Gateway West Transmission Line Draft EIS 

Appendix C 

Environmental Protection Plans and Measures 

 Appendix C-1 – Revised Environmental Protection Measures and Plans 

 Appendix C-2 – Revised Framework Reclamation Plan for Construction 

 Appendix C-3 – Revised Proposed Plant and Wildlife Conservation Plan – 

Construction Activities 

 Appendix C-4 – Revised Plan for Operations, Maintenance, and 

Emergency Response Activities 

 Appendix C-5 – Greater Sage-grouse Avoidance, Minimization, and 

Mitigation Measures 

 Appendix C-6 – Draft Framework for Compensatory Mitigation for and 

Monitoring of Unavoidable Impacts to Waters of the U.S. 
Gateway West Transmission Line Draft EIS 

Appendix C-1 

Revised Environmental Protection Measures and Plans 

(submitted to BLM by Idaho Power and Rocky Mountain Power 

October 2010) 
Appendix C-1 

Revised Environmental Protection Measures 

and Plans 

Gateway West Transmission Line Project 

Prepared by: 

Idaho Power Company 

1221 West Idaho Street 

Boise, ID 83702 

and 

Rocky Mountain Power 

1407 W North Temple 

Salt Lake City, UT 84116 

October 2010
TABLE OF CONTENTS 

1.0 ENVIRONMENTAL PROTECTION MEASURES .................................................. 1

2.0 ENVIRONMENTAL PROTECTION PLANS .......................................................... 2

3.0 LITERATURE SOURCES ..................................................................................... 2

LIST OF ATTACHMENTS 

Attachment A Traffic and Transportation Management 

Attachment B Stormwater Pollution Prevention

Attachment C Spill Prevention, Containment, and Countermeasures 

Attachment D Cultural Resource and Paleontological Monitoring and Mitigation 

Attachment E Blasting 
Environmental Protection Measures and Plans Appendix C-1 

October 2010 1 

1.0 ENVIRONMENTAL PROTECTION MEASURES 

This appendix specifies Environmental Protection Measures (EPM) that Idaho Power Company 

and Rocky Mountain Power (the Proponents) have incorporated as their best management 

practices and as part of the Project description. These measures have been developed by the 

Proponents to maintain environmental quality and meet requirements of various land 

management plans. These measures apply project-wide unless modified through negotiations 

with individual landowners or superseded by permits granted by federal, state, or local 

agencies. The Proponents will be responsible to ensure their contractors and employees will 

implement these measures. These EPMs apply to construction, operation, and maintenance as 

appropriate. 

 

Additional environmental protection measures are proposed in: 

• Appendix C-2 - Preliminary Reclamation Plan describing pre-construction planning, 

methods to limit erosion, a framework for the reclamation process and post 

construction monitoring and reporting standards to be followed. 

• Appendix C-3 (R) – Revised Proposed Plant and Wildlife Conservation Plan – 

Construction Activities 

• Appendix C-4 (R) - Revised Plan for Operations, Maintenance, and Emergency 

Response Activities 

This appendix (Appendix C-1) contains five attachments. Each Attachment presents the EPMs 

that the Proponents are presenting as part of the Gateway West Transmission Line Project 

(Gateway West or Project). These include: 

Attachment A, Traffic and Transportation Management, includes measures that 

require compliance with federal policies and standards relative to planning, siting, 

improvement, maintenance, and operation of roads for the Project. 

Attachment B, Stormwater Pollution Prevention, includes measures for temporary 

and permanent erosion and sediment control that will be used during construction, 

operation, and maintenance of the transmission line and ancillary facilities. 

Attachment C, Spill Prevention, Containment, and Countermeasures, includes 

measures for spill prevention practices, requirements for refueling and equipment 

operation near waterbodies, procedures for emergency response and incident 

reporting, and training requirements. 

Attachment D, Cultural Resource and Paleontological Monitoring and Mitigation, 

presents the procedures undertaken to inventory, evaluate, and protect cultural 

resources, treatment of any eligible or listed resource that cannot be avoided, and 

inadvertent discoveries during construction, operation, and maintenance. 

Attachment E, Blasting, outlines the procedures and safety measures for blasting 

activities. 
Environmental Protection Measures and Plans Appendix C-1 

October 2010 2 

2.0 ENVIRONMENTAL PROTECTION PLANS 

Each of these attachments serves as the basis for one or more plans that the Proponents must 

produce and submit to the BLM, Forest Service, and other appropriate agencies with regulatory 

authority over lands within the Project, for review and approval before receiving a Notice to 

Proceed to construct. These plans will include site-specific means of implementing the 

measures listed in this appendix, and cannot be finalized until the preferred route is chosen and 

the final design is advanced. Each of the attachments specifies elements that the plan must 

address and sets the standards that the plans must meet in order to be approved. 

3.0 LITERATURE SOURCES 

BLM (U.S. Department of Interior, Bureau of Land Management). 1981. Sun Valley 

Management Framework Plan, Shoshone District, Idaho. 

BLM. 1983. Bruneau Management Framework Plan, Step 3 – Decisions. 

BLM. 1984. Platte River Resource Management Plan, Wyoming. 

BLM. 1985 (1988). Cassia Resource Management Plan (and Amendment), Burley District, 

Idaho. 

BLM. 1986. Lander Resource Management Plan, Wyoming. 

BLM. 1986. Shoshone Monument Resource Management Plan, Shoshone District, Idaho. 

BLM. 1987. Cascade Proposed Resource Management Plan and Final Environmental Impact 

Statement, Boise District, Idaho. 

BLM. 1987. Jarbidge Resource Management Plan, Boise District, Idaho. 

BLM. 1990. Great Divide Resource Management Plan, Wyoming. 

BLM. 1990. Kuna Management Framework Plan, Idaho. 

BLM. 1997. Green River Resource Management Plan. Rock Springs Field Office, Wyoming. 

BLM. 1999. Owyhee Resource Management Plan, Lower Snake River District, Boise Field 

Office, Idaho. 

BLM. 2004. Fire, Fuels, and Related Vegetation Management Direction Plan Amendment and 

Environmental Impact Statement. Upper Snake River District, Idaho. 

BLM. 2006. Birds of Prey Resource Management Plan. Boise District Office, Idaho. 

BLM. 2006. Pocatello Resource Management Plan and Environmental Impact Statement. 

Pocatello Field Office, Idaho. 

BLM. 2007. Kemmerer Resource Management Plan. Kemmerer Field Office, Wyoming. 

BLM. 2007. Overland Pass Natural Gas Liquids Pipeline Environmental Impact Statement. 

BLM/WY/PL-07/026+5101 AS-06-01095. Wyoming State Office and Rawlins Field 

Office, Wyoming. 
Environmental Protection Measures and Plans Appendix C-1 

October 2010 3 

BLM. 2007. Record of Decision and Approved Casper Resource Management Plan. Casper 

Field Office, Wyoming. 

BLM. 2007. Surface Operating Standards and Guidelines for Oil and Gas Exploration and 

Development. BLM/WO/ST-06/021+3071/REV 07. Denver, Colorado. 84 pp. 

BLM. 2008. Rawlins Resource Management Plan and Environmental Impact Statement. 

Rawlins Field Office, Wyoming. 

DOE (U.S. Department of Energy), BLM, Forest Service (U.S. Department of Agriculture Forest 

Service), and DOD (U.S. Department of Defense). 2008. West-wide Energy Corridor 

Programmatic Environmental Impact Statement (Energy Corridor PEIS). 

IDEQ (Idaho Department of Environmental Quality). 2008. Accessed online at 

http://www.deq.state.id.us/. February. 

PacifiCorp. 2007. Preliminary Plan of Development for Bureau of Land Management, Wyoming 

State Office. Jim Bridger to Crystal 500kV Transmission Project. 

PacifiCorp. 2007. Preliminary Plan of Development for Bureau of Land Management, Wyoming 

State Office. Dave Johnston to Melba 500kV and 345kV Transmission Project. 
ATTACHMENT A 

TRAFFIC AND 

TRANSPORTATION 

MANAGEMENT 
Environmental Protection Measures and Plans Attachment A 

October 2010 A-1 

Traffic and Transportation Management 

This Attachment presents protection measures to be used to minimize impacts on roads, traffic, 

and other users of roads, and to reduce dust. The Proponents will prepare a Traffic and 

Transportation Management Plan, once the locations of access roads and crossings are known, 

that demonstrates how the measures specified herein will be implemented in the field. 

TR-1 A Traffic and Transportation Management Plan will be developed and implemented 

to provide site-specific details showing how the Project will comply with the EPMs 

listed in this attachment. This plan will be submitted to and approved by the 

appropriate federal, state, and local agencies with authority to regulate use of 

public roads, and approved, prior to the issuance of a Notice to Proceed with 

construction. 

TR-2 Dust suppression techniques will be applied, such as watering construction areas 

or removing dirt tracked onto a paved road as necessary to prevent safety hazards 

or nuisances on access roads and in construction zones near residential and 

commercial areas and along major highways and interstates. 

TR-3 If the Project proposes to obtain water from wells or surface water sources to 

suppress dust, written approval from the landowner or regulatory agency will be 

obtained prior to appropriation. 

TR-4 If a construction method requires the closure of a state- or county-maintained road 

for more than 1 hour, a plan will be developed to accommodate traffic as required 

by a county or state permit. 

TR-5 On county- and state-maintained roads, caution signs will be posted on roads, 

where appropriate, to alert motorists of construction and warn them of slow traffic. 

Traffic control measures such as traffic control personnel, warning signs, lights, 

and barriers will be used during construction to ensure safety and to minimize 

traffic congestion. 

TR-6 To reduce traffic congestion and roadside parking hazards, an equipment yard will 

be provided for primary parking for employee personal vehicles. 

TR-7 Unauthorized vehicles will not be allowed within the construction right-of-way 

(ROW) or along roadsides near the ROW. 

TR-8 Construction vehicles will follow a 25 mph speed limit on unposted project roads. 

TR-9 All temporary culverts and associated fill material will be removed from stream 

crossings after construction, and banks will be recontoured to their pre-disturbance 

conditions. 

TR-10 Landowners will be notified at least 48 hours prior to the start of construction within 

0.25 mile of a residence. 

TR-11 Emergency vehicle access to private property will be maintained. 

TR-12 Roads in residential areas will be restored as soon as possible, and construction 

areas near residences will be fenced off at the end of the construction day. 

TR-13 Roads negatively affected by construction and as identified by the Agencies will be 

returned to preconstruction condition. 

TR-14 Roads developed specifically for this project that are identified by the Proponents 

as no longer necessary will be reclaimed as specified in the Reclamation, 

Revegetation, and Weed Management Plan. 
ATTACHMENT B 

STORMWATER 

POLLUTION PREVENTION 
Environmental Protection Measures and Plans Attachment B 

October 2010 B-1 

Stormwater Pollution Prevention 

This attachment addresses measures to be undertaken to prevent stormwater pollution. To 

comply with criteria in Environmental Protection Agency’s (EPA’s) Clean Water Act, all 

construction site operators engaged in clearing, grading, and excavating activities that disturb 

one acre or more, must obtain a National Pollutant Discharge Elimination System (NPDES) 

permit for stormwater discharges (Code of Federal Regulations, Title 40, Parts 122 and 123). 

NPDES permits (also called Construction General Permits) are issued by EPA or similar 

authorized state entity following submittal of a Notice of Intent (NOI) for construction activities, 

and preparation of a Stormwater Pollution Prevention Plan (SWPPP) that describes how erosion 

and sediment transport will be minimized to adjacent waterbodies. At a minimum, two SWPPPs 

will be necessary for Gateway West. Wyoming has its own stormwater control program; 

therefore construction stormwater plans in Wyoming will be submitted to Wyoming Department 

of Environmental Quality (DEQ). 

Measures to assure that construction activities comply with state and EPA requirements for 

stormwater management to be incorporated into the SWPPP include: 

SW-1 The appropriate NPDES permits for construction activities that disturb one acre or 

more of land will be obtained from DEQ and EPA or their designees. 

SW-2 NPDES permit requirements will be met. This includes implementing and 

maintaining appropriate BMPs for minimizing impacts to surface water. 

SW-3 One or more responsible persons will be designated to manage stormwater issues, 

conduct the required stormwater inspections, and maintain the appropriate records 

to document compliance with the terms of the NPDES permit. 

SW-4 The SWPPPs will be modified as necessary to account for changing construction 

conditions. 

SW-5 The SWPPPs will identify areas with critical erosion conditions that may require 

special construction activities or additional BMPs to minimize soil erosion. 

SW-6 Migration of construction-related sediment to all adjacent surface waterbodies will 

be prevented. 

SW-7 Stormwater BMPs will be maintained on all disturbed lands during construction 

activities, as described in the SWPPP. 

SW-8 Approved sediment and erosion control BMPs will be installed and maintained until 

disturbed areas meet final stabilization criteria. 

SW-9 Temporary BMPs will be used to control erosion and sediment at staging areas 

(equipment storage yards, fly yards, lay down areas) and substations. 

SW-10 The construction schedule may be modified to minimize construction activities in 

rain-soaked or muddy conditions. 

SW-11 Damaged temporary erosion and sediment control structures will be repaired in 

accordance with the SWPPP. 

SW-12 Upon completion of construction, permanent erosion and sediment BMPs will be 

installed along the transmission line within the ROW, at substations, and at related 

facilities in accordance with the SWPPPs. 

SW-13 In areas of droughty soils, the soil surfaces will be mulched and stabilized to 

minimize wind erosion and to conserve soil moisture in accordance with the 

SWPPPs.
ATTACHMENT C 

SPILL PREVENTION, 

CONTAINMENT, AND 

COUNTERMEASURES 
Environmental Protection Measures and Plans Attachment C 

October 2010 C-1 

Spill Prevention, Containment, and Countermeasures

This attachment outlines spill prevention practices and requirements for refueling and 

equipment operation near waterbodies, procedures for emergency response and incident 

reporting, and training requirements. The Proponents will prepare a Spill Prevention, 

Containment, and Countermeasures Plan (SPCC Plan) for review and approval by the 

appropriate regulatory agencies. That plan will include site-specific implementation of cleanup 

procedures in the event of soil contamination from spills or leaks of fuels, lubricants, coolants, or 

solvents as outlined in this attachment. 

SPC-1 Construction industry standard practices and BMPs will be used for spill prevention 

and containment. 

SPC-2 Construction spills will be promptly cleaned up and contaminated materials hauled 

to a disposal site that meets local jurisdictional requirements. 

SPC-3 All staging areas will contain fueling areas with containment. Where fueling must 

be conducted along the ROW, the plan will specify BMPs. 

SPC-4 If an upland spill occurs during construction, berms will be constructed with 

available equipment to physically contain the spill. Absorbent materials will be 

applied to the spill area. Contaminated materials will be excavated and temporarily 

placed on and covered by plastic sheeting in a containment area a minimum of 100 

feet away from any wetland or waterbody, until proper disposal is arranged. 

SPC-5 If a spill occurs which is beyond the capability of on-site equipment and personnel, 

an Emergency Response Contractor will be identified and available to further 

contain and clean up the spill. 

SPC-6 For spills in standing water, floating booms, skimmer pumps, and holding tanks will 

be used as appropriate by the contractor to recover and contain released materials 

on the surface of the water. 

SPC-7 If pre-existing contamination is encountered during operations, work will be 

suspended in the area of the suspected contamination until the type and extent of 

the contamination is determined. The type and extent of contamination; the 

responsible party; and local, state, and federal regulations will determine the 

appropriate cleanup method(s) for these areas. 

SPC-8 The SPCC Plan will include details on the types and quantities of absorbent and 

protective materials (e.g., visqueen, booms) that must be readily available to 

construction personnel and requirements for the restocking of materials. 

SPC-9 Materials such as fuels, other petroleum products, chemicals, and hazardous 

materials including wastes will be located in upland areas at least 500 feet away 

from streams, 400 feet for public wells, and 200 feet from private wells. 

SPC-10 Pumps and temporary fuel tanks for the pumps will be stored in secondary 

containment. Containment will provide a minimum volume equal to 110 percent of 

the volume of the largest storage vessel located in the yard. 
ATTACHMENT D 

CULTURAL RESOURCE 

AND PALEONTOLOGICAL 

MONITORING AND 

MITIGATION 
Environmental Protection Measures and Plans Attachment D 

October 2010 D-1 

Cultural Resource and Paleontological Monitoring and Mitigation 

This attachment presents the procedures to be undertaken to inventory, evaluate, and protect 

cultural and paleontological resources. In addition to preparing a Cultural Resource and 

Paleontological Monitoring and Mitigation Plan, the Proponents will prepare and submit a 

Treatment Plan for any historic property eligible for or listed on the National Register of Historic 

Places (NRHP) that will be impacted by the Project. The plan will specify how each property will 

be treated, including mitigation measures. The Plan will include an Unanticipated Discovery 

Plan that details the steps to be taken during construction in response to a new find of an 

historic property potentially eligible for listing on the NRHP during construction. 

CUL-1 All work conducted under the Cultural Resources and Paleontological Monitoring 

and Mitigation Plan will be performed by qualified paleontologists and 

archeologists with trained assistants. 

CUL-2 An Unanticipated Discovery Plan will be included as part of the Cultural Resources 

and Paleontological Monitoring and Mitigation Plan. This plan will specify what 

steps will be taken if a subsurface cultural resource or fossil is discovered during 

construction, including stopping construction in the vicinity of the find, notification of 

the appropriate land management agency, identification of a qualified 

archaeologist or paleontologist to conduct an evaluation of the find, and the 

development of an approved data recovery program or other mitigation measures. 

CUL-3 The Cultural Resource and Paleontological Monitoring and Mitigation Plan will 

include provisions for the preparation and curation of any fossil collections from 

federal lands and for the preparation of a final report based on the data recovered 

for activities on federal lands. 

CUL-4 Class I and Class III surveys will be completed for cultural resources. Class I 

surveys will be conducted on public and private lands and will cover a study area of 

one mile on either side of the proposed and alternate transmission line alignments 

as well as areas identified for use as staging areas and access roads. Class III 

surveys will be conducted on 100 percent of federal and state lands, and for those 

private lands for which survey access is granted, prior to the completion of the 

National Environmental Policy Act (NEPA) process. A good-faith effort will be 

made to obtain survey permission prior to the completion of the NEPA process. 

CUL-5 If construction will adversely affect any properties listed on, or eligible for listing on, 

the NRHP, mitigation will be required. Mitigation may include, but not be limited to, 

one or more of the following measures: a) avoidance through the use of relocation 

of structures through the design process, realignment of the route, relocation of 

temporary workspace, or changes in the construction and/or operational design; b) 

data recovery, which may include the systematic professional excavation of an 

archaeological site or the preparation of photographic and/or measured drawings 

documenting standing structures; and c) the use of landscaping or other 

techniques that will minimize or eliminate effects on the historic setting or 

ambience of standing structures. 

CUL-6 Avoidance areas will be flagged prior to construction activities. Flagging will be 

removed once construction is completed in an area. 

CUL-7 To minimize unauthorized collecting of archaeological material or vandalism to 

known archaeological sites, all workers will attend mandatory training on the 
Environmental Protection Measures and Plans Attachment D 

October 2010 D-2 

significance of cultural resources and the relevant federal regulations intended to 

protect them. 

CUL-8 If remains are discovered, construction will be halted and the coroner will be 

notified. If human remains of Native American origin are discovered, or if 

associated grave goods, or objects of cultural patrimony are discovered on lands 

managed by a federal agency, the provisions of the Native American Graves 

Protection and Repatriation Act will be followed. 

CUL-9 If fossil materials are discovered during Project construction, all surface-disturbing 

activities in the vicinity of the find will cease until notification to proceed is given by 

the authorized officer. The site will be protected to reduce the risk of damage to 

fossils and context. Appropriate measures to mitigate adverse effects to significant 

paleontological resources will be determined by the authorized officer. 
ATTACHMENT E 

BLASTING 
Environmental Protection Measures and Plans Attachment E 

October 2010 E-1 

Blasting 

This attachment outlines the procedures and safety measures to be used if blasting activities 

are required during construction. The Proponents will prepare a site-specific Blasting Plan prior 

to construction that incorporates these measures and demonstrates how and where they will be 

applied in the field. 

BLA-1 The Blasting Plan will identify blasting procedures including safety, use, storage, 

and transportation of explosives that will be employed where blasting is needed, 

and will specify the locations of needed blasting. 

BLA-2 All blasting will be performed by registered licensed blasters who will be required to 

secure all necessary permits and comply with regulatory requirements in 

connection with the transportation, storage, and use of explosives, and blast 

vibration limits for nearby structures, utilities, wildlife, and fish (where blasting is 

conducted in waterbodies). 

BLA-3 Appropriate flags, barricades, and warning signals will be used to ensure safety 

during blasting operations. Blast mats will be used when needed to prevent 

damage and injury from fly rock. 

BLA-4 Blasting in the vicinity of pipelines will be coordinated with the pipeline operator, 

and will follow operator-specific procedures, as necessary. 

BLA-5 Damages that result from blasting will be repaired or the owner fairly compensated. 
Gateway West Transmission Line Draft EIS 

Appendix C-2 

Revised Framework Reclamation Plan for Construction Activities 

(submitted to BLM by Idaho Power and Rocky Mountain Power 

October 2010) 
 

 Appendix C-2 

Revised Framework Reclamation Plan for 

Construction Activities 

Gateway West Transmission Line Project 

Prepared by: 

Idaho Power Company 

1221 West Idaho Street 

Boise, ID 83702 

and 

Rocky Mountain Power 

1407 W North Temple 

Salt Lake City, UT 84116 

October 2010
 TABLE OF CONTENTS 

1.0 INTRODUCTION ................................................................................................... 1

1.1 RECLAMATION PLAN PURPOSE......................................................................... 1

1.2 RECLAMATION GOALS AND OBJECTIVES............................................................ 1

2.0 NOXIOUS AND INVASIVE WEED CONTROL ...................................................... 2

2.1 EXISTING CONDITIONS..................................................................................... 3

2.2 PRE-CONSTRUCTION SURVEYS ........................................................................ 4

2.3 PRE-CONSTRUCTION TREATMENT..................................................................... 4

2.4 WEED PREVENTION AND CONTROL................................................................... 5

2.5 POST-CONSTRUCTION WEED CONTROL AND MONITORING ................................. 6

3.0 TOPSOIL AND SPOIL TREATMENT .................................................................... 6

4.0 RIGHT-OF-WAY RECLAMATION ......................................................................... 7

4.1 SEEDBED PREPARATION .................................................................................. 8

4.1.1 Seeding Methods ............................................................................... 8

4.1.2 Seed Mixes ........................................................................................ 8

5.0 POST-CONSTRUCTION MONITORING AND REPORTING ................................ 9

5.1 MONITORING ACTIVITIES .................................................................................. 9

5.2 REPORTING .................................................................................................... 9

6.0 STORMWATER POLLUTION PREVENTION PLANS .......................................... 9

7.0 PLAN UPDATES ................................................................................................... 9

8.0 LITERATURE CITED .......................................................................................... 10

LIST OF ATTACHMENTS 

Attachment A Invasive and Noxious Plants in Project Area 

Attachment B Species Abundance Ratings
Framework Reclamation Plan Appendix C-2

October 2010 Page 1 

1.0 INTRODUCTION 

Idaho Power and Rocky Mountain Power (the Proponents) are proposing to construct and 

operate approximately 1,188 miles of new 230-kilovolt (kV) and 500kV electric transmission 

system consisting of 10 segments between the Windstar Substation at Glenrock, Wyoming, and 

the Hemingway Substation approximately 30 miles southwest of Boise, Idaho (hereafter referred 

to as Gateway West or Project). The Project includes ground disturbing activities associated 

with construction of above-ground single and double circuit transmission lines involving towers, 

access roads, staging areas, fly yards, pulling sites as well as associated substations, 

communication sites and electrical supply distribution lines. The Project crosses private land 

and public lands administered by the Bureau of Land Management (BLM), US Forest Service 

(USFS) and the states of Idaho and Wyoming. 

1.1 Reclamation Plan Purpose 

This preliminary reclamation plan (framework) describes the framework for development of the 

final Reclamation, Revegetation, and Noxious and Invasive Weed Control Plan (final 

Reclamation Plan). The focus of this framework and the final Reclamation Plan is to restore 

areas that have been temporarily impacted by construction activities. The framework and final 

Reclamation Plan are applicable project wide and will be modified as per agreement with federal 

land managing agencies, states, counties or individual landowners. The final Reclamation Plan 

is intended to meet the ten reclamation requirements specified in BLM Instruction Memorandum 

(IM) No. WY-2009-022 and guidance contained in Chapter 2840 of the Forest Service Manual 

as applicable. The final Reclamation Plan will be based on the final selected location of all 

project facilities and will be submitted to the BLM and US Forest Service prior to the issuance of 

a right-of-way grant. 

This framework and the final Reclamation Plan also incorporate by reference the Storm Water 

Pollution Prevention Plan(s) that will be developed to comply with Clean Water Act requirements 

and that will include measures to address erosion and sedimentation that could result from 

ground disturbing activities and the Proponents’ proposed Environmental Protection Measures 

(Appendix B of the POD). 

1.2 Reclamation Goals and Objectives 

The primary goal of conducting reclamation activities is to restore temporarily disturbed areas to 

pre-construction conditions, to the extent practicable. BLM reclamation goals emphasize 

stabilization and the protection of existing vegetation; minimal disturbance of the environment; 

soil stabilization; and establishment of vegetation consistent and compatible with adjacent land 

uses. The goal of this framework is to provide a structure for developing and implementing the 

reclamation process. The reclamation process is designed to restore temporary impacts to 

vegetation and resident soils and meet the goals and objectives described below: 

• Noxious and invasive weed control, 

• Topsoil segregation and stockpiling, 

• Right-of-way restoration, 

• Seedbed preparation and re-seeding, and 

• Road reclamation. 
Framework Reclamation Plan Appendix C-2

October 2010 Page 2 

Reclamation goals can be achieved through both short- and long-term objectives. The shortterm objectives for reclamation are to stabilize disturbed areas to minimize potential erosion and 

sedimentation, establish temporary vegetation cover; prevent or minimize the introduction and 

spread of noxious and invasive weed species; and conserve suitable topsoil for long-term 

reclamation activities. The long-term objective of reclamation is to establish permanent 

vegetation cover that is similar to pre-disturbance conditions, is self-sustaining, and where 

applicable, resistant to the introduction or spread of noxious and invasive weed species. 

Measures to achieve both short- and long-term objectives and reclamation goals include: 

• Using proper soil management techniques, including stripping, stockpiling, and reapplying topsoil material at temporarily disturbed areas to restore soil horizons, utilize 

the existing seedbank(s) and establish surface conditions that would allow for rapid reestablishment of vegetative cover. 

• Establishing stable soil surface and drainage conditions and utilizing applicable Best 

Management Practices (BMPs) which would minimize surface erosion and 

sedimentation and facilitate plant establishment. 

• Conducting pre-construction weed surveys, applying pre-construction weed control 

measures where appropriate, controlling weed introduction and spread during 

construction, and conducting post-construction weed monitoring and control activities 

where needed. 

• Re-seeding disturbed areas with plant species adapted to site conditions and compatible 

with pre-construction conditions and surrounding vegetation in order to establish longterm, productive, self-maintaining plant communities and concurrently minimize the 

chances for noxious and invasive weeds to establish. 

• Re-establishing topography to pre-construction conditions to the extent practicable. 

• Annual monitoring (and active corrective action) for three years following construction to 

measure the achievement of reclamation objectives. 

• Develop and implement contingency plan(s) in the event annual monitoring indicates 

lack of suitable progress towards achieving pre-defined success metrics. 

2.0 Noxious and Invasive Weed Control 

“Noxious weed” is a legal term, meaning any plant officially designated by a federal, state, or 

local agency as injurious to public health, agriculture, recreation, wildlife, or property (Sheley 

and Petroff, 1999). The more general term “invasive species” refers to species that are nonnative to the ecosystem under consideration and whose introduction causes, or is likely to 

cause economic or environmental harm or harm to human health (National Invasive Species 

Information Center 2008). Invasive plant species include those that are legally designated as 

noxious, as well as additional species that may be considered noxious in some areas but not 

others, and other species that are already widespread. 

Soil disturbances, such as those caused by construction of the Project could result in the 

establishment of new populations and spread of existing populations of noxious and invasive 

weeds. This section of the framework describes the known status of noxious weed species 

within the Project area, the regulatory agencies responsible for control of noxious and invasive 

weeds, and steps that the Proponents will take in preventing the establishment and spread of 
Framework Reclamation Plan Appendix C-2

October 2010 Page 3 

noxious and invasive weed species that are the result of the Proponents construction activities. 

In addition to providing updated information contained within this framework, the final 

Reclamation Plan will include information on locations of significant weed populations within the 

Project footprint and proposed treatment methods, as applicable. , 

The focus of the Proponents noxious weed control efforts will be to prevent the spread of new 

infestations resulting from their activities, and to assist adjacent land owners in their weed 

control responsibilities by reducing/eliminating existing infestations in the Project area. Without 

concurrent control of weed infestations by land owners on surrounding lands, weed control 

efforts by the Proponents in the Project area will be short lived. Surrounding populations of 

noxious weeds would continue to spread and infest the transmission line construction corridor. 

The Proponents are only responsible for control or eradication of noxious weeds and invasive 

species that are a result of their construction related surface disturbing activities. The 

Proponents are not responsible for noxious weeds and invasive species that occur adjacent to 

Project areas and are not responsible for eradicating a species that was present prior to the 

Project. For example, cheatgrass (Bromus tectorum), is widespread across large portions of the 

Project area. Eradication of these infestations is not the responsibility of the Proponents and 

would not be attempted. 

The objectives of noxious weed control for the Project are: 1) to inventory the existing 

occurrence, distribution and abundance of noxious weeds in the Project area prior to 

construction, 2) to annually inventory the occurrence, distribution and abundance of noxious 

weeds in the Project area for a period of three (3) years following the completion of construction 

activities, 3) to reduce/eliminate infestations of noxious weeds caused by Project-related 

activities and to prevent the spread of new and existing populations within the Project area for a 

period of three (3) years, 4) to insure any populations of rare plants along the transmission line 

are not negatively impacted by weed control activities, 5) to coordinate and consult with 

designated BLM and personnel regarding all noxious weed inventory and control activities 

conducted by the Proponents. 

2.1 Existing Conditions

Attachment A is a list of the noxious and invasive weed species that are known or expected to 

occur within the Project area, based on their recorded presence in the counties in which the 

Project is located. The BLM and Forest Service use the most current Idaho and Wyoming state 

noxious weed lists for managing weeds on federal lands, and the BLM in Wyoming also uses 

county declared species (Wyoming Weed and Pest Council 2008b). The final Reclamation Plan 

will include the most current noxious weed species lists produced by the two states and 

Wyoming counties available just prior to construction. 

The State of Wyoming has designated 25 plant species as noxious (Wyoming Weed and Pest 

Council 2008a) and the Idaho State Department of Agriculture (ISDA) has designated 57 plant 

species as noxious. Idaho’s noxious weeds are divided into three categories (ISDA 2008): 

• Statewide Early Detection and Rapid Response (EDRR) List: If weeds on this list are 

identified, they will be reported to ISDA within 10 days, and eradicated in the same 

growing season as identified. 

• Statewide Control List: This list contains species that are known to exist throughout the 

state. When identified, a control plan will be developed by the county, with active control 

methods to be employed in no more than 5 years. 
Framework Reclamation Plan Appendix C-2

October 2010 Page 4 

• Statewide Containment List: Weed list: This list contains species that are known to exist 

throughout the state. Weed control efforts may be directed at reducing or eliminating 

new or expanding populations, while known populations may be managed by any 

approved weed control methodology, as determined by the county. 

2.2 Pre-construction Surveys 

Pre-construction vegetation surveys will be conducted to document the vegetation species, 

evaluate the presence or potential habitat for plant species of special concern (state and 

federally listed), the overall landscape condition relative to plant growth (healthy plants, overgrazed, previously disturbed, recently burned, etc.), and the presence and extent of noxious or 

invasive weeds. These vegetation surveys will be conducted during the growing season and 

prior to construction and will provide baseline data to plan for weed control and provide 

additional information to guide short- and long-term reclamation. 

The locations of noxious weeds and invasive species would be documented with a hand-held 

global positioning system (GPS) instrument and used to develop a pre-construction map. The 

pre-construction map would be used to define the area(s) infested with noxious weeds before 

construction and would be used to document the weeds the Proponents’ are responsible for 

introducing and/or spreading. 

2.3 Pre-construction Treatment 

Mapped noxious and invasive weed species locations may be treated prior to transmission line 

construction. In Idaho, weed species on the EDRR list will be treated prior to the start of ground 

disturbing activities. For other weed species, the decision to treat prior to the start of 

construction activities will be based on the nature and extent of the infestation, surrounding 

conditions (e.g., predominance of weeds outside of project areas), landowner permission, and 

the construction schedule. The intent is for Project construction activities to not be delayed to 

facilitate pre-construction treatment of noxious and invasive weeds. If pre-construction treatment 

is necessary, the following measures would be implemented: 

REC – 1 Company personnel and their contractors will be trained on noxious and invasive 

weed identification to facilitate avoidance of infestations where possible or 

identification of new infestations.

REC – 2 Pre-construction weed treatment would be conducted prior to the start of grounddisturbing activities and at the time most appropriate for the target species. 

REC – 3 Pre-construction weed treatment would be limited to the areas that are expected 

to have surface-disturbing activities. The final Reclamation Plan will include a 

schedule showing the phased in-service dates for different segments. Preconstruction weed treatment will be scheduled accordingly. 

REC – 4 Pre-construction treatment may use mechanical control, hand spraying, grazing, 

or herbicides. The final Reclamation Plan will discuss those options, as 

applicable. 

REC – 5 All herbicide applications would comply with label restrictions, federal, state 

and/or county regulation, and landowner agreements. No spraying would occur 

prior to notification of the applicable land management agency. On federal or 

state controlled lands, a herbicide use plan will be submitted prior to any 
Framework Reclamation Plan Appendix C-2

October 2010 Page 5 

herbicide application as recommended in the BLM herbicide EIS 

http://www.blm.gov/wo/st/en/prog/more/veg_eis.html. The herbicide use plan will 

include the dates and locations of application, target species, herbicide, 

adjuvants, and application rates and methods (e.g., spot spray vs. boom spray). 

No herbicide would be applied to any private property without written approval of 

the landowner. The final Reclamation Plan will contain a list of herbicides that 

may be used, target species, best time for application, application rates, and if 

they are approved for use on BLM-managed and NFS lands. 

REC – 6 Herbicides may be applied using a broadcast applicator mounted on a truck or 

all-terrain vehicle (ATV), backpack sprayers, or with hand sprayers as conditions 

dictate. Herbicide applications would be conducted only by licensed operators or 

under the supervision of a licensed operator. Where allowed, a broadcast 

applicator would likely be used. In areas where noxious weeds are more isolated 

and interspersed with desirable vegetation, noxious and invasive weeds would 

be targeted, thereby avoiding other plants. Pre-construction herbicide 

applications would not occur adjacent to known special status species or near 

water bodies. 

REC – 7 All areas treated would be documented using GPS technologies and included in 

the annual report. 

2.4 Weed Prevention and Control

The Proponents will implement BMPs to eliminate or minimize the introduction and spread of 

noxious weeds and invasive species during construction. These include: 

REC – 8 Areas of existing noxious weeds and invasive species will be avoided where 

possible. 

REC – 9 Project vehicles will arrive at the job site clean of all soil and herbaceous 

material. 

REC – 10 When the contractors demobilize from the job site where identified infestations of 

noxious weeds are present, they will use appropriate decontamination measures 

as defined in the final Reclamation Plan. 

REC – 11 Soil stockpiles from areas that did not have noxious weeds or invasive species 

present, will not be placed adjacent to populations of noxious weeds or invasive 

species, where practicable. 

REC – 12 Areas disturbed by Project activities are susceptible to the establishment and 

spread of noxious weeds. Erosion control measures identified in the SWPPP(s) 

would also assist in preventing the establishment of weeds on exposed soils. 

REC – 13 Project-related storage and staging yards, fly yards, and other areas that are 

subject to regular long-term disturbance will be kept weed-free through regular 

site inspections and herbicide applications, subject to the consent of the land 

owner. 

REC – 14 Where pre-construction surveys have identified noxious or invasive weed species 

infestations, topsoil and other soils will be placed next to the infested area and 

clearly identified as coming from an infested area. Topsoil would be returned to 

the area it was taken from and will not be spread in adjacent areas. If the topsoil 
Framework Reclamation Plan Appendix C-2

October 2010 Page 6 

is not suitable for backfill, then it will be spread in another previously disturbed 

area and clearly identified for future weed treatments as applicable. 

REC -15 Straw or hay that may be used as a BMP to control erosion and sedimentation 

must be certified weed free. If certified weed-free materials are not available, 

then alternative BMPs will be used. The use of alternative BMPs will be 

coordinated with the construction storm water inspector. 

2.5 Post-Construction Weed Control and Monitoring 

Annual spraying will most likely occur during the months of May to June, however the potential 

for fall treatments, depending on the weed species, does exist. Following annual spraying, a 

monitoring survey will be conducted to verify locations of noxious weeds in the Project vicinity. 

These monitoring surveys are expected to occur in the fall (August-September) and will be 

conducted following the same methods as the pre-construction survey. The relative abundance 

(refer to Attachment B for abundance ratings) of each noxious weed will be recorded for the 

following three zones: 1) immediate area of disturbance (roadbed, lay-down yard, or pulling and 

tensioning site); 2) within 30 feet of the immediate area of disturbance; and 3) in the area 

greater than 30 feet from the immediate area of disturbance. Pedestrian surveys will be 

conducted in zones 1 and 2. Zone 3 will be surveyed at a reconnaissance level based on what 

is visible adjacent to the 30-foot buffer. Abundance will be recorded using the following eight 

abundance categories: rare, locally rare, occasional, locally occasional, frequent, locally 

frequent, abundant, and locally abundant. Abundance categories are defined in Appendix 1. 

Using prior years’ survey information, annual spraying will be planned by the Proponents and 

coordinated with the BLM to insure spraying will be conducted at the proper growing period, 

during favorable environmental conditions, and will use the appropriate chemicals to control 

targeted species. The chemicals used must be BLM approved. 

Spraying will be conducted by the Proponents or a licensed qualified contractor. The intent of 

applying herbicide will be to treat only the areas that need treatment, rather than broad 

application. It is anticipated that most spraying will be conducted using ATV mounted spray 

equipment, supported by a one or more four wheel drive pickups equipped with water tanks. 

Pickups will carry necessary chemicals, dyes, fluid pumps, tools and water to provide a base 

station for refilling of ATV spray tanks. Spraying weed infestations within the weed control area 

will be conducted by ATV, using hand held spray guns with 25 to 50-foot hoses attached to 

spray tanks or by using 8 to 12-foot spray booms. The spray booms will be utilized for treating 

larger areas on roadbeds and gentle to moderately steep terrain. 

The final Reclamation Plan will provide site-specific information on noxious and invasive weed 

species, relative abundance, and treatment methods. 

3.0 TOPSOIL AND SPOIL TREATMENT 

The Proponents and/or their contractor will minimize ground disturbance where practicable; 

however, there will still be extensive areas of soil disturbance due to the nature of the work and 

existing topography. The final Reclamation Plan will identify locations where management of 

topsoil is warranted, such as areas where topsoil supports native plant species or is important to 

a private landowner (e.g., agricultural soils). Generally, topsoil is considered the upper 6 to 12 

inches, but this can vary by soil type. To protect topsoil, the following measures will be 

implemented where applicable: 
Framework Reclamation Plan Appendix C-2

October 2010 Page 7 

REC – 16 The topsoil layer will be removed, taking care not to mix it with the underlying 

sub-soil. Where topsoil separation is employed, topsoil will be stored in a 

separate stockpile. 

REC – 17 Certified weed-free straw, mulch, grave, and other BMPs as appropriate, will be 

used as described in the SWPPP to stabilize the stockpile and limit erosion and 

standing water, control dust, and control the establishment of noxious or invasive 

weeds in stockpiled soils. 

REC – 18 Topsoil and sub-surface soils will be replaced in the proper order during 

reclamation. 

The timing of topsoil replacement will be dependent upon project constraints, season, weather, 

and landowner/manager requirements. 

During various construction activities, soil spoils will be generated along the Project route. The 

following measure will be implemented when soil spoils must be disposed of: 

 

REC – 19 Where it is necessary to spread spoils (subsurface soils or waste rock resulting 

from excavations or foundation drilling), it will be done where practicable and in 

close proximity to where the disturbance occurred (within the ROW). Material will 

be spread uniformly to match existing contours and covered with topsoil when 

available and re-seeded. 

4.0 RIGHT-OF-WAY RECLAMATION 

Reclamation of temporarily disturbed areas will involve replacing stockpiled subsoil and topsoil 

(where applicable), restoring pre-existing contours, installing permanent erosion control 

structures (i.e., water bars), and re-establishing vegetation. These methods are further 

discussed below. 

REC – 20 Re-contouring: Temporarily disturbed lands within the ROW will be re-contoured 

to blend with the surrounding landscape. Re-contouring will emphasize 

restoration of the existing drainage patterns and landform to pre-construction 

conditions, to the extent practicable. (Tower pads would not be recontoured.) 

REC – 21 De-compaction: Areas within the ROW, laydown or staging yards, and other 

areas of extensive vehicle travel will typically contain compacted soils. These 

soils will be de-compacted on a case-by-case basis through negotiation with the 

landowner or land management agency. 

REC – 22 Final Cleanup: Final cleanup will ensure that all construction areas are free of 

any construction debris including but not limited to: assembly scrap metals, oil or 

other petroleum based liquids, construction wood debris and worker generated 

litter. Permanent erosion control devices will be left in place. 

Some areas may not have extensive vegetation before Project construction, such as areas of 

shallow bedrock, shallow topsoil, steep slopes, or dry desert soils. These areas will be 

identified during pre-construction surveys and will not be reseeded. Where appropriate, other 

reclamation activities (e.g., restoring pre-construction contours) will be conducted. 
Framework Reclamation Plan Appendix C-2

October 2010 Page 8 

4.1 Seedbed Preparation 

As part of the reclamation process, the Proponents will prepare the seedbed to facilitate the 

restoration of vegetation to pre-construction conditions. General measures are discussed below 

and habitat-specific seedbed measures will be provided in the final Reclamation Plan. 

Soil amendments are intended to minimize soil erosion and subsequent sedimentation, 

conserve soil moisture, provide cover, and moderate temperatures to facilitate the germination 

of seeds. 

REC – 23 The Proponents will utilize soil amendments (e.g., fertilizer, wood or straw 

mulches, tackifying agents, or soil stabilizing emulsions) on a case-by-case basis 

and with landowner or land management agency approval. Specific soil 

amendments would be identified in the final Reclamation Plan and be consistent 

with the SWPPP. 

4.1.1 Seeding Methods 

Unless otherwise directed, following seedbed preparation, seed will be applied using a 

broadcast spreader, drill, and/or hydroseeder. The method used will depend on site conditions 

and seed mix. Seeding will be done as soon after ground disturbing activities are complete and 

at the appropriate time of year; preferably in the fall or in the spring if fall is not an option. If 

there is a lag-time between the end of ground disturbing activities and seeding, BMPs from the 

SWPPP will be implemented. Measures regarding seeding methods are as follows: 

REC – 24 Broadcast seeding will apply the seed directly on the ground surface. The type 

of broadcast spreader will depend on the size of the area to be seeded, and the 

terrain. Seed will be placed in direct contact with the soil, ideally at a depth of 

approximately 0.5 to 1-inch deep. It will then be covered by raking or dragging a 

chain or harrow over the seed bed; to remove air pockets. 

REC – 25 Drill seeding would be used on areas of sufficient size with moderate or favorable 

terrain to accommodate mechanical equipment. Drill seeding provides the 

advantage of planting the seed at a uniform depth. 

REC – 26 Hydroseeding, which is the spraying of seeds and water onto the ground surface, 

or hydroseeding/hydromulching, which is the spraying of seeds, mulch and 

water, may be implemented on steeper slopes. Tackifier may be added to 

facilitate adherence of hydromulch to slopes greater than 25%. 

4.1.2 Seed Mixes 

The choice of seed mixtures will be dependent upon the existing vegetation types, the 

availability of commercial, weed-free live seed at the time of seeding, and landowner approval.

The final Reclamation Plan will identify proposed seed mixes based on specific vegetation 

communities (e.g., Wyoming sagebrush, grassland, etc.); this will include the species, cultivar (if 

applicable), percent seed mix, pure live seeds per acre, and application rate. Proposed mixes 

will not be applied prior to landowner/ 

The Proponents will reseed some permanently disturbed areas as well. Roads that are created 

for this project and that are necessary for the long-term operation and maintenance of the 

transmission line are considered a permanent impact; however, the Proponents will reseed 

these areas as an environmental protection measure. The intent of this reseeding differs from 
Framework Reclamation Plan Appendix C-2

October 2010 Page 9 

the long-term objective of establishing plant communities and habitat. Therefore, the final 

Reclamation Plan will also include one or more seed mixes that will be used as a BMP for 

permanently disturbed areas. 

5.0 POST-CONSTRUCTION MONITORING and REPORTING 

The Proponents will conduct annual post construction surveys for a three year period following 

the conclusion of ground disturbing activities. Surveys will be conducted as described in 

Section 2.5 and would assess the effectiveness of weed control and seeding measures. 

Species, relative density, and location will be surveyed and compared to pre-construction and 

previous years’ data. This information will also be used to develop the weed control treatment 

plan for the following year. 

5.1 Monitoring Activities 

Successful re-vegetation will be determined by monitoring reclaimed areas against existing 

conditions. Species and relative density will be assessed annually and will be compared to 

baseline data collected prior to the start of ground disturbing activities. Reclamation will be 

determined successful if the seeded areas have germinated and are demonstrating that they 

will, over time, achieve a distribution and diversity similar to pre-construction conditions. If, after 

a second growing season, problem areas have been identified (e.g., seed germination is lower 

than expected; prevalence of noxious weed species), the area will be treated and re-seeded. 

Treatment may include additional seedbed preparation, control of noxious weeds, use of soil 

amendments, and/or use of another appropriate seed mix. Monitoring of reclamation activities 

and remedial measures on private lands will be up to the landowner and agreements they 

negotiate with the Proponents. 

5.2 Reporting 

The Proponents will document pre-construction observations, construction reclamation 

activities, and post-construction monitoring on federally and state managed lands in an annual 

report. Monitoring on private lands will be as agreed with the landowner. Annual reports would 

be prepared for submittal to federal or state entities that administer public lands in the Project 

area. The reports will provide a summary of project reclamation activities and observations, and 

include recommendations for additional corrective actions, if necessary. 

6.0 STORMWATER POLLUTION PREVENTION PLANS 

SWPPPs will be completed for the project in accordance with federal and state construction 

stormwater requirements. The SWPPPs will include erosion and sediment control BMPs that 

are also relevant to reclamation. The SWPPPs will be prepared as standalone documents and 

are incorporated by reference to this document and the final Reclamation Plan. 

7.0 PLAN UPDATES 

Once the proposed route is selected and final engineering is completed a final Reclamation 

Plan will be prepared. The final Reclamation Plan will be updated prior to the start of 

construction on each of the proposed 10 segments. As the Proponents better define the 

construction order for segments and the segment-specific construction schedule, the final 

Reclamation Plan will be updated to include the schedule for baseline vegetation and weed 
Framework Reclamation Plan Appendix C-2

October 2010 Page 10 

surveys, results of previous baseline surveys, identification of any areas for pre-construction 

noxious weed treatment, and a more detailed reclamation schedule and plan. 

8.0 LITERATURE CITED 

Idaho State Department of Agriculture. 2008. Idaho’s Official Noxious Weeds. Idaho Department 

of Agriculture in partnership with Idaho Weed Superintendents Association, Idaho Weed 

Coordinating Committee, Idaho Weed Awareness Campaign, and Idaho Weed Control 

Association. 115 pp. Available online at 

http://www.idahoag.us/Categories/PlantsInsects/NoxiousWeeds/watchlist.php 

National Invasive Species Information Center. 2008. Invasive Species. Available online at 

http://alic.arid.arizona.edu/invasive/sub2/index.shtml 

Sheley, R.L. and J.K. Petroff. 1999. Biology and Management of Noxious Rangeland Weeds. 

Oregon State University. Corvallis, Oregon. 

Sheley, R.L., Mangold, J., Goodwin, K., and J. Marks. 2008. Revegetation Guidelines for the 

Great Basin: Considering Invasive Weeds. USDA, Agricultural Research Service, 

Washington, D.C., No. ARS-168. 

USDA Forest Service 1990. FSM Chapter 2840 – Reclamation. Available online at 

http://www.fs.fed.us/im/directives/fsm/2800/2840.txthttp://www.fs.fed.us/im/directives/fsm

/2800/2840.txt

Wyoming Bureau of Land Management (BLM) Reclamation Policy, Instruction Memorandum 

No. WY-2009-022. Available online at 

http://www.blm.gov/pgdata/etc/medialib/blm/wy/resources/efoia/IMs/2009.Par.54664.File

.dat/wy2009-

022.pdfhttp://www.blm.gov/pgdata/etc/medialib/blm/wy/resources/efoia/IMs/2009.Par.54

664.File.dat/wy2009-022.pdf

Wyoming Weed and Pest. 2008a. Wyoming Weed and Pest Control Designated List. Available 

online at 

http://www.wyoweed.org/Documents/DocumentPage/WYOMINGWEEDList.pdf

Wyoming Weed and Pest. 2008b. Declared List of Weeds and Pests: Wyoming Weed and Pest 

Control Act of 1973. 
   

ATTACHMENT A 

INVASIVE AND NOXIOUS 

PLANTS IN PROJECT AREA
Attachment A. Invasive and Noxious Plant Species Potentially Present in the Gateway West Project Ana

Common Name Scientific Name 

Invasive 

exotic 

species1

Listed as Noxious2 Segmen

L

State of 

Wyoming 

(Designated) 

Wyoming 

Counties 

(Declared) 

State of Idaho4 Wyomi

Species on Wyoming or Idaho Noxious Weed List 

Black henbane Hyoscyamus niger 

Yes -- 

Albany, 

Converse, 

Lincoln, 

Natrona, 

Sweetwater 

Control All 

Buffalobur Solanum rostratum Yes -- Converse, Natrona Control All Canada thistle Cirsium arvense Yes X Containment All Common burdock Arctium minus Yes X -- -- 1E, 1W, Common St. Johnswort 

Hypericum perforatum Yes X -- -- 4 

Common Tansy Tanacetum vulgare Yes X -- -- All Dalmatian toadflax 

Linaria dalmatica Yes X -- Containment All 

Diffuse knapweed 

Centaurea diffusa Yes X -- Containment All 

Dyer’s woad Isatis tinctoria Yes X -- Control All Eurasian watermilfoil 

Myriophyllum spicatum Yes -- -- Control -- 

Field bindweed Convolvulus 

arvensis Yes X -- Containment All 

Hairy whitetop, Hoary cress 

Cardaria pubescens Yes X -- -- All 

Houndstongue Cynoglossum 

officinale Yes X -- Containment 1E, 1W, 
Attachment A. Invasive and Noxious Plant Species Potentially Present in the Gateway West Project Ana

Common Name Scientific Name 

Invasive 

exotic 

species1

Listed as Noxious2 Segmen

L

State of 

Wyoming 

(Designated) 

Wyoming 

Counties 

(Declared) 

State of Idaho4 Wyomi

Johnsongrass Sorghum 

halepense Yes -- -- Control -- 

Jointed goatgrass Aegilops cylindrica Yes -- Converse Containment 1E, 1W Leafy spurge Euphorbia esula Yes X -- Containment All Matgrass Nardus stricta Yes -- -- Control -- Musk thistle Carduus nutans Yes X -- Control All Orange hawkweed 

Hieracium aurantiacum Yes -- Converse Control -- 

Oxeye daisy Chrysanthemum 

leucanthemum Yes X -- Containment 1E, 1W, 

Perennial pepperweed 

Lepidium lapathifolium Yes X -- Containment All 

Perennial sowthistle 

Sonchus arvensis Yes X -- Control All 

Meadow hawkweed, yellow hawkweed 

Hieracium pretense, H. caespitosum 

Yes -- -- Control -- 

Plumeless thistle Carduus 

acanthoides Yes X -- Control 1E, 1W 

Poison hemlock Conium maculatum Yes -- -- Containment 1E, 1W, Puncture vine Tribulus terrestris Yes -- Natrona Containment 1E, 1WPurple loosestrife Lythrum salicaria Yes X -- Containment -- Quackgrass Agropyron repens Yes X -- -- All 
Attachment A. Invasive and Noxious Plant Species Potentially Present in the Gateway West Project Ana

Common Name Scientific Name 

Invasive 

exotic 

species1

Listed as Noxious2 Segmen

L

State of 

Wyoming 

(Designated) 

Wyoming 

Counties 

(Declared) 

State of Idaho4 Wyomi

Rush skeletonweed Chondrilla juncea Yes -- Converse Containment -- Russian knapweed Acroptilon repens Yes X -- Control All Russian olive Elaeagnus angustifolia Yes X -- -- 1E, 1W Salt cedar, tamarisk Tamarix spp. Yes X -- Containment All Scotch broom Cytisus scoparius Yes -- Converse Control -- Scotch thistle Onopordum acanthium Yes X -- Containment 1E, 1WSkeletonleaf bursage 

Artemisia tomentosa Yes X -- Control All 

Spotted knapweed 

Centaurea maculosa Yes X -- Containment All 

Silverleaf nightshade 

Solanum Elaeagnifolium Yes -- -- Control -- 

Syrian beancaper Zygophyllum zabago Yes -- Converse EDRR -- Tansy ragwort Senecio jacobaea Yes -- Converse Containment -- Vipers blugloss Echium vulgare Yes -- -- Control -- Whitetop, hoary cress 

Cardaria draba Yes X -- Containment 1E, 1W, 

Yellow starthistle Centaurea solstitialis Yes -- -- Containment -- Yellow toadflax Linaria vulgaris Yes X -- Containment 1E, 1W, 
Attachment A. Invasive and Noxious Plant Species Potentially Present in the Gateway West Project Ana

Common Name Scientific Name 

Invasive 

exotic 

species1

Listed as Noxious2 Segmen

L

State of 

Wyoming 

(Designated) 

Wyoming 

Counties 

(Declared) 

State of Idaho4 Wyomi

Other Species 

Absinth wormwood 

Artemisia absinthium Yes -- Converse -- 1E, 1W 

Baby’s breath Gypsophila paniculata Yes -- Converse -- -- Bull thistle Cirsium vulgare Yes -- Converse, Lincoln -- All Bur buttercup Ranunculus testiculatus Yes -- Converse -- All Cheatgrass/downy brome Bromus tectorum Yes -- Albany, Natrona -- All Chicory Cichorium intybus Yes -- Converse -- 1E, 1W Common cocklebur 

Xanthium strumarium Yes -- Converse -- All 

Common crupina Crupina vulgaris Yes -- Converse -- -- Common mullein Verbascum 

thapsus Yes -- Converse -- All 

Common sunflower Helianthus annuus Native -- Converse -- 1E, 1W Curlycup gumweed Grindelia squarrosa Native -- Natrona -- 1W Curly dock Rumex crispus Yes -- Converse -- All Dames rocket Hersperis matronalis Yes Converse -- 1E, 1W, Foxtail barley Hordium jubatum Native -- Sweetwater -- 3, 4 Geyer larkspur Delphinium geyeri Native -- Albany, Carbon -- 1E, 1W, 
Attachment A. Invasive and Noxious Plant Species Potentially Present in the Gateway West Project Ana

Common Name Scientific Name 

Invasive 

exotic 

species1

Listed as Noxious2 Segmen

L

State of 

Wyoming 

(Designated) 

Wyoming 

Counties 

(Declared) 

State of Idaho4 Wyomi

Goatsrue Galega officinalis Yes -- Converse -- -- Gorse Ulex europaeus Yes -- Converse -- -- Halogeton Halogeton glomeratus Yes -- Carbon, Converse, Natrona, -- All Iberian starthistle Centaurea iberica Yes -- Converse -- 1E, 1W Italian thistle Carduus pycnocephalus Yes -- Converse -- -- Japanese brome Bromus japonicus Yes -- -- -- All Lady’s bedstraw Galium verum Yes -- Converse -- 2, 3, 4 Locoweed Oxytropis spp. Native -- Albany -- 1E Meadow knapweed 

Centaurea nigrescens Yes -- Converse -- -- 

Medusahead Taeniatherum caput-medusae Yes -- Converse -- -- Mountain thermopsis 

Thermopsis montana Native -- Sweetwater -- 3, 4 

Musk mustard, blue mustard Chorispora tenella Yes -- Converse -- All Plains pricklypear Opuntia polyacantha Native -- Carbon -- 1E, 1W, Redstem filaree Erodium cicutarium Yes -- -- -- 1E Russian thistle Salsola iberica Yes -- -- -- All 
Attachment A. Invasive and Noxious Plant Species Potentially Present in the Gateway West Project Ana

Common Name Scientific Name 

Invasive 

exotic 

species1

Listed as Noxious2 Segmen

L

State of 

Wyoming 

(Designated) 

Wyoming 

Counties 

(Declared) State of Idaho4 Wyomi

Sandbur Cenchrus incertus Native -- Converse -- -- Scentless chamomile 

Tripleurospermum inodorum Yes -- Converse -- All 

Showy milkweed Asclepias speciosa Native -- Converse -- 1E, 1W Squarrose knapweed Centaurea virgata Yes -- Converse -- -- Sulfur cinquefoil Potentilla recta Yes -- Converse -- -- Teasel Dipsacus fullonum Yes -- Converse -- Wild licorice Glycyrrhiza lepidota Native -- Converse, Natrona -- 1E, 1W Wild oats Avena fatua Yes -- Lincoln -- All Wyeth’s lupine Lupinus wyethii Native -- Converse -- 1E, 1W 1 Included in Invaders database (University of Montana-Missoula 2009). 2 Source for status: ISDA 2008, Wyoming Weed and Pest 2008. ”—“means not listed. 3 Distribution based on Invaders database (University of Montana-Missoula 2009), Plants database (NRCS 2009), and Idaho State Depa

Distribution of native species is only shown for Wyoming counties where listed as noxious. 

4 Idaho listing categories are explained in text. 
   

ATTACHMENT B 

SPECIES ABUNDANCE RATINGS
   

ABUNDANCE RATINGS: 

Rare: 

Difficult to find; limited to one or very few individuals or colonies; < 1% of the total sample unit 

area; found in more than one place along the sample unit. 

Locally Rare: 

Difficult to find; limited to one or very few individuals or colonies; < 1% of the total sample unit 

area; found at only one site within the sample unit. 

Occasional: 

Widely scattered individuals or colonies, but not difficult to find; 1–5% of the total sample unit 

area; found in more than two sites within the sample unit. 

Locally Occasional: 

Scattered individuals or colonies, but not difficult to find; 1–5% of the total sample unit area; 

found in only one or two sites within the sample unit. 

Frequent: 

Easily found, but not dominant in any one place; 5–25% of the total sample unit area; a 

moderate number of occurrences over a good portion of the sample unit. 

Locally Frequent: 

Easily found, but not dominant in any one place; 5–25% of the total sample unit area; a 

moderate number of occurrences over a small portion of the sample unit. 

Abundant: 

Easily found; dominant or codominant in one or more areas; > 25% of the total sample unit; a 

high number of occurrences over most of the sample unit. 

Locally Abundant: 

Easily found; dominant or codominant in one or more areas; > 25% of the total sample unit; a 

high number of occurrences over a small portion of the sample unit. 
Gateway West Transmission Line Draft EIS 

Appendix C-3 

Revised Proposed Plant and Wildlife Conservation Plan – 

Construction Activities 

(submitted to BLM by Idaho Power and Rocky Mountain Power 

October 2010) 
Appendix C-3 

Revised Proposed Plant and Wildlife 

Conservation Plan – Construction Activities 

Gateway West Transmission Line Project 

Prepared by: 

Idaho Power Company 

1221 West Idaho Street 

Boise, ID 83702 

and 

Rocky Mountain Power 

1407 W North Temple 

Salt Lake City, UT 84116 

October 2010
TABLE OF CONTENTS 

1.0 INTRODUCTION .................................................................................................. 1

1.1 PURPOSE OF THE PLAN ................................................................................... 1

1.2 CONTENTS OF THE PLAN ................................................................................. 1

2.0 PROJECT CONSTRUCTION, OPERATION, AND MAINTENANCE ................... 2

2.1 PROJECT COMPONENTS .................................................................................. 2

2.1.1 Construction ..................................................................................... 2

2.1.2 Operation and Maintenance ............................................................. 3

3.0 SPECIES CONSIDERED FOR THE PLAN .......................................................... 4

4.0 DEVELOPMENT OF CONSERVATION PLAN ..................................................... 7

4.1 AVOIDANCE AND MINIMIZATION DEVELOPMENT AND IMPLEMENTATION ................. 7

4.1.1 Proposed Corridor Routing and Substation Siting ............................ 7

4.1.2 Planned Right-of-Way Refinement ................................................... 8

4.1.3 Construction Scheduling and Monitoring .......................................... 9

4.2 DEVELOPMENT OF CONSERVATION MEASURES ................................................. 9

4.2.1 Land Management Plans ................................................................ 11

4.2.2 Stipulation Selection ....................................................................... 11

4.2.3 Land Ownership ............................................................................. 11

4.2.4 Species-Specific and Site-Specific Variation .................................. 12

5.0 PROPOSED PLANT AND WILDLIFE CONSERVATION PLAN ......................... 12

6.0 LITERATURE CITED ......................................................................................... 21

LIST OF TABLES 

Table 1 Species Protected in the Gateway West Species Conservation Plan ........................... 4 

Table 2 Land Management Plans for the Gateway West Project ............................................. 10 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 1 

1.0 INTRODUCTION 

This document presents the plan proposed by Idaho Power and Rocky Mountain Power (the 

Proponents) for avoidance and minimization of impacts to special status plant and wildlife 

species as related to construction activities for the Gateway West Transmission Line Project 

(the Project). This plan summarizes the avoidance and minimization conducted during siting 

and routing of the Project components and outlines specific conservation measures to be 

implemented in the event that state or Federally listed species, Bureau of Land Management 

(BLM) sensitive species, or Forest Service special status species or their habitats are identified 

within or adjacent to the Project right-of-way (ROW). The Proponents will prepare and submit a 

separate plan that addresses avoidance and minimization measures related to operation and 

maintenance activities and emergency activities. 

1.1 Purpose of the Plan 

The objectives of this plan are to recognize the substantial effort already invested by the 

Proponents in avoiding and minimizing impacts on special status plant and wildlife species, and 

in addition, to present a comprehensive, Project-specific plant and wildlife conservation plan 

that: 

• Addresses avoidance and minimization of impacts to special status plant and wildlife 

species; 

• Provide consistency across jurisdictions; 

• Meet the intent of the current BLM and Forest Service management guidance for 

Federal lands; and 

• Balance cost, practicality, and feasibility of Project implementation with avoiding or 

minimizing environmental impacts. 

1.2 Contents of the Plan 

The components of this plan include: 

• Section 2: Brief background on the proposed transmission line and substation 

construction, operation and maintenance, and emergency response procedures (a 

complete description can be found in the August 2008 Gateway West Transmission 

Line Project Revised Plan of Development (POD), of which this plan is a part); 

• Section 3: A list of the special status species that the Proponents and the agencies 

(BLM, Forest Service, U.S. Fish and Wildlife Service (USFWS), Idaho Department of 

Fish and Game (IDFG), and Wyoming Game and Fish Department (WGFD)) have 

identified as occurring or potentially occurring within the Project area, and 

explanations as to how the proposed measures are appropriate and will meet the 

intent of the BLM and Forest Service land management plan restrictions; 

• Section 4: A summary of the avoidance and minimization measures used by the 

Proponents, in conjunction with the Agencies, during corridor and ROW routing and 

substation siting, and the assumptions made during that process; and 

• Section 5: This section is the heart of the plan that would be implemented after all 

reasonable avoidance and minimization measures were imposed during routing and 

siting. It includes the temporal and spatial restrictions the Proponents propose to 

implement to avoid or minimize direct impacts to special status species, together with 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 2 

the conditions under which the Proponents propose that restrictions could be limited 

or lifted, which includes the methods the Proponents propose to use to determine 

where and when the measures will apply across the project. 

2.0 PROJECT CONSTRUCTION, OPERATION, AND MAINTENANCE 

2.1 Project Components 

The proposed Project, as described in the August 2008 Gateway West Transmission Line 

Project Revised POD and the September 2008 Gateway West Transmission Line Project Siting 

Study (Idaho Power and Rocky Mountain Power, 2008), includes the following major 

components: 

• A total of 1,148 miles of transmission lines and associated support structures will be 

constructed, along with 71 miles to be re-conductored. Of this total: 

o Approximately 230 miles (1,265 support structures) will be single-circuit 230 

kilovolt (kV) steel H-frame structures between 60 and 90 feet tall with a 700-

foot average distance between structures; and 

o Approximately 918 miles (3,893 support structures) will be either single-circuit 

500kV lattice steel structures between 145 and 180 feet tall with a 1,200 to 

1,300-foot average distance between structures, or double-circuit 500kV 

lattice structures between 160 and 190 feet tall with a 1,200 to 1,300-foot 

average distance between structures. 

• Nine substations, including three proposed new Project-specific substations, four 

substations that are planned for construction for other projects and that will be 

expanded for this Project, and two existing substations that will be expanded for this 

Project; and 

• Ancillary facilities such as construction and permanent access roads, temporary 

construction staging areas, communications, power supply to new substations, and 

other similar facilities. 

• The Proponents propose to acquire a permanent ROW up to 300 feet wide for 

construction and operation of the double-circuit sections of the Project, a 250-footwide ROW for the 500kV single-circuit sections of the Project, and a 125-foot-wide 

ROW for the 230kV single-circuit sections of the Project. 

The POD (Idaho Power and Rocky Mountain Power, 2008) details the construction, operation, 

maintenance, and emergency response procedures that will be implemented during the course 

of the Project. The following section details the major aspects of the aforementioned 

components of the Project where conservation measures may be required to assess and avoid 

or minimize potential impacts to special status plant and wildlife species. 

2.1.1 Construction 

Various construction activities will occur during the construction process, with multiple 

construction crews operating simultaneously at different locations. The following key sections 

are described in detail in the POD: 

• Staging areas associated with development of the transmission line 

• On and off ROW access roads 

• Transmission line construction 

o Site access and preparation 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 3 

o Soil Boring 

o Structure foundation installation 

o Support structure erection 

o Stringing of conductors, shield wire, and fiber optic ground wire 

o Communications facilities (regeneration sites) 

o Cleanup and site reclamation 

• Substation construction 

o Access roads 

o Soil boring 

o Clearing and grading 

o Fencing 

o Foundation installation 

o Structure and equipment erection/installation 

o Landscaping and construction cleanup 

o Storage and staging yards 

• Special construction techniques 

o Blasting 

o Helicopter construction 

o Temporary water use during construction 

• Construction workforce 

• Construction equipment and traffic 

• Removal of facilities and waste disposal 

• Construction schedule 

2.1.2 Operation and Maintenance 

The Proponents have prepared internal operation and maintenance policies and procedures 

designed to meet the requirements of the North American Electrical Reliability Corporation 

(NERC), Western Electricity Coordinating Council (WECC), and the state public utility/service 

commissions (PUCs), while remaining in compliance with the applicable codes and standards 

with respect to maintaining the reliability of the electrical system 

Operation and maintenance activities will include transmission line patrols, climbing inspections, 

tower and wire maintenance, insulator washing in selected areas as needed, and access and 

service road repairs. Periodic inspection and maintenance is also a key part of operating and 

maintaining the electrical system. The following key sections are described in detail in the POD: 

• Routine system inspection, maintenance, and repair 

o Transmission line maintenance 

o Hardware maintenance and repairs 

o Right-of-way repair 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 4 

o Vegetation management 

• Substation and regeneration site maintenance 

In order to meet requirements by NERC and WECC regarding reliability, rigorous operation and 

maintenance activities need to be conducted. A plan to address wildlife conservation measures 

during operation and maintenance as well as during emergency response has been prepared 

under separate cover (Gateway West Transmission Line Project - Proposed Plant and Wildlife 

Conservation Plan – Operations and Maintenance and Emergency Response). 

3.0 SPECIES CONSIDERED FOR THE PLAN 

The following steps were taken to determine which species and habitats needed to be 

considered for avoidance, minimization, and conservation measures. The Proponents: 

• Identified potential habitats and special status species that may occur along the 

proposed corridor using available data from Federal and state wildlife agencies and 

from the BLM and Forest Service; 

• Discussed habitat types and special status species at kickoff meetings with agency 

resource specialists to identify which species are of greatest concern in the Project 

area; and 

• Refined the list of species and habitats to be addressed in Project plans through 

several subsequent meetings with state and Federal agency resource specialists. 

Table 1 presents the special status species that were discussed during the screening process 

described above. This list of species identifies those to be addressed in the Biological 

Assessment (BA) or Biological Evaluation (BE) and those that are to be emphasized in other 

Project documents. Note that some species appear on this table because a local field office or 

ranger district or concurrence at the Level 1 meetings requested their inclusion in the BA for 

completeness, but they are not addressed further in this conservation plan because they are not 

expected to be adversely affected by the Project due to lack of occurrence in the Project area, 

lack of direct impact to the species or its habitats from the Project, or a low level of anticipated 

impact at the population level. Also note that other species that are not listed in this table will be 

analyzed in other Project documents but are not addressed further in this conservation plan 

because they were not identified as primary concerns for the Project. 

Table 1 

Species Protected in the Gateway West Species Conservation Plan 

Species Regulatory Status within 

Project Area Analysis Included in Conservation Plan? 

Big Game

Antelope (Antilocapra

americana) None EIS Yes 

Bighorn sheep (Ovis canadensis) None EIS Yes 

Elk (Cervus elaphus) None EIS Yes 

Moose (Alces alces) None EIS Yes 

Mule deer (Odocoileus 

hemionus) None EIS Yes 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 5 

Table 1 

Species Protected in the Gateway West Species Conservation Plan 

Species Regulatory Status within 

Project Area Analysis Included in Conservation Plan? 

Other Mammals

Black-footed ferret (Mustela

nigripes) 

USFWS WY Endangered; 

USFWS Shirley Basin 

experimental population 

WY 

BA and EIS Yes 

Black-tailed prairie dog 

(Cynomys ludovicianus) 

USFWS removed as 

Candidate BA and EIS No 

Canada lynx (Lynx canadensis) USFWS WY and ID 

Threatened BA and EIS No 

Gray wolf (Canis lupus) USFWS WY and ID Delisted and Petitioned BA and EIS No 

Northern Idaho ground squirrel 

(Spermophilus brunneus) USFWS ID Threatened BA and EIS No 

Preble’s meadow jumping mouse 

(Zapus hudsonius preblei) USFWS WY De-listed 2008 BA and EIS No 

Pygmy rabbit (Brachylagus 

idahoensis) 

USFWS WY and ID 

Petitioned; WY BLM 

Sensitive; ID BLM 

Sensitive; ID USFS 

Sensitive 

BA and EIS Yes 

Southern Idaho ground squirrel 

(Spermophilus brunneus) USFWS ID Candidate BA and EIS No 

White-tailed prairie dog 

(Cynomys leucurus) 

USFWS WY Petitioned; WY 

BLM Sensitive BA and EIS Yes 

Wolverine (Gulo gulo) WY USFS Sensitive; ID 

USFS Sensitive 

BE and 

EIS No 

Wyoming pocket gopher 

(Thomomys clusius) 

USFWS WY Petitioned; WY 

BLM Sensitive BA and EIS No 

Raptors

Bald eagle (Haliaeetus 

leucocephalus) 

USFWS De-listed WY and 

ID 2007; MBTA; BGEPA EIS Yes 

Burrowing owl (Athene 

cunicularia) WY BLM Sensitive; MBTA BE and EIS Yes 

Ferruginous hawk (Buteo regalis) 

WY BLM Sensitive; WY 

USFS Sensitive; ID BLM 

Sensitive; MBTA 

BE and EIS Yes 

Flammulated owl (Otus 

flammeolus) 

WY USFS Sensitive; ID 

BLM Sensitive; ID USFS 

Sensitive; MBTA 

BE and EIS Yes 

Golden eagle (Aquila

chrysaetos) MBTA; BGEPA EIS Yes 

Northern goshawk (Accipiter 

gentilis) 

WY BLM Sensitive; WY 

USFS Sensitive; WY USFS 

MIS; ID BLM Sensitive; ID 

USFS Sensitive; MBTA 

BE and EIS Yes 

All other raptors MBTA EIS Yes 

Other Avian
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 6 

Table 1 

Species Protected in the Gateway West Species Conservation Plan 

Species Regulatory Status within 

Project Area Analysis Included in Conservation Plan? 

Columbian sharp-tailed grouse 

(Tympanuchus phasianellus 

columbianus) 

WY BLM Sensitive; WY 

USFS Sensitive; ID BLM 

Sensitive; ID USFS 

Sensitive 

BA and EIS No 

Greater sage grouse 

(Centrocercus urophasianus) 

USFWS WY and ID 

Petitioned; WY BLM 

Sensitive; WY USFS 

Sensitive; ID BLM 

Sensitive; ID USFS 

Sensitive 

BA and EIS Yes 

Greater sandhill crane (Grus

canadensis) MBTA EIS Yes 

Long-billed curlew (Numenius 

americanus) MBTA EIS Yes 

Mountain plover (Charadrius 

montanus) WY BLM Sensitive; MBTA BE and EIS Yes 

Mountain quail (Oreortyx pictus) ID BLM Sensitive BE and EIS No 

Three-toed woodpecker 

(Picoides dorsalis) ID USFS Sensitive; MBTA BE and EIS Yes 

Western yellow-billed cuckoo 

(Coccyzus americanus) 

USFWS Candidate WY and 

ID; WY BLM Sensitive; 

MBTA 

BA and EIS No 

Amphibians

Boreal toad (Bufo boreas 

boreas) 

WY BLM Sensitive; ID BLM 

Sensitive BE and EIS No 

Columbia spotted frog (Rana 

luteiventris) 

USFWS WY and ID 

Candidate BA and EIS No 

Great Basin spadefoot toad 

(Spea intermontana) WY BLM Sensitive BE and EIS No 

Northern leopard frog (Rana 

pipiens) 

USFWS WY Petitioned; WY 

BLM Sensitive; WY USFS 

Sensitive; ID BLM 

Sensitive; ID USFS 

Sensitive 

BA and EIS No 

Wyoming toad (Bufo hemiophrys 

baxteri) USFWS WY Endangered BA and EIS No 

Fish

Bonneville cutthroat trout 

(Oncorhynchus clarki utah) 

USFWS WY and ID 

Petitioned BA and EIS No 

Bonytail (Gila elegans) USFWS Endangered BA and EIS No 

Bull trout (Salvelinus 

confluentus) USFWS ID Threatened BA and EIS No 

Colorado pikeminnow 

(Ptychocheilus lucius) USFWS Endangered BA and EIS No 

Humpback chub (Gila cypha) USFWS Endangered BA and EIS No 

Pallid sturgeon (Scaphirhynchus 

albus) USFWS Endangered BA and EIS No 

Razorback sucker (Xyrauchen 

texanus) USFWS Endangered BA and EIS No 

Invertebrates

Bruneau Hot springsnail 

(Pyrgulopsis bruneauensis)

USFWS Endangered; ID 

BLM Sensitive BA and EIS No 

Idaho springsnail (Pyrgulopsis 

idahoensis)

USFWS ID De-listed; ID 

BLM Sensitive BA and EIS No 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 7 

Table 1 

Species Protected in the Gateway West Species Conservation Plan 

Species Regulatory Status within 

Project Area Analysis Included in Conservation Plan? 

Plants

Blowout penstemon (Penstemon

haydenii) USFWS WY Endangered BA and EIS Yes 

Colorado butterfly plant (Gaura 

neomexicana coloradensis) USFWS WY Threatened BA and EIS Yes 

Desert yellowhead (Yermo 

xanthocephalus) USFWS WY Threatened BA and EIS No 

Goose Creek milkvetch 

(Astragalus anserinus) USFWS ID Petitioned EIS No 

Slickspot peppergrass (Lepidium 

pappileferum) USFWS ID Threatened BA and EIS Yes 

Ute ladies’-tresses orchid 

(Spiranthes diluvialis) USFWS Threatened WY BA and EIS Yes 

Notes: 

BA = Biological Assessment 

BE = Biological Evaluation 

BGEPA = Bald and Golden Eagle Protection Act 

EIS = Environmental Impact Statement 

ID = Idaho 

MBTA = Migratory Bird Treaty Act 

WY = Wyoming 

USFS = U. S. Forest Service 

MIS = Management Indicator Species 

4.0 DEVELOPMENT OF CONSERVATION PLAN 

This section explains how the Proponents approached avoidance and minimization of impacts 

through data collection and careful routing and siting of the proposed facilities. 

4.1 Avoidance and Minimization Development and Implementation 

This section presents the data collection and analysis that have been and will be employed for 

the various stages of Project development. The stages of Project development addressed 

include the proposed corridor routing process, the proposed ROW routing process, the 

construction scheduling, operation and maintenance, and emergency response. 

4.1.1 Proposed Corridor Routing and Substation Siting 

Corridor evaluation was conducted in two phases. In the initial phase, the Proponents reviewed 

maps of the area to identify significant constraints and opportunities for selecting corridors 

between the proposed, planned and existing substations between the planned Windstar 

Substation near Casper, Wyoming and the proposed Hemingway Substation in Owyhee County, 

Idaho. Constraints included a wide array of natural resources and man-made features such as 

the Oregon Trail, sage grouse leks, airports, urban areas, rural residences, agricultural features 

(center pivot irrigation, feedlots, dairies), visual resource management areas (VRMs), areas of 

critical environmental concern (ACECs), National Monuments and National Wildlife Refuges 

(NWR). Opportunities include existing transmission corridors, West-wide Energy (WWE) 

corridors, pipelines, a USFS utility corridor, and railroads. Using these factors, the Proponents 

selected a proposed general corridor and then conducted a detailed evaluation of constraints to 

identify a proposed and alternate corridor between the above-referenced points of 

interconnection. 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 8 

Corridors were identified with the goals of maximizing the use of opportunities and minimizing 

crossings of areas with higher-level constraints. This step took into account corridors defined by 

existing transmission lines and other linear facilities as well as any additional corridors identified 

to date by the BLM, the Proponents, and the WWE Corridor study. The Proponents evaluated 

each corridor for a variety of environmental and engineering factors to identify the proposed and 

alternate corridors. This approach included development and use of an attribute matrix, which 

established the relative importance of each attribute and, as appropriate, analysis tools. 

Analysis tools included GIS-based routing and weighting, aerial photography, topographic 

maps, and limited field reconnaissance. The proposed and alternative corridors were then 

presented at BLM sponsored scoping meetings. Following scoping, BLM Field Offices reviewed 

proposed and alternative routes to determine which should be carried forward for detailed 

analysis in the EIS. 

Specifically, the Proponents acquired geographic information system (GIS) data and qualitative 

input from the USFWS, BLM, Forest Service, IDFG, and WGFD regarding known and potential 

locations of special status species and their habitats in the Project area. These data were used 

to develop the list of special status species of concern in the Project area. 

At the request of these agencies, the Proponents conducted additional data collection in 2008 to 

fill certain data gaps in the Project area, including a sage grouse lek survey, a raptor nesting 

survey, and detailed habitat mapping. 

The datasets described above were used during routing of the proposed corridor and substation 

siting. Certain plant and wildlife resources were identified as constraints to be avoided, 

including: 

• A 0.25-mile “no surface occupancy” buffer of all greater sage-grouse leks, regardless 

of recent occupancy, was entirely avoided during routing; 

• A 0.65-mile buffer of greater sage-grouse leks was avoided unless there was a 

compelling reason not to (e.g., a non-wildlife resource such as a home to be 

avoided); 

• A 0.50-mile buffer of raptor nests was avoided unless there was a compelling reason 

not to (e.g., a non-wildlife resource to be avoided); and 

• Special management areas established for the protection of plant or wildlife species 

were avoided, where possible. 

Other plant and wildlife resources (such as big game winter range and calving and fawning 

areas) were not necessarily avoided during routing and siting but were considered a constraint 

and were taken into consideration during design of the proposed Project. Additionally, proximity 

of the corridor to urban areas, agricultural areas and rural residences were taken into 

consideration during the routing and siting. 

 

The proposed and alternative routes are presented in the September 2008 Gateway West 

Transmission Line Project Siting Study (Idaho Power and Rocky Mountain Power, 2008), and 

Supplement Siting memo dated October 23, 2008. As site-specific environmental and 

engineering analyses are conducted along these routes, the proposed transmission line ROW 

will be refined to further avoid resources or minimize impacts upon them. 

4.1.2 Planned Right-of-Way Refinement 

The Proponents are conducting a comprehensive Project-wide habitat mapping effort that 

identifies habitats in the Project area and assesses the quality of those habitats for selected 

special status species. The habitat mapping is comprised of two field components: aerial 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 9 

photography acquisition and field verification. Based on the results of the habitat mapping, the 

Proponents will identify areas within the corridor where species-specific surveys may be 

necessary to either inform ROW refinement or specify where and when conservation measures 

apply. 

Based on preliminary evaluation of the habitat mapping, the Proponents may conduct where 

necessary, surveys prior to construction and in the appropriate season to meet agency survey 

and timing requirements for the following species: 

• Black-footed ferret; 

• Pygmy rabbit; 

• White-tailed prairie dog; and 

• Special status plants. 

In addition to the avoidance and minimization accomplished through routing, the Proponents 

have developed additional conservation measures, which are presented in this conservation 

plan and the POD. Some involve seasonal restrictions on construction, discussed in general in 

Section 4.1.3 and detailed by species in Section 5. Many of the measures detailed in Section 5 

require preconstruction surveys to determine if and when they apply. 

4.1.3 Construction Scheduling and Monitoring 

Avoidance can be geographic and/or temporal. Where disturbance during construction is of 

concern, construction is proposed to be limited to periods of species absence or reduced 

presence. In addition to limited operating seasons, which categorically restrict construction, 

environmental monitoring is also proposed where construction may be permitted but its 

conformance with minimization measures should be monitored and enforced. 

Environmental oversight will be conducted for construction activities. Monitoring entails being 

present during these activities, communicating with contractors, taking daily notes, ensuring that 

all impacts occur within the designated limits, ensuring that the requirements of the Project 

Environmental Protection Measures (EPMs) that the Proponents have incorporated as part of 

the Project are being met, and using best professional judgment to ensure that Project activities 

do not adversely affect special status plant and wildlife species. A biological monitor has the 

authority to issue stop work where agreed conditions protecting wildlife or plant species are 

being violated by the construction contractor. A biological monitor will work with the 

construction contractor, the regulatory agencies, and the Proponents to resolve noncompliances. The details of the Proponents environmental compliance program including roles 

and responsibilities, preconstruction surveys, monitoring and reporting will be detailed in the 

construction POD. 

4.2 Development of Conservation Measures 

After taking into consideration wildlife and plant resources as well as other important resources 

during siting and routing, the Proponents recognized the need for additional measures to 

minimize the impact from construction of the Project. The Proponents used the following steps 

to develop the measures found in Section 5: 

• Identified and reviewed the BLM and Forest Service land management plans 

applicable to the Project area (Table 2); 

• For each land management plan, recorded the surface use stipulations specific to 

each species of concern; 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 10 

• Provided to BLM and Forest Service resource specialists for their review a list of 

stipulations compiled from their jurisdiction; 

• Incorporated BLM and Forest Service comments, which included clarifications and 

updates to stipulations provided in the land management plans; 

• Distinguished between requirements and standards versus guidelines, 

recommendations, and BMPs; 

• Distinguished between measures designed to avoid or minimize direct impacts to 

individuals and those designed for habitat management; 

• Identified inconsistencies in requirements among jurisdictions; 

• Determined exception or waiver criteria, if applicable; 

• Identified data gaps, by species and by jurisdiction; and 

• Evaluated the stipulations on a resource by resource basis and developed the 

proposed Project-wide temporal and spatial restrictions and exception criteria. 

Table 2 

Land Management Plans for the Gateway West Project

Jurisdiction Plan Name Plan Date/Status 

Wyoming 

Casper BLM Field Office (FO) Casper Resource 

Management Plan (RMP) 2007 

Medicine Bow National Forest (NF) 

Medicine Bow NF 

Revised Land and 

Resource Management 

Plan 

2003 

Rawlins BLM FO Rawlins RMP 2008 

Rock Springs BLM FO Green River RMP 2004 

Kemmerer BLM FO Kemmerer RMP 1986 

Idaho

BLM Idaho Falls District, Pocatello FO Pocatello RMP 1988 

BLM Idaho Falls District, Pocatello FO Malad Management 

Framework Plan (MFP) 1981 

Caribou-Targhee NF, Caribou 

Administrative Unit 

Caribou NF Revised 

Forest Plan (RFP) 2003 

BLM Twin Falls District, Shoshone FO Monument RMP 1986 

BLM Twin Falls District, Shoshone FO Bennett Hills/Timmerman 

Hills MFP 1980 

Sawtooth National Forest Sawtooth National Forest 

Revised Forest Plan 2003 

BLM Twin Falls District, Burley FO Cassia RMP 1985 

Burley Field Office Twin Falls MFP 1987 

BLM Twin Falls District, Jarbidge FO Jarbidge RMP 1987 

BLM Boise District, Four Rivers FO Kuna MFP 1983 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 11 

Table 2 

Land Management Plans for the Gateway West Project

Jurisdiction Plan Name Plan Date/Status 

BLM Boise District, Four Rivers FO Cascade RMP 1987 

BLM Boise District, Four Rivers FO 

Snake River Birds of Prey 

National Conservation 

Area (NCA) RMP 

2008 

BLM Boise District, Bruneau FO Bruneau MFP 1983 

BLM Boise District, Owyhee FO Owyhee RMP 1999 

Nevada

Wells Field Office Wells RMP 1985 

4.2.1 Land Management Plans 

Wyoming land management plans within the Project area are recent, and overall, the specific 

temporal and spatial restrictions for a given species are consistent across these jurisdictions. 

Most of the relevant Idaho plans within the Project area are outdated, and additional information 

provided by the agencies in Idaho is very limited. In addition, these plans tend to have 

information gaps, contain restrictions that are not consistent across jurisdictions, and contain 

stipulation language that is not specific and require interpretation. RMPs from both states have 

phrases such as “avoidance where possible”, “request”, “recommend” “review on a case by 

case basis”, and “exceptions may be made” indicating many of the stipulations and restrictions 

need to be reviewed on a species by species basis within each field office. 

4.2.2 Stipulation Selection 

One set of measures is proposed for each species across the entire Project area. The 

Proponents propose Project-wide measures because they are easier to administer and explain 

to construction personnel. As a result, there are cases in which the proposed conservation 

measures deviate from those found in some of the land management plans. 

Many of the stipulations are designed to assume species presence and, in the case of seasonal 

restrictions, to broadly bracket the interval of time in which there could be adverse impacts. 

The Proponents include conditions for those stipulations that allow for flexibility on a case by 

case basis based on species occupancy and other local conditions. 

Finally, the Proponents did not include all measures found in all land management plans. 

Measures not included are those which are not specific enough to define a measurable 

stipulation, measures that describe general goals for the Federal lands but do not address new 

projects specifically, measures that address habitat management and treatment versus discrete 

temporal and spatial restrictions on project activities, cases in which the expectations of one 

land management plan extends well beyond that of the other plans, and measures that are not 

practical from a project design and development perspective. 

4.2.3 Land Ownership 

The Wyoming segments of the proposed Project cross a relatively large percentage of Federal 

land, and private lands tend to be unsigned and isolated sections of land in a checkerboard 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 12 

pattern. Therefore, in these segments the temporal and spatial restrictions on Federal lands will 

be applied to the entire segment (i. e., including the private and state land) in order to have a 

Project conservation plan that is consistent and thus easier to plan and implement. Exceptions 

to this strategy are: 

• The proposed substation and regeneration sites located on private land; 

• Stipulations that are only applicable to National Forest System lands; and 

• Variances on private property that are at the request of the property owner. 

In Idaho, land ownership patterns vary by segment. The proposed corridors for Segments 6, 8, 

and 9 are largely Federal land, with private and state land interspersed. Segments 4, 5, 7 and 

10 are predominantly private ownership in agriculture and other development, and for the most 

part, the Federal land in these segments is clustered. As with the Wyoming segments, the 

Proponents intend to implement the temporal and spatial restrictions for Federal land on all 

lands along these segments, with the exception of the proposed substation locations which will 

be on private land. 

4.2.4 Species-Specific and Site-Specific Variation 

The proposed Project conservation measures are framed with the understanding that the 

applicability of each measure is dependent upon species-specific and site-specific criteria. The 

Proponents have designed an intensive plan of habitat assessments, field surveys, and field 

monitoring that will identify the specific conditions under which each proposed measure must be 

implemented. This approach provides for protection of the species of concern while not 

unnecessarily limiting Project activities. The proposed conservation plan varies by species, 

based on factors such as: 

• The anticipated prevalence of the species in the Project area; 

• The sensitivity of the species to the activities that will be conducted in the Project area; 

• The listing status of the species; 

• The land management plan guidance and requirements regarding the presence of the 

species or its habitats; and 

• The quality and extent of the existing data related to the species. 

 

The proposed species conservation measures are presented in Section 5. Ultimately, the 

specific Project mileposts and schedule for which each measure applies will be identified. The 

POD will contain a plan that will provide the site-specific means of complying with the listed 

measures. 

5.0 PROPOSED PLANT AND WILDLIFE CONSERVATION PLAN 

The conservation measures that the Proponents propose to implement to avoid or minimize 

impacts to special status species in the Project area are presented below. This includes the 

special status species that have been identified by the Proponents and the Agencies as 

occurring or potentially occurring in the Project area, and presents the following information for 

each species: 

• Regulatory status, if any, which may include: Federally listed, candidate, proposed, 

or petitioned; state listed (only relevant for Idaho); BLM Sensitive; Forest Service 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 13 

Sensitive; Forest Service Management Indicator Species (MIS); Migratory Bird 

Treaty Act (MBTA); and Bald and Golden Eagle Protection Act (BGEPA); 

• Proposed methods of data collection; 

• Proposed temporal and spatial surface use stipulations; and 

• Proposed exceptions to the proposed surface use stipulations. 

Big Game 

For all species of big game exceptions include areas where regular human activity occurs (e.g., 

along highways) which has acclimated animals to disturbance. If the animals are habituated to 

disturbance, the surface use stipulation will be waived for the entire season. Proposed game 

conservation (PGC) measures are found below. 

Antelope Fawning Areas 

PGC-1 No construction May 1 to May 30 in identified areas. 

PGC-2 Weekly monitoring will commence May 15 and continue until PGC-3 is met. 

The Proponents will provide monitoring results to the appropriate land 

management agency. 

PGC-3 If animals are present after May 15, no construction until two consecutive 

weekly monitoring1

 sessions show no animals present or until July 1 if 

animals are present. 

Antelope Winter Range 

PGC-4 Weekly monitoring will commence November 15 in identified areas (see 

PGC-5). The Proponents will provide monitoring results to the appropriate 

land management agency. . 

PGC-5 Construction may continue past November 15 if no animals are detected, but 

contractor must be prepared to shut down once four or more antelope are 

seen in mapped habitat, and may not start work until March 1 at the earliest 

and if PGC-6 and -7 are met. 

PGC-6 Weekly monitoring will be reinitiated, beginning February 15 and continue 

until PGC-7 is met. The Proponents will provide monitoring results to the 

appropriate land management agency. 

PGC-7 If animals are present, no construction until May 1 or until two consecutive 

weekly monitoring sessions confirm no animals are present. 

Bighorn Sheep Lambing Grounds 

PGC-8 No construction May 1 to May 30 in identified areas. 

PGC-9 Weekly monitoring will commence May 15 and continue until PGC-10 is met. 

The Proponents will provide monitoring results to the appropriate land 

management agency. 

PGC-10 If animals are present after May 30, no construction until two consecutive 

weekly monitoring sessions show no animals present or until July 1 if animals 

are present. 

                                                            

1

 Monitoring constitutes two events per week with suitable weather conditions (no visual limitations – fog, 

precipitation) in a 1-mile buffer around active project facilities (for the following species: antelope fawning and 

winter range, big horn sheep lambing and winter range, elk calving and winter range, moose calving and winter 

range, and mule deer fawning and winter range). 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 14 

Bighorn Sheep Winter Range 

PGC-11 Weekly monitoring will commence November 15 in identified areas (see 

PGC-12). 

PGC-12 Construction may continue past November 15 if no animals are detected, but 

contractor must be prepared to shut down once one or more big horn sheep 

are seen in mapped habitat, and may not start work until March 1 at the 

earliest, and if PGC-13 and -14 are met. 

PGC-13 Weekly monitoring will be reinitiated beginning February 15 and continue until 

PGC-14 is met. The Proponents will provide monitoring results to the 

appropriate land management agency. 

PGC-14 If animals are present, no construction until May 1, or until two consecutive 

weekly monitoring sessions confirm no animals are present. 

Bighorn Sheep Year-long Habitat 

PGC-15 Surface disturbance is prohibited year-round within mapped habitat. 

Elk Calving Areas 

PGC-16 No construction May 1 to May 30 in identified areas. 

PGC-17 Weekly monitoring will commence May 15 and continue until PGC18 is met. 

The Proponents will provide monitoring results to the appropriate land 

management agency. 

PGC-18 If animals are present after May 30, no construction until two consecutive 

weekly monitoring sessions show no animals present or until July 1 if animals 

are present. 

Elk Winter Range 

PGC-19 Weekly monitoring will commence November 15 (see PGC-20). 

PGC-20 Construction may continue past November 15 if no animals are detected, but 

contractor must be prepared to shut down once four or more elk are seen in 

mapped habitat, and may not start work until March 1 at the earliest, and if 

the following conditions are met. 

PGC-21 Weekly monitoring will be reinitiated beginning February 15 and continue until 

PGC-22 is met. The Proponents will provide monitoring results to the 

appropriate land management agency. 

PGC-22 If animals are present, no construction until May 1 or until two consecutive 

weekly monitoring sessions confirm no animals are present. 

Moose Calving Areas 

PGC-23 No construction May 1 to May 30 in identified areas. 

PGC-24 Weekly monitoring will commence May 15 and continue until PGC-25 is met. 

The Proponents will provide monitoring results to the appropriate land 

management agency. 

PGC-25 If animals are present after May 30, no construction until two consecutive 

weekly monitoring sessions show no animals present or until July 1 if animals 

are present. 

Moose Winter Range 

PGC-26 Weekly monitoring will commence November 15 in identified areas (see 

PGC-27). 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 15 

PGC-27 Construction may continue past November 15 if no animals are detected, but 

contractor must be prepared to shut down once one or more moose are seen 

in mapped habitat, and may not start work until March 1 at the earliest, and if 

the following conditions are met. 

PGC-28 Weekly monitoring will be reinitiated beginning February 15 and continue until 

PGC-29 is met. The Proponents will provide monitoring results to the 

appropriate land management agency. 

PGC-29 If animals are present, no construction until May 1 or until two consecutive 

weekly monitoring sessions confirm no animals are present. 

Mule Deer Fawning Areas 

PGC-30 No construction May 1 to May 30 in identified areas. 

PGC-31 Weekly monitoring will commence May 15 and continue until PGC-32 is met. 

The Proponents will provide monitoring results to the appropriate land 

management agency. 

PGC-32 If animals are present after May 30, no construction until two consecutive 

weekly monitoring sessions show no animals present or until July 1 if animals 

are present. 

Mule Deer Winter Range 

PGC-33 Weekly monitoring will commence November 15 in identified areas (see 

PGC-34). 

PGC-34 Construction may continue past November 15 if no animals are detected, but 

contractor must be prepared to shut down once four or more mule deer are 

seen in mapped habitat, and may not start work until March 1 at the earliest, 

and if the following conditions are met. 

PGC-35 Weekly monitoring will be reinitiated beginning February 15 and continue until 

PGC-36 is met. The Proponents will provide monitoring results to the 

appropriate land management agency. 

PGC-36 If animals are present, no construction until May 1 or until two consecutive 

weekly monitoring sessions confirm no animals are present. 

Other Mammals 

Proposed mammal conservation (PMC) measures are found below. 

Black-Footed Ferret (bff) 

White-tailed prairie dog colonies that are larger than 200 acres are considered suitable habitat. 

PMC-1 No surface disturbance will occur in black footed ferret non-block-cleared 

areas that are part of a white-tailed prairie dog complex that is greater than 

200 acres and identified by USFWS as a potential black footed ferret 

reintroduction area (USFWS 1989) until cleared by species specific 

presence/absence protocol level surveys. 

PMC-2 Pre-construction presence/absence protocol surveys (USFWS 1989) would 

be conducted in suitable habitat within mapped non-block-cleared areas, as 

necessary. Results of surveys would be valid for a 12-month period. 

PMC-3 In the event that black-footed ferrets are documented, construction would 

cease within the vicinity of the documented occurrence and the USFWS 

would be notified. In addition, the transmission line or structures would be 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 16 

relocated to minimize direct impacts to prairie dog colonies to the extent 

possible. 

Pygmy Rabbit 

No surface disturbance of active burrows will occur. 

PMC-4 The year prior to construction, protocol level surveys (Ulmschneider 2004) 

would be conducted in suitable habitat (defined by both Project-specific 

mapping conducted in 2008 and agency habitat mapping) within 300 feet of 

and including the ROW. Survey results shall be provided to the appropriate 

land management agency. (A distance of 300 feet was chosen because 

burrow systems have been found to extend to approximately 300 feet 

[Bradfield 1974].) 

PMC-5 During the protocol level surveys, any areas of occupied habitat will be 

mapped with a GPS unit. No surface disturbances of active burrows will 

occur. 

PMC-6 Where feasible and if needed, the transmission line would be micro-sited to 

avoid occupied habitat. 

PMC-7 Within 30 days prior to construction, previously occupied habitat would be revisited to document presence using protocol level surveys (Ulmschneider 

2004). Occupied habitat would be re-mapped electronically and flagged in 

the field to allow additional micro-siting to avoid the occupied habitat to the 

extent possible. 

White-Tailed Prairie Dog 

Where possible, occupied habitat will be avoided. See proposed conservation measures 

associated with the black-footed ferret. 

Wyoming Pocket Gopher 

PMC-8 Protocol level surveys (Keinath and Beauvais 2006) would be conducted 

within suitable habitat in segments 2, 3, and 4, in order to determine species 

presence in areas that could be impacted by Project components. 

Proponents will provide survey results to the appropriate land management 

agency. 

PMC-9 All ground disturbances would be avoided to the extent practical where the 

Wyoming pocket gopher is documented. 

PMC-10 Previously documented occurrences of the Wyoming pocket gopher would be 

avoided during operation and maintenance activities. 

Exceptions include areas where regular human activity occurs (e.g., along highways) which has 

acclimated animals to disturbance. If the animals are habituated to disturbance, the surface use 

stipulation will be waived for the entire season. 

Raptors 

Proposed raptor conservation (PRC) measures are found below. 

Bald Eagle 

5.1.1.1.1.1.1 Active Nests 

PRC-1 A pedestrian or aerial survey of known nest locations within a 1 mile buffer of 

active project facilities will be conducted no more than 2 weeks prior to 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 17 

construction. The Proponents will provide survey results to the appropriate 

land management agency. 

PRC-2 If nesting bald eagles are present, the USFWS will be notified and monitoring 

will be conducted until the young have fledged or the nest fails, at which point 

construction can begin. 

PRC-3 If no nesting activity has been initiated by April 1, construction will be 

permitted for the remainder of the nesting season without further monitoring. 

Exceptions include areas where regular human activity occurs (e.g., along highways) which has 

acclimated the birds to disturbance. If the birds are habituated to disturbance, the surface use 

stipulation will be waived for the entire season. In addition, if topography is such that the 

Project activities are out of line of sight of the nest, the surface use stipulation will be waived. 

5.1.1.1.1.1.2 

5.1.1.1.1.1.3 Winter Roosts 

Known winter roosts will be monitored and exceptions based on bird occupancy: 

PRC-4 If roosting activity has been initiated, then no construction will be initiated 

within the prescribed buffer; however, if no roosting activity has been initiated 

by January 1, then construction will be permitted for the remainder of the 

roosting season without further monitoring. 

Exceptions include areas where regular human activity occurs (e.g., along highways) which has 

acclimated animals to disturbance. If the animals are habituated to disturbance, the surface use 

stipulation will be waived for the entire season. In addition, if topography is such that the 

Project activities are out of line of sight of the roost, the surface use stipulation will be waived. 

Burrowing Owl 

PRC-5 Within 30 days prior to construction, protocol level surveys (CDOW 2007) will 

be conducted in suitable or occupied habitat. Active burrows will be mapped 

electronically and flagged in the field to determine if transmission line features 

can avoid burrows. If avoidance is not feasible, construction will not begin 

until August 16. The Proponents will provide survey results to the appropriate 

land management agency. 

Ferruginous Hawk 

PRC-6 A pre-construction pedestrian or aerial survey will be conducted two weeks 

prior to construction, to identify active nests within 1 mile of the ROW. 

PRC-7 If an active nest is present, monitoring will be conducted until the young have 

fledged or the nest fails, whichever occurs sooner, and no surface-disturbing 

activities will occur within 1 mile of the nest while the nest is active. Monitors 

will observe the nests from an appropriate distance to avoid disturbing birds. 

PRC-8 If no active nests are detected during the pre-construction surveys 

construction will occur without further monitoring. 

Exceptions include areas where regular human activity occurs (e.g., along highways) which has 

acclimated the birds to disturbance. If the birds are habituated to disturbance, the surface use 

stipulation will be waived for the entire season. In addition, if topography is such that the Project 

activities are out of line of sight of the nest, the surface use stipulation will be waived. 

Flammulated Owl 

PRC-9 Preconstruction protocol level surveys (USFS 1993, 2008) will be conducted 

during the appropriate seasonal timeframe prior to construction in suitable 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 18 

habitat, to identify active nests within 0.25 of a mile of the ROW. Proponents 

will provide survey results to the appropriate land management agency. 

PRC-10 If an active nest is found during the protocol level surveys, construction is 

prohibited within 0.25 mile of the nest until monitoring shows that the young 

have fledged or the nest fails, whichever occurs sooner. 

PRC-11 If no active nests are detected during the pre-construction protocol surveys, 

construction will occur without further monitoring. 

Exceptions include areas where regular human activity occurs (e.g., along highways) which has 

acclimated the birds to disturbance. If the birds are habituated to disturbance, the surface use 

stipulation will be waived for the entire season. 

Golden Eagle 

PRC-12 A pedestrian or aerial survey of known nest locations will be conducted 

weekly during the appropriate seasons, beginning no more than 2 weeks 

prior to construction. The Proponents will provide survey results to the 

appropriate land management agency. 

PRC-13 If nesting eagles are present, monitoring will be conducted until the young 

have fledged or the nest fails, at which point construction can begin. 

PRC-14 If no active nests are detected during the pre-construction surveys 

construction will occur without further monitoring. 

Exceptions include areas where regular human activity occurs (e.g., along highways) which has 

acclimated the birds to disturbance. If the birds are habituated to disturbance, the surface use 

stipulation will be waived for the entire season. In addition, if topography is such that the 

Project activities are out of line of sight of the nest, the surface use stipulation will be waived. 

Northern Goshawk 

PRC-15 Pre-construction pedestrian surveys (USFS 1993, 2008) will be conducted 

during the appropriate seasonal timeframe prior to construction in suitable 

habitat, to identify active nests within 0.5 of a mile of the ROW within suitable 

habitat. Proponents will provide survey results to the appropriate land 

management agency. 

PRC-16 If an active nest is found during the protocol level surveys, construction is 

prohibited within 0.25 mile of the nest until monitoring shows that the young 

have fledged or the nest fails, whichever occurs sooner, and no surfacedisturbing activities will occur within 0.5 mile of the nest while the nest is 

active. 

PRC-17 If no active nests are detected during the pre-construction surveys 

construction will occur without further monitoring. 

Exceptions include areas where regular human activity occurs (e.g., along highways) which has 

acclimated the birds to disturbance. If the birds are habituated to disturbance, the surface use 

stipulation will be waived for the entire season. 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 19 

All Other Raptors 

PRC-18 Pre-construction surveys will be conducted during the appropriate seasonal 

timeframe prior to construction, to identify active nests within 0.5 of a mile of 

the ROW within suitable habitat. The Proponents will provide survey results 

to the appropriate land management agency. 

PRC-19 If an active nest is found during the protocol level surveys, construction is 

prohibited within 0.5 mile of the nest until monitoring shows that the young 

have fledged or the nest fails, whichever occurs sooner. The Proponents will 

provide survey results to the appropriate land management agency. 

PRC-20 If no active nests are detected during the pre-construction surveys 

construction will occur without further monitoring. 

Exceptions include areas where regular human activity occurs (e.g., along highways) which has 

acclimated the birds to disturbance. If the birds are habituated to disturbance, the surface use 

stipulation will be waived for the entire season. In addition, if topography is such that the 

Project activities are out of line of sight of the nest, the surface use stipulation will be waived. 

Other Avian 

Proposed avian conservation (PAC) measures are found below. It should be noted, the 

Proponents are preparing a Sage grouse mitigation plan to be submitted under separate cover. 

Columbian Sharp-tailed Grouse 

PAC-1 All previously identified Columbian sharp-tailed grouse leks within 1 mile of the 

center line of the Project will be surveyed during the breeding season (March 15 to 

June 15) prior to construction to determine if the lek is active. If no lek activity is 

observed by April 15th, no further restrictions apply for that year. Measures PAC2, -3, and -4 will not apply if lek is not active. The Proponents will provide survey 

results to the appropriate land management agency. 

PAC-2 Surface disturbance will be prohibited year-round within 0.25 mile of previously 

documented leks. 

PAC-3 No surface disturbance from 0.25 mile to 0.65 mile of a known active lek from 

March 1 to April 30. If no lek activity is observed by April 15th, no further 

restrictions apply for that year. If lek activity is observed, surface disturbance from 

0.25 mile to 0.65 mile may not occur until after June 30. 

PAC-4 Surface disturbance occurring more than 0.65 mile from the lek may occur at any 

time. 

PAC-5 Notification will be placed in areas frequented by on-site personnel (such as break 

rooms) to advertise the importance of complying with these restrictions. 

PAC-6 Operation and maintenance activities will be scheduled to avoid working within 

0.65 mile of previously documented leks from March 15 to July 15. 

Temporal and spatial restrictions do not apply when lek or nesting and brood rearing habitat is 

separated from Project activities by other forms of human disturbance (e.g., agriculture, 

highways) or by line of sight barriers. 

Greater Sandhill Crane 

PAC-14 A preconstruction aerial survey of suitable habitat and historic nest sites will be 

conducted. 

PAC-15 Nesting pairs within 0.5 mile of the ROW will be monitored until the nest is vacated, 

the young are no longer dependent on the nest, or June 30, whichever occurs 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 20 

sooner, and no surface-disturbing activities will occur within 0.5 mile of the nest 

while the nest is active. 

PAC-16 If no nesting pairs are observed during pre-construction surveys, construction can 

begin. 

PAC-17 In the event that the nest site is separated from the Project activities by other forms 

of human disturbance (e.g., a highway or active cropland), or by line of sight 

barriers, construction may start 

Long-Billed Curlew 

PAC-18 Within 30 days prior to construction, protocol level surveys will be conducted in 

known and occupied habitat within a 1 mile buffer of active project activities. 

Active nests will be mapped electronically and flagged in the field and monitored 

until the nest is vacated or June 30, whichever comes first, at which time 

construction can commence. 

Mountain Plover 

PAC-19 Preconstruction protocol level surveys (USFWS 2002) will be conducted during the 

appropriate seasonal timeframe prior to construction in suitable habitat, to identify 

active nests within 0.25 mile of the ROW. If no nests are found, construction can 

commence. The Proponents will provide survey results to the appropriate land 

management agency. 

PAC-20 If an active nest is found during the protocol level surveys, monitoring will be 

conducted until the young have fledged or the nest fails, whichever occurs sooner, 

and no surface-disturbing activities will occur within 0.25 mile of the nest while the 

nest is active. 

PAC-21 If no active nests are discovered during the preconstruction surveys (USFWS 

2002), construction will be permitted for the remainder of the nesting season 

without further monitoring. 

Exceptions include areas where regular human activity occurs (e.g., along highways) which has 

acclimated the birds to disturbance. If the birds are habituated to disturbance, the surface use 

stipulation will be waived for the entire season. In addition, if topography is such that the Project 

activities are out of line of sight of the nest, the surface use stipulation will be waived. 

Three-Toed Woodpecker 

PAC-22 Pre-construction protocol level surveys will be conducted during the appropriate 

seasonal timeframe prior to construction in suitable habitat, to identify active nests 

within the ROW. 

PAC-23 If an auditory response is received and an active nest is found, monitoring will be 

conducted until the young have fledged or the nest fails, whichever occurs sooner, 

and no surface-disturbing activities will occur within 0.25 mile of the nest while the 

nest is active. The Proponents will provide survey results to the appropriate land 

management agency. 

PAC-24 If no nests are discovered, construction will be permitted for the remainder of the 

nesting season without further monitoring. 

Exceptions include areas where regular human activity occurs (e.g., along highways) which has 

acclimated the birds to disturbance. If the birds are habituated to disturbance, the surface use 

stipulation will be waived for the entire season. 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 21 

Plants 

Proposed plant conservation (PPC) measures are found below. 

Blowout Penstemon (Penstemon haydenii) 

PPC-1 Surface disturbance will be allowed in suitable habitat where species-specific 

surveys have determined that no populations are present. The speciesspecific surveys will be conducted the year prior to construction, and the 

proposed disturbance areas will be redesigned to avoid direct impact to 

populations. 

Colorado Butterfly Plant (Gaura neomexicana coloradensis) 

PPC-2 Surface disturbance will be allowed in suitable habitat where species-specific 

surveys have determined that no populations are present. The speciesspecific surveys will be conducted the year prior to construction, and the 

proposed disturbance areas will be redesigned to avoid direct impact to 

populations. 

Slickspot Peppergrass (Lepidium pappileferum) 

PPC-3 Surface disturbance will be allowed in suitable habitat where species-specific 

surveys have determined that no populations are present. The speciesspecific surveys will be conducted the year prior to construction, and the 

proposed disturbance areas will be redesigned to avoid direct impact to 

populations. 

Ute Ladies’-Tresses Orchid (Spiranthes diluvialis) 

PPC-4 Surface disturbance will be allowed in suitable habitat where species-specific 

surveys have determined that no populations are present. The speciesspecific surveys will be conducted the year prior to construction, and the 

proposed disturbance areas will be redesigned to avoid direct impact to 

populations. 

6.0 LITERATURE CITED 

Bradfield, T.D. 1974. On the behavior and ecology of the pygmy rabbit Sylvilagus idahoensis. 

M.S. Thesis. Idaho State University, Pocatello, ID, 43 pp 

Bureau of Land Management (BLM). 2004. Exception Requests for Activities Involving 

Mountain Plover (MP). Instruction Memorandum No. WY-2004-035. April. 

BLM. 2008. Kemmerer BLM Pygmy Rabbit Cursory Analysis for Long Pipelines. Instruction 

Memorandum No. WY-2004-035. February 29. 

Colorado Division of Wildlife (CDOW). 2007. Recommended Survey Protocol and 

Recommended Actions to Protect Burrowing Owls when Conducting Prairie Dog Control. 

Revised March 2007. 

Connelly, et al. 2003. Monitoring of Greater Sage-grouse Habitats and Populations. University 

of Idaho. College of Natural Resources Experiment Station, Moscow, Idaho. Station 

Bulletin 80. October. 
Plant and Wildlife Conservation Plan Appendix C-3 

October 2010 22 

Fertig et. al 1994 - Fertig, W. , C. Refsdal, and J. Whipple. 1994. Wyoming Rare Plant Field 

Guide. Wyoming Rare Plant Technical Committee, Cheyenne. Jamestown, ND: 

Northern Prairie Wildlife Research Center Online. http://www. npwrc. usgs. 

gov/resource/plants/wyplant/index. htm (Version 16JUL97). 

Hoffman and Thomas 2007. Columbian sharp-tailed grouse. A Technical Conservation 

Assessment. Prepared for the USFS Rocky Mountain Region Species Conservation 

Project. 

Idaho Power and Rocky Mountain Power. 2008. Gateway West Transmission Line Project 

Revised Plan of Development. 

Idaho Power and Rocky Mountain Power. 2008a. Gateway West Transmission Line Project 

Siting Study. 

Laymon, Stephen. 1998. Draft Yellow-billed Cuckoo Survey and Monitoring Protocol for 

California. In: Yellow-billed Cuckoo (Coccyzus americanus): A Technical Conservation 

Assessment. Prepared for the USDA Forest Service, Rocky Mountain Region, Species 

Conservation Project. March 2005. 

Romin, Laura A. and James A. Muck. 1999. Utah Field Office Guide for Raptor Protection 

from Human and Land Use Disturbances. Utah Fish and Wildlife Service, Salt Lake 

City, Utah. May. 

Ulmschneider, Helen. 2004. Surveying for Pygmy Rabbits (Brachylagus idahoensis), Fourth 

Draft. June 3. Boise District, Idaho BLM. 

U. S. Fish and Wildlife Service (USFWS). 1989. Black-Footed Ferret Survey Guidelines for 

Compliance with the Endangered Species Act. Denver, Colorado and Albuquerque, 

New Mexico. April. 

USFWS 1992. Blowout Penstemon (Penstemon haydenii) Recovery Plan. 

USFWS. 2002. Mountain Plover Survey Guidelines – Montana. March. 

USFWS. 2004. Preble’s Meadow Jumping Mouse (Zapus hudsonius preblei) Survey 

Guidelines. Revised April 2004. 

U. S. Forest Service (USFS). 1993. Payette National Forest Region 4 Sensitive Species 

Broadcast Vocalization Compact Disk. 

USFS. 2008. March 4 email from Ann Keysor, Caribou-Targhee National Forest, Montpelier, 

Idaho, to Amanda O’Connor, URS Corporation. Subject: Re: Gateway West - draft 

survey protocol. 
Gateway West Transmission Line Draft EIS 

Appendix C-4 

Revised Plan for Operations, Maintenance, and Emergency Response 

(submitted to BLM by Idaho Power and Rocky Mountain Power 

October 2010) 
 

 Appendix C-4 

Revised Plan for Operations, Maintenance, and 

Emergency Response 

Gateway West Transmission Line Project 

Prepared by: 

Idaho Power Company 

1221 West Idaho Street 

Boise, ID 83702 

and 

Rocky Mountain Power 

1407 W North Temple 

Salt Lake City, UT 84116 

October 2010
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

Appendix C    

TABLE OF CONTENTS 

1.0 INTRODUCTION .................................................................................................. 1

2.0 OPERATION AND MAINTENANCE ..................................................................... 2

2.1 Routine Maintenance (Preventative Maintenance) ....................................... 2

2.2 Corrective Maintenance ................................................................................ 4

3.0 EMERGENCY SITUATIONS ................................................................................ 4

4.0 ENVIRONMENTAL PROTECTION MEASURES ................................................. 5

4.1 Site Access and Road Management ............................................................ 5

4.2 Vegetation Management .............................................................................. 9

4.3 Noxious Weed Control ................................................................................ 12

4.4 Protection Measures for Aquatic Resources .............................................. 12

4.5 Protection for Threatened, Endangered, and Sensitive Plant and Animal 

Species ....................................................................................................... 13

4.6 Restoration and Revegetation .................................................................... 14

4.7 Protection Measures for Cultural Resources .............................................. 15

4.8 Fire Protection ............................................................................................ 16

4.9 Emergency Notification Procedures ........................................................... 17

5.0 O&M PLAN HISTORY ........................................................................................ 17

6.0 LITERATURE CITED ......................................................................................... 18

LIST OF TABLES

Table 1. Company Proposed Seasonal O&M Restrictions by Time and Location for 

Big Game Crucial Winter Range ................................................................... 7 

Table 2. IVM Recommended Management Heights in the Wire Zone and Regions . 10 

Table 3. O&M Contact List ....................................................................................... 17 

LIST OF FIGURES 

Figure 1 Transmission Line Vegetation Management Zones ........................................ 9 

Figure 2 Vegetation Management Regions Based on Line Height .............................. 10 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 1 

1.0 INTRODUCTION 

This document presents the plan proposed by Idaho Power and Rocky Mountain Power (the 

Proponents) for conducting routine and emergency operation and maintenance (O&M) activities 

for the Gateway West Transmission Line Project (Project). This plan is intended to ensure the 

following: 

• O&M activities comply with applicable state and federal laws and policies; 

• Consistency across and within federal jurisdictions; 

• The Proponents are able to access the transmission line and ancillary facilities and 

implement the necessary O&M activities in a timely, cost effective and safe manner; 

• Impacts to the environment are avoided where practicable or are minimized; and 

• The Proponents comply with the North American Electric Reliability Corporation (NERC) 

and Western Electric Coordinating Council (WECC) reliability and service requirements. 

NERC’s mission is to ensure the reliability of the bulk power system in North America. To 

achieve that, NERC develops and enforces reliability standards; assesses adequacy annually 

via 10-year and seasonal forecasts; monitors the bulk power system; evaluates users, owners, 

and operators users for preparedness; and educates, trains, and certifies industry personnel. 

NERC works with eight regional entities to improve the reliability of the bulk power system. The 

members of the regional entities come from all segments of the electric industry: investor-owned 

utilities; federal power agencies; rural electric cooperatives; state, municipal and provincial 

utilities; independent power producers; power marketers; and end-use customers. These 

entities account for virtually all the electricity supplied in the United States, Canada, and a 

portion of Baja California Norte, Mexico. 

The Western Systems Coordinating Council (WSCC) was formed with the signing of the WSCC 

Agreement on August 14, 1967 by 40 electric power systems. Those "charter members" 

represented the electric power systems engaged in bulk power generation and/or transmission 

serving all or part of the 14 Western States and British Columbia, Canada. The WECC was 

formed on April 18, 2002, by the merger of WSCC, Southwest Regional Transmission 

Association (SWRTA), and Western Regional Transmission Association (WRTA). WECC's 

interconnection-wide focus is intended to complement current efforts to form Regional 

Transmission Organizations (RTO) in various parts of the West. 

WECC and the nine other regional reliability councils were formed due to national concern 

regarding the reliability of the interconnected bulk power systems, the ability to operate these 

systems without widespread failures in electric service, and the need to foster the preservation 

of reliability through a formal organization. 

WECC members have long recognized the many benefits of interconnected system operation. 

During the mid 1960s, expansion of interconnecting transmission lines among systems in the 

western United States and western Canada resulted in the complete interconnection of the 

entire WECC region. As this expansion was taking place, systems generally adopted the 

Operating Guides of the North American Power Systems Interconnection Committee (NAPSIC) 

to promote consistent operating practices within the region. NAPSIC later became the NERC 

Operating Committee. 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 2 

The reliability management system (RMS) was created as a way to enforce compliance. This 

contract obligates entities to abide by certain critical reliability standards and to provide the data 

needed to verify compliance. The contract also imposes sanctions, both monetary and nonmonetary according to a set schedule, for violations of reliability criteria. Currently all control 

areas but one are signatories to the RMS agreement, and almost 90% of the customer load in 

the Western Interconnection is served under RMS. 

The Proponents submitted the Revised Proposed Plant and Wildlife Conservation Plan - 

Construction Activities (Idaho Power and Rocky Mountain Power 2010) to the Bureau of Land 

Management (BLM) in January 2010. That document addressed avoidance and minimization 

measures during corridor and route selection and conservation measures, including temporal 

and spatial restrictions, to protect plant and wildlife species of concern during construction. The 

avoidance and minimization measures implemented during routing will also reduce the potential 

for adverse impacts during O&M activities. This Plan addresses routine, corrective and 

emergency response activities for operation and maintenance of the transmission line and its 

ancillary facilities. This Plan will be reviewed and updated as necessary and as agreed to by the 

Proponents and the Agencies.

2.0 OPERATION AND MAINTENANCE 

The Proponents perform a number of activities to keep transmission lines operational and in 

good repair. Most of these activities, such as those for routine patrols, inspections, or scheduled 

maintenance, are planned in advance. However, there will be an occasional need for 

emergency response in cases where public safety and property are threatened, to prevent 

imminent damage to the transmission line and ancillary facilities, or to restore service in the 

event of an outage. 

Routine, corrective, and emergency response activities will be conducted in accordance with 

this O&M Plan without previous notification or approval from the BLM, U.S. Forest Service, and 

Bureau of Reclamation (Agencies). Exceptions where prior notification and approval are 

required are described in Section 4. Maintenance activities outside of the right-of-way (ROW), 

outside of established service and access roads or other Project related ancillary facilities, or 

that are not identified in this Plan will not be conducted until approved by the Agencies. An 

exception to this would be when emergency action/maintenance is needed which requires some 

outside ROW work to be completed to ensure reliable power to customers. 

Typical schedules and equipment used for the O&M activities are provided below. However, 

additional vehicles and equipment may be necessary depending on the terrain, site access, and 

necessary maintenance work. Work may also be conducted outside of the typical schedule; 

schedule changes may occur as a result of weather, manpower, equipment availability, budgets, 

and other factors. 

2.1 Routine Maintenance (Preventative Maintenance) 

Routine maintenance activities are conducted on a regular basis and have been carried out 

historically to identify and repair any deficiencies. These activities do not damage vegetation or 

soil outside of the ROW, and do not adversely impact sensitive resources — including known 

federal and state listed species, waters of the United States, and cultural resources — and do 

not require land manager approval. Personnel are generally present in any one area for less 

than one day. The following are examples of routine maintenance activities: 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 3 

• Routine air patrols from a helicopter to inspect for structural and conductor defects, 

conductor clearance problems and hazardous trees. 

• Routine ground patrols to inspect structural and conductor components. Such 

inspections generally require either an all-terrain vehicle (ATV) or pickup and possibly 

additional support vehicles traveling on access and service roads and may rely on either 

direct line-of-sight or binoculars. In some cases, the inspector may walk the ROW. 

Patrols are typically conducted in the spring and fall. Follow-up maintenance is 

scheduled depending on the severity of the problem — either as soon as possible or as 

part of routine scheduled maintenance. 

• Climbing surveys may be necessary to inspect hardware or make repairs. Personnel 

generally access these structures by pickup, ATV, or on foot. 

• Structure or conductor maintenance typically occurs from a bucket truck or boom truck. 

The maintenance vehicle may be located on or off a road, and no-to-minimal grading is 

necessary to create a safe work area. 

• Cathodic protection surveys to check the integrity and functionality of the anodes and 

ground beds. These surveys typically require personnel to use an ATV or pickup and 

make brief stops. 

• Routine cyclical vegetation clearing to trim or remove tall shrubs and trees to ensure 

adequate ground-to-conductor clearances. Vegetation clearing cycles vary from 3 to 

10 years or as needed (dependent upon the vegetation present). Personnel generally 

access the area by pickup, ATV, or on foot; use chainsaws to clear the vegetation; and 

typically spend less than half a day in any one specific area. In some cases vegetation 

may be cleared using mechanical means. 

• Removal of individual trees or snags (hazard trees) that pose a risk of falling into 

conductors or structures and causing outages or fires. Personnel generally access 

hazard trees by truck, ATV, or by foot from an access or service road, and cut them with 

a chainsaw or similar tool. Any felled trees or snags are left in place as sources of large 

woody debris or as previously directed by the land management agency. Felled green 

trees are limbed to reduce fire hazard. 

• Wood poles are periodically treated to retard rotting and structural degradation. Wooden 

poles are limited to the distribution lines serving substations and regeneration stations 

on this Project. Personnel typically access structures by pickup, ATV, or on foot; inspect 

and test (including the subsurface) the poles; and then treat them by injecting 

preservatives into the poles if required. Wood pole inspections and treatments generally 

occur on a 10-year cycle. 

• Routine road maintenance, such as blading (as needed) the road to improve surface 

condition and drainage, or removing minor physical barriers, such as rocks and debris. 

All initial road maintenance is performed by field crews which typically use ATVs, 

pickups, chainsaws, and hand tools. Trees and brush are cut off at grade to minimize 

damage to vehicles. Slash, deadfall, and boulders are placed at the edge of the road or 

down slope of the road bed, depending on site topography, to serve as a filtering 

windrow to minimize erosion and sedimentation. Smaller vegetation (e.g., grasses) is left 

in the road bed unless it is too tall, hinders access, or could be construed as a fire 

hazard to O&M vehicles. 

• Vegetation removal may be required on service roads to allow the necessary clearance 

for access and provide for worker safety. Field crews access the service roads by pickup 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 4 

or ATV and use chainsaws and hand tools to clear the vegetation. Where practicable 

and feasible, mechanical methods may be used. 

• Installation of bird protection devices, bird perch discouragers, and the relocation or 

removal of bird problem nests posing imminent fire or outage risk. 

• Noxious weed control and vegetation management activities that includes the use of 

herbicides. Herbicide use is based on agreement with the landowner or federal land 

management agency for the parcel in question and the chemicals used are agreed to in 

advance. 

2.2 Corrective Maintenance 

Corrective maintenance activities are relatively large-scale efforts that occur infrequently, may 

result in more extensive vegetation clearing or earth movement, and may include rehabilitation 

seeding and associated activities (e.g., measures to control noxious weeds). Personnel are 

generally present in any one location or area for a prolonged time, generally more than one day. 

The following are examples of corrective maintenance: 

• Non-cyclical vegetation clearing to remove saplings or larger trees in the ROW. 

• Structure or conductor maintenance in which earth must be moved, such as the creation 

of a landing pad for construction or maintenance equipment. 

• Structure (e.g., cross-arm, insulator, structure) replacement. 

• Road maintenance involving erosion control, water drainage installation or repair (such 

as culverts or rock crossings), road rehabilitation after major disturbances (such as 

slumping or a storm event), or other road maintenance requiring heavy equipment (not 

including routine grading). 

• Follow-up restoration activities, such as seeding, noxious weed control, and erosion 

control. 

• Conductor repair or replacement, which requires the use of several types of trucks and 

equipment and grading to create a safe work area to hang and pull the conductor into 

place. 

3.0 EMERGENCY SITUATIONS 

Emergency situations are those conditions that may result in imminent or direct threats to public 

safety or threaten or impair the Proponents’ ability to provide reliable transmission service to its 

customers. Emergency situations may include: 

• Failure of conductor splices. 

• Damage to structures or conductors from wildfire, high winds, ice, or other weatherrelated conditions. 

• Line or system outages or fire hazards caused by trees falling into conductors. 

• Breaking or imminent failure of cross-arms or insulators, which could, or does, cause 

conductor failure. 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 5 

• Damage to structures or conductors from vandalism 

In the case of an emergency where life or substantial property is at risk or there is a potential or 

actual interruption in service, the Proponents will promptly respond to the emergency and 

conduct any and all activities, including emergency repair requiring heavy equipment access to 

the structures or other ancillary facilities, needed to remedy the emergency and will implement 

feasible and practicable Environmental Protection Measures (EPMs). Follow-up actions will 

follow this Plan. 

4.0 ENVIRONMENTAL PROTECTION MEASURES 

O&M activities are planned to minimize impacts to the environment. The following EMPs will be 

implemented by the Proponents during routine and corrective O&M activities and, to the extent 

possible, during emergency situations. 

4.1 Site Access and Road Management 

The Proponents describe roads necessary for the O&M of transmission lines as either access 

roads or service roads. The sole purpose of service roads is to provide maintenance crews 

access to the transmission lines. These roads would not exist if the transmission lines did not 

exist. In contrast, access roads serve a broader purpose, such as contributing to the federal, 

county or state road systems. Access roads provide direct or indirect access to the transmission 

lines, but that access is not their primary purpose. Public access to service roads is determined 

on a case-by-case basis by the appropriate federal land management agency. The Proponents 

are responsible for maintenance of roads that are closed to the public but accessible to federal 

personnel and the Proponents for maintenance purposes. Service and access roads are 

generally one of the following four types: 

• Public roads, including state highways and county roads—These roads are for public 

use, and the appropriate state or county entity maintains them. The Proponents consider 

these access roads. 

• Open roads on federal land—The appropriate federal agency (typically BLM or Forest 

Service) maintains these roads, which are open to the public. These roads, including 

drainage features, cuts and fill slopes, must be protected during O&M activities. The 

Proponents consider these access roads. The federal agency is responsible for 

maintenance. 

• Closed federal land roads—These roads are still needed for administrative or 

emergency functions, but they have been closed to the public because of management 

policies to protect natural resources or reduce maintenance costs. If utilized during O&M 

activities, these roads, including drainage features, cuts, and fill slopes, must be 

protected. Parties wanting to use these roads for access must obtain approval from the 

applicable federal agency. Additionally, parties using these roads will be assigned some 

maintenance responsibility proportionate to their use of the closed road. Although these 

roads may serve a broader purpose, the Proponents agree to maintain them as needed 

for O&M activities. These are considered access roads. 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 6 

• Transmission line service roads—These roads are necessary for access to, and 

maintenance of, transmission lines, structures or ancillary facilities, but they are not part 

of the public or federal network of roads. They are generally closed to the public. The 

Proponents will maintain these roads. They are considered service roads. 

The Proponents typically perform two types of road maintenance activities: (1) vegetation and 

debris clearing to maintain safe access and (2) repairs using heavy equipment. Roads are 

inspected generally every three to six years and repairs are made as necessary. Typically, a 

small crew uses hand tools to cut small brush and trees (greater than 12-inches tall); remove 

dead-fall and debris; and repair and replace signs on access and service roads. Crews also 

prepare an inventory of road damage that will require ground disturbance (e.g., repair of a failed 

bank), and repair work is scheduled accordingly (typically the following year). Inspections and 

maintenance are typically conducted from spring through summer, when roads are clear of 

snow. 

The Proponents will implement the following EPMs when maintaining roads: 

OM-1 The Proponents will comply with the road maintenance standards of the federal 

or state agency controlling the land. 

OM-2 Roads will be maintained to have crossroad drainage in order to minimize the 

amount of channeling or ditches needed. Water bars will be installed at all 

alignment changes (curves), significant grade changes, and as requested by the 

federal or state agency. 

OM-3 All existing service road drainage structures will be maintained or repaired by the 

Proponents during O&M activities or emergency response. 

OM-4 Although routine and corrective O&M is of limited duration and impact, the 

Proponents will attempt to adhere to specific closure periods and areas and are 

proposing not to conduct any routine and corrective O&M activities during the 

timeframes and at the locations identified in Table 1 to the greatest extent 

practical. The federal or state agency will notify the Proponents of any spatial 

or temporal restrictions that are in effect for the Project area (e.g., fire 

restrictions). 

OM-5 Existing improvements (fences, gates, etc.) will be repaired or replaced if they 

are damaged by O&M activities, as agreed to by the parties involved. 

OM-6 The Agencies may restrict general public access to closed federal or state roads 

and service roads that the Proponents maintain. In cases of restricted access, 

the Proponents will physically close the road with a gate. Gates will be locked 

with both a lock supplied by the Proponents, and with a federal agency lock. This 

Plan will be updated as necessary to reflect current road closures and gate 

locations. 
Plan for Operations and Maintenance and Emergency Response 

October 2010 Table 1. Company Proposed Seasonal O&M Restrictions by Time and Location for Big Game Crucia

Field Office Seasonal Timing Description Segment Proposed & Alternative Species Mile Marker where Seasonal Restriction is App

Mule Deer Elk Antelope 

BLM Casper 

Field Office 

No surface-disturbing and 

wildlife-disturbing activities are 

allowed from November 15 

through April 30 on all crucial big 

game winter ranges. 

1E None 21.2 – 22.2 (1) 3.6 -6.2 (2.6

7.4 – 8.4 (1) 

1Wa 15.7 -21.6 (5.9) None 3.5 – 6.9 (3.41Wb 15.7 – 22.1 (6.4) None 3.8 – 6.8 (3) 

1Wc 14.8 – 20.2 (5.4) None 2.4 – 6.6 (4.2

BLM Rawlins 

Field Office 

No surface disturbance and 

disruptive activities within big 

game crucial winter range are 

allowed from November 15 to 

April 30. 

3 23.4 – 46 (21.6) None 23.4 – 46 (21

BLM Rock 

Springs Field 

Office 

Big game winter ranges and 

parturition areas would be 

protected to ensure continued 

usability by limiting activities 

during crucial seasons of use 

and by limiting the amount of 

habitat disturbed. 

4 

0 – 1.7 (1.7) 

None 

0 – 1.7 (1.7) 

5.2 – 16.6 (11.4) 6.9 – 16.6 (9.19.8 – 20.7 (0.9) 19.8 – 20.7 (025.4 – 31.7 (6.3) 25.4 – 31.7 (6
Plan for Operations and Maintenance and Emergency Response 

October 2010 Table 1. Continued

Field Office Seasonal Timing Description Segment Proposed & Alternative Species Mile Marker where Seasonal Restriction is App

Mule Deer Elk Antelope 

BLM 

Kemmerer 

Field Office 

Big game crucial winter range 

closure occurs from January 1 to 

April 30 in Slate Creek, Rock 

Creek, and Bridger Creek. 

4 

121.7 – 128.2 (6.5) 

118.9 – 124.2 

(5.3) 52.5 – 58.5 (6

144.1 – 146.9 

(2.7) 84.1 – 85.7 (1

136.9 – 141.8 (4.9) 

4A 

0.4 – 6.5 (5.1) 61.6 – 66.8 

(5.2) 

0.4 – 6.5 (5.1

65 – 71.1 (6.1) 32 – 33.6 (1.6

82.5 – 85.1 (2.6) 

4B 

0.4 – 5.2 (4.8) 

66.2 – 70.4 

(4.2) 

0.4 – 5.2 (4.8

63.7 – 70.4 (6.7) 15.5 – 19.8 (4

96.8 – 100.2 (3.5) 

20.1 – 23.2 (2

43.5 – 47.5 (468.9 – 71.8 (2

4C 

0.4 – 5.2 (4.8) 

66 – 79.9 

(13.9) 

0.4 – 5.2 (4.8

63.7 – 83.5 (19.8) 15.5 – 19.8 (4

98.2 100.6 (2.4) 

20.1 23.2 (2.

43.5 – 47.5 (268.8 – 70.7 (1

4D 

0.4 – 5.2 (4.8) 

66.8 – 71 (2.2) 

0.4 – 5.2 (4.8

64.3 - 71 (6.7) 15.5 – 19.8 (4

97.4 – 100.8 (3.4) 

20.1 23.2 (3.2

43.5 – 47.5 (269.5 – 72.4 (2

4E 

0.3 – 5.2 (4.9) 66.6 – 71.2 (4.6) 0.3 – 5.2 (4.9

64.3 – 70.7 (6.4) 71.7 – 80.6 

(8.9) 

15.4 – 19.9 (4

73.2 – 73.6 (0.4) 20.1 23.2 (3.278.8 – 84.2 (5.2) 43.5 – 47.5 (2

98.7 – 102.2 (3.5) 69.4 – 71.3 (1

BLM 

Burley Field 

Office 

Big game crucial winter range 

closure occurs from January 16 

to March 15. 

7 114.2 – 118 (3.8) 

7G 0 – 3.2 (3.2) 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 9

4.2 Vegetation Management 

The Proponents manage vegetation within their ROWs and in access and service roads to 

minimize interference with the flow of electricity, to address safety issues, and to facilitate O&M 

activities. The vegetation management complies with the National Electric Safety Code, ANSI 

A300 Part 7: American Operations Integrated Vegetation Management and Electric Utility 

Rights-of-Way and the ISA Best Management Practices. Additionally, the Proponents comply 

with vegetation management standards required by the NERC and WECC Vegetation 

Management guidelines; failure to comply with these requirements can result in substantial 

financial penalties. 

Objectives of Integrated Vegetation Management (IVM) on utility rights-of-way are to establish 

sustainable plant communities that are compatible with the electric facilities. The intent is to 

provide stable, low growing plant ecotypes that reduce fire risk and maintain safe access to the 

line and associated facilities. In general, this involves removing tall growing tree species. 

Establishment of vegetation will also reduce the potential for noxious weeds to become 

established in the ROW. 

IVM has a series of control methods used to achieve the aforementioned objectives. These 

include, but are not limited to: 

• Manual Control Methods: workers with hand-carried tools, including power tools, 

used in selective or environmentally sensitive areas. 

• Mechanical Control Methods: conducted with a large variety of different types of 

machines that are efficient in clearing dense stands of vegetation. 

• Chemical Control Methods: 

o Tree Growth Regulators that are designed to reduce the natural growth 

rates by interfering with natural plant processes. 

o Herbicides: Noxious or invasive weeds along with stumps and saplings of 

tall growing species may be controlled with EPA approved herbicides. 

• Biological Control Methods: use of natural processes to control undesirable 

vegetation. 

• Cultural Control Methods: take advantage of seed banks of native, compatible 

species lying dormant on-site; this encourages the establishment of early 

successional plant communities. 

For the purposes of IVM, the ROW has been divided into the wire zone and the border zone as 

shown in Figure 1 and as defined below: 

• Wire Zone – The ROW portion directly under the wires and 10 feet beyond the 

outside phases. 

• Border Zone – The outside edge of the wire zone to the edge of the ROW. 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 10

Figure 1: Transmission Line Vegetation Management Zones. 

The IVM control method(s) implemented may be directed by the distance of the conductor to the 

ground surface (based on maximum calculated sag) as shown on Table 2 and Figure 2, and is 

defined by region as follows: Region A, where the lines are less than 50 feet off the ground, 

Region B where the lines are 50 to 100 feet off the ground, and Region C where lines are 

greater than 100 feet off the ground. Table 2 indicates the heights at which vegetation will be 

managed, based on zones and regions. 

Table 2. IVM Recommended Management Heights in the Wire Zone and Regions 

Zone Region 

Region A Region B Region C 

Wire Zone Remove All Trees 

Remove all trees if less 

than 50 feet clearance 

between top of tree and 

conductor. 

Remove all trees if less 

than 50 feet clearance 

between top of tree and 

conductor. 

Border Zone Remove all trees greater 

than 25 feet in height. 

Removal of any hazard 

trees*. 

Removal of any hazard 

trees*. 

* Hazard tree is defined as any tree that is structurally unsound that could strike a target (any utility related 

infrastructure) when it falls. Hazard trees can occur outside of the ROW and are typically removed annually. 

Generally, the Proponents propose to conduct IVM control methods/activities within the ROW 

every three to 10 years, depending on a variety of conditions such as topography, vegetation 

type and growth rates, and the potential for vegetation to interfere with safe operation of the line 

prior to the next clearing cycle. The Proponents propose to use a variety of IVM control methods 

and have developed the following EPMs for maintaining vegetation within the transmission line 

ROW. 

OM-8 Any integrated vegetation management (IVM) control method including those 

listed on pages 9 and 10 may be used to control the growth of trees and tall 

shrubs to maintain clearances, the IVM recommended wire and border zones as 

indicated in Table 2, and improve access to facilities. 

OM-9 Any IVM control method including those listed on pages 9 and 10 may be used to 

control the growth of additional vegetation to maintain clearances, the IVM 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 11

recommended wire and border zones as indicated in Table 2, and improve 

access to facilities. 

Figure 2: Vegetation Management Regions Based on Line Height. 

OM-10 Where possible, low-growing vegetation and small trees within the ROW that will 

not grow into the minimum required clearance distance will be left in place; trees 

may be removed on a subsequent maintenance cycle as they increase in size. 

Hazard trees are typically those trees or snags within or adjacent to the ROW 

that are likely to interfere with or fall into transmission lines or associated 

facilities. Hazard trees and other “hot spots” (high priority areas requiring 

vegetation management actions) are identified during routine line inspections and 

removed annually. In addition to hazard trees, other critical conditions that may 

require immediate attention include trees that interfere with transmission 

conductors and trees whose growth will not allow safe clearance until the next 

scheduled maintenance cycle. 

OM-11 Any control method may be used for vegetation maintenance on access and 

service roads; this is typically scheduled at the same time as vegetation 

maintenance within the ROW. However, in cases where vegetation grows 

quickly, removal may occur annually. Vegetation that will not interfere with the 

safe operation of vehicles and equipment will be left in place. 

OM-12 Slash will be lopped and scattered throughout the surrounding land. Stumps 

resulting from vegetation treatments will not be over 1 foot tall (unless the tree is 

not able to be safely cut at or below one foot from the ground surface), and 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 12

lopped slash will be left as close to the ground as possible. Lopped slash will be 

a maximum of 18 inches in length for small trees and limb wood. If the federal 

land managing agency determines that fuel levels are unacceptable, they shall 

notify the Proponents and develop a mutually agreed upon method to reduce 

fuels. This may include, but is not limited to, chipping. 

OM-13 Hazard trees will be felled in a direction away from the ROW. Slash and limbs 

that fall within the ROW will be treated as described above; boles of trees greater 

than eight inches will be left in place. 

OM-14 Any chemical control will be done in accordance with any applicable local, state, 

and federal rules and regulations. Herbicides or other chemical control will be 

selected from the BLM and Forest Service’s list of previously approved 

herbicides and in accordance with any herbicide plans. If the federal land 

managing agency determines that a previously approved herbicide and/or plan is 

unacceptable, they shall notify the Proponents. 

4.3 Noxious Weed Control 

Maintenance vehicles, ATVs, and equipment have the potential to transport weed seeds from 

one area to another via dirt and debris that inadvertently collects on the equipment. The 

Proponents will implement the following EPMs: 

OM-16 Before beginning an O&M project on federal or state land, the Proponents or 

their subcontractors will clean all equipment that will operate off-road or disturb 

the ground. Tracks, skid plates, and other parts that can trap soil and debris will 

be removed for cleaning when feasible, and the entire vehicle and equipment will 

be cleaned at an off-site location. 

OM-17 To help limit the spread and establishment of noxious weed species in disturbed 

areas, desired vegetation needs to be established promptly after disturbance. 

The Proponents will rehabilitate significantly disturbed areas as soon as possible 

after ground-disturbing activities and during the optimal period. Seed and mulch 

will be certified “noxious weed free” and seed mix will be agreed to in advance by 

the landowner or land managing agency. 

4.4 Protection Measures for Aquatic Resources 

Streams or watercourses with definable streambeds or stream banks, regardless of whether 

there is flowing water, are important because they provide habitat for a variety of animal and 

plant species. The Gateway West transmission lines parallel and cross numerous waterways 

and riparian areas. Of critical importance is the protection of habitat for sensitive plant and 

animal species, including aquatic species. The Proponents propose the following EPMs to 

protect aquatic resources while maintaining vegetation in and around important aquatic 

resources. 

OM-18 Routine and corrective O&M activities in streams with sensitive fish species will 

occur from July 1 to September 1 in an effort to minimize impact to spawning and 

migration activities. These activities include, but are not limited to, culvert 

installation and or replacement, stream bank stabilization. Fording streams at 

existing crossings on existing roads (e.g., dip, culvert, bridge) will occur as 

necessary throughout the year. 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 13

OM-19 Woody vegetation management within 50 feet of streams will be conducted by 

hand crews. 

OM-20 Herbaceous plants and low-growing shrubs will be left in place if they do not 

interfere with the safe O&M of Project lines and equipment as described in Table 

2. 

OM-21 The Proponents will use existing stream crossings or new, permanent crossings 

that were approved as part of the Project, and will not create additional crossings 

without prior agency permitting and approval. 

OM-22 Only herbicides approved by the land managing agency as safe to use in aquatic 

environments and reviewed by the Proponents for effectiveness will be used 

within 100 feet of sensitive aquatic resources. 

4.5 Protection for Threatened, Endangered, and Sensitive Plant and 

Animal Species 

The Proponents have taken a thorough, systematic approach in providing protection for 

threatened, endangered and sensitive plant and animal species. After taking into consideration 

wildlife and plant resources as well as other important resources during siting and routing, the 

Proponents recognized the need for additional measures to minimize the impact from 

construction of the Project and submitted a Wildlife Conservation Measures Plan. 

The Proponents will implement the following measures to protect plant and animal species 

during routine and corrective O&M activities: 

OM-23 Prior to the start of O&M activities, all supervisory personnel will be instructed on 

the protection of natural resources, including sensitive plant and wildlife species 

and habitats. If a contractor is used, the construction contract will address (a) the 

sensitive plant species that may be present in a particular area based on 

previous surveys and literature review; (b) the federal and state laws regarding 

protection of plants and wildlife; (c) the importance of these resources; (d) the 

purpose and necessity of protecting them; and (e) methods for protecting 

sensitive resources (e.g., Endangered Species Act, Migratory Bird Treaty Act, 

Bald and Golden Eagle Protection Act, and BLM wildlife policy). 

OM-24 Sensitive plant populations that occur within or near the ROW and work areas 

will be marked on the ground, where practical, to ensure that they are avoided. If 

species are discovered during the work, the Proponents will establish a spatial 

buffer zone, will contact the appropriate Agency within 24 hours, and will 

continue with the O&M activities outside of the established buffer unless 

otherwise directed. The Agency may evaluate the adequacy of the buffer on a 

case-by-case basis. Unless the Proponents are informed otherwise, work outside 

of the buffer area will continue. If the Proponents need to work within the buffer 

area, the Agencies and Proponents will work together to develop a solution that 

is acceptable to both parties and will allow for the Proponents to complete the 

work in a timely manner or within the scheduled outage window, if applicable. 

After the project is complete or no longer poses a threat to the plant population, 

the marking (stakes), if used, will be promptly removed to protect the site’s 

significance and location from unwanted attention. As needed, marking will be 

reinstated during the land rehabilitation period. 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 14

OM-25 If sensitive wildlife species are discovered during O&M activities, and the animals 

are not directly within ground disturbance areas, they will be protected by 

marking the edges of the ROW and service roads in the general vicinity to ensure 

that workers do not leave those areas. If the animals are within work areas that 

have, or will have, ground disturbance, the Proponents will establish an 

appropriate buffer zone and will contact the federal or state land manager 

immediately. The federal or state agency may evaluate the adequacy of the 

buffer on a case-by-case basis. Unless the Proponents are informed otherwise, 

work outside of the buffer area will continue. If the Proponents need to work 

within the buffer area, the Agencies and Proponents will work together to develop 

a solution that is acceptable to both parties and will allow for the Proponents to 

complete the work in a timely manner or within the scheduled outage window, if 

applicable. After the O&M activities are completed, or no longer pose a threat to 

the species, the marking (stakes) will promptly be removed to protect the site’s 

significance and location from unwanted attention. As needed, marking will be 

reinstated during the land rehabilitation period. 

OM-28 The Proponents will provide crews and contractors with maps showing avoidance 

areas; these maps will include work zones as well as ROW areas where overland 

travel will be avoided. 

OM-29 In the event any sensitive plants require relocation, permission will be obtained 

from the federal agency. If avoidance or relocation is not practical, the topsoil 

surrounding the plants will be salvaged, stored separately from subsoil, and 

respread during the restoration process. 

OM-30 If sensitive wildlife species are killed or injured due to O&M activities, the 

appropriate federal agency will be notified. 

OM-31 All on-site personnel will be made aware that all birds of prey are protected by 

federal and state laws. 

Nesting, roosting and perching birds can cause power outages if their feces or nesting materials 

interfere with conductors, insulators, or air gap. The Proponents, in consultation with the 

U.S Fish and Wildlife Service (USFWS), manage nesting on transmission line structures to 

reduce conflicts. Such management may include relocating nests, modifying structures, and 

providing nesting platforms. The Proponents will continue to consult with the USFWS, and when 

a problem nest is located on federal or state lands, the appropriate land management agency. 

If an emergency occurs and access is immediately needed, the federal agency will be notified 

as soon as possible. Depending on the urgency, the agency may not have responded until after 

the repair work has begun. Timing restrictions may not be adhered to, but the other measures 

listed above will be followed to the extent possible. 

4.6 Restoration and Revegetation 

The Reclamation, Revegetation, and Weed Management Plan to be written by the Proponents 

and approved by the appropriate agency with regulatory authority over lands within the Project 

area, will include site-specific restoration measures, species to be replanted, and monitoring. It 

combines the Proponents’ best management practices (BMPs) with site-specific mitigation 

developed in consultation with the agencies. After ground-disturbing maintenance activities, the 

Proponents propose to use the following EPMs presented in the Revised Plan of Development 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 15

(August, 2008) to assure that appropriate reclamation and revegetation is implemented, and to 

prevent accidental introduction or transport of noxious weeds along the ROW. Summaries of 

these EPMs are as follows: 

RRW-1 Propose to use industry standard practices and BMPs for site stabilization 

and vegetation restoration. 

RRW-2 Identify known occurrences of noxious and invasive weeds. 

RRW-7 Employ appropriate interim erosion control measures if seeding cannot take 

place immediately. 

RRW-8 Restore temporarily disturbed areas as closely as practicable to original 

contours. 

RRW-11 Use of certified weed-free cover materials. 

RRW-12 Seed mixes will be certified weed free. 

4.7 Protection Measures for Cultural Resources 

As part of the EIS preparation, and prior to any construction activities, a 100% pedestrian 

survey of the ROW and areas proposed for disturbance outside the ROW will have cultural 

and/or paleontological surveys conducted. All cultural and/or paleontological resources or 

historic or prehistoric sites or objects discovered by the Proponents, or their designated 

contractor, will be immediately reported. Additional surveys will not be conducted for O&M 

activities if the work area was previously surveyed prior to construction of the line and ancillary 

facilities. 

If new probable historic, cultural, or paleontological resources are discovered during routine or 

corrective O&M activities, potentially destructive work within 300 feet of the find will be halted 

and the appropriate federal or state agency notified. The Proponents will also immediately 

implement the following measures: 

a. Flagging will be erected to prohibit potentially destructive activities. 

b. The Proponents’ archaeologist or designated archaeologist will make a preliminary 

assessment of the newly discovered resource. 

c. If the archaeologist determines that the discovery represents a potential new site or 

an undocumented feature of a documented site, the appropriate federal or state 

agency will be notified. 

d. O&M will not resume in the identified area until cleared by the appropriate Agency. 

Regarding routine and corrective O&M, the Proponents propose to use the following EPMs 

presented in the Revised Plan of Development (August, 2008) to assure that appropriate 

protection to cultural resources is given. Summaries of these EPMs are as follows: 

CR-1 All Company personnel and contractors conducting the O&M activities will be 

instructed on the protection of cultural resources. 

CR-2 Travel will be restricted to designated routes for crew and vehicles. 

CR-3 The Proponents or their designated contractor will generically mark the known 

cultural or paleontological sites as an avoidance area prior to ground disturbance. 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 16

All human interments will be treated with the respect accorded them by state and federal laws 

applying to human remains. If human remains are discovered during O&M activities, the 

Proponents will stop all work in the immediate area to protect the integrity of the find and notify 

the appropriate law enforcement agency and the landowner or land management agency as 

soon as possible. In addition, the location of the find will be flagged or fenced off to protect it 

from further impacts. The law enforcement agency or coroner will determine the age of the 

human remains. If the remains are not modern, then the Proponents will work with the federal 

or state agency to determine what mitigation is necessary and, once the mitigation is complete, 

resume work in the area. 

4.8 Fire Protection 

Fire regulations on federally managed lands are generally in effect between April 1 and 

October 31 and at other times with unusual weather conditions. O&M activities will follow the 

requirements and procedures specified by the appropriate federal or state agency when 

conducted on federal or state lands. 

The Proponents are responsible for inspecting the transmission lines for fire hazards. When 

working during fire season, the Proponents and/or their contractor will carry the following 

suppression tools and equipment: 

• All power-driven equipment shall be equipped with one (1) fire extinguisher having a UL 

rating of at least 5 BC and one “D” handled or long handled round point shovel, size “0” 

or larger; 

• Each motor patrol, truck, and passenger-carrying vehicle shall be equipped with a 

double-bit axe or Pulaski, 31/2 pounds or larger; and 

• Each internal combustion engine shall be equipped with a spark arrester that meets the 

federal land managing agency’s standards. 

The Proponents and the federal or state land manager will work cooperatively to evaluate 

request for Industrial Fire Precaution Level (IFPL) Waivers that would allow the Proponents 

and/or their contractors to continue working when certain fire restrictions are in place.3 

Transmission lines in the western United States may be interconnected with the lines of other 

utilities. Continued operation of these lines provides stability to the entire interconnected 

Western transmission system. In addition, continuous operation of the transmission lines is 

necessary for the Proponents to supply electric service to their customers. Therefore, the 

federal or state agency will use its best efforts to avoid using fire suppression techniques that 

could take the lines out of service. If the federal or state land manager determines that it must 

use fire suppression techniques, they will notify the Proponents of any and all fire suppression 

efforts that could come into close proximity (2 miles) with the transmission lines prior to initiating 

those efforts. 

The Agencies will notify the Proponents if they are planning a prescribed burn within two (2) 

miles of the transmission line or ancillary facilities. 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 17

4.9 Emergency Notification Procedures 

If the Proponents become aware of an emergency situation that is caused by a fire on or 

threatening federal or state land that could damage the transmission lines or their operation, 

they will notify the appropriate federal contact. Likewise, if the federal or state land manager 

becomes aware of an emergency situation that is caused by a fire on or threatening federal or 

state land and that could damage the transmission lines or their operation, it will notify the 

Proponents. 

5.0 O&M PLAN HISTORY 

The O&M Plan is a living document and changes are anticipated after the plan’s acceptance. 

Amendments will include the date on which changes were made, a brief description of those 

changes, and the signatures of authorized representatives of the Proponents and the agency 

accepting the changes. 

This plan and its updates will be distributed to the following BLM and Forest Service field offices 

(see Table 3). Additionally, the Plan will be made available, as appropriate, to Company 

personnel and their contractors. The Proponents will be responsible for distributing updates 

when they are made. If the federal agencies identify additional parties that require a copy of the 

Plan, they are responsible for distribution and ensuring that party has the current plan. 

In addition, the following items will become part of this section of the O&M plan: 

• List of road closures, and gate locations. 

• Maps containing known locations of sensitive plant and animal species mapped as 

“sensitive areas” without specifying the resource. 

• Known locations of cultural features mapped as “sensitive areas” without specifying the 

resource. 

Table 3. O&M Contact List

Department/Role Contact Name Telephone Cell Phone Email 

Idaho BLM 

Boise District Office & Four 

Rivers Field Office 

3948 Development Avenue 

Boise, ID 83706 

John Sullivan (208) 384-3338 (208) 841-1045 john_sullivan@blm.gov 

Twin Falls District 

440 W F Street 

Shoshone, ID 83352 

Lori Armstrong (208) 732-7227 (208) 308-2950 valori_armstrong@blm.gov 

Bruneau Field Office 

3948 Development Avenue 

Boise, ID 83706 

Cecil Werven (208) 384-3455 None cecil_werven@blm.gov 

Owyhee Field Office 

20 First Avenue West 

Marsing, ID 83639 

Kelley Moore (208) 896-5917 None kelly_moore@blm.gov 

Jarbidge Field Office 

440 W F Street 

Shoshone, ID 83352 

Fred Pence (208) 736-2360 None fred_pence@blm.gov 

Burley Field Office 

15 East 200 South 

Burley, ID 83318 

Scott Barker (208) 677-6678 None scott_barker@blm.gov 
Plan for Operations and Maintenance and Emergency Response Appendix C-4 

October 2010 18

Department/Role Contact Name Telephone Cell Phone Email 

Shoshone Field Office 

440 W F Street 

Shoshone, ID 83352 

Debbie Kovar (208) 732-7201 None debra_kovar@blm.gov 

Idaho Falls District 

4350 Cliffs Drive 

Pocatello, ID 83204 

David Pacioretty (208) 478-6341 None david_pacioretty@blm.gov 

Wyoming BLM 

Wyoming State Office PO 

Box 1828 

Cheyenne, WY 82003 

Tamara Gertsch (307) 775-6115 None tamara_gertsch@blm.gov 

Rawlins Field Office 

PO Box 2407 

Rawlins, WY 82301 

Janelle Wrigley (307) 328-4279 None janelle_wrigley@blm.gov 

Rock Springs Field Office 

280 Highway 191 North 

Rock Springs, WY 82901 

Patricia Hamilton (307) 352-0334 None patricia_hamilton@blm.gov 

Lander Field Office 

PO Box 589 

Lander, WY 82520 

Leta Rinker (307) 332-8405 None leta_rinker@blm.gov 

Casper Field Office 

2987 Prospector Drive 

Casper, WY 82604 

Randy Sorenson (307) 261-7522 None randy_sorenson@blm.gov 

Kemmerer Field Office 

312 Highway 189 North 

Kemmerer, WY 83101 

Kelly Lamborn (307) 828-4505 None kelly_lamborn@blm.gov 

Forest Service 

Caribou/Targhee NF 

1405 Hollipark Dr 

Idaho Falls, ID 83401 

Lisa Klinger (208) 557-5790 None None 

Medicine Bow NF 

2468 Jackson St. 

Laramie, WY 82070 

Tom Florich (307) 745-2435 None tflorich@fs.fed.us

6.0 LITERATURE CITED 

Avian Power Line Interaction Committee (APLIC). 2006. Suggested practices for raptor 

protection on power lines: the state of the art in 2006. Edison Electric Institute, APLIC, 

and the California Energy Commission. Washington, D.C. and Sacramento, CA. 

Idaho Power and Rocky Mountain Power. 2008a. Gateway West Transmission Line Project 

Siting Study. 

Idaho Power and Rocky Mountain Power. 2010. Revised Proposed Plant and Wildlife 

Conservation Plan – Construction Activities. Report dated December 12, 2008 
Gateway West Transmission Line Draft EIS 

Appendix C-5 

Greater Sage-grouse Avoidance, Minimization, and Mitigation 

Measures 

(submitted to BLM by Idaho Power and Rocky Mountain Power 

October 2010) 
October 2010 

1 

Greater Sage-grouse Avoidance, Minimization, and Mitigation 

Measures: Gateway West Transmission Line Project 

Contents

1.0 Introduction .............................................................................................................................. 1

1.1 Existing Greater Sage-grouse Plans and Conservation Direction ........................................ 2

1.1.1 State and Local Working Group Plans .......................................................................... 2

1.1.2 BLM Resource Management Plans .............................................................................. 7

1.1.3 State of Wyoming Governor’s Order ............................................................................ 7

1.2 Idaho Power GIS Analysis ................................................................................................... 8

2.0 Avoidance and Minimization Measures ................................................................................ 10

2.1 Routing and Siting ............................................................................................................. 10

2.2 Conformance with State-wide Plans .................................................................................. 11

2.4 Temporal and Spatial Restrictions ..................................................................................... 13

3.0. Mitigation .............................................................................................................................. 14

4.0 References .............................................................................................................................. 18

Appendix A. Greater Sage-grouse Temporal and Spatial Restrictions by Bureau of Land 

Management Field Office ............................................................................................................. 19

1.0 Introduction 

This plan and its attached figures and tables are provided as a supplement to the August 2008 

Revised Plan of Development (POD) for the Gateway West Transmission Line Project (Project). 

Idaho Power Company and Rocky Mountain Power (Companies) have developed this plan to 

identify: 

• Specific measures that were applied during the development of the proposed corridor and 

route to avoid potential impacts to greater sage-grouse and their habitat1; 

• Environmental protection measures (EPM) that the Companies have incorporated into the 

Project description that will minimize impacts to greater sage-grouse and their habitat; 

and 

• Mitigation measures the Companies will implement to mitigate for adverse impacts to 

greater sage-grouse habitat. 

This plan also describes how the proposed corridor and avoidance and mitigation measures 

comply with, and differ from, state-wide sage-grouse conservation plan and Bureau of Land 

Management (BLM) resource management plan (RMP) protection measures. Where they are 

available and where appropriate, local working group (LWG) plan measures are also 

incorporated into this plan. 

 

1

 For purposes of this document, sage-grouse habitat is defined as those areas designated in Idaho’s state-wide plan 

and core areas designated by the State of Wyoming. For Idaho, mapped sage-grouse habitats include key areas (K) 

and restoration areas (R1, R2, and R3). For Wyoming, mapped sage-grouse habitat includes the following core 

breeding areas (Version 2; 08/15/2008): East of Casper, Alcova, Hanna, NE Baggs, South Pass, Little America, and 

Sage. 
October 2010 

2 

The overall goal for this plan and all of the Companies’ EPMs is to allow for fiscally responsible 

and timely construction, operation, and maintenance of the Project while avoiding, minimizing, 

or mitigating impacts to greater sage-grouse and their habitat. 

Identification of protection and mitigation measures is based on threats and conservation issues 

identified in state conservation plans, existing literature, and Idaho Power’s geographic 

information system (GIS) analysis of existing greater sage-grouse lek and transmission line data. 

In response to this plan, the Companies anticipate that the BLM Interdisciplinary (ID) Team and 

cooperating agencies will: 

 Consider the proposed measures when determining if the Project will impact greater 

sage-grouse and their habitat and the level of significance of the impact; and 

 Consider the Companies need to construct the Project in a timely and fiscally responsible 

manner. 

1.1 Existing Greater Sage-grouse Plans and Conservation Direction 

1.1.1 State and Local Working Group Plans 

Idaho and Wyoming have developed state-wide conservation plans for the greater sage-grouse 

(Idaho Sage-grouse Advisory Committee. 2006. and Wyoming Greater Sage-grouse 

Conservation Plan. June 2003.). Key issues, concerns, and mitigation measures are summarized 

below. Local working group (LWG) plans are also incorporated where available and applicable. 

How the Project’s POD conforms with or deviates from the guidelines is presented in italics after 

the guideline. 

1.1.1.1 CONSERVATION PLAN FOR THE GREATER SAGE-GROUSE IN IDAHO

The Idaho state-wide plan identifies the following management guidelines for power lines: 

1. Use of guywires should be avoided. 

The proposed steel lattice structures are self-supporting and will not require a guy wire. 

The proposed H-frame steel structures are not expected to require guy wires, but guy 

wires may be necessary in very limited situations (e.g., steep topography). 

2. Where existing utility lines, including smaller power distribution lines, telephone lines, or 

wireless communication towers are known to be causing adverse impacts locally, or 

where such impacts are likely, LWGs and/or land-management agencies should work 

closely with power companies and related entities in assessing problem areas and 

developing creative solutions. 

The Companies have not implemented measures to address this since we are only 

proposing distribution lines to the substations and regeneration sites. These lines will 

traverse short distances and are not expected to cause adverse impacts. 
October 2010 

3 

3. New above ground major power transmission lines should be sited in a manner that 

avoids sage-grouse habitat to the extent possible, or they should be buried. 

Refer to Section 2.1 for a detailed discussion of the measures that were implemented 

during development of the proposed corridor to avoid and minimize impacts to sagegrouse. 

While the technologies are emerging for placing 500kV underground, the following 

disadvantages significantly outweigh the advantages: 

• Limited experience – Very little experience exists worldwide, let alone in the US for 

500kV underground transmission. 

• Less capacity and lengthy repairs – Underground cables carry far less capacity than 

overhead lines and when repairs are needed, greater time constraints are required to 

find, excavate and fix the problems. 

• More equipment – Typically, more aboveground substations are required for 

underground lines. 

• Environmental impact – Underground transmission lines require large excavations 

through all habitat types. The right-of-way needs to remain free of all types of woody 

vegetation to prevent interference to the underground lines from tree roots. 

Underground systems tend to be less reliable than overhead installations due to a 

variety of environmental factors. These can include conductor heat buildup, 

underground water, and even attacks from bacteria. Road right-of-ways also need to 

be maintained for maintenance and repair. 

• Cost – Estimates vary widely, but the literature indicates costs could be as much as 

10 to 20 times the cost of overhead transmission lines. 

4. New smaller distribution lines should be buried or sited as far as possible, preferably at 

least 3.2 km from occupied leks and other important sage-grouse seasonal habitats as 

determined locally. 

The Companies are only proposing distribution lines to the substations and regeneration 

sites. The same criteria used during routing of the transmission line will be used during 

routing of the distribution lines. Lek buffers of 0.25 miles will be avoided and the 

Companies will attempt to avoid lek buffers of 0.65 miles. 

5. The placement of raptor perch deterrents on power poles and other structures, such as 

telephone poles, should be considered on a site-specific basis in areas where population 

impacts from raptors and ravens is likely or is a documented problem. 

To eliminate perching, all potential perching surfaces must have effective deterrents. 

There are currently no commercially available perch guards designed to keep raptors off 

an entire structure. Thus, perch deterrents reduce the number of birds perching, but do 

not completely eliminate perching (HawkWatch 2008, Lammers and Collopy 2007). The 

use of perch deterrents is not practicable on steel lattice structures. The Companies have 

also not proposed the use of perch deterrents on other structure types because the 

majority of the route is adjacent to other utilities and perch sites are not limited. This is 

consistent with HawkWatch (2008) which suggests that deterrent devices may be most 
October 2010 

4 

appropriate in extremely perch-limited (both natural and human-supplied) areas or to 

reduce use of specific pole perches in close proximity to a sage-grouse lek. 

Two areas of concern in adding perch deterrents are 1) the lifespan of perch deterrents 

and 2) the increased safety risk associated with the addition of perch deterrents. Many of 

the products become brittle in the sunlight and break or can become contaminated and 

cause outages. Therefore, they require frequent maintenance. Transmission system 

configurations and loading often do not accommodate taking lines out of service for 

maintenance, therefore, maintenance personnel are often required to do cross arm and 

pole replacements with lines energized. This work, by nature, is extremely sensitive and 

requires high levels of skill and training. The introduction of additional attachments to 

structures complicates maintenance efforts and exposes personnel to a higher degree of 

risk. The normal maintenance process requires the attachment of lifting and stabilizing 

devices to unobstructed portions of the structure. Placement of these devices is 

dependent on load centers of gravity, required clearances from energized parts, and 

necessary component movements. Anything that restricts or prevents the proper 

placement or operation of these stabilizing devices has the potential to cause serious 

personnel injury or death. Crews will be required to remove or attempt to work around 

the deterrents, adding cost and risk to the job. 

6. Utility companies should ensure access roads, rights-of-ways and disturbed areas 

associated with their facilities are managed in a manner that restores disturbed areas to 

perennial vegetative cover, and controls the spread of noxious weeds and invasive plant 

species. Coordinate with land-management agencies and others in selecting the most 

appropriate plant species. Consider the use of fire-resistant species in high fire 

frequency/cheatgrass areas. Encourage companies to participate in Coordinated Weed 

Management Areas. LWGs may be of assistance in helping to identify particular 

problem areas. 

As described in Section 2.3, the Companies EPMs will address revegetation of disturbed 

areas, use of fire resistant species, and noxious weed control. 

7. Inspections, maintenance work, and related human activities at or near (1 km or 0.6 

miles) occupied leks that results in, or will likely result in, disturbance to lekking birds 

should be avoided from approximately 6PM to 9AM. Utility companies should work 

closely with Idaho Department of Fish and Game (IDFG), land management agencies and 

landowners in scheduling such activities to minimize disturbance. In general this 

guideline should be applied annually from approximately March 15 to May 1 in lower 

elevation, and March 25 to May 15 in higher elevations. 

Section 2.4 describes the temporal and spatial measures the Companies have committed 

to implement. 

Not all sage-grouse planning areas in Idaho have LWGs, and of those areas within the Project 

area that do have a LWG, only the Owyhee and Jarbidge LWGs have completed plans. The 

state-wide plan identifies threats on a broad scale and proposes measures that the LWG can use 

on a finer scale. The expectation is that where a LWG plan exists, it will be used for specific 
October 2010 

5 

guidance and the state-wide plan will be used when the LWG plan is silent on an issue or 

concern. 

The Owyhee and Jarbidge sage-grouse conservation plans do not identify conservation measures 

specific to electric lines. The plans do identify the need for invasive and noxious weed control, 

habitat improvement, and predator control as tools to increase sage-grouse habitat and 

populations. 

1.1.1.2 WYOMING GREATER SAGE-GROUSE CONSERVATION PLANS 

The Wyoming state-wide plan identifies the following management guidelines for powerlines: 

1. Avoid construction of overhead lines and other perch sites in occupied greater sagegrouse habitat. Where these structures must be built, or presently exist, bury the lines, 

locate along existing utility corridors or modify the structures to prevent perching raptors, 

where possible. 

The Companies did consider greater sage-grouse habitat, lek locations and buffers, and 

existing utility corridors when developing routes (see Section 2.1). Please refer to 

Section 1.1.1.1 for a more detailed discussion of perch deterrents and the feasibility of 

placing the line underground. 

2. Control dust from roads. 

As described in Section 2.3, the Companies EPMs will address dust from roads and longterm BMPs.

LWG plans within Wyoming identified the following management guidelines: 

Bates Hole/Shirley Basin Greater Sage-Grouse Conservation Plan 

 Where possible, use the same corridor for all roads, pipelines and power lines. 

The Companies utilized, to the extent practicable, the designated West-Wide 

energy Corridors and other existing corridors. 

 

 Raptor-proof power poles within 0.5 miles of any greater sage-grouse lek to 

prevent raptors from perching on the poles. 

Please refer to Section 1.1.1.1 for a more detailed discussion of perch deterrents. 

In addition to the information presented in Section 1.1.1.1 regarding perch 

deterrents, it is stated in the Southwest Wyoming Sage-grouse Conservation 

Assessment and Plan that “more research needs to be done to determine 

effectiveness of anti-perch devices...” This suggests that perch deterrents may 

not be as effective as perceived and that other methods of mitigation may be 

appropriate.

 Locate power line in areas to minimize potential avian collisions. Potential 

modifications include burying the lines, avoiding areas of high avian use (for 

example, wetlands, prairie dog towns, and grouse leks), and increasing the 

visibility of individual conductors. 
October 2010 

6 

Please refer to Section 1.1.1.1 for discussion regarding feasibility of placing the 

line underground. Refer to Section 2.1 for a detailed discussion of the measures 

that were implemented during development of the proposed corridor to avoid and 

minimize impacts to sage-grouse and other sensitive areas. 

 When power lines are necessary within 3.4 miles of greater sage-grouse leks 

install underground power lines where feasible to minimize raptor 

perching/predation and collisions. Where practical, locate aboveground power 

lines at least 3.4 miles from any sage-grouse breeding or nesting grounds. 

Please refer to Section 1.1.1.1 for a more detailed discussion of the feasibility of 

placing the line underground. The Companies do not feel that there is substantial 

scientific evidence to support this restriction (please see Section 1.2). The 

Companies also acknowledge that there is not sufficient information to support an 

assertion that power lines do not have any effect on greater sage-grouse; 

therefore, our mitigation proposal does address indirect impacts of lines within 

one km or less of greater sage-grouse habitat.

Southwest Wyoming Greater Sage-Grouse Conservation Plan 

 A controlled surface use stipulation is applied from March 1 to May 15 within 

0.25 mile of the perimeter of active strutting grounds from 8 PM to 8 AM daily. 

Linear disturbances such as pipelines, seismic activity, could be granted 

exceptions. 

Please refer to Section 2.4 for temporal and spatial restrictions the Companies 

will implement; these are more restrictive than what is included in this 

conservation plan. 

 Seasonal restrictions are applied through July 15, within an additional 1.75 mile 

(2 mile total) radius from the perimeter of leks to protect greater sage-grouse 

nesting habitat. Areas within that radius not used for nesting can be excepted, 

provided actual nesting areas are not affected. 

Please refer to Section 2.4 for temporal and spatial restrictions the Companies 

will implement. 

 Seasonal stipulations for winter concentration areas can be applied on a case-bycase basis. 

 Use common and existing corridors where possible to minimize overall 

disturbance to the landscape. 

The Companies utilized, to the extent practicable, the designated West-Wide 

energy Corridors. Corridors are also located adjacent to existing corridors, 

which decreases adverse impact to greater sage-grouse and habitat. Refer to 

Section 2.2 for more discussion. 

 Install anti-perch structures in designated critical sage-grouse habitat.

Please refer to Section 1.1.1.1 for a more detailed discussion of perch deterrents.
October 2010 

7 

South Central Wyoming Greater Sage-Grouse Conservation Plan 

 Avoid high profile structures from 1⁄4 mile to 1 mile from lek perimeter (on caseby-case basis).

Structures will not be located within 0.25 miles of a known lek and will be sited 

0.65 miles from a known lek where practicable. Please refer to Section 2.1 for 

more discussion on route siting.

 Avoid human activity adjacent to leks during the breeding season between hours 

of 8 p.m. and 8 a.m. 

Please refer to Section 2.4 for temporal and spatial restrictions the Companies 

will implement. 

 Avoid construction of overhead lines and other perch sites. Where these 

structures must be built, or presently exist, bury the lines, locate along existing 

utility corridors or modify the structures in key areas. 

Please refer to Section 1.1.1.1 for a more detailed discussion of perch deterrents 

and the feasibility of placing the line underground.

1.1.2 BLM Resource Management Plans 

BLM Field Office (FO) RMP measures are summarized in Appendix A. Measures typically 

include temporal and spatial restrictions and these vary between RMPs. The Companies are not 

proposing to adopt all BLM RMP restrictions because of the variability between RMPs and 

differences with state requirements. Rather, our proposal incorporates aspects of the restrictions 

where appropriate and where they will allow the Companies to construct the Project in a timely 

and fiscally responsible manner. 

1.1.3 State of Wyoming Governor’s Order 

On August 1, 2008 the Governor of Wyoming issued Executive Order (EO) 2008-2 entitled 

“Greater Sage-Grouse Core Area Protection.” The intent of this EO is to demonstrate that the 

State of Wyoming is taking steps to prevent the listing of the greater sage-grouse. The State of 

Wyoming created a Governor’s Sage-grouse Implementation Team, which developed a core 

population area strategy to consolidate the various efforts across the state to conserve the species. 

The EO identifies 12 key objectives to the management of greater sage-grouse and the protection 

of its habitat. These objectives call for more restrictive measures when impacting habitat or the 

species within the core areas and encourage development outside the core areas. The most 

restrictive objective indicates that when development must occur within the core areas, it should 

only be authorized by the state agency when it demonstrates it will not cause declines in greater 

sage-grouse populations. 

Stipulations for development in core sage-grouse population areas for transmission line rights of 

way states, “To the extent possible, new rights-of-way should be authorized parallel and adjacent 

to existing rights-of-way. Above ground towers should be designed to minimize raptor perching. 

Any new rights-of-way not sited parallel and adjacent to existing rights-of-way should be routed 

at least 750 m (0.5 miles) from the perimeter of occupied greater sage-grouse leks.” 
October 2010 

8 

1.2 Idaho Power GIS Analysis 

Transmission siting distance recommendations vary widely between federal agencies, states, 

LWGs, and among industries. Recommendations range from 0.25 to 5 miles distance from leks. 

The most common siting distance recommendation is that new power lines should be built at 

least 2 miles (3.2 km) from sage-grouse habitat. Because the scientific community has little 

information regarding the impact of transmission lines to greater sage-grouse or their habitat and 

there are several petitions pending for the listing of the species with the federal Endangered 

Species Act, the tendency among regulatory agencies is to err on the side of caution. 

In response to this lack of data and to better understand the effect of power lines on greater sagegrouse, Idaho Power Company (IPC) conducted a spatial analysis using a GIS to evaluate the 

relationship between lek status and distance from existing power lines for both distribution and 

transmission poles within the Idaho portion our service territory. IDFG lek locations were 

overlayed with IPC’s spatial data for power structures. Only leks that have had surveys 

conducted since 1965 were included. As of 2007, 598 sage-grouse lek locations are known to 

exist in Idaho Power’s service territory: 238 active, 115 inactive, and 245 of unknown status. 

IDFG defines an active lek as a lek at which 2 or more sage-grouse have been observed 

attending in 2 or more of the previous 5 years. New leks (usually located during aerial 

surveys) receive an active status, even though they have not yet met the 5-year criteria. 

Some leks that are irregularly surveyed by air will receive an active status if displaying 

males are observed in at least 1 year out of 5. An inactive lek is one that was surveyed or 

censused at least 2 years in a 5 year period, but at which no male sage-grouse were 

observed. A lek with an unknown status does not meet either of the above criteria, usually 

because it is not regularly surveyed or censused. If a lek has not been surveyed in the past 

5 years, it automatically receives an unknown status, regardless of its past status. Some 

leks with an unknown status were part of historical documents, for which the location or 

status of the leks has not been confirmed. All reported leks in IPC’s service territory are 

within 18 km of a power line. 

Forty-two active leks and 27 inactive leks occur within 1 km of a power line (Table 1). The 

percentage of leks with known status that are active, categorized by distance from the nearest 

power pole, ranges from 40-84% (Table 1). 

Table 1. The number of active and inactive leks, categorized by increasing distances from the 

nearest powerpole, Idaho Power Service Territory. 

Distance (km) 

Lek Status 0-1 1-2 2-3 3-4 4-5 5-6 6-7 7-8 8-9 9-10 10-18 

 

Inactive 27 18 18 15 10 4 5 9 3 3 2 

Active 42 36 45 31 23 21 14 12 4 2 8 

% active 61 67 71 67 70 84 74 57 57 40 80 
October 2010 

9 

IPC evaluated active leks within 3 km of a power line to determine how many years following 

construction of a line leks have remained active. Within 3 km of a line, 110 leks have remained 

active for greater than 20 years after a line was built (Table 2). Ten leks within 300 m of a 

powerline have remained active a minimum of 28 years after a line was built (8 leks active 

longer than 43 years). These data indicate that leks can remain active for long periods of time 

following construction of a powerline. 

Table 2. Active leks within 1, 2 and 3 km of a powerline, categorized by years since the nearest 

power pole was built within IPC service territory. 

 

# of years lek 

has remained 

active following 

construction of 

a line 

0-1 

km 

1-2 

km 

2-3 

km 

 Total 

0-3 km 

 

 

< 10 years 4 1 0 5 

10-19 years 4 1 3 8 

20-29 years 7 9 7 23 

30-39 years 2 5 4 11 

>40 years 25 20 31 76 

 

Total 42 36 45 123 

The average number of males observed at active leks (5-year average) ranged from 10.6 to 15.2, 

with the highest number observed in leks near the power lines (Table 3). 

Table 3. Average number of males (5-year average, 2003-2007) 

observed at active leks, by distance category.

Lek Distance from Power Line Av. No. Males/Active Lek 

0-1 km 15.2 

1-5 km 14.0 

5-10 14.2 

10-18 km 10.6 

IPC evaluated 27 leks within 1 km of a powerline that have become inactive. We compared the 

year that a powerline was built, the last year that a lek was active, the first year that a lek was 

observed inactive, the percentage of land within 3.2 km of a lek that had recently burned or was 

converted to agriculture, and highways in close proximity to the lek. Several patterns emerged. 

Four leks became inactive prior to a line being built, eight leks became inactive after a line was 

built, five became inactive following extensive fires, six were located in areas with extensive 

agriculture and roads, and four were active 38 years or longer after a line was built before 

becoming inactive. From these data it is clear that many factors contribute to a lek becoming 

inactive and additional research is necessary to determine the role of power lines in greater sage 

grouse decline. 
October 2010 

10 

IPC data, indicating leks have remained active many years following line construction and the 

average number of males found at a lek is similar across IPC’s service territory regardless of 

distance to powerlines, contradict conventional wisdom that greater sage-grouse instinctively 

avoid tall structures or leks quickly disappear when power lines are built in close proximity. 

Based on IPC data, we believe that a lek located more than1 km (0.65 mile) from the proposed 

powerline will be minimally affected by construction, operation, and maintenance. 

2.0 Avoidance and Minimization Measures 

The Companies, recognizing the importance of reducing or eliminating impacts to greater sage 

grouse habitat, took several important steps to avoid and minimize impacts, which are detailed in 

this section. In addition, the Companies are offering compensatory mitigation where all impacts 

could not be avoided or minimized. This mitigation is discussed in Section 3.0. 

2.1 Routing and Siting 

The first step in the routing and siting process was the collection of applicable data in order to 

identify opportunities and constraints in selecting a proposed corridor between fixed points such 

as substation locations. In January 2008, the Companies, with BLM approval and assistance, 

requested data from state and federal agencies and specific individuals. The most common data 

received were lek location and the most common original data source were state game and fish 

management agencies, often amended or supplemented by additional local data and redistributed 

by the BLM state, district, or field offices. In the Casper, Rock Springs, Rawlins, Kemmerer, 

Pocatello, Burley and Shoshone field offices, resource specialists felt existing data were not 

adequate and requested additional field surveys. Nearly 300 miles of protocol level aerial 

surveys were conducted in 2008 within the aforementioned field offices and did not identify any 

new lek locations (Tetra Tech, December 15, 2008). 

In the routing and siting process, the data set used for greater sage-grouse leks included data on 

1)active leks, 2) leks that had not been used for a number of years (inactive), and 3) leks known 

to be abandoned or “historic”. Rather than attempt to sort the data set for active or recently 

active leks, all known lek location, including those known to be abandoned, were equally 

considered in the analysis and avoided, where possible, during the routing process. To avoid 

leks, the Companies applied a 0.25 mile buffer from the center of a lek to all leks and designated 

it as no surface occupancy (NSO). In other words, no land surface development or aerial 

encroachment could occur within 0.25 miles of the center of a lek. This buffer was applied to all 

mapped leks within the study areas and the Project was routed to avoid the buffered areas. 

During the several months of the routing and siting process, the BLM staff indicated that a new 

Instructional Memorandum (IM) would be issued and that this would require a 0.65 mile buffer 

around leks. To avoid having to reroute once the IM was issued, the Companies applied a 0.65 

mile radius buffer to each lek, and the routing made every attempt to avoid the larger area. 

Every proposed and alternate route the Companies presented to BLM for analysis in the EIS 

avoided, without exception, the 0.25 mile radius buffer on all mapped leks. In general, the 

proposed and alternate routes also avoided the 0.65 mile lek buffer, but there are cases where full 

avoidance was not practical given other constraints (e.g., residential or agricultural land use; 

visual resources). To date, the BLM has not issued an IM and a 0.65 mile buffer specific to 

transmission lines has not been established by the BLM. 
October 2010 

11 

Siting and routing are described in more detail in the Siting Study (Idaho Power and Rocky 

Mountain Power; September 2008) and an October 23, 2008 supplemental memo prepared by the 

Companies. 

2.2 Conformance with State-wide Plans 

Idaho and Wyoming state-wide plans identify the use of existing utility corridors and highway 

rights-of-way as a management guideline. As part of the routing and siting process, the 

Companies adopted an overall approach of conforming to existing rights-of-way unless there was 

a compelling reason not to. Table 4 summarizes the miles of the proposed corridor, by segment, 

that are within greater sage-grouse habitat and that are adjacent (within 1 km) to an existing 

corridor within greater sage-grouse habitat. 

Of the approximately 1,144 miles of proposed corridor, 238.4 miles occur within designated 

greater sage-grouse habitat (either core in Wyoming or key and restoration in Idaho); this 

represents 21 percent of the total proposed corridor. Within designated greater sage-grouse 

habitat, 157 miles (66%) are adjacent to an existing transmission line and an additional 25.3 

miles (11%) are adjacent to other corridors. Approximately 56.1 miles (23%) of the proposed 

corridor is not adjacent to an existing corridor within greater sage-grouse habitat. 

Table 4. Sage-grouse habitat intersected by the Project corridor and adjacency to existing 

transmission lines and other corridors. 

Line 

Segment 

Total 

Segment 

Length(mile) 

Total Length of 

Line w/in 

Designated 

Habitat (mile) 

Adjacent to 

Other 

Transmission 

Line w/in 

Designated 

Habitat (mile) 

Adjacent to 

Other Corridors 

w/in Designated 

Habitat2

 (mile) 

Greater than 1 km 

From Any Corridor 

w/in Designated 

Habitat (mile) 

Seg 01E 87.7 0.26 0.26 0.00 0.00 

Seg 01Wa 72.1 15.16 15.16 0.00 0.00 

Seg 01Wb 72.8 16.82 11.62 0.00 5.20 

Seg 01Wc 70.7 14.79 14.79 0.00 0.00 

Seg 02 93.7 50.50 22.4 13.47 14.63 

Seg 03 55.1 0 0 0 0 

Seg 04 200.6 52.00 35.22 3.21 13.56 

Seg 05 53 0 0 0 0 

Seg 06 No construction proposed for this segment

Seg 07 117.4 30.32 0.80 8.63 20.90 

Seg 08 130.9 38.24 37.53 0.00 0.71 

Seg 09 157.6 8.69 8.69 0.00 0.00 

Seg 10 32.9 11.61 10.51 0.00 1.11 

 

Total 1144.5 238.39 156.97 25.31 56.11 

 

2

 Other corridors include pipelines, railroads, road/highway, or a combination of these, but does not include 

transmission lines. 
October 2010 

12 

2.3 Environmental Protection Measures (EPM) 

Appendix B of the POD specifies EPMs that the Companies have incorporated as their BMPs 

and as part of the Project description. These measures have been developed by the Companies to 

maintain environmental quality and meet requirements of various land management plans. 

These measures are applicable Project-wide unless modified through negotiations with individual 

landowners or superseded by permits granted by federal, state, or local agencies. The 

Companies would be responsible to ensure their contractors and employees will implement these 

measures. These EPMs apply to construction, operation, and maintenance as appropriate. 

Implementation of the EPMs will help the Companies to avoid or minimize impacts to greater 

sage-grouse and their habitat. 

Appendix B of the POD contains the following attachments: 

Attachment A, Traffic and Transportation Management, includes measures that require 

compliance with federal policies and standards relative to planning, siting, improvement, 

maintenance, and operation of roads for the Project. This plan will address the following 

measures from the Wyoming state-wide greater sage-grouse conservation plan: 

• Consider developing travel management plans that would allow seasonal closure of roads 

for all but permitted uses (i.e., recreation and hunting) and encourage the reclamation of 

unnecessary or redundant roads. 

• Control dust from roads and other surface disturbances within the population’s season 

habitats. 

Attachment B, Reclamation, Revegetation, and Weed Management, addresses construction 

mitigation, reclamation, and revegetation for lands crossed by the Project. This plan also 

outlines measures to prevent accidental introduction or transport of noxious or invasive weeds. 

This plan will address the following recommendations from the Idaho state-wide greater sagegrouse conservation plan: 

“Utility companies should ensure access roads, right-of-ways and disturbed areas 

associated with their facilities are managed in a manner that restores disturbed areas to 

perennial vegetative cover, and controls the spread on noxious weeds and invasive plant 

species. Coordinate with land-management agencies and others in selecting the most 

appropriate plant species. Consider the use of fire-resistant species in high firefrequency/cheatgrass areas. Encourage companies to participate in Coordinated Weed 

Management Areas”. 

Attachment C, Stormwater Pollution Prevention, includes measures for temporary and 

permanent erosion and sediment control that will be used during construction, operation, and 

maintenance of the transmission line and ancillary facilities. 

Attachment D, Spill Prevention, Containment, and Countermeasures, includes measures for 

spill prevention practices, requirements for refueling and equipment operation near waterbodies, 

procedures for emergency response and incident reporting, and training requirements. 
October 2010 

13 

Attachment E, Cultural Resource and Paleontological Monitoring and Mitigation, describes 

the procedures undertaken to inventory, evaluate, and protect cultural resources, treatment of any 

eligible or listed resource that cannot be avoided, and inadvertent discoveries during 

construction, operation, and maintenance. 

Attachment F, Blasting, outlines the procedures and safety measures for blasting activities. 

Attachment G, Plant and Wildlife Species Conservation, outlines specific conservation 

measures to be implemented in the event state or federally listed species, BLM sensitive species, 

or Forest Service special status species or their habitat are identified within the Project area 

(including, but not limited to, this plan for greater sage-grouse). 

Attachment H, Facility Maintenance, describes the standard maintenance practices to be used 

to maintain the transmission line and associated facilities during operation. EPMs will be 

incorporated in a Facility Maintenance Plan for these practices. 

2.4 Temporal and Spatial Restrictions 

Temporal and spatial restrictions (summarized in Appendix A) vary between RMPs and states 

and can include conflicting requirements within the same RMP. Therefore, the Companies have 

committed to the following restrictions for the construction of this project: 

• All greater sage-grouse leks determined to be within 1 mile of the centerline of the 

Project would be surveyed using protocols, which have been approved by federal and 

state agencies, during the breeding season immediately prior to construction to determine 

whether the lek is active. The Proponents will provide survey results to the appropriate 

land management agency. 

• There would be no construction activities through Idaho’s key and restoration greater 

sage-grouse habitats and Wyoming’s core habitats within 1 mile of active leks from 

March 1 to May 15 between 6 p.m. and 9 a.m. Off-limit areas would be marked so that 

workers in the area are aware of these sensitive areas. 

• If no lek activity has been observed by April 25, construction activities may proceed. 

• Surface disturbance would be prohibited year-round within 0.25 mile of previously 

documented leks. 

• Notification would also be placed in areas frequented by on-site personnel (such as break 

rooms) to advertise the importance of complying with these restrictions. 

• Temporal and spatial restrictions do not apply when lek or nesting and brood rearing 

habitat is separated from Project activities by other forms of human disturbance (e.g., 

agriculture, highways) or by line of sight barriers. 

Adherence to these restrictions in conjunction with implementation of the EPMs and proposed 

mitigation is expected to protect greater sage-grouse and their habitat while still allowing for 

timely and fiscally responsible construction of the Project. 

Except in times of emergency, operation and maintenance activities will be scheduled to avoid 

working within 0.65 mile of active leks during the spring mating season, defined to be between 
October 2010 

14 

March 1 and May 15 in Wyoming and March 15 to May 15 in Idaho, between the hours of 6 PM 

and 9 AM. 

3.0.		Mitigation

In developing this proposal to mitigate for possible impacts to greater sage-grouse and their 

habitat associated with the Gateway West project, the Companies considered the avoidance and 

minimization measures that were incorporated into the routing and siting process; conformance 

with state-wide conservation plan management measures; hypothesized impacts from 

transmission lines; and results of Idaho Power’s spatial analysis. Additionally, environmental 

protection measures identified in the August 2008 POD and this plan were considered. 

The Companies are proposing an in-lieu fee payment for direct permanent impacts within 

mapped habitat. The Companies are not proposing any payment for temporary impacts within 

mapped habitat because temporary impacts will be restored. To acknowledge that current 

information does not clearly indicate the nature and extent of indirect impacts, the Companies 

have also proposed an in-lieu fee payment based on line miles within and adjacent (within one 

km) to mapped habitat. Mitigation funds will be paid to the Office of Species Conservation 

(OSC) in Idaho for impacts that occur in Idaho and to the Wyoming Wildlife and Natural 

Resource Trust (WWNRT) for impacts that occur in Wyoming. The OSC (ID) and WWNRT 

(WY) will disperse funds to sage-grouse local working groups that cover areas impacted by the 

project. These entities have not yet been contacted and their participation will need to be 

secured. 

Mitigation was divided into two main categories: right-of-way located within mapped greater 

sage-grouse habitat and ROW adjacent to greater sage-grouse habitat. Within habitat occurs 

when any portion of the ROW is inside mapped greater sage-grouse habitat. Adjacent to habitat 

is defined as the ROW is outside of mapped habitat by a distance of 1 km or less. Within each of 

these categories, mitigation was further differentiated if the proposed corridor was located 

adjacent to an existing corridor (e.g., transmission line; major highway or road; railroad, gas 

pipeline); and if the impact was direct permanent or temporary and indirect. 

Impacts will be quantified as follows: 

ROW within greater 

sage-grouse habitat: 

 Direct permanent impacts will be quantified by acres. 

 Indirect impacts will be quantified by line miles. 

ROW adjacent to greater 

sage-grouse habitat: 

 No mitigation is proposed for direct permanent impacts.

 Indirect impacts will be quantified by line miles. 

The Companies consider structure locations, regeneration stations, substations, and new service 

and access roads as direct permanent impacts. The Companies distinguish between service roads 

and access roads. The sole purpose of service roads is to provide maintenance crews access to 

the transmission lines. These roads would not exist if the transmission lines did not exist. In 

contrast, access roads serve a broader purpose, such as contributing to the federal, county, or 

state road systems, thus their existence is independent of the transmission line. Access roads 
October 2010 

15 

provide direct or indirect access to the transmission lines, but that access is not their primary 

purpose. Existing access roads are not included as an impact and no mitigation is proposed for 

these. Service and new access roads that will be closed to public use will be revegetated as a 

best management practice to control erosion and sedimentation. Crested wheatgrass (Agropyron 

cristatum) and forage kochia (Kochia prostrata) will be used for revegetation. Both of these plant 

species are fire resistant, will resist noxious weeds, and will also provide habitat for upland birds, 

small mammals, and reptiles. 

The Companies define areas used for storage or fly yards and areas disturbed within the ROW 

between structures during construction as temporary impacts. Temporary impacts will be 

restored in-kind (e.g., grassland will be restored to grassland) and no additional mitigation is 

proposed. Mitigation is summarized in Table 5. 

Wyoming’s core breeding areas have been mapped at a large-scale and consequently, core areas 

include habitats that do not support sage-grouse (e.g., urban areas, roads, etc.) While this plan 

has quantified impacts within and adjacent to core breeding areas, it has not differentiated among 

habitat types within core breeding areas. Final impacts and mitigation will be based on greater 

sage-grouse habitat within core breeding areas and is likely to be less than described in this 

document. The vegetation and habitat maps that are being developed for this Project will be 

used to identify greater sage-grouse habitat in core breeding areas and that will be the basis for 

quantifying impacts. Impacts are also likely to change as the route centerline is defined within 

the 2-mile wide planning corridor. 

Impacts will be quantified using as-builts that will be completed at the end of construction 

activities for each segment. 

Potential temporary and permanent impacts are identified in Table 6 and the number of line 

miles adjacent (within 1 km) to greater sage-grouse habitat and an existing corridor are identified 

in Table 7. 

Table 5. Mitigation for impacts to greater sage-grouse habitat3 associated with the Project. 

ROW4 Other Corridor5 Mitigation 

ROW w/in mapped 

habitat 

Corridor present  Mitigate direct permanent impacts to sage-grouse 

habitat at 1:1 (acre) 

 Mitigate indirect effects at 0.5:1 (line miles) 

 Corridor absent  Mitigate direct permanent impacts to sage-grouse 

habitat at 1:1 (acres) 

 Mitigate indirect effects at 0.75:1 (line miles) 

ROW adjacent to 

mapped habitat 

Corridor present  Mitigate indirect effects at 0.1:1 (line miles) 

 Corridor absent  Mitigate indirect effects at 0.3:1 (line miles) 

 

3

 Habitat or mapped habitat refers to areas delineated in state-wide greater sage-grouse plans. 

4

 Within habitat occurs when any portion of the ROW is inside mapped greater sage-grouse habitat. Adjacent to 

habitat is defined as the ROW is outside of mapped habitat by a distance of 1 km or less. 

5

 Corridor refers to other linear features such as transmission line, highway or major road, railway, or gas line. 
October 2010 

16 

Table 6. Preliminary temporary and permanent impacts associated with the construction and 

operation of the Project. 

Line Segment 

Temporary 

Impact 

(acres)6

Permanent Impact 

(acres)7

Seg 01E 12.11 115.11 

Seg 01W 52.49 0.00 

Seg 01Wa 9.39 111.40 

Seg 01Wb 43.84 144.29 

Seg 01Wc 14.76 83.62 

Seg 02 (1 DC)8 261.47 583.06 

Seg 02 (2 SC) 298.15 644.92 

Seg 03 0 0 

Seg 04 (1DC) 291.31 578.61 

Seg 04 (2 SC) 346.88 641.65 

Seg 05 0 0 

Seg 06 0 0 

Seg 07 204.53 319.86 

Seg 08 211.27 358.79 

Seg 09 119.83 174.04 

Seg 10 91.16 115.72 

Total Lines (1 DC) 1312.14 2584.49 

Total Lines (2 SC) 1404.40 2709.40 

 

Substations 

Aeolus 0 101.94 

Cedar Hill 0 19.62 

Midpoint 0 7.25 

Total Substation 128.82 

 

6

 Temporary impacts include pulling and tensioning sites, fly yards, and staging areas. 

7

 Permanent impacts include structure pads, existing roads that need improvement, new roads, and substations. 8

 Rocky Mountain Power is evaluating the following two options for construction in segments 2-4: one double 

circuit (1 DC) line or 2 single circuit (2 SC) lines. Only one of the options will be built. 
October 2010 

17 

Table 7. Summary of line miles adjacent to greater sage-grouse habitat and miles adjacent to an 

existing corridor. 

Line Segment 

Total Segment 

Length (miles) 

Adjacent to 

Mapped Habitat 

Total Shared Corridor 

Length (miles) 

Adjacent to Mapped 

Habitat 

Total Segment Length 

(miles) Adjacent to 

Mapped Habitat Outside a 

Corridor 

Seg 01E 2.160 0.413 0.407 

Seg 01Wa 5.318 4.381 0.936 

Seg 01Wb 4.351 2.796 1.555 

Seg 01Wc 4.800 3.864 0.936 

Seg 02 3.131 1.807 1.324 

Seg 03 2.293 0.77 1.523 

Seg 04 13.140 2.739 10.401 

Seg 07 16.759 0.775 13.702 

Seg 08 28.252 2.511 25.741 

Seg 09 17.557 2.316 15.241 

Seg 10 13.298 1.717 11.581 

Total 107.436 24.089 83.347 

Table 8 summarizes the mitigation requirements based on the ratios proposed in Table 5, and the 

preliminary impacts identified in Tables 4, 6, and 7. Actual impacts and mitigation requirements 

will be calculated as previously described. 

Table 8. Proposed mitigation ratios and estimated impacts. 

ROW Mitigation 

Within habitat Restore temporary impacts: 1 Double Circuit option: 1,312 acres 

2 Single Circuit option: 1,404 acres 

 Direct permanent impacts at 1:1 1 Double Circuit option: 2,584 acres 

2 Single Circuit option: 2,709 acres 

Substations: 129 acres 

 Indirect impacts adjacent to a corridor at 0.5:1 Adjacent to a transmission line corridor: 157 miles 

 Indirect impacts greater than 1km from a 

corridor at 0.75:1 

Outside a transmission line corridor: 25 miles 

Outside any corridor: 56 miles 

Adjacent to 

habitat 

Indirect impacts adjacent to a corridor at 0.1:1 Adjacent to a corridor: 24 miles 

 Indirect impacts greater than 1 km from a 

corridor at 0.3:1 

Outside a corridor: 83 miles 

Dollar amounts are based on published9 values and the Companies previous experience with 

other revegetation projects. Because of the wide range of activities that can be conducted (e.g., 

 

9

 Average and a range of costs for a variety of activities are provided in Public Review Draft Recommendations for 

Development of Oil and gas resources within Crucial and Important Wildlife Habitats. Version 2.0. revised 

December 9, 2008. Wyoming Game and Fish Department. 

http://www.pinedaleonline.com/news/2008/12/OGWildlifeRecommendations.pdf. Accessed January 15, 2009. 
October 2010 

18 

seeding, prescribed burning, fencing, guzzlers, etc.) to mitigate for impacts to greater sagegrouse and the wide variety of site conditions, cost estimates vary greatly. Costs in this proposal 

are based on average costs and the assumption that most mitigation activities would involve 

revegetation. 

In-lieu fee payments will be calculated using the following formulas: 

Direct permanent impacts: 

Mitigation funding = ($2,000/acre) (mitigation ratio) (acres of direct impact) 

Indirect effects: 

Mitigation funding = ($20,000/line mile) (mitigation ratio) (line miles) 

In-lieu fee payments will be paid over a ten-year period and will initially be estimated based on 

the proposed project. Ten percent of the cost will be paid each year and will be adjusted after asbuilts are finalized. 

4.0		References

HawkWatch International, Inc. 2008. Effectiveness of Raptor Perch Deterrents on an Electrical 

Transmission Line in Southwestern Wyoming. Salt Lake City UT. 24 p. 

Idaho Power Company and Rocky Mountain Power. August 2008. Plan of Development. 

Gateway West Transmission Line Project. 

Idaho Sage-grouse Advisory Committee. 2006. Conservation Plan for the Greater Sage-grouse 

in Idaho. 

Lamers, W. M., and M. W. Collopy. 2007. Effectiveness of avian predator perch deterrents on 

electric transmission lines. Journal of Wildlife Management 71:2752-2758. 

Southwest Wyoming Sage-grouse Conservation Assessment and Plan. July 2007. 

Wyoming Greater Sage-grouse Conservation Plan. June 2003. 
October 2010 

19 

Appendix A.		Greater Sage‐grouse Temporal and Spatial Restrictions by

Bureau of Land Management Field Office

Casper, Wyoming Field Office 

Within Bates Hole/Fish Creek/Willow Creek: 

 Occupied sage-grouse leks will have a 3⁄4-mile CSU buffer to protect breeding habitats. 

Human activity will be avoided between 8 p.m. and 8 a.m. from March 1 to May 15 

(TLS) within this buffer. 

 Occupied sage-grouse leks will have a 4-mile buffer. Within this buffer, surface 

development or wildlife-disturbing activities will be restricted March 15 through July 15 

(TLS). Also, within this 4-mile buffer (CSU), surface disturbing activities will avoid 

sagebrush stands of greater than 10 percent canopy cover. Within this 4-mile buffer, 

mitigate for power poles and other high profile structures that may provide raptor 

perches. Avoid placement of these structures if possible, or install devices to preclude 

raptor perching on the structures. 

 As sage-grouse winter habitats are designated, a TLS will restrict activities from 

November 15 to March 14. Within the designated winter habitats, CSU for surface 

disturbing activities in sagebrush stands of greater than 20 percent canopy cover. 

 The areas will have priority for vegetative treatments to improve sage-grouse habitats and 

for vegetation monitoring to ensure residual herbaceous vegetation is maintained for 

nesting cover on public lands. 

Outside of Bates Hole/Fish Creek/Willow Creek: 

 Avoid surface disturbance or occupancy within 1⁄4 mile of the perimeter of occupied sagegrouse leks. Avoid human activity between 8 p.m. and 8 a.m. from March 1 to May 15 

(TLS) within 1⁄4 mile of the perimeter of occupied sage-grouse leks. 

 Avoid surface-disturbing and disruptive activities in suitable sage-grouse nesting and 

early brood-rearing habitats within 2 miles of an occupied lek, or in identified sagegrouse nesting and early brood-rearing habitats outside the 

 2-mile buffer from March 15 to July 15 (TLS). 

 Avoid surface-disturbing and disruptive activities in sage-grouse winter habitats from 

November 15 to March 14 (TLS). 

Rawlins, Wyoming Field Office 

 Prohibit surface disturbance or occupancy year round within 1⁄4 mile of occupied leks, 

breeding, or nesting habitat. 

 Disruptive activities prohibited March 1 to May 20, 6 pm to 9 am within 1⁄4 mile of 

occupied leks, breeding, or nesting habitat. 

 Avoid surface disturbing activities Mar 1 – July 15 within 2 miles of identified 

nesting/early brood rearing habitat. 

 No surface disturbing or disruptive activities in winter concentration areas Nov 15 - 

March 14. 

 Construction activities within 500 feet of open water and/or 100 feet of intermittent or 

ephemeral channels in potential or known habitat for T&E and Special Status Species 

will be avoided. 
October 2010 

20 

 High-profile structures (e.g., power lines and towers) would be authorized on a case by 

case basis from 1⁄4 mile to 1 mile of an occupied lek. 

 Requesting installation of antiperching devices - TBD. 

Rock Springs, Wyoming Field Office 

 Seasonal restrictions within 1⁄4 mile radius of leks from March 1 to May 15. 

 Seasonal restrictions within 2 mile radius of lek in nesting areas from March 15 to July 

15. 

 Prefer that entire line be outside of 2-mile buffer, but outside of 1⁄4 mile from perimeter is 

acceptable. 

 Requesting installation of antiperching devices - TBD. 

Kemmerer, Wyoming Field Office 

 Avoid surface disturbance or occupancy within 1⁄4 mile of occupied leks. 

 Avoid human activity from 8 pm and 8 am from March 1 to May 15 within 1⁄4 mile of 

perimeter of occupied leks. 

 Avoid surface disturbing and disruptive activity in suitable nesting and early broodrearing habitats within 2 miles of occupied leks. 

 Avoid surface disturbing and disruptive activity in identified nesting and early broodrearing habitats outside the 2 mile buffer from March 15 to July 15. 

 Avoid surface disturbance and disrupting activities in occupied winter habitats from Nov 

15 to March 14. 

Four Rivers (Cascade), Idaho Field Office 

 RMP: No surface occupancy in winter range from December 1 to February 15. 

 RMP: No surface occupancy in breeding grounds from February 15 to June 30. 

 RMP: No surface occupancy within 2 miles of a lek from April 15 to June 30. 

 Guidance for protection is addressed in the MOA in the 1997 Idaho Sage Grouse 

Management Plan, as follows: 

o Avoid disturbance within 0.6 miles of occupied leks from 6 PM to 9 AM from 

March 15 to May 1 in lower elevations and from March 25 to May 15 in higher 

elevations. 

o Use of guy-wires should be avoided. 

o The placement of perch deterrents should be considered on a site specific basis. 

o New structures should be sited at least 2 miles from occupied leks or other 

important seasonal habitats. 

Four Rivers (Kuna), Idaho Field Office 

 MFP: Refer to “Guidelines for Habitat Protection in Sage Grouse Range” as published by 

the Western States Sage Grouse Committee, June 1974. 

Owyhee, Idaho Field Office 

 Guidance for protection is addressed in the MOA in the 1997 Idaho Sage Grouse 

Management Plan, as follows: 

 Avoid disturbance within 0.6 miles of occupied leks from 6 PM to 9 AM from March 15 

to May 1 in lower elevations and from March 25 to May 15 in higher elevations. 

 Use of guy-wires should be avoided. 

 The placement of perch deterrents should be considered on a site specific basis. 

 New structures should be sited at least 2 miles from occupied leks or other important 

seasonal habitats. 
October 2010 

21 

Bruneau, Idaho Field Office 

 MFP: Restrict from March to May any intensive disturbance activities within 2 miles of 

sage grouse strutting grounds, and avoid the establishment of major roads within 1⁄2 mile. 

 MFP: Restrict vehicular traffic to existing roads from November 1 to February 28 in sage 

grouse wintering habitats. 

 Guidance for protection is addressed in the MOA in the 1997 Idaho Sage Grouse 

Management Plan, as follows: 

 Avoid disturbance within 0.6 miles of occupied leks from 6 PM to 9 AM from March 15 

to May 1 in lower elevations and from March 25 to May 15 in higher elevations. 

 Use of guy-wires should be avoided. 

 The placement of perch deterrents should be considered on a site specific basis. 

 New structures should be sited at least 2 miles from occupied leks or other important 

seasonal habitats. 
Gateway West Transmission Line Draft EIS 

Appendix C-6 

Draft Framework for Compensatory Mitigation for and Monitoring of 

Unavoidable Impacts to Waters of the U.S. 

(submitted to BLM by Idaho Power and Rocky Mountain Power 

April 26, 2011) 


 DRAFT 

FRAMEWORK FOR COMPENSATORY 

MITIGATION FOR AND MONITORING OF 

UNAVOIDABLE IMPACTS TO WATERS OF THE 

U.S. 

Gateway West Transmission Line 

Prepared for: 

US Army Corps of Engineers 

Wyoming Regulatory Office 

2232 Dell Range Blvd, Suite 210 

Cheyenne, Wyoming 82009 

And 

Bureau of Land Management

Wyoming State Office 

5353 Yellowstone 

Cheyenne, Wyoming 82009 

Prepared By:

Idaho Power Company

1221 West Idaho Street

Boise, ID 83702

And

Rocky Mountain Power

1407 W North Temple

Salt Lake City, UT 84116

May 2011 
TABLE OF CONTENTS

1.0 INTRODUCTION.................................................................................................................. 1

1.1 PROJECT DESCRIPTION, PURPOSE, AND NEED..................................................................... 1

1.2 FRAMEWORK UPDATES ...................................................................................................... 7

2.0 AQUATIC RESOURCE REGULATIONS.............................................................................. 7

2.1 CWA - SECTION 303(D) LIST OF IMPAIRED WATERS ............................................................. 7

2.2 CWA - SECTION 130.7 TOTAL MAXIMUM DAILY LOAD ........................................................... 7

2.3 CWA - SECTION 401 WATER QUALITY CERTIFICATION ......................................................... 8

2.4 CWA - SECTION 402 NPDES PERMITS ............................................................................... 8

2.5 CWA - SECTION 404 WATERS OF THE U.S. PERMITS ........................................................... 9

2.6 RIVERS & HARBORS ACT OF 1899, SECTIONS 9 AND 10 ................................................10

2.7 OTHER PERMITS AND PROGRAMS.......................................................................................11

3.0 AVOIDANCE AND ENVIRONMENTAL PROTECTION MEASURES ..................................11

3.1 SITING ..............................................................................................................................11

3.2 ENVIRONMENTAL PROTECTION MEASURES AND PLANS........................................................13

3.3 ROAD AND WATERBODY CROSSING STANDARDS.................................................................14

4.0 PRELIMINARY ESTIMATION OF IMPACTS TO WATERS OF THE U.S............................15

4.1 METHODS .........................................................................................................................15

4.1.1 Indicative vs. Design Engineering .............................................................................16

4.2 IMPACTS TO WATER OF THE U.S.........................................................................................16

4.3 ALTERNATIVE ROAD DESIGNS IN WATERS OF THE U.S. CONSIDERED BUT NOT PROPOSED ....17

5.0 MITIGATION FRAMEWORK...............................................................................................18

5.1 MITIGATION BANKS............................................................................................................18

5.2 IN-LIEU FEE PROGRAM.......................................................................................................18

5.2.1 ILF Mitigation Parameters .........................................................................................19

5.3 PERMITTEE RESPONSIBLE MITIGATION ...............................................................................19

5.3.1 Compensatory Mitigation Sub-plans..........................................................................21

5.4 LOCATION OF REQUIRED MITIGATION AND KNOWN MITIGATION OPPORTUNITIES ...................22

5.4.1 Known Mitigation Opportunity....................................................................................25

6.0 REFERENCES ...................................................................................................................28
LIST OF TABLES

Table 1. Segment Summary...................................................................................................... 2

Table 2. Acres of Wetland and Riparian Impacts by 6th Order HUC across the Project .........22

LIST OF FIGURES

Figure 1. Wyoming Overview Map ............................................................................................ 3

Figure 2. Idaho Overview Map ................................................................................................. 5

Figure 3. 6th Order HUCs across the Project ................................................................23

Figure 4. Bear Lake County Leases........................................................................... 26

LIST OF APPENDICES

Appendix A. Impaired Waterbodies within the Proposed Route

Appendix B. Road and Culvert Crossing Examples

Appendix C. Current In-Lieu Fee Opportunities

Appendix D. Draft In-Lieu Fee Instrument
May 2011

ACRONYMS AND ABBREVIATIONS

BLM Bureau of Land Management

BMP Best Management Practice

CGP Construction General Plan

Companies Idaho Power and Rocky Mountain Power

CWA Clean Water Act

DEIS Draft Environmental Impact Statement

EPM Environmental Protection Measure

EPC Engineering, Procurement and Construction

GIS Geographic Information Systems

HUC Hydrologic Unit Code

IDEQ Idaho Department of Environmental Quality

IDWR Idaho Department of Water Resources

ILF In-Lieu Fee Program

IRT Interagency Review Team

IM Instructional Memorandum

kV Kilovolt

MW Megawatt

NDEP Nevada Department of Environmental Protection

NEPA National Environmental Policy Act

NERC North American Electric Reliability Corporation

NPDES National Pollutant Discharge Elimination System

NTP Notice To Proceed

O&M Operations and Maintenance

POD Plan of Development

Project Gateway West Project

RMP Rocky Mountain Power

ROD Record of Decision

ROW Right-of-Way

SPCC Spill Prevention, Control, and Countermeasures Plan

SWPPP Storm Water Pollution Prevention Plan

TMDL Total Maximum Daily Load

USACE U.S. Army Corps of Engineers

USEPA U.S. Environmental Protection Agency

USFWS U.S. Fish and Wildlife Service

USFS U.S. Forest Service

USGS U.S. Geologic Survey

WDEQ Wyoming Department of Environmental Quality

WECC Western Energy Coordinating Council

WWEC West-Wide Energy Corridor
May 2011 Page 1

1.0 INTRODUCTION

This Framework for Compensatory Mitigation for and Monitoring of Unavoidable Impacts to 

Waters of the U.S. (Framework) establishes a proposed concept and process to be undertaken 

for the mitigation and compensation of impacts to waters of the U.S. due to the construction and 

operation of the Gateway West Transmission Line Project (Project).

This document describes the proposed Framework for mitigating impacts to waters of the U.S.

that would result from the proposed Project and is intended to present an approach that would

satisfy the mitigation requirements of the United States Army Corps of Engineers (USACE)

1

. 

The overall objective of the Framework is to ensure that there would be no net loss of function 

or area of waters of the U.S. resulting from construction and long-term operation and 

maintenance (O&M) of the Project. The Project’s currently estimated permanent impacts to 

wetlands and riparian areas are approximately 27.4 acres for the Proposed Route. Temporary 

impacts to wetlands and riparian areas are currently estimated at 83.6 acres for the Proposed 

Route. Other alternative routes, suggested by agencies, local groups, and cooperating 

agencies, have different and sometimes larger impacts to wetlands and riparian areas. Impact 

estimates are based on indicative (desktop) design and would decrease as site-specific design 

engineering is completed. 

Other federal (e.g., Bureau of Land Management [BLM]) or state (e.g., Idaho Department of 

Water Resources [IDWR], Department of Environmental Quality [IDEQ]) agencies may also 

require additional mitigation for impacts to aquatic resources beyond those required for the 

Clean Water Act (CWA) Section 404 permit from the USACE. As those requirements are 

specified, they would be incorporated into this Framework. This Framework builds on the 

Aquatic Permitting Program (Idaho Power Company and Rocky Mountain Power, 2010, 

incorporated by reference) that proposes a phased approach to aquatic permitting that is 

appropriate for a multi-state, 1,000 plus mile long transmission line.

This Framework represents the commitment on the part of Idaho Power Company and Rocky 

Mountain Power (RMP) (the Companies) to work with the USACE and other agencies to 

develop a wetland mitigation program, and provides the structure for reaching agreement on the 

program. This Framework, together with the other proposed environmental protection 

measures, other plans, and project avoidance, minimization, and mitigation measures,

comprises the Companies’ commitment to wetland mitigation. 

1.1 Project Description, Purpose, and Need

The Companies are proposing to construct, operate, and maintain approximately 1,148 miles of 

new 230 kilovolt (kV) and 500kV electric transmission system consisting of 11 segments 

between the planned Windstar Substation at Glenrock, Wyoming, and the Hemingway 

Substation near Melba, Idaho (Figures 1 and 2). The Project would relieve existing congestion, 

capacity, and reliability constraints and would allow for the delivery of up to 3,000 megawatts 

(MW) of additional energy to service areas principally in Utah and Idaho, but also the larger 

service areas of the Companies. The first segment of the Project has a required in-service date 

 

1

40 CFR 230; Compensatory Mitigation for Losses of Aquatic Resources; Final Rule; April 10, 2008 

Federal Register 
May 2011 Page 2

of 2014; each segment has its own construction schedule that starts upon completion of the 

BLM-lead National Environmental Policy Act (NEPA) process and issuance of all necessary 

permits and authorizations. In addition to the transmission line and structures, the Project 

includes the following associated facilities:

Permanent access and service roads to each structure, substation, and regeneration 

site; 

Laydown yards, staging areas, and other temporary construction ground disturbances;

Construction of new substations; 

Expansion of existing substations, including those under construction for other projects;

Communication systems with optical fiber regeneration stations (regen sites); and

Substation distribution supply lines.

A more detailed description of the Project is provided in the Plan of Development (POD) (Idaho 

Power Company and Rocky Mountain Power, 2008) and subsequent revisions (incorporated 

herein by reference). The POD provides more detailed information on the purpose and need; 

proposed route; project-related facilities; details associated with construction, operation, and 

maintenance of the project; and applicant-proposed environmental protection measures 

(EPMs). The POD and other project-related documents can be accessed at: 

http://www.wy.blm.gov/nepa/cfodocs/gateway_west/documents.php. Table 1 provides a brief 

summary of the segments and the number of proposed alternatives that are being evaluated in 

the Environmental Impact Statement. 

Table 1. Segment Summary

Segment 

#

Proposed 

Length

Originating 

Substation

Terminating 

Substation

Number of

Alternatives

1E 100.5 Windstar Aeolus 3

1W(a) 76.5 Windstar Aeolus 1

1W(b) 70.6 Windstar Aeolus 0

2 96.7 Aeolus Creston 3

3 56.5 Creston Anticline 0

4 203 Anticline Populus 6

5 54.6 Populus Borah 5

7 117.9 Populus Cedar Hill 10

8 131 Midpoint Hemingway 4

9 161.7 Cedar Hill Hemingway 5

10 33.6 Cedar Hill Midpoint 0
May 2011 Page 3

Figure 1. Wyoming Overview Map
May 2011 Page 5

Figure 2. Idaho Overview Map
May 2011 Page 7

1.2 Framework Updates

This Framework is a living document and will be updated to include the following when available 

and appropriate:

Recommendations from the USACE, BLM, and state agencies on compensatory 

mitigation for impacts to waters of the U.S.;

Other federal and state agency requirements when specified;

Revised impact calculations based on avoidance and minimization measures, including 

changes in road or route alignment; 

Incorporate the preferred alternative for federal lands when identified by the BLM and 

USFS; and

Details on the Companies proposed mitigation for unavoidable impacts to waters of the 

U.S.

2.0 AQUATIC RESOURCE REGULATIONS

Construction, operation, and maintenance of the Project includes ground disturbing activities 

that could impact aquatic resources. The following regulations and associated permits and 

authorizations would be required for the Project. 

The CWA (33 USC Section 1251 et seq., formerly the Federal Water Pollution Control Act of 

1972), was enacted with the intent of restoring and maintaining the chemical, physical, and 

biological integrity of the waters of the United States. The CWA requires states to set standards 

to protect, maintain, and restore water quality through the regulation of point source and certain 

non-point source discharges to surface water. The CWA also requires the USACE to administer 

permits for dredge or fill in waters of the U.S.. Specific sections of the CWA that apply to the 

Project are described below, followed by a brief description of other aquatic resource permits 

required for the Project. 

2.1 CWA - Section 303(d) List of Impaired Waters

Section 303(d) of the CWA establishes requirements for states and tribes to identify and 

prioritize water bodies that do not meet water quality standards through current technologybased regulations and controls. A water quality standard defines the designated beneficial uses 

of a water segment and the water quality criteria necessary to support those uses. Currently, 

both IDEQ and Wyoming Department of Environmental Quality (WDEQ) are required to conduct 

a comprehensive analysis of their respective state’s water bodies every two years to determine 

if they meet water quality standards and develop a list of impaired or threatened waters that 

require Total Maximum Daily Load (TMDLs). The Project would need to implement measures to 

avoid and / or reduce the potential that it would contribute to the listing of a water body as 

impaired or be inconsistent with an adopted TMDL.

2.2 CWA - Section 130.7 Total Maximum Daily Load

Section 130.7 of the CWA requires states to establish TMDL programs, which are approved by 

the USEPA for streams and lakes that do not meet adopted water quality standards. A TMDL 

includes a quantitative assessment of water quality problems, contributing sources, and load 

reductions or control actions needed to restore and protect water bodies. A TMDL budget takes 
May 2011 Page 8

into account loads from point, nonpoint, and natural background sources. National Pollutant 

Discharge Elimination System (NPDES) permits address point-source pollution to surface 

waters. Non-point source pollution is addressed by the application of Best Management 

Practices (BMPs), EPMs, and mitigation measures. 

In compliance with the federal CWA, the IDEQ and the WDEQ have identified Section 303(d) 

water quality limited streams and lakes for development of TMDL criteria. TMDLs have been 

established for surface waters in Idaho. WDEQ has developed few TMDLS at this time as they 

are just beginning to implement the TMDL program; they are currently working on eight TMDLs. 

WDEQ projects that from the time of listing a waterbody as impaired, a TMDL for that waterbody 

would be developed within 1-5 years. 

Stream segments within the Project Area that have been identified on 303(d) lists as impaired 

due to either sedimentation (sediment-impaired streams) or high temperatures (temperatureimpaired streams), are listed in Appendix A for the Proposed Route. 

2.3 CWA - Section 401 Water Quality Certification

Pursuant to section 401 of the federal CWA, any permit or license issued by a federal agency 

for an activity that may result in a discharge into waters of the U.S. requires certification from the 

state in which the discharge originates. This requirement allows each state to have input into 

federally approved projects that may affect its waters (rivers, streams, lakes, and wetlands) and 

to ensure the projects would comply with state water quality standards and any other water 

quality requirements of state law. State certification ensures that the project would not 

adversely impact impaired waters (waters that do not meet water quality standards) and that the 

project complies with applicable water quality improvement plans (TMDLs). The States must 

grant, deny, or waive section 401 certification for a project before a federal permit or license can 

be issued. 

2.4 CWA - Section 402 NPDES Permits

The NPDES program requires facilities discharging from a point source into waters of the U.S. 

to obtain discharge permits. A point source is a conveyance such as a pipe, storm drain or 

other point. USEPA is responsible for permitting and enforcing all NPDES permits in Idaho. 

NPDES permits are administered by the WDEQ in Wyoming. Most storm water discharges are 

considered point sources and require coverage by a NPDES permit. The Project will need to 

obtain coverage under existing construction storm water programs in Idaho and Wyoming.

The NPDES Stormwater Program requires operators of construction sites that disturb one acre 

or more to obtain authorization to discharge stormwater under an NPDES construction 

stormwater permit. In Idaho and Wyoming, the EPA and WDEQ, respectively, have issued 

Construction General Permits (CGP). In order to be covered under the CGP, a site-specific 

Storm Water Pollution Prevention Plan (SWPPP) must be developed. The operator files a 

Notice of Intent which indicates the operator would comply with the CGP. The site operator

must document the erosion, sediment, and pollution controls that would be used during 

construction and operation, inspect the controls periodically, and maintain the controls 

throughout the life of the project. If a TMDL has been established for the water body where a 

project would discharge, and the TMDL indicates that it applies to construction or stormwater 

discharges, then the SWPPP must be consistent with the requirements of that TMDL.
May 2011 Page 9

If hazardous materials, including fuels and lubricants, are used or stored in quantities exceeding 

certain quantities, a Spill Prevention, Control and Countermeasure (SPCC) Plan is required. 

Section 311(j)(1)(c) of the CWA contains the regulations preventing discharge of oil to surface 

water. The SWPPP also contains measures regarding the handling and storage of such 

materials.

2.5 CWA - Section 404 Waters of the U.S. Permits

Section 404 of the CWA authorizes the USACE to regulate the discharge of dredged or fill 

material to the waters of the United States. Discharges are authorized through issuance of 

nationwide permits or individual permits for specific activities. 

The USACE jurisdiction over non-tidal waters of the United States extends to the “ordinary high 

water mark provided the jurisdiction is not extended by the presence of wetlands” (33 CFR § 

328.4); and under Title 40 CFR § 230.3 (s)(1). Waters of the United States are defined as:

“All waters which are currently used, or were used in the past, or may be susceptible to 

use in interstate or foreign commerce, including all waters which are subject to the ebb 

and flow of the tide, all interstate waters including interstate wetlands, all other waters 

such as intrastate lakes, rivers, streams (including intermittent streams), mudflats, 

sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, or natural 

ponds, the use, degradation or destruction of which would affect interstate or foreign 

commerce, including such waters which are or could be used by interstate or foreign 

travelers for recreational or other purposes, or from which fish or shellfish are or could 

be taken and sold in interstate or foreign commerce, or which are used or could be used 

for industrial purposes by industries in interstate commerce; all impoundment of waters 

otherwise defined as waters of the United States interstate commerce, tributaries of 

waters identified in paragraphs 1-4 of this section, the territorial seas; and wetlands 

adjacent to waters.”

Many wetlands are protected under the CWA as waters of the U.S. and special aquatic sites. 

Wetlands are defined by the USACE based on the presence of wetland vegetation, wetland 

hydrology, and hydric soils. In addition, Executive Order 11990, Protection of Wetlands (42 

Federal Register 26961), directs all federal agencies to minimize the destruction, loss, or 

degradation of wetlands, and to enhance the natural and beneficial values of wetlands. Federal 

regulation and management of wetlands follows a “no net loss” policy. Under Section 404, the 

USACE issues a number of nationwide permits for different types of activities that result in 

minimal individual and cumulative adverse effects on the aquatic environment and individual 

permits for larger and more complex impacts.

Nationwide permits. A nationwide permit is a general permit that authorizes a category of 

activities throughout the nation by streamlining the approval process for certain types of 

activities that have minimal impacts to aquatic resources. These permits are valid only if the 

conditions applicable to the permit are met. If the conditions cannot be met, a regional or 

individual permit would be required. Section 404 Nationwide Permit 12 (December 2007 

version) covers construction, maintenance, and repair of utility lines in all waters of the U.S.

provided that there is no change in pre-construction contours. This nationwide permit also 

covers related facilities including substations, structure foundations, and roads; provided that 
May 2011 Page 10

these activities do not result in the loss of greater than 0.5 acre of waters of the U.S. 

Nationwide Permit 12 also authorizes temporary structures, fill, and work necessary to conduct 

utility line activities as long as (1) appropriate measures are taken to maintain normal 

downstream flows and minimize flooding, (2) structures and fill consist of materials that would

not be eroded by high flows, and (3) structures and fill are removed in their entirety and the 

affected areas are returned to pre-construction elevations and re-vegetated as appropriate upon 

project completion. Impact limitations for Nationwide Permit 12 cover all disturbances at a 

single crossing of a wetland or stream, or multiple crossings of the same wetland or stream. 

Any permanent impacts over 0.1 acre to waters of the U.S. require full mitigation, regardless of 

permit type. Permanent loss of more than 0.5 acres of a water of the U.S. requires an individual 

(General) permit rather than coverage under a Nationwide Permit. 

Nationwide Permits contain general conditions that address potential impacts to the 

environment that could result from dredge or fill of waters of the U.S., such as adverse affects to 

soils, migration and spawning habitats, endangered species, or historic properties. 

Supplemental documentation may be required as part of a pre-construction notification package 

(e.g. plant and wildlife survey reports, cultural resource survey reports) to support compliance 

with the general conditions of the Nationwide Permit. Compliance with the National Historic 

Preservation Act and the Endangered Species Act is being addressed in the Environmental 

Impact Statement currently being prepared for this Project.

Individual Permits. Individual Permits are issued following a full public notice interest review of 

an individual application for a Department of Army permit. A public notice is distributed to all 

known interested persons. After evaluating all comments and information received, a final 

decision on the application is made. The final decision is made on a case-by-case evaluation 

and is generally based on the outcome of the public notice process and a determination of 

project benefits versus detriments (losses). 

2.6 RIVERS & HARBORS ACT OF 1899, Sections 9 and 10 

Section 9 of the Rivers and Harbors Appropriation Act of 1899 (33 U.S.C. 403; Chapter 425, 

March 3, 1899; 30 Stat. 1151) (Act) prohibits the construction of any bridge, dam, dike or 

causeway over or in navigable waterways of the U.S. without Congressional approval. 

Administration of section 9 has been delegated to the Coast Guard. Structures authorized by 

State legislatures may be built if the affected navigable waters are totally within one State, 

provided that the plan is approved by the Chief of Engineers and the Secretary of Army (33 

U.S.C. 401). 

Under section 10 of the Act, the building of any wharfs, piers, jetties, and other structures is 

prohibited without Congressional approval, and excavation or fill within navigable waters 

requires the approval of the Chief of Engineers. Authority of the USACE to issue permits for the 

discharge of refuse matter into or affecting navigable waters under section 13 of the 1899 Act 

(33 U.S.C. 407; 30 Stat. 1152) was modified by title IV of P.L. 92-500, October 18, 1972, the 

Federal Water Pollution Control Act Amendments of 1972 (33 U.S.C. 1341-1345; 86 Stat. 877), 

as amended, which established the National Pollutant Discharge Elimination System Permits. 
May 2011 Page 11

The Fish and Wildlife Coordination Act (16 U.S.C. 661-667e; 48 Stat. 401), as amended, 

provides authority for the U.S. Fish and Wildlife Service (USFWS) to review and comment on 

the effects on fish and wildlife of activities proposed to be undertaken or permitted by the 

USACE. USFWS concerns include contaminated sediments associated with dredge or fill 

projects in navigable waters. 

2.7 Other Permits and Programs

Executive Order 11988 requires federal agencies to avoid to the extent possible the long- and 

short-term adverse impacts associated with the occupancy and modification of floodplains and 

to avoid direct and indirect support of floodplain development wherever there is a practicable 

alternative. In accomplishing this objective, “each agency shall provide leadership and shall 

take action to reduce the risk of flood loss, to minimize the impact of floods on human safety, 

health, and welfare, and to restore and preserve the natural and beneficial values served by 

flood plains in carrying out its responsibilities.”

3.0 AVOIDANCE AND ENVIRONMENTAL PROTECTION MEASURES

To the greatest extent possible, the Project has been sited and designed to avoid and minimize, 

impacts to waters of the U.S., as well as other resources, including historic properties listed on 

the National Historic Register and species listed under the Endangered Species Act. This 

section describes the siting process for the Project, the environmental protection measures that 

would be implemented by the Companies, and the road standards used by the Companies to 

minimize impacts where waterbodies must be crossed.

3.1 Siting

The identification of an initial proposed route for the Project was constrained by the purpose and 

need for the project, which includes interconnecting 11 substations between Glenrock, Wyoming 

and the Hemingway Substation located southwest of Boise, Idaho. While some segments have 

one or more alternatives, each segment must begin and end at a particular substation to meet 

the segment’s and Project’s purpose and need. The route between substations was identified 

with the intent of avoiding as many environmental constraints as possible. Constraints were 

defined as resources or conditions that potentially limit transmission line routing because they 

are sensitive to facility construction or operation. Opportunities were defined as resources or 

conditions that can accommodate facility construction or operation because of their 

characteristics. Constraints taken into consideration during initial siting and routing included 

upland and wetland constraints, such as known locations of wetlands and water crossings, 

known concentration or nesting areas for sensitive wildlife species, known populations of rare 

plants, cultural resources, aesthetic resources, and recreational areas. Opportunities taken into 

consideration during initial siting and routing included existing transmission line and other utility 

rights-of-way; transportation corridors, and designated utility corridors.

This approach was implemented by completing the following tasks in coordination with the BLM 

and the United States Forest Service (USFS):

Definition of the Project study area, based on the location of each substation;

Definition of routing opportunities and constraints; 
May 2011 Page 12

Collection and mapping of existing information in the Project study area for each

category of routing opportunity and constraint;

Identification and evaluation of alternative substation sites, where applicable (several 

substations are already in place and/or are planned as part of other projects);

Identification of initial alternate transmission line corridors for each segment and subsegment;

Collection of routing constraint and opportunity information and focused field

reconnaissance in key selected areas;

Completion of initial agency consultation and consultation with other stakeholders (e.g., 

private land owners, counties) to identify potential issues and concerns regarding 

transmission line routing and other Project activities;

Coordination with agencies and groups in the development and refinement of alternative 

corridors in each segment;

Support for the BLM’s evaluation and comparison of alternative corridors in each 

segment; and

Identification of the Companies Proposed Route.

Two general approaches were used to identify and evaluate routes and select the proposed 

route for each segment.

1. In proposed and established utility corridors such as the Section 368 Energy Act WestWide Energy Corridors (WWEC, BLM et al. 2008), or BLM and USFS designated utility

corridors, and/or where existing transmission lines exist, analyses were completed to

characterize the resources present in the areas crossed by the corridors, and to

determine if use of such corridors would result in significant environmental effects. A

combination of constraint mapping, stakeholder input, and field reconnaissance was

used to confirm the use of existing or planned corridors. In several cases, alternative 

routes were proposed because of environmental constraints within or immediately 

adjacent to existing or planned corridors such as greater sage-grouse leks, raptor nests, 

oil and gas wells, etc.

2. Where no existing or planned corridors existed, a “greenfield” siting approach was

followed. In those cases, a Linear Routing Tool2 was used to identify initial corridors for 

further evaluation (Idaho Power and Rocky Mountain Power, 2009). Refinements of 

corridors identified by the LRT were made after reviewing aerial photography and 

topographic maps, known constraints and opportunities, input received from 

stakeholders, and field reconnaissance results.

The Companies conducted extensive routing and siting and proposed a route that best avoided 

most constraints while meeting the Companies’ purpose and need for that segment. Agencies 

 

2

The Geographic Information System (GIS) — based LRT determines the least-cost path between two 

points by first assigning, and then combining environmental acceptability values to GIS data layers within 

a project area. 
May 2011 Page 13

and other groups identified concerns with the route proposed by the Companies and proposed 

partial or complete alternatives for that segment to the BLM. The BLM considered those 

alternatives and included them in the DEIS where the BLM determined that they met the BLM’s 

purpose and need. The Companies worked closely with advocates of the alternative routes and 

conducted siting activities within the generally proposed alternative corridor to avoid known 

resource impacts where feasible, using the same tools and techniques used to determine the 

Proposed Route. 

3.2 Environmental Protection Measures and Plans

The Companies must produce a series of plans that include site-specific EPMs and submit them

to the BLM, USFS, and other appropriate agencies with regulatory authority for review and 

approval before receiving a Notice to Proceed (NTP) to begin construction. These plans have 

been presented in detailed outline form to the BLM for inclusion as part of the overall project 

description in the DEIS, and would be finalized when a final route is permitted and the final 

design is completed. In most instances these plans would either directly or indirectly provide 

protection to wetlands. Plans that are currently proposed and that can affect waters of the U.S. 

include the following:

Reclamation, Revegetation, and Noxious and Invasive Weed Control. The focus of 

this plan is to describe the measures that would be implemented to restore temporarily 

impacted areas. The plan would meet the reclamation requirements specified in BLM 

Instructional Memorandum (IM) No. WY-2009-022 and guidance contained in Chapter 

2840 of the Forest Service Manual as applicable. The plan would also incorporate by 

reference the SWPPP that would be developed to comply with CWA requirements and 

that would include measures to address erosion and sedimentation runoff that could 

result from ground disturbing activities. 

Plant and Wildlife Conservation. This plan presents avoidance and minimization 

measures to reduce impacts to special-status plant and wildlife species from

construction activities. This plan summarizes the avoidance and minimization measures 

conducted during siting and routing of the Project components and outlines specific 

conservation measures to be implemented in the event that state or Federally listed 

species, BLM sensitive species, or Forest Service special-status species or their habitats 

are identified within or adjacent to the Project Right of Way (ROW).

Plan for Operations, Maintenance, and Emergency Response Activities. This plan 

is intended to ensure 1) O&M activities comply with applicable state and federal laws 

and policies; 2) Consistency across and within federal jurisdictions; 3) The Companies 

are able to access the transmission line and ancillary facilities and implement the 

necessary O&M activities in a timely, cost effective and safe manner; 4) Impacts to the 

environment are avoided where practicable or are minimized; and 5) The Companies 

comply with the North American Electric Reliability Corporation (NERC) and Western 

Electric Coordinating Council (WECC) reliability and service requirements.

Stormwater Pollution Prevention. SWPPPs would be prepared in accordance with 

Idaho and Wyoming requirements. The SWPPP would provide detailed descriptions of 

potential pollutants and best management practices (including installation, maintenance, 

and removal standards) for construction activities and long-term stabilization of disturbed 

areas. The SWPPP would also include elements of the SPCC discussed below. 
May 2011 Page 14

Spill Prevention, Containment, and Countermeasures. This plan would outline spill 

prevention practices and requirements for refueling and equipment operation near 

waterbodies, procedures for emergency response and incident reporting, and training 

requirements. The plan would also include site-specific implementation of cleanup 

procedures in the event of soil contamination from spills or leaks of fuels, lubricants, 

coolants, or solvents. SPCC plans would be prepared for construction activities and for 

substation operation where applicable.

3.3 Road and Waterbody Crossing Standards 

The Companies plan to use existing roads and waterbody (e.g., channel, river, streambed)

crossings where practicable and feasible. The Companies conducted siting and design 

engineering to avoid new crossings of perennial streams, rivers, or artificial water conveyances 

such as canals as possible. New roads have been planned to cross waterbodies only where 

avoidance is infeasible and largely where waterbodies are ephemeral or intermittent. 

New road construction, which includes widening existing roads where necessary, would occur 

between existing roads to the ROW and each individual facility, including all transmission 

structures within the ROW. Repair or maintenance of existing roads was not included in impact 

calculations if the original road prism is not proposed to be enlarged. Examples of road 

crossing and culvert standards are found in Appendix B. The specific loads and the stream 

conditions would dictate the type of stream crossing. 

The following waterbody crossings would be used where avoidance is not possible:

Type 1—Drive through: Crossing of a channel with only minimal vegetation removal and no 

cut or fill. This is typical for much of the low-precipitation sagebrush country with rolling 

topography and dry washes or ephemeral draws that rarely carry surface water. 

Type 2—Ford: Crossing of a channel that includes grading and stabilization. Stream banks 

and approaches would be graded to allow vehicle passage and stabilized with rock or other 

erosion control devices. As necessary and where approved by the land-management agency or 

landowner, the stream bed would be reinforced with coarse rock material to support vehicle 

loads, prevent erosion, and minimize sedimentation into the waterway. The rock would be 

installed in the stream bed such that it would not raise the level of the streambed, thus allowing

continued movement of water, fish, and debris. A ford crossing would result in an average 

disturbance profile of 25 feet width (along the waterbody) and 50 feet length (along the 

roadway) for 1,000 square feet or 0.02 acre at each crossing. Ford performance and condition

would be monitored for the life of the road and maintained or repaired as necessary to protect 

water quality.

Type 3— Culvert: Crossing of a channel that include installation of a culvert and a stable road 

surface established over the culvert for vehicle passage. Culverts would be designed and 

installed under the guidance of a qualified engineer who, in collaboration with a hydrologist and 

aquatic biologist if required by the land management agency, would recommend placement 

locations; culvert gradient, height, and sizing; and proper construction methods. Culvert design 

would consider bedload, debris size, and volume. The average disturbance footprint for culvert 

installation is estimated to be 50 feet wide (along the waterbody) and 150 feet long (along the 

road) for 7,500 square feet or 0.17 acre at each crossing. 
May 2011 Page 15

The Companies have a standard set of BMPs in their road and construction manuals (examples 

in Appendix B) and would use additional BMPs where required by land-managing agencies 

during construction. The use of equipment in streams would be minimized where feasible. All 

culverts would be designed and installed to meet the land-managing agency standards and 

culvert slope would not exceed stream gradient. Typically, culverts would be partially buried in 

the streambed to maintain streambed material in the culvert. Adjacent sediment control 

structures such as check dams, rock armoring, or riprap may be necessary to prevent erosion or 

sedimentation. Culverts would be inspected and maintained on a regular basis for the life of the 

Project (estimated at 50 years) for proper operation and to protect water quality.

For waterbodies that are primarily dry, the crossing options include Type 1 through 3, and 

require agency consultation for crossings on Federal lands. For 303(d) listed streams with

sediment as the primary contaminant of concern, additional erosion and sediment control 

devices (e.g., turbidity curtains) would be used if flow is present during installation of in-stream 

structures and other BMPs are not effective. 

4.0 PRELIMINARY ESTIMATION OF IMPACTS TO WATERS OF THE 

U.S.

Preliminary impacts were identified through detailed remote sensing and image interpretation

with ground-truthing. More detailed mapping, field verifications, and jurisdictional 

determinations would be conducted on selected segments once engineering design is further 

developed and refined.

4.1 Methods

Waters of the U.S. were identified through multi-spectral imagery, National Wetland Inventory 

datasets, existing GIS hydric soil layers, and field verification. Details of this survey are 

presented in the Revised Habitat Baseline Technical Report (Tetra Tech 2010). Survey data 

were used to produced a baseline map of current vegetation that is consistent across 

ownership, can be used to route the project outside of sensitive resources to the extent 

practical, and provides the basis for impact assessment in the DEIS. 

The results of the remote sensing effort were validated using data obtained during systematic 

field sampling. Before mapping commenced, biologists field-sampled vegetation communities 

on accessible public lands. Field plot data were not made available to the crews that conducted 

field mapping or remote sensing interpretation; they were used as an independent way to check 

the accuracy of the field and remote sensing efforts The same biologists that collected field 

data also participated in the mapping and quality control effort; therefore, they were familiar with 

the vegetation communities within the Project area. 

To determine the acreage of impacts that could potentially occur to waters of the U.S., the 

Project’s construction and operational footprints were overlain onto the wet areas that were 

mapped through remote sensing. Areas where the Project’s construction or operational 

footprints were co-located with mapped waters of the U.S. were considered to be a direct impact 

and the acreage of impact was calculated using GIS. 
May 2011 Page 16

4.1.1 Indicative vs. Design Engineering 

Initial estimates of construction and operational footprints were determined through indicative 

engineering design. Indicative engineering used an initial project route and road layout that was 

developed based on aerial images, topographic maps, and road and environmental constraint 

data. As a result, they likely overestimate the impacts that would actually occur from Project 

construction and operation. Moreover, the majority of roads and structure locations would be

adjusted following field review and an iterative process that assess potential siting constraints 

and opportunities. For example, Project components would be sited outside of wetlands during 

the final siting process whenever possible as a standard engineering practice. In addition, the 

impacts resulting from tower pads were estimated by applying a standard width buffer to each 

indicative tower location for a construction work area. During engineering design, structure 

locations would be refined to further avoid and minimize impacts to waters of the U.S. where 

feasible.

In areas where the BLM has not included an alternative to the Companies’ proposed route in the 

DEIS, the Companies are in the process of developing an engineering design that integrates 

field work and avoids waters of the U.S. where feasible. To date, a final engineering design

centerline has been developed for Segments 2 and 3 in Wyoming. Because the level of detail in 

the engineering design is greater than indicative design, impacts to waters of the U.S. are less 

than originally estimated. Engineering design would be developed for the remaining segments 

in phases and is dependent on the certainty of agency approval and the amount of access 

granted by private property owners for engineering field verification. Engineering design for 

Segments 1-4 is anticipated to be completed before the Record of Decision (ROD) is published, 

while detailed engineering for Segments 5-10 would occur after the ROD is published. 

4.2 Impacts to Water of the U.S.

The Project comprises critical infrastructure for the Companies and the western U.S. electrical 

grid. Limiting the potential for, and duration of, unplanned outages, and planning for the use of 

live line maintenance techniques to minimize the requirement for any outages, is an important 

part of the design, construction, and O&M requirements for the Project. Because of the need to 

operate this line almost continuously and to avoid unplanned outages, permanent access to the 

line and structures is a critical component of the project. The Companies would use permanent 

fill to construct above-grade service roads in waters of the U.S. This would provide the most 

flexibility for construction and O&M activities and expedited access for emergency restoration 

throughout the year. Service and access roads account for the majority of unavoidable impacts 

to waters of the U.S. for this Project. Required vegetation management for the safe O&M of the 

line also contributes to wetland impacts.

Where avoidance through engineering design was not possible, impacts are being minimized 

where feasible through relocation or redesign of project features. For example, impacts have 

been minimized by reducing desired vegetation management areas and road width to the 

minimum needed for safe operation and compliance with regulatory requirements. Permanent 

and temporary direct and indirect impacts to waters of the U.S. that would result from 

construction and O&M activities are similar in nature but tend to vary in extent. Removal of 

vegetation and the introduction of fill material to waters of the U.S. could directly alter their 

ability to serve as wildlife habitat; their ability to trap sediment and nutrients; and their ability to 

moderate flood flow or facilitate surface water flow. This could also result in indirect impacts 
May 2011 Page 17

such as increased water and soil temperatures and/or alteration of species composition (which 

can also change the function) within these areas. Any blasting that may occur within or 

adjacent to a waters of the U.S. could fracture the bedrock and alter the hydrology of a perched 

water table and potentially lead to drier conditions that impair revegetation efforts. Withdrawal 

of water for use during construction may temporarily impact waters of the U.S. by reducing the 

water input that they would normally receive. 

Service road maintenance and vegetation management could result in minor impacts to 

wetlands or riparian areas. Vehicle traffic in wetlands and riparian areas has the potential to 

permanently alter soil characteristics and drainage patterns unless proper precautions are 

taken. Indirect impacts during maintenance may include compaction of soils, alteration of 

drainage patterns, erosion, and sedimentation. Erosion control and sedimentation runoff 

measures such as water bars, culverts, sediment basins, or perimeter control would be installed 

as required to minimize erosion.

Although some Project-related disturbances to vegetation would be temporary and associated

with construction activities, long-term impacts would occur in forested wetlands because of 

ongoing vegetation management and the time it takes for revegetation efforts to mature. 

Construction impacts in forested wetlands and forested riparian areas would generally involve a 

conversion to a different wetland type (i.e., a change to shrub or herbaceous type), rather than a 

loss of wetland or riparian acreage. The Companies would not actively restore forested 

wetlands because of the potential for trees to interfere with the transmission line. It is likely that 

recovery would be fairly rapid in herbaceous and shrub wetlands, and construction in these 

types is not likely to cause a conversion to a different wetland type. 

4.3 Alternative Road Designs in Waters of the U.S. Considered but not 

Proposed

The Companies have considered the following service road alternatives within waters of the 

U.S., but do not propose to utilize these alternatives because they do not provide safe, timely

year around access to each structure site:

At-grade roads: At-grade roads constructed with geotextiles and road materials which 

allow for water through-flow. This type of road would be below water during certain 

times of the year which would make locating the roads difficult, and the depth of the 

water over the drivable surface may make travel over the submerged road surface 

impractical or infeasible.

Construction timing: Construction within waters of the U.S. could be timed during dry or 

frozen conditions along with the use of low ground pressure tires or specialized tracked 

vehicles. This approach does not allow sufficient flexibility for emergency restoration 

and O&M as the depth of water and/or soil conditions would not allow access to the 

structures during certain times of the year. 

Matting materials: Mats could be temporarily installed to allow access for heavy 

vehicles and equipment. The mats typically come in the form of heavy timbers bolted 

together and spread the concentrated axle loads from equipment over a much larger 

surface area thereby reducing the bearing pressure on fragile soils. The effectiveness 

of mats decreases as standing water increases. Matting has a limited service life before 

replacement is required and must be stored for maintenance and emergency restoration 
May 2011 Page 18

activities. While matting is sometimes used during construction, the Companies do not 

consider it a suitable alternative for emergency restoration or for periodic O&M activities. 

Ice roads: Ice roads can be constructed if suitable winter conditions are present, 

although there is a relatively small window of time during the year where cold enough 

weather is present on the line routes. Ice roads obviously would not allow the flexibility 

required for O&M in other seasons besides winter.

Helicopter construction: This is commonly used in waters of the U.S.; however, the 

weight of the double-circuit 500kV towers preclude the use of helicopter erection. The 

lighter single-circuit 500kV towers would be designed such that they can be erected by 

helicopter if needed. The use of ground based vehicles would still be required for O&M 

activities (e.g., replace hardware; string and tension conductor) and would not eliminate 

the need for a service road to each structure. It is also unlikely that all construction 

activities could be conducted without the use of ground-based vehicles (e.g., 

transporting crews and equipment to the work site).

5.0 MITIGATION FRAMEWORK

The USACE recognizes three mechanisms for providing compensatory mitigation for 

unavoidable permanent impacts to waters of the U.S. Temporarily impacted areas would be 

restored to predisturbance conditions and are not included in the Framework. Listed in order 

from most favorable (preferred by the USACE) to least favorable, these include mitigation 

banks, in-lieu fee programs, and permittee-responsible compensatory mitigation. Both 

mitigation banks and in-lieu fee (ILF) programs involve off-site compensation activities that are 

conducted by a mitigation bank or an in-lieu fee program sponsor. Permittee-responsible 

mitigation is the most traditional form of compensation and continues to represent the majority 

of compensation acreage provided each year (USACE 2008a). As its name implies, the 

permittee retains responsibility for ensuring that required compensation activities are completed 

and successful. Compensatory projects can be located at or adjacent to the impact site (i.e., 

on-site compensatory mitigation) or at another location generally within the same watershed as 

the impact site (i.e., offsite compensatory mitigation). 

Project impacts would be largely confined to the requested ROW for the transmission line and 

roads, occur in multiple locations, and would generally be less than 0.5 acre at each site. The 

Companies would evaluate if on-site or off-site mitigation is appropriate and would consider 

surrounding land uses, the nature and extent of the impact, and agency requirements when 

determining mitigation sites. 

5.1 Mitigation Banks

The USACE prefers the use of mitigation banks, but has indicated that the Project does not fall 

within the service areas of any approved and operational mitigation banks (Johnson 2010; 

Joyner 2010). In addition, it is unlikely any approved mitigation banks would be operational 

within service areas appropriate for this Project on a schedule that would allow for timely Project 

permitting. The Companies’ are not considering creating a mitigation bank as part of this 

Project. Therefore, mitigation banks are not considered a feasible option.

5.2 In-lieu Fee Program

The Companies are proposing to mitigate unavoidable impacts to waters of the U.S. through the 

use of ILF. Second in preference for meeting compensatory mitigation requirements, ILF 
May 2011 Page 19

programs have been developed in some parts of the U.S., but few are present in the project 

area. There are two existing ILF programs in Idaho (Appendix C). The Companies are also 

considering a combination of ILF and permittee-responsible mitigation including preservation,

restoration, and/or enhancement of existing wetlands and/or creation of new wetlands. As 

wetland impacts are further refined and conversations with the USACE continue, the

Companies would determine which mitigation option(s) would be implemented. Suitable 

sponsors for an ILF program include national non-governmental organizations such as The 

Nature Conservancy, Ducks Unlimited, Trout Unlimited, or the Rocky Mountain Elk Foundation, 

state organizations such as the Wyoming Wildlife Federation, or local land trusts. 

The ILF framework and resulting mitigation would provide mitigation at a larger scale, with a 

greater likelihood of long-term success, and an opportunity to provide increased functions over 

smaller, isolated on-site mitigation. The proposed ILF mitigation provides a more robust 

approach to ensure long-term success of mitigation goals, i.e., full replacement of lost wetland 

functions and values.

5.2.1 ILF Mitigation Parameters 

Whether the Companies are able to use existing ILF programs or they must develop one or 

more in partnership with an organization capable of managing it, the following information would

be provided for each separate ILF sponsor:

A description of the sponsor’s experience and qualifications with respect to providing 

compensatory mitigation;

Potential site locations, baseline conditions at the sites, and general plans that indicate 

what kind of wetland compensation can be provided (e.g., wetland type, restoration or 

other activity, proposed time line, etc.);

Geographic service area;

Accounting procedures;

Methods for determining fees and credits including the allocation of advance credits;

A schedule for conducting the activities that would provide compensatory mitigation or a 

requirement that projects would be started within a specified time after impacts occur;

Performance standards for determining ecological success of mitigation sites;

Reporting protocols and monitoring plans;

Financial, technical and legal provisions for remedial actions and responsibilities (e.g., 

contingency fund);

Financial, technical and legal provisions for long-term management and maintenance 

(e.g., trust); 

Provision that clearly states that the legal responsibility for ensuring mitigation terms are 

fully satisfied rests with the organization accepting the fee; and

Review by the Interagency Review Team (IRT) as established by the district engineer in 

accordance with 40 CFR part 230, and public review and comment.

Appendix D contains proposed language for an ILF instrument.

5.3 Permittee Responsible Mitigation

The Companies may use permittee responsible mitigation by itself or in combination with an ILF 

program. While the USACE guidance (FR Vol. 65, No. 216; Nov 7, 2000) states a preference 

for on-site and in-kind mitigation, the Companies would propose mitigation that would likely 
May 2011 Page 20

result in off-site mitigation that includes in-kind and out-of-kind activities either near the impact 

site or in the same watershed/HUC unit. The Companies are not likely to propose on-site 

mitigation because of the need to access structures and associated facilities over the life of the 

project. The comprehensive mitigation plan that would be developed for permittee responsible 

mitigation would include the following:

Objectives—This section would discuss:

The resource type(s) and amounts that would be provided by the mitigation project;

The method of compensation (i.e., restoration, establishment, enhancement, and/or 

preservation); and

The manner in which the resource functions of the mitigation project would address 

the needs of the watershed, ecoregion, physiographic province, or other geographic 

area of interest.

Site Selection—This section would discuss the factors considered during the site selection 

process, such as:

Needs of affected watersheds;

On-site alternatives (where applicable); and

The practicability of accomplishing an ecologically self-sustaining aquatic resource at 

mitigation project site.

Site Protection Instrument — This section would describe measures that would be used 

to ensure the long-term protection of the mitigation project site; including legal 

arrangements and instruments, as well as site ownership.

Baseline Data—This section would discuss or include:

Historic and existing plant communities of the proposed mitigation site and the 

impact site(s);

Historic and existing hydrology of the proposed mitigation site and the impact site(s);

Soil conditions of the proposed mitigation site and the impact site(s);

Map(s) showing the locations of the impact and mitigation site(s) or the geographic 

coordinates for those site(s); and

Other site characteristics appropriate to the type of resource proposed as 

compensation, including delineation.

Mitigation Ratios—This section would describe the number of acres of mitigation wetlands 

to be preserved/created/enhanced based on determined mitigation ratios and total impact 

acres of the Project.

Monitoring—This section would include the following:
May 2011 Page 21

A description of parameters to be monitored in order to determine if the mitigation 

project is on track to meet performance standards, or if adaptive management is 

needed;

A schedule for monitoring and reporting to the responsible agency; and

A description of the length of the monitoring period and responsible party (minimum 

of 5 years and until success criteria or ecological performance standards are met).

Financial Assurances—This section would describe the financial assurances in-place and 

how these assurances are sufficient to ensure a high level of confidence that the mitigation 

project would be successfully completed, in accordance with its performance standards. 

The USACE may require additional information as necessary to determine the 

appropriateness, feasibility, and practicability of the mitigation project.

Ecological Performance Standards—This section would describe the ecologically-based 

standards that would be used to determine whether the mitigation project is achieving its 

objectives.

5.3.1 Compensatory Mitigation Sub-plans

The following sub-plans would also be included as part of the Comprehensive Mitigation Plan:

1. Work Plan—This plan would describe the following:

Geographic boundaries of the mitigation area(s) (including watershed size); 

Construction methods, timing, and sequence;

Source(s) of water, including connections to existing waters and uplands;

Methods for establishing the desired plant community;

Plans to control invasive plant species;

Proposed grading plan, including elevations and slopes of the substrate including 

plan-form geometry, channel form, and design discharge;

Soil management measures; and

Erosion control measures.

2. Maintenance Plan—This plan would include a description and schedule for the 

maintenance requirements to support continued viability of the resource once initial 

construction is completed.

3. Long-Term Management Plan—This plan would include a description of how the 

mitigation project would be managed after performance standards have been achieved 

in order to ensure the long-term sustainability of the resource, including long-term 

financing mechanisms and the party responsible for long-term management.

4. Adaptive Management Plan—This plan would include a description of how the 

mitigation plan would be revised and implemented if changes arise. This plan would 

also identify the party or parties responsible for implementing adaptive management 

measures.
May 2011 Page 22

5.4 Location of Required Mitigation and Known Mitigation Opportunities

Previous discussion with the USACE have indicated that offsite compensatory mitigation, if 

employed, must be located in the watershed in which the disturbance has taken place and that 

the watersheds must be 6th order Hydrologic Unit Code (HUC) or smaller. Figure 3 identifies the 

6

th order HUC boundaries crossed by the project. Table 2 lists the potential impacts from 

operation and maintenance in wetland and riparian areas by 6th order HUC. 

Table 2. Acres of Wetland and Riparian Impacts by 6th Order HUC across the Project

6

th Order HUC Name 6

th Order HUC 

Number

Acres of 

Wetland 

Impacts

Acres of 

Riparian 

Impacts

Total

North Platte 101800 2.66 6.02 8.68

Upper Green 140401 1.20 2.51 3.71

Great Divide Closed Basin 140402 0.30 0.76 1.06

White-Yampa 140500 0.00 0.00 0.00

Upper Bear 160101 1.95 0.08 2.03

Lower Bear 160102 6.12 2.44 8.56

Upper Snake 170402 0.93 1.03 1.96

Middle Snake-Boise 170501 0.47 0.93 1.40

Totals 13.6 13.8 27.4

Note: Acreages within the table are inclusive of unvegetated waters that are associated with wetland or 

riparian areas. Unvegetated waters such as intermittent drainages are not included in this table.

In the event ILF options do not meet the needs of the Companies, are not available when the 

Companies require them, or cannot be developed within these watersheds, the Companies 

would be responsible for the mitigation as described in Section 5.3. To identify land suitable for 

mitigation, priority would be given to sites exhibiting the following:

Stable, predictable water table;

Beneficial habitat features, such as, “in-kind” community design and connectivity to other 

protected or important habitats;

Proximity to other wetlands;

Existing functional features (e.g. flood detention);

Imminent risk for destruction or degradation from development;

Sufficient land area to provide ecologically meaningful upland buffer;

Previously degraded wetlands; and
May 2011 Page 23

Figure 3. 6th Order HUCs across the Project
May 2011 Page 25

Priorities for preservation or protection of existing wetlands are as follows:

contiguous with existing preserved or important habitat areas;

adjacent to areas with low potential for development;

probability for sustained ecological biodiversity value for foreseeable future (low 

probability for future development);

connects two or more preserved or important habitat areas; and

contains important wetlands—significant in maintaining water quality, stream flow and 

aquatic habitat in a contiguous or downstream watercourse, contains habitat, or has the 

potential for creation of habitat, for sensitive wildlife.

5.4.1 Known Mitigation Opportunity

In the upper and lower Bear 6th code HUC, Rocky Mountain Power (RMP) owns several large 

tracts of land within the floodplain of the Bear River (Figure 4). RMP has indicated that if the 

need exists, a portion of their lands could be used for mitigation. A preliminary field visit in 

August 2010, with the USACE, identified a location where mitigation could occur. If the 

Companies determine this is a viable mitigation opportunity, a comprehensive mitigation plan as 

outlined in Section 5.3 would be prepared. To date no other mitigation sites within the 6th order 

HUCs crossed by the project have been identified.
May 2011 Page 26

Figure 4. Bear Lake County Leases
May 2011 Page 28

6.0 REFERENCES

BLM and USFS. 2008. Programmatic Environmental Impact Statement, Designation of Energy 

Corridors on Federal Land in the 11 Western States (DOE/EIS-0386)

Hoobles, M. 2010. Personal communication (phone conversation) with Mathew Hoobles (State 

Coordinator for the Wyoming State Engineers Office) and John Crookston of Tetra Tech on 

June 9, 2010.

Idaho Department of Environmental Quality. 2008. Working Principles and Policies for the 2008 

Integrated (303[d]/305[b]) Report 2 May.

Idaho Power Company and Rocky Mountain Power Company. 2009 Revised Gateway West 

Transmission Line Siting Study. Memorandum to Walt George, BLM National Project 

Manager, December 30, 2009. Available online at: 

http://www.wy.blm.gov/nepa/cfodocs/gateway_west/documents/siting/GW_SitingStudy_08

0915.pdf

Johnson, Tom, 2010. USACE representative, Cheyenne Regulatory Office, Omaha District, 

personal communication with Walt Vering, January 27, 2010.

Joyner, James, 2010. USACE representative, Idaho Falls Regulatory Office, Walla Walla 

District, personal communication with Walt Vering, January 27, 2010.

Tetra Tech, 2010. Revised Habitat Baseline Technical Report for the Gateway West

Transmission Line Project. Boise, Idaho - 4040RPT.DOC.

The Environmental Law Institute (Accessed October 8, 2010; 

http://www.eli.org/Program_Areas/WMB/ilfresults.cfm?state=ID&district=&program=) and 

USACE databases were reviewed to identify existing mitigation opportunities in the project 

area.

USACE (U.S. Army Corps of Engineers). 1987. U.S. Army Corps of Engineers Wetland 

Delineation Manual. Wetlands Research Program Technical Report Y-87-1.

USACE. 2007. Reissuance of Nationwide Permits. Federal Register / Vol. 72, No. 47 / 

Monday, March 12, 2007 / Notices.

USACE. 2008a. Compensatory Mitigation for Losses of Aquatic Resources; Final Rule. 40 

CFR Part 230.

USACE. 2008b. Interim Regional Supplement to the Corps of Engineers Wetland Delineation 

Manual: Western Mountains, Valleys, and Coast Region ERDC/EL TR-08-13. Vicksburg, 

MS: U.S. Army Engineer Research and Development Center.

USACE). 2008c. Interim regional supplement to the Corps of Engineers Wetland Delineation 

Manual: Arid West Region. ERDC/EL TR-06-16. Vicksburg, MS: U.S. Army Engineer 

Research and Development Center.
APPENDIX A

WATERBODIES LISTED AS 

IMPAIRED ALONG THE

PROPOSED ROUTE
30

Waterbodies Listed as Impaired along the Proposed Route

Waterbody Name Segment Milepost 303d_List TMDL List

(Cat4a) TMDL Citation*

Bear River - Idaho/Wyoming border to railroad bridge (T14N, R45E, Sec. 21) Segment 4 139.9 Sediment ID16010102BR001_05

Sheep Creek - source to mouth Segment 4 144.0 Sediment ID16010102BR008_02

Sheep Creek - source to mouth Segment 4 144.9 Sediment ID16010102BR008_02

Bear River -railroad bridge (T14N, R45E, Sec. 21) to Alexander Reservoir Segment 4 148.2 Sediment ID16010201BR002_02

Bear River -railroad bridge (T14N, R45E, Sec. 21) to Alexander Reservoir Segment 4 148.7 Sediment ID16010201BR002_02

Bear River -railroad bridge (T14N, R45E, Sec. 21) to Alexander Reservoir Segment 4 149.1 Sediment ID16010201BR002_02

Bear River -railroad bridge (T14N, R45E, Sec. 21) to Alexander Reservoir Segment 4 149.8 Sediment ID16010201BR002_02

Bear River -railroad bridge (T14N, R45E, Sec. 21) to Alexander Reservoir Segment 4 152.9 Sediment ID16010201BR002_02

Swan Lake Creek Complex Segment 4 192.9 Sediment ID16010202BR018_02b

Marsh Creek - source to mouth Segment 4 195.7 Temperature Sediment ID17040208SK006_03a

Marsh Creek - source to mouth Segment 4 200.0 Temperature Sediment ID17040208SK006_03

Marsh Creek - source to mouth Segment 4 201.2 Temperature Sediment ID17040208SK006_03

Marsh Creek - source to mouth Segment 5 5.2 Temperature Sediment ID17040208SK006_04a

Hawkins Creek - Hawkins Reservoir Dam to mouth Segment 5 6.5 Sediment ID17040208SK011_02

Hawkins Creek - Hawkins Reservoir Dam to mouth Segment 5 7.6 Sediment ID17040208SK011_02

Hawkins Creek - Hawkins Reservoir Dam to mouth Segment 5 8.5 Sediment ID17040208SK011_03

Hawkins Creek - source to Hawkins Reservoir Segment 5 12.7 Sediment ID17040208SK013_02

Hawkins Creek - source to Hawkins Reservoir Segment 5 13.6 Sediment ID17040208SK013_02a

Hawkins Creek - source to Hawkins Reservoir Segment 5 14.9 Sediment ID17040208SK013_02

Bannock Creek - source to American Falls Reservoir Segment 5 23.1 Sediment ID17040206SK002_02

Bannock Creek - source to American Falls Reservoir Segment 5 23.4 Sediment ID17040206SK002_03

Bannock Creek - source to American Falls Reservoir Segment 5 25.8 Sediment ID17040206SK002_02

Bannock Creek - source to American Falls Reservoir Segment 5 26.7 Sediment ID17040206SK002_02

West Fork Bannock Creek - source to mouth Segment 5 27.8 Sediment ID17040206SK008_02

West Fork Bannock Creek - source to mouth Segment 5 29.5 Sediment ID17040206SK008_02

West Fork Bannock Creek - source to mouth Segment 5 29.6 Sediment ID17040206SK008_02

West Fork Bannock Creek - source to mouth Segment 5 30.7 Sediment ID17040206SK008_02

East Fork Rock Creek - source to mouth Segment 5 33.2 Sediment ID17040209SK010_02
31

Waterbody Name Segment Milepost 303d_List TMDL List

(Cat4a) TMDL Citation*

East Fork Rock Creek - source to mouth Segment 5 35.2 Sediment ID17040209SK010_03

East Fork Rock Creek - source to mouth Segment 5 36.0 Sediment ID17040209SK010_02

East Fork Rock Creek - source to mouth Segment 5 36.8 Sediment ID17040209SK010_02

East Fork Rock Creek - source to mouth Segment 5 37.4 Sediment ID17040209SK010_02

Marsh Creek - source to mouth Segment 7 4.8 Temperature Sediment ID17040208SK006_04a

Hawkins Creek - Hawkins Reservoir Dam to mouth Segment 7 6.4 Sediment ID17040208SK011_02

Hawkins Creek - Hawkins Reservoir Dam to mouth Segment 7 7.4 Sediment ID17040208SK011_02

Hawkins Creek - Hawkins Reservoir Dam to mouth Segment 7 10.5 Sediment ID17040208SK011_02

Hawkins Creek - Hawkins Reservoir Dam to mouth Segment 7 11.2 Sediment ID17040208SK011_02

Hawkins Creek - source to Hawkins Reservoir Segment 7 13.2 Sediment ID17040208SK013_02

Hawkins Creek - source to Hawkins Reservoir Segment 7 13.5 Sediment ID17040208SK013_02

Hawkins Creek - source to Hawkins Reservoir Segment 7 13.9 Sediment ID17040208SK013_02b

Hawkins Creek - source to Hawkins Reservoir Segment 7 16.8 Sediment ID17040208SK013_02b

Hawkins Creek - source to Hawkins Reservoir Segment 7 17.4 Sediment ID17040208SK013_02b

Bannock Creek - source to American Falls Reservoir Segment 7 21.2 Sediment ID17040206SK002_02

Bannock Creek - source to American Falls Reservoir Segment 7 22.3 Sediment ID17040206SK002_02

Bannock Creek - source to American Falls Reservoir Segment 7 23.1 Sediment ID17040206SK002_02

Bannock Creek - source to American Falls Reservoir Segment 7 23.5 Sediment ID17040206SK002_03

Bannock Creek - source to American Falls Reservoir Segment 7 23.6 Sediment ID17040206SK002_02

Bannock Creek - source to American Falls Reservoir Segment 7 26.4 Sediment ID17040206SK002_02

Bannock Creek - source to American Falls Reservoir Segment 7 27.6 Sediment ID17040206SK002_02

West Fork Bannock Creek - source to mouth Segment 7 30.6 Sediment ID17040206SK008_02

East Fork Rock Creek - source to mouth Segment 7 33.5 Sediment ID17040209SK010_02

East Fork Rock Creek - source to mouth Segment 7 35.4 Sediment ID17040209SK010_02

East Fork Rock Creek - source to mouth Segment 7 35.7 Sediment ID17040209SK010_02

East Fork Rock Creek - source to mouth Segment 7 37.4 Sediment ID17040209SK010_02

South Fork Rock Creek - source to mouth Segment 7 40.8 Sediment ID17040209SK009_04

Raft River - Heglar Canyon Creek to mouth Segment 7 59.4 Sediment ID17040210SK001_05

Unclassified Waters in CU 17040212 Segment 7 110.3 Sediment ID17040212SK000_02
32

Waterbody Name Segment Milepost 303d_List TMDL List

(Cat4a) TMDL Citation*

Unclassified Waters in CU 17040212 Segment 7 111.0 Sediment ID17040212SK000_02

Unclassified Waters in CU 17040212 Segment 7 111.3 Sediment ID17040212SK000_02

Dry Creek - source to mouth Segment 7 114.2 Temperature Sediment ID17040212SK022_03

Malad River - confluence of Black Canyon Creek and Big Wood River to 

mouth Segment 8 19.2 Sediment ID17040219SK001_06

Malad River - confluence of Black Canyon Creek and Big Wood River to 

mouth Segment 8 19.4 Sediment ID17040219SK001_06

Unclassified Waters in CU 17040212 Segment 8 29.6 Sediment ID17040212SK000_02

Clover Creek - Pioneer Reservoir Dam to mouth Segment 8 39.0 Temperature Sediment ID17040212SK034_04

Little Canyon Creek - source to mouth Segment 8 47.7 Sediment ID17050101SW012_03a

Little Canyon Creek - source to mouth Segment 8 48.2 Sediment ID17050101SW012_02

Cold Springs Creek - source to mouth Segment 8 52.9 Sediment ID17050101SW014_03

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 90.1 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 91.2 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 92.0 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 92.8 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 93.5

Sediment/

Temperature ID17050114SW003_03

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 93.8 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 95.0 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 95.4 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 98.8 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 99.6 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 100.9 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 101.0 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 101.1 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 101.7 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 102.9

Sediment/

Temperature ID17050114SW003_03

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 103.4 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 104.5 Sediment ID17050114SW003_02
33

Waterbody Name Segment Milepost 303d_List TMDL List

(Cat4a) TMDL Citation*

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 105.6 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 106.3 Sediment ID17050114SW003_02

Indian Creek - source to Sugar Ave.(T03N, R02W, Sec. 15) Segment 8 107.1 Sediment ID17050114SW003_02

Snake River - C.J. Strike Dam to river mile 425 (T02N, R04W, Sec. 02) Segment 8 118.0 Temperature ID17050103SW006_07b

Rock Creek - Fifth Fork Rock Creek to river mile 25 (T11S, R18E, Sec. 36) Segment 9 2.3 Sediment ID17040212SK016_04

McMullen Creek - source to mouth Segment 9 3.8 Temperature Sediment ID17040212SK015_02

McMullen Creek - source to mouth Segment 9 4.3 Temperature Sediment ID17040212SK015_02

McMullen Creek - source to mouth Segment 9 5.5 Temperature Sediment ID17040212SK015_02

McMullen Creek - source to mouth Segment 9 6.0 Temperature Sediment ID17040212SK015_02

McMullen Creek - source to mouth Segment 9 6.1 Temperature Sediment ID17040212SK015_03

Cottonwood Creek - source to mouth Segment 9 8.9 Sediment ID17040212SK014_04

Cottonwood Creek - source to mouth Segment 9 9.0 Sediment ID17040212SK014_04

Salmon Falls Creek - Salmon Falls Creek Dam to Devil Creek Segment 9 32.5 Temperature ID17040213SK003_06

Devil Creek - source to mouth Segment 9 37.2 Temperature ID17040213SK002_04

Deadman Creek - source to mouth Segment 9 48.5 Sediment ID17050101SW008_02

Deadman Creek - source to mouth Segment 9 49.0 Sediment ID17050101SW008_02

Deadman Creek - source to mouth Segment 9 49.5 Sediment ID17050101SW008_02

Deadman Creek - source to mouth Segment 9 51.4 Sediment ID17050101SW008_03

Deadman Creek - source to mouth Segment 9 51.7 Sediment ID17050101SW008_02

Deadman Creek - source to mouth Segment 9 53.1 Sediment ID17050101SW008_02

Deadman Creek - source to mouth Segment 9 61.3 Sediment ID17050101SW008_02

Deadman Creek - source to mouth Segment 9 62.6 Sediment ID17050101SW008_02

Deadman Creek - source to mouth Segment 9 72.2 Sediment ID17050101SW008_02

Deadman Creek - source to mouth Segment 9 76.5 Sediment ID17050101SW008_03

Sailor Creek - source to mouth Segment 9 82.1 Sediment ID17050101SW006_04

Sailor Creek - source to mouth Segment 9 82.7 Sediment ID17050101SW006_02

Browns Creek - source to mouth Segment 9 87.6 Sediment ID17050101SW003_04

Sugar Valley Creek - source to mouth Segment 9 104.5 Sediment ID17050102SW008_04

Jacks Creek - confluence of Little and Big Jacks Creeks to C.J. Strike 

Reservoir Segment 9 104.8 Temperature Sediment ID17050102SW002_05
34

Waterbody Name Segment Milepost 303d_List TMDL List

(Cat4a) TMDL Citation*

Birch Creek - source to mouth Segment 9 126.8 Sediment ID17050103SW021_03

Castle Creek - source to mouth Segment 9 131.6

Sediment/

Temperature ID17050103SW014_04

Sinker Creek - source to mouth Segment 9 143.8

Sediment/

Temperature ID17050103SW012_04

Snake River - Milner Dam to Twin Falls Segment 10 23.5 Temperature Sediment ID17040212SK020_07

Unclassified Waters in CU 17040212 Segment 10 26.9 Sediment ID17040212SK000_02

Unclassified Waters in CU 17040212 Segment 10 27.0 Sediment ID17040212SK000_02

Unclassified Waters in CU 17040212 Segment 10 27.5 Sediment ID17040212SK000_02

Unclassified Waters in CU 17040212 Segment 10 28.0 Sediment ID17040212SK000_02

Unclassified Waters in CU 17040212 Segment 10 28.3 Sediment ID17040212SK000_02

Unclassified Waters in CU 17040212 Segment 10 29.0 Sediment ID17040212SK000_02

Unclassified Waters in CU 17040212 Segment 10 29.6 Sediment ID17040212SK000_02

*From Idaho Department of Environmental Quality Working Principles and Policies for the 2008 Integrated (303[d]/305[b]) Report

Category 1 waters are attaining water quality standards and no uses are threatened.

Category 2 waters are attaining some designated uses, and no uses are threatened, but there is insufficient (or no) data and information available 

to determine if the remaining uses are attained or threatened.

Category 3 waters have insufficient data (or no data) and information to enable determining if designated uses are being attained.

Category 4 waters do not support (or threaten) a standard for one or more designated uses, but they do not require the development of a Total 

Maximum Daily Load (TMDL). There are three subcategories under Category 4:

Category 4a waters have had a TMDL completed and approved by EPA.

Category 4b waters have had pollution control requirements placed on them other than a TMDL—and these waters are reasonably 

expected to attain the water quality standard in the near future.

Category 4c waters are those waters for which nonsupport of the water quality standard is not caused by a pollutant.

Category 5 waters do not meet (or threaten) applicable water quality standards for one or more designated uses by one or more pollutants. 

Category 5 water bodies make up the 303(d) list of impaired waters.

NOTE: No impaired waterbodies occur within the project in Wyoming.
APPENDIX B

ROAD AND CULVERT 

CROSSING EXAMPLES
TA 501

Transmission

Construction Standard

7 Apr 08

Page 1 of 10

TA 501

Roads—Construction E 2008 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

Roads—Construction

A. Scope

This standard provides information about constructing transmission line access. All

road construction/improvements, fords, structure/equipment landings, and lay--down

yards shall be held to a minimum. On level terrain, road construction may only require

back-dragging a blade to remove brush to facilitate construction. In undulating or

mountainous terrain the following standards shall apply.

B. Index

The index below provides a quick reference to detailed figures contained in this

standard for road construction with varying slopes and conditions.

Referenced Road

Cross Section

Figure 2

Figure 3

Figure 4

Figure 5

Figure 2

Figure 2

Figure 2
TA 501

Page 2 of 10

Transmission

Construction Standard

TA 501 7 Apr 08

E 2008 by PacifiCorp. All rights reserved.

Roads—Construction

Engineer (C. Wright):

Standards Manager (G. Lyons):

C. Planning

Before construction can take place. the road system must be planned and located

properly. Poor planning or road location is associated with the following most common

causes of road failure (Furniss et al. 1991):

S Improper placement and construction of road fills.

S Insufficient culvert sizes.

S Very steep road grades.

S Improper placement or sidecast of excess materials.

S Removal of slope support by undercutting.

S Altering drainage by interception and concentration of surface and subsurface

flows.

A plan showing existing and new road locations shall be developed and shall be shown

on the company’s access road charts, plan maps, and transportation plan map. Road

locations shall be marked on the ground by survey stakes and blue-and-white, striped

flagging. GPS coordinates shall be obtained to define the road center--line. These

coordinates shall be used to create the transportation plan map. Road information shall

also be placed on transmission line plan maps.

In the event of conflict between the drawings and the staked locations, the latter shall

take precedence and transportation plan maps and the transmission line plan maps

shall be revised accordingly. Any culverts and gates listed in access road charts are

required. Fords, drainage improvements, rip-rap fills and crushed rock requirements

listed in the access road charts are anticipated; however, requirements will be determined based on actual site conditions encountered. If changes are made in the field, the

maps shall be revised to show these changes.

Because roads are long-term features, their location must be carefully chosen to

provide safe access, avoid long-term maintenance problems, reduce potential for

degrading water quality, and minimize costs over the short and long term. For more

information see the references in Section H.

D. Road Construction

Roads shall be constructed in a manner that will support equipment for construction of

the transmission line and to provide access roads for line inspection and maintenance

equipment after the line has been constructed.

All construction access roads on federally managed public lands are subject to

approval prior to construction. Other federal, state, and local landowners may require

approvals before road construction commences on their property. Where side slopes

exceed 60 percent, a full bench cut will be reburied. No side-casting of material will be

allowed in these areas; end-haul of material will be required to a designated location

approved by the federal agency or other property owner. Close coordination with the

federal agency will be required.

The detail drawings provided in this standard for completing cuts and fills, providing

drainage, and installing culverts are furnished as guidelines for the road construction.

Actual road construction cut slopes, fill slopes, drainage requirements, rip-rap, and
TA 501

Transmission

Construction Standard

7 Apr 08

Page 3 of 10

TA 501

Roads—Construction E 2008 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

crushed rock needs will be determined during construction based on site conditions.

Cut and fill quantities shall balance when possible, reducing the material removed or

brought in for road completion.

During road construction, consideration shall be given to restoration required after

construction completion, including re-vegetation, rock cover, and other drainage and

erosion control factors. Clearing and grading shall be minimized to reduce the restoration requirements for disturbed areas. The visual impact of roads on the surrounding

areas shall be considered at all times during construction.

Crushed rock shall be sound, hard, durable, angular, or sub-angular rock, suitable for

road base courses. Crushed rock shall be well graded 2I to 1/4I size (3I to minus-size

skip-graded is a minimum acceptable substitute).

Rip Rap shall be sound, hard, durable, rock ranging in size from 2I to 8I as specified

on drawings and as required by conditions.

Any improvements made, including spur roads, fords, bridges, equipment landings and

lay-down areas, shall be held to a minimum. Following completion of the work, the

removal of these improvements shall be at the discretion of company or its representative.

Roads shall be sufficiently wide, but not less than 14i in width. The construction shall

provide bench cuts, grading, filling, compaction, and ditches necessary to accommodate heavy construction equipment and other heavily loaded vehicles. Roads shall be

installed in accordance with the figures in this standard.

All roads shall be constructed with a smooth, uniform surface and shall be outsloped

where practical to provide drainage and minimum erosion. Avoid outsloped roads

where they will direct runoff onto erodible fill, embankments, or where they would cause

off-camber curves. Where outsloping is not practical, sufficient water dips, water bars,

or ditching, shall be installed as shown in the Section E of this standard. See standards

TA 503, Roads—Water Bars and Water Dips and TA 504, Roads—Culvert Installation

for further detail on proper drainage.

Outsloping a road means building the road surface so that it is tilted outward 2-3

percent so water can run off the road surface (see Figure 1). Outsloping works well

under the right conditions. The following conditions are favorable for use of outsloped

roads with no ditch:

S Short back slopes.

S Terrain slope less than 20 percent.

S Road grades steeper than 3 percent.

S Seasonal road use.

S Light traffic.

S Fast re-vegetation of cut and fill slopes.

Outslopes become a problem if roads are not maintained when ruts begin to form. The

ruts will then act as channels.

The following conditions are unfavorable for outsloping:

S Long back slopes.
TA 501

Page 4 of 10

Transmission

Construction Standard

TA 501 7 Apr 08

E 2008 by PacifiCorp. All rights reserved.

Roads—Construction

Engineer (C. Wright):

Standards Manager (G. Lyons):

S Terrain steeper than 20 percent.

S Steep, continuous road grade.

S Where ruts occur and allow water to concentrate and run along the road.

S Where winter hauling is required.

To minimize rutting and erosion of the right-of-way, road construction shall be completed during predominantly dry conditions. Fills, which will essentially consist of native

soils, shall not be made when the moisture content of the soils will not permit adequate

compaction.

As a minimum level of compaction, common fill shall be placed in 12I-thick, loose lifts

and each lift compacted by walking or tracking in with a heavy dozer or rubber-tired

(pneumatic) equipment. Each lift shall be compacted by at least four passes with the

equipment.

In areas of dense vegetation, the surface organic material shall be stripped from the

ground within the roadway and cut and fill areas. Stripping to a maximum depth of 6I

will be adequate unless otherwise directed by the company or its representative.

Stripped and disturbed areas shall be compacted as specified above or as shown in the

drawings or access road charts.

Personnel constructing the access road system shall be aware of the definition of a

wetland such that potential wetlands may be identified before work is begun. In some

cases where wetlands have been identified, road construction personnel shall comply

with requirements as directed by the company or its representative.

Ditches, installed culverts, and/or installed surface drains to drain wet areas resulting

from springs, seeps, or poor surface drainage may be required to construct the road.

Drainage ditches shall be shallow, not to exceed 18I in depth. The ditch bottom shall

have a width of approximately 1i and side slopes shall not exceed 1.5 to 1 (see

Figure 5).

All earthwork and grading, cut and fill slopes, and other disturbed areas shall be

re-vegetated with seed. Unless otherwise specified, the seed mix shall consist of 45

percent rye grass, 45 percent orchard or fescue grass, and 10 percent clover. The seed

shall be applied at a minimum of 60 pounds per acre. At locations where the ground

slope is greater than 10 percent, the seeds shall be covered with straw- or wood-fiber

mulch applied at a rate of one ton of mulch per acre. The seed shall be spread in early

fall when weather permits.

All phases of operation, including the construction of truck and tractor roads, shall be

conducted to minimize as much as practical the damage to the soil and to prevent

gullies and creation of other conditions conducive to soil erosion. Repair of all erosion

damage shall be accomplished as soon as it occurs to prevent further loss of material

into existing drainages. Cut slopes shall be stabilized. Care shall be taken to avoid

creation of wet land conditions.

Crew movement on the right-of-way, including access routes, shall be limited so as to

minimize damage to land or property. Crews shall endeavor to avoid marring the lands.

Ruts and scars shall be obliterated, damage to ditches, terraces, roads and other

features of the land shall be corrected, and the disturbed land beyond the access roads

and structure landings shall be restored, as nearly as practical, to its original condition

before final acceptance of the work.
TA 501

Transmission

Construction Standard

7 Apr 08

Page 5 of 10

TA 501

Roads—Construction E 2008 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

Erosion control measures shall be installed to minimize the transport of eroded

sediments to streams and other waterways. Erosion control measures may include, but

are not necessarily limited to, straw bales and silt fences.

E. Road Cross Sections

This section provides road cross sections, including required dimensions, cleared

right-of-way width, and other information. See general road construction notes in

Section G and references in Section H.
TA 501

Page 6 of 10

Transmission

Construction Standard

TA 501 7 Apr 08

E 2008 by PacifiCorp. All rights reserved.

Roads—Construction

Engineer (C. Wright):

Standards Manager (G. Lyons):

Figure 1—Typical Road Sections for Different Terrains
TA 501

Transmission

Construction Standard

7 Apr 08

Page 7 of 10

TA 501

Roads—Construction E 2008 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

Figure 2—Typical Cut and Fill Insloped Road Section

for Natural Side Slopes Less Than 30 Percent (15)

Figure 3—Typical Cut and Fill Insloped Road Section

for Natural Side Slopes Greater Than 30 Percent (15) and Less Than 60 Percent (30).
TA 501

Page 8 of 10

Transmission

Construction Standard

TA 501 7 Apr 08

E 2008 by PacifiCorp. All rights reserved.

Roads—Construction

Engineer (C. Wright):

Standards Manager (G. Lyons):

Figure 4—Typical Cut and Fill Section

for Natural Side Slopes Greater than 60 Percent (30).

F. Typical Ditch Section

Typical ditch construction is depicted in Figure 6. Many of the road cross sections

shown above use this ditch construction.

Figure 5—Ditch Section

Notes:

1. Slope the ditch so that it will drain; ditch shall have a minimum slope of 1 percent and

not to exceed 3 percent.

2. Remove all soil, rock, and other material loosened by grading from ditch.

3. Cut slopes will be determined during construction based on site conditions and as

approved by the company representative.
Figure 6—Poor Road

Construction in Wetland Area

TA 501

Transmission

Construction Standard

7 Apr 08

Page 9 of 10

TA 501

Roads—Construction E 2008 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

G. General Road Construction Notes

1. Roads shall follow natural contours as much as practical.

2. Maximum grade for roads shall be 10 percent. Grades up to 20 percent will be allowed

for a distance of 1000 feet where unavoidable and approved by the company.

3. Radius of curves shall be 200 feet, with a minimum of 80 feet when approved by

company. When curves are less than 200 feet, roadbed shall be widened as shown in

Table 1.

4. Cut and fill slopes will be determined during construction based on site conditions

encountered and as approved by the company.

5. Unless specified otherwise by the company, fill material shall consist of site material

excavated from RG-1 cuts. Fill material shall have a maximum particle size of 12I.

6. Fills placed on side slopes of 30 percent or less shall be placed in nominal 9I lifts and

compacted by walking in with at least four passes of earthwork equipment.

7. Fills placed on side slopes greater than 30 percent

shall be placed in nominal 12I-thick lifts and compacted to at least 90 percent of the maximum dry

density as determined by the ASTM D 696 method of

compaction.

8. Allow 1i additional road width on fill slopes for

sloughing. When fills are over 6i high at shoulder,

allow 2i additional road width.

9. Road construction across wetland areas may require

placement of fragmented 6I minus rock. Rock shall

be placed in 8I-thick lifts and compacted by a heavy

dozer or vibratory roller until well keyed. RB-(1) rock

will be provided and installed by the contractor.

Proper construction shall be use in wetlands so

conditions as shown in Figure 7 do not develop.

10. Geotextile fabric material shall consist of MIRAF1212

OHP or equivalent, as approved by the company.

Table 1—Road Width for Different Road Curves

Curve Radius

(feet)

Roadbed

Width (feet)

200 or > 14

150 to 200 16

100 to 150 18

80 to 100 20
TA 501

Page 10 of 10

Transmission

Construction Standard

TA 501 7 Apr 08

E 2008 by PacifiCorp. All rights reserved.

Roads—Construction

Engineer (C. Wright):

Standards Manager (G. Lyons):

H. References

1. Handbook for Forest and Ranch Roads, William E. Weaver, PHD. and Danny

K. Hagans, 1994.

2 A Landowner’s Guide to Building Forest Access Roads, United States Department of Agriculture, Forest Service, Northeastern Area State and Private

Forestry, July 1998.
Figure 1—Water Bar

TA 503

Transmission

Construction Standard

7 Apr 08

Page 1 of 4

TA 503

Roads—Water Bars

and Water Dips

E 2008 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

Roads—Water Bars and Water Dips

A. Scope

This standard describes drainage methods, including water bars, water dips, ditches,

and outsloping, which can be used where intermittent or permanent streams cross

roadways. Depending on the method used, drainage structures should be installed

during or after basic road construction. For information on ditches and culverts see TA

504, Roads—Culvert Installation.

B. Water Bars and Dips

Water bars are narrow structures

which can be constructed at various

depths depending on the need. Deep

bars are generally used on roads

closed to vehicle traffic. Figure 1

shows a typical shallow water bar

constructed across a road.

Water bars can be constructed with

hand tools, but bulldozers are most

commonly used. It is best to start at

the end of the road and work outward so the bars are not damaged

with frequent crossing by heavy

machinery.

Water bars should be installed at an approximate 30° angle downslope. Figure 2 shows

dimensions for construction of water bars and water dips with and without drainage

ditches to be used on access and right-of-way roads. The outflow end of the water bar

should prevent water from accumulating and should not flow directly into a stream. This

will allow sediment to settle out of the water, preventing erosion. As a supplement to

water bars on closed roads, logging slash can be lopped and scattered, grass can be

planted, or both. Table 1 shows recommended spacing between water bars for various

road grades.

Table 1—Distance Needed Between Water Bars

Road grade

(percent)

Distance

(feet)

2 250

5 135

10 80

15 60

20 45

25 40

30 35

Source: Kochenderfer 1970, p. 28
TA 503

Page 2 of 4

Transmission

Construction Standard

TA 503 7 Apr 08

Roads—Water Bars E 2008 by PacifiCorp. All rights reserved.

and Water Dips Engineer (C. Wright):

Standards Manager (G. Lyons):

Figure 2—Water Bar and Dip Construction Plan and Profile

C. Broad-Based Drainage Dips

Broad-based drainage dips are easily maintained and do not increase wear on vehicles

or reduce hauling speed when properly installed. Because of construction characteristics, these dips should not be used on roads graded in excess of 10 percent. (See

Figure 3.)
Figure 3—Typical Spacing Between Drainage Dips

TA 503

Transmission

Construction Standard

7 Apr 08

Page 3 of 4

TA 503

Roads—Water Bars

and Water Dips

E 2008 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

Table 2—Minimum Distance

Needed Between Water Bars

Road grade

(percent)

Distance

(feet)

2 -- 4 300 -- 200

5 -- 7 180 -- 160

8 -- 10 150 -- 140

Source: Kochenderfer 1970,

p. 19, 25

As with a water bar, care should be taken to ensure adequate drainage at the outflow

of a dip. Water dips should never be designed to discharge directly into a stream. The

discharge area should be protected with stone, grass, sod, heavy litter cover, brush,

logs, or other natural material which will reduce the velocity of the water. Natural litter

may be adequate in many cases if the terrain is not too steep.

Table 2 presents the spacing of broad-based dips as computed with the formula shown

in the figure.

Close attention should be paid to construction of broad-based dips, as they are often

made too small. Figure 3 shows minimum dimensions. Dips should be armored with

crushed rock or gravel. Figure 4 shows a practical example of how a broad-based

drainage dip can be used.

Figure 4—Drainage Dip
TA 503

Page 4 of 4

Transmission

Construction Standard

TA 503 7 Apr 08

Roads—Water Bars E 2008 by PacifiCorp. All rights reserved.

and Water Dips Engineer (C. Wright):

Standards Manager (G. Lyons):

This page is left blank intentionally.
TA 504

Transmission

Construction Standard

29 Sep 10

Page 1 of 12

TA 504

Roads—Culvert Installation E 2010 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

Roads—Culvert Installation

A. Scope

This standard provides information about the construction of surface drainage and the

installation of culverts. It is impossible to over-emphasize the importance of drainage in

maintaining stable roads and protecting water quality. Roads should be designed and

constructed to cause minimal disruption of natural drainage patterns. Provisions for two

components of road drainage should be included in every road project: 1) road-surface

drainage (including drainage which originates from the cutbank, road surface, and

fill-slope), and 2) hill-slope drainage (including drainage from large springs, gullies, and

streams which cross the road alignment).

B. Determining Culvert Diameter

Use pipe no smaller than 24I in diameter. A drainage table provides help in determining the proper size culvert (see Table 1 and Table 2). The following example illustrates

how to choose pipe size (Table 1) using the drainage table (Table 2). To use this

method, you will need information on slope, soils, and cover.

Example: The area to be drained is 70 acres on steep slopes with heavy soils and

moderate cover. In Table 2 under C opposite 70, find area required: 10.3 square feet.

Under the area table for round pipe (Table 1), the pipe size should fall between 42I and

48I. Use 42I pipe with an area of 9.6 square feet. If a wood or other type of box culvert

is planned, one 3i by 3.5i pipe would furnish the required area.

Table 1—Size of Round Pipe Needed for Area of Waterway

Area

(square feet)

Pipe diameter

(inches)

1.25 24

1.80 24

3.10 24

4.90 30

7.10 36

9.60 42

12.60 48

15.90 54

19.60 60

23.80 66

28.30 72

33.20 78

38.50 84

44.20 90

Source: Figure 45, Haussman and Pruett

1978, p. 36
TA 504

Page 2 of 12

Transmission

Construction Standard

TA 504 29 Sep 10

Roads—Culvert Installation E 2010 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

Table 2—Drainage Table Based on Talbot’s Formula for Rainfall

1-1/4I per Hour

Area required for waterway

Acres Impervious

100%

runoff

Steep slopes

Heavy soils

Moderate cover

Moderate slopes

Heavy to light

soils Dense cover

Gentle slopes

Agricultural

soil & cover

Flatland

Previous

soils

†C=1.00 C=0.80 C=0.70 C=0.60 C=0.50 C=0.40 C=0.30 C=0.20

Square Feet

2 0.5 0.4 0.4 0.3

4 0.9 0.7 0.6 0.5

6 1.2 1.0 0.8 0.7 0.6 0.5

8 1.5 1.2 1.0 0.9 0.7 0.6

10 1.7 1.4 1.2 1.0 0.9 0.7 0.3

20 2.9 2.3 2.0 1.8 1.5 1.2 0.5

30 4.0 3.2 2.7 2.4 2.0 1.6 0.5 0.3

40 4.9 3.9 3.4 3.0 2.5 2.0 0.9 0.4

50 5.8 4.7 4.0 3.5 2.9 2.3 1.2 0.6

60 6.7 5.4 4.6 4.0 3.4 2.7 1.5 0.8

70 7.5 6.0 5.2 4.5 3.8 3.0 1.8 1.0

80 8.3 6.7 5.8 5.0 4.2 3.3 2.0 1.2

90 9.1 7.3 6.3 5.5 4.6 3.6 2.3 1.4

100 9.9 7.9 6.8 5.9 4.9 3.9 2.5 1.5

150 13.5 10.6 9.3 8.0 6.7 5.4 2.7 1.7

200 16.6 13.4 11.5 10.0 8.4 6.7 2.9 1.8

250 19.8 15.8 13.6 11.9 9.9 7.9 4.0 2.0

300 22.9 18.1 15.5 13.6 13.5 9.0 5.0 2.7

350 25.5 20.3 17.5 15.3 12.7 10.1 5.9 3.3

400 28.0 22.5 19.5 17.0 14.0 11.1 6.8 4.0

450 30.9 24.9 21.0 18.5 15.3 12.1 7.5 5.1

500 33.4 26.4 23.0 20.0 16.6 13.3 8.4 5.6

600 38.5 30.8 26.3 23.0 19.0 15.2 9.0 6.2

700 43.0 34.2 29.8 26.0 21.5 17.0 9.9 6.6

800 48.0 38.1 32.9 28.5 23.8 19.0 11.4 7.7

900 52.0 41.5 35.9 31.1 26.0 20.8 12.9 8.6

1000 56.5 45.0 38.9 34.0 28.3 22.5 14.3 9.5

* See Table 1 for size of pipe needed.

{ C is the constant factor based on a combination of how much water the soil can hold, slope, and cover. C

= .70 is adequate for most conditions prevailing in the Northeast. C = 1.00 represents complete runoff of

precipitation (e.g., rock surfaces).
TA 504

Transmission

Construction Standard

29 Sep 10

Page 3 of 12

TA 504

Roads—Culvert Installation E 2010 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

Table 3 provides a simplified method for determining culvert size. To use this table,

determine the size of the drainage area (in acres) above the stream crossing as well as

the expected life of the culvert. A private consultant may provide assistance determining the size of a culvert. Make sure they do not size the culverts for a 50- or 100-year

storm, unless that is what is required. For low-traffic or temporary roads, a flood

frequency of 20 years can be used.

Table 3—Culvert Sizes by Drainage Area

Recurrence interval

(years)

10 20 50

Area (acres) Culvert diameter (inches)

10 24 24 18

20 24 24 20

30 24 24 24

40 24 24 26

50 24 24 28

60 24 24 28

70 24 26 30

80 24 26 30

90 24 28 32

100 26 28 34

125 28 30 36

150 28 32 38

175 30 34 40

200 32 36 42

Source: Table 3, Helvey and Kochenderfer 1988,

p. 125

C. Determining Culvert Lengths

The following simplified procedure can be used to determine culvert lengths needed for

new stream crossings or ditch-relief drains. Refer to Figure 1 for specific locations and

distances described in the step-by-step procedure. A complete example follows these

instructions.

1. Estimate the depth of the fill (F) at the running surface on the inside of the road above

the culvert inlet (point “a”).

2. Additional width (C) due to fill is then estimated as 1.5 times the fill depth (F) (that is, all

fill slopes are assumed to be 1.5:1 in steepness).

3. Add half the road width (1/2 W) and the fill width (C). Measure this distance horizontally

upstream from the center line of the road, and place stake at location A. The horizontal
TA 504

Page 4 of 12

Transmission

Construction Standard

TA 504 29 Sep 10

Roads—Culvert Installation E 2010 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

distance must be converted to slope distance before you can tape it off on the ground.

Use Table 4 to convert horizontal distance to slope distance (on-the-ground distance).

Figure 1—Culvert Length

4. Repeat steps 1 through 3 for the culvert outlet side of the crossing and place stake at

location B.

5. Measure the slope length between stakes A and B. This measurement, plus two to four

extra feet, is the length of culvert needed for the installation. The extra several feet are

added to extend the inlet and outlet beyond the edge of the fill.

Forty-four feet horizontal distance equals 52.4 feet slope distance on a 65 percent

slope.

horizontal distance × correction factor = slope distance

(44ft) × (1.19) = 52.4i

Example: What culvert length is needed for a 14i wide road crossing a

stream with a 55 percent gradient? The estimated inside fill-depth,

above the culvert inlet, will be 6i and the fill-depth above the

outlet will be 13i.

Step 1: Estimated depth of fill (F) at culvert inlet = 6i

Step 2: (C) = 1.5 × 6i = 9i

Step 3: 14i wide road (W), so 1/2 × 14i = 7i

Stake A (the location of the culvert inlet) should be placed on the

ground a distance of (9i + 7i) = 16 horizontal feet up the stream

channel from the flagged centerline of the road. According to the

correction table, 16 feet horizontally on a 55 percent slope is 18.2i

slope distance (16i × 1.14 = 18.2i).

Place the inlet stake (A) 18.2i up the channel from the centerline of the

road.
TA 504

Transmission

Construction Standard

29 Sep 10

Page 5 of 12

TA 504

Roads—Culvert Installation E 2010 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

Step 4: Estimated depth of fill (F) at culvert outlet =13i

Step 5: (C) = 1.5 ×13i = 20i

Step 6: 14i wide road (W), so 1/2 × 14 = 7i

Stake B (the location of the culvert outlet) should be placed on the

ground a distance of (13i + 20i) = 33 horizontal feet down the stream

channel from the flagged centerline of the road. According to the

correction table, 33 feet horizontally on a 55 percent slope is 37.6i

slope distance (33i × 1.14 = 37.6i).

Place the outlet stake (B) 37.6i down the channel from the centerline of

the road.

Step 7: Length of culvert needed = 18.2i + 37.6i = 55.8i or about 56i.

Approximately 2i--4i should be added to this length to make sure the

culvert inlet and outlet extend sufficiently beyond the base of the fill.

Final culvert length to be ordered and delivered to the site = 56i + 4i = 60i.

Table 4—Slope Correction Factors to (C) on Vertical-Horizontal Distance to Slope Distance

Hill slope or stream

channel gradient

(%)

Correction factor

(multiplier)

Hill slope or stream

channel gradient (%)

Correction factor

(multiplier)

10 1.001 45 1.10

15 1.01 50 1.12

20 1.02 55 1.14

25 1.03 60 1.17

30 1.04 65 1.19

35 1.06 70 1.22

40 1.08 75 1.25

1 For a slope of 10 percent or less, no correction factor is needed.

D. Culvert Installation for Ditch Relief

Insloped roads should be constructed: 1) where road-surface drainage discharged over

the fillslope would cause unacceptable erosion or discharge directly into stream

channels, 2) where fillslopes are unstable, or 3) where outsloping would create unsafe

conditions for use. It is generally preferable to outslope road surfaces in order to

disperse road-surface runoff before it has a chance to concentrate.

Insloped roads should be built with an inside drainage ditch to collect and remove road

surface runoff (TA 501, Roads—Construction). Roads steeper than about 8 percent

may be too steep for an inside ditch because of the potential for gullying in the ditch.

Inside ditches should also be drained at intervals sufficient to prevent ditch erosion or
TA 504

Page 6 of 12

Transmission

Construction Standard

TA 504 29 Sep 10

Roads—Culvert Installation E 2010 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

outlet gullying, and at locations where water and sediment can be filtered before

entering a watercourse. Filtering can be accomplished with thick vegetation, gentle

slopes, settling basins, or filter windrows of woody debris and mulches secured to the

slope.

As with outsloped roads, steep insloped road surfaces may be difficult to drain. Rolling

dips (for permanent, surfaced roads and seasonal roads) or waterbars (for seasonal or

temporary, unsurfaced roads) should be constructed at intervals sufficient to disperse

road surface runoff from steep road segments. See TA 503, Roads—Water Bars and

Water Dips for more information.

Ditches and culverts need occasional maintenance to maintain proper flow. Annual and

storm-period inspection can prevent small problems from growing into large failures.

When ditches become blocked by cutbank slumps, they need to be cleaned and the

spoil deposited in a stable location. However, excessive maintenance (i.e., grading) can

cause continuing and persistent erosion, sediment transport, and sediment pollution to

local streams. It may also remove rock surfacing.

Ditch relief culverts should be designed and installed along the road at intervals close

enough to prevent erosion of the ditch and at the culvert outfall, and at locations where

collected water and sediment is not discharged directly into watercourses (Table 5).

Table 5—Maximum Suggested Spacing for Ditch Relief Culverts (ft)

Road grade Soil Credibility

(%) Very High High Moderate Slight Very Low

2 600--800

4 530 600--800

6 355 585 600--800

8 265 425 525 600--800

10 160 340 420 555

12 180 285 350 460 600--800

14 155 245 300 365 560

16 135 215 270 345 490

18 118 190 240 310 435

On new roads, ditch flow should be directed into a culvert and discharged into buffer

areas and filter strips before it reaches a watercourse crossing. Ditches should neither

be discharged directly into the inlet of a watercourse crossing culvert, nor should ditch

relief culverts discharge into a watercourse without first directing flow through an

adequate filter strip. In addition to installing ditch relief culverts on either approach to

watercourse crossings, it is advisable to consider installing ditch drains before curves,

above and below through-cut road sections, and before and after steep sections of the

road.
TA 504

Transmission

Construction Standard

29 Sep 10

Page 7 of 12

TA 504

Roads—Culvert Installation E 2010 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

If a ditch is capable of transporting and delivering sediment to a Class I or Class II

watercourse during a flood event, it can be said to function the same as a Class III

watercourse. It has a bed and a bank, and it can transport sediment. Ditches which

drain directly into watercourse-crossing culverts should be treated and protected from

disturbance and erosion, just as is a Class III watercourse. Ditch relief culverts should

be installed across ditched roads before water course crossings so that water and

sediment can be filtered before reaching the stream.

Ditch relief culverts do not need to be large, since they carry flow only from the cutbank,

springs, and a limited length of road surface. In areas of high erosion and/or storm

runoff, nominal ditch relief culvert sizes should be 18I, but ditch relief culverts should

never be less than 15I diameter. Smaller culverts are too easily blocked (Figure 2).

Generally, culverts should have a grade at least 2 percent greater than the ditch which

feeds it to prevent sediment buildup and blockage. Where possible, ditch relief culverts

should be installed at the gradient of the original ground slope, so it will emerge on the

ground surface beyond the base of the fill. If this is not possible, the fill below the

culvert outlet should be armored with rock or the culvert fitted with an anchored

downspout to carry erosive flow past the base of the fill. Culverts should never be

“shot-gunned” out of the fill, thereby creating highly erosive road drainage waterfalls

(Figure 3).

Figure 2—Undersized Culvert Figure 3—Culvert Not Installed at the

Existing Stream Gradient

A 10 percent grade to the culvert will usually be self-cleaning. The culvert should be

placed at a 30_ angle to the ditch to improve inlet efficiency and prevent plugging and

erosion at the inlet. The pipe should be covered by a minimum of 18I of compacted

soil, or to a depth of 1.5 times the culvert diameter, whichever is greater. Finally, inlet

protection such as rock armoring or drop structures can be used to help minimize

erosion, slow flow velocity, and settle sediment before it is discharged through the pipe.

E. Culvert Installation for Stream Crossings

The importance of proper planning for stream crossings cannot be overstated. If stream

crossings are not planned and located before road construction begins, serious

problems may arise, including unintended damage to natural resources. Requirements

for stream crossings vary from state to state. Often, a permit is required; check with the

water division of the local natural resources agency.

Culverts can be considered dams that are designed to fail. The risk of culvert failure is

substantial for most crossings, so how they fail is critical. In the upper sketch in
TA 504

Page 8 of 12

Transmission

Construction Standard

TA 504 29 Sep 10

Roads—Culvert Installation E 2010 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

Figure 4, the crossing has failed and the road grade has diverted the stream down the

road, resulting in severe erosion and downstream sedimentation. Such damage to

aquatic habitats can persist for many years. Stream diversions are easy to prevent, as

illustrated by the lower sketch, in which the road grade was such that a failed crossing

caused only some loss of road fill.

Figure 4—Stream Crossing Failures

Culverts should be installed as road work progresses. The culvert and its related

drainage features should be installed via the following steps:

1. Place debris and slash to be used as a filter system, if needed.

2. Construct sediment ponds, if needed.

3. Complete downstream work first, such as energy dissipating devices and large rock

riprap.

4. Route stream around work area until pipe is installed.

5. Construct pipe inlet structure.

6. Install culvert pipe.

A culvert inlet should be placed on the same level as the stream bottom. Where the

culvert inlet has to be lower than the drainage gradient, a drop box can be constructed.

The box provides a place for sediment to settle before water enters the culvert. Drop

boxes require frequent maintenance.
Figure 5—Culvert Installed at Channel Gradient

TA 504

Transmission

Construction Standard

29 Sep 10

Page 9 of 12

TA 504

Roads—Culvert Installation E 2010 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

Install culvert pipes as near as

possible to the gradient of the natural

channel and so there is no change in

the stream bottom elevation

(Figure 5). Culverts should not cause

damming or pooling. Seat the culvert

on firm ground and compact the earth

at least halfway up the side of the

pipe to prevent water from leaking.

Pipe culverts must be adequately

covered with fill; the rule is a minimum of 30I or 1.5 times the culvert

diameter, whichever is greater.

If adequate cover cannot be achieved, an arch pipe or two small culverts should be

installed. The cover must also be compacted to prevent settling in the road. Debrisladen material should not be used to cover pipe culverts.

The following are additional guidelines for installing culverts in streams:

S Limit construction activity in the water to periods of low or normal flow.

S Minimize use of equipment in streams.

S Use soil stabilization practices on exposed soil at stream crossings. Seed/mulch

and install temporary sediment control structures, such as silt fences made of

straw bales or geotextiles, immediately after road construction. Maintain these

practices until the soil is permanently stabilized.

S Use materials that are clean, non-toxic, and which do not erode.

To prevent erosion and under-cutting of the inlet end of the culvert, provide a headwall.

Sandbags containing some cement mixed with the sand, durable logs, concrete, or

hand-placed riprap are suitable.
TA 504

Page 10 of 12

Transmission

Construction Standard

TA 504 29 Sep 10

Roads—Culvert Installation E 2010 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

Figure 6—Stream Crossing Culverts

Installation Notes for Figure 6:

1. Culverts for existing drainage shall be aligned with the drainage.
TA 504

Transmission

Construction Standard

29 Sep 10

Page 11 of 12

TA 504

Roads—Culvert Installation E 2010 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

2. Culverts for roadway and ditch drainage shall be oriented at an angle of 30_ to 45_ to

the roadway. See TA 503, Roads—Water Bars and Water Dips, for installation

instructions.

3. Culverts shall be sloped a minimum of 1 percent or at least 1 percent steeper than the

existing drainage.

4. When the culvert outlet is above grade, a plunge pool shall be constructed with length

and width equal to two pipe diameters and a depth of one pipe diameter. Line plunge

pool with geotextile fabric filled with 2I to 8I rock.

5. Culvert clogging debris located within 50i of a culvert inlet shall be removed.

6. Cut and fill slopes will be determined during construction based on site conditions and

as approved by the company.

7. See TA 501, Roads—Construction, for general road construction information.

8. Cover over culverts shall be 18I or 1.5 times the culvert diameter, whichever is greater.

To minimize damage from culvert failure, height of fill over culverts shall be as close to

minimum as practical.

9. Outlets on culverts with pipe slopes greater than 3 percent shall be protected with a 30i

× 10i strip of geotextile fabric fastened to culvert as a bib. Fabric shall be weighted

down with 6Ito 8I rock to slow runoff.

10. Bottom of culvert shall be cushioned with fine-grain site material when installed over

large rocks.

F. Fords

A ford is an alternative way to cross a water course where the streambed has a firm

rock or coarse gravel bottom; the approaches are low and stable enough to support

traffic; the stream is small to medium-sized, with water depth less than three feet and

stream flows not exceeding 6 fps; and vehicle traffic is light. Dry fords can often be

installed and used with minimal impact to the channel system.

The following standards apply when constructing a ford:

1. Install wing ditches, water-bars, dips, and level spreaders before the crossing. These

structures should disperse runoff into an established and stable stream buffer.

2. If corduroy, coarse gravel, or gabion is used to create a driving surface, it should be

installed flush with the streambed to minimize erosion and to allow fish passage.

3. Crossings should be at right angles to the stream.

4. Stabilize the approaches by using non-erodible material. The material should extend

at least 50 feet on both sides of the crossing.

5. Requirements for stream crossings vary from state to state. Often a permit is required;

check with the water division of the local natural resources agency.

6. Fords shall be designed for a low-maintenance long-term life. Rock size and grading,

depth of rock, fabric underlayment, etc. and approaches shall be designed for the

equipment expected to use the road.
TA 504

Page 12 of 12

Transmission

Construction Standard

TA 504 29 Sep 10

Roads—Culvert Installation E 2010 by PacifiCorp. All rights reserved.

Engineer (C. Wright):

Standards Manager (G. Lyons):

Figure 7 -- Ford Stream Crossing
APPENDIX C

CURRENT IN-LIEU FEE 

OPPORTUNITIES
The following two ILF programs were identified in Idaho:

Ducks Unlimited Program

State ID

Corps District Walla Walla 

Program Type Corps 

Sponsor Ducks Unlimited 

Sponsor Requirements Ducks Unlimited 

Administrator U.S. Army Corps of Engineers, Walla Walla District 

Completed Projects 1

Pending Projects 0

Total Acres of Permitted Losses 1

Total Acres Replaced 100

Total Feet of Permitted Losses 0

Delineated Service Areas No 

Description of Service Area The Corps tries to keep the restoration as local as possible. The 

projects have occurred in the same drainage basin as the impacts. 

Contact Information Mike Doherty 

Contact Address U.S. Army Corps of Engineers Walla Walla District 201 North 3rd 

Avenue Walla Walla, WA 99362-1876 

Replacement Ratio 

Determination 

Replacement ratios were not used. The Corps offered a project that 

it wanted done to the applicant and the applicant had a choice of 

whether to accept the project. 

Fee Amount Calculated For the Burlington Northern project, $265,000 was charged, based 

on the amount of money needed to complete the restoration project. 

Success Criteria The success criteria include vegetation planning, earthworks to 

ensure everything is at the right elevation, and required plantings. 

Monitoring for survival is required. 

Protection Mechanisms Project completed in federal wildlife refuge 

Entity Holding Funds Ducks Unlimited 

Funds To Date $265,000.00 

Date of Information 8/30/2001
The Nature Conservancy In-Lieu-Fee Program

State ID

Corps District Walla Walla 

Program Type Corps 

Sponsor The Nature Conservancy 

Sponsor Requirements The Nature Conservancy 

Administrator U.S. Army Corps of Engineers, Walla Walla District 

Completed Projects 1

Pending Projects 0

Total Acres of Permitted 

Losses 

4

Total Acres Replaced 100.8

Total Feet Replaced 560

Delineated Service Areas No 

Description of Service Area They try to keep the restoration as local as possible. The 

projects have occurred in the same drainage basin as the 

impacts. 

Contact Information Mike Doherty 

Contact Address USACE, Walla Walla District 201 North 3rd Avenue Walla 

Walla, WA 99362-1876 

Replacement Ratio 

Determination 

Replacement ratios were not used. The Corps offered a 

project that it wanted done to the applicant and the applicant 

had a choice of whether to accept the project. 

Success Criteria The success criteria include vegetation planning, earthworks 

to ensure everything is at the right elevation, and required 

plantings. Monitoring for survival is required. 

Protection Mechanisms conservation easement 

Entity Holding Funds Bonner Boundary Board 

Funds To Date $140,000.00 

Date of Information 8/30/2001
No ILF programs were identified for Wyoming; however, the following mitigation bank was

identified:

Wyoming Statewide Wetland Mitigation Bank

State WY

Agreement Status Approved-active 

Year Bank was Established 1995

Authorizing Legislation Wyoming Statutes 35-11-308 through 35-11-311 provide 

the legislative authority to establish the Wyoming Wetland 

Bank. Specifically, 35-11-311 requires the development of 

this document. Wyoming Wetlands Act (passed in 1991). 

The Act was further amended and refined in the 1994 

legislative session. See instrument for more information. 

Agreement Type: combination public/private 

Total Number of Sites 

Approved 

Don't operate with sites 

Total Acres Approved 600

Geographic Service Area Use of banked credits is confined to the Wyoming river 

basin in which the impacts will occur. In order to equalize 

the size differentials of the basins, the largest basins have 

been divided and the smaller ones consolidated. Banked 

wetland credits can only be withdrawn for use as mitigation 

within the following areas: South Platte & Lower North 

Platte; Upper North Platte & Great Divide; Cheyenne, Belle 

Fourche & Little Missouri; Powder & Tongue; Big Horn; 

Wind; Green & Little Snake; Bear & Snake; Yellowstone & 

Madison 

Agreement Sponsor Wyoming Department of Environmental Quality 

Contact Information Bill Dirienzo 

Contact Address 122 West 25th Street Herschler Building 4-W Cheyenne, 

WY 82002 

Credit Definition Other 

Specify if Other Calculated after construction - enhancement credits and 

creation/restoration credits - all credits are expressed in 

acre-units 

Site Selection Criteria Any person wishing to deposit wetlands in the State Bank 

must notify the department before beginning the creation, 

restoration or enhancement project. An on-site preconstruction evaluation will be made by the department or 

their designated representative. Along with a request for 

deposit, the applicant must provide proof of legal water 

rights. 
State WY

Sponsor Activities The State of Wyoming, through the Department of 

Environmental Quality will maintain all bank records and 

produce periodic reports concerning wetland gains and 

losses and credit and debit transactions for each account. 

Debiting Activities The options made possible by the wetland bank are 

available to both public and private entities. Any individual 

landowner, organization or public agency can earn credits 

for wetland creation, restoration or enhancement. Once 

the credits are recorded in the bank, they can be 

withdrawn by the owner or transferred to another party to 

meet mitigation requirements. Maintenance Requirements: 

Any improvements, enhancements or newly created 

wetlands are not required to be maintained under these 

guidelines unless the credit is withdrawn for mitigation 

purposes. 

Monitoring Requirements The department will maintain records, in perpetuity, of all 

Wetland Bank accounts and credit transactions. These 

records will be public information and will be made 

available to any interested person upon request. 
APPENDIX D

PROPOSED IN-LIEU FEE 

MITIGATION INSTRUMENT
Proposed In-Lieu Fee Mitigation Instrument Page 44

PROPOSED IN-LIEU FEE MITIGATION INSTRUMENT

The Companies would prepare a prospectus for the proposed ILF program that would include 

the following:

1. Objectives.

2. How the ILF would be established and operated.

3. Proposed service area(s).

4. Need and technical feasibility.

5. Ownership arrangements and long-term management strategy.

6. Sponsor qualifications.

7. Compensation planning framework.

8. Description of program account.

The prospectus would be provided to the USACE and the USACE is responsible for public 

notice and coordination with the IRT. If the USACE determines that the proposed ILF program 

has the potential to provide compensatory mitigation, the Companies would prepare a Draft 

Instrument. The Draft Instrument would include the following elements:

1. Service area.

2. Accounting procedures.

3. Provision stating legal responsibility to provide compensatory mitigation.

4. Default and closure provisions.

5. Reporting protocols.

6. Compensation planning framework.

a. Geographic service area(s)

b. Description of threats

c. Analysis of historic resource loss

d. Analysis of current resource conditions

e. Goals and objectives

f. Prioritization strategy

g. Preservation justification

h. Description of stakeholder involvement

i. Long-term protection and management strategies

j. Strategy for periodic evaluation and reporting

7. Advance credits.

8. Method for determining project specific credits and fees & draft fee schedule

9. In-lieu fee program account.

10. Transfer of long-term management responsibilities.

11. Financial arrangements for long-term management.

12. Other information deemed necessary by the USACE district engineer.
Proposed In-Lieu Fee Mitigation Instrument Page 45

The Draft Instrument is not a ILF mitigation plan. The Companies would also develop an ILF 

mitigation plan, concurrent with, and dependent upon, the ILF Instrument. The ILF mitigation 

plan would include:

1. Objectives.

2. Site selection (further described in §332.3(d)).

3. Site protection instrument (further described in §332.7(a)).

4. Baseline information.

5. Determination of credits (further described in §332.3(f)).

6. Mitigation work plan.

7. Maintenance plan.

8. Performance standards (further described in §332.5).

9. Monitoring requirements (further described in §332.6).

10. Long-term management plan (further described in §§332.7 and 332.8(u)).

11. Adaptive management plan (further described in §332.7(c)).

12. Financial assurances (further described in §332.3(n)).

The ILF mitigation plan is not discussed further in this Appendix.

Proposed Draft ILF Instrument

1.0 Service Area

The geographic service area3for the (Gateway West ILF Program) is defined as (specify the 

geographic unit). Idaho Power Company (IPC) and Rocky Mountain Power (RMP) (the 

Companies) would provide compensatory mitigation for permitted impacts within the same 

geographic service area in which the impacts occurs unless the district engineer, in consultation 

with the IRT, has agreed to an exemption. [Insert maps of project area, impacts, service area.] 

This service area was selected because the Companies, in consultation with the district 

engineer, has concluded that the scale is appropriate to ensure that the projects selected would

be able to effectively compensate for adverse environmental impacts across the entire service 

area. The Companies would not accept participation from other permittees; this ILF Program 

has been developed for the sole use of the Companies to mitigate for unavoidable impacts to 

waters of the U.S. resulting from the construction, operation, and maintenance of the Gateway 

West 500 Kilovolt Transmission Line Project. Individual mitigation projects would be proposed 

for specific service areas in project-specific mitigation plans.

2.0 Accounting Procedures

The Companies shall establish and maintain a system for tracking the production of credits, 

credit transactions, and financial transactions between the Companies and ILF sponsor. Credit 

production, credit transactions, and financial transactions must be tracked on a programmatic 

 

3

Service area is defined as: “the watershed, ecoregion, physiographic province and/or other 

geographic area within which the...in-lieu fee program is authorized to provide compensatory

mitigation required by DA permits.
Proposed In-Lieu Fee Mitigation Instrument Page 46

basis (i.e., the number of available credits for the entire program by service area) and 

separately for each individual project.

3.0 Provisions Stating Legal Responsibility to Provide Compensatory Mitigation

(Program Sponsor) assumes all legal responsibility for satisfying the mitigation requirements of 

the Corps/state permit for which fees have been accepted (i.e., the implementation, 

performance, and long-term management of the compensatory mitigation project(s) approved 

under this agreement and subsequent mitigation plans). The transfer of liability is established 

by: 1) the approval of this in-lieu fee instrument; 2) receipt by the district engineer of a credit 

sale form/letter/certificate that is signed by the (Program Sponsor) and the Companies and 

dated (see Section (X, “Reporting protocols”); and 3) the transfer of fees from the Companies to 

(Program Sponsor).

4.0 Default and Closure Provisions

If the Corps determines that (Program Sponsor) has failed to provide the required compensatory 

mitigation in a timely manner (i.e., (Program Sponsor) has failed to meet performance based 

milestones set forth in the project-specific mitigation plan, meet ecological performance 

standards, submit monitoring reports in a timely manner, establish and maintain an annual 

ledger report and individual ledgers for each project in accordance with the provisions in Section 

(X, “Accounting Procedures”), submit an annual financial assurances and long-term 

management funding report, report approved credit transactions, complete land acquisition and 

initial physical and biological improvements by the third full growing season after the first 

advance credit in that service area is secured by a permittee, and/or otherwise comply with the 

terms of the instrument), the district engineer must take appropriate action to achieve 

compliance with the terms of the instrument and all approved mitigation plans. Such actions 

may include suspending credit sales, decreasing available credits, requiring adaptive 

management measures, utilizing financial assurances or contingency funds, terminating the 

agreement, using the financial assurances or contingency funds to provide alternative 

compensation, directing the use of in-lieu fee program account funds to provide alternative 

mitigation (e.g., securing credits from another third party mitigation provider), or referring the 

non-compliance with the terms of the instrument to the Department of Justice. 

Any delay or failure of (Program Sponsor) to comply with the terms of this agreement shall not 

constitute a default if and to the extent that such delay or failure is primarily caused by any force 

majeure or other conditions beyond (Program Sponsor)’s reasonable control and significantly 

adversely affects its ability to perform its obligations hereunder, such as flood, drought, 

lightning, earthquake, fire, landslide, condemnation or other taking by any governmental body. 

(Program Sponsor) shall give written notice to the district engineer and IRT if the performance of 

any of its in-lieu fee projects is affected by any such event as soon as is reasonably practicable. 

Either party to this agreement may terminate the agreement within 60 days of written notification 

to the other party. In the event that the Gateway West ILF Program operated by (Program 

Sponsor) is terminated, (Program Sponsor) is responsible for fulfilling any remaining project 

obligations including the successful completion of ongoing mitigation projects, relevant 
Proposed In-Lieu Fee Mitigation Instrument Page 47

maintenance, monitoring, reporting, and long-term management requirements. (Program 

Sponsor) shall remain responsible for fulfilling these obligations until such time as the long-term 

financing obligations have been met and the long-term ownership of all mitigation lands has 

been transferred to the party responsible for ownership and all long-term management of the 

project(s). 

Funds remaining in the Gateway West ILF Program accounts after these obligations are 

satisfied must continue to be used for the restoration, establishment, enhancement, and/or 

preservation of aquatic resources. The Corps shall direct Gateway West ILF Program to use 

these funds to secure credits from another source of third-party mitigation, such as another inlieu fee program, mitigation bank, or another entity such as a governmental or non-profit natural 

resource management entity willing to undertake the compensation activities. The funds should 

be used, to the maximum extent practicable, to provide compensation for the amount and type 

of aquatic resource for which the fees were collected. The Corps itself cannot accept directly, 

retain, or draw upon those funds in the event of a default.

5.0 Reporting Protocols

The Companies must report to the district engineer and the IRT the following information:

1. Monitoring reports, on a schedule and for a period as defined by project specific 

mitigation plan(s).

2. Credit transaction notifications.

3. An annual program report summarizing activity from the program account (financial and 

credit accounting) as detailed below.

4. An annual financial assurances and long-term management funding report as detailed 

below.

Monitoring reports

Monitoring is required of all compensatory mitigation projects to determine if the project is 

meeting its performance standards and if additional measures are necessary to ensure that the 

compensatory mitigation project is accomplishing its objectives. If (Program Sponsor) fails to 

submit reports within 90 days of the deadlines outlined in the mitigation plan(s), the Corps may 

take appropriate compliance action (see Section (X, “Default and closure”)). Project-specific 

mitigation plans would detail the parameters to be monitored, the length of the monitoring 

period, the dates that the reports must be submitted (e.g., first of each month), the party 

responsible for conducting the monitoring, the frequency for submitting monitoring reports to the 

district engineer, and the party responsible for submitting those monitoring reports to the district 

engineer and the IRT. The level of detail and substance of the reports must be commensurate 

with the scale and scope of the compensatory mitigation project. The Corps is required to 

provide monitoring reports to interested federal, tribal, state, and local resource agencies, and 

the public, upon request.

Credit transaction notification

Section (X, “Provisions stating legal liability”) establishes the terms by which the legal 

responsibility for compensation requirements is transferred from the Companies to (Program 
Proposed In-Lieu Fee Mitigation Instrument Page 48

Sponsor). These terms require (Program Sponsor) to submit a credit sale form/letter/certificate 

to the Corps. The document must be signed by the (Program Sponsor) and the permittee and 

dated. The credit transaction form/letter/certificate must include the permit number(s) for which 

(Program Sponsor) is accepting fees, the number of credits being purchased, and resource 

type(s) (e.g., Cowardin class) of credits being purchased. (Program Sponsor) must submit the 

signed and dated credit transaction form/letter/certificate within 10 days of receiving the fees 

from the permittee. A copy of each credit transaction form/letter/certificate would be retained in 

both the Corps’ and (Program Sponsor’s) administrative and accounting records for the 

Gateway West ILF Program.

Annual program report

(Program Sponsor) must submit an annual report (annual ledger report) to the district engineer 

and the IRT. The report must be made available to the public upon request. The annual 

program report must be submitted no later than the last day of March, or the following business 

day if that date falls on a federal/state holiday or weekend. The annual report must include the 

following information:

Program account (financial) reporting:

All income received and interest earned by the program account for the program and by 

service area.

A list of all permits for which in-lieu fee program funds were accepted by service area, 

including (1) Corps permit number (and/or the state permit number); (2) service area in 

which the authorized impacts are located; (3) amount of authorized impacts; (4) amount 

of required compensatory mitigation; (5) amount paid to the in-lieu fee program; and (6) 

date the funds were received from the permittee.

A description of in-lieu fee program expenditures/disbursements from the account (i.e., 

the costs of land acquisition, planning, construction, monitoring, maintenance, 

contingencies, adaptive management, and administration) for the program and by 

service area.

Ledger (credit) reporting:

The balance of advance credits and released credits at the end of the report period for 

the program and by service area.

The permitted impacts for each resource type.

All additions and subtractions of credits.

Other changes in credit availability (e.g., additional credits released, credit sales 

suspended).

Financial assurances and long-term management funding report

(Program Sponsor) must submit an annual report on financial assurances and long-term 

management to the district engineer and the IRT. (Program Sponsor) is required to give the 

Corps at least (XX days; to be determined by the sponsor in consultation with the Corps and 

IRT) advance notice if required financial assurances would be terminated or revoked. In 

addition, the financial assurance instrument must be written in such a way that it is the 

obligation of the bonding company or financial institution to provide the Corps notice. Inclusion 

of a summary of any changes to the financial assurances in the reporting year does not alter 
Proposed In-Lieu Fee Mitigation Instrument Page 49

this separate obligation. The financial assurances and long-term management funding report 

must include:

Beginning and ending balances of the individual project accounts providing funds for 

financial assurance and long-term management.

Deposits into and any withdrawals from the individual project accounts providing funds 

for financial assurance and long-term management.

Information on the amount of required financial assurances and the status of those 

assurances, including their potential expiration for each individual project.

6.0 Compensation Planning Framework

The compensation planning framework must include the following ten elements:

1. The geographic service area(s), including a watershed based rational for the delineation 

of each service area.

2. A description of the threats to aquatic resources in the service area(s), including how the 

in-lieu fee program would help offset impacts resulting from those threats.

3. An analysis of historic aquatic resource loss in the service area(s).

4. An analysis of current aquatic resource conditions in the service area(s), supported by 

field documentation.

5. A statement of aquatic resource goals and objectives for each service area, including a 

description of the general amounts, types and locations of aquatic resources the 

program would seek to provide.

6. A prioritization strategy for selecting and implementing compensatory mitigation activities

7. An explanation of how any preservation objectives identified above satisfy the criteria for 

use of preservation.

8. A description of any public and private stakeholder involvement in plan development and 

implementation, including coordination with federal, state, tribal and local aquatic 

resource management and regulatory authorities.

9. A description of the long term protection and management strategies for activities 

conducted by the in-lieu fee program sponsor.

10. A strategy for periodic evaluation and reporting on the progress of the program in 

achieving the goals and objectives above, including a process for revising the planning 

framework as necessary. 

7.0 Advance Credits

Upon approval of this instrument for Gateway West ILF Program, (Program Sponsor) is 

permitted to sell advance credits in the amount indicated in the chart below. The number of 

advance credits available for sale varies by service area, as indicated. The number of advance 

credits available for sale is specified by service area, as indicated in (the chart). As the 

milestones in the schedule are reached (i.e., restoration, creation, enhancement and/or 

preservation is implemented), advance credits convert to released credits. At a minimum, 

credits would not be released until (Program Sponsor) has obtained IRT approval of the 

mitigation plan for the site, has achieved the applicable milestones in the credit release 

schedule, and the credit releases have been approved by the district engineer.
Proposed In-Lieu Fee Mitigation Instrument Page 50

Once (Program Sponsor) has sold all of its advance credits, no more advance credits may be 

sold until an equivalent number of credits has been released in accordance with the approved 

credit release schedule outlined in a project-specific mitigation plan. Once all advance credits 

are fulfilled, an equivalent number of advance credits may be made available for sale, at the 

discretion of the district engineer and IRT. (Program Sponsor) shall complete land acquisition 

and initial physical and biological improvements by the third full growing season after the sale of 

advance credits. If (Program Sponsor) fails to meet these deadlines, the district engineer must 

either make a determination that more time is needed to plan and implement an in-lieu fee 

project or, if doing so would not be in the public interest, direct (Program Sponsor) to disburse 

funds from the Gateway West ILF Program account to provide alternative compensatory 

mitigation to fulfill those compensation obligations.

8.0 Method for Determining Project-Specific Credits and Fees and Draft Fee Schedule

The draft fee schedule section should simply include a chart or list of the fees charged by the 

program per unit of credit and for each wetland type provided and in each service area in which 

the program operates. Fees for Gateway West ILF Program shall be determined based on an 

analysis of the expected costs associated with the restoration, establishment, enhancement, 

and/or preservation of aquatic resources in [the state/region/watershed]. The program costs 

included in this analysis are those related to land acquisition, project planning and design, 

construction, plant materials, labor, legal fees, monitoring, remediation or adaptive management 

activities, program administration, contingency costs appropriate to the stage of project 

planning, including uncertainties in construction and real estate expenses, the resources 

necessary for the long-term management and protection of the in-lieu fee project, and financial 

assurances (including contingency costs) that are expected to be necessary to ensure 

successful completion of in-lieu fee projects. These fees shall be reviewed annually and 

updated as appropriate. Credits generated by Gateway West ILF Program shall be based on 

[an appropriate assessment

method or other suitable metric] approved by the Corps. The standard mitigation ratios for 

wetlands are currently (insert chart). The standard mitigation ratios for streams are currently 

(insert chart).

9.0 In-Lieu Fee Program Account

Financial accounting

Reporting requirements for financial reporting are at Section (X, “Reporting Protocol.”) The 

Gateway West ILF Program account would track funds accepted from permittees separately 

from those accepted from other entities and for other purposes (i.e., fees arising out of an 

enforcement action, such as supplemental environmental projects). The account would be held 

at a financial institution that is a member of the Federal Deposit Insurance Corporation. Any 

and all interest accruing from the account would be used to provide compensatory mitigation for 

impacts to aquatic resources. The program account would be established after this instrument 

is approved and before any fees are accepted. If the Corps determines that the (Program 

Sponsor) is failing to provide compensatory mitigation by the third full growing season after the 

first advance credit is secured, the agency may direct the funds to alternative compensatory 

mitigation projects. Additional information on failure to fulfill the terms of the instrument is 
Proposed In-Lieu Fee Mitigation Instrument Page 51

discussed in Section (X, “Default & Closure”). The Corps has the authority to audit the program 

account records at any time. Funds paid into the Gateway West ILF Program account may only 

be used for the direct replacement and management of aquatic resources. This means the 

selection, design, acquisition (i.e., appraisals, surveys, title insurance, etc.), implementation, 

and management of in-lieu fee compensatory mitigation projects. This may include fees 

associated with securing a permit for conducting mitigation activities, activities related to the 

restoration, enhancement, creation, and/ or preservation of aquatic resources, maintenance and 

monitoring of mitigation sites, and the purchase of credits from mitigation banks. Use of fees is 

explicitly prohibited for activities such as upland preservation (other than buffers), research, 

education and outreach, or implementation of best management practices for wetlands unless 

these are directly associated with the success of the mitigation and have been identified in the 

mitigation plan. Up to (__%) of the fees paid into Gateway West ILF Program may be used for 

administrative costs. Such costs include bank charges associated with the establishment and 

operation of the program, staff time for carrying out program responsibilities, expenses for day 

to day management of the program, such as bookkeeping, mailing expenses, printing, office 

supplies, computer hardware or software, training, travel, and hiring private contractors or 

consultants.

Credit accounting

(Program Sponsor) shall establish and maintain an annual report ledger that tracks the 

production of released credits for Gateway West ILF Program and for each individual in-lieu fee 

project. Reporting requirements for the annual report ledger are at Section (X). On the income 

side, (Program Sponsor) shall track the fees and all other income received, the source of the 

income (i.e., permitted impact, penalty fee, etc.), and any interest earned by the program 

account. The ledgers shall also include a list of all the permits for which in-lieu fee program 

funds were accepted, including the appropriate permit number (Corps or state permit), the 

service area in which the specific authorized impacts are located, the amount (acreage or linear 

feet) of authorized impacts, the aquatic resource type impacted by Cowardin class, the amount 

of compensatory mitigation required, the amount paid to the in-lieu fee program for each of the 

authorized impacts, and the date the funds were received from the permittee. (Program 

Sponsor) shall establish and maintain a report ledger for Gateway West ILF Program that would

track all program disbursements/expenditures and the nature of the disbursement (i.e., costs of 

land acquisition, planning, construction, monitoring, maintenance, contingencies, adaptive 

management, and administration). (Program Sponsor) may also track funds obligated or 

committed, but not yet disbursed. The ledger shall also include, for each project, the permit 

numbers for which the project is being used to offset compensatory mitigation requirements, the 

service area in which the project is located, the amount of compensation being provided by 

method (i.e., restoration, establishment, enhancement, or preservation), the aquatic resource 

type(s) represented (e.g., Cowardin class), the amount of compensatory mitigation being 

provided (acres and/or linear feet), and the number of credits certified by the IRT. The annual 

report ledger shall also include a balance of advance credits and released credits at the end of 

the report period for each service area.

10.0 Transfer of Long-Term Management Responsibilities
Proposed In-Lieu Fee Mitigation Instrument Page 52

After securing approval from the district engineer, (Program Sponsor) shall transfer long-term 

management responsibilities to [name a specific land stewardship entity or “a land stewardship 

entity, such as a public agency, non-governmental organization, or private land manager”]. 

Transfer of long term stewardship responsibilities may occur before or after performance 

standards have been achieved. Once long term management has been transferred to land 

stewardship entity, said party is thereby responsible for meeting any and all long-term 

management responsibilities outlined in the project-specific mitigation plan. Until such time as 

long-term management responsibilities are transferred to another party, (Program Sponsor) 

would be considered responsible for long-term management of the mitigation project.

11.0 Financial Arrangements for Long-Term Management

If (Program Sponsor) chooses to transfer the responsibilities for long-term management to a 

long-term steward, (Program Sponsor) must seek Corps’ approval. The Corps must be given 

the option of being a signatory to any contract or other arrangement assigning the rights and 

delegating the responsibilities to the steward. If long-term stewardship responsibilities are 

transferred to (land stewardship entity), (Program Sponsor) shall also transfer the long-term 

management funds/account for otherwise arrange for disbursements from such funds/account 

to the (land stewardship entity).

12.0 Signatures

_______________________________________ _______________________

Program sponsor Date

_______________________________________ _______________________

District Engineer Date

_______________________________________ _______________________

IRT members choosing to participate Date