, and tractors needed for pulling and temporarily anchoring the shield wires, OPGW, and conductor would be necessary at each pulling site. There will be no blading at pull sites if the terrain is sufficiently level. Pull site locations will be determined during final design. 6.13 Cleanup Construction sites and access roads will be kept in an orderly condition throughout the construction period by using approved enclosed refuse containers. Refuse and trash will be removed from the sites and disposed of in an approved manner. No open burning of construction trash will occur without agency approval. 6.14 Landscape Rehabilitation Disturbance areas where vegetation was removed during construction activities that are no longer needed for future operation and maintenance will be restored in a manner to encourage natural revegetation. Temporary access roads or trails will be blocked if requested by the BLM to prevent public access. Where needed, these new roads will be encouraged to naturally revegetate, without re-contouring, to allow future access for transmission line maintenance activities. The prevention of non-local weeds and exotic species invasion will be addressed throughout construction. All heavy equipment utilized during construction will be washed prior to departure from the equipment storage facility. This will help ensure that weed seed from a different region is not transported into the ROW. Equipment will have accumulations of dirt removed before leaving the sites to contain weed seeds on the work site to the site.

7.0 Resource Values and Environmental Concerns



7.1 Standard Operating Procedures and Mitigation Measures Through development of the EIS for the Verde Project, the mitigation measures to lessen potential environmental impacts of the Project and to comply with requirements of the BLM’s Taos Resource Management Plan (RMP) will be identified. However, there are several standard measures that will be employed as part of the Project. The following table identifies those mitigation measures that would be applied to the Verde Project to avoid or reduce resource impacts and they are described in more detail following the table. Some of these mitigation measures would be applied to specific areas where needed (where a specific type of resource exists). In these cases, the locations where these geographically-specific measures would be applied will be shown on the detailed drawings prepared prior to construction.

MITIGATION MEASURES Included as part of Proposed Project

BIOLOGICAL RESOURCES Vegetation Adverse effects on vegetation disturbance during construction would be minimized as practicable.

1) During construction, travel would be restricted to the existing access roads and spur roads to the shortest feasible path to minimize impacts to vegetation communities.

2) Existing access roads would be used to the maximum extent allowable and construction of new access and spur roads would be limited to the extent practicable.

3) To the maximum extent possible, vegetation removal and trimming would be limited to that necessary for safe construction, fire control, and to meet electrical safely requirements.

4) To the extent possible, grading and grubbing of vegetative cover will be avoided on all spur roads and structure pad locations, and all vehicular traffic will drive within field designated overland routes.

The following prescriptions would prevent the spread of invasive weeds into previously uninfested areas in the designated construction right-of-way.

1) Prior to initiating construction activities, all clearing and grading equipment would have the tires, axles, frame, running boards, under carriages, and soil holding areas washed and cleaned at a designated station to prevent noxious weed species transport to previously-uninfested areas.

2) A qualified weed specialist, range ecologist, or arid botanist would survey the structure pad locations, stringing and tensioning sites, new spur road sites, existing access roads that require improvements, and construction material



staging areas prior to construction to identify any listed noxious species infestations. If an infestation is identified, the infestation area would be clearly delineated and staked prior to project construction and an appropriate buffer would be maintained. The lead environmental compliance monitor would ensure that construction-related activities would be prohibited within these designated exclusion zone(s). Where avoidance is infeasible, please refer to measures listed below.

3) Before beginning construction activities in unavoidable infestation exclusion zones, these infestations would be controlled through acceptable mechanical (e.g., topsoil excavation and removal), cultural, or herbicide applications.

4) If direct control methods or removal of noxious weed infestations in construction disturbance areas is not feasible, the noxious plants may be cut and disposed of (e.g., burned at an acceptable and permitted location) or destroyed in a manner that is acceptable to the BLM.

5) The lead environmental construction monitor would educate construction personnel on noxious weed identification and the legal requirement of controlling and preventing the spread of noxious weed infestations.

Wildlife Compensate for habitat modifications per coordination with responsible resource agencies.

1) Project mitigation could include habitat purchase and/or in-lieu fees or other measures provided to compensate for permanent loss of habitat for both common wildlife and special-status species.

Construction activities and vehicle operation would be conducted to minimize potential disturbance of wildlife.

1) Seasonal restrictions would be applied where necessary. 2) Vehicle speed would be limited along the right-of-way and access roads to 15

to 20 mph in sensitive habitats. In addition, construction and maintenance employees would also be advised that care should be exercised when commuting to and from the Project area to reduce road mortality.

3) Vehicle operation would be prohibited off the right-of-way by construction workers, including construction work and employee access, except where specified by the BLM or where roads already exist.

4) Stockpiling of equipment and parking of vehicles would be undertaken to the maximum extent allowable on previously disturbed areas near the construction zone.

5) Construction would be planned to attempt to utilize the minimum number and types of vehicles and equipment necessary on the right-of-way.



Design would minimize electrocution and collision potential for raptors.

1) Design would space conductors and ground wires sufficiently apart so that raptors cannot contact two conductors or one conductor and a ground wire to cause electrocution (APLIC 1996).

2) Design would also incorporate appropriate methods to reduce the risks of avian collisions (APLIC 2012).

Conduct pre-construction surveys prior to project initiation

1) Prior to Project construction activities, it would be determined where any tree or shrub removal or clearing would be needed. These areas would be avoided during the passerine and raptor nesting season (e.g., April 1 to August 31) if possible. If avoidance is not possible, nest surveys and clearance would be conducted prior to the nesting season.

Special Status Species Survey and avoid and/or salvage special-status species plants in areas to be disturbed by project activities.

1) A comprehensive focused survey designed with appropriate agency consultation would be conducted prior to construction and project-related activities to identify any special-status plant populations on proposed structure pads, spur roads, pulling and splicing sites, staging areas, or any other construction sites that would be temporarily or permanently disturbed.

2) If special-status plant(s) are identified during the pre-construction surveys, vegetation communities and plant locations would be delineated on aerial photography and incorporated into the construction plan. In addition, exclusion zones would be marked around identified populations and would be marked in the field with stakes and flagging. Where feasible, minor realignments would be implemented to avoid those populations within the designated structure pad and spur road locations.

3) Where avoidance is infeasible, a Plant Salvage Plan would be developed and submitted for approval from the appropriate responsible agencies.

Implement measures to decrease the likelihood of incidental take of special status wildlife species and impacts to critical habitat.

1) Identify all critical habitats for designated sensitive species.

2) Flag or otherwise mark the outer boundaries of the project construction areas where necessary to define the limit of work activities.

3) Minimize habitat degradation within key habitats by limiting travel to existing roads and surface disturbance to previously disturbed areas.

4) Implement a worker education program.



5) Provide monitors to remove sensitive species from within the right-of-way where needed. Pulling, staging, and equipment storage sites in this segment, where construction activities would be intense and extended over time, may be temporarily fenced to keep individual of sensitive species from construction zones.

Waters of the U.S. The following actions and all permit conditions issued within the COE Nationwide Permit would be implemented to minimize impacts to waters of the US.

1) A survey of “waters of the U.S.” would be completed and submitted to the COE. If construction activities result in the placement of fill material or divert, obstruct, or change the natural flow of the bed or channel, a Nationwide 12 Permit would likely be required prior to project construction activities.

2) The Project would be designed consistent with COE guidance to minimize impacts to floodplains and jurisdictional waters of the U.S., and construction of the transmission line would incorporate best management practices, include erosion control measures, and comply with all COE and State water quality permit terms and conditions to protect water quality in the Project area.

3) Spur roads and pad placement through wide washes would be minimized during the design engineering to the maximum extent allowable. Where such facilities are infeasible outside identified washes, habitat disturbance and tree removal would be minimized. These identified washes would be flagged prior to disturbance by a qualified resource specialist, and all construction activities would take place inside designated areas in order to ensure minimum habitat disturbance.

4) “Waters of the U.S.” would be restored in a manner that encourages vegetation to reestablish to its pre-construction condition and reduces the effects of erosion on the drainage system.

5) Additional compensatory, restoration, or avoidance mitigation measures may be identified by regulatory agencies as part of the permitting process and would be implemented into this POD.

CULTURAL RESOURCES Preparation of a Treatment Plan for avoiding and mitigating unavoidable direct adverse effects on resources eligible for National Register listing will be prepared and implemented.

1) Treatment of cultural resources will follow the procedures established for compliance with Section 106 of the NHPA in consultation with the Tribes and NMHPD. Treatment plans for tribal resources would be developed separately and confidentially as dictated by tribal preference.

2) Prior to construction, a Class III pedestrian inventory will be undertaken of all portions that have not been previously surveyed or identified by BLM or BIA as



requiring inventory to identify properties that are eligible for the NRHP. 3) A Treatment Plan will be prepared to identify methods of avoiding or

mitigating effects. A cultural resources evaluation report will be submitted to BLM and BIA for review, and for consultation purposes, as part of the development of the Treatment Plan.

4) Adverse effects to cultural resources will be avoided to the extent possible. Final design of the Proposed Project (for example, structure placement and work areas) will include measures to avoid National Register eligible sites where feasible. The final list of sites to be avoided during construction will be specified in the Treatment Plan. The Treatment Plan will also include detailed measures to ensure this avoidance is implemented during construction.

5) An Unanticipated Discovery Plan would be developed to outline procedures to be undertaken if unexpected resources are encountered during the course of construction.

6) A cultural resources monitor will be available at all times to respond within 48 hours to cultural resource issues that arise during construction.

7) Consultation will be conducted with concerned Native American groups to determine if the archaeological sites have additional sensitivities as TCPs.

AIR QUALITY The following mitigation measures would be implemented during the construction of the Proposed Project to reduce the exhaust emissions of CO, NOX, VOC, SOX, and PM10.

1) Heavy duty off road diesel engines or generators over 50 horsepower will meet appropriate standards for off-road or stationary equipment and will be properly tuned and maintained to manufacturers’ specifications to ensure minimum emissions under normal operations.

The following mitigation measures would be implemented for the Proposed Project to reduce fugitive dust emissions (including PM10):

1) Apply water or chemical dust suppressants to unstabilized disturbed areas and/or unpaved roadways in sufficient quantity and frequency to maintain a stabilized surface.

2) Water or water-based chemical additives will be used in such quantities to control dust on areas with extensive traffic including unpaved access roads. Water, organic polymers, lignin compounds, or conifer resin compounds will be used depending on availability, cost, and soil type.

3) Surfaces permanently disturbed by construction activities will be covered or treated with a dust suppressant within five days of the completion of activities at each site of disturbance.

4) Vehicle speeds on unpaved roadways will be restricted to 15 to 25 mph in areas where doing so would lessen the impact on air quality.

5) Vehicles hauling dirt will be covered with tarp or other means.



WATER RESOURCES A stormwater pollution prevention plan (SWPPP) would be prepared as required by the EPA Construction General Permit for storm water discharges. The SWPPP will include:

1) An outline of the areas of vegetative soil cover or native vegetation onsite that will remain undisturbed during the construction project.

2) An outline of all areas of soil disturbance including cut or fill areas which will be stabilized during the rainy season by temporary or permanent erosion control measures, such as seeding, mulch, or blankets, etc.

3) An outline of the areas of soil disturbance, cut, or fill which will be left exposed during any part of the rainy season, representing areas of potential soil erosion where sediment control BMPs are expected to be used during construction.

4) A proposed schedule for the implementation of erosion control measures.

5) The SWPPP will include a description of the BMPs and control practices to be used for both temporary and permanent erosion control measures.

Waterways, wells, and springs adjacent to construction areas would be protected.

1) Surveys of the route will be conducted prior to construction to identify surface waters, springs, and wells and their depths within 1,000 feet of construction activities. Construction activities will be limited in the following manner: (1) construction activities will not be carried out within 100 feet of a water way, spring or well without using BMPs; (2) blasting will be prohibited within 500 feet of a well; and (3) only size limited blasting will be authorized within 1,000 feet of a well. If damage occurs to a well or spring, the affected area will be repaired by the contractor.

2) The use or storage of hazardous material near a water way, well, or spring will be prohibited. Additionally, special precautions will be implemented to prevent spills or discharges of hazardous materials and wastes near a well or spring.

3) Dewatering activities for structure foundations or other deep excavations will be planned to minimize the effect on surface waters, wells, and springs.

GEOLOGY AND SOILS The Project would be designed to prevent damage resulting from seismic activity in the Project area.

1) Measures will be taken to the extent possible to avoid sites for transmission structures that are located within known fault zones.

2) A geotechnical engineering investigation consistent with geologic and engineering standards will be conducted for the Proposed Project by a licensed geotechnical engineer.

3) All practicable precautions will be taken to design and construction of transmission structures and new substations, substation facility



improvements, and equipment to withstand the projected ground shaking in the area.

Construction, operation, and maintenance activities will be restricted or controlled when the soil is too wet to adequately support construction or maintenance equipment (i.e., when heavy equipment creates ruts in excess of 4 inches deep over a distance of 100 feet or more in wet or saturated soils). Where the soil is deemed too wet, one or more of the following measures will apply:

1) When feasible, reroute all construction or maintenance activities around the wet areas while ensuring that the route does not cross sensitive resource areas.

2) If wet areas cannot be avoided, implement BMPs for use in these areas during construction and improvement of access roads, and their subsequent reclamation. This includes use of wide-track or balloon-tire vehicles and equipment, or other weight dispersing systems approved by the appropriate resource agencies. It also may include use of geotextile cushions, pre-fabricated equipment pads, and other materials to minimize damage to the substrate where determined necessary by resource specialists. If BMPs cannot be successfully applied to wet or saturated soil areas, construction or routine maintenance activities would not be allowed in these areas until the Project environmental monitor(s) determine it is acceptable to proceed.

3) This standard will not apply in areas with silty soils, which easily form depressions even in dry weather.

Areas of expansive soils would be mitigated to minimize damage from shrink / swell actions on equipment foundations.

1) Prior to construction, soils will be evaluated to determine if they are expansive and if they may have potential effects on the proposed facilities. Where they represent a potential hazard, solutions recommended by the Proposed Project’s geotechnical engineer, such as excavation and replacement of the expansive soils with compacted backfill, will be required.

Short-term erosion and sedimentation will be reduced and topography and vegetation will be quickly restored as practicable to pre-construction conditions in all areas required and approved by BLM, tribal, and private landowners.

Monitoring of the erosion control measures will continue until reclamation efforts are considered complete and successful. Measures to be implemented during the Proposed Project construction and reclamation are listed below. Implementation of the following environmental protection practices will minimize the effects of grading, excavation, and other surface disturbances in all Project areas. Schedules and specifications on the use of these features would be included in the final construction plan.

1) All vehicular traffic associated with construction would be limited to



designated right-of-ways, material yards, wire set-up sites, and access roads designated in the final POD.

2) Disturbance/removal of soils and vegetation would be limited to the minimum area necessary for access and construction.

3) Where vegetation removal is necessary, cutting/mowing methods would be used instead of blading, wherever possible.

4) Adhere to a construction methodology that mitigates impacts to less than significant levels in sensitive areas during severe weather events.

5) Inform all construction personnel before they are allowed to work on the Proposed Project of environmental concerns, pertinent laws and regulations, and elements of the erosion control plan. This could be presented in a multi-hour environmental training for project management and general foremen, and a short (one hour or less) environmental training session or series of toolbox talks for construction personnel.

6) Minimize grading to the extent possible. When required, grading will be conducted away from watercourses/washes to reduce the potential of material entering the watercourse.

7) Slope and berm graded material, where possible, to reduce surface water flows across the graded area.

8) Replace excavated materials in disturbed areas and minimize the time between excavation and backfilling.

9) Direct the dewatering of excavations onto stable surfaces to avoid soil erosion.

10) Use detention basins, certified weed-free straw bales, or silt fences, where appropriate.

11) Use drainage control structures, where necessary, to direct surface drainage away from disturbance areas and to minimize runoff and sediment deposition downslope from all disturbed areas. These structures include culverts, ditches, water bars (berms and cross ditches), and sediment traps.

12) Implement other applicable BMPs to minimize erosion-related impacts during construction and improvement of access roads, and their subsequent reclamation.

13) Re-establish native and, if necessary, non-persistent, non-invasive, non-native vegetation cover in highly erodible areas as quickly as possible following construction.

VISUAL RESOURCES The following mitigation measures will be implemented to minimize visual impacts where appropriate:



1) Non-specular materials (conductor and structure materials) may be used to minimize reflections and glare.

2) After Project construction is complete, ground surfaces within the

transmission line right-of-way and areas outside the right-of-way that are disturbed during project construction would be restored to their approximate pre-construction conditions, as outlined in the Reclamation Plan.

3) Staging areas would be revegetated as necessary, according to the Reclamation Plan.

4) Existing rock formations and vegetation would be retained whenever possible.

5) Access roads and the spur roads will be constructed at appropriate angles from the originating primary travel route to minimize extended, in-line views of newly graded terrain. This mitigation is dependent upon the ability to safely construct, maintain, and utilize the road/route.

TRAFFIC AND TRANSPORTATION The following measures would be implemented to minimize impacts to traffic and roads: Traffic controls could include ensuring that

1) The locations of intersections of newly constructed access roads with public roadways would be highly visible by placing signage and traffic control crews to ensure that motorists are aware of the presence of crossing or slow-moving construction vehicles.

2) Following construction, or during construction as necessary to maintain safe

driving conditions, any damage to existing roadways caused by construction vehicles would be repaired.

PUBLIC HEALTH AND SAFETY Detailed information about the use, storage and disposal of hazardous materials would be provided in the Health and Safety Plan that would be developed by the construction contractor. A Fire Prevention and Response Plan (FPRP) will be developed and implemented during construction, operation, and maintenance of the proposed transmission line.

7.1.1 Air Quality Impacts and Mitigation In order to minimize the air quality impacts of the proposed Verde Project during project construction and maintenance, specific mitigation measures will be identified prior to the beginning of construction. There are, however, several standard mitigation measures that will be utilized to diminish anticipated air quality impacts. Appropriate quantities of water and/or chemical dust suppressants will be utilized to stabilize



disturbed areas and unpaved roadways to reduce anticipated impacts of fugitive dust emissions during construction of the proposed transmission line. In addition, vehicle speeds will be limited to 15 to 25 mph on all unpaved roadways where implementation of that restriction would minimize impact on air quality, and vehicles transporting dirt will be covered with a dust suppressant such as tarp. If additional air quality impacts are identified prior to construction, appropriate measures will be specified and outlined to minimize them. 7.1.2 Paleontological Impacts and Mitigation Measures Detrimental effects to paleontological resources will be avoided whenever possible. Known paleontological sites will be avoided where feasible and an Unanticipated Discovery Plan will be developed to identify actions and measures to be taken if unexpected resources are found during project construction. A paleontological resources monitor will be available to inspect spoils from drilling at any sites where resources are anticipated and will be available to respond within 48 hours to any unexpected issues or discoveries during the course of construction. 7.1.3 Soils Impacts and Mitigation Measures In order to minimize soil impacts during construction, several standard mitigation measures will be implemented, and in the event that additional unanticipated impacts are identified, procedures will be outlined and utilized prior to beginning construction. In the event that soils are too wet to sufficiently support heavy equipment, construction and maintenance operations will be rerouted where possible. If it is not feasible to reroute vehicles/operations to avoid saturated soils, BMP’s such as approved weight dispersing systems and equipment pads will be implemented to minimize damage. If BMP’s cannot be implemented or are not successfully applied, operations will not be conducted in the wet areas until soils are determined to be in an acceptable condition. In addition to wet soil conditions, areas of expansive soils will be identified prior to construction and any potential adverse effects will require solutions by the Project’s geotechnical engineer. These may include the excavation of expansive soils and replacement with compacted backfill. Erosion and sedimentation measures will be implemented to mitigate anticipated impacts from project construction. In addition, pre-construction topographical conditions will be restored as best and quickly as practical after construction in impacted areas has been completed. All erosion control measures will remain in place until pre-construction conditions have been approved and deemed successful. The measures to be utilized will minimize the effects from all surface disturbances in project areas. Specifications of these measures will be provided in the final construction plan. Generally, construction vehicle traffic will be restricted to approved areas and roadways in the final POD plan. Also, disturbance and removal of vegetation and soils will be minimized to necessary construction areas, and blading and grading will be avoided



whenever possible. All material that is graded is to be sloped and bermed to reduce erosion of the graded areas. Additional BMP’s such as detention basins, culverts, water bars, silt fences, and sediment traps will be implemented where necessary to reduce run-off and erosion and direct drainage away from disturbed areas. Furthermore, all construction personnel will be educated and informed as to environmental issues and erosion control measures specific to the Proposed Project. 7.1.4 Water Resources Impacts and Mitigation Measures Identification and mitigation of potential impacts to water resources will be included in the Stormwater Pollution Prevention Plan as required by the EPA Construction General Permit. In the SWPPP, all disturbed and undisturbed areas of vegetative soil will be identified. In addition, sediment control BMP’s will be outlined for stabilization during the rainy season. A schedule for implementation of these erosion and sedimentation control measures will also be included in the SWPPP. Lastly, the SWPPP is to include both temporary and permanent erosion control BMP’s to be used. In addition to the SWPPP, wells and springs near construction areas will be protected by conducting surveys prior to construction to identify their locations within 1000 feet of construction operations. BMP’s will be implemented to wells within 100 feet of construction activity, and blasting will not occur within 500 feet of a well. And only size limited blasting will be used within 1000 feet of a well. Also, hazardous materials will not be stored near a well or spring and BMP’s will be implemented to prevent spills and discharges of hazardous materials and sedimentation. Lastly, though not anticipated, dewatering activities for deep excavation will be planned to lessen effects on any nearby wells and springs. In the event that unforeseen impacts are identified, appropriate measures will be implemented to mitigate them prior to the beginning of construction. 7.1.5 Vegetation Impacts and Mitigation Measures In order to minimize detrimental impacts on vegetation disturbance several measures will be utilized during construction activities. Travel in construction areas will be limited to the shortest possible path on previously existing access roads. Also, the use of the existing access roads will be maximized as to limit the construction of new roads. Vegetation removal and trimming will also be restricted in sensitive areas and generally minimized in all construction areas to areas where necessary for safe construction, fire control, and to meet electrical safely requirements In addition to minimizing adverse effects on existing vegetation, the spread of invasive weeds into previously uninfested areas will be prevented by keeping all grading and clearing equipment washed and clean before entering an uninfested area or before leaving an infested area. Existing infestations of noxious weeds will be identified by a qualified specialist prior to construction and avoided during the course of construction. If identified noxious weed infestations cannot be avoided, they will be removed and eliminated through an approved process such as burning and disposal. Finally, all



construction personnel will be educated on infestation identification to help avoid the spread and transport into uninfested areas. 7.1.6 Wildlife Impacts and Mitigation Measures Several anticipated wildlife impacts have been identified and mitigation measures planned. Pre-construction surveys will be conducted to determine if vegetation clearing is needed. If clearing or removal is required, it will be avoided in the vicinity of nests during nesting season. Also, design of the transmission line will minimize the potential for electrocution and collision of raptors. In addition, construction operations will be conducted to minimize potential disturbance of wildlife. Measures to do this will include restricting vehicle speeds in sensitive areas to 15 to 20 mph. Also, construction vehicle operation off the right-of-way will be prohibited, except where roads already exist, or unless approved by the BLM. Previously disturbed areas will be used to the maximum extent for the purposes of vehicle parking and equipment stockpiling. And the number of vehicles and equipment used will be minimized along the right-of-way. In addition to restricting vehicles and minimizing disturbance areas, wildlife mitigation may include compensation for habitat modifications and/or permanent loss of habitat. In the event that unanticipated wildlife impacts are identified, appropriate mitigation measures will be implemented prior to the beginning of construction. 7.1.7 Threatened and Endangered Species Impacts and Mitigation Measures Special status plant impacts will be minimized by conducting pre-construction surveys to identify any such plants on proposed structure pads, pulling/splicing sites, spur roads, or staging areas. If any special status plants are found during the surveys, locations will be delineated and incorporated into the construction plan. Also, these areas will be flagged and staked in the field and minor realignments utilized where feasible to avoid any such plants. Plant Salvage Plans will be created and submitted for approval in the event the avoidance is not feasible. A similar procedure will be implemented to identify and avoid special status wildlife species. Critical habitats for sensitive species will be identified and their boundaries will be flagged to limit work activities where necessary. In addition, within key habitats, travel will be limited to existing roads and previously disturbed areas to minimize habitat degradation. Monitors would provide for species removal from the right-of-way and construction personnel will be educated to identify special status species in construction areas. In the event that additional wildlife impacts are identified, procedures will be developed prior to construction. 7.1.8 Cultural Resources Impacts and Mitigation Measures A Treatment Plan will be developed and implemented for avoiding and mitigating unavoidable National Register eligible resources. The treatment of cultural resources will adhere to NMHPD and Tribal established procedures for compliance with Section 106 of the NHPA in consultation



with the Tribes and NMHPD. Treatment plans for tribal resources would be developed separately and confidentially as dictated by tribal preference. The treatment plan is to include a Class III inventory of all previously unsurveyed areas and areas requiring inventory by the BLM and BIA. The Treatment Plan will include avoidance methods and mitigation measures, and resources evaluation report will be submitted to the BLM and BIA. Cultural resources will be avoided to the maximum possible extent and the Treatment Plan will include a final list of sites to be avoided and the detailed measures to ensure they are avoided during construction. An Unanticipated Discovery Plan will be created to identify procedures to be followed if unexpected resources are discovered during construction. In addition, a cultural resource monitor will be available to respond to cultural issues encountered during construction. Finally, concerned Native American groups will be consulted to determine the extent that cultural sites have additional sensitivities as TCP’s. 7.1.9 Visual Resources Impacts and Mitigation Measures Several measures will be taken to minimize visual impacts from the Proposed Project. The new line would be constructed with similar colors and forms (structure shapes) as the existing 115 line and the use of non-specular conductor and structure materials may be used to reduce reflection and glare. Also, ground surfaces and staging areas disturbed during construction will be restored to approximate original grade and revegetated as necessary. Whenever possible, existing vegetation and rock formations will be retained in their original condition. Finally, as long as roads can be safely constructed, maintained, and utilized, they will be constructed at angles to minimize in-line views of newly graded terrain. 7.2 Pre-Construction Environmental Resource Surveys As identified in the mitigation commitments outlined above, surveys for biological and cultural resources would be conducted prior to the start of construction. Prior to construction, a Class III pedestrian inventory will be undertaken of all portions of the area affected by the Project that have not been previously surveyed or identified by BLM or BIA as requiring inventory to identify properties that are eligible for the NRHP. Consultation will be on-going and a treatment plan will be developed and implemented in consultation, as appropriate, with the BLM, BIA, NMHPD, and interested tribes. Recommended measures will include avoidance, spanning, and site testing and excavation; other possible mitigation techniques include adjusting structure site spacing or pull site location. Pre-construction surveys will be conducted for the biological habitats and species identified by the BLM, USFWS, and NMGFD. The details of these surveys would be coordinated with these agencies. Qualified biologists will conduct these site surveys. If



special status species are encountered during the pre-construction surveys or during construction, appropriate mitigation measures will be implemented at that time to minimize any anticipated impact. 7.3 Methods and Principles for Construction Standard operating and maintenance procedures will be conducted in construction areas including structure pad locations, spur roads, and stringing/tensioning sites. The following prescriptions would be implemented prior to construction activities commencing.

• Generally, standard equipment will be used in construction and to clear vegetation. Types of equipment needed will be determined on a site-by-site basis and may include the use of drilled shafts and piers, and caissons.

• Heavy duty trucks may also be needed in standard construction activities. The types of trucks used will be determined on a site specific basis and may include trucks with augers, cranes, bucket and material trucks, and ready mix trucks. Access to each of the specific sites and parking at those sites will be determined prior to construction beginning.

• Standard methods of construction and materials will be used for foundations at construction sites. This may include direct embedment and/or drilled shaft foundation construction processes. Specific methods of construction regarding excavation, steel caisson placement, anchor bolt placement, concrete filling and setting, and grout injection will be determined on a site-by-site basis prior to construction commencing and included in the final construction plan.

• Pole structures will be placed and set using generally accepted standards and operating procedures. Specific details, methods, and materials will be determined on a site specific basis prior to construction and will be included in the final construction plan. These may include on-site steel structure assembly, mounting of line hardware, erecting of steel poles, installation of steel arms for insulator and cable installation, and structure grounding. All needed equipment, storage, and impacted areas will be determined at each specific construction location.

8.0 Stabilization and Rehabilitation



8.1 Transmission Line Reclamation Reclamation activities will be conducted on disturbed construction areas including structure pad locations, spur roads, and stringing/tensioning sites. The following prescriptions would be implemented after final construction activities have been completed.

• Any new road construction and active construction areas would be graded in such a manner that berms would be limited to those area where needed for erosion control and drainage.

• To the maximum extent possible, vegetation removal and trimming would be limited to that necessary for safe construction, fire control, and to meet electrical safely requirements. In all other areas, only the crushing of vegetation would occur unless grading is necessary.

• If soil is to be excavated or graded in areas of temporary disturbance, topsoil will be salvaged and redistributed prior to reclamation to the extent practical.

• Subsurface soils, if excavated, would be used as initial fill for disturbed sites. Following this, salvaged topsoil would be spread on the disturbed area and raked with a narrow-toothed spike or similar equipment to create imprinting or micro-catchment depressions for water retention and seed collection. Unless deemed to be otherwise beneficial, no mulch would be applied in order to eliminate any barriers to seed deposition from wind dispersal and possible introduction of alien and noxious plant species.

• Following construction, disturbed areas would be restored as closely as practical to the original pre-construction topographic contours, unless otherwise agreed to by the landowners.

• Where hydrologic features and/or banks are disturbed, the original surface channel hydrologic features would be re-contoured to approximate pre-construction contours and bank slope margins would be backfilled.

• Compacted soils in construction areas would be ripped to a depth of 4 to 8 inches by a chisel, plow, disc, or other type of equipment to improve moisture permeability between the soil/spoil interface.

• The existing seed bank in the first several inches of soil would be used to the extent possible to revegetate a disturbed site. Supplemental seeding would only be used where necessary.

• Seed capture and propagation would be encouraged by mechanical pitting and imprinting.



• Where necessary (e.g., unstable soils, steep slopes), erosion control measures, including contouring, would be used to prevent erosion and sedimentation until vegetation becomes established.

• If vegetation has been cleared from a construction area, it would be respread within the reclaimed area to increase soil moisture and provide a catchment for wind dispersed seeds.

• Soil will be replaced and stabilized after construction

• If vegetation is unsalvageable, Verde will remove the vegetation based on approved BLM methods

• Seeding specification will be determined in consultation with the landowner for those areas that will be reseeded. Only approved seed mixes will be utilized.

• Fertilizer will only be used if required and approved by the BLM

• Temporary roads built for access during construction will be reclaimed

• All temporary construction sites, material storage yards, will be restored to their original use after construction and cleanup will be achieved.

• Trash will be removed and disposal of refuse and trash will be achieved through daily maintenance and trash removal. Construction debris will be removed based on approved procedures by the BLM.

8.2 Noxious Weed Species The control of noxious weed species can be achieved through proper revegetation using appropriate management practices during transmission line construction as well as reclamation of the disturbed areas. Measures associated with limiting the impact of noxious weed species are provided as follows:

• Construction supervisors and managers would be educated on weed identification and the importance of controlling and preventing the spread of noxious weed species infestations.

• Disturbed construction areas would be reclaimed as soon as possible after construction in the area is completed.

• Before beginning reclamation activities, previously identified noxious weed infestations would be controlled through acceptable mechanical (e.g., topsoil excavation and removal), cultural, and/or herbicide applications.



• Clearing and grading equipment would have the tires, axles, frame, running boards, under carriages, and soil holding areas washed and cleaned to prevent noxious weed species transport to unaffected areas.

8.2.1 Noxious Weed Monitoring Plan Monitoring of noxious weed populations in areas disturbed by the Project would be conducted annually until the weed abatement success criteria have been met. Noxious weed surveys would be conducted less frequently (e.g., every 3 years) if survey results indicate weed abatement criteria have been met. The monitoring would be conducted during the growing season for most weeds, generally between late March and mid-May. Lists of noxious weeds would be obtained from the BLM, BIA, tribes, and/or the State Departments of Agriculture. Surveys would be conducted in areas disturbed during construction on foot and/or by vehicle within the construction corridor, along spur roads and stringing and tensioning sites. Species names and locations of noxious weed infestations would be mapped (e.g., on USGS 7.5-minute quadrangle maps, or aerial photographs, and/or using a GPS) and transferred to an updateable GIS database. Photographs would be taken of treated populations prior to treatments and one year following treatments.

Noxious weed management would be considered successful if existing noxious weed infestations in areas disturbed by construction were no greater in density and extent one year following construction than they were surveyed prior to construction. 8.3 Restoration Success Criteria and Post-Construction Monitoring Restoration success criteria are defined as factors to evaluate the success of the post-construction reclamation, control the spread of noxious weeds, and effectiveness of erosion control measures. Post-construction monitoring would continue following reclamation until success criteria were met. If post-construction monitoring results indicate that project-affected sites were trending toward successfully meeting soil and noxious weeds criteria, monitoring may be conducted less frequently (e.g., every three years) subsequently, until success criteria were met.



8.4 Restoration of Temporary Disturbance Areas Reclamation success would be evaluated by comparing project-affected sites with pre-construction conditions and/or adjacent areas in terms of final grading and removal of any introduced berms, recontouring to approximate pre-construction contours, removal of noxious weed species, and relief of all compacted soils. The reclamation of sites would be considered successful if they are within a specified percentage of the mean native or pre-existing species composition and vegetation cover of the reference site(s). The reference sites would be either the Project-affected site as recorded during pre-construction conditions (if known) or representative areas which have the same target plant community adjacent to the affected site. 8.5 Erosion Control The effectiveness of erosion control measures would be evaluated by noting particular site conditions, including soil movement and downslope sedimentation, surface vegetative detritus (litter) movement, flow pattern development, rills and gullies, wind-scour depressions, and plant root system exposure. If the conditions listed are present, it would be assumed that project-related erosion is occurring, and options for remedial measures would be evaluated and implemented as needed. Erosion control measures would be considered successful when no project-related erosion is evident five years following project implementation.

9.0 Operation and Maintenance



This section outlines those procedures that will be employed during the operation and maintenance phase of the Project after construction and restoration have been completed. Following project construction, operation and maintenance of the new line would commence. Operation and maintenance activities would include all operation and maintenance requirements set forth by the New Mexico PRC and North American Electric Reliability Corporation (“NERC”) standards including activities such as patrol of the lines, climbing inspections, transmission structure (H-frame or pole) and wire maintenance and repair, routine line washing, and repairs of access and spur roads, permanent pulling sites and permanent helicopter platforms. Verde would keep necessary work areas around all structures clear of vegetation and would limit the height of vegetation along the ROW as needed for safe construction, fire control, to meet electrical safely requirements and reliability criteria. The following section provides details on the anticipated operation and maintenance requirements for the proposed transmission line. 9.1 Safety Safety is a primary concern in the design of the Project transmission line and related facilities. The transmission line will be protected with power circuit breakers and related line relay protection equipment. Lightning protection will be provided by overhead ground wires (shield wires or OPGW) along the line. Electrical equipment and fencing at the substation will be grounded. All existing fences, metal gates, pipelines, etc. that cross or are within the transmission line right-of-way will be grounded to prevent electrical shock. 9.2 Emergency Response Emergencies are any event requiring immediate response to a condition. These may include, but are not limited to, car-to-structure contacts, downed structures, fires, transformer outages and/or outages due to down wire as a result of extreme weather. Responding crews would vary in number and equipment needs depending on the size and severity of the emergency. Typically, a four-person crew with a line truck, aerial lift truck, and an assist truck would respond to the emergency to make repairs. Crews may be required to respond to an emergency in a remote area without roads. In areas without vehicle access, helicopters may be used to respond quickly to emergencies.



9.3 Inspection and Maintenance Schedule and Level of Use The Project ROW will be periodically patrolled to inspect its condition and identify problem areas so that maintenance crews may be scheduled to correct any problems. Ground and aerial inspections will be performed on average once per year, or as needed to detect facilities needing repair or replacement. Maintenance will be performed by project personnel or approved contractors. Normal maintenance or repairs to conductor or insulator components will not require notification of the BLM unless new ground disturbance outside of the original construction footprint is required. Access for this routine repair work will be confined to roads and access designated for this purpose. In emergencies arising from fire, flood, storms, vandalism or other factors causing or requiring an outage, repair work will be conducted as soon as the damage is detected. Crews will be instructed, in accordance with specific maintenance plans and procedures, to protect crops, vegetation, wildlife, and other resources of significance. Specific training will be provided to all maintenance crews instructing them on plan and procedure / policy requirements. Restoration procedures following completion of repair work will be similar to those prescribed for original construction. Substation maintenance activities will include routine scheduled equipment maintenance, groundskeeping, and emergency maintenance in the event of equipment failure. Substation maintenance will be performed by project personnel or approved contractors. 9.4 Transmission Line Maintenance 9.4.1 Inspection Patrols Regular ground and aerial inspections would be performed in accordance with the NMPRC and NERC requirements for transmission facility maintenance. Overhead transmission lines, transmission structures, and substations would be inspected for corrosion, equipment misalignment, loose fittings, and other mechanical problems. The need for vegetation management would also be determined during inspection patrols. Aerial inspection (visual and infrared) of the entire system and climbing inspections of transmission structures would be conducted regularly. Aerial inspection would be conducted by helicopter and would require two or three crewmembers, including the pilot. Ground inspections would be conducted by up to three crewmembers on a regular schedule



9.4.2 Hardware Maintenance and Repairs Electrical equipment housed on poles or H-frame support structures may include conductors, insulators, switches, transformers, lightning arrest devices, line junctions, fiber optic splice boxes and other electrical equipment. This equipment may require addition, replacement or repair over time. Typically, equipment repair or replacement would be conducted by a four-person crew with two or three trucks, a boom or line truck, an aerial truck and an assist truck. 9.4.3 Insulator Washing Arcing can occur when an electrical discharge is created from the combination of atmospheric condensation and dust on porcelain insulators. Arcing may cause electrical outages, but can be prevented by routinely washing the insulators to keep them free of dust. Insulator washing involves driving a water truck to within six feet of a structure base and using a high-pressure hose to spray deionized water at the insulators. Two crewmembers and a water truck are required for insulator washing. Typically, insulator washing takes approximately 30 minutes per transmission structure. Insulator washing is not expected more than twice a year and would require 300 gallons of water per structure and 3,000 gallons of water per day. 9.5 Right-of-Way Repair ROW repairs would include grading or repair of existing maintenance access roads and work areas, permanent pulling sites and helicopter platforms and spot repair of sites subject to flooding or scouring. Activities related to ROW repair are usually conducted after the rainy season, when water may have caused erosion damage. Required equipment may include a motor grader, backhoe, four-wheel drive pickup truck, and a cat-loader. The cat-loader has steel tracks whereas the grader, backhoe, and truck would typically have rubber tires. All access roads are maintained on a 2-year schedule. 9.6 Vegetation Management Necessary clearance would be maintained around the base or foundation of all electrical transmission structures. In addition, work areas will be maintained adjacent to access roads and electric transmission structures for vehicle and equipment access necessary for operations, maintenance and repair. Shrubs and other obstructions would be regularly removed as needed to facilitate safe inspection and maintenance of equipment, for fire control, to meet electrical safely requirements, and to ensure system reliability. Vegetation that would grow to a height that could compromise electrical safety and reliability requirements would be trimmed to avoid the proximity of



any overhead conductor or working area in order to protect system reliability and public safety. Vegetation would be removed using mechanical equipment such as chain saws, weed trimmers, rakes, shovels, mowers and brush hooks. The duration of activities and the size of crew and equipment required would be dependent on the amount and size of the vegetation to be trimmed or removed. Most vegetation removal or tree trimming activities can be completed in one day. Local application of approved herbicides would occur as specified in the vegetation management plan. Aerial application of herbicide is not anticipated. 9.7 Fire Control All applicable fire laws and regulations will be observed during the operation and maintenance period. All personnel would be advised of their responsibilities under the applicable fire laws and regulations, including taking practical measures to report and suppress fires. In some cases, the vegetation management required within the transmission ROW could help act as a fire-break in the event of a fire. BLM fire safety standards will be followed. Requirements for fire tool availability, spark arresters/mufflers on equipment, and coordination of extreme fire conditions with BLM representatives will be coordinated. When extreme fire conditions occur, BLM representatives will be contacted and access will be restricted. Refueling of equipment and helicopter staging areas will be at nearby airports or staging areas on private property. 9.8 Noxious Weed Control A comprehensive, adaptive Weed Control Plan for pre-construction and long-term invasive weed abatement will be prepared and implemented. Where Verde owns the ROW property, the Weed Control Plan will include specific weed abatement methods, practices and treatment timing developed in consultation with the county and State. On the ROW easement lands administered by public agencies (BLM) or the tribes, the Weed Control Plan will incorporate all appropriate and legal agency-stipulated and tribal-stipulated requirements. The Weed Control Plan will be submitted to the agencies, tribes, and landowners for final authorization of weed control methods, practices, and timing prior to implementation. Verde will also work with the landowners to obtain authorization of the weed control treatment required on their properties.



The Weed Control Plan will include the following:

• A pre-construction weed inventory will be conducted by surveying the entire ROW and areas immediately adjacent to the ROW (where access and permission can be secured) as well as at all ancillary facilities associated with the Project for weed populations.

• A pre-construction weed inventory will also be conducted by surveying areas that will be directly impacted by the Project for weed populations. These plant species will be treated prior to construction or at a time when treatments would be most effective based on phenology according to control methods and practices for invasive weed populations.

• Weed control treatments will include all legally permitted chemical, manual and mechanical methods applied with the authorization of the agencies, tribes, and landowners where appropriate. The application of herbicides will be in compliance with all state and federal laws and regulations.

• During project construction and operation/maintenance, all seeds and straw

materials will be certified weed free, and all gravel and fill material will be certified weed free to the extent possible.

• During project construction and operation/maintenance, vehicles and all equipment will be washed (including wheels, undercarriages, and bumpers) immediately before and after entering project construction areas and prior to returning to the original project construction area should equipment be used in a different construction area.

10.0 Termination and Restoration



This section outlines the measures that will be taken at such time in the future when the ROW has expired and the Project is terminated. At this time, these actions are anticipated to include:

• Removal of structures • Obliteration of roads, structure pads, etc. • Stabilization and re-vegetation of disturbed areas

Structures will be removed and structure sites will be cleared and graded only to the extent necessary. Clearing activities to reestablish or improve access will be performed in a manner agreed to by the BLM. Restoration activities will be similar to those described for post-construction. In construction areas (e.g., structure sites, pull sites, access roads) where ground disturbance is significant or where recontouring is required, surface restoration will occur as required by the BLM. The method of restoration will typically consist of returning disturbed areas to their natural contour (to the extent practical), installing cross drains for erosion control, placing water bars in the road, and filling ditches, using straw bales and sediment traps. In general, all construction and subsequent maintenance activities will be conducted in a manner that will minimize disturbance to soil and vegetation. In addition, all previously existing roads that will continue to be in use will be left in a condition equal to or better than their condition prior to construction of the transmission lines. All such measures will remain in place at the conclusion of reclamation until such time that they can be removed at the agreement of BLM. These temporary and permanent erosion control measures could include: sediment barriers, waterbars, erosion control, and mulching. Access roads or trails identified by the BLM will be blocked or fenced, if requested, to prevent future access by the public. Fences, gates, and cattleguards will be replaced if damaged or removed during termination and restoration. Methods of restoration when the ROW has expired and the Project is terminated will adhere to generally accepted standard operating procedures. Damage to existing structures will be minimized during construction to the extent possible. Any damage to existing facilities and structures during construction activities will be restored to a condition equal to or better than their pre-construction condition. Prior to restoration, any necessary surveys will be conducted in accordance with accepted standards and procedures. During the course of any necessary restoration activities, education similar to that given to construction crews will be given to workers regarding environmentally sensitive areas including: protection and avoidance of



cultural, paleontological, and biological resources, minimizing impact on special status species and containment and disposal of any hazardous materials. In addition, environmental monitors will be utilized at any areas deemed necessary. All restoration activities will be conducted in a manner that minimizes impacts to surrounding agricultural production and minimize radio or television interference. In addition, restoration will be implemented to achieve results that minimize any visual impacts of the Project and reuses/recycles materials to the maximum extent applicable. Standard safety procedures associated with restoration activities will be implemented. This will include properly marking structures and wires for visibility. If any special construction techniques are needed for restoration, safety procedures will be outlined and implemented prior to beginning of restoration activities.

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VERDE TRANSMISSION PROJECT - Hunt Power proposed Verde Transmission Project (Verde Project or...

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