Western Area Power Administration

Mitigation Action Plan

**for the**

# Los Banos -- Gates (Path 15) Transmission Project

1.  INTRODUCTION

    1.  HISTORY AND BACKGROUND

In May 2001, Secretary of Energy Spencer Abraham directed the Western
Area Power Administration (Western) to take the first steps, including
the preparation of environmental studies, toward developing the Los
Banos - Gates Transmission Project, also known as the Path 15 Project.
This directive was issued to carry out a recommendation in the May 2001
National Energy Policy. Western is a power marketing administration
within the Department of Energy (DOE) whose role is to market and
transmit electricity from multi-use water projects in the western United
States, including California. The Path 15 Project, located in
California's western San Joaquin Valley, would relieve a bottleneck
(Path 15) in the interstate power transmission system.

Path 15 is not a single transmission line, but rather a group of
interconnected lines that allow power to flow between northern and
southern California. Transmission restrictions on Path 15 can also
affect power flows in other western states. The Path 15 Project would
upgrade the current transfer capacity of Path 15, currently rated at
3,750 megawatts (MW) south-to-north, to 5,000 MW or more, and would
increase transfer capacity to meet California's energy needs. The
proposed Path 15 Project would consist of building a new 84-mile long,
500-kilovolt (kV) transmission line between Los Banos Substation in
Merced County, California, and Gates Substation near Coalinga in Fresno
County, California. Pacific Gas and Electric Company (PG&E) would make
related improvements at both substations, and in the underlying 230-kV
transmission system. Trans Elect, Inc. is a major participant in the
Path 15 Project, providing private funding for the construction of the
transmission line.

The Project, as proposed, is the same as the preferred alternative
described and analyzed in the environmental documents for the original
Los Banos -- Gates Transmission Project, which was prepared in
conjunction with the California - Oregon Transmission Project (COTP) in
1988. These two projects were the subject of a single set of documents
prepared in 1988 that served as the Final Environmental Impact Statement
(EIS) under the National Environmental Policy Act (NEPA) and the
Environmental Impact Report (EIR) under the California Environmental
Quality Act (CEQA). The EIS is entitled *"Final Environmental Impact
Statement for the California -- Oregon Transmission Project
(DOE/EIS-0128)."*

Since the Final EIS was prepared in 1988, Western elected to prepare a
Supplement Analysis to determine the revived Path 15 Project presented
substantial changes in the proposed action relevant to environmental
concerns, or if there were significant new circumstances or information
relevant to environmental concerns and bearing on the proposed action or
its impacts (10 Code of Federal Regulations \[CFR\] 1021.314 (c) and 40
CFR 1502.9 (c) (1) (i)). The Supplement Analysis was prepared by
reviewing the 1988 Final EIS environmental analysis and supporting
documents and the most current information available on the Project. It
was issued in August 2001.

The Supplement Analysis addressed resource and regulatory changes that
had occurred since 1988, but did not identify any substantial changes to
the significant environmental impacts identified in the 1988 Final EIS,
or any new significant impacts. Based on the findings of the Supplement
Analysis, Western determined that a Supplemental EIS was not required
and issued a Record of Decision (ROD) on December 20, 2001 (66 FR
65703).

As planning for the transmission line progressed, it became necessary to
relocate portions of the line from the tentative centerline studied in
the original EIS. Western prepared a second Supplement Analysis on these
relocations, as some of them were outside of the corridor established
for the original studies. The purpose of this second Supplement Analysis
was to assess the relocations, and determine if they were significant
enough to warrant the preparation of a Supplemental EIS. This Supplement
Analysis demonstrated that no substantial changes or significant new
circumstances were associated with the relocations. The level of
expected environmental impact from the Project was actually reduced by
the relocations, primarily because the original locations were on very
steep terrain and would require longer access roads on steeper slopes to
reach them. The relocations are closer to existing access and are on
milder terrain. The Supplement Analysis, along with a determination that
a Supplemental EIS was not necessary, was issued on May 9, 2003.

2.  FUNCTION AND ORGANIZATION OF THE MITIGATION ACTION PLAN

The DOE requirements for preparing a Mitigation Action Plan (MAP) are
specified in 10 CFR 1021 (Section 331(a), National Environmental Policy
Act Implementing Procedures). These regulations state that following the
completion of each EIS and its associated ROD, DOE shall prepare a MAP
that addresses mitigation commitments expressed in the ROD. The MAP
shall explain how the corresponding mitigation measures, designed to
mitigate adverse environmental impacts associated with the course of
action directed by the ROD, will be planned and implemented.

This MAP addresses the construction, operation, and maintenance of the
new 84-mile long 500-kV transmission line. Necessary work conducted by
PG&E at their substations will occur primarily within the previously
disturbed area inside the substation boundaries. At Los Banos, the
substation will be expanded to the east to incorporate approximately
four acres immediately adjacent to the substation. This area is outside
of the fence around the substation proper, but within PG&E's fenced
property. Western or Trans Elect, Inc. will also not have a role in
upgrading the various existing PG&E 230-kV system components.

Mitigation measures were identified in the 1986 draft EIS, the Final
EIS, and in the 2001 Supplement Analysis. The mitigation measures in the
original EIS were the basis for those adopted in the 2001 Supplement
Analysis. Since the original Los Banos -- Gates Transmission Project was
envisioned as a joint participation project with State-regulated
participants, the EIS was written to satisfy both NEPA and CEQA
requirements. The Project is now a Federal undertaking. As such, some of
the original mitigation measures that applied to the State-regulated
participants were not carried forward from the EIS into the Supplement
Analysis. The California Public Utility Commission's (CPUC) October 2001
*"Los Banos -- Gates 500-kV Transmission Project: Draft and Final
Supplemental Environmental Impact Report (SCH #850-40914)"* identifies
extensive mitigation and reporting/monitoring requirements which would
be imposed on PG&E if they were responsible for the Path 15 Project.
Western is familiar with these mitigation measures, and its identified
mitigation addresses many of the same concerns. However, Western, as a
Federal agency and not a State-regulated utility, is not subject to CPUC
authority or the mitigation provisions of that agency's EIR.

The following sections describe the plans and actions Western will
implement and verify mitigation action commitments expressed in the 2001
Supplement Analysis and the ROD. The second Supplement Analysis issued
in 2003 did not contain additional mitigation commitments that need to
be addressed in this MAP.

Section 3.0 describes the monitoring and verification of mitigation
actions and the reporting requirements. Section 4.0 describes the
mitigation commitments and action plans for the Path 15 Project. The
mitigation commitment and action plan, as specified in the 2001
Supplement Analysis and ROD, is composed of the tasks, responsible
parties, and action target completion dates for the mitigation.

3.0 MITIGATION ACTION PLAN MONITORING AND REPORTING SYSTEM

Section 5.d.(11)(f) of DOE Order 451.1B, National Environmental Policy
Act Compliance Program, requires Western to report MAP activities in its
Annual Site Environmental Report, published by January 31 of each year.
This annual report reflects new information or changed circumstances. If
major changes to mitigation included in this MAP are necessary, these
changes will be incorporated in an updated MAP and described in the
annual report. The revised MAP and annual report will be available to
the public and posted on Western's web site. The original MAP, Revision
1 was issued on January 28, 2003. This version, Revision 2, was issued
on the date below to show the progress on the mitigation commitments and
action plan provisions, and update the schedule dates on those
commitments and provisions. It also serves to incorporate the terms and
conditions contained in the U.S. Fish and Wildlife Service's Biological
Opinion, the U.S. Army Corps of Engineers' Section 404 Clean Water Act
permit, and the California State Regional Water Quality Control Board's
Section 401 Water Quality Certification.

A member of Western's environmental staff will verify mitigation results
and determine if the mitigation action achieved its intended purpose.
Western will use existing organizational and administrative controls to
gather information regarding implementation and status of mitigation
actions. Such controls include applicable reporting systems, inspection,
and verification. Western will report inspection and verification
results in its Annual Site Environmental Report on the anniversary of
the MAP. When mitigation actions are completed and verified, the
information will be included in the Annual Site Environmental Report.

Mitigation also may be monitored in accordance with Western's Mitigation
Monitoring Policy (Attachment 1).

The construction contractor shall secure all necessary permits required
by applicable Federal, State, and local environmental laws, orders, and
regulations. Western will obtain the Section 401 and Section 404 permits
referenced above. The construction contractor shall comply with any
mitigation conditions set in permits issued for the Path 15 Project.
Some of those conditions are not known at this time, so they are not
addressed in this MAP. In addition to the project area, all applicable
mitigation measures shall also be implemented on any lands obtained
directly by the construction contractor for materials storage/staging,
work offices, parking, etc. The contractor shall also hire, subject to
Western approval, independent qualified biological and cultural
resources monitors. The monitors shall ensure the protection of the
resources through adherence to all specified mitigation measures, permit
stipulations, Biological Opinion conditions, and cultural resources
Programmatic Agreement requirements.

4.  MITIGATION COMMITMENTS AND ACTION PLANS

Generic, general mitigation practices are part of Western's construction
standard specifications (Standard 13, Environmental Quality Protection).
More detailed mitigation measures, or those not covered in Standard 13,
are included in Divisions 2a and 13 of the construction specifications
package. All are made binding on the construction contractor as terms of
the contract. Applicable generic mitigation measures were defined for
the new transmission line, and are included in Table 4.1 below, along
with the parties responsible for their application, specific actions
needed to ensure effectiveness, and target dates for completion. The
generic mitigation practices are determined by the type of construction
project being considered and its environmental impacts. In some
instances, environmental impacts are reduced with the employment of
these mitigation measures. Western adopted the generic mitigation
measures as Appendix E of the 2001 Supplement Analysis. The MAP ensures
the generic mitigation practices are implemented. The short-term
mitigation commitments and action plan identified in the 2001 Supplement
Analysis are presented in Table 4.2. Table 4.3 presents the long-term
mitigation commitments and action plan that Western committed to in
Appendix E of the Path 15 2001 Supplement Analysis.

In addition to the mitigation in the tables below, Western also
committed in its ROD to the completion of the Endangered Species Act
Section 7 consultation, the National Historic Preservation Act Section
106 consultation, and the consultation with interested Native American
tribes. Formal consultation under Section 7 was completed with the
issuance of a Biological Opinion on June 10, 2003. However, Western will
continue provide information to the USFWS under the terms and conditions
in the Biological Opinion for the duration of the construction period.
Formal consultation with the SHPO was also concluded under the terms of
a Programmatic Agreement signed by affected agencies and parties.
Consultation and coordination with interested Native American tribes is
ongoing, and will continue for the duration of the Project. These
processes were all under way as the initial mitigation action plan was
finalized. The mitigation action plan is a living document and will be
updated periodically as tasks are completed, as demonstrated by the
issuance of this Revision 2.

Some of the mitigation measures below still reference PG&E actions or
obsolete transmission line segments. This is partly due to the fact that
the original mitigation measures are from the 1988 EIS. Also, when the
2001 Supplement Analysis was completed, PG&E was still involved in a
parallel CPUC applicant process. It was thought at that time that if the
project were to come under a Federal lead, it would remain a joint
participation project; this is no longer the case. For these reasons,
some of the mitigation measures below are no longer applicable and are
followed by notes in brackets to reflect the current situation.

**Table 4.1: Applicable Generic Mitigation Measures and Action Plan for
Path 15 Transmission Line Project.**

+------------------------------+------+------------------------+-------+
| **Generic Mitigation         | **R  | **Action**             | **T   |
| Commitment**                 | espo |                        | arget |
|                              | nsib |                        | Compl |
|                              | le** |                        | etion |
|                              |      |                        | D     |
|                              | *    |                        | ate** |
|                              | *Par |                        |       |
|                              | ty** |                        |       |
+==============================+======+========================+=======+
| 1\. Avoid active oil wells   | A    | Task a: Incorporate    | Com   |
| and water extraction wells   | 7900 | requirement into       | plete |
| and critical facilities.     |      | structure locations.   |       |
| Cross non-critical           | G    |                        | Com   |
| facilities if resources      | 5600 | Task b: Completed      | plete |
| cannot be avoided. \[Note:   |      | through centerline     |       |
| Since the FEIS was           | G560 | selection.             | 12/04 |
| completed, most of the       | 0/A7 |                        |       |
| oil/gas facilities at the    | 400/ | Task c: Monitor site   |       |
| south end of the project     |      | work.                  |       |
| have been abandoned, and     | Co   |                        |       |
| some removed.\]              | ntra |                        |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 2\. PG&E will work with      | G    | Task a**:** Determine  | Com   |
| California Department of     | 5600 | structure locations.   | plete |
| Water Resources (CDWR) to    |      |                        |       |
| site towers compatible with  | A74  | Task b: Coordinate     | Com   |
| the existing facilities at   | 00/N | with CDWR.             | plete |
| Little Panoche Reservoir     | 1600 |                        |       |
| (West-5) or the proposed     |      | Task c: Monitor site   | 12/04 |
| facilities at the Los Banos  | G560 | work.                  |       |
| Grandes Offstream Storage    | 0/A7 |                        |       |
| project (West-3 and East).   | 400/ |                        |       |
| \[Western will assume this   |      |                        |       |
| responsibility for the       | Co   |                        |       |
| proposed route.\]            | ntra |                        |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 3\. Conduct site specific    | A    | Task a: Obtain species | Com   |
| scoping sessions as required | 7400 | list for project area. | plete |
| under Section 7 (Endangered  |      |                        |       |
| Species Act, 1973, as        | A74  | Task b: Prepare        | Com   |
| amended) consultation        | 00/N | Statement of Work      | plete |
| procedures to focus field    | 5800 | (SOW) for contractor   |       |
| studies, impact analysis,    |      | to conduct field       | Com   |
| and potential mitigation     | N    | surveys for listed     | plete |
| assessments. \[The above     | 5800 | species.               |       |
| 1988 mitigation measure is   |      |                        | Ro    |
| poorly written and somewhat  | Co   | Task c: Procure        | lling |
| redundant with those below.  | ntra | contractor services.   | sch   |
| Western will coordinate with | ctor |                        | edule |
| Federal, State and Tribal    |      | Task d: Determine      |       |
| resource agencies to         | Cont | areas of active work   | Ro    |
| identify sensitive species   | ract | at least 30 days out.  | lling |
| and develop appropriate      | or's |                        | sch   |
| field surveys for those      | Moni | Task e: Conduct        | edule |
| species.\]                   | tors | surveys in accordance  |       |
|                              |      | with Biological        | 12/04 |
| Conduct pre-construction     | Cont | Opinion.               |       |
| surveys for listed and       | ract |                        | 12/04 |
| special-status animal        | or's | Task f: Prepare and    |       |
| species 14-30 days in        | Moni | deliver weekly reports |       |
| advance of ground-disturbing | tors | to Western.            |       |
| activities per Biological    |      |                        |       |
| Opinion and USFWS survey     | A    | Task g: Coordination   |       |
| protocols. This will require | 7400 | with USFWS and CA DFG  |       |
| a rolling schedule to ensure |      | as required.           |       |
| the 14-30-day window is      |      |                        |       |
| maintained.                  |      |                        |       |
+------------------------------+------+------------------------+-------+
| 4\. Conduct ground surveys   | Co   | Task a: Contractor to  | Com   |
| of potential sensitive plant | ntra | conduct field surveys  | plete |
| habitat during the           | ctor | per SOW.               |       |
| appropriate period, prior to |      |                        | Com   |
| selection of final           | Con  | Task b: Field maps     | plete |
| alignments.                  | trac | available.             |       |
|                              | tor/ |                        | Com   |
| Conduct pre-construction     |      | Task c: Contractor     | plete |
| surveys for listed and       | A    | prepares biological    |       |
| special-status animal        | 7400 | report in Biological   | Ro    |
| species 14-30 days in        |      | Assessment format.     | lling |
| advance of ground-disturbing | Co   |                        | sch   |
| activities per Biological    | ntra | Task d: Determine      | edule |
| Opinion and USFWS survey     | ctor | areas of active work   |       |
| protocols. This will require |      | at least 30 days out.  | Ro    |
| a rolling schedule to ensure | Co   |                        | lling |
| the 14-30-day window is      | ntra | Task e: Conduct        | sch   |
| maintained.                  | ctor | surveys in accordance  | edule |
|                              |      | with Biological        |       |
|                              | Cont | Opinion.               | 12/04 |
|                              | ract |                        |       |
|                              | or's | Task f: Prepare and    | 12/04 |
|                              | Moni | deliver weekly reports |       |
|                              | tors | to Western.            |       |
|                              |      |                        |       |
|                              | Cont | Task g: Coordination   |       |
|                              | ract | with USFWS and CA DFG  |       |
|                              | or's | as required.           |       |
|                              | Moni |                        |       |
|                              | tors |                        |       |
|                              |      |                        |       |
|                              | A    |                        |       |
|                              | 7400 |                        |       |
+------------------------------+------+------------------------+-------+
| 5\. Detailed mitigation      | A    | Task a: Prepare and    | Com   |
| plans would be developed     | 7400 | finalize Mitigation    | plete |
| that define the extent and   |      | Action Plan.           |       |
| types of additional field    | Con  |                        | Com   |
| studies, and how the results | trac | Task b: Complete       | plete |
| of these studies could be    | tor/ | cultural resources and |       |
| coordinated with detailed    |      | paleontological field  | Com   |
| engineering surveys. As part | A    | surveys.               | plete |
| of the siting process,       | 7400 |                        |       |
| numerous construction and    |      | Task c: Complete       | Com   |
| siting details will be       | A    | Biological Assessment  | plete |
| developed and presented to   | 7400 | and submit to FWS.     |       |
| the regulatory agencies for  |      |                        | Com   |
| review and comment. Where    | Con  | Task d: Conduct spring | plete |
| mitigation measures are      | trac | biological surveys on  |       |
| specified in the plan, field | tor/ | access road locations  | Ro    |
| monitoring schedules and     |      | and centerline         | lling |
| progress reports will be     | A    | relocations.           | sch   |
| prepared and submitted to    | 7400 |                        | edule |
| the agencies. Biologists and |      | Task e: Adjust         |       |
| archaeologists could         | G    | structure and access   | 12/04 |
| accompany crews during the   | 5600 | road locations to      |       |
| site selection and           |      | avoid sensitive        | 12/04 |
| construction phases to       | A74  | resources where        |       |
| ensure sensitive resources   | 00/G | necessary/possible.    | 12/04 |
| are identified and avoided.  | 5600 |                        |       |
| The results of the siting    |      | Task f: Ensure         | 11/   |
| and mitigation efforts for   | G560 | compliance with        | 15/03 |
| the Los Banos-Gates project  | 0/A7 | Biological Opinion     |       |
| would also be presented in a | 400/ | (BO); stake exclusion  | No    |
| report of findings to the    |      | areas in the field.    | com   |
| CPUC and other appropriate   | Co   |                        | ments |
| agencies. \[This measure is  | ntra | Task g: Monitor site   |       |
| written to accommodate a     | ctor | work for compliance    | 12/   |
| joint participation project. |      | with BO.               | 15/03 |
| Western has developed this   | G560 |                        |       |
| Mitigation Action Plan, and  | 0/A7 | Task h: Monitor site   |       |
| has (and will) utilize       | 400/ | work for undiscovered  |       |
| biological and cultural      |      | cultural resources;    |       |
| resources information in     | Co   | stop work and notify   |       |
| siting structures and        | ntra | if any are found.      |       |
| identifying exclusion areas. | ctor |                        |       |
| Reporting and coordination   |      | Task i: Monitor site   |       |
| appropriate for a Federal    | G560 | work for               |       |
| project will be              | 0/A7 | paleontological        |       |
| accomplished.\]              | 400/ | resources in           |       |
|                              |      | designated areas.      |       |
| Mitigation Action Plan       | Co   |                        |       |
| Revision 2                   | ntra | Task j: Revise MAP     |       |
|                              | ctor | with new provisions    |       |
|                              |      | from BO, etc. and      |       |
|                              | A    | correct/update target  |       |
|                              | 7400 | completion dates.      |       |
|                              |      |                        |       |
|                              | A    | Task k: Obtain FWS     |       |
|                              | 7400 | review and approval of |       |
|                              | /FWS | revised MAP.           |       |
|                              |      |                        |       |
|                              | A7   | Task l: Finalize and   |       |
|                              | 400/ | approve MAP; make      |       |
|                              |      | available to agencies  |       |
|                              | N    | and the public.        |       |
|                              | 6220 |                        |       |
+------------------------------+------+------------------------+-------+
| 6\. Technical specialists,   | Con  | Task a: Determine      | Com   |
| including biologists, will   | trac | site-specific          | plete |
| survey the preliminary       | tor/ | sensitive areas in the |       |
| alignment in the field to    |      | field.                 | Ro    |
| determine any site-specific  | A    |                        | lling |
| conditions that can be       | 7400 | Task b: Ensure         | Sch   |
| avoided. For biological      |      | compliance with BO;    | edule |
| resources, these will        | G56  | stake exclusion areas  |       |
| include San Joaquin kit fox  | 00/A | in the field.          | 12/04 |
| burrows and denning areas,   | 7400 |                        |       |
| areas where blunt-nosed      |      | Task c: Monitor site   | Ro    |
| leopard lizard occur, giant  | G560 | work for compliance    | lling |
| kangaroo rat burrows, raptor | 0/A7 | with BO.               | sch   |
| nesting areas, and           | 400/ |                        | edule |
| productive wetlands areas.   |      | Task d: Determine      |       |
| \[All applicable conditions  | Co   | areas of active work   | Ro    |
| in the Biological Assessment | ntra | at least 30 days out.  | lling |
| and Biological Opinion will  | ctor |                        | sch   |
| be adhered to in meeting     |      | Task e: Conduct        | edule |
| this mitigation measure.\]   | Co   | surveys in accordance  |       |
|                              | ntra | with Biological        | 12/04 |
| Conduct pre-construction     | ctor | Opinion.               |       |
| surveys for listed and       |      |                        | 12/04 |
| special-status animal        | Cont | Task f: Prepare and    |       |
| species 14-30 days in        | ract | deliver weekly reports |       |
| advance of ground-disturbing | or's | to Western.            |       |
| activities per Biological    | Moni |                        |       |
| Opinion and USFWS survey     | tors | Task g: Coordination   |       |
| protocols. This will require |      | with USFWS and CA DFG  |       |
| a rolling schedule to ensure | Cont | as required.           |       |
| the 14-30-day window is      | ract |                        |       |
| maintained. Includes field   | or's |                        |       |
| office locations, parking    | Moni |                        |       |
| areas, materials storage and | tors |                        |       |
| prefabrication sites, etc.   |      |                        |       |
| used by the construction     | A    |                        |       |
| contractor.                  | 7400 |                        |       |
+------------------------------+------+------------------------+-------+
| 7\. PG&E will continue to    | N1   | Task a**:** Coordinate | 12/04 |
| consult with Merced and      | 600/ | with and inform        |       |
| Fresno County officials      |      | counties of plans and  |       |
| during the siting process.   | Co   | crossings, as needed.  |       |
| County personnel will be     | ntra |                        |       |
| able to review the proposed  | ctor |                        |       |
| actions and submit their     |      |                        |       |
| recommendations to the CPUC. |      |                        |       |
| \[Western and/or the         |      |                        |       |
| construction contractor will |      |                        |       |
| continue to coordinate with  |      |                        |       |
| appropriate county officials |      |                        |       |
| until the project is         |      |                        |       |
| completed; reporting to CPUC |      |                        |       |
| will not be required.\]      |      |                        |       |
+------------------------------+------+------------------------+-------+
| 8\. Locate new access roads  | G    | Task a: Design access  | Com   |
| parallel to contours of      | 5600 | roads to follow        | plete |
| landform wherever feasible.  |      | landforms and minimize |       |
|                              |      | erosion potential.     |       |
+------------------------------+------+------------------------+-------+
| 9\. Avoid diagonal           | G    | Task a: Where          | Com   |
| orientations of transmission | 5600 | possible, site the     | plete |
| lines across cultivated      |      | transmission line to   |       |
| fields.                      | G56  | avoid agricultural     | Com   |
|                              | 00/N | areas entirely.        | plete |
|                              | 1600 |                        |       |
|                              |      | Task b: Where          |       |
|                              |      | avoidance is not       |       |
|                              |      | feasible, site         |       |
|                              |      | structures to minimize |       |
|                              |      | impact to agricultural |       |
|                              |      | activities. Landowner  |       |
|                              |      | coordination may be    |       |
|                              |      | necessary.             |       |
+------------------------------+------+------------------------+-------+
| 10\. If practical, tower     | G    | Task a: Where          | Com   |
| placement will be adjusted   | 5600 | possible, site the     | plete |
| to avoid orchards and        |      | transmission line to   |       |
| vineyards, row crops, and    | G56  | avoid agricultural     | Com   |
| furrow-irrigated crops (with | 00/N | areas entirely.        | plete |
| tower-furrow angles greater  | 1600 |                        |       |
| than 61%). When possible,    |      | Task b: Where          |       |
| the alignment should avoid   |      | avoidance is not       |       |
| more heavily cultivated      |      | feasible, site         |       |
| crops in preference for      |      | structures to minimize |       |
| nonagricultural land or      |      | impact to agricultural |       |
| crops such as alfalfa, corn, |      | activities. Landowner  |       |
| and small grains.            |      | coordination may be    |       |
|                              |      | necessary. In certain  |       |
|                              |      | areas, use a           |       |
|                              |      | single-pole design to  |       |
|                              |      | minimize impacts.      |       |
+------------------------------+------+------------------------+-------+
| 11\. When locating towers in | G    | Task a: Where          | Com   |
| row crops is unavoidable, if | 5600 | possible, site the     | plete |
| possible, preference should  |      | transmission line to   |       |
| be given to fields with rows | G56  | avoid agricultural     | Com   |
| that would be parallel,      | 00/N | areas entirely.        | plete |
| rather than perpendicular,   | 1600 |                        |       |
| to the transmission line.    |      | Task b: Where          |       |
|                              |      | avoidance is not       |       |
|                              |      | feasible, site         |       |
|                              |      | structures to minimize |       |
|                              |      | impact to agricultural |       |
|                              |      | activities. Landowner  |       |
|                              |      | coordination may be    |       |
|                              |      | necessary. In certain  |       |
|                              |      | areas, use a           |       |
|                              |      | single-pole design to  |       |
|                              |      | minimize impacts.      |       |
+------------------------------+------+------------------------+-------+
| 12\. Place transmission      | G    | Task a: Where          | Com   |
| lines and towers toward the  | 5600 | possible, site the     | plete |
| center of the field where    |      | transmission line to   |       |
| possible. Avoid placing      | G56  | avoid agricultural     | Com   |
| towers at the edge of fields | 00/N | areas entirely.        | plete |
| where canals or irrigation   | 1600 |                        |       |
| ditches are located.         |      | Task b: Where          |       |
|                              |      | avoidance is not       |       |
|                              |      | feasible, site         |       |
|                              |      | structures to minimize |       |
|                              |      | impact to agricultural |       |
|                              |      | activities. Landowner  |       |
|                              |      | coordination may be    |       |
|                              |      | necessary. In certain  |       |
|                              |      | areas, use a           |       |
|                              |      | single-pole design to  |       |
|                              |      | minimize impacts.      |       |
+------------------------------+------+------------------------+-------+
| 13\. Avoid angular joining   | G    | Task a**:** Consider   | Com   |
| of transmission line         | 5600 | when defining          | plete |
| alignments.                  |      | transmission line      |       |
|                              |      | centerline.            |       |
+------------------------------+------+------------------------+-------+
| 14\. Avoid mechanical move   | G    | Task a: Where          | Com   |
| irrigation systems. Select   | 5600 | possible, site the     | plete |
| crops using flood or border  |      | transmission line to   |       |
| check irrigation over those  | G56  | avoid agricultural     | Com   |
| using furrow irrigation.     | 00/N | areas, and especially  | plete |
|                              | 1600 | irrigated areas,       |       |
|                              |      | entirely.              |       |
|                              |      |                        |       |
|                              |      | Task b: Where          |       |
|                              |      | avoidance is not       |       |
|                              |      | feasible, site         |       |
|                              |      | structures to minimize |       |
|                              |      | impact to agricultural |       |
|                              |      | activities. Landowner  |       |
|                              |      | coordination may be    |       |
|                              |      | necessary.             |       |
+------------------------------+------+------------------------+-------+
| 15\. Tower placement should  | A74  | Task a: Evaluate       | Com   |
| avoid areas where riparian   | 00/G | riparian and other     | plete |
| vegetation or other          | 5600 | special vegetation     |       |
| vegetation communities of    |      | communities. Site      | 12/04 |
| value occur.                 | A740 | transmission line to   |       |
|                              | 0/G5 | avoid if possible;     |       |
|                              | 600/ | identify crossing      |       |
|                              |      | location(s) of least   |       |
|                              | Co   | impact if not          |       |
|                              | ntra | possible.              |       |
|                              | ctor |                        |       |
|                              |      | Task b: Monitor        |       |
|                              |      | construction           |       |
|                              |      | activities.            |       |
+------------------------------+------+------------------------+-------+
| 16\. Avoid siting towers on  | A74  | Task a: Incorporate    | Com   |
| ridgelines and hilltops      | 00/G | visual sensitivity     | plete |
| wherever possible. This      | 5600 | into transmission line |       |
| measure will serve to reduce |      | siting                 |       |
| the incidence of             |      | co                     |       |
| \"skylining;\" that is,      |      | nsiderations/criteria. |       |
| positioning a tower so that  |      |                        |       |
| it is seen silhouetted       |      |                        |       |
| against the skyline. The     |      |                        |       |
| measure will also help       |      |                        |       |
| prevent highly visible       |      |                        |       |
| alterations of land forms    |      |                        |       |
| resulting from grading       |      |                        |       |
| operations. \[The terrain in |      |                        |       |
| the Project area will        |      |                        |       |
| necessitate placing          |      |                        |       |
| structures on high points.   |      |                        |       |
| However, there will be two   |      |                        |       |
| existing transmission lines  |      |                        |       |
| in the foreground, and       |      |                        |       |
| higher ridges behind the new |      |                        |       |
| line, so visual impacts will |      |                        |       |
| be slight.\]                 |      |                        |       |
+------------------------------+------+------------------------+-------+
| 17\. Minimize the number of  | A74  | Task a: Incorporate    | Com   |
| towers visible from          | 00/G | visual sensitivity     | plete |
| sensitive viewpoints within  | 5600 | into transmission line |       |
| recreation areas.            |      | siting                 |       |
|                              |      | co                     |       |
|                              |      | nsiderations/criteria. |       |
+------------------------------+------+------------------------+-------+
| 18\. In areas identified as  | A    | Task a: Incorporate    | Com   |
| visually sensitive, the      | 7900 | requirement into       | plete |
| finish on transmission       |      | construction           |       |
| towers should be dull and    |      | specification --       |       |
| non-reflective.              |      | Divisions 4 and 5.     |       |
+------------------------------+------+------------------------+-------+
| 19\. Temporary facilities,   | G    | Task a**:**            | Com   |
| such as construction yards,  | 5600 | Incorporate            | plete |
| and conductor tensioning and |      | requirement into       |       |
| splicing sites should be     | G    | construction           | Com   |
| sited to minimize disruption | 5600 | specification.         | plete |
| of the landscape by landform |      |                        |       |
| alteration and vegetation    | A740 | Task b**:** Advise     | 12/04 |
| removal.                     | 0/G5 | construction           |       |
|                              | 600/ | contractor.            |       |
|                              |      |                        |       |
|                              | Co   | Task c**:** Monitor    |       |
|                              | ntra | site work.             |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 20\. PG&E will work with     | N16  | Task a: Work with      | Com   |
| affected property owners, as | 00/G | landowners on final    | plete |
| necessary, on alignment and  | 5600 | siting of structures   |       |
| tower location during the    |      | and access roads, if   |       |
| right-of-way acquisition     |      | necessary.             |       |
| process. \[Western will work |      |                        |       |
| with property owners on      |      |                        |       |
| alignment and structure      |      |                        |       |
| locations, as necessary.\]   |      |                        |       |
+------------------------------+------+------------------------+-------+
| 21\. Appropriate selection   | A    | Task a: Incorporate    | Com   |
| of design parameters (i.e,   | 7900 | into design.           | plete |
| conductor surface gradient,  |      |                        |       |
| conductor diameter, and      | N16  | Task b: Respond        | Open  |
| conductor configuration) and | 00/N | promptly to any        |       |
| proper location of the       | 5500 | complaints.            | Open  |
| transmission line route to   |      |                        |       |
| avoid critical locations     | N    | Task c: Complete       |       |
| will reduce corona-induced   | 5500 | modifications to       |       |
| radio and television         |      | mitigate problem.      |       |
| interference to acceptable   |      |                        |       |
| levels.                      |      |                        |       |
+------------------------------+------+------------------------+-------+
| 22\. Conduct                 | Con  | Task a**:** Conduct    | Com   |
| pre-construction field       | trac | intensive field        | plete |
| surveys to locate and record | tor/ | surveys.               |       |
| cultural and paleontological |      |                        | Com   |
| resources within the project | A    | Task b**:** Conduct    | plete |
| right-of-way and, in         | 7400 | ethnographic study.    |       |
| particular, resources that   |      |                        | 12/04 |
| are situated at proposed     | Con  | Task c**:** Consult    |       |
| facilities and roadway       | trac | with tribes.           | Com   |
| locations. \[Includes all    | tor/ |                        | plete |
| field office locations,      |      | Task d**:** Consult    |       |
| parking areas, materials     | A    | with the State         | Com   |
| storage and prefabrication   | 7400 | Historic Preservation  | plete |
| sites, etc. used by the      |      | Officer (SHPO).        |       |
| construction contractor.     | A    |                        | Com   |
| Also address traditional     | 7400 | Task e: Prepare and    | plete |
| cultural properties and      |      | execute a Programmatic |       |
| Native American use areas,   | A    | Agreement governing    | 12/04 |
| as identified by the         | 7400 | cultural resources     |       |
| ethnographic study.\]        |      | activities.            | Com   |
|                              | A    |                        | plete |
| Conduct paleontological      | 7400 | Task f**:** Determine  |       |
| survey for fossil resources. |      | project modifications  | 12/04 |
|                              | A74  | to avoid/minimize      |       |
|                              | 00/G | impact.                |       |
|                              | 5600 |                        |       |
|                              |      | Task g**:**            |       |
|                              | A740 | Construction           |       |
|                              | 0/G5 | monitoring.            |       |
|                              | 600/ |                        |       |
|                              |      | Task h: Field surveys  |       |
|                              | Co   | for paleo resources.   |       |
|                              | ntra |                        |       |
|                              | ctor | Task i: Field          |       |
|                              |      | monitoring in          |       |
|                              | Con  | sensitive areas.       |       |
|                              | trac |                        |       |
|                              | tor/ |                        |       |
|                              |      |                        |       |
|                              | A    |                        |       |
|                              | 7400 |                        |       |
|                              |      |                        |       |
|                              | Co   |                        |       |
|                              | ntra |                        |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 23\. Avoid sensitive         | Con  | Task a**:** Conduct    | Com   |
| resources by locating        | trac | intensive field        | plete |
| construction activities in   | tor/ | surveys.               |       |
| non-sensitive locations.     |      |                        | Com   |
| Consultation with cultural   | A    | Task b**:** Conduct    | plete |
| and paleontological resource | 7400 | ethnographic study.    |       |
| professionals during the     |      |                        | Com   |
| siting of the transmission   | Con  | Task c**:** Consult    | plete |
| line will facilitate         | trac | with tribes.           |       |
| mitigation through           | tor/ |                        | Com   |
| avoidance.                   |      | Task d**:** Consult    | plete |
|                              | A    | with SHPO.             |       |
|                              | 7400 |                        | Com   |
|                              |      | Task e**:** Determine  | plete |
|                              | A    | project modifications  |       |
|                              | 7400 | to avoid/minimize      | 12/04 |
|                              |      | impact.                |       |
|                              | A    |                        |       |
|                              | 7400 | Task f**:**            |       |
|                              |      | Construction           |       |
|                              | A74  | monitoring.            |       |
|                              | 00/G |                        |       |
|                              | 5600 |                        |       |
|                              |      |                        |       |
|                              | A740 |                        |       |
|                              | 0/G5 |                        |       |
|                              | 600/ |                        |       |
|                              |      |                        |       |
|                              | Co   |                        |       |
|                              | ntra |                        |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 24\. Conduct cultural        | Con  | Task a**:** Conduct    | Com   |
| resource data recovery       | trac | intensive field        | plete |
| programs, through surface    | tor/ | surveys.               |       |
| collection and excavation,   |      |                        | Com   |
| at significant resource      | A    | Task b**:** Conduct    | plete |
| sites where adverse impacts  | 7400 | ethnographic study.    |       |
| cannot be otherwise          |      |                        | Com   |
| mitigated. \[No eligible     | Con  | Task c**:** Consult    | plete |
| sites were recorded during   | trac | with tribes.           |       |
| the Class III survey of the  | tor/ |                        | Com   |
| right-of-way and access road |      | Task d**:** Consult    | plete |
| easements. Construction      | A    | with SHPO.             |       |
| monitoring not necessary     | 7400 |                        | Com   |
| unless cultural resources    |      | Task e**:** Determine  | plete |
| are discovered during        | A    | project modifications  |       |
| construction. Native         | 7400 | to avoid/minimize      | 12/04 |
| American monitoring of       |      | impact.                |       |
| certain locations important  | A    |                        |       |
| to affected tribes will be   | 7400 | Task f**:**            |       |
| monitored by a Native        |      | Construction           |       |
| American monitor.\]          | A74  | monitoring.            |       |
|                              | 00/G |                        |       |
| Monitoring of selected sites | 5600 |                        |       |
| by Native American monitor.  |      |                        |       |
|                              | A740 |                        |       |
|                              | 0/G5 |                        |       |
|                              | 600/ |                        |       |
|                              |      |                        |       |
|                              | Co   |                        |       |
|                              | ntra |                        |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 25\. Consult with Native     | Con  | Task a**:** Conduct    | Com   |
| Americans concerning Native  | trac | intensive field        | plete |
| American resources that      | tor/ | surveys.               |       |
| cannot be mitigated through  |      |                        | Com   |
| avoidance, in order to seek  | A    | Task b**:** Conduct    | plete |
| mutually acceptable          | 7400 | ethnographic study.    |       |
| solutions to minimize        |      |                        | Com   |
| project effects on           | Con  | Task c**:** Consult    | plete |
| significant resources.       | trac | with tribes.           |       |
|                              | tor/ |                        | Com   |
| Monitoring of selected sites |      | Task e**:** Determine  | plete |
| by Native American monitor.  | A    | project modifications  |       |
|                              | 7400 | to avoid/minimize      | 12/04 |
|                              |      | impact.                |       |
|                              | A    |                        |       |
|                              | 7400 | Task f**:**            |       |
|                              |      | Construction           |       |
|                              | A74  | monitoring.            |       |
|                              | 00/G |                        |       |
|                              | 5600 |                        |       |
|                              |      |                        |       |
|                              | A740 |                        |       |
|                              | 0/G5 |                        |       |
|                              | 600/ |                        |       |
|                              |      |                        |       |
|                              | Co   |                        |       |
|                              | ntra |                        |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 26\. Comply with all terms   | A    | Task a: Incorporate    | Com   |
| and conditions of the        | 7400 | requirement into       | plete |
| Section 401 Water Quality    |      | construction           |       |
| Certification and Section    | G    | specification --       | Com   |
| 404 Clean Water Act permits  | 5600 | Division 2a or 13.     | plete |
| as they apply to crossings   |      |                        |       |
| of Waters of the United      | G560 | Task b: Advise         | 12/04 |
| States.                      | 0/A7 | construction           |       |
|                              | 400/ | contractor.            |       |
|                              |      |                        |       |
|                              | Co   | Task c: Monitor site   |       |
|                              | ntra | work.                  |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 27\. Comply with all terms,  | A    | Task a: Incorporate    | Com   |
| conditions, and other        | 7400 | requirement into       | plete |
| requirements contained in    |      | construction           |       |
| the USFWS Biological Opinion | G    | specification --       | Com   |
| (June 10, 2003) for the Path | 5600 | Division 2a or 13.     | plete |
| 15 Project.                  |      |                        |       |
|                              | G560 | Task b: Advise         | 12/04 |
|                              | 0/A7 | construction           |       |
|                              | 400/ | contractor.            |       |
|                              |      |                        |       |
|                              | Co   | Task c: Monitor site   |       |
|                              | ntra | work.                  |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 28\. Coordinate with         | A    | Task a: Provide DFG    | Com   |
| California Department of     | 7400 | with applicable        | plete |
| Fish and Game on State       |      | project documents: BA, |       |
| special-status species.      | A    | BO, special-status     | Open  |
|                              | 7400 | species report, maps,  |       |
|                              |      | etc.                   | 12/04 |
|                              | G560 |                        |       |
|                              | 0/A7 | Task b: Address DFG    |       |
|                              | 400/ | comments/concerns.     |       |
|                              |      |                        |       |
|                              | Co   | Task c: Monitor site   |       |
|                              | ntra | work.                  |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+

#### Table 4.2: Short-term Mitigation Commitments and Action Plan for the Path 15 Transmission Project 

+------------------------------+------+------------------------+-------+
| **Short-term Mitigation      | **R  | **Action**             | **T   |
| Commitment**                 | espo |                        | arget |
|                              | nsib |                        | Compl |
|                              | le** |                        | etion |
|                              |      |                        | D     |
|                              | *    |                        | ate** |
|                              | *Par |                        |       |
|                              | ty** |                        |       |
+==============================+======+========================+=======+
| 1\. Soil surfaces will be    | A    | Task a: Incorporate    | Com   |
| wetted at a rate of 0.5      | 7400 | requirement into       | plete |
| gallons of water per square  |      | construction           |       |
| yard two times per day for   | G    | specification --       | Com   |
| dust control (EPA 1977).     | 5600 | Division 2a or 13.     | plete |
| This measure reduces dust by |      |                        |       |
| about 50 percent. \[Dusting  | G560 | Task b: Advise         | 12/04 |
| of agricultural crops,       | 0/A7 | construction           |       |
| orchards, vineyards,         | 400/ | contractor.            |       |
| grasslands, etc. will not be |      |                        |       |
| allowed. The Contractor      | Co   | Task c: Monitor site   |       |
| shall prevent generating     | ntra | work.                  |       |
| dust by watering, as         | ctor |                        |       |
| necessary, the roads,        |      |                        |       |
| structure sites, staging     |      |                        |       |
| areas, tensioning and        |      |                        |       |
| pulling sites, and any other |      |                        |       |
| construction area having the |      |                        |       |
| potential to generate        |      |                        |       |
| dust.\]                      |      |                        |       |
+------------------------------+------+------------------------+-------+
| 2\. When possible            | A    | Task a: Incorporate    | Com   |
| construction activities      | 7400 | requirement into       | plete |
| should be scheduled during   |      | construction           |       |
| periods of low wind to       | G    | specification --       | Com   |
| reduce fugitive dust         | 5600 | Division 2a or 13.     | plete |
| emissions.                   |      |                        |       |
|                              | G560 | Task b: Advise         | 12/04 |
|                              | 0/A7 | construction           |       |
|                              | 400/ | contractor.            |       |
|                              |      |                        |       |
|                              | Co   | Task c: Monitor site   |       |
|                              | ntra | work.                  |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 3\. All construction         | A    | Task a: Incorporate    | Com   |
| equipment should be          | 7400 | requirement into       | plete |
| frequently monitored and     |      | construction           |       |
| serviced to ensure           | G    | specification --       | Com   |
| conformance with exhaust     | 5600 | Division 2a or 13.     | plete |
| standards.                   |      |                        |       |
|                              | G560 | Task b: Advise         | 12/04 |
|                              | 0/A7 | construction           |       |
|                              | 400/ | contractor.            |       |
|                              |      |                        |       |
|                              | Co   | Task c: Monitor site   |       |
|                              | ntra | work.                  |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 4\. Existing roads will be   | A    | Task a: Incorporate    | Com   |
| used for access wherever     | 7400 | access road design     | plete |
| possible. Minimize number    |      | requirements into      |       |
| and length of new            | G56  | construction           | Com   |
| construction access roads    | 00/A | specification --       | plete |
| particularly in intensively  | 7400 | Division 2a or 13.     |       |
| farmed areas. Use temporary  |      |                        | Com   |
| spur roads to towers and     | G    | Task b: Identify       | plete |
| remove those roads not       | 5600 | existing roads to be   |       |
| required for maintenance.    |      | used, and additional   | 12/04 |
| Access roads should be       | G560 | access needs.          |       |
| designed to the minimum      | 0/A7 |                        |       |
| standard necessary for       | 400/ | Task c: Identify areas |       |
| construction and maintenance |      | where overland travel  |       |
| vehicle access.              | Co   | will suffice, and      |       |
|                              | ntra | where new roads will   |       |
|                              | ctor | be required.           |       |
|                              |      |                        |       |
|                              |      | Task d: Monitor site   |       |
|                              |      | work; restore/re-seed  |       |
|                              |      | where appropriate.     |       |
+------------------------------+------+------------------------+-------+
| 5\. Minimize vegetation      | A    | Task a: Incorporate    | Com   |
| stripping along the          | 7400 | requirement into       | plete |
| alignment.                   |      | construction           |       |
|                              | G560 | specification --       | 12/04 |
|                              | 0/A7 | Division 2a or 13.     |       |
|                              | 400/ |                        |       |
|                              |      | Task b: Monitor site   |       |
|                              | Co   | work; restore/re-seed  |       |
|                              | ntra | where appropriate.     |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 6\. Design drainage control  | A    | Task a**:**            | Com   |
| structures to carry runoff   | 7400 | Incorporate            | plete |
| at appropriate velocities.   |      | requirement into       |       |
| Use properly sized and       | G    | construction           | Com   |
| installed culverts under     | 5600 | specification --       | plete |
| permanent access road fill   |      | Division 2a or 13.     |       |
| sections and discharge       | G5   |                        | 12/04 |
| runoff to natural drainages  | 600/ | Task b: Advise         |       |
| that will not be overloaded. |      | construction           |       |
|                              | Co   | contractor.            |       |
|                              | ntra |                        |       |
|                              | ctor | Task c: Monitor site   |       |
|                              |      | work.                  |       |
+------------------------------+------+------------------------+-------+
| 7\. Minimize steepness and   | A    | Task a**:**            | Com   |
| unobstructed length of fill  | 7400 | Incorporate            | plete |
| slopes. Protect new          |      | requirement into       |       |
| constructed fills from rain  | G    | construction           | Com   |
| splash and surface runoff    | 5600 | specification --       | plete |
| with slope protection, such  |      | Division 2a or 13.     |       |
| as punch straw, tackifier,   | G56  |                        | 12/04 |
| or jute netting.             | 00/N | Task b: Advise         |       |
| \[Hydro-mulch or other more  | 1600 | construction           | 12/04 |
| recent methods for surface   |      | contractor.            |       |
| stabilization may also be    | G560 |                        |       |
| used.\]                      | 0/A7 | Task c: Coordinate     |       |
|                              | 900/ | restoration activities |       |
|                              |      | with landowner.        |       |
|                              | Co   |                        |       |
|                              | ntra | Task d: Monitor site   |       |
|                              | ctor | work.                  |       |
+------------------------------+------+------------------------+-------+
| 8\. Replant temporarily      | A    | Task a**:**            | Com   |
| disturbed areas with a       | 7400 | Incorporate            | plete |
| mixture of perennial         |      | requirement into       |       |
| grasses, forbs, brush,       | G    | construction           | Com   |
| shrubs, and tree species     | 5600 | specification --       | plete |
| that will provide effective  |      | Division 2a or 13.     |       |
| erosion control. Prepare a   | G56  |                        | 12/04 |
| firm, rough seedbed on fill  | 00/N | Task b: Advise         |       |
| or cut slopes and apply      | 1600 | construction           | 12/04 |
| appropriate types and        |      | contractor.            |       |
| amounts of fertilizers and   | G560 |                        |       |
| seed mixtures. Consider      | 0/A7 | Task c: Coordinate     |       |
| reseeding with native plants | 900/ | restoration activities |       |
| only in sensitive areas not  |      | with landowner.        |       |
| subject to grazing.          | Co   |                        |       |
| \[Reseeding mixtures shall   | ntra | Task d: Monitor site   |       |
| be landowner/manager         | ctor | work.                  |       |
| approved; an approved seed   |      |                        |       |
| mixture is provided in the   |      |                        |       |
| specifications package.\]    |      |                        |       |
+------------------------------+------+------------------------+-------+
| 9\. Avoid causative          | A    | Task a**:**            | Com   |
| construction operations      | 7400 | Incorporate            | plete |
| during the wet season. Moist |      | requirement into       |       |
| soil is generally more       | G    | construction           | Com   |
| susceptible to compaction    | 5600 | specification --       | plete |
| than dry soil. Minimize the  |      | Division 2a or 13.     |       |
| use of heavy equipment on    | G560 |                        | 12/04 |
| agricultural land to avoid   | 0/A7 | Task b: Advise         |       |
| soil compaction.             | 900/ | construction           |       |
|                              |      | contractor.            |       |
|                              | Co   |                        |       |
|                              | ntra | Task c: Monitor site   |       |
|                              | ctor | work.                  |       |
+------------------------------+------+------------------------+-------+
| 10\. Perform contour         | A    | Task a**:**            | Com   |
| discharge or ripping         | 7400 | Incorporate            | plete |
| operations at the conclusion |      | requirement into       |       |
| of construction. This would  | G    | construction           | Com   |
| loosen compacted soil and    | 5600 | specification --       | plete |
| develop the seedbed for      |      | Division 2a or 13.     |       |
| re-vegetation.               | G56  |                        | 12/04 |
| \[Agricultural areas only.   | 00/N | Task b: Advise         |       |
| Would increase natural       | 1600 | construction           | 12/04 |
| vegetation damage and        |      | contractor.            |       |
| erosion potential in other   | G560 |                        |       |
| areas.\]                     | 0/A7 | Task c: Coordinate     |       |
|                              | 900/ | restoration activities |       |
|                              |      | with landowner.        |       |
|                              | Co   |                        |       |
|                              | ntra | Task d: Monitor site   |       |
|                              | ctor | work.                  |       |
+------------------------------+------+------------------------+-------+
| 11\. In agricultural areas   | A    | Task a**:**            | Com   |
| where sites would be graded, | 7400 | Incorporate            | plete |
| topsoil should be            |      | requirement into       |       |
| stockpiled. After            | G    | construction           | Com   |
| construction, topsoil should | 5600 | specification --       | plete |
| be replaced and the site     |      | Division 2a or 13.     |       |
| graded to the original       | N    |                        | 12/04 |
| contours. If appropriate,    | 1600 | Task b: Advise         |       |
| the site should be reseeded  |      | construction           | 12/04 |
| in accordance with agency or | G560 | contractor.            |       |
| landowner objectives.        | 0/A7 |                        |       |
| \["Sites" refer to structure | 900/ | Task c: Coordinate     |       |
| locations and access         |      | with landowner.        |       |
| roads.\]                     | Co   |                        |       |
|                              | ntra | Task d: Monitor site   |       |
|                              | ctor | work.                  |       |
+------------------------------+------+------------------------+-------+
| 12\. Add chemical additives  | A    | Task a**:**            | Com   |
| to seedbed during            | 7400 | Incorporate            | plete |
| re-vegetation to counteract  |      | requirement into       |       |
| potential chemical           | G    | construction           | Com   |
| imbalances. \[If specified   | 5600 | specification --       | plete |
| by land management           |      | Division 2a or 13.     |       |
| agencies.\]                  | G560 |                        | 12/04 |
|                              | 0/A7 | Task b: Advise         |       |
|                              | 900/ | construction           |       |
|                              |      | contractor.            |       |
|                              | Co   |                        |       |
|                              | ntra | Task c: Monitor site   |       |
|                              | ctor | work.                  |       |
+------------------------------+------+------------------------+-------+
| 13\. Base the tower design   | A    | Task a**:**            | Com   |
| on geotechnical evaluation   | 7900 | Incorporate            | plete |
| and sound geotechnical       |      | requirement into       |       |
| engineering practice,        | G    | construction           | Com   |
| including analysis for cut   | 5600 | specification --       | plete |
| and fill slopes, compaction  |      | Division 2a.           |       |
| requirements, and surface or | G560 |                        | 12/04 |
| slope drainage. \[As a point | 0/A7 | Task b: Advise         |       |
| of clarification, the        | 900? | construction           |       |
| structure foundations need   |      | contractor.            |       |
| to be based on geotechnical  | Co   |                        |       |
| considerations.\]            | ntra | Task c: Monitor site   |       |
|                              | ctor | work.                  |       |
+------------------------------+------+------------------------+-------+
| 14\. Where possible, avoid   | A    | Task a: Incorporate    | Com   |
| road construction on very    | 7400 | access road design     | plete |
| steep slopes to minimize     |      | requirements into      |       |
| surface erosion and          | G56  | construction           | Com   |
| slumping.                    | 00/A | specification --       | plete |
|                              | 7400 | Division 2a or 13.     |       |
|                              |      |                        | Com   |
|                              | G    | Task b: Identify       | plete |
|                              | 5600 | existing roads to be   |       |
|                              |      | used, and additional   | 12/04 |
|                              | G560 | access needs.          |       |
|                              | 0/A7 |                        |       |
|                              | 400/ | Task c: Identify areas |       |
|                              |      | where overland travel  |       |
|                              | Co   | will suffice, and      |       |
|                              | ntra | where new roads will   |       |
|                              | ctor | be required.           |       |
|                              |      |                        |       |
|                              |      | Task d: Monitor site   |       |
|                              |      | work; restore/re-seed  |       |
|                              |      | where appropriate.     |       |
+------------------------------+------+------------------------+-------+
| 15\. Re-contour, prepare the | A    | Task a: Incorporate    | Com   |
| surface, and seed all roads, | 7400 | access road design     | plete |
| construction sites, and      |      | requirements into      |       |
| other disturbed areas not    | G56  | construction           | Com   |
| required for project         | 00/A | specification --       | plete |
| operation and maintenance.   | 7400 | Division 2a or 13.     |       |
|                              |      |                        | Com   |
|                              | G    | Task b: Identify       | plete |
|                              | 5600 | existing roads to be   |       |
|                              |      | used, and additional   | 12/04 |
|                              | G560 | access needs.          |       |
|                              | 0/A7 |                        |       |
|                              | 400/ | Task c: Identify areas |       |
|                              |      | where overland travel  |       |
|                              | Co   | will suffice, and      |       |
|                              | ntra | where new roads will   |       |
|                              | ctor | be required.           |       |
|                              |      |                        |       |
|                              |      | Task d: Monitor site   |       |
|                              |      | work; restore/re-seed  |       |
|                              |      | where appropriate.     |       |
+------------------------------+------+------------------------+-------+
| 16\. As much as possible,    | Con  | Task a: Determine      | Com   |
| avoid construction           | trac | site-specific          | plete |
| activities and land surface  | tor/ | sensitive areas in the |       |
| disturbance in the immediate |      | field.                 | Ro    |
| vicinity of unique plant     | A    |                        | lling |
| communities and habitat      | 7400 | Task b: Ensure         | sch   |
| features, such as remnant    |      | compliance with        | edule |
| sand dunes, rock outcrops,   | G56  | Biological Opinion;    |       |
| riparian zones, alkali       | 00/A | stake exclusion areas  | 12/04 |
| areas, other wetlands, kit   | 7400 | in the field.          |       |
| fox natal dens, and raptor   |      |                        |       |
| nesting cliffs. These unique | G560 | Task c: Monitor site   |       |
| features will be determined  | 0/A7 | work for compliance    |       |
| in consultation with the     | 400/ | with BO.               |       |
| resource agencies.           |      |                        |       |
|                              | Co   |                        |       |
|                              | ntra |                        |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 17\. Avoid construction      | Con  | Task a: Determine      | Com   |
| activities in watercourses   | trac | site-specific          | plete |
| and wetlands since these     | tor/ | sensitive areas in the |       |
| areas are both infrequent    |      | field.                 | Ro    |
| and sensitive in the         | A    |                        | lling |
| generally arid project area. | 7400 | Task b: Ensure         | sch   |
|                              |      | compliance with        | edule |
|                              | G56  | Biological Opinion;    |       |
|                              | 00/A | stake exclusion areas  | 12/04 |
|                              | 7400 | in the field.          |       |
|                              |      |                        |       |
|                              | G560 | Task c: Monitor site   |       |
|                              | 0/A7 | work for compliance    |       |
|                              | 400/ | with BO.               |       |
|                              |      |                        |       |
|                              | Co   |                        |       |
|                              | ntra |                        |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 18\. Avoid work on unstable  | A    | Task a: Incorporate    | Com   |
| slopes and rock outcrops.    | 7400 | access road design     | plete |
|                              |      | requirements into      |       |
|                              | G56  | construction           | Com   |
|                              | 00/A | specification --       | plete |
|                              | 7400 | Division 2a or 13.     |       |
|                              |      |                        | Com   |
|                              | G    | Task b: Identify       | plete |
|                              | 5600 | existing roads to be   |       |
|                              |      | used, and additional   | 12/04 |
|                              | G560 | access needs.          |       |
|                              | 0/A7 |                        |       |
|                              | 400? | Task c: Identify areas |       |
|                              |      | where overland travel  |       |
|                              | Co   | will suffice, and      |       |
|                              | ntra | where new roads will   |       |
|                              | ctor | be required.           |       |
|                              |      |                        |       |
|                              |      | Task d: Monitor site   |       |
|                              |      | work; restore/re-seed  |       |
|                              |      | where appropriate.     |       |
+------------------------------+------+------------------------+-------+
| 19\. Minimize surface        | A    | Task a**:**            | Com   |
| disturbing activities such   | 7400 | Incorporate            | plete |
| as grubbing, grading,        |      | requirement into       |       |
| ditching and filling to the  | G56  | construction           | Com   |
| extent possible.             | 00/A | specification --       | plete |
|                              | 7400 | Division 2a or 13.     |       |
|                              |      |                        | Com   |
|                              | G    | Task b: Identify areas | plete |
|                              | 5600 | where overland travel  |       |
|                              |      | will suffice, and      | 12/04 |
|                              | G560 | where new roads will   |       |
|                              | 0/A7 | be required.           |       |
|                              | 400/ |                        |       |
|                              |      | Task c: Advise         |       |
|                              | Co   | construction           |       |
|                              | ntra | contractor.            |       |
|                              | ctor |                        |       |
|                              |      | Task d: Monitor site   |       |
|                              |      | work; restore/re-seed  |       |
|                              |      | where appropriate.     |       |
+------------------------------+------+------------------------+-------+
| 20\. Provide fire protection | A    | Task a: Incorporate    | Com   |
| measures and avoid releases  | 7400 | requirement into       | plete |
| of fuels, oils, and other    |      | construction           |       |
| hazardous substances to the  | G    | specification --       | Com   |
| ground and water. \[No       | 5600 | Division 2a or 13.     | plete |
| smoking allowed at any time, |      |                        |       |
| anywhere on the project,     | G560 | Task b: Advise         | 12/04 |
| with the sole exception of   | 0/A7 | construction           |       |
| inside closed vehicles due   | 400/ | contractor.            |       |
| to extreme fire danger.      |      |                        |       |
| Butts shall remain inside    | Co   | Task c: Monitor site   |       |
| the vehicles.\]              | ntra | work.                  |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 21\. Schedule activities to  | Con  | Task d: Conduct spring | Com   |
| minimize construction in the | trac | biological surveys on  | plete |
| specific vicinity of golden  | tor/ | access road locations  |       |
| eagle nests or kit fox natal |      | and centerline         | Com   |
| dens during the periods of   | A    | relocations.           | plete |
| greatest sensitivity, i.e.   | 7400 |                        |       |
| February through the end of  |      | Task e: Adjust         | Ro    |
| the nesting or denning       | G    | structure and access   | lling |
| period.                      | 5600 | road locations to      | sch   |
|                              |      | avoid sensitive        | edule |
|                              | A74  | resources where        |       |
|                              | 00/G | necessary/possible.    | 12/04 |
|                              | 5600 |                        |       |
|                              |      | Task f: Ensure         |       |
|                              | G560 | compliance with        |       |
|                              | 0/A7 | Biological Opinion;    |       |
|                              | 400/ | stake exclusion areas  |       |
|                              |      | in the field.          |       |
|                              | Co   |                        |       |
|                              | ntra | Task g: Monitor site   |       |
|                              | ctor | work for compliance    |       |
|                              |      | with BO.               |       |
+------------------------------+------+------------------------+-------+
| 22\. Attach raptor nesting   | A79  | Task a: Incorporate    | Com   |
| platforms to towers at       | 00/A | requirement into       | plete |
| intervals greater than one   | 7400 | construction           |       |
| mile in raptor use areas.    |      | specification.         | Com   |
| Place these on the towers in | A    |                        | plete |
| positions least likely to    | 7400 | Task b: Determine      |       |
| cause operation and          |      | advisability of        | Com   |
| maintenance problems. The    | G    | installing raptor      | plete |
| number of nesting platforms  | 5600 | perching/nesting       |       |
| would be determined during   |      | platforms.             | 12/04 |
| the transmission line        | G560 |                        |       |
| alignment analysis. \[In     | 0/A7 | Task c: Advise         |       |
| order to minimize impact on  | 400/ | construction           |       |
| kit foxes and other listed   |      | contractor.            |       |
| species, raptor nesting      | Co   |                        |       |
| platforms will not be        | ntra | Task d: Monitor site   |       |
| installed in certain areas   | ctor | work.                  |       |
| along the line. Use single   |      |                        |       |
| pole steel structures with   |      |                        |       |
| anti-perching devices in     |      |                        |       |
| some areas to minimize       |      |                        |       |
| raptor advantages.           |      |                        |       |
| Desirability of raptor       |      |                        |       |
| perching/nesting platforms   |      |                        |       |
| will be determined in        |      |                        |       |
| coordination with            |      |                        |       |
| appropriate agencies and/or  |      |                        |       |
| landowners, but              |      |                        |       |
| perching/nesting platforms   |      |                        |       |
| will not be placed in        |      |                        |       |
| agricultural areas.\]        |      |                        |       |
+------------------------------+------+------------------------+-------+
| 23\. Construction of staging | A    | Task a: Incorporate    | Com   |
| areas and pulling sites      | 7400 | requirement into       | plete |
| should be located adjacent   |      | construction           |       |
| to roads where practical.    | G    | specification --       | Com   |
| Soil from construction       | 5600 | Division 2a or 13.     | plete |
| activities should be         |      |                        |       |
| properly disposed of.        | G560 | Task b: Advise         | 12/04 |
|                              | 0/A7 | construction           |       |
|                              | 400/ | contractor.            |       |
|                              |      |                        |       |
|                              | Co   | Task c: Monitor site   |       |
|                              | ntra | work.                  |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 24\. Construction should be  | A7   | Task a: Incorporate    | Com   |
| timed whenever practical to  | 900A | requirement into       | plete |
| minimize disruption of       | 7400 | construction           |       |
| normal seasonal activities   |      | specification --       | Com   |
| for both crop and range      | G    | Division 2a or 13.     | plete |
| land.                        | 5600 |                        |       |
|                              |      | Task b: Advise         | 12/04 |
|                              | G560 | construction           |       |
|                              | 0/A7 | contractor.            |       |
|                              | 400/ |                        |       |
|                              |      | Task c: Monitor site   |       |
|                              | Co   | work.                  |       |
|                              | ntra |                        |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 25\. Post-construction       | A    | Task a: Incorporate    | Com   |
| cleanup and removal          | 7400 | requirement into       | plete |
| practices detailed in        |      | construction           |       |
| Section 2.3.8 should be      | G    | specification --       | Com   |
| followed. \[Access roads and | 5600 | Division 2a or 13.     | plete |
| crane pads may be re-seeded, |      |                        |       |
| but kept for maintenance     | G560 | Task b: Advise         | 12/04 |
| use.\]                       | 0/A7 | construction           |       |
|                              | 400/ | contractor.            |       |
|                              |      |                        |       |
|                              | Co   | Task c: Monitor site   |       |
|                              | ntra | work.                  |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 26\. Whenever possible shift | A    | Task a: Incorporate    | Com   |
| construction areas (such as  | 7400 | requirement into       | plete |
| conductor pulling and        |      | construction           |       |
| splicing areas and           | G    | specification --       | Com   |
| construction yards) to       | 5600 | Division 2a or 13.     | plete |
| nonagricultural land or less |      |                        |       |
| sensitive crops.             | G560 | Task b: Advise         | 12/04 |
|                              | 0/A7 | construction           |       |
|                              | 400/ | contractor.            |       |
|                              |      |                        |       |
|                              | Co   | Task c: Monitor site   |       |
|                              | ntra | work.                  |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 27\. Existing roads damaged  | A    | Task a: Incorporate    | Com   |
| by activities related to the | 7400 | requirement into       | plete |
| transmission line should be  |      | construction           |       |
| repaired to a condition      | G    | specification --       | Com   |
| equal to or better than      | 5600 | Division 2a or 13.     | plete |
| their condition prior to the |      |                        |       |
| construction of the          | G560 | Task b: Advise         | 12/04 |
| transmission line.           | 0/A7 | construction           |       |
|                              | 400/ | contractor.            |       |
|                              |      |                        |       |
|                              | Co   | Task c: Monitor site   |       |
|                              | ntra | work.                  |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 28\. The limits of           | A    | Task a: Incorporate    | Com   |
| construction activities      | 7400 | requirement into       | plete |
| should normally be           |      | construction           |       |
| predetermined, with activity | G    | specification --       | Com   |
| confined within those        | 5600 | Division 2a or 13.     | plete |
| limits. All construction     |      |                        |       |
| vehicle movement outside the | G560 | Task b: Advise         | 12/04 |
| right-of-way should normally | 0/A7 | construction           |       |
| be restricted to             | 400/ | contractor.            |       |
| pre-designated access or     |      |                        |       |
| public roads.                | Co   | Task c: Monitor site   |       |
|                              | ntra | work.                  |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 29\. No paint or permanent   | A    | Task a: Incorporate    | Com   |
| discoloring agents should be | 7900 | requirement into       | plete |
| applied -to rocks or         |      | construction           |       |
| vegetation to indicate       | G    | specification.         | Com   |
| survey or construction       | 5600 |                        | plete |
| activity limits. Survey      |      | Task b: Advise         |       |
| markers, flagging, or other  | G560 | construction           | 12/04 |
| suitable material should be  | 0/A7 | contractor.            |       |
| used to delineate limits.    | 400/ |                        |       |
|                              |      | Task c: Monitor site   |       |
|                              | Co   | work.                  |       |
|                              | ntra |                        |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 30\. Where blasting is       | A    | Task a: Incorporate    | Com   |
| required for access roads or | 7400 | requirement into       | plete |
| tower footings, debris       |      | construction           |       |
| should be recovered and      | G    | specification --       | Com   |
| removed where practical.     | 5600 | Division 2a or 13.     | plete |
|                              |      |                        |       |
|                              | G560 | Task b: Advise         | 12/04 |
|                              | 0/A7 | construction           |       |
|                              | 400/ | contractor.            |       |
|                              |      |                        |       |
|                              | Co   | Task c: Monitor site   |       |
|                              | ntra | work.                  |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 31\. Excavated material or   | A    | Task a: Incorporate    | Com   |
| other construction materials | 7400 | requirement into       | plete |
| should be removed following  |      | construction           |       |
| construction. \[Will be done | G    | specification --       | Com   |
| in agricultural areas. In    | 5600 | Division 2a or 13.     | plete |
| grassland areas excavated    |      |                        |       |
| materials will be spread     | G560 | Task b: Advise         | 12/04 |
| around the structure base or | 0/A7 | construction           |       |
| used to level access road    | 400/ | contractor.            |       |
| and or crane pad at the      |      |                        |       |
| excavation site.\]           | Co   | Task c: Monitor site   |       |
|                              | ntra | work.                  |       |
|                              | ctor |                        |       |
+------------------------------+------+------------------------+-------+
| 32\. In construction areas   | A    | Task a**:**            | Com   |
| where excavation is not      | 7400 | Incorporate            | plete |
| required, vegetation should  |      | requirement into       |       |
| be left in place wherever    | G56  | construction           | Com   |
| possible and the original    | 00/A | specification --       | plete |
| contours should be           | 7400 | Division 2a or 13.     |       |
| maintained in an undisturbed |      |                        | Com   |
| condition.                   | G    | Task b: Identify areas | plete |
|                              | 5600 | where overland travel  |       |
|                              |      | will suffice, and      | 12/04 |
|                              | G560 | where new roads will   |       |
|                              | 0/A7 | be required.           |       |
|                              | 400/ |                        |       |
|                              |      | Task c: Advise         |       |
|                              | Co   | construction           |       |
|                              | ntra | contractor.            |       |
|                              | ctor |                        |       |
|                              |      | Task d: Monitor site   |       |
|                              |      | work; restore/re-seed  |       |
|                              |      | where appropriate.     |       |
+------------------------------+------+------------------------+-------+
| 33\. Where vegetation of     | A    | Task a: Incorporate    | Com   |
| high density or low          | 7400 | requirement into       | plete |
| diversity is encountered in  |      | construction           |       |
| the right-of-way, clearing   | G    | specification --       | Com   |
| to a harsh right-of-way edge | 5600 | Division 2a or 13.     | plete |
| should be avoided. Instead,  |      |                        |       |
| it should be done to emulate | G560 | Task b: Advise         | 12/04 |
| natural clearings with       | 0/A7 | construction           |       |
| irregular edges. \[Since the | 400/ | contractor.            |       |
| right-of-way is either       |      |                        |       |
| grassland or intensive       | Co   | Task c: Monitor site   |       |
| agriculture, this provision  | ntra | work.                  |       |
| will likely not be           | ctor |                        |       |
| employed.\]                  |      |                        |       |
+------------------------------+------+------------------------+-------+
| 34\. PG&E will provide clear | N    | Task a: Coordinate     | Open  |
| information about            | 1600 | with landowners.       |       |
| right-of-way acquisition,    |      |                        |       |
| construction and maintenance |      |                        |       |
| activities, and project      |      |                        |       |
| schedules. \[Western will    |      |                        |       |
| perform these tasks.\]       |      |                        |       |
+------------------------------+------+------------------------+-------+

#### Table 4.3: Long-term Mitigation Commitments and Action Plan for the Path 15 Transmission Project

+------------------------------+------+------------------------+-------+
| ##### Long                   | **R  | ### Action             | **T   |
| -term Mitigation Commitment  | espo |                        | arget |
|                              | nsib |                        | Compl |
|                              | le** |                        | etion |
|                              |      |                        | D     |
|                              | *    |                        | ate** |
|                              | *Par |                        |       |
|                              | ty** |                        |       |
+------------------------------+------+------------------------+-------+
| 1\. Avoid permanent access   | A    | Task a: Incorporate    | Com   |
| road clearing to the extent  | 7400 | access road design     | plete |
| possible, allowing the short |      | requirements into      |       |
| annual grasses to cover the  | G56  | construction           | Com   |
| ground surface.              | 00/A | specification --       | plete |
|                              | 7400 | Division 2a or 13.     |       |
|                              |      |                        | Com   |
|                              | G    | Task b: Identify       | plete |
|                              | 5600 | existing roads to be   |       |
|                              |      | used, and additional   | 12/04 |
|                              | G560 | access needs.          |       |
|                              | 0/A7 |                        |       |
|                              | 400/ | Task c: Identify areas |       |
|                              |      | where overland travel  |       |
|                              | Co   | will suffice, and      |       |
|                              | ntra | where new roads will   |       |
|                              | ctor | be required.           |       |
|                              |      |                        |       |
|                              |      | Task d: Monitor site   |       |
|                              |      | work; restore/re-seed  |       |
|                              |      | where appropriate.     |       |
+------------------------------+------+------------------------+-------+
| 2\. All access roads not     | A    | Task a: Incorporate    | Com   |
| required for maintenance     | 7400 | access road design     | plete |
| should be either permanently |      | requirements into      |       |
| closed using the most        | G56  | construction           | Com   |
| effective and least          | 00/A | specification --       | plete |
| environmentally damaging     | 7400 | Division 2a or 13.     |       |
| methods appropriate to the   |      |                        | Com   |
| landowners, or be re-graded, | G    | Task b: Identify       | plete |
| put to bed, and re-vegetated | 5600 | existing roads to be   |       |
| with concurrence of          |      | used, and additional   | 12/04 |
| landowner.                   | G560 | access needs.          | /     |
|                              | 0/A7 |                        | Open  |
|                              | 400/ | Task c: Identify areas |       |
|                              |      | where overland travel  |       |
|                              | Co   | will suffice, and      |       |
|                              | ntra | where new roads will   |       |
|                              | ctor | be required.           |       |
|                              |      |                        |       |
|                              |      | Task d: Monitor site   |       |
|                              |      | work; restore/re-seed  |       |
|                              |      | where appropriate.     |       |
+------------------------------+------+------------------------+-------+
| 3\. An ambient noise survey  | N16  | Task a: Identify       | Open  |
| will be conducted at         | 00/N | locations where        |       |
| selected, sensitive sites    | 5000 | ambient noise could    | Open  |
| along the route prior to     |      | potentially be a       |       |
| construction and operation   | N16  | problem.               | As    |
| of the line. These           | 00/N |                        | ne    |
| measurements will then be    | 5000 | Task b: Take field     | eded. |
| available if complaints are  |      | readings.              |       |
| received after the line is   | N16  |                        | As    |
| placed in operation. \[Due   | 00/N | Task c: Respond to     | ne    |
| to the remote location of    | 5300 | post-construction      | eded. |
| the proposed transmission    |      | noise complaints.      |       |
| line route the need for this | N    |                        |       |
| survey will be minimal.\]    | 5300 | Task d: Replace        |       |
|                              |      | damaged insulators or  |       |
|                              |      | conductor if found to  |       |
|                              |      | be the cause.          |       |
+------------------------------+------+------------------------+-------+
| 4\. PG&E will resolve AM     | N16  | Task a: Respond to     | As    |
| radio and television         | 00/N | post-construction      | ne    |
| interference complaints and  | 5300 | noise complaints.      | eded. |
| make every reasonable effort |      |                        |       |
| to promptly correct the      | N    | Task b: Replace        | As    |
| cause of the interference    | 5300 | damaged insulators or  | ne    |
| when it has been established |      | conductor if found to  | eded. |
| that this interference is    |      | be the cause.          |       |
| from PG&E facilities.        |      |                        |       |
| \[Western will conduct this  |      |                        |       |
| activity, unless the problem |      |                        |       |
| is PG&E substation           |      |                        |       |
| equipment.\]                 |      |                        |       |
+------------------------------+------+------------------------+-------+
| 5\. To provide a basis for   | N    | Task a: Identify       | Open  |
| evaluating and correcting    | 1600 | locations where        |       |
| any adverse effects caused   |      | transmission line      | Open  |
| by the transmission line,    | N16  | interference could     |       |
| radio and TV field strength  | 00/N | potentially be a       | As    |
| measurements will be made    | 5000 | problem.               | ne    |
| after the selection of the   |      |                        | eded. |
| final transmission line      | N16  | Task b: Take field     |       |
| alignment, prior to          | 00/N | readings.              | As    |
| construction and operation   | 5300 |                        | ne    |
| of the transmission line. If |      | Task c: Respond to     | eded. |
| complaints are received      | N    | post-construction      |       |
| after operation of the line, | 5300 | interference           |       |
| PG&E will be able to take    |      | complaints.            |       |
| corrective measures to       |      |                        |       |
| provide satisfactory         |      | Task d: Replace        |       |
| service. \[Due to the remote |      | damaged insulators or  |       |
| location of the proposed     |      | conductor if found to  |       |
| transmission line route the  |      | be the cause.          |       |
| need for this survey will be |      |                        |       |
| minimal. Western will        |      |                        |       |
| address any interference     |      |                        |       |
| issues as they may arise.\]  |      |                        |       |
+------------------------------+------+------------------------+-------+

**Note:** All dates are keyed to the September 29, 2003 Project
Schedule, and are subject to change as the Project Schedule is updated,
or as tasks are completed.

**Attachment 1**

**Mitigation Monitoring**

Policy: Western will ensure that we fulfill our commitments to mitigate
the environmental effects of our activities.

Background: Western routinely commits to specific actions for the
protection of cultural and biological components of the environment from
adverse effects of our activities. For example, before a
pole-replacement project, Western might locate an endangered plant
community on the transmission right-of-way. The NEPA document for the
project would most likely specify that the

maintenance crews would avoid the plants. Western routinely commits to
implement stormwater pollution prevention strategies, reduce visual
impacts, undertake erosion control, limit use of pesticides, and avoid
cultural sites, wetlands, riparian areas and other important habitats.

Such commitments often expedite the clearance process and allow Western
to proceed with minimum expense and delay. A project, which would
otherwise require an EA/FONSI, might be cleared with a CX because
Western committed to avoid important environmental resources, thus
eliminating adverse effects. In addition, meeting these commitments
enhances Western\'s reputation for responsible environmental stewardship
with regulators, land managing agencies, Native American tribes, and
private landowners.

To preserve these benefits, Western must ensure that we carry out the
mitigation actions to which we commit.

When Western makes mitigation commitments, DOE requires a mitigation
action plan that describes how mitigation will be planned and
implemented. In such projects, annual mitigation reporting is required
and will be submitted with Western\'s Annual Site Environmental Report.
The reporting is required until the mitigation is completed.

Process: Western will audit selected projects that have the following
characteristics for mitigation compliance:

National Register eligibility of cultural resources; presence of fossils

Sensitivity and importance of biological resources present

Size and scope of project

Interest from stakeholders

Mitigation reporting requirements

In addition, some projects will be selected at random.

Western will keep records in each regional office of monitored projects
and findings, and use this information at least annually to assess the
effectiveness of mitigation methods and the effectiveness of its
processes for ensuring that mitigation is carried out as planned.
Western will take corrective action as soon as deficiencies are
identified, and report the results of mitigation monitoring in the
Annual Site Environmental Report.