Northern Mid-Columbia Joint Project
The following comments were submitted in response to the open comment period described below.
Comments are numbered consecutively as they are received. Breaks in the number sequence result when comments are deleted because they
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In mid- November BPA released the draft environmental assessment (EA) for the proposed Northern Mid- Columbia Joint Project. If constructed, this proposed 230-kV transmission line and associated facilities would be located in the northern mid-Columbia area of Washington State, south of Wenatchee. The draft EA describes the project and why it is needed, discusses the environmental impacts the project could create, and describes mitigation measures that would avoid or lessen those impacts.
BPA welcomes public comments on the draft EA beginning November 17. Interested parties should send comments on the draft EA to BPA by January 14, 2015. All comments will be posted in their entirety on the project website.
Public meetings: December, 2014
BPA and Douglas PUD have scheduled two informal, open-house meetings to answer questions and accept comments on the draft EA for the proposed project. Meeting times and locations are:
Tuesday, December 9, 2014
4:30 to 7 p.m.
Rock Island Elementary School
5645 Rock Island Road
Rock Island, Wash. 98850
Wednesday, December 10, 2014
4:30 to 7 p.m.
Alcoa Inc. Production Facility
6200 Malaga / Alcoa Hwy.
Malaga, Wash. 98828
For More Information:
https://www.bpa.gov/goto/NorthernMidColumbia
Close of comment: 1/30/2015
- NMCJP14 0002 -
Theiler/Douglas County, WARemoval and maintenance of vegetaion within the shoreline environment, pursuant to the Douglas County Shoreline Master Program and the Washington State Shoreline Management Act, requires shoreline permitting and/or written shoreline exemptions from Douglas County. It would appear, based on observations of other BPA lines within the shoreline jurisdiction, that long term permanent vegetation removal in the shoreline jurisdiction is contemplated as part of maintenance for the transmission lines. Project permitting should account for this long term vegetation management and disturbance within the shoreline jurisdiction.
- NMCJP14 0003 -
Multiple commentsPlease see attached comments received at the public meetings that were held on 12/9/14 - 12/10/14.
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- NMCJP14 0004 -
/US Environmental Protection Agency Region 10Please see attached for comment
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- NMCJP14 0005 -
BLM/Bureau of Land Management WenatcheePlease see attached for comment.
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- NMCJP14 0006 -
PaceI’ve reviewed the Draft EA for the Joint Project and have several comments. First, the discussion of the need and purpose of the project needs to be clarified in the section titled need and purpose. As it now stands, the statement of need and purpose is scattered in the document. This is not a “fatal flaw” from an environmental compliance perspective; it’s just that there needs to be a clear statement of the need and purpose in the section of the text under that heading. As an aside, my understanding is that the Chelan County PUD has recently completed (or will soon complete) a strategic plan. The Draft EA should incorporate a discussion of how the Joint Project meets—or does not meet—the approach outlined in Chelan PUD’s strategic plan. This discussion should include, but should not be limited to, Chelan PUD’s recent moratorium place on applications for service by requesters seeking in excess of 1 aMW. The Draft EA should describe what is driving these unprecedented requests and how the Joint Project will—or will not—assist Chelan PUD in dealing with unanticipated demands that may result from such demands on its infrastructure. I also have concerns with BPA’s apparent intent to use chemical for vegetation management. This problem is not unique to the Joint Project. It’s a concern throughout BPA’s transmission system and needs to be addressed, particularly where the chemicals used for managing vegetation pose a threat to listed species. In particular, the Draft EA should consider the use of biological control measures rather than (or in addition to) chemicals for vegation management. Last, I note that the definition of the project area is arbitrary, capricious and not in accordance with legal requirements, for certain key species that may be impacted by the Joint Project. This requires a bit of development and a bit of study, but it’s clearly the case once you take a close look. According to the Draft EA, “The term project area is used to describe the area in the immediate vicinity of the project alternatives.” See Draft EA, p. 3-1. The “project area” is distinguished from the “study” area as follows: “To identify potential impacts on each resource, a defined area is considered, referred to as the study area. … Because the project could result in impacts on resources that are geographically removed from the project area … the study area for some resources extends beyond the project area.” Id. I noticed that “study areas” for other affected resources include all of Chelan and Douglas counties. Table 3.6-1 identifies special-status species of wildlife potentially occurring in Douglas and Chelan counties. However, for species that are, perhaps, of the greatest concern, the Draft EA only considers the immediate vicinity. For example, Table 3.6-1 states that pygmy rabbit, Brachylagus idahoensis, in neither detected nor known to occur within the project area. See Draft EA, p. 3-57. I could not find anything in the Draft EA that addressed potential impacts on pygmy rabbit populations within Douglas and Chelan counties. Table 3.6-1 also identifies greater sage grouse, Centrocrus urophasianus, but does not consider potential impacts. Instead, we are informed as follows: “Greater sage-grouse that might be present along the East Route would consist of transient individuals with no established populations present.” See Draft EA, page 3-57. I think that this approach—essentially, defining the study area as Chelan and Douglass counties for some species but confining the study area to the immediate vicinity for pygmy rabbits and for greater sage grouse—is, on its face, arbitrary and capricious and not in accord with the requirements of law. Bonneville really needs to take a consistent approach to its treatment of species that are potentially impacted by the project. More specifically, I hope BPA will consider the potential impact on pygmy rabbits and sage grouse within the wider two-county area. Not surprisingly, the more expansive approach I’m suggesting for consideration is supported by analyses completed by the U.S. Department of Agriculture, Farm Service Agency, which states as follows: “Douglas County isn't the largest population center in Washington State. With ten towns and 33,000 people, it isn't even close. But what this north central county does have that other places don't is one of the last remaining populations of three endangered animal species - the Sharp-Tail Grouse, the Sage Grouse, and the Pygmy Rabbit. For the past twenty years, the Conservation Reserve Program (CRP) has provided habitat for these species and eased threatened and endangered species requirements for agricultural producers. A federal judge's decision linking a threatened and endangered species ruling to the existence of CRP in Douglas County reflects the significance of the program. See USDA, Farm Services Agency, "CRP Saves Endangered Species Habitat," available online, emphasis added. Here is the link: http://www.fsa.usda.gov/FSA/newsReleases?mystate=wa&area=home&subject=copr&topic=crp-20&newstype=crpsuccessstories&type=detail&item=ss_wa_artid_661.html.
- NMCJP14 0007 -
Bowman/Chelan County PUDPlease see attached for comment
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- NMCJP14 0008 -
Ritter/Washington Department of Fish and WildlifePlease see attached for comment
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- NMCJP14 0009 -
McDowell/US Fish and Wildlife ServicePlease see attached for comment
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- NMCJP14 0010 -
Meninick/Yakama NationPlease see attached for comment
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- NMCJP14 0011 -
BLM/Bureau of Land Management WenatcheePlease see attached for additional cultural comments from BLM.
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- NMCJP14 0012 -
Palmer/Washington Department of Natural Resources
I appreciate the work that bpa has already done to avoid cultural resource impacts on this project, and I look forward to seeing the cultural resources report, mitigation plan, and other documentation when they’re ready. I’ve read the draft ea and have the following comments.
p. 2-24: I see a quantitiative discussion of lithosol impacts here and throughout the document but i am not seeing in the ea a specific discussion of lithosols as traditional root harvesting areas. has this been considered?
visual quality: I don’t see indigenous visual issues addressed in the viewshed analysis. the indigenous cultural significances of views along and adjacent to the columbia river are well-documented. do tribes have data to contribute to this discussion?
photographs 3.1-3, -4, -5, -7, and -9 in the visual quality section are out of focus. while I find this extremely funny, I also think it should be corrected in the final version of the document.
p. 3-103, second paragraph: “these criteria include an examination of the cultural resource’s age, integrity (of location, design, setting, materials, workmanship, feeling and association), significance in american culture, association with a significant person, possession of great artistic value, or properties that may yield important information about the past.”
this confuses the register’s significance criteria a through d – the last four items in this list, more or less – with age and integrity considerations. while age and integrity impact eligibility, they are not themselves national register criteria.
p. 3-104: why are the tribes which were consulted not identified in this section? which tribes are doing tcp studies?
we would like to review any tcp documentation which may relate to our management of dnr lands, at the discretion of the tribe or tribes preparing it.
p. 3-126: “the douglas county population (38,431) is estimated to consist of 80 percent white, 3 percent of two or more races, 1 percent asian, and 1 percent american indian.” this totals to 85%, not 100 %. table 3.14-4 appears correct, and I would recommend revising the text to conform with the figures in the table.
p. 3-169: this discussion of cumulative impacts is vague. for example, the text says, “the extent of looting and vandalism to cultural resources in the project vicinity is unknown,” but the cultural resources section indicates that considerable survey and testing took place within the project alignment. it should be possible to make some statement about the condition of sites, at least within the project corridor, based on this work. while I appreciate that we don’t want to disclose confidential site data, I do think it’s possible to make this section more concrete.
Cumulative impacts to TCPs and cultural landscapes from transmission structures should be addressed.
- NMCJP14 0013 -
Moura/Confederated Tribes of the Colville Reservation
Kimberly,
Please accept this e-communication as our official comment regarding cultural resources for the subject undertaking. We reviewed the draft Environmental Assessment on the Northern Mid-Columbia Joint Project with particular attention to the cultural resource section. We have no questions or comments. We find the document to be well written and prepared. We look forward to continued consultation on cultural resources.
Thank you for consulting with the Confederated Tribes of the Colville Reservation.
Guy Moura
Program Manager, History/Archaeology
Tribal Historic Preservation Officer
Confederated Tribes of the Colville Reservation
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