Transmission System Vegetation Management Program (DOE/EIS-0285)
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
were submitted in error or have inappropriate content (such as SPAM). If you do not see your comment two business days after
you submit it, please contact (800) 622-4519.
In June 2000, Bonneville Power Administration (BPA) issued the Transmission System Vegetation Management Program Final Environmental Impact Statement (EIS) that considered alternative ways to manage vegetation along BPA transmission facilities. In July 2000, the BPA Administrator issued a Record of Decision (ROD) that selected alternatives from the Final EIS for various components of vegetation management and set the policy and direction for managing vegetation at and along BPA transmission facilities, including in rights-of-way and access roads throughout the service area. BPA adopted a vegetation management program direction that is cost-effective, sensitive to environmental concerns, responsive to public and agency comment, and consistent with integrated vegetation management strategies.
BPA is proposing to prepare a supplement analysis to its 2000 Transmission System Vegetation Management Program Final EIS. BPA is planning to evaluate inclusion of aerial management techniques such as heli-saw and heli-feller operations as vegetation management techniques. BPA is also planning to evaluate inclusion of Aminocyclopyrachlor [Method 240SL], Indaziflam [Esplanade 200 SC], 2,4-D Choline Salt [Freelexx], Aminopyralid + Florpyrauxifen-Benzyl [TerraVue], and Triclopyr Choline [Vastlan] to BPA’s list of approved herbicides for selective and total vegetation control in Bonneville rights-of-way, access roads, electric yards, and non-electric facilities. These techniques and herbicides would help with more efficient removal of vegetation near BPA transmission lines and facilities and assist in efforts to minimize the effects of associated potential wildfires. The use of the new techniques and herbicides would be implemented in accordance with all local, state, and Federal regulated practices.
BPA’s transmission line system can be viewed on BPA’s geospatial portal at: https://bpagis.maps.arcgis.com/home/index.html, (select the BPA Transmission Assets map).
While this supplement analysis considers adding these herbicides and methods to the vegetation management program in accordance with the procedure identified in the EIS, actual implementation and utilization of any of these herbicides or methods would be examined separately in a project-specific supplement analysis following the 7-step process outlined in the EIS. Those project-specific supplement analyses would include all relevant National Environmental Policy Act coordination, consultation and findings, including Section 106 of the National Historic Preservation Act and Section 7 of the Endangered Species Act.
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 were submitted in error or have inappropriate content (such as SPAM). If you do not see your comment two business days after you submit i
For More Information:
David Kennedy, 503-230-3769 or e-mail at dkkennedy@bpa.gov
Close of comment: 1/18/2022
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Dinubilo/Cultural Resource Department of the Squaxin Island TribeThank you for contacting the Squaxin Island Tribe Cultural Resources Department regarding the above listed project for our review and comment. Before we can make a recommendation of effect to historic properties for your undertaking, we request additional information. In order for us to continue our review of the undertaking, we will need maps of the project area and to see the draft supplemental.
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Abrahamson/Spokane Tribe of IndiansMr. Kennedy,
Thank you for contacting the tribe’s Historic Preservation officer. We appreciate the opportunity to provide a cultural consult for your project.
Pursuant to compliance with section 106 of the National Historic Preservation Act and 36 CFR 800, we are herby initiating consultation for this project.
As you know there are important cultural considerations surrounding the aboriginal territory of the Spokane Tribe as I understand that BPA will begin their summer vegetation management project, please beware of tribal gathering plants such as wild strawberries, camas, sunflower plants and many others one of the most important plant is the huckleberry plants in the higher elevations areas as people are gathering these plants and berries so they are aware of the spraying, these areas will need putting signage up.
As always, if cultural resources or human remains are found upon inadvertent discovered this office should be notified. Should additional information become available or scope of work change our assessment may be revised.
Again, thank you for the opportunity to comment and consider this a positive action that will assist us in protecting our shared heritage. If question arise, please contact me at 258-4222.
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Martin/Coquille Indian TribeThank you for the opportunity to comment on the proposal for additional techniques to manage vegetation at the above referenced location. The Coquille Indian Tribe THPO concurs with the anticipatory finding of no historic properties/cultural resources effected. Extreme caution is recommended. If any known or suspected cultural resources are encountered during the work, ground-disturbing activities should cease and the landowner or contractor should contact our office immediately.
Please be aware that state statutes and federal law governs how archaeological sites are to be managed. 43 CFR 10 applies on tribal and federal lands, federal projects, federal agencies, as well as to federal actions and federally funded (directly or indirectly) projects. ORS 97.745 prohibits the willful removal, mutilation, defacing, injury, or destruction of any cairn, burial, human remains, funerary objects, or objects of cultural patrimony of a Native Indian. ORS 358.920 prohibits excavation, injury, destruction, or alteration of an archaeological site or object, or removal of an archaeological object from public or private lands. If archaeological materials are discovered, uncovered, or disturbed on the property, we will discuss the appropriate actions with all necessary parties.
Thank you again and feel free to contact me at (541) 217-5721 if you have any questions.
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Warren/State of Idaho
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pace
I’m really hesitant about some of the chemicals BPA proposes to add to its list of suitable control measures. This is especially the case for Freelexx, which is a 2-4,D avatar. Notwithstanding what the herbicide product labels claim, there is no such thing as “total” vegetation control. In the short term, it’s virtually impossible to ensure that application of herbicides will be even and/or effective. Because of wind, other weather conditions, terrain, etc. the “efficiency” of inexpensive aerial application techniques is misleading. It’s spotty and partial. Moreover, when the analytic time horizon is lengthened, repeated application of herbicide yields diminishing returns over time as undesirable plant communities adapt.
Consequently, control by herbicides should be integrated with other measures that avoid the adverse impacts on the herbicides. For example, BPA mentions helicopter logging for trees. A variety of other control measures are not mentioned in BPA’s notice to the public. For example, control measures using goats can be especially effective on broadleaf weeds. Another way to address the problem is to reduce peak line loadings, especially in summer when conductors “sag” near the ground.
These two examples are mentioned here because they do not require that BPA address exposure scenarios for people–and for wildlife. Where exposure scenarios are implicated, impacts on rural populations of humans, including but not limited to tribal members, must be addressed. With 15,000 miles of transmission rights-of-way, BPA’s basic approach should consider “outside the box” integrated measures with particular attention paid to drivers based on local circumstances. These conditions vary considerably throughout the region and include specific wildlife populations. For example, historic habitat required for endangered pygmy rabbits are widespread east of the Cascades, but are almost never seriously considered in transmission planning.
Pygmy rabbits are just one of the issues that arise. For example, vegetation management includes control measures for access roads. These access roads are typically used by hunters to poach deer and elk. This is especially the case on the western slope of the Cascades and coastal range. Roads and transmission rights-of-way in dense vegetation attract wildlife populations, where they can be efficiently harvested by legal and other means.
Finally, BPA indicates that it intends to address ESA section 7 compliance on a case by case basis. As background, I represented the Shoshone-Bannock Tribes, which submitted the first ESA petition on sockeye in 1991, and have been involved in FCRPS–nowadays CRS–for three decades. This experience taught me that there is no upside to lighting ESA fires that can never be extinguished. In the end, you just have federal action agencies operating CRS in an unlawful manner, which includes enviro groups filing “kitchen sink” litigation, BPA paying tribes to “Shut The F Up” in every fish forum and laundering the bribes required for their silence thru the Northwest Power Council while extinction continues apace under the curation and protective umbrellas provided by the federal district court and ninth circuit court of appeals.
I believe it’s important NOT to allow the enviros/STFU tribes to use bad faith litigation to parasitize ESA compliance for BPA’s transmission system. This hasn’t happened yet but that’s because the enviros don’t have any expertise, and are not interested in understanding how the transmission system works. It’s incredible, but I believe this has been the case from the early 1980s, as evidenced by breathtaking infirmities in the Northwest Power Council’s statement of losses and goals. Right now, ESA skirmishes involve links between threatened and endangered interior Columbia River fish populations and the southern killer whale population in the Pacific Ocean and Puget Sound. Once that “ore” is mined in the federal courts, I think it’s inevitable that litigants will focus their ESA attacks on the transmission system.
During the Trump administration, Representative McMorris-Rogers proposed legislation that would have (1) “frozen” FCRPS operations at 2014 reasonable/prudent alternatives and (2) placed the FCRTS system beyond the reach of litigants. The first part was highly controversial. The second part was barely even noticed by the I-5 snowflakes and STFU tribes. For consideration, I believe a much better approach would be for the Secretary of the Department of Defense to exempt the transmission system from the reach of ESA. Note that this will not affect the statutory authority of the Northwest Power Council and/or the consultations and findings required by Magnuson-Stevens fishery conservation. This “hard reset” of ESA status in advance of nefarious, never ending “legal fare” targeting the transmission system.
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Quaempts/Confederated Tribes of the Umatilla Indian Reservation
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Anderson/Washington State Dept. of EcologyThe applicant must determine if wastes produced at the facility or project site are dangerous wastes in Washington State. The regulations can be found in Chapter 173-303 of the Washington Administrative Code (WAC) online at: http://apps.leg.wa.gov/wac/default.aspx?cite=173-303.
For more information and technical assistance with determining whether wastes are dangerous wastes in Washington, contact Huckleberry Palmer at (509) 952-5442 or hpal461@ecy.wa.gov.
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Bonanno/USDAAttached file received by BPA's mail room after the comment period closed, 2/7/22.
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