ATTACHMENT 3

BEST MANAGEMENT PRACTICES AND MITIGATION MEASURES
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-1

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Climate and Air 

Quality Resources

Construction On-site wind speed monitors will be monitored during windy 

periods. Earthmoving activity will be minimized and vehicle speeds 

will be reduced if sustained winds exceed 22 miles per hour (mph), 

or if gusts exceed 30 mph.

4-11 Dust Plan, 4

Climate and Air 

Quality Resources, 

Visual Resources

Construction, 

Reclamation,

Decommissioning

Minimizing surface area disturbance, controlling erosion, applying 

dust suppression practices, and, where feasible, return disturbed 

areas as close as possible to the original condition, including grade 

and vegetation.

4-11, 4-74 B-10, B-11

Climate and Air 

Quality Resources

Construction Using aggregate materials on access roads and internal Project 

roads and design the roads using natural contours and avoiding 

excessive grades.

4-11 B-11 POD 2-7, and 

Section 3.2 

(similar text), 

Transportation 

and Traffic 

Control Plan

Climate and Air 

Quality Resources

Construction,

Operations

Restricting travel within the Project Area to the roads developed for 

the Project and enforcing posted speed limits on those roads to 

minimize the generation of dust. The magnitude of the limits will

be based on the localized soil stability conditions and will not 

exceed 25 mph.

4-11 B-11 POD Section 3.2 

(similar text)

Climate and Air 

Quality Resources

Construction Reducing the wind profile of stockpiled materials and covering or 

watering materials that could become a source of fugitive dust.

4-11 B-11

Climate and Air 

Quality Resources

Construction Employing blasting techniques that minimize the ejection of 

material into the air.

4-12 B-11 Blasting Plan (to 

be developed 

before NTP)

Climate and Air 

Quality Resources

Construction Utilizing dust abatement techniques, such as the application of 

water or appropriate palliatives (as pre-approved by BLM and/or 

Reclamation), prior to and during blasting activities, excavation, 

and surface clearing.

4-12 B-11 Blasting Plan (to 

be developed 

before NTP)

Climate and Air 

Quality Resources

Construction Placing cobble beds at egress points to minimize “trackout” onto 

paved roads.

4-12 SWPPP (to be 

developed 

before NTP)

Climate and Air 

Quality Resources

Construction,

Operations

Complying with the parameters of the Transportation and Traffic 

Plan with regard to projected road use, traffic volume minimization, 

and road maintenance.

4-12
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-2

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Climate and Air 

Quality Resources

Construction Requiring construction contractors to maintain equipment to meet 

federal and state requirements and conducting scheduled and 

unscheduled inspections to check for unnecessary idling and to 

confirm that equipment is in proper operation per the Health, 

Safety, Security and Environment (HSSE) plan and in adherence 

with manufacturer’s recommendations. 

4-12

Climate and Air 

Quality Resources

Construction Employing trained environmental monitors, who will be on site 

daily to observe dust-prone areas to ensure implementation of 

emission control and other mitigation measures.

4-12 Dust Plan, 2;

ECCMP

Climate and Air 

Quality Resources

Construction,

Operations,

Decommissioning

Trucks transporting mineral materials for road construction or to 

the two batch plants will be covered with tarps.

POD 2-6; 

Dust Plan, 2

Climate and Air 

Quality Resources

Construction BP Wind Energy will take preventative measures to limit dust from 

disturbed soils. Disturbed surface areas will be controlled via 

construction sequencing and clearing will be kept to a minimum 

width within the rights of way.

Dust Plan, 3

Geology, Soils and 

Minerals

Design,

Construction

If new roads are necessary, they shall be designed and constructed 

to the appropriate standard and be no higher than necessary to 

accommodate their intended functions (e.g., traffic volume and 

weight of vehicles). Road design should avoid changes to surface 

water runoff so erosion is not initiated. Excessive grades on roads, 

road embankments, ditches, wetlands, and drainages shall be 

avoided, especially in area with erodible soils. Slopes will be cut 

back to a stable grade. Special construction techniques shall be 

used, where applicable. 

4-17 B-4, B-11

Geology, Soils and 

Minerals

Design To the extent practicable, the locations of roads, turbines, and other 

structures will be chosen in an attempt to avoid placing them near 

unstable areas. 

4-17

Geology, Soils and 

Minerals

Construction,

Operations,

Decommissioning

Erosion controls that comply with county, state, and federal 

standards shall be applied. Practices such as jute netting, silt fences, 

and check dams shall be applied near disturbed areas.

B-10

Geology, Soils and 

Minerals

Construction Access roads shall be located to follow natural contours and 

minimize side hill cuts.

B-11
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-3

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Geology, Soils and 

Minerals

Construction,

Operations

Implementing BMPs and a Dust and Emissions Control Plan, 

including applying water to the ground surface and instituting a 

25 mph speed limit to minimize erosion and prevent soil loss.

4-17 Dust and 

Emissions 

Control Plan, 4

Geology, Soils and 

Minerals

Design,

Construction,

Monitoring

The Project shall be planned to use existing roads and utility 

corridors to the maximum extent feasible, and to minimize the 

number and length/size of new roads, lay-down areas, and borrow 

areas.

B-4, B-10, 

B-11

Geology, Soils and 

Minerals

Reclamation, 

Operations,

Decommissioning

All areas of disturbed soil shall be reclaimed using weed-free native 

shrubs, grasses, and forbs. Reclamation activities shall be 

undertaken as early as possible on disturbed areas.

B-10, B-14 Integrated 

Reclamation 

Plan, 6

(Sections 2.4.2, 

2.6)

Geology, Soils and 

Minerals

Reclamation,

Decommissioning

Abandoned roads and roads that are no longer needed shall be 

recontoured and revegetated.

B-11

Geology, Soils and 

Minerals

Reclamation To prevent localized landslides resulting from slope instability, 

disturbed areas will be recontoured with salvaged topsoil and soil 

removed during construction and later revegetated.

4-17 B-10, B-14

Geology, Soils and 

Minerals

Pre-construction,

Construction

Identify unstable slopes and local factors that can induce slope 

instability (such as groundwater conditions, precipitation, 

earthquake activities, slope angles, and the dip angles of geologic 

strata). Avoid creating excessive slopes during excavation and 

blasting operations. Special construction techniques shall be used 

where applicable in areas of steep slopes, erodible soil, and stream 

channel crossings.

B-10

Geology, Soils and 

Minerals

Construction Borrow material shall be obtained only from authorized and 

permitted sites. Existing sites shall be used in preference to new 

sites.

B-12

Geology, Soils and 

Minerals

Construction Foundations and trenches shall be backfilled with originally 

excavated material as much as possible. Excess excavation 

materials shall be disposed of only in approved areas or, if suitable, 

stockpiled for use in reclamation activities.

B-12

Geology, Soils and 

Minerals

Decommissioning A decommissioning plan shall be developed and approved by the 

BLM. The decommissioning plan shall include removal of all 

turbines and ancillary structures, a reclamation plan, and a 

monitoring program. 

B-14 POD, 3-4;

Integrated 

Reclamation

Plan
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-4

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Geology, Soils and 

Minerals

Decommissioning Topsoil from all decommissioning activities shall be salvaged and 

reapplied during final reclamation.

B-14

Geology, Soils and 

Minerals

Reclamation Re-grade site to pre-construction contours where feasible. After 

foundations are poured and concrete cures to engineered strength 

(approximately 30 days), soils moved from foundation areas will be 

replaced. Excess fill (excluding removed topsoil) will be packed 

around foundation bases or elsewhere in the Project, such as fill 

material for interior roads, and compacted to 80 percent or greater 

as required for soil stability.

2-38 POD Section 2.8 

(similar)

Geology, Soils and 

Minerals

Construction,

Reclamation,

Operations,

Decommissioning

Mulching (supplemented with vegetation removed during 

construction) will be implemented during all phases of 

development in reclaimed areas with certified weed-free mulch to 

protect the soil surface from wind and water erosion.

2-38 Integrated 

Reclamation 

Plan 

Sections 2.5, 

2.6, 2.8.2 

(similar)

Geology, Soils and 

Minerals

Construction,

Reclamation

Removed topsoil will be stored either in windrows along the edge 

of disturbance or in stockpiles designed to minimize the surface 

area occupied and constructed to maintain slope stability until they 

are used for reclamation. Soil stockpiles will be located near the 

edges of disturbance, but within the surveyed limits of disturbance 

and will be segregated from other stockpiles. While soil is stored in 

windrows and stockpiles, water will be added to the surface to 

control dust or tackifier will be added to form a crust. Flagging and 

staking should be used to prevent the soil stockpiles from being run 

over by equipment and to help maintain soil quality until it is used 

and distributed. Salvaged topsoil and subsoil will be identified, 

delineated, and segregated based on a site-specific soil evaluation, 

including depth, chemical, and physical properties.

Integrated 

Reclamation 

Plan 9-10; POD

(Section 2.6)

Geology, Soils and 

Minerals

Construction,

Reclamation

Topsoil stored for more than 6 months should be seeded using the 

approved seed mix (see Table 2 in the Integrated Reclamation Plan) 

and watered deep enough to stimulate germination (but not exhaust 

the nutrients in the soil), and maintained or watered for at least 

8 weeks (depending on the season). 

Integrated 

Reclamation 

Plan 9, 11; POD 

(Section 2.6)
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-5

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Geology, Soils and 

Minerals

Construction,

Reclamation

Pit slopes will be constructed at an inclination no steeper than 3:1 

(about an 18 degree angle of repose) with maximum height of about 

20 feet. At completion of mining, the pit will have slopes which are 

constructed at 3:1, including all points of use, and will be leveled 

after all equipment, structures, and the concrete batch plant have 

been removed from the site.

Mining Plan of 

Operations 5, 9;

POD 

(Section 2.8)

Water Resources Design,

Construction

Avoid locating Project features in jurisdictional waters, ephemeral 

washes, and aquatic features, as feasible, and/or minimize impacts 

through techniques such as bridging, using at-grade crossing for 

roads, providing adequate buffers for flood control, and minimizing 

the number of road crossings over waters.

4-28

Water Resources Design Existing drainage systems shall not be altered, especially in 

sensitive areas such as erodible soils or steep slopes. Potential soil 

erosion shall be controlled at culvert outlets with appropriate 

structures. Catch basins, roadway ditches, and culverts shall be 

cleaned and maintained regularly. Avoid creating hydrologic 

conduits between two aquifers during foundation excavation and 

other activities.

B-11, B-12

Water Resources Construction Explosives shall be used only within specified times and at 

specified distances from sensitive wildlife or streams and lakes, as 

established by the BLM or other federal and state agencies.

B-12 POD Section 2.6

Water Resources Pre-Construction,

Construction,

Operations,

Decommissioning

Develop and implement a Spill Prevention, Control, and 

Countermeasures Plan identifying where hazardous materials and 

wastes are stored on site, spill prevention measures to be 

implemented, training requirements, appropriate spill response 

actions for each material or waste, the locations of spill response 

kits on site, a procedure for ensuring that the spill response kits are 

adequately stocked at all times, and procedures for making timely 

notifications to authorities.

4-27 B-8 SPCC Plan (to 

be finalized 

before NTP)

Water Resources Pre-Construction,

Construction,

Operations,

Decommissioning

Prepare and implement a site-specific Stormwater Pollution 

Prevention Plan to control sediment (expected to be the primary 

nonpoint source contaminant); manage the collection, conveyance, 

and/or storage of storm water runoff at the Project Area; ensure 

compliance with applicable regulations; and prevent off-site 

migration of contaminated storm water or increased soil erosion.

4-27 B-8 SWPPP (to be 

developed 

before NTP)
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-6

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Water Resources Pre-Construction Obtain and comply with necessary permits in accordance with the 

Clean Water Act Section 404 and Section 401.

4-28

Water Resources Construction,

Reclamation,

Operations, 

Decommissioning

Control erosion per the Integrated Reclamation Plan. 4-28 Integrated 

Reclamation 

Plan

Water Resources Construction Avoid, to the extent possible, the occupancy and modification of 

floodplains.

4-28

Water Resources Construction,

Operations,

Decommissioning

Comply with all federal and state laws related to control and 

abatement of water pollution. All waste material and sewage from 

construction activities or Project-related features will be disposed of 

according to federal and state pollution-control regulations 

including the Clean Water Act, Arizona Surface Water Quality 

Standards (AAC Section R18-11-107) and Aquifer Water Quality 

Standards. 

4-28

Water Resources Construction,

Operations

Inspect site access roads monthly and after heavy rainfall events to 

identify and repair eroded areas or blocked culverts. 

4-28

Water Resources Design, 

Construction

Access roads shall be located to minimize stream crossings. All 

structures crossing streams shall be located and constructed so that 

they do not decrease channel stability or increase water velocity. 

All applicable federal and state permits shall be obtained.

B-11

Water Resources Design, 

Construction

Identify areas of groundwater discharge and recharge and their 

potential relationships with surface water bodies to gain a clear 

understanding of the local hydrogeology and avoid creating 

hydrologic conduits between two aquifers during foundation 

excavation, blasting, and other activities.

B-12

Water Resources Construction,

Operations

All efforts shall be made to prevent oil from reaching water. SPCC Plan 7 (to 

be finalized 

before NTP)

Water Resources Construction,

Operations

For a “minor” discharge (poses no significant harm (or threat) to 

human health and safety or to the environment), shut down the 

source of discharge; use sorbents, berms, fences, trenches, 

sandbags, or other material to contain the discharge; prevent the 

discharge from reaching off-site or surface water; and contact the 

Facility Manager.

SPCC Plan 9 (to 

be finalized 

before NTP)
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-7

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Water Resources Construction Precipitation falling in the materials pit (processing area) will be 

contained where the water will either percolate, evaporate, or be 

mechanically removed without creating additional runoff.

Mining Plan of 

Operations 8;

(Section 3.2)

Biological Resources Design,

Construction

Meteorological towers shall not be located in sensitive habitats or 

in areas where ecological resources known to be sensitive to human 

activities (e.g., prairie grouse) are present. Installation of towers 

shall be scheduled to avoid disruption of wildlife reproductive 

activities or other important behaviors.

B-4

Biological Resources Design Facilities shall be designed to discourage their use as perching or 

nesting substrates by birds including: 1) avoid the use of guy wires 

on met towers and other structures; 2) design of above ground 

transmission and collector lines will follow established Avian

Power Line Interaction Committee (APLIC) guidelines to minimize 

attracting nocturnal migrant birds, avoid collisions with birds, and 

avoid electrocution of raptors; and 3) use bird flight diverter 

devices where appropriate.

2-24, 

4-73, 4-74

B-6, B-10 ECP/BCS 

Sections 3.2, 4 

(similar)

Biological Resources Design Permanent met towers, transmission towers, and other facilities 

should be designed to discourage use by birds or other wildlife.

4-74 ECP/BCS 

Section 4 

(similar)

Biological Resources Design, 

Operations

Avoid night-lighting for facilities other than mandatory lighting on 

turbines to minimize attracting nocturnal migrant birds.

4-74 B-6 ECP/BCS 

Section 4

Biological Resources Design,

Construction

Minimize the disturbance footprints and co-locate roads, collector 

lines, and other linear facilities to the extent possible to minimize 

disturbance to biological resources. Overhead lines may be used in 

cases where burial of lines will result in further habitat disturbance.

4-74 B-10 POD Section 1.1

Biological Resources Pre-Construction,

Construction,

Operations

If pesticides are used on the site, an integrated pest management 

plan shall be developed and implemented to ensure that 

applications will be conducted within the framework of BLM and 

DOI policies and entail only the use of EPA-registered pesticides. 

Pesticide use shall be limited to nonpersistent, immobile pesticides 

and shall only be applied in accordance with label and application 

permit directions and stipulations for terrestrial and aquatic 

applications.

B-7 Integrated 

Reclamation 

Plan (similar)
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-8

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Biological Resources Pre-Construction,

Construction

Develop and implement a plan for control of noxious weeds and 

invasive species, which could occur as a result of new surface 

disturbance activities at the site. The plan shall address monitoring, 

education of personnel on weed identification, the manner in which 

weeds spread, and methods for treating infestations. The use of 

certified weed-free mulching shall be required. If trucks and 

construction equipment are arriving from locations with known 

invasive vegetation problems, a controlled inspection and cleaning 

area shall be established to visually inspect construction equipment 

arriving at the project area and to remove and collect seeds that may 

be adhering to tires and other equipment surfaces.

B-7 Integrated 

Reclamation 

Plan

Biological Resources Pre-Construction,

Construction,

Operations,

Decommissioning

Develop an Eagle Conservation Plan/Bird Conservation Strategy

(ECP/BCS). Implement the site-specific mitigation measures 

identified in the ECP/BCS that were developed in coordination with 

USFWS, BLM, Reclamation, Western, and Arizona Game and Fish 

Department (AGFD).

4-75 ECP/BCS

Biological Resources Pre-Construction,

Construction,

Reclamation,

Operations,

Decommissioning

Develop and implement an Integrated Reclamation Plan, including 

a Habitat Restoration Plan component, vegetation identification, 

soil stabilization, erosion reduction measures, and weed and 

invasive plant control. The plan shall require that restoration occur 

as soon as possible after completion of activities to reduce the 

amount of habitat converted at any one time and to speed up the 

recovery to natural habitats.

4-72, 

4-73, 4-75 

B-5, B-6, 

B-10

Integrated 

Reclamation 

Plan

Biological Resources Pre-Construction,

Design

Identify important, sensitive, or unique habitats in the vicinity of 

the Project and design the Project to avoid (if possible) or minimize 

impacts on these habitats (e.g., locate the turbines, roads, and 

ancillary facilities in the least environmentally sensitive areas; i.e., 

away from riparian habitats, streams, wetlands, drainages, or 

critical wildlife habitats).

4-72, 

4-73, 

B-5, B-11 ECP/BCS 

Section 4

Biological Resources Pre-Construction Review existing information on species and habitats in the vicinity 

of the Project Area to identify potential concerns.

4-72 B-5 ECP/BCS 

Section 4
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-9

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Biological Resources Pre-Construction Conduct surveys for federal and/or state-protected species and other 

species of concern (including special status plant and animal 

species) within the Project Area once the final disturbance areas are 

determined.

4-72 B-5 Integrated 

Reclamation 

Plan 5; 

ECP/BCS 

Section 4

Biological Resources Pre-Construction Evaluate avian and bat use of the Project Area and design the 

Project to minimize the potential for bird and bat strikes (e.g., 

development shall not occur in riparian habitats and wetlands). 

Scientifically rigorous avian and bat use surveys shall be 

conducted; the amount and extent of ecological baseline data 

required shall be determined on a project basis.

4-73 B-5 ECP/BCS 

Section 4; Bat 

Conservation 

Strategy 

Section 4

Biological Resources Pre-Construction Turbines shall be configured to avoid landscape features known to 

attract raptors, if site studies show that placing turbines there would 

pose a significant risk to raptors.

4-73 B-5 ECP/BCS 

Section 4

Biological Resources Pre-Construction Determine the presence of bat colonies and avoid placing turbines 

near known bat hibernation, breeding, and maternity/nursery 

colonies; in known migration corridors; or in known flight paths 

between colonies and feeding areas.

4-73 B-5 Bat Conservation Strategy 

Section 4

Biological Resources Pre-Construction Determine the presence of active raptor nests (i.e., raptor nests used 

during the breeding season). Measures to reduce raptor use at the 

Project Area (e.g., minimize road cuts, maintain either no 

vegetation or non-attractive plant species around the turbines) shall 

be considered.

4-73 B-5 ECP/BCS 

Section 4

Biological Resources Pre-Construction Procedures shall be developed to avoid or lessen potential impacts 

on special status species. Such measures could include avoidance, 

relocation of project facilities or lay-down areas, and/or relocation 

of biota.

4-72, 4-73 B-5 ECP/BCS 

Section 4; Bat 

Conservation 

Strategy 

Section 4

Biological Resources Pre-Construction,

Construction

Where practicable, avoid and minimize potential impacts to 

important, sensitive, or unique habitat and biota in the Project Area.

4-73

Biological Resources Pre-Construction Avoid or minimize impacts on sensitive wildlife and their habitat 

during Project planning and design.

4-73 B-5

Biological Resources Pre-Construction Develop and present an ecological awareness training program that 

discusses biological conservation measures, impacts minimization, 

and acceptable BMPs.

4-74 POD 2-4; 

ECCMP
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-10

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Biological Resources Pre-Construction Configure access roads and utility corridors to avoid high quality 

habitats and minimize habitat degradation and fragmentation.

4-74

Biological Resources Pre-Construction Minimize the number and extent of drainage crossings to limit 

impacts on high quality xeroriparian habitats.

4-74

Biological Resources Pre-Construction,

Construction

Employ BLM’s Strategy for Desert Tortoise Habitat Management 

on Public Lands in Arizona: New Guidance on Compensation for 

the Desert Tortoise (Instruction Memorandum No. AZ-92-46), as 

appropriate. 

4-75

Biological Resources Pre-Construction,

Construction

Avoid or minimize impacts on burrowing owls by following AGFD 

Burrowing Owl Project Clearance Guidance for Landowners 

(AGFD 2009b), to survey for burrowing owls and to institute the 

appropriate conservation measures for burrowing owls that occupy 

burrows in or near the construction footprint.

4-75 ECP/BCS 

Section 5

Biological Resources Pre-Construction,

Construction

Develop and implement guidelines to clean and inspect vehicles in 

an established wash site to prevent propagating reproductive 

materials of invasive plants and noxious weeds from entering the 

Project Area.

4-76 B-7 POD 2-1; 

Integrated 

Reclamation 

Plan 8

Biological Resources Construction, 

Operations

All construction employees, contractors, and site visitors shall be 

instructed to avoid harassment and disturbance of wildlife, 

especially during reproductive (e.g., courtship and nesting) seasons. 

In addition, pets shall not be permitted on site during construction.

B-10, B-13

Biological Resources Construction,

Operations

Observations of potential wildlife problems, including wildlife 

mortality, shall be reported to the BLM authorized officer 

immediately.

B-13

Biological Resources Construction Conserve and redistribute native topsoil and associated seed bank 

of rare plant species.

4-74

Biological Resources Construction Where only temporary disturbances are necessary (e.g., for pull 

sites or temporary construction areas), mow or crush vegetation in 

favor of land clearing methods where root systems are damaged.

4-74 Integrated 

Reclamation 

Plan Section 2.5 

(similar)

Biological Resources Construction Limit vehicle and foot traffic to areas within long-term and shortterm disturbance sites.4-74
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-11

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Biological Resources Construction Present the ecological awareness training program to Project 

personnel, construction contractors, and guest to the Project Area.

4-74 POD Section 2.5 

(briefly not 

entirely 

addressed);

ECCMP 

Section 3.0

Biological Resources Construction,

Operations

Employ wildland fire prevention measures including limiting 

vehicle travel to and within construction areas to only essential 

vehicles, establishing parking guidelines in remote areas, banning 

smoking and non-construction flame sources outside of vehicles, 

and establishing safety guidelines for construction flame and spark 

sources.

4-74

Biological Resources Construction Conduct vegetation clearing during the non-breeding bird season. If 

the bird breeding season cannot be avoided, conduct bird nest 

surveys in areas to be cleared and flag a non-disturbance area to 

avoid destroying active nests.

4-75 B-6 ECP/BCS 

Section 5

Biological Resources Construction,

Decommissioning

Follow AGFD guidelines for monitoring and handling of desert 

tortoises on construction projects. Employ qualified/certified desert 

tortoise monitors during construction and demolition. 

4-75

Biological Resources Construction Monitor or provide internal support (e.g., wadded paper) for 

tortoise burrows that collapse in blast areas. Inspect, remove, and 

relocate on-site eggs and tortoises from burrows that will be 

destroyed by land clearing activities. Collapse burrows after 

removal of contents.

4-75

Biological Resources Construction,

Decommissioning

Fill any trenches/holes immediately, or cover them at night and 

provide escape ramps every 147 feet (45 meters) when not in use. 

Escape ramps can be short lateral trenches or wooden planks 

sloping to the surface at an angle of 45 degrees or less to prevent 

entrapment of wildlife. Trenches that have been left open overnight, 

or after rain events will be inspected, and animals removed prior to 

backfilling. Trenches that have been left open overnight, or after 

rain events should be inspected, and animals removed prior to back 

filling.

4-75 POD Section 2.9 

(briefly not 

entirely 

addressed)
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-12

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Biological Resources Construction Limit access to Project Area to only construction and Projectrelated vehicles to limit establishing and spreading noxious weeds 

or invasive plants.

4-76

Biological Resources Construction,

Reclamation

Utilize fill materials from on-site sources to the extent possible to 

limit incursion of noxious weeds or invasive plants. Outside 

sources of fill material shall be from weed-free sources.

4-76

Biological Resources Reclamation Mulch material and seeds for reclamation shall be certified weed 

free.

4-76 Integrated 

Reclamation 

Plan Section 2.5

Biological Resources Construction,

Reclamation

Pre-treat reclamation sites to limit germination of noxious weeds or 

invasive plants in disturbance areas.

4-76

Biological Resources Construction,

Operations

Limit herbicides to non-persistent, immobile types, and apply these 

in accordance with their application and permit directions and use 

in terrestrial or aquatic applications.

4-76 Integrated 

Reclamation 

Plan Section 4.3 

(similar)

Biological Resources Construction Implement guidelines to clean and inspect vehicles in an 

established wash site to prevent propagating reproductive materials 

of invasive plants and noxious weeds from entering the Project 

Area.

4-76 B-7 Integrated 

Reclamation 

Plan 

Sections 2.5, 4.3 

(similar)

Biological Resources Reclamation,

Operations

Use an integrated approach to manage infestations that includes 

scheduled surveys and reporting of any infestations along Project 

roads, disturbance zones, and Project facilities. Utilize chemical, 

mechanical, or biological methods of weed control to limit the 

spread of noxious weeds and invasive plants and tailor treatments 

to specific weeds on site.

4-76 B-7 Integrated 

Reclamation 

Plan Section 4.3

Biological Resources Operations Complete two years of post-construction mortality monitoring for 

all birds and bats, complete and provide agencies with an annual 

report, and revisit at the end of the first two years of data collection 

to determine if any additional measures are needed. Avoid potential 

bat roost sites to the extent possible.

4-74 Bat Conservation Strategy 

Sections 6, 7, 

8.2, 8.2, 9
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-13

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Biological Resources Construction,

Operations,

Decommissioning

If BLM sensitive plants are identified within the limits of 

disturbance at any point during the life of the Project, BLM will be 

contacted prior to initiating the activity. If impacts to sensitive 

plants cannot be avoided, adaptive management strategies will be 

developed to minimize impacts, such as collect all seeds from the 

plant or transplant.

4-74

Biological Resources Reclamation Native plants that have been identified for transplanting as a result 

of ground disturbance activities will be transplanted during 

reclamation in a manner similar to natural vegetative spacing in the 

Project Area to the extent possible.

4-73 Integrated 

Reclamation 

Plan 

Sections 2.7.1.1, 

3.0

Biological Resources Construction,

Reclamation,

Operations,

Decommissioning

Consistent with the Vegetation Treatments Using Herbicides on 

Bureau of Land Management Lands in 17 Western States 

Programmatic Environmental Impact Statement, only BLMapproved herbicides will be used.

4-75 POD 

Section 3.1; 

Integrated 

Reclamation 

Plan Section 4.3

Biological Resources Construction If required, blasting with explosive material would be used within 

times and at specified distances from sensitive wildlife or surface 

waters as established by BLM or other federal and state agencies.

2-7 Blasting Plan (to 

be developed 

before NTP)

Biological Resources Construction Strip and segregate vegetation and topsoil where grading will occur 

to conserve the existing seed bank. Natural vegetation will be 

cleared or trimmed only when necessary to provide suitable access 

for construction, and O&M of the proposed wind farm facility. 

Where vegetation needs to be trimmed and/or removed for 

construction, but not for actual operations, it may be clipped or 

sheared at ground level to help facilitate resprouting.

2-38

Biological Resources Reclamation Imprint disturbed soils with equipment that will create indentations 

to catch seeds and water, aiding in the natural revegetation of the 

construction work area.

2-38
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-14

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Biological Resources Pre-Construction Prior to ground disturbance, a 100 percent pedestrian visual survey 

of the limits of disturbance will be completed using transects to 

assess plant community characterizations, list of key plant species, 

soil surface indicators and general soil types, areas where noxious 

and invasive weed species are present, and approximate number of 

individual plants for the salvage restricted species (see Integrated 

Reclamation Plan Table 3).

4-75 Integrated 

Reclamation 

Plan 5, 15; POD 

Section 2.3

Biological Resources Construction The area disturbed by installation of meteorological towers (i.e., 

footprint) shall be kept to a minimum.

B-4

Biological Resources Construction, 

Operations, 

Decommissioning

No disturbance will be allowed that may affect a federally listed 

plant species.

B-5

Biological Resources Reclamation The required reclaimed native vegetation cover will be 70 percent 

of the native background (pre-disturbance) vegetation cover for the 

area. Reclaimed areas must be capable of persisting without 

continued intervention, excluding noxious weed or invasive species 

management. 

B-14 Integrated 

Reclamation 

Plan 6

(Sections 2.4, 

2.4.1, 2.8.1)

Biological Resources Construction,

Reclamation

Special status species and salvage restricted plants identified for 

transplanting will be free from insect infestations or apparent 

diseases and representative of its species. These plants will be 

replanted in disturbed areas during reclamation or moved to a 

nursery for holding for later use.

Integrated 

Reclamation 

Plan 10

(Section 2.7.1.1)

Biological Resources Construction,

Operations

Employees will be prohibited from smoking outside of company 

vehicles during dry summer months.

POD 1-13

(Section 1.3.13)

Biological Resources Construction,

Operations

Each onsite company vehicle will contain a fire extinguisher, water 

spray can, shovel, Emergency Response procedures book, and a 

two-way radio for immediate communications with the O&M 

facility.

POD 1-13

(Section 1.3.13)

Biological Resources Operations Water buffaloes (water-carrying trailers) will be at hand during 

operations and brought to any job site where there is a substantial 

risk of fire.

POD 1-13

(Section 1.3.13)
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-15

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Cultural Resources Pre-Construction When any rights-of-way application includes remnants of a 

National Historic Trail, is located within the viewshed of a National 

Historic Trail's designated centerline, or includes or is within the 

viewshed of a trail eligible for listing on the NRHP, the operator 

shall evaluate the potential visual impacts to the trail associated 

with the proposed project and identify appropriate mitigation 

measures for inclusion as stipulations in the POD.

B-7

Cultural Resources Pre-Construction Determine if each of the National Register-listed or eligible historic 

properties could be avoided by construction (as preferred).

4-77 MOA Stip. III B 

and Table 2

Cultural Resources Pre-Construction Studies will be conducted to recover and preserve information and 

artifacts from sites that cannot be avoided.

4-78 MOA Stip. III A 

and B

Cultural Resources Pre-Construction Data recovery and monitoring procedures will be defined by a 

Historic Properties Treatment Plan (HPTP).

4-78 B-7 MOA Stip. III

Cultural Resources Pre-Construction In accordance with the HPTP, develop educational programs, 

curriculum materials, or public outreach designed to preserve 

information about the traditional cultural importance of the area for

the Hualapai Tribe and to reinforce the Tribe’s continuing cultural 

connections to the area. 

4-84, 4-85 MOA Stip. III E

Cultural Resources Pre-Construction Conduct supplemental surveys if final designs include Project 

facilities outside the areas that were surveyed for cultural resources 

during preparation of this EIS.

4-84 MOA Stip. II C; 

POD Section 1.1

Cultural Resources Pre-Construction,

Operations,

Decommissioning

In accordance with the procedures defined in the HPTP, train 

workers to protect cultural resources during construction, operation, 

and decommissioning of the Project and to report any discoveries 

that might be made.

4-84 MOA Stip. III C 

D; POD 

Section 2.5

Cultural Resources Pre-Construction Prepare and implement a Cultural Resource Management Plan 

(CRMP) in accordance with guidance of the BLM Programmatic 

Environmental Impact Statement on Wind Energy, including a Plan 

of Action to address any unanticipated discoveries of human 

remains, funerary objects, sacred objects, and objects of cultural 

patrimony in compliance with the Native American Graves 

Protection and Repatriation Act; measures to ensure continued 

access for traditional religious purposes or resource collection by 

tribes; and other potential measures for mitigating impacts on 

elements of the cultural environment that are not historic properties. 

4-85 B-7 CRMP (to be 

developed 

before NTP)
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-16

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

The CRMP also shall (1) establish a monitoring program, 

(2) identify measures to prevent potential looting/vandalism or 

erosion impacts, and (3) address the education of workers and the 

public to make them aware of the consequences of unauthorized 

collection of artifacts and destruction of property on public land.

Cultural Resources Construction, 

Operations

BLM will continue to consult with Indian Tribal governments to 

identify issues related to the presence of cultural properties, access 

rights, disruption to traditional cultural practices, and impacts to 

visual resources important to the Tribe(s) regarding discovery 

activities during construction, access to the area, or other concerns.

B-7 HPTP (to be 

finalized before 

NTP)

Cultural Resources, 

Paleontological 

Resources

Construction Unexpected discovery of cultural or paleontological resources 

during construction shall be brought to the attention of the 

responsible BLM authorized officer immediately. Work shall be 

halted in the vicinity of the find to avoid further disturbance of the 

resources while they are being evaluated and appropriate mitigation 

measures are being developed.

B-12 MOA Stip. III 

C; HPTP to be 

finalized before 

NTP and to 

include

Monitoring and 

Discovery Plan

Cultural Resources Construction,

Operations, 

Decommissioning

Monitor to ensure that avoided cultural resource sites are not 

damaged and check for vandalism or erosional damage to sites in 

the Project Area to ensure cultural resource sites are protected 

throughout the life of the wind farm.

4-78, 4-84 MOA Stip. III 

C; HPTP to be 

finalized before 

NTP and to 

include

Monitoring and 

Discovery Plan

Cultural Resources Construction,

Operations,

Decommissioning

Protect any unrecorded cultural resources that might be discovered 

during construction, operation, or decommissioning of the Project, 

and evaluating and treating such discoveries.

4-84 MOA Stip. III 

C; HPTP to be 

finalized before 

NTP and to 

include

Monitoring and 

Discovery Plan

Paleontological 

Resources

Pre-Construction Before any construction takes place, qualified paleontologists will

undertake a pedestrian survey for paleontological resources of the 

Tertiary and Quaternary sediments within the Project.

4-87 B-8 Paleontology

Monitoring Plan

(to be developed 

before NTP)
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-17

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Paleontological 

Resources

Pre-Construction,

Construction

Construction monitoring by a qualified paleontologist will take

place in areas determined to be sensitive (if such areas are present) 

based on a pre-construction survey. In addition, develop a plan to 

address next steps in the event that sites are discovered during 

construction survey. The paleontological resources management 

plan also shall (1) establish a monitoring program, (2) identify 

measures to prevent potential looting/vandalism or erosion impacts, 

and (3) address the education of workers and the public to make 

them aware of the consequences of unauthorized collection of 

fossils on public land.

4-87 B-8 ECCMP; 

Paleontology

Monitoring Plan

(to be developed 

before NTP)

Paleontological 

Resources

Pre-Construction A paleontological monitoring plan will be formulated by a qualified 

paleontologist after the preconstruction survey. The plan will

conform to the standards of the Society of Vertebrate Paleontology.

4-87 B-8 Paleontology

Monitoring Plan

(to be developed 

before NTP)

Paleontological 

Resources

Pre-Construction A worker environmental appreciation program for construction 

personnel will be developed and presented to construction 

personnel regarding the appearance of possible paleontological 

resources in the area and procedures to be followed if suspected 

paleontological resources are encountered.

4-87 B-8 ECCMP;

Paleontology

Monitoring Plan

(to be developed 

before NTP)

Paleontological 

Resources

Construction Paleontological resources collected during monitoring activities 

must be stabilized, prepared to the point of identification, and 

curated in a museum with a permanent paleontological collection.

4-87 B-8 Paleontology

Monitoring Plan

(to be developed 

before NTP)

Paleontological 

Resources

Construction A final report will be generated for all monitoring activities to 

summarize the results of the monitoring efforts, including a list and 

description of any resources found, and outlining the context and 

condition of these resources. This report will be submitted to the 

BLM and/or Reclamation depending on the locations of findings. 

The final report, maps of the localities and field notes must 

accompany any collected specimens.

4-87 B-8 ECCMP 

Section 5.2.4

Land Use Design Utilize existing roads and utility corridors to the maximum extent 

feasible.

4-97 B-4
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-18

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Land Use Pre-Construction,

Construction,

Operations

Continue to contact appropriate agencies, property owners, and 

other stakeholders during the permitting process to identify 

potentially sensitive land uses, and local and regional land use 

concerns. 

4-97 B-4

Land Use Pre-Construction,

Construction,

Operations,

Decommissioning

Plan for efficient use of the land and areas disturbed by 

construction, operation, and decommissioning of the Project 

through the use of the BMPs.

4-97 POD 

Section 3.4; 

Decommissioning Plan 

Section 2.2

Land Use, Noise Construction Implement a noise complaint process and hotline number for usage 

by members of the surrounding community (e.g., White Hills, 

Arizona). Upon establishment of the hotline, BP Wind Energy or its 

compliance inspectors will have the responsibility to receive, 

evaluate, and coordinate with the BLM or Reclamation 

representatives, respectively, and when appropriate make 

reasonable efforts to resolve noise complaints. The resolution and 

evaluation of noise complaints will be subject to appropriate criteria 

as described in the Final EIS, and as identified as the Mohave 

County Noise Standards – Maximum Noise Levels for Various 

Land Uses (see Figure 3-7 in the Final EIS).

4-97, 

4-185

4-98

Land Use Construction Gates or cattle guards will be installed where openings are needed 

within fences.

2-36 POD 

Section 1.3.14

Land Use Pre-Construction, 

Operations

Meteorological towers installed for site monitoring and testing shall 

be inspected periodically for structural integrity.

B-4

Transportation and 

Access

Pre-Construction A traffic management plan shall be prepared for the site access 

roads to ensure that no hazards would result from the increased 

truck traffic and that traffic flow would not be adversely impacted. 

This plan shall incorporate measures such as informational signs, 

flaggers when equipment may result in blocked throughways, and 

traffic cones to identify any necessary changes in temporary lane 

configuration.

B-6 Transportation 

and Traffic 

Control Plan 

Sections 4 and 8
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-19

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Transportation and 

Access

Pre-Construction An access road siting and management plan shall be prepared 

incorporating existing BLM standards regarding road design, 

construction, and maintenance such as those described in the BLM 

9113 Manual (BLM 1985) and the Surface Operating Standards for 

Oil and Gas Exploration and Development (RMRCC 1989) (i.e., 

the Gold Book).

B-6

Transportation and 

Access

Pre-Construction Develop and implement a Transportation Plan that identifies 

sensitive areas to be avoided. The plan also shall consider specific 

object sizes, weights, origin, destination, and unique handling 

requirements and shall evaluate alternative transportation 

approaches. In addition, the process to be used to comply with 

unique state requirements and to obtain all necessary permits shall 

be clearly identified.

4-104 B-6 Transportation 

and Traffic 

Control Plan

Transportation and 

Access

Pre-Construction In accordance with the Traffic Management Plan, survey and flag 

sensitive areas where disturbance needs to be avoided.

4-104 B-6 Flagging Plan

Transportation and 

Access

Construction,

Operations,

Decommissioning

Project personnel and contractors shall be instructed and required to 

adhere to speed limits commensurate with road types, traffic 

volumes, vehicle types, and site-specific conditions, to ensure safe 

and efficient traffic flow and to reduce wildlife collisions and 

disturbance and airborne dust.

B-11

Transportation and 

Access

Construction,

Operations,

Decommissioning

Traffic shall be restricted to the roads developed for the project. 

Use of other unimproved roads shall be restricted to emergency 

situations.

B-11

Transportation and 

Access

Construction Signs shall be placed along construction roads to identify speed 

limits, travel restrictions, and other standard traffic control 

information. To minimize impacts on local commuters, 

consideration shall be given to limiting construction vehicles 

traveling on public roadways during the morning and late afternoon 

commute time. 

B-11 POD 1-13

Transportation and 

Access

Construction Ongoing ground transportation planning shall be conducted to 

evaluate road use, minimize traffic volume, and ensure that roads 

are maintained adequately to minimize associated impacts.

B-13
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-20

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Transportation and 

Access

Construction If required by ADOT regulation, add turning lanes to US 93 to 

provide access to the Project Area in an effort to accommodate the 

anticipated volume of slow-moving, oversized loads and mitigate 

the potential for traffic back-ups on a federal highway.

4-104 Transportation 

and Traffic 

Control Plan 

Sections 6 and 7

Transportation and 

Access

Pre-Construction, 

Construction

Obtain the applicable permits needed to transport equipment and 

materials and coordinate closely with ADOT and other state 

transportation departments, as appropriate.

4-104 Transportation 

and Traffic 

Control Plan 

Sections 6 and 9; 

Table 1-6

Transportation and 

Access

Construction Personal vehicles of construction personnel will be parked at the 

main staging area for the site. BP Wind Energy will encourage ride 

sharing (at orientation for new workers and also from time to time 

at the morning meetings) to reduce the number of vehicles entering 

and exiting the site.

2-8, 2-36 POD Section 2.4

Transportation and 

Access

Construction Widening improvements will be made to US 93 near Milepost 22 to 

accommodate the turning movement requirements of the oversized 

transport vehicles, with as little disruption as reasonably possible to 

high speed background through traffic traveling along this segment 

of US 93. The widened section of the median will be striped as a 

non-travel area to prohibit use by non-oversized vehicles and 

reflectorized pavement markers will be installed to further delineate 

traffic lanes for non-oversized vehicles. An Encroachment Permit 

and Traffic Control Permit will be obtained to construct the 

intersection improvements within the US 93 Right-of-Way.

Transportation 

and Traffic 

Control Plan 

Section 7, 

page 13 and 

Section 9, 

page 14

Transportation and 

Access

Construction During construction of the wind facility it is anticipated that 

construction signage and LED advanced warning signs will be 

utilized ahead of the intersection, and flaggers will likely be used 

when oversized transport vehicles are entering and exiting the 

Project.

Transportation 

and Traffic 

Control Plan 

Section 8, 

page 14 

Visual Resources Design Turbine arrays and turbine design shall be integrated with the 

surrounding landscape. Design elements to be addressed include 

visual uniformity, use of tubular towers, proportion and color of 

turbines, non-reflective paints, and prohibition of commercial 

messages on turbines. Efforts shall be made to minimize the need 

for and amount of lighting on ancillary structures.

B-6
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-21

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Visual Resources Design, 

Construction,

Operations

Turbines will be a shade of light gray (no darker than RAL 7035 or 

equivalent) throughout the Project, to reduce visual contrast while 

meeting the Federal Aviation Administration’s (FAA) requirements 

for marking and lighting. 

2-67

Visual Resources Design, 

Construction

Access roads shall be located to follow natural contours and 

minimize side cuts where feasible to capitalize on opportunities for 

natural screening by locating roads behind small ridges when doing 

so would not compromise road engineering constraints, or other 

resource concerns, and would promote a reduction in impacts on 

visual resources from frequently seen viewpoints.

4-151

Visual Resources Design,

Construction

Structures for the majority of the transmission line will be steel or 

concrete monopoles that are nonspecular or a color suitable for the 

environment. The conductors will be nonspecular.

2-27, 

4-136

POD 

Section 2.9.2

Visual Resources Design,

Construction

Components of the substations will typically have a maximum 

height of 35 feet (lightning masts will have heights closer to 

75 feet) and the conductive components will have nonspecular 

metal surfaces. The small control buildings will be painted a neutral 

color with muted tones to blend with the environment.

2-25, 2-

26, 4-137

POD 

Section 2.9.1

Visual Resources Design,

Construction

The O&M building will be approximately 60 feet by 100 feet and 

16 feet high, with the roof and side panels painted a color to blend 

with the environment. Fences at the facility will be treated to 

minimize metal reflections.

2-30, 2-

37, 4-137

POD 

Sections 1.3.14 

and 3.3

Visual Resources Construction,

Reclamation

Side slopes at the Materials Source will be contoured to a 3:1 or 

flatter slope.

2-12, 

4-137

Mining Plan of 

Operations 

Section2.1

Visual Resources Construction Construction-related waste will be removed from the site. “Good 

housekeeping” procedures shall be developed and implemented to 

ensure that during operation the site will be kept clean of debris, 

garbage, carrion, fugitive trash or waste, and graffiti; to prohibit 

scrap heaps and dumps; and to minimize storage yards.

4-137 B-5 HSSE Plan 53; 

Waste Handling 

Plan (to be 

developed 

before NTP)

Visual Resources Construction Remove temporary facilities as soon as practical. 2-38, 

4-135
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-22

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Visual Resources Construction Construction of underground collection cables will occur 

concurrently with road construction. Collector line cables will be 

buried parallel to the interior roads connecting the turbine corridors; 

the construction area disturbance will range from 56 feet to 136 feet 

in width.

2-32, 4-

136

B-10 POD 

Sections 2.9 and 

4.2 – does not 

state 

concurrently –

grant states 

width

Visual Resources Construction For the installation of the overhead transmission line, no alteration 

to landform will be required beyond clearing or grading.

2-28, 4-

136

Visual Resources Operations Mitigation to reduce visual contrast resulting from lighting could 

include an Audio Visual Warning System, if approved by the FAA. 

Such a system will allow night lighting to remain off, unless an 

aircraft is detected in close proximity. BP Wind Energy will track 

FAA circulars and make annual requests to FAA for updates on any 

approved systems and inform BLM and Reclamation when there is 

an approved system. BLM, Reclamation, and BP Wind Energy will

discuss the potential application of an Advanced Warning System 

within one year of FAA approval and the availability of test 

application results being available for at least one commercial wind 

farm project. If the initial evaluation results in a decision to dismiss 

the application of the Advanced Warning System for the Project, a 

second review and evaluation will occur within five years of the 

initial decision to account for changes in technology, costs, or 

resource impacts that may occur over time. 

4-133

Visual Resources Reclamation,

Operations

After construction of the Project is completed, BP Wind Energy 

will be responsible for monitoring reclaimed areas until reclamation 

of the area meets BLM and Bureau of Reclamation success criteria 

for restoration of plant communities, as defined in the Integrated 

Reclamation Plan.

4-135 Integrated 

Reclamation 

Plan 13; 

ECCMP

Visual Resources Reclamation Post-construction width for all interior roads, including shoulders, 

will be narrowed to 20 feet and the former width will be reclaimed

and revegetated. Restoration will follow the Integrated Reclamation 

Plan.

2-33, 4-

136

POD 

Section 3.1; 

Integrated 

Reclamation 

Plan 
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-23

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Visual Resources Construction Reduce visual impacts during construction by minimizing areas of 

surface disturbance, controlling erosion, using dust suppression 

techniques, and restoring exposed soils as closely as possible to 

their original contour and vegetation.

B-10

Public Safety, 

Hazardous Materials, 

and Solid Waste

Pre-Construction Develop and implement a hazardous materials management plan 

and waste management plan identifying the waste streams that are 

expected to be generated at the site and addressing hazardous waste 

determination procedures, waste storage locations, waste-specific 

management and disposal requirements, inspection procedures, and 

waste minimization procedures. This plan shall address all solid 

and liquid wastes that may be generated at the site, and identify 

requirements for notices to federal and local emergency response 

authorities and include emergency response plans.

B-8 Waste Handling 

Plan (to be 

developed 

before NTP)

Public Safety, 

Hazardous Materials, 

and Solid Waste

Pre-Construction Supplemental plans will be prepared and implemented to contribute 

to maintaining a safe environment and/or minimizing the potential 

for adverse health effects associated with dust or pollutants in 

water. The additional plans include a site-specific SWPPP, Blasting 

Plan, Transportation and Traffic Management Plan, HSSE Plan, 

SPCC Plan, Dust and Emissions Control Plan, and Integrated 

Reclamation Plan. 

4-165 Transportation 

and Traffic 

Control Plan, 

HSSE Plan, Dust 

Plan, Integrated 

Reclamation

Plan; SWPPP, 

Blasting Plan, 

and SPCC Plan

to be developed 

or finalized 

before NTP

Public Safety, 

Hazardous Materials, 

and Solid Waste

Pre-Construction,

Operations

Develop and implement a fire management and response strategy to 

minimize the potential for a fire and to promptly extinguish fires.

4-165 B-9 POD 

Section 1.3.13; 

HSSE Plan

Attachment: Fire 

Prevention/

Protection Plan
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-24

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Public Safety, 

Hazardous Materials, 

and Solid Waste

Pre-Construction A safety assessment will be conducted to describe potential safety 

issues and the means that will be taken to mitigate them, including 

issues such as site access, construction, safe work practices, 

security, heavy equipment transportation, traffic management, 

emergency procedures, and fire control. This also will include 

preparation of an HSSE Plan that addresses safety issues related to 

workers and the public. Identify all applicable federal and state 

occupational safety standards; establish safe work practices for each 

task (e.g., requirements for personal protective equipment and 

safety harnesses; Occupational Safety and Health Administration 

[OSHA] standard practices for safe use of explosives and blasting 

agents; and measures for reducing occupational electric and 

magnetic fields [EMF] exposures); establish fire safety evacuation 

procedures; and define safety performance standards (e.g., electrical 

system standards and lightning protection standards). The program 

shall include a training program to identify hazard training 

requirements for workers for each task and establish procedures for 

providing required training to all workers. Documentation of 

training and a mechanism for reporting serious accidents to 

appropriate agencies shall be established.

4-165 B-8, B-9 POD 

Section 1.3.14; 

HSSE Plan

Public Safety, 

Hazardous Materials, 

and Solid Waste

Pre-construction Develop and implement a health and safety program that 

establishes a safety zone or setback for wind turbine generators 

from residences and occupied buildings, roads, rights-of-ways, and 

other public access areas that is sufficient to prevent accidents 

resulting from the operation of wind turbine generators. It shall 

identify requirements for temporary fencing around staging areas, 

storage yards, and excavations during construction or 

decommissioning activities. It shall also identify measures to be 

taken during the operation phase to limit public access to hazardous 

facilities.

B-9
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-25

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Public Safety, 

Hazardous Materials, 

and Solid Waste

Pre-construction The project shall be planned to minimize electromagnetic 

interference (EMI) (e.g., impacts to radar, microwave, television, 

and radio transmissions) and comply with Federal Communications 

Commission [FCC] regulations). Signal strength studies shall be 

conducted when proposed locations have the potential to impact 

transmissions. Potential interference with public safety 

communication systems (e.g., radio traffic related to emergency 

activities) shall be avoided.

B-9

Public Safety, 

Hazardous Materials, 

and Solid Waste

Construction,

Operations

Secondary containment shall be provided for all on-site hazardous 

materials and waste storage, including fuel. In particular, fuel 

storage (for construction vehicles and equipment) shall be a 

temporary activity occurring only for as long as is needed to 

support construction activities.

B-12 SPCC Plan (to 

be finalized 

before NTP)

Public Safety, 

Hazardous Materials, 

and Solid Waste

Construction,

Operations

Wastes shall be properly containerized and removed periodically 

for disposal at appropriate off-site permitted disposal facilities.

B-12 POD 

Section 1.3.12;

Waste Handling 

Plan (to be 

developed 

before NTP)

Public Safety, 

Hazardous Materials, 

and Solid Waste

Construction,

Operations

In the event of an accidental release to the environment, the 

operator shall document the event, including a root cause analysis, 

appropriate corrective actions taken, and a characterization of the 

resulting environmental or health and safety impacts.

B-12, B-13 POD Section 3.3 

(similar)

Public Safety, 

Hazardous Materials, 

and Solid Waste

Construction Temporary fencing shall be installed around staging areas, storage 

yards, and excavations during construction to limit public access.

B-13 POD 

Section 1.3.14 

(similar) 

(Excavation)

Section 2.1 

Laydown

Public Safety, 

Hazardous Materials, 

and Solid Waste

Construction Any wastewater generated in association with temporary, portable 

sanitary facilities shall be periodically removed by a licensed hauler 

and introduced into an existing municipal sewage treatment facility. 

Temporary, portable sanitary facilities provided for construction 

crews shall be adequate to support expected on-site personnel and 

shall be removed at completion of construction activities.

B-13
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-26

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Public Safety, 

Hazardous Materials, 

and Solid Waste

Construction,

Operations

Permanent fencing shall be installed and maintained around 

electrical substations, and turbine tower access doors shall be 

locked to limit public access.

B-14 POD 

Section 1.3.14 

(similar except 

does not address 

doors)

Public Safety, 

Hazardous Materials, 

and Solid Waste

Construction,

Decommissioning

Consult with local planning authorities regarding increased traffic 

issues during construction and decommissioning, including an 

assessment of the number of vehicles per day, their size, and type. 

Specific issues of concern (e.g., location of school bus routes and 

stops) shall be identified and addressed in the traffic management 

plan.

4-165 B-9

Public Safety, 

Hazardous Materials, 

and Solid Waste

Construction,

Operations

Comply with FAA regulations, including use of lighting 

requirements to warn aviators of obstructions, and plan project to 

avoid potential safety issues associated with proximity to airports, 

military bases or training areas, or landing strips.

4-165 B-9 POD 

Section 2.10 

(similar)

Public Safety, 

Hazardous Materials, 

and Solid Waste

Construction,

Operations

All stored chemicals, fuel, and oil will be secured in areas that 

provide for containment of spilled fluids in accordance with the 

SPCC Plan. Spill response kits will be located on equipment and in 

the on-site temporary storage facilities. Construction personnel will

be trained in spill response, the use of the spill response kits, and 

notification requirements.

2-12 SPCC Plan (to 

be finalized 

before NTP)

Public Safety, 

Hazardous Materials, 

and Solid Waste

Construction,

Operations

If oil or grease is spilled or leaked from equipment, the 

contaminated soil will be removed and hauled to an approved 

hazardous material dump. Used oil will be pumped into a truck and 

hauled to a recycling facility in Las Vegas, Nevada on an as-needed 

basis.

2-12 SPCC Plan (to 

be finalized 

before NTP)

Public Safety, 

Hazardous Materials, 

and Solid Waste

Construction BP Wind Energy will post safety and warning signs informing the 

public of construction activities where the road(s) enters the Project 

Area from a public road. During construction, access to the site will

be monitored and controlled, so as to prevent public access during 

such times when it would not be safe for public on-road or off-road 

use within the Project Area. During non-construction hours a 

security guard will patrol the Project Area.

2-36 POD 

Section 1.3.14
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-27

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Public Safety,

Hazardous Materials, 

and Solid Waste

Construction Good housekeeping rules will be followed to keep chemicals and 

waste materials from entering Detrital Wash. These rules include: 

providing a sediment pond for wash water from aggregate washing 

and other operations; proper disposal of oil and greasy substances 

to preclude them from mixing with the any surface water; and lined 

storage pits for chemical storage.

Mining Plan of 

Operations 6

(Section 2.9)

Microwave, Radar, 

and Other 

Communications

Design Wind turbines will be relocated or eliminated from the Project as 

necessary to avoid the 13 microwave beams that are near the 

Project Area.

4-167

Microwave, Radar, 

and Other 

Communications

Design,

Pre-Construction

Relocated wind turbines, if any, will be submitted to the FAA for 

review and require the issuance of new Determinations of No

Hazard. For Determinations set to expire in 2012, an extension 

request will be filed or, if necessary, the entire Project will be 

resubmitted to the FAA. The analysis area is all known radar and 

microwave communication facilities within 50 miles of the Project 

Area. The FAA-required notice of proposed construction will be 

made as early as possible to identify any air safety measures.

4-166, 

4-167

B-4

Microwave, Radar, 

and Other 

Communications

Construction Wind turbines will be marked with synchronized obstruction 

warning lights as required by the FAA Determination of No Hazard 

and FAA Advisory Circular 70/7460-1K. 

4-168 POD 

Section 2.10

Microwave, Radar, 

and Other 

Communications

Operations In the event an installed wind energy development project results in 

EMI, the operator shall work with the owner of the impacted 

communications system to resolve the problem. Additional warning 

information may also need to be conveyed to aircraft with onboard 

radar systems so that echoes from wind turbines can be quickly 

recognized.

B-14

Noise Pre-Construction,

Operations

Proponents of a wind energy development project shall take 

measurements to assess the existing background noise levels at a 

given sit and compare them with the anticipated noise levels 

associated with the proposed project.

B-6

Noise Construction All stationary construction equipment (i.e., compressors and 

generator) shall be located as far as practicable from nearby 

residences.

B-12
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-28

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Noise Construction If blasting or other noisy activities are required during the 

construction period, nearby residents shall be notified in advance. 

B-12 Blasting Plan (to 

be developed 

before NTP)

Noise Construction Noisy construction activities (including blasting) shall be limited to 

the least noise-sensitive times of day (i.e., daytime only between 

7 a.m. and 10 p.m.) and weekdays.

B-12

Noise Construction All noise-producing equipment and vehicles using internal 

combustion engines will be equipped with exhaust mufflers, airinlet silencers where appropriate, and any other shrouds, shields, or 

other noise-reducing features in good operating condition that meet 

or exceed original factory specification. Mobile or fixed “package” 

equipment (e.g., arc-welders, air compressors) will be equipped 

with shrouds and noise control features that are readily available for 

that type of equipment. The diesel generator, a potential power 

source for the batch plant, will similarly be equipped to keep its 

resulting sound emission to levels below 81 dBA at a distance of 

50 feet.

4-184, 4-

185

B-12

Noise Operations The proposed Project design and implementation will include 

appropriate noise attenuation measures adequate to help ensure that 

the noise levels from turbine transformers, substations, and other 

ancillary systems or components will not cause aggregate noise 

levels produced by operation of the Project to exceed identified 

thresholds. For instance, HVAC systems on an occupied control or 

maintenance building might feature, if needed, sound abating 

cabinet linings or intake/exhaust shrouds that are typically offered 

by manufacturers as optional equipment upgrades.

4-185

Noise Operations Maintenance and security patrol vehicles, such as pick-up trucks 

and/or all-terrain vehicles, using internal combustion engines will

be equipped with exhaust mufflers, air-inlet silencers where 

appropriate, and any other shrouds, shields, or other noise-reducing 

features in good operating condition that meet or exceed original 

factory specification. Operation of these vehicles will typically be 

expected to occur on access roads that interconnect turbine 

positions.

4-185
Attachment 3

Best Management Practices and Mitigation Measures

Attachment 3-29

Resource 

Area/Topic

Project 

Development 

Stage Commitment

Final EIS and POD Location and 

Page Number

Chapter 2 

or 4 Appendix B POD

Monitoring Monitoring,

Construction,

Operations

A monitoring program shall be developed to ensure that 

environmental conditions are monitored during the construction, 

operation, and decommissioning phases. The monitoring program 

shall identify the monitoring requirements for each environmental 

resource present at the site, establish metrics against which 

monitoring observations can be measured, identify potential 

mitigation measures, and establish protocols for incorporating 

monitoring observations and additional mitigation measures into 

standard operating procedures and BMPs. Site monitoring protocols 

defined in the POD shall be implemented. These will incorporate 

monitoring program observations and additional mitigation 

measures into standard operating procedures and BMPs to 

minimize future environmental impacts.

B-4, B-13

Monitoring Monitoring,

Construction,

Operations

Results of monitoring program efforts shall be provided to the 

BLM authorized officer.

B-13 ECCMP

Project Infrastructure Operations Inoperative turbines shall be repaired, replaced, or removed in a 

timely manner. Operators will be required to demonstrate due 

diligence in the repair, replacement, or removal of turbines; failure 

to do so could result in termination of the rights-of-way 

authorization.

B-13 POD 2-11

All Resources Construction,

Operations,

Decommissioning

All control and mitigation measures established for the project in 

the POD and the resource-specific management plans that are part 

of the POD shall be maintained and implemented throughout the 

operational and decommissioning phase, as appropriate. These 

control and mitigation measures shall be reviewed and revised, as 

needed, to address changing conditions or requirements at the site, 

throughout the operational phase. This adaptive management 

approach would help ensure that impacts from operations are kept 

to a minimum.

B-13